State of California
                            AIR RESOURCES BOARD
                                
                           State Office Building
                     455 Golden Gate Avenue, Room 1194
                             San Francisco, CA
                                
                             January 10, 1974
                                 9:30 a.m.
                                
                                  AGENDA

74-2-1    Approval of Minutes of December 18, 1973 Meeting.

74-2-2    Public Hearing - Proposed Enforcement Action With
          Respect to Variances for Stationary Sources.

74-2-3    Consideration of Yolo-Solano Air Pollution Control
          District Enforcement Actions - Yolo County Rice Mills.

74-2-4    Staff Report - Responses from Local APCD's Concerning
          Kraft Pulp Mill Control Programs.

74-2-5    Consideration of State Implementation Plan Revision to
          Provide Indirect Source Review Procedures.

74-2-6    Other Business -
          a.   Research Proposals
          b.   Executive Session - Personnel and Litigation

74-2-7    Remarks from Audience - End of Morning and Afternoon
          Sessions.

                        ITEM NO.:  74-2-2

Public Hearing on Proposed Enforcement Action With Respect to
Variances for Stationary Sources.

                          RECOMMENDATION

Adopt Resolution 74-1, which would allow for the assumption of
the powers, in certain air pollution control districts to enforce
applicable regulations or to grant or modify variances, including
conditions thereto and compliance schedules.  This would avoid
direct enforcement action by the Environmental Protection Agency.

                             SUMMARY

1.   The EPA has indicated that if approvable compliance
     schedules are not received from the State by March 15, 1974,
     EPA will bypass state and local air pollution control
     authority and take direct enforcement action.

2.   To avoid direct EPA enforcement action, the Air Resources
     Board should:

     a)   Assume the powers of the districts listed in Exhibit I,
          Resolution 74-1 to take appropriate legal action to
          enforce local regulation or to grant or modify
          variances, including conditions thereto, and compliance
          schedules for the sources listed in Exhibit I.  This
          action would be taken pursuant to Health and Safety
          Code Sections 39054, 39054.2, 39273, 39274, and 39276.

     b)   Continue this hearing until March 12, 1974 with respect
          to the assumption of the powers of the Districts listed
          in Exhibits II and III, Resolution 74-1, to take
          appropriate legal action to enforce local regulations
          or to grant or modify variances, including conditions
          thereto, and compliance schedules for the sources
          listed in Exhibits II and III.

                        ITEM NO.:  74-2-3

Consideration of Yolo-Solano Air Pollution Control District
Enforcement Actions - Yolo County Rice Mills.

                          RECOMMENDATION

Instruct the Executive Officer to:  1) write the District Hearing
Board and request that variance/compliance schedules be
established for all sources denied permits to operate, and 2)
request the district to determine whether proposed housekeeping
procedures for the bin on drier Number 2 would solve the problems
attributable to this source.  The matter should be continued to
February 14, 1974.

                           INTRODUCTION

In October, 1973 the staff received public complaints and
inquiries indicating a problem with emissions from rice drying
and milling operations in West Sacramento, which is in the
jurisdiction of the Yolo-Solano Air Pollution Control District. 
The staff established an ambient air suspended particulate
concentration monitoring facility in the area and confirmed the
problem.

In response to the complaint, the Board held a public hearing on
November 13, 1973 to consider whether emissions from the Rice
Growers Association (RGA) and Rice Mills products (RMP) rice
plants were in compliance with applicable rule and regulations of
the District, and whether the District had taken reasonable
action to enforce it regulations if emissions were not in
compliance.

District personnel testified that a meeting of the district
hearing board was scheduled for December 11, 1973 to consider
variances for both companies.  The ARB's November 13, 1973
hearing was continued until the January 10, 1974 meeting to allow
for consideration of the district hearing board actions.

          ARB STAFF COMMENTS REGARDING DISTRICT ACTIONS

The District Hearing Board issues variances for 3 of the 7 RGA
sources for which a variance was requested.  Emissions from the
sources for which a variance was not issued will be controlled by
RGA on its own time schedule.

It would have been better if the Hearing Board had issued
variances which required installation of control equipment on a
predetermined schedule for all seven sources.  This would
establish officially the compliance schedule the company outlined
for those sources the hearing board feels that variances are not
needed.  If the schedule was not met, the district could then
take immediate enforcement action, thereby preventing the
possibility of emissions from the noncomplying source causing
problems during the next drying season.  The District believes
this was not necessary because it has denied the company permits
to operate without appropriate control during the next harvest
season.

