United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/2-85-007
November 1985
Air
Progress in the
Prevention and
Control of Air
Pollution in 1984
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EPA-450/2-85-007
Progress in the Prevention and Control of
Air Pollution in 1984
Control Programs Development Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
November 1 985
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This report has been reviewed by the Environmental Protection Agency and approved for publication.
Copies of this report are available through the Library Services Office (MO-35), U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina 27711; or, for a fee, from the National Technical
Information Service, 5285 Port Royal Road, Springfield, Virginia 22161.
Publication No. SPA-450/2-85-007
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CONTENTS
Page
PREFACE v
I. INTRODUCTION AND SUMMARY
A. Overview 1-1
B. Air Quality Trends, Monitoring, and Modeling 1-1
C. Air Pollution Research Programs 1-3
D. Development of National Ambient Air Quality Standards. 1-4
E. Regulatory Assessment of Toxic Air Pollutants 1-4
F. Status of Air Quality Management Programs 1-5
6. Control of Stationary Source Emissions 1-8
H. Stationary Source Compliance 1-9
I. Control of Mobile Source Emissions 1-10
J. Litigation 1-11
II. AIR QUALITY TRENDS, MONITORING, AND MODELING
A. National Air Quality and Emission Trends II-l
B. Ambient Air Monitoring II-3
C. Air Quality Modeling II-6
D. Integration of Air Data Systems II-9
E. Emission Factor Development II-9
F. National Dioxin Study 11-10
III. AIR POLLUTION RESEARCH PROGRAMS
A. Introduction III-l
B. General Air Pollution Research Activities III-l
C. Acid Deposition Research Activities III-6
D. Energy-Related Research Activities III-8
IV. DEVELOPMENT OF NATIONAL AMBIENT AIR QUALITY STANDARDS IV-1
V. REGULATORY ASSESSMENT OF TOXIC AIR POLLUTANTS V-l
VI. STATUS OF AIR QUALITY MANAGEMENT PROGRAMS
A. Development of Policy and Regulations VI-1
B. Prevention of Significant Deterioration and
Nonattainment New Source Review Activities VI-4
C. Implementation Overview and Assistance VI-6
D. Air Pollution Training VI-12
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VII. CONTROL OF STATIONARY SOURCE EMISSIONS
A. New Source Performance Standards (NSPS) VII-1
B. National Emission Standards for Hazardous Air
Pollutants (NESHAP) VII-1
C. Delegation of NSPS and NESHAP , VI1-2
D. BACT/LAER Clearinghouse , VI1-3
VIII. STATIONARY SOURCE COMPLIANCE
A. General VIII-1
B. Litigation VII1-3
C. Continuous Compliance VI11-4
0. Timely and Appropriate Enforcement Response VIII-5
E. Civil Penalty Policy VIII-5
F. Compliance by Federal Facilities VIII-6
G. List of Violating Facilities VIII-6
IX. CONTROL OF MOBILE SOURCE EMISSIONS
A. Introduction IX-1
B. Standard Setting IX-2
C. Preproduction Compliance IX-3
D. Inspection/Maintenance , IX-4
E. Mobile Source Enforcement. IX-4
F. Imports IX-6
X. LITIGATION
A. Introduction X-l
B. Stationary Source Cases.. X-l
C. Mobile Source Cases X-3
D. District Court Cases „ X-3
XI. REFERENCES XI-1
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PREFACE
The Clean Air Act, as amended, authorizes a national program of air
pollution research, regulation, and enforcement activities. This program
is directed at the Federal level by the U.S. Environmental Protection
Agency (EPA). However, primary responsibility for the prevention and
control of air pollution at its source continues to rest with State and
local governments. EPA's role is to conduct research and development
programs, set national standards and regulations, provide technical and
financial assistance to the States, and, where necessary, supplement
State implementation programs.
Section 313 of the Clean Air Act requires the Administrator to report
on measures taken toward implementing the purpose and intent of the Act.
This report covers the period January 1 to December 31, 1984, and describes
the issues involved in the prevention and control of air pollution and
the major elements of progress toward that goal that have been made during
that time. In addition, this report also includes two other EPA reports
to Congress required under the Clean Air Act, as amended:
1. Section 306 report on Federal procurement and violating facilities
(Chapter VIII), and
2. Section 202(b)(4) report on measures taken in relation to motor
vehicle emissions control (Chapter IX).
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I. INTRODUCTION AND SUMMARY
A. OVERVIEW
This report describes the progress that the Environmental Protection
Agency (EPA) has made in the prevention and control of air pollution during
1984. The following paragraphs summarize the contents of the remaining
chapters of this report, especially insofar as those chapters illuminate
current understanding of air quality problems, controls, and administrative
apparatus. Since it takes approximately 1 year to assemble, analyze, and
report air quality and emissions data on a national basis, the latest air
quality and emissions data available for this report are for the year 1983.
8. AIR QUALITY TRENDS, MONITORING, AND MODELING
All of the pollutants showed improvements in air quality and emissions
between 1975 and 1983. However, ozone air quality levels increased signifi-
cantly between 1982 and 1983. Specific details on air quality and emissions
levels for each of the pollutants to which ambient air quality standards
apply are as follows:
0 Annual average ambient total suspended particulate (TSP) levels
decreased 20 percent from 1975 to 1983, while TSP emissions decreased 33
percent.
0 Annual average ambient levels of sulfur dioxide (S02) decreased 36
percent between 1975 and 1983 and total sulfur oxide emissions decreased 19
percent.
0 Ambient carbon monoxide (CO) levels decreased 33 percent between 1975
and 1983, although there was little change between 1982 and 1983. Total CO
emitted during this time decreased 16 percent.
e Average ambient nitrogen dioxide (N02) levels decreased 4 percent
between 1975 and 1983. Between 1979 and 1983 both ambient N02 levels and
nitrogen oxide emissions showed reductions of 15 and 8 percent, respectively.
0 The composite average of the second-highest daily maximum 1-hour
ozone (03) values decreased 8 percent between 1975 and 1983, largely due to
the change in the calibration procedure which took place between 1978 and
1979. In the post calibration period (1979-1983), 03 levels increased
slightly (2 percent). Between 1982 and 1983, however, 03 levels increased
11 percent due to a combination of an increase of 3 percent in volatile
organic compounds (VOC) emissions and meteorology which was generally more
conducive to ozone formation in 1983 than in 1982.
0 Ambient lead levels decreased 67 percent between 1975 and 1983.
This is consistent with a 68 percent decrease in overall lead emissions and
a 75 percent reduction in lead consumption in gasoline.
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EPA promulgated regulations in 1979 which required States to establish
and operate air monitoring networks and to report the data to EPA. Two
types of permanent stations are provided for in the regulations—State and
Local Air Monitoring Stations (SLAMS) and National Air Monitoring Stations
(NAMS). The SLAMS, which were designed to meet the overall monitoring
requirements of State implementation plan (SIP) activities, were required
to meet all provisions of the regulations by January 1, 1983. Through
December 1984, 4,693 SLAMS monitors out of a total operating network of
4,724 monitors met all requirements of the regulations. The NAMS, which
are a subset of the SLAMS network, are designed to provide a national
monitoring network as required by Section 319 of the Clean Air Act (Act).
Through December 1984, 1,347 NAMS monitors out of a total planned network
of 1,360 monitors met all requirements of the regulations.
During 1984, EPA continued its program to evaluate several categories
of air quality models. The evaluation of complex terrain models was
completed. The results clarified the limitations of these models and
reaffirmed the urgent need for output, from EPA's Complex Terrain Model
Development Program. The evaluations of long-range transport models and
mobile source models were initiated and will be completed in 1985. Efforts
to expand EPA's internal capability to routinely evaluate models on a
broader variety of data bases was continued and the identification of
effective graphical techniques to present statistical performance information
on models was initiated. Multi-year cooperative agreements with the States
of New York and Connecticut were initiated to evaluate strategies for the
control of photochemical air pollutants in the New York metropolitan
area. State-of-the-art photochemical modeling techniques will be used in
this effort which will extend into 1986. Efforts to improve guidance on
air quality models and to ensure consistency in their use were continued.
In 1984, work progressed on the air quality component of the Aerometric
Information Reporting System (AIRS). This system is an integrated data
system that will replace entirely the existing data bases, files, and
software now used by EPA for storing and retrieving ambient air quality
data, stationary source and emissions data, and source compliance data.
EPA continued to support State efforts to develop emission control
strategies by publishing emission factors on various pollutants including
potentially toxic pollutants. Emphasis was placed on sources of particles
less than 10 microns in size and on sources of acrylonitrile, carbon tetra-
chloride, chloroform, ethylene dichloride, formaldehyde, nickel, and chromium.
Also in 1984, EPA initiated the National Dioxin Study to assess the
potential extent of contamination of the environment with chlorinated
dioxin compounds.
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C. AIR POLLUTION RESEARCH PROGRAMS
EPA's air pollution research program provides scientific data bases,
methodologies, assessments, models, emission reduction technologies, and
corresponding quality assurance support to develop and implement air quality
standards and to ensure compliance with them. The research program focuses
on the six air pollutants for which national ambient air quality standards
(NAAQS) have been established and on potentially hazardous air pollutants
which are defined as pollutants which may cause irreversible or reversible
incapacitating illness and for which an ambient air quality standard
has not been established.
In 1984, EPA completed a number of general air pollution research
activities. The second external review draft of the criteria document for
lead and the first external review draft of the criteria document for ozone
and other photochemical oxidants were completed. The addendum to the 1979
criteria document for CO was also published. Final health assessment
documents were completed for carbon tetrachloride, coke oven emissions,
chromium, inorganic arsenic, manganese, mercury, and methyl chloroform.
Three articles were published on research responding to critical data
gaps in the dose-response data base for SOg and 03. Studies designed to
determine whether diesel emissions are carcinogenic, and if they are, how
potent they are, were completed. EPA also developed plans for a long-term,
interdisciplinary integrated air cancer project during 1984. The purpose
of the project is to provide an improved capability for performing cancer
risk assessments on airborne pollutants. The goals of the program are to
identify the principal airborne carcinogens, determine which emission
sources are major contributors of carcinogens to the ambient air, and
improve the estimate of comparative human cancer risk from specific air
pollution emission sources. In addition, in order to improve urban scale
ambient air quality models, a protocol for developing a reactivity classi-
fication system for VOC's was prepared in 1984. This protocol will
enable EPA to determine the extent that specific VOC's contribute to the
formation of 03. Also in 1984, EPA conducted research activities related
to characterizing gaseous and particulate mobile source emissions from
heavy-duty diesel and gasoline-powered trucks and buses.
Research to develop methods for monitoring various pollutants focused
on particulate matter (PM) in accordance with the proposed change in the
particulate matter air quality standard from total suspended particulates
to PMig. Standard operating procedures for sampling ambient particulate
matter were developed, and a detailed PM^Q inlet comparison study was
conducted. Research activities related to controlling particulate emissions
focused on improving the performance, reliability, and cost-effectiveness
of electrostatic precipitators and fabric filters in collecting small
particles. Other research activities in 1984 related to controlling pollutant
emissions were directed toward the use of flue gas desulfurization (FGD)
systems for control of S02, utilization of low nitrogen oxide (NOX)
burners, in-furnace NOX reduction, air staging/recirculation and
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catalytic reduction for control of NOX, the use of flares for VOC control,
and the identification of major sources of hazardous air pollutants and
applicable control technologies.
The EPA also conducted research activities in 1984 in the area of acid
deposition. The objective of the acid deposition research program is to
develop the necessary data to fully understand the sources and characteristics
of acid deposition, as well as the extent of damage or potential damage.
In 1984, EPA completed the Eastern Lakes field survey. This study will
enable EPA to determine what percentage of lakes and streams in the
susceptible regions are acidic or have low alkalinity. In addition, in
1984 EPA also conducted research to assess the geochemical and physical
characteristics of soils in order to better understand the rate and extent
of acidification of surface waters.
The EPA's energy-related research activities in 1984 focused on the
development of the limestone injection into the multi-stage burner (LIMB)
emission reduction technology that is designed to simultaneously reduce
both sulfur oxide (SOX) and NOX. Beyond the possible acid rain retrofit
applications, these developments may make the LIMB technology suitable for
use as a low cost control alternative for meeting new source performance
standards for boilers operating with low-sulfur coal.
D. DEVELOPMENT OF NATIONAL AMBIENT AIR QUALITY STANDARDS
The 1977 Clean Air Act Amendments require EPA to review and, if
necessary, revise the NAAQS on a 5-year basis. Reviews of all existing
NAAQS were in progress in 1984. In February, EPA proposed to retain the
existing primary and secondary NAAQS for N02. The EPA also proposed not
to set a short-term N02 standard since data to establish such a standard
were not adequate and the current annual standard protects against peaks of
concern. In March, EPA proposed changes to the NAAQS for particulate
matter (PM). For the primary standard, EPA proposed to replace the
current TSP standard with a standard that includes only those particles
less than 10 micrometers (PM^o). The proposal indicated that the EPA
intended to select final primary standards from ranges of 50-65 micrograms
per cubic meter (ug/m3), annual arithmetic mean, and 150-250 ug/m3,
maximum 24-hour concentration. The EPA proposed to retain a secondary
TSP standard from the range of 70-90 ug/m3, annual average, and to revoke
the current 24-hour secondary standard.
E. REGULATORY ASSESSMENT OF TOXIC AIR POLLUTANTS
The EPA continued to evaluate a number of toxic and potentially toxic
substances in 1984. Decisions were published not to regulate toluene and
polycyclic organic matter (POM) under the Act. For toluene, this decision
was based on a judgment that currently available information did not
indicate a threat to public health at concentrations found in the ambient
air. For POM, there was considerable uncertainty as to the magnitude
of the cancer risk to the public, as well as difficulties in devising an
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appropriate regulatory program for several important POM source categories.
Also in 1984, coke oven emissions were listed as a hazardous air pollutant
under Section 112 of the Act.
As part of the EPA's effort to develop a more comprehensive and
effective air toxics control program, a draft report on the nature and
scope of the national air toxics problem was completed and issued for public
comment. The study indicates that while maximum individual risks tend to
be associated with major point sources, the great majority of the predicted
cancer incidence associated with air pollution is not mitigated by point
source controls. This study and follow-on analyses will be used to shape
future policy directions in the air toxics area.
As part of the program for regulating benzene (listed as a hazardous
air pollutant under Section 112 of the Act), EPA has been assessing the
need to regulate sources in the gasoline marketing chain. An analysis of
regulatory strategies for the gasoline marketing industry was published for
public comment in August 1984.
Also in 1984, substantial activities were undertaken to establish a
National Air Toxics Information Clearinghouse in an effort to improve
communication among EPA, State, and local agencies. The goal of the
Clearinghouse is to disseminate knowledge about activities under way to
solve toxic air pollutant problems and to reduce duplication of effort.
The EPA began publishing the Air Toxics Information Clearinghouse Newsletter in
December 1983 and published five issues in 1984. Other publications in
1984 were a bibliography of EPA reports relevant to toxic air pollutants, a
bibliography of health and risk assessment information, a listing of EPA's
ongoing research and regulatory development projects, and an interim report
summarizing data submitted by State and local agencies.
F. STATUS OF AIR QUALITY MANAGEMENT PROGRAMS
As mentioned previously, EPA proposed revised NAAQS for particulate
matter in March 1984. The proposed standards consist of primary standards
that would apply to a size range of particles nominally 10 micrometers and
smaller in diameter (PM^o), and an annual TSP secondary standard. The focus
of the proposed primary standards on a new particle size range necessitated
preparation of regulations, policies, and technical guidance so that SIP's
for PMiQ can be developed by the States. In 1984, EPA prepared a Federal
Register notice which solicited public comment on a number of considerations
relative to implementing the proposed PM^g standards. The Federal Register
package was in preparation at the end of 1984 with publication anticipated
early in 1985.
In December 1982, a number of petitioners filed suit to compel EPA to
promulgate State plans for visibility protection under Section 110(c) of
the Act for those States which had not submitted such plans as required by
rules published by EPA in 1980. During 1983, EPA and the Environmental
Defense Fund negotiated and signed a settlement agreement which was
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accepted by the court on April 20, 1984. The settlement agreement called
for a two-part implementation of the 1980 rules. New source review (NSR)
requirements and a visibility monitoring strategy were proposed for the
deficient States on October 23, 1984,. The provisions will be promulgated
in 1985 to meet the first part of the settlement agreement. In compliance
with the second part of the agreement, the SIP's for the States will be
reviewed in 1985 to determine their adequacy for meeting the remainder of
the rules.
In November 1984, EPA proposed revised regulations under Section 123
of the Act limiting the extent to which stationary sources; may rely on
stacks in excess of "good engineering practice" ("GEP") or on other disper-
sion techniques in lieu of more stringent emission controls. These regula-
tions, known as the "stack height" regulations, were revis;ed in response to
a court mandate which followed a challenge by parties to regulations
promulgated under Section 123 by EPA in 1982.
In 1984, EPA continued to emphasize the importance of quality transfers
of the prevention of significant deterioration (PSD) and NSR programs since
the EPA believes that the critical growth decisions associated with the
preconstruction review process should be made at the State and local level.
Although several transfers are presently being delayed by litigation and
resulting policy clarification, significant progress was made nevertheless.
As of the end of 1984, 40 State and local agencies had either full delegation
of the PSD program or a PSD SIP, and 8 more had partial responsibility for
the PSD program.
In 1980, EPA promulgated a list of 30 source categories for which
fugitive emissions would be included in PSD applicability determinations.
Surface mining operations were not among these. The EPA was sued on
this point and the court remanded this matter to EPA for explanation of its
position. On October 26, 1984, EPA published final action on this issue,
reaffirming its current requirements for the inclusion of fugitive emissions
in calculating whether a source is "major" for purposes of NSR. The EPA
further proposed to extend the requirements for inclusion of fugitive
emissions to surface coal mining operations. This proposal remained open
for public comment at the end of 1984.
The National Air Audit System (NAAS) was developed in 1983 as a joint
effort by EPA, the State and Territorial Air Pollution Program Administrators
(STAPPA), and the Association of Local Air Pollution Control Officials
(ALAPCO). The primary goals of the NAAS are to identify any obstacles that
are preventing State and local air pollution control agencies from implementing
effective air quality management programs and to provide EPA with quantitative
information for use in defining more effective and meaningful national
programs. The NAAS was implemented initially in 1984 and a total of 68
State and local air pollution control agencies were audite;d by teams composed
primarily of EPA Regional Office personnel. The 1984 air audit program
focused attention upon various aspects of the national air quality management
program that need improvement. In some cases, it showed the need for
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improved guidance from EPA and, in other cases, it indicated areas where
State and local control agencies need to remedy deficiencies. A report
detailing the results of the 1984 air audit program was published by EPA
in December 1984.
