450/2-89-009
PROGRESS IN THE PREVENTION AND CONTROL
OF AIR POLLUTION IN 1987 -
ANNUAL REPORT OF THE ADMINISTRATOR
OF THE ENVIRONMENTAL PROTECTION AGENCY
TO THE
CONGRESS OF THE UNITED STATES
IN COMPLIANCE WITH
SECTIONS 313, 202(b)(4), AND 306
OF
42 U.S.C. 7401 ET SEQ.
THE CLEAN AIR ACT, AS AMENDED
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
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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 (MD-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. EPA-450/2-89-009
ii
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CONTENTS
Page
I. INTRODUCTION AND SUMMARY
A. Introduction ; 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. 1-6
E. Assessment and Control of Toxic Air Pollutants .... 1-7
F. Status of Air Quality Management Programs 1-9
G. Control of Stationary Source Emissions 1-12
H. Stationary Source Compliance 1-12
I. Control of Mobile Source Emissions 1-14
0. Stratospheric Ozone Protection 1-16
K. Radon Assessment and Remediation 1-17
L. Litigation 1-17
II. AIR QUALITY TRENDS, MONITORING, AND MODELING
A. National Air Quality and.Emission Trends II-l
8. Ambient Air Monitoring 11-3
C. Air^Djua.li±y Modeling II-6
- 13. Integration of-Mr-Data Systems. . '."". ...:.... 11-9
E. Emission Factor Development 11-9
F. References 11-9
III. AIR POLLUTION RESEARCH PROGRAMS
A. Introduction III-l
B. General Air Pollution Research Activities III-l
C. Acid Deposition Research Activities 111-14
D. References 111-18
IV. DEVELOPMENT OF NATIONAL AMBIENT AIR QUALITY STANDARDS
A. Description of Activities IV-1
B. References IV-2
V. ASSESSMENT AND CONTROL OF TOXIC AIR POLLUTANTS
A. Introduction V-l
B. Assessment and Regulatory Decisions V-l
C. Federal Regulatory Program - Stationary Sources . . . V-l
D. Mobile Sources V-4
E. Specific Point Sources V-4
F. Assessing Urban Risk V-5
G. Building State and Local Air Toxics Control Programs . V-6
H. References V-8
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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-9
E. References VI-10
VII. CONTROL OF STATIONARY SOURCE EMISSIONS r : ..
A. New Source Performance Standards (NSPS) VII-1
B. BACT/LAER Clearinghouse VII-1
C. References VII-1
VIII. STATIONARY SOURCE COMPLIANCE
A. General . VIII-1
B. Litigation VIII-4
C. Compliance and Enforcement Guidance VIII-6
D. Compliance by Federal Facilities . VIII-6
E. List of Violating Facilities VIII-6
£, References VI11-7
I-£ -CONTROlToF MOBILE-SOURCE EMISSIONS : :
A. Introduction IX-1
B. Ozone Control IX-1
C. Vehicle Fuels and Air Toxics IX-2
D. Standard Setting IX-4
E. Preproduction Compliance ...... IX-5
F. Vehicle Inspection Program IX-6
G. Mobile Source Enforcement IX-6
H. Imports IX-9
I. Litigation IX-9
J. References IX-10
X. STRATOSPHERIC OZONE PROTECTION
A. Description of Activities X-l
B. References X-2
XI. RADON ASSESSMENT AND REMEDIATION XI-1
XII. LITIGATION
A. Introduction XII-1
B. Landmark Decisions XII-1
C. Other Significant Decisions XII-1
IV
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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
continues to rest with State and local governments. The 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 l to
December 31, 198#j and describes the issues involved in the
prevention ajtwl control of air pollution and the major elements of
progress toward that :goaT 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. INTRODUCTION
This report, which has been prepared in order to satisfy the
requirements of sections 313, 202(b)(4), and 306 of the Clean Air Act (Act),
describes the progress that the Environmental Protection Agency (EPA) has
made in the prevention and control of air pollution during calendar year
1987. 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.
B. AIR QUALITY TRENDS, MONITORING, AND MODELING
(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 1986.)
All of the criteria pollutants .showed improvements in air quality and
emissions between 1977 and 1986. Specific details on air quality and
emissions levels, for each of the pollutants to which national ambient air
quality-standards (NAAQS) :app3ied in 1986, are as follows'.:.
0 Annual average ambient total suspended particulate (TSP) levels
decreased 23 percent between 1977 and 1986, while TSP emissions
decreased 25 percent. Between 1985 and 1986, ambient TSP levels were
unchanged, while TSP emissions declined 3 percent. On July 1, 1987,
EPA promulgated new standards for particles nominally 10 micrometers
and smaller in diameter (PMioK rather than TSP. PM^o monitoring
networks are now being deployed nationally.
0 Annual average ambient sulfur dioxide levels decreased 37 percent
between 1977 and 1986, while total sulfur oxide emissions decreased
21 percent. Between 1985 and 1986, ambient sulfur dioxide levels
declined 3 percent, while total sulfur oxide emissions declined 2
percent.
0 Ambient carbon monoxide levels decreased 32 percent between 1977
and 1986, while total carbon monoxide emissions decreased 26 percent.
Ambient carbon monoxide levels were basically unchanged between
1985 and 1986. The long term progress reflects the continuing
reductions in carbon monoxide emissions brought about by the Federal
Motor Vehicle Control Program.
0 Annual average ambient nitrogen dioxide levels decreased 14 percent
between 1977 and 1986. During this time, total nitrogen oxide
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emissions decreased by 8 percent, and highway vehicle emissions,
the source category likely impacting the majority of nitrogen
dioxide monitoring sites, decreased by 13 percent. Between 1985
and 1986, ambient nitrogen dioxide levels were unchanged, while
total nitrogen oxide emissions decreased 2 percent.
0 The composite average of the second highest daily maximum 1-hour
ambient ozone values decreased 21 percent between 1977 and 1986,
while volatile organic compound (VOC) emissions decreased 19
percent. The decrease in ambient, ozone levels vs .complicated by
the change in the ozone calibration procedure that occurred in the
1978-79 time period. In the post-calibration period (1979-1986),
ambient ozone levels decreased 13 percent, while VOC emissions
decreased 20 percent. The ozone trend in the 1980's shows that the
1980 and 1983 values were higher than those in 1981, 1982, 1984,
1985, and 1986. While 1986 levels are similar to 1985 levels, there
was a slight improvement of 2 percent in the national composite
average between these 2 years.
0 Ambient lead levels decreased 87 percent between 1977 and 1986,
while lead emissions decreased £4-percent. Between 1985 and 1986,
ambient lead levels declined. 3-5 percent, while lead emissions declined
59 percent. This extremely large decrease in both air quality levels
and estiinatedr emissions is largely due ta the Deduction of the lead
:- Content, of 1 eaded-gaso-1 i ne.
The 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 reyulations - 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 activities, were required to meet
all provisions of the regulations by January 1, 1983. Through December 1987,
4742 SLAMS monitors were operating in accordance with the 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
Act. Through December 1987, 1255 NAMS monitors were operating in accordance
with the requirements of the regulations.
To accompany the revisions to the national ambient air quality standard
for particulate matter, EPA, on July 1, 1987, also promulgated amendments to
40 CFR 58 (Air Quality Surveillance and Reporting Regulations). The revisions
to Part 58 established ambient air quality monitoring requirements for PMio
as measured by a new reference method promulgated as Appendix J of 40 CFR
Part 50 or an equivalent method. Specialized training was provided by EPA to
State and local agency personnel on the operation and maintenance of the
samplers. Also, in addition to using funds supplied by EPA, the States and
local agencies have separately purchased PM^o samplers bringing the total
number of operating PMio samplers to 884 at 583 sites as of December 31,
1987.
Ambient hydrocarbon data were collected at 32 sites in 1987 in order to
measure nonmethane organic compounds in various cities. Results from this
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activity will be used in estimating the amount of source control needed to
attain the ozone air quality standard.
During 1987 efforts to improve guidance on air quality models and to ensure
consistency in their use continued. An air quality model clearinghouse was
maintained to ensure that use of nonguideline techniques does not lead to
inconsistent regulatory decisions. Regulatory action to update the "Guidance
on Air Quality Models (Revised)" continued with a notice of final rulemaking
scheduled to take place in 1988. Also during 1987, EPA continued to provide
technical support and review of ozone model applications-~using the Empirical
Kinetics Modeling Approach (EKMA). The EKMA computer program was upgraded and
several draft documents describing how to apply EKMA underwent public comment.
During 1987, EPA continued work on receptor models by finalizing the
"Chemical Mass Balance (CMS) User's Manual." Operation of the CMB program
was described, along with further guidance on validating CMB applications and
reconciling differences between receptor and dispersion model results. Also
in the air quality modeling area, in June 1987 EPA published the document
"Onsite Meteorological Program Guidance for Regulatory Modeling Applications."
This report provides EPA's guidance on the collection and use of on-site
meteorological data intended for use in .regulatory modeling applications.
Efforts continued during 1987 tb'strengthen EPA's capabilities for
modeling potentwl r&leases of toxic chemicals into the atmosphere. A refined
model for the elevated, hig£f->m6mentum release of -heavier-than-ai r gases (such
as might" occur in the operation of-a pressure relief safety valve) was
developed under contract and is currently being assessed. Development of a
model for estimating airborne concentrations from mechanical draft cooling
towers was completed in 1987, and the model is currently being used to assess
the impact of chromium emissions from such towers. In addition, a major
effort undertaken in 1987 involved the application of integrated air emission
and dispersion models to facilities that treat, store and dispose of hazardous
wastes. These models were used to estimate ambient concentrations of a large
number of potentially hazardous substances emitted from the facilities.
Also in 1987, EPA published major revisions to emission factors for use
by States and others to estimate source emissions and to compile emission
inventories. Nearly all of these revisions involve additions of size-specific
emission factors, with emphasis on PMiQ, for use in implementing the new PMio
ambient air quality standard promulgated in 1987.
C. AIR POLLUTION RESEARCH PROGRAMS
The EPA conducted a number of research activities in 1987 to support
various air pollution control programs. Research was conducted to support
the development and review of national ambient air quality standards, to
develop new source performance standards and State implementation plans, and
to support regulations for hazardous air pollutants. Research was also
conducted to support the EPA mobile source regulatory program, the indoor air
pollution program, the stratospheric ozone program, and the Agency's global
warming program. Considerable research was also conducted by EPA in 1987 in
the area of acid deposition.
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In the area of research support to the national ambient air quality
standards process, EPA began work on the revision of the criteria documents
for carbon monoxide (CO) and oxides of nitroyen (NUX). An issue paper on the
health effects of acid aerosols was drafted and peer reviewed in June 1987. A
nonmethane organic compound (NMOC) monitoring project was carried out during
the summer of 1987 to assist States in meeting current ozone national ambient
air quality standards and to provide data needed by the agency in considering
revisions to the ozone air quality standards. In 1987, capabilities of EPA
and the State and local agencies to assess the performance of PMio dichotomous
samplers and continuous nitrogen dioxide (N02) monitors;was sharply improved by
development of audit materials for dichotomous flow and N02 monitors. Clinical
studies of human exposures to ozone were conducted in 1987 and several questions
were answered about the effects of criteria pollutants on asthmatics. In
addition, EPA continued to perform research on the potential neurotoxicity of
lead. In 1987, eight journal articles, two proceedings, and one in-house
report were published which described various results of the National Crop
Loss Assessment Network research program. In addition, EPA performed a
number of research activities related to visibility protection in 1987.
The EPA performed a number of research activities in 1987 to support the
development of new source performance standards and State implementation
plans. A new contract was awarded to.-apply reburning, a fuel staging combustion
modification technology, to a coal-fired, cyclone utility boiler. Based on
previous bench^rand pilot-scale tests, a NOX reduction of. 50 percent or
greater-is, expected. Aivrrehouse research project resulted in the design of
a heavy oil low NOX burner with advantages over previous designs. Development
of a low-cost process for sulfur dioxide (SOg) control continued in 1987 as
part of EPA's advanced flue gas desulfurization (FGD) program. An improved
chemical reaction mechanism was developed to quantify the atmospheric formation
of ozone from its precursors. This mechanism will provide an alternate
approach to the carbon bond mechanism currently used in some ozone air quality
models to develop cost-effective ozone control strategies. A computer model
which quantitatively describes the formation and removal of ambient particulate
matter was developed. A new tracer technique was applied to estimate source
strengths of pollutant emissions which are normally inaccessible with
conventional techniques. Two procedures for sampling stationary source
emissions of PMio were evaluated in field tests.
Numerous research activities related to the development of regulations
.for hazardous air pollutants were conducted in 1987. The health assessment
document for chromium was updated through the completion of an issue paper
which describes the health effects of substitutes for chromium in cooling
towers. New health assessment documents were published for beryllium,
acrolein, acetaldehyde, chlorine/hydrogen chloride, and phosgene. New
techniques for the classification and identification of toxic and potentially
toxic organic pollutants from gas chromatographic-mass spectrometric monitoring
data were developed and tested. The development, evaluation, and validation
of source test methods to support the regulatory process included studies of
methods for a number of organic compounds, including acrylonitrile, butadiene,
carbon tetrachloride, chloroform, dioxins, ethylene oxide, formaldehyde, and
methylene chloride. Ambient air quality measurements for a variety of
volatile organic compounds of interest to air programs were collected through
the Toxic Air Monitoring Stations (TAMS) program. Data from the network were
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validated and incorporated into EPA's air toxics data base. The first set of
Total Exposure Assessment Methodology (TEAM) studies measured personal exposures
of more than 700 persons in 10 cities for multiple VOC's in air and drinking
water together with exhaled breath concentrations. A comprehensive three-volume
report of these studies was published during 1987. Studies of phosgene and
p-xylene answered many questions about the kind and extent of the health effects
posed by these compounds. The effects of several well-defined physiological
or pharmacological treatments were investigated in rats, so that effect patterns
could be recognized in humans and rats exposed to unknown hazardous air
pollutants (HAP's). The identification of mutagenic and. carcinogenic nitroaromatic
compounds in combustion emissions and urban air particulate matter led to a
major research effort in 1987 to understand the sources, exposures, metabolism,
dosimetry, and effects of tnis class of organic compounds. Two wood stove
field studies were completed involving over 70 homes in the Northeast and
Northwest. A study and subsequent field testing for hospital sterilizer control
systems were completed in late 1987. A small pilot-scale laboratory facility
for evaluating the control of potentially toxic volatile organic compounds
via adsorption was brought into operation during 1987. In addition, a report
was prepared which describes the use of smog chambers and other data to
determine the atmospheric lifetimes of eJght air toxics currently under EPA
review, and studies were conducted of the- formation of mutagenic compounds in
urban air, using a controlled system of simulated urban photochemistry.
^.Numerous wobi-ie-source-related research activities were undertaken in
1987. The EPA conducted tire "first stage of a two-stage study to compare existing
formaldehyde methodologies in a worst-case microenvironment, an underground
parking garage. Upon completion, this study will result in base line
formaldehyde measurements from which to judge the future impact of changing
fuel mixtures and will provide tested monitoring methodologies for use by
the monitoring communities. Air quality modeling efforts related to mobile
sources were continued and research was conducted on the effects associated
with methanol fuels and diesel particles. The neurobehavioral consequences
of exposure to carbon monoxide continued to be monitored and reviewed. Mobile
source emissions were characterized from a variety of motor vehicles under a
number of different driving conditions.
The EPA also conducted a research project related to indoor air pollution in
1987. The Report to Congress, EPA's Indoor Air Quality Implementation Plan,
was released in July 1987. Methods development activities included evaluation
of analytical procedures for nicotine and polycyclic aromatic hydrocarbons
(PAH's), development of new methods for polar organics, development of a
miniature real-time monitor for N02, and continued evaluation of the canister
technology for VOC collection. A field demonstration study was initiated to
review the state of indoor monitoring technology and to develop an in-house
capability to conduct monitoring research. A comprehensive and systematic
research plan to investigate the health effects of exposure to volatile
organic compounds emitted from building materials and furnishings was developed.
Activated carbon was evaluated as a possible control measure for indoor
organics. A facility for evaluating the effectiveness of indoor particle
control devices was designed. With the cooperation of the Consumer Product
Safety Commission, EPA conducted the first comprehensive emission characterization
of the various designs of unvented kerosene heaters available to the public.
An initial assessment of asbestos in residences was also completed in 1987.
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In response to growing concern about the depletion of ozone from the
stratosphere and resulting increases in harmful ultraviolet light, EPA
increased its emphasis on research to determine the causes and effects of
stratospheric ozone depletion. This program has two major components:
ecological effects and control technology. A second Nitrous Oxide (NgO)
Workshop was held in Boulder, Colorado, which covered biogenic and combustion
generated NgO. Under the fundamental combustion research program, a kinetic
combustion model was developed which has led to a better understanding of the
formation/destruction pathways of N2<3 during fossil fuel combustion. Documen-
tation was completed on the cost of reducing or discontinuing the use of
chlorofluorocarbons (CFC's) in producing rigid and flextbTe cellular foams,
and in air conditioning and refrigeration. This .documentation was used in
the Regulatory Impact Analysis which supported the December 14, 1987 Federal
Register notice proposing regulations limiting CFC's and halons.
In 1987, EPA established a program to address the causes and effects of
global climate change. Workshops were held with experts from around the
country to provide a sound foundation for the development of a lony-range
global climate change research plan.
Acid deposition research programs In. EPA are coordinated through EPA's
National Acid Precipitation Assessment. Program (NAPAP), which is administered
by the Iflteragency Task Force on Acid'Precipitation. The objective of EPA's
acid deposition—research program is to develop necessary data to fully
understand the~sburces arid\ctwfacteristies of acid deposition, the extent of
damage or potential damage, and the corrective measures that may be used to
diminish the problem.
In 1987, acid deposition research produced scientific information on the
chemical status of a representative sample of lakes in the eastern United
States, and developed a preliminary 1985 man-made emissions data base. The
program established a cloud chemistry network to cover the major hiyh altitude
forest system in the eastern part of the nation. A deposition monitoring
network was installed. Significant progress was made in determining the
effects of acidic deposition on southern conifer and spruce/fir forests.
D. DEVELOPMENT OF NATIONAL AMBIENT AIR QUALITY STANDARDS
On July 1, 1987, EPA promulgated revisions to the air quality standard
for particulate matter. The revised standard replaced total suspended
particulate (TSP) as the indicator for particulate matter ambient standards
with a new one that includes only those particles less than or equal to 10
micrometers in diameter (PMm) and replaced the 24-hour primary TSP standard
with a 24-hour PMio standard of 150 micrograms per cubic meter with no more
than one expected exceedance per year. In addition, the revised standards
replaced the annual primary TSP standard with an annual PMiu standard of 50
micrograms per cubic meter expected annual arithmetic mean, and replaced
the secondary TSP standard with 24-hour and annual PMio standards that are
identical to the primary standards in all respects. Also on July 1, 1987, EPA
published an advance notice of proposed rulemaking soliciting public comment
regarding the development of a new secondary ambient air quality standard for
fine particles (those particles less than 2.5 micrometers in aerodynamic
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diameter). This action represents a continuation of the review process for
secondary standards for particulate matter and addresses regional haze
conditions associated with elevated levels of fine particles.
In April 1986, the Clean Air Scientific Advisory Committee (CASAC)
reviewed a revised draft of the ozone criteria document and the first draft
of the ozone staff paper. The CASAC completed its review of the criteria
document in October 1986. At a December 1987 meeting, CASAC reviewed a
revised staff paper and a research summary of more recent studies. Issues
were discussed regarding the existing 1-hour standard and the possible need
for new longer-term standards to protect against chronic health and welfare
effects. At the conclusion of this session, CASAC did not feel the group
had reached a point where it was adequately prepared to articulate and
communicate its recommendations to the EPA Administrator and thus it called
for an additional meeting in 1988. The CASAC plans to make recommendations
to EPA following this meeting.
With regard to reviews of the carbon monoxide and nitrogen dioxide air
quality standards, EPA began the process of preparing a new criteria document
for carbon monoxide in 1987. An external review draft of tne revised criteria
document is scheduled to be available for-public review in 1988. Development
of the criteria' document for nitrogen-dioxide will be initiated in 1989.
Act'ivities-^related to the review of the sulfur oxides air quality
standard-in 1987" fbcusedVorC completing the staff-paper addendum and the
development of a regulatory package. The EPA announced a proposed decision
to reaffirm the standards in April 1988.
With respect to the review of the ambient standard for lead, activities
focused on updating and validating the lead exposure methodology. It is
anticipated that CASAC will review a revised draft of the staff paper in
1988.
E. ASSESSMENT AND CONTROL OF TOXIC AIR POLLUTANTS
In 1987, EPA continued to implement an active program to screen and
assess potentially toxic air pollutants for possible regulation under the
Clean Air Act or other environmental authorities. A total of 34 chemicals or
emission mixtures were in various stages of assessment at the end of 1987.
Decisions not to pursue a regulatory program directed specifically at copper
and zinc and zinc oxide were published in 1987. Decisions on whether to
regulate 5-10 additional pollutants are expected in 1988. Also in 1987, final
efforts were completed for a report to Congress on the National Dioxin Study,
which was a coordinated effort of various EPA programs to assess the potential
extent of contamination of the environment with chlorinated dioxin compounds.
In addition, EPA also published a report to Congress on municipal waste
combustors (MWC) in 1987. The report addresses EPA's preliminary assessment
of the multi-media aspects of MWC, including releases to the air of dioxins,
furans, acid gas, and hydrocarbons as well as traditional air pollutants.
Based on the results of this study, EPA published an advance notice of proposed
rulemaking in July 1987 that announced its intent to regulate municipal waste
combustors under sections lll(b) and lll(d) of the Clean Air Act.
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In July 1987, the U.S. Court of Appeals for the District of Columbia
Circuit vacated EPA's 1985 withdrawal of a proposed revision of the National
Emission Standard for Hazardous Air Pollutants (NESHAP) for vinyl chloride.
In remanding the standard to EPA for reconsideration, the court held that EPA
had not shown that the vinyl chloride standard adequately protects public
health within the meaning of section 112 of the Clean Air Act. The EPA was
in the process of considering how to respond to the remand at the end of
1987. In June 1984, EPA promulgated a NESHAP for benzene equipment leaks and
withdrew proposed NESHAP's for benzene emissions from maleic anhydride plants,
ethylbenzene/styrene plants, and benzene storage tanks.'.'. Following the vinyl
chloride decision, EPA voluntarily accepted a remand of the benzene NESHAP to
reconsider the three withdrawn benzene proposals and the benzene fugitive
NESHAP. Final action on the remand is expected to be published in 1989.
In other activities related to emission standards for hazardous pollutants,
work continued on revising the asbestos NESHAP during 1987 and a revision to
the mercury NESHAP was promulgated. NESHAP development continued for chromium
emissions from electroplating and industrial cooling towers and a proposed
NESHAP for coke oven emissions was published. Work continued in 1987 on an
ethylene oxide NESHAP for commercial sterilization chambers and on a perchloro-
ethylene NESHAP. for the dry cleaning industry. In addition, EPA continued
work on an accelerated NESHAP development effort that will cover eight organic
compounds (ethyjlene oxide, methylene chloride, ethylene dichloride, perchloro-
ethylene, tn'cbloroethylene-, butadiene, chloroform, and carbon tetrachloride)
for -which intentions to Itsrt Tinder section 112 of the Cleoin Air Act have been
published.
Also in the area of hazardous pollutant emission standards, EPA has
accepted a voluntary remand of all radionuclide NESHAPs and is presently
working to repropose regulatory decisions for 12 source categories. In
addition, EPA issued a notice in the Federal Register that announced its
intent to regulate emissions from new and modified municipal waste comoustion
units using new source performance standards and section lll(d) plans for
existing sources, and work commenced in 1987 on a rule to regulate emissions
of volatile organic compounds and a number of toxic compounds from new and
modified municipal landfills using new source performance standards.
The Resource Conservation and Recovery Act (RCRA) requires EPA to
promulgate such regulations for the monitoring and control of air emissions
at hazardous waste treatment, storage, and disposal facilities (TSDF's) as
may be necessary to protect human health and the environment. Current EPA
plans call for development of regulations for these facilities in three
phases. The first group of standards addresses sources for which EPA can
develop standards relatively quickly because similar sources have already
been regulated under the Clean Air Act. These standards address air emission
vent and fugitive emissions from some of the treatment devices that will be
used to meet the RCRA land disposal restrictions. These standards were
proposed in 1987. The second group of standards, which addresses the bulk of
the sources, is scheduled for proposal in early 1989. The third group of
regulations will cover certain subsets of the source categories for which EPA
will likely be unable to develop rules during the second round. Work on this
third group of sources is expected to begin in 1989.
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In 1987, EPA continued to pursue that portion of its overall strategy
to control emissions of air toxics that provides State and local air
pollution control agencies with funding and technical support to evaluate
specific point sources. Sources that are candidates for this program
include those that have been identified through the Federal toxic air
pollutant assessment program as well as those certified by State and local
air pollution control agencies. In 1987, funding was provided for 22 State
and local evaluations of potential high risk point sources in a variety of
source categories. v
In 1986, EPA initiated planning activities to encourage States to
undertake new efforts toward assessing the scope and seriousness of current
exposures to the mixtures of air toxic compounds which are believed common-
place in large metropolitan areas. The EPA provided funds under section 105
of the Clean Air Act and technical assistance to States to encourage them to
undertake such assessment efforts in a number of areas. Initially, 30 areas
with populations over one million people were targeted for some level of
assessment. In 1987, available funds were provided through EPA Regional
offices, technical guidance was developed and distributed, and available
opportunities were utilized to provide evidence of the existence of the
problem and promotion of assessment programs. As a result of tnese
activities and "-of independent act ions-.on the part of State and local
agencies, several activities have been initiated and in many cases have
progressed to an-advanced stacje. In addition, activity op several Integrated
Environmental Management'Projects (IEMP) was continued. These projects,
while multimedia in nature, focus a major portion of study on the air toxics
aspects of the urban environment. In 1987, effort was completed for the
Baltimore area as a result of work in previous years. The Kanawha Valley
(West Virginia) Phase I study was concluded and sampling was initiated in the
Denver IEMP Study.
The EPA has established a goal to have quality programs in every State
and major local agency that are adequate to carry out certain roles envisioned
within the national air toxics strategy. During 1987, considerable progress
was made toward meeting this goal. The progress was in part due to EPA's
program to enhance State and local program development. This program uses
available grant funds to promote multiyear planning on the part of State and
local agencies and subsequent implementation of these plans for building their
air toxics capabilities and programs. To assist in implementation of multiyear
development plan activities, EPA expanded its program of technical support in
1987. First, EPA continued its practice of developing and distributing
technical assistance documents for assisting State and local agencies to
estimate air toxics emissions. Next, EPA's Control Technology Center (CTC)
became fully operational in 1987 and activities of the National Air Toxics
Information Clearinghouse (NATICH) were also continued. Finally, a series of
national workshops were conducted to assist State and local agencies in the
basic aspects of program development and implementation.
F. STATUS OF AIR QUALITY MANAGEMENT PROGRAMS
On July 1, 1987, EPA promulgated its revised NAAQS for particulate
matter. The new indicator for particulate matter is called PMiQ. At the
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same time, EPA published new regulations for implementing and monitoring
the PMiu standards. These regulations initiated a program which requires
the States to develop revisions to the State implementation plans to attain
and maintain the new standards. Also published on July 1, 1987 was a
notice soliciting comment on the need for a rural fugitive dust policy and
presenting three alternatives to EPA's existing rural fugitive dust policy,
and an advance notice of proposed rulemaking on a fine particle standard.
Over the past two years, EPA has been considering how it should deal
with the continuing violations of the national ambient air-quality standards
for ozone and carbon monoxide in many urbanized areas across the country.
The latest date for attainment mentioned in the Clean Air Act was December
31, 1987, and it is -apparent that many areas would not be able to meet
this deadline. The Act does not provide explicit direction on how to
handle these "post-1987" situations although EPA believes that the Act
does provide some guidance. The EPA proposed its post-1987 policy in the
Federal Register on November 24, 1987. The proposed strategy incorporates
the kinds of measures that can be implemented by Federal, State, and local
governments. It lays out flexible deadlines that cities and States can
meet through careful planning and determined implementation. It includes
sanctions against areas that fail to make adequate progress and areas that
fail to develop plans that demonstrate attainment within a near-term,
fixed attainment date. It would prohibit construction of major new
facilities if ;ai.ta.inment of the standards is not-projected within three or
five^years of .-the EPA's "approval of required new" State implementation
plans.
Also in 1987, EPA continued to implement its Class I area visibility
protection regulations by approving State submitted implementation plans
and by promulgating Federal implementation plans to address integral
vistas and long-term strategies for those States that failed to submit
plans. These plans implemented the remaining portions of the regulations
promulgated by EPA in 1980 implementing section 169A of the Clean Air Act.
In 1985, EPA adopted revisions to regulations originally promulgated
in 1982 which prohibit reliance by stationary sources on stack heights in
excess of "good engineering practice" or on any other dispersion techniques
in lieu of emission controls. During 1986, EPA received SIP revisions from
the States in response to the stack height regulations and most revisions
pertaining to rule changes were processed by EPA by the end of 1987.
