650978 ENVIRONMENTAL PROTECTION AGENCY DALLAS, fCXAI? OZONE ITS EFFECTS AND CONTROL U.S. ENVIRONMENTAL PROTECTION AGENCY OFFICE OF AIR QUALITY PLANNING AND STANDARDS RESEARCH TRIANGLE PARK, N.C. SEPTEMBER 1978 ------- i CONTENTS PREFACE 1 ' I INTRODUCTION 2 II DEFINITIONS, EFFECTS, AND STANDARDS 3 A. What are Photochemical Oxidants 3 , B. Are Oxidants Harmful? 3 j C. How Clean Should the Air Be? r III THE OZONE PROBLEM 7 A. Where Does Ozone Come From? 7 B. Which Sources Contribute Most to Ozone Problems. ... 7 C. How Does the Weather Affect Ozone Pollution g D. How Serious is the Ozone Problem in the United States 8 IV OZONE AND THE LAW .' ]Q A. What is Required? 10 B. Who is Responsible 10 C. What are the Penalties for Noncompliance 1 | V APPROACHES TO CONTROL 13 A. What Can Be Done? 13 B. What Measures are Appropriate 14 C. How Much Control Will be.Necessary ,. D. How Should Controls be Applied? -, -. l b E. Who Should be Involved •> , I o I ------- PREFACE Under provisions of the Federal Clean Air Act, the U.S. Environmental Protection Agency (EPA) has issued National Ambient Air Quality Standards (NAAQS). These standards specify the maximum amounts of air pollutants to which the general public may safely be exposed in the interest of health and welfare. When the NAAQS are found to be violated in any location, the Clean Air Act requires that steps be taken to bring the air in that location into compliance with standards by a specified date. Under the Clean Air Act Amendments of 1977, local governments are empowered and encouraged to participate fully in air-quality planning for their areas. Ozone is an air pollutant for which NAAQS have been issued by the EPA. Frequent and widespread violations have been recorded and extensive remedial measures will be required. Current efforts to mobilize the nation to solve the problem have been hampered by the complexity of the issues and controversy regarding appropriate solutions. To summarize and clarify the issues, the EPA Office of Air Quality Planning and Standards has prepared this document under contract. This summary attempts to provide the local decisionmaker and other interested persons with an understanding sufficient for informed consideration of evolving issues and arguments related to oxidant pollution and its control. Source material listed in the bibliography should be consulted by persons desiring a treatment of the issues in greater depth. ------- I INTRODUCTION By the Clean Air Act Amendments of 1970, Congress gave EPA the responsibility for setting air-quality standards. As an outgrowth of studies relating photochemical oxidants to health effects and damage to plant and materials, EPA in 1971 issued a standard for photochemical oxidants. This standard was set at 0.08 parts of oxidant per million parts of air as a one-hour average not to be exceeded more than once in any given year. Subsequent reevaluation led EPA in June of 1978 to propose a revised primary standard to apply only to the most abundant oxidant, ozone, as a one-hour average concentration of 0.10 ppm not to be exceeded more than an average of once per year. The proposed secondary, welfare related standard is 0.08 ppm. The Clean Air Act Amendments of 1977 require that the states make steps to achieve the standard by 1987 at the latest, and by 1982 where feasible. Because ozone pollution is substantial, widespread, and harmful to both health and welfare, extensive measures will be required to eliminate violations of the standard. The states are required to hold public hearing to receive comments on the issues before submitting to EPA their plans to implement appropriate measures. To further participation in the public hearing process, this document has been prepared to inform local decisionmakers and the interested public on the issues related to the nature and control of ozone pollution in the United States. ------- II DEFINITIONS, EFFECTS, AND STANDARDS A. What are Photochemical Qxidants? The term "oxidants" describes a complex group of compounds found in the ambient air. The term "photochemical" indicates that much of these particular oxidants are formed in the air by chemical reactions requiring the presence of sunlight. Oxidants in the ambient air were first associated with undesirable effects on human health and welfare three decades ago, when they were found to be major constituents of southern California "smog." Since that time, much more has been learned about the photochemical oxidants and their effects on public health, vegetation, certain ecosystems. and materials. Ozone—the most abundant oxidant—has been singled out for special concern from a public health and welfare standpoint. B. Are Oxidants Harmful? Numerous studies have been undertaken over the last three decades to determine how harmful the oxidants are to public health and welfare. The results are detailed in the EPA publication Air Quality Criteria for Ozone and Other Photochemical Oxidants.