THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Statutes and Legislative History
Executive Orders
Regulations
Guidelines and Reports
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THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Statutes and Legislative History
Executive Orders
Regulations
Guidelines and Reports
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JANUARY 1973
WILLIAM D. RUCKELSHAUS
Administrator
U-S. Envfronmtnta!
Region V, Library
230 South Dearborn Street
Chicago, Illinois 60604 ^
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For sale by the Superintendent of Documents, U. S. Government Printing Office
Washington, D. C. 20402 - Price $17.80 Per Set of Five Vols. (Sold in Sets Only)
Stock Number 5500-0064
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FOREWORD
It has been said that America is like a gigantic boiler in that once
the fire is lighted, there are no limits to the power it can generate.
Environmentally, the fire has been lit!
With a mandate from the President and an aroused public concern-
ing the environment, we are experiencing a new American Revolution,
a revolution in our way of life. The era which began with the industrial
revolution is over and things will never be quite the same again. We
are moving slowly, perhaps even grudgingly at times, but inexorably
into an age when social, spiritual and aesthetic values will be prized
more than production and consumption. We have reached a point
where we must balance civilization and nature through our technology.
The U.S. Environmental Protection Agency, formed by Reorganiza-
tion Plan No. 3 of 1970, was a major commitment to this new ethic.
It exists and acts in the public's name to ensure that due regard is
given to the environmental consequences of actions by public and
private institutions.
In a large measure, this is a regulatory role, one that encompasses
basic, applied, and effects research; setting and enforcing standards;
monitoring; and making delicate risks-benefit decisions aimed at
creating the kind of world the public desires.
The Agency was not created to harass industry or to act as a shield
behind which man could wreak havoc on nature. The greatest disser-
vice the Environmental Protection Agency could do to American
industry is to be a poor regulator. The environment would suffer,
public trust would diminish, and instead of free enterprise, environ-
mental anarchy would result.
It was once sufficient that the regulatory process produce wise and
well-founded courses of action. The public, largely indifferent to regu-
latory activities, accepted agency actions as being for the "public
convenience and necessity." Credibility gaps and cynicism make it
essential not only that today's decisions be wise and well-founded but
that the public know this to be true. Certitude, not faith, is de rigueur.
In order to participate intelligently in regulatory proceedings, the
citizen should have access to the information available to the agency.
EPA's policy is to make the fullest possible disclosure of information,
without unjustifiable expense or delay, to any interested party. With
iii
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iv FOREWORD
this in mind, the EPA Compilation of Legal Authority was produced
not only for internal operations of EPA, but as a service to the public,
as we strive together to lead the way, through the law, to preserving
the earth as a place both habitable by and hospitable to man.
WILLIAM D. RUCKELSHAUS
Administrator
U.S. Environmental Protection Agency
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PREFACE
Reorganization Plan No. 3 of 1970 transferred 15 governmental
units with their functions and legal authority to create the U.S.
Environmental Protection Agency. Since only the major laws were
cited in the Plan, the Administrator, William D. Ruckelshaus, re-
quested that a compilation of EPA legal authority be researched and
published.
The publication has the primary function of providing a working
document for the Agency itself. Secondarily, it will serve as a research
tool for the public.
A permanent office in the Office of Legislation has been established
to keep the publication updated by supplements.
It is the hope of EPA that this set will assist in the awesome task
of developing a better environment.
LANE WARD GENTRY, J.D.
Assistant Director for Field Operations
Office of Legislation
U.S. Environmental Protection Agency
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ACKNOWLEDGMENT
The idea of producing a compilation of the legal authority of EPA
was conceived and commissioned by William D. Ruckelshaus, Ad-
ministrator of EPA. The production of this compilation involved the
cooperation and effort of numerous sources, both within and outside
the Agency. The departmental libraries at Justice and Interior were
used extensively; therefore we express our appreciation to Marvin
P. Hogan, Librarian, Department of Justice; Arley E. Long, Land &
Natural Resources Division Librarian, Department of Justice;
Frederic E. Murray, Assistant Director, Library Services, Department
of the Interior.
For exceptional assistance and cooperation, my gratitude to:
Gary Baise, formerly Assistant to the Administrator, currently Direc-
tor, Office of Legislation, who first began with me on this project;
A. James Barnes, Assistant to the Administrator; K. Kirke Harper, Jr.,
Special Assistant for Executive Communications; John Dezzutti,
Administrative Assistant, Office of Executive Communications;
Roland O. Sorensen, Chief, Printing Management Branch, and
Jacqueline Gouge and Thomas Green, Printing Management Staff;
Ruth Simpkins, Janis Collier, Wm. Lee Rawls, Peter J. McKenna,
James G. Chandler, Jeffrey D. Light, Randy Mott, Thomas H. Rawls,
John D. Whittaker, Linda L. Payne, John M. Himmelberg, and
Dana W. Smith, a beautiful staff who gave unlimited effort; and to
many others behind the scenes who rendered varied assistance.
LANE WARD GENTRY, J.D.
Assistant Director for Field Operations
Office of Legislation
U.S. Environmental Protection Agency
VI
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INSTRUCTIONS
The goal of this text is to create a useful compilation of the legal
authority under which the U.S. Environmental Protection Agency
operates. These documents are for the general use of personnel of the
EPA in assisting them in attaining the purposes set out by the Presi-
dent in creating the Agency. This work is not intended and should
not be used for legal citations or any use other than as reference of a
general nature. The author disclaims all responsibility for liabilities
growing out of the use of these materials contrary to their intended
purpose. Moreover, it should be noted that portions of the Con-
gressional Record from the 92nd Congress were extracted from the
"unofficial" daily version and are subject to subsequent modification.
EPA Legal Compilation consists of the Statutes with their legisla-
tive history, Executive Orders, Regulations, Guidelines and Reports.
To facilitate the usefulness of this composite, the Legal Compilation
is divided into the eight following chapters:
A. General E. Pesticides
B. Air F. Radiation
C. Water G. Noise
D. Solid Waste H. International
AIR
The chapter labeled "Air," and color coded light blue, contains the
legal authority of the Agency directly related to air pollution. Several
documents under this title are applicable to other areas of pollution,
and when this occurs, a reference is made back to "General" where
the full text appears. This method is used in order that the documents
are not needlessly reproduced in each chapter.
SUBCHAPTERS
Statutes and Legislative History
For convenience, the Statutes are listed throughout the Compilation
by a one-point system, i.e., 1.1, 1.2, 1.3, etc., and Legislative History
begins wherever a letter follows the one-point system. Thusly, any
l.la, Lib, 1.2a, etc., denotes the public laws comprising the 1.1,
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viii INSTRUCTIONS
1.2 statute. Each public law is followed by its legislative history.
The legislative history in each case consists of the House Report,
Senate Report, Conference Report (where applicable), the Congres-
sional Record beginning with the time the bill was reported from
committee.
Example:
1.1 Clean Air Act, as amended, 42 U.S.C. §1857 et seq. (1970).
l.la Air Pollution Act of July 14, 1955, P.L. 84-159, 69 Stat. 322.
(1) Senate Committee on Public Works, S. REP. No. 389, 84th Cong.,
1st Sess. (1955).
(2) House Committee on Interstate and Foreign Commerce, H.R. REP.
No. 968, 84th Cong., 1st Sess. (1955).
(3) Congressional Record, Vol. 101 (1955):
(a) May 31: Amended and passed Senate, pp. 7248-7250;
(b) July 5: Amended and passed House, pp. 9923-9925;
(c) July 6: Senate concurs in House amendment, pp. 9984-9985.
This example not only demonstrates the pattern followed for legislative
history, but indicates the procedure where only one section of a public
law appears. You will note that the Congressional Record cited pages
are only those pages dealing with the discussion and/or action taken
pertinent to the section of law applicable to EPA. In the event there
is no discussion of the pertinent section, only action or passage, then
the asterisk (*) is used to so indicate, and no text is reprinted in the
Compilation. In regard to the situation where only one section of a
public law is applicable, then only the parts of the report dealing with
same are printed in the Compilation.
Secondary Statutes
Many statutes make reference to other laws and rather than have
this manual serve only for major statutes, these secondary statutes
have been included where practical. These secondary statutes are
indicated in the table of contents to each chapter by a bracketed cite
to the particular section of the major act which made the reference.
Citations
The United States Code, being the official citation, is used through-
out the Statute section of the compilation.
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INSTRUCTIONS
IX
TABLE OF STATUTORY SOURCE
Statute Source
1.1 The Clean Air Act, as amended,
42 U.S.C. §1857 et seq. (1970).
1.2 Public Contracts, Advertisements
for Proposals for Purchases and
Contracts for Supplies or Services
for Government Departments;
Application to Government Sales
and Contracts to Sell and to
Government Corporations, as
amended, 41 U.S.C. §5 (1958).
1.3 Advances of Public Moneys,
Prohibition Against, as revised,
31 U.S.C. §529 (1946).
1.4 Contracts: Acquisition, Construc-
tion or Furnishing of Test Facilities
and Equipment, as amended, 10
U.S.C. §2353 (1956).
1.5 Record on Review and Enforcement
of Agency Orders, as amended,
28 U.S.C. §2112 (1966).
1.6 Disclosure of Confidential Informa-
tion Generally, as amended, 18
U.S.C. §1905
1.7 Per Diem, Travel and Transporta-
tion Expenses; Experts and Con-
sultants; Individuals Serving With-
out Pay, as amended, 5 U.S.C.
§5703 (1969).
1.8 Highway Safety Act of 1966, as
amended, 23 U.S.C. §402 (1970).
1.9 Federal Salary Act, as amended,
5 U.S.C. §§5305, 5332 (1970).
1.10 The Federal Aviation Act of 1958,
as amended, 49 U.S.C. §1301 et seq.
(1970).
1.11 Department of Transportation Act,
as amended, 49 U.S.C. §1651
et seq. (1968).
1.12 The National Environmental Policy
Act of 1969, 42 U.S.C. §4332(2) (c)
(1970).
1.13 The Public Health Service Act,
as amended, 42 U.S.C. §§241, 243,
246 (1970).
1.14 The Davis-Bacon Act, as amended,
40 U.S.C. §§276a-276a-5 (1964).
1.15 Reorganization Plan No. 14 of
1950, 64 Stat. 1267 (1950).
Directly transferred to EPA in Reorg.
Plan No. 3 of 1970.
Referred to in the Clean Air Act at
§1857b-l(a)(2)(D).
Referred to in the Clean Air Act at
§1857b-l(a)(2)(D).
Referred to in the Clean Air Act at
§1857b-(a)(2)(D).
Referred to in the Clean Air Act at
§§1857c-5(f)(2)(B), 1857f-5(b)(2)(B)(ii).
Referred to in the Clean Air Act at
§§1857c-9(e), 1857d(j)(l), 1857f-6(b),
1857h-5(a)(l).
Referred to in the Clean Air Act at
§§1857d(i), 1857e(e), 1857f-6e(b)(2).
Referred to in the Clean Air Act at
§1857f-6b(2).
Referred to in the Clean Air Act at
§1857f-6e(b)(3)(A).
Referred to in the Clean Air Act at
§§1857f-10(a), (b), 1857f-12.
Referred to in the Clean Air Act at
§1857f-10(b).
Referred to in the Clean Air Act at
§1857h-7(a).
Referred to in the Clean Air Act at
§1857i(b).
Referred to in the Clean Air Act at
§1857j-3.
Referred to in the Clean Air Act at
§1857j-3.
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INSTRUCTIONS
1.16 Regulations Governing Contractors
and Subcontractors, as amended,
40 U.S.C. §276c (1958).
1.17 Federal Aid Highway Act, as
amended, 23 U.S.C. §109(h), (j)
(1970).
1.18 Airport and Airway Development
Act, as amended, 49 U.S.C.
§§1712(f), 1716(c)(4), (e)(1970).
1.19 Amortization of Pollution Control
Facilities, as amended, 26 U.S.C.
§169(d)(l)(B), (3) (1969).
1.20 Interest on Certain Government
Obligations, as amended, 26 U.S.C.
§103 (1969).
Referred to in the Clean Air Act at
§1857j-3.
Direct reference in Act to EPA and air
pollution at §109(h), (i), (j).
Direct reference in Act to air pollution
at §§1712(f), 1716(e)(l).
§169d(l)(B) makes direct reference to
the Clean Air Act.
At §103 (c) (4) (F) industrial development
bonds are exempt from taxes on air
pollution control facilities.
Executive Orbers
The Executive Orders are listed by a two-point system (2.1, 2.2,
etc.). Executive Orders found in General are ones applying to more
than one area of the pollution chapters.
Regulations
The Regulations are noted by a three-point system (3.1, 3.2, etc.).
Included in the Regulations are those not only promulgated by the
Environmental Protection Agency, but those under which the Agency
has direct contact.
Guidelines and Reports
This subchapter is noted by a four-point system (4.1, 4.2, etc.). In
this subchapter is found the statutorily required reports of EPA,
published guidelines of EPA, selected reports other than EPA's and
inter-departmental agreements of note.
UPDATING
Periodically, a supplement will be sent to the interagency dis-
tribution and made available through the U.S. Government Printing
Office in order to provide an accurate working set of EPA Legal
Compilation.