Several interested parties filed for judicial review of the revised stack
height regulations and, in addition, several of those parties also filed
petitions for reconsideration of those regulations. Some of the petitions
which dealt with a specific source were denied in 1986. Since the other
petitions dealt with the basic legal foundations for the regulations, EPA
deferred responding to them until judicial review of the revised regulations
was completed. The Court of Appeals for the D.C. Circuit responded to the
petition in January, 1988. While upholding most of EPA's regulations,
it remanded to EPA three issues relative to a grandfathering provision,
stack height credits allowed to certain pre-1979 sources, and certain
sources with merged stacks.
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With regard to the prevention of significant deterioration of air
quality (PSD) program, in 1987, EPA continued its progress in transferring
implementation of this program to State and local agencies. The majority
of PSD permits are now issued by these agencies. As of the end of 1987,
47 State and local agencies had either full delegation of the PSD program
or a PSD SIP, and 6 more had partial responsibility for the PSD program.
A matter of considerable controversy has 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 plantwi.de. definition that
was challenged by environmental groups and resulted in an appeal to the U.S.
Supreme Court. The Supreme Court upheld EPA's definition and, as a result,
EPA developed a policy in 1987 which will aid in the processing of SIP's
that pertain to the definition of source. This policy should significantly
accelerate the processing of revisions to the nonattainment portions of
SIP's.
In 1986, the Sierra Club and other environmental groups filed suit to
force EPA to develop PSD regulations for NOX, as required by section 166 of
the Clean Air Act amendment of 1977. The last of these suits was filed in
early February 1987. In April of 1987,-the court ordered EPA to develop
PSD regulations for NOX on an expedited schedule. Specific deadlines were
to propose regulations by February 9, 1988 and promulgate them by October 9,
1988. At the ind ofH987t EPA. was working toward completjon of a Federal
Register: proposal notice-in-order to meet the court-ordered requirements.
In 1987, EPA announced proposals to disapprove State clean air plans
for 14 metropolitan areas that have not shown they can achieve EPA's ozone
and/or carbon monoxide air quality standards by the end of 1987 or in the
near-term. Along with the disapprovals, EPA proposed bans on construction
in those 14 areas for major new sources and certain major changes to
existing sources of those air pollutants. The construction bans were
proposed to go into effect upon a final determination by EPA and would
prevent the approval of permits for building major new sources or modifica-
tions of existing sources of volatile organic compounds or carbon monoxide,
depending on the pollutant for which the area is not attaining the standard.
During 1987, EPA formed a task group to investigate the basic approaches
being used to review, comment on, and approve or disapprove revisions
submitted both to existing and to new SIPs. Major improvements in the SIP
processing system were recommended which dealt with the elimination of
excessive review within EPA and improvement in the certainty of the decision
process. Implementation of the recommendations of the task group will be
undertaken in 1988.
In 1985 and 1986, EPA initiated a program of studies related to
implementing possible acid deposition control programs that might be required,
These studies, called State Acid Rain (STAR) projects, were to be conducted
by individual States although the results could have broad applicability to
other States that might be involved in a possible acid rain control program.
By the end of 1987, work had been completed on 21 of the 46 total STAR
projects, and EPA began summarizing the results for a final report on the
program. Also, in 1987, EPA began an effort analogous to the STAR program
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to identify and study the implementation issues which will confront the State
public utility commissions in an acid rain program.
Also in 1987, EPA continued to provide technical training in the
abatement and control of air pollution. This training included short course
presentations (3 to 5 days in length), self-study courses, technical
assistance to others who conduct training, and the support of traineeships
and fellowships for graduate air pollution training.
G. CONTROL OF STATIONARY SOURCE EMISSIONS
In 1987, 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. During 1987, NSPS were promulgated for emissions of volatile
organic compounds from rubber tire manufacturing and volatile organic liquid
storage tanks and for SOg emissions from industrial boilers. The existing
NSPS for lime manufacturing plants was revised and the fossil fuel fired
steam generator standard was amended to provide alternative compliance
provisions for one power station. Standards were proposed for polymeric
coating, petroleum refinery wastewater, polymers manufacturing, and
residential wood combustion.
—The.EPA estabiished:1ih$;: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 report
published in 1987 contains over 1300 BACT/LAER determinations.
H. STATIONARY SOURCE COMPLIANCE
The EPA conducted a number of activities in 1987 to assure that stationary
sources of air pollution comply with emission standards. To do this, EPA
currently monitors the compliance status of over 36,000 stationary sources of
air pollution. Approximately 31,500 of these sources are Class A SIP sources,
about 3,5UO are NSPS sources, and about 1,000 are non-asbestos NESHAP sources.
At the end of 1987, compliance rates ranged from approximately 87 percent for
NESHAP sources to over 91 percent for Class A SIP sources.
The demolition and renovation of old buildings, often in densely populated
urban areas, can be a major source of asbestos exposure. Such sources are
regulated under the NESHAP for asbestos. During 1987, EPA and the States
received 43,496 asbestos demolition or renovation notifications, conducted
17,616 asbestos inspections, and found 2,191 violations.
The Clean Air Act provides a variety of administrative enforcement
mechanisms for dealing with both special situations and relatively easily
corrected violations. During 1987, EPA issued immediate compliance orders
under Section 113(a) of the Act to 185 sources (108 of which were asbestos
sources) and issued or approved delayed compliance orders under section H3(d)
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for three sources. In addition, ten cases were initiated in 1987 under
section 120 of the Act which is an administrative remedy designed to recoup
economic benefit which may come from violating air pollution control
regulations. The EPA is also authorized to file civil and criminal actions
in Federal District Court to compel a source to comply with applicable
requirements, to pay penalties, or both. A total of 73 Federal civil actions
were filed in 1987 against stationary sources for violations of the Clean
Ai r Act.
A major focus of the stationary source compliance program is the effort
to return to compliance those sources considered to be "significant violators."
For 1987, EPA identified 637 significant violators pending at the beginning
of the fiscal year. By the end of the fiscal year, 490 had been addressed.
Of these, 247 were returned to compliance, 108 were placed on an acceptable
compliance schedule, and 135 had an enforcement action pending. In addition,
583 significant violators were newly-identified during fiscal year 1987 and,
of these, 187 were addressed by the end of the fiscal year.
The EPA has concluded that in most major urban areas, small sources of
volatile organic compounds must be controlled if the ozone air quality
standard is to be reached. Consequently.,. EPA initiated a small source
compliance program in 1987 to encourage these sources to comply with existing
regulations. The special problems that small businesses experience have been
taken into consideration and each jurisdiction has been given enough flexibility
to allow- for innovative .and-cost efficient approaches, to "control..
Encouraging the installation and use of continuous emission monitors is
one component of EPA's continuous compliance effort. On July 28, 1987,
guidance was issued calling for increased use of continuous emission monitors
and integration of information reported by continuous emission monitors into
survei11ance/compliance activities.
The EPA also made significant progress in the area of enforcement-related
training. During 1987, EPA prepared a multilevel curriculum for EPA personnel
engaged in stationary source compliance inspections. The objectives are to
ensure that every inspector can conduct advanced levels of inspection and
that experienced personnel can stay current and can develop specialized
skills.
A number of significant enforcement actions were decided by the courts
in 1987. In United States v. Ford Motor Co., the Sixth Circuit held that the
U.S. can enforce the current federally-approved State implementation plan even
though the defendant and the State of Michigan had entered a consent judgment
in State court invalidating the SIP regulation. In United States v. Wheeling-
Pittsburgh Steel Corp., the Third Circuit also ruled that Federal enforcement
of an existing SIP could proceed despite the pendency of a SIP revision.
However, in American Cyanamid Co. v. EPA, the Fifth Circuit held that the
agency could not pursue a section 120 penalty action until it rejected a
State-proposed SIP revision which would have put the company in compliance.
With regard to compliance by Federal facilities with air pollution
control requirements, a total of 369 Class A SIP, NSPS, and NESHAP Federal
facilities are tracked in the air program. As of September 1987, 302
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(81 percent) were in compliance, 11 were meeting schedules that will bring
them into compliance, 26 were in violation and not yet on an acceptable
schedule, and 7 were of unknown compliance status.
Section 306 of the Clean Air Act provides the authority for EPA to place
facilities on the List of Violating Facilities, thereby prohibiting any
Federal agency from procuring goods or services produced at that facility.
During 1987 EPA listed two facilities under the Clean Air Act as a result of
criminal convictions for violations of the asbestos removal standards, removed
three facilities from the list, handled one appeal, andr.rev-iewed three recommen-
dations to list. At the end of 1987, there were three facilities on the list
for Clean Air Act violations, one decision.to list pending appeal, and two
listing proceedings pending,
I. CONTROL OF MOBILE SOURCE EMISSIONS
The EPA made significant progress in 1987 in implementing its mobile source
control program. With the increased focus on reducing ozone levels, EPA has
continued work on several areas directly aimed at this goal. One of the key
actions is controlling excess evaporative-emissions through regulation of
in-use gasoline" volatility. The EPA.-proposed a rule in 1987 on gasoline
volatility and a final rule is expected in 1989. In addition, EPA proposed a
rule establishing refueling emission standards for automobiles along with the
gaso-Tinervolatility prop~os-a-}V Another ozone-related action taken by EPA in
1987 was the continued development of a notice of proposed rulemaking which
would tighten the light-duty truck exhaust hydrocarbon standard. Publication
of the proposal is expected in 1988.
Three EPA initiatives were related to vehicle fuels in 1987. In the
first, EPA began to develop a comprehensive study of the potential costs and
benefits of reducing the sulfur and aromatics content of diesel fuel, an
action that may lead to significant reductions in particulate emissions from
diesel engines. A second initiative was a proposal to establish testing
protocols to determine the health effects of fuels and fuel additives.
Finally, a motor vehicle assessment for an Agency-wide task force on
formaldehyde exposure and control strategies was completed.
The lead phasedown program required by EPA continues to achieve significant
reductions in the use of lead in gasoline, from ten billion grams in 1986 to
six billion in 1987. This represents a 97% decrease from the 206 billion
grams of lead which were used in gasoline in 1973. In 1987, EPA and the U.S.
Department of Agriculture (USDA) issued a study on the use of low-leaded
gasoline (0.10 grams per leaded gallon) and unleaded gasoline in agricultural
equipment designed for leaded gasoline, as required by the 1985 Farm Bill. A
report to the President and the Congress was drafted for issuance in early
1988. As part of the program to reduce lead in gasoline, EPA prepared a
final rule eliminating lead in test fuel in 1987. This will mean that
manufacturers of engines not requiring catalysts, such as certain heavy-duty
gas-powered engines, must meet emission standards using unleaded gasoline.
The EPA pursued several other mobile source regulatory activities in 1987.
In anticipation of the development of methanol as an alternative fuel, EPA
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moved forward in the development of emission standards for methanol-fueled
vehicles. The EPA held a workshop on and began developing a proposed rulemaking
to permit the banking and trading of oxides of nitrogen and participate
matter emission credits among heavy-duty gasoline, diesel, and methanol
engine manufacturers. The EPA continued to promulgate nonconformance penalties
for those heavy-duty engine families unable to meet certain standards applicable
to a given model year. A proposal to increase the stringency of the 1991
light-duty diesel truck particulate standard for light-duty trucks with
heavy-duty engines and to propose nonconformance penalties was published in
1987. In addition, EPA incorporated newly received emissions data into a
study of railroad emissions which it has been conducting. The complete study
is scheduled for release in 1988.
One of EPA's key techniques for assuring the compliance of vehicles with
the motor vehicle emissions standards is the preproduction certification
program. Initiated in 1968, the program involves the engineering review and
testing by EPA staff of engine families representing new vehicles which are
to be sold in the United States. The EPA's National Motor Vehicle Emission
Laboratory performed over 2,500 emission tests on 750 preproduction prototype
vehicles and 500 in-use vehicles in 1987.
An effective strategy for dealin.g:with 1 n-use emissions problems is the
establishment of motor vehicle inspection and maintenance (I/M) programs.
In 1987, EPA continued to promote the implementation of I/M programs in each
local-ity-where they were :rfeeded. By the end of the year,'60 of 64 areas had
initiated programs. To assure that operating I/M and antitampering programs
actually achieve the planned emission reductions, EPA has initiated a systematic
I/M auditing plan. In 1987, EPA notified governors or other high officials
in 6 states that major problems had been found, and requested corrective
plans. In addition to I/M programs, EPA has promoted the implementation of
State and local antitampering and anti-fuel switching enforcement programs.
By the end of 1987, 36 programs had been implemented.
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. In order to assure that production vehicles
and heavy-duty engines are built in accordance with emissions standards, EPA
conducts Selective Enforcement Audit (SEA) test programs at manufacturers'
facilities. In 1987, EPA conducted 22 SEA'S, including four at foreign
manufacturer's facilities, with a new effort in testing heavy-duty engines
for compliance. 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 their useful lives. During 1987,
a total of 1,537,000 vehicles were recalled as a result of EPA investiga-
tions. In the same period, manufacturers voluntarily recalled an additional
1,408,706 vehicles to correct emissions problems. The EPA has greatly increased
its lead phasedown enforcement activities. In 1987, EPA issued 18 Notices of
Violation (NOV's) in this area with $24 million in proposed penalties. In a
related area, EPA relaxed restrictions on a fuel additive waiver for a methanol
blend in 1987. This is expected to become an increasingly important area in
response to the ongoing lead phasedown program, as refiners experiment with
various additives as substitutes for lead in vehicle fuel. The EPA is also
responsible for carrying out programs designed to deter tampering with vehicle
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emissions control systems or using leaded fuel in vehicles which require
unleaded fuel. Surveys undertaken by EPA in 1987 show that tampering and
fuel switching are continuing serious problems which undermine the emissions
control performance of many in-use vehicles. Tampering and fuel switching
enforcement activities continued in 1987 with the issuance of 297 notices of
violation with proposed penalties of $2.6 million. In addition, EPA is also
responsible for assessing whether the Federal emission warranty requirements
of sections 207(a) and (b) of the Act are implemented. During 1987, EPA
responded to a total of 1,253 inquiries in this area.
The control of emissions from imported vehicles has become a major
issue in recent years. In 1987, EPA received 2U,OUO applications and
29,000 inquiries concerning these automobiles. Also in 1987, EPA promul-
gated a final rule updating its regulations controlling these automobiles.
The goal of these rules is to streamline the process for demonstrating
compliance with Federal emission requirements. The EPA has also been
investigating various laboratories to ensure that nonconforming imports
have been tested properly to demonstrate conformity with U.S. emissions
standards. In 1987, EPA successfully prosecuted five laboratories resulting
in 27 individual convictions and one corporate conviction for falsifying
test results. --
Several mobile source litigation actions took place in 1987. In one,
a U.S. District^eourk in New York City imposed a judgment for $180,000
agai-ost.-.a corporation fOF--«r--violation of the fuels provis-lons of section 211
of the Clean Air Act. Enforcement of lead phasedown also resulted in
criminal prosecution of individuals. At least two criminal cases were
pending at the end of 1987 which were developed in the course of EPA
investigations. Other cases, including four related cases with potential
penalties of $40 million, are currently pending. The EPA also issued notices to
eighteen refiners or importers proposing a total of $24 million in civil
penalties. In addition, in 1987 EPA continued to pursue litigation activities
against manufacturers and installers of devices designed to illegally replace
automotive catalytic converters.
J. STRATOSPHERIC OZONE PROTECTION
On December 14, 1987, EPA proposed regulations pursuant to section 157(b)
of the Clean Air Act to implement the Montreal Protocol on Substances that
Deplete the Ozone Layer, which was signed by 24 nations in September 1987.
Currently, 30 nations including all the major chlorofluorocarbon producers
have signed the Protocol. This landmark environmental agreement calls for a
50 percent reduction in use of CFC's and a freeze on use of halons over the
next ten years. By reducing the future use and emissions of CFC's and halons,
these restrictions will help to protect the earth's stratospheric ozone layer.
The EPA proposed that control requirements only take effect if the United
States ratifies the Protocol and following its entry into force. The Protocol
is expected to enter into force on January 1, 1989, following ratification by
eleven nations representing two-thirds of global consumption. The United
States ratified the protocol in April 1988.
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K. RADON ASSESSMENT AND REMEDIATION
The goal of EPA's Radon Action Program is to significantly reduce the
health risks of radon through a partnership with other Federal agencies and the
States. The Radon Action Program's initial efforts in 198b were concentrated in
the Reading Prong area of Pennsylvania, New Jersey, and New York where elevated
levels of indoor radon were first discovered in homes. The EPA provided these
States with assistance in radon measurement and mitigation of radon exposure in
affected homes. Since then, high radon levels have been found in nearly every
State and program activities were expanded in 1986 and t987 in response to the
growing scope and complexity of the radon problem. To accomplish its goal, EPA
continues to develop and disseminate technical knowledge to encourage, support,
and facilitate the development of State programs and private sector capabilities
to reduce exposure to radon. The EPA's program focuses upon problem assessment,
mitigation and prevention, capability development and public information.
While much of EPA's activity was initially directed at States in the Reading
Prong area, the Radon Action Program is now assisting States throughout the
country. Technical assistance activities will continue as an increasing number
of States, Indian Nations and Federal agencies work to identify and address radon
exposure problems. The EPA will also cojitinue to expand its technical assistance
capabilities in' response to the increasing complexity of the radon problem.
L. XlTTGATION" " i:~~ -• - '•
During 1987, two significant precedent-setting cases involving the Clean
Air Act were decided in the courts. In a major ruling on EPA's obligations
under section 112 of the Clean Air Act (NRDC v. Thomas), the entire D.C.
Circuit held that while consideration of costs and feasibility is not precluded
for purposes of setting standards for hazardous air pollutants, EPA must first
determine a level representing an "acceptable risk." The court also concluded
that section 112 does not require elimination of all risk, but that EPA
should follow a process under which a decision is first made on a level
representing an "acceptable risk" for a pollutant, followed by a second
step in which cost and feasibility could be considered in providing an "ample
margin of safety." The decision of the court modified a previous panel
decision in the same case, issued in 1986, that upheld EPA's approach in all
respects.
In another case of great significance to EPA's program for areas with
serious nonattainment problems, the Ninth Circuit overturned EPA's partial
approval of ozone and carbon monoxide SIP's for California's South Coast air
basin, and ordered EPA to disapprove those SIP's for failure to meet the
statutory requirements for attainment by December 31, 1987 (Abramowitz v.
EPA). The EPA had initially approved the control measures in the SIP, but
withheld approval or disapproval as to attainment. The court held that the
Act does not authorize EPA to approve control measures independent of a
determination on whether the SIP demonstrates attainment.
In addition to the Abramowitz decision discussed above, three other
significant suits which had been filed to force State and Federal agencies to
revise, implement, or promulgate SIP's were decided in 1987. In Natural
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Resources Defense Council (NRDC) y. New York State Department of Environmental
Conservation, the district court held that the plaintiffs were entitled to a
finding of liability regardless of the State's reasons for failing to carry
out its obligations, and ordered the State to promulgate certain regulations,
including those addressing installation of gasoline vapor recovery devices on
service station pumps. In American Lung Association of New Jersey v. Kean,
the court rejected the State's good faith intentions, and interpreted New
Jersey's 1983 SIP submission as binding, judging that any ambiguities in the
SIP would properly be construed against the creator of the SIP—the .State
itself. In Wilder v. Thomas, the court held that the faj.lure of the SIP to
attain the national standard was not, in and of itself, a violation of a
condition or requirement of a SIP, or otherwise actionable under the citizens
suit provision of the Act.
In another decision, the Ninth Circuit upheld EPA's disapproval of an
Arizona SIP revision for total suspended particulates and new source review,
and imposition of a construction ban against a challenge by the State. In a
second decision related to Arizona, the Ninth Circuit also upheld EPA's
decisions to disapprove Arizona's carbon monoxide SIP's for the Tucson and
Phoenix areas, and to impose construction .bans.
In a case-related to the prevention, of significant deterioration
provisions of the Act, a citizens group sued to compel EPA to issue regulations
to prevent significant detfir.loration of air quality from emissions of nitrogen
oxides.-The EPA admitted-it trad failed to issue such regulations as required by
the Clean Air Act and the opinion focused on how fast EPA should be required
to act. The court imposed a deadline equivalent to the amount of time Congress
originally allotted to EPA for taking the action. In a second related case,
the D.C. Circuit dismissed a petition seeking to require EPA to complete
rulemaking on whether strip mines should be subject to regulations governing
fugitive dust. The court judged that a three year delay since issuance of
proposed rules was not unreasonable under the circumstances.
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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 1986, the latest year for which EPA has complete.'statistics.
A. NATIONAL AIR QUALITY AND EMISSION TRENDS
Although considerable progress has been made controlling air pollution,
it still remains a serious public health problem. In 1986, 75.0 million
people were living in counties with measured air quality levels that violated
the national ambient air quality standard for ozone. This compares with 41.7
million people for total suspended particulate, 41.4 million people for
carbon monoxide, 7.5 million people for nitrogen dioxide, 4.5 million people
for lead and 0.9 million people for sulfur dioxide.
Nationally, long-term 10-year (1977 through 1986) improvements can be
seen for TSP, sulfur-dioxide, carbon monoxide, nitrogen dioxide, ozone,
and ..Had, The. trend in-Qzone^is complicated by: a major drop in measured
concentration'levels which occurred between 1978 and 1979, largely due to a
change in the ozone measurement calibration procedure. Therefore, special
attention is given to the period after 1978, because the change in the
calibration procedure is not an influence during this time.
The 10-year trend (1977-1986) is complemented with a more recent 5-year
trend (1982-1986). The 5-year trend increases the number of sites available
for trend analysis. Emphasis is placed on the post-1981 period to take
advantage of the larger number of sites and the fact that the data from this
period should be of the highest quality, with sites meeting uniform siting
criteria and high standards of quality assurance. Nationally, improvements
can be seen for all the pollutants during the 5-year period.
All of the ambient air quality trend analyses are based on monitoring
sites which recorded at least 8 of the 10 years of data in the period
1977 to 1986 or 4 out of 5 years in the period 1982 to 1986. Each year
had to satisfy an annual data completeness criterion.
Total Suspended Particulate (TSP) - Annual average TSP levels, measured
at 1,435 sites, decreased 23 percent between 1977 and 1986. This corresponds
to a 25 percent decrease in estimated particulate emissions for the same
period. Air quality levels for TSP generally do not improve in direct
proportion to estimated emission reductions, however, because air quality
levels are influenced by factors such as natural dust, reentrained street
dust, and construction activity which are not included in the emissions
estimates. The EPA has also found that the TSP data collected during the years
1979-1981 may be biased high due to the glass fiber filter used during
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these years, and that most of the large apparent 2-year decrease in pollutant
concentrations between 1981 and 1982 can be attributed to a change in these
filters. The more recent TSP data show a leveling off with a 3 percent
decrease in ambient TSP levels and a 4 percent decrease in estimated emissions
for the 1982-86 time period. Some minor year-to-year fluctuations may in
part be attributable to changes in meteorological conditions such as
precipitation. On July 1, 1987, EPA promulgated new standards for particulate
matter using a new air quality indicator, particles nominally 10 micrometers
and smaller in diameter (PMio). rather than TSP. (See Chapters IV and VI for
more information related to the PMio air quality standard.) These standards
focus on those particles with aerodynamic diameters smaTler than 10 micrometers,
which are likely to be responsible for adverse health effects because of
their ability to reach the thoracic or lower regions of the respiratory
tract. Monitoring networks for PMio are now being deployed nationally and
future reports will present analyses based on the new particulate matter
standards.
Sulfur Dioxide - Annual average sulfur dioxide levels measured at 302
sites with continuous sulfur dioxide monitors decreased 37 percent from 1977
to 1986, improving at a rate of approximately 4 percent per year. 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 improvement was observed
in the estimated number of exceedances of the 24-hour standard, which decreased
98 percent. Howeverr most of the exceedances as well as the bulk of the
improvements occurred atvsoor^e-oriented sites including a few smelter sites
in particular^ There was a 21 percent drop in sulfur oxide emissions during
this 10-year period. The difference between emissions and air quality trends
can be attributed to several factors. Sulfur dioxide monitors with sufficient
historical data for trends are mostly urban population-oriented and as such
do not monitor many of the major emitters which tend to be located in more
rural areas. The residential and commercial areas, where most monitors are
located, have shown sulfur oxide emission decreases comparable to the sulfur
dioxide air quality improvements.
Carbon Monoxide - Nationally,,the second highest non-overlapping 8-hour
average carbon monoxide levels at 182 sites decreased 32 percent between 1977
and 1986. The median rate of improvement has been about 4 percent per year.
The estimated number of exceedances of the 8-hour national ambient air quality
standard decreased 89 percent between 1977 and 1986. Emissions of carbon
monoxide decreased 26 percent during the same period. Because carbon monoxide
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. The 1985 and 1986 levels are similar and
indicate improvement relative to previous years.
Nitrogen Dioxide - Annual average nitrogen dioxide levels, averaged over
111 sites, increased from 1977 to 1979, and decreased through 1986, except
for a slight increase in 1984. The 1986 composite nitrogen dioxide average,
however, is 14 percent lower than the 1977 level indicating a downward trend
during the overall period. The trend in the estimated nationwide emissions
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of nitrogen oxides is similar to the nitrogen dioxide air quality trend.
Between 1977 and 1986, total nitrogen oxide emissions decreased by 8 percent,
and highway vehicle emissions, the source category likely impacting the
majority of nitrogen dioxide monitoring sites, decreased by 13 percent.
Between 1985 and 1986, the nitrogen dioxide composite average remained constant
while the estimated emissions of nitrogen oxides decreased by 2 percent.
This small year-to-year difference between the ambient levels and the emissions
percent change is likely not significant given the relatively low ambient
nitrogen dioxide levels.
Ozone - Nationally, the composite average of the second highest daily
maximum 1-hour ozone values, recorded at 242 sites, decreased 21 percent
between 1977 and 1986. However, this comparison is affected by a calibration
change for ozone measurements that occurred in the 1978-79 time period. In
the post-calibration period (1979-1986), ozone levels decreased 13 percent.
Volatile organic compound (VOC) emissions decreased 19 percent for the 1977-86
10-year period and 20 percent for the post-calibration 1979-86 period. The
estimated number of exceedances of the ozone standard decreased 38 percent
between 1979 and 1986. The ozone trend in the post-calibration period shows
1979, 1980, and 1983 being higher than the other years. Meteorological
conditions, likely contributed to the higher 1983 levels.
Lead - The composite maximum quarterly average of ambient lead levels,
recorded at 82-urbarv sites, decreased 87 percent between 1977 and 1986. Lead
emissiofls declined 94 percent during the same period. In order to increase
the number of trend sites, the 1982 to 1986 time period was examined. During
this period, a total of 326 urban trend sites measured a 68 percent decline
in ambient lead levels, while lead emissions were estimated to have decreased
by 84 percent. Between 1985 and 1986 ambient lead levels declined 35 percent,
while lead emissions are estimated to have declined 59 percent. This extremely
large decrease in both air quality levels and estimated emissions is largely
due to the reduction of the lead content of leaded gasoline.
B. AMBIENT AIR MONITORING
General
Section 110(a)(2)(C) of the Clean Air Act requires State implementation
plans to include provisions for the 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 stations and report the data to EPA.1
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 regulations. 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
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requirements in the regulations. The SLAMS had until January 1, 1983 to
meet all of the provisions in the regulations. Based on 5 years of operating
experience with the NAMS and SLAMS networks, some relatively minor modifications
of the 1979 regulations were promulgated in the Federal Register in 1985.2
These modifications were intended to simplify and improve the overall monitoring
program required by the Act.
Overall, State and local progress in meeting the requirements of the
regulations continues to be excellent. Table II-l shows the status of the SLAMS
network at the end of 1987. There are a total of 4,187 operating monitors in
the network meeting requirements of the regulations. Table 11-2 shows that 1,260
NAMS were in operation and meeting the requirements of the regulations through
December 1987. Table 11-3 lists, by pollutant, the number of SLAMS and NAMS.
Table II-l. SLAMS Status Through December 1987
Number of
Monitors
Monitors operatidnarthrough 12/87 " 4,742
Total planned network for 1988* 4,567
*Includes NAMS monitors and includes 583 PMjo sites
which will become part of the SLAMS network during 1988.
Table I1-2. NAMS Status Through December 1987
Number of
Monitors
Monitors operational through 12/87 1,255
Total planned network for 1988 955*
*Total reflects the removal of 573 TSP sites and the
addition of 273 PMio sites during 1988.
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Table I1-3. National Summary of Operating Air
Monitoring Stations Us of 12/87)
Pollutant
TSP
PMio
S02
N02
CO
03
Pb
—TOTAL
SLAMS
(including NAMS)
2,028
583
494
226
448
610
153
4,742
NAMS
573
-
179
58
118
217
110
.1,255
Particulate Monitoring
To accompany the proposed revisions to the national ambient air quality
standard for particulate matter discussed elsewhere in this report, on July
1, 1987, EPA also promulgated amendments to 40 CFR 58 (Air Quality Surveillance
and Reporting Regulations).3 The revisions to Part 58 establish ambient air
quality monitoring requirements for particulate matter as measured by a new
reference method proposed as Appendix J of 40 CFR Part 50 or an equivalent
method. The requirements are comparable to those already established for the
other pollutants for which air quality standards have been set. These
include requirements for reporting and assuring the quality of ambient
particulate matter data, designing monitoring networks, and the siting of
samplers. Since most areas of the country did not have particulate matter
ambient monitoring data, EPA, in late 1984, procured 662 particulate matter
samplers for distribution to State and local agencies. Since then funds have
been allocated each year to procure additional particulate matter samplers.