In 1984, EPA continued to emphasize the attainment of NAAQS for
those areas of the country which were deficient in this area. Some areas
of the country that are currently nonattainment for carbon monoxide and
ozone were granted extensions of the attainment date until 1987 if they
submitted SIP's containing certain provisions. Forty-seven areas in 31
States that could not demonstrate timely attainment of the NAAQS for
ozone or carbon monoxide were allowed an extension of the attainment date
until December 31, 1987. By September 30, 1984, the date by which all
extension areas SIP's were to be finally approved or disapproved in the
Federal Register, EPA had published final approval in whole or in part
for 35 plans.None of the plans were finally disapproved. As of
December 31, 1984, final action on one of the 12 remaining submittals had
been published and final action on another was pending.
Certain areas of the country which did not receive an attainment date
extension were found by EPA not to have attained applicable air quality
standards by December 31, 1982, as required. In 1984, EPA issued calls for
SIP revisions for a total of 40 areas in 21 States. These calls require
that the States revise their SIP's for these areas within 1 year. Revised
SIP's are required to demonstrate attainment as expeditiously as possible.
The EPA continued to work toward assuring that all areas of the country
have acceptable lead SIP's in place. For the 56 States and territories at
the end of 1984, 45 have submitted complete lead SIP's on which EPA published
final rulemaking; 9 have submitted draft or final SIP's that cover complete
States, but on which EPA has not yet completed rulemaking; and 2 have not
submitted final SIP's that cover complete States.
The EPA undertook a number of activities related to emissions trading
in 1984. By the end of the year, EPA had approved 37 bubbles and proposed
to approve another 11 bubbles resulting in an estimated savings of more
than $200 million over the cost of conventional pollution controls, with
many producing energy savings and greater emission reductions than
traditional regulation. In addition, as of December 31, 1984, EPA had
approved generic trading rules for nine States or local areas which allow
these States to approve bubbles without prior Federal approval. In total,
over 200 bubbles were approved, proposed, under review, or under development
in 29 States throughout the nation through the end of 1984.
Emissions reduction banking allows firms to get credit for surplus
emission reductions and to store such emission reduction credits (ERC's)
in a legally-protected manner. ERC's can be "banked" (stored) and used
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in bubble applications to meet control requirements for existing plants
more flexibly and efficiently. As of December 31, 1984, EPA had approved
formal banking rules for four States and local areas and four Statewide
or local area banking programs had been proposed.
In 1984, EPA initiated an effort to explore the potential issues
that could arise in implementing possible acid deposition control programs.
State and local air pollution control agencies submitted 53 proposals to
conduct a variety of projects to analyze various implementation issues.
EPA eventually selected 31 projects for funding. Work on the projects
will begin in 1985.
In 1984, EPA continued to provide technical training in the abatement
and control of air pollution. This training included short course
presentations of 3 to 5 days in length, self-study courses, technical
assistance to others who conduct training, and the support of the
traineeships and fellowships for graduate air pollution training.
6. CONTROL OF STATIONARY SOURCE EMISSIONS
In the area of stationary source controls, work progressed on the
development of emissions standards for those major source categories not
yet regulated under new source performance standards (NSPS) and on the
revision of various NSPS as appropriate. NSPS for five new categories
were promulgated in 1984 and existing NSPS for four categories were
revised. Eighteen promulgations are planned for 1985. Control techniques
guidance documents for three source categories also were published in
1984.
Section 112 of the Act authorizes EPA to establish national emission
standards for hazardous air pollutants (NESHAP). Regulatory activities
under this section limiting emissions of arsenic, benzene, asbestos,
mercury, vinyl chloride, chromium, and coke oven emissions were under way
in 1984. With regard to benzene, a NESHAP for benzene emissions from
coke oven by-product plants was proposed in 1984 and a NESHAP for benzene
equipment leaks from fugitive sources was promulgated. Proposed regulations
for control of benzene emissions in maleic anhydride plants, ethylbenzene/
styrene plants, and benzene storage facilities were withdrawn. The
withdrawal was based on the fact that public health risks for these
sources were determined not to be significant. Standards proposed under
Section 112 for four sources of radionuclides were withdrawn, with
revised standards for three subsequently being issued.
Also in 1984, EPA continued to make progress in delegating responsibility
for implementing NSPS and NESHAP programs to the State and local air
pollution control agencies. At the end of 1984, approximately 92 percent
of applicable NSPS and 95 percent of applicable NESHAP had been delegated.
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The EPA also continued to maintain the Best Available Control
Technology/ Lowest Achievable Emission Rate (BACT/LAER) Clearinghouse in
1984 in order to assist State and local agencies in their BACT and LAER
determinations.
H. STATIONARY SOURCE COMPLIANCE
The EPA closely monitors the compliance status of about 30,000
stationary sources of air pollution. Approximately 26,500 of these
sources are SIP sources, about 2,500 are NSPS sources, and about 1,000
are NESHAP sources. At the end of 1984, as has been the case since the
late 1970's, the compliance rates were high and generally stable. SIP
sources had a compliance rate of over 92 percent, NESHAP sources were
over 90 percent, and NSPS sources were over 88 percent.
The Act provides a variety of administrative enforcement mechanisms
for dealing with both special situations and relatively easily corrected
violations. During 1984, EPA issued immediate compliance orders under
Section 113(a) of the Act to 84 sources and issued delayed compliance
orders under Section 113(d) to 7 sources. In addition, EPA filed 56
civil actions in 1984 against stationary sources for Act violations and a
total of 85 such actions were pending at the end of the year.
An area of increasing focus by EPA is the regulation of sources of
VOC's. During 1984, EPA completed a major effort to identify all major
VOC sources and began the process of verifying the compliance status of
sources added to the VOC inventory.
On April 6, 1984, the stationary source compliance program issued an
asbestos NESHAP strategy for ensuring compliance at building demolition
and renovation sites. The strategy addresses training, inspection
techniques, enforcement mechanisms, and other aspects essential for a
successful program of compliance. In 1984, EPA initiated civil actions
against 21 companies found in violation of asbestos regulations. At the
end of 1984, three cases were concluded. In addition, on July 11, 1984,
EPA issued a vinyl chloride NESHAP enforcement strategy which facilitates
the development of civil complaints against violators of vinyl chloride
regulations. EPA filed five civil actions during 1984 for violations of
the vinyl chloride regulations.
Several significant enforcement actions were concluded by EPA in
1984. These included an action against Kaiser Steel Corporation for
visible emission standard violations which resulted in a civil penalty of
$825,000 being levied against the company, a settlement with the Jones and
Laugh!in Company that included new schedules for the installation of
controls and demonstrations of compliance, and enforcement of a decree
requiring the City of Providence, Rhode Island, to control particulate
emissions from its sewage treatment plant.
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In 1984, EPA developed a strategy to assure continuous compliance by
stationary sources. The strategy builds upon current use of on-site
inspections as a major compliance monitoring method and outlines a number
of areas, such as unannounced inspections, better targeting of sources,
and improved inspection techniques, in which inspections can be made more
responsive to determining the compliance status of sources. The strategy
also calls for an increased use of continuous emissions monitoring (CEM)
data, supported by a major EPA initiative to enhance CEM usage. To
implement this strategy, EPA has been conducting pilot studies to determine
the most promising techniques to address the problem of assuring continuous
compliance. In 1984, EPA completed the first phase of the Virginia pilot
inspection system. The study, conducted in the Valley of Virginia region
of the State, looked at methods to improve the effectiveness and efficiency
of the inspection progress.
I. CONTROL OF MOBILE SOURCE EMISSIONS
With the achievement of effective reductions of passenger car
emissions, EPA has increasingly turned its regulatory focus toward the
development of parallel standards for heavy-duty trucks and other commercial
vehicles. Accomplishments in this area during 1984 included publishing
proposed regulations for particulate and NOX emissions for heavy-duty
diesel engines. In addition, EPA provided manufacturers with extensive
support to assure that the implementation in model year 1985 of new and
more stringent standards for heavy-duty vehicle exhaust hydrocarbons and
carbon monoxide and evaporative hydrocarbons would be met. In 1984, EPA
also commenced the development of noncompliance penalties for those
engine families unable to meet the standards applicable to a given model
year.
In the category of light-duty vehicles and light-duty trucks, the
primary focus of EPA in 1984 was in the area of the control of diesel
particulate emissions. EPA promulgated a regulation delaying particulate
emission standards for light-duty cars and trucks from 1985 to 1987, in
order to allow time for manufacturers to develop trap oxidizer technologies
for these vehicles.
In August 1984, EPA proposed a rule which would expedite the reduction
of allowable lead in gasoline. This action was prompted by accumulating
evidence of the health and other effects associated with the presence
of lead in the gasoline. Finalization of this rule is expected early
in 1985.
An effective strategy for dealing directly with in-use emissions
problems is the establishment of motor vehicle inspection and maintenance
(I/M) programs. In 1984, EPA continued to promote the implementation of
I/M programs in each locality where it is required by the Act. By the
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end of the year, 43 of 52 areas had Initiated I/M programs. In addition,
in order to assure that operating I/M programs actually achieve the
planned emissions reductions, EPA initiated in 1984 a systematic I/M
auditing plan to pinpoint and lead to correction of any major deficiencies
in individual I/M programs.
Section 207(c) of the Act authorizes EPA to order the recall of
vehicles if a substantial number of any class of vehicles do not conform
to emissions standards. During 1984, 1,206,900 vehicles were recalled
either by direct order of EPA or as a result of an EPA investigation.
In the same period, manufacturers voluntarily recalled 867,770 vehicles
to correct emissions problems.
The EPA has responsibility for enforcing Section 211 of the Act,
relating to the regulation of fuels and fuel additives. One of the
regulations under this section of the Act is aimed at protecting the
catalytic converters on 1975 and later model year cars. EPA has established
a nationwide fuels enforcement program to ensure that affected retail
outlets comply with these regulations. EPA conducted 12,500 inspections
under this program during 1984.
The EPA is also responsible for carrying out programs designed to deter
tampering with vehicle emissions control systems or using leaded fuel in
vehicles which require unleaded. Surveys undertaken by EPA have shown
tampering and fuel switching to be continuing serious problems and that
about 28 percent of the vehicle fleet is subject to gross tampering, and
about 16 percent to fuel switching. In order to combat this problem, EPA
has promoted the implementation of State and local antitampering enforcement
programs. In 1984, nine local antitampering programs were set up as a
result of this initiative.
J. LITIGATION
The most important Clean Air Act case of the year was the Supreme
Court decision in Chevron v. Natural Resources Defense Council. In this
opinion, the court held that EPA could legally allow States to exempt
factories from "modification" review if an emissions increase at one
facility within the factory was offset by emissions decreases at another.
In effect, the opinion allows the entire factory to be treated as a
"source" for new source review purposes. In a second Supreme Court
opinion, Stauffer Chemical Corp. v. EPA, the court let stand a lower
court ruling that EPA could not designate employees of contractors as EPA
"representatives" entitled to conduct inspections under Section 114 of
the Act.
In addition to these two Supreme Court decisions, the Federal Courts
of Appeals handed down 11 decisions involving the Act in 1984.
Of these, two involved the operations of the combined State and Federal
mechanism for establishing "SIP's," two involved the workings of the
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Act's "PSD" system, two involved measures for the control of sulfur
oxides, and one involved the legal doctrine of "standing." Apart from
these decisions, which all involved control of stationary sources of air
pollution, 1984 also saw four decisions under the "mobile source" control
provisions of Title II of the Act. EPA won six of these decisions and
lost four. The remaining decision, though mixed, was basically favorable
to EPA.
In addition, four district court cases decided in 1984 included
Clean Air Act Issues. In one of these decisions, EPA was ordered to
issue final radionuclide standards or delist radionuclides as a hazardous
air pollutant.
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II. AIR QUALITY TRENDS, MONITORING, AND MODELING
This chapter describes current trends in ambient air quality levels
(the concentration of a given pollutant in the atmosphere), as well as trends
in estimated emissions into the air of various pollutants. In addition,
the chapter discusses the topics of air quality monitoring and air quality
modeling. Data on ambient air quality levels and emissions are through
1983, the latest year for which EPA has complete statistics.
A. NATIONAL AIR QUALITY AND EMISSION TRENDS
National long-term (1975 through 1983) improvements can be seen for
sulfur dioxide (S02), carbon monoxide (CO), and lead (Pb). Improvements
can also be seen for nitrogen dioxide (N02) in the period 1979 through 1983
and for total suspended particulate (TSP) between 1978 and 1983. In contrast
to the other pollutants, ozone (03) has increased slightly between 1979 and
1983 and has sharply increased between 1982 and 1983 through a combination of
an increase in volatile organic chemical (VOC) emissions and meteorology
which was generally more conducive to ozone formation in 1983 than in 1981
and 1982.
The trend in 03 is complicated by a major drop in measured concentration
levels which occurred between 1978 and 1979 largely due to a change in the
03 measurement calibration procedure. Therefore, special attention is
given to the 1979 through 1982 period, because the change in the calibration
procedure is not an influence during this period.
The trend in TSP is complicated by the fact that the glass fiber
filters used to collect TSP data were changed in 1978, 1979, and again in
1982. Although the filters used in 1978, 1982 and 1983 were comparable,
the filters used during 1979, 1980 and 1981 were different. Therefore,
special attention is given to the trend from 1978 to 1983, with less credence
given to the intervening years.
All of the ambient air quality trend analyses which follow are based
on monitoring sites which recorded data in at least 7 of the 9 years in
the period 1975 through 1983. In each of these years, annual data completeness
criteria also had to be met. As a result of these criteria, only a subset
of the total number of existing sites are used for trend purposes.
Total Suspended Particulate (TSP) - Annual average TSP levels measured
at 1510 sites decreased 20 percent between 1975 and 1983. This corresponds
to a 33 percent decrease in estimated TSP emissions for the same period.
TSP air quality levels generally do not improve in direct proportion to
estimated emissions reductions, because air quality levels are influenced
by factors such as natural dust, reentrained street dust, construction
activity, etc., which are not included in the emissions estimates. Since
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1977, the glass filters used at TSP monitoring sites have been centrally
procured by EPA for the State and local agencies in order to obtain uni-
formity in TSP collection nationwide at reduced cost. The filters used
in 1979, 1980, and 1981 were found to record higher values; than the filters
used in 1978 and 1982, because of higher filter alkalinity, which is
related to artifact error. The filters used in 1978, 1982!, and 1983 were
supplied by the same manufacturer and found to be comparable based on
similar alkalinity levels. Therefore, although the air quality values
for 1979, 1980, and 1981 are probably biased high, the trend between 1978
and 1983 is due not only to reductions in TSP emissions, but also to more
favorable meteorology in 1983. An analysis of meteorological conditions
for 1983 indicated a potential for lower TSP concentrations due to abnormally
high precipitation.
Sulfur Dioxide (SO?) - Annual average S0£ levels measured at 286 sites
with continuous S02 monitors decreased 36 percent from 1975 to 1983. A
comparable decrease of 43 percent was observed in the trend in the composite
average of the second maximum 24-hour averages. An even greater improve-
ment was observed in the estimated number of exceedances of the 24-hour
standard, which decreased 92 percent. Correspondingly, there was a 19
percent drop in sulfur oxide emissions. The difference between emissions
and air quality trends arises because the use of high sulfur fuels was
shifted from power plants in urban areas, where most of the monitors are,
to power plants in rural areas which have fewer monitors. Further, the
residential and commerical areas, where the monitors are located, have
shown sulfur oxide emission decreases comparable to S02 air quality
improvements. These decreases in sulfur oxide emissions are due to a
combination of energy conservation measures and the use of cleaner fuels
in the residential and commercial areas.
Carbon Monoxide (CO) - Nationally, the second highest non-overlapping
8-hour average CO levels at 174 sites decreased at a rate of approximately
5 percent per year, with an overall reduction of 33 percent between 1975
and 1983, although there was little change between 1982 and 1983. An even
greater improvement was observed in the estimated number of exceedances,
which decreased 87 percent. CO emissions decreased 16 percent during the
same period. Because CO monitors are typically located to identify potential
problems, they are likely to be placed in traffic saturated areas that may
not experience significant increases in vehicle miles of travel. As a
result, the air quality levels at these locations generally improve at a
rate faster than the nationwide reduction in emissions.
Nitrogen Dioxide (Nfe) - Annual average N02 levels, measured at 177
sites, increased from 1975 to 1979 and then began declining. The 1983
ambient N02 levels are 4 percent less than the 1975 levels. While the
trend pattern in the estimated nationwide emissions of nitrogen oxides is
similar to the N02 air quality trend pattern, nitrogen oxides emissions
increased 2 percent between 1975 and 1983. Between 1979 and 1983, both
ambient N02 levels and nitrogen oxide emissions showed reductions of 15 and
8 percent, respectively.
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Ozone (03) - Nationally, the composite average of the second-highest
daily maximum 1-hour 03 values, recorded at 176 sites, decreased 8 percent
between 1975 and 1983. The VOC emissions decreased 12 percent during the
same period. The improvement in ozone levels, however, between 1975 and
1983 is largely due to the change in the calibration procedure, which
took place between 1978 and 1979. In the period following the calibration
change (1979 to 1983), ozone levels increased slightly (2 percent) between
1979 and 1983, and sharply (11 percent) between 1982 and 1983. The
increase between 1982 and 1983 appears to be due to a combination of an
increase of 3 percent in VOC emissions and meteorology which was generally
more conducive to ozone formation in 1983 than in 1981 and 1982. The
increase was observed all across the United States with the exception of
the Northwestern States (EPA Region X). The patterns observed in changing
ozone levels are similarly observed in the estimated number of daily
exceedances of the ozone standard in the ozone season, which increased
6 percent between 1979 and 1983 and 46 percent between 1982 and 1983.
Lead (Pb) - The composite maximum quarterly average of ambient lead
levels, measured at 61 urban sites, decreased 67 percent between 1975 and
1983. This sample of sites satisfied a minimum of 7 years of data in the
1975-83 time period and were heavily weighted by sites in Texas (39 percent)
In all, a total of only 10 States were represented in the sample. In
order to increase the number of sites and their geographical representa-
tiveness, lead trends were studied again over the 1980-83 time period. A
total of 138 urban sites from 28 States satisfied the minimum data require-
ment of at least 3 out of the 4 years of data. An improvement in ambient
lead concentrations of 34 percent was observed at these sites and for the
61 sites mentioned above over this same 1980-83 period. Even this larger
group of sites was disproportionately weighted by sites in Arizona,
California, Minnesota, Pennsylvania, and Texas. These 5 States accounted
for 52 percent of the 138 sites represented. The lead consumed in gasoline
dropped 75 percent from 1975-83, primarily due to the use of unleaded
gasoline, catalyst equipped cars, and the reduced lead content in leaded
gasoline. Likewise, trends in national lead emissions showed a drop of 68
percent.
