oversight

Federally Assisted Air Pollution Control Programs in the Chicago Metropolitan Region

Published by the Government Accountability Office on 1971-04-20.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                      B-766506




Environmental   Protection   Agency
           ,   ,



                     COMPTROLLER     GENERAL      OF      THE   UNITED   STATES
                                   WASHINGTON.     D.C.     20548




    B-166506




    Dear       Senator    Percy:

           Pursuant   to your request      of January     30, 1970, this           is
    our report   on the federally   assisted     air pollution   control
    programs    in the Chicago    metropolitan      region.

            The matters   included    in this report  have been dis-
    cussed with officials     of the city of Chicago   and the Environ-
    mental    Protection  Agency,    but written   comments   were not
    obtained.

            We plan to make no further      distribution  of this re-
    port unless copies are specifically        requested,  and then we
    shall make distribution     only after your agreement       has been
    obtained   or public announcement      has been made by you con-
    cerning   the contents  of the report.

                                                 Sincerely          yours,




                                                 Comptroller             General
                                                 of the United           States

   z’i!d
r\ 1 The Honorable         Charles        H. Percy
“/     United States      Senate




                   50Tl-l ANNIVERSARY            1921- 1971
I
I
I   COMPTROLLER GENERAL'S REPORI TO                        FEDERALLY ASSISTED AIR POLLUTiOh
I
I   THE HONORABLE CHARLZS H. PERCY                         CONTROL PROGRAMSIN THE
I   UNITED STATES SEAlATE                                  CHICAGO METROPOLITAN REGIO?I
I
I                                                        / Environmental Protection Agency 2d
I                                                          B-166506
I
I
I
     DIGEST
    ------
I

I
I
I   i&Y THE REVIEW WAS MADE
I
I
I
          Senator     Charles   H. Percy   of Illinois   requested   the General   Accounting
I
I
I
I
I
I
I
          As r.equested by Senator PercyIs    Office,  GAO did not obtain the formal
          comments of the city of Chicago or of the Environmental       Protection
          Agency on the matters   discussed   in this  report.  These matters,     however3
          were discussed with officials     of the city and the Environmental      Protec-
          tion Agency as GAO's review progressed.


    FINDINGS MD CONCLUSl-OI1'S

          Financial     Assiskvmz

          During fiscal    years 1965-70,     six local agencies within      the Metropolitan
          Chicago Interstate     Air Quality     Control    Region were awarded Federal air
          pollution   control   grants totaling     about $5.4 million.       In addition
          these agencies budgeted non-Federal           funds of about $11.1 -million.
          The city of Chicago was awarded about $4.3 million            of the Federal grants
          and budgeted about $9.9 million         of the non-Federal    funds.

          For calendar years 1965-69,    the six local agencies'    expenditures  for
          air pollution   control amounted to about $11.4 million.       Local agency
          expenditures  of non-Federal   funds increased    from about $600,000 in
          1964 to about $2.3 million   in 1969.     (See pp. 12 to 16.)


    1On December 2, 1970, in accordance with Reorqanization      Plan No. 3 of 1970,
     the air pollution  control  program was transferred  from the Department    of
     Health, Education,  and Welfare to the Environmental    Protection  Agency.




    Tear Sheet
Generally     the city of Chicago's        equipment purchases were made in ac-
cordance with accepted procurement             practices,     and the equipment was
being utilized        effectively.      The city,    however9 did not maintain
effective     control      over equipment purchased with Federal funds.            The
city's    inventory      was incomplete     and did not include      (1) the location
of specific      equipment items,       (2) inventory     control   numbers, (3) the
date of acquisition,            and (4) in some cases, cost data.        (See pp. 18
to 19.)

The staff    of the six     local   agencies    increased     from 104 employees at
January 1, 1965, to 206 employees             at December 31, 1969.       During that
time the city of Chicago's       staff      increased     from 88 to 153.     All employ-
ees of the city's    air pollution         control    agency must be approved by the
city's  Civil Service    Commission,        the budget office,      and the office    of
the mayor.

Although most city      employees are required    to take a competitive     examina-
tion to acquire permanent civil       service  status,   temporary   appointments
without    an examination    may be made for a period of 60 days and may be
extended for unlimited       periods.  As of July 1970, 75 of 177 staff         meo-
bers of the city‘s      air pollution  control   agency were classified      as
temporary.

The city’s     position     descriptions       include     "desirable     minimum qualifica-
tions."      GAO's review indicated          that the executive          management and
technical     professional       staff   generally     met the requirements         of the
position     descriptions       but that many of the technicians              and inspectors
did not. A Civil Service Commission official                      told GAO that the position
descriptions      merely provided        desirable     qualifications        and were not bind-
ing.     Evironmental      Protection     Agency officials         stated   that the Environ-
mental Protection         Agency could not control            or influence     State or local
government personnel          in the hiring       of staff.

Although the city's       general policy was to hire from Civil   Service Commis-
sion examination    lists,     of 44 employees included  in GAO's sample5 39 had
been hired prior    to taking examinations      and 17 had never been certified
by the Civil   Service Comz!lssion.       (See pp- 20 to 23.)




It is the responsibility           of the States to establish          air quality     stan-
dards for various       pollutants       and to adopt plans for implementation             of
the standards.      As of December 31, 1970, the States of Illinois                    and
Indiana had established          standards     for two of five pollutants          for which
standards    were due and had submitted            implementation      plans for the con-
trol   of -Ihe two pollutants       --sulphur     oxides and particulates--for          En-
vironmental    Protection      Agency approval.         Implementation      plans for the
other three pollutants         were not required        to be summitted      at that time.


                                      2
             There appears to be little          in the way of a regional            approach to air
             pollution     control    in the Chicago control         region.     No agency had been
             established       for administering      an air pollution       control     program for the
             entire    region.      Rather,   a number of State and local agencies were being
             awarded Federal grants.           Furthermore,     officials     of the local agencies
             told GAO that State personnel           had not contacted        them with regard to the
             development       of the implementation      plans.       These officials       also said
             that their     programs had been limited         to local areas of jurisdiction           and
             that there had been little          contact    or coordination       with other State or
             local agencies.         (See pp. 24 to 29.)


             Progress in &veZoping
             control  progra?ns
I
             The city of Chicago had compiled             emission    inventories  for two pollutants.
             Although som,n of the other local            agencies    in the Chicago control    region
             were in the process of compiling             emission    inventories,   none had com-
             plete,? any such inventory.   (See           pp. 30 to     32.)

             The city of Chicago had an air-monitoring          network of 20 stations           with
             manual sampling equipment to monitor        sulphur     dioxide     and particulates.
             Eight of the stations      also had telemetered      air-monitoring       equipment.
             Data obtained    from the manual equipment      at the 20 stations         indicated
             that the level of particulates       in the air remained relatively             constant
             from 1965-69.      The levels however, was about SO percent            higher than
             the Environmental     Protection   Agency's criteria       of 80 micrograms        per
             cubic meter.    f\lot only did the annual average exceed the criteria,                 but
             also the particulate      readings  at each of the 20 stations          exceeded 80
             micrograms   per cubic meter.

             Data indicated   also     that the annual average of sulphur     dioxide  declined
             from a high of .053       parts per million     in 1966 to .026 parts per million
             in 1969.    At four of      the stations,    however, the level of sulphur dioxide
             in 1969 exceeded the        criteria   of .04 parts per million.

             Data obtained     from the telemetered     equipment         at the eight stations for
             the same period indicated       that the level of          sulphur  dioxide remained
             relatively   constant     at an annual average of          from .06 to .07 parts per
             million.    City officials     said that technical          difficulties    had been
             experienced    with the telemetered      equipment        and that telemetered  infor-
             mation was not as reliable        as that obtained         from the manual equipment
             at the 20 stations.

              Of Cook County's    16 air-monitoring    stations,     four are telemetered        and
              are interconnected    with Chicago's   eight telemetered         stations.      None
              of the local agencies in Indiana have telemetered equipment; nor is
              there any interconnection      of the air-monitoring       stations      between the
              Indiana agencies or between State and/or local agencies in Illinois                  and
              State and/or local agencies in Indiana.            (See pp. 33 to 36.)