Specialized training was provided by EPA to State and local agency personnel
on the operation and maintenance of the particulate matter samplers. Also,
the States and local agencies have separately purchased particulate matter
samplers, bringing the total number of operating particulate matter samplers to
884 at 583 sites as of December 31, 1987. The data from these sites will be
used by the States in developing particulate matter State implementation
plans.
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Nonmethane Organic Compounds Monitoring
Ambient hydrocarbon data were collected at 32 sites during 1987. This
was the fourth consecutive summer of field studies to measure nonmethane
organic compounds (NMOC) in various cities. These data are needed to derive
NMOC/oxides of nitrogen ratios, an important factor in predicting the effect
of control programs to reduce ozone. As in past years, data capture was high
and results were reproducible using different measurement techniques. Need
for a similar program is envisioned for 1988.
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.
Regu1atory_ Applications
During 1987 efforts to improve guidance on air quality models and to
ensure consistency in their use continued. An air quality model clearinghouse
was maintained to ensure that use of nonguideline techniques does not lead to
inconsistent regulatory decisions. A workshop was held with modeling contacts
in EPA's ten Regional Offices and five representative State agencies to improve
communications on the use of models and to resolve common problems.
Regulatory action to update the "Guideline on Air Quality Models (Revised)4"
continued with preparation of Supplement A which incorporates a new third level
screening model, the Rough Terrain Diffusion Model (RTDM), adds a revised
version of the Industrial Source Complex (ISC) model, lists the Offshore
Coastal Dispersion Model as a preferred model for specific applications, and
adds the AVACTA II model to the list of those models that can be used on a
case-by-case basis. Notice of final rulemaking should take place in 1988
with distribution of Supplement A shortly thereafter.
All air quality dispersion model computer codes that support the regulatory
guidance were transferred to EPA's new IBM 3090 system located at the National
Computer Center at Research Triangle Park, North Carolina. Several supporting
systems and procedures were also transferred and included significant enhancements
allowing for greater user accessibility. For 1988, it is anticipated that
several of the regulatory models will be converted for operation on EPA's
personal computers.
Also during 1987, EPA continued to provide technical support and review
of ozone model applications using the Empirical Kinetics Modeling Approach
(EKMA). The EKMA is widely used by State and local agencies to estimate
emission controls necessary to attain the ambient air quality standard for
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ozone. The EKMA computer program was upgraded and several draft documents
describing how to apply EKMA are undergoing public comment. During 1988,
EKMA will undergo further evaluation and will be revised to incorporate public
comments.
To resolve issues associated with the analyses of State implementation
plans for carbon monoxide, discussions were held with the Federal Highway
Administration (FHWA) regarding requirements and procedures for modeling roadway
intersections. A joint FHWA/EPA work group was formed to determine.the most
appropriate techniques for modeling intersections. In 1988 studies will be
conducted to compare the emissions and traffic components of several available
intersection models. A number of FHWA/EPA work group meetings will be held to
arrive at a consensus on the most technically sound intersection modeling
procedure. Guidance from both agencies will then be revised to reflect the
recommendations.
Receptor models are data analysis tools frequently used to supplement air
quality models or to replace them when appropriate dispersion techniques are
unavailable. During 1987, EPA continued work on receptor models by finalizing
the "Chemical Mass Balance (CMB) User's Manual."5 Operation of the CMB program
was described, along with further guidance on validating CMB applications and
reconciling differences between receptor and dispersion model results. During
1988, computer software which facilitates application of the CMB model, and
helps users to—review default^ source profiles, in.-the U.S.. EPA Receptor Model
Source Composition Library will be developed. In addition, active assistance
to States will be provided in applying receptor models to develop effective
State implementation plans for attainment of the PM^g air quality standards
promulgated in 1987.
In June 1987, EPA published the document "On-site Meteorological Program
Guidance for Regulatory Modeling Applications."6 This report provides EPA's
guidance on the collection and use of on-site meteorological data intended for
use in regulatory modeling applications. Recommendations are provided regarding
specific procedures and methods from sensor selection and siting to data
processing and quality assurance. Members of the work group responsible for
preparing the document will continue their efforts in 1988 by reviewing and
initiating the evaluation of techniques and procedures for determining on-site
atmospheric stability.
Planning began in 1987 for the Fourth Conference on Air Quality Modeling.
Section 320 of the Clean Air Act specifies that this conference be held every
three years. The intended purpose of the next conference will be to report
to the public on new models, procedures and related modeling issues being
considered by EPA. The public will be invited to respond in a way that
guides EPA in preparing any future notice of proposed rulemaking to revise
the modeling guideline. The conference is being planned for September 1988
in Washington, D.C.
Air Toxics
Efforts were continued during 1987 to strengthen EPA's capabilities for
modeling potential releases of toxic chemicals into the atmosphere. A refined
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model for the elevated, high-momentum release of heavier-than-air gases
(such as might occur in the operation of a pressure relief safety valve) was
developed under contract and is currently being assessed. Development of a
model for estimating airborne concentrations from mechanical draft-cooling
towers was completed in 1987, and the model is currently being used to assess
the impact of chromium emissions from such towers. Plans for 1988 include the
development and implementation of a refined modeling program which will more
accurately predict the combined impact of continuous and short-duration pol-
lutant emissions as well as the geographical extent of this impact under
various meteorological conditions. ~
In addition, a major effort undertaken in 1987 involved the application of
integrated air emission and dispersion models to facilities that treat, store
and dispose of hazardous wastes. These models were used to estimate ambient
concentrations of a large number of potentially hazardous substances emitted
from the facilities. The concentration estimates were used to assess both
carcinogenic and noncarcinogenic health effects associated with exposure to
concentrations at the estimated levels. The results are being incorporated in
the EPA program to determine the appropriate limits on air emissions of
hazardous substances needed at these types of facilities. During 1988,
supplemental modeling analyses will be performed in support of establishing
these emission limitations.
Regional tteone Modelin.g.jf.or Northeast Transport (ROKNET)
The ROMNET is a three year program to apply the EPA regional oxidant model
for selected regional emissions control strategies on the Northeast. The
program is designed to provide States, EPA and other planning organizations
with information on the effectiveness of such strategies in reducing ozone
concentrations in this region and also the data bases to support urban scale
modeling for use in the development of State implementation plans. During 1987
the program protocol was prepared and distributed to participants for review.
Outputs for 1988 will include establishing the management and technical
committees which will be conducting the program, selection of episodes for
mode! application, preliminary identification of regional strategies of
interest, and completion of the base year emissions inventories.
Model Evaluation
During 1987 EPA continued its program to evaluate air quality models.
This program was developed in response to recommendations of the American
Meteorological Society (AMS) under its cooperative agreement with EPA. A
statistical technique for intercomparing the performance of air quality
simulation models was developed and tested using two rural air quality
evaluation data bases. The technique relies on the bootstrap resampling
procedure which results in confidence limits on the overall relative
performance of two or more models. An important by-product of the bootstrap
procedure is the ability to translate estimates of model reliability into
confidence statements regarding the probable success of regulatory decisions.
During 1988, EPA plans to develop additional information regarding how model
accuracy may be used to determine confidence in model-based emission control
1imits.
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In addition, the evaluation of toxics models was initiated in 1987.
Toxic pollutant release types, models, and test data sets were identified.
In 1988, test data set archiving and model selection will be completed and
model performance evaluations will be initiated.
D. INTEGRATION OF AIR DATA SYSTEMS
The Aerometric Information Reporting System (AIRS) is a new integrated
data system being developed by EPA to entirely replace the existing data bases,
files, and software now used by EPA for storing and retrieving ambient air
quality data, stationary source emissions, and compliance data. The AIRS is
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 1986 the air quality component of AIRS went into full production within
the Agency and was also installed in six pilot State agencies. Full implementation
in another 19 State agencies was under way in 1987 with training, user manuals,
and troubleshooting services being provided to the user community. Design of
the integrated AIRS Facility Subsystem proceeded well during 1987 with the
production system scheduled to be implemented by EPA in 1989. Replacement of
existing software used by State agencies will begin in 1990.
E. EMISSION FACTOR DEVELOPMENT
In 1987, EPA published major revisions to emission factors for use by
States and others to estimate source emissions and to compile emission
inventories. Emission factor information is published and distributed for
criteria pollutants in a publication entitled Compilation of Air Pollutant
Emission Factors, AP-42.7 The revisions were published in Supplement A#
and distributed in early February 1987. Nearly all these revisions involve
additions of size-specific emission factors, with emphasis on PMiu* f°r use in
implementing the new PMio ambient air quality standard promulgated in 1987.
Additional criteria pollutant emission factors are being readied for publication
in another AP-42 supplement in 1988.
F. REFERENCES
1. 44 FR 27558, May 10, 1979.
2. 50 FR 9538, March 8, 1985.
3. 52 FR 24634 July 1, 1987.
4. "Guideline on Air Quality Models (Revised)," EPA 450/2-78-027R, 1986.
5. "Receptor Model Technical Series, Volume III (Revised) -- User's Manual
for Chemical Mass Balance Model," EPA 450/4-83-014R, 1983.
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6. "On-Site Meteorological Program Guidance for Regulatory Modeling
Applications," EPA 450/4-87-013, 1987.
7. Compilation of Air Pollutant Emission Factors, Volume I. Stationary
Point and Area Sources, AP-42, U.S. EPA. Research Triangle Park, N.C.,
September 1985.
8. Supplement A to Compilation of Air Pollutant Emission Factors,
Volume I, Stationary Point and Area Sources, AP-42,-U^S. EPA, Research
Triangle Park, N.C., November 1986.
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III. AIR POLLUTION RESEARCH PROGRAMS
A. INTRODUCTION
In support of the Clean Air Act, EPA's Office of Research and Development
(ORD) provides health and ecological effects data bases, monitoring and model-
ing methods, risk assessments, emission reduction and mitigation technologies,
and the corresponding quality assurance and technical assistance to develop
regulations. In addition, ORD assists States in developing State implementation
plans (SIP's) by providing improved monitoring, modeling, and control technology
as they become available. In areas where EPA's responsibility is limited to
providing technical and public assistance, such as indoor air quality and
radon, ORD research provides essential information on risks, prevention, and
mitigation.
B. GENERAL AIR POLLUTION RESEARCH ACTIVITIES
Significant changes were made in tfrve focus of EPA's air pollution research
program in 1987. The EPA began a program to study the effects of global climate
change and possible strategies for eliminating or controlling emissions of
compounds which:-contribute to global climate change. In view of the considerable
problems- associated with attaining national ambient air quality standards
(NAAQS) for ozone, EPA accelerated efforts to refine the Regional Ozone Model
and to improve technologies for controlling emissions of nitrogen dioxide
(N02) and volatile organic compounds (VOC's).
For several years, ORU has maintained a small program to study the
effects of increased levels of ultraviolet radiation in the 290 to 320
nanometer wave band (UV-B) on crops. Increases in UV-B radiation result from
depletion of ozone in the stratosphere. In 1987, research on compounds which
contribute to stratospheric ozone depletion was begun. Also in 1987, EPA
developed an indoor air implementation plan and initiated work to develop a
long-range research strategy for indoor air.
Scientific Support to Develop and Review National Ambient Air Quality
Standards
Air Quality Criteria Documents - Work began on revision of the criteria
documents for carbon monoxide (CO) and oxides of nitrogen (NOX). An issue
paper on the health effects of acid aerosols was drafted and peer reviewed in
June 1987.1 Research-needs documents for ozone and lead were prepared and
reviewed in April by the Clean Air Scientific Advisory Committee, a standing
committee of EPA's Science Advisory Board.2,3.
Ambient Monitoring - In association with the July 1, 1987 regulatory
changes which required monitoring of ambient particulate matter in the size
range of 10 micrometers and smaller (PMio). a new reference method and procedures
for designating reference and equivalent methods for PM^Q were promulgated.
These are for use by States in their compliance monitoring networks. Two new
chapters to Volume II of the Quality Assurance Handbook were prepared which
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address quality assurance and quality control procedures for current versions
of PM^o samplers. A nonmethane organic compound (NMOC) monitoring project was
carried out during the summer of 1987, the fourth in a continuing series to
assist States in meeting current ozone national ambient air quality standards
and to provide data needed by the agency in considering revisions to the
ozone air quality standards. A seventh site was added to the network of the
National Bureau of Standards (NBS)-Certified Standard Reference Photometers
(SRP) that has been established to allow State and local air monitoring
agencies to compare their ozone standards with authoritative NBS. standards.
Quality Assurance - In accordance with the 1986 revisions to 40 CFR
Part 58 Ambient Air Quality Surveillance, raw precision and accuracy data
from each State and local air monitoring station (SLAMS) must be reported to
EPA beginning January 1, 1987. With these data, probability limits are
computed for each site and are made available to the originating agencies
within a week of receipt of the data. These data will enable assessments and
comparisons to be made on a site-by-site basis. Further, all data reported
are identified by the specific method used at each site. Comparisons of the
performance of the various methods for each pollutant measurement are now
being made to identity where new or impcaved methods and quality assurance
materials and procedures are needed. In 1987, capabilities of EPA and the
State and local agencies to assess the performance of PMio dichotomous samplers
and continuous_Np2. monitors was sharply improved by development of audit
materials for dichotomous-fJow and NOg monitors. These a-udit materials will be
introduced into the National Ambient Air Performance Audit Program in early
1988.
Health Effects: Clinical Studies - Researchers in EPA's clinical
laboratory observed pulmonary function and symptom responses in normal humans
exposed to 0.12 ppm ozone for six and three-quarter hours. A follow-up to
that study was begun to evaluate the concentration response at three different
levels of ozone. The results of these studies will be used in conjunction
with studies of pulmonary immune effects to determine the need for a long-term
ambient air quality standard for ozone.
Several questions were answered about the effects of criteria pollutants
in asthmatics. First, in a study of N02 effects, mildly asthmatic subjects
were exposed to one of three levels of N02 (0.15 - 0.60 parts per million
[ppm]) while performing light exercise. No measurable pulmonary effects
were seen, thus indicating that NOg at these levels does not aggravate breathing
problems in mild asthmatics. In a similar study of sulfur dioxide ($02),
bronchoconstriction was observed in mild asthmatics during two minutes of
moderate exercise while breathing air containing 1.0 ppm S02. Results of
another study of S02 in asthmatics were published in the American Review of
Respiratory Diseases.4 This study described the effects of continuous versus
intermittent exercise in asthmatic subjects during exposure to S02. Another
study was initiated in 1987 to determine the effects of S02, exercise, and
cold or dry air on airway responses in asthmatics. To increase accuracy and
consistency in studying the relationship between pollutant exposure and
response in asthmatics, a method was devised to rank the severity of asthma,
based on symptoms and clinical signs.
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Health Effects: Non-clinical Studies - Studies with human pulmonary cells
are in progress to evaluate the cellular response to in vitrg_ ozone exposure.
Pulmonary natural killer cells, alveolar macrophages, and pulmonary lymphocytes
are being studied. The purpose of these studies is to examine man's ability
to resist infections and determine whether mediators normally active in the
lungs are affected by exposure to pollutants. They will provide data which
will be especially useful in risk assessment activities.
Additional work to measure the amount of ozone removed in the nasal
passages, the pharynx, the mouth, or the lungs was completed. A follow-up
study is in progress to determine if there is a direct relationship between
the amount of ozone removed and pulmonary function response to ozone. These
studies are important to the extrapolation efforts being carried out by EPA's
Health Effects Research Laboratory. In addition, these studies are seen by
the program offices as critically important to regulatory and risk assessment
activities.
All exposures (1 week, 3 weeks, 3 months, and 18 months) for the ozone/
nitrogen dioxide (Os/NC^) chronic exposure study were completed. Additional
animals were held in clean air for up to six months after exposure to determine
progression or-reversibility to disease. Preliminary results indicate significant
pulmonary biochemical and structural changes, as well as aging effects. Final
results are pand-ing the completion of statistical analysis.
Studies designed to fill a significant data gap concerning the effect of
ozone on susceptibility to viral infections showed that five repeated daily
exposures to ozone enhanced the severity of influenza infection in mice if
the infection occurred on the second day of exposure.5 This effect did not
appear to be due to effects on anti-viral immune defense mechanisms. Effects
on viral susceptibility were not as dramatic as previously demonstrated
effects on bacterial susceptibility.
The potential neurotoxicity of lead continues to be monitored. Mounting
evidence suggests that lead neurotoxicity in children may result in hearing
difficulties, even at relatively low blood lead levels. Based upon suggestive
findings obtained from neurophysiological tests for children with elevated
lead levels, and from analysis of data obtained from the second National
Health and Nutrition Examination Survey, a neurophysiological test was inserted
into a large ongoing longitudinal study of lead in children being performed by
the University of Cincinnati. Initial evaluation of many of the children in
the study has been accomplished. The EPA-funded portion of a study of the
behavioral and neurophysiological effects of prenatal or postnatal exposure
to lead in monkeys was completed, and a subset of the results was prepared
and accepted for publication. Neurophysiological tests similar to those
performed on children revealed effects suggestive of lead-induced auditory
dysfunction. Behavior studies of these same monkeys suggested that exposure
to lead increased the distractability of the monkeys. In 1988, the monkey
study will be completed and data from the study of lead-exposed children will
be analyzed.
Two peer-reviewed articles were published which described results to
date from the study of lung cancer in China.6,7 The study results were also
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presented in the Berlin International Conference on Indoor Air Quality and
Climate in August 1987. This study may help our understanding of non-tobacco
related environmental causes of lung cancer in humans.
Several on-going epidemiologic studies in the U.S. are assessing
respiratory effects of ubiquitous air pollutants. The major emphasis of these
studies is directed to acute and chronic effects of ozone, acid aerosols,
and PMiQ. Some of the studies have strong indoor air pollution components.
Reports on various aspects of this work have been published during the year
in scientific journals and presented at meetings.
Ecological Effects Studies - The National Crop Loss Assessment Network
(NCLAN) reached its culmination in 1987 with an international conference on
"Assessment of Crop Loss from Air Pollutants."8 Over 150 researchers from
around the world participated in the conferences. This conference included
sessions on the need for crop loss assessment, the role of meteorology and
atmospheric chemistry, regional monitoring and extrapolation, field approaches
for measuring crop loss yield assessments, physiological understanding of
crop losses, and several other topics. In 1987, eight journal articles, two
proceedings, and one in-house report were published which described various
results of NCLAN research.9"19 Numerous other articles were accepted by
reference journals and are in various" stages of publication.20-24
-, In 1987, ~tfh~e initiaul. wock was done to prepare for a.long-term study of
the effects of ozone on forests and forest ecosystems. The shift from crop
to forest research requires a substantially different research plan, although
much of the exposure technology developed in NCLAN will be useful in the
forest effects program.
Visibility Research - Preliminary results were published from an extensive
cooperative monitoring program with the Department of Defense on the levels and
sources of visibility impairment in the Mojave Desert of California.25-28 /\n
analysis for the study area indicates that the five most important pollutant
species and their contributions to visibility are organics (24 percent), sulfates
(23 percent), elemental carbon (20 percent), soil dust (19 percent), and nitrates
plus N02 (14 percent). Worst case visibility conditions occurred during conditions
ot transport from the Los Angeles Basin and the Central Valley of California.
Efforts were made to establish visibility monitoring in California and to develop
visibility monitoring performance standards that will promote the collection of
comparable data without hampering the future development of improved monitoring
techniques.29 A computer module has been developed which translates urban
aerosol concentrations to visibility parameters.^ This module can be used in
conjunction with existing regional scale models to predict large-scale haze
problems in the U.S.
Scientific Support to Develop New Source Performance Standards (NSPS)
and State Implementation Plans (SIPs)
NOX Control Activities - A new contract was awarded to apply reburning, a
fuel staging combustion modification technology, to a coal-fired, cyclone utility
boiler. Based on previous bench- and pilot-scale tests, an NOX reduction of
50 percent or greater is expected. Reburning is the only known combustion
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modification technology which can achieve this level of NOX reduction on
cyclone boilers. The only alternative would be more costly flue gas treatment.
Reburning has the potential to become an important retrofit technology if NOX
reductions from existing boilers are required in the future. This project is
equally co-funded by EPA, the Electric Power Research Institute (EPRI), and
the Gas Research Institute (GRI).
An in-house research project has resulted in the design of a heavy oil,
low NOX burner. This new design has two advantages over previous designs.
It is smaller and it provides a better turndown ratio. -The new burner utilizes
a combination of the precombustor concept and reburning to achieve these
goals. It is capable of firing nitrated fuel oil (e.g., No. 6 oil) or nitrated
liquid waste but can maintain NOX levels of approximately 125 ppm. A technical
paper summarizing this research was accepted for publication in Environmental
Progress.3^
The 1987 Joint Symposium on Stationary Combustion NC^ Control was held
in New Orleans in March 1987.32 This four-day biennial meeting was
co-sponsored with EPRI, and is recognized as the main international symposium
on NOX control technology. More than 350 professionals attended, including
representatives and speakers from Canada, Europe, and Japan. It was apparent
that NOX control is of growing concern worldwide, based on information provided
in approximately 50 technical papers.
FTtre Gas-OesulfurizatrorT (FGD) Activities - Development of a low-cost
process for sulfur dioxide control continued in 1987 as part of the advanced
FGD program. A process for duct injection of damp calcium silicate powder
has shown greater than 90 percent S02 removal with fabric filters, and over
50 percent removal in the ducts. Four patents are being filed and one vendor
is planning a demonstration of the advanced silicate (ADVACATE) process.
Scale-up to commercial size during 1988 will be made through a
cooperative agreement between EPA and a major FGD vendor. Application to
waste incinerators for acid gas emission control will also be developed.
The electrically stimulated fabric filters (ESFF) particulate removal system
which was developed previously was found to decrease emissions and achieve a
lower pressure drop when compared to conventional fabric filtration. A
mathematical model has been developed to predict non-uniform deposition of
particulate matter and relative pressure drop expected.
Modeling Support Activities - An improved chemical reaction mechanism
was developed to quantify the atmospheric formation of ozone from its
precursors (hydrocarbons and oxides of nitrogen).33 This mechanism, which
uses a lumping procedure to characterize the hydrocarbon mixture, will
provide an alternate approach to the carbon bond mechanism currently used in
some ozone air quality models to develop cost-effective ozone control
strategies. A paper was prepared which describes the role of hydrocarbons
and nitrogen oxides in the formation of atmospheric ozone.34 The paper
examines the air quality impact associated with various emission control
scenarios for achieving the ozone air quality standard.
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A computer model which quantitatively describes the formation and
removal of ambient particulate matter was developed. This model, designed to
operate in conjunction with an existing regional scale model, will allow a
more accurate prediction of the air quality impact of control abatement
strategies for particulate matter.
A new tracer technique was applied to estimate source strengths of
pollutant emissions which are normally inaccessible with conventional
techniques. This technique may be applied to estimate s.urface release ot
fugitive emissions.
Based on an air quality and emissions data base obtained during a 1982
field study in Philadelphia, the Pollution Episodic Model (PEM) was evaluated.
The PEM model, which incorporates important atmospheric processes, such as dry
deposition and sedimentation, will be used to predict short-term concentrations
of particulate matter for urban areas.
The EPA's Fluid Modeling Facility was used extensively to simulate a wide
variety of air pollution processes. A report was prepared which documents
these simulations, including those that-can be used to assess the impact of
terrain roughness, air flow near bui.ldings, and roadway turbulence on air
quality,35
"Monitoring Support Activities - Two procedures for sampling stationary
source emissions of PMio were evaluated in field tests. The two test methods
are entitled Emission Gas Recycle (E6R) and Simulated Method 5 (SIM 5). The
EGR method allows for a longer term and potentially more accurate measurement
to be made. The SIM 5 method allows several size-classified Method 5-type
samples to be collected for PMio and therefore does not require the special
testing equipment of the EGR method. Both of these procedures will be
recommended for use in SIP's when ambient air quality standards are exceeded
and additional PMio control strategies must be employed.
Scientific Support to Develop Regulations for Hazardous Air Pollutants
(HAPs)
Health Assessment Documents - In 1987, the Health Assessment Document for
chromium was updated through the completion of an issue paper which describes
the health effects of substitutes for chromium in cooling towers.36 New
Health Assessment Documents were published for beryllium, acrolein, acetaldehyde,
chlorine/hydrogen chloride, and phosgene.37-41 Draft Tier I health summaries
were prepared for nine compounds. These were sodium hydroxide, hydrogen cyanide,
hydrogen fluoride, inorganic phosphorus, organic phosphorus, methanol, dimethy-
lamine, non-asbestos mineral fibers, and naphthlene.42-50 Final Tier I
health summaries were completed for propylene oxide and zinc/zinc oxide.51.52
A summary report was prepared which detailed the results of an October
1986 workshop on multimedia approaches to assessing and managing hazardous
air pollutants.53 This workshop was conducted in conjunction with the North
Atlantic Treaty Organization. In cooperation with the Office of Air Quality
Planning and Standards, ORD produced a survey of EPA risk assessment methods
for incineration for use by the Air Office and the Office of Solid Waste in
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reyulatory decision-making.54 /\ draft document on interim methods for developing
inhalation reference doses was prepared and reviewed at a public workshop
held in October 1987.55
Monitoring, Measurement Development, and Quality Assurance - Cryogenic
preconcentration and stainless steel canisters were used to collect volatile
toxic organic compounds in air samples before analysis by gas chromatography
and/or mass spectrometry. These methods were demonstrated in a mobile van
established for real-time analysis during a two-week field study in Virginia.
These collection procedures reduce the possibility of arttfacts produced by
some solid sorbent collection methods. A portable gas chromatograph was also
evaluated. This device employs a very sensitive photoionization detector,
which produces real-time analysis of volatile toxic organic pollutants without
preconcentration. It provides an inexpensive rapid screening method for
organic air pollutants where unambiguous pollutant identification is not
requi red.
A joint US-USSR air monitoring field study was conducted in June 1987 at
Research Triangle Park, North Carolina, to compare U.S. EPA canister collection
methods for volatile organic compounds with USSR solid sorbent collection
methods. This study was conducted under the guidance of the US-USSR Joint
Committee on Cooperation in the Field- of Environmental Protection.
New pattern" recdgnition.jtechniques for classification and identification
of toxfc and potentially toxic organic pollutants from gas chromatographic-mass
spectrometric monitoring data were developed and tested. These procedures
were successfully evaluated on calibration and actual field monitoring mass
spectral data for target compounds. The methods are applicable to environmental
media other than air and can be applied retrospectively to archived data. The
classification results alone may be of use for survey studies, particularly
in determining human health risk.
The development, evaluation, and validation of source test methods to
support the regulatory process included studies of methods for a number of
organic compounds, including acrylonitrile, butadiene, carbon tetrachloride,
chloroform, dioxins, ethylene oxide, formaldehyde and methylene chloride.
The dioxin investigations uncovered problems with the sampling method when high
concentrations of particulate are present. The method for methylene chloride
was validated. A method for cadmium emissions from stationary sources was
also investigated and validated. A study was undertaken of continuous
emission monitors for benzene emissions from gasoline bulk storage facilities.
The study was completed and a set of performance specifications was developed
for the monitors.
Ambient air quality measurements tor a variety of volatile organic
compounds of interest to air programs are being collected through the Toxic
Air Monitoring Stations (TAMS) program. Multiple monitoring stations are
operated in Houston, Boston, and Chicago while a single site has been established
in the Seattle-Tacoma area. Samples are collected over a 24-hour period
every twelfth day and sent to a central analytical laboratory for analysis.
Sample collection mechanisms have been run in parallel at a selected site in
Houston to evaluate method comparability. Currently, samples are collected
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in 6-liter stainless steel canisters and analyzed by gas chromatography-mass
spectrometry detection (GC/MSD). Data from the network are validated and
incorporated into EPA's air toxics data base.
The first set of Total Exposure Assessment Methodology (TEAM) studies
measured personal exposures of more than 700 persons in 10 cities for multiple
volatile organic compounds (VOC's) in air and drinking water together with
exhaled breath concentrations. A comprehensive three-volume report of these
studies was published during l987.56-58 A major finding was that personal
and indoor concentrations of many of the measured compounds exceeded outdoor
levels, even in petrochemical refinery areas of northern New Jersey^9 and
southern California.60 Important sources of exposure were cigarette smoking
for benzene and styrene,61,62 hot shower use for chloroform, dry-cleaned
clothes for tetrachloroethylene, and moth crystals and room deodorizers for
paradichlorobenzene.63
In order to re-examine and extend these important results, a new group
of TEAM studies employing recently developed methodology was conducted during
1987. VOC studies using canister and Tenax samples were performed in Los
Angeles and Baltimore. In Los Angeles,-approximately 50 homes and individuals
from the previous study were resampled during both February and July. In
Baltimore, a new TEAM location without petrochemical refiner proximity, over
800 canister samples.and a larger number of Tenax samples were collected
from 155 Baltimore area residents. The laboratory analys-es for a set of 25
VOC's are now complete for both studies; statistical analyses are still in
progress. Planning for a follow-up study in northern New Jersey has been
completed. A screening study of 22 houses was performed in October to select
11 homes for a December study for sources of exposure to benzene, tetrachloro-
ethylene, and paradichlorobenzene. A particle exposure study has also been
planned with data collection scheduled for next year.