B. AMBIENT AIR MONITORING
General
Section 110(a)(2)(C) of the Clean Air Act (Act) requires State
Implementation Plans to include provisions for establishment and operation
of systems for monitoring ambient air quality. In addition, Section 319
of the Act requires the development of uniform air quality monitoring
criteria and methods and the establishment of an air quality monitoring
system throughout the United States which uses uniform monitoring criteria
and methods. To satisfy these requirements, EPA promulgated regulations
in 1979 which required States to establish and operate air monitoring
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stations and report the data to EPA*., The two principal types of stations in
the State networks are State and Local Air Monitoring Stations (SLAMS) and
National Air Monitoring Stations (NAMS). The monitoring stations of the
SLAMS and NAMS must adhere to the uniform monitoring criteria described in
the regulation. These criteria cover quality assurance, monitoring methods,
network design, and probe siting. January 1, 1981 was the deadline by which
all NAMS were to meet all of the requirements in the regulations. The SLAMS
had until January 1, 1983 to meet all of the provisions in the regulations.
Overall, State and local progress in meeting the requirements of the
regulations continues to be excellent. Table 1 shows the status of the
SLAMS network at the end of 1984. Of the 4724 operating monitors in the
system, 4693 or 99 percent of the total monitors were meeting all requirements
of the regulations. The remaining operating monitors should meet the
requirements with some small changes in monitor siting and improvements in
their standard operating procedures. Table 2 shows that of the 1360 planned
NAMS, 1347 or 99 percent were in operation and were meeting all requirements
of the regulations through December 1984. Table 3 lists, by pollutant, the
number of SLAMS and NAMS.
Table 1. SLAMS Status through December 1984
Number of Percent of
Monitors Network
Total planned network for 1985* 4567
Monitors operational through 12/84 4724
Monitors in operation meeting all 4693 99
requirements of the regulations
* Includes NAMS monitors and reflects small reductions
planned by a number of control agencies.
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Table 2. NAMS Status through December 1984
Total planned network
Monitors
operational
Monitors In operation meeting all
requirements of the regulations
Table 3. National Summary
Air Monitoring Stations (
Number of
Monitors
1360
1347
1347
of Operating
as of 12/84)
Percent of
Network
100
99
99
Pollutant
TSP
S02
N02
CO
03
Pb
SLAMS
(including NAMS)
2493
564
250
433
598
386
NAMS
640
218
58
113
213
105
TOTAL 4724 1347
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Particulate Monitoring
To accompany the proposed revisions to the National Ambient Air Quality
Standards (NAAQS) for participate matter (PM) discussed In Chapter IV of
this report, EPA on March 20, 1984, also proposed amendments to 40 CFR 58
(Air Quality Surveillance and Reporting Regulations)^. The proposed revisions
to Part 58 would establish ambient air quality monitoring requirements for
PMio as measured by a new reference method proposed as Appendix J of 40 CFR
Part 50 or an equivalent method. In addition, new network design and moni-
toring siting requirements were proposed for the secondary TSP standard.
The proposed requirements are comparable to those already established for
the other pollutants for which NAAQS have been set. These include require-
ments for reporting and assuring the quality of ambient PM^g data, designing
monitoring networks, and the siting of samplers. Since most areas of the
country did not have PMjg ambient monitoring data, EPA procured 662 PM^g
samplers in late 1984 for distribution to State and local agencies.
Specialized training was provided by EPA to State and local agency personnel
on the operation and maintenance of the PM^g samplers. States will begin
collecting ambient PM^g data ">n 1985. These data will be used by the States
in developing PM^g State implementation plans which will be required upon
promulgation of a PM^g NAAQS.
Nonmethane Organic Compounds (NMOC) Monitoring
During the summer of 1984 a new method for measuring the concentration
of hydrocarbons in the ambient air was utilized in a 22 city study. The
data from this study show that the new method yields a much more accurate
measure of ambient hydrocarbon concentrations than previously available
methods. The more accurate data will permit better estimates of the level
of hydrocarbon control required in metropolitan areas to achieve the NAAQS
for ozone. Several agencies have indicated that they want to make additional
measurements in 1985. During 1985, EPA will provide technical support to
these efforts and analyze the data collected during 1984 in greater depth.
C. AIR QUALITY MODELING
An air quality model is a set of mathematical equations that describes
the atmospheric transport, dispersion, and transformation of pollutant
emissions. By means of these equations, a model can be used to calculate
or predict the air quality impacts of emissions from proposed new sources,
emissions from existing sources, or changes in emissions from either of
these source categories. These models are of great utility because they
provide a means whereby the effectiveness of air pollution controls can
be estimated before action is taken.
During 1984, a major EPA program to evaluate several categories of
models was continued. This program was developed in response to recom-
mendations of the American Meteorological Society under its cooperative
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agreement with EPA^. The evaluation of complex terrain models was completed4
in a manner consistent with earlier evaluations of rural point source
models and urban models. The full evaluations of eight short-term,
long-range transport models and four mobile source models was initiated
and will be completed in 1985. The evaluation of models for toxic air
pollutants and industrial source complexes will also be initiated in
1985.
The evaluation of eight complex terrain models for two data bases,
including both S02 and tracer measurements, clarified the limitations of
these models. Generally, the models demonstrated a systematic bias toward
overestimating the maximum concentrations for both data sets. Problems
with model performance extend beyond plume impaction situations to a
variety of meteorological conditions and averaging times. Only one of
the models demonstrated some 'ability to predict with a range of reliability
providing assurance that design concentrations would be neither overly
conservative nor too lenient. However, one of the models frequently used
as a screening technique indicated an accuracy typically acceptable for
screening approximations. A peer scientific review of these models is
also in preparation. Preliminary results indicate that these models are
not up-to-date scientifically, even though one did seem to provide a
superior statistical performance. Also, the need for improved diagnostic
evaluation tools to better understand model performance was indicated.
These results reaffirm the urgent need for a useful refined model that
should result from EPA's complex terrain model development program.
The EPA is also automating a procedure for generating tabulations of
model performance statistics and for producing graphic displays that
contrast performance levels among models. The model evaluation support
system which provides for storage and retrieval of ambient data bases and
predicted concentrations and produces standardized tabular summaries of
model performance was completed in 1984. Documentation and implementation
of several additional data sets will be completed in 1985. The most
effective graphic displays of the performance statistics have been
selected. Utility routines to manage and plot selected pairs of performance
statistics will be completed in 1985. These plots will be useful for
intercomparing the performance of several models simultaneously and for
displaying multiple performance statistics for any one model.
Cooperative agreements have been initiated with the States of New York
and Connecticut to perform photochemical modeling of the New York
metropolitan area, including parts of New Jersey and Connecticut. This
effort, entitled "Oxidant Modeling for the New York Metropolitan Area
Project" (OMNYMAP), will test existing and alternative control strategies
for attaining the ozone NAAQS. As part of this analysis, the performance
of the Airshed Model will be evaluated and its sensitivity to specific
variations in model inputs will be tested. In this way, the most critical
parameters affecting control strategies will be identified. This work is
expected to continue into 1986.
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Preliminary work on a technique to explicity consider the impact of
model uncertainty on regulatory decisionmaking was completed in 1984.5
The method for the Calculation of Uncertainty Estimates (CUE) was applied
to a typical regulatory analysis and its sensitivity to various input
factors was tested. The technique was found to be useful in succinctly
characterizing model performance, estimating the probability of NAAQS
attainment, and estimating the average emission rate allowable for
achieving a desired probability of attainment. The technique is also
useful for dealing with variations in acceptable probability levels and
model bias and precision. In 1985, the applicability of the technique
and its potential for routine use by air quality managers will be further
explored.
Efforts to improve guidance on air quality models^ and to ensure
consistency in their use have also continued. Model clearinghouse
activities were continued to ensure that use of nonguidellne techniques
does not lead to inconsistent regulatory decisions. A workshop was held
with modeling contacts in EPA's ten Regional Offices to improve communications
on the use of models and to resolve problems common to several Regions.
In early 1985, the revised "Guideline on Air Quality Models" will be
subjected to a public hearing and comment. The hearing will be conducted
in conjunction with the Conference on Air Quality Modeling (Third) which
is required at 3-year intervals by Section 320 of the Act., The guideline
will be incorporated by reference in EPA's prevention of significant
deterioration (PSD) regulations, with final promulgation expected in 1986.
Receptor Model Activities
During 1984, EPA continued its series of reports to describe the
uses, capabilities, and limitations of specific receptor models. One
such report was prepared and distributed.? In addition, a computer model
(Chemical Mass Balance Model or CMB) and accompanying documentation were
made available to the user community. Tests were initiated to determine
sensitivity of CMB solutions to various input assumptions,, and a catalog
of chemical composition profiles for various sources of particulate
matter was developed for use with the CMB. During 1985, EPA plans to
subject the source catalog to extensive peer review and to continue with
the CMB sensitivity tests. The end objective is to foster appropriate
and consistent application of this model by State and local agencies.
EPA also will continue with its series of reports describing specific
receptor models.
Ozone Modeling
During 1984, EPA produced a guideline document describing how to use
the Empirical Kinetics Modeling Approach (EKMA) with newer chemical
mechanisms which reflect recent experimental data.°»9 The EKMA is widely
used by State and local agencies to estimate emission controls necessary
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2o attain the ambient air quality standard for ozone. In addition, the
computer software for EKMA was updated and improved. This software and
its accompanying documentation has been widely distributed. Continuing
efforts are under way to improve the EKMA model and to assist State and
local agencies in its application.
D. INTEGRATION OF AIR DATA SYSTEMS
The Aerometric Information Reporting System (AIRS) is a new integrated
data system being developed by EPA to replace entirely the existing data
bases, files, and software now used by the EPA for storing and retrieving
ambient air quality data, stationary source and emissions data, and source
compliance data. The AIRS project was fully approved by senior EPA
management in December 1980 after the earlier comprehensive feasibility
study revealed the advantages of a truly integrated data system. Detailed
performance specifications were completed in 1981-82 which defined the
overall structure of AIRS. The AIRS will be composed of two relatively
separate components (air quality and facility data) but will use common
sets of geographical and other codes and draw upon a state of the art
data base management system.
In 1984, work progressed on the air quality component of AIRS. This
segment is expected to be fully available for use by the States by late
1986 with pilot installations at the State level in 1987.
E. EMISSION FACTOR DEVELOPMENT
In 1984, EPA published emission factors for use by States and others
to estimate source emissions and compile emissions inventories. Emission
factor information is published and distributed for criteria pollutants
in a publication entitled "Compilation of Air Pollutant Emission Factors."
Current emphasis is on developing size-specific emission factors with
special emphasis on particles less than 10 microns.
EPA also distributed guidance in 1984 on procedures for estimating
emissions for selected, potentially toxic pollutants. Final reports were
distributed for acrylonitrile, carbon tetrachloride, chloroform, ethylene
dichloride, formaldehyde, nickel, and chromium. Reports are now in
preparation for manganese, phosgene, vinylidene chloride, epichlorohydrin,
chlorobenzenes, PCB's, and ethylene oxides. Issuance of these additional
documents is scheduled for 1985, pending the completion of peer review
for each document.
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F. NATIONAL DIOXIN STUDY
In 1984, EPA initiated the National Dioxin Study to assess the
potential extent of. contamination of the environment with chlorinated
dioxin compounds. One portion of the study is assessing the potential
air contamination from various combustion sources. A literature review
has been completed and a program plan developed for undertaking this
effort. A program to collect stack samples from about 10-12 combustion
sources and ash samples from 40 to 50 such sources has been initiated.
The project is scheduled for completion in December 1985.
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III. AIR POLLUTION RESEARCH PROGRAMS
A. INTRODUCTION
The EPA's Office of Research and Development (ORD) supports EPA's
mission of protecting human health and the environment by both responding
to its short-term regulatory needs for scientific information and
technical assistance and by anticipating future information needs and
initiating research to satisfy those needs.
Air pollution research programs in 1984 were planned by ORD in
conjunction with senior managers from the appropriate program offices,
and two senior regional office representatives through the Air and Radiation
and Multi-media Energy Research Committees. The committees provide a
mechanism for ORD to communicate research information and resource changes
to the program offices and Regions, as well as a mechanism for the program
offices to communicate to ORD any proposed or contemplated regulatory
changes that may affect the research program.
In an effort to develop more cohesive and responsive long-range
research programs, the EPA Assistant Administrators for Research and
Development and Air and Radiation identified priority research issues.
These issues cut across scientific disciplines (e.g., monitoring, health,
engineering, environmental processes), and the pollutant-specific structure
of the research programs. The following discussion of EPA's major research
accomplishments in 1984 are organized by these issues.
B. GENERAL AIR POLLUTION RESEARCH ACTIVITIES
The ORD air pollution research program provides EPA with the scientific
data bases, methodologies, assessments, models, emission reduction technolo-
gies and corresponding quality assurance support to develop and implement
air quality standards and to ensure compliance with them. The research
program focuses on the six air pollutants for which national ambient air
quality standards (NAAQS) have been established under Section 109 of the
Act (ozone, carbon monoxide, particulate matter, sulfur dioxide, nitrogen
dioxide and lead), and on potentially hazardous air pollutants which are
defined as pollutants which may cause irreversible or reversible incapaci-
tating illness and have not already been regulated under Section 109.
Summarized below are the major air pollution research activities in these
areas undertaken by EPA in 1984.
Risk Assessment Documents Needed to Support Regulatory Activities
The EPA completed the second external review draft of the criteria
document for lead* and the first external review draft of the criteria
document for ozone and other photochemical oxidants2 in 1984. In addition,
the addendum to the 1979 criteria document for carbon monoxide (CO) was
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also published.3 Final health assessment documents were completed for
carbon tetrachloride.4 coke oven emissions,5 chromium,6 Inorganic arsenic,7
manganese,8 mercury,', and methyl chloroform.10 External review draft
documents also were completed for six additional chemicals.11*12,13,14,15,16
Information on the Uncertainties Associated With Adverse Health
Effects of Air Pollutants
Three articles were published on research responding to critical
data gaps in the dose-reponse data base for sulfur dioxide (S02) and
ozone (63). One article described the pulmonary responses of exercising
asthmatics exposed to SC^ in controlled laboratory conditions. The other
two articles discussed in-vitro and in-yivo animal tests which were
conducted to measure changes in immune function, metabolism, and other
biological parameters following acute exposures to Sfy and °3*
The early phases of studies assessing the effects of low level CO
on patients with angina were completed to support the review of the CO
NAAQS. Reports have been written and prepared for publication.
Studies designed to determine whether diesel emissions are carcinogenic,
and, if they are, how potent they are, were completed to support activities
related to in regulating mobile source emissions. A report on the use of
tier bioassays in evalutating unregulated motor vehicle emissions was
completed.19
Several in-yivo and in-vitro studies identifying the metabolites and
routes of metabolism and activation of 1-nitropyrene were completed.
This chemical, which has been identified as as a mutagen and carcinogen,
is a common combustion product. The results of these studies will be
used for developing strategies to control combustion product emissions.
Neurotoxicity studies of toluene were completed.20,21 Based upon the
results of these studies and other data already gathered on toluene, EPA
decided not to list toluene as a hazardous air pollutant. An article on
the reproductive effects of exposure to manganese on the male rat was
prepared to support listing decisions.22
Models Needed to Extrapolate From Animal to Human Risks, From High
to Low Doses, and From Acute to Chronic Effects
In 1984, EPA initiated a multi-phase program to develop quantitative
models to extrapolate from acute human studies and acute and chronic
animal studies to long-term human health effects of air pollutants. A
report describing the sensitivity of several animal species, including
humans, to 03 inhalation was produced.
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Research on the Contribution of Air Pollution to the Incidence of
Cancer in the United State?
Plans for a long-term, interdisciplinary integrated air cancer project
were developed by EPA during 1984. The purpose of the project is to
provide an improved capability for performing cancer risk assessments on
airborne pollutants. The goals of the program are to identify the principal
airborne carcinogens, determine which emission sources are major contribu-
tors of carcinogens to the ambient air, and improve the estimate of
comparative human cancer risk from specific air pollution emission sources.
Information on the Welfare Effects of Pollutants
Based upon data gathered through the National Crop Loss Assessment
Network (NCLAN), an economic assessment on the effects of 03 on agri-
culture was produced.24 Reports of the economic methodology used to
assess 03 damage were also produced in 1984."
A comprehensive multi-year research plan was developed in 1984 to
assess the problem of visibility degradation. In addition to developing
this plan, a number of studies on the optical properties of ambient air
aerosols and plume visibility were completed.
Information on the Atmospheric Chemistry and Physics of Air Pollutants
To improve urban scale ambient air quality models, a protocol for
developing a reactivity classification system for volatile organic compounds
(VOC's) was in preparation in 1984. When complete, this protocol will
enable EPA to determine the extent that specific VOC's contribute to the
formation of 03. This information is needed to determine whether certain
VOC emissions need to be controlled to achieve 03 standards.
Field and laboratory studies were conducted to determine the lifetimes,
spatial and temporal distributions, and transformation products of selected
hazardous air pollutants. The roles of wet and dry deposition in removing
such pollutants from the atmosphere were determined.
An improved second generation regional 03 model was completed. This
model will be used to predict the air quality impact of long-range 03
transport to urban areas located downwind. Analysis of the results of
the Cross Appalachian Tracer Experiment was completed. This was a multi-
agency effort to quantify long-range gas and particulate transport processes.
An assessment document was prepared on the status of complex terrain
dispersion models. These models enable EPA to better predict the impact
of sources on ambient air quality in areas with complex terrain. Also,
fluid modeling studies were completed for a variety of complex terrain
effects.
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Several user's guides were developed to assist Regional, State, and
local air pollution officials in applying specific air quality models.
In 1984, user's guides were completed for the Pollution Eoisodic Model, 26
a Single Source Gaussian Puff Dispersion Model (INPUFF),2/ and a Photochemical
Box Model28 and Mesopuff-II.29
Mobile Source Emission Characterizations Needed to Evaluate the
"Effectiveness of Control Strategies
Research characterizing gaseous and particulate mobile source emissions
from heavy-duty diesel and gasoline-powered trucks and buses was completed.
The data will be used by EPA to assess the impacts of mobile source
emissions on ambient air quality. Real-time measurement procedures were
refined to more accurately analyze methanol and formaldehyde emissions
from vehicles fueled by pure methanol and methanol-gasoline blends.