 I
     Tear -.-Sheet
I




                                                      3
The city of Chicago has attempted              to control    air pollution      by enforcing            i
ordinances,     operating      a permit system for construction,           and encouraging              ;
private    industry      to take appropriate      control    measures voluntarily.         En-          ,
forcement     activities      have been directed      principally    toward ensuring       corn-        ;
pliance   with the ordinances         pertaining    to particulate       emissions.      (See           ,
PP. 37 to 40.)                                                                                          I
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                           Contents
                                                           Page

DIGEST                                                       1

CHAPTER

  1        INTRODUCTIONAND SCOPE
               Legislation
               Metropolitan Chicago Interstate   Air
                 Quality Control Region

           TECHNICAL AND FINANCIAL ASSISTANCEPRCVIDED
           TC CHICAGOCONTROLREGION                           9
               Technical assistance                          9
               Financial   assistance                       12
                    Funding                                 13
                    Expenditures                            14
                    Grant administration                    16

           EQUIPMENTAND STAFFING                            18
               Equipment                                    18
               Staffing                                     20

           AIR QUALITY CONTROLSTANDARDSAND IMPLEMEN-
           TATION PLANS                                     24
               Metropolitan Chicago Interstate Air
                 Quality Control Region                     25
               Clean Air Amendments of 1970                 27

           PROGRESSACHIEVED By LOCAL AGENCIES IN AD-
           MINISTERING AIR POLLUTION CONTROLPROGRAMS        30
               Emission inventories                         30
               Air monitoring                               33
               Enforcement                                  37

APPENDIX
   I       Letter dated January   30, 1970, from Senator
             Charles H. Percy                               43
                         ABBREVIATIONS

APCO   Air   Pollution   Control      Office

EPA    Enviromnental     Protection      Agency

GAO    General Accounting      Office
COMPTROLLERGENERALIS REPORT TO                   FEDERALLY ASSISTED AIR POLLUTION
THE HONORABLE CHARLES H. PERCY                   CONTROL PROGRAMSIN THE
UiUTED STATES SENATE                             CHICAGO METROPOLITAN REGION
                                                 Environmental Protection Agency
                                                 B-166506


DIGEST
------


WHY THE REVIEW WAS MADE

     Senator Charles I-l. Percy of Illinois      requested   the General Accounting
     Office  (GAO) to examine into the administration          of the air pollution
     control  program by the Department       of Health,   Education,  and Welfare1
     and to give particular    attention    to the use of Federal air pollution
     control  grant funds by the city of Chicago.

     As requested  by Senator Percy's    Office,  GAO did not obtain the formal
     comments of the city of Chicago or of the Environmental        Protection
     Agency on the matters   discussed   in this report.   These matters,      however,
     were discussed with officials     of the city and the Environmental       Protec-
     tion Agency as GAO's review progressed.


FINDINGS AND CONCLUSIONS

     FinaneiaZ   Assistmee

     During fiscal    years 1965-70, six local agencies within         the Metropolitan
     Chicago Interstate     Air Quality    Control    Region were awarded Federal air
     pollution   control   grants totaling    about $5.4 million.       In addition
     these agencies budgeted non-Federal          funds of about $11.1 million.
     The city of Chicago was awarded about $4.3 million           of the Federal grants
     and budgeted about $9.9 million        of the non-Federal    funds.

     For calendar years 1965-69, the six local agencies'       expenditures  for
     air pollution   control amounted to about $11.4 million.       Local agency
     expenditures  of non-Federal   funds increased    from about $600,000 in
     1964 to about $2.3 million   in 1969.     (See pp. 12 to 16.)


'On December 2, 1970, in accordance with Reorganization      Plan No. 3 of 1970,
 the air pollution  control  program was transferred  from the Department    of
 Health, Education,  and Welfare to the Environmental    Protection  Agency.
Equipment       and Staffing

Generally       the city of Chicago's      equipment purchases were made in ac-
cordance with       accepted procurement       practices,     and the equipment was
being utilized        effectively.      The city,    however, did not maintain
effective     control      over equipment purchased with Federal funds.            The
city's    inventory      was incomplete     and did not include      (1) the location
of specific      equipment items,       (2) inventory     control   numbers, (3) the
date of acquisition,            and (4) in some cases, cost data.        (See pp. 18
to 19.)

The staff       of the six     local   agencies   increased     from 104 employees at
January 1, 1965, to 206 employees               at December 31, 1969.       During that
time the city of Chicago's       staff        increased     from 88 to 153.     All employ-
ees of the city's    air pollution           control    agency must be approved by the
city's  Civil Service    Commission,          the budget office,      and the office    of
the mayor.
Although most city employees are required         to take a competitive     examina-
tion to acquire permanent civil       service  status,   temporary   appointments
without    an examination   may be made for a period of 60 days and may be
extended for unlimited      periods.   As of July 1970, 75 of 177 staff        mem-
bers of the city's      air pollution  control   agency were classified     as
temporary.

The city's     position     descriptions       include    "desirable       minimum qualifica-
tions."      GAO's review indicated          that the executive           management and
technical     professional       staff   generally     met the requirements          of the
position     descriptions       but that many of the technicians               and inspectors
did not.      A Civil     Service Commission official             told GAO that the position
descriptions      merely provided        desirable     qualifications         and were not bind-
ing.     Evironmental      Protection     Agency officials          stated that the Environ-
mental Protection         Agency could not control            or influence      State or local
government personnel          in the hiring       of staff.

Although  the city's       general policy was to hire from Civil   Service    Commis-
sion examination     lists,     of 44 employees included  in GAO's sample, 39 had
been hired prior     to taking examinations      and 17 had never been certified
by the Civil   Service      Commission.    (See pp. 20 to 23.)


Air   quaZi?g     standards

It is the responsibility           of the States to establish         air quality     stan-
dards for various       pollutants      and to adopt plans for implementation             of
the standards.      As of December 31, 1970, the States               of Illinois     and
Indiana had established          standards    for two of five pollutants          for which
standards    were due and had submitted           implementation      plans for the con-
trol   of the two pollutants--sulphur            oxides and particulates--for          En-
vironmental    Protection      Agency approval.        Implementation      plans for the
other three pollutants         were not required       to be summitted       at that time.
There appears to be little          in the way of a regional             approach to air
pollution     control   in the Chicago control           region.     No agency had been
established       for administering      an air pollution        control     program for the
entire    region.     Rather,    a number of State and local agencies were being
awarded Federal grants.           Furthermore,      officials     of the local agencies
told GAO that State personnel            had not contacted        them with regard to the
development of the implementation             plans.       These officials       also said
that their     programs had been limited          to local areas of jurisdiction           and
that there had been little          contact    or coordination        with other State or
local agencies.        (See pp. 24 to 29.)


Proqmss in d.eveZoping
eontroz programs
The city of Chicago had compiled           emission    inventories  for two pollutants.
Although some of the other local           agencies    in the Chicago control    region
were in the process of compiling           emission    inventories,   none had com-
pleted any such inventory.    (See         pp. 30 to     32.)

The city of Chicago had an air-monitoring          network of 20 stations           with
manual sampling equipment to monitor sulphur dioxide                and particulates.
Eight of the stations     also had telemetered       air-monitoring      equipment.
Data obtained from the manual equipment at the 20 stations                indicated
that the level of particulates        in the air remained relatively            constant
from 1965-69.     The level,    however, was about 50 percent higher than
the Environmental    Protection    Agency's criteria      of 80 micrograms per
cubic meter.    Not only did the annual average exceed the criteria,                   but
also the particulate     readings at each of the 20 stations            exceeded 80
micrograms per cubic meter.

Data indicated    also    that the annual average of sulphur dioxide declined
from a high of .053       parts per million     in 1966 to .026 parts per million
in 1969.    At four of      the stations,    however, the level of sulphur dioxide
in 1969 exceeded the        criteria    of .04 parts per million.

Data obtained from the telemetered         equipment        at the eight stations      for
the same period indicated       that the level of         sulphur dioxide remained
relatively   constant     at an annual average of         from .06 to .07 parts per
million.    City officials     said that technical          difficulties  had been
experienced    with the telemetered      equipment       and that telemetered     infor-
mation was not as reliable        as that obtained        from the manual equipment
at the 20 stations.

Of Cook County's    16 air-monitoring    stations,     four are telemetered        and
are interconnected    with Chicago's   eight telemetered         stations.     None
of the local agencies in Indiana have telemetered             equipment;     nor is
there any interconnection      of the air-monitoring       stations     between the
Indiana agencies or between State and/or local agencies in Illinois                  and
State and/or local agencies in Indiana.            (See pp. 33 to 36.)
The city of Chicago has attempted             to control    air pollution      by enforcing
ordinances,    operating      a permit system for construction,           and encouraging
private   industry      to take appropriate      control    measures voluntarily.         En-
forcement    activities      have been directed      principally    toward ensuring       com-
pliance with the ordinances          pertaining    to particulate       emissions.      (See
PP. 37 to 40.)
                              CHAPTER1

                      INTRODUCTIONAND SCOPE

      In accordance with the request of Senator Charles H.
Percy, dated January 30, 1970 (see app. I>, we examined
into the administration,     by the Air Pollution  Control Of-
fice (APCO), Environmental     Proctection  Agency (EPA>,l of
the air pollution    control program in the KeZropolitan   Chi-
cago Interstate   Air Quality Control Region,

        The principal    cause of air pollution       is the imperfect
burning of fuel and other material.             The sources of pollu-
tion generally      are divided into five categories--transpor-
tation,    power plants,     space heating,     refuse disposal,   and
industry.      Air pollution     from mobile and stationary      sources
are separate and distinct          problems.    The Federal Government
is responsible      for prescribing      standards applicable    to the
emission of pollutants        from motor vehicles,

     APCO has established       standards for certain pollutants,
with which the automobile manufacturers          must comply by 1975.
In addition     APCO is trying to develop feasible      and economi-
cal testing procedures to be used by the States in enforcing
the standards.     We currently     are reviewing APCO's program
for controlling    air pollution     from motor vehicles.    We ex-
pect to complete our review by about December 1971.