Health Effects Studies - Studies of phosgene and p-xylene answered many
questions about the kind and extent of the health effects posed by these
compounds. Inhalation of phosgene resulted in suppressed pulmonary immune
response which, in turn, compromises the body's defenses against infections
or neoplastic diseases. Phosgene also caused increases in drug-induced
sleep, thereby suggesting an effect on the metabolic function of the liver.
P-xylene also affected the liver when combined with carbon tetrachloride.
Neither p-xylene nor carbon tetrachloride alone caused such an effect.
P-xylene was also shown to affect the nervous system by interfering with
protein synthesis. Inhalation of p-xylene at high levels produced significant
changes in flash-evoked potential. The method used to determine the neuro-
behavior effects of p-xylene in animals can also be used in humans and is
being testing in humans exposed to toluene.
In 1987, the effects of several well-defined physiological or pharmaco-
logical treatments were investigated in rats, so that effect patterns could
be recognized in humans and rats exposed to unknown hazardous air pollutants
(HAP's). Among the treatments examined were urethane hypothermia--a common
consequence of HAP exposure, and the amino acid blocker called ketamine.
Neurotypic and gliotypic proteins were investigated as biochemical
markers for detection of neurotoxicity. Work describing the regulation of
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these proteins by glucocorticoids and environmental challenge was completed
and prepared for publication. In addition, as part of the validation process,
it was demonstrated that acute exposure of the neonatal rat to a prototypical
neurotoxicant, triethyltin, produced persistent changes in both neurotypic
and gliotypic proteins.
The identification of mutagenic and carcinogenic nit roaromatic compounds
in combustion emissions and urban air particulate matter has led to a major
research effort to understand the sources, exposures, metabolism, dosimetry,
and effects of this class of organic compounds. Using « bioassay directed
fractionation and chemical characterization, it was determined that many of
the polar mutagens present in ambient air are polycyclic aromatic hydrocarbons
(PAH's) with a nitro substituent (N02-PAH's). Humans are also exposed in urban
air to many nitroaromatic compounds with additional oxygenated substituents
(e.g., nitrophenols and other ring substitutions such as nitrogen heterocycles.
The first nitroaromatic compound identified was 1-nitropyrene, which was present
in diesel emissions together with many other N02-PAH's and dinitro PAH's (e.g.,
1,6-dinitropyrene). Many nitroaromatic compounds are mutagenic and several
have been shown to be carcinogenic in animals. The dinitropyrenes, however,
have exceptionally high mutagenic activity and when present in mixtures at
concentrations less than a part per minion, are found to contribute sub-
stantially to the ultimate mutagenictty and carcinogen!city of these mixtures.
Deoxyribcmuclefc acid (DNA) adduct studies, using the 32p-post label ing
methodrsuccessfully detected and quantitated the DNA adducts resulting from
human exposure to complex combustion emissions, as well as animal and cellular
exposures. Research was completed on a comparison of two methods to increase
sensitivity in the postlabeling adduct assay. DNA adduct studies using this
highly sensitive postlabeling method were applied to lung cells as well as
human intestinal bacteria treated with individual PAHs and N02-PAHs as well
as complex mixtures to determine DNA adduct types and levels. These studies
have successfully detected and quantified the C-8-animopyrene DNA adduct
resulting from nitroreduction of 1-NP in both tracheal cells and anaerobic
human microflora.
Direct mutagenesis bioassay methods were developed to assess gaseous
mutagens. These methods have been applied to smog chamber studies of individual
hydrocarbons (e.g., toluene, propylene, ethane) and recently to chlorinated
hydrocarbons. These studies show that atmospheric transformation can often
increase the mutagenicity and potential cancer risk of hydrocarbons in the
atmosphere.
Wood Stove Control Studies - Two wood stove field studies were completed
involving over 70 homes in the Northeast and Northwest. Results showed that
the emission reduction performance of stoves meeting EPA's proposed 1990 wood
stove new source performance standard was highly variable. On average,
catalytic stoves achieved only a 25 percent emission reduction relative to
conventional stoves as contrasted with lab tests showing a 90% reduction.
Corresponding results for low emission noncatalytic stoves were 30% in the
field versus 85% in the lab. In a few cases, however, the new technology
stoves performed very well indicating that the technology has the potential
to reduce this most significant source of emissions of PMjQ and polycyclic
organic matter. It is believed that operator variances such as improper fuel
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loading play a significant role in the ability of the technology to achieve
its potential for emissions reductions. Follow-on work is planned in 1988 to
better understand why the new technology did not perform consistently well
and what changes should be implemented to achieve anticipated emission
reductions consistently.
A study and subsequent field testing for hospital sterilizer control systems
was completed in late 1987. A total of seven potential control concepts was
reviewed. Two concepts were selected for field and laboratory testing including
acid hydrolysis and low temperature catalytic oxidization. Test results indicate
that both techniques have destruction efficiencies of up to 99 percent.
A small pilot-scale laboratory facility for evaluating the control of
potentially toxic volatile organic compounds via adsorption was brought into
operation during 1987. Testing of the effect of relative humidity on single
component adsorption of three compounds on activated carbon was completed.
Atmospheric Formation of HAP's - In 1987, a report was prepared which
describes the use of smog chambers and other data to determine the atmospheric
lifetimes of eight air toxics currently-under EPA reviews. Smog chamber
studies can be used to simulate a variety of atmospheric conditions and provide
useful information on atmospheric lifetimes and transformation products.
Studies were conducted^ the formation of mutagenic compounds in urban
air, using a controlled system of simulated urban photochemistry.64 The
results to date using smog chamber irradiation studies suggest that the gas
phase reaction products show higher mutagenicity than the particulate phase.
Integrated Air Cancer Program - A major field study was conducted in
Boise, Idaho, where both wood stoves and mobile sources contribute to high con-
centrations of particulate and organic matter. A large number of samples were
collected, including airborne particles, semivolatile and volatile organics,
acid, and aldehydes. These samples are currently being chemically characterized
and studied in other mutagenesis bioassays and whole animal tests.
Scientific Support to the Mobile Sources Program
Exposure Monitoring and Modeling - The EPA's Office of Mobile Sources has
been concerned that the level of exposure to formaldehyde might increase as
more automobiles burn fuel containing methanol. ORD conducted the first stage
of a two-stage study to compare existing formaldehyde methodologies in a
worst-case microenvironment, an underground parking garage. The first stage of
the study was conducted during a period of high photosensitivity (summer) and
the second stage will be conducted during a period of low photosensitivity
and when direct automobile emissions are more likely to be the highest (winter).
Upon completion, this study will result in baseline formaldehyde measurements
from which to judge the future impact of changing in fuel mixtures and will
provide tested monitoring methodologies for use by the monitoring communities."5
Two modeling efforts were continued: validation and modification of
existing exposure models—Simulation of Human Air Pollutant Exposure (SHAPE)66
and the National Ambient Air Quality Standards Exposure Model (NEM)67 and
development of an automotive emission exposure model. Particular emphasis
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has been directed toward moditication of NEM to include minute-by-
minute activity patterns based on actual measured activity profiles.
This improvement, once incorporated, will more accurately estimate
exposure for both seasonal and national projections. Development of a
two-stage automotive emission exposure model continued with improved
predictive power which is superior to any of the 33 models initially
developed, with about 75 percent of the variation in observed commuter
exposure explained.68
Health Effects Studies - The neurobehavioral consequences of
exposure to CO continue to be monitored and reviewed. Controversy has
existed about the levels of exposure to CO which produce neurobehavioral
effects. A major difficulty in performing and evaluating this work has
been that studies are generally performed at or near the presumed
threshold level for effect. In addition, the rate at which exposure
occurs may be a significant variable. In 1987, studies were performed in
which humans were exposed to levels of CO sufficient to produce
carboxyhemoglobin (COHb) levels of 16-23 percent. Most literature
suggests that these exposures should be sufficient to produce symptoms,
yet no symptoms were reported by the subjects in this study. In addition,
no effects were observed on the electroencephalogram or on compensatory
tracking. A report describing these "data has been accepted for
publication by__the Journal of Neurotoxicology and Teratology. Researchers
attempted to replicate --the-findings of previous authors at lower COHb
levels. In these studies, humans were requested to perform a sophisticated
task requiring eye-hand coordination in the tracking of a visual stimulus.
These experiments succeeded in repeating the earlier findings, thus
indicating a mild tracking deficit after exposure to levels of CO
sufficient to produce COHb levels of 5-6 percent. A current study is
exploring the differences between the rapid attainment of high COHb
levels and the low attainment of low (5-6 percent) COHb levels.
Emissions Studies - Mobile source emissions were characterized
from a variety of motor vehicles under a number of different driving
conditions. In one study, the effects of fuel volatility and methanol
blend usage on evaporative emissions was determined.69 The results
suggested that evaporative emissions with methanol-gasoline blended fuels
were nearly equivalent to corresponding emissions with gasolines of
similar volatility characteristics. In another study, the influence of
ambient temperature on tailpipe emissions from light duty gasoline motor
vehicles was investigated.?0 This study provides quantitative emissions
data on speciated hydrocarbons, aldehydes, and carbon monoxide concentra-
tions emitted at lower ambient temperatures. The study showed that the
concentrations of these pollutants increased as temperature decreased.
Additionally, the rate and composition of refueling emissions were
determined using laboratory simulations of summer and winter refueling
conditions. The emissions were determined to be dominated by the volatile
butane and pentane components of gasoline.71 A study was also published
describing the organic composition of tailpipe and hot soak evaporative
emissions from 46 consumer-owned motor vehicles. Emission rates of 82
hydrocarbon and 10 aldehyde compounds were reported.72
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Scientific Support to EPA'^ Indoor Air Program
Scientific Assessment - A report to Congress. "EPA Indoor Air Quality
Implementation Plan," was released in July 1987.73-77 This five-volume
document was jointly prepared by ORD and EPA's Office of Air and Radiation. A
draft research needs statement was completed that identifies the indoor air
research questions still to be addressed by EPA and other Federal agencies.
A matrix manager was designated to provide overall coordination and quality
control of the indoor air research program.
Monitoring and Exposure Activities - Methods development activities
included evaluation of analytical procedures for nicotine and PAH's,
development of new methods for polar organics, development of a miniature
real-time monitor for N02, and continued evaluation of the canister technology
for VOC collection. A field demonstration study was initiated in response to
Scientific Advisory Board recommendations that EPA review the state of indoor
monitoring technology and develop an in-house capability to conduct monitoring
research. The planned effort includes a measurement precision study conducted
at the EPA/AEERL test home in Gary, North Carolina, followed by an applied
effort in Baltimore, Maryland. MethodoJogies being reviewed in the program
include those .for VOC's, semivolatile organic compounds (SVOC's), particulate
matter in the size range of 2.5 micrometers and smaller (PM2.5J and PMiQ
particle fractions, metals, air exchange rate and nicotine. *The problem of
"Sick Building Syndrome"-was-addressed by supporting several external field
efforts aimed at not only identifying problems, but developing questionnaires
and procedures to assist State/local agencies in responding to complaint
situations. One of these studies is at the Library of Congress facilities in
Washington, D.C. where occupant complaints have baffled researchers trying to
find causes.
Health Effects Research - A comprehensive and systematic research plan to
investigate the health effects of exposure to volatile organic compounds
emitted from building materials and furnishings was developed. Initial work
focused on planning, implementing, and replicating the essential features for
a Danish study. The Danish study was aimed at determining whether sick
building syndrome complaints could be accounted for by exposure to a mixture of
21 volatile organic compounds. The most important finding of the study was
that memory appeared impaired in those exposed to low concentrations of this
mixture. Because of the potential significance of this finding and some
critical flaws in the experimental design, careful plans were made to replicate
this study. During 1987, a protocol was developed, the human exposure chambers
were modified to accommodate this complex mixture, the behavioral testing
component was largely computerized and plans were made for computer acquisition
of the data. The attempt to replicate the Danish study will be made during 1988,
Source Characterization and Control Technology - Activated carbon was
evaluated as a possible control measure for indoor organics. For the low
concentrations expected in indoor environments, carbon does not appear to be
a feasible control technology. Alternative VOC control techniques will be
evaluated in 1988. Measurements of particle size distribution of typical
indoor air particulate matter were made in a typical office. The data show
that the particulates all fall into the PM^g range.
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A facility for evaluating the effectiveness of indoor particle control
devices was designed and is under construction. This facility will be used
to determine air cleaner effectiveness for all particle size ranges expected
in the indoor environment. Ozone generation by electrostatic precipitator
(ESP's) will also be determined.
With the cooperation of the Consumer Product Safety Commission (CPSC),
EPA conducted the first comprehensive emission characterization of the
various designs of unvented kerosene heaters available _to. the publtc. While
numerous studies of kerosene heaters have been conducted relative to criteria
pollutants, only limited data on organic emissions were available. These
preliminary data suggested a potential major health problem based on particle-
bound, semivolatile organic emissions and the large number of kerosene heaters
(several million) in use in the U.S. In the 1987 study, kerosene heaters of
various designs were evaluated. Particulate, organic, and inorganic emission
data were collected. This comprehensive assessment identified high emissions
of acid aerosols which are believed to cause respiratory illness. The
particulate matter was evaluated via bioassays to determine mutagenic potential;
emissions from all of the heaters gave positive bioassay results. While full
evaluation of the data from this study -has not been completed, preliminary
assessments indicate that kerosene heater emissions pose a serious health
threat to exposed individuals.
--'- In-order to provide-fr-fnll-scale, controlled research environment, EPA
established a test house in the vicinity of Research Triangle Park, North
Carolina. The test house will allow evaluation of the emission characteriza-
tion results obtained in our chamber research vis-a-vis their application to
an actual indoor environment. The house also serves as a "test platform" for
the evaluation of indoor air quality (IAQ) monitoring equipment, the evaluation
of IAQ control strategies and techniques, and the evaluation of IAQ models. To
date, air exchange measurements and background organic characterization have
been accomplished, and testing has been conducted on kerosene heaters and moth
crystals. Data evaluation for the kerosene heaters is underway. Concentrations
of paradichlorobenzene from moth crystal cakes placed in a closet were measured
at several locations in the house and were used to evaluate a user-friendly,
general purpose IAQ model which EPA is developing. The model provides a useful
set of tools for analysis of IAQ issues.
An initial assessment of asbestos in residences was completed. The
assessment showed that residences with asbestos building material and insula-
tion have airborne asbestos. The probable risk due to the measured levels of
asbestos are being assessed.
Scientific Support for the Stratospheric Ozone Program
In response to growing concern about the depletion of ozone from the
stratosphere and resulting increases in harmful ultraviolet light, EPA is
increasing its emphasis on research to determine the causes and effects by
stratospheric ozone depletion. This program has two major components:
ecological effects and control technology. The largest part of the program
consists of research on the effects of radiation in the 29U-320 nanometer
wave band (UV-B) on food crops. Major crop systems such as soybeans and
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wheat have shown measurable damage after prolonged exposure to UV-B
radiation.78-82 Research was begun in 1987 to quantify the range and
degree of injury on growth and yield. Research was also conducted on the
influence of UV-B on plant competition pike, seedling growth, and marine
ecosystems.83-85
A second workshop was held in Boulder, Colorado, which covered biogenic
and combustion generated NjX). The workshop was co-sponsored by EPA, National
Aeronautics and Space Administration, National Oceanic _ah.d Atmospheric
Administration, and United States Department of Agriculture, and had approxi-
mately 50 attendees, including representatives from government, industry, and
universities.
Under the fundamental combustion research program, a kinetic combustion
model was developed which has led to a better understanding of the formation/
destruction pathways of NgO during fossil fuel combustion. Preliminary test
burns with gas and coal have verified the model.
Documentation was completed on the cost of reducing or discontinuing
the use of chlorofluorocarbons (CFC's) 4n producing rigid and flexible cellular
foams, and in -air conditioning and refrigeration. This documentation was
used in the regulatory impact analysis which supports the December 14, 1987,
Federal Register notice proposing regulations limiting CFC's and halons.
Reports-were prepared which-tletai 1 CFC consumption, emission, and control
options for rigid and flexible cellular foam production. These reports also
address the possibility of alternatives to CFC's in foam manufacturing. An
international panel of experts was convened to advise EPA on possible chemical
substitutes for the suspect ozone-depleting CFC's as well as on means of
advancing commercialization of such substitutes.
A project will be initiated in 1988 to examine the properties of proposed
alternative compounds, with regard to their suitability as possible replacements
for the ozone-depleting fullyhalogenated CFC's and halons currently used as
refrigerants, foam blowing agents, solvents, and fire extinguishants. Engineering
studies will continue that evaluate process modification technologies to
reduce CFC emissions, add-on controls to collect and recycle emissions and to
destroy CFC's.
Scientific Support for the Global Warming Program
In 1987, EPA established a program to address the causes and effects of
global climate change. Workshops were held with experts from around the
country to provide a sound foundation for the development of a long-range
global climate change research plan.
C. ACID DEPOSITION RESEARCH ACTIVITIES
Acid Deposition - General
Research on acid deposition is coordinated through EPA's National Acid
Precipitation Assessment Program (NAPAP), which is administered by the
Interagency Task Force on Acid Precipitation. The term "acid rain" means the
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atmospheric deposition of acidic or acid forming compounds in either dry or
wet form. These compounds exist in the atmosphere as gases or aerosol particles
containing sulfur oxides, nitrogen oxides, hydrogen chloride, sulfuric acid,
nitric acid, and certain sulfate and nitrate compounds. The objective of
acid deposition research is to develop necessary data to fully understand the
sources and characteristics of acid deposition, the extent of damage or
potential damage, and the corrective measures that may be used to diminish
the problem.
In 1987, acid deposition research produced scientffic information on
the chemical status of a representative sample of lakes in the eastern
United States, and developed a preliminary 1985 man-made emissions data base.
The program established a cloud chemistry network to cover the major high
altitude forest system in the eastern part of the nation. A deposition
monitoring network was installed. Significant progress was made in
determining the effects of acidic deposition on southern conifer and spruce/
fir forests.
Long-term Deposition Monitoring Data (Both Wet and Dry) to Provide Trends
Analyses, Evaluate Atmospheric Models, and Determine Exposure in Effects
Studies .
In" 1987,jthe deposition monitoring research program continued to provide
the.deposition data on wet-precipitation through the National Trends Network
(NTN). The network, consisting of IbO stations, operated at full capacity.
Data reports covering the first four years of operation of the deposition
network were published.86-87 A report was produced which analyzed the wet
deposition network design and seasonal trends.88
Several advances were made in dry deposition research. A siting plan
for dry deposition in the West was developed and approved. A report was
published which detailed the results of a siting study in the Southeast.89
Another report was published which describes interim annual estimates of
eastern dry deposition.90
Activities to Improve the Scientific Understanding of Atmospheric Processes
In 1987, the first generation Regional Acid Deposition Model (RADM I)
was evaluated against data collection during Oxidation and Scavenging
Characteristics of April Rains (OSCAR) and the First GARP Global Experiment
(FGGE). This version of the RADM was used to develop dry deposition estimates
for the Direct Delayed Response Program models.
An extensive review of the RADM I was conducted in May 1987, and improve-
ment to the gas phase chemistry and scavenging module were recommended. The
improved gas phase module was completed by November as part of a second
generation version of RADM, RADM II. The RADM Scavenging Model (RSM) was
delivered in October. Because of the increased computer time required to run
the RADM with the RSM when it was first delivered, two versions of RADM II
were configured; a full "scientific" version (RADM IIS) incorporating the RSM,
and an "applications" version (RADM IIA), which utilizes a simpler scavenging
model with consequent reduced computer time.
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A sulfur-only "engineering" version of RADM I, called the Engineering
Model (EM), was also completed in 1987. Although no longer intended for use
as an assessment version of RAOM, the EM still can be used to provide insight
into source attribution.
A scheme to aggregate selected runs of RADM II to provide seasonal and
annual estimates of wet and dry deposition has been developed. Included in
this methodology is an estimate of the error of the long-term deposition.
Once completed, this methodology is expected to be applied to policy assessment
activities using the RADM IIA.
Planning for the model evaluation field study continued during 1987. A
contract was awarded to install the ME-35 surface network, and to plan and
implement the diagnostic evaluations using aircraft during field investigations.
Preliminary plans for the diagnostic evaluations were developed. An agreement
was reached with the Federal Republic of Germany to have the Hawker-Sidley
research aircraft from the Fraunhoter Institute participate in the field
intensives in 1988.
The International Sulfur Deposition-Model Evaluation (ISOME) report was
completed. Further improvements on one of the models used in this report, the
Regional Lagrangian Model of Air Pollution (RELMAP), was used to develop dry
deposition estimates.as part of an EPA staff paper on the state of science of
acid deposition. Further- improvements have subsequently-been made to the
model to represent boundary layer processes more realistically.
Activities to Improve the Scientific Understanding of the Aquatic Effects
of Acid Deposition on Surface Waters Watersheds, and Aquatic Biota
Acid deposition is believed to be a major contributor to chronic depressions
in aquatic systems. Effects which may result include effects on fish and other
aquatic organisms and drinking water quality. The population-at-risk of surface
waters and aquatic biota in the United States is only partially known. Improve-
ments are needed in both the scientific understanding and: (1) the current
status of surface waters and watersheds including episodes, (2) the chemical
and biological changes to those resources, and (3) the rate of change resulting
from current and altered loadings of acidic or neutralizing substances. These
improvements will allow the development of more scientifically acceptable, yet
simplified relationships and models for assessment and policy needs.
The rate of change of systems is being investigated by the Direct/Delayed
Response Project. Three different levels of modeling activities will supply
target loading predictions by region. Verification of prediction of the
Direct/Delayed Response Project will be undertaken by field and pilot level
manipulations of watersheds as part of the Watershed Manipulation Project.
The research plan for this project was developed and reviewed in 1986;
manipulation trials began in 1987.
Long-term monitoring provides the ultimate verification of model
predictions by producing information on water quality trends, especially
in sensitive systems. The Temporally Integrated Monitoring of Ecosystems
(TIME) Project is being designed based on the results of the NSWS to maximize
its applicability to detecting changes in sensitive surface waters.
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Activities to Improve the Scientific Understanding of the
Terrestrial Effects of Acid Deposition on Forests, Soil,
and Watersheds
Various adverse changes in forest conditions have been observed in the
United States since the early 1980's. Increased forest mortality has been
observed in high elevation stands of red spruce and balsam fir. There is
some indication that annual growth is reduced in these stands. These
observed symptoms are nonspecific and could be caused by several different
factors or combinations of factors. Acidic deposition and its associated
pollutants have been implicated as causal factors.
A joint EPA/U.S. Forest Service research program, the Forest Response
Program (FRP), was established in 1986 to investigate: (1) extent of damage
to forest ecosystems which might be caused by acid deposition, (2) cause and
effect relationships, and (3) dose response relationships. During 1985 and
1986, the FRP established the Spruce-Fir, Southern Commercial, Eastern
Hardwoods, and Western Conifer research cooperatives. Also, the National
Vegetation Survey was implemented and a Synthesis and Integration Team has
been established. Research continues in-all of these activities..
Spruce-Fir Research Cooperative"- This cooperative addresses the
question of extent of forest damage and investigates most of the major
hypotheses of cause and «ftect related to the impact of atmospheric
deposition on Northeastern spruce-fir and Appalachian spruce-fir.
Southern Commercial Forest Research Cooperative - The Southern Commercial
Cooperative is investigating the physiology of southern pine species
(principally loblolly) in relation to air pollutants in the laboratory and
"intensive" field research sites.
Eastern Hardwood Research Cooperative - The Eastern Hardwood Cooperative
has concentrated on the spatial extent and temporal development of adverse
.changes in forest condition in eastern hardwood species, including sugar maple.
Also included are studies concerning the effects of atmospheric deposition on
physiological and nutritional processes.
Western Conifers Research Cooperative - Similar to Eastern Hardwood, the
thrust of this cooperative is problem definition. Western conifer forests
are diverse and subject to pollutant stresses on both a local and regional
basis.
National Vegetation Survey - Projects undertaken by the National Vege-
tation Survey explore the questions of the temporal development and spatial
extent of changes in forest condition. These include analysis of available
data, field observations, and studies along known deposition gradients.
Synthesis and Integration - The Synthesis and Integration Project plans,
tracks, and summarizes Forest Response Program research. Data management
and modeling assist the scientific assessment of air pollution effects on
forests.
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Activities to Improve the Scientific Understanding of the Effects
of Acid Deposition on Materials
The materials effects research program is directed toward understanding
the quantitative relationships between the various forms of acidic deposition
and the resulting damage rates to materials and identifying the geographical
extent of materials-at-risk. As a result of major program and project review
conducted with NAPAP, the materials research program was reconstructed in
1986. A major initiative was the development of a research program to determine
the effects of acid deposition on paint/substrate systems. In 1987 a peer
reviewed paint research plan was produced.yl
A preliminary physico-chemical model of acid deposition on galvanized
steel was prepared. This demonstrated the ability to predict damage in the
field from information gathered in the laboratory. Additional laboratory and
field studies are being conducted to refine and test the model. Field studies
on other common metals are in progress at five materials exposure sites.
Initial results of the field study were published that indicate the sensitivity
of metal surfaces to acid deposition changes over time as a corrosion layer
is formed. This has led to the development of a model of deterioration based
on the formation of a carbonate layer as a rate-controlling step in deposition.
Provision—Of -Additional Information to Document the Reliability and
-=- Cost-Effectiveness of tfre Limestone Injection Multistage Burner
TTlMB) Control Technology to~Reduce Sulfur Oxides and Nitrogen Oxides
The EPA continues to develop LIMB technology that is designed to reduce
emissions of both sulfur oxides and nitrogen oxides, the two major acid
deposition precursors. The LIMB emission reduction technology is designed to
be retrofitable to both large and small existing coal-fired boilers.
In 1987, work continued on the development of high surface area sorbents
and sorbents treated with "promoters" to improve the sulfur capture ability
of the LIMB technology. Also, EPA continued the laboratory and pilot-scale
research of the LIMB process to improve engineering knowledge of the effects
of operating parameters and systems variables associated with nitrogen oxides
control and sulfur dioxide capture. The wall-fired LIMB demonstration was
started and removal objectives for SOg and NOX were initially met. A contract
was awarded for the tangentially-fired boiler demonstration.
D. REFERENCES
1. U.S. Environmental Protection Agency. "An Acid Aerosols Issue Paper:
Health Effects and Aeronautics." Draft No. ECAO-R-140, 1987.
2. U.S. Environmental Protection Agency. "Research for Future Decisions on
National Ambient Air Quality Standards for Ozone." Draft No. ECAO-CD-81-
1RN-002, 1987.
3. U.S. Environmental Protection Agency. "Research for Future Decisions in
National Ambient Air Quality Standards for Lead." Draft No. ECAO-CD-81-
2RN-001, 1987.
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4. Lehrl, H.R., L.J. Roger, Hazuka, and D.H. Horstman. "Differing Response of
Asthmatics to S02 Exposure with Continuous and Intermittent Exercise,"
American Review of Respiratory Disease, 135:350-355, 1987.
5. Belgrade, M.J.K., J.W. Illing, D.M. Starnes, A.G. Stead, M.6. Menache,
and M.A. Stevens. "Evaluation of Effects of Ozone Exposure on Influenza
in Mice Using Several Indicators of Susceptibility." Submitted to
Fundamentals and Applied Toxicology, 1987.
6. Mumford, J.L., X.Z. He, R.S. Chapman, S.R. Cau, D.B". Harris, X.M. Li,
Y.L. Xian, W.Z. Jiang, C.W. Xu, d.C. Chuang, W.E. Wilson, and M. Cooke.
"Lung Cancer in Xuan Wei, China," Science. 235:217-220, 1987.
7. Mumford, J.L., D.B. Harris, K. Williams, J.C. Chuang, and M. Cooke.
"Indoor Air Sampling and Mutagenicity Studies of Emissions from Unvented
Coal Combustion," Environmental Science and Technology, 21:308-311, 1987.
8. U.S. Environmental Protection Agency. International Conference: Assessment
of Crop Loss from Air Pollutants, Raleigh, N.C., October 25-29, 1987.
Proceedings in print.
9. Amundson, R.G., Kohut, A.W. Schbettle. R.M. and P.B. Reich. "Correlated
Reductions^ n Whole-plant Photosynthesis and Yield of Winter Wheat Caused
-.by..Ozone." Phytopathology, 77:75-79, 1987.
10. King, D.A. "A Model for Predicting the Influence of Moisture Stress on
Crop Losses Caused by Ozone." Ecological Modeling, 35:29-44, 1987.
11. Kohut, R.J., R.6. Amundson, L. Colavito, L. van Leuken and P. King.
"Effects of Ozone and Sulfur Dioxide on the Yield of Winter Wheat."
Phytopathology, 77:71-74, 1987.
12. Guerdin, R. and D.T. Tingey. "Notwendigkeit und Ableitung von Grenwertzen
fur Stickstoffoxide." Berchte 1/87, Umweltbundesamt, Berlin. Erich
Schmidt Verlag, Berlin; pp. 178, 1987.
13. Heagle, A.S., R.B. Flagler, R.P. Patterson, V.M. Lesser, S.R. Shafer and
W.W. Heck. "Injury and Yield Responses of Soybean to Chronic Doses of
Ozone and Soil Moisture Deficit." Crop Science, 27:1016-1024, 1987.