Monitoring Systems and Methods Needed to Support Regulatory Activities
Research to develop methods for monitoring various pollutants focused
on PM^Q in accordance with the proposed change in the particulate matter
air quality standard from total suspended particulates to PMig. Standard
operating procedures for sampling ambient particulate matter were developed,
and a detailed PMio inlet comparison study was conducted.
A study of methods available for source sampling of hazardous air
pollutants was conducted to determine where losses and transformations
occur. Stationary source emission test methods were developed and validated.
Source emission continuous monitors were evaluated under field conditions
and the data compared to compliance methods. Data on the ultraviolet
and infrared spectra, the distribution of organics between the gaseous
and solid phases, and the speciation of compounds was produced to develop
methods for measuring hazardous air pollutants in the ambient air.
Human exposure data collected during the winter of 1982-83 as part
of the Denver and Washington, D.C., CO studies was analyzed. Statistical
analyses of the exposure and activity patterns in these cities were
conducted and papers prepared summarizing these data. 30,31, 32 /\s part of
the indoor air research program, an air quality research strategy was
developed.
Quality Assurance Support
To ensure that EPA decisions are backed by technical data that
are of known accuracy and precision, ORD provided quality assurance (QA)
support in accordance with EPA policy and QA requirements contained in
EPA regulations. Quality assurance support for the State and Local
Ambient Air Monitoring Stations (SLAMS) and National Source and Ambient
Monitoring Programs (NAMS) was provided. The repository for reference
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samples was maintained, and standard reference materials were prepared
and distributed. Two standard ultraviolet spectrophotometers were obtained
from the National Bureau of Standards and deployed to the EPA Regions to
measure 03 levels. Monitoring activities associated with the National
Atmospheric Background Network, which was designed to provide data on 03
concentrations in remote areas of the country, were completed and the
sites restored.
Stationary Source Emission Characterizations and Technology Evaluations
Research to control particles focused on improving the performance,
reliability and cost-effectiveness of electrostatic precipitators (ESP's)
and fabric filters in collecting small particles. The technical limits
of applying large diameter electrodes in new or existing ESP's were
determined. These studies indicated that particulate emissions can be •
reduced by as much as a factor of four in some retrofit applications.33
The ESP's which combine the features of large diameter electrodes and two
stage ESP's into one multi-stage unit appear to be especially economical
for power plants using low sulfur coal. A two dimensional computer model
was developed to assess the electrical nature of ESP designs. The ESP
vendors hope to utilize this model to improve their designs while the EPA
will use the model as a diagnostic aid for compliance and permitting
activities. Preliminary research on a multi-stage ESP designed to control
both S02 and particulates produced results of 40-90 percent S02 removal
while still meeting applicable particulate standards.34
The performance of fabric filtration continues to be improved with
the application of electrostatically enhanced fabric filtration (ESFF).
In 1984, a test of commercial-sized fabric filter bags was conducted at a
pilot baghouse. This test demonstrated that ESFF is operable at one-half
the energy loss of the conventional bags in service.35 Additional research
indicates that one-fourth the energy loss expected in a spray dryer/baghouse
combination can be achieved with ESFF.36 The application of this technology
could reduce capital costs by 50 percent and result in lower maintenance
costs for baghouse filters which are extensively used for cleaning gases.
Wind tunnel experiments were conducted in 1984 and were used to
develop a mathematical model to determine the optimal windbreak porosity,
size and location of fugitive emissions. This model will be used to control
fugitive emissions from storage piles.
In conjunction with The Electric Power Research Institute (EPRI), the
Fifth Symposium for the Transfer and Utilization of Particulate Control
Technology was conducted to extend particulate control technology to
designers, users, and educators.
III-5
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Research to control S02 emissions resulted in a full-scale field
evaluation of a lime spray dryer method. Short-term test results showed
that the new source performance standards (NSPS) for S02 and particulate
matter can be met at costs lower than when conventional wet scrubbing
systems are used.37 A full-scale evaluation of a flue gas desulfurization
(FGD) method was conducted using a dibasic acid to enhance the performance
of limestone scrubbing FGD systems. The results of this test indicated
that compliance S02 removal could be obtained consistently with reduced
operational maintenance problems at an estimated annual cost savings of
$600,000 per year.38
The Ninth FGD Technology Symposium was conducted in conjunction with
the EPRI to provide the utility industry, vendors and regulatory officials
with up-to-date guidance on technologies for SOg control and acid deposi-
tion mitigation options.
Research to control NOX emissions focused on low NOX burners, in-furnace
NOX reduction, air staging/recirculation and catalytic reduction. In
1984, a low NOX burner was successfully evaluated on an oil field steamer
with 75 percent reduction of NOX emissions. Also, two demonstrations
utilizing second generation (recirculation) low NOX burners were successfully
completed. One demonstration was on a 400-megawatt (MW) tangentially-fired
utility boiler, and the other was on a 200-MW wall-fired, industrial size
utility boiler. In both cases NOX emissions of 0.4 lb/105 Btu were
achieved.40
Pilot- and commercial-scale destruction efficiency tests of VOC's were
conducted using industrial flares. The results of the VOC flare tests
were used by EPA to revise a number of industry-specific NSPS. The
results were also instrumental in achieving a settlement with the Chemical
Manufacturers Association in their petition on industrial flare performance.
Research to control hazardous air pollutants focused on identifying
the major sources and evaluating applicable control technologies. In
1984, source assessments for copper and butadiene emissions were made.
Also, a comprehensive literature review of control technologies for
hazardous air pollutants was conducted, and a method for ranking industrial
sources of hazardous air pollutants by process parameters was developed
for the Office of Air and Radiation.
C. ACID DEPOSITION RESEARCH ACTIVITIES
Research on acid deposition is coordinated through the National Acid
Precipitation Assessment Program (NAPAP), which is administered by the
Interagency Task Force on Acid Precipitation. The EPA is one of three joint
chairs of the Interagency Task Force, and has the lead role in the aquatic
effects, control technology and assessment research areas. The term
"acid rain" means the atmospheric deposition of acidic or acid-forming
111-6
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compounds in either dry or wet form. These compounds exist in the atmos-
phere as gases or aerosol particles containing SOX, NOX, hydrogen chloride,
sulfuric acid, nitric acid and certain sulfate and nitrate compounds. While
scientists generally agree that these compounds are responsible for
deposition of varying degrees of acidity, many questions still remain
about the causes, effects, and methods of mitigating or controlling acid
deposition. The objective of the acid deposition research program is to
develop the necessary data to fully understand the sources and characteristics
of acid deposition, as well as the extent of damage or potential damage.
As part of its effort to provide current acid deposition research informa-
tion to EPA policymakers and the general public, EPA published in 1984
"The Acidic Deposition Phenomenon and Its Effects—Critical Assessment
Review Papers."41
Little data exist on dry deposition due to the difficulty in developing
and deploying accurate monitoring instrumentation. Monitoring is made
difficult by the fact that dry deposition rates vary with surface cover
and topography, as well as with environmental variables such as wind
speed and humidity. In 1984, field tests of the prototype dry deposition
monitor were initiated by EPA.
Research Into the Effects of Acid Deposition on Aquatic Resources
As part of the first phase of the National Surface Water Survey (NSWS),
research was conducted to quantify the chemistry of lakes and streams in
areas now believed to contain the majority of low-alkalinity waters. In
1984, the Eastern Lakes field survey was completed. This will enable EPA
to determine what percentage of lakes and streams in the susceptible
regions are acidic or have low alkalinity. Following this determination,
regionally representative surface waters will be selected to quantify
future changes in aquatic resources through a long-term monitoring program.
One of the most important questions in the aquatic effects research
program is the extent of direct response and delayed response systems in
the United States. If direct response systems prevail in sensitive areas
of the country, then no additional changes in surface water chemistry are
expected given that there are no changes in present acidic loading rates.
However, if delayed response systems predominate, then more waters may
become acidic due to acidic deposition even if current loading rates do
not change. In 1984, a research plan to investigate the direct/delayed
response phenomenon was developed. The results from this research will
influence decisions concerning the immediacy of possible controls on
sulfur emissions.
Acid Deposition Effects on Watersheds, Soils, and Forests
Many processes within watersheds affect the rate and extent of
acidification of surface waters. Watershed bedrock geology, system
III-7
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hydrology and biological processes are all important determinants of the
response of surface waters to acidic inputs from the atmosphere. In
1984, research in this area focused on assessing the geochemical and
physical characteristics of soils.
D. ENERGY-RELATED RESEARCH ACTIVITIES
In 1984, research continued to focus on the development of the
limestone injection into the multistage burner (LIMB) emission reduction
technology that is designed to simultaneously reduce both SOX and NOX.
During 1984, ORD developed high surface area sorbents and sorbents treated
with "promoters" such as sodium carbonate to improve the sulfur capture
ability of the LIMB technology. Beyond the possible acid rain retrofit
applications, these developments may make the LIMB technology suitable for
use as a low cost control alternative for meeting new source performance
standards for boilers operating with low-sulfur coal. Laboratory tests
to define the optimum conditions for the injection of the sorbent were
initiated. In 1984, a contract was awarded to the Babcock and Wilcox
Company to conduct a full-scale demonstration of LIMB on a wall-fired
utility boiler. This demonstration will be co-funded with the Electric
Power Research Institute.
III-8
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IV. DEVELOPMENT OF NATIONAL AMBIENT AIR QUALITY STANDARDS
The 1977 Clean Air Act Amendments require EPA to review regularly
and revise, if necessary, all of the national ambient air quality standards
(NAAQS). Reviews of all existing NAAQS were in progress during 1984.
During 1984, work continued on finalizing EPA's proposal of August 19,
1980, to revise the NAAQS for carbon monoxide (CO).* As a result of
questions raised concerning the adequacy of several of the key studies
used in developing the 1980 proposal, the EPA issued an addendum^ to the
CO criteria document and a staff paper^ reassessing how the scientific
data reviewed in the addendum might be used in selecting final CO standards.
Final action on the CO standards is scheduled in 1985.
On February 23, 1984, EPA proposed to retain the existing primary
and secondary NAAQS for nitrogen dioxide (N02) of 100 micrograms per
cubic meter (ug/nH), annual average. The EPA also proposed not to set
a short-term N0£ standard, since data were not adequate to establish such a
standard and the current annual standard protects against peaks of concern.
Final action on this proposal is expected in early 1985.
On March 20, 1984, EPA proposed changes to the NAAQS for particulate
matter (PM)5 that would make major changes to the national control program
for airborne particles. For the primary standard, EPA proposed to replace
the current total suspended particulate matter (TSP) standard with a standard
that includes only those particles less than 10 micrometers (PMio). The
proposal indicated that the EPA intended to select final primary standards
from ranges of 50-65 ug/m3, annual arithmetic mean, and 150-250 ug/m^,
maximum 24-hour concentration. The EPA proposed to retain a secondary
TSP standard from the range of 70-90 ug/m^, annual average and to revoke
the current 24-hour secondary standard. All standards would be expressed
in statistical terms (expected exceedances). As a result of a number of
requests from the public and delays in publishing guidance for development
of implementation plans, the comment period on the proposed standards was
held open through the end of 1984. Consequently, final promulgation is
not expected until 1986.
Concurrence by the Clean Air Scientific Advisory Committee (CASAC)
on the scientific accuracy and completeness of the staff paper6 for
sulfur oxides (SOX) was received in 1983. Work on the exposure analysis
and the cost, economic and benefits analyses were nearly completed by the
end of 1984. A proposal to revise or reaffirm the standards is scheduled
in 1985.
Work on the revisions to the criteria documents for ozone and lead
continued in 1984 with the release of the first external review draft
for ozone and the second external review draft for lead. The CASAC review
IV-1
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of these documents and the staff papers for ozone and lead are scheduled
in 1985. Work also continued in 1984 on the development of the regulatory
impact analyses and the development and application of risk assessment
methodologies for these standard reviews.
IV-2
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V. REGULATORY ASSESSMENT OF TOXIC AIR POLLUTANTS
The status of the toxic air pollutant evaluation and control program
as of the end of 1984 is reflected in Table V-l. In 1984, decisions were
published not to regulate toluene1 and polycyclic organic matter (POM)2
under the Clean Air Act. For toluene, this decision was based on a judg-
ment that currently available information did not indicate a threat to
public health at concentrations found in the ambient air. For POM, there
was considerable uncertainty as to the magnitude of the cancer risk to the
public, as well as difficulties in devising an appropriate regulatory
program for several important POM source categories such as wood stoves,
forest fires, and agricultural burning. Also in 1984, coke oven emissions
were listed as a hazardous air pollutant under Section 112 of the Clean
Air Act.3 Assessments containing information on the emission sources,
public exposure, health effects, current controls, and possible control
improvements were completed for most of the substances shown in the
"Regulatory Options Analysis" column of Table V-l. Decisions on whether
to regulate these compounds are expected to be published in 1985.
As part of the EPA's effort to develop a more comprehensive and
effective air toxics control program, a draft report on the nature and
scope of the national air toxics problem was completed and issued for
public comment.4 The study indicates that while maximum individual
risks tend to be associated with major point sources, the great majority
of the predicted cancer incidence associated with air pollution is not
mitigated by point source controls. The study suggests that area-wide
risk can be high in urban areas as a result of exposure to multiple
pollutants emitted from many diverse sources. Small area sources may
contribute as much as 75 percent of predicted cancer incidences. This
study and follow-on analyses will be used to shape future policy directions
in the air toxics area, including discussions on possible Clean Air Act
amendments.
As part of the program for regulating benzene (listed as a hazardous
air pollutant under Section 112), EPA has been assessing the need to regu-
late sources in the gasoline marketing chain. This assessment was further
spurred by data indicating that unleaded gasoline causes cancer in laboratory
animals and should be considered a probable human carcinogen. An analysis
of regulatory strategies for the gasoline marketing industry was published
for public comment in August 1984.5 The options considered were: (1) no
additional control, (2) control of vehicle refueling (Stage II) in ozone
non-attainment areas, (3) control of gasoline marketing emissions nation-
wide via (a) Stage II controls, (b) onboard vehicle controls, and (c) con-
trols on bulk terminals and plants (Stage I). A decision on the appropriate
regulatory option is expected in 1985.
V-l
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Also in 1984, substantial activities were undertaken to establish a
National Air Toxics Information Clearinghouse in an effort to improve
communication between EPA and State and local agencies, and among State
and local agencies. The Clearinghouse is funded by EPA and is a cooperative
effort between EPA and the State and Territorial Air Pollution Program
Administrators and Association of Local Air Pollution Control Officials.
The goal of the Clearinghouse is to disseminate knowledge about activities
underway to solve toxic air pollutant problems and to reduce duplication
of effort. Some of the kinds of information included in the Clearinghouse
are: (1) regulatory program activities, including acceptable ambient limits;
(2) source information, such as pollutants emitted and required control
technology; and (3) source test and ambient monitoring methods in use.
Automation of the data base and publication of the first report compiling
all the information contained in the Clearinghouse are scheduled for
completion in the late spring of 1985. Because State and local agencies
indicated an immediate need for information exchange to begin, EPA began
publishing the Air Toxics Information Clearinghouse Newsletter in December
1983, and published five issues in 1984. Other publications in 1984 were
a bibliography of EPA reports relevant to toxic air pollutants,6 a bibli-
ography of health and risk assessment information,-7 a listing of EPA's ongoing
research and regulatory development projects^ and an interim report summarizing
data submitted by State and local agencies.9
V-2
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I
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VI. STATUS OF AIR QUALITY MANAGEMENT PROGRAMS
A. DEVELOPMENT OF POLICY AND REGULATIONS
Implementation Policy and Guidance for Revised Particulate Matter
Standards'
As discussed in Chapter IV of this report, EPA proposed revised
national ambient air quality standards (NAAQS) for particulate matter on
March 20, 1984. The proposed standards consist of two primary standards
(an annual and a 24-hour standard) that would apply to a size range of
particles nominally 10 micrometers and smaller in diameter (PMig), and an
annual total suspended particulate (TSP) secondary standard. The focus
of the proposed primary standards on a new particle size range has
necessitated preparation of regulations, policy, and technical guidance
so that State implementation plans (SIP's) for PM^g can be developed by
the States.
In 1984, EPA prepared a Federal Register notice which solicited
public comment on (1.) regulatory amendments which would accommodate the
focus of the primary standards on the PMig size range and which would
establish the requirements for new source review programs, (2) a policy
for SIP development for primary and secondary standards and the EPA's
interpretation of the Clean Air Act which results in that policy, and (3)
technical guidance specific to dealing with the PM^Q S1ze range. The
proposed regulatory amendments would focus the health-protecting air
pollution episode programs on PMig rather than TSP and would lay out the
requirements for a dual new source review system, e.g., new sources would
be reviewed for both PM^g and TSP emissions. The SIP development policy
would establish time frames for SIP development and standards attainment
for the primary and secondary standards. The PMig technical guidance
addresses development of emission inventories, dispersion and receptor
modeling, ambient monitoring and data reporting, using ambient TSP data
where PM^g data are n°t available, and monitoring for prevention of
significant deterioration purposes.
The package has undergone review within the EPA and by representatives
of State and local air pollution control agencies. Federal Register
publication was scheduled for early in 1985.
Visibility Protection
Section 169A of the Clean Air Act establishes as a national goal
"the prevention of any future, and the remedying of any existing, impairment
of visibility in mandatory Class I Federal areas which impairment results
from manmade air pollution." On December 2, 1980, EPA promulgated
VI-1
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regulations implementing this section.1 All States which contained
mandatory Class I Federal areas were to develop and submit SIP revisions
to EPA which implemented these regulations.
On December 20, 1982, a number of petitioners filed suit in the
United States District Court for the Northern District of California
seeking to compel EPA to promulgate State plans for visibility protection
under Section 110(c) of the Clean Air Act for those States which had not
submitted such plans. During 1983, EPA and the Environmental Defense
Fund negotiated and signed a settlement agreement which was accepted by
the court on April 20, 1984. The settlement agreement calls for a two-
part implementation of the 1980 rules. New source review requirements
and a visibility monitoring strategy were proposed for the deficient
States on October 23, 1984.2 These provisions will be promulgated in
1985 to meet the first part of the settlement agreement.
In compliance with the second part of the agreement, the SIP's for
the States will be reviewed in 1985 to determine their adequacy for
meeting the remainder of the rules. Federal plans to implement the
deficient portions are scheduled to be proposed in 1986 and promulgated
in 1987.
A Visibility Task Force was formed in 1983 to develop recommendations
on a long-range strategy for dealing with visibility impairment from
pollution-derived regional haze. The group is charged with defining
goals, research needs, and regulatory options and serves to integrate
regional haze issues in mandatory Class I Federal areas with more general
visibility protection considerations under the NAAQS and with related
aspects of other air pollution control programs that affect visibility.