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CONTENTS
B. Air
VOLUME I
Page
1. STATUTES AND LEGISLATIVE HISTORY
1.1 Clean Air Act, as amended, 42 U.S.C. §1857 et seq. (1970) 1
l.la Air Pollution Act of July 14, 1955, P.L. 84-159, 69 Stat.
322 ." 81
(1) Senate Committee on Public Works, S. REP. No.
389, 84th Cong., 1st Sess. (1955) 83
(2) House Committee on Interstate and Foreign Com-
merce, H.R. REP. No. 968, 84th Cong., 1st Sess.
(1955) 93
(3) Congressional Record, Vol. 101 (1955):
(a) May 31: Amended and passed Senate, pp.
7248-7250 104
(b) July 5: Amended and passed House, pp. 9923-
9925 106
(c) July 6: Senate concurs in House amendment,
pp. 9984-9985 110
l.lb Extension of §5-a of Air Pollution Act of July 14, 1955,
September 22, 1959, P.L. 86-365, 73 Stat. 646 114
(1) House Committee on Interstate and Foreign Com-
merce, H.R. REP. No. 960, 86th Cong., 1st Sess.
(1959) 115
(2) Senate Committee on Public Works, S. REP. No.
182, 86th Cong., 1st Sess. (1959) 123
(3) Committee of Conference, H.R. REP. No. 1187,
86th Cong., 1st Sess. (1959) 136
(4) Congressional Record, Vol. 105 (1959):
(a) Sept. 1: Passed House, pp. 17584-17586 140
(b) Sept. 9: Amended and passed Senate, pp.
18733-18734 144
(c) Sept. 10, 11: House and Senate ask for con-
ference, pp. 18997, 19046 146
(d) Sept. 14: House and Senate agree to conference
report, pp. 19704-19705, 19434-19435 146
l.lc Motor Vehicle Exhaust Study Act of June 8, I960,
P.L. 86-493, 74 Stat. 1625 153
(1) House Committee on Interstate and Foreign Com-
merce, H.R. REP. No. 814, 86th Cong., 1st Sess-
(1959) 154
(2) Senate Committee on Labor and Public Welfare.-
S. REF. No. 1410, 86th Cong., 2d Sess (1960) 171
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xii CONTENTS
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(3) Congressional Record:
(a) Vol. 105 (1959), Aug. 17: Passed House, pp.
16074-16080 176
(b) Vol. 106 (1960), May 26: Passed Senate, p.
11209 191
l.ld Amendment of Act of July 14, 1955, October 9, 1962,
P.L. 87-761, 76 Stat. 760 192
(1) Senate Committee on Public Works, S. REP. No.
1083, 87th Cong., 1st Sess. (1961) 193
(2) House Committee on Interstate and Foreign Com-
merce, H.R. REP. No. 2265, 87th Cong., 2d Sess.
(1962) 199
(3) Congressional Record:
(a) Vol. 107 (1961), Sept. 20: Passed Senate, pp.
20417-20418 220
(b) Vol. 108 (1962), Sept. 17: Amended and passed
House, pp. 19658-19661 223
(c) Vol. 108 (1962), Sept. 26: Senate concurs in
House amendments, pp. 20802-20803 232
l.le The Clean Air Act, December 17, 1963, P.L. 88-206,
77 Stat. 392 235
(1) House Committee on Interstate and Foreign Com-
merce, H.R. REP. No. 508, 88th Cong., 1st Sess.
(1963) 247
(2) Senate Committee on Public Works, S. REP. No.
638, 88th Cong., 1st Sess. (1963) 277
(3) Committee of Conference, H.R. REP. No. 1003,
88th Cong., 1st Sess. (1963) 295
(4) Congressional Record, Vol. 109 (1963):
(a) July 24: Considered and passed House, pp.
13273-13281; 13283-13285 305
(b) Nov. 19: Considered and passed Senate,
amended, pp. 22321-22326; 22329-22331 328
(c) Dec. 10: House and Senate agree to conference
report, pp. 23954; 23959-23966; 21083-21085.. 344
l.lf Motor Vehicle Air Pollution Control Act, and Solid
Waste Disposal Act, October 20, 1955, P.L. 89-272,
79 Stat. 992 364
(1) Senate Committee on Public Works, S. REP. No.
192, 89th Cong., 1st Sess. (1965) 377
(2) House Committee on Interstate and Foreign Com-
merce, H.R. REP. No. 899, 89th Cong., 1st Sess.
(1965) 410
(3) Congressional Record, Vol. Ill (1965):
(a) May 18: Considered and passed Senate, pp.
10779; 10782-10783 431
(b) Sept. 23: Considered in House, pp. 24941-
24943 434
(c) Sept. 24: Considered and passed House,
amended, pp. 25049-25059; 25061-25065;
25072 436
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CONTENTS xiii
Page
(d) Oct. 1: Senate concurred in House amendments,
pp. 25847; 25850-25851 471
l.lg Clean Air Amendments of 1966, October 15, 1966, P.L.
89-675,80 Stat. 954 473
(1) Senate Committee on Public Works, S. REP. No,
1361, 89th Cong., 2d Sess. (1966) 475
(2) House Committee on Interstate and Foreign Com-
merce. H.R. REP. No. 2170, 89th Cong., 2d Sess,
(1966) 493
(3) Committee of Conference, H.R. REP. No. 2256,
89th Cong., 2d Sess. (1966) 514
(4) Congressional Record, Vol. 112 (1966):
(a) July 11: Considered in Senate, p. 15169 517
(b) July 12: Considered and passed Senate, pp.
15248-15262 518
(c) Oct. 3: Considered and passed House, amended.
pp. 24853-24855 549
(d) Oct. 13: House agreed to conference report, p
26596 555
(e) Oct. 14: Senate agreed to conference report,
p. 26808-26809 557
l.lh Air Quality Act of 1967, November 21, 1967, P.L.
90-148, 81 Stat. 485 560
VOLUME II
(1) Senate Committee on Public Works, S. REP. No.
403, 90th Cong., 1st Sess. (1967) 593
(2) House Committee on Interstate and Foreign Com-
merce, H.R. REP. No. 728, 90th Cong., 1st Sess.
(1967) 703
(3) Committee of Conference, H.R. REP. No. 916,
90th Cong., 1st Sess. (1967) 834
(4) Congressional Record, Vol. 113 (1967):
(a) July 18: Considered and passed Senate, pp.
19164, 19171-19186 839
(b) Nov. 2: Considered and passed House, amended,
pp. 30939-30963; 30975-30981; 30988-30989;
30999 872
(c) Nov. 9: Senate rejected House amendments,
pp. 32072-32073; 32079 965
(d) Nov. 13: House insisted on amendments and
agreed to conference, p. 32213 965
(e) Nov. 14: Senate and House adopted conference
report, pp. 32475-32479 966
l.li Authorization for Fuel and Vehicle Research, 1969.
Decembei 5, 1969, P.L. 91-137, 83 Stat. 283 97S
(1) Senate Committee on Public Works, S. REP. No,
91-286. 91st Cong., Isl Sess. (1969) 973
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(2) House Committee on Interstate and Foreign Com-
merce, H.R. REP. No. 91-349, 91st Cong., 1st Sess.
(1969) 990
(3) Committee of Conference, H.R. REP. No. 91-690,
91st Cong., 1st Sess. (1969) 997
(4) Congressional Record, Vol. 115 (1969):
(a) July 8: Considered and passed Senate, pp.
18540-18541; 18544 1000
(b) Sept. 3, 4: Considered and passed House,
amended, pp. 24005-24006; 24356-24372;
24374-24378 1003
(c) Nov. 25: House and Senate agreed to conference
report, pp. 35640; 35805-35807 1050
l.lj Extension of Clean Air Act, July 10, 1970, P.L. 91-316,
84Stat. 416 1054
(1) Senate Committee on Public Works, S. REP. No.
91-941, 91st Cong., 2d Sess. (1970) 1054
(2) Congressional Record, Vol. 116 (1970):
(a) June 25: Considered and passed Senate, pp.
21363-21364 1056
(b) June 30: Considered and passed House, p.
22095 1056
l.lk Clean Air Amendments of 1970, December 31, 1970,
P.L. 91-604, 84 Stat. 1676 1057
(1) House Committee on Interstate and Foreign Com-
merce, H.R. REP. No. 91-1146, 91st Cong., 2d Sess.
(1970) 1115
VOLUME III
(2) Senate Committee on Public Works, S. REP. No.
91-1196, 91st Cong., 2d Sess. (1970) 1189
(3) Committee of Conference, H.R. REP. No. 91-1783,
91st Cong., 2d Sess. (1970) 1367
(4) Congressional Record, Vol. 116 (1970):
(a) June 10: Considered and passed House, pp.
19200-19244 1391
(b) Sept. 21, 22: Considered and passed Senate,
amended, pp. 32837; 32900-32928; 33072-
33121 1493
(c) Dec. 18: Senate and House agreed to conference
report, pp. 42381-42395; 42519-42524 1672
(5) The President's Remarks Upon Signing the Bill into
Law, Dec. 31, 1970, Weekly Compilation of Presi-
dential Documents, Vol. 6, No. 1, January 4, 1971
(p. 11) 1717
1.11 Technical Amendments to the Clean Air Act, November
18, 1971, P.L. 92-157, §302, 85 Stat. 464 1719
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CONTENTS xv
Page
(1) House Committee on Interstate and Foreign Com-
merce, H.R. REP. No. 92-258, 92d Cong., 1st Sess.
(1971) 1720
(2) Senate Committee on Labor and Public Welfare
S. REP. No. 92-251, 92d Cong., 1st Sess. (1971) 172C
(3) Committee of Conference, H.R. REP. No. 92-578,
92dCong., 1st Sess. (1971) 172C
(4) Congressional Record, Vol. 117 (1971):
(a) July 1: Considered and passed House; * 1721
(b) July 14: Considered and passed Senate, amended
in lieu of S. 934; * 1721
(c) Oct. 19: Senate agreed to conference report; *__ 1721
(d) Nov. 9: House agreed to conference report. *__ 1721
1.2 Public Contracts, Advertisements for Proposals for Purchases
and Contracts for Supplies or Supplies for Government Depart-
ments; Application to Government Sales and Contracts to Sell
and to Government Corporations, as amended, 41 U.S.C. §5
(1958). [Referred to in 42 U.S.C. §1857b-l(a)(2)(D)]. (See,
"General 1.14" for legislative history). 1721
1.3 Advances of Public Moneys, Prohibition Against, as revised,
31 U.S.C. §529 (1946). [Referred to in 42 U.S.C. §1857b-
l(a)(2)(D) 1722
1.3a Advances of Public Moneys; Prohibition Against, August
2, 1946, R.S. §3648, §11, 60 Stat. 809 1722
1.3b E.G. 10410, Specification of Laws From Which the
Escapee Program Administered by the Department ot
State Shall be Exempt, November 14, 1952, 17 Fed.
Reg. 10495 1723
1.3c E.O. 11223, Relating to the Performance of Functions
Authorized by the Foreign Assistance Act of 1961,
May 12, 1965, 30 Fed. Reg. 6635 1723
1.4 Contracts: Acquisition, Construction or Furnishing of Test
Facilities and Equipment, as amended, 10 U.S.C. §2353 (1956).
[Referred to in 42 U.S.C. §1857b-l(a)(2)(D)] 1726
1.4a Act of July 16, 1952, P.L. 82-557, 66 Stat. 725 1726
(1) House Committee on Armed Services, H.R. REP.
No. 548, 82d Cong., 1st Sess. (1951) 1730
(2) Senate Committee on Armed Services, S. REP. No.
936, 82dCong., 1st Sess. (1951) 1743
(3) Congressional Record:
(a) Vol. 97 (1951), Oct. 19: Objected to in Senate,
p. 13530 1755
(b) Vol. 98 (1952), July 3: Passed Senate, pp.
9053-9054 1756
(e) Vol. 98 (1952), July 4: Passed House, pp.
9374-9375 1757
1.4b An Act to Revise, Codify and Enact Into Law Title X
of the United States Code, August 10, 1956, §2353,
70A Stat. 149 1759
(1) House Committee on the Judiciary, H.R. REP. No.
970, 84th Cong., 1st Sess. (1955) 1760
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xvi CONTENTS
Pages
(2) Senate Committee on the Judiciary, S. REP. No.
2484, 84th Cong., 2d Sess. (1956) 1761
(3) Congressional Record:
(a) Vol. 101 (1955), Aug. 1: Amended and passed
House, p. 12719 1762
(b) Vol. 102 (1956), July 23: Amended and passed
Senate, p. 13953 1762
(c) Vol. 102 (1956), July 25: House concurs in
Senate amendment, p. 14455 1762
1.5 Record on Review and Enforcement of Agency Orders, as
amended, 28 U.S.C. §2112 (1966). [Referred to in 42 U.S.C.
§§1857c-5(f)(2)(B), 1857f-5(b)(2)(B)(ii)]__ 1763
1.5a Record on Review and Enforcement of Agency Orders,
August 28, 1958, P.L. 85-791, §2, 72 Stat. 941 1765
(1) House Committee on the Judiciary, H.R. REP. No.