14. Heagle, A.S., W.W. Heck, V.M. Lesser and J.O. Rawlings. "Effects of
Daily Ozone Exposure Duration and Concentration Fluctuation of Yield of
Tobacco." Phytopathology, 77:856-862, 1987.
15. Lefohn, A.S., H.P. Knudsen, J. Logan, J. Simpson and C. Bhumralkar. "An
Evaluation of the Kriging Method, as Applied by NCLAN, to Predict 7-h
Seasonal Ozone Concentrations." Journal of the Air Pollution Control
Association, 37:595-602, 1987.
16. Lefohn, A.S., W.E. Hogsett and D.T. Tingey. "The Development of Sulfur
Dioxide and Ozone Exposure Profiles that Mimic Ambient Conditions in the Rural
Southeastern United States." Atmospheric Environment, 21(3)-.659-668. 1987.
II1-19
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17. Heck, W.W. "Assessment of Crop Loss from Atmospheric Deposition in the
U.S." A summary presented at the National Association of Conservation
Districts, Reno, NV. 5 pp; Feb. 1-5, 1987.
18. Tingey, D.T., T.J. Moser, D.F. Zirkle, and M.D. Snow. "A Plant Cultural
System for Monitoring Evapotranspiration and Physiological Responses."
International Conference on Measurement of Soil and Plant Water Status,
Logan, UT, 1987.
19. Ziminski, P.K. and S.R. Holman. "An Automated Data Acquisition and Control
System for Air Pollution Research." HP Chronicle, pp. 12-15; March 1987.
20. Flagler, R.B., R.P. Patterson, A.S. Heagle, and W.W. Heck. "Ozone and
Soil Moisture Deficit Effects on Nitrogen Metabolism of Soybeans."
Crop Science. (In Press).
21. Heggestad, H.E., E.L. Anderson, T.J. Gish, and E.H. Lee. "Effects of
Ozone and Soil Water Deficit on Roots and Shoots of Fieldgrown Soybeans."
Journal of Environmental Pollution. (In Press).
22. King, D.A." and W. L. Nelson. "Assessing the Impacts of Soil Moisture
Stress on Regional Soybean Yield and its Sensitivity to Ozone." Agriculture
Ecosystems-Environments. (In Press). . .. _.
23. Lefohn, A.S., C.E. David, C.K. Jones, D.T. Tingey, and W.E. Hogsett.
"Co-occurrence Patterns of Gaseous Air Pollutant Pairs at Different Minimum
Concentrations in the United States." Atmospheric Environment. (In Press).
24. Temple, P.J., R.W. Lennox, A. Bytnerowicz, and O.C. Taylor. "Interactive
Effects of Simulated Acidic Fog and Ozone on Field-grown Alfalfa."
Experimental Environmental Botany. (In Press).
25. Blumenthal, D.L., J. Trijonis, R. Kelso, M. Pitchford, M. McGown, T.
Dodson, R. Flocchini, A. Pitchford, A. Waggoner, and J. Ouimette. "Design
and Initial Findings of the RESOLVE Desert Visibility Study," Proceedings
of the APCA Specialty Conference on Visibility Protection—Research and
Policy Aspects, 1987.
26. Trijonis, J.C. and M. McGown, "Preliminary Extinction Budget Results from
the RESOLVE Program," Proceedings of the APCA Specialty Conference on
Visibility Protection—Research and Policy Aspects, 1987.
27. Pitchford, M. and M. McGown, "An Approach for Calculating Inherent Contrast
of Teleradiometer Targets," Proceedings of the APCA Specialty Conference
on Visibility Protection—Research and Policy Aspects, 1987.
28. Blumenthal, D.L., R. Flocchini, T.B. Smith, W.R. Knuth, and M. McGown.
"Meterological Regimes and Transport Patterns Associated with Visibility
Impairment in the California High Desert Region," Proceedings of the APCA
Specialty Conference on Visibility Protection—Research and Policy
Aspects, 1987.
III-2U
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29. Tombach, I., W. Malm, and M. Pitchford. "Performance Criteria for Monitoring
Visibility-Related Variables," Proceedings of the APCA Specialty Conference
on Visibility Protection—Research and Policy Aspects, 1987.
30. U.S. Environmental Protection Agency. User's Guide: Visibility Module
which Converts Aerosol Concentrations to Visibility Parameters-An Empirical
Relationship for Calculating Visibility Distance from Particle Concentrations
Calculated by Regional Models.
31. Srivastova, R. and J.A. Mulholland. "Low NOx, High"Efficiency, Multi-
Staged Burner: Gaseous Fuel Results," Environmental Progress, 1:63-70, 1987.
32. Electric Power Research Institute/U.S. Environmental Protection Agency.
Proceedings of 1987 Joint EPA-EPRI Symposium on Stationary Combustion NOX
Control, 1987.
33. U.S. Environmental Protection Agency. "Report on Surrogate Species
Chemical Reaction Mechanisms for Urban-Scale Simulation Models, Vol. 1--
Adaptation of the Mechanism, Vol. 2~Guidelines tor Using the Mechanism."
EPA 600/3-87/014a,b. Available from NTIS, Springfield, VA. - PB87-180592
and PB87-180600, 1987.
34. U.S. Environmental Protection Agency. "Chemistry of Oxidant Formation:
Imp-lications for Designing Effective Control Strategies." EPA 600/D-
87/114. Available from NTIS, Springfield, VA, PB87-179990, 1987.
35. U.S. Environmental Protection Agency. "Contributions of the Fluid Modeling
Facility to EPA's Complex Terrain Model Development." EPA 600/3/-87/026.
Available from NTIS, Springfield, VA, PB87-227682, 1987.
36. Victery, W. "Review of Health Effects of Substitutes for Chromates in
Comfort Cooling Water Treatment Program." EPA 60U/X-87/079, 1987.
37. U.S. Environmental Protection Agency. "Health Assessment Document for
Beryllium." EPA 600/8-84/026F, 1987.
38. U.S. Environmental Protection Agency. "Health Assessment Document for
Acrolein." EPA 600/8-86-014A. Available from NTIS, Springfield, VA;
PB87-139960/AS, 1986.
39. U.S. Environmental Protection Agency. "Health Assessment Document for
Acetaldehyde." EPA 600/8-86/OlbA. Available from NTIS, Springfield, VA;
PB87-202446, 1987.
40. U.S. Environmental Protection Agency. "Health Assessment Document for
Chlorine and Hydrogen Chloride." EPA 600/8-87/041A, 1987.
41. U.S. Environmental Protection Agency. "Health Assessment Document for
Phosgene." EPA 600/8/022A. Available from NTIS, Springfield, VA;
PB87-147039/AS, 1986.
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42. U.S. Environmental Protection Agency. "Summary Review of Health Effects
Associated with Sodium Hydroxide: Health Issue Assessment." Draft No.
ECAO-R-135, 1987.
43. U.S. Environmental Protection Agency. "Summary Review of Health Effect
Associated with Hydrogen Cyanide: Health Issue Assessment." Draft No.
ECAO-R-133A, 1987.
44. U.S. Environmental Protection Agency. "Summary Rev-iew of Health Associated
with Hydrogen Fluoride: Health Issue Assessment." Draft No. ECAO-R-131,
1987.
45. U.S. Environmental Protection Agency. "Summary of Health Effects Associated
with Elemental and Inorganic Phosphorous Compounds: Health Issue Assessment."
Draft No. ECAU-R-132A, 1987.
46. U.S. Environmental Protection Agency. "Summary Review of Health Effects
Associated with Organic Phosphorous Compounds: Health Issue Assessment."
Draft No. ECAO-R-199, 1987.
47. U.S. Environmental Protection Agency. "Summary Review of Health Effects
Associated with Methanol: Health Issue Assessment." Draft No. ECAO-R-134A,
1987. — - - _
48. U.S. Environmental Protection Agency. "Summary Review of Health Effects
Associated Dimethyl amine: Health Issue Assessment." Draft No. ECAO-R-149,
1987.
49. U.S. Environmental Protection Agency. "Summary Review of Health Effects
Associated with Mineral Fibers other than Asbestos: Health Issue Assessment."
Draft No. ECAO-R-053A, 1987.
50. U.S. Environmental Protection Agency. "Summary Review of Health Effects
Associated with Naphthalene: Health Issue Assessment." Draft No.
ECAO-R-U77A, 1987.
51. U.S. Environmental Protection Agency. "Summary Review of the Health
Effects Associated with Propylene Oxide: Health Issue Assessment."
EPA 600/8-86/007F. Available from NTIS, Springfield, VA; PB87-216438,
1987.
52. U.S. Environmental Protection Agency. "Summary Review of Health Effects
Associated with Zinc and Zinc Oxide: Health Issue Assessment."
EPA 600/8-87-U22F. Available from NTIS, Springfield, VA; PB88-107628,
1987.
53. Bradow, F.V.; App, A. "Multimedia Approaches to Assessment and Management
of Hazardous Air Contaminants: A Report from NATO/CCMS Follow-up Workshop,"
Denver, Colorado, U.S.A., October 8-1U, 1986. EPA 600/8-87-012. Available
from NTIS, Springfield, VA; PB87-19880/AS, 1987.
II1-22
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54. U.S. Environmental Protection Agency. "Municipal Waste Combustion Research
Plan." Washington, DC: Office of Environmental Engineering and Technology
Demonstration; Draft No. ECAU-R-123, 1987.
55. U.S. Environmental Protection Agency. "Interim Methods for Development
of Inhalation Reference Doses." Draft No. ECAO-R-204, 1987.
56. Wallace, Lance A., The Team Study: Summary and Analysis: Volume 1, U.S.
EPA, Washington, DC 1987. EPA 600/6-87/002a. NTIS PB 88-1000 60.
57. Pellizzari, E.D., Perrit, R., Hartwell, T.D., Michael, L.C., Sheldon,
L.S., Sparacino, C.M., Whitmore, R., Leninger, C., Zelon, H., Handy,
R.W., Smith, D., and Wallace, A., Total Exposure Assessment Methodology
(TEAM) Study; Elizabeth and Bayonne, New Jersey. Devils Lake, North
Dakota, and Greensboro, North Carolina: Volume 11. U.S. EPA, Washington,
DC., 1987. EPA 600/6-87/002b.NTIS PB 88-100078.
58. Pellizzari, E.D., Perrit, R., Hartwell, T.D., Michael, L.C., Whitmore,
R. Handy, R.W., Smith, D., Zelon, H. and Wallace, Lance A., Total
Exposure Assessment Methodology (TEAM) Study; Selected Communities
in Northern and Southern California; Vol. 111.U.S. EPA, Washington,
DC, 1987. EPA 600/6-87/002C. NTIS PB 88-100086.
59. Wai-lace, Lance A., Pell-irzari, E.D., HartweH. T.D., -Sparacino, C.,
Whitmore,' R., Sheldon, L., Zelon, H. and Perritt, R., "The TEAM
Study: Personal Exposures to Toxic Substances in Air, Drinking Water,
and Breath of 400 Residents of New Jersey, North Carolina, and North
Dakota" Environmental Research 43: 290-307, 1987.
60. Pellizzari, Edo, Hartwell, T., Whitmore, R., Michael, L.C., Perritt,
K., Smith, D.J., and Wallace, Lance A., "Personal Exposure and Breath
Monitoring in Subjects of Several California Communities, " Invited
Paper, Workshop on Human Exposure Assessment, October 1-2, 1985,
Harvard University. Submitted to Atmospheric Environment.
61. Wallace, Lance A., Pellizzari, E., Hartwell, T., Perritt, K., and Ziegenfus,
R., "Exposures to Benzene and Other Volatile Organic Compounds from Active
and Passive Smoking, "Archives of Environmental Health, in press.
62. Wallace, Lance A., "Personal Exposures, Indoor and Outdoor Concentra-
tions, and Exhaled Breath Concentrations of Selected Volatile Organic
Compounds Measured for 550 Residents of New Jersey, North Dakota, North
Carolina, Toxicology and Environmental Chemistry, 12: 215-236, 1986.
63. U.S. Environmental Protection Agency, "Atmospheric Persistence of Eight
Air Toxics." EPA 600/3-87/004, NTIS No. PB 81-145306, January I^d7.
64. U.S. Environmental Protection Agency. "The Production of Mutagenic
Compounds as a Result of Urban Photochemistry." EPA 600/3-87/020,
NTIS No. PB87-199675, June 1987.
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65. Hoffman, Alan J.; "Project Description and Sampling for Formaldehyde
Method Intercomparison Study." Environmental Monitoring Systems
Laboratory, Research Triangle Park, NC, October 1987.
66. Ott, Wayne; "Exposure Estimates Based on Computer Generated Activity
Patterns." Paper No. 81-57.6. Presented at the 74th Annual Meeting of
the Air Pollution Control Association, Philadelphia, June 21-26, 1981.
67. Johnson, Ted and Roy, Paul; "The NAAQS Model (NEM) Applied to Carbon
Monoxide." PEDCo Environmental, Inc., 505 South Duke Street, Durham,
NC, September 1983.
68. Flachbart, Peter G. and Clayton, Ah Yo; "Microenvironmental Models of
Commuter Exposure to Carbon Monoxide from Motor Vehicle Exhaust."
Environmental Monitoring and Services, Inc., 4756 Calle Quetzal,
Camarillo, CA, August 1987.
69. Gabele, P.; "The Effects of Fuel Volatility and Methanol Blend Usage
on Evaporative Emissions." Presented at Annual Air Pollution Control
Association Meeting, New York, June 1987.
70. Stump, F. et. al; "The Influence of Ambient Temperature on Tailpipe
Emissions-from Late Model Light-Duty Gasoline Motor Vehicles." Accepted
by-Atmospheric Environment, July 1988. "
71. Braddock, J. N.; "Factors Influencing the Composition and Quantity of
Passenger Car Refueling Emissions - Part II." SAE 880712, Society of
Automotive Engineers, Warrendale, PA, February 1988.
72. Sigsby, J.E., Tejada, S., Ray, W., Lang, J. M., and Duncan, J.W.;
"Volatile Organic Compound Emissions from 46 In-Use Passenger Cars."
Environmental Science Technology 21, 466-475, May 1987.
73. U.S. Environmental Protection Agency. "EPA Indoor Air Quality Implementa-
tion Plan." EPA 600/8-87/031. Available from NTIS, Springfield, VA;
PB87-210746, 1987.
74. U.S. Environmental Protection Agency. "EPA Indoor Air Quality Implementation
Plan. Appendix A: Preliminary Indoor Air Pollution Information Assessment."
EPA 600/8-87-014. Available from NTIS, Springfield, VA; PB87-210746,
1987.
75. U.S. Environmental Protection Agency. "EPA Indoor Air Quality Implementation
Plan. Appendix B: FY 87 Indoor Air Research Program." EPA 600/8-87-032.
Available from NTIS, Springfield, VA; PB87-210746, 1987.
76. U.S. Environmental Protection Agency. "EPA Indoor Air Quality Implementation
Plan. Appendices C and D: Research Needs Assessment and Resources."
EPA 600/8-87/015. Available from NTIS, Springfield, VA; PB87-21076U, 1987.
77. U.S. Environmental Protection Agency. "EPA Indoor Air Quality Implementation
Plan. Appendix E: Indoor Air Reference Data Base." EPA 600/8-87-016.
Available from NTIS, Springfield, VA; PB87-210761, 1987.
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78. Barnes. P.M., S.W. Flynt, and M.M. Caldwell. "Photosynthetic Damage and
Protective Pigments in Plants from a Latitudinal Arctic/Alpine Gradient
Exposed to Supplemental UV-B Radiation in the Field. Arctic and Alpine
Research 19:21-27, 1987.
79. Teramura, A.H., and J.H. Sullivan. "Soybean Growth Responses to Enhanced
Levels of Ultraviolet-B Radiation Under Greenhouse Conditions." American
Journal of Botany 74(7):97b-979, 1987.
80. Barnes, P.W., P.M. Jordan, W.G. Gold, S.D. Flynt, and M.M. Cal dwell.
"Competition, Morphology, and Canopy Structure in Wheat (Tritium
aestivum) and Wild Oat (Avena Fatua) Exposed to Enhanced Ultraviolet-
B Radiation." Functional Ecology (submitted).
81. Murali, N.S., A.M. Teramura, and S.K. Randall. "Ultraviolet-B Sensitivity
Differences Between Two Soybean Cultivars: Possible Causes." Physiologia
Plantarum (submitted).
82. Murali, N.S., and A.H. Termura. "Insensitivity of Soybean Photosynthesis
to Ultraviolet-B Radiation Under Phosphorous Efficiency." Journal of Plant
Nutrition 10:1-10, 1987. .
83. Caldwell,-MjM. -"Plant Architecture and Resource Competition." Potentials
and-Limitations of Ecosystem Analysis (E. Schulze and H. Zwoelfer, eds.),
pp. 164-179. Springer-Verlag, 1987.
84. Sullivan, J.H., and Teramura. " The Effects of Ultraviolet-B Irradiation on
Seeding Growth in the Pinaceae." American Journal of Botany (in press), 1987.
85. Thomson, B.E., R.C. Worrest, and A. Robinson. "The Effect of UV-B Radiation
(290-320 nm) on Travel Development in Four Species of Bivalve Mollusk."
Journal of Experimental Marine Biology and Ecology (submitted).
86. Seilokop, S.K., "Evaluation of the National Trends Network's Site Placement
Design." Project report on EPA Contract # 68-01-6849 (027), June 1987.
87. Daly, D.S., and Olsen, A.R., "Seasonal Deposition of Acidifying Substances."
Project report on EPA/DOE contract # DE-AC06-76RLO 1830, August 1987.
88. Olsen, A.R. "Trends Analysis of Wet Deposition Data." Project report on
EPA/DOE contract # DE-AC06-76RLO 1830, September 1987.
89. Dennis, R. "Southeast Siting Study for the National Dry Deposition Network."
Internal EPA report, June 1987.
90. Dennis, R., "Interim Estimates of Annual Dry Sulfur Deposition for the
Eastern United States for the Aquatics Research Program." Internal EPA
report, August 1987.
91. Spence, J.W., and Haynie, F.H.; "Research Plan for Determining the Effects of
Acid Deposition on Exterior Coatings." Internal EPA report, February 1987.
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IV. DEVELOPMENT OF NATIONAL AMBIENT AIR QUALITY STANDARDS
A. DESCRIPTION OF ACTIVITIES
The 1977 Clean Air Act Amendments require EPA regularly to review and,
if appropriate, to revi.se all of the national ambient air quality standards.
The review of the particulate matter air quality standard-was completed in
1987 and reviews of other standards were in process.
On July 1, 1987, EPA promulgated revisions to the air quality standard
for particulate matter1. The revised standard replaced total suspended
particulate matter (TSP) as the indicator for particulate matter for ambient
standards with a new one that includes only those particles less than or
equal to 10 micrometers in diameter (PM^o) anc* replaced the 24-hour primary TSP
standard with a 24-hour PMio standard of 150 micrograms per cubic meter with no
more than one expected exceedance per year. In addition, the revised standards
replaced the annual primary TSP standard with an annual PM^o standard of 50
micrograms per cubic meter expected annual arithmetic mean, and replaced the
secondary TSP standard with 24-hour.and annual PMio standards that are identical
to the primary standards in all respects. The July 1 notice also announced a new
reference method for-measuring PMiy in the ambient air as well as final
regulations concerning ambtent air monitoring reference and equivalent methods,
ambient air quality surveillance, and implementation requirements.
Also on July 1, 1987, EPA published an advance notice of proposed
rulemaking soliciting public comment regarding the development of a new
secondary ambient air quality standard for fine particles (those particles
less than 2.5 micrometers in aerodynamic diameter)2. This action represents
a continuation of the review process for secondary standards for particulate
matter. This secondary standard would address regional haze conditions
associated with elevated levels of fine particles. The notice specifically
asked for comment on the regional character of visibility, determination of
adverse effects, pollutant/visibility/source-receptor relationships, and
timing of standards development with respect to acid deposition strategies.
The public comment period on the advance notice closed on September 29, 1987.
(For related information on visibility protection, see Chapter VI, Section A,
Visibility Protection in Federal Class I Areas.)
In April 1986, the Clean Air Scientific Advisory Committee (CASAC)
reviewed a revised draft of the ozone criteria document and the first draft
of the ozone staff paper. The CASAC completed its review of the criteria
document in October 1986. At a December 1987 meeting, CASAC reviewed a
revised staff paper and a research summary of more recent studies. Issues
were discussed regarding the existing 1-hour standard and the possible need
for new longer-term standards to protect against chronic health and welfare
effects. At the conclusion of this session CASAC did not feel the group had
reached a point where it was adequately prepared to articulate and communicate
its recommendations to the EPA Administrator and thus it called for an
additional meeting in 1988. The CASAC plans to make recommendations to EPA
following this meeting.
IV-1
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Reviews of the carbon monoxide and nitrogen dioxide air quality standards
were completed in 1985. The EPA began the process of preparing a new criteria
document for carbon monoxide in 1987. The EPA is following several ongoing
studies of the health effects of carbon monoxide, including a major study
which should better identify the relationship between carbon monoxide and
possible aggravation of pre-existing cardiovascular disease. Results from
this study are expected to be released in 1988. An external review draft of
the revised criteria document is also scheduled to be available for public
review in 1988. Development of the criteria document for.nitrogen dioxide
will be initiated in 1989.
Activities related to the review of the sulfur oxides air quality standard
in 1987 focused on completing the staff paper addendum^ and the development
of a regulatory package. The CASAC reviewed a draft of the addendum in
October 1986 and submitted its closure letter in February 1987. The EPA anticipates
announcing a proposed decision on whether to reaffirm or revise the standards
in 1988.
With respect to the review of the ambient standard for lead, activities
focused on updating and validating the lead exposure methodology. It is
anticipated that CASAC will review a .revised draft of the staff paper in
1988. .
Al-so during 1987, EPA -prepared a draft document entitled "Acid Aerosols
Issues Paper" which assesses the available scientific and technical information
on the health effects of acid aerosols and identifies critical research
needs. The draft paper will be reviewed by CASAC in early 1988.
B. REFERENCES
1. 52 FR 24634, July 1, 1987.
2. 52 FR 24670, July 1, 1987.
3. Review of the National Ambient Air Quality Standards for Sulfur Oxides:
Updated Assessment of Scientific and Technical Information. Addendum to
the 1982 OAQPS Staff Paper, EPA 450/86-013, December 1986.
IV-2
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V. ASSESSMENT AND CONTROL OF TOXIC AIR POLLUTANTS
A. INTRODUCTION
In 1985, EPA announced its strategy for the control of both routine and
accidental releases of toxic air pollutants.! The following sections discuss
the activities and progress made in 1987 to implement this strategy.
B. ASSESSMENT AND REGULATORY DECISIONS
In 1987, EPA continued to implement an active program to screen and
assess potentially toxic air pollutants for possible regulation under the
Clean Air Act or other environmental authorities. As shown in Table V-l,
34 chemicals or emission mixtures were in various stages of assessment at the
end of 1987. Decisions not to pursue a regulatory program directed specifically
at copper2 and zinc and zinc oxide3 were published in 1987. Decisions on
whether to regulate 5-10 additional pollutants are expected in 1988.
In 1987, final efforts were completed for a report to Congress on the
National Dioxia Study, which was a coordinated effort of various EPA programs
to .assess the potential extent of contamination of the environment with
chlorinated dioxin compounds. Air related activities were centered in Tier 4
of the study,4 which primarily addressed combustion sources and emissions to
the atmosphere. In addition to the report to Congress, other supporting
technical reports have been published which address engineering and air
quality data analysis.
In June 1987, EPA also published a report to Congress on municipal waste
combustors (MWC).5 The report addresses EPA's preliminary assessment of the
multi-media aspects of MWC, including releases to the air of dioxins, furans,
acid gas, and hydrocarbons as well as traditional air pollutants. Based on
the results of this study, EPA published an advance notice of proposed rulemaking
in July 1987 that announced its intent to regulate municipal waste combustion
under sections lll(b) and lll(d) of the Clean Air Act.6
C. FEDERAL REGULATORY PROGRAM - STATIONARY SOURCES
1. National Emission Standards for Hazardous Air Pollutants (NESHAP)
° Vinyl Chloride - In July 1987, the U.S. Court of Appeals for the
District of Columbia Circuit vacated EPA's 1985 withdrawal of a proposed
revision of the NESHAP for vinyl chloride. In remanding the standard to EPA
for reconsideration, the court held that EPA had not shown that the vinyl
chloride standard adequately protects public health within the meaning of
Section 112 of the Clean Air Act. The EPA is in the process of considering
how to respond to the remand.
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0 Benzene - In June 1984, EPA promulgated a NESHAP for benzene
equipment leaks and withdrew proposed NESHAP for benzene emissions from
maleic anhydride plants, ethylbenzene/styrene plants, and benzene storage
tanks. Following the vinyl chloride decision, EPA voluntarily accepted a
remand of the benzene NESHAP to reconsider the three withdrawn benzene
proposals and the benzene fugitive NESHAP. Final action on the remand is
expected to be published in 1989. In addition, work continued in 1987 on a
NESHAP for coke oven by-product plants.
0 Asbestos - Work continued on revising the asbestos NESHAP during
1987. The revision will cover the demolition and renovation provisions and
monitoring requirements for several other source categories.
0 Mercury - A revision to the mercury NESHAP was promulgated in
1987.7
0 Chromium - During 1987, NESHAP development continued for chromium
emissions from electroplating and industrial cooling towers. Regulations to
prohibit the use of chromium in comfort cooling towers are being considered
under the authority of the Toxic Substances Control Act. Other chromium
sources st'ill under consideration for NESHAP include utility boilers, industrial
boilers, chromium chemical manufacturing, steel production, refractory
manufacturing,_sewage sludge incinerators, municipal incinerators, cement
manufacturing, chromite ore- refining, and ferrochromium production.
0 Coke oven emissions - A proposed NESHAP for coke oven emissions^
was published in 1987.A supplemental proposal will be published in 1989 to
reevaluate the proposed standard consistent with the above-mentioned court
decision on vinyl chloride.
0 Ethylene Oxide - Work continued in 1987 on a NESHAP for commercial
^
ch
sterilization chambers.
0 Hazardous Organic NESHAP (HON) - The HON is an accelerated NESHAP
development effort that will cover eight organic compounds (ethylene oxide,
methylene chloride, ethylene dichloride, perchloroethylene, trichloroethylene,
butadiene, chloroform, and carbon tetrachloride) for which intentions to list
under section 112 of the Clean Air Act have been published. The HON will
cover 13 source categories in the organic chemicals industry. Publication of
a proposed rule is scheduled for 1988.
0 Perchlorpethylene - A decision to propose a NESHAP for control of
perchloroethylene emissions from drycleaning industry sources resulted from
an EPA precedent-setting effort to integrate cross-media analyses of health
and enviroi ;ental exposure risks associated with chlorinated solvents. This
analysis was conducted as part of an Interagency Chlorinated Solvents
investigation in which EPA decided to first look at the total risk potential
and then to consider what regulatory controls would be appropriate and under
what statutory authority. The EPA is proceeding with development of a NESHAP
for control of perchloroethylene emissions from drycleaning industry sources.
0 Radionuclides - EPA also requested a voluntary remand of all
radionuclide NESHAP and is presently working to repropose regulatory decisions
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for 12 source categories: Nuclear Regulatory Commission (NRC)-licensees,
Department of Energy (DOE) facilities, radon emissions from DOE facilities,
high-level waste facilities, uranium fuel cycle facilities, elemental phosphorus
plants, coal fired boilers, underground uranium mines, open pit uranium
mines, phosphogypsum piles, active mill tailing piles and disposed mill
tailings. In the past, the EPA has decided not to promulgate NESHAP for radon
emissions from DOE facilities, high-level waste facilities, uranium fuel
cycle facilities, open pit uranium mines and phosphogypsum piles. As part of
the repromulgation process EPA will reconsider whether NESHAP are necessary
for all or some of these source categories.
Also in the area of radiation, EPA's air program began development in
1987 of a regulation to control the disposal of low level radioactive waste
under the authority of the Toxic Substitutes Control Act (TSCA).
0 Solvent Decreasing - Work continued in 1987 on a NESHAP for
solvent degreasing equipment. The NESHAP will address emissions of
perchloroethylene, trichloroethylene, and methylene chloride.
0 Cadmiurn - Decisions on which source categories of cadmium warrant
regulation are- still under consideration. The categories under consideration
are primary cadmium smelters, lead smelters, copper smelters, pigments
manufacturi ng^-stabi-lizers manufacturing, and zinc and zinc oxides production.
0 Municipal Waste Combustors - A detailed risk and control technology
assessment was published in 1987. As a result, EPA issued a notice in the
Federal Register that announced its intent to regulate emissions from new and
modified municipal waste combustors using new source performance standards.9
Pollutants to be regulated are expected to include one or more designated
pollutants (pollutants not regulated under sections 108-110 or 112) thus
invoking section lll(d) of the Clean Air Act which would require States to
develop additional emissions standards for existing municipal waste combustors
units.
0 Municipal Landfills - Work commenced in 1987 on a rule to regulate
emissions from new and modified municipal landfills using new source performance
standards. Pollutants to be regulated are expected to include one or more
designated pollutants thus invoking section lll(d) of the Clean Air Act.
