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Beck, William B.
Chairman
HAOS Technical Subcommittee
Houston Area Oxidants Study
29
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HOUSTON AREA OXIDANTS STUDY
P.O. Box 53269
Houston, Texas 77052
(713)651-1313
January 5, 1979
Mr. G. K. Tannahill
Senior Program Manager
Radian Corporation
P. 0. Box 9948
Austin, Texas 78766
Dear Mr. Tannahill:
The following comments are submitted by the Technical
Subcommittee of the Houston Area Oxidant Study to the Radian .
Corporation. HAOS, a project sponsored by the Houston Chamber
of Commerce to investigate aspects of air pollution in the
Houston Area, has been a cooperative effort from its outset in
1976. Contacts have been maintained with the various regulatory
agencies, specifically the Texas Air Control Board, the City of
Houston and the U. S. Environmental Protection Agency; and
others engaged in air pollution activities. The EPA-Research
Triangle Park, has been informed of the HAOS activities and
research plans. These comments represent, therefore, a general
review of what information has already been supplied to the EPA
as pertaining to the current EPA study of Houston air pollution.
Additionally, comments are included that were presented to the
EPA as the results of the HAOS project became known.
It is the sincere desire of the Houston Chamber of
Commerce and other sponsors and participants in the HAOS project
that the results of HAOS may serve the new EPA research effort
in the Houston Gulf Coast an as extension of the data base, and
to provide a foundation upon which EPA effort can build new
understanding. To this end all HAOS data and project analysis
will be made available to the EPA and the general public.
Sincerel
William B. Beck, Chairman
HAOS Technical Subcommittee
WBB:aeb
Att.
30
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COMMENTS ON
EPA AIR POLLUTION RESEARCH PLANNING
Presented By
The Houston Area Oxidant Study Technical Committee
to
The Radian Corporation
October 12, 1978
***
From the perspective of planning, executing and now wrapping up an
extensive multi-disciplined air pollution research program in the Houston
Area, the HAOS technical subcommittee appreciates the logic of the current
efforts of the EPA to solicit input into the formation of both an air chemistry
research plan and a plan for health effects studies.
A. BASICS TO ANY RESEARCH REPORT
The following major points are recommended as basic to any research
effort:
1. Planning
Formation of a plan that is both comprehensive, to evaluate the coordinated
effects of the many facets of air pollution and yet at the same time detailed
enough to allow for close examination and control of the critical specific
parts. Such planning should include such inputs as:
• Hypothesis testing,
• Reevaluation of previous research efforts, both in the local area
and elsewhere,
* Adequate consolidation with local research groups.
2. Peer Reviews
Peer reviews of plans and specific projects that comprise the plan were
an important aspect of the HAOS program. Most major projects received a peer
review prior to starting the project. This is essential to insure all the
critical aspects have been considered.
Major investigations into health and socio-economic effects required both
a prestudy and post-study reviews. In addition to peer reviews, the EPA should
also involve the general public to the greatest extent possible to afford the
public opportunity for input.
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3. Data Quality Assurance
Data quality assurance has proven to be an essential but expensive part
of the HAOS aerometric monitoring program. While selection of competent
contractors who are experienced in air quality monitoring and who have exten-
sive QA laboratory capabilities is necessary to a good data quality program,
a separate and independent audit program will prove valuable.
Based on HAOS experience, the value of an independent third party QA
check is certainly equal to what would be gained by increasing the frequency
of internal audits. Moreover, an outside QA check brings to the QA program
the added creditability of the third party.
4. Open Review of Data
To the foundation of good planning, peer review and an extensive QA
program, timely reporting and review of data strengthens any research program.
While this is sometimes limited by the complexity of the data and its analysis,
much value is gained by a review of the results as early as possible. This
is especially true in research efforts such as these where public participation
and interest is so great.
5. Establishment of an Accessible Data Archive
A recent trend in regional air pollution studies is that they provide
for the establishment, or add to an already existing data base. This archive
of data must understandably be accessible and in a format that is usable by
others with wide variations in facilities and interests. For this reason,
HAOS established both an extensive computer based data archive and also
established, where possible, hard copy data summaries and individual project
reports. The advantage of these individual project reports is that they
allowed for an early release to the public of the specific work, allowed for
results to be presented in hard copy, and yet provided for overall analysis.
B. AIR MONITORING - GENERAL COMMENTS
The foundation of air pollution research is an adequate knowledge of air
quality and the weather patterns or meteorology that exerts so much influence
on air pollution. While this can differ from location to location, depending
on many factors, for the Houston area, HAOS has found that a rather extensive
air monitoring network is essential to accurately characterize the area's
air quality and to provide the basis for any attempt to identify the sources,
the fate and impacts of this air pollution. To this end HAOS established a
multi-station ground network shown in the attached Figures 1 and 2, which
extended from Hempstead, northwest of Houston, to an off-shore oil rig platform
some 60 km southeast. This network included existing regulatory stations,
TACB, City of Houston and the EPA, as well as volunteer industrial and private
research sites to augment the sites and equipment operated by HAOS contractors.
Over 30 ground sites were used for HAOS monitoring. In addition to the ground
stations, HAOS also used a fixed wing aircraft to monitor the area in three
32
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dimensions. This aircraft monitoring has greatly expanded the fixed station
network in terms of the vertical distribution of pollutants. Moreover, it
has also give HAOS a perspective to upwind, crosswind and downwind air quality.
For a comprehensive evaluation and assessment of air quality, the monitoring
network must be more extensive than what is currently in the plan and must be
capable of evaluating the quality of the background or transported air that
washes the Texas Coastal Zone with the diverse and frequent changes in the
area's meteorological conditions.
1. Ground Station Monitoring Limitations
During the HAOS monitoring program, concern was expressed about the
ability of point monitoring located at a height of three to five meters to
adequately represent the true quality of air around this point. This same
issue has received considerable attention by others. Increasing the number
of points sampled and frequency of sampling improves the representativeness
of the data. However, the issue of air quality with depth or height of the
atmosphere is not addressed. The HAOS effort at three dimensional monitoring,
while limited, reveals that ground station sampling by itself can be misleading.
For a variety of meteorological reasons the concentration of pollutants in the
air can be altered over a wide range. Inversions, changes in mixing depths,
wind shear and pressure gradients can all affect this. Since many pollutants
are carried aloft and transported that are difficult to detect with ground
level monitors, care must be exercised in attempting to extrapolate ground
station point sampled data.
2. Use of Distant Ground Station Monitors
The HAOS experience in assessing the general air quality in the Texas
Gulf Coast has led to the observation that there are frequent widespread
episodes of air quality changes. This is especially true for ozone. The
significance of this to the question of monitoring is that, while monitors
in the Houston area may indicate different levels of pollutants, they should
be integrated with values from surrounding cities, even out to 100-200 miles
distant, to provide a better picture of possible causes of air pollution on
a "macro" scale.
3. Air Monitoring Duration
The HAOS experience in monitoring air quality and in studying the TACB
records for the past years indicates that the period of air pollution activity
must be regarded as variable at best. Thus variability appears to be related
to the variability in weather conditions from year to year and month to month.
A monitoring program must take this into account. For example, in a given
year, moderate to strong ozone levels have been recorded as early as March
and as late as November. However, isolated examples of ozone peaks have been
measured in every month of the year. The levels of other pollutants have not
been followed as closely as ozone but it is expected that they would be
similar in behavior.
33
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C. AIR MONITORING - SPECIFIC POLLUTANTS
Incorporated into the HAOS program were projects aimed at the monitoring
of specific non-criteria pollutants. This was done either because no such
data on these pollutants existed, these pollutants were indicators of other
more generalized air pollution problems or they could be used as tracers or
surrogates to help in understanding the sources or causes of air pollution.
The following comments include specific pollutants HAOS did monitor and some
that in retrospect should have been monitored.
1. Beryllium-Isotope
This relative short half life isotope of beryllium is beginning to be
studied as an indicator of significant stratospheric air intrusion into the
lower troposphere. HAOS included it to a limited extent in our intensive air
monitoring program conducted in the Houston area in the summer of 1977. Pre-
liminary data, as measured by the radio activity of particulate matter indicates
that there are substantial intrusions of Be7 into the ground level atmosphere
at various times during the fall months. These intrusions may be associated
with macroscale weather changes and also seem to be related to increases in
measured ozone levels. This is the first such data collected in latitudes
as low as the Houston area. This work should be repeated for several summer-
fall periods.
2. Peroxyacetyl Nitrate (PAN)
HAOS through its contractor, Rockwell International, collected extensive
PAN data. Levels in Houston were found to be low relative to the California
basin. This work should be repeated over at least one more season. The rela-
tionship between ozone and PAN should also be studied more completely.
3. Detailed Hydrocarbons
HAOS has devoted a limited amount of its effort to detailed hydrocarbon
analysis. The benefit of this knowledge is obvious. Particular attention
should be paid to identified hazardous pollutants such as benzene, polynuclear
aromatics and others of this nature. These higher molecular weight hydrocar-
bons may exist as aerosols, or as absorbed on the surface of particulates.
Special sampling and analytical techniques will need to be used. HAOS recog-
nized the limitations of its GC-FID and GC-MS programs in this regard.
Natural hydrocarbons, the terpenes, etc. are quite reactive and must be
analyzed very quickly after samples are taken. Sample containers and tech-
niques are critical—specially cleaned stainless steel containers were used in
the HAOS program. Another aspect of hydrocarbon studies that HAOS was unable
to examine was the nature of hydrocarbons collected over water as compared to
urban and rural samples. Additionally, it is important to establish the
vertical extent, nature and concentration of hydrocarbons in the atmosphere.
34
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In the Houston area it has been suggested that anthropogenic sources account for
considerably less of the total hydrocarbons than expected. Biogenic sources
of hydrocarbons, normally referred to as natural sources, are a big factor.
Finally, the role of geogenic source hydrocarbons has been largely neglected.
This could be a most significant factor.
4. Other Compounds
Some other compounds of potential interest in an air monitoring program
are: nitric acid and hydroxyl radicals, asbestos, lead and other heavy metals
in the respirable range.
D. HEALTH EFFECTS STUDIES
The challenge of a meaningful air pollution health effects study is a
complex and tough one to meet. The literature is full of critiques on the
pros and cons of previous studies. HAOS contracted with Equitable Environ-
mental Health to review and critique previous work before selecting the Houston
Longitudinal Asmatics Study performed by Baylor College of Medicine and Southwest
Research Institute. A copy of the Equitable Planning study is attached and
it contains a presentation of some five other studies that could be performed
in the Houston area. HAOS believes that some combination of epidemiological/
chamber or controlled environment test would represent a good compromise.
Selection of subjects and test protocol could be designed to incorporate the
stress factor which is normal in most chamber studies. Unfortunately, chronic
exposure versus acute exposure is a key question that is not answered even
in a 6 month or longer test. One observation made by HAOS as a result of
it Houston Health Response Study is that design of the study protocol and
design of the data analysis is critical to obtain clear cut results. Another
observation is that a study is likely to produce more data than anticipated
and so a sizable allocation of funding should set aside for data analysis.
In this regard, a first approach EPA might wish to take is to examine more
fully the HAOS Health Study results. These should be available early in 1979.
Another suggestion regarding an EPA study would be to extend the HAOS
study into the second and third air pollution season, using all or some of the
same participants. This would eliminate considerable expense and time in
getting such a study underway. Additionally, EPA could alter the program
with a minimum of effort to add or delete objectives.
E. OTHER SUGGESTED AIR POLLUTION STUDIES
As a result of the experience gained in the HAOS project, the following
additional studies are suggested for EPA's consideration. HAOS will be happy
to expand on these if requested.
1. Captive Air Bag Studies
"Smog" chamber studies, largely conducted indoors, have not really ex-
plained real world behavior in air pollution studies. HAOS suggests that a
35
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large (1,000 cu. ft.) captive air bag chamber be operated in the Houston area
to conduct tests on real world air and solar radiation conditions. This chamber
could be moved about the area to sample different air mixes. HAOS has such
a chamber and would make it available to the EPA for this research. Addition-
ally, HAOS has obtained several interesting and sound captive air bag research
plans from outside contractors. These plans have already been provided to
the EPA.
2. Ozone Episode Studies
The behavior of ozone has been characterized as area-wide ozone fluctua-
tions affected by localized increases and decreases from local causes. The
question of this area-wide base level of ozone has been difficult to study.
It could however explain the phenomenon of ozone episodes that have been
observed over areas hundreds of miles in size. Because of the general flat
and basin-like character of central and southeast Texas, this is an ideal
area for study.
36
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Bevis, Martha
37
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October 4, 1978
Radian Corpora t ion
8500 Shoal Creek Blvd. Re: Possible Fluoride Emissions
Austin, Texas 78766 Houston-Calveston Area
Att: Mr. Gary K. Tannahill
Gentlemen:
The enclosed material will give you the basis for
including possible fluoride emissions in your study of causes
and effects of pollution in the Houston-Galveston area.
This summer I talked to Dr. Flannery at the Texas Air
Control Board and he said they check for fluoride if it is
suspected; that the last check they had made was a plant in
La Porte in '72 or '73. He suggested I send information to
Mr. Bill Stewart. I didn't get around to doing that, and since
you were conducting a study here, I thought it best to give it
to you. Perhaps you will share this information with Mr. Stewart.
1. ENVIRONMENTAL FLUORIDE 1977: National Research Council of
Canada. This is the latest and most comprehensive
study published - July, 1978. Additional copie's did
not arrive in time so I copied a part of this 156 page
study. See index for all material covered.
2. INTERN. JOURNAL ENVIRONMENTAL STUDIES: "The Summing of
Fluoride Exposures".
3. MICHIGAN STUDY OF TOTAL FLUORIDE INTAKE: Statement of Gov.
Milliken. The Michigan study for total fluoride intake
is being done because the fluoride ion affects human
health whether it enters the body via food, air or
water. Gov. Milliken had asked that this study be
finished by July. You might check and see what the
status is at this time.
4. MONITORING FLUORIDE POLLUTION: Insect & Disease Branch,
Forest Service, Missoula, Montana. I've copied part of
this study to show you the type of testing they used.
5. EPA ABSTRACT NO. 28556 - 1971: EPA will furnish you with
hundreds of additional abstracts on fluoride.
6. AIR POLLUTION PRIMER: American Lung Assoc. The chapter on
fluorides is enclosed.
7. JOURNAL OF THE AMERICAN MEDICAL ASSOC.: "Chronic Fluorine
Intoxication". States that in 1943 25,000 tons of
fluorine went into the atmosphere annually.
8. NEWSPAPER ARTICLE: April, 1978, Fluoride emission, Urbana,
Ohio.
9. LIBRARY OF CONGRESS: "Effects of Chronic Exposure to Low-Level
Pollutants in the Environment". This was published in
1975 and you should be able to get it from the Library
of Congress.
38
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Radian Corp. October 4, 1978
10. NEWSPAPER ARTICLE: Soybean Contamination - Tulane Univ.
PARTIAL LIST OF INDUSTRIES WITH POSSIBLE FLUORIDE EMISSIONS:
Steel, fertilizer (phosphate), aluminum, iron,
ceramics, brick, copper, glass, cement, chemical,
hydrofluorice acid production, zinc, tile, petroleum,
clay, coal (used as energy), teflon, nuclear (rocket
propellant), frit smelting, plastics, areosols, lead.
(One study stated more than fifty industries have
possible fluoride emissions).
Since fluoride in any form affects human health, I include the
following:
11. LIST OF STUDIES OF HEALTH EFFECTS OF FLUORIDE: Submitted
to Committee on Fluoridation (from Rice, TSU and
U of B) set up by Houston City Council.
If, after looking at the above list, there are special
studies you want, please call me.
12. ADVERSE EFFECTS OF FLUORIDATION: Submitted to Houston City
Council by Committee on Fluoridation.
Sincerely,
Mrs. R. M. Be vis 686-8391
7706 Brykerwoods
Houston, Texas 77055
CC: Dr. Flannery, T.A.C.B.
Dr. McKee, Air Pollution Control
Mr. Akers, Health Systems Agency
Dr. Raymer, San Jacinto Lung Assoc.
Others
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Clench-Aas, Jocelyne
Sierra Club
40
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December 5, 1978 '
Jocelyne Clench-Aas
1023 Lyndon # 8
Houston, Texas 77030
Home Phone: (713) 790-1956
Office (713) 792-4321
Gary Tannahill
Program Manager
Radian Corporation
8500 Shoal Creek Blvd.
P.O. Box 9948
Austin, Texas 78766
Dear Mr. Tannahill,
I am sending xyou a copy of a critique I did on behalf of the Sierra Club
concerning the Health Effects Section of the Houston Study, Contracts
and Grants. This document has been sent to Dr. Chapman of the EPA. I
would very much appreciate any comments you may have; and can be reached at
the above address and phone numbers.
This is not intended to be a literature review nor a proposal, merely
a set of suggestions.
In order to let you know a little of my background I am enclosing a
curriculum vitae and abstracts of some of our papers. I am also enquiring
about the possibilities of employment within your organization at Radian,
in the air pollution study since I am most interested in it.
I look forward to hearing from you and remain,
Sincerely yours,
Jocelyne Clench-Aas
41
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The briefness of the Health Studies section of the Contracts: and Grants
of the Houston Study, leaves the reader unclear as to how questions will
be resolved. As I see ft, there are two primary problems to be solved:
1) what is the lowest level of photochemical oxidants in the atmosphere
tolerable to human health, and 2) what health effects can be anticipated
due to chronic exposures to low doses and acute exposures to more critical
doses. The solution to these problems necessitates answering two secondary
questions: 1) which group of individuals constitute the "at risk" population
and 2) have urban dwellers "adapted" to pollution (Bell et al. 1977,
Hackney et al. 1977).
"At risk" individuals are those least able to physiologically adapt
either through impaired detoxification systems or inability to physiologically
compensate. The capacity to adapt is a function of environmental,
physiological and genetic factors operating together. Therefore these
three areas need to be taken into account in planning a protocol. Differences
inany of the above areas can lead to altered physiological states, thus
altering the capacity to adapt.
To facilitate this discussion I am only concerned here with photochemical
oxidants (hereafter referred to as ozone). However, most of this discussion
pertains to the other pollutants as well.
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ENVIRONMENTAL FACTORS
1) Climate
Houston has a particular combination of climatic features that distinguishes
it from Los Angeles, thus necessitating a special experimental protocol.
Although we share the same lack of temperature extremes, the range in
Houston is greater than the range in Los Angeles. What is especially notable
in Houston is the high humidity (often around 100%) coupled with high tempera-
tures, two factors that have been indicated as potentially affecting lung
functional response (Folinsbee et al. 1977 as cited in EPA document
60018-78-004, Stokinger 1965).
2) Air Quality
Air quality is a function of both manmade and natural pollution. It
seems to have a seasonal component (.Houston Study Section C-9) as well as
a daily component.
In evaluating health effects on man, however, several additional para-
meters need to be kept in mind since they ultimately affect the air quality
surrounding particular individuals.
Socio-economic status can have sizeable ramifications on the quality of
the air breathed. The use and effectiveness of air conditioning as well
as heating is a function of socio-economic status. Likewise certain classes
of society are more likely to be situated geographically near refineries,
storage tanks etc. In addition those working in industrial plants face
another quality of air. The toxicity of interacting pollutants (including
industrial pollution) remains largely unknown.
Superimposed on these environmental trends are seasonal and daily patterns
of climate, pollution and activity. For example, joggers tend to jog before
43
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or after work, I.e. 06 or 18°° (military time). Evening joggers are
subject to highest environmental pollutant load. Similarly, although
winter Is not necessarily the highest pollution seasdn, it involves the
least use of air conditioning and probably the least air filtration. Houston
has an exceptionally h{gh pollen load whose effects may aggravate existing
pollution effects and whose seasonal rhythm seems to coincide with
pollution patterns.
PHYSIOLOGICAL FACTORS
1} Sex and Age
Sex and agt are two very important parameters contributing to the
identification of physiological states. Age is known to have a profound
effect on the adaptability of the human (Bafitis. Sargent 1977), the
most adaptable period of the human life cycle being around the tate teens
or early twenties. Resistance to hypoxia has been indicated in the elderly
(Schwartz. 1936, Stupfel et al. 1975. Bruner et al. 1961) and related to
a decrease in oxygen consumption with age. This may also hold true for
ozone toxicity. There are different activity-patterns with age. This can
alter the pattern of air quality individuals are subject to.
2) Nutritional Status
Another important parameter possibly influencing ozone toxicity is
nutritional status. High levels of Vitamin C (Matzen 1957), glutathione
(Stokinger 1965) Vitamin I, Selenium and sulfer ion forming amino
acids (Shakman 1974) have been implicated in the reduction of ozone
toxicity. It must be remembered that the question of interest is not only
to what degree is ozone toxicity affected by nutritional status but also
how dots ozone toxicity affect nutritional status.
44
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3) Biological Rhythms
Circadian and circannual rhythms of physiological functions can influence
penetration of ozone into the hody, the sensitivity of target organs, pharmaco-
kinetics, etc., and must be taken into account (Reinberg, 1976; Refnberg,
Clench, 1976; Reinberg, Gervais 1972; Stupfel, 1975; Stupfel et-al. 1977).
Even though air pollution levels are highest in the summer, mortality due
to certain diseases of the lung peak in January (Stupfel et al. 1977).
4) Temperature Stress
Temperature stress can be an important parameter influencing physiological
states in the the Houston area. For those individuals using air conditioning,
adaptation to the heat and humidity never takes place. Each time they go
outside they subject themselves to heat stress.
5) Disease States
Disease states can alter the sensitivity to toxic agents and vice versa,
toxic agents can increase susceptiblity to disease. Ozone increases
susceptibility to bacterial agents (Coffin and Blommer 1967). In measuring
the effects of pollutants it is necessary to include diseases of bacterial
origin in morbidity. A question of interest is to what degree does infection
affect ozone toxicity.
A di-sease of particular interest in the Houston area is allergy. Ozone
has been shown to increase sensitivity to subcutaneous histamine in guinea
pigs (Easton and Murphy 1967). This has huge renrifications in a city having
a high pollen count that has a higher than normal number of people suffering
from histamine reaction. Not all people having allergic responses are
aware of them as such. I personally think that a prime reason for so few
calls being received in the Houston area complaining of health effects of
pollution stems from an inherent confusion of whether or not it is an
allergic response or a pollution effect. Many constituents of air pollution
45
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are water soluble. The effect of high pollution coupled with high humidity
on skin allergies and even possibly on neoplasms of the skin wo"qjd constitute
interesting fields of study.
In estimating the influence of air pollution on the response to histamine,
the circadian response of the human organism must be taken into account.
Maximal response to histamine is around 23°°, well after the usual time
for clinical observation of patients (Reinberg et al. 1969).
6) Miscellaneous
Other factors contributing to the physiological state of an organism
that can influence ozone toxicity are smoking and variously induced states
of anemia. Occupational exposure to other toxic substances (e.g. lead) can
influence ozone toxicity (McClimans et al. 1978).
GENETIC FACTORS
Although genetic differences in sensitivity...to-ozone toxicity probably
do exist, the identification of these genetic hyperreactors has not been
stressed, tlectrophoretic studies of the enzymes important in ozone
detoxification followed by studies of the enzyme kinetics of the electro-
phoretically determined variants would be of interest in the two groups:
1) hyperreactors and their siblings and parents, and 2) non-reactors and
their siblings and parents.
46
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OVERVIEW
In trying to establish the lowest ozone levels tolerable to human health,
the physiological response most sensitive to pollutant levels (e.g. possibly
eye irritation) should be studied in the most "at risk" population.
In studying the effects of chronic exposure several phenomena must
be kept in mind. It has been suggested that adaptation may have occurred
in the Los Angeles as compared to the Canadian populations.(Hackney
et al. 1977). However, in both acclimatization and adaptation, the organism
may show a greater ability to tolerate a certain level of aggression but
may not have the ability to adapt to levels over and above the adapted levels.
For example increased erythropoiesis is an adaptive response to hypoxia and
is evident at altitude. However, if smoking leading th higher CO in the
blood is superimposed on altitude hypoxia, the disease polycythemia
results in many cases. In this .case, if adaptation to chronic air pollution
doe in fact occur, is the organism's ability to respond to sudden acute
episodes or other toxic agents altered?
Having briefly outlined the spectrum of ideas I consider important to
consider in a proper evaluation of the health effects of air pollution,
I will proceed to a more specific commentary on the Guideline to Contracts
and Grants - Section 0 -12 and 13.
47
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1. Effect of Short-term Exposure to Texas Gulf Coast Air Pollution in 111
and Healthy Persons.
Choice of Subjects
Several problems came to my attention when evaluating the EPA guidelines
to contractors.- I do not think asthmatics should be excluded, although I
do feel that they should constitute a separate study group. I do not
think children under 15 should be excluded since children suffering from
asthma or COLD may be the most sensitive to air pollution. What kind of
medical exam will be given? What parameters explored? A simple questionnaire
is hardly enough. I think a greater diversity of disease situations should
be chosen. Why not select a population of known hyperallergic individuals
as revealed by hypersensitivity testing. There are several allergy clinics
in the city that could provide such individuals.
You indicate that the final count of panalists will include 100 COLD
(Chronic Obstructive Lung Disease) panalists'and'200 control panalists.
However, you have not clearly defined how many categories of indivudals
will be examined. For example how may stations will be used?, how many-
age groups?, how many socio-economic classes? how many occupational
categories?. I would calculate 1} at least three stations, 2} at least
4 age groups (6-15, 16-30, 36-45, 46 +), 3) two sexes, 4) three socio-
economic classes (poor, middle and wealthy) and at least four occupational
categories ( indoor office, indoor home, outdoor, and industrial). This
comes to a total of 16 categories. You should have at least 10 - 15 individuals
per cateogory totalling 160 to 240 individuals in each study set, COLD and
control. By my count you have too few subjects..
Environmental Conditions
Eight months is too short a period. The underlying assumption is that
the greatest effect of air pollution will accompany the highest environmental
48
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levels. This need not be the case, should susceptibility be higher at another
period. As I have indicated before, mortality due to lung disease is highest
in winter while pollutant load is highest in summer. If the lowest
environmental levels of air pollution are in the winter and infections are
highest at that time, this could lead to higher susceptibility. There
are seasonal rhythms of susceptibility (Momiyama 1977).It would; in my
opinion, be better to have readings every other month or even preferably
every two weeks over a 12 month period, with possibly extra readings right
around the period of peak pollution levels.
You indicate many questions on heating systems, type of fuel, etc.
However, there is not a word about air conditioning. Air conditioning is
an important part of Houston living both in motor vehicles and" in homes.
However, it is also a function of socio-economic status. The poor either
do not use them or have poorly functioning ones. Similarly even though a
person indicates that he is a non-smoker, he may have a heavy smoker in the
home or office. This should be noted.
Occupations can lead to varying exposures to air conditioned or filtered
air. Even if air pollution levels are highest in the summer, actual
exposure may be higher in the winter in certain professions.
I do not know the answers to these questions. I am merely indicating
that these questions exist and should be addressed.
Measuring at the same time each day for a given individual does not remove
the circadian effect from the total data. The hour of the test should be
noted and a comparison made between tests done at different hours of the day. Peopl
sensitivity to drugs (Reinberg, Clench 1976), histamine and allergens (Reinberg
et al. 1969) varies significantly over the 24-hour period. Tests should be run to
establish this hour of maximum sensitivity to each component of air pollution.
Subsequently tests should be run both at times of peak concentration and
49
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peak, sensitivity.
To decrease sample size separate studies could be run to progressively
single out the most susceptible population group. I would suggest one
experiment run on a homogenous (in age, sex and health status) group to
determine the hour of peak sensitivity (using 10 to 15 individuals). This
should be followed by a series run on at least four age groups of only
one sex (at the peak sensitivity time) to establish the most vulnerable
age group. A separate study on populations exposed versus not exposed to
air conditioning could be run to see if this in fact complicates the issue.
Once the most vulnerable population has been isolated, than a complete
series of pulmonary function tests could be run on that group. However,
it would be of interest to study a larger population as well using self-
measurement and continuous monitoring devices. For example, peak flow could
be measured by the Wright Peak Flow Meter (Airmaid, England). MEDILOGS
(Ambulatory Monitoring Instruments, Ardsley, N.Y.) can measure such parameters
as heart rate (an indicator of exercise), skin temperature (an indicator
of whether the individual is indoors or outdoors) and chest expansion.
There is a whole battery of measurements that can be done by the individual
such as time to add a series of random numbers, auto-estimation of fatigue,
oral temperature, a test of dexterity etc. These could be included in an
inexpensive (cuts down the need for experimenters) and usually well
received longitudinal study that would ennable a direct comparison with
air pollution readings at any given hour.
50
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2 Effect of Exposure to Te*as Gulf Coast Air Pollution in Maximally Exercising
Healthy Persons.
It should be recognized, that this study, although of interest has
severe limitations. By selecting young presumably male athletes you are
selecting the population that is possibly the most able to adapt to
environmental challenges (Bafitis, Sargent 1976). A measured effect in this
sample may indicate that another more vulnerable population will show an
even greater effect. No effect does not indicate that another population
would not reveal an effect. These reservations in mind, pass to specific
comments in the suggestions to contractors.
Choice of Subjects
I do find it dangerous to rely on questionnaires in determining
health status in this population. The individuals are young, less know-
ledgable about their own health and probably-very reluctant to release
information that may in their minds jeapordize their position in the
cross-country team.
Environmental Conditions
As much data as possible should be gathered. Hourly averages over
the 24-hour span should be indicated. Air quality information both within
the school and within the home should be acquired. The environmental information
that should be gathered is : temperature (averages and hour by hour),
humidity (similarly averages and hour by hour), 24-hour air-pollution
averages for each of the major pollutants as well as peak values and time
of peak.
May I suggest the use of continuous monitoring devices (again measuring
heart rate, skin temperature, and lung expansion) during the events themselves.
51
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This paper has not been an attempt either to review the literature or
to present a protocol. It is given merely as an indication of where I
feel there are weak points, and why I think these may be important to
consider. I do not think the study is specific enough to Houston and
Houston's problems. I am aware that to do all that I suggest would
be prohibitively expensive. I 'do think it is possible to take into consideration
some of the suggestions however.
I should also add that theproblemof the interaction of various chemical
pollutants needs looking into. I would presume that animal worlc .is
currently going on to determine the carcinogenic, teratogenic and toxicologic
effects of the individual pollutants and different chemical combinations
of them. This is another phase of the research effort and I will not dwell
on it here.
52
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Bafitis.F., Sargent, F., (1277} Human physiological adaptability through
the life sequence. J. of Geront. 32(_4}:402-410.
Bell, K.A., Linn, W.S., Hazucha, M., Hackney, J.D., Bates, D.V. (1977)
Respiratory effects of exposure to ozone plus sulfer dioxide in Southern
Californians and Eastern Canadians. Am. Indust. Hyg. Assoc. J. 38:696-706.
Bruner, H., Jovy, D., Klein, K.E. (1961) Hypoxia as a stressor. Aerospace
Medecine. Nov. 1961:1009-1018.
Coffin, D.L., Blommer, E.J. (1967) Acute toxicity of irradiated auto exhaust.
Its indication by enhancement of mortality from Streptococcal pneumonia.
Arch. Environ. Health 15:36-38.
Easton, R.E., Murphy, S.O. (1967) Experimental ozone preexposure and
histamine. Arch. Environ. Health 15:160-166.
Folinsbee, L.J., Horvath, S.M., Raven, P.B., Bedi, J.F., Morton, A.R.,
Drinkwater, B.L., Boldman, N.W., Gliner, J.A. (1977) Influence of exercise
and heat stress on pulmonary function during ozone exposure. J. Appl.
Physio!., REEP 43(3):409-413.
Hackney, J.D., Linn, W.S., Karuza, S.K., Law, D.C., Bates, D.V., Hazucha, M.,
Pengelly, L.D., Silver-man, F. (1977) Effects of ozone exposure in Canadians
and Southern Californians: evidence for adaptation? Arch. Environ. Health
32:110-116.
Matzen. R.N. (1957) Effect of Vitamin C and hydrocarbons on the pulmonary
edema produced by ozone in mice. J. Appl. Physiol. 11:105-109.
McClimans, C.O., Severs, R.K., Forthofer, R.N., Selwyn, W.J., Jenkins, D.E.
(1978). An investigation of ttv> relationship between respiratory morbidity
and ambient air pollution in an industrial population. In: Abstracts of
71st APCA Annual Meeting and Exhibition. Albert Thomas Convention Center
Houston, Texas 1978.
Momiyama, M.S. (1977) Seasonality in Human Mortality. A Medico-Geographical
Study. Tokyo: University of Tokyo Press.
Reinberg, A. (1976) Advances in human chronopharmacology. Chronobiologia
3(2):151-166.
Reinberg, A., Clench, J. (1976) Progress in human chronopharmacology.
Et Al. 4(1):58-60.
Reinberg, A., Gervais, P. (1972) Circadian rhythms in respiratory function
with special reference to human chronphysiology and chronopharmacology.
Bull, Physio-Pathol. Resp. 8:663-674.
Reinberg, A., Zagula-Mally, Z., Ghata, J., Halberg, F. (1969) Circadian reactivity
rhythm of human skin to house dust, penicillin and histamine. J Allergy
44:292-306. ^
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Schwartz, W. (1936) Der einfluss des alters auf die widerstands fahighkeit
gegen sauerstoffmangel. Luftfahrtmed. 1:39-43
Shakman, R.V. (1974) Nutritional influences on the toxicity of environmental
pollutants. Arch. Environ. Health 28:105-113.
Stokinger, H.E. (1965) Ozone toxicology. A review of research and industrial
experience: 1954-1964. Arch. Environ. Health 10:719-731.
Stupfel, M. (1975) Rhythms and air pollution. Chronobiologia Z(Z):105-115.
Stupfel, M., Halberg, F., Merdelet-Dembrine, M., Magnier, M. (1977)
Perspectives in chronobiology of air pollution. Chronobiologia 4(4):333-351.
Stupfel, M., Moutet, J.P., Magnier, M., (1975) An apparently paradoxical
action of aging: decrease of acute hypoxic mortality in male aged rats.
J. Geront. 30:154.
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CURRICULUM VITAE
NAME: Jocelyne Clench-Aas
ADDRESS: 1023 Lyndon #8
Houston, Texas 77030
TELEPHONE: Home-(713) 790-1956; Office (713) 792-4321
EDUCATIONAL BACKGROUND:
University of Texas - School of Public Health at Houston 1976 - present
Ph.D. Candidate
Area of Specialization - Human Ecology
Degree Expected -March to June 1979
Course work included :
Biochemical Nutrition Bioclimatology
Environmental Physiology Abiotic Environment
Physiology of Work Haste Management
Cellular Metabolism Hydrology
Intermediate Statistics Ecology
Mathematical 4 Computer Behavior and Adaptation
Methods in Time-Series Evolution
and Geographical Analysis Toxicology
Thesis topic: Characterization of Red Cell ATP and 2,3-DPG as a
Function of Altitude, Time, Genetic .Structure, Sex, Age, and
Environmental Lithium levels.
University of Paris VI 1971 - 1976
"License" in Animal Physiology in 1972
"Maitrise" (equivalent to Masters of Science) in Zoology in 1974
Course work included :
Biochemistry Animal Physiology
Lipids Physio!. of the Nervous System
Proteins Physio!. of the Cardiovascular System
Carbohydrates Physiol. of the Circulatory System
Enzymes Physiol. of the Renal System
Intermediary Metabolism Endocrinology
Nucleic Acids The Axon
Neurophysiology Physiological Psychology
The Nerve Cell The Ear
Motor Reflexes I & II The Eye
The Vestibular System Ethology
The Sensory System The Limbic System
Receptors Major Pathways of the Motor & Sensory
Sys terns
Homeostatic Regulation
Photoperiodicity
55
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Ph.D. Candidate
Area of Specialization - Human Physiology
Degree expected - Fall 1978
Thesis title: The circadian chronopharmacology of ethanol, Indomethacin
and sodium salicylate in healthy Man.
University of California - Santa Barbara 1967 - 1971
B.S. in Zoology
WORK EXPERIENCE:
University of Texas - School of Public Health 1977-1978
Graduate Assistant for Dr. Frederick Sargent II
1) Worked on preparing course material on land use and migration
in Latin America
2) Did research on the Changing Adaptability over the life sequence
of the human female.
Equipe de Recherche - C.N.R.S. -sur la Chronobiologie Humaine
under Dr. Alain Reinberg 1971 - 1977
Research Assistant
1) Circadian chronopharmacology of Ethanol in presumably healthy
male adults. (Funded by the D.R.M.E.)
2) Circadian chronopharmacology of Indomethacin in presumably, healthy
Han. (Funded by Merck, Sharpe & Dohme)
3) Circadian chronopharmacology of sodium salicylate in Man.
4) Circannual variations of leucocytes, total proteins and iimmoglobul ins
in presumably healthy young adults.
Tasks involved :
writing protocols; organizing research program; administrating and
actual running of experiment; analysis of raw data; treatment by
both conventional statistical analysis and by sophisticated computer
programs; writing of papers, etc.
University of California - Santa Barbara 1969 - 1971
Institute of Environmental Stress under Dr. Steven Horvath
Work Study
Laboratory Technologist with special emphasis on blood gas physiology.
MEMBERSHIPS: International Society for Chronobiology; AAAS.
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PUBLICATIONS:
1) Reinberg, A., Schuller, E., Delasnerie, N., Clench, J., Hedary, M. ,
(1977) - Rythmes circadiens et circannuelles des leucocytes, proteines
totales, IgA, IgG, IgM d'adultes jeunes st sains.
(Circadian and circannual rhythms in the blood (leucocytes, total
proteins, IgA, IgG, and IgM) of young healthy hunan adults.)
Nouvelle Presse Medicale
2) Clench, J., Reinberg, A., Dziewenoska, J., Ghata, J., Dupont, J.,
(1977) - Chronopharmacokinetics of Indomethacin in 9 healthy young
human adults. Chronobiologia 4(2): 105.
3) Reinberg, A., Clench, J., (1976) - Progress in Human Chrcnopharnacology.
Et Al. 4(1):58-60.
4) Clench, J., Reinberg, A., Ghata J., Dupont, J., (1975) - Chrono-
pharmacologic effects of Indomethacin in healthy young human subjects.
Chronobiologia 'Suppl , 1:14-15.
5) Reinberg, A., Clench, J., Aymard, N., Gaillot, M. , Bourdon, R.,
Gervais, P., Abulker, Ch., Oupont, J., (1975) - Variations
circadiennes des effets de 1'ethanol et de 1 'ethanolemie chez
Thomme adulte sain (etude chronopharmacologique). J. Physiol (Paris) 70:1-22
(Circadian variations of the effects of ethanol and ethanolemia in the
young healthy adult (chronopharmacological study).
6) Reinberg, A., Clench, J., Ghata, J. , Kalberg, F. , Abulker, Ch.,
Dupont, J. , Zagula-Mally, Z., (1975) - Rythmes circadiens des
parametres de 1' excretion urinaire du salicylate (chronopharraacocirtetique)
chez Thomme adulte sain. Comptes-Rendus Acad. Sc. Paris. 280:1697.
(Circadian rhythms of the parameters of the urinary excretion of
salycilate (Chronopharmacokinetics) in the healthy adult man.)
7) Reinberg, A., Clench, J., Aymard, N., Gaillot, M. , Gervais, F.,
Abulker, Ch., Dupont, J., (1974) - Rythmes circadiens des parametres
de 1 ' ethanolemie provoquee chez six hommes adultes jeunes et sains.
C. R. Acad. Sc. Paris. 278:1503.
(Circadian rhythms of the parameters of induced ethanolemia in
six healthy young adult males).
References and transcripts will be furnished upon request.
57
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Jocelyne Clench-Aas
CIRCADIAN CHRONOPHARMACOLOGY OF ETHANOL, INDOMETHACIN AND SODIUM
SALICYLATE IN HEALTHY ADULT MAN
ETHANOL
Six healthy young men (22 to 26 years) who had fasted for 12 hours volun-
teered for this study (subject synchronisation: diurnal activity from 0700
to midnight and nocturnal rest). A set dose of ethanol (0.67 g/kg body
weight) was ingested at the fixed (and random) hours of 0700, 1100, 1900,
and 2300, with a week between tests.
A set of physiological variables: psychological tests (self-rating >of
mood, of physical vigor and of ebriety, tempo, random number addition
tests); physical variables (heart rate, systolic and diastolic blood pres-
sure, peak expiratory flow, oral temperature and grip strength); blood
variables^ plasrna+ethanol, cortisol. lactic acid, pyruvic acid, glucose
and erythrocyte K ) and urinary variables (volume, epinephrine, nor-epinephrine,
and 5-HIAA) were documented at least at 4 hourly intervals and set times.
The cosinor method was used for chronobiological statistical analyses.
The parameters characterizing the ethanol pharmacokinetics (chronopharma-
cokinetics) demonstrated a circadian rhythm (p<0,05); e.g. the peak height
of ethanolemia is greater when ethanol is ingested at 0700 than at other
times.
Also a circadian rhythm in biosystems susceptibility can be demonstrated
(p<-0.05)(chronesthesy) with a peak time not necessarily corresponding either
to that of ethanolemia or to that of other variables.
The overall circadian changes in ethanol effects (chronergy) can be
viewed as a combination of both ethanol chronesthesy and chronokinetics.
FROM: Reinberg, A..Clench,J..Aymard, N., Galliot, M.,Bourdon, R., Gervais, P.,
Abulker, Ch., Oupont, J., Variations circadiennes des effets de 1'ethanol
et de 1'ethanolemie chez 1'homme adulte sain. Etude ch>-onopharmacologique.
J. Physiol., Paris, 1975, 70: 435-456.
IMDOMETHACIN
Nine subjects (19 - 29 years) including two females were studied from
Nov. to Feb. Subjects synchronisation: diurnal activity (0700 to 0000) and
nocturnal rest. A single dose (100 mg) of Indomethacin was ingested at each
of the 5 different fixed test times, one week apart (Saturday-Sunday). The
fixed clock hours were: 0700, 1100, 1500, 1SOO and 2300. The test order
was randomized. Test duration was 28 hours. El even phys"1o1o"g7ic2"l variables
were documented (post absorption) at intervals £t=0.5, 1.0, 1.5, 2.0 and 4.0
hrs thereafter, as well as 2 hourly testing done on a control day.The variables
measured were: self-rating of mood and fatigue, heart rate, systolic and
diastolic blood pressure, oral temperature, grip strength, joint size,
eye-hand skill, random number addition test and capillary resistance.
Venous blood was sampled at; 0, 0.33, 0.67, 1.00, 1.50, 2.00, 4.00, 6.00,
8.00 and 10.00 hrs from ingestion time. The spectrophotofluorometric method
of L. A. Grabowski was used for plasma Indomethacin determinations. The
The pharmacokinetic agent was characterized by: the peak of the plasma
concentration (peak height), the span of time to reach this peak (time to
peak) and the area under concentration/time curve (area). Both conventional
and single cosinor methods were used for statistical analyses.
58
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INDOMETHACIN cont.
The mean cosinor analysis showed that a statistically significant
rhythm (p<0.05) was validated: 1) on the control day and 2) when
Indomethacin was ingested at 1900 and/or at 2300 for the following variables:
self-rating of mood and fatigue, heart rate, systolic and diastolic blood
pressure, oral temperature, grip strength, joint size, eye-hand skill,
random number addition test.
A circadian rhythm of the peak height was validated (p<0.005) with
mesor M=5.21)ugm/ml; amplitude A (as % of M) = 23.2 (from 14.6 to 31.7);
acrophase 0C tm'dm'ght as 0 reference) = 08.52 (from 0706 to 1037). A
circadian rhythm in the time to peak is validated as well (p<0.005) with:
M = 129 minutes; A (as % of M) = 31.8 (from 20.2 to 43.4); 0 = 20.13
(form 1834 to 2200). The area does not show a circadian variation. Thus
the ingestion of Indomethacin around 1900 is associated with: 1) the
smallest peak height and the longest time to peak.This may help explain the
findings of the physiologic variables that indicate that the subjects's
.emporal structure is not altered by an evening ingestion and more or
less perturbed by a morning one. Indomethacin induced changes (expressed
as individual ratios; measurements at TO + 4hrs/ those on corresponding
clock hours on control day) also show statistically significant circadian
rhythms for most of the studied variables. Evening ingestion of the drug
seems to be less disturbing, despite some undesirable effects (e.g.
capillary resistance, addition test) found in a few variables.
FROM: Clench, J., Reinberg, A., Ghata, 0., Dupont, J., Chronopharmacological
effects of Indomethacin in healthy young human subjects.
AND: Clench, J., Reinberg, A., Dziewanoska, J., Ghata, J., Dupont, J.,
Chronopharmacokinetics of Indomethacin in 9 healthy young human adults.
Chronobiologia 2(suppl. 1):26 and 4(2):22. 1975 and 1977 respectively.
SODIUM SALICYLATE
A solution containing 1 gm of crystallized sodium salicylate was in-
gested in four separate tests at least one week apart, by six volunteer
healthy adults at each of the following test times: 0700, 1100, 1900 and
2300. The subjects had been on a routine of diurnal activity with lights
on from 0700 to 2300 and collected urine at four-hourly intervals for 48 hrs
following drug ingestion. By the mean cosinor summary of least squares fits
of a 24 hour cosine curve, or by other testing, a within day difference is
established for several chronopharmacokineticparameters characterizing
urinary salicylate excretion. By criteria including the height of peak '
excretion, the span necessary to reach the peak, etc., it is shown that
as compared ''to drug administration at other times, salicylate is
excreted faster into the urine, reaches higher values sooner and is falling
off faster when the drug is ingested between 1900 and 2300.
FROM: Reinberg, A., Clench, J., Ghata, J., Halberg, F_, Abulker, Ch.,
Dupont, J., Zagula-Mally, Z., Rythmes circadians des parametres de
1'excretion urinaire du salicylate (chronopharmacocinetique) chez 1'Homme
adulte sain. C.R. Acad. Sc. Paris, t. 230 (Havn'l 1975)
59
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Cooper, Hal, B.H., Jr., Ph.D., P.E.
Environmental Studies Coordinator
University of Texas at Austin
Center for Energy Studies, Austin
60
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Prepared Comments
on the
TEXAS GULF COAST STUDY PLAN
on the
AIR POLLUTION RESEARCH PROGRAM
for the
U.S. ENVIRONMENTAL PROTECTION AGENCY
under the
CONTRACT NO. 68-02-2955
Prepared by
Hal B. H. Cooper, Jr., Ph.D., P.E.
Environmental Studies Coordinator
University of Texas at Austin
Center for Energy Studies
Austin, Texas 78712
Presented at the
Preliminary Planning Meeting
Sponsored by the Radian Corporation
Holidav Inn Medical Center
6701 South Main Street
Houston, Texas 77021
October 3, 1978
61
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INTRODUCTION
Purpose
The U. S. Environmental Protection Agency is preparing to conduct
a detailed three year study of air pollution and related health effects pro-
blems along the Texas Gulf Coast. The three million dollar study program will
be administered by the Radian Corporation, which is responsible for
developing a detailed study plan. The first phase of the plan development
process involves an identification of specific research needs and capabilities
by local organizations. The present study was mandated by passage of the
recent 1977 Amendments to the Federal Clean Air Act.
The purpose of the contract is to develop base and perform analyses
of air quality along the Texas Gulf Coast. The study is to be composed
of specific topics relating to literature review, emission characterization,
regional meteorology, pollutant nature, fate and control. The ultimate
purpose of the study is to provide a suitable data base for understanding
the unique air pollution characteristics of the Texas Gulf Coast. The
information developed in the study can then be used as a basis for an air
quality management plan for assisting the Gulf Coast area to comply with
Federal air qulaity requirements while maintaining a healthy economy.
Problem
The Texas Gulf Coast is the center for the nation's petroleum and
petrochemical industries, with approximately 25% of the National refining
capacity and over 40% of its petrochemical production. The Houston-Galveston
62
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metropolitan area is the nation's most energy-intensive urban region, and
account for almost three percent of the nation's total energy consumption.
The Beaumont-Port Arthur and Corpus Christi-Point Comfort metropolitan
regions are also very energy-intensive in a manner far out of proportion
to their populations. The Houston-Galveston metropolitan region is also
the nation's fastest growing metropolitan area in terms of population,
because of its healthy economic stituation, with a growth rate exceeding
2,000 persons per week.
The Houston-Galveston metropolitan region is presently classified
as a nonattainment region in terms of Federal primary ambient air quality
standards for photochemical oxidants and particulate matter. This designation
as a nonattainment region has resulted in.the necessity for the area to
implement the emission offset policy, where no net increases in the designated
air pollutant emissions for the region would be allowable. In addition,
prevention of significant deterioration requirements would severely restrict
the siting of new industrial facilities in the region. Air quality require-
ments will also mean that significant reductions in air pollutant emissions
will also be necessary from transportation sources. Serious conflicts
between air quality and economic growth will result unless rational air
pollution control strategies are developed for the Texas Gulf Coast.
SITUATION
Energy Usage
Texas is the nation's largest producer of energy resources with just
over 10% of the total energy production. Texas produces 35% of the nation's
63
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oil and 37% of Us natural gas, Texas is also becoming a major coal-
producing state, with 14 million tons of low grade lignite coal produced
in 1976. Total lignite coal production in Texas is expected to reach 58
million tons per year by 1985. This lignite, along with an estimated 40
million tons per year of Western coal, will mean that Texas will be using
almost 10% of the desired national total under the National Energy Plan.
The Texas Gulf Coast is the most energy-intensive region of the
country, and constitutes approximately five percent of the national total
energy use. Conservative projections of increased coal use in the Houston-
Galveston metropolitan area indicate that nine million tons of coal will
be used in the industrial sector by 1985, partially as the result of Texas
Railroad Commission Docket No. 600. In addition, an estimated ten million
tons per year of coal will be burned for electric power generation in the
Houston-Galveston metropolitan area by 1985. If all possible'applications
for coal use in the industrial, utility and transportation sectors were
converted, the total coal use in the Houston-Galveston region would exceed
150 million tons per year.
The energy goals mandated by the Texas Railroad Commission under
Docket No. 600 on natural gas phaseout and by the U. S. Department of Energy,
under the coal conversion provisions of the forthcoming National Energy
Act will be in direct conflict with some of the air quality goals in the
recently enacted Federal Clean Air Act. The present study needs to address
the air quality impacts of these energy goals in terms of emission control
requirements,projected air quality levels of aerosols and gaseous, and
potential health effects. The overall question of energy facilities siting
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for industrial, utility and transportation uses needs to be a part of the
present study in terms of urban versus nonurban siting and concentrated
versus dispersed siting.
Emission Trends
Previous studies of the impact of the above-mentioned increased coal
utilization on air pollutant emissions in the Houston-Galveston metropolitan
region have been made by the University of Texas at Austin. Particulate
matter emissions resulting from increased coal combustion in the Houston-
Gal veston region are expected to reach 13,700 tons per year by 1985, or
11% of the 1973 Region 7 total. Sulfur oxides emissions from increased
coal combustion in the region are expected to be between 128,000 and
224,000 tons per year by 1985, an increase of 66 to 115% of the 1973
Region 7 total. Nitrogen oxides emissions from increased coal combustion
alone are estimated as 172,000 tons per year, or 58% of the 1973 Region 7
total.
The above calculations presume the primary use of low sulfur Western
subbituminous coal as the predominant fuel in the Houston-Galveston region.
The significant use of the higher sulfur Eastern coals and Texas lignites
would greatly increase the estimated air pollutant emissions in the region,
especially for sulfur oxides. The problem would be especially great for
large scale use of high sulfur bituminous coal in onsite industrial stoker-
type boilers in existing industrial plants immediately upwind of populated
areas.
Several air quality impacts may result from the proposed increased use
of coal along the Texas Gulf Coast. Particulate burdens in the atmosphere
65
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will increase because of increased primary fly ash and secondary nitrate
and sulfate aerosol contents, which may result in reduced visibility
and increased health-related impacts. The increased sulfate and nitrate
aerosol contents resulting from the greater sulfur oxides and nitrogen oxides
emissions will aggravate acid rainfall in the area to the detriment of
material surfaces, drinking water quality, aquatic and marine life. The
increased nitrogen oxides emissions may alter the photochemical reaction
mix of hydrocarbons-to-nitrogen oxides, with possible changes in reaction
product distribution and reaction rates.
Local Uniqueness
The Texas Gulf Coast has several unique characteristics which make it
different from other metropolitan regions in terms of air quality considerations,
First, the area has a relatively high relative humidity level, which tends
to enhance heterogeneous gas-liquid reactions on the surfaces of particles.
As a result, sulfate and nitrate-production are encouraged by catalytic
reactions of nitrogen and sulfur oxides. The relative predominance of first
or second order reaction mechanisms is still an unresolved research question.
The second unique feature of the Texas Gulf Coast region is the high
reaction ratio of hydrocarbons-to-nitrogen oxides in photochemical atmospheres.
The result is to encourage the formation of aldehydes and epoxide aerosols
at the expense of peroxyacyl nitrates, nitrosamines and nitrate aerosols.
As a result, nitrogen oxides may prove to be the limiting reactant in the
photochemical atmospheres. Significant increases in nitrogen oxides con-
centrations may alter reaction rates and reaction products. The presence
66
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of substantial hydrocarbon concentrations may accentuate the oxidation of
sulfur oxides and nitrogen oxides to organic-based sulfate and nitrate
aerosols.
RECOMMENDATIONS
A number of specific recommendations need to be made as a part of the
proposed study plan in the following areas.
B. Emissions and Resultant Air Pollution
1. Emission data will need to be gathered for organic compounds in
terms of types and amounts of specific types of compounds in terms of
photochemical reactivity. Nitrogen oxides- and sulfur oxides emissions
need to be categorized by source and amount. Particulate emission character-
ization needs to be made by source. Projections of all of the pollutants
need to be made into the future for alternative industrial development and
energy use scenarios. Of particular concern is to delineate the direct
combustion of coal in new boilers in urban areas as compared to conversion
to synthetic fuels outside of urban areas with subsequent combustion in
urban areas in existing boilers.
2. The gathering of ambient pollutant concentrations should include
the determination of the trace metal concentrations in particulate matter
as a function of particle size. Of particular concern is to determine the
cationic association of sulfate and nitrate aerosols.
3. The uniqueness studies of the Texas Gulf Coast should include the
high relative humidities and the hydrocarbon-to-nitrogen oxides reactant
ratios.
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E. Pollutant Nature, Sources, Fate and Control
1. The studies on nature, sources and fate of aerosol pollutants
should include studies of removal mechanisms including the resulting chemical
composition of precipitation in terms of acid-producing and metallic con-
stituents. The impacts of sulfate and nitrate aerosol concentrations on
total particulate burdens need to be evaluated in terms of possible control
strategy development. Baseline total suspended particulate levels need
to be developed for sulfate, nitrate, trace metal, trace organic and radio-
isotope contents by mass concentration and particle size as a baseline for
future coal and lignite utilization.
4. Air Quality Simulation Model Validation
Laboratory studies need to be performed of sulfur dioxide and nitrogen
dioxide oxidation in highly humid atmospheres in the presence of hydrocarbons
and particulate matter. Reaction rate constants need to be developed and
suitable air quality models need to be developed. Photochemical models of
sulfur dioxide and nitrogen dioxide reactions need to be developed and
verfied through field and laboratory studies.
F. Local Agency Facilities
The University of Texas at Austin has laboratory and computer facilities
which could be used for the proposed studies. The Center for Energy Studies
at the University of Texas at Austin can enter into contractual agreements
with the U. S. Environmental Protection Agency to carry out any specific
research projects, either alone or in conjunction with other organizations.
Research projects can be conducted both by laboratory and computer studies
in Austin and on field projects in Houston or elsewhere.
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The University -if Texas at Austin
Environmental Studies Program
Center for Energy Studies
Austin, Texas
PROPOSALS
The Center for Energy Studies at the University of Texas at Austin
is submitting two preliminary research proposals as a part of the Texas
Gulf Coast Planning Study. These proposals are briefly described in the
following discussions.