The task force will involve several EPA offices, other Federal agencies,
concerned States, environmental organizations, and industry. In December
1984, the task force held two public meetings in order to obtain comments
from the private sector on regional haze issues. The major task force
output will be a report, currently scheduled for early 1985, containing
its findings and recommendations and a summary of supporting material and
analyses. The group will also issue interim research and analytical
recommendations.
Tall Stacks and Other Dispersion Techniques
On February 8, 1982, EPA promulgated regulations required by Section
123 of the Clean Air Act.3 These regulations, known as the "stack height"
regulations, limit the extent to which stationary sources may rely on
stacks in excess of "good engineering practice" (GEP) or on other dispersion
techniques in lieu of more stringent emission controls. The regulations
were challenged by the Sierra Club Legal Defense Fund, Inc.; the Natural
Resources Defense Council, Inc.; and the Commonwealth of Pennsylvania in
Sierra Club v. EPA, 719 F.2d 436 (D.C. Cir. 1983). As a result of this
VI-2
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challenge, the U.S. Court of Appeals for the District of Columbia Circuit
ordered EPA to reconsider part of its regulations. The court provided
EPA with detailed instructions to follow in subsequently revising its
regulations.
A petition for writ of certiorari filed by a group of affected
industries was rejected by the U.S. Supreme Court on July 2, 1984, and on
July 18, the Appeals Court issued its mandate requiring EPA to revise the
stack height regulations not later than January 18, 1985. Proposed
revisions to the regulations were published in the Federal Register on
November 9, 1984.4 A 30-day period for public comment was provided
initially but, in response to numerous requests, EPA obtained an extension
of the court-ordered promulgation deadline, enabling it to extend the
public comment period and to hold a public hearing on the proposed
regulation in Washington, D.C., on January 8, 1985.
Restructuring SIP Preparation Regulations
On October 11, 1983, EPA published in the Federal Register proposed
changes to the SIP preparation regulations of 40 CFR 51.5 The proposal
would delete obsolete provisions and rewrite the regulations in a new,
shorter, and better-organized format. States using the revised regulations
to prepare SIP's would find them current and easier to follow than the
present regulations. The new format also has a flexible structure into
which future requirements can be more easily incorporated. The EPA
received many comments during 1984 on the proposal indicating widespread
interest in the project. Final promulgation of this rulemaking is now
scheduled for 1985.
Federal Enforcement of Visible Emissions
The EPA intends to propose and promulgate a new, modified visible
emission test method for evaluating compliance with certain types of SIP
opacity standards where the State has not specified a test method in the
SIP. The existing method for Federal enforcement of SIP opacity limits
in such cases is Test Method Number 9 of 40 CFR 60. This proposal, which
EPA started to develop during 1984 and will complete during 1985, will
provide EPA with an expanded array of specific visible emissions testing
procedures for various types of SIP opacity emission limitations. This
will allow EPA to better enforce SIP provisions since the new regulations
will provide the necessary flexibility in responding to the many and
varied SIP regulations. The new procedures will appear in a new
Appendix F in Part 52 of the Code of Federal Regulations.
VI-3
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Guidance to Promote Consistency in the Application of National
Policies
During 1984, EPA continued to provide information to assist State
and local agencies in the development of SIP's and other air programs by
distributing updates of the "Air Programs Policy and Guidance Notebook" and
the "Air Programs Reports and Guidelines Index." The notebook includes a
collection of current memoranda and documents concerning national policy
and guidance. The index represents a compilation of bibliographic
information on current technical and guideline documents prepared by EPA
over the past several years. The udpates were distributed to about 350
State and local agencies in addition to Regional and Headquarters personnel,
all of whom are holders of the notebook and index.
B. PREVENTION OF SIGNIFICANT DETERIORATION AND NONATTAINMENT NEW
SOURCE REVIEW ACTIVITIES
The EPA made significant progress in 1984 in carrying out its
responsibilities under the Clean Air Act regarding the preconstruction
review of new and modified stationary sources. Major 1984 activities are
described below.
PSD Program Transfer
The EPA continues to emphasize the importance of quality transfers
of the prevention of significant deterioration (PSD) and new source
review (NSR) programs. In addition to the strong legal and resource
reasons for implementation by State and local authorities rather than
EPA, the EPA believes that the critical growth decisions associated with
the preconstruction review process should be made at the State and local
level. The permitting process, once transferred, forms the key for
minimizing source-specific SIP revisions in the future. In 1984, EPA
continued its progress in transferring implementation of the PSD program
to State and local agencies. The majority of PSD permits are now issued
by these agencies. Although several transfers are presently being held
up by litigation and resulting policy clarification, significant progress
was made nevertheless. As of the end of 1984, 40 State and local agencies
had either full delegation of the PSiD program or a PSD SIP, and 8 more
had partial responsibility for the PSD program.
Modifications to Permits
In response to several requests, EPA is researching the possibilities
for developing a national policy for reviewing proposed PSD permit modifi-
cations and extensions. Such a policy appears to be increasingly important
as many of the source owners with valid PSD permits wish to change
conditions within their permits on the eve of their construction or
operation. A permit modification policy would provide a new opportunity
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for applicants, owners, and operators who propose changes to obtain
revisions of existing permits or applications rather than having to apply
for totally new permits. Currently, EPA believes that it is possible to
develop a policy which does not allow circumvention of the present process
and yet provides an easier means of making changes.
Chemical Manufacturers Association v. EPA
As previously reported, the EPA's PSD and nonattainment new source
review regulations have been challenged by a variety of entities. These
challenges were consolidated as Chemical Manufacturers Association v. EPA
(CMA), D.C. Cir. No. 79-1112. On February 22, 1982, EPA entered into a
litigation settlement with the industry petitioners in which it agreed to
propose certain regulatory changes. An important part of the settlement
agreement was satisfied by EPA's Federal Register proposal of August 25,
1983.6 That proposal addressed the topics of fugitive emissions in new
source review applicability determinations, Federal enforceability of
various emissions reductions, "buffer zones" around Class I areas, review
of secondary emissions, and offset credit for past source shutdowns.
An important matter of controversy h.as been the definition of "source"
for the purposes of nonattainment new source review. The Clean Air Act
is not clear in this area. In 1980, EPA promulgated a dual source
definition that minimized the opportunity for modifications to sources to
avoid review in nonattainment areas. This was challenged by industry in
the CMA suit, but was not of primary concern in the settlement because EPA
had replaced it with a "plantwide" definition in its rulemaking of
October 14, 1981. The Natural Resources Defense Council claimed that
the plantwide definition is inconsistent with the Act and, on August 17,
1982, the D.C. Circuit Court of Appeals ruled in their favor. Both EPA
and industry representatives appealed this ruling, and on June 25, 1984,
the Supreme Court decided in favor of EPA and the industry litigants.
The EPA is presently developing a policy which will aid the Regions in
processing proposed SIP's converting to a plantwide definition. Resolution
of the definition of source should significantly accelerate the transfer
of the nonattainment program to State and local agencies.
In its August 7, 1980, promulgation, EPA listed 30 source categories
for which fugitive emissions would be included in PSD applicability
determinations. Surface mining operations were not among these. The
Sierra Club sued EPA on this point and on August 26, 1983, the D.C.
Circuit Court of Appeals remanded this matter to the EPA for explanation
of its position. On October 26, 1984, EPA published final action on this
issue, reaffirming its current requirements for the inclusion of fugitive
emissions in calculating whether a source is "major" for purposes of NSR.
EPA further proposed to extend the requirements for inclusion of fugitive
emissions to surface coal mining operations. This proposal remained open
for public comment at the end of 1984. According to the rulemaking
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criteria established by EPA, the proposed listing of surface coal mines
is only a presumption which can be overcome if the rulemaking record
reveals that the costs associated with listing are unreasonable relative
to the corresponding benefits.
The remaining issues in the August 25, 1983, proposal are addressed
in a draft Federal Register notice which will be published in 1985.
C. IMPLEMENTATION OVERVIEW AND ASSISTANCE
National Air Audit System
The National Air Audit System (NAAS) was developed in 1983 as a
joint effort by EPA, the State and Territorial Air Pollution Program
Administrators (STAPPA), and the Association of Local Air Pollution Control
Officials (ALAPCO). The need for the NAAS resulted from the fact that
State and local air pollution control agencies have assumed responsibility
for an increasing number of programs under the Clean Air Act over the
years. The primary goals of the NAAS are to identify any obstacles that
are preventing State and local air pollution control agencies from
implementating effective air quality management programs and to provide
EPA with quantitative information for use in defining more effective and
meaningful national programs. The NAAS was implemented initially in 1984
and a total of 68 State and local air pollution control agencies were
audited by teams composed primarily of EPA Regional Office personnel.
The four program areas selected for the 1984 audit were Air Quality and
SIP Activity, New Source Review, Compliance Assurance, and Air Monitoring.
The 1984 air audit program focused attention upon various aspects of
the national air quality management program that need improvement. In
some cases, it showed the need for improved guidance from EPA and, in
other cases, it indicated areas where State and local control agencies
need to remedy deficiencies. A report detailing the results of the 1984
air audit program was published by EPA in December 1984.7
Adjustments to the audit program in 1985 will be made in order to
make it even more useful. These adjustments include redesigning the
audit questionnaires to make the questions clearer and more uniform,
streamlining the questionnaires by removing unnecessary material, and by
developing more specific guidelines for the FY 1985 audit program.
In order to assure that solutions were developed for the problems
that were identified in the 1984 audit, EPA planned a symposium to be
held early in 1985 that would develop specific recommendations for future
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improvements to the air program. This symposium would be attended by
selected EPA, State, and local air pollution control officials who would
be given the responsibility to critically examine the audit results and
then develop workable and realistic recommendations for improvement.
Post 1982 Attainment of Air Quality Standards
1. Extension Areas
Part D of the Clean Air Act requires that primary NAAQS for particulate
matter, sulfur dioxide, nitrogen dioxide, carbon monoxide, and ozone be
attained no later than December 31, 1982. State implementation plan
revisions providing for attainment of these standards were to have been
submitted to EPA by January 1, 1979. Extensions of the attainment date
to 1987 were authorized under prescribed conditions for the carbon monoxide
and ozone air quality standards. One condition was the submission to EPA
of an additional SIP revision by July 1, 1982, which demonstrated attainment
of these standards not later than December 31, 1987. Forty-seven areas
in 31 States that could not demonstrate timely attainment of the NAAQS
for ozone or carbon monoxide were allowed an extension on the attainment
date until December 31, 1987.
By September 30, 1984, the date by which all extension areas SIP's
were to be finally approved or disapproved in the Federal Register, EPA
had published final approval in whole or in part for 35 plans. None of
the plans were finally disapproved. As of December 31, 1984, final
action on 1 of the 12 remaining submittals had been published and final
action on another was pending. Final action on the other 10 plans is
expected in 1985.
2. Nonextension Areas
The Clean Air Act gives EPA the authority to require States to revise
their SIP's if they are found to be substantially inadequate to achieve
the NAAQS. In February 1984, EPA issued calls for SIP revisions for 27
areas in 15 States that had not received an attainment date extension.
Calls for revisions to SIP's for particulate matter were deferred because
of the pending proposed revision to the particulate matter air quality
standard.
During the summer of 1984, air quality data through 1983 (and into
1984, if available) were reviewed to determine if additional areas needed
to revise their SIP's. Based on this analysis, EPA determined that the
SIP's for nine additional areas were substantially inadequate to provide
for attainment and maintenance of certain primary (health-related) NAAQS,
and notified those States by letter of this determination. Additional
SIP calls were made separately for four more areas in 1984. Two States
notified EPA by letters from their Governors that they will make SIP
revisions. All areas receiving calls for SIP revisions had 1 year to
submit a SIP revision to EPA.
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Status of Nonattalnment Areas
The following table lists those areas of the country that were not in
attainment with air quality standards as of the end of 1984. Note that
totals are not shown since the same area may be nonattainment for more
than one pollutant.
Number of
Pollutant Nonattainment Areas*
Particulate matter (primary standard) 161
Particulate matter (secondary standard) 156
Sulfur oxides (primary standard) 56
Sulfur oxides (secondary standard) 13
Nitrogen oxides 4
Carbon monoxide 142**
Ozone 390***
*Areas listed in this table are either counties or portions of
counties. The extension and nonextension areas discussed in
the previous section are urbanized areas.
**96 areas received an extension until December 31, 1987.
***152 areas received an extension until December 31, 1987.
Lead SIP's
In October 1978, EPA published an NAAQS for airborne lead under
Section 109 of the Clean Air Act.8 Section 110 of the Act required each
State to adopt and submit to EPA within 9 months (i.e., by July 1979) a
plan to implement that standard. The Act further required EPA to approve
or disapprove these SIP's within 4 additional months (by November 1979)
and to promulgate SIP's within 2 additional months beyond that (by January
1980) for States that did not meet the requirements specified in the Act.
In 1982, the Natural Resources Defense Council (NRDC) and other
parties filed suit in the U.S. District Court for the District of Columbia
to require EPA to promulgate lead SIP's for those States that had been
submitted but on which EPA had not taken final rulemaking. The Lead
Industries Association and St. Joe Minerals Corporation intervened in
the suit on behalf of EPA.
The EPA and NRDC negotiated a Settlement Agreement which was entered
by the court on July 26, 1983. The Agreement allowed States additional
time to prepare and submit lead SIP's before EPA was required to prepare
a Federal plan. The Settlement Agreement established different schedules
for different categories of States. For States that had already submitted
SIP's before EPA reached agreement with NRDC, the Settlement Agreement
required EPA to publish final approval or proposed disapproval by November
1983; with the exception of one extension approved by the court, EPA
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achieved this objective. For States with either major sources of lead or
recent violations of the lead standard but which had not yet submitted
lead SIP's, the Agreement set a trigger date of August 1, 1983, for
submission of SIP's. The Agreement required EPA to publish final rulemaking
on these SIP's by August 1984. The EPA met this commitment except for
six States, where additional work is needed; EPA is negotiating with NRDC for
extensions for these areas. The EPA also had to publish final rulemaking
by January 1, 1985, for those States and territories that did not have
an existing lead air quality problem but which still needed a SIP to
assure that future problems did not occur. The EPA met this commitment
except for five territories. In addition, EPA has proposed Federal
implementation plans for lead for two areas around primary lead smelters
that have incomplete or disapproved plans—El Paso, Texas, and Kellogg,
Idaho. The EPA must take final rulemaking on those proposals in 1985.
It appears that there are no known areas that will have continuing
lead air quality problems due solely to mobile source lead emissions.
All of the known air quality problems regarding lead appear to be caused
by stationary sources, such as primary and secondary lead smelters and
gasoline lead additive plants. For the 56 States and territories at the
end of 1984, 45 have submitted complete SIP's on which EPA published
final rulemaking; 9 have submitted draft or final SIP's that cover complete
States, but on which EPA has not yet completed rulemaking; and 2 have not
submitted final SIP's that cover complete States.
Emissions Trading
Emissions trading includes several alternatives to traditional
regulation. These alternatives do not alter existing air quality require-
ments but simply gives States and industry more flexibility to meet these
requirements. Bubble trades and emissions reduction banking are two of
the major emissions trading concepts being promoted by EPA.
1. Bubble Trades
Bubble trades allow existing plants (or groups of plants) to treat
all of their emission points as though they were under a giant bubble and
reduce or eliminate pollution controls where costs are high, in exchange
for compensating increased control at emission sources where control costs
are low. They give firms increased compliance flexibility, meet current
or future pollution control requirements more quickly, make innovative
control approaches profitable, and can result in significant savings over
the costs of conventional controls. In 1982, EPA issued a proposed
emissions trading policy to replace the original bubble policy and to
streamline procedures, giving States and industry more opportunities to
use bubbles in many more circumstances and geographic areas. Since that
time, EPA has reviewed numerous formal comments on the policy and developed
alternatives to respond to specific issues raised by the commenters. In
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1983, EPA proposed alternatives for shutdowns for public review and
additional comment. EPA plans to issue the policy in final form after
considering all of the comments that were submitted on the proposals. As
of December 31, 1984, EPA approved 37 bubbles and proposed to approve
another 11 bubbles resulting in an estimated savings of more than $200
million over the cost of conventional pollution controls, with many
producing energy savings and greater emission reductions than traditional
regulation.
Bubbles can be approved by the States without case-by-case EPA review
if evaluated under EPA-approved State procedures known as generic trading
rules that assure no bubble will interfere with timely attainment and
maintenance of the NAAQS. State generic rules are approved by EPA only
if their procedures are replicable in operation to meet this test. As of
December 31, 1984, EPA approved generic trading rules for nine States or
local areas which allow these States to approve bubbles without prior
Federal approval. Twenty-five bubbles have been approved by States under
generic trading rules. At least 130 bubbles are under development or
review either as SIP revisions or under generic rules. In total, over
200 bubbles were approved, proposed, under review, or under development
in 29 States throughout the nation through the end of 1984. The total
estimated savings from these bubbles exceeds $700 million. Generic rules
have been approved by EPA for nine States or local areas and proposed for
one more. At least 11 additional States or local areas are developing
such rules.-
2. Emissions Reduction Banking
Emissions reduction banking allows firms to get credit for surplus
emission reductions and to store such emission reduction credits (ERC's)
in a legally-protected manner. ERC's can be "banked" (stored) and used in
bubble applications to meet control requirements for existing plants more
flexibly and efficiently, as offsets to support economic growth in areas
not meeting air quality standards, or in "netting" to exempt certain
expansions or modernizations from new source review. Banking rules can
speed trades between firms, expand opportunities for bubbles, and encourage
the production of cheap ERC's at optimal times. Banking systems also
provide the certainty needed for firms to invest in ERC's when meeting
other control requirements, creating a pool of readily available credits
that make trading easier, and speeds permit issuance while assuring progress
toward clean air.
As of December 31, 1984, formal banking rules have been approved for
four States and local areas and four Statewide or local areas banking
programs have been proposed. Nine additional areas have adopted at the
State or local level banking programs, some of which are under EPA review.
Banking rules are known to be under development or consideration in seven
more areas.
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Acid Deposition Implementation Issues
In 1984, EPA initiated an effort to explore with the States the
potential issues that could arise in implementing any possible acid
deposition control program. Accomplishing this effort was planned in
three phases: identifying key implementation issues and major options for
dealing with them; evaluating various options using both "in-the-field"
and "in-house" approaches; and preparing preliminary or prototype guidance
on the issues.
An EPA committee with Headquarters and Regional Office representatives
produced an initial list and description of over 200 implementation
issues. Early coordination on the development of these issues was
established with State and local air regulatory agencies (through a
STAPPA/ALAPCO task force) as well as with certain industrial and
environmental groups.