842, 85th Cong., 1st Sess. (1957) 1768
VOLUME IV
(2) Senate Committee on the Judiciary, S. REP. No.
2129, 85th Cong., 2d Sess. (1958) 1777
(3) Congressional Record:
(a) Vol. 103 (1957), Aug. 5: Amended and passed
House, pp. 13617-13618 1802
(b) Vol. 104 (1958), Aug. 14: Passed Senate, p.
17537 1804
1.5b Rules of Civil Procedure, November 6, 1966, P.L.
89-773, §5(a), (b), 80 Stat. 1323 1804
(1) Senate Committee on the Judiciary, S. REP. No.
1406, 89th Cong., 2d Sess. (1966) 1805
(2) House Committee on the Judiciary, H.R. REP. No.
2153, 89th Cong., 2d Sess. (1966) 1814
(3) Congressional Record, Vol. 112 (1966):
(a) July 27: Passed Senate, p. 17306 1824
(b) Oct. 20: Passed House, p. 28141 1825
1.6 Disclosure of Confidential Information Generally, as amended,
18 U.S.C. §1905 (1948). [Referred to in 42 U.S.C. §§1857c-9(c),
1857d(j)(l), 1857f-6(b), 1857h-5(a)(l)]. (See, "General 1.16a-
1.16a(3)(d)" for legislative history) 1828
1.7 Per Diem, Travel, and Transportation Expenses; Experts and
Consultants; Individuals Serving Without Pay, as amended,
5 U.S.C. §5703 (1969). [Referred to in 42 U.S.C. §§1857(d)(i),
1857e(e), 1857f-6e(b)(2)]. (See, "General 1.15a-1.15b(3)(c)"
for legislative history). 1828
1.8 Highway Safety Act of 1966, as amended, 23 U.S.C. §402
(1970). [Referred to in 42 U.S.C. §1857f-6b(2)] 1829
1.8a Highway Safety Act of 1966, September 9, 1966, P.L.
89-564, Title I, §101, 80 Stat. 731 1832
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CONTENTS xvii
Page
(1) Senate Committee on Public Works, S. REP. No.
1302, 89th Cong., 2d Sess. (1966) 1838
(2) House Committee on Public Works, H.R. REP.
No. 1700, 89th Cong., 2d Sess. (1966) 1861
(3) Committee of Conference, H.R. REP. No. 1920,
89th Cong., 2d Sees. (1966) 1885
(4) Congressional Record, Vol. 112 (1966):
(a) June 27: Amended and passed Senate, pp.
14936-14938 1898
(b) Aug. 18: Amended and passed House, pp.
19926-19939; 19940-19944 1898
(c) Aug. 31: House agrees to conference report, pp.
21355-21358 1937
(d) Sept. 1: Senate agrees to conference report, p.
21595-21596 1944
1.8b Highway Safety Program, August 23, 1968, P.L. 90-495,
§13, 82 Stat. 822 1946
(1) Senate Committee on Public Works, S. REP. No.
1340, 90th Cong., 2d Sess. (1968) 1946
(2) House Committee on Public Works, H.R. REP. No.
1584, 90th Cong., 2d Sess. (1968) 1950
(3) Committee of Conference, H.R. REP. No. 1799,
90th Cong., 2d Sess. (1968) 1952
(4) Congressional Record, Vol. 114 (1968):
(a) July 1: Amended and passed Senate, p. 19552 1952
(b) July 3: Amended and passed House, p. 19950-- 1952
(c) July 26: House agrees to conference report, p.
23713 1952
(d) July 29: Senate agrees to conference report,
p. 24038 1952
1.8c Federal Aid Highway Act of 1970, December 31, 1970,
P.L. 91-605, Title II, §§202(c)-(e), 84 Stat. 1740, 1741__ 1953
(1) House Committee on Public Works, H.R. REP.
No. 91-1554, 91st Cong., 2d Sess. (1970) 1954
(2) Senate Committee on Public Works, S. REP. No.
91-1254, 91st Cong., 2d Sess. (1970) 1962
(3) Committee of Conference, H.R. REP. No. 91-1780,
91st Cong., 2d Sess. (1970) 1970
(4) Congressional Record, Vol. 116 (1970):
(a) Dec. 7 Considered and passed House, p. 40096_ _ 1971
(b) Dec. 7: Amended and passed Senate, p. 40095-_ 1971
(c) Dec. 18: House agrees to conference report,
pp. 42514-42523 1972
(d) Dec. 19: Senate agrees to conference report,
pp. 42714-42723 1979
1.9 Federal Salary Act, as amended, 5 U.S.C. §§5305, 5332 (1970).
[Referred to in 42 U.S.C. §1857f-6e(b)(3)(A)] 2002
1.9a General Schedule, September 6, 1966, P.L. 89-554,
80 Stat. 467 2007
(1) House Committee on the Judiciary, H.R. REP. No.
901, 89th Cong., 1st Sess. (1965) 2008
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xviii CONTENTS
Page
(2) Senate Committee on the Judiciary, S. REP. No.
1380, 89th Cong., 2d Sess. (1966) 2010
(3) Congressional Record:
(a) Vol. Ill (1965), Sept. 7: Passed House, p.
22954 2012
(b) Vol. 112 (1966), July 25, 27: Amended and
passed Senate, pp. 17010 2012
(c) Vol. 112 (1966), Sept. 11: House concurred in
Senate amendments, p. 19077 2014
1.9b Registers, Individuals Receiving Compensation;
September 11, 1967, P.L. 90-83, §1(18), 81 Stat. 199 2014
(1) House Committee on the Judiciary, H.R. REP. No.
124, 90th Cong., 1st Sess. (1967) 2015
(2) Senate Committee on the Judiciary, S. REP. No.
482, 90th Cong., 1st Sess. (1967) 2015
(3) Congressional Record, Vol. 113 (1967):
(a) April 3: Amended and passed House, p. 8109 __ 2015
(b) Aug. 4: Amended and passed Senate, p. 21414 2016
(c) Aug. 24: House concurs in Senate amendments,
pp. 23904-23905 2016
1.9c Postal Revenue and Federal Salary Act of 1967, Decem-
ber 16, 1967, P.L. 90-206, Title II, §202(a), 81 Stat. 624_ 2016
(1) House Committee on Post Office and Civil Service,
H.R. REP. No. 722, 90th Cong., 1st Sess. (1967) 2016
(2) Senate Committee on Post Office and Civil Service,
S. REP. No. 801, 90th Cong., 1st Sess. (1967) 2025
(3) Committee of Conference, H.R. REP. No. 1013;
90th Cong., 1st Sess. (1967) 202?
(4) Congressional Record, Vol. 113 (1967):
(a) Oct. 10, 11: Amended and passed House, pp.
28410, 28412, 28648-28649, 28655 2030
(b) Nov. 28, 29: Amended and passed Senate, pp.
33975, 34013-34014, 34227-34228, 34261 2037
(c) Dec. 11: House recedes from its disagreement to
the Senate amendment, and concurs therein,
with an amendment, p. 35842 2044
(d) Dec. 12: Senate concurs in House amendment to
Senate amendment, pp. 36104 2044
1.9d E.G. 11413, Adjustment of Pay Rates Effective July 1,
1969, June 11, 1968, 33 Fed. Reg. 8641 2047
1.9e E.G. 11474, Adjustment of Pay Rates Effective July 1,
1969, June 16, 1969, 34 Fed. Reg. 9605 2050
1.9f E.G. 11524, Adjustment of Pay Rates Effective First Pay
Period on or After December 27, 1969, April 15, 1970.
35 Fed. Reg. 6247 2053
1.9g E.O. 11576, Adjustment of Pay Rates Effective January
1, 1971, January 8, 1971, 36 Fed. Reg. 347 2056
1.9h E.O. 11587, Federal Executive Salary Schedule, March
15,1971 36 Fed. Reg. 4973 2059
1.10 The Federal Aviation Act of 1958, as amended, 49 U.S.C.
§1301 et seq. (1970). [Referred to in 42 U.S.C. §§1857f-10(a),
(b). 1857f-12] 2060
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CONTENTS xix
Page
l.lOa The Federal Aviation Act of 1958, August 23, 1958,
P.L. 85-726, §§101-701, 72 Stat. 731 2132
(1) Senate Committee on Interstate and Foreign Com-
merce, S. REP. No. 1811, 85th Cong., 2d Sess.
(1958) 2153
(2) House Committee on Interstate and Foreign Com-
merce, H.R. REP. No. 2360, 85th Cong., 2d Sess.
(1958) 2161
(3) Committee of Conference, H.R. REP. No. 2556,
85th Cong., 2d Sess. (1958) 2163
(4) Congressional Record, Vol. 104 (1958):
(a) July 14: Amended and passed Senate, pp.
13621-13636, 13645-13650 2164
(b) Aug. 4: Amended and passed House, p. 16088_. 2179
(c) Aug. 11: Senate agrees to conference report,
p. 16887 2179
(d) Aug. 13: House agrees to conference report,
p. 17457 2179
l.lOb Occupational Safety and Health Act of 1970, December
29, 1970, P.L. 91-596, §31, 84 Stat. 1619 2179
(1) Senate Committee on Labor and Public Welfare,
S. REP. No. 91-1282, 91st Cong., 2d Sess. (1970)._. 2180
(2) House Committee on Education and Labor, H.R.
REP. No. 91-1291, 91st Cong., 2d Sess. (1970) 2181
(3) Committee of Conference, H.R. REP. No. 91-1765,
91st Cong., 2d Sess. (1970) 2182
(4) Congressional Record, Vol. 116 (1970):
(a) Nov. 17: Amended and passed Senate, p.
37632 2183
(b) Nov. 24: Amended and passed House, p.
H10711 2183
(c) Dec. 16: Senate agrees to conference report, p.
41764 2183
(d) Dec. 17: House agrees to conference report, p.
42209 2183
l.lOc Clean Air Amendments of 1970, December 31, 1970,
P.L. 91-604, §ll(b)(l), 84 Stat. 1705 2183
(1) House Committee on Interstate and Foreign Com-
merce, H.R. REP. No. 91-1146, 91st Cong., 2d Sess.
(1970) 2184
(2) Senate Committee on Public Wcrks, S. REP. No.
91-1196, 91st Cong., 2d Sess. (1970) 2186
(3) Committee of Conference, H.R. REP. No. 91-1783,
91st Cong., 2d Sess. (1970) 2190
(4) Congressional Record, Vol. 116 (1970):
(a) June 10: Considered and passed House, p. 19228. 2192
(b) Sept. 22: Considered and passed Senate,
amended, p. 33105 2192
(c) Dec. 18: Senate agrees to conference report,
p. 42391 2192
(d) Dec. 18: House agrees to conference report,
p. 42519 2193
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xx CONTENTS
Page
l.lOd Amendments to the Fish and Wildlife Act of 1956,
November 18,1971, P.L. 92-159, §2a, 85 Stat. 481 2193
(1) House Committee on Merchant Marine and Fish-
eries, H.R. REP. No. 92-202, 92d Cong., 1st Sess.
(1971) 2194
(2) Senate Committee on Commerce, S. REP. No.
92-421, 92d Cong., 1st Sess. (1971) 2195
(3) Congressional Record, Vol. 117 (1971):
(a) May 17: Considered and passed House, pp.
H3973-H3977 2196
(b) Nov. 4: Considered and passed Senate, amended,
p. 517630* 2196
(c) Nov. 5: House concurred in Senate amendments,
p. H10550* 2196
l.lOe Airport and Airway Programs, November 27, 1971,
P.L. 92-174, §§5(b), 6, 85 Stat. 492 2197
(1) House Committee on Interstate and Foreign Com-
merce, H.R. REP. No. 92-459, 92d Cong., 1st Sess.
(1971) 2197
(2) Senate Committee on Commerce, S. REP. No.
92-378, 92d Cong., 1st Sess. (1971) 2197
(3) Senate Committee on Commerce, S. REP. No.
92-394, 92d Cong., 1st Sess. (1971) 2198
(4) Committee of Conference, H.R. REP. No. 92-624,
92d Cong., 1st Sess. (1971) 2198
(5) Congressional Record, Vol. 117 (1971):
(a) Sept. 22: Considered and passed House* 2198
(b) Oct. 12: Considered and passed Senate,
amended* 2198
(c) Nov. 8: Senate agreed to conference report* 2198
(d) Nov. 16: House agreed to conference report*-- 2198
l.lOf Noise Control Act of 1972, October 27,1972, P.L. 92-574,
86 Stat. 1234 2198
(1) House Committee on Interstate and Foreign Com-
merce, H.R. REP. No. 92-842, 92d Cong., 2d Sess.
(1972) 2202
(2) Senate Committee on Public Works, S. REP. No.
92-1160, 92d Cong., 2d Sess. (1972) 2207
(3) Congressional Record, Vol. 118 (1972):
(a) Feb. 29: Considered and passed House, pp.