* It should be noted that with synergistic effects of ozone and other air contaminants, there has not been a sufficient study to understand this relationship. The following is a summary of the most significant effects. *EPA-600/8-78-004 (April 1978) An earlier edition was published in 1971, at the time the original NAAQS was adopted. ------- Public Health o The mechanical function of the lung is affected by exposure to ozone for periods on the order of two hours. The effect is pronounced at concentrations of 0.37 ppm or more; evident but less pronounced at concentrations from 0.25 to 0.37 ppm, and in some subjects this effect occurs at concentrations in the range of 0.15 to 0.25 ppm. o Asthma attacks occur more often when ambient concentrations of ozone reach 0.20 ppm for a one-hour period. For some asthmatics and other sensitive people, there is a likelihood of effect at concentrations from 0.15 to 0.20 ppm. o Ozorie exposures in the range of 0.15 to 0.25 ppm for an hour or so increase the risk of cough, chest discomfort, headache, and eye irritation. o There is evidence of impairment of physical performance (athletic performance) at ozone concentrations as low as 0.15 ppm. o Vigorous exercise is likely to increase the risk of health effects from ozone. o Existing evidence shows no consistent relationship between ozone exposures and mortality rates. o No convincing evidence is yet available relating either short- term or long-term ozone exposure to chronic health effects. Public Welfare o Ozone cause visible injury to a variety of plant species. o Ozone reduce the yields of citrus, cotton, potatoes, soybeans, wheat, spinach, and other sensitive crops. o Concentrations of ozone as low as 0.1 ppm for a one-hour exposure and 0.04 ppm for a four-hour exposure will affect some vegetation. o Ozone affect entire ecosystems, as evidence by damage to mixed conifer forests in California, reduction in the fruit and seed diet of small mammals, and alterations in species composition and wildlife habitat. o Ozone accelerates the deterioration or rubber, textile dyes and fibres, and certain paints and coatings. o Both health and welfare effects have severe economic impacts, which can be measured in terms of monetary losses totalling hundreds of millions of dollars each year. ------- C. How Clean Should the Air Be? Under the provisions of the Clean Air Act, EPA is charged with the establishment of standards for the cleanliness (quality) of the ambient air. "Ambient air" means the outdoor air to which the general public, structures, plants, and animals are exposed. A standard is a combination of the amount of pollutant in the air and the length of exposure permitted as a maximum in the interest of public health and welfare. Standards are established by the EPA after consideration of effects and application of an adequate margin of safety. Separate standards are authorized by the Clean Air Act for protection of public health (primary standards) and for protection of public welfare (secondary standards). On 30 April 1971 the EPA published a primary (and secondary) standard for photochemical oxidants of 0.08 ppm as a one-hour average not to be exceeded more than once in any given year. The human health effect category of most concern is aggravation of chronic lung disease and the basic work documenting the effect is the Schoettlin and Landau asthma study. This was a key study in determining the level of the existing standard. Based on a reevaluation of this study, the current criteria document attributes an increase in asthmatic attacks to a level of 0.25 ppm and not 0.10 ppm as presumed when the existing standard was promulgated. On 22 June 1978, the EPA proposed a new one-hour average primary standard of 0.10 ppm for ozone alone, not to be exceeded more than one time per year on the average. The secondary standard remains at 0.08 ppm. This proposed standard anticipates a few excesses in some years, balanced by years with no excesses at all to give an average of one excess or less per year. Because ozone consititutes the bulk or oxidants in the air and has been associated with most of the ------- health effects previously ascribed to total oxidant, ozone is proposed to replace total oxidants as the pollutant of concern. Ozone can also be measured more reliably than the other oxidants. Because of the specific importance of ozone, the probability of a revised standard, and the confusion attending the alternate use of the terms "oxidant" and "ozone," the term "ozone" is used exclusively throughout the remainder of this document. ------- Ill THE OZONE PROBLEM A. Where Does Ozone Come From? Unlike many other pollutants, ozone is not introduced directly to the air by man or nature, but forms in the air by chemical reaction. The compounds called "precursors," that eventually react to form ozone may be natural constituents of the atmosphere (as are oxygen and nitrogen), may be introduced directly as pollutants, or may be formed (as is ozone itself) by chemical reaction. High in the upper atmosphere, large amounts of ozone are produced by sunlight from the oxygen present in the air. Near the ground, ozone is produced primarily from man-made compounds. While many different compounds are involved, two basic precursor classes control the ozone production process: volatile organic compounds (VOC) and oxides of nitrogen (NO ). J\ VOC enters the air from a variety of human activities, among them fossil fuel combustion (primarily in auto exhaust), chemical processing, fuel storage and handling and solvent usage (such as painting or degreasing). VOC also enter the air from natural sources, such as biological decay and the vegetative growth process. Oxides of nitrogen, a component in the photochemical process, is primarily emitted to the atmosphere from the burning of fossil fuels. B. Which Sources Contribute Most to Ozone Problems? Because the air moves readily from one location to another, the air we breathe at a given place and time will contain ozone from natural as well as man-made sources. Measurements have shown, however, that ozone concentrations ------- in and near large urban centers where man-made sources predominate, are frequently far greater than concentrations in remote locations unaffected by human activity. These measurements; coupled with a variety of theoretical studies, point to human activity—especially that concentrated in large urban centers—as the source of primary concern. Control of emissions