I. Title: Imoact of Fuel Conversion Strategies on Emission Trends
and Air Quality along the Texas Gulf Coast
Time: Two years (24 months)
Amount: 375,000
Person: R. W. Miksad
The impact of alternative strategies for fuel conversion ton coal
and fuel oil is to be determined for several alternative energy scenarios
by a computer modeling study. Projections of combustion-related emissions
are developed for alternative direct combustion and synthetic fuels develop-
ment. Air Quality impacts on sulfur and nitrogen oxides transformations
in Gulf Coast atmospheres will be determined based on already developed
atmospheric dispersion models. Control strategies can then be developed
based on the results of the study.
II. Title: Chemical Characterization of Precipitation as a Pollutant
Scavenging Mechanism along the Texas Gulf Coast
Time: Three Years (36 months)
Amount: 5130,000
Person: H. B. H. Cooper
The chemical composition of precipitation in the Texas Gulf Coast
region is to be determined in terms of acid-producing, trace metals and
organic compounds as a scavenging mechanism and a potential water quality
problem by a field study. The buffering capability of particulate matter
and ammonia in Gulf Coast atmospheres will be determined as an offset to
sulfate and nitrate-bearing acid components. Time and space variations
in chemical composition of precipitation will be established to develop
baseline data in terms of emission trends for the future, as well as to
establish the basis for control strategy development.
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ADDITIONAL REFERENCES SUBMITTED
Prepared Testimony on the POTENTIAL FOR INCREASED COAL UTILIZATION IN THE
STATE OF TEXAS. Submitted by: Hal B. H. Cooper, Jr., University of Texas
at Austin, Austin, TX. Presented to: Railroad Commission of Texas, June
20, 1978.
NATIONAL ENERGY POLICY: A CONTINUING ASSESSMENT, January 1978. Council
on Energy Resources, The University of Texas at Austin.
TEXAS RESEARCH NEEDS IN AIR POLLUTION CONTROL, Texas Air Control Board,
Austin, TX, April 1977.
A METHOD OF INCLUDING SECOND-ORDER OXIDATION OF S02 IN AN URBAN AIR QUALITY
MODEL. A. R. Laird, Atmospheric Sciences Group, Center for Energy Studies
University of Texas at Austin, Austin, TX, January 15, 1978.
AN APPLICATION OF A PSUEDO-SECOND ORDER S02 REACTION ALGORITHM TO URBAN
AIR POLLUTION MODELING. A. Rachel Laird and Richard W. Miksad, College
of Engineering, University of Texas at Austin, Austin, TX. Presented at
71st Annual Metting of the Air Pollution Control Association, Houston,
Texas, June 25-30, 1978. Accepted for publication in The Journal of .the
Air Pollution Control Association, 1978.
OBSERVATIONS ON THE PARTICIPATE CHLORINE DISTRIBUTION IN THE HOUSTON-GAL-
VESTON AREA. A. R. Laird and R. W. Miksad, Atmospheric Science Group,
University of Texas, Department of Civil Engineering, Austin, TX, December
1, 1977.
CHEMICAL COMPOSITION OF ACID PRECIPITATION IN CENTRAL TEXAS. Hal B. H.
Cooper, Jr. and Jose A. Lopez, University of Texas at Austin, Austin,
TX and Jerry M. Demo, Texas Air Control Board, Austin, TX, May 26, 1976.
AN EVALUATION OF THE RESTRICTIVENESS OF TEXAS AIR CONTROL BOARD REGULATION
V ON CONTROL OF VOLATILE ORGANIC COMPOUND EMISSIONS FROM PETROLEUM STORAGE
AND OTHER FACILITIES. Michael L. Magee and Hal B. H. Cooper, Jr., Center
for Energy Studies, The University of Texas at Austin, Austin, TX,
Environmental Study No. 1, June 1978.
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Faucette, James R.
Chairperson
Air Quality Committee
Galveston Bay Conservation and Preservation
Association
71
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Oonf,i? .nation and (Pur;e;ttat io n c^ooe iat ic
0 'Sot 323 Seob/toct. j'^ao 77536
October 2, 1978
Mr. Gary Tannahill
Program Manager
Radian Corporation
8500 Shoal Creek Blvd.
Austin. Texas 78766
Dear Mr. Tannahill:
As chairperson of the Air Quality Committee of the Galveston Bay Conservation and
Preservation Association, I want to thank the Environmental Protection Agency and
the Radian Corporation for the letter received by us, dated August 29, 1978, and
inviting us to participate in the project on air pollution and related health problems
in the Texas Gulf Coast area. Let me say to you that I am representing a sizeable
group of citizens about 400 of whom are organized into a dynamically active volunteer
citizens organization. The concerns expressed here are intended to have in mind
the well-being of citizens and residents.
First, it would be helpful to have some clarification as to the intent, direction, and
scope of the project as summarized in the August letter. The mandate from Congress
seems to clearly focus on two matters of utmost importance to many citizens who
reside in this area: (1) Attention/research of health problems and the health effects
of air pollution; and (2) the cooperative participation of local groups in the project.
In the August letter the reference to the scope of the project is ambiguous in saying
that "among other tasks, we are collecting information on air pollution and its
health effects in the Texas Gulf Coast region... ". The ambiguity arises from the
reference to "among other tasks" and it would be important to know what are the
other tasks referred to in that statement. The task mandated seems to be the single,
and sole task involved in the project. We would want that kind of concentrated effort
and feel that the singleness of purpose in understanding the health effects of air pollution
in the area merits full attention. If the money and effort is to be directed to other
tasks then these need to be explained. The matter is raised only because we would
not want to have the results of this important work diluted. We need thorough and
accurate results which can help people from the various sectors of interest in this
area make decisions which can be based on valid and solid information. Regarding
the second matter on the mandate we would understand this to mean an ongoing oppor-
tunity to participate and not just a one-time opportunity at the meeting in October.
We request that in addition to this informal meeting another meeting be held at which
time a progress report be made and another opportunity for assessment and input be
given interested area groups.
It is necessary for us to raise questions about the contracting between E. P. A. and
the Radian Corporation. The mailing address of 8500 Shoal Creek Blvd in Austin
72
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places them in close proximity to the Texas Air Control Board at 8520 Shoal Creek
Blvd. This location leaves as needing assurances of the corporations' autonomy and
their objectivity in conducting the study. To what extent will they be influenced by
the Texas Air Control Board? It is important that this study be contracted for so
as to assure professional independency, autonomy, objectivity, and competency.
Who are the health experts with this corporation by position or in consultation for
this study?
Another matter we write to ask about has to do with the absence of any indication
at this point as to how you plan to collect data. What are going to be the building
blocks for your data base? It is important and necessary that you establish your
separate monitoring system in order to provide comparative data and in order to
fill in gaps where the kind of data needed is not available.
Now, for a response to the three page exhibit A on the scope of work. This design
is one-sidedly emphasizing the technical aspects of certain air pollutants and there
is not enough definition given to the health effects aspect of the study. There is
inadequate reference to available and known health effects data which would be
germame and essential to the study. The design thus far does not indicate that
there is to be a well-balanced integration of technical air pollution data and scien-
tific health effects data. Then, of course, for the study to be useful it must be
applicable and practical. Some concerns are:
It is essential to give much attention to the specific, known, suspected,
and potential carcinogenic and mutagenic agents as well as chemical
agents or properties capable of chromosomal damage. These should be
listed and studied in terms of isolated and cumulative or combined
effects. There is a definite need for studies to be applied related to the
long term effects of low level exposures. Available information needs
to be compiled so as to pin-point sources and emission levels of the
potentially harmful sources of air pollution and then this information
, collated with the location and dwelling of people and related health effects.
Consideration needs to be given to short term, critical upset, and long
term effects with the dormancy threat. The distinction between community/
residential exposures for 24 hours a day and the worker exposure of
8 hours a day needs to be applied to the study in determining the effects
of pollutants and the possible safe levels of any exposure in an area
where people reside.
Definitive studies are needed on the effects of SO^ and the issue of con-
verting to coal from natural gas for the Houston area. Specific attention
needs to be given to particular respiratory health problems and air
pollution. Several recent public hearings by the Texas Air Control Board
highlight some of the basic health concerns and issues which were raised
by citizen organizations and municipalities. We invite your attention to
the transcript of the proceedings of Public Hearing 114 and 116, and are
available to help locate the information within these records. Numerous
references on the health affects of air pollution can be found in those re-
cords.
I summarize our concern with an illustration. We want the study to be conducted
73
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in such a way so that even if the results were to justify placing a notation on the sales
contract of a house in an area of pollution which states: "breathing the contents of the
air in this location over an extended period of time could be injurious to your health",
those results will be available for consideration by the public and all persons con-
cerned.
-Sincerely youivs,
James R. Faucette, Chairperson
Air Quality Committee
JRF/oh
74
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Mannchen, Brandt
75
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October 3, 19?3
Areas for Research on «ir Pollution
in the Houston Region
1.) What S02 control strategies exist today (FGD, burning of
low sulfur coals, burning of naturnl gas, PBG, coal cleaning before
contustlon, etc.) and how do these strategies compare in economic
costs, environmental costs (are they throw away or regener-.ble sy-
stems), what saleable by-products cars be recovered, technological
feasibility, reliability, efficiency, and nuinten^nce (cost and ease
cf repair or maintenance)? What future control strategies look :i ••-
rising? These questions should be addressed with the fuol switch
&vsr fron natural gas and fuel oil to coal in mind
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other fetors in the formation of Ozone and other oxidants, controls
necessary to reduce undesirable concentrations.
^i.) The synersristic effects of air pollutants in the Houston
->rea. Especially addressing the number of different air pollutants
and the difficulties of the early warning problems for health effects,
t^* irdivijuE-i hsrlth effects (wh^t concentrations cause problems,
thresholds if there --re any), carcino^-j.-is, teratogens, mutagens,
respiratory illnesses, etc.), how th^se pollutants interact with each
other (whether they combine to form more toxic, lass toxic, or seuon-
lary pol]ut-nts).
5.) Spiderciological studies on populations in the vicinity of
different rsjor industrial plants or in the path of their plumes and
hew their r--.t» of cancer, birth defects, .Tiutatir.ns, respiratory dis-
»as»s (-.<"?lth effects in general or specific hft "> v.h effects) compare
••'ith ar?"s r.ofc in close proximity to such industrial complexes or
thftir plurss. The ?cononic cost of the pollut .nts rr. the victims and
their property losses and on society as a whole r.c. ,nich if any
socioec^^oiric or =ee group is most likely to t,-. - f facted (aged, chil-
dren, n:."_crit;!e7, wealthy, athletes, etc.). I'.:, effects that pollu-
tion is '--.•:::~ en /sgetation and VsrtouE nater-i.-ls.
*-..] " .-'.ft is the magnitude of odor poll :t 3 or. ir the Houston
^re?. :ri >''r *• -b.-t^raent strategies or control =•-\--i~rent are available
or need tc 'c» i•?'/•!oped to reduce this prc'cl^-'.
?.) ',-.'::;.t v.-ill be the amount and the effect of an increased
amount of tr^ce metals, radioactivity, Nitrogen Oxides, and parti-
c'-lates from the irore^sed burr.ir-s; of co&l? The problem of increased
acid r-irfnll in *'"« Houston .-..rea from thr- burn!1"? of coal.
77
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?.) What are the health effects of small particle, particulate,
ar.d aerosols and the control strategies and monitoring capabilities
for abating these pollutants? The problems of increased Sulfites
should be examined since there will be increased coal burning.
9.) Additional monitoring studies in undeveloped areas of the
Houston Region to determine how much the ambient lex'els of air pol-
lutsr.ts increase (is there significant deterioration) after residen-
tial development occurs.
To: Gary K. Tsnnahill
?.?dian Corporation
°500 Shoal"Creek Blvd.
Austin, Texas ?8?66
From: Brandt !''annchen
ii05; South Braesvood # 303
Houston, Texas 77025
78
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Marrack, D., M.D.
79
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420 Kulberry Lane
Belial re,Texas 77401
October ,1978
Radian Corporation
5500 Shotl Creek Blvd.
P.O.Box 9948
Austin, Texas 78766
Dear Sir:
COMMENTS ON POSSIBLE AREAS OP RESEARCH IK THE HOUSTON AREA
ON AIR POLLUTION
1) Give additional support to the U. of T. M.D.Anderson Hospital and
Tumor Institute - Epidemiology Departrasnt's studies on cancer distri-
bution in H-GAC Area and adjacent areas as needed for effective objec-
tivity.
2) Establish a grid of not less than 20 low-level-concentretion Helogen-
ated (especially chlorinated) Hydrocarbon, Polycyclic Matter (POM & BaP)
air pollution detectors about the ship channel industries and on the
N.Y*. - S.E. extensions of this area. These detectors to operate 24 hrs.
a day 365 days/yr. on a. continuous basis or on repeated sampling at not
less than 10 min. period samples.
3) Extend through using larger samples of population and in conjunction
v;ith concurrent 24 hour Air sampling
a) Particulates less than 1 diameter and those greater than 1.0
and up to 100 diameter particles size
b) NOX , SOX
c) Ozone. PAM, etc.
01 res-Dimtory illnesses in adults and school children in the manner
done by Dr. Dan Jenkins, Dept. Pulmonary Disease, Baylor College of
L'.edicine, Houston.
4) Establish an atmospheric chemistry research program for the Air of
the Gulf Coast industrial area to determine the dynamics of air poll-
ution chemistry by day and night for the area, the products produced;
80
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Radian Corp.
their half lives and their respiratory and other biological effects.
5) Determine the quantities of Asbestos and fiberglass particles less
than 1 dianeter in the Houston air fc«y sampling programs.
6) Establish and operate on a 24 hr. basis mobile air sampling systems
tc track air pollutant releases from ship channel and other ulant
excursions, malfunctions end start up and shut down operations.
Thank you for the opportunity of participating in your hearing
and for the inclusion of this in your report.
Yours sincere ly, •>
'
D. Marrack,lI.D.
81
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McKee, Herbert C.
Assistant Health Director
for Pollution Control
City of Houston
82
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~ff
HOUSTON
JIM McCONN, MAYOR
HOUSTON, TEXAS 77001
October 9, 1978
CITY COUNCILMEN
LARRY MCKASKLE
JUDSON ROBINSON, JR.
Louis MACEY
HOMER I_ FORD
FRANK O. MANCUSO
JIM WESTMORELAND
FRANK E. MANN
JOHNNY GOYEN
CONTROLLER
KATHRYN J. WHITMIRE
Mr. Gary Tannahill
Program Manager
Radian Corporation
P. 0. Box 9948
Austin, Texas 78766
Dear Qary:
OCT12J978
At your public meeting on October 3 to aid in planning for
the Houston Air Pollution Study, you mentioned that you would
like to have information from the City of Houston documenting
our reservations about the oxidant standard and control require-
ments to achieve that standard. In a brief period of time, the
only thing we can do is send copies of various documents that
were prepared for previous hearings and other purposes. Many of
these were not intended to be scientific reviews, so they may be
of only limited use to you.
The following items are included:
+r
I. "Petition for Review and Revision of Ambient Air Quality
Standard for Photochemical Oxidants and Requirements for
Control" submitted to Environmental Protection Agency by
City of Houston July 11, 1977.
2. Letter of November 2, 1977 to Dr. J. H. B. Garner of EPA
from Albert G. Randall, M.D., Director of Public Health,
Subject: External Review Draft No. 1, Air Quality Cri-
teria for Photochemical Oxidants and Oxidant Precursors.
3. Letter of November 22, 1977 to Dr. J. H. B. Garner of
EPA from Herbert C. McKee, Ph.D., of the City of Houston
Health Department, commenting on the subject of natural
organic constituents and their action as oxidant pre-
cursors in response to questions raised by Dr. Basil
Dimitriades of EPA.
83
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Mr. Gary Tannahill October 9. 1978
4. Letter of January 27, 1978 to Mr. Joseph Padgett of EPA
from Herbert C. McKee, Ph.D., City of Houston Health
Department, enclosing the following:
A. Comments on proposed revision of Oxidant Standard
presented by Herbert C. McKee, Ph.D., City of
Houston Health Department, at Environmental Pro-
tection Agency public meeting, January 30, 1978.
B. R. K. Severs, Ph.D., "A Critique: A Method for
Assessing the Health Risks Associated with Alter-
native Air Quality Standards for Photochemical
Oxidants."
5. Letter of February 21, 1978 to Dr. J. H. B. Garner of
EPA from Herbert C. McKee, Ph.D., City of Houston Health
Department, Subject: External Review Draft No. 2,
Air Quality Criteria for Ozone and Other Photochemical
Oxidants.
6. Herbert C. McKee. "Testimony at Public Hearing Regard-
ing Air Quality Standard Nonattainment Designations."
Public Hearing, Texas House of Representatives, Select
Committee on Offset Emissions Standards, Corpus Christi,
Texas. April 26, 1978.
7. Herbert C. McKee. "Comments on Revision of Photochemical
Oxidant Standard." Public Hearing, Environmental Protec-
tion Agency, Dallas, Texas. August 22, 1978
8. Herbert C. McKee. "Testimony at Public Hearing Regarding
Auto Emission Control and Emission Offset Requirements."
Public Hearing, Texas House of Representatives, Select
Committee on Offset Emissions Standards, Houston, Texas.
October 4, 1978.
There is a lot of duplication between these various documents,
and I am sorry that we don't have time to edit them so that you
84
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Mr. Gary Tannahill
October 9, 1978
could avoid reading so much repetitive material. Except for that,
I think these documents summarize the problems we see in controlling
photochemical oxidant, and the problems that present and future
research should examine. I hope this information will be useful.
Best regards.
Very truly yours,
Herbert C. McKee, Ph.D.
Assistant Health Director
for Pollution Control
HCM/ah
Encls.
APPROVED:
Watson, M.D. , M.P.H.
tor of Public Health
85
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Pier, Dr. Stanley M.,
Chairman
Gulf Coast Air Pollution Research Committee and
also Associate Professor of Environmental Health,
School of Public Health, University of Texas
Health Science Center at Houston
86
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Statement of Dr. Stanley M. Pier, Associate Professor of
Environmental Health, School of Public Health, The University
of Texas Health Science Center at Houston and Chairman, Gulf
Coast Air Pollution Research Committee.
I am most pleased to have the opportunity of appearing
before you to present my views relative to the air pollution
situation along the Texas Gulf Coast. You are aware of the
fact that in response to the 1977 Clean Air Act Amendments,
there was established the Gulf Coast Air Pollution Research
Committee, of which I serve as Chairman, with the charge of
providing the Environmental Protection Agency with "local
inputs." All that I say here today has already been communicated
to EPA in one form or another, but repetition will not be harm-
ful.
The research program which brings Radian to Houston to-
day is one concerning which my committee had involvement during
the formative stages of the Request for Proposal. We urge
EPA - successfully - to undertake the study as a needs assess-
ment in the fullest sense of the phrase: a study of the nature,
source and effects of the atmospheric stew known as Houston's
air. We strongly urge that the effort be pursued with a fully
open mind, without preconceived notions or constraints, so
that the problem can indeed be defined, leading to productive
research germane to the problem. Radian's work is especially
important because it should constitute the basis and framework
for further extensive and costly research which holds major
87
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implications for the health of our citizens as well as the
economic development of the area we call home.
Several technical problems demand your consideration.
High on the priority list is a clear definition of the
chemistry and composition of Houston's air. An especially
important matter relates to the mixture known as oxidants.
We must define the nature and concentrations of oxidizing
constituents other than ozone and oxides of nitrogen. This
must be done to ascertain whether or not Houston has a pro-
blem similar to that studied in Los Angeles. A major corollary
question is whether the Los Angeles control strategy is appli-
cable to the Houston situation, an answer that can be given
only on the basis of comprehensive analysis. You are certainly
familiar with the fact, that EPA has recently changed the
standard from oxidant to ozone, an administrative determination
that may not be appropriate to the facts of the situation.
The fact is inescapable that although Houston achieves ozone/
oxidant levels comparable to those experienced in Los Angeles,
the effects are not comparable, suggesting at least a possi-
bility that we are dealing with different problems.
The need for a comprehensive study of the chemistry of
the Gulf Coast air pollution problem is emphasized by the
dramatic discovery by the Texas Air Control Board research
staff of a possible role for singlet oxygen in oxidant forma-
tion. If these results are borne out, it is not impossible
that the entire control strategy will be shown to be seriously
flawed.
88
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A related question concerns the analytical measurement
of ozone/oxidants. We have shown that measuring the Houston
air by the method employed during the development of the
oxidant standard and that presently utilized for enforcement
at times gives results which are neither equivalent, nor
correlatable. These findings ought not be dismissed as
"operator error." We need a confirmatory study to establish
exactly what we are measuring, and how these measurements
related to the health effects which have been postulated or
observed.
Another concern relating to ozone/oxidants deals with
the origin of these pollutants in our air and the contribution
of uncontrollable natural background levels of precursor
contaminants. There is disagreement as to how much contri-
bution is made by the coniferous and other vegetation not
very far from the Houston area. A comprehensive look should
be taken at this question so that a final determination can be
made as to precisely what improvement in air quality may be
expected from the far-reaching, costly and potentially dis-
ruptive controls proposed.
The properties of Houston's air as they relate to the
health of our citizens should be the paramount concern. Thus,
the greatest attention should be paid to recommending the health
studies most likely to provide answers relating to what controls
are needed and what controls are unnecessary. These studies
proposed to date by EPA are of limited scope and utility.
89
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The study of chronic obstructive pulmonary disease patients
reads suspiciously like the CHESS study. Independent researchers,
the U.S. Congress Committee on Science and Technology and the
General Accounting Office have levelled very serious criticism
at the technical aspects of the CHESS study, and it is imper-
ative that the mistakes of that very expensive and nonproductive
program not be repeated. The question must also be posed as
to whether the study of high school athletes will provide any
useful information when one takes account of the differences
between Houston and Los Angeles where the original study was
conducted.
Inasmuch as the Radian study is charged to assess research
needs in terms of both present and future air pollution pro-
blems, I would draw your attention to a potential problem
that has not affected the Gulf Coast in the past to any signi-
ficant degree. I refer to sulfur oxides pollution. Like the
rest of the country, we will be called upon to increase our
use of higher sulfur fuels for industrial and power generation
purposes. This will add increments of sulfur oxides to our
community air from a baseline that is essentially negligible.
While the health effects of sulfur oxides have been studied
extensively - though firm conclusions still elude us - the
combination of sulfur oxides, heat and humidity, which will
characterize the Gulf Coast situation, has not been investigated.
This should be done before significant amounts of sulfur oxides
are allowed to intrude into our air.
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In your letter soliciting statements, you indicated
that the identification of local resources which might be
brought to bear on the problem was a key component of your
study. I shall again mention the Gulf Coast Air Pollution
Research Committee. This committee is composed of people who
have much to contribute to studying and solving the problem.
I wish to advise you, as we have advised EPA, that this
committee is not being used to anything approaching the extent-
possible, and this will work to the detriment of the overall
program. I urge you to assure that this valuable resource is
employed.
In addition to the committee to which I have referred,
I would draw your attention to the School of Public Health,
where there is a tradition of research in air pollution dating
back to the very beginning of the institution. We stand ready
to assist beyond what we have already done in making facilities
available to EPA and providing them with the results of our
research, which we trust will receive a considered and
respectful hearing.
In sum, I feel that the Radian study potentially has
extreme importance. The value and utility of the study
result will be determined primarily by how thoroughly and
openly the task is approached and pursued. The study should
stress investigation rather than advocacy, because only in
such a spirit can a true "needs assessment" be accomplished.
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Shelton, Nancy (for Dr. Joe W. Pyle, Director of
Physical Planning and Development)
Houston - Galveston Area Council
92
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STATEMENT PRESENTED AT PUBLIC HEARING
OCTOBER 3-4, 1978
HOLIDAY INN MEDICAL CENTER
Conducted by
THE RADIAN CORPORATION
Austin, Texas
On behalf of the elected officials that constitute the
leadership of the Houston-Galveston Area Council, I am pleased
to make this statement today. I am Nancy Shelton, transportation
planner for the H-GAC and I am making this statement for Dr. Joe
W. Pyle, Director of Physical Planning and Development, who
could not be here today.
The Houston-Galveston Area Council is the local planning
agency and the council of governments charged with the respon-
sibility of developing specific plans for the 13-county area
around the Houston and Galveston population centers. This area,
known as the Gulf Coast State Planning Region, has a population
approaching three million people and approximately 12% thousand
square miles. The work program undertaken by the Area Council
is under constant scrutiny by the local elected officials and
significant outputs require their approval prior to official
acceptance.
On May 19, 1978, the Texas Air Control Board approved a
resolution designating the Houston-Galveston Area Council, func-
tioning as the Metropolitan Planning Organization for multi-modal
transportation planning in the Gulf Coast State Planning Region,
to develop local responses to comply with the Clean Air Act
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Amendments of 1977. Section 174 of this act specifically states
that local organizations composed of elected officials should
be involved in the planning process necessary to reduce the
effects of pollution. Subsequent to the Texas Air Control Board
resolution, Governor Briscoe officially designated the H-GAC to
perform this service for the region in his letter of July 24,
1978, to the Administrator of EPA. The Area Council is now
developing a work program consistent with Federal and State regu-
lations that will assist the Texas Air Control Board in the prep-
aration of revisions to the State Implementation Plan.
By agreement with the Texas Air Control Board, the H-GAC
has two specific functions that will augment the TACB's effort in
the preparation of the revisions to the State Implementation Plan
that must be forwarded to the Environmental Protection Agency by
January 1, 1979. These two areas are (1) Section 121 of the Fed-
eral Clean Air Act, Consultation, which addresses the information
flow to the local governments of the region, and (2) Section 174,
Planning Procedures, which specifies that local organizations of
elected officials should be identified in those areas of non-
attainment for carbon monoxide or photo chemical oxidants to par-
ticipate in the process. The H-GAC agreement specifically identi-
fies the responsibility for the evaluation of transportation
control measures necessary to address mobile sources.
The success of the air quality problem is highly contingent
upon excellent coordination and a sincere level of cooperation
among those entities that are involved in the local area. It is
to this end that I wish to make my official statement today. If
94
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the Radian Corporation, or anyone else, proposes to undertake a
significant study of air pollution sources and consequences in
the Houston area, it is essential that the highest level of coordi-
nation be undertaken with other organizations that have a mutual
interest. Therefore, I request that the Houston-Galveston Area
Council be advised, consulted and involved in all aspects of this
study that have a direct bearing on the work program of the Area
Council.
An example of mutual interest is the emissions inventory
update in the work program proposed by Radian. A similar respon-
sibility is the charge of the Area Council in response to the
agreement with the Texas Air Control Board. It is only logical
that any emissions inventory resident within the state offices,
the local agencies, or to be developed in any research activity,
be consistent and shared. All federal agencies support the com-
monality of data bases developed on public funding. It would be
inconsistent with federal policy and, in fact, unconscionable to
have separate efforts simultaneously underway in the Houston area
without coordination.
Another area of mutual interest is the process of computer
modelling and simulation to augment actual data. This area has
not been fully developed locally; the mobile source aspect is an
integral part of the overall problem and should involve the exper-
tise of transportation planners that are currently involved in the
planning process at H-GAC.
To summarize the position of the Area Council, it will be
in the best interest of the citizens and the local governments
95
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in the Houston-Galveston area, if local resources are utilized to
the fullest extent. Therefore, the expertise and involvement of
the Area Council will improve the acceptability of the research
undertaken by the Environmental Protection Agency. Only with
the participation of the local elected officials can the results
be useful and disseminated optimally. We look forward to cooperat-
ing in every way possible with the Environmental Protection Agency
to the successful conclusion of the research project.
96
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Smith, Francis V.
97
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302 Southchester Lane
Houston, Texas, 77079
October 6, 1978
Mr. Gary Tannahill
Radian Corporation
8500 Shoal Creek Blvd.
Austin, Tx., 78766
Dear Mr. Tannahill:
Having been an attendee at your October 3rd program at
the Holiday Inn in Houston, I have a few comments and questions
which came to mind after the presentations and discussions.
Although I am a member or officer of several different environ-
mental groups, I am writing solely as a private citizen, and
not as a spokeman for any of them.
I am concerned that not enough emphasis was placed on long
term chronic effects studies. I realize that these are difficult,
expensive and time consuming. But they have been done in other
parts of the country, and if such a long term study were to be
done here, it might help explain the higher than average mortality
rates in Houston for some types of cancer, and respiratory diseases.
While current funding does not permit such a long term study, a
statement that such a study should be done with proper funding,
could be included in your research plan. Do I presume correctly
that the two health effects studies ( mentioned in the EPA
newsletter) are two of several more to be contracted for in the
future?
As sulfur oxides may well become a problem on the Gulf Coast
with fuel conversion, S02 and sulfate studies seem to be contemplated.
Are you also going to include consideration of sulfites, which also
seem to be a health hazard?
In general I concur in the opinion that the air over greater
Houston should be characterized and studied, with the emphasis
being placed on the possible health effects on the persons breathing it.
I hope you will have further meetings such as this one
as your work progresses, because further updates and discussions
could be very helpful and informative - hopefully for you
as well as for those of us who live in the area.
Sincerely,
OCT
Frances V. Smith
98
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Spaw, Steve, P. E., Deputy Director
Stewart, Bill, p. £., Executive Director
Texas Air Control Board
99
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TEXAS AIR CONT]
8520 SHOAL CREEK BOULEVARD
AUSTIN, TEXAS 78758
"512/451-5711
JOHN L.BLAIR !1==~L WILLIAM N. ALLAN
Chairman ydS^lX, JOE C. BRIDGEFARMER.P. E.
CHARLES R.JAYNES m&^&*\ FRED HARTMAN
Vice Chairman f (OK&SfcV\ D- JACK Kl LlAN-M" D"
^^L^M/Fl FRANK H. LEWIS
BILL STEWART, P. E. \>|W^/ WILLIAM D. PARISH
Executive Director ^^+^r JEROME W. SORENSON, P. E.
October 2, 1978
Radian Corporation
8500 Shoal Creek Boulevard
Austin, Texas 78756
Attention: Mr. Gary K. Tannahill
Dear Mr. Tannahill;
Enclosed are our comments for your consideration in devel
oping a plan for an air pollution study program in the
Texas Gulf Coast area.
We appreciate the opportunity to offer these comments.
If we can be of further assistance, please let me know.
Bi'll^Stewart, P.E'.1
Executive Director
Enclosure
100
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STATEMENT BY
STEVE SPAW, P,E,, DEPUTY DIRECTOR
TEXAS AIR CONTROL BOARD
AT
PUBLIC MEETING
TO RECEIVE COMMENTS ON THE OBJECTIVES
OF A PLAN FOR AN EPA AIR POLLUTION STUDY PROGRAM
IN THE TEXAS GULF COAST AREA
ON
OCTOBER 3, 1978
IN
HOUSTON, TEXAS
101
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As A CONTROL AGENCY, THE TEXAS AlR CONTROL BOARD (TACB)
NEEDS TO KNOW WHAT BAD EFFECTS AIR POLLUTION IS HAVING
AND WHAT FURTHER EMISSION CONTROLS ARE NEEDED TO PREVENT
THOSE EFFECTS, OBTAINING THIS INFORMATION REQUIRES A
THOROUGH KNOWLEDGE OF THE RELATIONSHIPS BETWEEN LOCAL
EMISSIONS AND RESULTING AIR CONTAMINANTS AND BETWEEN
THE CONTAMINANTS AND EFFECTS, SlNCE WE ARE A CONTROL
AND NOT A RESEARCH AGENCY, WE ARE LARGELY DEPENDENT ON
THE EFFORTS OF OTHERS TO PRODUCE THAT INFORMATION,
FOR THIS REASON, WE ARE ESPECIALLY PLEASED THAT THE TEXAS
GULF COAST AIR POLLUTION RESEARCH PROJECT rs UNDERWAY,
THE EFFORTS OF OUR TEXAS CONGRESSMEN WHOSE WORK LED TO
THE AUTHORIZATION AND FUNDING OF THIS PROJECT DESERVE
SPECIAL MENTION, WE HAVE HIGH HOPES FOR THIS EFFORT AND
STRONGLY RECOMMEND THAT THIS TYPE OF AIR POLLUTION RE-
SEARCH EFFORT CONTINUE IN THE FUTURE BEYOND THE THREE
YEAR PERIOD FOR WHICH YOU ARE PREPARING THE RESEARCH PLAN,
EPA DESERVES PRAISE FOR BEGINNING THE TEXAS GULF COAST
AIR POLLUTION RESEARCH PROGRAM WITH A NEEDS ASSESSMENT
PROJECT AND DEVELOPMENT OF A COMPREHENSIVE RESEARCH PLAN,
ONE OF THE REQUIREMENTS FOR THIS NEEDS ASSESSMENT PROJECT
YOU ARE WORKING ON IS SO IMPORTANT THAT IT DESERVES
SPECIFIC MENTION, IT IS THE REQUIREMENT TO ANALYZE EACH
PROPOSED PART OF THE RESEARCH EFFORT THOROUGHLY TO DETER-
MINE WHETHER IT IS WORKABLE AND LIKELY TO PRODUCE DEFINI-
TIVE RESULTS, EACH PART OF THE PLAN MUST FIT TOGETHER
WITH THE OTHER PROJECTS IN THE PLAN TO PRODUCE THE MOST
USEFUL INFORMATION POSSIBLE, WE ARE PLEASED THAT THESE
SPECIFICATIONS HAVE BEEN WRITTEN INTO THE CONTRACT FOR
PREPARING THE RESEARCH NEEDS ASSESSMENT AND PLAN,
102
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WE AGREE WITH THE INDICATION IN SECTION E OF THE "SCOPE
OF WORK" THAT THE MOST IMPORTANT FOCUS OF THIS STUDY OF
AIR POLLUTION IN THE TEXAS GULF COAST AREA SHOULD BE
HUMAN HEALTH EFFECTS, WE ARE ALL AWARE THAT THE AIR IN
THIS AREA SOMETIMES STINKS AND IS HAZY, HOWEVER, WE DO
NOT YET KNOW WHETHER THE POLLUTION WE CAN OBSERVE WITH
OUR SENSES CAUSES ANY SIGNIFICANT HEALTH EFFECTS, WE
ARE NO MORE CERTAIN ABOUT THE H€ALTH EFFECTS OF OZONE OR
OF THE ORGANIC CHEMICALS THAT WE CAN DETECT ONLY WITH
INSTRUMENTS,
WE ARE, THEREFORE, CONCERNED THAT THE HEALTH EFFECTS
STUDIED BE MORE COMPREHENSIVELY DEFINED THAN IN MOST PAST
EFFORTS TO RELATE HEALTH EFFECTS TO AIR POLLUTION, THE
RANGE OF HEALTH EFFECTS CONSIDERED SHOULD INCLUDE CHRONIC
EFFECTS SUCH AS EMPHYSEMA, WE NEED TO KNOW WHETHER CON-
TAMINANTS IN OUR AIR CONTRIBUTE TO THE RISKS OF MUTATION
AND OF CANCER, ADDITIONALLY, IT IS NOT ENOUGH TO KNOW
WHETHER AIR POLLUTION IN THIS AREA AGGRAVATES SYMPTOMS IN
PATIENTS ALREADY SUFFERING FROM CHRONIC RESPIRATORY
DISEASE; WE NEED ALSO TO KNOW WHETHER THIS AIR POLLUTION
CAUSES OR ACCELERATES THE DEVELOPMENT OF SUCH HEALTH
PROBLEMS, IF THE CAREFUL SCREENING OF THE RESEARCH TOOLS
AVAILABLE INDICATES THAT THEY ARE INADEQUATE TO LOOK AT
THE RELATION OF EACH OF THESE EFFECTS TO AIR POLLUTION,,
THAT FACT SHOULD BE DOCUMENTED IN THE STUDY PLAN YOU ARE
PREPARING, IT .IS OUR HOPE THAT THE TEXAS GULF COAST
STUDY PLAN WILL COMPLIMENT PAST AND PRESENT EFFORTS OF
THE TEXAS AIR CONTROL BOARD AND OF OTHERS,
WE ARE CONTINUING AND REFINING OUR REVIEW OF TOXIC AND
SUSPECT COMPOUNDS THAT ARE EMITTED BY INDUSTRIAL FACILI-
TIES IN TEXAS, A PART OF THIS WORK INVOLVES REFINING
OUR EMISSIONS INVENTORY SO THAT IT WILL PROVIDE THE INPUT
103
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FOR MATHEMATICAL MODELING OF EMISSIONS, THIS CAPABILITY
WILL BE USED TO CALCULATE PUBLIC EXPOSURE TO EACH COM-
POUND UNDER REVIEW, MONITORING FOR SPECIFIC COMPOUNDS
AND EMISSIONS INVENTORY EFFORTS AS PART OF THE TEXAS GULF
COAST PROJECT COULD SUPPLEMENT AND VERIFY THE RESULTS OF
OUR INVENTORY AND MATHEMATICAL MODELING PROJECT, OUR
EMISSIONS DATA"/ AS WELL AS AIR QUALITY AND PERMITS DATA,
ARE, OF COURSE, AVAILABLE FOR YOUR USE,
I HAVE PROVIDED YOU WITH COPIES OF A REPORT ENTITLED
"TEXAS RESEARCH NEEDS IN AIR POLLUTION CONTROL", THIS
REPORT WAS PUBLISHED IN 1977 AND LISTS OVER 150 RESEARCH
PROJECTS WE RECOMMENDED FOR TEXAS, WHILE THE SCOPE OF
OUR RESEARCH NEEDS LIST WAS SOMEWHAT BROADER THAN THE
PROJECT YOU ARE NOW WORKING ON, MANY OF THE SUGGESTIONS
DISCUSSED IN THE LIST ARE RELEVANT TO THIS PROJECT AND
SHOULD BE CONSIDERED, HOWEVER, THEY SHOULD BE SUBJECTED
TO THE SAME CRITICAL REVIEW AS ALL OTHER PROPOSALS CON-
SIDERED IN THE NEEDS ASSESSMENT PROJECT YOU ARE BEGINNING,
IN CONCLUSION, I WANT TO REITERATE OUR PLEASURE IN SEEING
THIS PROJECT FINALLY TAKING PLACE, IT REPRESENTS THE
CULMINATION OF LONG AND ARDUOUS EFFORTS BY MANY PEOPLE
WHO RECOGNIZE THE PROBLEMS OF THIS AREA AS BEING SOMEWHAT
UNIQUE AND DESERVING OF SPECIAL STUDY, IT IS OUR SINCERE
HOPE THAT EXPERIMENTS CAN BE DEVISED TO ANSWER MANY OLD
AND PERPLEXING PROBLEMS, AS WELL AS ADDRESSING NEW AREAS
OF CONCERN, AGAIN, I CAN ASSURE YOU OF THE ASSISTANCE
AND COOPERATION OF THE AlR CONTROL BOARD IN PROVIDING
WHATEVER INFORMATION AND DATA WE HAVE THAT MAY BE HELPFUL
IN DEVELOPING THE STUDY PLAN YOU ARE PREPARING,
THANK YOU FOR THE OPPORTUNITY TO PARTICIPATE IN THIS MEET-
ING, IF THERE ARE ANY QUESTIONS, I WILL BE GLAD TO TRY
TO ANSWER THEM,
104
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Tarr, Jim
Toxcon Engineering Company, Houston
105
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THE REASONS UHY HOUSTON'S
AIR ISN'T CLEAN
A Report for the Environmental Protection
Agency and the Texas Air Control Board
October 1, 1978
TOXCON ENGINEERING COMPANY
Houston, Texas
106
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THE REASONS WHY HOUSTON'S
AIR ISN'T CLEAN
The discussion which follows is an effort to clarify the air pollution
abatement process. In Texas, air pollution abatement is achieved by
developing, implementing, and enforcing regulations which limit atmos-
pheric emissions. It follows then that this paper is primarily a dis-
cussion of the way in which air pollution regulations are developed.
The responsibilities of the state and federal governments in this
process will be indicated. Constraints which inhibit the development
of technically sound air pollution regulations will be identified.
Some simple suggestions about how the process might be improved will
be listed.
The thesis of what is written here is simple. Houston's air pollution
problems haven't been solved because the basic, fundamental tools
required to understand them properly haven't been developed. In short,
that which is emitted into the atmosphere is largely undefined. How it
acts when it gets there is also not understood.
As mandated by Sections 109 and 110 of the federal Clean Air Act, the
development of air pollution regulations is a two step process. The
first step, a federal responsibility, requires the establishment of
primary ambient air quality standards for so-called criteria pollutants.*
Intended to protect public health with "an adequate margin of safety",
the primary ambient air quality standards define a maximum acceptable
concentration of pollutants in the air that the public breathes. Primary
ambient air quality standards have been established for carbon monoxide,
hydrocarbons, oxides of nitrogen, particulate matter, photochemical
oxidants, and sulfur dioxide.
The second step involves the development of implementation plans by
state governments. An implementation plan is simply a description of
the specific means to be utilized by a state to reduce air emissions
from sources such that ambient air concentrations are maintained within
the limits set by the primary standards. Stated another way, the
Environmental Protection Agency (EPA) defines acceptable ambient air
concentrations, and the Texas Air Control Board (TACB) limits emissions
from fixed and mobile sources to achieve those concentrations.
*Secondary ambient air quality standards, requisite to protect public
welfare, have also been mandated for the criteria pollutants. In the
interests of brevity, the secondary standards will not be discussed.
107
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At first glance, the problem of designing a regulation to limit
emissons into the atmosphere to achieve a well defined concentration
appears elementary. Consider the simplest case of a single stack
emitting particulate matter into the atmosphere. Imagine a box of
known dimensions situated in such a way that all particulate matter
which leaves the stack is captured in the box. Now, utilizing a simple
mathematical procedure, the concentration of particular matter in the
box can be calculated at any time if the flowrate of particulate matter
from the stack is known. Furthermore, by adjusting the flow of par-
ticulate matter from the stack, the concentration in the box can be
maintained at any desired value.
In actual practice, the process of developing an air pollution regula-
tion is quite complex. Consider the problem of limiting emissions into
the atmosphere such that the primary ambient air quality standard for
photochemical oxidants is achieved. Thinking in terms of the one
stack-one box example, the regulation development process involves
relating stack emissions (pounds per hour) to atmospheric concentra-
tion (parts per million) through an appropriate mathematical manipulation
(or model). Given an acceptable concentration of photochemical oxidants,
the difficulties can be grouped into three categories of constraints.
Those categories are natural constraints, mathematical constraints, and
socio-economic constraints.
Natural constraints that inhibit the development of effective regula-
tions include the effect of weather, the effect of atmospheric inter-
actions, and the difficulty of "dimensioning the box". Weather has a
tremendous effect on the concentration of pollutants in the atmosphere.
As wind speed and atmospheric turbulence increase, the concentration of
pollution downwind of the source of air emissions will decrease. A
change in wind direction will radically change the concentration of
pollution seen by an observer if the new wind blows from source to
observer instead of from observer to source. Predicting the precise
effect of weather changes on the ambient air concentration of pollutants
is an art, not a science.
Another natural constraint includes the effect of atmospheric inter-
actions. Photochemical oxidants are a family of chemical compounds that
result from a series of complex reactions that occur in the atmosphere.
The necessary constituents for the formation of photochemical oxidants
are hydrocarbons, oxides of nitrogen, and sunlight. The exact way in
which these three constituents interact to form photochemical oxidants
is not known. Furthermore, depending upon which particular hydrocarbons
are involved in the reaction mixture, reaction pathways and products may
vary considerably.
108
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As photochemical oxidants can be added to the atmosphere by chemical
reaction, they may also be removed by processes of absorption and
adsorption. Water soluble photochemica1 oxidants can be absorbed into
solution when contacted by small water droplets that exist in the
atmosphere in the form of fog or clouds or both. Other photochemical
oxidants may be physically attached (or adsorbed) on the surface of par-
ticulate matter present in the atmosphere from a variety of sources.
The net result is that photochemical oxidants appear and disappear in
the atmosphere in ways little understood and at rates that are
generally unknown.
The difficulty of "dimensioning the box" is also considerable. To con-
trol the concentration of any material in the atmsophere, it is necessary
to define a three dimensional space of known dimensions. As no portion
of the atmosphere can be realistically considered a closed space, the
choice of appropriate dimensions becomes difficult. Should a "box" cover
the limits of a city, a county, several counties, or even a state?
Once an area is chosen, should the depth be hundreds of feet, thousands
of feet, or miles? These questions have not been appropriately answered
to date.
Another group of difficulties are the mathematical constraints. The
mathematical constraint most easily dealt with involves a compilation of
atmospheric emissions known as an emission inventory. Considering the
photochemical oxidant problem again, the emissions that must be compiled
include hydrocarbons and oxides of nitrogen. The existing emission inven-
tories for both of these pollutants are inadequate, but the following
observations will focus only upon hydrocarbons.
The emission inventory for hydrocarbons is both incomplete and inaccurate.
For the most part, only hydrocarbon emissions from discrete point sources
in industrial facilities are compiled. Hydrocarbon emissions from sources
other than stacks are generally not compiled. The vast majority of so-
called fugitive emissions from industrial facilities are disregarded.
Likewise, hydrocarbon emissions from mobile sources such as cars, buses,
trucks, and ships are not routinely inventoried. With regard to accuracy,
most existing information related to hydrocarbon emissions from point
sources is based on estimates instead of actual measurements. The
estimates that are made vary from crude to sound and sophisticated.
Taken as a whole, the existing emission inventory for hydrocarbons
is suspect. It also happens to be nearly three years old. An accurate
emission inventory for hydrocarbons emitted into the atmosphere over
Houston has never been compiled.
The mathematical model used to relate emissions and atmospheric concen-
trations is another problem. With regard to photochemical oxidants,
an appropriate model must somehow relate the emissions of hydrocarbons
and oxides of nitrogen from tens of thousands of sources to an atmospheric
concentration of a group of reaction products that arise by an undefined
mechanism while accurately accounting for space, time, and weather. That
109
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task is clearly beyond existing capability. Lacking an appropriate
model, an approximation has been substituted. The model most recently
employed is called the proportional rollback model. This model simplis-
tically assumes that if hydrocarbon emissions are reduced fifty percent,
then photochemical oxidant concentrations in the atmosphere will be re-
duced fifty percent. A twenty-five percent emission reduction will cause
a twenty-five percent reduction in atmospheric concentration, etc. Events
in the Houston area have clearly shown that the proportional rollback
model is not appropriate.
In light of the failure of the proportional rollback model to adequately
relate hydrocarbon emissions and atmospheric ozone concentrations, it has
been abandoned. Implementation plan development will now be based on a
"kinetic" model. This new modeling approach can accurately be described
as a modest revision of the proportional rollback model. It is a
simplistic, empirical attempt to describe a complex, inadequately under-
stood phenomena. In all probability, it will also fail.
Confounding the mathematical constraints mentioned above are two other
factors which deserve mention. One of these factors involves the routine
monitoring of ambient air quality. The other factor concerns attempts
to conceptually compare estimated emission rates with measured ambient
air quality.
As explained above, the EPA has developed a primary ambient air quality
standard for photochemical oxidants. Ozone is one of the photochemical
oxidants. There are an unknown number of other photochemical oxidants
formed in the atmosphere. In this area, ozone is the only photochemical
oxidant that is routinely monitored. In effect, the presence of all
other photochemical oxidants is ignored.
A second cause of confusion involves attempts to relate reported emission
reductions to ambient air quality. The claim is often made that local
hydrocarbon emissions have been reduced dramatically without a correspond-
ing decrease in the measured ambient air concentration of ozone. State-
ments to this effect represent a classic example of attempting to equate
apples and oranges. Inventories of hydrocarbon emissions from industrial
facilities have been compiled. These numbers are normally estimates, not
measured values. Typically, they are derived by the use of emission
factors originally developed in California oil refineries some twenty
years ago. Furthermore, The emission estimates are routinely reported
in units of tons per year. Conversely, the ambient air concentration
of ozone is measured at a number of sites in and around Houston every
five minutes. Twenty four times a day, twelve consecutive measurements
are combined to yield an hourly average ozone concentration. In a given
year then, each ozone monitoring site will report approximately 8500
separate hourly averages. Attempting to compare an annual average
hydrocarbon emission '"ate with a single hourly average ozone co^centra-
tion is statis'/cal and mathematical nonsense.
no
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The last set of constraints can be labeled socio-economic. Examples of
this kind of constraint can be observed among both those who are regulated
and those who regulate. Owners and operators of most sources of air
emissions will not readily accede to make the commitment necessary to
reduce those emissions. The most popular example is the automobile.
It has been suggested that one effective way of reducing air emissions
from automobiles is to limit vehicle miles traveled through gasoline
rationing and other means. That suggestion was greeted with a resounding
no thank you by the general public. Industrial operators are also some-
what reluctant to reduce air emissions, particularly when the costs involved
are high. In certain situations plant operators may obtain exemptions
that allow significant quantities of hydrocarbon emissions from point
sources. This is exemplified by Rule 505.232 of the TACB which allows
unabated hydrocarbon emissions of as much as 250 pounds per hour per
stack under certain circumstances.
Another important socio-economic constraint concerns the existing relation-
ship between the TACB and the EPA. Over the years the association between
these two government entities has deteriorated. Too often, the two groups
are rivals pitted against each other in an unseemly struggle for position
and prestige. The common goal of protection of the public health is
qbscured in personality conflict, bureaucratic ineptitude, and plain
hard headedness. This lack of cooperation is best illustrated by the
inability of the two agencies to agree upon a rational plan to control
hydrocarbon emissions. With regard to this problem, lawsuits and recrimina-
tion have often been substituted for cooperation and dialogue.
Clearly then, there are a number of identifiable reasons why Houston's
air isn't clean. These reasons can be grouped into three categories.
The quest for clean air is frustrated by natural constraints, mathe-
matical constraints, and socio-economic constraints.
If Houston's air pollution problems are to be solved, then at least three
critical steps must be taken. An accurate, up-to-date emission inventory
must be developed. A mathematic model that can realistically relate
atmospheric emissions and ambient air quality must be designed. Most
importantly, the government agencies responsible for overseeing air
pollution control efforts must forget their differences and work
together for the common good.
111
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ADDITIONAL REFERENCE SUBMITTED
TEXAS RESEARCH NEEDS IN AIR POLLUTION CONTROL, Texas Air Control Board,
Austin, TX, April 1977.
112
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Walker, Harry M., Ph.D.
Monsanto Chemical Intermediates Co.
113
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Monsanto
MONSANTO CHEMICAL INTERMEDIATES CO.
P. 0. Box 711
Alvin, Texas 77511
Phone: (713) 581-2161
October 12, 1978
Mr. G. K. Tannahill
Radian Corporation
8500 Shoal Creek Blvd.
Austin, Texas 78758
Subject: Technical Recommendations for the
HAPS Program
Dear Gary:
I am sending you my suggestions by letter rather than presenting them at your
October 3rd meeting for two reasons. First, I did not have them in writing at
that time. Second, as usual these days the presentations made, as long as I
stayed at the meeting, tended to be more political than technical.
I am limiting my suggestions to just three, all in the ozone/oxidants area; one
regarding health effects and the others regarding atmospheric chemistry. A
discussion of each follows.
I. HEALTH EFFECTS — Personal Oxidant Monitors
I am convinced that epidermic logical studies concerning the health effects
of ambient ozone on oxidants are going to continue to be inconclusive until
a method of accurately quantizing the exposure of each individual subject
is available. Personal monitoring devices are the answer as outlined in
the attached letter to Dr. Chapman. The technology to use personal pumps
now exists. Badges which are oxidant sensitive can probably be developed
rather readily. (See the letter for details.)
I don't believe that any more epidermiological studies for ozone or
oxidant effects should be attempted until these techniques are established.
Once they are, a number of old studies should be repeated and many new ones
can be devised with assurance that they are then more likely to yield
definite results.
I am in correspondence with Dr. Chapman on this matter and am sending him
additional information which he requested. Radian's support would help
to bring the program about.
114 OCT 1 6 1978
-------
Mr. G. K. Tannahill October 12, 1978
II. ATMOSPHERIC CHEMISTRY
A. NOX vs. NMHC - Aerometric
Despite all that has been done by many groups including HAOS, there
is no clear real-world evidence as to which pollutant, NOX or hydro-
carbons, controls photochemical ozone formation in a city such as
Houston.
Much effort has been made to establish such evidence by data analysis
of routine aerometric measurements taken at agency sites. In general,
this work has been inconclusive although general studies suggest that
NOX emissions control. This was the result of the study done by
Dr. Worley of the University of Houston for HAOS.
The problem is, to a considerable degree, analytical. In the past,
NMHC and NOX analyzers have shown both poor reliability and poor
accuracy, particularly at the low end of the scale, which is critical
to such a study.
Probably the Beckman 9800-type NMHC analyzer is inadequate for the task
and future effects will have to be based on GC analysis for hydrocarbons.
Older NOX analyzers are probably similarly unequal to the task. However,
new units can now get down to 2 pbb and should do the job.
One problem with aerometric data taken at fixed sites is that the
upwind HC/NOX pollutant ratio is going to be relatively invariant for
each site. True, this ratio will shift with wind direction but in
Houston, at least, episodic levels of ozone generally are characterized
by winds from a narrow arc centered on ENE.
Without the leverage of major shifts in HC/NOX ratio, the problem of
defining the controlling pollutant is not going to be elucidated from
the analysis of aeromatic data.
The more I think about the problem the more I am convinced that measuring
pollutant concentrations before the reaction takes place than correlating
these data with ozone concentrations taken 5 to 8 hours later is not
going to work. Six to nine a.m. pollutant concentrations vary widely
but do not represent real variations in pollutant emission rates which
are essentially invariant. Variations in the 6-9 a.m. concentrations
depend almost entirely on the micrometeorology of the site subject only
in a limited way to the general meteorology of the time and area.
Thus, 6-9 a.m. pollutant concentrations observed with zero wind and an
inversion at 200' will be much higher than those observed at 2 mph and
1000'. However, the ultimate dilution 6 hours and 25 miles downwind
with identical 4000' mixing heights could easily be the same.
The present EPA program going on in Houston seeks to avoid this problem
by monitoring precursors intensively in a "window" using both surface
115
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Mr. G. K. Tannahill October 12, 1978
A. NOX vs. NMHC - Aerometric (Continued)
and aerial monitors. If the actual flow through the window can be
defined for an adequate period, then correlations with downwind ozone
maxima could work. However, I feel that major uncertainties are still
going to remain because of inability to sample in the critical ozone
between the surface and perhaps 500', and because of major abrupt
horizontal variations in source strength across the window area.
It, therefore, appears to me that the best way to really get at
pollutant concentration is to measure then after the reaction. True,
this is also after dilution which makes it much harder and after much
has reacted away. However, if the instruments are sufficiently sensi-
tive the dilution problem can be handled.
Reaction is more complex. Using GC hydrocarbons analysis, we can track
the unreactives such as the paraffins making the assumptions that only a
limited and relatively constant amount has reacted. Thus, final HC will
be a direct function of initial HC and correlation should be preserved.
Since the amount destroyed will actually be a function of the degree of
photochemical reaction going on, a more sophisticated assumption might
be this:
HC initial ' HC final &' + f^ m»
NOX concentrations presents more of a problem because of its greater
reactivity. However, something like:
N°x initial = N°x final d- + f^°3 "«».
seems appropriate. If PAN data are taken, PAN could be added in.
Consideration of a number of factors suggests that this isn't going to
work if the reaction path is across a region with many sources. There-
fore, the correlation attempts should be confined to downwind points
in the plume areas outside the dominant source areas.
All this complicated discussion leads to a pretty simple recommended
experiment.
Field Experimental Program:
Using a mobile monitoring van equipped for ozone, NOX and hydro-
carbons via GC; sample in 4-6 hours downwind plume areas at maximum
ozone time. In practice, monitor from 12:00 p.m. to 4:00 p.m. each
day at chosen downwind points meeting the criteria discussed. The
monitoring points should be based upon 10 meter surface winds
between 6 and 12 a.m. in the general area.