H1508-H1539 2250
(b) Oct. 12: Considered in Senate, pp. S17743-
S17764, S17774-S17785 2278
(c) Oct. 13: Considered and passed Senate,
amended, pp. S17988-S18014 2305
(d) Oct. 18: House concurred in Senate amendment.
with an amendment, pp. H10261-H10262,
H10287-H10300 2327
(e) Oct. 18: Senate concurred in House amendment
pp. S18638-S18646 2330
1.11 Department of Transportation Act, as amended, 48 U.S.C.
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CONTENTS xxi
Page
§1651 et seq. (1968). [Referred to in 42 U.S.C. §1857f-10b].
(See, "General 1.5a-1.5c(3)(d)" for legislative history) 2334
1.12 National Environmental Policy Act of 1969, 42 U.S.C.
§4332(2)(c) (1970). [Referred to in 42 U.S.C. §1857h-7(a)].
(See, "General 1.2a-1.2a(4)(e)" for legislative history) 2334
1.13 Public Health Service Act, as amended, 42 U.S.C. §§241, 243,
246 (1970). [Referred to in 42 U.S.C. §1857i(b)]. (See, "General
1.12a-1.12ae" for legislative history) 2335
1.14 The Davis-Bacon Act, as amended, 40 U.S.C. §§276a-276a-5
(1964). [Referred to in 42 U.S.C. §1857j-3]. (See, "General
1.13a-1.13h" for legislative history) 2353
1.15 Reorganization Plan No. 14 of 1950, 64 Stat. 1267 (1950).
[Referred to in 42 U.S.C. §1857j-3] 2357
1.16 Regulations Governing Contractors and Subcontractors, as
amended, 40 U.S.C. §276c (1958). [Referred to in 42 U.S.C.
§1857j-3] 2357
1.16a Secretaries of Treasury and Labor Shall Make Regula-
tions for Contractors and Subcontractors, June 13, 1934,
P.L. 73-324, §2, 48 Stat. 948 2358
(1) Senate Committee on the Judiciary, S. REP. No.
803, 73rd Cong., 2d Sess. (1934) 2358
(2) House Committee on the Judiciary, H.R. REP. No.
1750, 73rd Cong., 2d Sess. (1934) 2359
(3) Congressional Record, Vol. 78 (1934):
(a) April 26: Passed Senate, p. 7401 2360
(b) June 7: Passed House, p. 10759 2360
1.16b Amendments to Act of June 13, 1934, May 24, 1949, P.L.
81-72, §134, 63 Stat. 108 2360
(1) House Committee on the Judiciary, H.R. REP. No.
352, 81st Cong., 1st Sess. (1949) 2361
(2) Senate Committee on the Judiciary, S. REP. No.
303, 81st Cong., 1st Sess. (1949) 2362
(3) Congressional Record, Vol. 95 (1949):
(a) April 4: Passed House, p. 3819 2364
(b) May 6: Passed Senate, p. 5827 2365
1.16c Amendment of 1958, August 28, 1958, P.L. 85-800, §12,
72 Stat. 967 2365
(1) Senate Committee on Government Operations, S.
REP. No. 2201, 85th Cong., 2d Sess. (1958) 2365
(2) Congressional Record, Vol. 114 (1958): 2368
(a) Aug. 14: Passed Senate, p. 17539
(b) Aug. 15: Passed House, p. 17909 2368
VOLUME V
1.17 Federal Aid Highway Act, as amended, 23 U.S.C. §109(h), (j)
(1970). (See, "General 1.6a-1.6d(4)(f)" for legislative history). 2369
1.18 Airport and Airway Development Act of 1970, as amended,
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xxii CONTENTS
Page
49 U.S.C. §§1712(f), 1716(c)(4), (e) (1970). (See, "General
1.7a-1.7a(4) (d)" for legislative history) 2369
1.19 Amortization of Pollution Control Facilities, as amended,
26 U.S.C. §169 (1969). (See, "General 1.4a-1.4a(5)(c)" for
legislative history) 2369
1.20 Interest on Certain Government Obligations, Int. Rev. Code
of 1954, as amended, §103, 26 U.S.C. §103 (1969). (See,
"General 1.9a-1.9d(4)(d)" for legislative history) 2369
1.21 Motor Vehicle Information and Cost Savings Act, 15 U.S.C.
§§1961-1964 2369
1.2 la Motor Vehicle Information and Cost Saving Act, October
20, 1972, P.L. 92-513, Title III, §301(b)(2), 302(b)(l),
86Stat. 960 2372
(1) Senate Committee on Commerce, S. REP. No. 92-
413, 92d Cong., 1st Sess. (1971) 2375
(2) House Committee on Interstate and Foreign Com-
merce, H.R. REP. No. 92-1033, 92d Cong., 2d Sess,
(1972) 2375
(3) Committee of Conference, H.R. REP. No. 92-1476,
92d Cong., 2d Sess. (1972) 2375
(4) Congressional Record:
(a) Vol. 117 (1971), Nov. 3: Considered and passed
Senate, p. S17570-S17575, S17578-S17591* 2376
(b) Vol. 118 (1972), May 22: Considered and passed
House, amended in lieu of H.R. 11627, p.
H4754-H4755, H4774-H4793* 2376
(c) Vol. 118 (1972), Oct. 4: House agreed to con-
ference report, p. H9138-H9139* 2376
(d) Vol. 118 (1972), Oct. 6: Senate agreed to con-
ference report, p. S17175-S17176* 2376
2. EXECUTIVE ORDERS
2.1 E.O. 11282, Prevention, Control and Abatement of Air Pollu-
tion by Federal Authorities, May 28, 1966, 31 Fed. Reg.
7663 (1966) 2379
2.2 E.O. 11507, Prevention, Control and Abatement of Air and
Water Pollution at Federal Facilities, February 5,1970, 35 Fed.
Reg. 3573 (1970) 2382
2.3 E.O. 11523, National Industrial Pollution Control Council,
April 9, 1970, 35 Fed. Reg. 5993 (1970) 2388
2.4 E.O. 11587, Placing Certain Positions in Levels IV and V of the
Federal Executive Salary Schedule, March 15, 1971, 35 Fed.
Reg. 475 (1971) 2389
2.5 E.O. 11602, Providing for Administration of the Clean Air Act
with Respect to Federal Contracts, Grants, or Loans, June 29,
1971, 36 Fed. Reg. 12475 (1971) 2390
3. REGULATIONS 2395
3.1 Entry of Motor Vehicles and Motor Vehicle Engines Under
Vehicle Air Pollution Control Act, Bureau of Customs, 19
C.F.R. §12.73 (1972)
3.2 Grants for Air Pollution Control Programs, Environmental
Protection Agency, 42 C.F.R. §§456.1-456.45 (1971) __
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CONTENTS xxiii
Page
3.3 National Primary and Secondary Ambient Air Quality Stand-
ards Environmental Protection Agency, 40 C.F.R. §§50.1-
50.11 (1971)
3.4 Requirements for Preparation, Adoption, and Submittal of
Implementation Plans, Environmental Protection Agency,
40 C.F.R. §§51.1-51.32 (1971)
3.5 Approval and Promulgation of Implementation Plans, Environ-
mental Protection Agency, 40 C.F.R. §52 (1972)
3.6 Standards of Performance for New Stationary Sources, En-
vironmental Protection Agency, 40 C.F.R. §§60.1-60.85
(1971)
3.7 Prior Notion of Citizen Suits, Environmental Protection
Agency, 40 C.F.R. §§54.1-54.3 (1971)
3.8 Prevention, Control and Abatement of Air Pollution from
Federal Government Activities: Performance Standards and
Techniques of Measurement, Environmental Protection
Agency, 40 C.F.R. §§76.1-76.9 (1971)
3.9 Registration of Fuel Additives, Environmental Protection
Agency, 40 C.F.R. §§79.1-79.31 (1971)
3.10 Air Quality Control Regions, Criteria and Control Techniques,
Environmental Protection Agency, 40 C.F.R. §§81.1-81.114
(1971)
3.11 Control of Air Pollution from New Motor Vehicles and New
Motor Vehicle Engines, Environmental Protection Agency,
40 C.F.R. §§85.1-85.327 (1972)
4. GUIDELINES AND REPORTS
4.1 Environmental Protection Agency, Reports to Congress as
required by the Clean Air Act 2399
4.la "The Economics of Clean Air," Report to Congress by
the Administrator of the Environmental Protection
Agency, December 1970 2399
4.1b "Progress in the Prevention and Control of Air Pollu-
tion," Report to Congress by the Administrator of the
Environmental Protection Agency, January 1971 2561
4.1c "Development of Systems to Attain Established Motor
Vehicle and Engine Emission Standards," Report to
Congress by the Administrator of the Environmental
Protection Agency, September 1971 2587
4.Id "Progress in Prevention and Control of Air Pollution,"
Report to Congress by the Administrator of the En-
vironmental Protection Agency, February 1972 2626
4.2 Criteria and Control Techniques Summaries 2640
4.2a Criteria 2640
(1) "Criteria for Carbon Monoxide," National Air
Pollution Control Administration, March 1970 2640
(2) "Criteria for Hydrocarbons," National Air Pollution
Control Administration, March 1970 2651
(3) "Criteria for Particulate Matter," National Air
Pollution Control Administration, January 1969 2658
(4) "Criteria for Photochemical Oxidants," National
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xxiv CONTENTS
Page
Air Pollution Control Administration, January
1969'_ 2672
(5) "Criteria for Sulfur Oxides," National Air Pollution
Control Administration, January 1969 2690
(6) "Criteria for Nitrogen Oxides," Environmental
Protection Agency, January 1971 2707
4.2b Control Techniques 2725
(1) "Control Techniques for Carbon Monoxide from
Stationary Sources," National Air Pollution Control
Administration, March 1970 2725
(2) "Control Techniques for Carbon Monoxide, Nitro-
gen Oxide and Hydrocarbons from Mobile Sources,"
National Air Pollution Control Administration,
March 1970 2727
(3) "Control Techniques for Hydrocarbons and Organic
Solvents from Stationary Sources," National Air
Pollution Control Administration, March 1970 2732
(4) "Control Techniques for Nitrogen Oxides Emissions
from Stationary Sources," National Air Pollution
Control Administration, March 1970 2737
(5) "Control Techniques for Particulates," National Air
Pollution Control Administration, January 1969 2744
(6) "Control Techniques for Sulfur Oxides," National
Air Pollution Control Administration, January
1969 2753
4.3 Selected Reports 2759
4.3a Semiannual Report, Prepared by the Committee on
Motor Vehicle Emissions of the National Academy of
Sciences, January 1, 1972 2759
4.4 Interagency Agreements 2822
4.4a Interagency Agreement Between Environmental Pro-
tection Agency and Department of Transportation
National Highway Traffic Safety Administration 2822
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STATUTES AND LEGISLATIVE HISTORY 2369
1.17 FEDERAL AID HIGHWAY ACT, AS AMENDED
23 U.S.C. §109(h), (j) (1970)
(See "General 1.6-1.6d(4) (f)" for text and legislative history.)
1.18 AIRPORT AND AIRWAY DEVELOPMENT ACT OF
1970, AS AMENDED
49 U.S.C. §§1712(f), 1716(c)(4), (e) (1970)
(See "General 1.7-1.7d(4) (d)" for text and legislative history.)
1.19 AMORTIZATION OF POLLUTION CONTROL
FACILITIES, AS AMENDED
26 U.S.C. §169 (1969)
(See "General 1.4-1.4a(5) (c)" for text and legislative history.)
1.20 INTEREST ON CERTAIN GOVERNMENT
OBLIGATIONS, INT. REV. CODE OF 1954, AS AMENDED
26 U.S.C. §103 (1969)
(See "General 1.9-1.9d(4) (d)" for text and legislative history.)
1.21 MOTOR VEHICLE INFORMATION AND
COST SAVINGS ACT
15 U.S.C. §§1961-1964
SUBCHAPTER III.—DIAGNOSTIC INSPECTION
DEMONSTRATION PROJECTS
§ 1961. Powers of Secretary—Establishment of demonstration
projects; commencement of inspections
(a) The Secretary shall establish motor vehicle diagnostic
inspection demonstration projects, inspections under which shall
commence not later than January 1,1974.
Grants and technical assistance to States; consultations with
Administrator of Environmental Protection Agency
(b) To carry out the program under this subchapter, the Secre-
tary shall—
(1) make grants in accordance with subsection (e) of this
section and furnish technical assistance to States; and
(2) consult with the Administrator of the Environmental
Protection Agency.
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2370 LEGAL COMPILATION—AIE
Conduct or supervision by States of demonstration projects;
nonprofit performance of diagnostic inspection services;
limitations on demonstration projects
(c) (1) Any demonstration project under this subchapter
shall be conducted by, or under supervision ofs a State in accord
ance with the application of the State submitted under section
1963 of this title, and may provide for the performance of diag-
nostic inspection services either by public agencies or by private
organizations, but no person may perform diagnostic inspection
services for profit under any such program,
(2) Not less than five nor more than ten demonstration projects
may be assisted by the Secretary under this subchapter. No more
than 50 per centum of the projects so assisted may permit diag=
nostic inspection services to be performed under the project by
any person who also provides automobile repair services or who is
affiliated with, controls, is controlled by, or is under common con-
trol with, any person who provides automobile repair services.