of ozone precursors associated with human activity will be instrumental in achieving the ozone standard throughout the United States. C. How Does the Weather Affect Ozone Pollution? Ultraviolet radiation from sunlight is required for the photochemical process. Ozone episodes therefore occur typically on sunny days in spring, summer, and fall, when the sun is high enough to provide sufficient ultraviolet radiation. On cloudy days and during the winter months, ozone levels rarely exceed the federal standard. Sluggish air movement aids in ozone production by allowing air parcels to remain longer over the source areas and permitting large amounts of precursors to accumulate and ozone to form. Temperature inversions (i.e., layers of warm air several hundred meters above the cooler air nearer the ground) frequently trap the pollutants near the ground. Warm temperatures have always been associated with ozone episodes, although the precise role of temperature in ozone production has not been adequately defined. D. How Serious is the Ozone Problem in the United States? Measurements indicate that ozone levels in violation of the standard occur in virtually every part of the United States. Ozone problems have been found in rural as well as urban areas. The highest concentrations of ozone are usually found a few miles downwind from large urban centers, ------- which are the principal source areas. The ozone standard is exceeded frequently in and near these urban centers, as often as 100 or more days per year in some locations. Concentrations exceeding 0.2 ppm are not uncommon and concentrations as high as 0.5 ppm have occurred at times in a few communities. The seriousness of the problem is highlighted by the fact that violations of the ozone standard have been detected in virtually every area where measurements have been taken, with the exception of a few predominantly rural locations. ------- IV OZONE AND THE LAW A. What is Required? Under the Clean Air Act, states must submit to EPA State Implementation Plans (SIPs), detailing approaches toward attainment and maintenance of all air-quality standards. In areas where the ozone standard has not yet been attained (nonattainment areas), SIPs must be revised to include control strategies which provides for attainment of standards by December 31, 1982. In areas where the attainment of standards cannot be demonstrated by implementing reasonably available control measures the deadline can be extended (up to 5 years) until 1987. Implementation planning for nonattainment areas must be completed in time for submittal of SIP revisions to EPA by January 1, 1979. B. Who is Responsible? While the EPA bears ultimate responsibility for enforcing requirements of the Clean Air Act, the law provides for maximum participation of state and local governments in the formulation and implementation of plans and strategies aimed at achieving the air-quality standard for ozone. Each state must provide for implementation, maintenance, and enforcement of primary and secondary air-quality standards in designated areas. Since many control measures for ozone reduction will strongly affect local jurisdictions, the Act provides that attainment plans be prepared, where possible, by an organization of elected officials of local governments in the affected areas certified by the state for this purpose. Otherwise, a state agency must prepare the plans. The plan must demonstrate that necessary requirements, ------- timetables, and compliance schedules have been adopted through submitta.l of a legally enforceable document and that the agency or organization identified in the plan as being responsible for carrying out the plan are committed to the implementation and enforcement of appropriate plan elements. Attainment plans must be developed with the continuing cooperative, and comprehensive transportation planning process mandated by federal law and with the general air-quality maintenance planning process of the SIP. Attainment planning requires a coordinated effort and includes local agencies responsible for transportation and maintenance planning. In carrying out any requirements of the Act that bear upon the perogatives of local government, the states must provide a satisfactory process of consultation with general-purpose local governments and designated organizations of their elected officials. C. What are the Penalties for Noncompliance? One of the principal penalties attached to inadequate planning for nonattainment areas has to do with the construction or modification of major stationary sources, such as industrial facilities. After June 30, 1979, no such construction or modification that contributes to violations of NAAQS may take place in a nonattainment area unless an adequate plan for attainment exists. In addition, inadequate implementation planning in nonattainment areas precludes the approval of projects and grants for transportation or air quality authorized under the United States Code, other than for safety, mass transit, or transportation improvement related to air-quality improvement or maintenance. EPA is required to enforce any requirement of a State Implementation Plan when it is determined that the state has failed to enforce the plan effectively. Enforcement against a source may take the form of an order to 11 ------- comply or a civil action. Persons violating or refusing to comply with any order of the EPA Administrator or violating requirements of an applicable implementation plan during a period of federally assumed enforcement can be subject to a civil penalty of not more than $25,000 per day of violation, or to permanent or temporary injunction, or both. ------- APPROACHES TO CONTROL A. What Can Be Done? As