Section lll(d) would require States to develop emission standards for existing
landfills. Pollutants of concern include volatile organic compounds and a
number of toxic compounds (e.g. methylene chloride, vinyl chloride, and
benzene).
2. Hazardous Waste Treatment, Storage, and Disposal Facilities (TSDF)
In November 1984, the Resource Conservation and Recovery Act (RCRA)
was reauthorized. Section 3004(n) of the reauthorization requires EPA to
promulgate such regulations for the monitoring and control of air emissions
at hazardous waste TSDF's as may be necessary to protect human health and the
environment. Air emission sources of concern include surface impoundments,
landfills, land treatment units, waste piles, wastewater treatment systems,
pretreatment units, and transfer, storage and handling operations. The
number of TSDF facilities is currently estimated at between 2,000 - 3,000.
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Preliminary assessments of the industry show that TSDF's may pose
significant health and environmental risks to the air. Emissions of volatile
organic compounds (VOC's), which lead to ozone formation, may be as high as
10 percent of the total nationwide VOC emissions. In addition, cancer incidence
from toxic compounds may be as high as 140 cases per year. There is a great
deal of uncertainty in these estimates, and a better understanding will be
gained over the course of the regulatory development process.
Current plans call for development of TSDF regulations in three phases:
0 The first group of standards addresses sources for which EPA can
develop standards relatively quickly because similar sources have already
been regulated under the Clean Air Act. These standards address air emission
vent and fugitive emissions from some of the treatment devices that will be
used to meet the RCRA land disposal restrictions. The standards were proposed
in 1987.10
0 The second group of standards, which addresses the bulk of the
TSDF sources, is scheduled for proposal in 1989. The sources to be included in
this proposal are landfills, surface impoundments, land treatment, pretreatment,
waste piles, wastewater treatment tanks,, and transfer, storage, and handling
facilities.
" — ° The third group" of regulations will cover certain subsets of the
seven TSDF source categories for which EPA will likely be unable to develop
rules during the second round. These may include dewatering devices (belt
presses, filter presses, and centrifuges) and waste fixation in the
pretreatment source category and operations associated with containers
(filling, emptying, cleaning, etc.). Less data exist on these sources to
quantify the extent of the problem or to address the solution. In addition,
the land ban rules being developed under other sections of RCRA will require
treatment before disposal of hazardous wastes. This program is expected to
cause major shifts in the TSDF industry and could cause new sources of air
pollution which need to be addressed as the industry develops new treatment
technologies. Work on the third group of TSDF's is expected to begin in
1989.
D. MOBILE SOURCES
(Mobile source activities related to air toxics are described in
Chapter IX of this report.)
E. SPECIFIC POINT SOURCES
In 1987, EPA continued to pursue that portion of its overall strategy
to control emissions of air toxics that provides State and local air
pollution control agencies with funding and technical support to evaluate
specific point sources. Sources that are candidates for this program include
those that have been identified through the Federal toxic air pollutant
assessment program as well as those certified by State and local air pollution
control agencies. This program was initiated in 1984 with a pilot program
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involving the chemical acrylonitrile, a carcinogen for which the public
health risks are limited due to the existence of only a limited number of
industrial facilities. As previously reported, evaluations involving all 26
acrylonitrile facilities in 14 States have been completed and the reports
accepted by the appropriate State and local agencies. Additional control
will be achieved at 15 of the 26 facilities, with total acrylonitrile emissions
being reduced by 50 percent after all controls are implemented. In addition,
maximum risk to the most exposed individual will be reduced by 60 percent,
and the predicted cancer incidence is expected to decrease by 66 percent.
In 1987, funding was provided for 22 State and local agency evaluations of
potential high risk point sources in a variety of source categories. This
program is expected to proceed like the one for acrylonitrile, but in a less
formal way. In selecting these facilities for inclusion in the program,
a variety of factors was considered, including the magnitude of the perceived
risk, the likelihood of further air toxics program development, the availability
of resources, the potential for overlap with other programs, and the national
applicability of the reported findings.
In 1988, additional guidance will -be provided to State and local control
agencies on how to identify and evaluate high risk point sources. The guidance
will incorporate knowledge gained from the acrylonitrile efforts and the
additional source .evaluations begun in 1987. State and local agencies will
then screen a reasonable-number of candidate high risk point sources in order
to take appropriate follow-up action.
F. ASSESSING URBAN RISK
In 1986, EPA initiated planning activities to encourage States to undertake
new efforts toward assessing the scope and seriousness of current exposures to
mixtures of air toxic compounds which are believed commonplace in large metro-
politan areas. The EPA provided funds under section 105 of the Clean Air Act
and technical assistance to States to encourage them to undertake such
assessment efforts in a number of areas. Initially, 30 areas with populations
over one million people were targeted for some level of assessment. State-
initiated efforts included ambient monitoring, source/emission inventory
analyses, and risk assessment activities to help determine whether such
problems indeed exist and, if so, how serious they are.
In 1987, available funds were provided to States through EPA Regional
Offices, technical guidance was developed and distributed, and available oppor-
tunities were utilized to provide evidence of the existence of the problem
and promotion of assessment programs. As a result of these activities and of
independent actions on the part of State and local agencies, several activities
have been initiated and in many cases have progressed to an advanced stage.
For example, nineteen toxic air quality sampling sites in eighteen urban areas
are now collecting data as part of EPA's Urban Air Toxics Sampling Program.
Many areas are inventorying toxic air pollutant emissions and several have
initiated or completed major studies aimed at assessing urban air toxics
impacts and risks.
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In addition, activity on several Integrated Environmental Management
Projects (IEMP) was continued. These projects, while multimedia in nature,
focus a major portion of study on the air toxics aspects of the urban environ-
ment. The Kanawha Valley (West Virginia) Phase I study has been concluded and
sampling is well advanced in the Denver IEMP Study. Separate efforts in
areas such as Staten Island, New York will provide further assessments of the
problem. Such work is expected to result in some determination of what
mitigation activities might be warranted. In addition, a large local program
was also completed in the Los Angeles, California area.. . .
The EPA also distributed additional guidance in 1987 on procedures for
estimating air emissions for selected potentially toxic pollutants. Final
reports were distributed for benzene and storage tanks and a compilation of
emission factors for air toxics compounds was prepared. Other emission
estimation reports are now in review for municipal incinerators and sewage
sludge incinerators. These documents are scheduled for publication in 1988.
Additional work includes development of improved emission factors for various
area sources of toxic air pollutants and guidance for developing emission
inventories for air toxics.
G. BUILDING STATE AND LOCAL AIR TOXICS CONTROL PROGRAMS
The EPA has established^ goal to have quality programs in every State
and major local agency that are adequate to carry out certain roles envisioned
within the national air toxics strategy. These roles are: (1) accepting
delegation and enforcing NESHAP, (2) identifying , evaluating, and mitigating
(as necessary) point sources of local concern not addressed by NESHAP, (3)
addressing urban problems arising from complex multisource, multipollutant
interactions, and (4) enhancing program capabilities to conduct applicable
activities in the first three areas and to facilitate implementation of other
programs specific to the needs of each State or community.
During 1987, considerable progress was made toward meeting this goal.
The progress was in part due to EPA's program to enhance State and local
program development. This program uses available grant funds to promote
multiyear planning on the part of State and local agencies and subsequent
implementation of these plans for building their air toxics capabilities and
programs. Within a multiyear development plan, State and local agencies were
encouraged to develop and conduct the above-mentioned activities related to
EPA's national strategy. In response, EPA has now received about 70 multiyear
development plans from 49 States and 21 local agencies. The major emphasis
of the current State and local activities within these plans varies. Most,
however, focus on development of toxic emissions inventories and modifying
existing new source review permit systems to incorporate consideration of air
toxic concerns. Other State and local agencies are actively developing more
comprehensive regulations to address both new and existing sources while a
few are actually implementing such programs. In all, the amount of State and
local program development has about doubled since 1983.
To assist in implementation of multiyear development plan activities, EPA
expanded its program of technical support in 1987. First, EPA continued its
practice of developing and distributing technical assistance documents for
V-6
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assisting State and local agencies in estimating air toxics emissions. A series
of documents on locating and estimating emissions of various air toxic pollutants
(or sources) now covers sixteen pollutants with the release of reports on
polycyclic organics and polychlorinated biphenyls in 1987. Documents on
benzene, storage tanks, and municipal and sewage sludge incinerators will be
distributed in 1988. A compilation of toxic air pollutants was distributed
in 1987 and is being expanded and improved for release again in 1988. Other
documents designed to assist State and local agencies, including a guide for
associating source categories with various pollutants and a compilation of
air toxics questionnaires, will be released in 1988. Next,. EPA's Control
Technology Center (CTC) became fully operational (see below) in 1987 and
activities of the National Air Toxics Information Clearinghouse were also
continued (see below). Finally, a series of national workshops were
conducted to assist State and local agencies in the basic aspects of program
development and implementation. These workshops were conducted by EPA in
conjunction with the State and Territorial Air Pollution Program Administrators
(STAPPA) and the Association of Local Air Pollution Control Officials
(ALAPCO). The workshops were well-attended and were cited by State and local
agencies as a successful example of how they were able to work cooperatively
with EPA.
In 1987, EPA continued to operate and improve the National Air Toxics
Information Clearinghouse (NATICH). the most significant improvement was
the development .of, a-, system to allow State and local agency personnel to add
or r-evis.e data for their-.agency in the NATICtt computer ft-les electronically
rather than by hard copy reporting. Established in 1983, the Clearinghouse
provides a tangible method of improving communication among EPA and State
and local agencies. The Clearinghouse is funded by EPA and is a cooperative
effort among EPA, STAPPA and ALAPCO. The goal of the Clearinghouse is to
disseminate information about activities under way 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 the status and scope of air toxics control programs and
state-adopted acceptable ambient levels; (2) source permit data, including
the number of air toxics permits issued .by an agency, site-specific permit
data, pollutant-specific emission limits, and required control technology;
(3) source test data, including quantities of pollutants emitted from specific
sites and sampling and analytical techniques used; (4) ambient monitoring
methods in use; (5) bibliographic citations for reports and Federal Register
notices related to air toxics; (6) ongoing research and regulatory development
activity descriptions; (7) emissions inventory information; and (8) selected
EPA risk assessment results. With the implementation of the NATICH data
base, the Clearinghouse users (e.g., State and local air quality management
agencies, EPA, industry, environmental groups, and the public) may now have
direct access to the Clearinghouse information through interactive programs.
In addition to direct computer access to the data base, hardcopy reportsll»12,13
of the data base information are printed and distributed annually. Other
Clearinghouse publications distributed in 1987 include four issues of the
Newsletter and a special report on qualitative and quantitative cancer risk
assessment14. Plans for 1988 include continuation of the prior publications,
publication of a special report on risk communication and updates of users'
guides, increasing publication of the Clearinghouse Newsletter to six issues,
and streamlining the on-line data base.
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The CTC completed its first year of operation in 1987. The CTC supports
the implementation of State and local programs by providing technical
assistance and support on air pollution control technology. While the major
portion of the CTC's assistance efforts in 1987 have been related to air
toxics, the CTC is designed to respond to control problems for criteria
pollutants as well. The CTC provides three levels of assistance:
1. Hotline. The CTC Hotline provides an initial, rapid response based
on information available immediately from EPA staff and contractors.
In 1987, the hotline responded to over 200 requests from State and
local agencies.
2. Engineering Assistance. In some cases, it is appropriate to go
beyond the rapid response level of support and provide more detailed
engineering assistance. Assistance may include engineering analysis
and on-site support tailored for each situation. In 1987, the CTC
provided direct engineering assistance to three States. In each
case, a State or EPA Regional Office had requested support in
resolving technical issues involved with regulations development or
permitting.
3. Technical Guidance. The third level of support involves programs to
transfer available technical"information on state-of-the art pollution
"- controls to State and local agencies. Guidance prepared by the CTC
-^ .^ focuses"on current,topics of national interest that come apparent
"through contact with control agencies. In 1987, the CTC published and
distributed a document on the control of toxic and organic emissions
from air stripping towers.15 in addition, work was under way in 1987 on
a series of workshops for State and local agencies on permitting toxic
air pollution sources and on personal computer-based software to help
evaluate applications for operating permits tor air toxics. Both of
these products will be available in 1988.
H. REFERENCES
1. "A Strategy to Reduce Risks to Public Health from Air Toxics,"
June 1985.
2. 52 FR 5496, February 23, 1987.
3. 52 FR 32597, August 28, 1987.
4. "National Dioxin Study Tier 4 Combustion Sources, EPA-450/4-84-014g,
September 1987.
5. "Municipal Waste Combustion Study: Report to Congress,"
EPA/53U-SW-87-U2/a-i, June 1987.
6. 52 FR 25399, July 7, 1987.
7. 52 FR 8724, March 19, 1987.
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8. 52 FR 36594, September 20, 1987.
9. 52 FR 25399, July 7, 1987.
10. 52 FR 3748, February 5, 1987.
11. "NATICH Data Base Report on State, Local and EPA Air Toxics Activities,"
July 1987, EPA-450/5-87-UU6.
12. "Bibliography of Selected Reports and Federal Register Notices Related
to Air Toxics (Vols. 1 and 2)," July 1987, EPA-450/5-87-CHJ5.
13. "Ongoing Research and Regulatory Development Projects," June 1987,
EPA-450/5-87-004.
14. "Qualitative and Quantitative Carcinogenic Risk Assessment," June 1987,
EPA-450/5-87-003.
15. "Air Stripping of Contaminated Water Sources," August 1987,
EPA 450/3-87-017.
V-9
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VI. STATUS OF AIR QUALITY MANAGEMENT PROGRAMS
A. DEVELOPMENT OF POLICY AND REGULATIONS
Parti oil ate Matter Implementation Policy and Guidance
On July 1, 1987, in conjunction with the promulgation of the revised
national ambient air quality standard, EPA published revised particulate
matter implementation and monitoring regulations and guidelines. 1 The
regulations require the States to revise their implementation plans to attain
and maintain the new standards for ambient particul ate matter in the size range
of 10 micrometers and smaller (PMio). However, due to a lack of current PMio
data, EPA used other particul ate matter data to determine which areas would
be required to develop new control strategies to attain the revised standards.
Since these data were not directly correlatable to PMio, EPA developed a
probability guideline to relate the data to PMio. Using the probability
guideline and other information, EPA classified all areas of the country as
Group I, II, or III. On August 7, 1987, EPA published a list of 68 counties
(or parts of counties) which were classjfied as Group I or as having a high
probability of violating the PMio standards, and a list of 112 counties which
are Group II or where the data are inconclusive. 2 The rest of the country was
classified as Group III or having a high probability of attaining the PMiQ
standards. FojLjth.e JEroujx 1 areas , EPA's policy called upon the States to
immediately revise their pa-rticul ate matter State implementation plans (SIP's)
to include new control strategies and emission limitations which will result
in attainment of the PMio air quality standards. For the Group II areas,
EPA's policy called for intensive monitoring to determine if the area is
attaining the PMio standards. If violations of the PMio standards are observed,
the States were to revise their SIP's to attain the standards. For Group III
areas, EPA presumed that the existing particul ate matter control program was
adequate to attain and maintain the PMio standards. All States, however,
regardless of the group to which they belonged, were to revise their SIP's to
ensure they contain appropriate definitions of the pollutants being regulated
and that the definitions include PMio, to revise their emergency episode plans
to meet the new significant harm level, to incorporate PMio into their new
source review procedures, and to meet new monitoring requirements.
While EPA revised the new source review requirements to include PMiQ,
it also retained the statutory prevention of significant deterioration (PSD)
increments which prevent significant deterioration of particul ate matter
air quality measured as total suspended particul ate (TSP). The EPA acted in this
way to maintain a PSD program for particulate matter during the time required
to develop new PSD increments for PMiQ. One result of this decision is that
two different indicators of particulate matter, PMio and TSP, will be regulated
as an interim approach to controlling emissions from new source construction.
The EPA's objective is to develop new PMio increments that will prevent
significant air quality deterioration so that the PMiQ increments can be used by
State and local air pollution control agencies in lieu of the TSP increments.
Promulgation of PSD increments for PMio ^s currently scheduled for 1989.
In the April 1985 proposal of its PMio implementation regulations, EPA
proposed to continue its existing rural fugitive dust policy. The EPA received
VI-1
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significant negative comment on that proposal. Therefore, on July 1, 1987,
EPA solicited comment on the need for such a policy and on three alternatives
to the existing policy3. The alternatives differ on the priority given to
attaining either the 24-hour or annual PM^Q standards. The EPA also requested
comment on its definition of the rural fugitive dust area to which the rural
fugitive dust policy applies. On September 30, 1987, EPA closed the comment
period on the proposal.
Post-1987 Ozone/Carbon Monoxide Policy
Over the past 2 years, EPA has been considering how it should deal with
the continuing violations of the national ambient air quality standards for
ozone and carbon monoxide in many urbanized areas across the country. The
latest date for attainment mentioned in the Clean Air Act was December 31,
1987, and it is apparent that many areas have not been able to meet this
deadline. By the end of 1987, law suits to compel EPA to promulgate Federal
implementation plans were pending for Los Angeles, Sacramento, and Ventura
County, California, and for the Chicago metropolitan area.
Since 1970, most of these areas have gone through several rounds of
planning for attainment of these standards, first as a result of the 197U
Clean Air Act and next under the 1977-Amendments to the Act. Each round has
produced new State implementation plans that in turn have produced significant
progress towardjjuontrolling the emissions of pollutants that cause violations
of the .Standards. Despiie-a-H of the progress, ftowever,-it is quite clear
that the present SIP's in in many areas cannot bring attainment and need to
be tightened, in many cases substantially, to produce attainment. The EPA
estimates that at least 50 areas, mostly larger metropolitan areas, will have
failed to meet the standards for either ozone or carbon monoxide, or both, by
December 31, 1987. The EPA is waiting to compile the 1987 air quality data
before making final determinations.
Because of the imminent final attainment date of December 31, 1987, EPA
began 2 years ago to develop a policy for dealing with the likely nonattainment
of a large number of large urbanized areas. The Act does not provide explicit
direction on how to handle these "post-1987" situations although EPA believes
that the Act does provide some guidance. For that reason, EPA began to
develop a policy to guide State and local planners in a new round of planning.
EPA proposed its post-1987 policy in the Federal Register on November 24,
1987.4 jhe proposed strategy incorporates the kinds of measures that can be
implemented by Federal, State, and local governments. It lays out flexible
deadlines that cities and States can meet through careful planning and determined
implementation. It includes sanctions against areas that fail to make adequate
progress and areas that fail to develop plans that demonstrate attainment
within a near-term, fixed attainment date. It would prohibit construction of
major new facilities if attainment of the standards is not projected within 3
or 5 years of EPA's approval of required new State implementation plans.
The EPA intends to evaluate the 1987 air quality data and to begin to issue
calls for new State implementation plans in 1988. States would have 2 years
to develop their plans, although certain commitments would be needed soon
after the SIP calls. Major planning reviews would also be required at specified
intervals to ensure development of the plan.
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Visibility Protection in Federal Class I Areas
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 regulations
implementing this section.5 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 plaintiffs 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 plaintiffs 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. In compliance
with the first part of the settlement agreement, new source review requirements
and a visibility monitoring strategy were proposed for 34 deficient States in
October 1984.6 in a series of actions started on July 12, 1985 and finishing
in 1986, EPA promulgated Federal implementation plans (FIP's) or approved
State-submitted implementation plans to deal with visibility monitoring and
new source review and thus fulfilled its responsibilities under the first
part of "the settlement -agreement.
On September 9, 1986, the court approved a revision to the second part of
the settlement agreement. Under that revised agreement, EPA was allowed to
delay proposing portions of the implementation plans dealing with existing
visibility impairment until August 1988. On November 24, 1987, EPA promulgated
Federal plans for 29 States to satisfy the second part of the settlement
agreement and thereby implement the remaining portions of the 1980 regulations
(For related information on visibility protection, see Chapter IV, Section A.)
Tall Stacks and Other Dispersion Techniques
In July 1985, EPA adopted revisions to regulations originally promulgated
in 1982 which prohibit reliance by stationary sources on stack heights in
excess of "good engineering practice" or on any other dispersion techniques
in lieu of emission controls.8 In accordance with the Clean Air Act, States
were given 9 months to review their rules and source emission limitations and
to revise their SIP's and to resubmit them to EPA as necessary. During 1986,
EPA received SIP revisions from the States in response to the stack height
regulations. Most revisions pertaining to rule changes were processed by EPA
by the end of 1987. SIP revisions pertaining to source emission limitations
continued to be received and processed in 1987.
Several interested parties filed for judicial review of the revised
stack height regulations and, in addition, several of those parties also
filed petitions for reconsideration of those regulations. Some of the
petitions which dealt with a specific source were denied in April 1986.9
Since the other petitions dealt with the basic legal foundations for the
regulations, EPA deferred responding to them until judicial review of the
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revised regulations was completed. The Court of Appeals for the D.C. Circuit
responded to the petitions in January 1988. While upholding EPA's regulations
in most respects, it remanded to EPA three issues relative to a grandfathering
provisions, stack height credits allowed to certain pre-1979 sources, and
certain sources with merged stacks.
B. PREVENTION OF SIGNIFICANT DETERIORATION AND NONATTAINMENT NEW
SOURCE REVIEW ACTIVITIES
The EPA made significant progress in 1987 in carrying out its responsi-
bilities under the Clean Air Act regarding the preconstruction review of new
and modified stationary sources. Major 1987 activities are described below.
PSD Program Transfer
The EPA continues to emphasize the importance of high quality transfers
of PSD and new source review 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 1987, EPA continued its progress in
transferring iapjemeotation of the PSD program to. State and local agencies.
The majority of PSD permits^ :2Fre now issued by these agencies. Although
several transfers are presently being held up by litigation and resulting
policy clarification, progress was made nevertheless. As of the end of 1987,
47 State and local agencies had either full delegation of the PSD program or
a PSD SIP, and 6 more had partial responsibility for the PSD program.
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 1983.10 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, health and welfare equivalence when netting
emissions, and offset credit for past source shutdowns. At the end of 1986, EPA
had prepared final action on a significant portion of the settlement. These
documents underwent internal EPA review during 1986. During that review, a
number of controversial issues emerged which required EPA resolution. Publica-
tion of a final action on a portion of the CMA suit (Exhibit A) is planned
for 1988 and final action on the second portion (Exhibit B) is planned for 1990.
An important related matter of controversy has been the definition
of "source" for the purposes of nonattainment new source review. The Clean
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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.11 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,
1981.12 The Natural Resources Defense Council (NRDC) claimed that the plantwide
definition is inconsistent with the Clean Air 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. In- 1987» EPA developed a
policy which will aid the Regions in processing proposed SIP's converting to
a plantwide definition. This policy should significantly accelerate the
processing of revisions to the nonattainment portions of SIP's.
In an August 7, 1980 promulgation, EPA listed 30 source categories for
which fugitive emissions would be included in PSD applicability determinations.il
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. In October 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 new source review.13 The EPA further proposed to
extend the requirements for inclusion" of fugitive emissions to surface coal
mining operations.l^: According to the rulemaking criteria established by EPA,
the.^proposed-listing of slir-fa-ee 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. A regulatory
impact analysis was prepared on that proposal and was made available for
public comment in early 1986. During 1987, EPA held a public hearing on the
regulatory analysis and analyzed the issues which were raised by the impact
analysis. In addition, EPA consulted with the Department of the Interior on
various matters related to the regulation of strip mines. Final action on
this issue is under development.
PSD Regulations for Nitrogen Oxides
In 1986, the Sierra Club and other environmental groups filed suit to
force EPA to develop PSD regulations for nitrogen oxides (NOX), as required
by section 166 of the Clean Air Act amendment of 1977. Late in 1986, the court
asked litigants to submit affidavits supporting their respective positions.
The last of these was filed in early February 1987. In April 1987, the
court ordered EPA to develop PSD regulations for NOx on an expedited schedule.
Specific deadlines were to propose regulations by February 9, 1988 and
promulgate them by October 9, 1988. At the end of 1987, EPA was working
toward completion of a Federal Register proposal notice in order to meet the
court-ordered requirements. Since then, EPA has completed the rulemaking
process.I5
New Source Review Task Force
In 1986, EPA formed a special Task Force on New Source Review. The
principal purpose in organizing this task force was to address growing concerns
VI-5
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about the consistency and certainty of permits issued under the Clean Air
Act's new source review (NSR) programs. The task force identified specific
measures to ensure that delegated permitting agencies have the knowledge and
skills necessary to correctly implement the NSR programs and to provide EPA
with adequate information to assure that the technology and other program
requirements are implemented consistent with Clean Air Act requirements. In
1987, based on the task force findings and recommendations, EPA commenced a
long range plan to improve the timeliness, certainty, and effectiveness of
the NSR permit process.
C. IMPLEMENTATION OVERVIEW AND ASSISTANCE
Proposed Ozone and Carbon Monoxide SIP Disapprovals
In 1987, EPA announced proposals to disapprove State clean air plans
for 14 metropolitan areas that have not shown they can achieve EPA's ozone
and/or carbon monoxide air quality standards by the end of 1987 or in the
near term.16 Along with the disapprovals, EPA proposed bans on construction in
those 14 areas for major new sources and certain major changes to existing
sources of those air pollutants. -"-"
The metropolitan areas affected are:
-"^Chicago, IL, for bzomrr :
0 East St. Louis, IL, for ozone;
0 Indiana portion of Chicago for ozone;
0 Indiana portion of Louisville for ozone;
0 Cleveland, OH, for carbon monoxide;
0 Atlanta, GA, for ozone;
0 Dallas-Ft. Worth, TX, for ozone;
0 Denver, CO, for carbon monoxide;
0 South Coast (including Los Angeles), CA for ozone and carbon monoxide;
0 Fresno County, CA, for ozone and carbon monoxide;
0 Sacramento County, CA, for ozone;
0 Ventura County, CA, for ozone;
0 Kern County, CA, for ozone; and
0 Washoe County (Reno), NV, for carbon monoxide.
The construction bans were proposed to go into effect upon a final deter-
mination by EPA and would prevent the approval of permits for building major
new sources or modifications of existing sources of volatile organic compounds
(key elements in the formation of ozone) or carbon monoxide, depending on the
pollutant for which the area is not attaining the standard. A major new source
is defined as having the potential to emit 100 tons or more of the pollutant
per year.
For the Cleveland area, in addition to the proposed construction ban,
EPA proposed to restrict Federal highway funding and clean air grant funding
because the State plan did not provide for implementing a vehicle inspection
and maintenance program with tailpipe emissions tests in that area as required
by the Clean Air Act.
VI-6
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State Implementation Plans for Lead
In July 1982, the Natural Resources Defense Council (NRDC) filed suit to
require EPA to approve, or disapprove and promulgate, lead SIP's for States
that did not submit adequate SIP's. The EPA negotiated a settlement with the
NRDC giving States and EPA additional time for completing the SIP's. During
the time provided for in the settlement agreement, the EPA and the States
completed rulemaking for 29 of the 36 outstanding lead-plans.
In 1987, EPA continued work on completing the remaining lead plans.
During the year, the EPA approved three SIP's: Omaha, Nebraska; Northern
Mariana Islands (new source review); and New Jersey (the three sources that
were not approved in 1986). In addition, Jefferson County, Alabama, was
approved with the stipulation that additional studies still need to be completed
tor a secondary lead smelter located there.
At the end of 1987, lead SIP's were still outstanding for Minnesota,
Indiana, and for the area surrounding a lead smelter in El Paso, Texas.
These actions (including the completion of the Jefferson County, Alabama
studies) are scheduled for completion fn 1988.
SIP Prooe4sing-
Dufing 1987, EPA formed a task group to investigate the basic approaches
being used to review, comment on, and approve or disapprove revisions submitted
both to existing SIP's and to new SIP's. These SIP revisions generally
result from the need to meet new Federal requirements, changes in State
legislation, and source-specific requests for changes to permissible operating
parameters. The task group examined current SIP processing procedures, both
formal and informal, evaluated the effectiveness ot the current methods, and
recommended certain modifications to the process and procedures in order to
more effectively employ EPA's resources and reduce the amount of time required
for final EPA action on these submittals.
Two major improvements in the SIP processing system were recommended.
First, the elimination of excessive review within EPA and second, improvement
in the certainty of the decision process. More specifically, the task group
recommended accomplishment of the first objective by implementing a series of
increasingly comprehensive reviews including early rejection of incomplete
packages, delegation of approval authority to EPA Regional Administrators
for selected actions, thereby eliminating headquarters review, and full
headquarters review of nationally significant SIP's. Implementation of the
second objective is to be achieved by more strict adherence to current formal
procedures, an improved management system, evaluating SIP's on the basis of
policies in effect when submitted, whenever possible, and improved guidance
and communication.
Implementation of the recommendations of the task group will be undertaken
in 1988. Where possible, the recommendations will be handled administratively
with appropriate notice to State and local agencies. However, the public
will be informed of the full range of improvements in the SIP review process
through a notice to be published in the Federal Register in 1988.
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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 possible acid deposition control pro-
grams that might be required. Accomplishment of this effort was planned in
three phases--identifying key implementation issues and major options tor
dealing with them, evaluating various options using both "in-the-field" and
"in-house" approaches, and preparing preliminary or prototype guidance on the
issues. Major progress was made in 1984 on the first phase as EPA, in coordin-
ation with State and local air agencies, produced an initial listing and
description of over 200 potential implementation issues.