The only data used would be daily 03 maximum, the HC scan and the
NOX data for the same hour. Data correlation treatment should
be as discussed.
116
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Mr. G. K. Tannahill October 12, 1978
A. NOX vs. NMHC - Aerometric (Continued)
It is most probable that correlation will be more successful under
non-episodic conditions as the initiation factors which control
episodes may be so dominant as to completely override pollutant
concentrations. Therefore, the correlations should be tried for
non-episode days alone, for episode days alone, and for all days.
A variety of cut points can be tested to separate episode and non-
episode days.
I would anticipate that the analysis might result in a good
correlation between NOX and 03 maximum for non-episode days; no corre-
lation for HC on any basis, and no correlation for NOX on episode days.
If good correlations should be obtained for hydrocarbons or for episode
days,of course, it would provide major support for the EPA position
that only concentration counts and that hydrocarbons control.
In support of this line of reasoning, I am attaching a recent paper by
Graedel which seems to present the best overall picture of the current
photochemical process that I have seen. Note that the entire paper
deals with non-episodic levels. Even Graedel excepts episodes though
perhaps not for the same reasons that I except them.
Another experimental program stemming from this line of logic
would be to mount a program for the field measurement of hydroxyl ion
concentration. This would be particularly pertinent if done in rural
areas. If it can be shown that rural hydroxyl increases after fronts,
before episodes or during episodes, it would be an important insight and
would help complete the picture spanning the gap between stratospheric
injection, fronts, 7Be and photochemical episodes.
Unfortunately, I am not sure of the state of the art of this measurement.
It may be too complex for a real field study. I hope you can look into
this.
B. NOX vs. NMHC - Experimental
Another approach to the question would be the Captive Air Program con-
sidered by HAOS. I feel that our concept of collecting real-world air
samples and running the experiment in two bags with one bag as a control
and one with conditions perturbed is basically sound. Certainly it can
answer questions concerning the effects of initial reactant concentration.
Initiation effect probably cannot be evaluated because the bags are going
to become free-radical contaminated like all smog-chambers.
You are familiar with the HAOS thinking on this program. I suggest that
this program be a part of Radian's recommendations to EPA for inclusion
in HAPS.
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Mr. G. K. Tannahill October 12, 1978
Sincerely,
Harry M. Walker, Ph.D.
HMWrfin
Attachments
cc: Dr. Basil Dimitrides
U.S. Environmental Protection Agency
Environmental Research Laboratories MD-59
Research Triangle Park, N.C. 27711
118
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Monsanto
MONSANTO CHBfllCAL INTERMEDIATES CO.
f- 0. Boi 711
Alvin, T«xn 77311
Phone (713) 581-2161
September 1, 1978
Dr. Robert Chapman
United States Environmental Protection Agency
Health Effect Research Laboratories
Environmental Research Laboratories
Research Triangle Park, NC 27711
Dear Dr. Chapman:
I attended the EPA meeting in Houston on July 26 which was for the
purpose of reviewing and discussing the EPA proposals for research to be
included in the pending Houston Air Pollution Study (RAPS).
I came prepared to offer constructive suggestions on details of the
research. However, when the political types, who had no interest whatsoever
in research, were permitted to intrude into and largely take over the meeting
it was obvious that there was no point in presenting my thoughts at that tijne.
Kith respect to ozone health effects, I believe that the most seriously
neglected facet is the question of actual human exposures vs. the official
monitored levels. Limited existing data suggests that most people, in their
daily activities, will be exposed to less (probably much less) than one-half
o£ the officially measured value reported for any areas. This is so because
of the rapid destruction of ozone on surfaces. This rapidly reduces its
concentration in enclosed areas; areas under trees, between buildings, etc.
This phenomenon does represent an important natural protection factor which
merits consideration in the standard setting process.
This factor was referred to by several speakers at the recent Dallas
hearing on the ozone standard (August 22). I am attaching a copy of my
remarks which developed the subject rather fully. I am also attaching a
copy of my follow-up letter providing supplementary information and additional
references.
Despite the studies cited which strongly support the assertion that no pne
is exposed to ozone at the monitored concentrations, I believe'that additional
quantative data is needed.
The most direct way to measure actual exposure will be with personal
monitoring devices which can be worn by the subjects.
At the moment, the only credible way to do this would be with battery-
operated personal pumps. These would sample ambient air taken via a Teflon
tube beginning near the subject's breathing zone and deliver this air to a
sampling solution. The pumps are now widely used in industrial hygiene-type
119
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Dr. Robert Chapman September 1, 1978
exposure studies. They sell for about $100 each and have entirely adequate
sample flows. Tne flowing sample would pass through midget impingers con-
taining NBKI reagent. With this technique a meaningful, though limited,
program could be mounted soon and would be worth doing.
The real potential of the program, however, will depend upon the develop-
ment of exposure badges; A great deal has been accomplished in developing
such badges in recent years and it is my opinion that units specific for
photochemical oxidants can readily be developed using a variation of the
KI technique.
I would attempt to incorporate a buffered KI reagent in a starch-containing
gel protected by a very thin film of silicone rubber. The badges would later
be read by transmission photometry at the proper wavelength for the starch-I»
complex. If the silicone film limits sensitivity too much, I would test
microporous Teflon as an alternate.
For the purposes of this type of research, I do not believe that the
differences between ozone and oxidants are significant.
With simple monitoring badges, people can be exposure-tested by the
hundreds. Various intervals of time can be used probably from 3 hours up to
several days. Naturally, numerous calibration and validation procedures would
have to be incorporated including exposure of badges right at the local
agency-monitoring manifolds.
With a large study it will become possible to classify percentage exposures
by population groups — housewives, office workers, construction workers, taxi
drivers, etc. Ultimately, the badges could be used in conjunction with a real
epidermiological study where the ozone control would be from the badge measure-
ments rather than from the local monitor. Without a doubt, a major problem
with many past epidermiological studies has been the fact that actual individual
exposures were not properly reflected by the agency monitors referenced.
Accordingly, it is recommended:
(1) That EPA include a limited program of personal pump monitoring in its
immediate program (perhaps 25 individuals, 4 hours/day, for 30 days).
(2) That EPA award contracts for the development of a Kl-based photochemical
oxidant personal exposure badge.
(3) That EPA plan an extensive badge study in the 1979 and 19§0 segments of
the HAPS program.
Sincerely,
-///Kvv-r M- iS*.'^.^.
Harry M. Walker, Ph.D.
Air Control Coordinator
HMW:fm
Attachment s
120
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APPENDIX A
CONGRESSIONAL HEARINGS
SPECIAL URBAN AIR POLLUTION PROBLEMS: DENVER AND HOUSTON
121
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SPECIAL URBAN AIR POLLUTION PROBLEMS:
DENVER AND HOUSTON
HEARINGS
BEFORE THE
SUBCOMMITTEE ON THE
ENVIRONMENT AND THE ATMOSPHERE
OF THE
COMMITTEE ON
SCIENCE AND TECHNOLOGY
U.S. HOUSE OF REPRESENTATIVES
NINETY-FIFTH CONGKESS
FIRST SESSION
NOVEMBER 19, 21, 1977
[No. 52]
Printed for the use of the
Committee on Science and Technology
U.S. GOVERNMENT PRINTING OFFICE
34-742 O WASHINGTON : 1978
122
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COMMITTEE ON SCIENCE AND TECHNOLOGY
OLIN E. TEAGUE, Texas, Chairman
DON FCQUA, Florida
WALTER FLOWERS, Alabama
ROBERT A. UOE, New Jersey
MIKE McCORMACK, Washington
GEOKGK E. BROWN, JR., California
DALE MILFORD, Texas
RAY THORNTON, Arkansas
JAMES FI. SCHEUER. New York
RICHARD L. OTTINGER, New York
TOM HARKIN, Iowa
JIM LLOYD, California
JEROME A. AilBRO, New York
ROBERT (BOB) KRUEGER, Tezas
MARILYN LLOYD, Tennessee
JAMES J. BLANCHARD, Michigan
TIMOTHY E. WIRTH, Colorado
STEPHEN L. NEAL, North Carolina
THOMAS J. DOWNEY. New York
DOUG WALGREN, Pennsylvania
RONNIE G. FLIPPO, Alabama
DAN GLICKMAN, Kansas
BOB GAMMAGE, Texas
ANTHONY C. BEILBNSON, California
ALBERT GORE, JR., Tennessee
WES WATKINS, Oklahoma
ROBERT A. YOUNG, Missouri
JOHN W. WYDLER, JB., New York
LARRY WINN, JR., Kansas
LOUIS FREY. JR., Florida
BARRY M. GOLDWATER, JR., California
GARY A. MYERS, Pennsylvania
HAMILTON FISH, JB., New York
MANUEL LUJAN, JB., New Mexico
CARL D. PURSELL, Michigan
HAROLD C. HOLLENBECK, New Jersey
KLDON RUDD, Arizona
ROBERT K. DORNAN, California
ROBERT S. WALKER, Pennsylvania
EDWIN B. FORSYTHE, New Jersey
CHARLES A. MOSHER, Executive Director
HA HOLD A. GODLD, Deputy Director
PHILIP B. YEAGER, Ccvnitl
JAMES E. WILSON, Technical Contultant
WILLIAM G. WELLS, Jr., Technical Contultant
RALPH N. READ, Technical Contultant
ROBBBT C. KETCHAM. Couniel
JOHN P. ANDELIN, Jr., Science Contultant
JAMES W. SPENSLET, Ceuntel
RBGINA A. DAVIS, Chit; Cleric
PAUL A. VANDER MTDE, Minority staff Director
SUBCOMMITTEE ON THE ENVIRONMENT AND THE ATMOSPHERE
GEORGE E. BROWN, JR., California. Chairman.
ROBERT S. WALKER, Pennsylvania
LARRY WINN, JB., Kansas
MANUEL LL'JAN, JR.. New Mexico
TIMOTHY E. WIRTH, Colorado
JEROME A. AMBRO, New York
DOUG WALGREN, Pennsylvania
JAMES H. SCHEUER, New York
ANTHONY C. BEILENSON, California
WES WATKINS, Oklahoma
JAUES W. SPENSLET, Staff Director
RADPORD BTERLY, Jr., Science Contultant
123
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CONTENTS
Page
Letter of transmittal V
Charter for the Hearings IX
PART I—DENVER
ORAL TESTIMONY OF WITNESSES
November 19, 1977:
Dr. Val Veirs, chairman, Colorado Air Pollution Commission 3
Hon. Patricia Schroeder 16
Dr. John C. Cobl>, professor of preventive medicine, University of
Colorado Medical School 20
Dr. Hyman Chai, director of clinical services and research, National
Asthma Center 22
Dr. J. Douglas McCluskie, director, Environmental Health Services,
Denver Department of Health and Hospitals 22
John Simpson, executive director and general manager, Regional
Transportation District 26
Dr. Anthony Robbing, director, Colorado Department of Health 33
Lou Johnson, chief, Planning and Evaluation, Air Quality Branch,
Environmental Protection Agency 37
Dr. C. S. Kiang, Denver Brown Cloud Group 43
Ernest W. Karger, chairman, Metropolitan Air Pollution Task Force,
Denver Chamber of Commerce 47
Don Fausett, chairrrtan, Air Quality Committee, Sierra Club 51
Appendix I—Prepared statements—Denver:
Val R. Veirs, chairman, Colorado Air Pollution Control Commission,
Senior Fellow, National Center for Atmospheric Research, and
assistant professor of physics, Colorado College 55
John C. Cobb, M.D., M.P.H., professor of preventive medicine,
University of Colorado Medical Center 79
John D. Simpson, executive director and general manager, Regional
Transportation District 84
Dr. Anthony Robbing, executive director, Colorado Department of
Health 89
Louis W. Johnson, chief, Air Planning and Operations Section, En-
vironmental Protection Agency, Region VIII 92
Chai Szu Kiang, Denver Brown Cloud, leader, Atmospheric Aerosol
Project, research scientist, National Center for Atmospheric Re-
search, professor of geophysical science, Georgia Institute of Tech-
nology 100
Myron L. Corrin, Department of Atmospheric Sciences, Colorado
State University 108
Edward A. Martell, National Center for Atmospheric Research 112
Ernest Karger, chairman, Metro Air Pollution Task Force, Energy,
Environment and Transportation Council, Denver Chamber of
Commerce 116
Donald W. Fausett, chairman, Air Quality Committee, Enos Mills
Group, Sierra Club 126
Honorable William H. McNichols, Jr., mayor, City and County of
Denver ." 132
John C.Thomas, Gray Panthers of Denver 135
Dr. C. Gordon Little, Director, Wave Propagation Laboratory,
Environmental Research Laboratories, National Oceanic and
Atmospheric Administration 136
(in)
124
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IV
Appendix II—Additional material for the record—Denver:
John C. Cobb, M.D., M.P.H., Reducing Denver's Air Pollution,
Why and How? 141
John C. Cobb, Philip C. Weiser and Philip A. Russell, Health Effects
of Air Pollution in Denver 154
Study of Effects of CO on Human Judgment (proposal. November 1977). 184
John C. Cobb, M.D., M.P.H., Statement to the Citizens Forum on
Urban Growth 186
Amory B. Lovins, Fluidized Bed Reactors for Burning Coal Cleanly 189
Letter from William Scott Graeme, November 19,1977 192
Value Capture Opportunities, North-South Rapid Transit Project 193
PART II—HOUSTON
ORAL TESTIMONY OF WITNESSES
November 21, 1977:
Troy Webb, Office of the Attorney General, State of Texas, Austin 280
Bill Stewart, P.E., executive director, Texas Air Control Board,
Austin .- 281
Hon. Jon Lindsay, Harris County Judge, Harris County, Tex 288
Dr. Stanley M. Pier, associate professor of environmental health,
School of Public Health, University of Texas, Houston. _ 293
Dr. Richard K. Severs, representing the San Jacinto Lung Association. 298
Hon. Lloyd Bentsen, Senator from Texas 314
Eloy R. Lozano, director, Air and Hazardous Materials Division,
EPA Region VI 317
A. D. Cyphers, representing the Texas Chemical Council 326
Larry Feldcamp, chairman, Houston Area Oxidant Study Steering
Committee — ... 332
Dr. Herbert C. McKee, assistant health director for pollution control,
city of Houston 340
Ms. Mary Rollings, Citizens Clean Air Advisory Council, Houston.. 345
Hon. John L. Hill, Attorney General of Texas 349
Appendix III—Additional material for the record—Houston:
Houston Area Oxidants Study, November 1977, Houston Chamber of
Commerce 355
Statement of A. R. Pierce, director, Harris County Pollution Control
Department 395
Statement of Brenda Gehan, president of the League of Women
Voters of Houston.. _ 398
Statement of Stennie Meadows, Galveston Bay Conversation and
Preservation Association 401
Statement of John W. Hathorn, Applied Meteorology, Inc 416
State Implementation Plan for Texas, July 21,1977 422
Minutes of October 19, 1977, meeting between EPA and Citizens'
Liaison Committee 432
Draft revision of the summary statement from the advisory panel on
health effects of photochemical oxidants, August 29, 1977, U.S.
EPA 438
Technical support document/hydrocarbon-photochemical oxidant
control strategy for the State of Texas, January 1976, U.S. EPA 456
125
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LETTER OF TRANSMITTAL
Hon. OLIX E. TEAGUE,
Chairman, Committee on Science mid Technology.
U.S. Ilouxe of Reprcsentatirrs
DEAR MR. CHAIRMAN : I am transmitting herewith the record of
two days of hearings that the Subcommittee on the Environment, and
the Atmosphere held in Houston and Denver to investigate the par-
ticular air pollution problems of those cities. I also want to discuss in
this letter some of the findings of our hearings.
First, the two cities displayed many similarities and differences. For
example, Denver now appeal's to be in many ways at a stage of develop-
ment which Houston passed through several years ago. And each city
seems to have a rather unusual air pollution situation. In the case of
Denver, it is the large number of automobiles which are operated at
the high altitudes of Denver and therefore emit more pollutants than
they would at sea level. In the case of Houston, there is the unusual
concentration of petrochemical plants, resulting in high levels of hy-
drocarbon emissions. Thus, the two cities seem to be on similar develop-
mental courses (but Houston is a little bit ahead) and each seems to
have its own unique air pollution problem.
The several witnesses that testified in Denver seemed to be saying
that they are quite aware that Deliver has an air pollution problem; in
fact, it even has a name, the "Brown Cloud" (for which I take no
credit), and yet they do not know how to attack this problem. There
seems to be belief that automobile emissions are largely responsible for
the pollution, and there have been some attempts to reduce vehicle
miles traveled, for example, through increased use of buses, but this has
had very little impact on the problem. In fact, the increase in bus
ridership has made less than a 1 percent impact on total vehicle miles
traveled. Dr. C. S. Kiang made the very good point that there is a
need for a long-term research program to develop a sound and funda-
mental understanding of Denver's problem in order to avoid attempt-
ing a "quick fiix" solution that in the long run only causes more prob-
lems. In last year's EPA research authorization bill, our committee
report recommended that EPA conduct a study of Denver's air pollu-
tion problems, but it does not appear that they are undertaking such
work on their own. On the other hand, the Motor Vehicle Manufac-
turers' Association has begun a $700,000 study in this area and EPA
intends to cooperate with them. I intend to urge EPA to make this an
active cooperation, and indeed, to devote some resources of their own
to a parallel and related study.
In Houston, the witnesses agreed that several expensive control
measures have been adopted which appear to have reduced hydrocar-
bon emissions by 40 percent. Despite this apparent reduction "in emis-
sions, there have been no changes in the oxidant concentrations and
(V)
126
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VI
Houston does not meet the national ambient air quality standard. The
witnesses almost unanimously questioned whether or not further hydro-
carbon reduction (which is what is required in the EPA-mandated
State implementation plan to enable Houston to reach the oxidant
standard) will indeed result in reduction in oxidant concentrations.
The question that arises—which no one was able to answer—is whether
or not there really has been a 40 percent reduction of hydrocarbon
emissions. Apparently this 40 percent is calculated from emission
inventory data, which is not always reliable. Nevertheless, it seems to be
true, based on testimony of the EPA witness, that EPA cannot promise
that further reduction of hydrocarbons will lead to a proportionate
reduction in oxidant concentrations. That is, it appeal's that the agency
policy is that hydrocarbon reduction will result in reduction of oxidant
concentrations, but the physical mechanism for explaining exactly how
this will occur was not described. This was brought out in a dialogue
between Mr. Eloy R. Lozano, EPA Region VI, and Congressman Bob
Eckhardt, of Houston, who accepted my invitation to attend the hear-
ings because of their importance to his district.
It thus appears that in both the Houston and Denver cases a solid,
fundamental, understanding of the photochemistry of air pollution
would help a great deal in alleviating the tremendous uncertainty as to
the causes and cures of the respective problems. In fact, Dr. Herbert
McKee of the city of Houston's health department testified that if
research could confirm certain tentative conclusions about the rela-
tionship between emissions and concentrations of oxidants, "the im-
portance of such a conclusion in devising future control strategies is
almost beyond calculation." I think that this testimony as to the value
of good research is very true and it would apply to Denver, which is
now grappling with the question of what to do about its problems, as
well as to Houston, which is trying to understand the apparent lack of
effectiveness of measures already undertaken.
On the other hand, Mary Rollins of the Citizens' Clean Air Coali-
tion in Houston pointed out that, "For sure, there shouldn't be a
moratorium on regulations while we await the results from the needed
research.'' This epitomizes the problem facing EPA; they have to act
because they know there are problems and yet they have to act on the
basis of incomplete information.
In my view, what is needed is a coordinated program of control and
research. The air-regulatory office under Assistant Administrator
Hawkins must cooperate with Steve Gage's Office of Research and
Development in planning, supporting and executing a long-range pro-
gram of research to develop the information needed to understand
urban air pollution problems.
A pait of this research program must be communication with the
regulatory offices so that as new information is obtained it can be fed
as appropriate into the regulatory process.This is not the Avay EPA
research is often conducted now. At present, it appeal's that EPA
research programs are typically conducted as a series of short-term
projects, eacli generating an incremental bit of information. That is,
there appears to be a need for more continuity and coordination
between the series of projects. By providing in the Fiscal Year 197(
Research Authorization bill (Public Law 94-47;i) that EPA shall
develop a .Vyear research plan, we have tried to encourage them tc
proceed in this direction.
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vn
Finally, Mr. Chairman, I would like to discuss the research project
now underway in Houston. This work is being carried out as a result
of a provision in the Clean Air Act Amendments of 1977 (section
403(d) of Public Law 95-95), which calls for a study of gulf coast
air pollution problems. Funds for that study have been authorized by
the Science Committee. "We had hoped that this could be an exemplary
project in which Federal, State, local and private cooperation could be
demonstrated. Such cooperation could lead to better acceptance of the
results of the research and, more important of course, better acceptance
and implementation of any subsequent pollution control measures
found to be necessary. We were hoping that interested local groups
would participate in a constructive way in the Federal program.
Unfortunately, I have to say that as of now the degree of co-
operation has not met my hopes, and that it appears that, the lack of
full cooperation is at least partly and perhaps totally the responsibility
of EPA. That is, I feel it is incumbent upon the agency to seek out
the citizens, not for citizens to have to travel, for example, from
Houston to the relevant EPA laboratory in North Carolina to make
their input to the research planning and evaluation. A particular prob-
lem has been the insertion of the EPA Eegion VI office between the
interested Houston groups and the Office of Research and Develop-
ment. Forcing communication through the regional office seems to have
made it slow and tenuous. We intend to look into this matter again
in the next Congress and take corrective action if necessary.
Mr. Chairman, I commend this record to you and to other members
of the committee.
Sincerely.
GEORGE E. BROWN, Jr.,
Chairman, Subcommittee on the Environment and the Atmosphere.
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SPECIAL URBAN AIR POLLUTION PROBLEMS
Part II—Houston
MONDAY, NOVEMBEB 21, 1977
U.S. HOTJSE OF REPRESENTATIVES,
COMMITTEE ON SCIENCE AND TECHNOLOGY,
SUBCOMMITTEE ON THE ENVIRONMENT AND THE ATMOSPHERE,
Houston, Tex.
The subcommittee met, pursuant to notice, at 9:30 a.m., in room 101
of the Texas School of Public Health Building, Hon. George E.
Brown, Jr., chairman of the subcommittee, presiding.
Dr. PIER. I am Stan Pier, with the School of Public Health, and
you'll hear further from me later, but at the moment all I would like
to do is to extend a welcome to this distinguished group on behalf of
the School of Public Health and the University of Texas Health
Science Center in general. For those of you who've come out of State,
I'd like particularly to welcome you to Texas, the largest glacier-free
State in the Union. I know that you'll have a productive day here and
we look forward to this entire morning. Thank you.
Mr. BROWN. This morning, the Subcommittee on the Environment
and the Atmosphere of the Committee on Science and Technology is
having the second day of 2 days of hearings on special urban air pollu-
tion problems. We had the first day of the hearings up in Denver, where
despite all of their favorable environment they still seem to have some
serious air pollution problems somewhat different from those that are
common to the rest of the country. This subcommittee has jurisdiction
over the general problem of environmental research, including air
pollution research, and we are here today basically, in our oversight
role, to determine the adequacy of our knowledge base in the par-
ticular area of regional air pollution problems.
I want to emphasize that our concern is primarily with research and
that as a committee we are not directly responsible for regulatory
legislation per ae. We are concerned with all of the research activities
of the EPA, including that which is conducted in support of regula-
tory actions and policies as prescribed in the Clean Air Act and in
other laws. Thus, we must be cognizant of the regulatory needs which
drive the agencies' research programs. The general problem that
we want to discuss today is how specialized local problems can be
fitted into a national program of research, in particular, air quality
research. Clearly, we want to have air quality standards which are
applied equitably through a national program. On the other hand, one
can imagine that local factors, such as geography or special emissions,
for example, might exacerbate certain pollution effects. Therefore, we
279
129
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280
want to consider whether or not there is adequate research directed
toward such questions.
Of particular interest here is how shall we implement section 403(d)
of the Clean Air Act, which directs the EPA to conduct a study of air
quality in the gulf coast region, including an analysis of the fine aero-
sols problem and their impact on the public health. This study is very
important in itself, and we will be particularly interested in watch-
ing it as an example of Federal, State, and local, and private coopera-
tion. Finally, I want to say that we are very glad to be here; we
appreciate the welcome from Dr. Pier and the general hospitality that
we've experienced since we've been here. We have had an enthusiastic
welcome insofar as it may be1 judged by the large number of people who
expressed a desire to testify. We have not been able to accommodate
all of them, and I will apologize for any who wanted to testify and are
not included.
I would make it clear that this is not deliberate, it is just the normal
foul-up of scheduling which happens all the time, and that if anyone
who has a contribution to make and is not a part of today's schedule
wishes to submit a statement for the record it will be included in full
in today's hearing record as if it had been presented. If it is of suffi-
cient importance we will arrange for further hearings at a later date
to try to accommodate the individual or groups concerned. Now, our
first witness this morning was scheduled to be the distinguished at-
torney general of the State of Texas, Mr. John Hill, and his office has
been involved in many matters involving air quality and of course his
insight would have been particularly useful. In his absence, which I
understand is unavoidable and due to litigation of an important nature,
his testimony will be presented by Mr. Troy Webb, so I will ask Mr.
Webb if he could come forward at this time. And we're very happy to
have you here, Mr. Webb, in place of the attorney general.
Mr. WEBB. Thank you, Mr. Chairman. I do regret that Attorney
General Hill was unable to be here, but as you indicated he was ordered,
somewhat at the last minute, to be in court in a matter of great impor-
tance to the State, and we do have a prepared statement that I have
furnished your staff. And, not being the attorney general, I'm not
going to take a great deal of time. I'll just very briefly summarize for
you, Mr. Chairman, what the attorney general's comments are
generally.
Having been deeply involved in air pollution enforcement over the
past 5 years, and having had a very aggressive enforcement policy
working often in conjunction with the city of Houston and Harris
County, it has become obvious that the air pollution problems here
in Houston far transcend the five criteria pollutants and their control
strategies, and that our problems are different from those that are
found in Los Angeles and those that are indicated by studies in other
metropolitan areas. And so the need for regional research has been
amply demonstrated, particularly into the problem of aerosol haze.
I will leave it to the Texas Air Control Board to go into the more
technical details, but, Mr. Chairman, I do want to personally convey
the attorney general's thanks and our thanks on his staff for the efforts
that you have given to see that we can get some regional research, and
it is our hope, and we feel that your presence here today indicates that
we can put behind us some of the past disputes that we have had over
control strategies and various problems here in Houston and go on
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281
about the business of determining what is causing our air pollution
problem and proceeding vigorously to solve it. Thank you, Mr. Chair-
man.
Mr. BROWX. Thank you, Mr. Webb. Our next witness this morning
will be Mr. Bill Stewart, who is executive director of the Texas Air
Control Board. Mr. Stewart, we are pleased to have you here and look
forward to your testimony helping us to understand the problems of
the area.
Mr. STEWART. Mr. Brown, Mr. Wirth, and members of the staff. I
have a prepared statement, which you have, and I will be speaking
from that.
[The prepared statement of Mr. Stewart follows:]
PBEPABED STATEMENT or BILL STEWART, P.E., EXECUTIVE DIRECTOR,
TEXAS Ais CONTROL BOARD
I appreciate very much the time you have taken to come to Houston In order
to receive testimony on how research efforts can help us understand the air pol-
lution problems of this region. I also appreciate the opportunity to present the
Texas Air Control Board's viewpoint on how these research efforts should be
directed.
Mr. Brown, we have one member of our Air Control Board In the audience
this morning, Dr. Jack Killian, who's a licensed M.D. in the State of Texas.
He is here to assist in any way possible.
Houston is a heavily industrialized region, and a tour through the Houston
ship channel area is impressive. The figures are impressive also. Over 40 percent
of the United States' petrochemical production is here, along with over fcO per-
cent of the U.S. petroleum refining capacity. Though generally well controlled,
the emissions from this industrial base are of sufficient magnitude to render
the local air pollution situation very different from any other portion of the
United States. Emissions from fixed point sources still comprise 64 percent of
total hydrocarbon emissions in Houston, versus about 43 percent in the Los
Angeles area.
Mobile sources emit about 35 percent of the total hydrocarbons here versus
51 percent in the Los Angeles area. Because of these differences, the minor
amount of air pollution health effects data that is available from other areas
of the United States may not be applicable here. We, therefore, believe that ex-
tensive research is required to determine what harmful effects, if any, air pol-
lution is having on the more than 2 million people that reside in the gulf coast
region of Texas.
Controls that have been placed on fixed point sources of hydrocarbon emis-
sions have reduced these emissions by about 50 percent since 1971. There has been
no observable decrease in either the severity of ozone peaks or the frequency
with which the oxidant standard is exceeded.
The controls which have been implemented also appear to have had little ef-
fect on the aerosol haze that is so often visible in this region. The small air-
borne particles that cause this haze are a source of concern to all segments of
the community: The citizens, the air pollution control officials, and the public
health experts.
In addition to the concern about reduced visibility caused by the haze, there
is apprehension over adverse human health effects that may result from either
short or long-term exposure to such pollution. Unanswered questions concerning
air pollution effects compound the anxiety of the residents in this area.
The information that we need in order to understand air pollution in this
region covers a wide range of complex subjects. To obtain 'the entire amount of
information that we would like to have would be a staggering task. We realize,
however, that any research program must be realistic in scope. We, therefore,
suggest, the following three-pronged approach.
First, an extensive project should be started immediately for the purpose of
determining the major constituents and sources of Houston's area aerosols,
and the geographic extent of the areas affected. From this information we would
have an indication of possible control strategies and an Initial Indication of
possible adverse health effects.
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Second, a study of the health effects of exposure to the Houston atmosphere
should be started as soon as possible, but only after careful planning. Many
past health effects studies have been of marginal use because of the utilization
of data that was either inaccurate or unrelated to any air pollution effect.
The first phase of the health effects study should be the determination of the
types of data that will ultimately be most meaningful in demonstrating any
acute or chronic adverse health effects. Then, mechanisms to collect the data
should be established. Without careful attention to these problems, any health
effects study may suffer the same weaknesses that have plagued past studies.
Data describing a large number of environmental parameters will have to be
collected over the same time period. These two data sets can then be cor-
related. We realize that this will be an expensive and lengthy project. The
results should elucidate adverse health effects that arise from a variety of pol-
lutants, not simply aerosols or oxidaiits.
Finally, while funding limitations may prohibit it at this time, another project
that must be started soon is to determine the health effects that are going to
occur as a result of increasing emissions. Predicting the future is always a
hazardous process, but we must try if our control strategies are going to 'be
logical. In a study for the Governor's Energy Advisory Council conducted in 1974,
we studied the historical growth patterns for this region, and the expected switch
from natural gas to alternate fuels. Assuming present day control technology
to be utilized, we found that by the year 2000 emissions of hydrocarbons could
double, particulate emissions could be up by a factor of 8, nitrogen oxides could
also be up by a factor of 8, and sulfur dioxide emissions could be up by a stagger-
ing factor of 24 times present emission rates. And, again, that's assuming current
best available control technology on all sources.
We do not expect this to occur due to the Improving technology that will help
reduce the rates of these Increases, but we use this example to illustrate the
potential for problems in this region.
This year, the Texas Air Control Board appointed a panel of well-known
medical experts to assist the Board. Members of this group, the Medical Re-
sources Advisory Panel, have a wide range of expertise in public health matters.
The panel was appointed because of the concern of the Texas Air Control Board
with both present and future health problems that may result due to air pollu-
tion. I am confident that the members of this panel will want to assist in every
possible way those responsible for the health effects research.
A mechanism must be established to assure efficient long-term research in the
Gulf Coast Area because of Its unique character. The many research activities
that are needed cannot be accomplished over a period of one or two years. To
fragment the research into a succession of unrelated, short-term efforts would
be an obvious means of assuring inefficiency and probable failure. A mechanism
is needed to assure the continuing and coordinated involvement of research
personnel located In this region where the problem exists.
That involvement must Include priority setting and review of project design.
Both political and technical interest must be represented within the group
that controls the research.
We understand that the design of the two initial research studies will be
developed by EPA with the advice and assistance of the Gulf Coast Air Pollution
Research Committee headed by Dr. Stanley Pier of the University of Texas
School of Public Health. Representatives of the Texas Air Control Board, the
City of Houston and Harris County air pollution control agencies, the San
Jacinto Lung Association, citizens groups, the National Aeronautics and Space
Administration, and the Houston Area Oxldant Study also serve on this
Committee. Most of the Committee members serve in a private or personal ca-
pacity without the benefit of corporate expense accounts or any other form of
funding. While we expect that this Committee will 'be beneficial in developing
the initial studies proposed by EPA, neither this nor any other committee will
be able to effectively assist with the long-term and complex research require-
ments without some form of continuing financial support.
We believe that a portion of the one million dollars, which we understand
has 'been appropriated to EPA to fund Gulf Coast Research activities during
1978, should 1*> used to defray the expenses necessary for the effective operation
of the Gulf Coast Air Pollution Research Committee.
The Gulf Coast Air Pollution Research Committee should take as one of its
early tasks the determination of the optimum mechanism to assure effective
long-term research. The Committee itself can function to oversee research efforts
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tor a reasonable period of time if financial supix>rt is provided and each of its
institutional members recognizes its function and importance, and if its pur-
pose and status are recognized by those other groups with which It must
interact.
Most important is that we have a continuing involvement of an organization
located in the Texas Gulf Coast Region, and that organization should be respon-
sible for determining research priorities and should be empowered to coordinate
long-term research projects until sufficient data are available to allow us to
understand the specific air pollution problems.
As I stated earlier, it is our understanding that funds have 'been made avail-
able through EPA for the initial research efforts, with $400,000 to be used for
the aerosol studies and $600,000 for health effects studies. While we greatly
appreciate these initial research efforts, they can answer only a small portion
of the questions that we have. In our opinion, the money presently available
for health effects studies is enough to make only a start and more money will
be needed for the future. However, only a small portion of the funding currently
available could, and we believe, should be used to complete an inventory of
available air quality and health effects data and to develop a comprehensive
long-range research program for this region.
This Subcommittee could be of great assistance to the citizens of this region
by assuring that the research efforts that are being started will be continued
and will be managed so as to provide the greatest possible benefit to the public
health and welfare.
Thank you very much for the opportunity to make these statements. I'm avail-
able to assist the Committee with questions, if that can be of assistance.
Mr. BROWX. Thank you, Mr. Stewart. If you'll remain there just for
a moment, we may have some questions. Let me welcome Congressman
Eckhardt, who has just shown up and invite him to come up here and
join us. Good morning, Mr. Eckhardt. We expect Congressman Gam-
mage also.
Mr. ECKITARDT. Congressman Gammage is also present.
Mr. BROWX. And of course we're very pleased to have both of these
distinguished gentlemen present, and 1 might say that in large part
because of their activities that the funds that you have referred to,
Mr. Stewart, were earmarked for the special purpose of the research
in this region. Mr. Wirth, do you have any questions of Mr. Stewart
at this point ?
Mr. WIRTH. Briefly, Mr. Chairman. At the start of your testimony,
Mr. Stewart, you say that "we therefore believe that extensive research
is required to determine what harmful effects, if anv, air pollution is
having on the more than 2 million people in the gulf coast region of
Texas." Is there still any debate in the Houston area as to whether
or not air pollution does have health impact on the people who live
here?
Mr. STEWART. I think the biggest debate would be to what extent
is that impact, rather than whether or not there is any impact from
the pollution in this area. I think there is certainly no question in the
mind of the individual citizen that resides in this area. Most of them
believe, I think very strongly, that there is a problem with the health
effects of the air pollution in the Houston area. Without an adequate
data base upon which to make a decision an agency such as ours or
EPA or others are in an awkward position of trying to assert, in fact,
that there is an adverse health effect from the materials that we're
seeing in the atmosphere, when in fact, the criteria pollutants as es-
tablished by EPA, perhaps, are not being exceeded in the area except
for the photochemical oxidant.
Mr. WIRTH. The reason I'm asking, is that we just had hearings
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in Denver on Saturday, and whereas 5 yea re ago you would have had
a debate as to whether or not there was a health impact, that issue is
gone, and everybody agrees that it's there and the question now is how
severe is it and what are we going to do about it. And that's why I was
questioning your comment, "what harmful effects, if any"—there
really isn't any debate, is that correct ?
Mr. STEWART. I believe the major debate would be not whether there
is zero health effects but at what level do the health effects begin and
then how severe are they with the pollution that's in the atmosphere.
Mr. WIRTH. And do you have a sense that that's pretty well under-
stood by the citizenry here, so that the kinds of activities or the kind
of action program that might be put together related to the health
impacts would be supported by the people living in the greater Houston
area?
Mr. STEWART. There's no doubt in my mind that the citizens of this
area are concerned about it and would very definitely support an
effort to try to determine and try to alleviate the problem; yes.
Mr. WIRTH. On that front I think these things are very interesting
and in a comparable situation we can learn one from another. We
have found out in Denver that, generally, the people of the metro-
politan area are probably way out in front of the industry groups and
the automotive industry. Our problem there is primarily an automobile
problem, but the people are just very, very far out in front of those
industry groups that are going to have to catch up with what people
w ant to have done. Thank you very much.
Mr. BROWN. Mr. Eckhardt, do you have any questions of Mr.
Stewart?
Mr. ECKHARDT. I have none at this point.
Mr. BnowN. Mr. Stewart, I think that your statement very ade-
quately outlines the regional problem here, and it is a little frighten-
ing when you look at the future. I was struck particularly by your
description of the possible increase in SO2, which probably would
mean a similar, parallel increase in sulfates and other related deriva-
tives of the sulfur compounds. And I think it is correct to say that we
do not have a sound data base as to the health effects or other effects
of that kind of increased concentration of sulfates. I'm reminded that.
EPA did conduct a national study of the health effects of sulfur
dioxide several years ago, the so-called CHESS studies, in a number
of communities. And the general reaction in the scientific community
to that study was that its scientific structure was sufficiently flawed
that the data really wasn't conclusive as to the health effects. Do you
think there's a possibility that this area could become a guinea pig
for a more definitive, properly designed, thoroughly adequate from
,i scientific basis study of the sulfate problem if it appears that that
is ffoine: to be a major item in your air pollution problem ?
Mr. STEWART. Yes, sir, I surely do. Let me tell you basically why.
The Houston area, as most of Texas, is unique in the sense that we
have historically had a supply of natural gas upon Tvhich to base our
fuel consumption and fuel burning. As you are well aware, that base
is no longer there and, in fact, the sources in this area are beginning
to convert to higher sulfur fuels. Houston would be unique in the
sense that we have a heavy industrial base, there basically is very little
sulfntc in the atmosphere and in the future we are going to have it.
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so to me it would be an ideal place to do that type of research, very
definitely needed.
Mr. BROWX. Well, I might say that that problem ranks very high in
priority to the Nation as a research problem, in view of the probable
need to convert to fuels which will produce sulfur in the atmosphere
over the next generation. And you are now facing that problem now,
as you have to move from your natural gas economy to a coal or lignite
economy.
Mr. STEWART. Yes, sir, we surely are.
Mr. BROWX. Mr. Spensley.
Mr. SPENSLEY. Yes, Mr. Stewart, you mention that the Texas Air
Control Board has appointed a panel of well-known experts. Is it
your intention that that panel will work with the EPA team in doing
these studies ?
Mr. STEWART. Yes; I would very definitely. Through the efforts of
Dr. Jack Killian, who is the M.I), on our board, we would offer the
services of that group to work with EPA in whatever way it can in
determining health effects data needs, as well as reviewing data, and
doing other things that would help with that entire capacity. The air
control board stands ready to assist in any way we can, whatever the
effort might be.
Mr. BROWN. Mr. Stewart, just looking around us here, it would
appear that the resources for a major attack on understanding of the
health effects of air pollution exists right here in, the region. For
example, I'm sure this hospital, all of the hospitals in the area and
the medical profession, have at least some understanding; of the
carcinogenic and the pulmonary effects of air pollution, and that there
are tremendous resources here to structure a scientific health effects
study. Am I correct in that ?
Mr. STEWART. Yes, sir, you certainly are. And I think that, again,
that one of the reasons that we're addressing this committee in terms
of trying to maintain or establish and maintain some localized base
that is in this area, that we'll live here, be here and reside in this area
to assist and help carry out some of this effort. I think that's very
important.
Mr. BROWN. That seems so logical to me that I can't understand
where the objection to it might come from.
Mr. STEWART. Mr. Chairman, I don't believe there is objection. I
believe the problem, perhaps, is getting the mechanisms to establish
that and to assure that there is a long-term, continuing effort. We
would encourage the committee to assist us with that very point and
in establishing with EPA the priorities of how to proceed—as to how
is the proper way to do it.
Mr. BROWN. I think that we'll be able to be of some help in that,
Mr. Stewart. Any further questions? Mr. Byerly, do you have any
questions ? Mr. Clement ?
Mr. STEWART. Again, Mr. Chairman, we appreciate your coming to
Houston. Thank you.
Mr. BROWN. Thank you very much, Mr. Stewart. Mr. Eckhardt,
before we introduce the next witness, would you care to make a state-
ment on the hearings at this time ?
Mr. ECKHARDT. Mr. Chairman, we tremendously appreciate the
effort that you and your committee have made in making available
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funds in an area we think is so essential, and I think I can speak
for my constituents here and other persons in Houston to say that we
very much appreciate your holding the field hearings here. Your
questions of the last witness indicate a sympathetic knowledge of the
situation that, exists in this area. My statement will be brief, because I
prefer that those with technical expertise, be afforded ample time. It
appeai-s to me that there are two definite aspects of this gulf coast
research study which arc most, important. One is the health effects of
pollutants, about which we know little, such as fine participate matter
and carcinogens. Second, the case of photochemical oxidants. the role
that nature plays in the creation of this pollutant, the extent to which
man should control emissions of its precursors.
"\Vith respect to small particulates, Charles Barden, until recently
the executive director of the Texas Air Control Board and now a con-
sultant in private industry and a man who was most competent and
thoughtful and progressive in developing and identifying our prob-
lems here in Texas, testified before your subcommittee last February
and pointed out some of the problems. He indicated that limited re-
search done by his staff shows these, particulates to be composed, of
sulfate and nitrate aerosols. From this research Barden deduced that
these pollutants are not so much generated by emissions from smoke
stacks as from an agglomeration of gaseous emissions from the. auto-
mobile. However, a great deal of more research is needed on this mat-
ter, not only to determine where such pollutants are originating but
how they can be controlled and what their effects upon human health
are.
The second facet of the study should deal with a problem which has
concerned me a great deal for several years—photochemical oxidants.
The San Jacinto Lung Association, whose foremost interest, is reducing
respiratory ailments, has had an Air Conservation Committee func-
tioning for many years. For several years I was a member of that com-
mittee and still have a member of my staff representing my office on
the committee. One of the committee's concerns has dealt with the
photochemical oxidant problem, and it has emphasized consistently
that the problem in Houston is not the same as the problem Los An-
geles is experiencing. Your last witness, of course, pointed out that
the proportion of the total pollution is much more heavily from indus-
trial plants here than in Los Angeles. Another difference is, of
course, that the Los Angeles area is in something of a bowl with moun-
tains surrounding several sides of that bowl as I understand. Our prob-
lem here is that normally we have southeast winds which vie with the
frontal systems coming from the northwest. And frequently these
winds clear out the area, but on occasion this vying force, when it re-
sults in a draw, creates a kind of stationary front situation or an occlu-
sion, which creates something of the same situation that I imagine you
have in your own area. However, the factors are different. The, contrib-
utors to pollution and the nature of the weather systems and the situa-
tions topographically are quite different and, we find that some of the
things that seem to have worked in the Los Angeles area may not work
in Houston.
Dr. Richard Severs, of the School of Public Health and also a mem-
ber of the Air Conservation Committee of the Lung Association, raises
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another interesting question concerning the origins of photochemical
pxidants. On December 14,1976, Dr. Severs testified at the public hear-
ing held by the Environmental Protection Agency on proposed amend-
ments to the hydrocarbon/photochemical oxidant strategy. His re-
search indicates that the photochemical oxidant problem may not be
caused by emission of hydrocarbons but by emissions of oxides of nitro-
gen, about which very little is known. His position was supported by
Dr. Albert Randall, at that time director of the public health for the
City of Houston. Dr. Randall pointed out that control measures im-
posed upon both stationary and mobile sources had resulted in a 40-
percent reduction in total hydrocarbon emissions. Now, one would
think that a reduction of that great an amount in emissions would have
resulted in some reduction in the photochemical oxidant pollution.
Such is not the case. In fact, in a letter dated November 22,1976, to the
Air Control Board, Kenneth W. McKenzie. Jr., Chief of the City Air
Pollution Department, pointed out that the Houston area had its worst
case of photochemical oxidant pollution ever during the summer of
1976. Oxidant pollution exceeded 0.2 parts per million during 30 per-
cent of the days in September and more than 25 percent of the days in
August Dr. Randall, in his testimony last year, reported that 1976
showed more high ozone dajrs than any other year since adequate
monitoring results were obtained.
In view of the current uncertainties concerning photochemical oxi-
dants, I handled the amendment to the Clean Air Act which provided
additional time to reach the health-related ambient standard for photo-
chemical oxidants, and such provision became law. Under the amend-
ments signed into law in August, areas with severe photochemical oxi-
dant problems, such as Houston, were provided significant leeway
until December 31 of 1982. However, in July of 1982. States with severe
oxidant problems must come forward with the revised implementation
plan containing enforceable measures to achieve the primary standards
for oxidants by 1987.
In developing this clean air regulatory strategy, with the input of
State officials, it was my intent that intensive research concerning oxi-
dants during the next several years would make it possible to develop
an effective oxidant control strategy by 1982. I believe that such re-
search should be given a high priority in the Gulf Coast research
program.
I would also like to touch briefly on three other points. First, to
be able to continue the economic prosperity which the Houston area
has enjoyed, we must find research answers. If emissions of oxides of
nitrogen are the chief culprit in producing photochemical oxidants,
I think we must look at the question of what kind of controls we place
on other emissions. Though I am an adamant supporter of environ-
mental quality, one must push as rapidly as possible to identify that
type of pollutant which, if reduced, will have the greatest efficiency
in reducing oxidants in this area. As has been said here, we are in a
situation of very quickly moving from a gas fuel base to a coal base,
and we do have considerable pressures on development of industry
because of that fact. So it becomes extremely important that the most
careful scrutiny and the most precise identification of the cause be de-
termined as quickly as possible.
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The second point I wish to make is to strongly emphasize that this
re-search study must not be a one-shot affair. As this subcommittee has
wisely recognized in the conference report of the fiscal year 1978 EPA
authorization, such research must be an ongoing project. I do not be-
lieve that the answers we need can be obtained within a short period. I
will ardently support all efforts to provide adequate funding until the
answer is obtained.
Finally, I want to commend the Environmental Protection Agency
for proceeding rapidly with the study. Already two meetings have
been held with interested agencies and citizens' groups in efforts to de-
termine the direction of the study. I would encourage the EPA to use
whatever data is already available rather than to duplicate research
that already has been done. This research study must be coordinated
with such groups as the Houston Area Oxidant Study, and the San
Jacinto Lung Association, as well as the Texas Air Control Board. I
would like to see a liaison committee established by the EPA, to keep
interested groups informed as to the progress being made in the study.
Again. I want to thank you for coming to Houston and listening to
our problem; it is my hope that the hearing today will help to provide
a consensus as to research priorities and facilitate the type of com-
munication which is so essential to an effective research program. It
is my intent that the Gulf Coast Research Program will further the
public health and improve our clean air regulatory program. Thank
you very much, Mr. Chairman.
Mr. BROWN. Thank you, Mr. Eckhardt. I appreciate your statement
and I would reiterate that your support for adequate research in gen-
eral and for the needed program for this area has been extremely im-
portant in developing the program to the point that we have today,
and we hope even more in the future. Mr. Gammage, would you like to
make a statement?
Mr. GAMMAGE. Thank you, Mr. Chairman, I'll be very brief. I'd like
to welcome the committee to the Houston area, the greater Houston
area, and specifically the 22d Congressional District today. I appre-
ciate your coming here to pave the way for the regional study and the
regional redirection of EPA in the area of air pollution. I think my
colleague and friend, Congressman Eckhardt, has adequately pointed
out the necessity for this redirection and obviously the committees of
the Congress and the Congress saw the necessity for this effort and
also, and more pointedly, their cooperation with State and local en-
tities that are concerned on the local scene with the state of their en-
vironment. I understand our county Judge, Jon Lindsay, is going
to be the next speaker and must move on to preside over Commissioners
Court, I presume over flooding and transportation, having encountered
some of those problems this morning on the way here, so I'll close with
that brief statement.
Mr. BROWX. Thank you, Mr. Gammage. Our next witness is Hon.
Jon Lindsay, Harris County Judge, and we invite him to come for-
ward and welcome him to the subcommittee's hearings.
Mr. LINDSAY. Thank you, Chairman Brown and members of the
committee. And, Bob, it's true—that's why I was late, too. I got stuck
in our own flood and traffic jam and it was something fierce, this morn-
ing. I think, as I came in, there was a little confusion about what the
County Judge is in Texas. A very brief explanation of that might be
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just to tell those it is the chief administrative office of the county that is
elected in Texas—I don't know what it is in California, but I'm sure
you have a similar position there.
Mr. BROWN. The Lord appoints them in California.
Mr. LINDSAY. It's not that way here.
[The prepared statement of Judge Jon Lindsay follows:]
STATEMENT sr HABBIS COUNTY JUDGE JON LINDSAY TO THE SUBCOMMITTEE ON
THE ENVIBONMENT AND THE ATMOSPHERE
Gentlemen, first let me thank yon for taking an active interest in the pollu-
tion problems in the Harris County area. Harris County is a rapidly expanding
area. Approximately 80,000 people moved into the county last year alone. These
people are coming here to take advantage of an expanding job market that has
its roots in the vast petrochemical industries of the region. Harris County is
unique because there is probably no other region in the world that has a similar
industrial complex. We therefore have pollution problems here that are equally
unique.
I hope that your presence indicates that the Environmental Protection Agency
will direct its research efforts to the problems of the local area. Hopefully they
will not set across-the-board-standards that might apply in the East or in Denver,
Colorado, and therefore not be feasible here.
Three obvious problems involving our area with corresponding research needs
are immediately apparent:
(a) The little understood and all pervasive oxidant problem,
(6) The aerosol haze, and
(e) The increasing sulfur dioxide concentration being added to our already
polluted air.
1. Our ambient air levels of oxidants (as measured by ozone) regularly violate
the national standard. This condition exists in spite of millions of dollars having
been spent at the insistence of EPA to control hydrocarbon emissions. Our oxi-
dant episodes are no less frequent and no less severe today than they were several
years ago before controls had been implemented removing thousands of tons of
hydrocarbons from our atmosphere. Obviously this strategy has not been effec-
tive, yet the EPA persists in requiring further reduction of hydrocarbons without
proof that further reduction will improve oxidant levels. Apparently it has not
occurred to the EPA that the oxidant standard may be improperly set. We would
recommend research be directed toward developing a proper oxidant standard.
Research is definitely needed to explore the enigma as to why oxidant levels are
not reduced as hydrocarbon levels are reduced. In addition, measuring oxidants
by measuring ozone has obvious drawbacks which are becoming more and more
apparent.
2. Aerosol haze plagues the Harris County horizon. Its origin, its composition
and its effects are equally unknown. As a visibility problem it is substantial and
it appears also to impair health. Health effects have gone almost totally unex-
plored. The need to do lengthy and indepth research cannot be questioned. The
question is not "does the Harris County haze need to be studied?" but rather,
"How soon can the study begin?"
3. Local sulfur dioxide measurements do not approach levels of noncompllance;
however, it is reliably predicted that conversion to fuel oil and coal will prob-
ably cause the Harris County area to become nonoompliant Coupled with an
increasing sulfur dioxide concentration will be health problems, some caused
directly by sulfur dioxide, some caused by a synergistic effect due to the presence
of other airborne pollutants. The devastating effects on pulmonary conditions
caused by sulfates (sulfur dioxide is a precusor) is just beginning to be under-
stood. I call to your attention the research done by Dr. Judith Graham of the
EPA.
A second purpose of this hearing is to discover how local groups can have input
to the research planning.
During the past 2 months several meetings have been held between interested
local parties and representatives of the Texas Air Control Board and EPA. At a
meeting on October 19, 1977 in the local offices of the TACB, attended by 28
persons representing a cross section of vitally interested parties, a liaison com-
mittee was formed. The function of this committee is to have informal and un-
offlcial input to the EPA regarding the research studies to be conducted in the
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Gulf Coast area. At the time of formation it seemed apparent that the EPA is
not eager to hare outside guidance, yet I believe local input on a continuing basis
is an absolutely necessary ingredient to the success of any research program
conducted in this area.
This committee has no official standing, but the membership represents local
and State government, organized research, medical agencies and environmental
groups. It is our desire for this committee to be officially recognized and to be
able to interrelate on a positive basis with the EPA.
We live with our pollution problems on a day-to-day basis and have an under-
standing bred of familiarity. That our resources are not sufficient to totally deal
with our pollution problems should not exclude us from having a say in the solu-
tion to these problems. Because EPA has the personnel and the equipment and the
financial resources to deal with problems of such magnitude as found locally,
it logically places them in the research role, but local input and cooperation Is
vital to success. I therefore respectfully request that this committee, as shown
by the attachment, or a similarly constituted committee be given official sanction
and granted an advisory role to council with the EPA in directing the research
activities to be conducted in Harris County.
The EPA has a propensity for demanding specific action to cure a given con-
dition without fully understanding the causative factors leading to that condition
or the Impact of the action required. The classic example of this, of course, is
the oxidant reduction strategy which has cost millions of dollars and has not re-
duced the oxidant level in this area. The EPA has a "cart before the horse"
philosophy which leads to coming up with answers and then trying to fit them
to likely problems. We have had enough of that and yet, if I understand the
Clean Air Act Amendments of 1977, we are probably faced with more of the same.
"We have a golden opportunity as concerned, Intelligent citizens to sit down to-
J gether and explore solutions to our air pollution problems and then working to-
gether in full cooperation to solve those problems as the facts developed by re-
search dictate. Think how much we can accomplish if we approach this situation
without bias, without preconceived opinions and without individual selfishness.
Thank you, Mr. Chairman, and members of the committee.
LIAISON COMMITTEE FORMED os OCTOBER 19, 1977
Dr. Stanley M. Pier, chairman, University of Texas School of Public Health;
Dallas Evans, City of Houston Air Pollution Control; Allison R. Peirce, Harris
County Pollution Control Department; Jim Payne, Texas State Air Control
Board; Mary Rollins, Citizen's groups: League of Women Voters, Citizens En-
vironmental Coalition, Citizens Clean Air Advisory Committee; Larry Feld-
camp, Houston Area Oxidant Study; Dr. Richard Severs, San Jacinto Lung As-
sociation ; Unnamed, Harris County Medical Society; ex officio Ray Loznno, Fed-
eral EPA (Dallas) ; ex officio Robert Rowley, Federal NASA.
Mr. BROWN. Thank you very much, Mr. Lindsay, for your statement.
Mr. Wirth, do you have any questions?
Mr. WIRTH. Thank you, Mr. Chairman. Mr. Lindsay, on the second
page of your testimony you talked about how EPA is persisting in re-
quiring further reduction of hydrocarbons without proof that further
reduction can improve the oxidant level. Does the EPA have other
reasons for pressing for the reduction of hydrocarbons other than just
the improvement of oxidant levels ?
Mr. LINDSAY. Well, I'm not sure what their reasons would be. I'm
assuming that they would, yes.