Using the initial listing and description of issues as a basis, EPA
and the STAPPA/ALAPCO task force determined those issues that might be
most amenable to the "in-the-field" studies by State and local agencies.
These studies would be eligible for funding through a $3 million Congressional
appropriation for the development of "the technical and institutional
foundations for future acid deposition control strategies."
In application for this funding, State and local agencies submitted
53 proposals to conduct a variety of projects (called State Acid Rain—
STAR—projects) to analyze some of the implementation issues and options.
An evaluation procedure was developed by EPA to score and rank the
proposals and, based on the resulting ranking and with the concurrence of
STAPPA/ALAPCO, 31 STAR projects were initially selected for funding.
Work on the projects will begin in early 1985 and will be completed on a
12- to 18-month time frame.
Meanwhile, EPA began to identify other important issues and options
that should be investigated with "in-the-field" or "in-house" studies but
were not being examined in the STAR projects. EPA also began to determine
what types of projects would be appropriate for examining these other
issues and options.
VOC RACT Clearinghouse
The EPA has specified that the SIP revisions for areas designated as
not attaining photochemical oxidant standards should contain, as a minimum,
regulations for controlling volatile organic compound (VOC) emissions
from stationary sources. These regulations must provide for the
implementation of reasonably available control technology (RACT). To
assist the States in defining RACT, EPA prepared a series of documents,
referred to as control techniques guidelines (CTG's), which address
various control options for a variety of individual stationary sources.
Since EPA cannot publish CTG's for all affected VOC source categories,
States may have to develop regulations using information sources other
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than CTG's. The purpose of the VOC RACT clearinghouse is to provide a
means by which State and local air pollution control agencies can exchange
technical information, minimize duplication of effort and resources, and
provide guidance regarding VOC controls for various sources. The VOC
RACT clearinghouse is a cooperative effort with STAPPA, AL.APCO, and EPA.
The VOC RACT clearinghouse output takes several forms, including a
VOC RACT clearinghouse newsletter, which is targeted for publication on a
quarterly basis. During 1984, four newsletters were issued. Other
outputs during 1984 were a directory of air pollution control agency
VOC contact persons, a summary of State and local agency VOC regulatory
developments, and a bibliography of pertinent VOC technical reports.
D. AIR POLLUTION TRAINING
In 1984, EPA continued to provide technical training in the abatement
and control of air pollution. This training included short course
presentations (3 to five days in length), self-study courses, technical
assistance to others who conduct training, and the support of the
traineeships and fellowships for graduate air pollution training.
During 1984, EPA conducted 29 short courses in 16 different subject
areas for a total of 658 students. These courses were presented in
locations across the United States by seven universities designated as
area training centers. Technical assistance was provided to States and
EPA Regional Offices for the conduct of 10 additional courses reaching a
total of 190 students.
In support of the delegation of more air quality management
responsibilities to the States, EPA continued emphasis on self-study
courses as a means of providing training to more air pollution personnel.
During 1984, 984 students applied for the 23 self-study courses presently
available.
As an additional means of developing qualified personnel, EPA
supported 15 graduate traineeships/fellowships to employees of State and
local air pollution control agencies.. These awards are for both part-
time and full-time graduate study in the field of air pollution control.
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VII. CONTROL OF STATIONARY SOURCE EMISSIONS
A. NEW SOURCE PERFORMANCE STANDARDS (NSPS)
During 1984, NSPS were promulgated under Section 111 of the Clean
Air Act (Act) for five new categories: metallic mineral processing plants,1
synthetic fiber production facilities,2 petroleum refinery equipment leaks,3
flexible vinyl and urethane coating printing operation,^ and petroleum dry
cleaning.5 The existing NSPS for lime manufacturing plants,6 glass manu-
facturing plants,7 steel plants (electric arc furnaces),8 and secondary brass
and bronze ingot production plants^ were revised. Standards were proposed
for five new categories: industrial boilers (NOX, PM), , volatile organic
liquid storage vessels,H wool fiberglass insulation manufacturing,!2 and
onshore natural gas processing (2 NSPSH3 Revisions were proposed for three
source categories: kraft pulp mil Is,^ metal furniture surface coating,!5
and auto coating giants, [Section lll(j) waivers],16 The reviews of NSPS for
copper smelters,^7 grain elevators,!8 and nitric acid plants^ were completed.
Three control techniques guideline documents were published for volatile
organic compound equipment leaks from natural gas/gasoline processing
plants, volatile organic compound fugitive emissions from synthetic organic
chemical manufacturing, and polymers and resins manufacturing equipment.
Standards development programs now underway are planned to result in the
promulgation of 18 standards, the proposal of 12 standards, and completion
of reviews for 4 existing NSPS during 1985..
B. NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)
0 Arsenic - Work on the proposed NESHAP under Section 112 of the Act
covering glass manufacturing, high arsenic primary copper smelters, and low
arsenic primary copper smelters is continuing with a promulgation planned
in 1985.
0 Benzene - A NESHAP for benzene emissions from coke oven by-product
plants was proposed in 1984.20 /\ NESHAP for benzene equipment leaks from
fugitive sources was promulgated in 1984.21 The proposed regulations for
control of benzene emissions in maleic anhydride plants, ethyl benzene/styrene
plants, and benzene storage facilities were withdrawn in 1984.22 The
withdrawal was based on the fact that public health risks for these
sources were determined not to be significant.
0 Asbestos - A rule was published in 1984 to repromulgate the asbestos
work practice standards and reorganize the standard for clarity.23 The
enforceability of the work practice standards has been under question
because work practice standards were not explicitly authorized under the
Act until several years after publication of the asbestos NESHAP. Work
continues on the review of the demolition and renovation provisions of the
regulation. Any revisions that are necessary will be proposed in 1986.
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0 Mercury - The review of this standard was completed and a proposed
revision to the NESHAP was published in 1984.24 yne proposed revision
addressed recordkeeping and monitoring requirements for mercury-cell
chlor-alkali plants.
0 Vinyl chloride - Revisions to the vinyl chloride NESHAP are under
development and will be proposed in 1985. The revision will redefine
and clarify the relief value discharge part of the regulation.
0 Chromium - A project was started in 1984 to develop a NESHAP for
chromiunuThe NESHAP will limit chromium emissions from source categories
that are determined to pose significant risks. The source categories
identified as candidates for regulation include electroplating, cooling
towers, utility boilers, industrial boilers, chromium chemical manufacturing,
steel production, refactory manufacturing, sewage sludge incinerators,
municipal incinerators, cement manufacturing, chromite ore refining, and
ferrochromium production.
0 Coke oven emissions - Standards development work continued in 1984
for coke oven emissions sources in the iron and steel industry. A proposed
NESHAP for coke oven emissions is planned for 1985.
0 Radionuclides - Standards proposed under Section 112 for the
following source categories were withdrawn: (1) elemental phosphorus
plants; (2) Department of Energy. (DOE) facilities; (3) facilities licensed
by the Nuclear Regulatory Commission and non-DOE Federal facilities; and
(4) underground uranium mines. For the first three source categories,
the Administrator determined that current practice adequately protects
the public health. In the case of underground uranium mines, the standard
was withdrawn because the EPA concluded that the standard did not meet
the legal requirements of Section 112. At the same time, advance notices
of proposed rulemaking were published concerning radon-222 emissions from
underground uranium mines and from licensed uranium mills. Standards
were subsequently issued for the first three categories as a result of a
court order, and work was begun on a standard for uranium mines.
C. DELEGATION OF NSPS AND NESHAP
The EPA continued to make progress in 1984 in delegating responsibility
for implementing the NSPS and NESHAP programs to the State and local air
pollution control agencies. The number of applicable NSPS and NESHAP
vary for each State or local agency depending on the types of source
categories that either exist or are likely to be built in the future. At
the end of 1984, 34 State and local agencies had accepted delegation of
all applicable NSPS and 47 had accepted delegation of all applicable
NESHAP. These numbers represent delegation of approximately 92 percent
of applicable NSPS and 95 percent of applicable NESHAP nationwide.
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D. BACT/LAER CLEARINGHOUSE
New or modified facilities that are to be constructed in areas of the
country that are currently attaining the national ambient air quality
standards are required by the Act to install best available control
technology (BACT). In those areas of the country that have not yet
achieved compliance with the air quality standards, new or modified
facilities are required to meet the lowest achievable emission rate (LAER)
for that particular type of source. Both BACT and LAER requirements are
determined on a case-by-case basis. Often an air pollution control
agency will need to establish BACT or LAER requirements for a source type
that is completely new to them or for which they have had only minimal
experience. In these cases, the permitting agency may not be knowledgable
of the more recent advances in control technology for such sources and it
is extremely helpful if the agency can refer to BACT or LAER determinations
made by other control agencies.
The EPA established the BACT/LAER Clearinghouse several years ago in
order to assist State and local air pollution control agencies by promoting
the sharing of air pollution control technology information. The primary
output of the Clearinghouse is an annual report of information about
BACT/LAER determinations made by the various control agencies. The most
recent report contains over 950 BACT/LAER determinations.25 An updated
compilation containing approximately 1050 determinations is scheduled to
be distributed in 1985. The report is available in hard copy and through
an automated system. The automated data base can be accessed by both the
public and the private sectors.
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VIII. STATIONARY SOURCE COMPLIANCE
A. GENERAL
The goal of the Clean Air Act is to protect public health and welfare
and enhance the quality of the nation's air. The stationary source
compliance program is designed to assure compliance with air emission
standards by stationary sources of air pollution, including such major
facilities as power plants, steel mills, smelters, and refineries.
In addition to ensuring compliance with emission limitations contained in
State implementation plans (SIP's), EPA and delegated States are responsible
for ensuring that sources comply with new source performance standards
(NSPS) and national emission standards for hazardous air pollutants
(NESHAP).
The EPA closely monitors the compliance status of about 30,000 stationary
sources of air pollution. Approximately 26,500 of these sources are SIP
sources, about 2,500 are NSPS sources, and about 1000 are NESHAP sources.
At the end of 1984, as has been the case since the late 1970's, the
compliance rates were high and generally stable. The compliance status
for the Federally-tracked stationary sources is the following:
In In Violation;
Compliance- Meeting Schedule
In Violation;
No Schedule Unknown
SIP (Class A)*
NSPS
NESHAP
92.2%
88.5%
90.9%
1.6%
1.5%
0.8%
3.8%
5.3%
4.5%
2.4%
4.7%
3.8%
The responsibility for the compliance monitoring of stationary
sources lies principally with the States. In order to obtain information
for purposes of determining compliance status or preparing a possible
enforcement action or for other reasons, the States (and EPA) have the
authority to enter and to inspect stationary sources. In 1984, the
States conducted inspections of 21,465 Class A SIP, NSPS, and NESHAP
sources.
The EPA overviews States' compliance monitoring activities and supplements
the States' enforcement efforts to resolve violations of air quality
regulations. In 1984, EPA conducted inspections, for purposes of overviewing
or case development, of 1,684 Class A SIP, NSPS, and NESHAP sources.
*A Class A SIP source is a stationary source with potential uncontrolled
emissions, while operating at design capacity, equal to or greater than
100 tons per year of any regulated air pollutant.
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The Clean Air Act provides a variety of administrative enforcement
mechanisms for dealing with both special situations and relatively easily
corrected violations. During 1984, EPA issued immediate compliance
orders under Section 113(a) of the Act to 84 sources and issued delayed
compliance orders under Section 113(d) to seven sources.
Section 120 of the Clean Air Act is an administrative remedy designed
to recoup the economic benefit which may come from violating air pollution
control regulations. Congress established the program in 1977, EPA promulgated
regulations implementing Section 120 in 1980, and the D.C., Circuit Court
of Appeals generally sustained the regulations in January,, 1983. Prior
to fiscal year (FY) 1984 (the period starting October 1, 1983, and
ending September 30, 1984), implementation of the program was in its
developmental stage and during this period EPA initiated only twenty
Section 120 proceedings. Twenty-two Section 120 cases were initiated in
FY 1984, more cases than in the three previous years combined.
The EPA is also authorized to file a civil complaint In federal district
court to order a source to comply with applicable regulations, to pay
civil penalties, or both. There were 56 civil actions filed in 1984
against stationary sources for violations of the Clean Air Act. As of
January 1985, there was a total of 85 such actions pending with the U.S.
District Courts. These judicial actions addressed a broad spectrum of
violations including violations of SIP's, violations of federally-promulgated
standards, and contempt actions for violations of judicial decrees.
One criminal indictment was entered in 1984 against a source for
violations of visible emission limitations. In addition, four cases were
referred to the Department of Justice for criminal prosecution.
A major focus of the stationary source compliance program is the
effort to return to compliance those sources meeting the definition of a
significant violator. The universe of sources covered by this program
includes sources that are in violation of NESHAP and NSPS regulations
and major SIP sources in violation of a SIP requirement located in a
nonattainment area for the pollutant for which the source is in violation.
For FY 1984, EPA identified 326 significant violators pending at the
beginning of FY 1984 and by the end of the fiscal year 126 were returned to
compliance, 51 were placed on an acceptable compliance schedule, and 92
had an enforcement action pending. Uith an expanded definition of a
significant violator which now includes all Class A SIP sources in or
impacting a nonattainment area for the pollutant for which the source is
in violation, EPA has identified 513 such sources pending at the beginning
of FY 1985. The States and Regional Offices have committed to resolve
390 of these significant violators by the end of the fiscal year.
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An area of increasing focus by EPA, reflected in the large growth in
the number of significant violators, is the regulation of sources of
volatile organic compounds (VOC's). Such sources are major contributors
to the ozone nonattainment problem and some emit compounds which are
highly toxic in nature. In response to requirements contained in the
1977 Clean Air Act Amendments, many States adopted regulations requiring
compliance of VOC sources on or before the end of 1982. Therefore, the
effort to assure the initial compliance of VOC sources is relatively new.
As with any new program, some basic problems need to be addressed, including
the lack of an adequate VOC stationary source inventory, limited experience
in determining compliance with complex VOC regulations, and inexperience
with control of some VOC source categories. During 1984, EPA completed a
major effort to identify all Class A VOC sources and began the process of
verifying the compliance status of sources added to the VOC inventory.
Building expertise in the VOC area is also an ongoing effort.
In 1984, the asbestos NESHAP was repromulgated, which allowed the
stationary source compliance program to begin a major initiative to
ensure demolition and renovation sites are in compliance with these
regulations. The demolition and renovation of old buildings, often in
highly populated urban areas, is a major source of asbestos exposure.
Because of the large number of demolition sites, a strong State and EPA
effort is necessary to the success of the program. On April 6, 1984,
the stationary source compliance program issued an asbestos NESHAP strategy
for ensuring compliance at demolition and renovation sites. The strategy
addresses training, inspection techniques, enforcement mechanisms, and
other aspects essential for a successful program of compliance. In 1984,
since repromulgation, EPA initiated civil actions against 21 companies
found in violation of asbestos regulations. At the end of 1984, three
cases were concluded. Delegated States also conducted a high level of
asbestos enforcement action during 1984.
On July 11, 1984, EPA issued a vinyl chloride NESHAP enforcement
strategy which facilitates the development of civil complaints against
violators of vinyl chloride regulations. EPA filed five civil actions
during 1984 for violations of the vinyl chloride standards. At present,
twelve enforcement actions for violation of these standards are pending
in court.
B. LITIGATION
The following cases are examples of several significant enforcement
actions which were concluded in 1984.
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United States v. Kaiser Steel Corporation (C.D. Cal. Jan. 26, 1984)
A civil action was filed against the Kaiser Steel Corporation in May
1982 for visible emission standard violations at its blast furnace casthouses
located at Fontana, California. At the conclusion of a lengthy trial,
Judge Irving Hill found the violations to be "extremely serious," and
imposed a civil penalty of $825,000. Judge Hill further concluded that
"economic and technologic infeasibility" were not defenses to liability
for Clean Air Act violations and that each blast furnace was a separate
source of emissions each subject to a maximum penalty of $25,000 per day
of violation.
United-States v. Jones & Laugh!in Steel Inc. and The LTV Corporation
Contempt actions were filed on January 6 and 7, 1983, against Jones
and Laughlin in Indiana, Pennsylvania, and Ohio U.S. District Courts
alleging violations of three 1981 consent decrees. The violations of the
consent decrees took place at the Aliquippa, Pittsburgh, East Chicago,
Campbell, and Cleveland plants. A comprehensive settlement was reached
in 1984 that included new schedules for the installation of controls and
demonstrations of compliance. The settlement also assessed against Jones
and Laughlin a penalty of $4 million and established a requirement to
undertake projects which will yield environmental results beyond what are
currently required by Federal and State law. Two of the decrees reflecting
this settlement were entered in the Indiana and Pennsylvania courts in
1984. The third decree was not entered by the Ohio court. The government
filed an appeal with the Sixth Circuit challenging the Ohio court's refusal
to enter the settlement.
City of Providence, Rhode Island (D.R.I. June 8, 1984)
In this case, EPA sought enforcement of a 1977 consent decree in the
District Court for Rhode Island. The decree required Providence to
control particulate emissions from its sewage treatment plant. The
United States negotiated a substantial civil penalty ($180,000) despite
the court's initial statement that the defendant should be required to
pay no more than $5,000. The United States' brief persuaded the court
that it did not have authority to reduce the stipulated penalties in the
original decree.
C. CONTINUOUS COMPLIANCE
In the past, the focus of the stationary source compliance program
was to ensure that major sources of particulates and sulfur dioxide
achieved initial compliance with Clean Air Act regulations, generally by
either installing required control equipment or by switching to cleaner
fuels. The more recent focus of attention, which will continue in the
future, is addressing the continuous compliance problems of particulate
and sulfur dioxide sources (while continuing to work to ensure the initial
compliance of VOC sources.)
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In 1984, EPA developed a strategy to assure continuous compliance by
stationary sources. The strategy builds upon current use of on-site
inspections as a major compliance monitoring method. It outlines a
number of areas, such as unannounced inspections, better targeting of
sources, and improved inspection techniques, in which inspections can be
made more responsive to determining the compliance status of sources and
assuring compliance on a basis more representative of day-to-day source
operation. The strategy also calls for an increased use of continuous
emissions monitoring (CEM) data, supported by a major EPA initiative to
enhance CEM usage.
To implement this strategy, EPA has been conducting pilot studies to
determine the most promising techniques to address the problem of assuring
continuous compliance. In 1984, EPA completed the first phase of the
Virginia pilot inspection system. The study, conducted in the Valley of
Virginia region of the State, looked at methods to improve the effectiveness
and efficiency of the inspection process. In 1985, EPA is expanding the
Virginia pilot to cover the entire State to determine if benefits comparable
to that achieved by the more limited pilot can be obtained. Also, EPA
continued a continuous emission monitoring pilot in Region VII that
provided methods and procedures for upgrading the national CEM program.