        Consequently,    this review dealt only with the adminis-
tration    of the air pollution     control program for stationary
sources and was primarily        concerned with (1) the financial
and technical     assistance   provided the Chicago control region
by APCO, (2) the manner in which the local agencies utilized
APCO grant funds, and (3) the progress made in the Chicago
control region in preventing         and controlling air pollution.


1
 EPA became effective  on December 2, 1970, in accordance
  with Reorganization Plan No. 3 of 1970. Prior to that
 date APCOwas in the Department of Health, Education,     and
 Welfare.
      We reviewed the city of Chicago's efforts          in compiling
emission inventories,     establishing    air-monitoring     networks,
and enforcing   air pollution     control  laws; we reviewed also
the manner in which the city accounted for APCO grant funds.
We also made a limited      review of the activities       of other
air pollution   control agencies within the region,

      We visited  APCO headquarters     in Rockville,     Maryland,
and Durham, North Carolina;      the APCO regional    office    in
Chicago; the air pollution      control agencies in Chicago and
Cook County, Illinois,    and Gary, East Chicago, Hammond,
and Lake County, Indiana;     and State air pollution       control
agencies in Springfield,    Illinois,     and Indianapolis,     Indi-
ana.
        We reviewed legislation       and regulations   and examined
records at APCO headquarters,           at APCO's Chicago regional
office,    and at State and local agency offices.           We also dis-
cussed the air pollution        activities     with APCO and EPA head-
quarters and regional      officials       and State and local air
pollution     control agency personnel.

LEGISLATION

        The Clean Air Act of 1963 (42 U.S.C. 1857) provided
that the responsibility         for the control of air pollution
rested primarily       with State and local governments but that
the Federal Government was to aid State and local govern-
ments in the development and execution of their control pro-
grams and was to stimulate         an increased level of air pollu-
tion control     activity.      The act authorized    grants to air
pollution    control     agencies to develop, establish,     and im-
prove programs for the prevention          and control of air pollu-
tion,

        The act authorized     also higher rates of Federal grant
support to intermunicipal         or interstate    air pollution  con-
trol agencies than it authorized           to single States or munic-
ipalities.      In 1966 the Clean Air Act was amended (Pub. L.
89-675) to authorize       grants for maintaining      programs for
the prevention     and control of air pollution.




                                   6
      The Air Quality Act of 1967 (Pub. L. 90-148) amended
the Clean Air Act and provided for a regional            approach to
air pollution    control.    The act directed      the Administrator,
EPA, to (1) define the broad atmospheric areas of the Na-
tion,   (2) designate specific     air quality     control regions,
(3) develop and publish air quality        criteria     for pollutants,
and (4) establish     a time table which States must follot~ in
developing air quality      standards and plans for implementing
such standards within designated regions.

METROPOLITANCHICAGOINTERSTATE
AIR OUALITY CONTROLREGION

       The Metropolitan    Chicago Interstate       Air Quality Con-
trol Region was established         in December 1968 and includes
six counties in northeast       Illinois--McHenry,        Lake, Kane,
Cook, Will, and DuPage-- and two counties in northwest Indi-
ana--lake     and Porter.   The region covers about 4,650 square
miles and has a population        of about 7.5 million.         It is
highly industrialized      with steel mills,       petroleum refin-
eries, and steel and petroleum support industries.                 The
following     chart shows the source, by major categories,             of
particulates,      carbon monoxide, and sulphur dioxide emissions
in the Chicago control      region.       The data was compiled by
APCO in 1967 and was the most recent information               available.

                               Sources of Emissions in the
                                 Chicago Control Region

                           Particulates          Carbon monoxide       Sulphur dioxide
                         Tons per       Per-    Tons per    Per-      Tons per     Per-
                           year       centage     year     centage      year      centage
Fuel combustion:
    Residential            24,110       4.1        46,310      1.7       183,900    10.3
    Commercial             81,750      14.0        81,300      3.0       165,690     9.3
    Industrial            120,260      20.5         7,630        .3      349,000    19.6
    Power plants           48,430       8.3         3,980        .1   1,021,500     57.4
          Total           274,550      46.9       139,220      5.1    1,720,090     96.6

Refuse
Industrialdisposal
               process    266,650
                           25,910      45.5         66,800     2.5    '   49,000     2.8
                                        4.4         58,380     2.1                     .2
Transportation             18,860       3.2     2,461,500     90.3         8,320
                                                                           2,905       .4
          Total           585,970     100 0
                                      __I_      2.725.900    -100 0   1,780,315    100 0
                                                                                   __L
        Within the region, four county and four municipal       air
pollution     control agencies were established   in Illinois,
and two county and three local agencies were established            in
Indiana.      As of June 30, 1970, the city of Chicago and five
other agencies within the region had been awarded Federal
air pollution      control grants totaling  about $5.4 million.
(See p. 13.)
                               CXAPTER2

              TECHNICAL AND FINANCIAL ASSISTANCE

                PROVIDEDTO CHICAGOCONTROLREGION

TECHNICAL ASSISTANCE

      The Clean Air Act of 1963 directs     the Administrator,
EPA, to provide technical    assistance   to State and local
governments in connection with their air pollution        control
programs.    APCO's policy is to provide such technical        assis-
tance upon request,    to the extent that resources are avail-
able,    APCO has provided assistance   for such things as de-
velopment of air-monitoring    programs, compilation     of emission
inventories,   and development of State and local laws and
regulations.

       The city of Chicago received extensive Federal technical
assistance     in the development of an air pollution         control
program.     In   October  1962, prior  to enactment    of  the  Clean
Air Act of 1963, the city of Chicago entered into a 5-year
cooperative      agreement with APCO's predecessor       agency, the
Public Health Service, Division        of Air Pollution.

       Under the agreement Public Health Service personnel were
assigned to the city and provided assistance             related   to (1)
the type and placement of air-monitoring            equipment, (2) the
compilation     of an emission inventory,       (3) air pollution       con-
trol legislation,      and (4) training.      The Public Health Ser-
vice also provided some laboratory          analysis    services.      This
assistance     began to decline about 1965. APCO personnel told
us that they provided little        technical    assistance     to Chicago
since 1967. They stated that the decline was due to (1) a
reduction    in APCO technical    support staff (most of the staff
was reassigned to work related         to the designation       of air
quality    control  regions)   and (2) the fact that the city was
considered     to have a more advanced program than many other
local agencies.

     In June 1968 Department of Health, Education,     and Wel-
fare internal auditors    reviewed the expenditures  of the city
of Chicago's air pollution     control agency for the period

                                    9
November 1964 through November 1967. This was the only such
audit made of agencies within the Chicago control region.

        The auditors     reported deficient         accounting     and adminis-
trative    practices,      including      (1) discrepancies      in travel ex-
penses charged to grants,            (2) failure     to establish     separate
fund accounts for Federal and non-Federal                 expenditures     for
each project,      and (3) failure         to reconcile     the air pollution
control    agency expenditure         records with records maintained
by the city comptroller's            office.     In August 1969 city of-
ficials    told APCO that they had made a number of changes in
their accounting       and administrative         practices    to comply with
the internal      auditors'      recommendations.

     In May 1970 four APCO technical   staff members made a
Z-day visit to the city of Chicago to review the control
agency's operations  to determine areas of program weakness
and to make recommendations to improve program effectiveness.

        The report of the APCO staff members recommended that
the city (1) reevaluate            the existing    organization    and func-
tional     activities      for the purpose of avoiding duplication
of activities,        (2) initiate      procedures for program planning,
(3) develop a program of continuing               education and training
to keep the staff abreast of program and technological
changes, (4) review and upgrade field               service position
qualifications        and requirements       to increase the level of
capability       of staff,     (5) make a &major effort       to complete
and update emission inventories,               (6) develop additional     use
of telemetered        air-monitoring       network data to justify      the
time, money, and effort            devoted to this operation,       and (7)
maintain an inventory           of equipment and location        and main-
tenance records.

      APCO officials    told us that the report was for the pur-
pose of assisting    the city in improving the administration
of its program and that no formal response was required from
the city.




                                     10
      APCO officials    stated also that APCO had provided some
technical    assistance  to other agencies within the Chicago
control   region, primarily    related    to determining  sources of
emissions and developing      air pollution    control ordinances.
APCO also assisted the Illinois        and Indiana State agencies
in developing emission inventories         and diffusion mode1s.l

1A diffusion   model mathematically    describes the relationship
 between pollutant    emissions and- air quality   by simulating    -
 the effect of atmospheric elements on the transport        and
 dispersion  of pollutants     emitted into the atmosphere.




                                  11
FINANCIAL ASSISTANCE

       The Clean Air Act authorizes      the Administrator,      EPA,
to award grants to State and local air pollution            control
agencies for part of the cost of planning,         developing,estab-
lishing,    improving, and/or maintaining     programs for the pre-
vention and control    of air pollution.      These grants are
categorized    by APCO as either project     or maintenance,       ac-
cording to the purpose that they are intended to serve.

      APCO guidelines  to applicants   state that, to be eligible
for project grants,   an air pollution    control  agency must
plan, develop, or have an acceptable      "workable program."
The workable program should include information       on the need
for an air pollution   control program, its objectives      and
goals, its legal authority,    and what has been and is pro-
posed to be done to accomplish program objectives       and goals.