Mr. WIRTH. Isn't EPA probably after a whole variety of pollutants
in the air ? They're going after various nitrogen oxides and various sul-
fur oxides and particulate matter, looking at these and the relationships
between them. I guess it's unclear as to what the relationship of all of
these may be. I would suspect that what EPA is trying to do is to bring
the whole level of air pollution down, and the level of oxidants, albeit
the biggest problem here right now, is one of many problems that the
EPA is trying to address.
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Mr. LINDSAY. Well, I believe they're taking a kind of shotgun ap-
proach, and they're shooting at everything and there may be a more
economical and more reasonable way to pinpoint, through research,
what some of the problems are and then go towards the prime pollu-
tants and working in those areas that do seem to have the most impact
on the pollution in our country. And, of course, this is what we're
encouraging.
Mr. WIBTH. Well, now, understand that we want to pick off the
most important one and that problem would exist here as in other
cities like my own city of Denver. But I would also say that it's im-
portant to look at everything the EPA is trying to do. Albeit we may
not agree with or we may not like what EPA is trying to do, prob-
ably they're on the right track in a lot of things. It's easy to take a
shot at what EPA's trying to do. They haven't solved it all today as
you know. We can get angry at that, but on the other hand I think
we want to try to understand the overall impact of what they're doing.
Mr. LINDSAY. I think, as Congressman Eckhardt pointed out in his
statement, that there are certainly other things to consider in our
community. We do have an economy to consider, and by taking a
shotgun approach we may be stopping economic development of any
kind if we're not careful. And we need to be objective in the sources
that we're going after, I believe, in order to hold the confidence of
not only the people that we are providing the protection for, but also
the industries that are providing the jobs for those same people.
Mr. BROWN. Mr. Eckhardt ?
Mr. ECKHARDT. Mr. Chairman, I know that Judge Lindsay is one
of the persons in Harris County who has been most vitally concerned
with environmental matters—I think mostly the question of pre-
serving the streams. I have been associated with him in some of
those endeavors. What I say here is not critical of his base, but I
do think it might be a little unfair to blame EPA too much in this
area. It's not usual for Members of Congress to say, "Look, why don't
you throw a little of the blame on us. Maybe we had to guess at a time
and then we had to reconsider and take further action." But you say,
judge, "if I understand the Clean Air Act Amendments of 1977, we
are probably faced with more of the same"—driving in a given direc-
tion that may or may not produce results. I guess that's what you
meant—is that right?
Mr. LINDSAY. Well, that's kind of what I meant. I hope I'm wrong
on that, though.
Mr. ECKHARDT. Well, I think you may be. I think EPA was actual-
ly required, under the statute, the Clean Air Act, which we drafted,
to put into effect some kind of rather stringent limitation on further
building of facilities in a noncompliance area when the ambient air
standard levels were not met in 1977. Now, we wrote that into
law and EPA was doing what thev felt the law required. And
they provided a certain degree of feniency which may somewhat
have stretched the law in what is called the offset policy, which has
been much criticized. So in the 1977 act, we recognized that there al-
ways must be a goal and an estimate to reach in obtaining clean air.
Recognizing that such goal may have been too tight, we provided for
further flexibility with respect to six pollutants, and provided that
the ambient air standards be met by 1982, and in the case of oxidants
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and carbon monoxide by 1987 at the latest. Now, I think this may an-
swer the statement you made on page 2 that apparently it has not oc-
curred to the EPA that the oxidant standard may be improperly set.
It certainly was recognized by Congress—and by my colleague, Bob
Gammage, who was one of the first to point this out and to raise this
question in committee—we together worked on amendments in that
commitee and ultimately on the floor. EPA was pretty much bound
to operate within the original statute. Now, of course, with a further
extension of time to meet the oxidant standard, we are here trying to
point out that we want to get the necessary research so that in placing
limitations on industrial emissions, we won't actually stymie industrial
growth.
I hope that EPA is as concerned about this question as you and I
are, and I'm quite sure that our committee will be watching its prog-
ress in trying to identify the culprits here and to take that kind of
regulatory action which attains the maximum cleanup of the air while
at the same time affording the minimum of limitation on industrial
growth in the area. Incidentally, I might mention that in the new
Act we provide that any State may put into effect the California stand-
ards with respect to automobile emissions, and a little tougher stand-
ard on automobile emissions may give us a little more leeway and
flexibility in industrial growth.
I have more made a statement that I have asked a question, but if
you'd like to comment, please do so.
Mr. LINDSAY. Well, I think I have little comment, except I am en-
couraged with what appears to be a changing attitude or more direct
influence from Congress on EPA than has been in the past, and I look
forward to that continuing in the future.
Mr. ECKHARDT. Thank you, Judge. Thank you, Mr. Chairman.
Mr. BROWN. Mr. Gammage, do you have any questions ?
Mr. GAMMAOE. Thank you, Mr. Chairman. If I read him correctly,
what Judge Lindsay is alluding to is a disgruntlement and disenchant-
ment of local people on both sides of various regulatory issues. It's not
what EPA is doing so much as how they're going about it. In all defer-
ence to the Agency, however. Judge, it should be clarified that the offset
policy that many people find so Onerous was an effort on the part of
the EPA—which they technically really had no authority to do—to
get out from under a very arbitrary standard that was established in
law in order to permit whatever growth they could in those noncom-
pliance areas by allowing offset, which was not provided for in law.
In this session of Congress we did recognize that offset, and, I think,
made it a little more flexible. I believe the Congress has recognized the
fact—and we made a point of it on both sides of the Rotunda when
this legislation was being considered—have recognized that nationally
imposed standards don't necessarily get the same results in one area
of the country as in another. What is true in Los Angeles or St. Louis
may not be true in Houston or elsewhere and that there must be re-
gional redirection as far as establishing how can we get where we want
to go while balancing environmental integrity and economic devel-
opment in these communities.
It was brought to their attention very suddenly and with great
impact when it was realized that any national energy policy that is
established by the Congress in this session or any other is going to
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require substantial conversion to less clean souces of energy. Therefore,
we need to be concerned about our environment more than ever but
we also need to consider economic impact—in that reference, I would
refer you to some remarks on page 514 of the committee report on the
Clean Air Act—at that particular point in time they were unfortu-
nately minority remarks, but I think they were more or less adopted
by the Congress when the final bill came out. No one has a right to
expect that the Congress should always make perfect and timeless
statutes, but the citizens have a right to insist that the Congress should
bring its laws into compliance with economic and physical realities
and the dictates of common sense. I think that's what the citizens want,
and I think that's what you're talking about, and I think we're moving
in that direction with this regional redirection and in appearing here
today.
Mr. LIXDSAY. I certainly am encouraged myself, and I think the
main point, of course, is that we are emphasizing local input to re-
search that does go on and I think that's the most important part of
my statement. We do have expertise in Harris County and Texas
area—they're qualified, they've done a lot of research on their own,
but they unfortunately do not have the monetary facilities to do every-
thing that's needed. With the Federal Government's help, perhaps,
we can work together and solve our problems. We have to find out
what our problems are, first, though.
Mr. BROWN. Well, we appreciate that statement very much, Judge
Lindsay, and if there are no more questions we will let you get back
to work.
Mr. LINDSAT. Thank you.
Mr. BROWN. Our next witness this morning will be Dr. Stanley Pier,
School of Public Health at the University of Texas, one of the experts
that I hope we can count on to solve some of these problems.
Dr. PIER. Possibly the most important part of my statement is this:
The lady who is attempting to record these proceedings for the record
has asked for you to speak into the microphone or we will not pick
it up. We are not having trouble from the podium, but we are having
trouble from the table.
[The prepared statement of Dr. Pier follows:]
STATEMENT OF STANLEY M. PIEB, PH. D.
My name is Stanley M. Pier. I am an Associate Professor of Environmental
Health at the School of Public Health, The University of Texas Health Science
Center at Houston. I serve on the Technical Advisory Committee and the Med-
ical Advisory Resources Panel to the Texas Air Control Board. I also serve as
the Chairman of the Gulf Coast Air Pollution Research Committee to the En-
vironmental Protection Agency, an entity very recently established to work with
EPA in formulating the research programs mandated by the Clean Air Act
Amendments of 1977 and the subject of this hearing.
I have noted these affiliations only by way of establishing some credentials
for appearing before this Committee. The views which I will express here this
morning are however those of a private citizen—hopefully an informed one—and
do not necessarily reflect the views of the Texas Air Control Board or The Uni-
versity of Texas. However, the statements which I shall make do have the con-
currence and sanction of the EPA liaison committee to which I have referred.
In addition to the associations which I have mentioned, I serve as a con-
sultant to the National Institute for Occupational Safety and Health, the Pan
American Health Organization of'the United Nations World Health Organiza-
tion, the National Aeronautics and Space Administration, and the American
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I'etroleum Institute. All in all, I have spent much of my professional career In the
field of the health and ecological effects of environmental stress, including air
pollution.
I have lived in Houston for almost 11 years, and I have been directly involved
in our air pollution problem for all of that time. Houston does have an air pol-
lution problem. We have industrially generated odors which particularly affect
the eastern areas of our city. We exceed the ambient air quality standards for
particulates and oxidants frequently for whatever that may mean in terms of
human health. We have a distinct problem of visibility impairment, a condition
generally perceived by the general populace and which may or may not have
health impacts. Finally, we have long periods of high temperatures and humid-
ities. Looking into the future, we can anticipate a possible new problem—that of
increasing levels of sulfur dioxide produced by a conversion from gas to coal for
industrial use and electric power generation, as may be required by legislation to
deal with our energy problem.
I should like to address several of these problems.
First, the matter of airborne aerosols. These solid particulates and liquid drop-
lets are readily perceived by the populace and really constitute the major evi-
dence of air pollution to most people. Both natural atmospheric processes and
human activities produce these aerosols, and it is imperative that we deter-
mine what these are and how they arise. The contribution of humidity is signifi-
cant—and uncontrolled.
Airborne particulates have been monitored longer than any other pollutant.
Yet we must now recognize the most generally used technique is not directed
toward public health. Pollution monitoring by high volume air sampling fails
to determine the most important component of airborne particulates, those fall-
ing within the respirable range. We must study the suspended particulates in
the Houston environment and determine the extent and composition of the
respirable fraction, with special emphasis on the degree to which this fraction
is composed of toxic components or materials capable of interacting with and
potentiating the action of irritating gaseous pollutants. We must also determine
the origin of the respirable aerosols, including contributions of biogenic mate-
rials such as sulfates from our coastal zones and the products of photochemical
reactions of hydrocarbons produced by vegetation. Once the aerosol fraction of
our atmosphere has been characterized, some assessment of health impacts
should be possible. Work such as this should put our haze problem into perspec-
tive, and establish whether we are dealing with a health problem or a more
readily tolerable esthetic degradation, or some combination of the two. As of
now, we simply don't know.
The oxidant problem is a major point of contention and the three previous
speakers have already alluded to this. We are designated a nonattainment area.
This despite the fact that we don't know what we actually have in our atmos-
phere, we don't know where it comes from, we don't know if the measurement
technique is applicable, we don't know what the health effects are by whatever
we have and we don't know if compliance is realizable with even the most ex-
treme control measures. We do know however that the control measures pro-
posed are costly and disruptive.
The ambient air quality standard for oxidants was established with a meas-
urement technique which measured the total oxidizing capacity of the atmos-
phere. It was recognized that oxidants were a complex mixture, of which the
major constituent was ozone. At the current standard, some 50-60 percent of
the total ozone permitted is of natural origin. Because of difficulties with the
original analytical method, we are now monitoring compliance with a method
that measures ozone. The assumption is that all atmospheres have roughly the
same mix of ozone and oxidants as in Los Angeles, where the basic data were
developed. This fact has certainly not been demonstrated with respect to Hous-
ton's air. Nonetheless, the same strategies for control developed for Los Angeles
are being imposed on Houston.
Research done at this institution points up serious problems with respect to the
relationship between the two analytical methods, the one which formed the basis
for the standard and the one in current use for enforcement. These data have
been provided and have been dismissed as "operator error," a resolution which
we cannot accept. However, this matter demands resolution in the forthcoming
research program. The fact that the original analytical method, which established
the standard, is designated a* "unreliable" in the revised oxidnnt document now
under development by EPA does not give much cause for encouragement. If a
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standard was developed based on an unreliable analytical method, considera-
tion must lie given to the strong possibility that the standard too is unreliable.
There is other strong evidence that our oxidant or ozone problem is different
from that in Los Angeles. We have areas in our State with hydrocarbon levels
substantially less than 10% of those prevailing in Houston. Nonetheless, these
areas are also out of compliance with the oxidant standard. These data too have
been provided to EPA. Hydrocarbon emission reductions of the order of 95%
are either impossible or intolerably costly, and if this is what is required, the
standard is impossible to achieve.
Other information points to the fact that we have a different problem in Hous-
ton from that in Los Angeles. We attain oxidant/ozone levels similar to those
reached in Los Angeles, at which levels there would be severe eye irritation and
extensive vegetation damage. These symptoms are not experienced here. We also
find instances in which there is a simultaneous increase in ozone levels across
wide areas of the State, and frequently during dark hours. This is not charac-
teristic of Los Angeles type photochemical smog. Long range transport of ozone
does not explain the whole problem. We also find high levels where pollution is
not an issue. All of this suggests a source other than or in addition to industrial
or automotive discharges.
Just within the past week, an announcement came out of the National Bureau
of Standards reporting that their scientists have discovered an entirely new and
possibly very important intermediate in photochemical smog formulation. It was
specifically noted that this finding could alter our computer models simulating the
formation and spread of smog. This affords further evidence of the incomplete
understanding which we have of this problem, and attests to the imperative of
developing a better understanding before we impose costly measures of uncer-
tain effect and merit
Despite all this uncertainty as to the degree to which the Houston and Los
Angeles problems are equivalent, we are proceeding with the imposition of Los
Angeles-developed control strategies here. We need more information as to the
composition and source of our ozone problem before these measures are imposed
with the costs and disruptions associated with these controls. Anyone concerned
with human health strives to err on the side of caution in the protection of the
public health, but it seems to me that we are moving too far and too fast in the
face of what seems to be a manifestly unsound basis. We must establish the na-
ture of the Houston problem and design a remedy for Houston rather than assum-
ing that we have the same problem as Los Angeles and that the same controls
are applicable.
Our most important air pollution problem may in fact not yet exist. This in-
volves future increases in sulfur dioxide and derivative levels as we abandon
natural gas for industrial and power generation use and switch to coal. We are
in compliance currently with both the primary and secondary air quality
standards for SOs, but this happy state may not continue. A critical point is that
we have a population generally not acclimated to this pollutant. Further, we
must anticipate human contact with SO» under conditions of high temperature
and humidity. We do not know what this combination will produce in terms of
adverse health effects, and this must be determined before we can judge what
levels of sulfur oxides can be tolerated. We must also investigate possible inter-
actions between SOS and ozone, even if the ozone itself has no adverse effects at
present levels. We can anticipate a more rapid conversion of the atmospheric SOi
to the much more offensive SO> and sulfuric acid mist. This interaction should be
studied in chamber experiments. In conjunction with these, we should be determin-
ing the sulfate bnseline in this area now, before a significant increase in emissions
occurs, as a means of establishing man's contribution to this possibly important
pollutant.
To summarize, the following are, in my judgment, the most critical research
needs pertaining to Houston's air pollution situation:
1. We need to quantify and characterize the respirable portion of suspended
particulates, both liquid and solid, and determine what toxic and potentiating
substances may be present This will require Improved collection systems to pre-
clude altering the aerosols during the collection phase and more sophisticated
analyses.
2. We must conduct intensive analyses of the oxidant mix to detemine what por-
tion is ozone and what portion consists of the more deleterious components such
as the peroxyacetyl nitrates. As part of this effort, \ve must determine the origins
of the oxidant precursors and define the relative proportions of uncontrollable
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natural contributors and controllable man-related emissions. The most critical
need is for a determination of the appropriateness of the control strategy.
3. We should establish a comprehensive health surveillance system to monitor
human litalth as related to air i>ollution. We especially need to determine whether
there are significant adverse health effects associated with oxidant episodes. We
should also monitor vegetation more closely to detect characteristic oxidant dam-
age—or the absence thereof.
4. The health surveillance system just referred to should be established at the
earliest possible time, but certainly before there is significant intrusion of sulfur
oxides into our environment. This system could serve as an early warning- for
adverse effects of exposures to SO2 and derivatives.
5. Research should be conducted on the interactions or synergisms, if any,
among sulfur dioxide, high temperature, humidity and other pollutants as a
means of establishing the tolerable sulfur pollution levels, considering present
and anticipated future technology for extraction of sulfur oxides from flue gases.
We must recognize that what I have outlined is not a one-year study. Rather,
it will take an extended period of time and considerable money. Certainly the in-
vestigation of local problems at the level of the affected area is the preferred
approach.
In the time allotted for this presentation, it is obviously not possible to provide
siwciflc details of research protocols. However, the Gulf Coast Air Pollution
Research Committee is ready to work with EPA in the planning, implementation
and evaluation of research studies in these areas. It is critical that this research
be conducted with the best talent and techniques available. It must be conducted
so as to -find answers and not to confirm preconceptions or established positions.
Only in this way will we achieve the goal to which all of us subscribe—an op-
timum air environment for all our citizens.
Mr. BROWX. Thank you very much, Dr. Pier. That was an excellent
statement, a very fine description of the research needs. I might say
that if we had a program adequate to do the job that you describe, it
probably would solve not only the problems you have in this area, but
those in Los Angeles as well.
Dr. PIER. It would be desirable, in that case.
Mr. BROWX. Well, I don't want to appear to be parochial; obviously
it would have widespread national implications. Mr. Wirth, do you
have questions?
Mr. WIRTH No.
Mr. BROWX. Mr. Eckhardt?
Mr. ECKHARDT. Doctor, I just was a little bit concerned about your
statement that we may be moving too fast. Do you think that we made a
mistake in taking the measures that have reduced total hydrocarbon
emission by about 40 percent ?
Dr. PIER. Xo; I don't think we made a mistake. The fundamental
question comes down to, what have we gotten for what we have spent?
I think that the element that we have to ask for is not how much hydro-
carbon or anything else we've pulled out of the atmosphere. The ques-
tion is, What improvement have we made in the quality of the air?
That, to me, is the important question. And the question therefore comes
down to, what have we gotten for what we have spent—and I don't
know what the total dollar amount is. The question is, Have we gotten
an improvement in the quality of the air, and the answer that has been
provided is "so far. no.'' We have spent a great deal of money and oxi-
dant episodes have not been significantly reduced. I think a more fun-
damental question is whether oxidant is the pollutant that we should be
going after. It is implicit in my statement that we have to know what
the health effects of oxidant are. That there are instances of eye irrita-
tion and certainly a rather cruddy-looking atmosphere in California is
incontrovertible. Do we have these here? So far we don't think so.
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important ingredient that we know about? Is it representative of the
total number of parties that are concerned ?
Dr. PIER. The secret ingredient is money. As has already been alluded
to, we have no sanction. We have no way of implementing a more
formal effort—we're all doing this, along with 20 or 30 other tilings. If
we did have some support, if we did have some capability to work
closely on—not on the day to day, certainly, but on a reasonable fre-
quency basis with EPA, which will take some kind of funding—I
think we could do an effective job.
Mr. BROWX. Alright. I thank you very much for your testimony, Dr.
Pier, and we will look forward to working with you in the future. Our
next witness will be a colleague of Dr. Pier's, Dr. Richard K. Severs,
also of the School of Public Health at the University of Texas. We
welcome you and look forward to your testimony.
Dr. SEVERS. Thank you. Chairman Brown, Congressmen, ladies and
gentlemen, I'd like to take the opportunity first to acknowledge the
work of this committee in connection with the Clean Air Act Amend-
ments of 1977. I think you are to be congratulated for getting a very
good set of amendments in a very difficult situation. I have a rather
long statement, so with your indulgence I'll paraphrase part of it and
try and skip the redundant sections.
Mr. BROWN. Without objection, the full text of the statement will be
included in the record at this point, and we would encourage you to
make whatever abstraction from it that you care to, Dr. Severs.
Dr. SEVERS. Thank you. I would like to describe the problem, its
effects, and possible strategies. The observed and measured differences
between the Houston and Los Angeles area environments have already
been alluded to many times, and they lead most of us locally to believe
that major regional differences do exist. Parallel measurements of
ozone and oxidants in this environment, conducted by three different
teams on three different occasions, indicated disagreement between
measurement techniques some of the time. This is also unlike the Los
Angeles experience, where such parallel measurements are said to agree
in both the laboratory and the field. The nonmethane hydrocarbon-
nitrogen oxides ratios are also different than in other re
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299
The most unique feature of the current Houston atmosphere will
soon come to an end. Ambient air measurements reveal a sulfate level
of 10-15 micrograms per cubic meter across the entire region, with few
manmade sources of sulfur oxide identifiable. In most regions, sulfates
are thought to be the result of conversion from SO2 from coal-fired
powerplants. Thus the Houston area has benefited from low SO2 con-
centrations, while we experience a sulfate level that ordinarily is
thought to be high. The probability that SOs will be introduced into
this Houston atmosphere in the future, with new energy sources, just
boggles the mind. The potential risk is vast for a population to suffer
the ill health effects associated with the mixture of the known air pol-
lutants that we have with our environmental stresses and then add
sulfur dioxide to it. It should make the London disaster of 1952 look
like a picnic.
The environmental degradation respects no manmade bound-
aries, as we've seen here. And in Harris County and the ship
channel area this fact is amplified as a problem in air pollution, since
we have a political problem of overlapping or adjacent jurisdiction of
air pollution control districts. Without the threat of Federal interven-
tion, the local programs, in my opinion, would not have had the success
they can claim in controlling emissions to the ambient airshed. Our
permit system for control of airborne emissions has been in effect since
1971 in Texas, but it only addresses the standard air pollutants. Haz-
ardous pollutants of small concentrations, like vinyl chloride or cad-
mium, are just not reported. Only by special case ambient air analysis
are they detected at all, and little is done with such data. However, the
technical capabilities of the State and local agencies are excellent.
and I think can easily be utilized with greater funding and Federal
guidelines.
In the effects area, the impact of the environment on Houston popu-
lation has not really been adequately assessed. The local health studies
have been short, incomplete, and inconclusive. It doesn't mean we
haven't done something, though. Significantly positive correlations
have been found between mortality rates and suspended particulate
levels, mortality rates and temperature and humidity, lower than
average lung function in older workers with heavy smoking experi-
ence that live in high suspended particulate zones. And we have
suggestions of significant correlations between ozone episodes and
decreased lung function in asthmatic school children. And yet to be ex-
plained are the higher than the annual average population mortality
rates for specific types of cancer, respiratory diseases and cardiovas-
cular diseases. Environmental factors are known to contribute to these
increased rates in other regions, but they have not been evaluated in
terms of the health impact on the Houston population. Awareness of
the citizens to the problems of the degraded environment is easily seen
by the growth of the affluent residential areas in the northwest. This
, area has more environmental amenities and less obvious pollution—air
or water—than any other part of the city. The flight of the middle
class from the eastern portion of the city represents the negative
aspect of this socioeconomic problem. The resultant dislocation of
people from job sites, increased highway burdens, and changing
neighborhoods are just part of the kaleidoscope of the socioeconomic
problems that have not been addressed but can be seen to already exist.
Clouds of haze can be seen developing in the petrochemical industrial
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area—if you're downtown in one of the high-rise buildings—which
then sweeps across the city. The aerosol size is so small that nothing
out of the ordinary is registered on the weight basis suspended par-
ticulate standard measurements.
However, it's often accompanied by noxious odors, and these com-
plaints are registered regularly with the Houston Pollution Control
Division. This is the cloud of haze that scares most of the citizens. Its
color, density, origin and smell make this haze highly suspect as a de-
terminant factor in the ill health suffered by Houston residents. The
adverse impacts of a deteriorating environment are difficult to calcu-
late or estimate with the current data bases most people have already
set. The area health plans produced by the local health systems agen-
cies may attempt such analyses in the future, since they include envi-
ronmental health as an integral part of any plan to decrease disease
rates and thus the cost of ill health care. However, it's a vety difficult
task.
What do we do ? From the foregoing, it can be seen that little is
known in depth about the Houston environment, including its atmos-
pheric characteristics or about any environmental impact on the
health of the community. Thus many questions are posed. The largest
is what needs to be done. Current control strategies are based on
knowledge being gained elsewhere, and the few facts known about the
Houston atmosphere indicate regional differences exist that may make
that knowledge useless or even detrimental when used as a basis for
control strategies in the gulf coast. Thus, we need research. Research
to characterize the environment, research to characterize the health
status of the population, research to delineate the social costs of the
polluted environment, and to anticipate regulatory needs and give
them a strong regionally based criteria for action. The Texas Air
Control Board has made excellent suggestions on the mechanisms nec-
essary to see that this research is done adequately. I'm not going to
repeat all of those research needs my colleagues have already empha-
sized—however, I would like to suggest some especially important
considerations.
Currently, the EPA health studies have looked at air pollution
alone, and I would suggest that we look at the total body burden of
pollutants—whether it comes from air, water or food—as the primary
basis for establishing ill health effects. I don't really believe we can
split the environment into air, and water and other components—we
have to look at it as a total environmental stress to the human body.
And in the same way, I would characterize the research that I suggest
for the atmosphere. We need to go back to base one. Currently, the
EPA research studies tend to concentrate on measurement of standard
pollutants that we already know cause ill health effects. Well, if you
get into a region like this where we have different problems, that may
not be the best approach. So I would suggest that we characterize the
how much of our aerosol is a wet aerosol, how much is a dry aerosol,
and so on. So I'd like to have an overall approach that's somewhat
different than is characteristic now of the research that's being sug-
gested. Now, research is expensive. And the limitations exist m the
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number of qualified individuals available to work on a project of the
magnitude indicated, as well as the funds available. So one of the
first steps needed is the establishment of a research priority list. Since
conflict is bound to occur when expenditures are involved, the mech-
anisms should be established to see that the interested parties all
have input. And I, too, believe that an informed citizens' liaison group
should be appointed to represent the interests of the community oeing
studied. These people representing not only their community but
factions within that community have a vested interest in the research
outcome—namely, they live in the community. This liaison commit-
tee should also have the benefit of a staff scientist. If the body is not
sanctioned by some political group, I don't believe it will be effective
at all.
Regional research is not a new concept. The uniqueness of the en-
vironment on a large scale has been recognized in the establishment
of watersheds, regionally planned districts, meteorologic zones, agri-
cultural land use and so on. So it's not surprising that we're seeing it
appear now as a research need in air pollution, indeed in the environ-
mental area. The mechanism for implementation of these results to
national ambient air quality standards is a very difficult one. I think
we certainly need to protect human health to the same necessary degree
in all regions. The concept of the national ambient air quality stand-
ard has to be maintained, and still allow for the concept of regional
differences. With different mixes of environmental stresses in each
region, however, this does present a problem. I really can't suggest a
solution to it, but I know we can't solve it by ignoring it. The total
body burdens of lead, for example, comes from an intake of air, water
and food, with air accounting for less than 10 percent of the average
intake. Well, the last effort to pass a standard for lead—where you
adopt a control strategy that only regulates air intake—is tantamount
to expecting the tail to wag the dog. You just can't have regulated 10
percent of a pollutant without doing something about the other 90
percent. So, in conclusion I'd like to suggest that the criteria and con-
trol strategies developed from this research must be part of a federally
orchestrated effort in which the differing agencies or divisions of
agencies with environmental responsibilities must work together in
order to achieve maximum meaningful and useful results. And I'd
like to see this represented in the approach that's a human ecological
approach in the biosphere.
[The prepared statement of Dr. Severs follows:]
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Testimony presented by invitation to the U. S.. House of Representative*
Committee on Science and Technology
November 21, 1977, Houston, Texas
STATEMENT OF RESEARCH NEEDS
by Richard Severs, Ph.D.
Associate Professor of Environmental Science
The University of Texas Health Science Center at Houston
Representing the-San Jacinto Lung Association
DESCRIPTION OF PROBLEM:
Observed and measured differences between the Houston and Los Angeles air en-
vironments lead local researchers to believe that major regional differences
exist. In the Houston area, high ozone values, e.g., 0.25 ppm hr, have been
recorded without an associated brown haze, plant damage, or eye irritation
complaints. This is most unlike the Los Angeles experience. Parallel mea-
surements of ozone and oxidant in the real environment, conducted by three
different teams on three different occasions, indicated a disagreement be-
tween measurement techniques some of the time (Appendix 1). This is also un-
like the Los Angeles experience where such parallel measurements are said to
agree in both the laboratory and field within experimental error. Non-methane
hydrocarbon-nitrogen oxides ratios are also different than other regions. The
non-methane hydrocarbon mix of the atmosphere has never been characterized
thoroughly over an extended time period. Background hydrocarbon levels differ.
The Houston haze has been noted by citizens and scientists alike. It occurs
frequently during the year and although it certainly has some components of a
Gulf Coast sea haze the associated odors indicate a more complex mixture.
f
Technically speaking, there is a large area located from downtown Houston to
Deer Park to the east, that is above the national primary ambient air quality
standard (NPAAQS). As far as I can tell from the ambient air quality data
this has been true since monitoring began in 1968 (Appendix 2). This area
combines a lower economic, mixed ethnic residential area with all classes of
industry. The Houston ship channel cuts through this non-attainment area.
Currently the entire region is classified as non-attainment for oxidants (mea-
sured as ozone). Yet a reduction of more than 50 percent in hydrocarbon emis-
sion inventories has not favorably changed the frequency or concentration of
ozone excursions above the NAAQS. The presence of the huge petrochemical in-
dustrial complex compounds the problem due to its complex organic emissions.
However, the ozone levels have been seen to rise and fall simultaneously
across huge areas of the state indicating this is a regional ozone problem as
well as a point source emission problem.
The most unique feature of the current Houston atmosphere will soon come to
an end. Ambient air measurements reveal a sulfate level of 10 to IS Ug/m1
across the entire region with no man-made source of sulfur dioxide (SOj) iden-
tifiable. In most regions sulfates are thought to be the result of conversion
from SO2 from coal fired power plants; thus the Houston area has benefited
from SO: concentrations below the secondary ambient air quality standard while
experiencing a sulfate level thought by some experts to be associated with
ill-health effects to the population. The probability that SOj will be intro-
duced into the Houston atmosphere in the future for the sake of new energy
sources boggles the mind. The potential risk is vast for a population to suf-
fer ill-health effects associated with a mixture of the known air pollutants
and environmental stresses (small suspended aerosols, ozone, relative humidity,
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and temperature) with sulfur dioxide. The resultant mixture presents a
potentially disastrous situation for asthmatics, cardiovascular patients
and respiratory patients and older people in general.
Environmental degradation respects no man-made boundaries. And in Harris
County, in the ship channel area, this fact is amplified as a problem in air
pollution since there exists a political problem of overlapping or adjacent
jurisdiction of air pollution control districts. Without the threat of fed-
eral intervention the local programs, in my opinion, would not have had the
success they can claim in controlling emissions to the ambient air shed. The
permit system for control of air borne emissions has been in effect since
1971 in Texas but only addresses the standard air pollutants. Hazardous pol-
lutants of small concentrations are not reported. Only by special case am-
bient air analyses are they detected at all and little is done with such
data. However, the technical capabilities of the state and local agencies
are excellent and can easi'y be utilized with greater funding and federal
guidelines.
EFFECTS
The impact of the environment on Houston's population has not been assessed.
Local health studies have been short, incomplete, and inconclusive, signifi-
cant, positive correlations have been found between mortality rates and sus-
pended particulate levels, mortality rates and temperature and humidity, lower
than average lung function in older workers with heavy smoking experience and
suspended particulate levels, and suggestions of significant correlations be-
tween ozone episodes and decreased lung function in asthmatic children. Yet
to be1 explained are the higher than annual average population mortality rates
for specific types of cancer, respiratory diseases, and cardiovascular classes.
Environmental factors are known to contribute to these increased rates in
other regions, but these factors have not been evaluated in terms of their
health impact on the morbidity rates jn Houston.
respiratory
A central/disease registry doesn't exist in Houston, Harris County, or Texas.
The existence of such a registry would help enormously in the conduct of epi-
demiological morbidity studies that are needed to delineate the role air pol-
lution may play in the community disease patterns.
Awareness of the citizens to the problems of a degraded environment can easily
'be seen by the growth of the affluent residential areas in the northwest.
This area has more environmental amenities and less obvious pollution, air or
water, than any other quadrant of the city. The flight of the middle class
from the eastern portion of the city represents the negative aspect of this
socio-economic problem. The resultant dislocation of people from job sites,
increased highway burdens, and changing neighborhoods are just part of a
kaleidoscope of socio-economic problems that have not been addressed but can
be seen to already exist. Decreases in visibility are believed due, in part,
to atmospheric aerosol growth due to air pollution. Clouds of haze can be
seen developing in the petrochemical industrial area which then sweep across
the city. The aerosol size is small so that nothing out of the ordinary is
registered on the weight based suspended particulate standard measurements.
It is often accompanied by noxious odors. Odor complaints are registered
regularly with the Houston Pollution Control Division. This is the cloud of
haze1 that scares most citizens. Its color, density, origin, and smell make
this haze highly suspect as a determinate factor in the ill-health suffered
by Houston residents.
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The adverse impacts of a deteriorating environment are difficult to calculate
or estimate with the current data base. Such benefit-cost analyses done else-
where have produced gross estimates never validated. Area health plans pro-
duced by local HSAs may attempt such analyses in the future since they include
environmental health as an integral part of any plan to decrease disease rates
and thus the cost.of ill-health care. Currently it is thought that prevention
of disease due to environmental control is analogous to that which occurred
with the reduction of infectious disease rates when environmental control mea-
sures were instituted.
STRATEGIES
From the above sections entitled "Description" and "Effects" it can be seen
that little is known in depth about the Houston environment, including its at-
mospheric characteristics or about any environmental impact on the health of
the community. Thus many questions are posed in this regard, the largest of
which is what needs to be -.one. Currently control strategies are based on
knowledge gained elsewheri. The few facts known about the Houston atmosphere
indicate regional differences exist that may make that knowledge useless or
even detrimental when used as a basis for control strategies on the Gulf Coast.
Thus we need research—research to characterize the environment, research to
characterize the health status of the population, research to delineate the
social costs of a polluted environment, research to anticipate regulatory
needs and give them a strong regionally based criteria for action.
Research needs that both I, as a professional, and tht San Jacinto Lung Asso-
ciation, as an organization, see to be necessary and sufficient follow. Each
could be justified in depth but this seems to be the proper place for just an
indication of our interests. These are not listed by priority, only classi-
fied into three groups.
Health Effects Studies
1. Health studies should include other stresses besides those of air
pollutants. These should include socio-economic factors, ethnic considera-
tions, occupational stresses, past history of disease for several generations,
ir> vivo data on expected physical or pathological changes, and environmental
factors which are known to have an effect on people at any reactant level from
behavioral to mortality.
2. Study mortality data longitudinally, retrospectively at several
levels of sophistication. Follow any plausible clues even further.
3. Conduct prospective epidemiological studies:
a. Survey lung function of school children in different parts of
the city simultaneously. Also in vivo parameters if possible.
b. Evaluate and delineate areal distribution of disease related
to or aggravated by air pollution. Areal correlations inter-
and intra-city are needed in the same meteorological zone.
c. Conduct panel studies with sensitives and biologically important
personal monitoring. Dust and pollen badges, atmospheric acid-
ity, respirable particles, and oxidation potential all should
be considered.
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4. Collect morbidity data from all existing sources: cancer registry,
hospital admissions, clinics, etc., in order to determine what data are avail-
able or needed.
5, Develop new criteria for the role of specific environmental deter-
minants and their-impact on human health. These should include polynuclear
aromatics, cadmium, radioactive isotopes, and other elements mentioned in the
Clean Air Act Amendments of 1977. But they should be studied as part of human
ecology in the context of the biosphere and not limited to their role as air
pollutants. Thus total body dose should be assessed in each study delineating
the role of pollutants in impacting human health.
Atmospheric Air Quality Characteristics
1. The natural background level of pollutants needs to be determined:
specifically, THC, NMHC levels to the NW and SE of Houston on an annual basis.
Terpenes and other classes of organics including polycyclics need to be evalu-
ated and quantified as to the gross amount as needed in emission inventories.
'. 2. Determine the chief constituents of the fine size respirable aero-
sols. Are the liquid aerosols organic, polycyclic, paraffins?
3. Determine the surface activity of the fine size respirable suspended
particulates. Further, if they are active under what conditions—solar cataly-
sis? What conversions take place? What adsorption-desorption takes place?
4. Determine the fraction of respirable suspended aerosols that is
liquid. Identify possible sources—theoretical, secondary reaction products
as well as known point source emission.
5. Determine the physical characteristics of the aerosols of interest,
and how they affect total atmospheric properties.
6. Conduct an areawide survey to determine the most hazardous areas
with regard to both liquid and solid suspended aerosol concentrations.
7. Investigate reported differences in oxidant/ozone measurement re-
sults.
8. What oxidant concentration exists other than ozone in the Houston
area?
9. What are the chemical properties of the total ambient atmosphere?
10. >ionitor unusual atmospheric characteristics vital to physiology
during health studies: acidity, potential E, +/- ion pair ratio, hygroscopic
properties of aerosols.
Environmental Health Planning
Risk-benefit analyses should precede any proposed action. These guidelines
should be followed:
1. In every environmental and health assessment, the risk or effects
(biological and economic) of a given action should be weighed against the
risk or effects of not taking action.
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2. All risks or effects should be expressed in terras of changes that
would be produced in our existing state.
3. In all estimates of risk or effects, there should be a -:lear state-
ment of the uncertainties that pertain to the assessment to be u:>ed in deci-
sion makiny (proposed by C. Comar, Science 198(4317)s567, 1977). With the
data generated from the first two classifications and risk-benefit analyses
included in environmental health planning at every decision-making level, a
mis-use of newly generated criteria for environmental standard setting would
be avoided.
Research is expensive and limitations exist in the number of qualified individ-
uals required to work in a project of the magnitude indicated. So one of the
first steps needed is the establishment of a research priority list. Conflict
is bound to occur when expenditures are involved, so a mechanism should be es-
tablished to see that the interested parties all have an input. I believe
that an informed citizens' liaison group should be appointed to represent all
the interests of the community being studied. These people, representing not
only their community but factions within that community, each have a vested in-
terest in the research outcome. This liaison committee should meet with the
funding agency and major researchers (contractors or government scientists)
and review the goals and objectives of each piece of proposed research. This
committee could point out the need for specific research projects as perceived
by the community, take part in the priority setting process, suggest mid-term
project corrections through review procedures, and have as a court of last re-
sort the new National Commission on Air Quality. The later group should be
arbitrator since the EPA Administrator has ostensibly agreed to the position
of his scientists by the time such difficulty would have arisen. Above all
the group should be sanctioned by some political body.
Regional research is not a new concept. The uniqueness of the environment on
a large scale has been recognized in the establishment of watersheds, regional
planning districts, meteorological zones, and agricultural land use. Demog-
raphy uses the concept in its organizational makeup. Economically much is
being said about sun belt vs snow belt policies. So the idea of regional dif-
ferences permeates the social, economic, and environmental sciences. It is
not surprising that the need for regional research finally has surfaced.
The concept of national ambient air quality standards must be maintained and
still allow for the concept of regional differences. Every community should
have the right to the same amount of public health protection. With differ-
ent mixes of environmental stressors in each region this does indeed present
a complex problem, but it can't be solved by ignoring it. Total body burden
of lead, for example, comes from an intake of air, water, and food with air
accounting for less than 10 percent of the average intake. To adopt a control
strategy that only regulates air intake is tantamount to expecting the tail to
wag the dog. Criteria and control strategics development must be part of a
federally orchestrated effort in which the differing agencies or divisions of
agencies with environmental responsibilities must work in a concerted effort
in order to achieve maximum meaningful and useful results. This represents the
approach in terms of human ecology.
The mechanism for implementation of these results to yield NAAQS's which are
fair to each region economically, socially, and protect human health to the
same necessary degree is beyond the scope of our understanding. Thus we
propose it as another research area.
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SUMMARY
The San Jacinto Lung Association, a voluntary agency serving 12 counties,
and I, personally, believe the impact of environmental stresses to be an im-
portant determinant on the health state of the local population. This is a
regional situation with unique environmental components that cannot be as-
sessed elsewhere. The potential for a local air pollution disaster due to
forced coal conversion as an energy source, mandated under new legislation
which now exists, desperately needed a risk-benefit analysis before such
decisions were made and serves as an example of this need across tfie board.
Research needs are paramount with input and liaison with local interests
served by new liaison mechanisms. Determination of atmospheric characteris-
tics, interaction with other environmental stresses, of the role the local
environment plays in the health state of the community, are all necessary be-
fore environmental health ilanning and control strategies can be conceived.
Risk-benefit analyses of c mteir.plated actions should be undertaken before
each action. We believe that using this human ecology approach to the prob-
lem of protecting the public from environmental stresses which produce ill-
h^alth will yield the most results for the least effort and still yield data
effective for control strategies and ultimately reduce morbidity and mortal-
ity rates of environmentally influenced diseases.
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APPENDIX 1: SELECTED REFERENCES
Severs, Richard, "Problems in sampling atmospheres." Chemosphere (accepted,
11/77).
Severs, R.K., R.M. Neal, and T.D. Downs, "Tine as a factor in atmospheric
sampling." American Ind. Hyq. Assoc. J. 38, March 1977.
Neal, R., and R. Severs, "Simultaneous cheniluminescent ozone and KI oxidant
measurements in Houston, Texas, 197S." Proceedings of specialty con-
ference on: Ozone/Oxidants-Interactions with the Total Environment.
APCA, Dallas, Texas, March 1976.
Severs, R.K., "The oxidant controversy." Chemosphere 6:345-355, 1975.
«
Severs, R.K., "Simultaneous total oxidant and cherailuminescent ozone mea-
surements in ambient air." Air Poll. Control 3. 25(4);394-396, 1975.
Severs, R.K., "Air pollution and health." Texas Rep. Biol. Hed. 33:1, 1975.
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APPENDIX 2; HOUSTON AREA SUSPENDED PARTICULATE LEVELS
Figure 1. Distribution of Suspended Particulates in Houston
Annual Geometric Mean, 1976.
Figure 2. Distribution of Suspended Particulates in Houston
Annual Geometric Mean, 1973.
Figure 3. Distribution of Suspended Particulates in Houston
Anifaul Arithmetic Mean,- 1969.
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Mr. BROWN. Thank you very much, Dr. Severs. I think your stress
on the kind of research that's needed here is extremely important. Txiat
emphasis is all too often neglected because of the way in which Con-
gress has written the laws, for one thing, and sometimes because c.
the way the scientific process itself works, which tends to function on
a small part of something rather than looking at the total effects. Mr.
Wirth, do you have any questions ?
Mr. WIRTH. Yes. As our energy plans seem to project we move into
the burning of coal, and as you suggest in your paper as well, we're
going to end up with all kinds of new compounds, right?
Dr. SEVERS. Kight.
Mr. WIRTH. And that is what you're pointing out as a great, great
concern down the line for Houston, correct \
Dr. SEVERS. My great concern is with the small particulate load,
which will come out of the coal-fired power plants and the S02 addi-
tion to the air. In this environment we already have the humidity and
in February, January, we have the same kind of meterological condi-
tions that existed in London during their disasters. We haven't had
the SO2 and we haven't had the small aerosols, so we haven't had the
problems. What I'm suggesting is that in the future, if we're not very,
very careful and if we don't write standards for small particulates,
by number rather than weight, we're going to have a problem.
Mr. WIRTH. Now, a big piece contributing to this are the hydro-
carbons, right?
Dr. SEVERS. The hydrocarbons present a different kind of problem
to me. They're the lead—well, I don't know where they lead to. Pre-
sumably, we're looking at carcinogens. We may be looking at aggrava-
tors of other health effects. But in terms of the acute problem, no.
Mr. WIRTH. The hydrocarbons are not—down the line, isn't there
the potential of the hydrocarbons combining with the sulfates ?>
Dr. SEVERS. Certainly. But I don't know what the resultant action
would be. I don't know what the result would be of that. It may indeed
be a detrimental aspect, but I haven't done the research to say what
this would be.
Mr. WIRTH. I'm just trying to get at—it seems to me if we in Hous-
ton had not been removing a lot of these hydrocarbons now we'd po-
tentially have or have the potential of even deeper problems down
the line with the conversion of coal if we had up there not the reduc-
tion of 40 percent of whatever it has been but had a level of 100 per-
cent and added all of the emissions from our coal conversion program
that we would have accelerated rather than at least trying to hold a
bit of a line.
Dr. SEVERS. Certainly there's a synergism in the environment that's
going to cause more and more problems as we have more and more
pollutants. And unlike some of the other previous speakers I believe
we've done a very good thing to remove the amount of hydrocarbons
from the atmosphere we have. If we are going to control the oxidant
problem at all, eventually that had to come out. Now, we may also have
to control oxides of nitrogen as well, and I'm sorry we haven't begun
doing that. But I think that the action we've taken up to now has
been a wise one. It was necessary; I think it's necessary to go further.
Mr. WIRTH. I guess that's what I was trying to get at, that I've been
a little bit surprised at the criticism of the strategy to try to remove
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as many hydrocarbons as have been removed, and it seems to me that
all the evidence, at least that I have seen in my time in the Congress,
is that that probably is going to be a positive contribution toward the
maintenance of the public health.
Dr. SEVERS. I think it certainly will be in the future. I think what
you've been hearing is the frustration of seeing this removed at an
enormous cost without seeing any effects yet. Well, I view that as be-
ing necessary at this point, and we have to go further along with the
oxides of nitrogen removal. When the two of them together have been
accomplished, I think we may see some results.
Mr. WIRTH. And that's when, hopefully, we'll get a new coalition
that'll be able to go after all of the wonderful people in Detroit that
bring us a lot of the oxides of nitrogen, right 'I
Dr. SEVERS. Well, I noticed in the new Clean Air Act Amendments
that you certainly put a lot of emphasis on the study of oxides of nitro-
gen and their effects.
Mr. WIRTH. Unfortunately, there was more emphasis on studying
it than there was on removing it.
Dr. SEVERS. We have a little problem there.
Mr. WIRTH. Thank you, Mr. Chairman.
Mr. BROWN-. Mr. Eckhardt?
Mr. ECKHARDT. I have no questions.
Mr. BROWN*. Mr. Gainmage?
Mr. GAMMAGE. No questions.
Mr. BROWN. May I ask you just one further question? Are you able
to characterize the state of the technology with regard to the measure-
ment of the small aerosols, the respirable particulates ?
Dr. SEVERS. They're very expensive to measure—that's one of the
problems. The equipment is available, but each individual instrument
costs thousands of dollars. So it's been mainly a research effort, and
control agencies have not, as a rule, measured the concentration of
small particulates in the atmosphere.
Mr. BROWN. This committee has been very much concerned about
the general situation with regard to monitoring technology, and pre-
vious investigations of the subcommittee have indicated that it is de-
ficient in a number of particulars and in this area the difficulties are
particularly great.
Dr. SEVERS. Yes, they are. It is a very difficult problem. Particularly
if you're looking at the total aerosol composition.
Mr. BROWN. Well, we thank you very much for your contribution,
Dr. Severe.
Dr. SEVERS. Thank you for the opportunity.
Mr. BROWN. We understand that Senator Bentsen is here and in
deference to his schedule we wanted to allow him to make a brief
statement at this time. We would like to take him at this time, before
going to our next witness this morning. Senator, we welcome you here
this morning; your timing is absolutely perfect. We invite you to take
the podium and give us the benefit of your statement. It's a pleasiire
having you. We welcome Senator Bentsen, who is very much concerned
about this general problem of air pollution in the- area, and whose
suggestions as to the way to approach it, I'm sure, will be very helpful
and valuable to the subcommittee. Senator Bentsen.
Mr. BEXTSEN. Mr. Chairman, I want to welcome you and the dis-
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tinguished members of this committee, and congratulate you for ?
interest you have shown in these environmental problems. Texans hu
always told you that they were unique, and in this instance we remain
so. But unfortunately, under these conditions, we're not particularly
proud of the problem. We have made great strides in Houston along
the Gulf Coast area in cutting back on the emission of hydrocarbons,
and yet we've seen smog increase. What appears to work for New York
and California and other parts of the country just doesn't seem to
work for us. So that's why I was delighted to join with Congressmen
Eckhardt, Gammage, and with you, Mr. Chairman, in fighting on the
other side—on the Senate side—to get through the Bentsen amend-
ment, the $3 million in authorizations, and to help with the $1 million
in appropriations. Several months ago, when the Senate was consider-
ing the Clean Air Act, I made the case before the Environment and
Public Works Committee, of which I am a member, for trying to de-
velop a study for the Gulf Coast area.
I did so because I had very serious concerns that the control strategies
being used by the Environmental Protection Agency would not be
effective in relating to the health and visibility problems we have in
Houston and other gulf coast cities. This region has a combination
of environmental and technological features which do not necessarily
lend themselves to the control strategies being employed in other
parts of the country. With our level terrain, a highly concentrated
petrochemical complex, persistently high humidity and the added com-
plication of salt from gulf coast air, it is my view, and the view of
the Texas Air Quality Board, that it is wasteful and unwise to tie
ourselves to an inflexible control strategy, without a thorough investi-
gation of the features of the gulf coast region. In other words, we
have to know what we're confronted with before we know how to
apply our full energies to clean it up. Anyone who's been in Houston
for a period of time knows that our air pollution is severe. I wish
you could have been here last week, Mr. Chairman, to see what we
are confronted with. And the monitoring data bears that out. When
considering oxidants—thought to be the major component of photo-
chemical smog—Houston's readings are typically three to four times
the national standard, and among the Nation's worst.
Sure, Houston is a driving and a dynamic city—one of the fastest
growing areas of the Nation. Just 17 years ago. in 1960, the population
of the Houston metropolitan area was 1.4 million. Today it's approxi-
mately 2.5 million, and by 1985 we'll have another 800,000 people here.
And in the midst of all of that growth, we're proud of our efforts to
clean up both water and air. The Houston ship channel, not many years
ago. was just a river of waste. It was one of the few bodies of water in
the United States that deserved an octane rating. Now it's coming back.
You see fish swimming upstream in the Houston ship channel. From
1971 to 1976 the Texas Air Board reported an 85 percent reduction in
hydrocarbon emissions from stationary sources, a 60 percent, reduction
from all stationary sources, and a 43 percent net reduction in all hydro-
carbon emission sources. Yet despite these major efforts, we have been
confounded in our effort to reduce overall oxidant levels. EPA has
long insisted that these levels are to be determined by measuring
ozone and by rigid control of hydrocarbons, and tied itself to a con-
trol strategy that's had little effect in grappling with the specific air
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pollution problems in the Houston area. There are many—and I in-
clude myself among them—who are not convinced that this strategy
will ever succeed.
In Houston, data from the Texas Air Control Board indicates that
even eliminating the hydrocarbon emissions from all automobiles—
that is, if they all stopped out here at Eagle Lake or Arcola, on the
city limits of this town and all the people walked to work—we would
not meet the oxidant standards. Or on the other hand, if we closed
down all the factories, told the workers there were no jobs left in
Houston and sent them home, we again would not meet the oxidant
standard. Yet that strategy remains inflexible, and the people of
Houston continue to suffer. We believe there must be better ways to
meet this problem. In the first place, we want to see a thorough exami-
nation of the sources of Houston's pollution—and that includes not
just a measurement of ozone, which is an inexact and a controversial
process, but also a look at the aerosols, at the sources of the small
particles found in Houston's air. We want to know about those parti-
cles which affect visibility, and those which affect health. And we want
to know if there are possible ways to reduce the incidence of both.
And also, at some point during the final stages of the study, we want
to know whether the total EPA policy for oxidant control should
apply along the gulf coast, or whether we would do well to explore
new, more innovative methods. Now, that's a tall order for such a study,
but I'm convinced that the people of this region, in cooperation with
EPA, can arrive at the proper answers.
That brings me to my final point: the structure of the study itself.
For the people of Houston to have confidence that this will be a care-
ful review of Houston's air problems, it's crucial for EPA to work
actively with the groups in this region who are qualified to assist, and
who have a deep concern and a substantial knowledge about the prob-
lem. A liaison committee has been established, headed by Dr. Stanley
Pier, of the University of Texas School of Public Health, to work
with EPA on the study. Dr. Pier's committee consists of representa-
tives of the Harris County Medical Society, the San Jacinto Lung
Association, the Houston Health Department, the Houston Area Oxi-
dant Study, the Texas Air Control Board, and others. It's a responsi-
ble group, created not to compete with EPA but to cooperate with it.
Much of the success of this endeavor will depend on the working rela-
tionship that's established between this committee and the EPA offi-
cials, and I want to strongly urge that a spirit of cooperation be estab-
lished early and maintained through the course of this studv. This is
not and should not develop into an adversary relationship. I am con-
fident that this process will succeed. It has a broad level of support
at the local level and a substantial promise of assistance from the
Federal Government. It is a timely study, coming shortly after the
passage of the comprehensive Clean Air Act Amendments. Further,
it directs air pollution research funds to an area of the country that
has long been shortchanged in the distribution of these funds.
Once again, Mr. Chairman, I'm delighted to be with you. I appre-
ciate your real concern for the problems of this gulf coast area and am
pleased to sec. my distinguished colleagues, Congressman Gammage
and Congressman Eckhardt, join with you in this effort.
Mr. BROWN. I want to thank you very much, Senator, for your con-
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tribution. There's nothing that helps to establish the fact of the hig.
priority which the citizens of Texas attribute to this problem than
to have you here this morning and to have you make the kind of state-
ment that you've made. I know that much of the research on atmos-
pheric air pollution has historically stemmed from the problems of
the Southern California Air Basin. I don't like to see the competition
between California and Texas extended to that kind of problem,
but I am personally convinced that by using the example of the Hous-
ton area, together with the resources of the Houston area, we can
make a contribution to the solution not only of Houston's problems
but California and the nation's problems. And I would like to see
that kind of cooperation between your citizens in this area and the
EPA and others concerned with the problem.
Mr. BENTSEN. Mr. Chairman, let me say, when much of the Wash-
ington press is commenting today about Congressmen junketing
around the country, and around the world, I'm delighted to see this
delegation down here, seriously at work, concerned about a major
problem of the Nation, and dedicating their efforts to try to work
toward its solution.
Mr. BROWN. Thank you very much. Does any member of the com-
mittee have any questions they'd like to ask the Senator?
Mr. WIRTH. I just had a comment, if I might, Mr. Chairman. I real-
ly appreciate being here from the perspective of Denver. We're at
a population figure now where you were in 1960, and growing at that
same kind of a rate. We have our own unique kind of air pollution
problems in Denver, where Chairman Brown happily brought the
subcommittee last week. We were examining Denver's problems, so
we've got to stick together on this. I appreciate your being here,
Senator.
Mr. BROWN. Thank you very much. Senator, we appreciate it. Our
next witness this morning will be Mr. Ray Lozano, who is director
of the Air and Hazardous Materials Division of EPA, and we're
very pleased to have Mr. Lozano here. It seems to me there's been
a remarkable demonstration of unanimity of viewpoint on the impor-
tance of this problem, which I'm sure Mr. Lozano shares, and it may.
be that we're further along toward achieving a structure of organiza-
tion to meet this need than we had thought. You may proceed, Mr.
Lozano, and the full text of your statement will be made a part of
the record at this point, if you feel a desire or need to summarize
any portion of it.
Mr. LOZANO. Thank you very much, Mr. Chairman, members of the
committee. It's going to be a tough act to follow, Senator Bentsen
speaks so eloquently.
Thank you for the opportunity to testify at this hearing. Before I
present my statement I would like to introduce a few fellows that are
in the audience that represent our headquarters office of EPA and
also some representatives from Research Triangle Park. Dr. Basil
Dimitriades is in the second row, from Research Triangle Park En-
vironmental Sciences Research Laboratory, and Dr. Carl Hayes of our
Office of Health Effects at RTF and MiC Stan Blacker, who's in the
rear, from our Office of Research and Development in Washington.