The results of these pilots will allow EPA to issue needed technical
guidance to the Regional Offices and the States. On October 5, 1984, EPA
issued technical guidance on the review and use of excess emission
reports submitted by sources with CEM systems.1 •
Also, EPA provided revised inspection frequency guidance to the
States that provided them greater flexibility to target inspection resources
to address their most significant air quality problems. A joint EPA,
State, and local agency effort was initiated in 1984 to investigate the
possibility of making further improvements to EPA's inspection frequency
guidance. EPA also issued guidance on the use of unannounced inspections
by EPA as a component of an overall inspection program.
0. TIMELY AND APPROPRIATE ENFORCEMENT RESPONSE
A major 1984 initiative was the development of guidance on what
constitutes a "timely and appropriate" EPA/State enforcement response for
significant air violators. This guidance, developed jointly with the
States, is a first step toward clarifying the roles and expectations of
the respective parties to the EPA/State partnership in the enforcement of
air quality regulations for stationary sources. The guidance also provides
timeliness for action, addresses EPA issuance of notices of violation, and
discusses when penalties must be obtained.
E. CIVIL PENALTY POLICY
On September 12, 1984, the Office of Enforcement and Compliance
Monitoring and the Office of Air and Radiation jointly issued a new Clean
Air Act Stationary Source Civil Penalty Policy. This program-specific
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policy supersedes the general Civil Penalty Policy issued July 8, 1980,
and applies to civil cases referred to the Department of Justice after
October 12, 1984. In addition to procedures for assessing penalties
based on the recapture of economic benefit, the policy contains procedures
for assessing a component of the civil penalty that represents the severity
of the violation. For the first time, the factors that are considered in
assessing severity have been identified and dollar amounts assigned
according to the size of each factor. The policy also describes procedures
for mitigation of the severity, or "gravity," component if circumstances
so dictate.
The general policy applies to most Clean Air Act stationary source
violations. Some types of violations, however, do not fit the general
policy framework. Therefore, the Policy contains four appendices with
separate penalty assessment procedures for types of cases where penalties
can not be calculated under the general policy. The appendices cover
permit violations, asbestos demolition, vinyl chloride emission violations,
and volatile organic compound emission violations where the source intends
to comply by using low solvent technology.
F. COMPLIANCE BY FEDERAL FACILITIES
During 1984, Federal facilities demonstrated a good record of compliance
with applicable air pollution regulations. As of the end of 1984, 307
(94 percent) of the 327 major Federal'facilities met applicable emissions -
limitations. Of the 20 remaining facilities, 11 are meeting compliance
schedules that will bring them into compliance, 6 are in violation and
not yet on an acceptable schedule, and 3 are of unknown compliance
status.
6. LIST OF VIOLATING FACILITIES
The list of violating facilities, under Section 306 of the Clean Air
Act, is designed to prevent the Federal government from subsidizing
certain Clean Air Act violators with contract, grant, or loan monies. No
violators were listed under Section 306 of the Act in 1984.
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IX. CONTROL OF MOBILE SOURCE EMISSIONS
A. INTRODUCTION
Control of motor vehicle emissions has been a Federal responsibility
since 1968. The requirements of the Clean Air Act (CAA) relating to
mobile sources have been subsequently refined several times, most recently
in 1977. The Clean Air Act Amendments of 1977 established an ambitious
regulatory program which addressed remaining problems in the motor vehicle
emissions control program and bolstered efforts to attain and maintain
the national ambient air quality standards for carbon monoxide (CO) and
ozone (03). Below are listed some of the the mobile source provisions
of the 1977 Act.
- A schedule was established for implementation of
stringent emissions standards for automobiles—0.41 grams
per mile (gpm) for hydrocarbons (HC), 3.4 gpm for CO, and
1.0 gpm for oxides of nitrogen (NOX). The table below
displays the level of control mandated by the standards.
New Light-Duty Vehicle Emissions
Without 1977 CAA Percent
Control Standard Reduction
Hydrocarbons 8.8 gpm .41 gpm 95%
Carbon Monoxide 87.0 gpm 3.40 gpm 96%
Oxides of Nitrogen 3.6 gpm 1.00 gpm 72%
- Similarly, the amendments tightened standards for
emissions of the above-mentioned pollutants from
heavy-duty engines.
- Standards for the control of particulate emissions from
diesel engines were mandated.
- Areas not meeting CO and 03 ambient air quality
standards were required to implement motor vehicle
inspection and maintenance (I/M) programs.
Since the enactment of the 1977 amendments, the Environmental Protection
Agency has made steady progress toward achieving the Act's goals. The
agency has made a number of modifications to its motor vehicle emissions
standards in order to assure that they attain the goal of cleaner air as
effectively and efficiently as possible. In 1984, EPA made significant
progress toward the implementation of this program.
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B. STANDARD SETTING
Heavy-Duty Vehicles
With the achievement of effective reductions of passenger car emissions,
EPA has increasingly turned its regulatory focus toward the development
of parallel standards for heavy-duty trucks and other commercial vehicles.
Projections indicate that these vehicles will contribute an ever-increasing
percentage of the mobile source emissions generated for the rest of this
century. It is therefore important to establish standards for these
vehicles to help insure better air quality.
Accomplishments in this area during 1984 include the following:
- EPA moved forward in its development of standards for particulate
and NOX emissions for heavy-duty diesel engines. Proposed regulations
were published establishing a standard of 6.0 grams per brake horse-
power-hour for NOX and 0.60 grams per brake horsepower-hour for
particulate emissions, starting in the 1987 model year.l The
regulations also propose that the standards be tightened even
further in 1990 with an averaging program for meeting particulate
standards. Final promulgation of these rules is anticipated early
in 1985.
- EPA prepared for the implementation of new and more stringent
heavy-duty exhaust HC and CO and evaporative HC standards, taking
effect in model year 1985. In order to assure that manufacturers
were in a position to meet these standards, EPA provided them with
extensive support on technological and test procedure issues.
- In order to ease manufacturers' transition to stricter standards,
EPA commenced the development of noncompliance penalties for those
engine families unable to meet the standards applicable to a given
model year. This mechanism assures that no manufacturer benefits
financially from noncompliance, and that technological laggards do
not determine the stringency of standards for the entire industry.
(This rulemaking was the first EPA action to feature an innovative
process known as regulatory negotiation, in which all interested
parties meet in an effort to settle their differences prior to
initiation of the formal rulemaking process. The regulatory
negotiation process proved to be extremely successful in this
case.)
Light-Duty Vehicles
During 1984, the primary focus of EPA in the regulation of light-duty
vehicles (LDV's) and light-duty trucks (LDT's) has been in the control of
diesel particulate emissions. EPA promulgated a regulation delaying
particulate emission standards for light duty cars and trucks from 1985
to 1987, in order to allow time for manufacturers to develop trap oxidizer
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technologies for these vehicles.2 This action also delayed the diesel
particulate emissions averaging regulations, which were applicable to the
stricter standards, until 1987.
Other Vehicle Categories
EPA modified its emissions standards for jet aircraft engines in
1984, eliminating the production limit of 20 engines per year from
the low production engine provisions of the aircraft standards.3 This
change allowed engine manufacturers more flexibility in their production
schedules.
The EPA also moved forward in its study of railroad emissions, due
to be published in 1985.
Fuels
In August 1984, EPA proposed a rule which would expedite the reduction
of allowable lead in gasoline.^ This action was prompted by accumulating
evidence of the health and other effects associated with the presence
of lead in the gasoline. The regulation will significantly reduce
atmospheric lead contaminations, and consequently blood lead levels and
related medical costs. In addition, it should significantly curtail
consumer fuel switching activities, which undermine EPA's mobile source
emission control efforts. Finalization of this rule is expected early in
1985.
In a related area, EPA continued to process applications for fuel
additive regulations waivers, primarily for methanol blends, in 1984.
This waiver process assures that new fuels do not harm emission control
devices or cause vehicles to exceed applicable standards. This is expected
to become an increasingly important area in response to the progressing
lead phasedown program, as refiners experiment with various additives as
substitutes for lead in vehicle fuel.
C. PREPRODUCTION COMPLIANCE
One of EPA's long-standing techniques for assuring compliance with
motor vehicle emissions standards is the preproduction certification
review program. Initiated in 1968, the program entails engineering
review by EPA staff of engine families representing new vehicles to be
sold in the United States. Steps in the process include submission by
manufacturers of technical data about respective vehicles, emissions
testing of prototypes by manufacturers, review of engineering data and
test results by EPA, and, in certain cases, confirmatory testing of
prototypes at EPA's laboratory facility in Ann Arbor, Michigan.
A series of regulatory reforms implemented over the last several years
have made certification a much stronger and more efficient and flexible
program. As a result of computerization, elimination of redundancy, and
administrative streamlining, the program has retained its full effectiveness
while easing the procedural burden to manufacturers.
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D. INSPECTION/MAINTENANCE
An effective strategy for dealing directly with in-use emissions
problems is the establishment of motor vehicle inspection and maintenance
(I/M) programs. EPA's basic approach in this area was determined by the
1977 amendments to the Clean Air Act. Urban areas of the country which
obtained an extension in the deadline for attaining the ambient air
quality standards for automotive-related pollutants beyond 1982 are
required by the Act to implement an I/M program. In 1984,, EPA continued
to promote the implementation of I/M programs in each locality where it
is required by the Clean Air Act. By the end of the year, 43 of 52 areas
had initiated I/M programs.
In order to assure that operating I/M programs actually achieve the
planned emissions reductions, EPA initiated in 1984 a systematic I/M
auditing plan. Auditing and thorough followup by Federal, State, and
local officials will pinpoint and lead to correction of any major deficiencies
in individual I/M programs.
E. MOBILE SOURCE ENFORCEMENT
The EPA mobile source enforcement program is directed primarily
toward achieving compliance with motor vehicle emissions standards and
fuel regulations as required by the Clean Air Act. The major goals and
objectives are to: (1) assure that both new and in-use vehicles meet
emissions standards; (2) assure that emissions control systems are not
removed or rendered inoperative; (3) assure that harmful additives are
not present in gasoline; (4) administer statutory and California emissions
standards waivers; and (5) administer the statutory emissions warranties.
In order to accomplish these goals, EPA maintains a number of basic
motor vehicle enforcement programs as described below.
Recall Program
Section 207(c) of the Clean Air Act authorizes EPA to order the
recall of vehicles if a substantial number of any class of vehicles do
not conform to emissions standards. During 1984, 1,206,900 vehicles were
recalled either by direct order of EPA or as a result of an EPA investigation.
In the same period, manufacturers voluntarily recalled 867,770 vehicles
to correct emissions problems. EPA conducted a total of 35 recall investi-
gations in 1984, and performed 661 tests of in-use vehicles at laboratory
facilities in Springfield, Virginia and Ann Arbor, Michigan.
The recall program has traditionally focused on light-duty vehicle
exhaust emissions. However, as new categories of emissions come under
stringent control, the recall strategy must be applied to them. Therefore,
in 1984, EPA began small-scale efforts toward implementing light-duty
evaporative emissions and heavy-duty exhaust emissions recall programs.
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Selective Enforcement Auditing
In order to assure that production vehicles are built in accordance
with emissions standards, EPA conducts Selective Enforcement Audit (SEA)
test programs at manufacturers' facilities. EPA has found that the SEA
program encounters few failures because automobile manufacturers routinely
test on a voluntary basis many more vehicles than are strictly required
through SEA orders. Therefore, beginning in 1981, EPA changed its SEA
policy to place greater reliance on manufacturer testing programs and
less on EPA-mandated audits. In fiscal year 1984, EPA conducted 17 SEA
test programs, including four at foreign manufacturers' facilities.
Unleaded Gasoline Enforcement Program
The EPA has responsibility for enforcing Section 211 of the Clean Air
Act, relating to the regulation of fuels and fuel additives. One of the
regulations under this section of the Act is aimed at protecting the
catalytic converters on 1975 and later model year cars.
The EPA has established a nationwide fuels enforcement program to ensure
that affected retail outlets comply with these regulations. This program
includes sampling of the fuel at retail outlets by Regional EPA field
inspectors and private or State inpectors under EPA contract in order to
measure the fuel's lead content. EPA conducted 12,500 inspections under
this program during 1984.
As mentioned before, proposed rules expediting the lead phasedown
schedule are expected to take effect in 1985. These rules will create a
demand for other additives which will have a potentially harmful impact
on auto emissions. EPA expects that the proliferation of additives will
create a need to monitor the composition of vehicle fuels even more
closely than in the past.
Tampering/Fuel Switching
The EPA is also responsible for carrying out programs designed to deter
tampering with vehicle emissions control systems or using leaded fuel in
vehicles which require unleaded. Surveys undertaken by EPA have shown
tampering and fuel switching to be continuing serious problems which
undermine the emissions control performance of many in-use vehicles. The
latest survey indicates that about 28 percent of the vehicle fleet is
subject to gross tampering, and about 16 percent to fuel switching.
Federal efforts alone cannot effectively address these problems.
Consequently, EPA has promoted the implementation of State and local
antitampering enforcement programs. In 1984, nine local antitampering
programs were set up as a result of this initiative.
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F. IMPORTS
The control of emissions from imported vehicles has become a major
issue in recent years. Due to various changes in consumer taste and the
strength of the dollar in foreign exchange rates, vehicle imports have
vastly increased their share of the U.S. auto market. Correspondingly,
there has been a significant increase in the number of independent auto
importers bringing cars into this country for resale. This has created
several problems in regulating the emissions from these cars. In 1984,
EPA received 8,500 applications and 27,400 inquiries concerning the
importation of non-conforming autos into the U.S. In response, the
EPA is modernizing its imports program to handle this increase in demand,
and is revising its regulations to make the process work more smoothly
and efficiently. A notice of proposed rulemaking addressing the problems
created by this increased demand was in preparation in 1934.
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X. LITIGATION
A. INTRODUCTION
Without question, the most important Clean Air Act case of the year
was Chevron v. Natural Resources Defense Council (NRDC), [467 U.S.
(1984); 52 USLW 4845J.Under the nonattainment provisions of the Clean
Air Act, any "modified" source must undergo review and meet certain
control requirements. A source is "modified" if its emissions increase.
In this opinion, the Supreme Court held that EPA could legally allow
States to exempt factories from "modification" review if an emissions
increase at one facility within the factory was offset by emissions
decreases at another. In effect, the opinion allows the entire factory
to be treated as a "source" for new source review purposes. The court's
opinion contains very broad language about the authority of agencies to
interpret with binding effect the statutes they administer. It is likely
to be an important precedent both for the Clean Air Act and for administrative
law in general.
In a second Supreme Court opinion, Stauffer Chemical Corp. v. EPA
(467 U.S. ; 52 USLW 4022), the court let stand a lower court ruling
that EPA could not designate employees of contractors as EPA "representa-
tives" entitled to conduct inspections under Section 114 of the Clean Air
Act. The court reached this decision not on the merits, but by applying
against the Government the doctrine of "collateral estoppel," which
generally forbids a litigant who has lost a case involving a legal question
in one court from relitigating the same legal question against the same
opposing party in any other court.
In addition to the two Supreme Court decisions described above, the
Federal Courts of Appeals handed down 11 decisions involving the Clean
Air Act in 1984. Of these, two involved the operations of the combined
State and Federal mechanism for establishing "State implementation plans,"
("SIP's") two involved the workings of the Act's "prevention of significant
deterioration ("PSD") system, two involved measures for the control of
sulfur oxides, and one involved the legal doctrine of "standing." Apart
from these decisions, which all involved control of stationary sources of
air pollution, 1984 also saw four decisions under the "mobile source"
control provisions of Title II of the Clean Air Act. EPA won six of
these decisions and lost four. The remaining decision, though mixed, was
basically favorable to EPA.
B. STATIONARY SOURCE CASES
1. The SIP System
Probably the most important stationary source case in 1984 was
Bethlehem Steel Corp. v. EPA. 742 F.2d. 1028 (7th Cir.). In this case,
Judge Posner, reaching beyond the normal time limits on judicial review,
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examined EPA's conduct in approving most portions of an Indiana rule to
control the "opacity" of emissions, but disapproving a 15-minute exemption
from compliance. He ruled that, though EPA did have power to approve
some parts of a State implementation plan and disapprove others, that
power was analogous to the power of a State governor exercising "item
veto" authority and could not be used to create a new regulatory command
beyond the intent of the original authors. He found that EPA had acted
beyond that limit in the case before him.
In a related case, Judge Posner found that EPA could not simply
"decline to act" on a SIP revision submitted by a State, but would have
to approve or disapprove it within a reasonable time. Indiana & Michigan
Electric Co. v. EPA, 733 F.2d. 489 (7th Cir. 1984).
2. Review of New Sources and Major Modifications
In Hawaiian Electric Power Co. v. EPA, 723 F.2d. 1440 (9th Cir.
1984), the court upheld EPA's determination that a potential switch by a
power company from low-sulfur to high-sulfur oil, resulting in an emissions
increase, would be a "major modification" to the plant that would subject
it to PSD review under 40 CFR 52.21.
In NRDC v. EPA (GATX Terminals). 723 F.2d. 761 (D.C. Cir. 1974), the
D.C. Circuit upheld EPA's decision not to count the emissions from tankers
moving to or from docking facilities as part of the docking facilities'
emissions for purposes of new source review of those facilities. The
court agreed with EPA's conclusion that counting vessel emissions in this
manner was inconsistent with the Act's bar on review of "indirect sources"
of air pollution. The court remanded to EPA for reconsideration the
question whether emissions from docked vessels were so closely associated
with the docking facilities' emissions that they should be; included in
them.
3. Sulfur Dioxide (SO?) Control
In Air Pollution Control District of Jefferson County, Kentucky, v.
EPA, 739 F.2d. 1071 (6th Cir. 1984), the court agreed with EPA's
conclusion that interstate pollution that did not violate either an
ambient standard or a PSD increment did not present a ground for relief
under Section 126 of the Clean Air Act.
In Ohio Power Co. v. EPA, [729 F.2d. 1096], the court rejected
industry challenges to the way EPA modeled power plant emissions, finding
that the petitioners had not shown tnat the EPA decision was "arbitrary
or capricious."
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4. Other
In Edwards Engineering Corp. v. EPA, D.C. Cir. No. 83-2083 (decided
May 16, 1984), the court held that a manufacturer of pollution control
equipment lacked "standing" to challenge a new source performance standard
that could affect it by affecting the market for its products.