       The guidelines    provide for project       grants in three
 stages.   In the first     stage grants may     be awarded for plan-
ning or developing      a workable program.        They generally  are
expected to be completed in 2 years or           less and must be de-
signed to lead to the establishment       of     an air pollution   con-
trol program.

       In the second stage grants may be awarded for "estab-
lishment"    projects for activation of an air pollution con-
trol program for up to 3 years after a program has been ob-
tained.

      In the third stage grants may be awarded for "improve-
mentff projects   for up to 3 years for the purpose of better-
ing a program, when a workable program is in operation.
Grants may be awarded to applicants     for any or all stages.

        The guidelines    state that maintenance grants are in-
tended to provide air pollution          control    agencies with con-
tinuing    Federal financial     assistance     for the maintenance of
effective    workable programs which are capable of accomplish-
ing appropriate      air quality   objectives      within appropriate
time schedules.        APCO awards maintenance grants for a maxi-
mum of 1 year at a time; once support has been provided to
a grantee agency, however, it can plan on continuing               support


                                    12
as long as satisfactory     progress is made in the execution of
the program for which the support has been provided,      subject
to the availability     of funds.
       Information  pertaining  to funding,                       expenditures, and
staffing    for the local agencies within                       the Chicago control
region is presented below.

Funding
     During fiscal   years 1965-70, six local agencies within
the region were awarded air pollution       control grants total-
ing about $5,4 million.    In addition    these agencies budgeted
about $11.1 million   of non-Federal   funds, as shown below.

                                              Fiscal      Federal
                                              years        grant        Local
                                              grants       funds        funds          Total
                                             cwarded      awarded      budgeted       funding

      Illinois:
             Chicago                         1965-70    $4,261,300   $ 9,919,053    $14,180,353
             Cook County   (exclusive   of
                Chicago)                     1965-68       469,218       522,411        991,629
      Indiana:
           Gary                              1965-70       324,644       395,267        719,911
          East Chicago                       1965-70       121,220       165,160        286,380
          Hammond                            1967-70       133,900        97,592        230,592
          Lake County (exclusive        of   1969 and
            above three cities)              1970           46,150         28,200         74,350

               Total                                    $5,355,532   $11,127,683    $16,483,215



       Grant awards to the city of Chicago included project
grants during fiscal     years 1965-70, totaling   about $2 mil-
lion,    and maintenance grants during fiscal    years 1968-70,
totaling    about $2.3 million.   The other agencies were
awarded project grants.

       In addition    to the project  and maintenance grants,     the
city of Chicago was awarded Federal demonstration          grants to-
taling   about $294,000 during fiscal      years 1967-69.     These
grants were for projects      to demonstrate     new or improved
methods of air pollution      control  or abatement, such as test-
ing control     devices for fuel-fed   incinerators.



                                                13
        Illinois    and Indiana State agencies were awarded proj-
ect grants totaling        about $731,000 and $340,000, respec-
tively,      during fiscal    years 1965-70.   State officials     told
us that the State agencies did not provide financial              assis-
tance to local agencies within the Chicago control             region.
We did not ascertain        to what extent,  if any, the Illinois
and Indiana State agencies contributed          to the air pollution
control      program within the region.

Expenditures

       A distinction     is made by APCO between those non-Federal
funds required to match the Federal grant funds and addi-
tional   non-Federal     funds to meet the maintenance-of-effort
requirement.       The law sp:ecifies that no agency shall receive
any project     grant during any year in which its program ex-
penditures     for other than nonrecurrent    expenditures     will be
less than its expenditures        were for such programs during the
preceeding year.       Also, no agency shall receive a maintenance
grant unless the Administrator,        EPA, is satisfied    that   such
grant   will   be used to supplement and, to the extent practi-
cable, increase the level of State, local,          or other non-
Federal funds.

      Local agencies in the Chicago control   region were first
awarded APCO grants in fiscal   year 1965. Local agency ex-
penditures  of non-Federal funds increased from about
$600,000 in 1964 to about $2.3 million    in 1969, as shown be-
low.

                                         Local                       1969 expenditures
                         Year of       expendi-            Federal
                         initial          tures             grant         Local
          Agency           grant        in 1964             funds         funds          Total

       Chicago                  1965       $573,094       $894,349     $2,175,168    $3,069,517
       Cook County              1965          8,500          (a)            (a)            (a>
       Gary                     1965         12,020         17,068          70,528         87,596
       East Chicago             1965         11,325         21,402          31,752         53,154
       Hammond                '1967                         19,543          21,007         40,550
       Lake County              1969                        13,093          12,471         25,564

           Total                           $604,939       $965,455     $2,310,926    $3,276,381

       aNo Federal    grant     in 1969;     local    expenditures       nor determined.




                                                     14
        For calendar years 1965-69, total expenditures       for air
pollution    control   reported by the six local agencies within
the Chicago control region amounted to about $11.4 million.
These expenditures       included $8.5 million   for personnel,
$1.1 million     for equipment, and $1.8 million     for other ne-
cessities.      The following    summary shows the total expendi-
tures reported by each agency.

                                    Federal
                                     grant              Non-Federal   funds
                                     funds       Hatching                 Other         Total
Chicago:
     Project    grants:
          Personnel              $1,102,831      S   728,348          $3.340.319    $ 5,171,498
          Equipment                  285,370          20,171              149,440        454,981
          Other                      328,624         125,374              728,177     1,182,17>
                                  1.716,825          873,893           4,217,936       6.808,654
       Maintenance     grants:
             Personnel               611,547     1,115,653                415,325     2,142,525
             Equipment               295,246         30,693                 1,382        327,321
            Other                    193,245         87,010               157,467        437,722
                                  1.100,038      1,233,356                574,174     2,907,568
Cook County :
    Project    grants:
          Personnel                  284,394         294,566             103,820         682,780
         Equipment                   128,089                              23,662         151,751
         Other                        37.314          39,439              25,257         102,010
                                     449,797         334,005              152,739        936,541
Gary :
     Project    grants:
          Personnel                   93,914         102,614               87,821        284,349
          Equipment                   34,730          11,936               16,366         63,032
          Other                       37,486          17,194                9,465         64,145
                                     166,130         131,744             113,652         411,526
Hammond:
    Reject     grants:
         Personnel                    16.963          51,424                6,000         74,387
         Equipment                    39,515                                              39.515I---

         Other                        14,663                                              14,663
                                      71,141          51.424                6,000        128.565
East    Chicago:
       Project    grants:
            Personnel                 51,197          44,466               56,800        152,463
            Equipment                 16,935           3,905                8,206         29,046
            Other                     19,042           1,479               10,512         31,033
                                      87,174          49,850               75,518        212,542
Lake County:
    Project    grants:
          Personnel                       361          8,250                4,221         12,832
          Equipment                    8,817                                               8,817
         Other                         3,915                                               3,915
                                      13,093           8,250                4,221         25,564
                  Total          $3.604,198     $2,682,522            S5,144,240    $11,430,960
                                                                                     ___-




                                                15
      Although these agencies'   expenditures    increased,   APCO
considered   the programs in northwest Indiana to be under-
manned and lacking in sufficient    professional     talent to do
much more than a minimal job of abating air pollution.          On
the other hand, APCO considered the city of Chicago to have
a comprehensive program.

Grant administration

        Prior to January 1970 administration         of the grant pro-
gram, which included review and approval of applications
and awards of funds, was centralized          in the APCO Bureau of
Abatement and Control,       Division   of Control Agency Develop-
ment, in Raleigh, North Carolina.          Beginning in January
1970 the responsibility       for review and approval of grant ap-
plications    was decentralized      to EPA regional    offices.

        In applying for APCO grants, an agency must show the
relationship      of its project   to its workable program.        APCO
operating    personnel told us, however, that project          grants,
considered to be for the purpose of stimulating            local con-
trol activities,       were awarded with little   reliance     on the
relationship      of the project   to a workable program.

        Our review showed that APCO had no manuals or written
policies     or procedures for review and approval of applica-
tions.      APCO officials  told us that initial    grant applica-
tions were reviewed by program advisors and centralized
technical     support staff to ensure that the proposed programs
met APCO requirements.       With regard to continuing      grant ap-
plications,     however, we found that grants were awarded on
the basis of the judgement and experience of program advi-
sors who used the data provided by the grantee without ex-
tensive verification.       An APCO Chicago regional     office   offi-
cial told us that, after the responsibility         for awarding
grants had been delegated to the regions,        his staff also re-
viewed all grant applications.
      As discussed on page 12, APCO guidelines   state that
grant support of improvement projects    may be provided for up
to 3 years.    We found that APCO had awarded grants to local
agencies in the Chicago control   region for improvement proj-
ects for substantially   more than 3 years.


                                  16
          .   .




      APCO officials    told us that, even though State and lo-
cal agencies had made progress in developing        and implement-
ing more effective     air pollution  control  programs, the agen-
cies, generally,     had not progressed to the point of qualify-
ing for maintenance grant support.        Consequently,   APCO's
policy was to award such agencies additional        improvement
grants.