In 1985 and 1986 the focus shifted to analyzing the issues and evaluating
the options for dealing with them, particularly through "in-the-field" studies.
These studies, called State Acid Rain (STAR) projects, were to be conducted
by individual States although the results could have broad applicability to
other States that might be involved in a possible acid rain control program.
The projects were eligible for $3 million in funds that Congress had appropriated
for this effort. In all, 46 projects were funded; thirty-seven States were
involved in the effort directly and special procedures were established to
allow other St-ates to participate in.the review and evaluation of the projects.
A national STAR workshop was held in November 1985 for EPA and the States to
discuss and review ttie progress of the STAR projects. In 1986, work on the
STAK projects."continued.an
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planning and SIP activities, new source review, compliance assurance, and
air monitoring are included in the NAAS. During 1987, specific State agency
deficiencies identified during previous audits were being corrected through
agreements between the EPA Regional Offices and the audited agencies.
VOC RACT Clearinghouse
For several years, EPA has published a Clearinghouse on matters relating
to reasonably available control techniques (RACT) for volatile organic
compounds (VOC's). The VOC RACT Clearinghouse is intended to be a long-term
project to exchange technical information, to minimize duplication of effort
and resources, and to provide guidance to regulatory agencies regarding VOC
controls. The Clearinghouse is a joint effort with the STAPPA, ALAPCO, and
EPA.
For 1987, EPA published three issues of the Clearinghouse covering the
following topics:
0 Common SIP Deficiencies
0 Low-solvent Wood Furniture Coating
o
Area So.urce Documentation for the National Acid Precipitation
Assessment Program
0 VOC Control Sessions at Air Pollution Control Association
._.., ConferefTces " _-^.-.-.-.-=..-.
0 Documents Available
0 VOC Leaks in the Synthetic Organic Chemical
Manufacturing Industry and Refineries
0 Control Cost Manual
0 Proposed Auto Emissions Controls
0 STAPPA/ALAPCO Ozone Strategy
0 Definition of VOC's
0 CTG VOC Source Cut-offs
0 Proposed Disapproval of Ozone/CO Clean Air Plans
0 Vessel Hydrocarbon Recovery Study
0 Alternative Compliance for Graphic Arts RACT
0 Post-1987 Ozone and Carbon Monoxide Policy -
Summary of Concepts and Features
D. AIR POLLUTION TRAINING
In 1987, EPA continued to provide technical training in the abatement and
control of air pollution. This training included short course presentations
(3 to 5 days in length), self-study courses, technical assistance to others who
conduct training, and the support of traineeships and fellowships for graduate
air pollution training.
During 1987, EPA conducted 38 short courses in 19 different subject areas
for a total of 1,050 students. These courses were presented in locations
across the U.S. by six universities designated as area training centers.
Technical assistance was provided to States and EPA Regional Offices for
conducting 32 additional courses reaching a total of 888 students.
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In support of the delegation or" more air quality management responsi-
bilities to the States, EPA continued emphasis on self-study courses as a
means of providing training to more air pollution personnel. During 1987,
1644 students applied for the 30 self-study courses presently available.
As an additional means of developing qualified personnel, EPA supported
8 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.
-v— "•
E. REFERENCES:
1. 52 FR 24672, July 1, 1987.
2. 52 FR 29383, August 7, 1987.
3. 52 FR 24716, July 1, 1987.
4. 52 FR 45044, November 24, 1987.
5. 45 FR 80084, December 2, 1980. '
6. ,49 .FR 42671J7 October, 23=,,=L984. ,-. -.
7. 52 FR 45132, November 24, 1987.
8. 50 FR 27892, July 8, 1985.
9. 51 FR 1588b, April 29, 1986
10. 48 FR 38742, August 25, 1983.
11. 4b FR 52676, August 7, 1980.
12. 46 FR 50766, October 14, 1981.
13. 49 FR 43202, October 26, 1984.
14. 49 FR 43211, October 26, 1984.
Ib. 53 FR 40656, October 17, 1988.
16. 52 FR 26404, July 14, 1987.
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VII. CONTROL OF STATIONARY SOURCE EMISSIONS
A. NEW SOURCE PERFORMANCE STANDARDS (NSPS)
Section 111 of the Clean Air Act requires EPA to regulate new stationary
sources of air pollution from source categories which cause, or contribute
significantly to, air pollution which may reasonably be anticipated to endanger
public health or welfare. During 1987, NSPS were promulgated under this section
for emissions of volatile organic compounds from rubber tire manufacturing!
and volatile organic liquid storage tanks2 and for sulfur dioxide emissions
from industrial boilers.3 The existing NSPS for lime manufacturing plants
was revised^ and the fossil fuel fired steam generator standard was amended to
provide alternative compliance provisions for one power station.5 Standards
were proposed for polymeric coating, petroleum refinery wastewater, polymers
manufacturing, and residential wood combustion.6,7,8,9
B. 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 tjyiltlie Llea/i, AXr..Act to install best available control technology
(BACT}.1I In those areas, of-tire 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 knowledgeable 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 report
published in 1987 contains over 1300 BACT/LAER determinations.10 The report
is available in hard copy or through an automated system. The automated data
base can be accessed by both the public and private sectors.
C. REFERENCES
1. 52 FR 34868, September Ib, 1987.
2. 52 FR 11420, April 8, 1987.
3. 52 FR 47826, December 16, 1987.
VII-1
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4. 52 FR 4773, February 19, 1987.
5. 52 FR 28946, August 4, 1987.
6. 52 FR 15906, April 30, 1987.
7. 51 FR 6334, May 4, 1987.
8. 52 FR 36678, September 3U, 1987. ..-_--.
9. 52 FR 4994, February, 18, 1987.
10. "B/VCT/LAER Clearinyhouse - A Compilation of Control Technology Determinations,
Second Supplement to 1985 Edition," June 1987.
VII-2
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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 to 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 36,342 stationary
sources of air pollution. Approximately 31,500 of these sources are Class A
SIP sources*, about 3,500 are NSPS sources, and about 1,000 are non-asbestos
.NESHAP sources. At the end of 1987, as has been the case since the late
1970's, the compliance rates were high as shown in the table below:
Comp-liance Status of Federally Tracked Stationary Sources
ZT- ~ - -1/1...-. In Violation, In Violation, Status
- Source Type Compliance Meeting Schedule No Schedule Unknown
Class A SIP 91.3% 1.9% 4.1% 2.6%
NSPS 89.9% 2.0% 4.9% 3.3%
NESHAP 86.9% 1.8% 4.7% 6.5%
The compliance status of stationary sources is determined and tracked
principally by the States. The States (and EPA) have the authority to enter
and inspect stationary sources in order to obtain information tor determining
compliance status or for preparing possible enforcement actions or for other
purposes. In 1987, the States conducted 33,481 inspections and source tests
of Class A SIP, NSPS and non-asbestos NESHAP sources.
The EPA overviews the compliance monitor!ny activities of the States
and supplements their enforcement efforts to resolve violations of air quality
regulations. In 1987, EPA conducted 2,377 inspections and source tests of
Class A SIP, NSPS and non-asbestos NESHAP sources.
The demolition and renovation of old buildings, often in densely populated
urban areas, can be a major source of asbestos exposure. Such sources are
regulated under the NESHAP for asbestos. Because of the large number of
demolition sites, and the transient nature of the potential asbestos releasing
* A Class A SIP source is a stationary source which, while operating at
design capacity, has actual or potential uncontrolled emissions equal
to or greater than 100 tons per year of any regulated air pol lutant.
VIII-1
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activity, these sources are tracked and reported separately from other
stationary sources of air pollution. During 1987, EPA and States received
43,496 asbestos demolition or renovation notifications (an increase of 61%
over 1986), conducted 17,616 asbestos inspections, and found 2,191 violations.
The Clean Air Act provides a variety of administrative enforcement
mechanisms for dealing with both special situations and relatively easily
corrected violations. During 1987, EPA issued immediate compliance orders
under section 113(a) of the Act to 185 sources (108 of which were asbestos
sources) and issued or approved delayed compliance orders^under section
113(d) for 3 sources.
Section 120 of the Act is an administrative remedy designed to recoup
economic benefit which may come from violating air pollution control regulations
Ten section 120 cases were initiated in 1987.
The EPA is also authorized to file civil and criminal actions in Federal
District Court to compel a source to comply with applicable requirements, to
pay penalties, or both. A total of 73 Federal civil actions were filed in
1987 against stationary sources for violations of the Clean Air Act. Most
were caused by.violation of standards regulating emissions of asbestos, or
particulates, or volatile organic, compounds. As of January 1988, a total
of 125 such actions were pending with the U.S. District Courts. During fiscal
year_(FY) 198ZZCthe Jperipd.starting October 1-,-1-986 and ending September 30,
1987^, two criminal cases-were filed for violation of asbestos regulations
and subsequent violation of an EPA administrative order. On December 30,
1986, the defendants pled guilty to violating NESHAP standards, and each was
sentenced to a $1,000 fine.
A major focus of the stationary source compliance program is the effort
to return to compliance those sources considered to be "significant violators."
The universe of sources covered by this proyram includes those that are in
violation of NESHAP or NSPS regulations, and non-compliant Class A SIP sources
which contribute significantly to nonattainment of the national ambient air
quality standards. For FY 1987, EPA identified 637 significant violators
pending at the beginning of the fiscal year. By the end of the fiscal year,
490 had been addressed. Of these, 247 were returned to compliance, 108 were
placed on an acceptable compliance schedule, and 135 had an enforcement
action pending. In addition, 583 significant violators were newly-identified
during FY 1987 and of these, 187 were addressed by the end of the fiscal year.
In 1984, EPA issued guidance on the "timely and appropriate" EPA/State
enforcement response for significant air-violators. On April 11, 1986, this
guidance was reissued to include NESHAP violators. The guidance provides
timeliness for action, addresses EPA issuance of notices of violation
(particularly when the primary agency does not take action), and discusses
when penalties must be obtained. In 1987, for the third consecutive year,
EPA evaluated the implementation of the "timely and appropriate" guidance.
The evaluation showed that, while certain requirements of the guidance were
not always met, implementation has been successful in that it has caused
expeditious resolution of violations. It eliminates disagreements over who
has responsibility for a violation and provides notice to States and sources
VIII-2
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on when EPA may step in and initiate an enforcement action. Major highlights
of the evaluation are:
0 71% of violations remaining at the beginning of the fiscal year or
noted in the first three quarters were resolved by November 1, 1987.
0 Enforcement actions were instituted for approximately half the
violations resolved, and almost all of the resolutions included
penalties. When EPA took primary responsibility for a violation,
the likelihood of resolution through enforcement action was higher,
as was the likelihood of assessment of penalties.
For the last 4 years, EPA's air pollution compliance program has focused
considerable attention on control of emissions of volatile organic compounds.
These sources are major contributors to the ozone nonattainment problem, and
some emit compounds which are highly toxic. In response to requirements
contained in the 1977 Clean Air Act Amendments, many States adopted regulations
requiring compliance of such sources on or before the end of 1982. These
regulations have increased the number of major regulated sources and
implementation has led to a steady increase in the number of significant
violators. I -
Small sources of volatile organi'c compounds have recently come under
increasing scrutiny.: Emitters such as gas stations, paint spraying operations,
printing presses, architectural coatings and certain personal consumer
products individually contribute small amounts of volatile organic compounds;
however, their aggregate contribution impacts ozone attainment. The EPA has
therefore concluded that in most major urban areas, small sources of volatile
organic compounds must be controlled if the ozone standard is to be reached.
Consequently, EPA has initiated a small source compliance program to encourage
these sources to comply with existing regulations. The special problems that
small businesses experience have been taken into consideration and each
jurisdiction has been given enough flexibility to allow for innovative and
cost efficient approaches to control.
In the decade of the 1970's, the stationary source compliance program
focused on ensuring that major sources of particulates and sulfur dioxide
achieved initial compliance with Act regulations, generally by installing
control equipment or switching to cleaner fuels. The more recent focus of
attention is concerned with the continuous compliance of particulate and
sulfur dioxide sources (while continuing work to ensure initial compliance
for sources of volatile organic compounds).
Encouraging the installation and use of continuous emission monitors is
one component of the continuous compliance effort. On July 28, 1987, guidance
was issued calling for increased use of continuous emission monitors and
integration of information reported by continuous emission monitors into
surveillance/compliance activities. Another component of the continuous
compliance effort is the targeting of inspections to help maximize the effective
use of limited inspection resources. In the past, EPA guidelines have focused
on source size as the determinant whether a source should be inspected. The
EPA has conducted several pilot programs for the purpose of including other
VIII-3
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factors such as compliance history and air quality as determinants. Pilot
programs in Michigan and Colorado were used to develop a procedure (called a
targeting model) for using such information to target inspections; success of
the targeting model to date indicates that a more widespread application is
justified.
On February 18, 1987, EPA proposed a new source performance standard
for residential wood heaters under section 111 of the Clean Air Actl. This
standard allows for certification of woodstove model lines. In 1987, this
certification program was put into place. Nine laboratories have been accredited,
numerous tests have been performed, one wood heater has been approved by EPA
directly for certification, and ten additional model lines have been approved
under the "grandfather" certification program.
Significant progress has also been made in the area of training. During
1987, EPA prepared a multilevel curriculum for EPA personnel engaged in
stationary source compliance inspections. The objectives are to ensure that
every inspector can conduct advanced levels of inspection and that experienced
personnel can stay current and can develop specialized skills. Emphasis is
on quality inspections, health and safety, and transferability to State/local
programs. A total of 35 workshops were-~cbnducted in 1987. Courses and work
materials will.'be streamlined, consolidated, and updated over the next three
to four .years. An air training advisory board composed of Federal, State,
and local pers_enne.l will oversee the program..
B. LITIGATION
The following are examples of significant enforcement actions which were
taken in 1987:
1. Significant Judicial Decisions
United States v. Ford Motor Co.. 814 F.2d 1099 (6th Cir. 1987)
The Sixth Circuit held that the U.S. can enforce the current federally-
approved State implementation plan (SIP) even though the defendant and the
State of Michigan had entered a consent judgment in State court invalidating
the SIP regulation. The court held that the State could revise its SIP only
by submitting a revision to EPA for approval. The court distinguished this
case from previous cases which recognized a State court invalidation of SIP
regulations based on procedural deficiencies in adoption of the regulations.
The Sixth Circuit also ruled that Federal enforcement of the current SIP
regulation could proceed despite the pendency of a SIP revision proposed by
the State.
United States v. Wheeling-Pittsburgh Steel Corp., 818
F.2d 1077 (3rd. Cir. 1987)
The Third Circuit also ruled that Federal enforcement of an existing SIP
could proceed despite the pendency of a SIP revision. In this case, the
District Court had ordered a modification to a consent decree based in part
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on a "bubble" proposal which the State had not formally submitted to EPA.
The Circuit Court ruled that the district court erred and held that the
company was not relieved of its obligations to comply with existing SIP
requirements.
American Cyanamid Co. v. EPA. 810 F.2d 493 (5th Cir. 1987)
The Fifth Circuit held that the agency could not pursue a section 120
penalty action until it rejected a State-proposed SIP revision which would have
put the company in compliance. The court found that EPA must accept or
reject a proposed SIP revision within the same four month interval specified
by Congress for EPA to take action on original SIPs. Moreover, the court
ruled that EPA may not commence an action to collect administrative noncompliance
penalties under section 120 of the Clean Air Act where the State had submitted
a proposed SIP revision that would put the company in compliance and where
EPA failed to reject the revision in four months. The court also held that
EPA may not collect section 120 penalties from the date of submittal of such
a proposed revision to the date EPA rejects it.
2. Significant Administrative Decisions
International Harvester Co,,; Appeal No. 87-1
The EPA QEtef. Judicial. Hfficer ruled that technical .and economic infeasi-
bility^inay not be raised as-a-defense to assessment of administrative
noncompliance penalties. The decision on appeal affirmed an Administrative
Law Judge's finding of violation.
Youngstown Thermal Corp., No. CAA-V-85-A-24
In a preliminary ruling, an Administrative Law Judge held that where a
company is not complying with either the existing regulation or a proposed
SIP revision, EPA may proceed to assess penalties even when the proposal has
been pending more than four months.
3. Significant Settlements
United States v. Magma Copper Co., Civ. No. 87-106 TUC
WDB (D. Ariz.)
A consent decree was entered on September 28, 1987 resolving a civil action
against Magma Copper. The consent decree requires the company to comply with
applicable particulate and sulfur dioxide emission limitations by November 1,
1988. Magma must pay a civil penalty of $600,000.
United States v. Occidental Chemical Corp., Civ. No. 85-
4558 (AET) (D. N.J.)
A consent decree was entered on July 2, 1987 resolving a civil action
against Occidental Chemical Corporation for violations of the national emission
standard for vinyl cnloride, a hazardous air pollutant. The decree requires
the company to implement a detailed compliance plan to prevent emissions of
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vinyl chloride to the atmosphere from a polyvinyl chloride plant. The decree
also requires Occidental to pay a civil penalty of $490,000.
4. Enforcement Initiative
Automobile Coating Cases
The United States filed four civil actions in 1987 against automobile
coating facilities owned by General Motors Corporation. The cases allege
violations of SIP requirements to control emissions of volatile/organic
compounds, which contribute to the formation of ozone. All of the facilities
are located in primary nonattainment areas for ozone.
C. COMPLIANCE AND ENFORCEMENT GUIDANCE
In 1987, EPA issued the following guidance memorandums:
"Review of State Implementation Plans and Revisions for Enforceability
and Legal Sufficiency (September 23, 1987)." This document describes
elements which must be included in-a SIP or a SIP revision in order to
make it enforceable. A checklist is included.
"Setting .Enforcement Actions in Clean Air Act Nonattainment Areas
-"Against Stationary Air-" Sources which wiTl not be In:Compl iance by the
Applicable Attainment Date (November 23, 1987)." This document discusses
the criteria for allowing a source to remain in operation and out of
compliance beyond the attainment date. These criteria must be elements
of a Federal consent decree.
D. COMPLIANCE BY FEDERAL FACILITIES
A total of 369 Class A SIP, NSPS and NESHAP Federal facilities are tracked
in the air program. As of September 1987, 302 (81%) were in compliance, 11 were
meeting schedules that will bring them into compliance, 26 were in violation and
not yet on an acceptable schedule, and 7 were of unknown compliance status.
E. LIST OF VIOLATING FACILITIES
Section 306 of the Clean Air Act provides the authority for EPA to place
facilities on the List of Violating Facilities, thereby prohibiting any
Federal agency from procuring yoods or services produced at that facility.
Section 306 is implemented through Executive Order 11738 and EPA regulations
codified at 40 CFR Part 15. In 1985 EPA promulgated revised regulations for
implementing section 306. Under the revised regulations, facilities where
criminal violations of the Clean Air Act occurred are automatically placed on
the List of Violating Facilities, effective the date of the conviction.
Other facilities which have continuing and recurring violations may be placed
on the List at the discretion of the EPA, after notice to the owner or operator
and the opportunity for an administrative hearing.
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During 1987, a Contractor Listing Task Force met regularly to address
issues related to contractor listing. In October 1987, EPA issued contractor
listing protocols, a guidance document which sets forth the procedures that
EPA will follow in carrying out the contractor listing regulations, and the
assistance that is required from other EPA offices supporting the contractor
listing program. This guidance is intended to enable the enforcement offices
in EPA's Regional Offices to make greater use of contractor listing as a
supplemental enforcement tool.
With the development of the protocols, EPA is placing/more emphasis on
enforcement actions under the contractor listing authority. During 1987, EPA
listed two facilities under the Clean Air Act as a result of criminal convictions
for violations of the asbestos removal standards, removed three facilities
from the list, handled one appeal, and reviewed three recommendations to
list. At the end of 1987, there were three facilities on the list for Clean
Air Act violations, one decision to list pending appeal, and two listing
proceedings pending.
F. REFERENCES
1. 52 FR-4994, February 18, 1987.
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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 (Act) 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 and ozone. Below are
listed some of the mobile source provisions of the 1977 Act.
0 A schedule was established for implementation of stringent emissions
standards for automobiles — 0.41 grams per mile (gptn) for hydrocarbons
(HC), 3.4 gpm for carbon monoxide (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
zz: : : . Control . Standard Reduction
Hydrocarbons 8.8 gpm .41 gpm 95%
Carbon Monoxide 87.0 gpm 3.4 gpm 96%
Oxides of Nitrogen 3.6 gpm 1.0 gpm 72%
0 Similarly, the amendments tightened standards for emissions of the
above mentioned pollutants from heavy-duty engines.
0 Standards for the control of particulate emissions from heavy-duty
diesel engines were mandated.
0 Areas not meeting carbon monoxide and ozone ambient air quality
standards by 1982 were required to implement motor vehicle inspection
and maintenance (I/M) programs.
Since the enactment of the 1977 amendments, EPA has made steady progress
toward achieving the Act's goals. The EPA 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 1987,
EPA made significant progress toward the implementation of this program.
B. OZONE CONTROL
With the increased focus on reducing ozone levels, EPA has continued
work on several areas directly aimed at this goal. One of the key actions
is controlling excess evaporative emissions through regulation of in-use
gasoline volatility. The EPA proposed a rule in 1987 on gasoline volatility.1
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Hearings were held in October and a final rule is expected in 1989. A second
action aimed at ozone reduction is control of refueling emissions. The EPA
proposed a rule establishing refueling emission standards for automobiles
along with the gasoline volatility proposal.2 A third ozone related action
was the continued development of a notice of proposed rulemaking which would
tighten the light-duty truck exhaust hydrocarbon standard. Publication of
the proposal is expected in 1988. Other work related to ozone (and carbon
monoxide) control involved providing guidance to States on how to assess the
effects of alternative fuels on their air quality. A guidance document was
developed with release expected in 1988. In parti cular^,.£xhaus-t emission
credits are provided, for the use of gasoline-oxygenate blends of ethanol,
methanol, and methyl tertiary butyl ether (MTBE) as well as fuel methanol and
compressed natural gas. This guidance document was also an important piece of
EPA's carbon monoxide attainment strategy. In addition, EPA worked closely
with Colorado and Arizona in 1987 in their development of alternative fuel
programs.
C. VEHICLE FUELS AND AIR TOXICS
Several initiatives were related t-0-vehicle fuels in 1987. In the first,
EPA began to develop a comprehensive .study of the potential costs and benefits
of reducing the sulfur and aromatics content of diesel fuel, an action that
may lead to significant reductions in particulate emissions from diesel engines.
Str4ngent technology-forc4mj-standards were established in 1985 for 1991 and
1994 and later heavy-duty diesel engines. Reducing the fuel content of sulfur
and/or aromatics may improve the ability of manufacturers to meet these
standards, as well as provide other economic and environmental benefits. In
1987, EPA decided to directly pursue a notice of proposed rulemaking,
incorporating the study as a part of the regulatory impact analysis supporting
the rulemaking. Publication of the proposal is expected early in 1989. A
second initiative was a proposal to establish testing protocols to determine
the health effects of fuels and fuel additives. An inventory of current
commercially-available fuel additive materials was developed. An advance
notice of proposed rulemaking on this topic will be published in 1989. In
another initiative, a motor vehicle assessment for an Agency-wide task force on
formaldehyde exposure and control strategies was completed. Finally, EPA also
initiated a program effort to evaluate the importance of photochemical
transformation chemistry to the mutagenicity of motor vehicle emissions.
Actual vehicle emissions were irradiated in a laboratory chamber with changes
in mutagenicity evaluated using bioassays. Results of this program are
scheduled for publication in 1990.
The EPA also 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 EPA field inspectors and private or State inspectors under
EPA contracts or grants, in order to measure the fuel's lead content. The EPA
conducted approximately 18,001) inspections under this program during 1987.
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The lead phasedown program continues to achieve significant reductions
in the use of lead in gasoline, from ten billion grams in 1986 to six billion
in 1987. This represents a 97 percent decrease from the 206 billion grams of
lead which were used in gasoline in 1973. The ability to use banked lead
usage rights ended in 1987. This, combined with an anticipated decrease in
demand for leaded gasoline, will result in further reduction in lead usage.
The standard remains at 0.10 grams per leaded gallon (0.10 gplg) as a quarterly
average for a refinery or importer. In 1987, EPA and the U.S. Department of
Agriculture (USDA) issued a study on the use of low-leaded (0.10 gplg) and
unleaded gasoline in agricultural equipment designed for leaded gasoline, as
required by the 1985 Farm Bill. The study found 0.10 gplg to be adequate,
but that some engines designed for use with leaded fuel would have some
premature exhaust valve wear if operated exclusively on unleaded gasoline.
Three public hearings were held to receive comments on the study. A report
to the President and the Congress was drafted for issuance in early 1988.
The EPA mobile source air pollution control program has shifted
enforcement efforts from fuel switching to the fuel refiner/importer audit
program to assure compliance with the lead phasedown regulations. Investiga-
tion and enforcement in this area involves extensive analysis of the produc-
tion, importation and blending of gaso!4ne, gasoline blendstocks and lead
additives. The EPA also tracks the.banking and withdrawal of lead rights and
related" documents and records and has successfully conducted a number of
these audit-tyjle Investigations. Computer programs help, analyze the refiners'
records-land a strategy has-been developed to integrate and evaluate all
sources of data available to identify potential refiners and importers for
investigation. The EPA conducted investigations of more than 20 refiner
facilities during 1987 and 18 Notices of Violation (NOV's) were issued with
proposed penalties of over $24 million. Three large lead phasedown settlements
in 1987 resulted in penalties of approximately $4.2 million. Future cases of
this type are also likely to involve significant violations with proposed
penalties and settlement amounts in the multi-million dollar range.
As part of the reduction of lead in gasoline, the EPA Administrator signed
a final rule eliminating lead in test fuel.3 This will mean that manufacturers
of engines not requiring catalysts, such as certain heavy-duty, gas-powered
engines, must meet emission standards using unleaded gasoline.
The Fuel and Fuel Additive Registration System has been overhauled in
1987 to improve its effectiveness in quickly identifying environmental problems
associated with chemical substances used in motor fuels. This registration
function will assure that EPA is knowledgeable about the chemical content of
fuels and fuel additives. In conjunction with EPA's development of test proto-
cols for assessing health effects, the system will enable EPA to assure that
proper restrictions are placed on substances which cause harm to the environment
and/or public health. Further, the registration system permits EPA to
monitor the compliance of fuel and fuel additive manufacturers with the
requirements of Section 211 of the Clean Air Act concerning waivers for
new fuels or additives.
Increasingly, attention is being focused on toxic air pollution in urban
areas. Mobile sources contribute as much as sixty percent of the urban air
toxics emissions. In 1987, EPA released a technical report providing a
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compilation of available information on air toxics emissions from motor
vehicles, the status of regulations affecting these emissions, and a range of
risk estimates for their effect on public health both now and for future years.
0. STANDARD SETTING
As part of an ongoing effort in controlling ozone, EPA in 1987 continued
its efforts in the development of alternative fuels technologies. .These
efforts have additional benefits in helping to reduce emissions of carbon
monoxide and other pollutants, as well as reducing our dependence on foreign
oil. In addition, as mentioned before, there has been significant activity
in the effort to reduce particulate matter from diesel engines. Accomplishments
in this area in 1987 include the following:
0 As mentioned before, EPA proposed refueling emission standards for
motor vehicles, and also proposed volatility standards for vehicle
fuels in order to reduce hydrocarbon emissions.
0 In anticipation of the development of methanol as an alternative
fuel, EPA moved forward in the^development of emission standards
for methanol-fueled vehicles. Methanol has the potential to reduce
hydrocarbon emissions from gasoline engines and particulate emissions
fromjiteset engjneSj. A final rulemak-iny is,planned for 1988.
0 The EPA held a workshop on and began developing a proposed rulemaking
to permit the banking and trading of oxides of nitrogen and particulate
matter emission credits among heavy-duty gasoline, diesel, and methanol
engine manufacturers. A proposal is expected in 1988.
0 The EPA continued to promulgate nonconformance penalties for those
heavy-duty engine families unable to meet certain standards applicable
to a given model year. This mechanism assures that no manufacturer
benefits financially from nonconformance with the emission standard,
and that the least effective technology does not determine the
stringency of standards for the entire industry. A proposal to
increase the stringency of the 1991 light-duty diesel truck particulate
standard for light-duty trucks with heavy-duty engines and to propose
nonconformance penalties was published in 1987.4 The final rule is
planned for 1988. Rulemaking proposals to make nonconformance •
penalties available for 1991 and 1994 heavy-duty vehicle and heavy-duty
engines and to allow EPA to waive the payment of nonconformance
penalties for engines sold in California on which nonconformance
penalties have been paid to the State of California are planned for
1988.
0 The EPA incorporated newly received emissions data into a study of
railroad emissions which it has been conducting. The complete study
is scheduled for release in 1988. In addition, completion of a more
general contractor report on emissions from all off-road diesel
vehicles is expected early in 1988.
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E. PREPROUUCTION COMPLIANCE
One of EPA's key techniques for assuring the compliance of vehicles with
the motor vehicle emissions standards is the preproduction certification
program. Initiated in 1968, the program involves the engineering review and
testing by EPA staff of engine families representing new vehicles which are
to be sold in the United States. This process includes the submission of
technical data from manufacturers about prospective production vehicles,
emissions testing of prototypes by manufacturers, a review of engineering
data and test results by EPA personnel, and, in certain..cases, confirmatory
testing of prototypes at EPA's National Motor Vehicle Emissions Laboratory in
Ann Arbor, Michigan. This procedure identifies and resolves potential problems
which could result in excessive in-use emissions. Correcting these problems
at the preproduction stage assures maximum environmental benefits and reduces
compliance cost to the industry compared to correcting the problems when
discovered in use.