Mr. BROWN. We're very pleased to see these gentlemen here this
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morning. I'm sure it will contribute to the effectiveness of communicat-
ing the input from the hearing to have them here listening to the
proceedings.
Mr. LOZANO. That's exactly why I invited them.
[The prepared statement of Mr. Lozano follows:]
STATEMENT OF Ma. ELOY K. LOZANO, DIRECTOR, AIB AND HAZARDOUS MATERIALS
DIVISION, ENVIRONMENTAL PROTECTION AGENCY, REGION VI
CURRENT AIB QUALITY PROBLEMS IN HOUSTON
Houston has for many years had air pollution problems which include haze,
high levels of photochemical oxidants and particulates, and odors. These prob-
lems are not unique to Houston, but are typical of several industrialized Golf
Coast areas including Corpus Christ!, Beaumont/Port Arthur, and parts of
Louisiana, in this region. The problems in Houston are most pronounced
due to the greatest concentration of industry and people along the Gulf Coast
These problems originate primarily with emissions from the high concentration
of petroleum and petrochemical industry in the area and to a lesser degree
with automobiles. In addition, the warm humid climate is another contributing
factor, we believe particularly that of haze.
Through local, State and EPA efforts, there has been significant abatement of
emissions in the Houston area. Abatement efforts have thus far been directed to
hydrocarbons (to control oxidants) and particulates, since these are the estab-
lished air quality standards which are being exceeded In Houston.
However, due to growth in the area, more and better air quality data, and
for other yet unidentifiable reasons, air quality does not appear to be greatly
improved. I say "appear" since it is questionable whether or not there is enough
data taken over a sufficiently long time period to really establish a trend. At
any rate there are still frequent violations of the oxidant standard (up to two
to three times the standard) and the haze continues to persist. For the record
I am including with my statement copies of the EPA document EPA 906/9-76-
001 "Technical Support Document, Hydrocarbon/Photochemical Oxidant Control
Strategy for the State of Texas" and a copy of the July 21, 1977 EPA regulations
promulgated for Houston and other Texas cities which describe the Texas
oxidant/hydrocarbon problem and the control measures pursued thus far by
EPA. These measures included extension of existing TACB Regulation V, con-
trol of evaporative losses from the filling of gasoline storage vessels in the
Houston, San Antonio, and Dallas/Ft Worth areas, the control of evaporative
losses from storage vessels for crude petroleum in certain counties, an incen-
tive program to reduce vehicle emissions through increased bus and carpool
use, an employer mass transit and carpool incentive program, and a transpor-
tation mode trends monitoring regulation.
We believe all of these regulations that have been promulgated for the Houston
area to be reasonable and will contribute to reduction of the oxidant problem.
As recognized by the 1977 amendments the standards have not been attained
and additional measures will be required. In the case of photochemical oxidants
the standard of 0.08 ppm may well not be attainable in Houston, but, even if
this is the case, additional controls are needed to keep the situation from getting
any worse and to reduce the severity and frequency of violations.
We still maintain that hydrocarbon reduction will eventually lead to the
reduction of oxidants. There's just an overwhelming amount of evidence that
the two are definitely related—maybe not on a one-to-one basis, such that we
can see immediate improvements—but we still maintain that the oxidant problem
is here and it will be controlled through hydrocarbon controls.
RESEARCH EFFORTS
While much air pollution health effects research work has been conducted
in other parts of the Nation, admittedly little has been specifically accomplished
by EPA in the Houston area. The Houston Area Oxidant Study is developing
additional information and we are very much interested in that effort and
have kept abreast of their efforts in order to coordinate our ongoing research
activities.
We do have information and are gathering more on the health effects of oxi-
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dants and the more we look, the more the 0.08 ppm health standard is substa,
tiated. I believe that a recent draft summary statement from the advisory pane»
on health effects of photochemical oxidants summarizes the status on oxidant
health effects as well as any document I've seen and I'd like to read a summary
paragraph from that document as follows:
"In reviewing the body of evidence on health effects, the health panel con-
cluded that there is no compelling reason to suggest a change from the concen-
tration defined by the existing primary air quality standard, namely 0.08 ppm.
This conclusion was based upon the previously cited panel consensus that a
variety of adverse effects are likely to occur in some segments of the popula-
tion from short-term ozone exposures of 0.15 to 0.25 ppm, and upon other evi-
dence that suggests, though less conclusively, the possibility of effects at con-
centrations as low as 0.10 ppm. The Panel recognized that this standard pro-
vides very little margin of safety, for the reasons cited immediately above."
I am including a copy of the entire document with my statement, since this
subject is of great interest in the Houston area. Of course, the air quality stand-
ard for photochemical oxidants is still being reviewed, as required, by the Ad-
ministrator of the EPA, and a decision on whether to revise the standard will
be made at a later time.
Another area of concern is the health effect of aerosols and fine partlculates.
There have been some EPA studies conducted, but much more is needed as
pointed out by the Texas Air Control Board and others here today and as recog-
nized by the requirements of Section 403(d) of the 1977 Clean Air Act Amend-
ments. At present there is $1,000,000 of EPA Research and Development money
for FY 78 allocated for the Gulf Coast Study. This amount may be expanded to as
much as $3 million, and it is my understanding that this may come about soon
through the appropriations from Congress. A technical liaison committee has been
formed and is made up of a cross-section of representatives from the Houston
area, the Texas Air Control Board, and myself as an ex officio member. We met
on October 19, 1977 to discuss air pollution research needs for the Houston area
and I have included with my statement a copy of the minutes of that meeting,
which I moderated. There was a concensus of the committee that EPA's initial
research efforts should be directed at:
1. Determining the impact of aerosols (fine partlculates) on health effects;
2. Defining the sources of these aerosols, and to what extent these are na-
tural or anthropogenic, or primary or secondary sources;
3. Developing improved techniques to collect/measure aerosols; and that the
first health effects undertaking should be to;
4. Develop a health effects surveillance system for the area. This system should
be aimed at defining the extent of the air pollutant related health effects and
what are the appropriate health indicators (associated with air pollution) of
these effects.
Another thing that came out at that meeting, and I didn't include it with my
statement and I should have—it's in the minutes of the meeting—was that the
Citizens Clean Air Coalition seemed to think that the EPA was not doing enough
in the chronic effects of air pollution area, and I think that that was an im-
portant statement. Our reply at the time of the meeting was that there's cer-
tainly a need to look into that area but it's quite costly to look at chronic effects
and on the short-term perhaps not the best way to go.
To me, one of the most significant items to result from these discussions was
the consensus that prior to Initiating any air pollution research studies, in Hous-
ton that EPA should develop an overall research plan for the Houston area. It
is my understanding that our office of Research and Development is well on its
way to accomplishing this prior to initiating any of the other proposed studies
for the area.
I can assure you that EPA is listening to the comments that were made that
day and to the comments of the committee that was formed. County Judge Lind-
say asked for an official, some sort of official sanction and I personally intend
to look into this possibility either with our people from Washington or perhaps
with the regional office, but I intend to investigate it in some way.
As this research effort proceeds, other specific projects will be identified, but
I think this is n good start.
This concludes my remarks. Thank you.
Mr. BROWN. Thank you very much, Mr. Lozano, for your excellent
statement and the additional materials which you have submitted.
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There's a very strong theme underlying the testimony we've had here
this morning—the importance and need for some local input to the
structuring and conduct of any research activities that take place
here and the Gulf Coast Air Pollution Research Committee has been
suggested as a mechaiiism for doing that. Do you think that you per-
sonally or the EPA has any problem with this idea of having an ade-
quate local advisory input to research programs addressing a local
problem ?
Mr. LOZANO. None whatsoever. I think that we encourage it, and I
personally was very pleased that the committee had the makeup that
it did and that it kind of represents a cross section of the entire Hous-
ton community—we have representatives there from industry, from
the community, from the citizens' groups, the regulatory agencies, the
health association—I think that we're very much encouraged by that
and will listen to them very intently in the development of any re-
search plans that we have for our area.
Mr. BROWN. Now, with regard to the overall adequacy of EPA's
research program in the Houston area—and I'm not in any way trying
to imply criticism, because I am as aware as almost anyone of the con-
straints that exist on all of EPA's programs—do you feel that there
has been a substantial amount of EPA research directed at those as-
pects of the local problems that are distinctive or unique ? Is there any
component of the research that would characterize those features of
Houston's problem ?
Mr. LOZANO. I think that the major emphasis of our agency in its
research efforts has been towards studying the health effects or the
transport—other air pollution related type of activities—concerned
with the national air quality standards. Those pollutants that have
been thought to be nationwide problems and that were first identified
by the agency as a result of the original Clean Air Act, the Clean
Air Act of 1970. Most of the effort that has been done across the coun-
try has been aimed at those particular pollutants. That's not to say
that there haven't been some projects—a few projects—that were aimed
at other things, such as carcinogens and diesel exhaust and things like
this that were not really aimed specifically at the air quality standards
or the criteria pollutants, but that has been the emphasis. Here in
the Houston area, there very well may be some additional compounds
in the air that we have not looked at—that we're not aware of, and
maybe that's the area that we should concentrate on in the near future.
These are the things that we need to look at. The relationship between
hydrocarbons and oxidants is a controversial one; it's been around for
some time, and we've been studying that aspect, some here in the Hous-
ton area, some, in other parts of the country. But these other pollut-
ants—the more exotic pollutants, if you might call them this—have
not been looked at much in Houston, and I think that perhaps they
should be.
Mr. BROWN. What about some of the nonexotic pollutants like the
potential for a 2,400 percent increase in SO2 over the next, say, 15 or
20 years as a result of combustion of coal and lignite. Is there any
prospective analysis been made on this kind of a situation ?
Mr. LOZAXO. I'm aware that some studies have been conducted, on
paper, by our energy office, of the projections on the amount of sulfur
emissions, the increased amounts that will occur in areas like Houston.
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As to what impacts these might have on air quality, I'm not aware
any studies that have been conducted, but there very well may be son.
Mr. BROWN. There are some general problems in this environmental
area that in my opinion are still not adequately addressed, and it
probably will be years before they are. Both of the things that I have
in mind have been brought up here this morning. One is the adequacy
of a comprehensive monitoring program—are we actually anywhere
close to having a monitoring system and technology adequate to
characterize the environmental pollutants in the area? Second—and it
stems in part from the first—is there any systematic effort to relate
monitoring data to health effects? If you don't have good monitoring
data, you can't have good health effects data, to begin with. What is
the situation as far as that's concerned in this area ?
Mr. LOZANO. With respect to the development of a comprehensive
monitoring system, this State is very fortunate in having what I would
describe one of the best monitoring systems in the country. Unfor-
tunately, that is not true in other parts of even our EPA region and
certainly not in other parts of the country. EPA, in the development
of regulations concerning monitoring, tried to develop a minimum
sampling network to describe, again, the criteria pollutants. That's
been the big emphasis of our agency all along. And I think that there
probably is a minimum network operating across the country now—
it should be much better than that. A year ago, the agency realized
that we weren't doing enough in this area, that some of these pollutants
were getting bias, there were some areas of the Nation that were not
being covered, and there was a system developed between the States
and EPA to improve that situation. It was a working group of in-
dividuals developed who came up with what I think is a very practical
and very comprehensive monitoring plan for the country. And this is
now being implemented. It calls for, m some cases, reduction of moni-
toring in some areas, because where it's well saturated with monitors
it may be that it's necessary to cut back. But I think that as a result of
this—at least for the criteria pollutants—we're going to have a much
better data base. And for the more exotic things, I think that areas that
need these measurements will be getting them.
Mr. BROWN. We'll stipulate for the criteria pollutants that we have
an adequate network. What about the situation with regard to the de-
velopment of adequate monitoring for the small aerosols and respirable
particulates ?
Mr. LOZANO. No, sir. I'm afraid we just don't have a network that
will get that kind of a measurement for us across the country, cer-
tainly. Maybe in certain parts of the country we might be able to have
information available on these pollutants because of some specialized
study that was conducted there. But nothing comprehensive, nothing
routine that I would say really would describe the overall problem.
Mr. BROWN. And if that is a unique aspect of the Houston pollution,
then we're just not prepared to adequately monitor it, then, are we?
Mr. LOZANO. Well, the techniques are there. The instrumentation—
the methods of collection for aerosol—may not be 100 percent proven
but the techniques are there and I think, particularly on a research
basis, they could be implemented to get a much better data base in the
Houston area.
Mr. BROWN. Mr. Wirth, do you have any questions? Mr. Eckhardt?
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Mr. ECKHARDT. Mr. Lozano, there are six pollutants that you use
with respect to your ambient air quality requirements—particulates,
photochemical oxidants, sulfur dioxide, carbon monoxide, oxides of
nitrogen, and nonmethane hydrocarbons; is that right?
Mr. LOZANO. Yes, sir.
Mr. ECKHARDT. And those are the only things that you actually set
ambient air standards on, as such.
Mr. LOZANO. That's correct.
Mr. ECKHARDT. But you consider hydrocarbons as a precursor to
photochemical oxidants, and therefore you require a reduction of hy-
drocarbons in the air in this and other areas in order to accomplish
that objective, right?
Mr. LOZANO. Yes, sir.
Mr. ECKHARDT. And under the existing amended Act of 1977, these
must be reduced to the allowable level in the case of all but photo-
chemical oxidants at least by 1981. And in the case of photochemical
oxidants, by 1986, right?
Mr. LOZAXO. I think it's 1982 and 1987. An extensioji mav be granted
for the automotive pollutants, for the carbon monoxide and the
oxidants, to 1987.
Mr. ECKHARDT. I know I'm perhaps oversimplifying it, but you re-
quire that there be steps toward the ultimate objective in increments
which may be found acceptable to the EPA during that period of time.
Now during that period of time, do you set certain goals or require-
ments with respect to hydrocarbons, say, in this area, or reduction of
hydrocarbon levels in order to achieve the reduction of photochemical
(t.xidants?
Mr. LOZANO. Yes, sir. I think that the way the act reads is that in
the case of the hydrocarbons, if it cannot be demonstrated that the
attainment will occur by 1982 through implementation of reasonably
available control technology and that further more stringent measures
are required to achieve that standard, then these can be, the legislative
process can be, accomplished by 1982. I'm thinking specifically of such
things as inspection/maintenance of automobiles, which right now will
require, in most areas, some more legislative changes to accomplish.
And these can be specified by 1982, but attainment need not be de-
monstrated until 1987.
Mr. ECKHARDT. But there's not anything in the Act concerning
hydrocarbons. That's something that is considered by the agency as a
precursor and therefore standards are established with respect to
hydrocarbons looking toward reducing photochemical oxidants, iten't
that true? Except, of course, the methane hydrocarbons?
Mr. LOZANO. These methods to achieve the standards are called
hydrocarbon control measures.
Mr. ECKHARDT. Well, isn't that your agency's program, not the
language of the statute ?
Mr. LOZANO. Hmm. I believe the term "hydrocarbon control" is in
there.
Mr. ECKHARDT. Well, let me ask you this. If—suppose you found
that certain oxides of nitrogen were one of the causes. Could you not
require a reduction of the oxides of nitrogen to a greater extent and
the reduction of hydrocarbons to a lesser extent within the authority
of your agency ?
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Mr. LOZAXO. Yes, sir, we could.
Mr. ECKIIARDT. Have you decided that the continued reduction o.
hydrocarbons, looking toward the reduction of photochemical oxidants,
will be the sole means of achieving the goals with respect to photo-
chemical oxidants?
Mr. LOZAXO. The research that we have conducted in this area leads
us to believe that the the primary emphasis of control toward attaining
the oxidant standard is hydrocarbon control. It very well may be that
there may be some studies developed which would lead us to change
our minds in this area—I don't really know. But I don't think that is
the case for the time being. I have seen no change in emphasis on the
part of our agency of going to any other type of control other than
hydrocarbon control.
Mr. ECKHARDT. Well, we've heard statements here, and I have also
read statements of various persons who have studied the question, that
the hydrocarlxm level has been decreased in this area by a net of ap-
proximately 40 percent and yet there has not been a substantial reduc-
tion of oxidants in the area.
Mr. LOZANO. I do not have an answer for that.
Mr. ECKHARDT. Is that correct?
Mr. LOZAXO. That's time. There has been an overall reduction of
hydrocrabons that can be calculated on paper and I believe personally
that there are other factors involved—perhaps the oxides of nitrogen;
I'm not discounting that—but I wonder if indeed the amount of
hydrocarbon reduction that is being shown by our agency and others
is actually occurring? I'm thinking that perhaps the amount of hydro-
carbon reduction that we can calculate from automobiles, because of
the new autos coming on line, is actually being achieved. Once that auto-
mobile gets out on the road I don't doubt that the emissions standards
are being met as it rolls off the assembly line, but I'm wondering if,
indeed, these same levels are being maintained for the first 1, 2, 3. or
4 years and through the life of that automobile. I know that
our
Mr. ECKHARDT. Suppose hydrocarbon pollution in this area has been
reduced by 40 percent. What would you anticipate as the required per-
centage reduction within the near future—do you have any views
on that?
Mr. LOZAXO. Well, the levels that are required for the Houston area
are something like 60 percent, 65 percent, as I recall. To achieve the
standard.
Mr. ECKHARDT. Sixty-five percent below that which existed at what
time? Before the 40-percent reduction was calculated, or further
reduction ?
Mr. LOZAXO. Before the 40-percent calculation was made. We needed
a 65-percent reduction to achieve the standard.
Mr. ECKHARDT. And if the 40-percent did not seem to move in the
direction of achieving the standard, why do you anticipate that the
further reduction of 25-percent more would improve the situation?
Mr. LOZAXO. I don't have an answer for that, Congressman. I admit
that these are unidentifiable reasons. What I question is whether there
has been the reduction. Because in other parts of the country—and
maybe Houston is singular, I don't know, I don't want to argue that—
but in other parts of the country where hydrocarbon reductions have
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been achieved over a long period of time, and we have an adequate data
base to see what the oxidant levels have done over a long period of time,
these reductions have been demonstrated.
Mr. ECKHARDT. Well how long would it be permissible to continue
with industrial growth in this area, without reducing the hydrocarbon
level by a 65 percent, or an additional 25 percent ? Or would you simply
put the lid on now ? I assume there would be some time lapse, because
under the statute a considerable period of time is allowed to meet the
oxidant levels. But what would be the immediate goal—say within a
year or two—that would necessarily be met in order to continue to
build plants. As I understand that act, if they are new plants, they must
be built with the highest attainable level of pollution control.
Mr. LOZAXO. That's an excellent question, Congressman. I foresee
the time, it seems to me, that even under the offset policy as it presently
exists, that we continue to make up the amount of hydrocarbon in-
creases through reductions elsewhere, and if we continue to see no im-
provement whatsoever I just don't know what we're going to do. Cer-
tainly I would hope that his research effort would help us in that
area,
Mr. ECKHARDT. We don't know What the oxidant level was before
industry developed in this area and automobiles began to boom—there's
no way we can look back, because we didn't have the techniques then.
So we don't know whether oxidant levels have greatly increased except
from our common experience. I think that as one who has lived here a
good while I can say that that which is visibly obvious as a result of
photochemical oxidants indicates that they have increased. But we
don't know precisely what caused the increase.
Would it be conceivable at your agency, having a period of time
granted under the statute for compliance in this area, might relax the
movement toward reduction of hydrocarbons pending some specific
study in this area fhat might implicate some other cause? Of course, if
no other cause can be found, you might have to go back to your hydro-
carbon theory, but it would seem to me—listening to Senator Bentsen's
testimony, it seemed to me that he considered your program rather
rigidly attached to hydrocarbons. I don't know whether that's a fair
judgment of your program or not—perhaps you'd comment on that or
perhaps comment as to whether or not there could be a degree of flexi-
bility, at least during a period of time when the specific problems of
the area are being studied.
Mr. LOZAXO. We have been very rigid in the development of hydro-
carbon control strategies, and, as 1 see it, we will continue to do so in the
immediate future. Whether there could be a moratorium tlhere while
something else is studied, I don't think I could answer that.
Mr. ECKHARDT. I'm not exactly asking for a moratorium, but per-
liaps a standard of reduction that doesn't call for what may be an eco-
nomically impossible result. Now, I want to tell you right off that I
agree with you in insisting on a program by the Texas Air Control
Board which is acceptable by EPA before you move to that instead
of simply applying your present offset policy. And I'm not asking you
to do other than to set some kind of reasonable requirement for such an
alternate program before you move that way. But it does seem to me
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that, from your statements and from the facts we've had here, .t you
may be a little too rigid with respect to assuming that the re ,jtion
of hydrocarbons will move us in the direction of meeting the standards
with respect to photochemical oxidants. It would seem to me that there
may be some quite valid argument—at least, most of the persons who
have test i lied here indicate that there might be a valid argument—that
other pollutants may be the factors. Even your own statement opens
that possibility. I understand that in a hearing you can't make a state-
ment of policy that your agency is going to follow in the future.
I'm just suggesting that all the testimony here seems to indicate to me
that, at least for a period of time, increments that would achieve the 65-
percent reduction may be too great to be feasible under the circum-
stances, and if imposed now might be irrationally rigid.
Mr. LOZAXO. I think that the strategies that have been developed, the
control measures that have been imposed, represent our best estimate
of what "reasonable" is, and even though in some cases they are costly,
they are measures that have been used in other parts of the country,
without a severe impact to my knowledge on any community or on
anv industry. We will continue to use them in the future, realizing
full well that we want to get to the standards as quickly as we can—
that's our mandate. Some of these things that we're talking about as
hydrocarbon controls are indeed the ones that have been discussed
as more stringent measures, for example, the offset and controls on
ship and barge, things that obviously have a high cost factor—we've
delayed. We've held back on these because we do want to try and main-
tain reason, and I think over the period between now and 1982 we look
for the 1979 plan to be submitted by the States to contain reasonable
measures. Not because we're so uncertain that hydrocarbons, reduction
of hydrocarbons will eventually get us there, but because of the fact
that some of these things are brand new to us, some of these techniques
are brand new in the area of controls, and we're trying to go slow with
them. But I think the agency is firm in its position that hydrocarbons
are the principal culprit here.
Now, there may be other things that will come along in other
studies—perhaps even oxides of nitrogen, even thoueh our agency has
not accepted that the control of that particular pollutant is a way to
go in uroanized areas—but it could, indeed, as new studies are per-
formed, we could be altering our position. But that's where it is right
now. There's too much evidence to indicate—in the laboratory and
other places—that this is the way to control oxidants. And for that
reason, we're sticking to it.
Mr. ECKHARDT. I compliment you for your fh-mness, but perhaps
not for your rigidity.
Mr. BROWX. Thank you, Mr. Lozano. I'm sure that we would like to
have you spend some more time with us, but we have several more
witnesses this morning, and we'll have to defer the pleasure of interro-
gating you further.
Our next witness will be Mr. A. D. Cyphers, president of the Texas
Chemical Council. We welcome him here this morning. You may pro-
ceed with your statement, Mr. Cyphers.
[The prepared statement of Mr. Cyphers follows:]
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STATEMENT BY THE TEXAS CHEMICAL COUNCIL TO THE HOUSE COMMITTEE ON
SCIENCE AND TECHNOLOGY SUBCOMMITTEE ON THE ENVIBONMENT AND THE AT-
MOSPHEBE IN HOUSTON, TEX., ON NOVEMBER 21, 1977
Good morning. I am A. D. Cyphers, and I represent the Texas Chemical
Council (TCC). The Texas Chemical Council is an association of 73 chemical
companies. We have over 60,000 employees and represent approximately 90 per-
cent of the installed capacity of that industry in the State of Texas. Essentially
all of it is along the Gulf Coast, and we're proud that we produce over half of
the country's petrochemicals. The council tries to contribute constructively to
policy and rulemaking activities whenever we can, and we certainly appreciate
this opportunity to comment.
Let me start by posing what we see as the two basic questions about Gulf
Coast air pollution. We perceive these two problems:
First, what causes the haze and reduced visibility which occurs in the Houston
area ? Does this haze cause adverse health effects?
Second, is the photochemical oxidant standard, developed largely from Los
Angeles health data, applicable to the Gulf Coast area? Are the local oxidant
concentrations harmful to health?
Let me address briefly the status of our knowledge about each of these
questions.
Haze, aerosols and fine partieulates are subjects that have proven to be difficult
to study. For example, we do not know the sources, the components, nor the pre-
requisite condition for formation of the typical Houston haze. We do not know
the conditions that cause it to be stable after it has formed. And we do not know
the effects of atmospheric conditions on it, beyond a general observation from a
Texas Air Control Board study that haze is aggravated by high humidity.
We have no data on either the short or long range health effects, if any,
except that the Houston haze does not have the eye watering or respiratory
effects that were noted in Los Angeles. Thus, all areas associated with haze
problems need research and additional information.
In contrast, a considerable body of oxidant data have been gathered since the
EPA standard was imposed late in 1970. From these data it can readily be con-
cluded that the standard as presently defined, 0.08 PPM, l-hour average, not to
be exceeded more than once per year, will never be met in a great many areas
of the United States, both heavily, and lightly populated places.
For example, in the Houston area .which typifies the Gulf Coast region, hydro-
carbon emissions were reduced by 40 percent between 1973 and 1975 and yet
there was no decrease in oxidant levels for the same period. Many rural areas
will never meet it. The EPA, the Texas Air Control Board, and private industry
have measured ozone values above the standard in rural air over 100 miles from
any large population center and also in air that was blown in from the Gulf of
Mexico. This situation results from both natural and manmade causes, and the
economic and social disruptions required to attain even a close approach are
totally unacceptable. These views are not only ours but represent the consensus
of most technical experts in air pollution.
Additionally, there are serious and valid technical questions regarding the
analytical basis for the .08 ppm standard. The Los Angeles health effect correla-
tions also draw severe criticism as to their applicability to the pulf coast area.
Because of the many uncertainties about the oxidant standard the council and
many of its member companies have been active supporters of the Houston area
oxidant study whose activities are described in the following Chamber of Com-
merce statement. This study, which represents to me a most remarkable coalition
of public and private interests, is the forerunner of the kind of research needed
in this area with a program that was well planned, broad in scope, and extends
over a time period.
Having posed the question of what we think the gulf coast pollution problems
are and the status of each, let me now turn to our recommendations. We believe
the following areas need investigation :
First, epidemiological and clinical studies of the health effects of Houston
area haze and oxidants,
Second, the collection and detailed characterization of fine partieulates and
aerosols. This study should include airborne as well as ground level sampling
and should be carried out over an extended time period,
Third, expanded meteorological data collection and analyses, and
Finally, environmental chamber studies to evaluate the potential of par-
ticular Houston area air for hnze and smog formation.
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As to how these are to be accomplished we heartily endorse the recomme
tions of your conference report (No. 95-722). We are greatly pleased to see
the conference committee anticipated that the needed studies would require a
coordinated research program continuing for several years. We are also grati-
fied that it anticipated making considerable use of local facilities and personnel.
We believe such participation is essential to avoid overlooking important local
conditions that might affect the validity of the study and to coordinate with past
and ongoing efforts. We believe that the state of our present knowledge is so
meager that all available monies should be spent on technical and scientific
studies.
We commend that HAOS approach to you. We recommend a local steering
committee, with a technical subcommittee, be formed to help identify specific
programs, priorities and provide direction. The Texas Chemical Council offers to
make available for such an approach the technical expertise that we have in our
industry.
These studies are aimed at the gulf coast and Houston Is the essence of a
gulf coast urban area. We think regional studies should be done here as Houston
is uniquely suited for this, with its collection of universities and colleges, medical
and health schools, and private and Government research centers. Additionally,
Houston has an already extensive air pollution monitoring network operated by
the city's health department and the Texas Air Control Board. The Industrial
community also operates a number of meteorological stations and air pollution
monitors.
We believe that such studies can make a vital and much needed contribution
to solving our common problem of how to have clean air.
Thank you very much.
A. D. CYPHERS, JB.
A. D. Cyphers, Jr., is the manager of the du Pont plant at Victoria, Tex., and
currently the president of the Texas Chemical Council (TCC).
Mr. Cyphers, who was born in Yukon, W. Va., started working for du Pont in
1948 after receiving his B.S. and M.S. degrees in chemical engineering from
Virginia Polytechnic Institute and after serving for 2 years in the U.S. Navy
in the Pacific Theater. He is a registered professional engineer in the State of
Texas, a member of the American Institute of Chemical Engineers, and many
other civic organizations.
TEXAS CHEMICAL COUNCIL PRESENTATION AT TEXAS AIR CONTROL BOARD HEARING
MAY 28, 1975, HOUSTON
"ADDITIONAL HYDROCARBON CONTROLS1'
My name is R. G. Dillard. I am manager of Shell's Deer Park Manufacturing
Complex and Chairman of the Texas Chemical Council's Air Conservation Com-
mittee. It is in the latter position that I appear at this hearing today.
The Texas Chemical Council has 63 member companies engaged in the manu-
facture of plastics, synthetic rubber, metals, petro-chemicals, and a myriad of
inorganic and organic chemicals that are an essential part of our present econ-
omy and basic to our standard of living. Collectively, the TCC member companies
directly employ more than 49,000 people in Texas. Indirectly, untold numbers
of Texans are employed in supplying our industry, using our products, and con-
structing our plants.
The TCC is deeply concerned with the subject of this hearing. We are con-
cerned not only by the direct subject of this hearing, additional hydrocarbon
controls, but more so by the indirect subjects, the inadequate knowledge, fuzzy
thinking, and oblique rationale that have led us to this hearing today. We must
not continue unalterably down this present chaotic path. It is time to assess the
past, present, and future of the total plan.
Our member companies fully support the goal of providing clean, healthy ait
for the citizens of this country. We feel we have contributed much toward at-
taining that goal. We have shared our industry's expertise in previous hearings
such as this. We have allocated hundreds of man-years and millions of dollars
in the implementation of the TACB regulations. Reactive hydrocarbon emissions
from stationary sources in this region have been reduced by 160,000 tons, 53
percent, in the last three years. In fact, there are no significant stationary emis-
sions of reactive hydrocarbons not now controlled.
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The Texas Chemical Council's assessment of the present status of the plan
toward attaining the goal of air free from harmful concentrations of photochem-
ical oxiduuts is in brief:
(1) No satisfactory or consistent method of measuring and monitoring the
pollutant, photochemical oxidants, has been established.
(2) The health effects of various concentrations of photochemical oxidants
and therefore the standard are in doubt, since the measurement method has
not been established.
(3) The strategy for control of photochemical oxidants is in error.
The TCC has provided a more detailed written discussion in a series of sep-
arate papers as a part of the record of this hearing. Today, we pause and look
with alarm and misgivings at a plan based on inadequate monitoring and a
doubtful ambient air standard requiring an unacceptable control strategy.
The goal of our plan, as stated in the statement of purpose of the Clean Air
Act, is "... to protect and enhance the quality of the Nation's air resources so
as to promote the public health and welfare and the productive capacity of" its
population;...". The achievement of the goal requires:
(1) The ability to measure and monitor a pollutant, in this case photochemi-
cal oxidants;
(2) Establishing a relationsip between the concentration of photochemical
oxidants and health effects and adopting a standard to protect health and wel-
fare and the productive capacity of its population; and
(3) A control strategy to meet the standard.
First, let us discuss the measurement of photochemical oxidants. The Los
Angeles County Air Pollution Control District (APCD) started the chain of
events which has led us to a totally confused air quality monitoring position
today. In the 1950's and 60's, the Los Angeles District used a continuous, neu-
tral, phosphate-buffered potassium iodide method to measure "total oxidants".
This method measures ozone, aldehydes, peroxyacetyl nitrate (PAN), chlorine,
bromine, sulfur dioxide, nitrogen dioxide, and hydrogen sulflde. Since most
of the oxidants of concern are produced photochemicaHy, the Los Angeles Dis-
trict and later the EPA called the measured pollutants "photochemical oxidants".
Later this method was corrected for interference. Next a more suitable method
called FAS wa.s adopted for the EPA monitoring network. This method had
only a 10 'percent efficiency for ozone. Then, the EPA adopted the chemilumines-
cent method. It was efficient and specific for ozone, the major component of the
Los Angeles "total oxidant" and assumed to approximate the original Los
Angeles District method. This assumption is probably not valid for many cities.
Recent evidence indicates that in some cases the cbemiruminescent method reads
as much as twice the continuous Los Angeles method. The uncertainty of th»
EPA standard method for monitoring is disclosed in the February 18, 1975,
Federal Register. Herein the EPA states that the Nation's air pollution con-
trol program has a satisfactory air quality test method for only one- air pol-
lutant, sulfur dioxide. Without a consistent and established monitoring method.
the entire air pollution control plan is precariously based, and of grave concern.
We strongly recommend that the first order of business be the adoption of a
standard method for monitoring photochemical oxidants related to health. This
task might best be undertaken by a group outside of those directly concerned,
perhaps reporting to the National Academy of Sciences.
Now let's look at the national standard for just a moment, the second area for
discussion. The standard was primarily based on health studies made ID Los
Angeles in the 50's and 60's. There was no doubt there were occasions when
photochemical oxidants were a problem in that city. Tearful eyes and a distinc-
tive odor were obvious manifestations to everyone.
These health-effect studies utilized the only available ambient air data, that
of the APCD obtained by the continuous potassium iodide method. These data
were used in establishing a relationship between the concentration of photo-
chemical oxidants and health. These same health studies were the basic input
to the EPA national standards set at 0.08 ppm In 1971. The standard was set
from measurements using the Los Angeles District method but almost no meas-
urements have been made in Texas over the past four years with this method.
We are comparing apples and oranges to decide the seriousness of the problem.
or whether there is a problem. It is imperative that a health standard be prop-
erly set.
Third, let us discuss the control strategy for photochemical oxidnnts. Photo-
chemical oxidants are the product of hydrocarbons, nitrogen oxides, sunlight.
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and time. The control strategy is based on control of hydrocarbon emissioL
more specifically reactive hydrocarbons. Formation of oxidants is very complex:
different hydrocarbons react lo form photochemical oxidnnts at different rates
and to a greater or lesser degree, depending on what mixture of hydrocarbons
and other pollutants is in the air. Despite these very complex reactions, the EPA
has promulgated a control strategy which says that photochemical oxidants, as
ozone, can be controlled by a proportionate reduction of hydrocarbons. The EPA
further states that it should be assumed that there is no natural background con-
centration of ozone. Furthermore, the strategy presumes that the standard may
not be exceeded more than one hour in a year by the total of the area's monitor-
ing measurements in order to protect health and welfare.
There is considerable evidence that there is a very poor relationship between
the hydrocarbons measured and the photochemical oxidants (ozone) measured
in this region and many other parts of Texas. Second, there is ample evidence
that there is considerable background ozone from natural sources, not only in
this region but in many other areas. So-called minimum background ozone levels
in some areas exceed the standard. Certainly an account must be taken of back-
ground ozone as it is for other pollutants.
Third, it is arbitrary and unreasonable to set the second highest measured
value as representative of the level to which an area must control. In this region,
the second highest value for 1974 was 0.20 ppm. However, the standard of 0.08
was exceeded only 3 percent of the time, based on 7,083 hourly measurements
during the year. We suggest that use of the second highest one-hour value for pur-
poses of determining the degree of control necessary is entirely unrealistic when
it is realized that excursions may randomly occur from effects completely out of
the control or knowledge of anyone.
Lastly, what will be the effects of the proposed additional controls? Some of
these proposed controls will be the first to directly affect the citizens. These con-
trols are estimated to require a direct cost in excess of 100 million dollars for this
region alone. This is only the tip of the iceberg. The attendant social and economic
costs have not been, nor can they be, estimated.
The proposed controls, outside of the reduction in vehicle miles traveled and
the limitation on industrial growth, are calculated to reduce hydrocarbon emis-
sions only 11-14 percent and almost certainly will have little effect on the ozone
levels in this area.
The "biggies" of the proposed control strategy are reduction of the vehicle
miles traveled and limitation of industrial growth. The "no-growth" regulation
promulgated by EPA for this region will prevent the construction or modifica-
tion of any facility that might emit hydrocarbons in excess of three pounds per
hour or fifteen pounds per day. This emission level is not technically feasible nor
economically viable. Local refineries, chemical plants, and petrochemical opera-
tions will be limited to their present size. Service stations similarly may be limited
to their present number. New surface coating operations, dry cleaning plants.
and printing plants may not be built nor existing ones modified. Other types of
industries, commerce, and businesses will be limited. The logical consequences of
this "no-growth" policy are relocation of people, death of income-producing activi-
ties, decline of property values, and other huge indirect economic costs and depri-
vations to citizens. Unless the concept of "no-growth" is promptly rejected, EPA
is likely to extend such regulations to many, if not most, major urbanized areas
in connection with either its "transportation and land use control" program or
its "air quality maintenance area" program. Devastating effects on the populace
will result in the name of protecting our health and welfare. The industrial "no-
growth" regulation is totally unacceptable in light of our present knowledge and
definition of goals.
In summary, the TCC believes that neither the EPA nor anyone else knows
where we have been, where we are, nor where we are going in the control of
photochemical oxidants. We have not defined the problem. We are blindly follow-
ing a control strategy with no knowledge that this strategy will provide an air
quality to protect health and welfare and no recognition of the cost-benefit rela-
tionships. We must stop and revise our plan.
No revised plan is acceptable unless
(1) A monitoring measurement method applicable to the photochemical oxi-
dants' effect on health is properly defined and agreed to; unless
(2) The relationship between health effects and properly and consistently
measured pollutant levels are redefined preferably by a fully accredited agency or
group independent of the EPA and its enforcement role; unless
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(3) A control strategy is developed which encompasses all the valid relation-
ships, including social and economic considerations; and unless
(4) the public is provided real participation in the decisionmaking processes.
Therefore, the Texas Chemical Council recommends the following courses of
action be undertaken immediately :
(1) The Texas Air Control Board petition for a review and justification of
the oxidant standard and EPA oxidant control strategy; and
(2) That the Texas Air Control Board, the Texas State Attorney General, and
other interested parties take immediate court action to prevent implementation
of additional hydrocarbon regulations. Kvideuce introduced at this hearing and
from other sources is sufficient cause to stop, reassess our plan, and correct its
direction.
I thank you for this opportunity to express the views of our membership and
would refer you to the more technical group of papers submitted to this hearing
for additional details.
Mr. BROWN. Thank you very much, Mr. Cyphers. Mr. Gammage, do
you have any questions?
Mr. GAMMAGE. Thank you, Mr. Chairman. More by way of a state-
ment than a question, Mr. Cyphers, I think your testimony, in conjunc-
tion with that of Senator Bentsen and the other expertise that's been
demonstrated here today in testimony from those with a technical
knowledge, and Congressman Eckhardt's interrogation of Mr. Lozano
established two things—First, we all know where we want to get, but
there are large questions of exactly what we need to do to get there.
And second that rigid and arbitrary standards that have no rational
basis, at least as far as we can determine, may not be the best but may
well be the most inefficient and expensive way of trying to get there.
The combined efforts of the public and private sectors, particularly
with regard to local input, local experience and local expertise, are
critical to getting to that goal, which is to promote and preserve the
health of this community, both environmentally and economically. I
thank you for your efforts and cooperation in this direction.
Mr. CITHERS. Thank you very much.
Mr. BROWN. Mr. Cyphers, is there any serious conflict between the
various local groups as to the mechanism for closer cooperation with
EPA in structuring the necessary research? Obviously, I think, there's
agreement on all parts that we do need a strong local input into the
program. My question is: Is there serious conflict with regard to the
mechanism of the local input ? Does the Chamber want to hog the whole
act or anything like that ?
Mr. CYPHERS. Well, I think the committee that's already started
certainly represents a fine approach. I would certainly recommend
the chemical industry segment, particularly since it is so large in
the Houston area, be a part of such a steering committee or liaison
committee, and we certainly stand ready to offer people who can
bring a great deal to bear in their technical expertise and industrial
knowledge to such a committee.
Mr. Bnowx. Well, it seems like a very reasonable approach. As n
matter of fact, the chemical engineering profession has frequently
made a substantial contribution to some of these environmental prob-
lems, and I would think that you'd have a very strong professional
organization amongst the chemists and chemical engineers in this
area. Well, we thank you very much for your contribution.
Our next witness will be Mr. Larry Feldcamp, who is chairman of
the Houston Area Oxidant Study Steering Committee for the Houston
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Chamber of Commerce. We appreciate your being here tliis morning,
Mr. Feldcamp, and we look forward to your testimony.
Mr. FELDCAMP. Mr. Chairman, if I may, I may deviate slightly from
the text which you have in front of you to comment on some questions
that were made to Mr. Lozano as to maybe some of the thrust of onr
study.
Mr. BROWX. That's quite appropriate, and the full text of your
statement will be included in the record and we will welcome any com-
ments you have about the previous testimony.
[The prepared statement of Mr. Feldcamp follows:]
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STATEMENT
OF
HOUSTON CHAMBER OP COMMERCE
HEARING OF THE
ENVIRONMENT AND ATMOSPHERE SUBCOMMITTEE
SCIENCE AND TECHNOLOGY COMMITTEE
U. S. HOUSE OF REPRESENTATIVES
NOVEMBER 21, 1977
The Houston Chamber of Commerce, concerned
about the impact of Houston's growth on the quality of
life of its citizens, has over the years sponsored and
encouraged studies and projects dealing with such topics
as mass transportation, health care, education, water
and air pollution. Because of the recent concern by
governmental agencies and others regarding the photo-
chemical oxidants levels measured in the Houston area,
the Chamber through its Environment Committee supported
the creation of the Houston Area Oxidant Study (HAOS).
Initiated in 1976, HAOS is a two-year objective, scien-
tific study on the causes and impacts of airborne oxidants
and haze in Houston and surrounding areas along the Texas
Gulf Coast. HAOS includes technical studies in four sub-
ject areas:
(1) Air quality definition of ozone and other oxidants
(2) Air quality definition of haze
(3) Health effects of air pollutants
(4) Socioeconomic effects of control measures
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A more detailed description of the individual projects
and their status are set forth in the HAOS 12-Month Status
Report, dated November 1977, which we request be made part
of the record of this hearing.
HAOS is financed by contributions from about
200 private organizations in the Houston area. Augmenting
the HAOS projects, however, are data obtained from public
and private sources, the value of which, if financed by
HAOS, would add over $4 million to the $1.3 million HAOS
budget. Cooperating public agencies include the City of
Houston, Texas Air Control Board and the Environmental
Protection Agency.
All HAOS data will be publicly available for use
by private and public groups. A data archive, consistent
with EPA's system, has been organized and designed so as
to provide a stepping stone for future detailed studies
on Houston air quality and its effects.
Although it is the goal of HAOS to obtain the
information and data on oxidants and haze to provide a
sound basis for developing realistic and effective con-
trol strategies for achieving clean, clear, healthy air,
it is recognized that additional studies beyond HAOS are
necessary to achieve this goal. Based upon the experience
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of HAOS in developing and implementing their study pro-
gram, we recommend that one of the initial projects, using
the HAOS health effects study as a starting point, be the
development of a comprehensive long-range plan for deter-
mining the health effects of aerosols, ozone and other
oxidants as well as other criteria pollutants that may
pose a health problem in the area. In developing its
health effects study, HAOS went through' a similar planning
process which was felt to be very useful. In considering
the health effects study to be implemented, consideration
should be given to the following:
(1) Expanding the present HAOS epidemio-
logies 1 study to a second city which
can be used as a control case, as
well as extending the study for a
longer period of time;
(2) Conducting a clinical ozone/oxidant
study; and
(3) Conducting epidemiological study of
metals in aerosols.
In other areas we recommend that the following
projects be considered for inclusion in any future Gulf
Coast air pollution study:
(1) A detailed analysis of particulate
samples collected by HAOS for metals
content;
(2) Development and implementation of im-
proved methods and techniques for
aerosol collection and identification;
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(3) Conducting large outdoor chamber studies
of Houston air to determine the poten-
tial for aerosol and oxidant formation;
(4) A detailed analysis of organic com-
pounds in the ambient air;
(5) A further detailed three-dimensional
analysis of oxidants, nitrogen oxides
and hydrocarbons in the ambient air; and
(6) Expanded meteorological data collection
and analyses.
The primary objective of HAOS is to perform a
credible, factual, scientific study of the Houston area
air pollution problem. We emphasize the words "credible"
and "factual" as they are very important in connection
with any air pollution research. HAOS has made a concen-
trated effort to establish the credibility of its study,
such as by conducting an extensive quality assurance pro-
gram and seeking the advice and assistance of federal,
state and local regulatory groups as well as other air
pollution and medical experts.
We believe that the EPA will be confronted with
credibility problems if they perform the study on the Gulf
Coast without the involvement of local interests. In such
a situation the expenditure of $1 million may provide ad-
ditional information and data but not a resolution of the
Gulf Coast air pollution problems. This could in effect
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result In the wasteful expenditure of $.1 million of the
taxpayers' money.
Therefore, to assure the highest possible
credibility and to make maximum and expeditious use of
federal monies, we strongly endorse and support the need
for close coordination and cooperation between the EPA and
local and private interests with respect to any future air
pollution research on the Gulf Coast. Only through such
coordination and cooperation can there be a mutual under-
standing of and solutions to the air pollution problems.
Based on the experience of HAOS, we recommend
that future Gulf Coast research activities be outlined and
coordinated through a local Steering or Advisory Committee,
who would provide general direction, and a Technical Sub-
committee, who would define the specific research projects.
The Steering or Advisory Committee should include the re-
cently formed Gulf Coast Air Pollution Research Committee
on which there are representatives from the Texas Air Con-
trol Board, Harris County, and City of Houston as well as
from industry, citizen groups, medical associations, and
universities. In view of the broad base of this committee,
it can bring together the considerable expertise and re-
sources in this area that can be utilized along with EPA's
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expertise and resources in resolving the area's air pol-
lution problems.
We earnestly solicit your committee's endorse-
ment of the close coordination and cooperation between
EPA and local interests in the implementation of air pol-
lution research on the Gulf Coast and any assistance that
you may provide in effecting such cooperation and coordi-
nation .
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Mr. FELDCAMP. I also would like to make part of the record the 12-
month status report on the Houston area oxidant study, dated Novem-
ber 1977, which gives more detail about our study.
Mr. BROWN. Without objection, that will be made a part of the
record, also.
[See appendix III, page 355.]
Mr. FELDCAMP. As indicated in the statement, one of the four major
study areas is air quality definition of ozone and other oxidants. Now,
in the context of your questions previously, this is really an expanded
monitoring network for ozone and other photochemical oxiaants—
including not only the normal methods of measuring total oxidants,
but some specific compounds like the PAN, or peroxyacetyl nitrate,
which is thought to be the cause of eye irritation in some areas. A
second study area is the air quality definition of haze. We think we
have some study projects which have not been done before here in the
Houston area, to define the amounts of respirable particulates, to try
to analyze the aerosols, both chemical and physical analyses. Third,
and this is one of the most important areas of the study, is the health
effects which we think is unique. This is probably the first time this
has really ever attempted to be done on a broad basis here in Houston.
as far as Ave're aware. And we're trying to correlate the measurable
health effects with measurements of these various pollutants, including
the aerosols. The fourth area is the socioeconomic effects of control
measures, both the benefits and the negative aspects of these control
measures.
As indicated in our statement, our study has a budget of $1.8 Million.
but I think I would make mention that really the study, in effect, if we
had to pay out cash for everything that we have done it was really more
than $5 million, because we have received contributions of services in
kind, if you will, from the State, the city, other private organizations—
especially in the monitoring network. The great heart of our monitor-
ing network is the city of Houston, and the Texas Air Control Board
systems, but which we have expanded considerably. All our HAOS
data will be publicly available for use by public and private groups.
and data archives consistent with EPA systems have been organized
and designed so as to provide a stepping stone for future detailed
studies on Houston air quality and its effects. Although it is the goal
of HAOS to obtain the information and data on oxidants and haze
to provide a sound basis for developing realistic and effective control
strategies for achieving clean, clear, healthv air in this area, it IP
recognized that additional studies beyond HAOS are necessary to
achieve this goal. Based upon the experience of HAOS in develop-
ing and fmplementing their study program, we recommend that one of
the initial projects, using the HAOS health effects study as a starting
point, be the development of a comprehensive, long-range plan for
determining the health effects of aerosols, ozone, and other oxidants.
as well as other criteria pollutants that may pose a health problem in
the area. In developing this health effects study. HAOS went through
a similar planning process, which wns felt to be very useful.
As to specific projects, consider t.ion should bo jn'ven to the follow-
ing : Expanding the present HAOS epidemiological study to a second
city which rnn be used as a control case, as well as extending the study
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for a longer period of time; second, conducting a clinical ozone/o?i
dant study; and, third, conducting an epidemiological study of metai-
and aerosols. In other areas, we recommend that the following projects
be considered for inclusion in any future gulf coast air pollution study:
A detailed analysis of particulatc samples collected by HAOS for
metals content. Second, development and implementation of improved
methods and techniques for aerosol collection and identification. Third,
conducting large, outdoor chamber studies of Houston air to determine
the potential for aerosol and oxidant formation. Fourth, a detailed
analysis of organic compounds in the ambient air. Fifth, a further
detailed, three-dimensional analysis of all oxidants, nitrogen oxides,
and hydrocarbons in the ambient air. And sixth, expanded meteoro-
logical data collection and analyses. The primary objective of HAOS
is to perform a credible, factual scientific study of the Houston area
air pollution problems. We emphasize the words credible and factual
as they are very important in connection with any air pollution re-
search. HAOS has made a concent rated effort to establish the credi-
bility of its study, such as by conducting extensive quality assurance
program, and by seeking the advice and assistance of Federal, State
and local regulatory groups, as well as other air pollution and medical
experts. We believe that EPA will be confronted with credibility prob-
lems if they perform the study on the gulf coast without the involve-
ment of local interests.
In such a situation, expenditure of $1 million may provide addi-
tional information and data, but not a resolution of tne gulf coast
air pollution problems. This could, in effect, result in the wasteful
expenditure of $1 million of the taxpayers' money. Therefore, to as-
sure the highest possible credibility and to make maximum and expe-
ditious use of Federal moneys, we strongly endorse and support the
need for close coordination and cooperation between the EPA and local
and private interests, with respect to any future air pollution research
on the gulf coast. Only through such coordination and cooperation
can tlu'iv In- a mutual understanding of nml '-olulions to the air pollu-
tion problems. Based on the experience of HAOS, we recommend
that future gulf coast research activities be outlined and coordinated
through a local steering or advisory committee, who would provide
general direction, and a technical subcommittee, who would define the
specific research projects. The steering or advisory committee should
include the recently formed Gulf Coast Air Pollution Research Com-
mittee, on which there are representatives from the Texas Air Control
Board, Harris County, and the city of Houston, as well as some in-
dustry and citizens groups, medical associations, and universities. In
view of the broad base of this committee, it can bring together the
considerable expertise and resources in this area that can be utilized
along with EPA's expertise and resources in resolving the area's air
pollution problems. We earnestly solicit your committee's endorse-
ment of the close coordination and cooperation between EPA and
local interests in the implementation of air pollution research on the
gulf coast and any assistance that vou may provide in effecting such
. cooperation and coordination. Thank you.
Mr. BROWN. Thank you very much for your statement, Mr. Feld-
camp. It answers a number of questions that I had.
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As far as I can tell, there should be no problem in coordinating the
Chamber's operations with the other programs in the area for a closer
relationship with EPA.
Mr. FELDCAMP. I don't see any problem at all.
Mr. BROWX. There will, of course, always be a suspicion on the part
of some people that the Chamber or the local business groups and
chemical industry have an ulterior motive, in wanting this coordina-
tion. I think that it would be an error to assume that. It is the local
business community that has a financial stake in the success of this
program and in the viability of this community, and without their
assistance I doubt if any control strategy would work very well. Would
you concur in that ?
Mr. FELDCAMP. I would concur with that. We need a mutual under-
standing for mutual solutions to the problem.
Mr. BROWN. Thank you very much. That will be fine.
Our next witness will be Dr. Herbert C. McKee, who is Assistant
Health Director for Pollution Control of the City of Houston's Health
Department. We're happy to sec you here, Dr. McKee, and look for-
ward to your testimony.
Dr. McKEE. Thank you, Mr. Chairman. I'm delighted to be here and
to testify at this hearing. We're talking about a matter which is of
grave importance to public health, and by accident or design I'm the
only person on the list of witnesses whose full time professional
responsibility is public health.
Mr. BROWX. It s a tribute to your high competence, doctor. We knew
you could deal with your job as representing all the people concerned
with this area.
Dr. McKEE. Thank you, Mr. Chairman. Many of the other agencies
that are represented here are concerned with public health, but not as
a full time, sole activity as is the case with our city health department.
We have a comprehensive air pollution control program within that
department which includes monitoring, compliance inspections, en-
gineering studies and enforcement, all intended to improve air quality
in the city of Houston. Based on that experience, I would like to dis-
cuss the need for the research studies that are being considered at this
hearing.
First of all, the charter for this hearing mentions the fact that differ-
ent cities have different climate and other factors that influence air
pollution problems, and that solutions to these problems need to be
changed to reflect those conditions. Certainly, this is true of Houston,
as we've heard many times this morning. Our control efforts have
achieved a high degree of success in reducing sulfur dioxide, carbon
monoxide, many local nuisance problems, and in other ways. But lack
of knowledge has caused previous control efforts to fall far short of
our objectives in the control of photochemical oxidants, as shown by
the high ozone readings which still occur. Based on the control re-
quirements of the Environmental Protection Agency, hundreds of
millions of dollars have been spent in Houston to reduce hydrocarbon
emissions in the belief that this would reduce the ozone episodes.
This includes the cost of very substantial control measures by local
industries, and also many millions of dollars spent by the average car-
owner for catalytic converters, unleaded gasoline, and other vehicle
control measures. These efforts have undoubtedly improved air quality
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in many ways, and I'm not sorry that those measures have been im
plemented. But in terms of the original objective of decreasing the
ozone episodes, they have been a failure. Ozone episodes have not
changed in either frequency or severity by any measurable amount, in
spite of the very massive expenditure and the substantial reduction in
hydrocarbon emissions that has occurred in the last few years. Some
of the community leaders in Houston axe naturally rather dismayed
at this expenditure without achieving the desired and announced ob-
jective. It is obvious that additional control measures are needed, but
it is also obvious that these control efforts must be effective if public
disillusionment and loss of credibility for future control efforts are to
be avoided.
I'd like to address a question raised previously by Congressman
Wirth. He asked if there was public support for air pollution con-
trol efforts in the Houston area. As one who is in contact with the public
every day concerning air quality in the Houston area, I can assure him
and you that the answer is a resounding yes. The hundreds of millions
of dollars that have been spent are positive evidence of that support.
But that support will not continue indefinitely, if future expendi-
tures continue to fail in reaching announced objectives. We can achieve
a lot with the control measures that have already been implemented,
but since that was done to reduce ozone episodes and it has not done
so, the public is not going to regard our efforts as a resounding suc-
cess. When we start on a revised program to spend additional hundreds
of millions of dollars, we will have public support. We have it now. But
we cannot afford to fail too many times in succession, if we want to
maintain that public support. That's why it is important to talk about
the research needs of this area. We need to understand the unique
nature of our problems here in Houston, and without that understand-
ing there can be no assurance that our future control efforts to reduce
ozone episodes will be any more effective than our past efforts, no mat-
ter what other benefits those efforts may produce.
Based on our experience and observations, several suggestions are
included in my written testimony for consideration in this research
effort, and I'll review those briefly. First of all, the effects on human
health should be determined in the Houston area. We have reason to
believe that our problems are unique enough in this area—although
there are certain common factors with other cities—that what we know
about health effects in Los Angeles or Chicago or what happens in a
laboratory in North Carolina does not give a complete and an ade-
quate understanding of the health effects in Houston.
Second, the role of oxides of nitrogen should be determined, as was
discussed before by Mr. Eckhardt and others. There is some evidence
which suggests that no amount of hydrocarbon reduction—50-percent,
60-percent, 90-percent, or even 100-percent reduction of manmade
hydrocarbons—would achieve the oxidant standard, so long as oxides
of nitrogen are not also reduced along with the hydrocarbon reduc-
tion. If that tentative conclusion is confirmed by further research, the
importance of such a conclusion in devising future control strategies is
almost beyond calculation.