       We found that during the period 1965-70, APCO awarded
grants to the East Chicago, Gary, and Hammond agencies for
two improvement projects         for 6 consecutive years.    Further-
more, Gary applied for and was awarded a grant of $55,009
for a third improvement project          for 1971. APCO officials
told us that they would not approve the East Chicago and
Hammond agencies'    applications      for 1971 improvement grants
unless they submitted more comprehensive programs for air
pollution    control activities.
                                        CHAPTER3

                             EQUIPMENTAND STAFFING

EQUIPMENT

      The local agencies in the Chicago control region           ex-
pended about $1.1 million     for equipment from 1965-69; the
city of Chicago's expenditures       accounted for about 73 per-
cent of such expenditures.       The following     table shows the
expenditures   for the purchase of equipment, classified          by
major equipment category,     as reported by the six agencies.
The table does not include equipment expenditures           of
$118,085 by Chicago because a detailed         breakdown of this
amount was not readily    available,    and the city's    inventory
records were incomplete (see p. 19).

                          Air
                         moni-       Labo-         Tech-         Vehi-            Other
                       torinq        ratory        nical         cles          (note a)     Total
    Chicago          $287,949      $47,557      $17,s5SE $ 8;,;;;             $228,745    $664,217
    Cook County       114,247       15,758                                      16,262     151,751
    Gary               19,341        7,598          2,421        16;053         17,619      63,032
    Hammond            21,197                                     8,184         10,134      39,515
    East Chicago        6,317         4-316              585     12,798          5,030      29,046
    Lake County         6,192          :             -            2,625            -         8.817
         Total       $455,243
                      -___         $75,229      $21,380        $126,736       $277.790    $956.378

    aConsists    primarily       of furniture        and office          'equipment.



       We reviewed Chicago's procurement procedures and found
that equipment purchases generally       were made in accordance
with accepted procurement practices.        Our examination  of
selected equipment items showed that the equipment generally
was being utilized    effectively.    (See pp. 33to 36 for a
discussion    on the utilization   of air-monitoring   equipment.)
      APCO regulations   require that grantees maintain records
in sufficient   detail to show the exact nature of expendi-
tures and the identity    and location of all property

                                              18
purchased in whole or in part with grant funds.      In addition
the regulations   specify that, when equipment purchased with
grant funds is disposed of or transferred    to another activ-
ity, an amount equal to the current value of the equipment
is to be deposited in the grant account or returned to APCO.
        We found that the city of Chicago did not maintain ef-
fective    control   over equipment purchased with Federal fi-
nancial assistance       for use by the city's      air pollution    con-
trol agency.       Both the city's    air pollution     control   agency
and the comptroller's        office maintained records of expendi-
tures for equipment.         These records were not, however, recon-
ciled periodically,        and we noted discrepancies       in the items
of equipment listed        and the value assigned to specific
pieces of equipment.
       The city of Chicago was unable to provide us with a
complete inventory      of air pollution   control    equipment pur-
chased prior or subsequent to inception         of Federal financial
assistance,     In addition    to being incomplete,      the city's    in-
ventory did not include (1) the location          of specific     items
of equipment (although the air pollution          control   agency's
equipment was located at about 30 sites throughout            the city),
(2) inventory    control    numbers, (3) date of acquisition,         and
(4) in some cases, cost data.
       We brought this matter to the attention       of city and
APCO officials.       Subsequently,   in its report to the city on
the results     of its May 1970 review of the city's      air pollu-
tion control     program (see p. ), APCO recommended that the
city maintain an inventory        of equipment and location   and
maintenance records.       As of December 1970 the city was com-
piling   an equipment inventory.

      In view of APCO regulations,  the amount of funds ex-
pended, and the diverse location   of equipment, we believe
that APCO should require the city to maintain an up-to-date
inventory   of equipment.




                                   19
STAFFING

      Air pollution     control   is a highly technical      field and,
as such, requires     highly trained     technical,   scientific,   and
professional    personnel.      One of the primary prcblems cur-
rently faced by air pollution        control agencies is the acqui-
sition and retention       of capable staff.      As shown in the fol-
lowing table, the staff of the agencies in the Chicago con-
trol region increased from 104 employees as of January 1,
1965, to 206 employees as of December 31, 1969.

                    Techni-                         Execu-
                    cal and                          tive     Clerical,
                    profes-     Labo-    Inspec-   manage-   custodial,
                     sional   ratory        tors     ment    and other    Total

January 1965:
     Chicago           14           9        44        3          18        88
     Cook County         1                    5        3           4        13
     East Chicago      -        -            -1       -1          -1         3

         Total                  x ‘9                  =7
December 1969:
    Chicago            34       20           59        4          36       153
    Cook County         6        1           16        3           6        32
    QrY                          1            2        1           4         8
    Hammond                                   3        1           1         5
    East Chicago                              3        1           1         5
    Lake County                 -            -2       -1         -           3

         Total         40


        Technical and professional           personnel include chemists,
engineers,     and meteorologists;         laboratory     personnel include
weather,     electronic,       engineering,      and environmental-
sampling technicians;          and inspectors      include combustion en-
gineers who perform annual inspections                of fuel and refuse
burning equipment and personnel who patrol the city in ve-
hicles to detect emissions and investigate                 complaints.    Be-
cause of Senator Percy's expressed interest,                  we examined
into the staffing        policies    and practices      of Chicago's air
pollution     control agency.

        The city of Chicago has a Civil Service Commission that
classifies     positions, administers examinations, and

                                        20
maintains    the official     personnel records of all city em-
ployees.     Applications     for employment in air pollution        con-
trol activities      may be made to either the Civil Service
Commission or to the Department of Environmental             Control
 (the city's    air pollution     control agency).    Although the
Department hires its own personnel,         all applications     must
be approved by the Civil Service Commission, the budget of-
fice, and the office of the mayor.

      With the exception of elected and certain appointed
employees, all city employees are required to take a compet-
itive examination    to acquire permanent civil   service status.
Temporary appointments without an examination,      however, may
be made for a period of 60 days, and these appointments may
be extended for unlimited     periods,  Our review showed that
75 of 177 staff members of the Department of Environmental
Control were classified    as temporary employees as of July
1970, including   the Deputy Commissioner who was originally
hired in 1962.

       To evaluate the hiring practices       of the city, we re-
viewed the policies    and procedures of the Civil Service
Commission and the Department of Environmental            Control,  in-
terviewed commission and department officials,            and reviewed
personnel files of several Department of Environmental             Con-
trol employees, selected on the basis of a random sample of
departmental    staff, excluding   clerical    personnel.      Our sam-
ple included 44 employees-- 25 percent of the executive man-
agement and technical    professional     personnel and 50 percent
of the inspectors.
     A Civil   Service Commission official    told us that there
were no formal written    procedures for the hiring    of person-
nel.  In addition    the personnel files   of both the commis-
sion and the department were incomplete.        Consequently,
much of our information    was obtained orally.

        Civil Service Commission position          descriptions     include
"desirable     minimum qualifications."         To ascertain     the qual-
ifications      of department personnel,       we compared the infor-
mation we obtained from the personnel files and interviews
with the employees' position         descriptions.        Our comparison
indicated     that the executive management and technical              pro-
fessional     staff generally    met the requirements         of the

                                     21
position     descriptions.      On the other hand, our comparison
indicated      that six of eight weather equipment and
environmental-sampling        technicians   and 17 of 23 inspectors
included in our sample did not meet the desired minimum
qualifications       for their current positions.

    For example, one individual       who had worked as a city
highway timekeeper for 24 years was hired in 1967 as an in-
spector III and later became an equipment technician.          The
position  description     for an inspector   III includes the fol-
lowing desirable     minimum qualifications:
      --Graduation    from high    school.

      --Three years of experience as an inspector      II, or
         6 years of experience as an inspector    I, or an equiv-
         alent combination   of training and experience.

      --Knowledge of fuel-burning         and combustion-control
         equipment.

      --The ability  to instruct        operators  in the proper   op-
         eration of fuel-burning        equipment.

The individual   was not a high school graduate, had no expe-
rience as an inspector     I or II, and apparently     had no knowl-
edge of fuel-burning     and combustion-control     equipment.
Furthermore,   the individual   had not taken a Civil Service
Commission examination for inspectors,        although such an ex-
amination had been given subsequent to his employment as an
inspector.

        Several of the employees in our sample held positions
with other city of Chicago or Cook County agencies prior to
employment by the Department of Environmental           Control as
 inspectors     III.    One was a municipal   court assistant   office
supervisor,       another a clerk in the Cook County Recorder of
Deeds Office,        and a third a public works cashier and a mu-
nicipal     court clerk.      We found no indication  that any of
these individuals        had experience as inspectors    I or II or
that they had knowledge of, or experience with, fuel-
burning and combustion-control         equipment.



                                   22
       A Civil Service Commission official   told us that the
position   descriptions merely provided desirable   qualifica-
tions and were not binding.     He stated that, when a posi-
tion was to be filled   and the candidates   did not meet the
desired qualifications,   the department could hire someone
and train him for the position.