The EPA's National Motor Vehicle Emission Laboratory performed over 2500
emission tests on 750 preproduction prototype vehicles and 500 in-use vehicles
in 1987. Correlation activities with the regulated industry increased with the
commencement of a technical exchange program with the Motor Vehicle Manufacturers'
Association (MVMA). This effort should result in better correlation with
industry and thus less time spent by industry contesting EPA data.
-- Tlie EPA';s vehicle cert-Hi cat ion program is "the only-vehicle emission
compliance program which evaluates all vehicle designs from each manufacturer.
It is also the only program which screens vehicles for elements of design known
as defeat devices, A defeat device allows a vehicle to pass emission standards
when tested according to Federal test procedures but produce unacceptably higher
emissions when operated under other conditions. Coupled with the Selective
Enforcement Audit and in-use compliance test programs, the certification
program establishes the necessary oversight to assure vehicles are adequately
designed and constructed for satisfactory in-use emissions performance.
As a result of a series of regulatory reforms implemented over the last
several years, the certification process has become a more flexible and
efficient program. Reduced testing requirements, administrative streamlining,
and effective use of computerization has eased the procedural burdens to the
manufacturers and increased the speed and efficiency of EPA's review and approval
process. The process has evolved from one of EPA directing and approving every
step to one that is largely self-implemented by the manufacturers subject to
EPA's audit. This has resulted in a highly leveraged program which allows EPA
to focus its resources on oversight of potential problem areas while giving
the manufacturer maximum control over the timing of the more routine events.
In 1987,-EPA published a notice of proposed rulemaking which would
greatly expand the voluntary aftermarket parts certification program.5 Expected
to be promulgated in late 1988, this change in regulations will allow manufacturers
to certify for emission compliance a wide range of aftermarket parts. Consumers
will be able to purchase these aftermarket parts for vehicle maintenance with
confidence that the parts will allow their vehicles to maintain good emission
performance. Use of these certified parts will also protect the vehicle owner's
emission performance warranty.
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The current emphasis is on assuring maximum in-use benefit from the
preproduction certification program. This emphasis includes three parts:
(1) careful monitoring to confirm full compliance with existing regulations,
(2) in-use vehicle testing to quantify the level of emissions performance
slippage between the preproduction prototype vehicle certification test
results and actual in-use vehicle emission performance, and (3) identification
of potential certification program changes to improve its cost-effectiveness.
F. VEHICLE INSPECTION PROGRAM ;;".;- :
An effective strategy for dealing with in-use emissions problems is the
establishment of motor vehicle inspection and maintenance (I/M) programs. The
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 ozone and
carbon monoxide beyond 1982 are required by the Clean Air Act to implement an
I/M program. The EPA has also interpreted the Act to require areas which did not
achieve attainment in 1982 as predicted to implement I/M programs unless they
could otherwise prospectively demonstrate attainment by 1987. In 1987, EPA
continued to promote the implementation-of I/M programs in each locality
where they were needed. By the end-of the year, 60 of 64 areas had initiated
programs.
-TTdVassure that operating I/M and antitampering programs actually achieve
the planned emission reductions, EPA has initiated a systematic I/M auditing
plan. In previous years, EPA conducted 31 initial audits and 8 follow-up
audits. In 1987, EPA audited an additional 9 I/M programs and conducted 6
follow-up audits. Auditing and thorough follow-up by Federal, State and
local officials will pinpoint and lead to correction of any major deficiencies
in individual programs. In 1987, EPA notified governors or other high officials
in 6 states that major problems had been found, and requested corrective plans.
In addition to I/M programs, EPA has promoted the implementation of State
and local antitampering and anti-fuel switching enforcement programs. By the
end of 1987, 36 programs had been implemented. Tampering and fuel switching
programs focus on correcting and deterring the removal and rendering inoperative
emission control devices. Therefore, they complement the tailpipe I/M programs.
In seven I/M programs no emission check is performed, but antitampering and
fuel switching checks make up the entire inspections. By the end of 1987, a
total of 25 antitampering and anti-fuel switching programs had been added to
existing tailpipe I/M programs.
6. 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) assure the
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reductions of lead in gasoline are achieved, (5) administer statutory and
California emissions standards waivers, and (6) administer the statutory
emissions warranties. To accomplish these goals, EPA maintains a number of
basic motor vehicle enforcement programs:
Selective Enforcement Auditing
In order to assure that production vehicles and heavy-duty engines are
built in accordance with emissions standards, EPA conducts Selective
Enforcement Audit (SEA) test programs at manufacturers1";.facilities. The SEA
program is a highly leveraged one. For every car EPA requires manufacturers
to test during an audit, over a hundred cars are voluntarily tested by auto
producers to assure that the audits do not result in a failure which could
affect vehicle production. Since this close scrutiny by manufacturers
results in the repair of vehicle classes that are only marginally meeting
requirements, EPA has been able to reduce the number of audits it requires.
In 1987, EPA conducted 22 SEA's, including four at foreign manufacturer's
facilities, with a new effort in testing heavy-duty engines for compliance.
Additionally, five production compliance audits for nonconformance penalties
were conducted, and approximately $7.4 million in penalties were collected.
Recall Program ".'.'.
Section ZD-I(c) -of the.CJean Air Act authorizes EPA to order the recall
of vehixles tf a substantta-l~number of any class" of vehicles do not conform
to emissions standards during their useful lives. During 1987, a total of
1,537,000 vehicles were recalled as a result of EPA investigations. In the
same period, manufacturers voluntarily recalled an additional 1,408,706
vehicles to correct emissions problems. The EPA conducted a total of 33
recall investigations in 1987. and performed 658 tests of in-use vehicles at
laboratory facilities in Springfield, Virginia and Ann Arbor, Michigan.
In 1987, the City of New York started a methanol bus demonstration
program, using methanol-fueled buses provided by General Motors Corporation
under a settlement agreement reached with EPA as a remedy for the recall of
certain models of 1979 and 1980 General Motors automobiles for excessive NOX
emissions. General Motors agreed to provide New York with a total of 32
buses.
Historically, the motor vehicle recall program focused its efforts on
light-duty automobiles as they comprise the majority of the vehicles on the
road. In 1987, however, the program expanded its surveillance of light-duty
trucks and heavy-duty engines in recognition of the increasingly stringent
emission standards and useful life requirements applicable to these vehicles.
This coverage included emission testing of light-duty trucks and field surveys
of heavy-duty engines emission control systems.
Fuels Enforcement Program
As mentioned before, EPA has greatly increased its lead phasedown enforce-
ment activities in 1987. In 1987, EPA issued 18 notices of violation with
$24 million in proposed penalties. In addition, EPA worked with the Justice
Department in civil and criminal prosecution of refiners based on notices
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of violation issued in previous years. These rules are creatiny a demand tor
other additives which may have a harmful impact on auto emissions. The 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.
In a related area, EPA relaxed restrictions on a fuel additive waiver for
a methanol blend in 1987. This is expected to become an increasingly important
area in response to the ongoing lead phasedown program, as refiners experiment
with various additives as substitutes for lead in vehicle fuel.
Analysis of gasoline for various additives, primarily lead and alcohol,
was an area of substantial effort by the Motor Vehicle Emission Laboratory in
1987. Over 10,000 samples from EPA's National Tampering Survey were analyzed
for lead. For specific enforcement cases, 500 samples were analyzed for lead
and 1000 for alcohol. In addition, a major effort in the area of fuel volatility
was begun as part of the previously-mentioned regulation proposed in 1987.
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 fuel.. Surveys undertaken by EPA have shown
tampering and fuel switching to be continuing serious problems which undermine
the.emissionsIcontrdl performance of many in-use vehicles. The 1987 Motor
Vehvcl^"-Tampering Survey imttcates that about 19 percent'of the vehicle fleet
is subject to gross tampering, and about 7 percent to fuel-switching. Tampering
and fuel-switching enforcement activities continued in 1987 with the issuance
of 297 notices of violation with proposed penalties of $2.6 million. Of
these, 65 were tampering violations with proposed penalties of $1.6 million.
Similarly, EPA settled a total of 406 fuels and tampering cases during the
year for $3.3 million. Also, as mentioned above, EPA has promoted the
implementation of State and local antitampering enforcement programs. By
the end of 1987, 36 programs had been implemented.
Development of Aftermarket Catalytic Converter Policy
A critical element of State and local tampering inspections is the
availability of replacement emission control components. The EPA published a
policy regarding attermarket catalytic converters that established test
procedures, performance standards and installation requirements for
aftermarket converters. Under this policy, replacement converters would be
used only in specified circumstances. Any other replacements would have to
be equivalent to those installed by the vehicle manufacturer. The policy
also contains reporting and record-keeping requirements to aid EPA in monitoring
appropriate use of aftermarket converters. A number of investigations were
initiated during the year to determine compliance with the policy. The policy
became effective in late 1986, but has been clarified for 1988, at which time
EPA will intensity monitoring compliance and bring enforcement actions when
warranted. The EPA has already brought enforcement actions proposing penalties
of $120,000 against two automobile dealerships for aftermarket converter
violations. The EPA also investigated one manufacturer of aftermarket catalysts
and determined that the devices did not perform the essential function of a
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catalytic converter. A Federal District Court granted EPA's request for an
injunction preventing further marketing of the device, and ordered the company
to notify each purchaser that the installation of the device could result in
tampering liability. The EPA's action in this case heightened awareness in
the industry and strongly conveyed EPA's intent to enforce these requirements.
Emission Warranty Enforcement
The EPA is also responsible for assessing whether the Federal emission warranty
requirements of sections 2U7(a) and (b) of the Act are implemented. During 1987,
EPA responded to a total of 1,253 inquiries. Of these,'153 were complaints speci-
fically related to warranty coverage and were referred to the appropriate vehicle
manufacturer for resolution. A pamphlet outlining the section 207(a) performance
warranty was updated in 1987. It will be printed and made available to State and
local programs. Other related actions include preliminary work on clarifying
section 207(a) regulations and a national warranty awareness campaign.
H. IMPORTS
The control of emissions from imparted vehicles has become a major issue in
recent years. -Due to the desire for;luxury imported cars and the strong dollar
throughout most of this decade, the importation of cars which do not conform to
applicable airjp.oT.luJion. control regulations increased from 1,500 in 1980 to a
hiyfr oC68,000 in 1985. . -In- 1987, EPA received 20,OOU appIications and 29,000
inquiries coricerning these automobiles. The EPA believes the decrease in imports
from its 1985 peak is largely attributed to the dollar's decline in exchange
value in foreign markets, rather than a change in consumer taste. The EPA has
substantially automated the processing of applications and test data for cars
which have been modified for compliance with emission standards. In 1987, EPA
promulgated a final rule updating its regulations controlling these automobiles.6
Under these revised rules, the vast bulk of these imported vehicles will be
allowed to enter the U.S. via EPA's new vehicle certification program. The new
procedures will increase EPA's confidence that the vehicles have been properly
designed to assure continued satisfactory in-use emission performance.
The EPA has also been investigating various laboratories to ensure that
noncontorminy imports have been tested properly to demonstrate conformity
with U.S. emissions standards. These laboratories are required to conduct a
Federal test procedure and submit the results to EPA for approval. Some
laboratories, however, have been falsifying the results of these tests. In
1987, EPA successfully prosecuted five laboratories resulting in 27 individual
convictions and one corporate conviction. The EPA took administrative action
against two additional laboratories.
I. LITIGATION
Fuels Enforcement
On June 30, 1987, a U. S. District Court in New York City imposed a
judgment for $180,000 against a corporation for a violation of section 211 of
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he Clean Air Act. The case is significant since it is the second time a
]J![fl 1 District Court awarded per-day penalties for each and every day of
the continuance of the violation.
Lead Phasedown
Enforcement of lead phasedown has resulted in criminal prosecution of
individuals. At least two criminal cases are now pending which were developed
in the course of EPA investigations. The EPA attorneys are participating in the
prosecution of these cases in conjunction with the environmental crimes unit
of the U.S. Department of Justice. Other more egregious cases, including
four related cases with potential penalties of $40 million, are pending. The
EPA has also issued notices to 18 refiners or importers proposing a total or
$24 million in civil penalties. The parties were cited for failure to file
quarterly reports, overuse of lead in gasoline production or the illegal
creation of lead usage rights (banking violation).
Tamperi ng
In 1986, EPA, in separate violation notices, cited 16 repair facilities
in Indiana, New York, and Colorado for Clean Air Act tampering violations
by allegedly removing catalytic converters from 33 vehicles so that converter
replacement pipes could be installed." The EPA also cited the manufacturer of the
replacement pipes for "causing" the violations. ..In 1987, a $7b,OOU settlement
was-.reached with one of tnel nation's largest manufacturers of catalytic .
converter replacement pipes. The manufacturer is also prohibited from any
further marketing of the devices. The EPA worked with the State of Indiana to
resolve this and related cases against parts distributors who sold the devices
and repair facilities who installed them on vehicles. The State cases also
involved a large number of catalyst replacements as a condition of settlement
and the collection of substantial penalties against the distributors and
installers as well. Investigations of all other major manufacturers of
catalytic converter replacement devices known to EPA are ongoing. The first
year EPA settled cases based on the "causing" language of section 203 of the
Clean Air Act was 1987.
J. REFERENCES
1. 52 FR 31274, August 19, 1987.
2. 52 FR 31162, August 19, 1987.
3. 53 FR 470, January 7, 1988.
4. 52 FR 21075, June 4, 1987.
5. 52 FR 924, January 9, 1987.
6. 52 FR 36136, September 25, 1987.
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X. STRATOSPHERIC OZONE PROTECTION
A. DESCRIPTION OF ACTIVITIES
On December 14, 1987, EPA proposed regulations! to implement the Montreal
Protocol on Substances that Deplete the Ozone Layer, which was signed by 24
nations in September 1987. Currently, 30 nations including all the major
chlorofluorocarbon (CFC) producers have signed the Protocol. This landmark
environmental agreement calls for a 50 percent reduction in use of CFC1s and a
freeze on use of halons over the next ten years. By reducing the future use
and emissions of CFC's and halons, these restrictions will help protect the
earth's stratospheric ozone layer.
The EPA proposed to limit the production and consumption of certain
CFC's and halons to reduce the risks of stratospheric ozone depletion.
Specifically, the proposal requires a freeze at 1986 consumption and produc-
tion levels of CFC-11, -12, -113, -114, and -115 on the basis of their
relative ozone depletion weights, followed by reductions up to 80 percent
and 50 percent of 1986 levels beginning_ln mid-1993 and mid-1998, respectively.
It would also prohibit production and consumption of Halon 1211, 1301, and
2402 from exceeding 1986 levels on a weighted basis beginning in approximately
1992. Under limited circumstances, somewhat higher levels of production
(but,not consujipt.i.ori) would.be. permitted. Consumption is defined in the rule
as production plus imports -mfnus exports of the bulk chemicals as listed
above.
The EPA proposed that quotas reflecting the allowable level of production
and consumption be allocated to each of the firms that engaged in these
activities in 1986. As alternatives and supplements to this approach, EPA is
evaluating and has requested comments on other control mechanisms such as
regulatory fees and auctioning of production rights.
The EPA proposed its regulations pursuant to section 157(b) of the
Clean Air Act. This proposal constitutes the United States' implementation
of the Montreal Protocol. The EPA proposed that the control requirements
listed above only take effect if the United States ratifies the Protocol and
following its entry into force. The Protocol is expected to enter into force
on January 11, 1989, following ratification by 11 nations representing two-
thirds of global consumption. United States ratification occurred in April
1988.
The EPA's proposed action was in response to growing scientific evidence
linking increased atmospheric levels of chlorine and bromine to anticipated
depletion of the ozone layer. If ozone depletion occurs, increased levels of
harmful ultraviolet radiation would penetrate to the earth's surface, resulting
in substantial damage to human health and the environment. In the thirteen
years since concern about CFC's and ozone depletion was first raised, substantial
scientific research has supported the general conclusion that concentrations
of chlorine, as well as from bromine from halons, in the stratosphere pose
substantial risks of depletion.
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Two extensive assessments of stratospheric risks were completed and
relied upon by EPA in evaluating the need for additional restrictions on the
use of potential ozone-depleting chemicals. The first, Atmospheric Ozone
19852 provides an extensive review of the current state of knowledge concerning
atmospheric chemistry and modeling, past changes in trace gases that affect
ozone levels, and current trends in ozone levels. A second study, An Assessment
of the Risks from Trace Gases that can Modify the Stratosphere3 was prepared
by the EPA and reviewed by its Science Advisory Board. This study summarizes
the state of knowledge related to both atmospheric issues (e.g., possible
future changes in ozone levels) and human health and environmental effects if
the ozone layer were depleted.
B. REFERENCES
1. 52 FR 47489, December 14, 1987.
2. Atmospheric Ozone - Assessment of Our Understanding of the Processes
Controlling Its Present DTstn'bution and~Change, Work Meteorological
Organization (3 Volumes), 1986.
3. EPA 400/1-87/001.
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XI. RADON ASSESSMENT AND REMEDIATION
Radon is a radioactive gas produced by the decay of uranium, which
occurs naturally in soils and rocks. The EPA estimates that indoor exposure
to radon may cause 5,000 to 20,000 lung cancer deaths each year. A recent
report of the National Academy of Sciences identified radon as a serious
national public health issue, and confirmed EPA risk estimates.
The EPA's Radon Action Program's initial efforts in 1985 were concentrated
in the Reading Prong area of Pennsylvania, New Jersey, and New York where
elevated levels of indoor radon were first discovered iji homes. The EPA
provided these States with assistance in radon measurement and mitigation of
radon exposure in affected homes. Since then, high radon levels have been
found in nearly every State. Program activities were expanded in 1986 and
1987 in response to the growing scope and complexity of the radon problem.
The goal of EPA's Radon Action Program .is to significantly reduce the
health risks of radon through a partnership with other Federal agencies and the
States. To accomplish this goal, EPA is developing and disseminating technical
knowledge to encourage, support, and facilitate the development of State programs
and private sector capabilities. The program has four major elements:
1) Problem Assessment - To identify areas with high radon levels in
1 houses_ and to determine the national distribution of radon levels
... _ and associated health risks.
2) Mitigation and Prevention - To identify cost-effective methods to
reduce radon levels in existing structures and to prevent elevated
radon levels in new construction.
3) Capability Development - To stimulate the development of State and
private sector capabilities to assess radon problems in homes and to
help people mitigate such problems.
4) Public Information - To work with States to provide information to
homeowners on radon, its risks, and what can be done to reduce those
risks.
The EPA's accomplishments in these areas during 1987 include the following:
Problem Assessment
0 Standardized measurement protocols for seven measurement methods
were issued to help ensure that radon measurements are comparable
and accurate.
0 Assistance was provided to ten States in designing and conducting
surveys to identify areas where indoor radon may be a problem. The
EPA is assisting seven additional States and numerous Indian Nations
with similar surveys in 1988.
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0 Identification of geological factors and characteristics which are
useful as indicators of areas with high radon levels was begun.
0 The use of soil gas measurements to predict radon problems on
potential building sites was investigated.
0 Research and design for a national assessment of radon in homes,
schools and occupational settings was begun in order to characterize
indoor radon levels across the United States. This national assess-
ment is required by the 1986 Superfund Amendments and Reauthorization
Act (SARA).
Mitigation and Prevention
0 The House Evaluation Program (HEP) was established in order to
assist States in evaluating and mitigating radon exposure in houses
discovered to have elevated radon levels. The HEP has provided
"hands-on" training to officials from New York, Virginia, Pennsylvania,
New Jersey, Tennessee, Ohio, the National Park Service, and the
Seneca Indian Nation in evaluating and mitigating radon exposure in
80 selected houses in their respective areas.
0 The EPA cooperated with the National Association of Homebuilders and
private-homebuilders to develop, demonstrate, and release interim
--• guidance for preventing radon in new constructton.
0 The EPA worked with model building codes organizations to begin the
process of incorporating radon prevention techniques into national
building codes.
0 Research and operational programs were begun in order to expand
mitigation and prevention activities into schools and workplaces.
0 Selected radon exposure mitigation techniques were researched and
demonstrated in houses in the Reading Prong. Sixty-four houses
have been completed and the program has been expanded into Maryland,
Tennessee, Alabama, and Florida.
Capability Development
0 A technical training course on radon diagnostics and mitigation
techniques was developed for States and private contractors.
Twenty-nine courses were conducted and 1,501) participants from 40
States were trained. To meet with growing demand, a video tape of
the course was produced and distributed through Regional Offices
for use by all fifty States.
0 The Radon Measurement Proficiency Program was established in order
to allow private firms and other organizations to demonstrate their
proficiency in measuring radon. When the program began in 1986, 35
companies participated; by the end of 1987, the list of participants
had grown to over 350.
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Public Information
0 Five radon brochures were developed and distributed:
"A Citizen's Guide To Radon: What It Is and What To Do About It;"
"Radon Reduction Methods: A Homeowner's Guide;"
"Removal of Radon from Household Water;"
"Radon Reduction in New Construction: An Interim Guide;" and,
"Radon Reference Manual."
0 In addition, EPA participated in many national conferences and
workshops on indoor radon, provided information and interviews to
the media, oryanized and conducted press conferences and briefings
on radon issues, and responded to thousands of public inquiries
regarding indoor radon exposure.
While much of EPA's activity was initially directed at States in the
Reading Prong area, the Radon Action Program is now assisting States throughout
the country. Technical assistance activities will continue as an increasing
number of States, Indian Nations and Federal agencies work to identify and
address radon exposure problems. The EPA will also continue to expand its
technical assistance capabilities in response to the increasing complexity of
the radon problem.
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XII. LITIGATION
A. INTRODUCTION
During 1987, two significant precedent-setting cases involving the Clean
Air Act (Act) were decided in the courts and are discussed below. Following
those cases is a discussion of a number of others with important implications,
but which are not as broadly significant.
B. LANDMARK DECISIONS
1. Hazardous Air Pollution Decision: NRDC v. Thomas
In a major ruling on EPA's obligations under section 112 of the Clean Air
Act, the entire D.C. Circuit held that while consideration of costs and feasi-
bility in standard setting on hazardous air pollutants is not precluded for
purposes of setting standards, EPA must first determine a level representing
an "acceptable risk." The court also concluded that section 112 does not
require elimination of all risk, but th^t EPA should follow a process under
which a decision is first made on a".level representing an "acceptable risk"
for a pollutant, followed by a second step in which cost and feasibility
could be considered in pj-ov-tding an "ample margin of safety." The decision
of the -court 'modified a prevtous panel decision "in the same case, issued in
1986, that upheld EPA's approach in all respects.
2. Ozone and Carbon Monoxide Nonattainment; Abramowitz v. EPA
In a case of great significance to EPA's program for areas with serious
nonattainment problems, the Ninth Circuit overturned EPA's partial approval
of ozone and carbon monoxide State implementation plans (SIP's) for California's
South Coast air basin, and ordered EPA to disapprove those SIP's for failure
to meet the statutory requirements for attainment by December 31, 1987. The
EPA had initially approved the control measures in the SIP, but withheld
approval or disapproval as to attainment. The court held that the Act does
not authorize EPA to approve control measures independent of a determination
on whether the SIP demonstrates attainment.
C. OTHER SIGNIFICANT DECISIONS
1. Attainment Deadlines
Following the inability of many areas of the country to attain national
ambient air quality standards (NAAQS) by the deadline established by the Act,
a number of lawsuits have been filed to force State and Federal agencies to
revise, implement, or promulgate SIP's. In addition to the Abramowitz decision
discussed above, three others were decided in 1987.
Natural Resources Defense Council (NRDC) v. New York State Department
of Environmental Conservation was a citizens suit against the State of New
York and EPA by NRDC to compel the State to carry out portions of its previously
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approved ozone and carbon monoxide SIPs and to require a new SIP in light of
anticipated failure to attain by the December 1987 attainment deadline
specified in the Act. The district court held that the plaintiffs were
entitled to a finding of liability regardless of the State's reasons for
failing to carry out its obligations, and ordered the State to promulgate
certain regulations, including those addressing installation of gasoline
vapor recovery devices on service station pumps.
American Lung Association of New Jersey v. Kean involved.a citizens
suit to force New Jersey to implement nine ozone reduction.strategies that
the State had neglected to carry out. The court rejected the State's good
faith intentions, and interpreted New Jersey's 1983 SIP submission as binding,
judging that any ambiguities in the SIP would properly be construed against
the creator of the SIP—the State itself.
Wilder v. Thomas was a case in which the court dismissed a citizens
suit complaint seeking to halt the Times Square Redevelopment Project in
Manhattan, based on air pollution impacts from increased commercial activity
and vehicular traffic, arguing that construction of the project would assure
carbon monoxide nonattainment beyond the statutory deadline. The court held
that the failure of the SIP to attain the national standard was not, in and
of itself, a v-iolation of a condition or requirement of a SIP, or otherwise
actionable under the citizens suit provision of the Act.
--" 2^ SIP Approval: "Concerned Citizens of Bridgesburg v. EPA
Two citizens groups challenged an EPA final decision that emissions of
offensive odors are not separately regulable under section 110 after EPA
disapproved odor regulations contained in the Pennsylvania SIP. The citizens
groups contended that EPA should have followed the revisions procedure under
section 110(c) and provided Pennsylvania with reasonable notice and hearing
prior to disapproving. The Third Circuit held that any modification of a SIP
constitutes a "revision," which can be accomplished only through the statutory
procedures.
3. SIP Disapproval and Sanctions: Arizona v. Thomas (two cases)
In one decision, the Ninth Circuit upheld EPA's disapproval of an Arizona
SIP revision for total suspended particulates and new source review, and
imposition of a construction ban against a challenge by the State. Arizona
had argued that: (1) in 1984 EPA proposed a revised standard for particulate
matter and, consequently, deferred issuing SIP calls for other TSP SIP's, and
(2) as a result, EPA, by disapproving Arizona's SIP revision and imposing the
construction ban, unfairly singled out Arizona for harsher treatment than
imposed on other States. The court rejected the argument, explaining that
the State had not shown it was subject to harsher treatment than any other
similarly situated State.
In a second decision, the Ninth Circuit also upheld EPA's decisions to
disapprove Arizona's carbon monoxide SIP's for the Tucson and Phoenix areas,
and to impose construction bans. In challenging the disapprovals, the
State argued that because EPA had previously approved the SIP's as providing
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for attainment by 1982, its action should have been merely to issue a SIP
call, not to disapprove and impose a ban. The court agreed with EPA that
EPA and Arizona had both recognized before disapproval that the prior SIP's
did not provide for attainment, and that EPA had properly imposed the ban.
4. Prevention of Significant Deterioration: Sierra Club v. Thomas
(two caseTT
One case was a citizens suit to compel EPA to issue, regulations to
prevent significant deterioration of air quality from emissions-of nitrogen
oxides. The EPA admitted it had failed to issue such regulations as required
by the Act and the opinion focused on how fast EPA should be required to act.
The court imposed a deadline equivalent to the amount of time Congress
originally allotted to EPA for taking the action, and rejected EPA's claim
that the task could not be accomplished in that time.
In the second case, the D.C. Circuit dismissed a petition seeking to
require EPA to complete rulemaking on whether strip mines should be subject
to regulations governing fugitive dust. The court judged that a three year
delay since issuance of proposed rules _was not unreasonable under the
circumstances,, recognizing that while agencies have a duty to avoid
unreasonable delay, courts should be'hesitant to upset an agency's priorities.
..._ 5. Sect Con. 211"-: Regulation of Fuels
In Union Oil Co. v. EPA, the D.C. Circuit rejected a challenge to lead
"banking" regulations under the lead phasedown program. In 1985, EPA
imposed phased reductions on the lead content of gasoline, including
allowance of "banking" of credits for reductions below required levels.
This permitted refiners to "bank" credits for the difference, and to use or
trade them with others to offset lead usage exceeding the current limits.
6. Enforcement
In decisions involving State implementation plans, two circuit courts
held that EPA can enforce a current SIP while a source owner is trying to
change the regulation. In United States v. Ford Motor Co., the Sixth Circuit
held that the current federally-approved standard could be enforced even
though Ford and the State of Michigan had entered a consent judgment in State
court invalidating the regulation. The court viewed Michigan's act as
modification of the SIP based on revised notions of technological and economic
feasibility, but held that EPA had the final say on modifying the SIP. In a
second decision, the Third Circuit also held that Federal enforcement of an
existing SIP could proceed in United States v. Wheeling-Pittsburgh Steel
Corp. In this case, the company had submitted an emissions trading ("bubble")
proposal to the West Virginia agency, but the proposal had not been formally
submitted to EPA. The Circuit concluded that the district court erred in
relying on the bubble as a basis for ordering modification of the existing
consent decree.
In American Cyanamid Co. v. EPA, a case which involved noncompl iance
penalties, the Fifth Circuit held that EPA could not collect administrative
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penalties until it rejected a State proposal that would have brought the
company into compliance. The court found that EPA must act on a proposed SIP
revision within the four month period specified in section 110(a)(2) of the
Act.
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