Third, the relationship between ozone and other constituents of
photochemical oxidants needs to be better understood. We measure
ozone because there is a convenient and accurate method of doing it.
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But we do not need to control ozone to protect public health, at least
at the levels existing in Houston most of the time. We get pretty
close to that level, and I worry some about ozone on its own merits.
But I worry much more because of the potential health hazard of the
other constituents that may or may not occur along with the ozone
that we're measuring. So we certainly need to address the relationship
between ozone and other constituents of photochemical smog before we
can really understand potential health hazards and be able to alleviate
them.
Other speakers have mentioned the role of small particles and the
haze formation, along with the ozone episodes that occur, and this is
extremely important. We don't know what role these small particles
have in causing effects on human health. There's another haze problem
that I would like to separate from that one, and that is the haze that we
get when we do not have elevated ozone levels. We may have two
separate haze problems—one with ozone, one without. We need to
understand the health implications of both, so that we can deal with
them effectively.
Another major topic is the role of vehicle exhaust. The conventional
understanding of photochemical smog assigns vehicle exhaust a major
role in its formation, and yet there is some rather conclusive circum-
stantial evidence that in Houston the role of vehicle exhaust in our
ozone episodes or in photochemical oxidant formation is much less—
perhaps almost negligible—compared to that conventional understand-
ing. The city of Houston has accomplished much to reduce vehicle
traffic—a better bus system, a park and ride system, a carpool program
on a citywide basis—and these are going to continue. These programs
are going to benefit air quality, to some extent at least. But certainly
the very expensive and restrictive transportation control measures
that have been advocated by the Environmental Protection Agency in
the past should not be imposed on the public unless there is much more
definite proof than now exists of the need for measures of that type.
The final area that I would like to mention has also been mentioned
before; the new and additional problems we face in the future due to
conversion to coal. Widespread use of coal is certainly essential as a
national objective, because of the need to reduce oil imports and also be-
cause of the price and availability of alternate fuels. But it is also essen-
tial to think about public health in that conversion to coal, or with
Avhatever measures we ultimately devise to meet our energy problems.
With 40 or 50 large industrial plants in a limited geographical area
along the Houston Ship Channel even the best and most modern con-
trol technology will not be adequate to avoid hazards to public health
if all of them are forced to convert to coal. For this reason, research
studies should be started now to see what additional health hazards will
be caused by sulfur dioxide and small particles from burning coal.
These hazards will be added to the existing problems that already occur
in that area. There is some scientific evidence indicating that ozone and
sulfur dioxide together are much more damaging than either one by
itself, and since we already have high ozone episodes, the addition of
significant amounts of sulfur dioxide might create much more serious
problems than exist at present. Among other possible solutions. I cer-
tainly hope that the energy legislation which is now pending in
Congress will provide for some continued use of natural gas for in-
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dustrial use, in urban areas where large numbers of industrial sourct
exist in close proximity to each other and also close to residentia*
areas.
These are some of the technical and engineering areas that we think
are of paramount importance in the research efforts that are needed
in this area, so we can understand our problems and control them more
effectively than we have in the past. If future research can provide an
adequate understanding—or even a reasonably adequate understand-
ing—of these problems, certainly our efforts will be more successful
than they would be otherwise. But it is obvious to us that such research
needs to be done on a local or a regional basis.
The city of Houston Health Department is not a research orga-
nization, but we do have a monitoring network, and we have scientists
and engineers who are involved in every phase of our local control
program. These people provide a reservoir of talent that could be
useful. We have already furnished air monitoring data to the Houston
Area Oxidant Study and to other health effects studies in the Houston
area, and with some expansion of these activities we could be of even
more help in future research efforts that are undertaken.
Finally, let me observe that the Clean Air Act provides for national
standards that in the words of the act "are requisite to protect the
public health." As a representative of a local health department, let
me assure you that the city of Houston wants the same protection for
public health as any other city. But our experience indicates that these
national standards must be implemented in different ways in different
cities, because of the variations between different cities—which you
mention in your charter for this hearing—if these different cities are
to achieve that same protection for public health which we want.
This can only be achieved by developing control measures that are
tailor-made for the local conditions of each region. Without additional
research to identify and understand these local conditions, our future
efforts cannot be completely successful. We appreciate your interest,
and look forward to further cooperation in planning and conducting
research that will aid in meeting our common objectives in the public
interest.
Mr. BROWN. Thank you Dr. McKee, that will be very helpful. Mr.
Eckhardt?
Mr. ECKHARDT. Dr. McKee, your qualifications in this field are of
course well known in this community, and I think they must be under-
stood by the committee after hearing your testimony. I have been
troubled by one thing, and I don't know whether you can answer this
or someone else can. We talk about a reduction by 40 percent of hydro-
carbon levels in the air in this area, and I assume that's over a certain
number of years—I'm not sure how many years—and I'm not sure
where we start as compared to hydrocarbon content of the air in other
parts of the country, or in comparable areas.
Dr. McKEE. First of all, that's a 40-percent reduction in what we
can identify by means of an emission inventory. The city of Houston
furnishes some data and cooperates with the Texas Air Control Board
in compiling this inventory. If there are sources that have not been
identified and included in that inventory, they don't affect either the
beginning or the final figures in that 40-percent reduction. The 40
percent occurred approximately between 1973 and 1975 or 1976. It is
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probably a little bit more than that now, although I'm not sure that our
figures are accurate enough to add a few more percent to the total. But
certainly it is something in the range of 40 to 50 percent total reduction
since about 1973.
Mr. ECKHARDT. How do we compare with respect to the amount of
hydrocarbons in the air as compared to a comparable city of this size—
is there any way to gage that question? Are we way up above most
areas in hydrocarbon content, are we about average, or what?
Dr. McKEE. There are several things to consider. In terms of total
tonnage, we started out higher than an urban area might be expected
to have with our population, 2l/2 million, more or less. This is because
of the very large contribution of the industrial component, but that
industrial contribution has now been reduced to perhaps 10 or 15 per-
cent or, at most, 20 percent of the previous figure, so that portion is a
lot less than it once was in terms of total tons emitted to the atmosphere.
Let me also mention oxides of nitrogen. The industrial contribution
to oxides of nitrogen is about two-thirds of the total for this entire
urban area. Furthermore, that two-thirds is concentrated primarily in
the ship channel area, which is a small portion of the total metropolitan
area. Most of the remaining one-third comes from motor vehicles, but
those vehicles are spread out throughout much of the city and beyond.
In term of concentration in a given air mass, the industrial contribu-
tion to oxides of nitrogen is much more than the 2:1 ratio of absolute
tonnages. Our hydrocarbon emissions at the present time are probably
in the range that one would expect for any city of 2l/2 million—or
maybe a little higher—but since the city is spread over a wide geo-
graphical area, maybe the total amount isn't of paramount importance.
But one important factor about oxides of nitrogen is what the effect
may be of that concentration in the ship channel area, which amounts
to two-thirds of the total tonnage but is much more than that in terms
of concentration in a limited region or a given air mass.
Mr. ECKHARDT. Thank you. Thank you, Mr. Chairman.
Mr. BROWN. May I pursue that just for a moment? Mr. Eckhardt was
trying to raise a question that would differentiate between emissions
and concentrations, and yet I'm still a little confused about that. Can
we use an index of emissions as a surrogate for concentrations on the
theory that the atmosphere is washed out every day or periodically
and so it's only the emissions ?
Dr. McKEE. No, sir, not directly. The total emission in tons is only a
starting point, and one must then consider what happens to that
amount over a few hours or days before one can really understand what
the tonnage figures mean. To illustrate, let me make a comparison be-
tween Houston and Los Angeles, In the Los Angeles area—or the South
Coast Air Basin, which is a term you're probably familiar with—a
given air mass drifts back and forth within that basin, receiving more
pollutants and reacting to form more oxidants for as much as 4 or 5
days, under stagnation conditions. So an air mass that finally leaves
that area is about 4 or 5 davs old, and contains the accumulated by-
products of that area and the reaction products for 4 or 5 days, in
Houston, due to the relatively flat terrain and somewhat better wind
velocity, that degree of stagnation is almost inconceivable. Under most
stagnation conditions that occur, a given air mass passes into and out
of the Houston area in, at most, 18 to 24 hours. Of course, there may be
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exceptions, but if there are we haven't identified them. We had
series of 10 consecutive days in June of this year with high ozone read-
ings, but that was not the same air mass; there was some new air com-
ing into the area each day and some going out each day. In terms of
the atmospheric reactions that occur, it is necessary to consider the
difference between continually reacting for 4 or 5 days in the South
Coast Air Basin, or reacting for only 18 to 24 hours in the Houston
area.
That is certain to change the chemistry of what happens in the
atmospheric reactions, and therefore change the final products of that
reaction system. That is one illustration of the difference—you can't
take the total tonnage in Houston and divide that into the total ton-
nage in the South Coast Air Basin and assume that we have one
fourth or one fifth of the problem that occurs in southern California.
Mr. BROWN. All right, that helps me to understand the situation.
What you've said in general applies, then, to all of the pollutants—
the ozone and other things as well.
Dr. McKJEE. It doesn't apply so much to meeting the present stand-
ards for carbon monoxide and sulfur dioxide, because the carbon
monoxide that goes out of the tailpipe of an automobile is still carbon
monoxide when it gets diluted and ultimately removed from the atmos-
phere. So you don't have the complication of the very complex reac-
tion systems that produce ozone and other oxidants. You do have to
consider atmospheric dispersion patterns in any area—Houston or any
other area—to know what those tonnage figures mean. But it's a much
more complex situation in evaluating oxidants, because one must start
with the total amounts of hydrocarbons and oxides of nitrogen, then
consider how these are dispersed and mixed by meteorological condi-
tions, and then consider what reactions occur in the atmosphere during
this mixing to produce the ozone and PAN and other products that
we're worried about because of their potential effect on human health.
Mr. BROWN". Well, we thank you very much for your contribution,
Dr. McKee. It's helped my understanding of the problem and I'm sure
the other members of the committee.
Dr. McKEE. Thank you very much, Mr. Chairman. We appreciate
your presence here and we would like to invite you to come back to ob-
serve our progress as we learn more about this problem in the future,
Mr. Brown. You can count on our being back. Our last scheduled
witness this morning is Ms. Mary Rollins, representing the Citizens
Clean Air Advisory Council.
Ms. ROLLINS. Congressman Brown, I assume you saved the best until
last?
Mr. BROWN. You may assume that.
Ms. ROLLINS. Thank you. I'm not going to read my testimony be-
cause I understand you must all eat lunch and then catch a plane, and
I think much of what needed to be said today has been said. But let me
reiterate a few things that I think are very important. I am vice chair-
man of the Citizens Clean Air Advisory Council, a group of citizens—
we call ourselves, I think, practical activists—we would like to see
things done in cleaning up our air and I can assure you it is a frustrat-
ing business at times. I'm also a member of the steering committee, the
liaison unit, to guide EPA research on the gulf coast on air pollution.
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We were invited for the first time to a meeting on October 19, that Mr.
Lozano referred to, several of the people referred to, and I think it
would be only fair for me to report that we, as kind of outsiders and
stragglers, were very taken aback to see that many of the people that
we assumed were in the business of taking care of the air—EPA, Texas
Air Control Board, School of Public Health—all the other groups who
were there representing what they say is public health, that many of
them had met each other for the first time.
Several hadn't seen each other for a very long time, and some had
only corresponded. This didn't lead to a great deal of equanimity in
the citizens'eyes, because we felt that they were about their business of
cleaning up the air. Now, most certainly, they have •been working at it
very hard. But not to take exception to some of the testimony that has
been given here this morning, there was reference by Dr. McKee of
the strides that we have made in public transportation. I have been
involved in that for quite a few years, and I think if you look at the
record we have fewer than 2 percent of our people who take public
transportation. Beyond that, we have 300 newly registered vehicles that
come into Harris County per day. Now you can talk about reduction,
reduction, reduction, but if 1 plus 2 plus 3 add up to something then
perhaps we have a problem that we really haven't addressed. Beyond
the things that we are looking into—and I'm very concerned about
the use of coal in this area—I keep thinking that in the wisdom of the
Congress perhaps we will be allowed to keep what natural gas is here,
but I think that would 'be a foolish assumption. But once we start add-
ing sulfur to the atmosphere I wonder what else it is that will come
forth. I think it all points to what the others have said here and the
reason for you being here today, and it's the real, necessary reason for
research in this area—an ongoing program that will not just measure
what is there—we need to know that—but also the acute health prob-
lems and the long range chronic problems.
There are references that I have made to my testimony that have
not come from environmental manuals but from industry and from
Mr. Barden, then executive director of the Texas Air Control Board,
when he testified before your committee on February 23. He
spoke then of the inadequate research that we have and of nis concern
for the presence of carcinogenic and otherwise toxic materials in the
ambient air. Even Fortune magazine that is not necessarily known as
a pro-environmental magazine, saying in November of 1976 that we
know very little of the thousands of new substances like the PCB's
that are finding their way, not just into the air, but into the water and
food. Most of these are present at low levels, but many are 'known to
be toxic or carcinogenic and only a few are now controlled. To me
that just screams for research, and it's you people who have the mech-
anism to see that we get it here in Houston.
I will say that the several times that we have met with the steering
committee, I think that it is a working committee, I think they are rea-
sonable, I know for sure I am, and I feel that there is a great deal of
work that we can do. Last night the HAOS study was presented to our
environmental group, and I must say that I was impressed, because
my suspicions were. I should say, not golden. I was wondering why
would these people be spending that kind of money, and having been
involved in research myself I do know and am fairly good at slanting
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arguments in the way I'd like to see them go. So the HAOS peopk
have turned up with sun. incredible amount of data that needs to be
assessed, but only with the help that perhaps you gentlemen on this
panel can provide will we find some of those answers.
Do you have any questions ?
Mr. BROWX. Well, let me thank you for your testimony. We do ap-
preciate your input. Our agenda was not overloaded with representa-
tives of public interest groups this morning, and you have an impor-
tant contribution to play. Do you have any questions, Mr. Eckhardt?
Mr. ECKHARDT. No, no questions, but I might say to Ms. Rollins,
as well as some of the other witnesses, that the conference committee
has now completed their work on what is called the coal conversion
provisions of the Energy Bill. In that is the recognition of the need to
continue to use gas in certain nonattainment situations. In addition,
of course, with respect to coal conversion in the electric utility field,
the deadlines are quite short. They call on us to use our maximum
efforts to try to solve these questions before there is too much coal
moving into an area.
Ms. ROLLINS. How about the study that has just, I think, started
at the University of Arizona. Will you benefit from that? It is a $6
million fund that is beginning to look into what coal conversion will
cause, and so I'm hoping that we, too, will benefit from what they find
out there.
Mr. ECKHARDT. Thank you, Mr. Chairman.
[The prepared statement of Ms. Rollins follows:]
TESTIMONY BEFORE THE SUBCOMMITTEE OF THE ENVIRONMENT AND THE ATMOS-
PHERE OF THE U.S. HOUSE OF REPRESENTATIVES SCIENCE AND TECHNOLOGY
COMMITTEE
MARY ROLLINS, VICE CHAIRMAN, CITIZENS CLEAN AIB ADVISORY COUNCIL,
HOUSTON ABEA
I'm Mary Rollins, vice-chairman of the Citizens Clean Air Advisory Council,
Houston area, and a member of the steering committee, liaison unit to guide EPA
research on gulf coast air pollution.
According to your invitation for me to speak here before you gentlemen today,
you asked that I address certain issues pertaining to urban air pollution prob-
lems. There are other spokesmen here who have more expertise than I. For that
reason I shall resort to testimony that you heard February 23, 1977 concerning
our local problem from then executive director of the Texas Air Control Board,
Mr. Charles R. Barden, P.E. He clearly stated that his capable staff "found
fragments of Information—largely from other parts of the country—available
data and research information so totally inadequate that little more can be
done until some reasonable amount of data and research Information relevant
to local conditions can be collected". He spoke to you of the pervasive brown or
gray haze which hangs over most of the nation's larger cities" and that "the
presence of carcinogenic and otherwise toxic materials in ambient air is the
other major concern".
Along that same line, Mr. Tom Alexander, in an article published by Fortune
magazine, November 1976, wrote that "there's good reason to suspect that even
now we may be spending too much money and manpower on pollutants that are
no longer much of a problem, while neglecting pollutants that are genuine haz-
ards. In particular, very little is known about thousands of new substances that,
like the PCB's, have been finding their way into water and air. Most of these
are present in low levels, but many are known to be toxic or carcinogenic, and
only a few are now controlled".
These statements, to me and I hope to you gentlemen, point to the need for
an adequately funded on-going research program whereby these toxic sub-
stances and carcinogenic substances can clearly be Identified as hazardous or
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nonhazardous. Only then will we citizens know if the air we breathe here in
Houston allows an adequate margin of safety to protect the public health. Too,
you gentlemen must concern yourselves with the transport problem. It is common
knowledge that if we are fortunate enough to get a "northerner" we've little or
no haze for a day or two but that when we get a "southerner" there are a few
complaints beyond the northern limits of Harris County and the southern limits
of Montgomery County.
"With our .current low level of knowledge, it is rather difficult if not impossible
to state whether the air here is unique or unusual. We think It is but thinking
alone doesn't constitute a reasonable amount of data and research Information
relevant to the local condition.
There will be testimony here today from heads of the regulatory agencies
who will tell you much as they've told me, that "We've turned the screws as
tight as we can on industry and even with the additional emphasis on better
catalytic converters, the problem is still here".
Perhaps more regulations won't improve the air appreciably but enforce-
ment should continue. For sure there shouldn't be a moratorium on regulations
while we await the results from the needed research.
As concerns strategies, you ask if there are alternatives to the controls. Sev-
eral have been suggested. First, the U.S. EPA in a publication by the National
Academy of Sciences, Washington, D.C., 19T7. It refers to the use of economic
incentives as an approach to environmental management It argues in favor of
the economic Incentive over the present emission standard.
Another person who agrees with that approach is Dr. Wilfred Beckerman
in his popular book "Two Cheers for the Affluent Society." He states that "pollu-
tion can be controlled when it Is recognized that the problem is not growth
but a misallocation of resources." "Because we do not consider that people
'own* clean air, clean water, 'quiet' and so on, we cannot easily extract payment
from people who use them by polluting them. Hence, the costs of pollution are
not usually borne by those that are responsible for the pollution, but instead
by the victims."
If we've a dearth of knowledge on the physical-chemical nature of the local
problem, then we've scant knowledge on acute health effects and an exiguous
knowledge of chronic health effects. What studies exist in Houston have
been sent to the EPA. Others here today will speak to it but In talking
with them and from our own work into the air pollution problem it is
very clear that we need research where we hope to find out what is in the air,
how elements and compounds react and interact and what the effects are eco-
logically and more importantly bodily over both short-term and long-term. The
cost of adverse impacts such as health effects cannot be calculated or estimated
until we know what it Is we breathe. I suspect the cost is very high indeed but
there are others here today who will argue that the benefits far outweigh the
risk. Only with a better information base will we stand a better chance of pre-
senting facts rather than suspicions.
In your question on how local groups should make input into the research
planning, I believe that we citizens witnessed and became part of the process
beginning October 19, 1977 when EPA invited us to participate in the planning.
We representatives of the Citizens Clean Air Advisory Council were there with
EPA. TACB, city and county pollution control, U. of Texas of School of Public
Health, Houston Chamber of Commerce. Rice U. and several other representatives.
We citizen representatives were somewhat surprised to see that several people
from these agencies met for the very first time, others had corresponded only and
others had not seen one another for a long time. We reached a consensus that it
is rather difficult to expect "cooperation" between agencies when there is in
fact very little "communication."
But, the communication did begin which is important and it is my hope that
our steering committee will continue to exist and for the betterment of air
quality in Houston that it function as well.
In summation, we citizens ask that the ambient air quality standards be set so
that their attainment and maintenance allow an adequate margin of protection
of public health, that the degree of protection be constant across the country, that
the Conjrress make a firm commitment to an adequately funded long-term re-
search effort so as to identify and deal with acute and chronic health effects here
in Houston and the gulf coast.
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Mr. BROWX. Thank you very much, Ms. Rollins, for your testimoi.
and may I urge you to continue to cooperate with the local groups.
You can help keep them honest, possibly. We have one final witness
who was originally scheduled to be first this morning, and instead will
be last this afternoon, the Honorable John Hill, Attorney General of
the State of Texas, and we welcome him here this afternoon.
Mr. HILL. Mr. Chairman, I am grateful to you for permitting me to
appear before the distinguished subcommittee. I know you've probably
endured about all you ought to have to endure by way of statements
here today, but I do feel deeply about this subject and your presence
here, so permit me if I might to have a word about our concern over
the need for additional research into the air pollution problem in
Houston and Harris County, and feel free, of course, to interrupt me
at any time for any question you might have.
Mr. BROWN. May I say, Mr. Hill, that your commitment and dili-
gence to getting here and testifying indicates the importance of the
subject, and we do appreciate it.
Mr. HILL. Well, you're kind to say that, but I did almost 5 years
ago now, when I became attorney general of this State. January 1,
1973, enter the office with a strong environmental platform,
with a pledge to enforce the environmental laws of this State, and
particularly here in the gulf coast where I'd spent most of my adult
life, and like everyone else living here was familiar with the serious
air pollution problem that we did have and, to some extent, of course,
still have. We've tried to keep that pledge and I'd like to give special
recognition to the late Dr. Quebedeaux, to whose efforts all of us owe
so much. We worked jointly with Dr. Quebedeaux and with the city of
Houston. I'd also like to pay my respects to the people that have
worked in that department so diligently and to the Air Control Board,
one of our really better clients that we feel have done a good job in
trying to reduce the amount of air pollution in this area. And I also
want to say that there's been significant voluntary compliance by local
industry in helping us work out this problem. I can say with, I believe,
a reasonable degree of certainty that as a result of all that cooperation
and working together that there is not a single major emitter of air
pollutants in the gulf coast area that's in violation of our State imple-
mentation plan, our State regulations. These efforts have resulted in
a tremendous reduction in the contaminants that are being emitted
into Houston's air, and I don't think there's any doubt that if it hadn't
been for those efforts that air pollution here would be far worse than
it is today, and indeed would probably be among the worst in the
world.
But despite these important gains, one does not need to be an en-
vironmental specialist, Mr. Chairman, to realize that we still do have
a major air pollution problem. One need only live here and breathe
the air to know that. And having worked closely with air pollution
experts for the last 5 years, it has become increasingly obvious to me
that our air pollution problem in this area transcends the five Federal
criteria pollutants, and the control strategies for those pollutants. And
the EPA has understandably concentrated its efforts on problems that
appear to be common throughout the Nation. And that's understand-
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able—it's aimed its programs at the handful of pollutants that it is
believed would have the most significant health effects nationally.
But as they've done so, it seems to us that other problems have gone
unsolved. And that's why we believe it's imperative, Mr. Chairman,
that Congress do provide the EPA the resources and that EPA use
those resources so that the next phase of pollution control in this
area can be aimed at providing programs that recognize and seek to
solve what we believe may well be a regional problem, to some extent.
Now the new $1 million study for Houston is an excellent first step,
but a first step is all that study could be. Houston's unique air pollu-
tion problem, it seems to us, demands more. And as I'm sure you're
aware, Mr. Chairman, Houston's air pollution does not fit the tradi-
tional model for air chemistry developed from the Los Angeles studies
and studies of other major cities in the country. The combination of a
warm climate, high humidity, close proximity to the ocean and the
high concentration of petroleum and chemical industries causes, we
believe, some uniqueness to this situation. As one result, the aerosol
haze in Houston is really not being reduced significantly under our
current program. And this is particularly disturbing because a large
percentage of these aerosols are within the particle size range, which
seems most likely to be able to cause adverse health effects. That has to
concern us all.
The failure of present Federal programs and the State's programs
to which they are tied by law, the failure of those programs to solve
those problems, it is only part of the reason this committee should, we
believe, be interested in further research for this part of the United
States, because Houston provides a unique opportunity to examine
problems associated with new fuel conversion programs. Since Texas
has an abundance of clean burning natural gas, the Houston air has
not been significantly contaminated, for example, with the sulfur com-
pounds common in other areas where coal and oil are burned. And that
situation, as you well know, is changing, and likely will be even accel-
erated in its change under certain proposals that are likely to pass the
Congress. And conversion to coal in Texas will create many new
sources of sulfur dioxide and sulfates. Research, then, into the current
components of the air pollution in Houston and the changes that result
with increased coal conversion should not only assist this part of the
country in solving new pollution problems, but would, we believe, aid
the country generally in the understanding of the air chemistry appli-
cable throughout the Nation.
Further, it seems to us that it's imperative that the new programs
mandated by the 1977 Clean Air Act get off to a good start. Because of
the complexity of the problem, the vast uncertainties and the tight
schedule required to get these programs started, EPA has often based
its decision, it seems to us, on limited and unpublished research. Pro-
grams that require the expenditure of millions of dollars and affect
the health of the public require a substantiated, accredited, factual,
scientific foundation understandable to those in our State who deal
with these EPA decisions. And the courts of the United States, by
repeatedly rejecting EPA decisions as lacking in scientific support,
have created the most obvious demand for this factual basis for deci-
sionmaking. One such case was the Texas case that, we filed over
the EPA's transportation control plan and which I personally
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handled. This plan was remanded to the EPA because of an inadequate
scientific basis. Now we do not enjoy having to sue a Federal agency
whose goals are the same as ours, but we do demand these regulatory
actions be knowledgeable and reflect an understanding of the problem,
and be based upon evidence that the regulations will actually result in
an improvement of air quality commensurate with the economic and
social burdens that they impose.
To insure, also, that regional research programs such as the Hous-
ton air pollution study are of a high scientific quality and are creditable
and are relevant to the actual problems, there must be an opportunity
for participation by local experts and by affected citizens— and we
are fortunate here in Houston to have an abundance of such local re-
sources—Rice University, the University of Houston, the medical
schools, the NASA facilities, the oxidant research presently being un-
dertaken by the chamber of commerce, the data collected and work
done by the fine staff of Dr. McKee and Ken MacKenzie, and the staff
and facilities of the Texas Air Control Board, just to name a few. And
I would hope that EPA would draw upon all of these resources. I fur-
ther urge that EPA recognize and use the citizens' committee currently
being organized to assist in developing its own research plan. This
committee can facilitate the exchange of technical information and
can reflect the concerns of the average citizen in the Houston area.
The ultimate purpose of all of this—or any research—is to have the
results accepted, first, and then acted upon. Since our hope is that the
Texas Air Control Board will adopt regulations on the basis of this
research, it is imperative, we believe, that citizens, the board, and lo-
cal air pollution experts be intimately involved in the research pro-
gram to insure their confidence—the citizens' confidence—and the com-
munity's acceptance of the ultimate result. And I want to stress that
the research needed for Houston must be relevant to the immediate
problems. We do not seek a laboratory in Houston for fundamental
research; instead we seek research into the sources and health effects
of the Houston aerosol haze, and the other pollutants that result from
chemical reactions in the air. A thorough review of the available in-
formation should be, we believe, followed by an assessment of where
research money can best be spent to aid in solving the gulf coast pollu-
tion problems.
And finally, then, Mr. Chairman, and again with great appreciation
for your indulgence, I know you're aware of the longstanding contro-
versy between the State of Texas and the EPA concerning oxidant con-
trol strategies, and it's not my intent to reopen this controversy here.
However, because of this disagreement, Texas officials have been
viewed in some quarters as having less than a total commitment to
clean air.
I want to dispel that misconception. And that misconception would
be that—if anyone holds it—that we are not totally committed to
clean air in this area. The citizens are, the air control board is, the
city offices are, the EPA—all of us—our office, the city attorney, the
county officials—I think it's fair to say that our record speaks for it-
self. We've not always been perfect, but we've tried hard. And I'd stack
up our efforts against anyone's. I've always believed that the State
should lead and not follow progress. And the State should be strongly
committed to clean air and clean water. And I assure you that we take
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a backseat to no one in our concern for this air pollution problem and
its health effect, and I assure you ours is not a philosophical dispute as
to whether or not we should have that clean air, but a technical dis-
pute as to how it can best be achieved. And your appearance here to-
day gives me hope that we can put this dispute behind us, so that we
can get the facts, make a resolution of the best possible program to
meet the real problem that exists, clear up the air pollution that we
have here, to write a great legacy for the future as far as this impor-
tant part of the United States is concerned, provide the quality of
life that must go with any dynamic city, and go about the business of
determining what is causing this problem and then proceeding vigo-
rously to solve it. And I'm so grateful, and I'm sure I speak the con-
cerns of the citizens of this area and of our State for your interest in
the matter. Thank you very much, Mr. Chairman.
Mr. BROWN. Thank you, Mr. Hill. I want to express my own ap-
preciation for your very sound and wise comments. I don't always
feel that brief hearings of this sort make a contribution to the solu-
tion of a problem, but I'm inclined to feel that because of the high
quality of the witnesses we've had, exemplified by yourself, as well as
Senator Bentsen and the various technical experts, that we may actu-
ally have made a contribution to getting us on the right track here.
And I am grateful to you.
Mr. HILL. Thank you very much.
Mr. BROWN. Do you have any questions ?
Mr. HILL. I might pay my special respects to our distinguished
Congressman, Mr. Bob Eckhardt of this area, and I don't know of
anyone in Congress that tried harder through the years to deal with
the environmental concerns of our State. I for one appreciate it, and
I'm sure that the citizens appreciate it, Mr. Congressman.
Mr. BROWN. Well, we're aware of his contribution in Washington,
and I said earlier today that our hearing here is due to the persuasive
efforts of Mr. Eckhardt, Mr. Gammage, and other members of the
Texas delegation and we really hope we can be helpful.
Mr. HILL. Yes, indeed, and Congressman Gammage is likewise fol-
lowing in that tradition of environmental concern and certainly we're
all aware of the good work of Mr. Bentsen. So thank you.
Mr. BROWN. And with those good words, the subcommittee will be
adjourned. We thank the members of the audience for their patience
in being with us these last 4 hours.
[The prepared statement of Mr. Hill follows:]
PREPARED STATEMENT OF JOHN L. Hnx, ATTORNEY GENERAL OP TEXAS
Mr. CHAIRMAN : Having spent considerable time and effort over the past five
years on the vexing problem of air pollution here in the Gulf Coast area, and
having long voiced my concern for the need for additional research into this
problem, it is with special pleasure that I welcome you to Houston and commend
you for the interest you have shown in our unique situation.
I was first elected attorney general on a strong environmental platform with
a firm pledge to enforce the environmental regulations of this state, particularly
here in the Gulf Coast area. This is a pledge that has been kept. Since January 1
of 1973, my office, working with the Texas Air Control Board, has prosecuted
over 100 lawsuits in the Houston area alone to abate violations of state and
federal air pollution regulations. Over 1% million dollars have been collected
in civil penalties in these cases. In many cases, we worked jointly with the City of
Houston, or Harris County and the late Dr. Quebedeaux, to whose efforts we
all owe so much. As a result of these State and local efforts, and the significant
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volutary compliance by local industry, I think I can say with a reasonable degree
of certainty that there is not a single major emitter of air pollutants in the Gulf
Coast area in violation of State regulations and the State's implementation plan.
These efforts have resulted in tremendous reductions in the amount of con-
taminants emitted into Houston's air. I don't think there is any doubt that had
it not been for these efforts air pollution in this area would be far worse than
it is today, and indeed would be among the worst in the world. However, despite
these important gains one does not need to be an environmental specialist to
realize that we still have a major air pollution problem—one need only live here
and breathe the air. Having worked closely with air pollution experts for the
last five years, it has become increasingly obvious to me that our air pollution
problem transcends the five federal criteria pollutants and the control strategies
for those pollutants.
While EPA has, understandably, concentrated its efforts on problems that ap-
peared to be common throughout the nation and has aimed its programs at the
handful of pollutants that it believed would have the most significant health
effects, other problems have gone unsolved.
Therefore, It is imperative that Congress provide EPA the resources, and that
EPA use those resources, so that the next phase of pollution control can be
aimed at providing programs that recognize and seek to solve unique regional
problems. The new million dollar study for Houston is an excellent first step.
A first step, however, is all that the study is. Houston's unique air pollution prob-
lem demands more.
As I am sure you are aware, Mr. Chairman, Houston's air pollution does not fit
the traditional model for air chemistry developed from the Los Angeles study
and studies of other major cities in the country. The combination of a warm
climate, high humidity, dose proximity to the ocean and the high concentration
of petroleum and chemical industries causes this unique situation. As one result
the aerosol haze in Houston is not being reduced significantly by current pro-
grams. This is particularly disturbing because a large percentage of these aero-
sols Is within the particle size range which seems most likely to cause adverse
health effects.
The failure of present Federal programs and the State's programs to which
they are tied by law to solve Houston's problem is only part of the reason this
committee should be interested in further research for this area of the country.
Houston provides a unique opportunity to examine problems associated with new
fuel conversion programs. Since Texas has had an abundance of clean burning
natural gas the Houston air has not been significantly contaminated with the
sulphur compounds common in other areas where coal and oil are burned. This
situation is changing, and conversion to coal in Texas will create many new
sources of sulphur dioxide and sulphates. Research into the current components
of the air pollution in Houston and the changes that result with increased coal
conversions should not only assist this part of the country in solving the new
pollution problems, but would aid in the understanding of air chemistry appli-
cable throughout the nation.
Further, it is imperative that the new programs mandated by the 1977 Clean
Air Act get off to a good start. Because of the complexity of the problem, the
vast uncertainties and the tight schedules required to get programs started.
EPA has often based its decisions on limited, unpublished research. Program*
that require the expenditure of millions of dollars and affect the health of th<»
public, however, require a substantiated, credible, factual foundation, under-
standable to those who must deal with EPA decisions.
The courts, by repeatedly rejecting EPA decisions lacking scientific support,
have created the most obvious demand for such a factual basis for decision. One
such case was the State of Texas' lawsuit over EPA's transportation control
plan, which I personally handled. This plan was remanded to EPA because of an
inadequate scientific basis. We do not enjoy having to sue a federal agency whose
goals are the same as ours, but we do demand these regulatory actions be knowl-
edgeable, reflect an understanding of the problem, and be based upon evidence
that the regulations will result in an improvement of air quality commensurate
with the economic and social burdens they impose.
To ensure that regional research programs, such as the Houston air pollution
study, are of high scientific quality, are credible, and are relevant to the actual
problem, there must be an opportunity for participation by local experts and
affected citizens. We are fortunate to have an abundance of local resources—Rice
University and the University of Houston, the medical schools, the NASA facili-
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ties, the oxidant research presently being undertaken by the Chamber of Com-
merce, the data collected and work done by the fine staff of Dr. McKee and
Ken MacKenzie, and the staff and facilities of the Texas Air Control Board,
to name a few.
I would hope that EPA would draw upon all of these resources. I further urge
that EPA recognize and use the citizens committee currently being organized to
assist in developing its research plan. This committee can facilitate the exchange
of technical Information and can reflect the concerns of the citizens in the Hous-
ton area. The ultimate purpose of this, or any, research is to hare the results
acepted and acted upon. Since our hope is that the Texas Air Control Board will
adopt regulations on the basis of this research, it is imperative that citizens,
the Board and local air pollution experts be intimately involved in the research
programs to ensure their confidence in the ultimate result.
I want to stress that the research needed for Houston must be relevant to the
immediate problem. We do not seek a laboratory in Houston for fundamental
research. Instead we seek research into the sources and health effects of the
Houston aerosol haze and the other pollutants that result from chemical reac-
tions in the air. A thorough review of the available information should be fol-
lowed by an assessment of where research money can best be spent to aid in solv-
ing the Gulf Coast pollution problem.
Finally, Mr. Chairman, I know you are aware of the long standing controversy
between the State of Texas and EPA concerning oxidant control strategies. It is
not my intent to reopen this controversy here. However, because of this disagree-
ment Texas officials have been viewed, in some quarters, as having Jess than a
total commitment to clean air. I would like to dispel this misconception. I take
a back seat to no one in concern for air pollution and its health effects; and I
know this is true of our state and local air pollution officials. I assure you ours
is not a philosophical dispute as to whether or not we should have clean air, but
a technical dispute as to how it can best be achieved. Your appearance here today
gives me hope that we can put this dispute behind us, so we can go about the
business of determining what is causing our air pollution problem and proceeding
vigorously to solve It.
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STATEMENT PRESENTED TO THE ENVIRONMENT AND .
THE ATMOSPHERIC SUBCOMMITTEE OF THE COMMITTEE ON SCIENCE AND TECHNOLOGY
GEORGE E. BROWN OF CALIFORNIA, CHAIRMAN I
NOVEMBER 21, 1977 j
i
I sincerely appreciate this opportunity to present testimony to'the
conmittee on behalf of the Harris County Pollution Control Department. He
are vitally concerned with the pollution problems of this area and are
looking forward to the proposed air pollution research to be undertaken by
the E.P.A. in this area. Other testimony presented to you at this time
will outline the research-activities which we believe are necessary po de-
v
fine our air pollution problems and ultimately suggest practical control
methods. •
The E.P.A. is in possession of a list of specific projects which I
proposed on October 19 and delivered to Mr. Ray Lozano of the Dallas of-
fice. In that statement I proposed that the E.P.A. station in Houston
for a period of not less than twelve months a'task force composed of its
own personnel to conduct research studies related to air pollutants and
their health effects. This task force should be empowered with sufficient
funds and flexibility to alter the course of their research program as
accumulating data dictates.
Further, I stated it is absolutely necessary that a local steering
committee be given official recognition to act in an advisory capacity to
the E.P.A. research staff. A committee was formed on October 19 and is
actively planning to interface with the E.P.A. to the extent allowed. A
copy of the comnit^ee membership is attached.
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Local entities, which have first hand knowledge of our day to
day problems, acting in cooperation with the E.P.A., which has the
personnel and equipment, can form a team capable of providing answers
to otjjc local, air DpJJution problems.
- s .-
A. R. Peirce
Director
Harris County Pollution Control Dept.
ARP/lb
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LIAISON COMMITTEE FORMED ON OCTOBER 19, 1977
Chairman - Or. 'Hioley .'1. Pier - University of Texas
School of Public Health
Dallas Evans
Allison R. Peirce
Jim Payne
Mary Rol1 ins
Larry Feldcamp
Dr. Richard Severs
Unnamed
Ex officio Ray Lozano
Ex officio Robert Rowley
City of Houston
Air Pollution Control
Harris County
Pollution Control Department
State
Texas Air Control Board
Citizens Groups
League of Women Voters
Citizens Environmental Coalition
Citizens Clean Air Advisory Committee
Houston Area Oxidant Study
San Jacinto Lung Association
Harris County Medical Society
Federal
E.P.A. - Dallas
Federal
NASA
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• 14 HAROLD ' HOUSTON. TEXAS 77OO*
LEAGUE OF WOMEN VOTERS OF HOUSTON
TESTIMONY SUBMITTED TO THE U.S. HOUSE OF REPRESENTATIVES
CCMMITTEE ON SCIENCE AND TECHNOLOGY
from
Brenda Gehen
President of the League of Wonen Voters of Houston
Because of our deep concern for the public health of the citizens of
Houston, the League of Wonen Voters of Houston has decided to submit testimony
regarding the need for research in the area of air pollution in Houston/Harris
County* As a citizen's group that has worked in the field of air quality for
many years, the Houston League regularly sends representatives to public
hearings, educational conferences and briefings, so that our Information on
local air quality is kept as current and as complete as possible. We have
identified several Issues of local significance that we believe should
receive attention and thorough research.
We are concerned about preventing the possible development of chronic
respiratory and cardiovascular diseases, which nay be the result of un-
controllable levels of ozone (0-a). The high levels of Oj that often exceed
the primary national ambient air quality standard (NAAQS) In Houston do not
seen to elicit the same physiological responses that a corresponding level
does in California. While eye lacrimation and vegetation danage do not seen
to occur in Houston, as in California, suggesting that another photo-
chemical oxidant may be responsible for these effects, we recognise that
0^ itself may be damaging to health. Presently, in Houston, 0-a does not
-1-
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appear to be responding to the Los Anpales developed control strategy to
prevent its formation. This indicates that there nay be some regional
differences between the Los Angeles air and the Houston air. We believe
that a more appropriate control strategy for Oj in the Gulf Coast area needs
to be developed. In this regard, the data provided by the Houston Area
Oxldant Study should be analyzed and built upon. Because the clinical
effects study was deleted due to inadequate funding, this needs to be
initiated. In addition, the epidemiological studies need to be continued
on a long tern basis.
We are concerned that the respirable particulates, which are the most
damaging to public health are not being measured by present monitoring
techniques. We are aware that particulates exceed the primary NAAQS in
Houston. Their size and composition need to be adequately determined. Of
particular concern is the possibility that they nay be carrying carcinogenic
substances. Thus improved methods of analyzing and measuring resplrables,
including aerosols, need to be developed.
Many Houstonians are concerned about the public health implications of
fossil fuel conversion due to natural shortages. The large number of
industrial facilities in the Houston area make this a potentially wide-
spread problem. The high humidity will hasten the conversion of sulfur dioxide
(S02) to sulfites and sulfates which researchers seem to be recognizing as
being more damaging to health than 502 ^tself. An assessment needs to be
made about these health implications.
Another concern is that the possible synergistic action of these
pollutants (0-j, particulates/aerosols, and SOz) with each other, as well
as with the complex organic emissions of Houston's petrochemical-refinery
industries is not presently bei-g determined. This area needs to be researched.
-2-
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400
What may be of the highest priority is the need to determine the re-
lationship between Houston's air pollution constituents and the unusually
high cancer mortality rates in our region.
At a meeting in Houston this January at M.D. Anderson and Tumor Institute,
Dr. Joseph Frauneni, chief of environmental epidemiology with the National
Cancer Institute (NCI), said that in a survey of U.S. cancer deaths his
group found a significantly higher death rate from lung cancer in Southeast
Atlantic and Gulf Coast counties, including Harris County (in which Houston
is locatedX He pointed to the petrochemical industry as being one of the
common elements in the counties with high incidences of lung cancer.
Relatedly, in a survey of cancer mortality conducted by the NCI in
counties where the petroleum industry is most heavily concentrated, NCI
epidemiologists observed in the October 7, 1977 issue of Science thati
'The correlations with lung cancer in the study are a
cause for concern because lung cancer occurs excessively
among other polycycllc aromatic hydrocarbon exposed
groups.....| and the high rates of lung cancer among
female residents in the petroleum industry counties raise
the possibility of a pollution hazard spreading beyond
the workplace."
In conclusion, Houston's needs, and the concentration of its medical
and other research facilities make it appear to be an ideal place for the
acquisition of new knowledge, by developing appropriate methods and
techniques, and by initiating clinical effects and epidemiological studies.
In addition, the concentration of petrochemical industries suggests Houston
as being an ideal location for initiations programs to discover a possible
environmental/occupational link to increased cancer mortality rates.
-3-
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TESTIMONY
BEFORE THE SUBCOMMITTE ON THE ENVJHONMENT
AND TH2 ATMOSPHERE
DP THE U. S. HOUSE OP REPRESENTATIVES
SCIENCE AND TECHNOLOGY COMMITTEE
November 21, 1977
Houston, Texas
Stennie Meadours
Galveston Bay Conservation and Preservation Association
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I an representing Galveston Bay Conservation and Preservation Association
). Our organisation acts aa environmental vatohdog for Calve*ton Bay
and the La Porte, Shoreacres, Seabrook and Clear Lake area.
At present I an employed a* a Naturalist at the Arnand Bayou Nature
Center. In December of 197? 1 will receive a BS degree in Public Affairs,
Environmental Management. At this time I am serving a three year term on
the Executive Board of the GBCPA, and am a member of the newly formed
Citizens Clean Air Advisory Council for the Houston Area. I participated in
a consulting capacity In the Bayport Channel Citizens Commission's (BCCC)
actions. And moct recently testified at the Texas Air Control Boaru (TACB) -
American Hoechst Corporation ajudacatlve hearing.
GBCPA represents a unique community. The residents, approximately
UO.OOO, are a mix of Black, Brown and Whitei volunteer, blue collar, white
collar and professional,. The majority are employed by NASA, University of
Houston at Clear Lake City and local Industry. The school systems are
excellent, where industrial taxes play a key role. Tear-round extra-
clrlcular activities for children aboundi scouting, soccer, baseball, foot*
•ball and competative swimming. Many adults give time, love and energy as
volunteer coaches and scout leaders. In addition, this particular geo-
graphical area offers a diversity of outdoor recreational activities) fishing)
shrimping, crabbing, sailing, canoeing, tennis, hiking and blrdlng.
Here exists a high degree of community Identity and oohesiveneas. It Is
• i'p»r«nl that Ihe reeld«nl.m value the quality of life limy iiresently •n.loy.
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Paradoxloally, this community Is on intimate tents with Industry and
Industrial pollution. It Is bounded by Calveston Bay to the East, Bayport
Industrial Complex to the Vest, Texas. City Industrial Complex to the South
And the Houston Ship Channel and Harbour's Cut to the North. We see, hear,
smell and taste industrial pollution in varying degrees every day of the year.
Vdslcol, -f the recent "Phosvel Zombie* tragedy, is one mile from my home.
As a a naturalist I appreciate the biological diversity that exists herei
alligator, bobcat, coyote, deer, osprey, houndreds of shore and migratory birds,
the flood plain forest, the ooastal prarie, and of course the Gulf Coast,
As a mother of three children I appreciate the human diversity represented
in my community. I believe my children will be better prepared for adult
life as a result of their exiosure to people of differing social, economic and
racial backgrounds.
I have spent a good deal of your and my time explaining the character
of our community. I do this so you will realize the value of what is being
threatened.
This hearing is being held by the Committee on Science and Technology
Sub-committee on the Environment and the Atmosphere. The majority of
testimony, I understand, will address areas where scientific studies and
technological advances will, hopefully, improve the environmental quaillty
of the greater Houston area. The object of this testimony is not to refute
the value and necessity of research. Rather, to address areas where, in
addition to environmental Improvements brought about by researchi environ-
mental quality can be enhanced by changes in Texas Air Control Board policy
and procedures.
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Recent experience with the CBCPA community's attempts to maintain
environmental quality haa pointed, very clearly, to environmental legislation
Inconsistencies and the need for changes in TAGS's present methods.
To properly define the Issues, I Hill precede as followsi First, a
brief overview of the area's past environmental conflicts. Secondly, using
actual examples fro* these activities, delineate the specific inconsistencies
and procedural problems encountered. And lastly, to present a proposed solutlo
As a common denominator to the following cases) In 1961* during the land
acquisition phase of Bayport, residents were assured that there would be no
producing plants east of Hwy..l46 and for further protection the north bank
would be left vacant to act as a buffer cone.
In 1975 Atlantic Richfield Company applied for a permit from the Corps of
Armay Engineers to construct an off-dock loading facility on the north bank of
the Bayport channel. This facility would be capable of handling 2 million
barrels of crude oil a day; it would accommodate the VLC tanker, 130,000 dead
weight ton*, ( the VLCs are so large that for them to navigate the Houston ship-
ohannel one-way traffic would be required) and this facility wa» to be located
approximately 125 feet from established homes. Previous to permit Issuance
at a public hearing and by letter the community voiced its opposition. The
Corps stated that an Environmental Impact Statement (BIS) was not required and
issued the permit. The BCCC was formed, then filed wilt* ifaJnst the Corps on
UM Ktttundi that in KTS was required. After Judge Bue ordered an BIS the permit
application was essentially dropped. No further actions were taken by the
Corps or ARCO. This process cost the citliens approximately $17,000.00 in
legal fees.
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In July of 1977 Texas Cir Control Board Issued a peralt to construct to
Anerlcan Hoachst Corporation, a German based firm. The facility was to be
located on the east side of Hwy. 1<*6 between the communities of Shore acres,
Bay Colony and El Jardln. The proposed plant utilized benzene, a known
carcinogen, to produce styrene Bonomer, a known odor pollutant. It «as to be
located such that the res'rtantlal areas ware directly downwind from the
prevailing air flow. The permit application snowed the plant to have unusually
high pollution control technology with only 71* tons of emissions per year.
The affected residents work in the petrochemical Industry, they know
how pollution abatement devices and TACB permits work on the day to day reality
basis. Area citizens also know that no Batter how good a permit looks on
paper they can be 100!< sure that the plant will have more emissions then stated
on the permit. The community became alarmed| the GBCPA appealed the permit.
Again the citizens bore the cost of lawyer fees. This tine for a TACB
adjucative hearing. A hearing that pitted lay citieens against a state agency,
TACB defending their previously issued permit, and American Hoechst a 9i billion
dollar foreign firm.
At present the American Hoechst hearing is in the process of a Texas Air
Control Board review and decision. The American Hoechst hearing was the first
ajudacatlw hearing held by the air board. Following are the policy and
procedural problems which beoaae apparant.
I. TACB rules and regulation preclude public input and parllclpatUm.
The air board does not provide any form of public notice of either permit
applications, or of permitting actions taken by the board. Bay area residents
learned of the permit via a newspaper article on the American Hoechst land
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optlon. Harold Scarlett, the Houston Post Environmental Writer, after
attending several sessions of the hearing captures the essence of the situation
in his featured column.
"Three years ago, after a similar laok of public notice in a
Spring Branch case, the air board pledged to hold public heajMn»s in
all future cases involving potentially controversial permits.
)Tet, Incredibly, the air board even nov still has no Machinery
for notifying oltleenn of the new Industrial projects that could affect
their neighborhoods.
The agency, in fact, has mo-red in the opposite direction, toward
even less communication with the public.
Last February, pleading excessive expense, the air board
stopped sending mill notices to interested cltltens and groups
who had requested them.
It said interested persons oould henoe-forth find such Infor-
mation published in the new Texas Register (subscription price 1(25. 00
a year)."
"But, it turned out, the air board does not publish construction
permit applications in the Register."
"Air board pernlt applications appear only (and there In skeleton
font) in the Texas Pollution Rep ort, a private Austin publication
that costs $50.00 a year. Even there, the permit listing was instigated
by the publication not the air board."
"As of today, the air board still does not advise the public In
any way-not even in a newspaper legal notice -- of even major
industrial projects such as the Hoechst plant."
The TACB public notice and hearing policies axe in direct contrast to those
of Texas Water Resources;
When a citizen or a group requests, they are placed on the TWR mailing
list. Then then receive notices of all public hearings) the time, place and
the pertinent permit application Information. The WH holds a public hearing
for all permit applications. In addition, TOR gives timely notioei two months
to six weeks In advance of the hearing.
At TVB public hearings all interested parties may speak with no prior
notification to the TVJt. To contrast TACB ajudaoatlve hearings a summary of
TACB procedural rule 5^.6 follows.
Cltisen'e wishing to be hard must notify the TACB by a certain date,
then a prehearlng conference, where the issues are defined, Is held. At the
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prahearing conference the parties are required toi present a list of
witnesses, and a brief summary of their prospective testimony, present a
written statement of the disputed issues, present a copy of written state-
Bents and all other written testimony or evidence the party intends to use
at the hearing. The hearing examiner at the prehearing conference has complete
authority over what may be submitted as evidence and what Issues are revelant.
1 returned from a Thanksgiving trip late Sunday night Nov. 27, 1977.
1 checked my mail on return from work Monday the 8th. As a member of CCAAC I
regularly receive •; packets with information of TACB recent activities. On the
8th such a packet, post marked Nov. 23, was in my mall. This packet contained
a notice of a permit application hearing set Dec. 19, 1977. The subject of the
hearing was a B. f. Goodrich permit to construct on a site east of Hwy. 1^6
in the Bayport complex. The notice stated, "No person shall be admitted a
party unless the request Is received at the address shown above by November 28,
1977. At the hearing, only those persons admitted as parties will be permitted
to present evidence and argument and to crossexaiMne witnesses. The timing of
this notification precluded my participation as a concerned citizen and as a.
member of the CCAAC.
TACB is also out of phase with the Corps public notice procedure. The
Corps maintains a notification list. When your name is placed on the list,
you receive a copy of a detailed description and location of the proposed
project. The Corps holds public hearings when public response to a particular
permit demonstrates a need.
Kvms If fflran t1m«ly notice, th» oltlMn lias »n<>th«r obstaaj* In his
efforts to have some input in TACB permit decisions, it is almost impossible
for the lay citicen to effectively manuever through the legal maice required
by an ajudacative hearing. If this is accomplished, and if other hearings
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are anything like the American Hoectsh hearing, the company lawyer's legal
skill and experience could easily devlstate citizen parties. Thus to be e
effectively represented TACB ajudaoative hearings require legal council for
the citizen.
Neither 7V» or the Corps require legal council for the lay citizen
to effectively participate at a hearing.
2. TACB citizen response time. Permit application Information Is
difficult and sometimes impossible to get.
On Nov. 8, 197? a request for permit application information on the
Goodrich plant was made by CBCPA. The TACB wrote backet and said that the
request would be forwarded to the permit applicant's (B. P. Goodrich) lawyer
and he would forward the information. About two weeks later a latter was
sent to the GBCPA stating that to avoid confusion all future request should
be made the the TACB lawyer. Finally on Nov. 25, 1977 the information was
received. It was packaged so badly that the postman had to put rubber bands
around it to keep it together, It is a wonder that the post office delivered it
at all.
When CBCPA requested information on the American Hoechat permit a three
week delay ensued, then only s portion of the permit Information was made
available. This three week delay was in a period of preparation for the
ajudacatlve hearing, where only permit Issues can be discussed.
Understandably the above two Incidences, the only occasion* CHCPA
has had to request permit application information, have added to citizen
frustration and In fact has limited participation.
Possibly the reason is as Harold Scarlett mentions, TACB has no Internal
machinery for this function. What ever the reason, In reality these actions
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wlden the gap In TACB and citizen trust. An area of extreme distrust has
been created by present TACB policies and procedures. This distrust Bakes
environmental issues sore difficult and expensive to resolve.
3- TACB designates land use but does not consider land-use impacts,
Texas lax requires a TACB permit to construct be granted first before any
other pernits Bay be obtained. In fact, financing and land options are held
until the construction permit is Issued. It cannot be denied that social,
economic and environmental impacts will accompany the new facility and its
resulting activities, thus affecting the surrounding area.
During the course of the Hoectsh hearing TACB lawyer and staff members
maintained that only air emissions Impacts to surrounding area could be
considered in construction permits.
Following are excerpts from the Texas Clean Air Act. I propose that
the TCAA does not preclude, but rather includes, land use considerations in
the decision to Issue a construction permit.
"Policy and purpose"
"Section 1.02. It is the policy of this state and the purpose of
this Act to safeguard the ari resources of the state from pollution
by controlling or abating air pollution and emissions of air con-
taminants, consistent with the protection of health, general welfare.
and the physical property of the people, including the esthetic enjoy-
ment of the air resources by the people and the maintenance of ade-
auate visibility."
"Factors to be considered"
"Sectloo 3.13. In making orders and determinations, the board shall
oonsldsr all of the facts and olrouBstanoes bearing upon the reason-
ableness of any emissions being made, inoludimi
"(1) the character and degree of injury to, or interference with,
the health and physical property of the peoplei
"(2) the social and economic value of ti» sourcei
"(3) the question of priority of location In the area involved* and
"(U) the technical practicability and economic reasonableness ••{
reducing or eliminating the emissions resulting from the source."
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"Construction Permit"
"(c) If, from the information submitted under subsection (b) of
this section, the board finds no indication that the proposed facility
will contravene the intent of +h» Texas Clean Air Act, Including proper
consideration of land use, the board shall grant within a reasonable
tine a permit to construct.....ot the proposed facility."
The Clean Air Act of 1977 as»ends "Implementation Plans" section
110(a) (2) (B).of the Federal Clean Air Act of 1970. In a TACB staff summary
report of the Clean Air Act of 1977, *h*y interpret!