       Civil Service Commission personnel told us that the
general policy was to hire personnel from commission exam-
ination    lists.  We found, however, that 39 of the 44 employ-
ees in our sample were hired prior to taking civil    service
examinations.     Furthermore, 17 of the employees have never
been certified    by the Civil Service Commission.

      We reviewed activities     of the inspectors    and found that
(1) they were performing     their assigned duties,      (2) records
were maintained of their activities,        (3) supervisors    eval-
uated the work of the inspectors,        and (4) there was followup
on reported violations.      We were not, however, able to eval-
uate the effectiveness     or efficiency    of the work performed
by the inspectors.

        Because many of the Chicago staff members did not meet
the qualifications       included in the position       descriptions,
we examined into the extent of training            provided to air
pollution     personnel.     We found that neither      the city of
Chicago nor APCOmaintained          sufficiently    detailed    records
which provided information         on the type and extent of train-
ing.     Limited data available      indicated   that training      was
primarily      for executive management and technical          and pro-
fessional     staff rather than for inspectors         or engineering
technicians.
     We found also that the turnover        of the Chicago staff
for all positions, including  clerical,       averaged about
15.4 percent from 1965-69.

      In May 1970, APCO personnel evaluated the city of Chi-
cago's air pollution     program and made recommendations re-
lated to the qualifications       and training    of field personnel
 (see p. 10). APCO officials      told us, however, that APCO
could not control    or influence      State or local government
personnel in the hiring      of staff.


                                   23
                                  CHAF'TER4

                     AIR QUALITY CONTROLSTANDARDS

                       AND IMPLENENTATIONPLANS

        The Clean Air Act, as amended by the Air Quality Act
of 1967, provides for an intergovernmental              system for the
prevention     and control    of air pollution      on a regional      basis.
The act requires       that the Administrator,        EPA, designate air
quality    control    regions and issue air quality         criteria     and
control    techniques     for various pollutants.        The act re-
quires also that air quality         control    regions be designated
on the basis of jurisdictional         boundaries,      urban-industrial
concentrations,       and other factors     including    atmospheric
areas necessary to provide adequate implementation                  of air
quality    standards.      As of December 31, 1970, 100 air quality
control    regions had been designated.

        EPA is responsible         for developing       and issuing air qual-
 ity criteria     reflecting       available    scientific     knowledge of
the adverse effects          of various air pollutants           on public
health and welfare.           Air quality      criteria     documents sum-
marize available        information       on the relationship       between
exposures to air pollutants              and their effects       on man and
his environment.          As of December 31, 1970, air quality              cri-
teria for five air pollutants--sulphur                  oxides, particu-
lates,    carbon monoxide, hydrocarbons,               and photochemical      ox-
idants--had     been issued.          Reports on control       techniques
were issued simultaneously             with the criteria,         These re-
ports provided information             on the availability        and appli-
cability     of techniques       for the prevention         and control    of
air pollutants       at their sources and on the cost and effec-
tiveness     of such techniques,

        The States were then required to establish,     for appli-
cation in the designated air quality       control regions,  air
quality    standards for each of the pollutants    for which air
quality    criteria  and control techniques were issued.     Stan-
dards are the desired limits     on levels of the pollutants      in
the air.



                                      24
        The States were required also to adopt plans for im-
plementation     of the air quality    standards.   APCO guide-
lines specified     that implementation     plans were to describe
the steps that would be taken to ensure attainment          of air
quality    standards within a reasonable time.       The air qual-
ity standards and implementation        plans were to be submit-
ted to EPA for review and approval.

       The act required that the States act in accordance
with the following     timetable.       The States had 90 days in
which to notify    the Administrator,       EPA, in writing  of their
intent to adopt air quality         standards for those pollutants
for which air quality      criteria     had been issued by EPA, 180
additional   days in which to establish         air quality standards,
and 180 additional     days to develop an implementation        plan
to achieve these standards.

         The various requirements       of an implementation         plan
must be enforceable       by State action.          This does not mean
that the States cannot utilize           the capabilities        of city3
county, and regional        air pollution       control    agencies.
States may elect to assign such agencies responsibility                    for
conducting     enforcement,     air-monitoring,        and other activi-
ties, but the States (1) should oversee and coordinate                    ac-
tivities     to insure uniformity,        (2) should provide technical
assistance     and financial     support,     and (3) must have legal
authority     broad enough to permit the State to enforce re-
quirements for the application           of control      techniques     in ac-
cordance with the implementation            plan's timetable.

METROPOLITANCHICAGOINTERSTATE
AIR QUALITY CONTROLREGION

       In regions that include parts of two or more States,
the establishment     and implementation         of air quality    stan-
dards requires     cooperation       and coordination     among the States
involved.     Because the Chicago control           region included six
counties in northeast       Illinois     and two counties in north-
west Indiana,    the States of Illinois         and Indiana were re-
quired to establish      air quality      standards for five pollu-
tants (see p. 24) and to adopt implementation               plans for
such standards.



                                     25
      The Secretary of Health, Education,        and Welfare issued
air quality   criteria   for sulphur oxides and particulate        mat-
ter in February 1969 and criteria        for photochemical    oxidants,
hydrocarbons,    and carbon monoxide in March 1970. The fol-
lowing table shows the status,       as of December 31, 1970, of
the States of Illinois      and Indiana in establishing     air qual-
ity standards and implementation       plans for the Chicago con-
trol region.
                                               Illinois                               Indiana

                                       Date        Date           Date       Date        Date        Date
                                      -due     submitted       approved     -due     submitted    approved

 Sulphur      Oxides and Par-
   ticulates:
       Standards                    11-10-69    ll-   3-69      3-27-70   U-10-69     11-10-69     3-27-70
       Implementation        plan    5 7-70     12-23-70            -      5- 7-70    12-14-70         -
 Photochemical        Oxides,
   Hydrocarbons        and Carbon
   Monoxide:
       Letter     of intent          6-19-70     6-10-70          N/A      6-19-70     6- l-70       N/A
       Standards                    12-14-70    not sub-
                                                   mitted           -     12-14-70    not sub-
                                                                                         mitted
      Implementation      plan       6-14-71          -                    6-14-71        -


        The States of Indiana and Illinois       coordinated  their
efforts    in developing   air quality    standards for sulphur ox-
ides and particulates.        State officials    told us also that
there was some coordination        in developing    the implementation
plans and strategies     for the control of these pollutants.

      Although the States of Indiana and Illinois      were to
submit to APCO implementation     plans for the control   of sul-
phur oxides and particulates    by May 7, 1970, they did not
submit the plans until    December 14 and 23, respectively.
Indiana submitted an introduction      to its plan on May 12,
1970, and an interim plan on July 29, 1970.

      APCO officials  reviewed the plan and concluded that
the plan lacked information       on local regulations,       time
schedules for adoption of proposed regulations,            time sched-
ules for compliance,    interstate     cooperation,     and an ade-
quate emergency episode plan.        APCO concluded also that the
State did not have adequate authority          in certain areas.
APCO provided the State technical        assistance     in revising
its plan which was submitted on December 14, 1970. This
plan contained provisions      for intergovernmental       cooperation.


                                                          26
       On May 5, 1970, the State of Illinois     submitted a sta-
tus report on its plan, which summarized the provisions          of
the State's plan.     APCO reviewed the report and, in July
1970, concluded that the plan should be revised substan-
tially   if it were to be approved.    Revisions were needed
with regard to provisions     for (1) additional    State legisla-
tion,   (2) more effective  interstate  cooperation,     and (3)
more effective   plans for emergency episodes,       APCO  re-
quested that the State advise it as to when a plan would be
submitted.

      By letter  dated September 8, 1970, Illinois      State offi-
cials told APCO that they could submit an implementation
plan by December 31, 1970, and enact the necessarq statutes
to enforce the plan by Februaryl,       1971. They attributed
the delay in submitting    the implementation    plan to a major
reorganization   of the State agencies responsible      for envi-
ronmental matters.     The implementation    plan was submitted on
December 23, 1970, This plan did not contain provisions
for intergovernmental    cooperation.

       We discussed the State standards and implementation
plans with local agency officials         who told us that State
air pollution     control personnel had not contacted them with
regard to the development of the implementation            plans.    Lo-
cal officials    also stated that their programs had been lim-
ited to local areas of jurisdiction         and that there had been
little   contact or coordination      with other State or local
agencies.     No agency had been established       for the purpose
of administering     an air pollution     control program for the
entire region.      Rather, a number of State and local agencies
were being awarded Federal grants.          Thus, although air qual-
ity control    regions have been established       to control pollu-
tion on a regional       basis, there appears to be little        in the
way of a regional      approach to air pollution      control   in the
Chicago control region,

CLEAN AIR AMENDMENTS
                   OF 1970

        The Clean Air Amendments of 1970 (Pub. L. 91-6041, en-
acted on December 31, 1970, revised substantially            the Clean
Air Act as it related    to air quality    control    regions,    stan-
dards, and implementation    plans.     The principal     revisions
follow.

                                   27
--Within    90 days after enactment of the act, the Ad-
  ministrator,     EPA, would designate the remaining in-
  terstate     and major intrastate  air quality control
  regions.

--Within    30 days after enactment of the act, the Ad-
  ministrator    would publish a list of air pollutants
   for which air quality     criteria were to be issued.