Pub.L. 92-513, Title III, § 301, Oct. 20, 1972, 86 Stat. 959.
§ 1962. Eligibility of States for grants or other assistance;
determination by Secretary of requirements for demonstration
projects
(a) A State may be eligible for grants or other assistance under
this subchapter if the Secretary determines on the basis of an
application by such State that such State will undertake a motor
vehicle diagnostic inspection demonstration project which meets
the requirements of subsection (b) of this section.
(b) (1) A motor vehicle diagnostic inspection demonstration
project shall be designated, established, and operated to conduct
periodic safety inspections of motor vehicles pursuant to criteria
established by the Secretary by regulation and emission inspec-
tions pursuant to criteria established by the Secretary by regula-
tion in consultation with the Administrator of the Environmental
Protection Agency.
(2) Such project shall require an additional inspection of any
motor vehicle subject to the demonstration project (as determined
by the Secretary) —
(A) whenever the title to such motor vehicle is transferred
to another person unless the transfer is for the purpose of
resale; and
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STATUTES AND LEGISLATIVE HISTORY 2371
(B) whenever such motor vehicle sustains substantial dam-
age to any safety-related or emission-related system or sub-
system, as prescribed by the Secretary.
(3) To the greatest extent practicable, such inspections shall be
conducted so as to provide specific technical diagnoses of each
motor vehicle inspected in order to facilitate correction of any
component failing inspection.
(4) A demonstration project shall provide for reinspection of
vehicles which initially fail to meet the safety and emission stand-
ards established for the project after repair.
(5) Each project shall provide to the Secretary information and
data relating to the development of diagnostic testing equipment
designed to maximize the interchangeability and interface capabil-
ity of test equipment and vehicles, and information, and data
relating to the costs and benefits of such projects, including infor-
mation and data relating to vehicle-in-use standards, vehicle de-
signs which facilitate or hinder inspection and repair, the stand-
ardization of diagnostic systems and test equipment, the capability
of the motor vehicle repair industry to correct diagnosed deficien-
cies or malfunctions and the costs of such repairs, the relative
costs and benefits of the project, the efficiency of facility designs
employed, recommendations as to feasible reject levels which may
be employed, in any such project and such other information and
data as the Secretary may require.
Pub.L. 92-513, Title III, § 302, Oct. 20, 1972, 86 Stat. 960.
§ 1963. Application by State for grant or other assistance;
form, contents, and manner of application; limitation on amount
of grant; time period for availability of financial assistance for
inspection costs; retention of equipment by State, manner of
payments
(a) A grant or other assistance under this subchapter may be
obtained upon an application by a State at such time, in such
manner, and containing such information as the Secretary pre-
scribes, including information respecting categories of expendi-
tures by the State from financial assistance under this subchapter.
(b) Upon the approval of any such application, the Secretary
may make a grant to the State to pay each fiscal year an amount
not in excess of 90 per centum of those categories of expenditures
for establishing and operating its project which the Secretary
approves. Federal financial assistance under this subchapter shall
not be available with respect to costs of inspections carried out
after June 30, 1976, under such a project. Any equipment pur-
-------
2372 LEGAL COMPILATION—AIK
chased with Federal funds may be retained by a State for its
inspection activities following the demonstration project with the
approval of the Secretary. Payments under this subsection may be
made in advance, in installments, or by way of reimbursement.
Pub.L. 92-513, Title III, § 303, Oct. 20, 1972, 86 Stat. 961.
§ 1964, Authorization of appropriations
There is authorized to be appropriated to carry out this sub-
chapter $15,000,000 for the fiscal year ending June 30, 1973;
$25,000,000 for the fiscal year ending June 30, 1974; and
$35,000,000 for the fiscal year ending June 30, 1975. Not more
than 20 percent of the amount appropriated under this section for
any fiscal year may be granted for projects in any one State.
Pub.L. 92-513, Title III, § 304, Oct. 20, 1972, 86 Stat. 961.
1.21a MOTOR VEHICLE INFORMATION AND COST
SAVINGS ACT
October 20, 1972, P.L. 92-513, Title III, §§301-304, 86 Stat. 959
AN ACT
To promote competition among motor vehicle manufacturers in
the design and production of safe motor vehicles having greater
resistance to damage, and for other purposes.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled. That this Act
may be cited as the "Motor Vehicle Information and Cost Savings
Act".
TITLE III—DIAGNOSTIC INSPECTION DEMONSTRATION
PROJECTS
POWERS AND DUTIES
SEC. 301. (a) The Secretary shall establish motor vehicle diag-
nostic inspection demonstration projects, inspections under which
shal] commence not later than January 1, 1974.
(b) To carry out the program under this title, the Secretary
shall-
[p. 12]
(1) make grants in accordance with subsection (c) and
furnish technical assistance to States; and
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STATUTES AND LEGISLATIVE HISTORY 2373
(2) consult with the Administrator of the Environmental
Protection Agency.
(c) (1) Any demonstration project under this title shall be
conducted by, or under supervision of, a State in accordance with
the application of the State submitted under section 303, and may
provide for the performance of diagnostic inspection services ei-
ther by public agencies or by private organizations, but no person
may perform diagnostic inspection services for profit under any
such program.
(2) Not less than five nor more than ten demonstration projects
may be assisted by the Secretary under this title. No more than 50
per centum of the projects so assisted may permit diagnostic
inspection services to be performed under the project by any per-
son who also provides automobile repair services or who is affili-
ated with, controls, is controlled by, or is under common control
with, any person who provides automobile repair services.
ELIGIBILITY AND CRITERIA
SEC. 302. (a) A State may be eligible for grants or other assist-
ance under this title if the Secretary determines on the basis of an
application by such State that such State will undertake a motor
vehicle diagnostic inspection demonstration project which meets
the requirements of subsection (b) of this section.
(b) (1) A motor vehicle diagnostic inspection demonstration
project shall be designed, established, and operated to conduct
periodic safety inspections of motor vehicles pursuant to criteria
established by the Secretary by regulation and emission inspec-
tions pursuant to criteria established by the Secretary by regula-
tion in consultation with the Administrator of the Environmental
Protection Agency.
(2) Such project shall require an additional inspection of any
motor vehicle subject to the demonstration project (as determined
by the Secretary) —
(A) whenever the title to such motor vehicle is transferred
to another person unless the transfer is for the purpose of
resale; and
(B) whenever such motor vehicle sustains substantial dam-
age to any safety-related or emission-related system or sub-
system, as prescribed by the Secretary.
(3) To the greatest extent practicable, such inspections shall be
conducted so as to provide specific technical diagnoses of each
-------
2374 LEGAL COMPILATION—Am
motor vehicle inspected in order to facilitate correction of any
component failing inspection.
(4) A demonstration project shall provide for reinspection of
vehicles which initially fail to meet the safety and emission stand-
ards established for the project after repair.
(5) Each project shall provide to the Secretary information and
data relating to the development of diagnostic testing equipment
designed to maximize the interchangeability and interface capabil-
ity of test equipment and vehicles, and information, and data
relating to the costs and benefits of such projects, including infor-
mation and data relating to vehicle-in-use standards, vehicle de-
signs which facilitate or hinder
[p. 13]
inspection and repair, the standardization of diagnostic systems
and test equipment, the capability of the motor vehicle repair
industry to correct diagnosed deficiencies or malfunctions and the
costs of such repairs, the relative costs and benefits of the project,
the efficiency of facility designs employed, recommendations as to
feasible reject levels which may be employed, in any such project
and such other information and data as the Secretary may re-
quire.
APPLICATIONS AND ASSISTANCE
SEC. 303. (a) A grant or other assistance under this title may
be obtained upon an application by a State at such time, in such
manner, and containing such information as the Secretary pre-
scribes, including information respecting categories of expendi-
tures by the State from financial assistance under this title.
(b) Upon the approval of any such application, the Secretary
may make a grant to the State to pay each fiscal year an amount
not in excess of 90 per centum of those categories of expenditures
for establishing and operating its project which the Secretary
approves. Federal financial assistance under this title shall not be
available with respect to costs of inspections carried out after
June 30, 1976, under such a project. Any equipment purchased
with Federal funds may be retained by a State for its inspection
activities following the demonstration project with the approval
of the Secretary. Payments under this subsection may be made in
advance, in installments, or by waj' of reimbursement.
-------
STATUTES AND LEGISLATIVE HISTORY 2375
AUTHORIZATION
SEC. 304. There is authorized to be appropriated to carry out
this title $15,000,000 for the fiscal year ending June 30, 1973;
$25,000,000 for the fiscal year ending June 30, 1974; and
$35,000,000 for the fiscal year ending June 30, 1975. Not more
than 20 percent of the amount appropriated under this section for
any fiscal year may be granted for projects in any one State.
[p. 14]
1.21a(l) SENATE COMMITTEE ON COMMERCE
S. REP. No. 92-413, 92d Cong., 1st Sess. (1971)
[No Relevant Discussion of Pertinent Section]
1.21a(2) HOUSE COMMITTEE ON INTERSTATE AND FOR-
EIGN COMMERCE
H.R. REP. No. 92-1033, 92d Cong., 2d Sess. (1972)
[No Relevant Discussion of Pertinent Section]
1.21a(3) COMMITTEE OF CONFERENCE
H.R. REP. No. 92-1476, 92d Cong., 2d Sess. (1972)
MOTOR VEHICLE INFORMATION AND COST SAVINGS
ACT
SEPTEMBER 28,1972.—Ordered to be printed
Mr. STAGGERS, from the committee of conference,
submitted the following
CONFERENCE REPORT
[To accompany S.976]
-------
2376 LEGAL COMPILATION—Am
TITLE III
DIAGNOSTIC DEMONSTRATION PROJECTS
Title III of this bill provides for demonstration projects to ex-
plore the feasibility of using diagnostic test devices to conduct
diagnostic safety and emission inspections of motor vehicles. The
Senate bill and the House amendment are virtually identical in
substantive effect except for the section dealing with authorization
of funds for functions under Title III. The Committee of Confer-
ence has agreed to accept the House amendment to Title III. There
was a wide disparity, however, in the authorization levels pro-
posed in the Senate bill and those contained in the House amend-
ment. The Senate bill provided an authorization of up to $200
million for the course of the program. The House amendment
limited the total amount to $50 million. The Committee of Confer-
ence in attempting to strike a balance between these two figures
has determined to increase the House amendment by a total of $25
million over fiscal years 1973, 1974 and 1975. Accordingly, the
Committee has agreed on authorization levels of $15 million for
fiscal year 1973, $25 million for fiscal year 1974 and $35 million
for fiscal year 1975. The Committee of Conference also made clear
that no more than 20 percent, of authorized funds may be allocated
to any one State for the purpose of conducting demonstration
projects under this title.
[p. 25]
*****
1.21a(4) CONGRESSIONAL RECORD
L21a(4)(a) VOL. 117 (1971): Nov. 3: Considered and passed Sen-
ate, pp. S17570-S17575, S17578-S17591
[No Relevant Discussion of Pertinent Section]
1.21a(4)(b) VOL. 118 (1972): May 22: Considered and passed
House, amended in lieu of H.R. 11627, pp. H4754-H4755, H4774-
H4739
[No Relevant Discussion of Pertinent Section]
1.21a(4)(c) VOL. 118 (1972): Oct. 4: House agreed to conference
report, pp. H9138-H9139
[No Relevant Discussion of Pertinent Section]
1.21a(4)(d) VOL. 118 (1972): Oct. 6: Senate agreed to conference
report, pp. S17175-S17176
[No Relevant Discussion of Pertinent Section]
-------
Executive
Orders
-------
-------
EXECUTIVE ORDERS 2379
2.1 E.G. 11282, PREVENTION, CONTROL AND ABATEMENT
OF AIR POLLUTION BY FEDERAL AUTHORITIES, MAY
28, 1966
31 Fed. Reg. 7663 (1966)
PREVENTION, CONTROL, AND ABATEMENT OF
AIR POLLUTION BY FEDERAL ACTIVITIES
By virtue of the authority vested in me as President of the
United States and in furtherance of the purpose and policy of the
Clean Air Act, as amended (42 U.S.C. 1857), it is ordered as
follows:
SECTION 1. Policy. The heads of the departments, agencies, and
establishments of the Executive Branch of the Government shall
provide leadership in the nationwide effort to improve the quality
of our air through the prevention, control, and abatement of air
pollution from Federal Government activities in the United States.
In order to achieve these objectives—
(1) Emissions to the atmosphere from Federal facilities and
buildings shall not be permitted if such emissions endanger health
or welfare, and emissions which are likely to be injurious or haz-
ardous to people, animals, vegetation, or property shall be mini-
mized. The procedures established in section 3 of this Order shall
be followed in minimizing pollution from existing facilities and
buildings.
(2) New Federal facilities and buildings shall be constructed so
as to meet the objectives prescribed by this Order and the stand-
ards established pursuant to section 5 of this Order.
(3) The Secretary of Health, Education, and Welfare shall, in
administering the Clean Air Act, as amended, provide technical
advice and assistance to the heads of other departments, agencies,
and establishments in connection with their duties and responsibil-
ities under this Order. The head of each department, agency, and
establishment shall establish appropriate procedures for securing
advice from, and consulting with, the Secretary of Health, Educa-
tion, and Welfare.