The variance issued for drier Number 2 did not include control of
emissions, beyond housekeeping, from the bin near the top of the
drier.  Fine material is emitted from this elevated source and
may contribute to the problem in the trailer court.  The district
should determine that housekeeping, without control equipment
will solve the problem.

                      POSSIBLE BOARD ACTION

At the close of the hearing, the Air Resources Board, may:

1.   Find the District Hearing Board actions inadequate and take
     appropriate legal action pursuant to Health and Safety Code
     Section 39274 to enforce the local air pollution control
     plan, including the emission standards and enforcement
     procedures therein, and may take any action the District is
     authorized to take;

2.   Instruct the Executive Officer to:  a) write the District
     Hearing Board and request that variance/compliance schedules
     be established for all sources denied permits to operate,
     and b) request the district to determine whether proposed
     housekeeping procedures for the bin on drier Number 2 would
     solve the problems attributable to this source.  The matter
     should be continued to February 14, 1974, and

3.   Find that the District has taken reasonable steps to control
     this problem and require no further action.

                          RECOMMENDATION

The staff recommends alternative Number 2 and that the entire
matter be continued to February 14, 1974, to consider the
District's response.

                        ITEM NO.:  74-2-4

Informational Report on District Responses to the Report "Kraft
Pulp Mill Emissions in California".

                          RECOMMENDATION

Continue to follow the actions being taken by the Humboldt County
Air Pollution Control District and the Bay Area Air Pollution
Control District to implement the recommendations made in the
kraft pulp mill report.  Follow the action being taken by EPA
concerning the compliance schedule adopted by the Shasta County
Air Pollution Control District for the Simpson Lee Paper Company.

                            DISCUSSION

At the November 13, 1973 Air Resources Board meeting in
Sacramento, a report "Kraft Pulp Mill Emissions in California"
was discussed.  As a result of this discussion, the Board
directed the staff to transmit the recommendations made in the
report to the three Districts in which pulp mills are located and
to report to the Board on January 10, 1974 on the responses of
the Districts to the recommendations.

The Humboldt County Air Pollution Control District and the Bay
Area Air Pollution Control district are both taking positive
actions to implement the recommendation made in the report.  The
Shasta County Air Pollution Control District has adopted a
compliance schedule for the Simpson Lee Paper Company with a
final compliance date of January 15, 1976.  The Board had
recommended that a compliance schedule be adopted that would
bring particulate emissions from the mill into compliance with
District regulations by EPA cutoff date July 31, 1975.  EPA has
stated that the compliance schedule as adopted cannot be approved
and that further action will be taken.  The other recommendations
made for Shasta County will be implemented.

                        ITEM NO.:  74-2-4

Informational Report on District Responses to the Report "Kraft
Pulp Mill Emissions in California".

                            DISCUSSION

At the May 2, 1973 Air Resources Board meeting in Eureka, the
Board directed the staff to investigate the variance granted the
Simpson Lee Paper Company in shasta County and to prepare a
report on the program that the two pulp mills in Humboldt County
were implementing to reduce odor emissions.  In order to
accomplish these tasks, the staff studied the programs currently
used to control odor emissions at the four kraft pulp mills
located in California.

At the November 13, 1973 Air Resources Board meeting in
Sacramento, a report "Kraft Pulp Mill Emissions in California"
was discussed in detail.  Representatives of the Humboldt County
Air Pollution Countrol Distirct, the Shasta County Air Pollution
Control District, and the Bay Area Air Pollution Control District
and representatives of the four kraft pulp mills made
presentations to the Board.  After hearing these comments, the
Board directed the staff to transmit to the appropriate districts
the recommendations made in the report and to report back to the
Board on January 10, 1974 on the districts' responses.  Letters
transmitting the recommendations were mailed on November 23, 1973
(letter attached).

                        ITEM NO.:  74-2-5

Consideration of State Implementation Plan Revision to Provide
for Indirect Source Review Procedures.

                          RECOMMENDATION

To be made After Board's Wednesday, January 9, 1974 workshop on
this subject.

                             SUMMARY

The Board help public hearings on November 13, 1973 and December
18, 1973 to consider amendments to the State Implementation Plan
to provide for the review and regulation of indirect sources of
air pollution.  Action on the proposed amendments was deferred
until January 10, 1974 to provide time to receive additional
testimon