--Within  12 months after the pollutants   are listed,
   the Adminstrator must issue air quality    criteria     doc-
  uments and reports on control techniques.

--The requirement    that States were to develop ambient
   air quality  standards for each pollutant   for each
   air quality region was abolished,

--Within    120 days after enactment of the act, the Ad-
  ministrator      would promulgate national   ambient air
   quality    standards for the five pollutants    for which
   air quality     criteria had been issued.

--The States are to submit implementation        plans for
   each pollutant   to the Administrator   within 9 months
   after promulgation    of the standards.
--The Administrator    is to approve or disapprove the
   States' plans within 4 months after they are received.

--Requisites   of an implementation   plan were codified
   in the act.

--If the States do not submit an implementation       plan
   within 6 months after the time prescribed,      or the
   Administrator   determines within this time that the
    States' plan did not meet the requirements     of the
   act, the Administrator    will promulgate appropriate
   emission control regulations     for those States.
--Implementation  plans adopted and submitted by the
   States as of December 31, 1970, were to be approved
   if they met the requirements of the amendments to
   the act,


                          28
         These amendments will affect the Illinois       and Indiana
programs to the following        extent,   State standards for pho-
tochemical     oxides, hydrocarbons,     and carbon monoxide, which
were to be submitted to EPA by December 14, 1970, will not
be required.       Rather, the Administrator,     EPA, is to promul-
gate standards for these pollutants         by April 30, 1971. The
States will have 9 months after the standards are promul-
gated to submit plans to EPA for implementing the standards,
Prior to enactment of the Clean Air Amendments of 1970,
Illinois     and Indiana 'had only until    June 14, 1971, to sub-
mit implementation       plans for the three pollutants,




                                29
                                  CHAPTER5

              PROGRESSACHIEVEDBY LOCAL AGENCIES IN

          ADMINISTERING AIR POLLUTION CONTROLPROCRAMS

       The primary objective         of air pollution       control    programs
should be the enhancement of the quality               of the air.       APCO
guidelines    for the development of air quality              standards and
implementation      plans state that, in developing a program, a
control    agency should (1) have an inventory              of the sources
of emissions of each pollutant,            (2) maintain an air-
monitoring    network to obtain data on the concentration                  of
each pollutant      at strategically       located points, and (3) have
and enforce effective        laws and regulations.           The following
sections discuss the efforts           made and progress achieved by
local agencies in the Chicago control              region in compiling
emission inventories,        establishing      air-monitoring       networks,
and enforcing     laws and regulations.

EMISSION INVENTORIES

      An ideal emission inventory      should include all sources
of air pollutants    within a specified     area.    Because it is
not economically    feasible   to obtain emission data from every
source, however, it is the general policy of APCO and State
and local agencies to obtain data on the major sources
(point sources) and to combine lesser sources into groupings
(area sources).     The inventory   should contain such informa-
tion as the name and location      of the source; type of pollu-
tants emitted;    and magnitude, frequency,       and duration of
the emissions.

      APCO considers a point source as any stationary     source
that emits more than 10 tons per year of any pollutant.
Point sources include major fuel users, incinerators,      open
burning dumps, and industrial  plants.   Information   on point
sources is usually obtained through mailed questionnaires,
personal contacts with source officials,    and visits  to the
sources.

      APCO considers area sources to be stationary   sources
that emit less than 10 tons of pollutants    per year and mobile
sources, regardless  of size.   Area sources include residences,

                                      30
small buildings,  and vehicles.                   According to APCO these
sources should be divided into                   groupings by type and geo-
graphic location  and estimates                  of emissions calculated  by
the use of various mathematical                   techniques.

      APCO has divided         air     pollution        sources     into   four   cate-
gories.

      1. Fuel combustion             (residential,        commercial,       industrial,
         and utility).

      2. Industrial      process         losses      (losses      from manufacturing
         processes).

      3. Solid   waste disposal.

      4. Transportation.
       We examined into the city of Chicago's development of de-
tailed emission inventories     for sulphur dioxide and suspended
particulates,     the two major sources of pollutants     from sta-
tionary    sources.   With the assistance  of APCO personnel,     the
city completed, in 1965, an emission inventory        from fuel
combustion sources.      The emission data is summarized below.

                                Sulphur                             Suspended
                                dioxide                           particulate
  Source                Tons                Percent            Tons           Percent

Industrial              65,400                   10.5             44,700           30.8
Utilities              426,700                   68.6             20,100           13.8
Commercial              47,300                    7.6             18,800           12.9
Residential             83,000                   13.3             61,700           42.5
      Total            622,400                                 145,300

      In 1966 a power company submitted updated estimates
that showed that sulphur dioxide and particulate       emissions
from the utilities   had been reduced to 373,100 and 18,000
tons, respectively,    Beginning in 1967 the city distributed
about 35,000 questionnaires     requesting  updated information
for emissions from fuel-burning      equipment.   City officials
told us that responses to the questionnaires       had been


                                            31
received and that the results         should    be tabulated   and sum-
marized in February 1971.

      From 1966 to 1969 the city compiled data on particulate
emissions from other sources.       A 1966 study indicated    that
about 15,200 tons of suspended particulates      were emitted
annually from sources used for solid waste disposal.          In
1967 the city estimated that about 13,700 tons of particu-
lates were emitted annually from transportation       sources.
Also in 1967 the city completed an inventory      of particulate
emissions from industrial     process losses, which has been
updated annually, as follows:
                   Particulate    Emissions From
                   Industrial    Process Losses
                       Year                    Tons
                       1967                90,000
                       1968               110,000
                       1969                84,300

     Although some of the other local agencies in the Chi-
cago control    region were in the process of compiling emis-
sion inventories,     none had completed any such inventory.




                                 32
AIR MONITORING

     APCO guidelines   for the development of implementation
plans provide that a system for surveillance    of air quality
is necessary to assess progress being made in implementing
air quality  standards within a region and to identify    poten-
tial high pollutant   concentrations  in time to take preven-
tive action.
       An air-monitoring       system is the means by which data is
obtained on the nature and extent of pollution              in the atmo-
sphere.     Such a system consists of a network of air-sampling
and meteorological       instruments     located to provide representa-
tive coverage of an area.            The devices in the network range
from simple static       devices,     such as dustfall   jars, to sophis-
ticated    equipment that automatically         samples and analyzes
pollutants    and telemeters       the data to a central receiving
station for immediate interpretation.             Generally   separate
equipment is required for each pollutant.

     The following  table shows the air-monitoring   stations
for sulphur dioxide and particulates   for each of the agen-
cies within the Chicago region.
                          Number of Air-monitoring     Stations
                                             Pollutant
     Agency            Total    Sulphur dioxide        Particulates

Illinois:
       Chicago           20               20                   20
       Cook County       16                8                   15
Indiana:
       Gary                6                3                    6
       Hammond             4                3                    4
       East Chicago        5                5                    5
       Lake County         8                8                    8

      In 1963 the city of Chicago established         an air-monitoring
network of 20 stations       with manual sampling equipment to
monitor sulphur dioxide and/or particulates.           In 1965 tele-
metered air-monitoring       equipment was installed     at eight of
the stations   to monitor sulphur dioxide,         By July 1970 the
eight telemetered     stations    also monitored particulates.


                                    33
        APCO criteria    for particulates     states that adverse
health effects       are noted when the annual geometric mean
level of particulate        matter in the atmosphere exceeds 80
micrograms per cubic meter.           Data obtained by the city from
the manual equipment at the 20 stations            indicated    that the
level of particulates        in the air had remained relatively
constant since 1965. As shown by the following               table, the
annual average has been about 50 percent higher than APCO's
criteria   of 80 micrograms per cubic meter.

                                          Micrograms
                Year                    per cubic meter
                1965                          123
                1966                          133
                1967                          115
                1968                          123
                1969                          120

Not only did the annual average exceed APCO's criteria,             but
also the particulate  readings at each of the 20 stations
exceeded 80 micrograms per cubic meter.

      APCO criteria    for sulphur dioxide states that adverse
health effects     are noted when the annual arithmetic     mean
level of sulphur dioxide in the atmosphere         exceeds .04 parts
per million.     Data obtained by the city from the manual
equipment at the 20 station      network indicated    that the annual
average of sulphur dioxide had declined from a high of
.053 parts per million      in 1966 to ,026 parts per million     in
1969. At four of the stations,       however, the level of sul-
phur dioxide in 1969 exceeded .04 parts per million.

       Data obtained from the telemetered       equipment at the
eight stations    for the same period indicated       that the level
of sulphur dioxide remained relatively        constant at an annual
average of .06 to .07 parts per million,          City officials
told us that they had experienced technical          difficulties
with the telemetered      equipment and that the telemetered          in-
formation was not as reliable       as that obtained from the
manual equipment at the 20 stations.         City officials       stated
that data on overall      trends in air quality    was obtained from
the manual equipment at the 20 stations         and that data from
the telemetered     system was used primarily     for predicting

                                   34
adverse conditions  that mi ht necessitate        the activation    of
an emergency episode plan. t?