(4) The head of each department, agency, and establishment
shall ensure compliance with section 107 (a) of the Clean Air Act,
as amended (42 U.S.C. 1857f(a», which declares it to be the
intent of Congress that Federal departments and agencies shall, to
the extent practicable and consistent with the interests of the
United States and within available appropriations, cooperate with
-------
2380 LEGAL COMPILATION—AIR
the Department of Health, Education, and Welfare and with any
air pollution control agency in preventing and controlling pollu-
tion of the air.
SEC. 2. Procedures for new Federal facilities and buildings. A
request for funds to defray the cost of designing and constructing
new facilities and buildings in the United States shall be included
in the annual budget estimates of a department, agency, or estab-
lishment only if such request includes funds to defray the costs of
such measures as may be necessary to assure that the new facility
or building will meet the objectives prescribed by this Order and
the standards established pursuant to section 5 of this Order. Air
pollution control needs shall be considered in the initial stages of
planning for each new installation.
SEC. 3. Procedures for existing Federal facilities and buildings.
(a) In order to facilitate budgeting for corrective and preventive
measures, the head of each department, agency, and establishment
shall provide for an examination of all existing facilities and
buildings under his jurisdiction in the United States and shall
develop and present to the Director of the Bureau of the Budget,
by July 1, 1967, a phased and orderly plan for installing such
improvements as may be needed to prevent air pollution, or abate
such air pollution as may exist, with respect to such buildings and
facilities. Subsequent revisions needed to keep any such plan up to
date shall be submitted to the Director of the Bureau of the
Budget with the annual report required by paragraph (b) of this
section. Future construction work at each such facility and the
expected future use of the facility shall be considered in develop-
ing such a plan. Each such plan, and any revision therein, shall be
developed in consultation with the Secretary of Health, Education,
and Welfare in order to ensure that adoption of the measures
proposed thereby will result in the prevention or abatement of air
pollution in conformity with the objectives prescribed by this
Order and the standards prescribed pursuant to section 5 of this
Order.
(b) The head of each department, agency, and establishment
who has existing facilities and buildings under his jurisdiction in
the United States shall present to the Director of the Bureau of
the Budget, by July 1, 1968, and by the first of each fiscal year
thereafter, an annual report describing progress of his depart-
ment, agency, or establishment in accomplishing the objectives of
its air pollution abatement plan.
-------
EXECUTIVE ORDERS 2381
SEC. 4. Objectives for Federal facilities and buildings, (a) Ex-
cept for discharges of radioactive emissions which are regulated
by the Atomic Energy Commission, Federal facilities and build-
ings shall conform to the air pollution standards prescribed by the
State or community in which they are located. If State or local
standards are not prescribed for a particular location, or if the
State or local standards are less stringent than the standards
established pursuant to this Order, the standards prescribed pur-
suant to section 5 of this Order shall be followed.
(b) The emission of flyash and other particulate matter shall be
kept to a minimum.
(c) Emission of sulfur oxides shall be minimized co the extent
practicable.
(d) Whenever appropriate, tall chimneys shall be installed in
order to reduce the adverse effects of pollution. The determination
of chimney height shall be based on air quality criteria, land use,
and meteorological, topographical, aesthetic, and operating fac-
tors.
(e) Solid fuels and ash shall be stored and handled so as not to
release to the atmosphere dust in significant quantities. Gasoline
or any volatile petroleum distillate or organic liquid shall be stored
and handled so as not to release to the atmosphere vapor emissions
in significant quantities.
(f) In urban areas refuse shall not be burned in open fires and
in rural areas it shall be disposed of in such a manner as to
reasonably minimize pollution. Refuse shall not be left in dumps
without being covered with inert matter within a reasonably short
time. Whenever incinerators are used they shall be of such design
as will minimize emission of pollutant dusts, fumes, or gases.
(g) Pollutant dusts, fumes, or gases (other than those for
which provision is made above), shall not be discharged to the
atmosphere in quantities which will endanger health or welfare.
(h) The head of each department, agency, and establishment
shall, with respect to each installation in the United States under
his jurisdiction, take, or cause to be taken, such action as may be
necessary to ensure that discharges of radioactive emissions to the
atmosphere are in accord with the rules, regulations, or require-
ments of the Atomic Energy Commission and the policies and
guidance of the Federal Radiation Council as published in the
FEDERAL REGISTER.
(i) In extraordinary cases where it may be required in the
public interest, the Secretary of Health, Education, and Welfare
-------
2382 LEGAL COMPILATION—AIR
may exempt any Federal facility or building from the objectives
of paragraphs (a) through (g) of this section.
SEC. 5. Standards, (a) The Secretary of Health, Education, and
Welfare shall prescribe standards to implement the objectives pre-
scribed by paragraphs (a) through (g) of section 4 of this Order.
Such standards may modify these objectives whenever the Secre-
tary of Health, Education, and Welfare shall determine that such
modifications are necessary in the public interest and will not
significantly conflict with the intent of this Order. Prior to issuing
any changes in such standards, the Secretary of Health, Educa-
tion, and Welfare shall consult with appropriate Federal agencies
and shall publish the proposed changes in the FEDERAL REGISTER
thirty days prior to their issuance. All such standards prescribed
by the Secretary shall be published in the FEDERAL REGISTER.
(b) The permits authorized by section 107 (b) of the Clean Air
Act, as amended (42 U.S.C. 1857f(b)), may be used to carry out
the purposes of this Order as the Secretary of Health, Education,
and Welfare may deem appropriate.
SEC. 6. Prior Executive Order superseded. Executive Order No.
10779 of August 20, 1958, is hereby superseded.
LYNDON B. JOHNSON
THE WHITE HOUSE,
May 26, 1966.
2.2 E.G. 11507, PREVENTION, CONTROL, AND ABATEMENT
OF AIR AND WATER POLLUTION AT FEDERAL FACIL-
ITIES, FEBRUARY 5, 1970
35 Fed. Reg. 3573 (1970)
PREVENTION, CONTROL, AND ABATEMENT OF AIR AND WATER POL-
LUTION AT FEDERAL FACILITIES
By virtue of the authority vested in me as President of the
United States and in furtherance of the purpose and policy of the
Clean Air Act, as amended (42 U.S.C. 1857) [section 1857 et seq.
of this title], the Federal Water Pollution Control Act, as
amended (33 U.S.C. 466) [section 466 et seq. of Title 33, Naviga-
tion and Navigable Waters], and the National Environmental Pol-
icy Act of 1969 (Public Law. No. 91-190, approved January 1,
1970) [this chapter], it is ordered as follows:
SECTION 1. Policy. It is the intent of this order that the Federal
Government in the design, operation, and maintenance of its f acil-
-------
EXECUTIVE ORDERS 2383
ities shall provide leadership in the nationwide effort to protect
and enhance the quality of our air and water resources.
SEC. 2. Definitions. As used in this order:
(a) The terra "respective Secretary" shall mean the Secretary
of Health, Education, and Welfare in matters pertaining to air
pollution control and the Secretary of the Interior in matters
pertaining to water pollution control.
(b) The term "agencies" shall mean the departments, agencies,
and establishments of the executive branch.
(c) The term "facilities" shall mean the buildings, installations,
structures, public works, equipment, aircraft, vessels, and other
vehicles and property, owned by or constructed or manufactured
for the purpose of leasing to the Federal Government.
(d) The term "air and water quality standards" shall mean
respectively the quality standards and related plans of implemen-
tation, including emission standards, adopted pursuant to the
Clean Air Act, as amended, and the Federal Water Pollution Con-
trol Act, as amended, or as prescribed pursuant to section 4 (b) of
this order.
(e) The term "performance specifications" shall mean permissi-
ble limits of emissions, discharges, or other values applicable to a
particular Federal facility that would, as a minimum, provide for
conformance with air and water quality standards as defined
herein.
(f) The term "United States" shall mean the fifty States, the
District of Columbia, the Commonwealth of Puerto Rico, the Vir-
gin Islands, and Guam.
SEC. 3. Responsibilities, (a) Heads of agencies shall, with re-
gard to all facilities under their jurisdiction:
(1) Maintain review and surveillance to ensure that the stand-
ards set forth in section 4 of this order are met on a continuing
basis.
(2) Direct particular attention to identifying potential air and
water quality problems associated with the use and production of
new materials and make provisions for their prevention and con-
trol.
(3) Consult with the respective Secretary concerning the best
techniques and methods available for the protection and enhance-
ment of air and water quality.
(4) Develop and publish procedures, within six months of the
date of this order, to ensure that the facilities under their jurisdic-
-------
2384 LEGAL COMPILATION—AIR
tion are in conformity with this order. In the preparation of such
procedures there shall be timely and appropriate consultation with
the respective Secretary.
(b) The respective Secretary shall provide leadership in imple-
menting- this order, including the provision of technical advice and
assistance to the heads of agencies in connection with their duties
and responsibilities under this order.
(c) The Council on Environmental Quality shall maintain con-
tinuing review of the implementation of this order and shall, from
time to time, report to the President thereon.
SEC. 4. Standards, (a) Heads of agencies shall ensure that all
facilities under their jurisdiction are designed, operated, and
maintained so as to meet the following requirements:
(1) Facilities shall conform to air and water quality standards
as defined in section 2(d) of this order. In those cases where no
such air or water quality standards are in force for a particular
geographical area, Federal facilities in that area shall conform to
the standards established pursuant to subsection (b) of this sec-
tion. Federal facilities shall also conform to the performance spec-
ifications provided for in this order.
(2) Actions shall be taken to avoid or minimize wastes created
through the complete cycle of operations of each facility.
(3) The use of municipal or regional waste collection or dis-
posal systems shall be the preferred method of disposal of wastes
from the Federal facilities. Whenever use of such a system is not
feasible or appropriate, the heads of agencies concerned shall take
necessary measures for the satisfactory disposal of such wastes,
including:
(A) When appropriate, the installation and operation of their
own waste treatment and disposal facilities in a manner consistent
with this section.
(B) The provision of trained manpower, laboratory and other
supporting facilities as appropriate to meet the requirements of
this section.
(C) The establishment of requirements that operators of Fed-
eral pollution control facilities meet levels of proficiency consistent
with the operator certification requirements of the State in which
the facility is located. In the absence of such State requirements
the respective Secretary may issue guidelines, pertaining to opera-
tor qualifications and performance, for the use of heads of agen-
cies.
-------
EXECUTIVE ORDERS 2385
(4) The use, storage, and handling of all materials, including
but not limited to, solid fuels, ashes, petroleum products, and other
chemical and biological agents, shall be carried out so as to avoid
or minimize the possibilities for water and air pollution. When
appropriate, preventive measures shall be taken to entrap spillage
or discharge or otherwise to prevent accidental pollution. Each
agency, in consultation with the respective Secretary, shall estab-
lish appropriate emergency plans and procedures for dealing with
accidental pollution.
(5) No waste shall be disposed of or discharged in such a
manner as could result in the pollution of ground water which
would endanger the health or welfare of the public.
(6) Discharges of radioactivity shall be in accordance with the
applicable rules, regulations, or requirements of the Atomic En-
ergy Commission and with the policies and guidance of the Fed-
eral Radiation Council as published in the FEDERAL REGISTER.
(b) In those cases where there are no air or water quality
standards as defined in section 2(d) of this order in force for a
particular geographic area or in those cases where more stringent
requirements are deemed advisable for Federal facilities, the
respective Secretary, in consultation with appropriate Federal,
State, interstate, and local agencies, may issue regulations estab-
lishing air or water quality standards for the purpose of this
order, including related schedules for implementation.
(c) The heads of agencies, in consultation with the respective
Secretary, may from time to time identify facilities or uses
thereof which are to be exempted, including temporary relief,
from provisions of this order in the interest of national security or
in extraordinary cases where it is in the national interest. Such
exemptions shall be reviewed periodically by the respective Secre-
tary and the heads of the agencies concerned. A report on exemp-
tions granted shall be submitted to the Council on Environmental
Quality periodically.
SEC. 5. Procedures for abatement of air and water pollution at
existing Federal facilities, (a) Actions necessary to meet the re-
quirements of subsections (a) (1) and (b) of section 4 of this
order pertaining to air and water pollution at existing facilities
are to be completed or under way no later than December 31,1972.
In cases where an enforcement conference called pursuant to law
or air and water quality standards require earlier actions, the
earlier date shall be applicable.
(b) In order to ensure full compliance with the requirements of
section 5 (a) and to facilitate budgeting for necessary corrective
-------
2386 LEGAL COMPILATION—Am
and preventive measures, heads of agencies shall present to the
Director of the Bureau of the Budget by June 30, 1970, a plan to
provide for such improvements as may be necessary to meet the
required date. Subsequent revisions needed to keep any such plan
up-to-date shall be promptly submitted to the Director of the Bu-
reau of the Budget.
(c) Heads of agencies shall notify the respective Secretary as to
the performance specifications proposed for each facility to meet
the requirements of subsections 4 (a) (1) and (b) of this order.