•Land Use
The phrase •land-use" is deleted from section 110(a) (2) (B) of the
act, which sets out requirements for State implementation plans.
The words "air quality maintenance plans, and preconstructlon review
of direct sources of air pollution" are substituted, ^reconstruction
reviews of direct sources are to Include consideration of energy, envlren-
mental and economic Impacts. The only land-use regulations which may
result from Implementation of this act are those which are needed to
assure attainment and maintenance of ambient air quality standards
and prevent significant deterioration of air quality."
I interpret this to mean TACB may not issue land use regualtlons unless it
is required to "assure....attainment....prevent significant deterioration
of air quality".
Further, preconstructlon reviews are defined as considerations of energy,
environment and economic impacts. I read the auendment to formal Ire the consid-
erations of land-use Impacts Into preconstruction reviews. The preconstructlon
reviews make considerations of energy, environmental and economic Impacts a legal
requirement in the State implementation plans.
In the determination to issue a permit to construct, rwn when th>-
n»siiMtnf: facility In netting a precedent in land-use, or when there Is con-
flicting land use, i.e. constructing a facility that utilises large quantities
of highly toxic benzene in a coastal natural hazzard area where subsidence,
faulting and hurricanes are commom, the TAGS maintains that they cannot legally
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conslder Impacts other than air in their decision making.
This is Indeed arbitrary and capricious decision making; diametrically
opposed to the spirit and intent of the Claan Air Act of 1977 and the National
Environmental Policy Act of 1969.
In Texas, the task >f environmental considerations and reasonable land use
Seems to have fallen to the citizen. He performs this job by the costly
process of litigationj this is in addition to his normal tax burden.
1*. Comprehensiveness and credibility of TAGS permit evaluation data.
Within the next 30 days EPA will decide if Texas will receive a waiver
to the new off-set policy. In the near future industrial plants may be required
to switch to an alternate fuel, possibly coal. The Anerican Hoectsh permit
did not list an alternate fuel as such.; it listed another grade of the same fuel,
A company official testified that American Hoechst had unlimited access to
fuel oil #2 and #6. He further testified that the plant, as designed in this
permit, could not operate with coal as a fuel, (this does not preclude the
possibility of plant modificationi this could not be discussed, however, because
according to TACB rules only information pertaining to this permit could be
addressed).
A permit to construct was granted based on the use of fuel oil #2 and #6 only.
Once the plant would be operating, and the switch to coal required, it becomes
an economic matter to rationalize the resulting pollution.
With off-set and alternate fuel policy decisions pending atculrt not
consideration be given to future possible air emissions when TACB evaluates
an application for a .pernit to construct.
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Heoently \n the Corpus Chrlstl Petrochemical Plant ease, EPA Invalidated a
TACB permit to construct because TACB 4id not consider fugitive emissions.
The American noechst pemit is siiiilar. An American Hoectah official testified
under oath that there would be no fugitive emissions. No consideration of
fugitive emissions Here given In the pemlt. It Is truly hard to conceive of
an industrial plant without fugitive emissions. TACB publlcally accepted the
assertion that there would be no fugitive missions in either of American Hoectsh's
ethlbencene strrene monomer plant and the high density polyethlene plant.
For pemit evaluation TACB requires modeling of air emissions. The
model presented by Anerlcan Hoectsh and accepted by TACB was predicated on
questionable data. Inacurracles in prevailing wind direction and participation
rates were brought out by citieen testimony. These Inaccuracies partially
Invalidate the results of the Modeling, yet| a pemlt has been Issued utilizing
this data.
Included in the air quality assessment, prepared by a private environmental
fin, was additional data concerning fugitive dust emissions. This data
accompanying the American Hoechst pemit application was accepted as credible
b) TACB. This study compared the level of fugitive dust emissions of the
undeveloped site with fugitive emissions after the proposed facility is completed.
The fugitive dust emissions study states that a simplified verm Ion of a
certain equations is used, but It does not give the simplified version. The
study also, did not state which factor was used for the different ponuioters,
1. e. I- soil credibility, K- surface roughness, C- climatic factor, and Lf-
unsheltered field factor. The modeling was based on the site soil being
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being sandy loam with 5<# vegetation coverage.
The outcome of the air modeling Is stated In the study.
"Employing these assumptions, the model y^»\ds a total participate
emission of 69.3 tons/year for the undeveloped site and 29.3 tono/year
for the site after the proposed chemical plant Is completed. This latter
value employs the assumptions that the barren surface within the chemical
plant boundaries Is treated with stabilizing chemicals. The construction
of the chemical plant would therefore reduce fugitive partlculate
emissions of the site by 1*0. tons/year CO percent of present emissions)."
A quick check in the Soil Survey of Harris County, Texas, United States
Department of Agriculture Soil Conservation Service, shows the soil to be
Beaumount clay, not sandy loam. A comprehensive personal inspection of the
site showed it to be densly covered (96/t -100£) in coastal prarie grasses.
The basic assumptions having been provn nrronous completely Invalidates
the study.
The question must be asked, why would such inaccurate, biased data
be presented and then accepted by .TACB.
The reports conclusion, even if it were accurate, that American Hoectsh will
reduce pollution by chemical plant construction, denuding the remaining site
and applying chemicals is an insult to the intelligence of even my 12 year old •
In conclusion, If we add the "fugitive emissions reduced by construction"
(29.3 tons/year) to those produced by plant operation (73.6. tons/year) tbe
result is 103.2 tons/year. This would push the American Hoectsh plant Into the
major source catagory.
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In the above I have pointed out the areas where Texas citizens have set
with frustration and confusion in their attempe to have an accounting for
environmental quality in their community. A large part of the confusion and
frustration is due to the fact that TACB, a state environment agency, sup-
ported by tax dollars, does not offer affected eltitensi the courtesy of notice,
an opportunity to offer input, nor the assurance of accountability.
The solutions we propose are not new, but have proven effective by
Texas Water Resources and the Amy Corps of Engineers.
To insure proper notice, opportunity of Input and to provide pertinent
information for affected citizens the CBCPA strongly ur^s TACB to promulgate
public notice rules and regulations.
These public notice rules and regulations, if promulgated, would foster
trust between citizens and TACB and would validate full representation of
citizen, government and industry. In such a dynamic and resource rich state,
such as TexasI it is almost incredible that the machinery for a public notice
and response process does not already exist,
Secondly, in order that acknowledgement and considerations be given
to the full implications of a penult to construct, to insure proper land-use
considerations, and to have comprehensive accurate and pertinent data used in
permit evaluation, GBCPA propose that legislation be passed, or TACB Interpret
the TCAA, requiring an Environmental Impact Statement when, land-use permitted
by * permit to construct Is precedent setting or when the results of a permit
to construct would significantly affect the hvunan environment.
California and North Carolina are two states that require EIS'si surely
Texas resources, land-use, cltlsen health, welfare, property , environmental
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quality and economy -are as valuable as Claifornla's and North CarolinU's.
If we are to learn how to control air pollution, research Bust continue,
however, Its value will be diminished unless adequate environmental considera-
tions are made on the implementation level of government. As the Texas Clean
Air is presently interpreted, the issues of TAGS public notice and participation,
citizen response, land -use designation without considerations and comprehensive
and credible permit evaluation data, provided serious loopholes in the imple-
mentation of TCAA. If these loopholes are not closed citlcens , government
and industry will continue to lose money, tima , resources and environmental
quality.
The National environmental Policy Act of 1969 requires balancing of
economic and environmental Issues. Our life support system, the biosphere is
based on the balance of environmental and biological factors. Is It not
reasonable that the State of Texas provide a means to intelligently balance
Industrial development and human habitat?
The CBCPA community is involved and caring, however, there will be a
point, (possibly the proximity of one more Industrial paint), where each
individual will decide that thl> their present home is no longer safe.
This is a threshold decision, based on the value each person places on
environmental quality. Some of our neighbors have reached that threshold.
The destruction of human habitat Is the ultimate threat of industrial
encroachment, this is what we fear. Our community is precious to us.
Respectfully submitted,
Stennie Headours, Spokesman CBCPA
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JlT"~ J.g^iWfl-LAl-l.ll/L^-
^_5_r* 4?«a' "«w»jf,
STATEMENT FOR THE HEARING OF
THE ENVIRONMENT AND ATMOSPHERE SUBCOMMITTEE
COMMITTEE ON SCIENCE AND TECHNOLOGY
U.S. HOUSE OF REPRESENTATIVES
By
John W. Hathorn, Vice President
APPLIED METEOROLOGY, INCORPORATED
9000 Southwest Freeway
Suite 111
Houston, Texas 77074
December 1, 1977
SUBJECT:
• RECOMMENDATION -
-To Study Synoptic Weather Pattern's
Influence on Ozone Eplsodes-
« PHOTOCHEMICAL OXIDANTS STUDY IN GULF
COAST AREA
• ENVIRONMENT AND ATMOSPHERE SUBCOMMITTEE
OF U.S. HOUSE OF REPRESENTATIVES
My name 1s John Wesley Hathorn, and I am submitting this statement 1n my capa-
cities both as a professional consulting meteorologist for Applied Meteorology,
Incorporated, and as an Interested and concerned private citizen of Houston,
Texas. Since the opinions that I now hold are based on information accumulated
over several years of experience, I will begin by discussing my credentials.
After this brief resume, I will summarize the characteristics associated with
ozone episodes In the eastern United States. Next. I will enumerate several
facts concerning the photochemical oxidants problem in Houston and the eastern
United States. I will then conclude my statement by recommending an area of
study that has received little attention but which I feel has a high probability
of explaining both the high frequency of ozone episodes In the eastern United
States, and why the Hydrocarbon Control Strategy is not reducing photochemical
oxidant concentrations there.
My credentials are as follows:
1. I have a bachelor of science and a master of science degree in
meteorology from Florida State University.
2. In 1963 and 1964. while at Florida State University, I worked in the
Upper Atmospheric Laboratory where weekly ozone soundings from the
ground-level into the stratosphere were made.
3. Since graduation, I have accumulated fourteen years of experience
1n meteorological analysis and atmospheric chemistry (Including
instrumentation and monitoring, field diffusion/tracer studies,
airborne sampling, computer modeling and diffusion analyses, and
overall environmental program design and management]. This experi-
ence was obtained as a meteorologist and weather forecaster for the
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I/pat Reteribgr it
U.S. Weather Bureau, as a research meteorologist for the Boeing
Company (on the Saturn V/Apollo Program), and as a consulting
meteorologist (for AMI and another environmental consulting com-
pany) in Atlanta, Chicago, and Houston.
4. I have experience in analyzing and forecasting the weather phenomenon
in the eastern United States since I grew up in Baton Rouge, Louisiana,
was a meteorologist at the National Weather Stations in Port Arthur/
Beaumont, Texas; Memphis, Tennessee; and Huntsvllle, Alabama. Also,
I was formally taught "current synoptic weather" at Florida State
University, Tallahassee, Florida.
5. I assisted the Houston Area Qxldants Study (HAOS) 1n designing their
program and wrote the HAOS Program Description (.referred to as the
"Blue Book").
6. I have published a paper at the International Conference on Photo-
chemical Oxidant Pollution and Its Control (Hathorn & Walker, 1977).
This paper described (1) an analyses of an ozone episode which I
personally prepared (based upon data supplied by Monsanto Chemical)
and (2) a postulation of "ozone enhancement" by Dr. Harry Walker
(Monsanto Chemical).
I recognize that there are many excellent meteorologists who have advised the
EPA on the meteorological aspects of the photochemical oxldants problem; however,
because I have worked in an operational weather station on the Gulf Coast (I.e.,
Port Arthur/Beaumont, Texas), I have an appreciation for a little understood,
but routinely occurring, weather phenomenon:
the dissipation of the cold front's structure after it has
pushed out over the warm waters of the Gulf of Mexico.
Understanding this phenomenon 1s basic to understanding the cause of ozone epi-
sodes In the eastern United States.
I would now like to list some of the typical characteristics for regional ozone
episodes as follows:
1. High ozone concentrations will persist for several days.
2. Both rural and urban air quality monitoring (AQM) stations through-
out a large region, whether upwind or downwind of urban or industrial
areas, will experience the episode.
3. Concentrations of other contaminants will not necessarily be high
at the same time that the ozone concentrations are high.
4. Ozone concentrations rise sharply after sunrise and decrease after
dark.
5. Usually the wind is from the southern quadrant and there is a large
subtropical anticyclone (in other words, high pressure area) located
east to northeast of the region experiencing the episode. (This is
referred to as "being in on the backside of a high.")
6. The frequency of occurrences is large (e.g., In Texas, more than
three times in some months).
7. These episodes occur so routinely in the eastern United States that
2.
ENV S ATM SUBCOH
December 1, 1977
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418
JDT
EPA has suggested to all eastern states that they categorize their
entire state as a non-attainment area for photochemical oxidants
(unless they have monitoring data to prove otherwise).
8. Typically the air in an ozone episode in the eastern United States
is not necessarily classified as "stagnant" but does have notion
and is characterized by some mixing.
There are several facts about the photochemical oxidants problem that are routinely
seen in publications by EPA and other researchers:
1. Because of the data available, EPA has instructed all states 1n the
eastern United States to consider all areas of their state as non-
attainment areas for photochemical oxidants (unless there is data
to prove otherwise).
2. Even though the Hydrocarbon Control Strategy has been applied in
the Houston area, ozone episodes are just is severe and just as
frequent as before hydrocarbon emission reductions were Implemented.
3. Estimates of the contribution to ground-level ozone concentrations
from the stratospheric source range from 25-33 ppb (Mohnen, 1976)
on an annual average.
Some additional facts that are necessary to understanding weather 1n the eastern
United States are:
4. Cold fronts (polar outbreaks) push down across the Great Plains
into the south and out into the Gulf of Mexico.
S. The waters in the Gulf of Mexico are typically wanner than the
air behind a cold front.
6. As cold air pushes out over the warm waters of the Gulf of Mexico,
It begins to warm with time. The longer the air travels over the
warm water, the warmer the air gets.
7. Since the cold front weather patterns typically move eastward,
and the cold front is followed by a high pressure area on the sur-
face of the earth, there is a trailing edge of the cold air which,
because it is not associated with any severe weather, has received
very little attention 1n the literature. (See Figure 1)
3.
ENV & ATM SUBCOH
December 1, 1977
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JDT
8. The cold front's trailing edge may dissipate near tbe surface when
1t has pushed out over the warm Gulf waters. This dissipation will
allow any air (or pollutant) trapped within the frontal zone (or
layer) to mix to the surface.
Other facts that have been observed, but are not so frequently cited 1n litera-
ture, are:
9. Stratospheric ozone has been observed In the frontal layer In the
mid and upper troposphere.
10. Frequently, during air pollution episodes for other contaminants
(such as sulfur dioxide; where a trapping Inversion 1s overlaying
an area, high ozone concentrations have been measured within the
trapping Inversion.
11. The air within the trapping Inversion can be directly Identified
as being an old cold front that has previously pushed through the
area.
12. The occurrence of ozone episodes in the eastern United States can
be shown to be closely linked to the frequency of weather patterns
(cold fronts and associated Highs) as they move through the area.
By this straightforward listing of known or demonstratable facts, you probably
have already seen the explanation:
'Because we can demonstrate that there Is ozone (whose source
was stratospheric) trapped within the frontal layers and because
this frontal layer will probably dissipate out over the warm
Gulf waters, the areas where the 'trailing edge" (.but now dissi-
pated edge) of Uie cold front would have touched the ground will
frequently experience ozone episodes."
This area begins around Houston and 'moves" northeastward across the eastern
United States as the cold front and associated high pressure area move eastward
across the United States. (The geographical pattern Implied 1n this description
conforms closely to 'stratospheric" radiolsotope fallout patterns published by
Reiter, 1977.)
The remaining question 1s: "How much ozone can be contributed 1n this manner?"
Two techniques can be used to estimate this amount (however, an airborne samp-
ling program specifically planned to measure 1t would be most accurate):
1. Note the Increase In rural ozone concentrations located up or cross-
wind from urban sources during regional episode situations. Typi-
cally, these increases are 50 to 100 ppb.
2. Convert the "estimates of stratospheric ozone's annual average con-
tribution (e.g., 25 to 33 ppb)" to a "batch" Injection occurring
only about three times per month (for a two-day period).
-To Illustrate: Even though a man's take-home pay may be $5/hr,
the payrole clerk does not drop by his desk each hour to give him
a $5 bill. Rather, he Is paid In a two week "batch" of $400.
A "batch" Injection of stratospheric ozone one fifth of the time
4.
ENV I ATM SUBCOM
December 1, 1977
228
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420
would range from 125 to 165 ppb - easily enough to be the cause
of episodes and explaining why hydrocarbon control on urban
sources have not reduced the frequency or severity of episodes.
The theory that I offer explains why:
1. Ozone episodes simultaneously occur state(s) wide.
2. Why they are predominantly in the eastern United States.
3. Why they follow high pressure areas and typically have southerly
winds.
4. Why the radioisotope fallout patterns measured across the eastern
United States occurred as they did.
5. Why a hydrocarbon control strategy will not appreciably reduce the
frequency or severity of the ozone episode conditions but may be
linplemental 1n reducing the average background level in an area
particularly as It occurs down the prevailing winds of a large
urban source area.
In summary, 1 would like to encourage the Environment and Atmosphere Subcommittee
to allocate some of their funds for a detailed study of stratospheric ozone In-
trusion. Presently, EPA has ongoing studies to examine the urban plume downwind
of the large urban areas. The Houston Area Oxldants Study has numerous projects
to measure the many varied precursors and Individual constltuants in photochemical
oxidants (ozone, PAN, total oxidants, etc.). However, with their limited funds,
neither are attempting to specifically analyze the stratospheric ozone Intrusion.
I. therefore, strongly urge this Subcommittee to implement, as a portion of their
total program package, a study which would examine this phenomenon that is present-
ly not being examined by either EPA, HAOS, nor any other program which we are
aware. I feel that this area of study not only offers a greater than SO! proba-
bility of explaining the major contributing factor to why ozone episodes occur
in the eastern United States, but also offers additional trajectory and analytical
results pertinent to other areas of environmental interest, namely:
1. The fluorcarbon/aerosol spray Issue,
2. The future Impact of supersonic transport In depleting the stra-
tosphere ozone layer, and
3. The civil defense aspects of fallout patterns in the United States.
I would be pleased to answer any questions at this time or participate in a fur-
ther, more detailed presentation of the Information and support in the theory
which we are presenting today. If I can be of any help, I can be contacted
either by phone at (713) 777-0106, or
Applied Meteorology, Incorporated, 9000 Southwest Freeway,
Suite 111, Houston, Texas 77074.
I thank you for this opportunity to include this on the public record, and will
make myself available to answer any questions concerning the information that I
have included herein.
5.
ENV I ATM SUBCOM.
December 1, 1977
229
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421
Hathorn, J.W. and Walker, H.M.; 1977. *A 'Texas Size1 Ozone Episode Tracked
to Its Source". In: Proc. International Conference on Photochemical
Oxldants and Its Control. U.S. Environmental Protection Agency, ORD,
Research Triangle Pa^k. N.C. EPA-600/3-77-001a. January 1977.
Mohnen, V.A.; 1976. Analysis of the Evidence and Viewpoints Presented at
the 1976 International Conference on Qxldants. Part III: The Issue of
Stratospheric Ozone Instruslon. U.S. Environmental Protection Agency, ORD.
Research Triangle Park, N.C. EPA-600/3-77- .
Relter, E.R. The Role of Stratospheric Transport on Tropospherlc Ozone Con-
centrations. In: Proc. International Conference on Photochemical Oxldant
and Its ControTT U.S. Environmental Protection Agency, ORD, Research
Triangle Park. N.C. EPA-600/3-77-001A. January 1977.
230
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APPENDIX B
CONGRESSIONAL HEARINGS
1979 AUTHORIZATION FOR THE OFFICE OF RESEARCH
AND DEVELOPMENT, ENVIRONMENTAL PROTECTION AGENCY
231
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1979 AUTHORIZATION FOR THE OFFICE
OF RESEARCH AND DEVELOPMENT,
ENVIRONMENTAL PROTECTION AGENCY
HEARINGS
BEFORE THE
SUBCOMMITTEE ON THE
ENVIRONMENT AND THE ATMOSPHERE
OF THE
COMMITTEE ON
SCIENCE AND TECHNOLOGY
U.S. HOUSE OF REPRESENTATIVES
NINETY-FIFTH CONGRESS
SECOND SESSION
FEBRUARY 7, 8, AND 9, 1978
[ No. 99 ]
Printed for the use of the
Committee on Science and Technology
U.S. GOVERNMENT PRINTING OFFICE
M-323 0 WASHINGTON : 1978
232
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COMMITTEE ON SCIENCE AND TECHNOLOGY
OLIN E. TKAGDE, Texas, Chairman
DON PUQUA, Florida
WALTER FLOWERS, Alabama
ROBERT A. ROE, New Jersey
MIKE McCORMACK, Washington
GEORGE E. BROWN, JR., California
DALE MILFOED, Texas
RAY THORNTON, Arkansas
JAMES H. SCHEDER, New York
RICHARD L. OTTINGER, New York
TOM HARKIN. Iowa
JIM LLOYD, California
JEROME A. AMBRO, New York
ROBERT (BOB) KRUEGER, Texas
MARILYN LLOYD, Tennessee
JAMES J. BLANCHARD, Michigan
TIMOTHY E. WIRTH, Colorado
STEPHEN L. NEAL, North Carolina
THOMAS J. DOWNEY, New York
DOUG WALGREN, Pennsylvania
RONNIE Q. FLIPPO, Alabama
DAN GLICKMAN, Kansas
BOB GAMMAGE, Texas
ANTHONY C. BEILENSON, California
ALBERT GORE, JR., Tennessee
WES WATKINS, Oklahoma
ROBERT A. YOUNG, Missouri
JOHN W. WYDLBR, JR., New York
LARRY WINN, JR., Kansas
LOUIS FRET, JR., Florida
BARRY M. GOLDWATER, JR., California
GARY A. MYERS, Pennsylvania
HAMILTON FISH, JR., New York
MANUEL LUJAN, JR., New Mexico
CARL D. PURSELL, Michigan
HAROLD C. HOLLENBECK, New Jersey
ELDON RDDD, Arizona
ROBERT K. DORNAN, California
ROBERT S. WALKER, Pennsylvania
EDWIN B. FORSYTHE, New Jersey
CHARLES A. MOSBIR, Executive Director
HAROLD A. GOULD, Deputy Director
PHILIP B. YEAGER, Counsel
JAMES E. WILSON, Technical Consultant
WILLIAM G. WELLS, Jr., Technical Consultant
RALPH N. READ, Technical Coniultant
ROBERT C. KETCHAM, Counsel
JOHN P. ANDELIN, Jr., Science Consultant
JAMES W. SPENSLET, Couniel
REOINA A. DAVIS. Chief Clerk
PAUL A. VANDER MZDB, Minority Staff Director
SUBCOMMITTEE ON THE ENVIBONMENT AND THE ATMOSPHERE
GEORGE E. BROWN, JR., California, Chairman
ROBERT S. WALKER, Pennsylvania
LARRY WINN, JR.. Kansas
EDWIN B. FORSYTHE, New Jersey
TIMOTHY E. WIRTH, Colorado
JEROME A. AMBRO, New York
DOUG WALGREN, Pennsylvania
JAMES H. SCHEtJER, New York
ANTHONY C. BEILENSON, California
WES W ATKINS, Oklahoma
JAMES W. SPENSLET, Staff Director
RADFOBD BTERLT, Jr., Science Coniultant
YACOV Y. HAIMES, Congressional fellow
233
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CONTENTS
WITNESSES
February 7, 1978:
Dr. Stephen J. Gage, Acting Assistant Administrator for Research
and Development, EPA; accompanied by Dr. Delbert S. Earth;
Dr. Courtney Riordan; Dr. Steven R. Reznek; and Albert C.
Trakowski 2
February 8, 1978:
Dr. Emil Mrak, chairman, EPA Science Advisory Board, University
of California, Davis, Calif.; accompanied by Dr. Richard Dowd— 104
Gen. William Whipple, Jr., director, Water Resources Research
Institute, Rutgers State University, New Brunswick, N.J 118
Dr. Frederick Urbach, president, American Society of Photobiology,
and Skin Cancer Hospital, Philadelphia, Pa 127
February 9, 1978:
Dr. Norton Nelson, director, Institute of Environmental Medicine,
New York University Medical Center 139
Dr. Sheldon Friedlander, Department of Physics, California Institute
of Technology, Pasadena, Calif 142
Dr. Adel F. Sarofim, professor of chemical engineering, Massachusetts
Institute of Technology, Cambridge, Mass 146
Dr. Marcus Key, professor of occupational medicine, School of Public
Health, University of Texas, Houston 157
G. Wade Miller, director, Public Technology, Inc., Washington, D.C.,
and Dr. Rip G. Rice, corporate manager,. government relations,
Jacobs Engineering Co., Washington, D.C 174
Dr. Riley D. Housewright, Project Director, Safe Drinking Water
Committee, National Academy of Sciences 203
Larry Feldcamp, chairman, Houston Area Oxidant Study Steering
Committee, Houston Chamber of Commerce, Houston 213
Dr. Stephen Gage, Acting Assistant Administrator, Office of Re-
search and Development, Environmental Protection Agency; accom-
panied by Dr. David Shearer 234
APPENDIXES
1. Report of the Committee on Health and Environmental Effects of
Increased Coal Utilization (the "Rail Committee"), December 23,
1977 243
2. Letter from Hon. Russell Train, former Administrator of EPA to Hon.
George E. Brown, Jr., chairman, Subcommittee on the Environment
and the Atmosphere, January 31, 1978 291
3. Letter from Carl E. Bagge, president, National Coal Association to
Hon. George E. Brown, Jr., chairman, Subcommittee on the Environ-
ment and the Atmosphere, February 7, 1978 294
4. Letter from David Swan, vice president, technology, Kennecott Copper
Corp., to Hon. George E. Brown, Jr., chairman, Subcommittee on
the Environment and the Atmosphere, February 2, 1978 299
5. Abstract of "A Review of 'Aggravation of Asthma by Air Pollutants:
1971 Salt Lake Basin Studies.' " Report of A.D. Little, Inc., to
Kennecott Copper Corp., September 27, 1977 301
6. Letter to Hon. Jerome A. Ambro, from Bernard Manowitz, Brookhaven
National Laboratory, February 16, 1978 307
234
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IV
7. Letter from Zach D. Taylor, Association of Central Oklahoma Govern-
ments, to Hon. George E. Brown, Jr., chairman, Subcommittee on
the Environment and the Atmosphere, concerning the Garber Welling-
ton Aquifer together with related funding proposal, February 27,
1978 — 309
8. Statement by the Houston Chamber of Commerce 336
With attachments:
(a) Active projects of the Houstoa area oxidants study 343
(b) Comments on Texas hydrocarbon/photochemical oxidant
strategy 384
(c) Petition of the American Petroleum Institute to the U.S.
EPA in re photochemical oxidant standards, et cetera.. 396
9. Summary report: "Drinking Water and Health," National Academy
of Sciences, 1977 _ 547
235
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213
STATEMENT OF LARRY FELDCAMP, CHAIRMAN, HOUSTON AREA
OXIDANT STUDY STEERING COMMITTEE, HOUSTON CHAMBER
OF COMMERCE, HOUSTON
Mr. FELDCAMP. Mr. Chairman, as I represented earlier, I am stand-
ing in today for Dr. Stanley Pier who is chairman of our Gulf Coast
Air Pollution Research Committee. Dr. Pier could not be here at the
last moment.
Mr. BROWN. Well, without objection the full text of Dr. Pier's
statement will be put in the record and you may proceed as you see
fit to amplify or abstract from it.
Mr. FELDCAMP. I am going to try to summarize in view of the
time, and I think I would like to use the approach of what I would
describe as the elements of an effective cooperative research program
which is what we are involved with now in the Houston Gulf Coast
area, and relate to these elements what we have experienced so far
since last October.
I think one necessary element is the interest and willingness of all
those groups to work together and with the EPA officials. I think
we have such a situation in Houston. We have now on our Gulf Coast
Committee 14 members that come from various groups. We have
about four from environmental groups, about four from business
and industry. You have the city, the county, the State representatives,
the medical society, the university.
We also have an overall interest in the area in doing something
about the problems. I think, as you know, from the hearing in Houston.
on November 21, that the Houston Area Oxidant Study, which was ini-
tiated by the private sector, is such an effort to gain more information
on the air pollution problems.
The second element I think necessary is the involvment of the
local groups to identify the local problems and help to define the scope
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214
of the research program. This was done initially in our situation at
the October meeting with EPA officials during which the committee
was initially formed. One thing that we helped direct the EPA to
was the needs assessment project—to define what kind of problems
we have what the health effects are, and what should be looked at.
And I think until we brought this into focus with the EPA the
EPA may have been going in a different direction based upon what
they had seen in the statute and the legislative history.
The third element I think, even after the initial identification, is
the continued involvement of local groups in the development and
execution of the research program so that eventually you will end
up reaching a mutual solution of the problem and acceptance of the
necessary controls by all affected groups.
I think once all groups are involved in the full program, they will
have some input. And I do not think you have such a diverse interest
that we cannot work together. We have not seen the result so far. It has
been a unanimous viewpoint so far which we have seen from pur
committee. We had another meeting in December with EPA officials
to generally outline the program. We then commented as to certain
elements of the program that were being left out. That has helped
to some extent and we still have not seen the program as defined by
EPA in their request for proposals to contractors, the type of pro-
gram we would like to see. I think eventually we may be able to
work that out, but I think that both groups are in a learning process
in dealing with this type of program. But hopefully EPA will listen
to the viewpoints of the local groups.
Mr. BROWN. Mr. Feldcamp, if I may interrupt at that point.
One of the earlier witnesses today, I will have to look at the record
to refresh my memory, spoke specifically to the oxidant problem as
one of the areas on which there should not be an extension of stand-
ards which have been set.
Mr. FELDCAMP. I think that was Dr. Key, who mentioned that,
and this is really the problem that we are looking at in Houston on
the oxidant problem. And we do not think the Los Angeles situation
may be as applicable to ours, and we think that that is really one area
of focus.
In the Houston area right now is the oxidant and ozone problem
which is related to hydrocarbons. The other problem is particulates
and aerosols. We have haze which is composed of aerosols and fine
particulates—I think these have not been addressed in the standards
at this point—and are there health effects from these ? And we think
both of these should be looked at. Right now we do not see nitrogen
oxides, carbon monoxides, or the sulfur oxides as problems. That is a
thing that is coming because we are getting into the fuel conversions.
This was mentioned in some previous testimony.
It seems we have a situation of defining a baseline with the monitor-
ing now going on and then seeing the fuel conversions taking place
and determining what are the effects.
As a further element, I am not sure what exactly is the solution,
but we on the committee feel that there should be some kind of official
recognition given to a group such as ours and I would like to quote
from Dr. Pier's statement on that because I think he summarizes this
and his statement has been approved by the entire committee:
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215
The committee maintains that it has a most important mission in providL
informed, expert local viewpoints to EPA in the pursuit of this phase of the.
research. However, at this point, the committee is an informal aggregation
of interested parties lacking any official status or recognition. As was pointed
out in the November hearing in Houston, the functioning of the committee
would be improved by such sanction. We don't ask to be loved—only listened
to. We have had official statements of endorsement and support from local
and State agencies, but it is the Federal recognition that counts.
And an additional thing that Dr. Pier has in his statement which
I think is more important, especially to the environmental groups
or other citizen groups Avho are involved, is the matter of financing:
It has also become clear that the functioning of the committee in the manner
intended by the legislation would be materially aided by some funds to support
contact with EPA and research contractors. As of now, contracts with EPA
can only be accomplished with funds which entail sacrifice to other activities
or which may not be available at all.
This is a serious impediment if we are to aid EPA in research planning and
implementation, especially at this very early phase of a critical program. I
would therefore suggest, speaking for the committee, that a small portion of
the budget, or supplementary funds, be provided to support limited travel by
committee members. We do not ask for any compensation, only reimbursement
for transportation and reasonable living expenses. Such funding would also
enable the committee to initiate actions rather than merely being responsive
to requests from EPA.
Let me mention a couple more elements, and then I will conclude.
I think that we have in Houston an oxidant problem, although
we think we differ from Los Angeles and maybe more reflect
the problem in other areas. And I guess any type of program where
we go into some type of funding should be in relation to the national
problem in the sense that there would be funding for that. And if
there is such a situation where it may have a national impact, then I
think the fundinrr should be sufficient, to see to the completion of
that program, and I think this was indicated by some of the previous
speakers referring to "steadiness of purpose," I think was the phrase
used by one; that is, we see to the completion of it. Although I think
that there has been talk of $3 million for a studv over a 3-vear period.
this initial needs assessment study may be indicative of what we need
to have in the long run. It seems like we ought to see the study
to completion instead of doing it partiallv and still leave further
confusion or uncertainty as to what is required.
That sums up my points on the necessary elements and some of our
experience.
Mr. BROWN. Thank you very much, Mr. Feldcamp.
I think that your comments and Dr. Pier's statement are extremely
helpful to the committee.
I might say that as far as I am personally concerned. T am very
much interested in using the Houston situation as a prototvpe of new
institutional arrangements involving the local community, local indus-
try, and local health people in all of which areas there are outstanding
resources. I am as much interested in developing new methods for
bringing about mutual and cooperative involvement of these groups
as T am in the technical details of the air pollution problem.
Mr. FKLDCAMP. We are going through some of that right now trying
to work that out.
Mr. BROWX. T think it would be extremely useful if we conM struc-
ture something which would by virtue of its success be applied crea-
tively in other areas involving resources or whatever type it might be.
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Dr. Pier indicated a need for a prototype monitoring system, and I
can assure you that I will certainly want to look supportively at the
need for the additional money. That is always a very sticky problem
around here but with the continued support of perhaps this delegation
I think we might have a chance to do something like that.
Dr. Byerly ?
Dr. BTERLY. Mr. Feldcamp, you are the chairman of the coordi-
nating committee for the Chamber of Commerce ?
Mr. FELDCAMP. Chairman of the steering committee.
Dr. BYERLY. Right. And you have expressed an interest in getting
yourself involved in the planning of the EPA research program.
Would the Chamber of Commerce make a reciprocal sort of offer and
really make a cooperative
Mr. FELDCAMP. We did not initially when we were trying to get the
study underway because at first we did not know whether we could
pull that off and get enough funds. We had to go out and solicit the
funds first and got over 200 contributors. Once we got it underway or
shortly thereafter we contacted the EPA to get their viewpoints on
certain of our projects and programs, and we did get, I think, cooper-
ation. I guess the EPA questioned a little bit—are these people for
real—initially, but I think this disappeared after we sat down and
explained to them we were really serious and objective in what we were
trying to do. And we did get some input from EPA people in most
areas but with one exception, the health effects. We did not get—I
would say and I think most of our people would say—the full cooper-
ation there. We would have liked to really had more. Because more
of our people involved are more of the chemists and engineer types,
not so much the health effects types where EPA has the expertise. I
think we are hopeful of getting more EPA involvement in the pres-
ent study and with the Gulf Coast Committee that we have had. We
have tried to keep EPA advised of what we were doing and considered
any EPA inputs in redefining the scope of our projects.
Dr. BYERLY. So you do feel that you are open for EPA participa-
tion in planning your side?
Mr. FELDCAMP. Yes, for all the planning work, though right now
we are into the evaluation.
Dr. BYERLY. I realize that. Some is behind you, but in future efforts?
Mr. FELDCAMP. Yes, and I dp not knew where we are going to go.
As I said we are going to finish our $1.4 million program and get
something out before we go back to contributors and ask for more
money.
Mr. BROWN. Mr. Feldcamp, I am not really up to speed on all the
elements of the study down there, but may I ask if there' is any intent
as far as you know to include some analysis of the environmental im-
pact of the rapid conversion from oil and natural gas to coal-burning
electric generating plants ? Might you have to rely heavily on lignite
resources of the area ?
Mr. FELDCAMP. Our oxidant study does not include any plans of
that sort other than measurements of the levels of sulfates or sulfur
oxides present in the air. This could be something that could come
out of the EPA study or at least to find a baseline of what is the
situation, for we are just now on the threshold of starting to convert.
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People are having their gas supplies curtailed or they are going t
have to convert pursuant to Federal requirements. So far it has not
we have not got into that area.
Mr. BROWN. It seems to me that that is one of the more striking ex-
amples throughout the Nation of potential environmental change of
a fairly massive nature based upon the requirements of the conversion
of energy sources.
Mr. FELDCAMP. Yes, I think we are probably more gas-dependent
now than probably any other major locale in the country and many
of us are concerned about that, but there have been no studies initiated
on that at this time.
Mr. BROWN. Well, maybe we could use that to justify a continua-
tion of the funding over a little longer period of time.
I want to thank you very much for your testimony and we will not
keep you any longer at this time. If we need to get in touch with you
we will communicate in writing.
Mr. FELDCAMP. Thank you.
[The prepared statement of Dr. Stanley M. Pier follows:]
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STATr.MCNT OF
DR. STANLEY M. PIER, CHAIRMAN
GULF COAST AIR POLLUTION RESEARCH COMMITTEE
Mr. Chairman, members of the Subcommittee on the Environment and
the Atmosphere. I appear before this body by virtue of ay position as
Chairman of the Gulf Coast Air Pollution Research Committee. This state-
Bent has been developed with the advice and concurrence of the whole
committee and should therefore be taken to constitute the position of the
entire committee and not simply as a personal expression.
The Gulf Coast Air Pollution Research Conmittee was organized on
19 October 1977. It was established in consequence of provisions of the
1977 Amendments to the Clean Air Act, requiring that the Environmental
Protection Agency conduct research on a number of regional air pollution
problems. This mandate arose from the fact that there is considerable
uncertainty in the scientific community as to the origin and nature of the
air pollution problems in a number of areas. This uncertainty generates
questions as to the appropriateness and efficacy of control measures ex-
tablished or promulgated by EPA to accomplish the reduction of air pol-
lution. The 1977 Amendments also mandated the establishment of local
committees to assist the EPA in this admittedly complex and difficult
research effort by assuring input from local experts who are especially
knowledgeable concerning the local problems. The Gulf Coast Air Pollution
Research Committee is one such entity, and the membership encompasses all
of the local interests. Please accept my assurance, if any were needed,
that my committee is exceedingly eager to provide such assistance to EPA.
Although the committee was established in October, substantive work
did not begin until the very last portion of the year. On 16 December, a
meeting was held in Houston attended by key people in the EPA research
organization who would be concerned with what I shall refer to as the Houston
or Gulf Coast Study. The atmosphere at the meeting was one of open and frank
cooperation, which is not to say that there was complete agreement on all
points. The members of my committee came away from this meeting in antic-
ipation of a good and close working relationship with EPA's research
scientists. Nonetheless we detected a distinct reluctance on the part of
EPA to address the problem of ozone/oxidants in the Houston atmosphere.
While I certainly do not wish to represent the oxidant problem as the only
one we face, it certainly is at least as important as any other.
In a hearing by this Subcommittee held in Houston on 21 November,
there was considerable technical discussion of the complexities of this
subject which I will not repeat here. There have been significant devel-
opments since, especially the denial of the petition of the Texas Air Control
Board for a waiver from the EPA offsets policy. As a result of this, Texas
will be required to implement costly and potentially disruptive controls on
industrial and other development in areas of our State - including the Gulf
Coast - which are out of compliance with the particulate and oxidant standards.
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The key point is that major actions arc being taken to attempt attainment of
a standard - and many feel that attainment is impossible on virtually any
basis - which has an extremely tenuous technical foundation. This makes it
even more important that research on the ozone/oxidant problem be imple-
mented with dispatch in order that appropriate action can be taken to termi-
nate disruptive programs if the results show the standard to be unnecessarily
restrictive.
In early meetings of my committee, we enthusiastically supported a
suggestion of the EPA research group that the first project implemented be
a "needs assessment" - a review hy a qualified research organization of the
extensive data concerning Gulf Coast pollution and a reasoned judgment as to
what research might be needed to elucidate all aspects of the problem -
physical, chemical and the most critical, health effects. The coomittee
requested an opportunity to review the draft Request for Proposal, as a
result of which a copy was provided. The draft was found to be extremely
directive in that it channelled the contractor heavily into the area of
aerosols. The committee considers aerosols a problem requiring study, but
there seemed to be no reason why the RFP should be as directive as it was.
We suggested to EPA that a needs assessment might best be written as a needs
assessment, i.e., leaving it to the judgment of the investigators to discern
the needs, which after all is the purpose of the study in the first place.
A revised draft was prepared and provided to the committee; it was still
somewhat directive toward aerosols, but did allow for consideration of other
pollutants.' However, most surprisingly, the revised draft specifically
excluded consideration of the health effects of ozone/oxidants. This must
be considered a significant omission in view of the needs of the area and
the extensive discussions between the committee and EPA research people. 1
have had further contact with a senior EPA research official, in which a
willingness was indicated to remove this restriction, though it was suggested
that the RFP may in fact have been issued to prospective contractors with
the restriction.
As another aspect of the oxidant subject, I should like to remind
this committee that a revised oxidant criteria document, which forms the basis
for the definition of the ambient air quality standard, is now under review.
Two members of my committee have been requested by EPA, independent of the
committee and independent of each other, to review the draft document. One
of these reviewers. Dr. H.C. McKee, serves in the Department of Public Health
of the City of Houston, and the other. Dr. Richard K. Severs, is » »e»ber of
the faculty of the School of Public Health of'the University of Texas. Both
have found the draft document seriously flawed, especially with respect to
the research methodology employed in the association of ambient air levels
of ozone/oxidants and health effects. I have appended to this testimony a
presentation made before the EPA review committee by Dr. McKee on 30 January
which includes the views of Or. Severs. If the judgment of these highly
qualified professionals is correct, we are Imposing costly and disruptive
regulatory requirements in prusuit of a standard that may be substantially in
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error. This affords further evidence Of the imperative of doing the research
to resolve this question.
EPA has stated that the stress placed by the« on aerosols is a
result of the language in the 1977 Amendments. This position would be
justified, if only the language of the Act were available. However, there
has been ouch discussion between my committee and EPA to convey a clear and
unequivocal local view that research mist be done on the ozone/oxidant
question, though not to the exclusion of other matters. In addition, Senator
Lloyd Bentsen, who was instrumental in incorporating the local research
requirement in the legislation, has told me and senior EPA officials that it
was his intention that the oxidant question be resolved. I have appended to
this testimony a letter which I received from, the Senator just last week
which confirms «y several contacts with him and his staff.
The situation which I have described illustrates a dilemma that goes
quite beyond the specifics discussed. For some time, the Texas air pollution
authorities have maintained that the Gulf Coast has a problem intrinsically
different from that existing in Los Angeles, and therefore the Los Angeles-based
controls will be ineffective. On the other hand, the Environmental Protection
Agency, under Federal mandate but with limited resources has been called upon
to develop and implement a national air pollution control program. This has
resulted in the definition of two basic categories of air pollution problems:
the "snow-belt" problem characterized by sulfur oxides and particulates, and
the "sun-belt" syndrone of photochemical smog. What if there are situations
which do not conform to either? Should it fall to the local area to prove that
it has a different problem before Federally promulgated controls are imposed?
Obviously this would be beyond the capabilities, financial and technical, of
most local jurisdictions. It would equally obviously tax the Federal resources
if it became necessary to study a very large number of special cases. This
situation falls well within the truism that for every difficult problem there
is a solution that is quick, easy, cheap - and wrong! What then might offer
an approach to resolution?
First, it would seem reasonable that congress adopt a more realistic
attitude toward deadlines. These are complex problems, and a legislative
mandate that < question be resolved by a certain date does not guarantee
success. Tight deadlines and the crisis mentality should be reserved for
clear threats to the public health. Cooperative research is an obvious
answer, but larger scale efforts almost certainly complicate the matter of
•eeting deadlines. An obvious need is for a more open and cooperative atti-
tude among all concerned, and less of the compulsion to prove at all costs
previously adopted positions. It has also long impressed oe that there would
be considerable merit to separating the research and regulatory functions, as
was the carefully considered determination of the Congress in establishing
two agencies, the National Institute for Occupational Safety and Health and
the Occupational Safety and Health Administration to deal with health hazards
in the workplace.
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Given acceptance of the notion that these are complex technical
matters, there is obviously a need for continuing oversight of the tech-
nical elements of any program, and certainly by an entity other than the
agency concerned. Finally, logic dictates that if a regulatory action has
been shown to be ineffective but otherwise onerous in a reasonable period
of tine, there should be mechanism for suspending the regulation pending
the definition of a better solution without destroying an entire program.
The notion of cooperative research figures strongly in what I have
presented here. This is devoutly to he wished, but very difficult to achieve.
An essential of a successful cooperative research effort is for all parties
concerned to want to work cooperatively. I regret to say that this ingredient
is frequently lacking. Without becoming mawkish, I would hope that a more
tolerant, respectful and trusting atmosphere could be established. He should
dispense with attitudes such as that expressed by the statement in the EPA
draft RFP for the Houston area needs assessment reading, "...viewpoints...
are often conflicting and influenced by special interests." Having said all
these heartwarming words, I must frankly tell you that I cannot offer a means
for reducing the confrontational attitude that characterizes all too many aspects
of the Federal-local relationships in the environmental area. As a final
observation, I do recall that good, cooperative research did take place in the
days before the crisis mentality and near-impossible deadlines were imposed
by Federal fiat.
The Gulf Coast Air Pollution Research Committee maintains that it has
a most important mission in providing informed, expert local viewpoints to EPA
in the pursuit of this phase of their research. However, at this point, the
committee is an informal aggregation of interested parties lacking any offical
status or recognition. As was pointed out in the November hearing in Houston,
the functioning of the committee would he improved by such sanction. We don't
ask to be loved - only listened to! We have had official statements of en-
dorsement and support from local and State agencies, but it is the Federal
recognition that counts.
It has also become clear that the functioning of the committee in the
manner intended by the legislation would be materially aided by some funds to
support contact with EPA and research contractors. As of now, contacts with
EPA can only be accomplished with funds which entail sacrifice to other acti-
vities or which may not be available at all. This is a serious impediment if
we are to aid EPA in research planning and implementation, especially at this
very early phase of a critical program. I would therefore suggest, speaking
for the committee, that a small portion of the budget, or supplementary funds,
be provided to support limited travel by committee members. We do not ask for
any compensation, only reimbursement for transportation and reasonable living
expenses. Such funding would also enable the committee to initiate actions
rather than merely being responsive to requests from EPA. An important specific
benefit*of such support relating to the growing need for Federal, State and
local cooperation is a greater likelihood that we will be able to integrate
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the EPA program to be developed with the extensive research program conducted
under tne Houston Area Oxidant Study, so that raaxinum use can be made of
severely limited resources. We have an excellent opportunity to coordinate
complement and supplement research if a close working relationship can be
established.
To SUB up, we have several components of the Gulf Coast Air pollution
nix with insufficient data. The most critical question concerns the health
effects of chronic exposure to our air. A budget of $3 million, however it
may be spaced, must be considered a minimum cooaitment of tine and money.
Mr. Chairman and members of the Subcommittee, I speak for a group
that is exceedingly eager to discharge the function for which it was con-
stituted. Our ability to do so will be strongly influenced by the extent
to which we establish frank and open communication with the research staff
and other officials of EPA. Ne are looking forward to expanded contacts
at all levels, and we request that this Subcommittee do whatever it can
to facilitate our task.
8 February 1978
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COMMENTS ON PROPOSED REVISION OF OXIDANT STANDARD
(For presentation at public meeting to discuss
issues related to a possible revision of the
National Ambient Air Quality Standard for
Photochemical Oxidants)
Prepared for
ENVIRONMENTAL PROTECTION AGENCY
401 M STREET SW
WASHINGTON, D.C. 20460
Presented by
Herbert C. McKee, Ph.D.
Assistant Health Director for Pollution Control
City of Houston Health Department
1115 North MacGregor
Houston, Texas 77030
January 30, 1978
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INTRODUCTION
The City of Houston Health Department appreciates the oppor-
tunity of commenting on the subject of proposed revisions of the
Photochemical Oxidant Standard. As the local air pollution con-
trol agency for the City of Houston, our Air Pollution Control
Program has worked for many years to alleviate some of the serious
air pollution problems in the City. Substantial progress has been
made, as shown by the fact that many of the most serious nuisances
which existed in previous years have been eliminated, plus the
fact that the ambient air quality standards for carbon monoxide,
sulfur dioxide and nitrogen dioxide have not "been exceeded at
any of the City's monitoring stations for the past several years.
The only violations of the primary particulate standard in 1977
occurred in portions of the Industrial district and the downtown
area, and a pilot program is under way to determine the reasons
for these violations and to identify proper corrective actions
for future implementation.
The most significant air pollution problem in the Houston
area is that of photochemical oxidants, as shown by the occasional
high ozone readings which are recorded. Based on the hydrocarbon
control requirements of the Environmental Protection Agency as
written into the State Implementation Plan, hundreds of millions
of dollars have been spent in the Houston area during the past
few years to reduce hydrocarbon emissions, on the assumption
that such action would reduce ozone and photochemical qxidants.
These expenditures include the cost of very substantial control
measures by local industries and also the cost to the average
motorist of catalytic converters, unleaded gasoline and other
vehicle control measures. These efforts have undoubtedly im-
proved air quality in several ways, but in terms of the original
objective of reducing ozone episodes, they appear to have been
a failure. Ozone episodes have not changed much in frequency
or severity since before the controls were implemented; while
some random year-to-year variation occurs due to changing weath-
er patterns, it is obvious that any reduction in ozone formation
has been much less than predicted at the time the control require-
ments were established. In fact, no statistically significant
reduction in ozone episodes can be demonstrated!
Because of this major unsolved problem, the subject of pro-
posed revisions to the oxidant standard is a matter of major im-
portance to the Houston area. Additional control efforts are
needed, but those control efforts must be effective if public
disillusionment and loss of credibility for future control efforts
are to be avoided. Therefore, it is imperative that a revised
standard be developed which defines the nature and magnitude of
the problem in the Houston area. Control measures required to
achieve a revised standard must be based on an accurate under-
standing of the mechanism of ozone formation; these control mea-
sures must be more effective in reducing ozone episodes than the
hydrocarbon reduction requirements which were implemented in the
past few years.
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The background documents furnished by EPA have been reviewed,
including the following:
1. A Method for Assessing the Health Risks
Associated with Alternative Air Quality
Standards for Photochemical Oxidants Jan. 1978
2. Summary Statement from the EPA Advisory
Panel on Health Effects of Photochemical
Oxidants Jan. 1978
3. Alternate Forms of the Ambient Air
Quality Standard for Photochemical
Oxidants Jan. 1978
4. Revision of the National Ambient Air
Quality Standard for Photochemical
Oxidants Jan. 6, 1978
Comments are presented here on several portions of these docu-
ments, based on our experience in the Houston area and on factors
which seem to be important in addressing the oxidant problem in
Houston. While our experience is limited to the problems of the
Houston area, the information presented here likely is applicable
in other cities as well. However, it is important to stress that
oxidant problems are not the same in every city. Some evaluation
and understanding of the problem is necessary in each metropolitan
area, if a standard is to reflect the actual problems in that area
and especially if the control measures selected are to be effective
In alleviating those problems.
RELATIONSHIP BETWEEN OXIDANT AND OZONE
In comments on External Review Draft No. 1 "Air Quality Cri-
teria for Photochemical Oxidants and Oxidant Precursors" dated
November 2,- 1977, the City of Houston stated that the distinction
between ozone and photochemical oxidants was not adequately ex-
plained. Despite the present attempts to change from an oxidant
standard to an ozone standard, we find that some of the same con- .
fusion still exists. The distinction is not'clear between the
effects of ozone per se, and the effects of a mixture of oxidants,
with ozone measurements being used as an indicator of the mixture.
Epidemiological studies based on oxidant measurements in ambient
atmospheres are used as support for a proposed ozone standard,
despite the fact that ambient atmospheres inevitably will contain
other contaminants in addition to pure ozone. The presumption
that most of the adverse effects of oxidant are due to the ozone
contained in such atmospheres does not seem to be supported very
strongly by the available evidence.
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This problem is aggravated in the Houston area by the problem
mentioned in the previous comments on the criteria document, be-
cause of the lack of agreement between the potassium iodide meas-
urements and the chemiluminescent measurements. Much of the air
quality data used in evaluating health effects was obtained by
potassium iodide methods; the lack of agreement between these
methods in Houston raises serious questions about the validity
of these data with respect to ozone and/or oxidant problems in
Houston. This in turn tends to cast serious doubt on the pre-
sumption that any health effects in Houston would be due only to
ozone. The applicability of the proposed ozone standard in the
Houston area would also be open to question.
The change from an oxidant standard to an ozone standard
appears to be justified. The use of ozone measurements as an
indicator of an oxidant mixture is uncertain, because the rela-
tionship between ozone and other oxidant constituents appears to
be highly variable and possibly unpredictable. However, the
distinction between oxidant and ozone should be clear and unmis-
takable, both in the Criteria Document and in the development of
a revised standard. Also, to protect public health, separate
standards for PAN and possibly other oxidant constituents should
be developed as soon as available information will permit.
NUMERICAL VALUE OF STANDARD
Our major objection to the proposed revision is the retention
of the 0.08 ppm numerical value for an oxidant standard. We ques-
tion the wisdom of extrapolating from "probable effects in the
range of 0.15 to 0.25 ppm" to establish a standard of 0.08 ppm.
The evidence presented in External Review Draft No. 1 of the
Criteria Document does not seem to warrant this extrapolation as
found in the background documents referenced above. As a public
health agency, we would be delighted to achieve a standard which
provided for essentially background conditions with little or no
contamination from man-made sources. However, we believe that
maintaining the Ambient Air Quality Standard at the current level
of 0.08 ppm is unwise for two reasons.
First, the available information presents little or no credible
evidence for any adverse effect below some value in the range of
0.15 to 0.25, as stated. Any evidence for any adverse effect be-
low that range is unconfirmed, and not generally accepted within
the scientific community. On the other hand, a number of scien-
tific investigations have failed to find any adverse effects at
lower levels. These studies with negative results below 0.25 ppm
should also be mentioned in the summary. To discard numerous
studies which find no adverse effects, and then to give total cre-
dence to one or two unconfirmed studies which indicate a slight
possibility of such effects, is to violate all reasonable stand-
ards of scientific accuracy and credibility. Certainly, in legal
terms, the preponderance of evidence would indicate that the thresh-
old for significant adverse effects of ozone appears to be some-
where around 0.25 ppm for an exposure of around two hours.
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The second reason for suggesting that a numerical standard
of 0.08 ppm is undesirably low is the more practical matter of
public acceptance and support. Ideally, any man-made changes in
air quality should be kept to a minimum, and a standard consider-
ably more restrictive than any level that can be justified by
the available scientific data is acceptable and desirable, pro-
vided this lower level is capable of attainment. From a practical
standpoint, however, attainment of a standard of 0.08 ppm would
appear to be impossible during the foreseeable future, not only
in Houston but in many other cities throughout the nation. Natural
ozone levels, as EPA now recognizes, occasionally reach 0.05 to
0.06 ppm. Allowing for some possible errors in measurement, in-
strumental readings as high as 0.07 might be recorded occasionally,
due entirely to natural atmospheric conditions that cannot be
changed. Since the difference between the maximum probable read-
ing due to natural conditions and the value of the standard is
only 0.01 ppm, this allows practically no margin for any man-made
influence. Almost total elimination of man-made oxidant precur-
sors would be necessary to attain a standard of 0.08 ppm.
Such a degree of control appears to be impossible, especially
when the oxidant precursors responsible for ozone formation in
Houston have not even been identified. The lack of success with
previous reductions in hydrocarbon emissions would indicate that
further hydrocarbon reductions do not appear to be the answer.