      In commenting on the telemetered air-monitoring   system,
APCO technical  staff members who had reviewed the City's
program in May 1970 stated that:

     "The maintenance and servicing        of this network
     has proven to be a serious problem,          Some of the
     problems are associated       with location   (accesible
     only during 8 to 5 working hours), lack of space,
     nonrepresentable      areas (severe influence    of lo-
     cal sources),    etc.     As a result the system has
     not provided the quality       and quantity   of data ex-
     pected."t
       Four of the Cook County air-monitoring          stations are
telemetered   and are interconnected        with Chicago*s eight
telemetered   stations.        None of the local agencies in Indiana
have telemetered       equipment, and local agency officials       told
us that they had no plans for installing           telemetered  equip-
ment.    The officials      also stated that there was no intercon-
nection of air-monitoring         stations  between the Indiana agen-
cies; norwas there any interconnection           between State and/or
local agencies in Illinois         and State and/or local agencies
in Indiana.

      As part of its surveillance     program, the city desired
to install    "eye in the sky" cameras at strategic     locations
throughout     the city.   These cameras were to revolve and have
the capability     of detecting  areas of intensive  pollution,
The city purchased, with non-Federal       funds, one eye-in-the-
sky camera in 1966 at a cost of $5,500.
      In its grant application     for 1969, the city requested
$75,000 to purchase and install       a microwave station that in-
cluded an additional   eye-in-the-sky     camera. APCO's grant

1
 A plan for short-term     control designed to protect      the pub-
 lic against the acute effects       of high concentrations    of
 pollutants.    The plan includes methods of identifying        sit-
 uations where corrective      action should be taken and proce-
 dures and strategies    for control when action is necessary
  to prevent further   deterioration    of air quality.
                                  3.5
to the city for 1969 included the requested $75,000.    APCO
advised the city, however, that, before expending Federal
funds for the microwave station,  APCO approval was required.
The city did not purchase the station.




                             36
ENFORCEMENT

       The city of Chicago has attempted to control          air pol-
lution by enforcement of ordinances,        operation   of a permit
system for construction,      and encouraging private      industry
to take appropriate    control measures voluntarily.          City or-
dinances prohibit   open burning and burning of refuse in
boilers,   limit the amounts of visible      and particulate       emis-
sions, and, since July 1, 1970, provide a timetable             for re-
duction of sulphur content in fuels.

      Enforcement activities      have been directed       principally
toward ensuring compliance with the ordinances pertaining
to particulate   emissions.      As of February 1970 the city had
37 inspectors   and 20 radio-equipped        vehicles    used primarily
to enforce ordinances pertaining          to particulates.       Thirty-
one inspectors   patrolled    the city to detect emissions,            and
six inspectors   investigated     citizen    complaints    and odor
problems.
      Offenders involved in minor violations        of the ordi-
nances were ticketed    and fined $10 prior to June 1, 1970,
and fined $100 after that date.       Repetitive    offenders   and
offenders   involved in major violations      of the ordinances
were subject to fines of from $10 to $200 prior to June 1,
1970, and from $100 to $500 thereafter.          The ordinances
also provided for the sealing of equipment that was in vio-
lation of emission standards.      That action,     however, had to
be approved by the mayor,
       The following statistics          taken from the city's  annual
reports summarize the actions            taken for calendar years
1965-69.

   Action   taken          1965          1966     1967     1968     1969

Tickets issued             2,635         2,156    1,876    1,752    3,517
Suits originated              523           307      253      291      411
Fines levied
   from court action         609           291      250      302      336
       The fines levied prior to June 1, 1970, in accordance
with   the city's   ordinance,   did not, in many instances, pro-
vide   an effective    deterrent  to polluters, because they were

                                    37
not commensurate with     the cost     of installing    pollution   con-
trol equipment.

      For example, a smelting company had a record of viola-
tions of the ordinance since 1965 and had been fined $10 on
several occasions.    Furthermore,    between September 1969 and
March 1970, the city filed nine suits against the company--
four of which had been brought to court by June 1970. In
all four cases the company was found guilty        of violating
the ordinance;  however, the fines levied totaled only $250
plus $20 court costs for the four suits.        City officials
estimated that effective    pollution   control equipment for
the company would cost about $20,000.

      The city used a permit system to control certain            emis-
sions --primarily    particulates.       Before the installation,
construction,     or alteration     of industrial   process, fuel-
burning,    or refuse-burning      equipment, a permit had to be
obtained from the Chicago Building           Department.   A permit
was issued when an air pollution           control engineer reviewed
the plans and specifications         of the proposed equipment and
concluded that air pollution         requirements   were complied with.

       The equipment was inspected after it had been installed
to ensure that it conformed with the plans and specifica-
tions.    A certificate of operation was granted if the in-
stalled   equipment met the city's  air pollution requirements.
The equipment is inspected annually and the certificate      must
be renewed each year.

       The city had about 20 employees who inspected facili-
ties that burned fuel or refuse.          When inspections   disclosed
defects that could alter the burning characteristics            of the
equipment, the inspectors       issued defect notices to the own-
ers of record.      City regulations     provided that, when owners
did not respond to defect notices,          second and third notices
were to be sent to the owners,         If the defects were not cor-
rected after three notices were issued within a go-day pe-
riod, their certificates      of operation     could be revoked.
City officials    told us that they issued about 15,000 defect
notices annually.

      We found that the first defect notices           were issued on
a timely basis but that, in many instances,            the second and

                                  38
third defect notices were not sent within the prescribed
go-day period,     Also, notifications   of corrective    action
were not verified     by city personnel until   the following
year's inspection.      As a result there were no assurances
that defects were in fact corrected      as reported.

       The city had a staff of seven engineers to inspect
about 2,100 plants that had particulate           emissions from in-
dustrial    processes.     Plants that operated in compliance with
particulate     emission standards were awarded certificates           of
operation.      Plants  that   did  not  comply with   the standards
were denied a certificate         and given the opportunity     to re-
duce emissions to an acceptable          level through engineering
control programs.

       Cit]~ personnel provided technical      assistance to plants
operating under control programs and monitored the progress
of the programs.      The city also agreed not to initiate
court action for violation       of the standards against the
plants while operating under the control programs,          Plants
were given a reasonable time to correct the deficiencies.
The city's    policy was to give plants a 6-month "period of
grace" if the control programs could be completed within
that time.      If the completion   of their control programs ex-
ceeded 6 months, the plants had to obtain the city's         agree-
ment to vary from the city's       ordinances.

       The city's     policy was to review a plant's progress un-
der its control program and to issue certificates        of opera-
tion when the deficiencies       had been corrected.  Plants that
did not make satisfactory       progress or did not correct the
deficiencies      within the agreed period were subject to court
action.

       City of Chicago records showed that 107 companies that
emitted an estimated 93,000 tons of particulates        annually
were operating      under control programs as of May 1970. Of
the companies, 24 substantially      had completed the control
programs and were awaiting inspections       for the purpose of
obtaining   certificates    of operation;  20 companies had failed
to comply with their control      programs and had been referred
to the courts for enforcement action;       62 companies were in
the process of complying with their programs; and one com-
pany had gone out of business.

                                  39
                           Through its ordinances,     permits,      and plants'   control
                    programs, the city of Chicago       has the means for an effective
                    program.     As part of another    review, we are examining into
                    the effectiveness    of Federal,     State, and local air pollution
                    control agencies'    enforcement     activities.      The Illinois,
                    Indiana, and Chicago agencies       have been included in that re-
                    view.    We expect to complete     the review and issue a report
                    to the Congress by the end of        1971.




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. :,.
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                                                       40
APPENDIX




 41
                                                                                    APPENDIX I




                    January     30, 1970


                    The Honorable   Elmer 7). Staats
                    Coinptroller  General of the United         States
                    441 C Street,    N.W.
                    Washington,   D.C.    20548

                    Dear Xr.     Staats:
                    Please     find enclosed copies of two recent     CHICAGO TP,ZLJI\TF
                    articles       xherein it is alleged that Federal   air pollution
                    control      funds may be misused by the City of Chicago.
                    One article     appears to bring into question          the whole con-
                    cept of a State's      delegation     of air pollutio:!      control    _
                    operations     and the Teaera      Government's     authority      to
                    sanction    thein.   In addition,     se,-ious q*Jestions     would appear
                    to exist    over the effective      use of equipment acquired
                    through Federal      3Lnancial    assistance.
                    The second article      m:-ises serio>x     concern over the contri-
                    bution   of Bederal.funds      to the City of Chicazo for employ-
                    geht ol" air pollution      inspectors   and the value the taxpayers
                    are getting   fron the expenditure       of   such  funds.
                    Iti light  of these articles        and with the gror\;ing incidence
                    of air pollution       in Chicago and else?.?here, T believe            it
                    would be rnoct xorth7Mle         if the Seneral Jxcounting           Xfice
                    could use these alleged        incidei;ts   to examine into the
                    adzinie txa';lon    of the air pA.liltion     co:-itrol   progiqn:n 's;r the
                    Depa3xent      of 'rrealth, Pducatior?,    and "Telfa:"e,    treatl2z
                    Chicczo c"s E test case.




U.S.   GAO Wash.,    D.c.

                                                     43