Where the respective Secretary finds that such performance speci-
fications are not adequate to meet such requirements, he shall
consult with the agency head and the latter shall thereupon de-
velop adequate performance specifications.
(d) As may be found necessary, heads of agencies may submit
requests to the Director of the Bureau of the Budget for exten-
sions of time for a project beyond the time specified in section
5(a). The Director, in consultation with the respective Secretary,
may approve such requests if the Director deems that such project
is not technically feasible or immediately necessary to meet the
requirements of subsections 4(a) and (b). Full justification as to
the extraordinary circumstances necessitating any such extension
shall be required.
(e) Heads of agencies shall not use for any other purpose any
of the amounts appropriated and apportioned for corrective and
preventive measures necessary to meet the requirements of
subsection (a) for the fiscal year ending June 30, 1971, and for
any subsequent fiscal year.
SEC. 6. Procedures for new Federal facilities, (a) Heads of
agencies shall ensure that the requirements of section 4 of this
order are considered at the earliest possible stage of planning for
new facilities.
(b) A request for funds to defray the cost of designing and
constructing new facilities in the United States shall be included
in the annual budget estimates of an agency only if such request
includes funds to defray the costs of such measures as may be
necessary to assure that the new facility will meet the require-
ments of section 4 of this order.
(c) Heads of agencies shall notify the respective Secretary as to
the performance specifications proposed for each facility when
action is necessary to meet the requirements of subsections
4(a)(l) and (b) of this order. Where the respective Secretary
-------
EXECUTIVE ORDERS 2387
finds that such performance specifications are not adequate to
meet such requirements he shall consult with the agency head and
the latter shall thereupon develop adequate performance specifica-
tions.
(d) Heads of agencies shall give due consideration to the qual-
ity of air and water resources when facilities are constructed or
operated outside the United States.
SEC. 7. Procedures for Federal water resources projects, (a) All
water resources projects of the Departments of Agriculture, the
Interior, and the Army, the Tennessee Valley Authority, and the
United States Section of the International Boundary and Water
Commission shall be consistent with the requirements of section 4
of this order. In addition, all such projects shall be presented for
the consideration of the Secretary of the Interior at the earliest
feasible stage if they involve proposals or recommendations with
respect tc the authorization or construction of any Federal water
resources project in the United States. The Secretary of the Inte-
rior shall review plans and supporting data for all such projects
relating to water quality, and shall prepare a report to the head of
the responsible agency describing the potential impact of the proj-
ect on water quality, including recommendations concerning any
changes or other measures with respect thereto which he considers
to be necessary in connection with the design, construction, and
operation of the project.
(b) The report of the Secretary of the Interior shall accompany
at the earliest practicable stage any report proposing authoriza-
tion or construction, or a request for funding, of such a water
resource project. In any case in which the Secretary of the Inte-
rior fails to submit a report within 90 days after receipt of project
plans, the head of the agency concerned may propose authoriza-
tion, construction, or funding of the project without such an ac-
companying report. In such a case, the head of the agency con-
cerned shall explicitly state in his request or report concerning the
project that the Secretary of the Interior has not reported on the
potential impact of the project on water quality.
SEC. 8. Saving provisions. Except to the extent that they are
inconsistent with this order, all outstanding rules, regulations,
orders, delegations, or other forms of administrative action issued,
made, or otherwise taken under the orders superseded by section 9
hereof or relating to the subject of this order shall remain in full
force and effect until amended, modified, or terminated by proper
authority.
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2388 LEGAL COMPILATION—AIR
SEC. 9. Orders superseded. Executive Order No. 11282 of May
26, 1966, and Executive Order No. 11288 of July 2, 1966, are
hereby superseded.
RICHARD NIXON
2.3 E.O. 11523, NATIONAL INDUSTRIAL POLLUTION CON-
TROL COUNCIL, APRIL 9, 1970
35 Fed. Reg. 5993 (1970)
NATIONAL INDUSTRIAL POLLUTION CONTROL COUNCIL
By virtue of the authority vested in me as President of the
United States, and in furtherance of the purpose and policy of the
National Environmental Policy Act of 1969 (Public Law 91-190,
approved January 1, 1970) [this chapter], it is ordered as fol-
lows:
SECTION 1. Establishment of the Council, (a) There is hereby
established the National Industrial Pollution Control Council
(hereinafter referred to as "the Industrial Council") which shall
be composed of a Chairman, a Vice-chairman, and other represent-
atives of business and industry appointed by the Secretary of
Commerce (hereinafter referred to as "the Secretary").
(b) The Secretary, with the concurrence of the Chairman, shall
appoint an Executive Director of the Industrial Council.
SEC. 2. Functions of the Industrial Council. The Industrial
Council shall advise the President and the Chairman of the Coun-
cil on Environmental Quality, through the Secretary, on programs
of industry relating to the quality of the environment. In particu-
lar, the Industrial Council may—
(1) Survey and evaluate the plans and actions of industry in
the field of environmental quality.
(2) Identify and examine problems of the effects on the envi-
ronment of industrial practices and the needs of industry for
improvements in the quality of the environment, and recommend
solutions to those problems.
(3) Provide liaison among members of the business and in-
dustrial community on environmental quality matters.
(4) Encourage the business and industrial community to im-
prove the quality of the environment.
(5) Advise on plans and actions of Federal, State, and local
agencies involving environmental quality policies affecting indus-
try which are referred to it by the Secretary, or by the Chairman
of the Council on Environmental Quality through the Secretary.
-------
EXECUTIVE ORDERS 2389
SEC. 3. Subordinate Committees. The Industrial Council may
establish, with the concurrence of the Secretary, such subordinate
committees as it may deem appropriate to assist in the perform-
ance of its functions. Each subordinate committee shall be headed
by a chairman appointed by the Chairman of the Industrial Coun-
cil with the concurrence of the Secretary.
SEC. 4. Assistance for the Industrial Council. In compliance
with applicable law, and as necessary to serve the purposes of this
order, the Secretary shall provide or arrange for administrative
and staff services, support, and facilities for the Industrial Coun-
cil and any of its subordinate committees.
SEC. 5. Expenses. Members of the Industrial Council or any of
its subordinate committees shall receive no compensation from the
United States by reason of their services hereunder, but may be
allowed travel expenses, including per diem in lieu of subsistence,
as authorized by law (5 U.S.C. 5703) [section 5703 of Title 5,
Government Organization and Employees] for persons in the Gov-
ernment service employed intermittently.
SEC. 6. Regulations. The provisions of Executive Order No.
11007 of February 26, 1962 (3 CFR 573) [set out as a note under
section 901 of Title 5, Government Organization and Employees],
prescribing regulations for the formation and use of advisory
committees, are hereby made applicable to the Industrial Council
and each of its subordinate committees. The Secretary may exer-
cise the discretionary powers set forth in that order.
SEC. 7. Construction. Nothing in this order shall be construed as
subjecting any Federal agency, or any function vested by law in,
or assigned pursuant to law to, any Federal agency to the author-
ity of any other Federal agency or of the Industrial Council or of
any of its subordinate committees, or as abrogating or restricting
any such function in any manner.
RICHARD NIXON
2.4 E.G. 11587, PLACING CERTAIN POSITIONS IN LEVELS
IV AND V OF THE FEDERAL EXECUTIVE SALARY
SCHEDULE, MARCH 15, 1971
35 Fed. Reg. 475 (1971)
AMENDING EXECUTIVE ORDER No. 11248, PLACING CERTAIN POSI-
TIONS IN LEVELS IV AND V OF THE FEDERAL EXECUTIVE SALARY
SCHEDULE
By virtue of the authority vested in me by section 5317 of title 5
of the United States Code, as amended, section 2 of Executive
-------
2390 LEGAL COMPILATION—Am
Order No. 112481 of October 10, 1965, as amended, placing certain
positions in level V of the Federal Executive Salary Schedule, is
further amended by substituting for the words "Commissioner,
Federal Water Pollution Control Administration, Department of
the Interior," in item (8) thereof, the words "Commissioner,
Water Quality Office, Environmental Protection Agency."
RICHARD NIXON
2.5 E.G. 11602, PROVIDING FOR ADMINISTRATION OF THE
CLEAN AIR ACT WITH RESPECT TO FEDERAL CON-
TRACTS, GRANTS, OR LOANS, JUNE 29, 1971
36 Fed. Reg. 12475 (1971)
PROVIDING FOR ADMINISTRATION OP THE CLEAN AIR ACT WITH
RESPECT TO FEDERAL CONTRACTS, GRANTS, OR LOANS
By virtue of the authority vested in me by the provisions of the
Clean Air Act, as amended (42 U.S.C. 1857 et seq.), and particu-
larly section 306 of that Act as added by the Clean Air Amend-
ments of 1970 (Public Law 91-604, approved December 31, 1970),
it is hereby ordered as follows:
SECTION 1. Policy. It is the policy of the Federal Government to
improve and enhance environmental quality. In furtherance of
that policy, the program prescribed in this Order is instituted to
assure that policy, the program prescribed in this Order is insti-
tuted to assure that each Federal agency empowered to enter into
contracts for the procurement of goods, materials, or services and
each Federal agency empowered to extend Federal assistance by
way of grant, loan, or contract shall undertake such procurement
and assistance activities in a manner that will result in effective
enforcement of the Clean Air Act (hereinafter referred to as "the
Act").
SEC. 2. Designation of Facilities, (a) The Administrator of the
Environmental Protection Agency (hereinafter referred to as "the
Administrator") shall be responsible for the attainment of the
purposes and objectives of this Order.
(b) In carrying out his responsibilities under this Order, the
Administrator shall, in conformity with all applicable require-
ments of law, designate facilities which have given rise to a con-
viction for an offense under section 113(c) (1) of the Act. The
Administrator shall, from time to time, publish and circulate to all
Federal agencies lists of those facilities, together with the names
-------
EXECUTIVE ORDERS 2391
and addresses of the persons who have been convicted of such
offenses. Whenever the Administrator determines that the condi-
tion which gave rise to a conviction has been corrected, he shall
promptly remove the facility and the name and address of the
person concerned from the list.
SEC. 3. Contracts, Grants, or Loans, (a) Except as provided in
section 8 of this Order, no Federal agency shall enter into any
contract for the procurement of goods, materials, or services
which is to be performed in whole or in part in a facility then
designated by the Administrator pursuant to section 2.
(b) Except as provided in section 8 of this Order, no Federal
agency authorized to extend Federal assistance by way of grant,
loan, or contract shall extend such assistance in any case in which
it is to be used to support any activity or program involving the
use of a facility then designated by the Administrator pursuant to
section 2.
SEC. 4. Procurement, Grant, and Loan Regulations. The Federal
Procurement Regulations, the Armed Services Procurement Regu-
lations, and, to the extent necessary, any supplemental or compa-
rable regulations issued by any agency of the Executive Branch
shall, following consultation with the Administrator, be amended
to require, as a condition of entering into, renewing, or extending
any contract for the procurement of goods, materials, or services
or extending any assistance by way of grant, loan, or contract,
inclusion of a provision requiring compliance with the Act and
standards issued pursuant thereto in the facilities in which the
contract is to be performed, or which are involved in the activity
or program to receive assistance.
SEC. 5. Rules and Regulations. The Administrator shall issue
such rules, regulations, standards, and guidelines as he may deem
necessary or appropriate to carry out the purposes of this Order.
SEC. 6. Cooperation and Assistance. The head of each Federal
agency shall take such steps as may be necessary to insure that all
officers and employees of his agency whose duties entail compli-
ance or comparable functions with respect to contracts, grants,
and loans are familiar with the provisions of this Order. In addi-
tion to any other appropriate action, such officers and employees
shall report promptly any condition in a facility which may in-
volve noncompliance with the Act or any rules, regulations, stand-
ards, or guidelines issued pursuant to this Order to the head of the
agency, who shall transmit such report to the Administrator.
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2392 LEGAL COMPILATION—AIR
SEC. 7. Enforcement. The Administrator may recommend to the
Department of Justice or other appropriate agency that legal pro-
ceedings be brought or other appropriate action be taken when-
ever he becomes aware of a breach of any provision required,
under the amendments issued pursuant to section 4 of this Order,
to be included in a contract or other agreement.
SEC. 8. Exemptions—Reports to Congress, (a) Upon a determi-
nation that the paramount interest of the United States so re-
quires—
(1) The head of a Federal agency may exempt any contract,
grant, or loan, and, following consultation with the Administrator,
any class of contracts, grants or loans from the provisions of this
Order. In any such case, the head of the Federal agency granting
such exemption shall (A) promptly notify the Administrator of
such exemption and the justification therefor; (B) review the
necessity for each such exemption annually; and (C) report to the
Administrator annually all such exemptions in effect. Exemptions
granted pursuant to this section shall be for a period not to exceed
one year. Additional exemptions may be granted for periods not to
exceed one year upon the making of a new determination by the
head of the Federal agency concerned.
(2) The Administrator may, by rule or regulation, exempt any
or all Federal agencies from any or all of the provisions of this
Order with respect to any class or classes of contracts, grants, or
loans which (A) involve less than specified dollar amounts, or (B)
have a minimal potential impact upon the environment, or (C)
involve persons who are not prime contractors or direct recipients
of Federal assistance by way of contracts, grants, or loans.