C. MOBILE SOURCE CASES
In the most important mobile source case of the year, General Motors
Corp. v. Ruckelshaus, 742 F.2d. 1561 (D.C. Cir. 1984), the D.C. Circuit,
sitting en bane, addressed the provisions of the Clean Air Act that
require cars to meet emissions standards for a "useful life" of 5 years
or 50,000 miles. The court upheld EPA's position that it could compel
the recall and repair of automobiles that had passed their statutory
"useful life" period, as long as they had exceeded the applicable standards
within that useful life period. The court reversed an earlier panel
opinion rejecting EPA's position.
In Center for Auto Safety v. EPA, 747 F.2d. 1 (D.C. Cir.), however,
the court rejected EPA's contention that, when acting to correct violations
of auto emission standards, it could accept a manufacturers' offer to
build cars that did better than the standards to "offset" the emissions
of the violating vehicles, rather than ordering a recall and repair. The
court found recall to be the only remedy authorized by the statute.
In CEDs Inc. v. EPA. 745 F.2d. 1092 (7th Cir.), the court found that
EPA had authority under Section 114 of the Clean Air Act to inspect
premises and records of a company that it suspected of selling devices
used to disconnect auto emission control systems. It reversed a district
court opinion to the contrary.
In American Methyl. Inc. v. EPA, 749 F.2d. 824, the D.C. Circuit
held that EPA had no power (absent fraud or similar circumstances) to
"withdraw" permission granted under Section 212 to use a fuel additive.
EPA would have to restrict or forbid use by affirmative rulemaking under
Section 211(c) instead.
D. DISTRICT COURT CASES
The most interesting district court litigation of the year involved
EPA's establishment of standards for sources of radionuclide emissions
under Section 112 of the Clean Air Act. In July, Judge Orrick of the
Northern District of California ordered the Administrator to issue final
radionuclide standards or delist radionuclides as a hazardous air pollutant.
Sierra Club v. Ruckelshaus [84-0656 WHO]. In response, the Agency found
that three of the four categories of sources for which regulations had
been proposed did not present "significant risks" and, therefore, should
not be regulated and that the fourth could not be regulated without
additional notice and comment.
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Judge Orrick subsequently found the EPA and the Administrator in
contempt of court and ordered regulations issued for all four source
categories. Sierra Club v. Ruckelshaus, (84-0565 WHO). The EPA
initiated steps to comply with the order while also pursuing an appeal.
Standards were signed by the Administrator covering DOE- and NRC-licensed
facilities and elemental phosphorous plants, while work progressed on the
standard for uranium mines.
Three other district court cases under the Clean Air Act also involved
statutory deadlines. In State of New York v. EPA [No. 82-CIV-4695(S.D.N.Y.)],
the court ordered EPA to reach a decision on whether or not to regulate
polycyclic organic materials (POM's) under Section 112 of the Clean Air
Act. In State of New York v. Ruckelshaus [21 Env. Rep. Cases 1721], the
court ordered EPA to reach a final decision on petitions for relief
against "interstate pollution" filed under Section 126 of the Clean Air
Act. In NRDC v. Ruckelshaus [No. 84-758 (D.D.C. Sept. 14, 1984)], the
court ordered EPA to issue certain standards for air emissions from
trucks.
The EPA has complied or is complying with all three orders.
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XI. REFERENCES
Chapter II
1. 44 Federal Register 27558 (May 10, 1979).
2. 49 Federal Register 10436 (March 20, 1984).
3. D. Fox, "Judging Air Quality Model Performance," Bulletin of the
American Meteorological Society, 62(5):599-609, 1981.
4. D. Wackter and R. Londergan, "Evaluation of Complex Terrain Air
Quality Simulation Models," EPA-450/4-84-017, 1984.
5. A. Thrall, T. Stoeckenius, C. Burton, "A Method for Calculating
Dispersion Modeling Uncertainty Applied to the Regulation of an
Emission Source." EPA Contract No. 68-02-3870, Research Triangle
Park, NC 27711, 1984.
6. "Guideline on Air Quality Models," EPA-450/2-78-027, 1978.
7. "Receptor Model Technical Series, Volume V: Source Apportionment
Techniques and Considerations in Combining Their Use,"
EPA-450/4-84-020 (July 1984).
8. "Guidelines for Using the Carbon Bond Mechanism in City-Specific
EKMA," EPA-450/4-84-005 (February 1984).
9. "User's Manual for OZIPM-2: Ozone Isopleth Plotting With Optional
Mechnisms, Version 2," EPA-450/4-84-024 (August 1984).
Chapter III
1. Air Quality Criteria for Lead (4 Volumes). Second External Review
juanty u
~. EPA^S
Draft.EPA-600/8-83-028B, NTIS PB85-163996, September, 1984.
2. Air Quality Criteria for Ozone and Other Photochemical Oxidants
(5 Volumes).First External Review Draft.EPA-600/8-84-020A,
NTIS PB-600/8-84-020A.
3. Revised Evaluation of Health Effects Associated with Carbon Monoxide.
Final . EPA 6—/8-83-033F, NTIS PB85-103471.
4. Health Assessment Document for Carbon Tetrachloride, EPA-600/882-001F,
NTIS PB85-124-196, September 1984.
5. Carcinogen Assessment of Coke Oven Emissions, EPA-600/6-82-003F, NTIS
PB84-17018Z, February 1984.
XI-1
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6. Health Assessment Document for Chromium, EPA-600/8-83-14F, NTIS PB85-
115905, August 1984.
7. Health Assessment Document for Inorganic Arsenic, EPA-600/8-83-021F,
NTIS PB84-190891, March 1984.
8. Health Assessment Document for Manganese, EPA-600/8-83-013F, NTIS
PB84-229954, August 1984.
9. Health Issue Assessment - Mercury Health Effects Update, EPA-600/8-84-019F,
NTIS PB85-123925, August 1984.
10. Health Assessment Document for 1,1,1-Trichloroethane (Methyl Chloroform),
EPA-600/8-82-003F, NTIS P884-183565, February 1984.
11. Asbestos Health Assessment Update. First External Review Draft.
EPA-600/8-84-003A, NITS PB84-1868~32, February 1984.
12. Updated Mutagenicity and Carcinogenicity Assessment of Cadmium. Second
External Review Draft.EPA-600/8-83-025B, NTIS PB85-116150, April 1984.
13. Health Assessment Document for Chlorinated Benzenes (2: Parts). First
External Review Draft.EPA-600/8-84-015A, NTIS PB84-220359, April 1984.
14. Health Assessment Document for Chloroform (2 Parts). First External
Review Draft.EPA-600/8-84-004,NTIS PB84-195163, March 1984.
15. Health Assessment Document for Hexachlorocyclopentadiene. First External
Review Draft. EPA-600/8-84-001A,, NTIS PB84-182880, February 1984.
16. Health Assessment Document for Polychlorinated Dibenzo-p-Dioxins (2 parts).
First External Review Draft.EPA-600/8-84-014A, NTIS PB84-220268, May 1984.
17. Horstman, D.H., L.J. Rogers, H. Kehrl, and M.J. Hazucha, "Distribution of
Airway's Sensitivity to Sulfur Dioxide in Asthmatics," Nature,
(In Press-1984).
18. Graham, J.A., and D.E. Gardner, "Altered Immune Fuction and Host Resistance
Following Exposure to Common Airborne Pollutants," The Immunological
System As A Target for Toxic Damage, (In Press-1984~JT
19. Brusick, D.J., R.R. Young, and D.R. Jagannath, "Use of Short-Term Genotoxic
Bioassays in the Evaluation of Unregulated Auto Emissions," EPA 600/1-84-011,
NTIS PB84-226 976.
20. Benignus, V.A. " Neurobehavioral Effects of Toluene - A Review," Neurobe-
havioral Toxicology and Teratology, Vol. 3, pp. 407-415, 1981, NTIS PB82-246851
XI-2
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21. Benignus, V.A., K.E. Muller, J.A. Graham, and C.N. Barton, "Toluene Levels
in Blood and Brain of Rats as a Function of Toluene Levels in Inspired
Air," Environmental Research, Vol. 33, pp. 39-46, 1984, EPA-600/J-82-010,
NT IS PB84-197 532.
22. Laskey, J.W., 6.L. Rehnberg, J.F. Hein, S.C. Laws, and F.W. Edens, "Assess-
ment of the Male Reproductive System in the Preweanling Rat Following
MN304 Exposure," Toxicology and Environmental Health, (In Press-1984).
23. Graham, J.A. , and G.E. Hatch. "Integration of Ozone and Nitrogen Dioxide
Health Data from Animals to Man," Journal of the Air Pollution Control
Association, (In Press-1984), EPA-600/D-84-125, NTIS PB84-195-312.
24. Adams, R.M., S.A. Hamilton, and B.A. McCarl , "The Economic Effects
of Ozone Pollution on U.S. Agriculture." Submitted to Journal of the
Air Pollution Control Association, June ~
25. Adams, R.M., S.A. Hamilton, and B.A. McCarl, "The Benefits of Air
Pollution Control to U.S. Agriculture: Methodological and Policy
Issues." Submitted to American Journal of Agricultural Economics,
August 1984.
26. "Pollution Episodic Model User's Guide," EPA-600/8-84-008, March 1984.
27. "INPUFF-A Single Source Gaussian Puff Dispersion Algorithum User's
Guide," EPA-600/8-84-027, October 1984.
28. "User's Guide for the Photochemical Box Model (PBM) and Mag Tape,"
EPA-600/8-84-022A/B, August 1984.
29. "User's Guide to the Mesopuff-II Model and Related Processor Programs,"
EPA-600/8-84-013, April 1984.
30. Whitmore, R.W., S.M. Jones, and M.S. Rosenweig. "Final Sampling Report
for the Study of Personal CO Exposure," EPA-600/S4-84-034, NTIS PB84-
181957, May 1984.
31. Johnson, T. "A Study of Personal Exposure to Carbon Monoxide in Denver,
Colorado," EPA-600-4-84-014, NTIS PB84-146125, May 1984.
32. Hartwell, T.D., C.A. Clayton, R.M. Mitchie, R.W. Whitmore, H.S. Sheldon,
S.M. Jones, and D.A. Whitehurst, "Study of Carbon Monoxide Exposure of
Residents in Washington, D.C., and Denver, Colorado," EPA-600/S4-84-031,
NTIS PB84-183516, May 1984.
33. Bush, P.V., D.H. Pontius, and L.E. Sparks, "Performance of Large Diameter
Wires as Electrodes in Electrostatic Precipitators." Paper presented at
the Fifth Symposium on the Transfer and Utilization of Particulate
Control Technology. EPA and EPRI, Kansas City, MO, August 27-30, 1984.
XI-3
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34. Sparks, L.E., G.H. Ramsey, R.E. Valentine, and C. Bullock, "Removal
of Sulfur Dioxide and Particulate Using E-SOX." Paper presented at the
Fifth Symposium on the Transfer and Utilization of Particulate Control
Technology. EPA and EPRI, Kansas City, MO, August 27-30, 1984.
35. Chambers, R., J.J. Spivey, and D,,L. Harmon, "ESFF Pilot Plant Operation
at Harrington Station." Paper presented at the Fifth Symposium on the
Transfer and Utilization of Particulate Control Technology. EPA and
EPRI, Kansas City, MO, August 27-30, 1984.
36. Hovis, L.S., B.E. Daniel, Y.J. Chen, and R.P. Donovan, "Laboratory
Studies of Electrically Enhanced Fabric Filtration." Paper presented
at the Fifth Symposium on the Transfer and Utilization of Particulate
Control Technology. EPA and EPRI, Kansas, MO, August 27-30, 1984.
37. Blythe, G.M., J.M. Burke, T.G. Brna, and R.G. Rhudy, "Field Evaluatin
of a Utility Dry Scrubbing Systan," Proceedings of the Eighth Symposium
on Flue Gas Desulfurization, Vol. II, pp. 736-757, EPA-600/9-84-017a.
38. Mobley, J.D., "Proceedings: EDA's Industry Briefing on the Organic
Acid-Enhanced Limestone FGD Process (July 1984)," EPA-600/9-85-009,
March 1985.
39. Englund, G., et, al., "Evaluation and Demonstration of Low NOx Burner
Systems for TEOR Steam Generators-Design Phase Report," EPA-600/7-84-
076, July 1984.
40. Englund, G., et. al., "Evaluation and Demonstration of Low NOx
Burner Systems for TEOR Steam Generator-Design Phase Report," EPA
600/7-84-076, July 1984.
41 "The Acidic Deposition Phenomenon and Its Effects - Critical Assessment
Review Papers," EPA 600/8-83-016A/B.
Chapter IV
1. 45 FR 55066 (Aug. 18, 1980).
2. "Revised Evaluation of Health Effects Associated with Carbon Monoxide
Exposure," (EPA-600/8-83-033 F) July 1984.
3. "Review of the NAAQS for Carbon Monoxide: Reassessment of Scientific
and Technical Information," (EPA-600/5-84-004) July 1984.
4. 49 FR 6866 (Feb. 23, 1984).
5. 49 FR 10408 (Mar. 20, 1984).
6. "Review of the NAAQS for Sulfur Oxides: Assessment of Scientific and
Technical Information - OAQPS Staff Paper," (EPA-450/5-82-007) Nov. 1982.
XI-4
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Chapter V
1. 49 FR 22195 (May 25, 1984).
2. 49 FR 31680 (Aug. 8, 1984).
3. 49 FR 36560 (Sept. 18, 1984).
4. E. Haemisegger et al., The Magnitude and Nature of the Air
Toxics Problem in the United States (Draft), Sept. 1984.
5. 49 FR 31706 (Aug. 8, 1984).
6. Post, Barbara K., Ruth C. Mead and Alice S. Pel land,
Bibliography of EPA Reports, Office of Air Quality
Planning and Standards (OAQPS), Research Triangle
Park, NC 27711, March 7, 1984.
7. Pel land, Alice S., Barbara K. Post and Ruth C. Mead,
Selected Bibliography of Health Effects and Risk
Assessment Information, Office of Air Quality Planning
and Standards (OAQPS), Research Triangle Park, NC 27711,
July 1984.
8. Mead, Ruth C. and Alice S. Pel land, Ongoing Research
and Regulatory Development Projects, Office of Air
Quality Planning and Standards (OAQPS), Research
Triangle Park, NC 27711, March 1984.
9. Smith, Carolyn S. and Sandra A. Smith, Interim Report of
Selected Information on State and Local Agency Air Toxics
Activities, Office of Air Quality Planning and Standards
(OAQPS), Research Triangle Park, NC 27711, September 21,
1984.
Chapter VI
1. 45 FR 80084 (December 2, 1980).
2. 49 FR 42670 (October 23, 1984).
3. 47 FR 5864 (February 8, 1982).
4. 49 FR 44878 (November 9, 1984).
5. 48 FR 46152 (December 11, 1983).
6. 48 FR 38742 (August 25, 1983).
7. National Air Audit System FY 1984 National Report, EPA-450/2-84-009.
8. 43 FR 46246 (October 5, 1978).
XI-5
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Chapter VII
1. 49 Federal Register 6458
2. 49 Federal Register 13646
3. 49 Federal Register 22598
4. 49 Federal Register 26884
5. 49 Federal Register 37328
6. 49 Federal Register 18076
7. 49 Federal Register 41030
8. 49 Federal Register 43838
9. 49 Federal Register 21864
10. 49 Federal Register 25102
11. 49 Federal Register 29698
12. 49 Federal Register 4590
13. 49 Federal Register 2636
14. 49 Federal Register 32987
15. 49 Federal Register 40542
16. 49 Federal Register 32743
17. 49 Federal Register 8572
18. 49 Federal Register 11750
19. 49 Federal Register 13654
20. 49 Federal Register 23522
21. 49 Federal Register 23498
22. 49 Federal Register 23478
23. 49 Federal Register 13658
(February 21, 1984).
(March 5, 1984).
(May 30, 1984).
(June 29, 1984).
(September 21, 1984),
(April 26, 1984).
(October 19, 1984).
(October 31, 1984).
(May 23, 1984).
(June 19, 1984).
(July 23, 1984).
(February 7, 1984).
(January 20, 1984).
(August 17, 1984).
(October 16, 1984).
(July 29, 1984).
(March 7, 1984).
(March 3, 1984).
(April 5, 1984).
(June 6, 1984).
(June 6, 1984).
(June 6, 1984).
(April 5, 1984).
XI-6
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24. 49 Federal Register 50146 (December 26, 1984).
25. "BACT/LAER Clearinghouse - (May, 1984).
A Compilation of Control
Technology Determination"
Chapter VIII
1. "Technical Guidance on the Review and Use of Excess Emission Reports,"
(EPA-340/1-84-015), October 1984.
Chapter IX
1. 49 Federal Register 40258 (October 15, 1984).
2. 49 Federal Register 3010 (January 24, 1984).
3. 49 Federal Register 41000 (October 18, 1984).
4. 49 Federal Register 31032 (August 2, 1984).
XI-7
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing!
1. REPORT NO. ' 2.
EPA 450/2-85-007
4. TITLE AND SUBTITLE
Progress in the Prevention and Control of
Air Pollution in 1984
7 *XXK$5W?X
Project Officer— William F. Hamilton
9' OrTfcirS? ^^^Tf^W^ft^n^^a5 Standards
Control Programs Development Division
Mail Drop 15
Research Triangle Park, N.C. 27711
12. SPONSORING AGENCY NAME AND ADDRESS
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
November 1985*
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NC
10. PROGRAM ELEMENT NO.
A13A2A
11. CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVERED
1984 (Final)
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
Annual Report of the Administrator of the Environmental Protection Agency to the
Congress under Sections 313, 202, and 306 of the Clean Air Act
16. ABSTRACT
The report addresses the progress made in the prevention and control of air
pollution in 1984. It covers the areas of air quality trends and monitoring,
development of air quality criteria and standards, the status of State Implementation
Plans, the control of stationary and mobile source emissions, enforcement, and
litigation. The report is the annual report of the Administrator of EPA to the
Congress in compliance with Sections 313, 202(b)(4), and 306 of the Clean Air Act,
as amended.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Air Pollution
Environmental Engineering
Pollution Abatement
Pollution Regulations
Public Health
18. DISTRIBUTION STATEMENT
Release unlimited. Available through
NTIS
b. IDENTIFIERS/OPEN ENDED TERMS
19. SECURITY CLASS (This Report)
Unclassified
20. SECURITY CL.^SS (This page)
Unclassified
c. COSAT1 field/Group
21. NO. OF PAGES
79
22. PRICE
EPA Form 2220-1 (Rev. 4—77) PREVIOUS EDITION is OBSOLETE
*Date of transmittal to the Congress.
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