discussed earlier, the ozone problem results primarily from chemical reaction of man-made VOC and NO . It is logical, that the control of ozone A precursors generated by human activity, particularly in large urban centers, is necessary to achieve reductions in ambient ozone levels. Laboratory studies suggest that control of VOC is an effective approach to lowering ozone levels in urban areas and their immediate environs. Significant downtrends in ozone pollution have been recorded in the Los Angeles Basin and the San Francisco Bay Area, where VOC control programs have been underway for some time. Studies suggest that control of NO may A not be as effective in reducing ozone in urban areas. Because of the demonstrated effectiveness of VOC control, the current EPA strategy for reducing of the oxidant problem in urban areas is focused primarily on VOC control, however programs such as the FMVCP reduce emission of both VOC and NO . Recent research, has indicated that rural areas may also suffer from A ozone pollution and that urban pollutants—ozone as well as its precursors- can travel considerable distances at relatively high concentrations. Because the chemical composition of rural air differs from that of urban areas, NO control may be more effective in controlling rural ozone problems. A For this reason, NO control has received greater attention in recent years A both for rural areas and for urban areas affecting rural areas through transport. On the whole, studies indicate that a more effective program for reducing urban ozone concentrations should emphasize the control of VOC. Current strategy favors a vigorous control program for VOC but a cautious 13 ------- approach to control of NO beyond that required to attain the ambient air X quality standard for nitrogen dioxide. Additional emphasis on NO control may be required, however, at a later date. B. What Measures are Appropriate? State Implementation Plans for areas which have not attained the NAAQS for ozone, must contain limitations on the amount of ozone precursors that enter the air and timetables for compliance with such limitations. Other measures must be contained, as necessary, including (as a minimum) transportation controls, inspection and maintenance plans for autos for cities greater than 200,000 population when a state has requested an extension beyond 1982, and preconstruction review of direct sources of air pollution. State Implementation Plans may (but are not required to) contain provisions for land use controls, preconstruction review of indirect* sources of air pollutants, and other such measures as may be appropriate. c. How Much Control Will be Necessary? Maximum ozone levels in and around major urban centers are typically two to three times the federal ambient standard. Assuming a direct proportion between VOC and ozone reductions, VOC emissions in these areas will have to be reduced to one-half to one-third of their current values. This represents a conservative estimate, since studies have indicated that reductions in VOC yield less than proportional reductions in ozone concentration. When *An indirect source is a facility such as a parking lot that tends to increase air pollution from mobile sources (e.g., cars). 14 ------- ozone contribution from natural sources (including vegetation and particularly upper atmospheric ozone intrusion) is considered, which amounts to approximately 0.04 ppm, an even greater reduction in the contribution from man-made activities may be required. Methods for estimating required degree of control have been and are continuing to be developed. Although no single currently available model is satisfactory in every respect, evidence from a variety of modeling techniques indicates a substantial control requirement in many areas. Research is continuing at EPA to develop improved models to aid in determining the most effective approaches to ozone control. D. How Should Controls be Applied? Most urban and many rural areas now have ozone concentrations greater than the national standard. Since attainment of the ozone standard will be costly, there is an obvious and justifiable interest in achieving the most equitable distribution of the burden and the most efficient application of the control program. One of the most sensitive issues at present concerns the division of responsibility for control when a portion of a local ozone problem results from pollutants transported from nonlocal source areas. This is especially sensitive in those parts of the United States where transported pollutants from urban centers in close proximity accumulate under stagnant weather conditions to form a regional "blanket" of bexkground ozone. At present it is difficult to partition responsibility for ozone control. Considering, however, the degree of control that will be required to attain the standard, it is reasonable, until more information is at hand, for everyone to exert maximum effort toward local control of VOC 15 ------- emissions. Cooperative efforts in implementation planning among the States should minimize any gross inequities. E. Who Should be Involved? The ozone problem is one that affects every citizen: Very few urban locations are free of ozone pollution and none are free of sources of pollution which cause ozone and virtually everyone is subject to the health and welfare effects. Because ozone is a regionwide problem with a full spectrum of sources and causes, everyone will bear some portion the great cost for ozone control. For these reasons, everyone should involve themselves in the solution of the ozone problem by keeping well informed and cooperating fully in the planning and implementation phases of the solution process. 16 ------- |