If oxides of nitrogen must be controlled to reduce ozone episodes
in Houston, the technology for application to large stationary
sources has not been developed, and thus cannot be available for
many years. Unless some major breakthrough occurs that changes
our understanding of the mechanism of ozone formation to a signifi-
cant degree, there appears to be no possibility that a standard of
0.08 ppm can be attained within the foreseeable future.
We suspect that the same is true of many other cities in the
nation. To retain the present numerical standard, and then to
proceed with implementation plan revisions which by law must be
"guaranteed" to attain this standard, will only deceive the public
and lead to further disillusionment and loss of credibility. We
suggest that a more realistic appraisal of the available informa-
tion be conducted, and that a revised standard be promulgated
that can alleviate the significant adverse effects of ozone with-
out attempting to accomplish the impossible. In public health
practice, there is no precedent for attempting to prevent all
adverse'effects in every individual member of the public. As
commendable as this would be, our skills and technology do not
permit us to achieve this degree of perfection.
As a first step in that appraisal, we suggest another con-
sideration of the technique of "probability encoding" that was
used in evaluating potential health risks. This procedure seems
to be rather questionable in view of the nature of the data avail-
able. This method attempts to attach objective numerical measures
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to subjective judgments. Such a numerical expression cannot be
any more accurate than the subjective judgment on which it is
based, even though the act of manipulating a series of numbers
creates the appearance of a higher degree of accuracy. This
method is a variation of the Delphi technique, which is helpful
in substituting subjective judgment for data when no data are
available. However, it is not valid for extending the range
or the applicability of experimental data; therefore, the use
of this method to establish lower threshold limits based on
experimental data in the range of 0,3 - 0.5 ppm is -not valid.
USE OF AMBIENT AIR STANDARDS
We would like to express strong support for one statement
made on Page 19 oi Document No. 2 (Summary Statement...) listed
above. This is the suggestion that an ambient air quality stand-
ard should be considered as a guideline which is used as a public
health objective for developing control strategies, rather than
as a signal for injunctive legal actions. This is the only way
in which an ambient air quality standard can be used. Urban
life is too complex to be drastically modified or rearranged
without advance notice, if some air pollution monitoring instru-
ment suddenly exceeds some magical number. This problem is
especially important in using a standard for photochemical
oxidants or ozone, since the exact mechanism of ozone formation
is not known. The consequences of various control actions can-
not be predicted accurately, and the public cannot be expected
to make radical changes in lifestyle every time some complex
atmospheric reaction turns out differently than expected. For
example, a restriction on the use of private automobiles on high
ozone days has been discussed; imagine the problems that would
occur if people who drive to work in the morning are told at
noon that they cannot drive their cars home that evening! (This
•was actually suggested a few years ago as a control measure to
be considered.) Using the standard as a planning guide is a
tremendous improvement over the administrative procedures of
the past, where every single violation of a standard produced
a demand for some immediate enforcement action or other immediate
response by the state or local control agency.
STATISTICAL BASIS OF STANDARD
The problem of evaluating alternate forms of a standard and
selecting a suitable statistical basis for expressing a standard
is a. formidable one, with no easy answers. We agree that a
standard expressed as the second highest hourly reading in any
one year is not satisfactory. At any single location in Houston,
the two highest hourly readings in any one year frequently occur
as consecutive hours on the same day. We agree also with the
statement that annual average values are not appropriate. The
use of an annual average is even less suitable for oxidant than
for other contaminants because of the existence of natural back-
ground ozone during daylight hours. This natural ozone varies
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229
as a function of weather conditions, so an annual average is a
very poor measure of ozone episodes of higher than normal concen-
tration. However, it is these episodes that are responsible for
any adverse effects which may occur, and which should be controlled.
Any statistical form that is chosen must identify high ozone epi-
sodes if the standard Is to achieve the objective of protecting
public health.
As an additional item of interest, Table 2 of Document No. 3
(Alternate Forms....) lists the annual geometric mean as one of
the alternate statistical forms to be considered. Since the loga-
rithm of zero is minus infinity, any set of numbers which includes
one or more values of zero cannot be averaged to determine a geo-
metric mean and hence this alternative is theoretically impossible.
CONCLUSION
Much has been learned about photochemical oxidant since the
original ambient air quality standard was promulgated in 1971.
The staff of EPA is to be commended for the thorough, meticulous
work that has been accomplished to assemble this information and
to attempt to resolve problems due to inconsistent or missing
pieces of the puzzle.
Unfortunately, our knowledge is still incomplete in some areas,
especially our understanding of the variability in oxidant problems
from one urban area to another. The oxidant problems of each area
must be identified and understood, to see how they vary from the
problems of other areas. This appears to be the biggest problem
still remaining, before this type of air pollution can. be controlled
to a reasonable degree. We have made some progress in understanding
the ozone episodes that occur in Houston, but we still lack answers
on many important aspects of the problem.
Because of this variability, some flexibility is needed so
that state and local control agencies can evaluate their individual
problems and can develop control measures that will be effective in
alleviating whatever health hazards exist. This flexibility is most
important in developing control strategies, but should also be con-
sidered in developing a revised standard.
The hundreds of millions of dollars that have been spent in
the Houston area without any measurable reduction in ozone episodes
have already had a serious effect on the credibility of our air pol-
lution control efforts and on the confidence of the public. Commu-
nity leaders are naturally dismayed that this expenditure has not
achieved the desired objectives. It is obvious that additional
efforts are needed, but it is also obvious that these efforts must
be effective. While there are no easy answers, we hope that the
ideas presented here will be useful to the Environmental Protection
Agency in developing realistic standards for photochemical oxidants
and in establishing implementation plan requirements to attain such
standards.
252
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230
IHCrnteb -States S
COMMITTECONPINAMCK
WASHINGTON. D.C. 10510
January 25, 1978
Dr. Stanley M. Pier, Chairman
Gulf Coast Air Pollution Research Committee
The University of Texas
Health Science Center at Houston
P.O. Box 20186
Houston, Texas 77025
Dear Dr. Pier:
Thank you for your recent letter.
I appreciate your taking the time to keep me up to date on the
developments of the Gulf Coast Air Pollution Research Committee. I
have discussed the study vith both Mrs. Harrison and Dr. Shearer
at EPA and I have made it clear that ve expect the study to include
a thorough analysis of both the sources and the control of oxidants
in the Gulf Coast area. You can be assured that I intend to follow
through on this commitment.
Again, thank you for contacting me.
Sincerely,
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A Critique: A Method for Assessing the Health Rlnka Associated
with Alternative Air Quality Standards for Photo-
cheoical Oxldants.
by R. K. Sever*
Ph.D.
This draft report prepared by staff of the Strategies nn4 Atr
Division, EPA, coiuist* of • string of arguments that If accepted would Jus-
tify an ambient air standard of 0.000000 parts per billion of anything. Th?
mathematics or statistic* of each step are Internally consistent. The problcr
lies in the proper us* of the techniques and the definition of each problem
component. These total alscooceptlons and misplaced applications have to be
accepted before the document can be taken seriously. Pcvral examples are
cited below.
First, declsional management techniques are frequently utilized to re-
duce variation and thus risks of bad decisions in area* In "hlcli no data exit'.
In these eases, data do not exist because no on* has tried ro collect data In
that range, or previous data Indicate the problen is In ••< •'ITrrent range. As
applied to the oxldant/ozon* exposure risks this Iraplio (;<>.-• •-• existing clin-
ical or epidemiologies! evidence of risks nov defines the concentration rang*
of hazardous exposures. This is certainly not the case. If no scientific evi-
dence of risk is discovered below this range or level a "no threshold" cannot
be assumed and no extrapolation into a lover range can be justified. Clinical
and epldeniologlcal data exist with respect to ozone/ozidant exposure. There-
fore the use of the method known as probability encoding cannot be Justified
and any standard oust be baaed on clinical and epid*alblogie*l data that do
exist.
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232
Second, probability encoding represent* the first step In a note
sophisticated declslooal management technique known as the "Delphi Method"
developed by Rand Corporation. The purpose la again to reduce variation
among experts vhere little scientific data exist In order to reduce the
risks of bad decisions. The methodology requires a reiteration of the
questions In an anonymous fashion with all experts having access to the
previous opinion poll. After due reflection a second poll Is conducted and
then In a similar manner, the third. This repeated review Is an essential
characteristic of the technique. The product of this procedure Is a etrenr,t
•aing of the central tendency of the probability distribution vlth a reducti
in outlying variation. Occasionally a blnodal distribution will occur If r
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233
defined. Introduction of a new concept: of a health «sff'3<:t threshold instead
of reliance on physiological respousn rhveaholds does not mike clear or pre-
cise the meaning of a health effect.
The individual susceptibilities still underly the population distribu-
tions of susceptibility and are thus still r«l«ted to individual physiological
response levels. The population health effect threshold la difficult to de-
fine vhcn approached from a group viewpoint. This original recognition several
decades ago led to the reliance on clinical and epldemloloc.ical data as the
best criteria for development of air quality standards.
Thus even, though the Individual components of the argument are veil exe-
cuted In developing a method for assessing the health risks associated vith
alternative air quality standards for photochemical oxldants, the components
of the argument seem inappropriate, subject to disagreement, and in general
misused.
Richard K. Severs, Ph.D., Associate Professor of Environmental Sciences,
University of Texas Health Science Center at fouston. School of Public Health,
P.O. Box 20186, Houston, Texas 77025
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Mr. BROWN. We have Dr. Gage scheduled as the last witness for
any comments he might wish to make and I would like to invite Mr.
David Shearer up also. He can fill in until Dr. Gage gets here.
STATEMENT OF DR. STEPHEN GAGE, ACTING ASSISTANT ADMIN-
ISTRATOR, OFFICE OF RESEARCH AND DEVELOPMENT, ENVI-
RONMENTAL PROTECTION AGENCY, ACCOMPANIED BY DR.
DAVID
Dr. SHEARER. Thank you, Mr. Chairman.
Mr. BROWN. Do you have any comments, Mr. Shearer, with regard
to the Houston study?
Dr. SHEARER. Yes, Mr. Chairman, I would like to make a few com-
ments in response to the testimony of Mr. Feldcamp. Also, I have read
Dr. Pier's statement and would like to respond to several items within
that statement.
EPA has begun on a large scale to involve the local Gulf Coast Air
Pollution Research Committee in our design of the EPA study. We
had a meeting with them in December. We are scheduled to have
another meeting with them on February 22, in Houston, to continue
our technical dialog and design our study.
Coupled with that February 22 meeting, the regional administrator
in our region VI, Mrs. Harrison, will be present to give the official
recognition, if you will, of the involvement of this local committee
with EPA.
Mr. BROWN. Is there some formal way in which this can be done?
Dr. SHEARER. She is in the process, as I understand Mr. Chairman,
of transmitting a letter f rom her to the committee next week indicating
our recognition of this committee as a partner with us in the design
elements of the conduct of the study.
In addition, at the February 22 meeting, we will have present
health experts to have more detailed discussions on that aspect of the
study with the local health officials, both the medical and the private
health officials in the community, as well as the atmospheric chemistry
experts.
We have received quite a bit of health data that have been gathered
by the local people. We have the progress reports and the first annual
report on the Houston air oxidant study for evaluation. We are
planning to evaluate the health data and use all of this data that
has been gathered by local people to date as input into the design
for the EPA studies. We intend, Mr. Chairman, to continue this dialog
with the local people and we are in telephone communication with
them. We are also in communication with officials of the Texas Air
Control Board. They are represented on the Gulf Coast Research
Committee.
Those are some comments, Mr. Chairman, I would like to respond
to in relation to Mr. Feldcamp's testimony.
I would also like to make an additional comment about EPA going
into this particular study. We are going into it with no preconceived
notions or ideas of what we are going to find or not going to find. We
are going into it with a completely objective scientific open approach
to find what we will. We are going to investigate not only the local at-
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mospheric mix, but we are also going to investigate the transport in,
the area from other areas as well as natural sources ozones and/or their
precursors. We also will be looking very carefully at some of the data
that will be coming out of the study. I transmitted to Dr. Pier last
week a detailed study outline, which Dr. Byerly has a copy of as well
as Mr. Feldcamp, which explains in more detail what we plan to do
this present fiscal year. We anticipate, barring unforeseen instru-
mentation procurement difficulty, beginning the monitoring in that
area in June of this year.
In our early discussions with the full committee we have had dis-
cussions along the lines of areas in the monitoring and research work
that the local universities, school of public health, and local people can
participate in with us to help perhaps do some of the work. So we are
carrying on this dialog, Mr. Chairman, with the local people.
Mr. BROWN. I have stressed and this is a personal view but I think
it is shared by other members of the committee and other Members of
Congress from Texas—the view that we need to look upon this as an
opportunity situation not a confrontation situation.
Dr. SHEARER. Yes.
Mr. BROWN. It has some of the elements which exist nationally and a
resistance of large industry to making expensive changes without being
absolutely sure that there is a sound basis for it. I see this as a chance
for a cooperative analysis of the problem in the collection of the data
and its analysis and the health effects study where they have their
own very highly qualified health people in the community there to
come up with what you might call a consensus—that might be a little
too vocal to expect to get that—but at least to see what progress we can
make in view of the fact that we may have to put a lot of pressure on the
Gulf Coast industries.
I do not want to—and I know the Members of Congress and I sus-
pect the administration do not want to—get into a big fight with all
the people in Texas without having a very strong base on which to
justify that. And this project I think provides an ideal opportunity
to develop such a base.
Now, more specifically on the finances, how far is this million dollars
in the budget for the current year going to go with regard to complet-
ing the work on scale that would do the job?
Dr. SHEARER. Mr. Chairman, as you know, the funding for this fiscal
year is at the million-dollar level. And we anticipate, pending con-
gressional and OMB sanction, additional funding for the subsequent
fiscal years 1979 and 1980.
Mr. BROWN. At the same level ?
Mr. SHEARER. At approximately the same level, yes.
Mr. BROWN. All right.
Dr. GAGE. We may find that this is not adequate, Mr. Brown. What
we are doing the first year is trying to get our hands around the
problem.
Mr. BROWN. When you have the scope of the problem then you can
decide how much it is going to cost.
Now, Dr. Gage, we 'have had 3 interesting days of testimony which
you started nnd are finishing, and you probably have been in on at least
the thrust of the testimony intervening, I would like to have you offer
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any comments tha-t you might wish to about any of the general themes
that have emerged from the testimony.
If you forget what the themes are, I can remind you if you like.
Dr. GAGE. I really do not have any prepared closing statement, Mr.
Chairman. I would reiterate that we are in a very exciting time in the
research program at the Environmental Protection Agency. I think
now with a firmer legislative basis for our regulatory program, our
research is going to have a much more solid basis on which to fund its
activities.
One thing that has impressed me in my 3 years in the Environmental
Protection Agencv is that it is incredibly difficult to plan and to exe-
cute research projects in the constantly changing flux of regulatory
thrust, let alone regulatory deadlines. I think that is changing. I
think the Congress and the administration, including the Environ-
mental Protection Agency, are coming to one mind as to what we need
to do, taking somewhat more realistic views of what our real thrusts
are in terms of environmetnal protection, and we are focusing; more of
our attention and more of our resources on solving these problems.
I think that research may just be coming into its own in the Environ-
mental Protection Agency. This may be wishful thinking, but from
what I have seen, the contributions we have made in the past vear, such
as developing a criteria document for lead under the Clean Air Act. and
providing the scientific and technological base for the trihalomethane
standard for the interim drinkinsr water standards, have been signifi-
cant research inputs to the Agency's regulatory thrust.
I have emphasized this in talks and speeches a number of times,
but I think if there is one new and really important factor that I have
had the opportunity to deal with during my tenure, it is that of putting
EPA on a more solid long-term research -base. The National Academy
study, the Authorization Act, and implementation of thfv recommen-
dations of that NAS study—to put EPA in the business of conducting
longer term exploratory anticipatory research—is just a very impor-
tant step forward.
It really struck me full in the face as I was preparing speeches and
testimony earlier this vear that surprisingly no one or no group had
really established the basis for the Office of Research and Develop-
ment to conduct those tvpes of activities. Cons?nuently. there was al-
ways tension within the Agency as to whether EPA should even be in-
volved in those long-term activities. Now I think that is changed and
we will change with it. We made that change in a very straightforward
wav. It is up to us to bring that into reality.
We only have a modest amount of monev in that anticipatory re-
search category now—some $14 million. We do have a number of other
associated research programs which probably bring the total in the
general exploratory research area up to around $30 or $40 million.
That mav not even be enough, but it is certainly in the right focus—a
very major difference from the situation even a few years ago when
there was not any financial commitment from the Agency to be doing
those tvpes of activities.
I think working with the universities and broader scientific com-
munity to give those programs direction and to involve the people in
those programs is going to make a little difference in 3 to 5 years in the
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credibility and reputation of the research in the Environmental Pro-
tection Agency.
I was not going to make an initial statement but those thoughts just
came to mind.
Mr. BROWN. That is a fine statement, Dr. Gage.
I would like to say a word, not exactly in response, but as a comment.
I have a feeling that the quality of the program is constantly im-
proving. I hope the programs will continue to improve their focus and
control. It is important that they be presented to the committee in a
rational and understandable way. That is always going to pose a prob-
lem in a complex program such as you have. I want to compliment you
on both of these to the extent that you have the responsibility for them.
That is not the whole of the problem.
The need for the longer term research and for what we might call the
basic research as compared with the regulatory-oriented research I
think still exists. It was disturbing to hear the witnesses this after-
noon—for example from the Rail committee—in discussing the health
effects of coal to state that we cannot specify the chemical species that
are involved. We do not know the things that transport the chemical
species, and obviously we cannot know the health effects if we do not
know what the species are or the things they are transported on. You
can be doing another test study on the effects of coal combustion and
end up finding out that you did not have the basic data, what it was
that was causing the health effects and how it is being distributed.
Now, as a mechanism several of the witnesses have suggested that
these kind of research problems could best be addresed to a relation-
ship with the broader research community, possibly the university com-
munity, and I know you have undoubtedly given thought to this.
Probably along the lines of—we do not have enough money to keep
our own labs going, how can we do university research.
But I think that this committee and possibly the Congress would look
favorably upon some addition to the funding of ORD if it were
recognized that this were part of a program in which we would involve
the best research capabilities in the university community in attack-
ing and solving these basic problems which for one reason or another
have not been adequately attacked under the present program. I am
speaking here without pretending the detailed knowledge of exactly
what you are doing in your labs but I would ask you to comment on
that possibility.
Dr. GAGE. We have been doing some very serious thinking along just
the lines which you outlined. Mr. Brown.
We were also instructed by the Congress to look at—in addition to
the study concerning management of the research program—the feasi-
bility of using research institutes, including university communities,
which. I believe, is roughly the way it was worded. We have taken that
second charge very seriously and have a panel of EPA scientists and
engineers working now for 3 or 3*A months looking at those issues.
One of the ideas that we very definitely are considering would be the
establishment of a limited number of university research centers with
given areas of responsibility or areas of research. We do not have
resources to establish multipurpose, multidisciplinary research
laboratories.
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On the other hand, I have been very much impressed in knowing,
since I came from the university community, of excellent areas of
work going on around the country. Since working in the Federal Gov-
ernment I have become aware of many more of these spots of expertise.
I think wo can build activities in limited areas and establish such
centers. This may be one of the areas that you want to examine very
carefully in the coming year. We are going to have a report to you on
March 31, with some suggestions as to how you might proceed to best
combine our efforts with those of the university researchers. This may
be one area that you would like to select as a growth area. If the
experiments in the first year prove to be successful, then we could move
up cautiously in adding additional centers.
I spent Monday with Dr. Dave Rail down at the National Institute
for Environmental Health Sciences in North Carolina. I have been
asked by Dr. Hall to be a member of his national advisory council for
the center and we were in the process of reviewing grants and contracts
that NIEHS puts out in the university community.
I was struck by the similarity of 'his approach and what we have
been slowly evolving independently, and that is the use of centers.
He does have a number of these special centers essentially to fill in
gaps in the research spectrum. Most of the projects of the NIEHS are
funded as a result of research proposals which are submitted to the
Institute by university researchers. As NIEHS's staff reviewed the
pattern of proposals over the years there were gaps in the spectrum of
activities that the university researchers proposed. So they targeted
a limited number of centers to fill in some of these gaps. We may be
well along the way doing such things right now. One of the gaps we
have perceived very clearly is that in the ground water research area,
and I think we are moving out quite strongly to do something in that
area. We seem to be converging on that particular problem from many
different directions. In a limited number of ether areas we may well
be able to fill in areas of research that just are not being filled by any
institutional effort at this time.
Mr. BROWN. You will not forget the trermndous resources available
in Ada, Oklahoma, for ground water research ?
Dr. GAGE. I certainly will not. I have already made that commit-
ment, Mr. Brown.
Mr. BROWN. Mr. Watkins ?
Mr. WATKINS. I would like to continue the discussion, Dr. Gage,
because you have submitted some figures.
We talk about doing research in-house or out of house. As a business-
man I alway have to figure in overhead. Anyone who takes a research
grant has to figure in, Mr. Chairman, a certain amount of overhead.
When a lot of work is not done in our research centers—like the lab-
oratory at Ada—then we are underwriting sometimes as high as a
third of our project costs for overhead, just for facilities. We could
probably get a greater use of our research dollar by trying to make
sure we have very efficient use of our facilities—maybe in-house con-
tracts. And I think that we can get a tremendous amount of needed
research taken care of. I have discussed it with you and I have dis-
cussed it with many others. I think that is being looked into as some-
thing we may want to do and I know you are well aware of that, but
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I would like to indicate as we talk about research centers and univei
sity personnel some of them may definitely come and work and do this
in-house because we may be losing 25 percent of the money for overhead
expenses at a lot of the institutions.
I would like to go to one other question unless you would like to
make a comment on that, Dr. Gage.
Dr. GAGE. I quite understand what you are saying, Mr. Watkins.
I was just jotting down a couple of numbers here. I recall roughly
$75 million—one-quarter of our budget—is tied in with the salaries
and wages of the field personnel, the laboratory grants, et cetera, just to
provide the basic staffing and facilities for our laboratory efforts. I
think that would be considered a very low overhead when compared to
most external institutions involving scientific and technical operations.
So we, in fact, are starting from a very cost-effective base and we
dilute that to a considerable extent by turning so strongly to external
contracts. We ought to look at ways to recapture some of the benefits
of the local overhead operations.
Mr. WATKINS. I would like to ask about something that was dis-
cussed in the testimony of Dr. Miller and Dr. Rice. They talk about
potential impact of proposed regulations on the water utilities.
Reading a couple more sentences of this I would like to focus on
something. There is one EPA regulation for control of THM and syn-
thetic organic chemicals to go into effect in mid-1979, and water utili-
ties will have to react.
I am quite sure we in Congress are going to have another reaction. I
would like to try to be a step ahead here, Mr. Chairman. They are going
to have to make an analysis of the finished water; second, if a problem
exists to conduct a study of available opportunities to solving the prob-
lem that indeed exists, and, third, adopting an approach for correcting
the problem. I think this is an opportunity that maybe we should take
to be out front because I think this is where a tremendous amount of
criticism of EPA comes in—about some of the regulations that are put
into effect.
They do not have a particular procedure. They do not know which
way to go, which direction to take except to say you have got to do
something about it. So I would like for us to think about this. I would
like a word with you, Dr. Gage, on this particular facet because a cou-
ple of previous speakers have commented that most of these commu-
nities of 10,000 to 75,000 are using ground water or well water as their
water base and that essentially of the other 37,000 or less population
cities which encompasses basically all of my area use ground water.
They are going to react to these regulations and rightly so. I think that
we need to provide in our legislation and in the bill a method of making
these analyses of how many communities do we have today, what per-
centage have problems like this, and what is the economic impact. And
I plan to continue to make comments such as this because we have got
to come with something to prevent all this reaction and hopefully to
take care of the well water problem.
The next part is the assistance needed for water utilities. First, there
has got to be some training to educate the parties to be affected. Second,
technical assistance has got to be available. Third, a planned program
of assistance to water utilities is probably going to be required.
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Mr. Chairman. I think we may want to pursue this if you and the
rest of the committee feel like it. We need to go for some guaranteed
loans and probably grants to meet these requirements from EPA be-
cause many do not have a tax base to do that job. We must support the
realistic regional approach for providing monitoring and laboratory
services.
I am willing to spend some time with you and your staff, Dr. Gage,
and Mr. Chairman, in discussing this and trying to develop a proposal
to handle this before those regulations are in effect in 1979, because I
think we are going to create one of the largest—I say we—I think the
EPA regulations will create one of the largest impacts across this
country.
They stated on page 16 that the total package would cost more than
$100,000. Most of the communities just ain't got that kind of money.
Do you have any response to maybe moving in that direction?
Dr. GAGE. I would just say, pursuant to the Safe Drinking Water
Act of 1974, Mr. Watkins, EPA is, of course, the Agency which is
responsible for implementing the act passed by the Congress, but I
do appreciate your recognition that the Congress does have a very big
hand in this. That act does not really contemplate a major grant pro-
gram for States and municipalities to meet those
Mr. BROWN. Did it contemplate any kind of a grant or minor grant?
This is not something comparable to the $25 billion that we are putting
into waste disposal.
Dr. GAGE. No, I cannot say for sure that there were not minor grant
activities in there, but there was not a major grant program.
Of course, YOU did put an authorization section into the Environ-
mental R.D. & D Act for drinking water grants. There was not any
corresponding appropriation so there is no funding to do that.
I guess I would probablv even amplify your remarks, Mr. Watkins,
and yoiir point directly. I think that the regulations that we have
established now or are proposing as the interim drinking water stand-
ards for cities over 75,000 probably can be met in most cases by the
cities. They do have a good tax base. They are able to raise money.
They have what technical expertise is available at the local level, and
even with the estimated pricetag of something like $300 million for the
activated charcoal systems for those 50-some cities that might have to
put those units on, that is probably doable. If not. then I am sure you
will be hearing from municipalities to give them some assistance.
Mr. WATKINS. I think Oklahoma City may be one of those and 1
think I have already seen the editorials about it.
Dr. GAGE. The thrust as I recall is primarily on surface waters. We
do have the humic acid building up from decaying leaves interacting
with the chlorine in the water treatment plant. That is the major health"
impact there. It is not all of the problem.
But there are two very major exceptions here. There is a grounc
water section—we have spent quite a bit of time talking about that ir
the last few davs. There do appear to be contaminated groundwatei
supplies. The interim standards do not address that in a straight
forward way. I am sure that the standard for trihalomethanes migh
apply in some very indirect ways. But that is a standard basically foi
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chlorine, and the contaminants that seem to be showing up in ground
water supplies are many of the other types of organic chemicals, not
chloroform.
The other major exception that I point out are the cities under
75,000 relying on surface waters for their drinking water supplies.
The 75,000 limitation was drawn in order to keep the smaller cities
from going under in terms of the economic burden. Now the smaller
cities are concerned about their water supply. There have been meas-
urements made of the water quality in a number of these places and
there is contamination. I am sure you are going to be hearing about
that.
We also are going to be hearing about that, and we are thinking
about how we will take the next step in the Safe Drinking Water Act
to extend the public health protection to a large number of additional
people who are not covered under the interim standards proposed
recently.
I guess to sum up we have two problems which have not yet been
addressed.
Mr. WATKIXS. I will be looking forward to following up with you
on some of this because I think we can do some preventive work here
that will make all of our jobs a litttle more acceptable by the mass of
people out there who we are supposed to be serving.
Dr. GAGE. You mentioned training; I would like to speak up for a
couple of my colleagues. Tom Jorling and David Hawkins, the as-
sistant administrators for water and air programs, respectively. They
both were faced, as a result of the zero-base budget review, with re-
ductions in their training programs. In Jorling's case that meant a re-
duction in his drinking water supply training program. That is the
program which has been training the State officials and State techni-
cians in order that they may go on to train municipal expertise to meet
these drinking water standards. That is just one of the other areas that
did receive lower priority. So that is another place where the tight con-
trols of priorities have possibly exacerbated some difficulties at the
local level.
Mr. BROWX. Just one additional question, Dr. Gage, a matter which
came up during the course of the hearing.
Your statutory authority for multiyear funding of the research pro-
grams. Are there any impediments to multiyear funding that you
know of ?
Dr. GAGE. There is one that comes to mind immediately and that is
that the funds that we are appropriated have a 2-year limitation on
them. In other words, if we do not expend them within 2 years, they
lapse, and we have to come back for a new appropriation. We can get
around that to an extent by what we call front-end funding of a
research proposal. That starts a certain momentum in the research
program in that we have to have fairly large blocks of money avail-
able to front-end fund research center which, say, might be running at
one-half million dollars a year and we want to fund that for 3 to 5
years. That means we have to have $1.5 or $2.5 million in hand when
we set that center into motion. Now that just distorts everything else
we are trying to do during the startup year, and probably also dis-
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torts things during the next couple of years because we had to arrange
the program to come up with the front-end funding. I think that is
something that will bear our mutual investigation.
Mr. BROWN. Maybe after we have gone through enough of these
hearings we will want to go back to 2- or 3-year authorization hearings
legislation.
Dr. GAGE. Does that mean more or less hearings for me ?
Mr. BROWN. That means less hearings. [Laughter.]
I did want to commend you for designating Mr. Shearer to be th<
focal point for the Houston study. We certainly look forward to con-
tinued reports on how that is going along.
Recognizing the lateness of the hour and other factors, I think wt
will refrain from further questioning and again thank you for youi
assistance and cooperation and the excellent quality of your presenta-
tion even though we did not necessarily agree with it in every detail
With that the subcommittee will be adjourned.
[Whereupon, the subcommittee was adjourned at 5:45 p.m.]
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COMMENTS ON TEXAS HYDROCARBON/PHOTOCHEMICAL
OXIDANT STRATEGY
MEDICAL CENTER, HOLIDAY INN'
DECEMBER M, 1976, 10:00 A.M.
PRESENTED TO THE FEDERAL ENVIRONMENTAL
PROTECTION AGENCY
BY: ALBERT G. RANDALL, M.D.
DIRECTOR OF PUBLIC HEALTH
CITY OF HOUSTON HEALTH DEPARTMENT
REPORT PREPARED BY: CITY OF HOUSTON HEALTH DEPARTMENT
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THE POLLUTION CONTROL PROGRAfl OF THE CITY OF
HOUSTON HEALTH DEPARTMENT, AS THE LOCAL ENFORCEMENT
AGENCY FOR THE CITY OF HOUSTON. PRESENTS THIS TESTIMONY
CONCERNING THE PORTIONS OF THE PROPOSED AMENDMENTS TO
THE HYDROCARBON/PHOTOCHEMICAL OXIDANT STRATEGY FOR TEXAS
.THAT AFFECT THE CITY OF HOUSTON AMD ITS RESIDENTS. THE
CITY OF HOUSTON HAS HAD AN EFFECTIVE POLLUTION CONTROL
PROGRAM FOR MANY YEARS AND, IN COOPERATION WITH OTHER
AGENCIES AT THE FEDERAL, STATE, AND LOCAL LEVEL, HAS
ACCOMPLISHED MUCH TO ALLIEVIATE ENVIRONMENTAL PROBLEMS • •
IN THE CITY AND PREVENT NEW PROBLEMS FROM DEVELOPING
AS THE CITY AND THE SURROUNDING AREAS CONTINUE TO GROW •
AND EXPAND. HOWEVER, CONTINUED STUDY IS NECESSARY TO
IDENTIFY REMAINING PROBLEMS OR NEW PROBLEMS THAT MY
OCCUR, AND CONTINUED EFFORT IS REQUIRED TO MAINTAIN A
SATISFACTORY DEGREE OF CONTROL OVER THESE PROBLEMS.
OF ALL THE ENVIRONMENTAL PROBLEMS IN THE HOUSTON AREA,
NONE HAS BEEN MORE PERPLEXING OR MORE DIFFICULT TO SOLVE
THAN THE PROBLEM OF SO-CALLED PHOTOCHEMICAL SMOG. SINCE
THE OXIDANT STANDARD WAS PROMULGATED BY THE ENVIRONMENTAL
PROTECTION AGENCY IN APRIL, 1971, CONTINUING STUDY AND
EVALUATION BY THE CITY OF HOUSTON AND MY MANY OTHERS HAS
PROVIDED SOME UNDERSTANDING OF THE NATURE OF THIS PROBLEM
IN HOUSTON, BUT ADEQUATE KNOWLEDGE TO PERMIT THE. ESTABLISH-
MENT OF POSITIVE CONTROL EFFORTS TO ACHIEVE THE EPA
STANDARD IS STILL LACKING. AS OUTLINED IN PREVIOUS
TESTIMONY BY THE CITY OF HOUSTON AT SEVERAL HEARINGS, THE
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CITY HAS IMPLEMENTED A NUMBER OF CONTROLS AIMED AT
REDUCING VEHICULAR CARBON MONOXIDE EMISSIONS, AS HELL
AS HYDROCARBON EMISSIONS FROM BOTH VEHICULAR AND
STATIONARY SOURCES. THESE INCLUDE THE LOCAL ENFORCE-
MENT PROGRAM BASED ON REGULATION V AND OTHER REGULATIONS
OF THE TEXAS AIR CONTROL BOARD, AS WELL AS LOCAL
ORDINANCES, AND ALSO SEVERAL TRANSPORTATION MEASURES,
INCLUDING IMPROVEMENTS IN HouTRAN, THE CITY-OWNED BUS
SYSTEM; A MiNiBus SYSTEM SERVING THE CENTRAL BUSINESS
DISTRICT; IMPROVEMENTS IN TRAFFIC CONTROL; CAR$HARE, A
COMPUTER-BASED CARPOOL MATCHING SYSTEM, AND PARK-AND-RIDE
FACILITIES NEAR THE DOWNTOWN AREA. THESE WILL BE DES-
CRIBED IN SEPARATE TESTIMONY BY THE CITY'S OFFICE OF
PUBLIC TRANSPORTATION. '
THESE MEASURES HAVE BENEFITTED THE PEOPLE OF HOUSTON
BY MINIMIZING TRAFFIC DELAYS AND REDUCING EMISSIONS FROM
VEHICLES AS MUCH AS POSSIBLE WITH EXISTING STREETS AND
FREEWAYS, AND WITHOUT EXCESSIVE COST OR DISRUPTION OF
ESSENTIAL TRANSPORTATION TO THE PUBLIC. THE RESULTS IN
TERMS OF AIR QUALITY HAVE BEEN MIXED.
FIRST, THESE EFFORTS, AND PERHAPS TO A GREATER EXTENT
THE FEDERAL STANDARDS LIMITING EMISSIONS FROM NEW VEHICLES,
HAVE REDUCED CARBON MONOXIDE LEVELS DRAMATICALLY. MONITOR-
ING STATIONS OF BOTH THE CITY OF HOUSTON AND THE TEXAS AIR
CONTROL BOARD HAVE SHOWN LEVELS EXCEEDING THE EPA STANDARD
AN AVERAGE OF ONLY 3 TIMES PER YEAR. THIS DOES NOT MEAN
THAT WE CAN FORGET CARBON MONOXIDE; CHANGES OR INCREASES
IN TRAFFIC DENSITY COMBINED WITH UNUSUALLY SLOW TRAFFIC ON
A DAY OF METEOROLOGICAL STAGNATION STILL MIGHT CAUSE AN
-2-
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INCREASE IN THE NUMBER OF VIOLATIONS, BUT FOR NOW, IT APPEARS
THAT CARBON MOMXIDE DOES'NOT POSE ANY SIGNIFICANT THREAT
TO THE PEOPLE OF HOUSTON. WITH THE MORE RESTRICTIVE
EMISSION STANDARDS APPLICABLE TO NEW VEHICLES, THERE IS
EVERY REASON TO HOPE AND BELIEVE THAT THIS WILL CONTINUE
TO BE TRUE.
UNFORTUNATELY, THE OXIDANT STANDARD PRESENTS A DIF-
FERENT STORY. OZONE LEVELS, WHICH ARE THE MEASUREMENTS
SPECIFIED TO DETERMINE COMPLIANCE WITH THE OXIDANT STANDARD,
CONTINUE TO EXCEED THE STANDARD FREQUENTLY. ACCORDING TO
TEXAS AIR CONTROL BOARD INVENTORY FIGURES, THE COMBINATION
OF CONTROL MEASURES DESCRIBED ABOVE HAS RESULTED IN A
REDUCTION OF APPROXIMATELY 40Z IN HYDROCARBON EMISSIONS
FROM ALL SOURCES, COMPARED TO THREE OR FOUR YEARS AGO WHEN
CONTROL. EFFORTS WERE JUST BEGINNING. ACCORDING TO THE
"LINEAR ROLLBACK" OR "PROPORTIONAL ROLLBACK" PRINCIPLE
THAT IS THE BASIS FOR THE CONTROL MEASURES BEING DISCUSSED
TODAY AND OTHERS THAT WILL BE PROPOSED IN THE FUTURE,
THIS SHOULD HAVE RESULTED IN A REDUCTION IN OZONE LEVELS
OF AROUND 40Z. NO SUCH REDUCTION HAS OCCURRED. IN FACT,
1976 SO FAR HAS SHOWN MORE "HIGH OZONE"'DAYS THAN ANY
OTHER YEAR SINCE ADEQUATE MONITORING RESULTS WERE OBTAINED.
(EXHIBIT A). THIS MAY BE DUE IN PART TO AN UNUSUALLY LARGE
NUMBER OF DAYS DURING *976 WHEN METEOROLOGICAL STAGNATION
OCCURRED. BUT THIS LACK OF ANY CORRELATION SUGGESTS THAT'
THE MEASURES TAKEN SO FAR HAVE NOT BEEN EFFECTIVE IN
IMPROVING AIR QUALITY, AT LEAST IN MOVING TOWARD ACHIEVE-
MENT OF THE PHOTOCHEMICAL OXIDANT STANDARD. CERTAINLY, IF
-3-
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HYDROCARBON REDUCTIONS OF'THE MAGNITUDE AS STATED
EARLIER HAVE BEEN ACCOMPLISHED WITHOUT ACHIEVING THE
DESIRED REDUCTION IN OZONE LEVELS, IT WOULD SEEM
APPROPRIATE TO RE-EVALUATE THE SITUATION.
THE SCIENTIFIC QUESTIONS THAT HAVE BEEN RAISED CON-
CERNING THE APPLICATION OF THIS STANDARD IN HOUSTON HAVE
BEEN MANY AND VARIED, AND HAVE BEEN RAISED BY A NUMBER
OF SCIENTISTS. THESE QUESTIONS WILL NOT BE REVIEWED
HERE, BUT IT IS APPROPRIATE TO MENTION TWO NEW ITEMS OF
INFORMATION THAT ADD TWO MORE PIECES TO THE JIGSAW PUZZLE.
THAT EVERYONE IS TRYING TO ASSEMBLE TO UNDERSTAND THIS
COMPLEX PROBLEM.
THE FIRST NEW EVIDENCE CONCERNS THE NON-METHANE HYDRO-
CARBON STANDARD THAT ACCOMPANIES THE OXIDANT STANDARD
AND FORMS THE BASIS FOR THE PRESUMED RELATIONSHIP BETWEEN
HYDROCARBON EMISSIONS AND OXIDANT FORMATION. SEVERAL
BRIEF STUDIES IN THE PAST HAVE PROVIDED RESULTS THAT
RAISED QUESTIONS ABOUT POSSIBLE NATURAL CONSTITUENTS OF
THE ATMOSPHERE THAT WERE MEASURED AS NON-METHANE HYDRO-
CARBONS, BUT NOW A MORE COMPREHENSIVE STUDY HAS BEEN
COMPLETED. EXPERIMENTAL DETAILS WILL BE PRESENTED IN
OTHER TESTIMONY AT THIS HEARING BY DR. RICHARD SEVERS OF
THE UNIVERSITY OF TEXAS SCHOOL OF PUBLIC HEALTH. THIS STUDY
SUGGESTS THAT NON-METHANE HYDROCARBON LEVELS IN RURAL AREAS
AROUND HOUSTON EXCEED THE EPA STANDARDS AND, THEREFORE,
MAY BE UNATTAINABLE.
A MAJOR UNANSWERED QUESTION CONCERNS THE REACTIVITY
OF THESE PRESUMABLY NATURAL MAIERIALS IN THE ATMOSPHERE.
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JF THEY PARTICIPATE IN PHOTOCHEMICAL REACTIONS TO FORM
OZONE, AS GASOLINE VAPOR AND OTHER MAN-MADE HYDROCARBONS
DO, THEN NO DEGREE OF REDUCTION IN MAN-MADE HYDROCARBON
EMISSIONS CAN ELIMINATE OZONE FORMATION. IF THIS IS
TRUE, THEN THE ENTIRE SYSTEM IN THE HOUSTON AREA MAY BE
DEPENDENT ON OXIDES OF NITROGEN RATHER THAN HYDROCARBONS,
SINCE THE REACTIVE OXIDES OF NITROGEN PRESUMABLY RESULT
PRIMARILY FROM MAN'S ACTIVITIES AND NOT TO ANY SIGNIFICANT
DEGREE FROM NATURAL ORIGINS. LABORATORY EXPERIMENTS
SUGGEST THAT THE ENTIRE REACTION MECHANISM IS SENSITIVE TO
CHANGES IN THE RATIO BETWEEN HYDROCARBONS AND OXIDES OF
NITROGEN, AND THAT REDUCING HYDROCARBONS MAY INCREASE
PHOTOCHEMICAL SMOG INSTEAD OF DECREASE IT, IF OXIDES OF
NITROGEN ARE NOT DEDUCED PROPORTIONATELY. IT WOULD BE
EXTREMELY IRONIC IF THE MASSIVE CONTROL EFFORTS SO FAR
HAVE MADE THIS PARTICULAR TYPE OF PROBLEM WORSE INSTEAD
OF BETTER.
THE SECOND ITEM OF NEW EVIDENCE IS ONLY CIRCUMSTANTIAL
'IN NATURE, BUT FROM A HEALTH POINT OF'VIEW, IS DISTURBING.
DURING THE PAST 20 YEARS OR SO THAT -INTERMITTENT SCIENTIFIC
STUDES HAVE BEEN MADE OF HOUSTON'S AIR POLLUTION PROBLEMS,
THERE HAVE BEEN ONLY RARE DOCUMENTED INCIDENTS THAT SUG-
GEST THE LOS ANGELES-TYPE EYE IRRITATION. THESE REPORTED
INSTANCES OF EYE IRRITATION HAVE BEEN CLOSE TO NEARBY
CHEMICAL PLANTS, SUGGESTING THAT ACCIDENTAL RELEASES OF
IRRITATING CHEMICALS WERE THE CAUSE. DURING THE PAST YEAR,
HOWEVER, AN INCREASED NUMBER OF UNSOLICITED COMPLAINTS OF
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271
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390
EYE IRRITATION WERE RECEIVED BY THE CITY OF HOUSTON
HEALTH DEPARTMENT THAT COULD NOT BE ATTRIBUTED TO A
NEARBY CHEMICAL PLANT OR OTHER OBVIOUS SUSPECT. THIS
RAISES THE SERIOUS QUESTION OF THE SOURCE OF THESE
IRRITATING MATERIALS. ARE THEY FORMED BY PHOTOCHEMICAL
REACTIONS IN THE ATMOSPHERE? ARE THEY SIMILAR TO THE ' .
MATERIALS THAT CAUSE EYE IRRITATION IN SOUTHERN CALIFORNIA?
DOES THIS INDICATE A CHANGE IN THE NATURE AND EXTENT OF
PHOTOCHEMICAL SMOG IN HOUSON THAT IS NOT MEASURED BY THE
OZONE INSTRUMENTS? OZONE AT THE LEVELS OCCURRING IS NOT.
KNOWN TO CAUSE EYE IRRITATION, BUT OZONE IS USED AS'AN .
INDICATOR OF THE ENTIRE PHOTOCHEMICAL SMOG COMPLEX. IF
THIS COMPLEX MIXTURE IS BEGINNING TO CONTAIN MATERIALS
THAT CAUSE EYE IRRITATION, ARE THESE CHANGES RELATED TO THE
SUBSTANTIAL REDUCTION IN HYDROCARBON EMISSIONS THAT HAS
TAKEN PLACE?
THESE QUESTIONS CANNOT BE ANSWERED NOW, BUT THE CITY
OF HOUSTON HEALTH DEPARTMENT INTENDS TO DO EVERYTHING
POSSIBLE TO OBTAIN ANSWERS. THIS IS ONE MORE AREA IN WHICH
MORE INFORMATION IS ESSENTIAL, IF FUTURE CONTROL EFFORTS
ARE TO BENEFIT THE PUBLIC. THE CITY PETITIONS EPA TO JOIN
IN THIS SEARCH, AND TO LEARN MORE ABOUT THIS PARTICULAR
PROBLEM BEFORE ADDITIONAL COSTLY AND DISRUPTIVE CONTROL
MEASURES ARE PROMULGATED. THIS IS APPARENTLY THE INTENTION
OF EPA IN DIVIDING THE OXIDANT CONTROL STRATEGY INTO AN
INTERIM PLAN AND A LONG RANGE PLAN. THE CONTROLS PRESENTLY
PROPOSED DO NOT APPEAR TO INVOLVE EXCESSIVE COST OR DIS-
RUPTION FOR THE PUBLIC, BUT HI: WOULD URGE IHAT A MUCH BETTER
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391
UNDERSTATING Of THIS I'HOBLL'Ii LE OBTAINED BEFORE
ADDITIONAL MEASURES ARE PROPOSED.
TURNING NOW TO THE SPEC1FID MEASURES PROPOSED IN
THE FEDERAL REGISTER ON NOVEMBER II, 1976, I WOULD LIKE
TO COMMENT ON THOSE THAT ARE OF CONCERN TO THE CITY OF
HOUSTON HEALTH DEPARTMENT.
SECTION 52.2294 REQUIRES THE STATE AND/OR LOCAL
AGENCIES TO COMPLETE A FEASBILITY STUDY OF MEASURES TO
INCREASE THE USE OF BUSES OR OTHER MASS TRANSIT FACILITIES
AND CARPOOLS. THE CITY OF HOUSTON WILL ASSIST IN THIS
STUDY IN ANY WAY POSSIBLE, SHARING INFORMATION ON PREVIOUS
EXPERIENCES AND PROBLEMS WITH THE CARSHARE PROGRAM, WITH
ATTEMPTS TO IMPROVE THE HouTRAN SYSTEM, WITH WORK IN
TRAFFIC CONTROL, AND ANY OTHER PERTINENT: EFFORTS. THE CITY
HAS MADE MAJOR EFFORTS IN THESE AREAS, AND IT IS HOPED THAT
THIS EXPERIENCE WILL BE USEFUL IN PLANNING FURTHER EFFORTS.
SECTION 52.2296 REQUIRES THAT°FOUR CITIES IN TEXAS,
INCLUDING HOUSTON, IMPLEMENT A CARPOOL MATCHING AND PRO-
MOTION SYSTEM. AS'PRESENTLY PROPOSED, THE CARSHARE PLAN
BEING OPERATED .BY THE CITY APPEARS TO MEET ALL OF THE RE-
QUIREMENTS SPECIFIED. IF THIS REGULATION IS PROMULGATED
AS PROPOSED, THE REPORTS SPECIFIED WILL BE PREPARED FOR
SUBMISSION TO THE REGIONAL ADMINISTRATOR.
SECTION 52.2297 REQUIRES MASS TRANSIT AND CARPOOL
INCENTIVE PROGRAMS BY EMPLOYERS AND EDUCATIONAL INSTITUTIONS
LARGER THAN A SPECIFIED MINIMUM SIZE. PARAGRAPH (c) (5)
OF THAT SECTION REQUIRES A CARPOOL MATCHING PROGRAM, EITHER
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392
ALONE OR AS A PORTION OF A LARGER PROGRAM. FOR MANY
EMPLOYERS AND EDUCATIONAL INSTITUTIONS IN THE HOUSTON
'AREA, THE CITY'S CARSHARE PROGRAM MAY MEET THIS RE-
QUIREMENT AND IS AVAILABLE TO FILL ANY NEEDS THAT IT
CAN MEET.
NEXT, WE WOULD LIKE TO COMMENT ON THE QUESTIONS
RAISED CONCERNING INSPECTION/MAINTENANCE OF MOTOR VEHICLES.
IN PRINCIPLE, AN INSPECTION SYSTEM LEADING TO BETTER
VEHICLE MAINTENANCE WOULD PROVIDE SIGNIFICANT BENEFITS,
BOTH FOR AIR QUALITY IN THE COMMUNITY, AND FOR THE
MOTORIST. BETTER MAINTENANCE MAY ALSO HELP TO SAVE
GASOLINE, ALTHOUGH EXCESSIVE EMISSIONS AND WASTED
GASOLINE DO NOT NECESSARILY OCCUR SIMULTANEOUSLY.
HOWEVER, IT APPEARS THAT THERE ARE MANY PROBLEMS
TO BE SOLVED BEFORE AN INSPECTION/MAINTENANCE PROGRAM
WILL BE ABLE TO PROVIDE SIGNIFICANT BENEFITS AT REASONABLE
COST. THE EXHAUST GAS A^LYZERS NOW AVAILABLE ARE
EXPENSIVE, AND THEY REQUIRE SKILLED PERSONNEL FOR
MAINTENANCE AND CALIBRATION. FOR ANY'MANDATORY INSPECTION
SYSTEM, AN EXTENSIVE SYSTEM OF CALIBRATION AND QUALITY
CONTROL WOULD BE ESSENTIAL, COVERING ALL INSPECTION
STATIONS, AS WELL AS ALL FACILITIES WHERE REPAIR AND TUNE-
UP WORK COULD BE PERFORMED TO OBTAIN COMPLIANCE. OTHER-
WISE, A CAR THAT FAILED INSPECTION AT ONE STATION MIGHT
PASS AT ANOTHER. OR, A MOTORIST WHOSE CAR FAILED MIGHT
BE TOLD TO GET A TUNE-UP WHEN IN FACT HIS CAR WOULD PASS
IF TESTED PROPERLY.
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274
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393
THE FQJLKAL ICGISItR L1SILD CI'LCIFIC QULS1IONS OF
INTEREST REGARDING INSPECTION/MAINTENANCE PROGRAMS. THE
FIRST CONCERNS THE ROLE OF FEDERAL, STATE AND LOCAL
GOVERNMENTS. IT IS DIFFICULT TO SEE HOW CITIES COULD
EFFECTIVELY CONDUCT SUCH A PROGRAM. THE CITY OF HOUSTON
HAS JURISDICTION ONLY WITHIN THE HOUSTON CITY LIMITS,
NOT IN THE 31 OTHER INCORPORATED CITIES IN HARRIS COUNTY •
OR IN THE UNINCORPORATED AREAS OF THE COUNTY, EXCLUDING '
AREAS OF EXTRA-TERRITORIRAL JURISDICTION FOR CERTAIN
PURPOSES. EVEN A COUNTY-WIDE PROGRAM-COULD COVER ONLY A
PORTION OF THE VEHICLES THAT MIGHT CONTRIBUTE EMISSIONS,
SINCE MANY VEHICLES FROM SURROUNDING COUNTIES COME INTO '
HOUSTON DAILY OR WITH SOME FREQUENCY. THEREFORE, IT WOULD
SEEM THAT LEGAL REQUIREMENTS AND IMPLEMENTATION SHOULD BE
A STATE FUNCTION. THE PRESENT VEHICLE SAFETY INSPECTION
IS ALSO A STATE REQUIREMENT, AND EMISSIONS CONTROL COULD
MOST LOGICALLY BE COMBINED WITH THE SAFETY INSPECTIONS.
A TEST BASED ON A COMPLETE DRIVING CYCLE IS MORE
LIKELY TO PROVIDE VALID RESULTS THAN AN IDLE-ONLY TEST,
BUT THE COST AND COMPLEXITY ARE SUCH THAT THIS LIKELY WILL
NOT BE FEASIBLE. THEREFORE, PRACTICAL CONSIDERATIONS
LIMIT THE AVAILABLE METHODS TO THE IDLE-ONLY TEST, THUS
FURTHER DECREASING THE POTENTIAL VALUE OF AN INSPECTION/
MAINTENANCE PROGRAM.
ANOTHER FACTOR TO BE CONSIDERED IS THE RELATIVE IMPOR-
TANCE OF VEHICLE EMISSIONS IN CAUSING OR AFFECTING HOUSTON'S
AIR POLLUTION PROBLEMS. THE PEOPLE OF HOUSTON HAVE DEMON-
STRATED A CONCERN FOR AIR QUALITY AND A WILLKJGNFSS TO TAKE
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275
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394
THE NECESSARY STEPS AND CAY I HE NECESSARY PRICE FOR
IMPROVED AIR QUALITY. HOWEVER, AS DISCUSSED FREQUENTLY
IN THE PAST FEW YEARS, THE AVAILABLE EVIDENCE INDICATES
THAT VEHICLE EMISSIONS ARE A RELATIVELY MINOR CONTRIBUTOR
TO WHATEVER PROBLEMS EXIST IN THE HOUSTON AREA. THIS
WILL UNDOUBTEDLY AFFECT THE PUBLIC'S REACTION TO AN
INSPECTION/MAINTENANCE PROGRAM.
FINALLY, WE WOULD LIKE TO REQUEST THAT ANOTHER HEAR--
ING BE HELD ON THE ADDITIONAL CONTROL MEASURES THAT WILL
BE PROPOSED AS THE SECOND PORTION OF THE INTERIM PLAN ' .
IN THE SPRING OF 1977.
BOTH IN THE DEVELOPMENT OF THESE ADDITIONAL CONTROLS,
AND IN EVALUATION AND PROMULGATION OF THE CONTROLS ALREADY
PROPOSED, THE CITY WILL PROVIDE ANY ASSISTANCE POSSIBLE
TO EPA, THE TEXAS AIR CONTROL BOARD, AND OTHER AGENCIES
INVOLVED. THE CITY OF HOUSTON HAS MADE A FIRM COMMITMENT
TO IMPROVING THE ENVIRONMENT AND TO SAFEGUARDING THE IMPROVE-
MENTS ALREADY ACHIEVED. WE WANT TO DO EVERYTHING POSSIBLE
TO UTILIZE ALL CONTROLS THAT ARE FEASIBLE AND THAT WILL
IMPROVE AIR QUALITY IN THE CITY OF HOUSTON AND THE SUR-
ROUNDING AREA AND WE WANT TO DO IT IN A RESPONSIBLE MANNER.
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276
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395
EXHIBIT A
1976 CHAMPS DATA
PEHCENT OF DAYS HAVING PEAK HOURLY OZONE
LEVELS IN THE INDICATED RANGES
P»rc«nC Of Day.
60
40
'10
0
0.2—0.3
t — i 1
\ 1 \ \ I §
ppm
,nnn
:» t> a.
•^ 3 V
n
O
O
Health Department Air Pollution Bulletins are issued vhcn ozone reaches 0.2 ppm.
0.08—0.109 ppm
3 60
t4
0
o •">
c
S 2°
s.
0
-
-
_
• _ .l~l l~l
C X. I.
«) «i q
>? t, «
|
&
1
n
na
*
c
3
^
Ml.
3k
a
•^
Ot
3
-c
__.
(X
«l
Ul
u
0
JOO L
0--0.079 ppm
J]J1
3-
ui
277
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1
4.
7
9
12
15
1b
REPORT NO |2.
EPA-600/8-79-008e 1
i ITLE AND SUBTITLE
PLAN FOR AIR POLLUTION RESEARCH IN THE TEXAS GULF
COAST AREA
Volume V. Local Viewpoints on Research Needs
AU , HOR(S)
Bryan Lambeth
Gary Tannahill
PERFORMING ORGANIZATION NAME AND ADDRESS
Radian Corporation
P. 0. Box 9948
8500 Shoal Creek Boulevard
Austin, TX 78758
SPONSORING AGENCY NAME AND ADDRESS
Environmental Sciences Research Laboratory-RTF, NC
Office of Research and Development
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
. SUPPLEMENTARY NOTES
. ABSTRACT
In response to Congressional mandates
Agency will conduct an extensive study of
i
*
3. RECIPIENT'S ACCE'.'.SION-r-iC. |
5. REPORT '
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