(b) Federal agencies shall reconsider any exemption granted
under subsection (a) whenever requested to do so by the Adminis-
trator.
(c) The Administrator shall annually notify the President and
the Congress of all exemptions granted, or in effect, under this
Order during the preceding year.
SEC. 9. Related Actions. The imposition of any sanction or pen-
alty under or pursuant to this Order shall not relieve any person
of any legal duty to comply with any provision of the Act.
SEC. 10. Applicability. This Order shall not apply to contracts,
grants, or loans involving the use of facilities located outside the
United States.
RICHARD NIXON
-------
Regulations
">2fi-70i O - 74 - 4
-------
-------
REGULATIONS 2395
[EPA's regulations are available in full text in the Code of Federal
Regulations (CFR), which are periodically updated by the Federal Register.]
3.1 Entry of Motor Vehicles and Motor Vehicle Engines Under
Vehicle Air Pollution Control Act, Bureau of Customs, 19
C.F.R. §12.73 (1972)
3.2 Grants for Air Pollution Control Programs, Environmental
Protection Agency, 42 C.F.R. §§456.1^56.45 (1971)
3.3 National Primary and Secondary Ambient Air Quality Stand-
ards Environmental Protection Agency, 40 C.F.R. §§50.1-50.11
(1971)
3.4 Requirements for Preparation, Adoption, and Submittal of
Implementation Plans, Environmental Protection Agency, 40
C.F.R. §§51.1-51.32 (1971)
3.5 Approval and Promulgation of Implementation Plans, Envi-
ronmental Protection Agency, 40 C.F.R. §52 (1972)
3.6 Standards of Performance for New Stationary Sources, En-
vironmental Protection Agency, 40 C.F.R. §§60.1-60.85 (1971)
3.7 Prior Notion of Citizen Suits, Environmental Protection
Agency, 40 C.F.R. §§54.1-54.3 (1971)
3.8 Prevention, Control and Abatement of Air Pollution from
Federal Government Activities: Performance Standards and
Techniques of Measurement, Environmental Protection Agen-
cy, 40 C.F.R. §§76.1-76.9 (1971)
3.9 Registration of Fuel Additives, Environmental Protection
Agency, 40 C.F.R. §§79.1-79.31 (1971)
3.10 Air Quality Control Regions, Criteria and Control Tech-
niques, Environmental Protection Agency, 40 C.F.R. §§81.1-
81.114 (1971)
3.11 Control of Air Pollution from New Motor Vehicles and New
Motor Vehicle Engines, Environment Protection Agency, 40
C.F.R. §§85.1-85.327 (1972)
-------
-------
Guidelines
and
Reports
-------
-------
GUIDELINES AND REPORTS 2399
4.1 ENVIRONMENTAL PROTECTION AGENCY
Reports to Congress, as Required by the Clean Air Act
4.1a "THE ECONOMICS OF CLEAN AIR"
Report to Congress by the Administrator of the Environmental
Protection Agency, December 1970
This report, the third submitted to Congress in accordance with
Section 305 (a) of Public Law 90-148, the Clean Air Act, as
amended, is the first one submitted by the Administrator of the
Environmental Protection Agency. The first and second reports,
"The Cost of Clean Air," were submitted to the Congress of the
United States by the Secretary of Health, Education, and Welfare
in June 1969 and March 1970, respectively. The present report
does not take into account the Clean Air Act amendments that
were being considered by the Congress as of De?ember 1, 1970.
Section 305 (a) reads as follows:
"Sec. 305 (a) In order to provide the basis for evaluating pro-
grams authorized by this Act and the development of new pro-
grams and to furnish the Congress with the information neces-
sary for authorization of appropriations by fiscal years begin-
ning after June 30, 1969, the Secretary, in cooperation w'th
State, interstate, and local air pollution control agencies, shall
make a detailed estimate of the cost of carrying out the provi-
sions of this Act; a comprehensive study of the cost of program
implementation by affected units of government; and a compre-
hensive study of the economic impact of air quality standards
on the Nation's industries, communities, and other contributing
sources of pollution, including an analysis of the national re-
quirements for and the cost of controlling emissions to attain
such standards of air quality as may be established pursuant to
this Act or applicable State law. The Secretary shall submit
such detailed estimate(s) and the results of such comprehen-
sive study of cost for the five-year period beginning July 1,
1969, and the results of such other studies, to the Congress not
later than January 10,1969, and shall submit a reevaluation of
such estimate (s) and studies annually thereafter."
-------
2400 LEGAL COMPILATION—AIR
TABLE OF CONTENTS
Page
PREFACE ii
LIST OF TABLES vi
LIST OF FIGURES viii
Chapter 1: Overview 1-1
I. INTRODUCTION 1-1
A. Background and Purpose 1-1
B. Scope 1-1
C. Cost Estimations and Impact 1-2
D. Report Organization 1-4
II. SUMMARY 1-4
A. Governmental Programs 1-5
B. Mobile Sources 1-5
C. Stationary Sources 1-7
Chapter 2: Governmental Programs 2-1
I. INTRODUCTION 2-1
II. NATIONAL PROGRAM 2-1
III. STATE AND LOCAL PROGRAMS 2-6
IV. FEDERAL FACILITIES 2-6
V. COST ESTIMATES 2-7
Chapter 3: Mobile Sources 3-1
I. INTRODUCTION 3-1
II. EMISSIONS 3-2
A. Nature and Sources of Emissions 3-2
B. Emission Levels and Effects of Standards 3-4
III. STATE-OF-THE-ART OF CONTROL TECHNOLOGY
FOR MOBILE SOURCES 3-9
A. Vehicle Controls 3-9
B. The Overlook for Unleaded Gasoline 3-12
IV. COST ASPECTS OF COMPLIANCE WITH
STANDARDS 3-15
V. CONCLUSIONS 3-20
Chapter 4: Stationary Sources 4-1
I. INTRODUCTION 4-1
II. SOLID WASTE DISPOSAL 4-4
A. General Description of 1967 Practices 4-4
B. Effect of Air Pollution Control Alternatives 4-4
C. Cost of Control 4-5
III. STATIONARY FUEL COMBUSTION 4-6
A. Introduction 4-6
B. Commercial-Institutional Heating Plants 4-10
C. Industrial Boilers 4-11
D. Residential Heating Plants 4-12
E. Steam-Electric Power Plants 4-13
IV. INDUSTRIAL PROCESSES 4-15
A. Introduction 4-15
B. Asphalt Batching 4-21
C. Brick and Tile 4-25
D. Coal Cleaning 4-30
-------
GUIDELINES AND REPORTS 2401
TABLE OF CONTENTS (continued)
Page
E. Cement 4-34
F. Elemental Phosphorus and Phosphate Fertilizer 4-43
G. Grain Milling and Handling 4-55
H. Gray Iron Foundries 4-60
I. Iron and Steel 4-67
J. Kraft (Sulfate) Pulp 4-73
K. Lime 4-79
L. Petroleum Refining and Storage 4-92
M. Primary and Secondary Nonferrous Metallurgy 4-100
N. Rubber (Tires) 4-118
0. Sulfuric Acid 4-121
P. Varnish 4-123
V. IMPACT OF THE COST OF EMISSION CONTROLS
ON THE PRICE LEVEL OF THE U. S. ECONOMY 4-128
A. Introduction 4-128
B. Impact on the Price Level for Specific Industries 4-128
C. Key Industries 4-131
VI. CONCLUSIONS 4-134
A. General Economic Impact of Air Pollution Control 4-134
B. Solid Waste Disposal 4-135
C. Stationary Fuel Combustion 4-136
D. Industrial Processes 4-136
Appendix I: Selection of 298 Metropolitan Areas 1-1
Appendix II: Assumed Emission Standards II-l
LIST OF TABLES
Page
1-1 A Display of Frameworks Used in the Three 305(a) Reports
to Congress 1-2
1-2 Vehicular Unit Control Cost for Cars and Light-Duty Trucks
Resulting From the Implementation of the Clean Air Act 1-6
1-3 Projected Emission Levels and Relative Effects of the Act by
the End of Fiscal Year 1976 1-9
2-1 Projected Cost of Federal, State, and Local Air Pollution
Control Programs 2-7
3-1 Mobile Source Growth and Potential Emissions FY 1967-1976
(1967 Baseline) 3-5
3-2 Effects of Controls on Mobile Source Emissions, FY 1967-
1976 (1967 Baseline) 3-7
3-3 Current and Anticipated Standards for Mobile Sources, 1967-
1976 3-8
3-4 Unit Control Methods and Costs, 1967-1976 Model Years
Cars and Light-Duty Trucks 3-16
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2402 LEGAL COMPILATION—AIR
LIST OF TABLES (continued)
Page
3-5 Unit Control Methods and Costs, 1967-1976 Model Years
Heavy-Duty Gasoline Trucks 8-17
3-6 Costs of Controls and Effectiveness in Reducing Emissions,
FY 1967-1976, All Autos and Gasoline Trucks 3-21
4-1 Stationary Sources—Estimates of Potential and Reduced
Emission Levels and Associated Costs [298 Metropolitan
Areas] 4-8
4-2 Estimated Emission Levels for Stationary Fuel Combustion
Sources Nationally and in 298 Metropolitan Areas [Calen-
dar Year 1967] 4-8
4-3 Stationary Fuel Combustion Sources—Estimates of Potential
and Reduced Emission Levels and Associated Costs [298
Metropolitan Areas] 4—9
4-4 1967 Statistics for Industrial Process Sources [Nationally
and in 298 Metropolitan Areas] 4-17
4-5 Estimated 1967 Emission Levels for Industrial Process
Sources (Nationally and in 298 Metropolitan Areas) 4—18
4-6 Industrial Process Sources—Estimates of Potential and Re-
duced Emission Levels and Associated Costs [298 Metro-
politan Areas] 4-19
4-7 Expected Annual Control Costs Relative to Capacity, Pro-
duction, and Shipments of Industrial Process Sources
[Fiscal Year 1976; 298 Metropolitan Areas] 4-20
4-8 1967 Statistical Data on the Elemental Phosphorus Industry 4-50
4-9 1967 Statistical Data on the Phosphate Fertilizer Industry — 4-50
4-10 1967 Statistics on the Kraft (Sulfate) Pulp Industry 4-75
4-11 1967 Statistics on the Petroleum Refining Industry 4-95
4-12 1967 Statistics on the Petroleum Products and Storage In-
dustry 4-95
4-13 Cell Control Equipment 4-101
4-14 1967 Statistics for Primary Nonferrous Metallurgical Sources 4-105
4-15 1967 Statistics for Secondary Nonferrous Metallurgical
Sources 4-105
4-16 Estimated Impact of the Costs of Emission Control on the
Price Level 4-130
4-17 Estimated Emissions from all Stationary Sources, FY 1976
[298 Metropolitan Areas] 4-135
LIST OF FIGURES
3-1 Approximate Distribution of Emissions by Source for a
Vehicle not Equipped with any Emission Control Systems 8-8
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GUIDELINES AND REPORTS 2403
CHAPTER 1: OVERVIEW
I. INTRODUCTION
A. Background and Purpose
Section 305 (a) of the Clean Air Act requires annual reports on
the prospective costs of implementing the Act's provisions for
governmental and private efforts to control air pollution. This
report is the third submitted under section 305(a); the two
previous reports were submitted to the Congress in June 1969
and April 1970. It provides estimates of the costs of implement-
ing governmental—Federal, State, and local—air pollution con-
trol programs and applying air pollution control measures to
selected stationary sources and motor vehicles.
B, Scope
Twenty-three types of stationary sources are discussed under
three major categories. The section on solid waste disposal gives
estimates of the costs of controlling air pollution arising from
open burning and incineration. Four types of fuel combustion
sources are covered in the second section: steam-electric power
plants, industrial boilers, commercial-institutional heating
plants, and residential heating plants. The third section covers
industrial process sources within the following industries: kraft
(sulfate) pulp, iron and steel, gray iron foundry, sulfuric acid,
petroleum refining, asphalt batching, cement, primary nonfer-
rous metallurgy, phosphate fertilizer, lime, coal cleaning, petro-
leum products storage, grain milling and handling, varnish, rub-
ber (tires), secondary nonferrous metallurgy, elemental phos-
phorus, and brick and tile. One mobile source, motor vehicles, is
discussed.
This report gives the estimated costs of controlling six types of
pollutants from stationary sources: particulate matter, sulfur
oxides, carbon monoxide, hydrocarbons, fluorides, and lead. Es-
timates are given for controlling four types of pollutants from
mobile sources: carbon monoxide, hydrocarbons, nitrogen oxides
and particulate matter. In some of the source categories consid-
ered in this report, there are other pollutants that are signifi-
cant problems; estimates of the
[p. 1-1]
additional cost of controlling them are not included in this re-
port. A comparison of frameworks used in the three reports is
given in Table 1-1.
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2404 LEGAL COMPILATION—AIR
TABLE-l.l-A DISPLAY OF FRAMEWORKS USED IN THE THREE 305 (a) REPORTS TO CONGRESS
Report
1st 2d 3d
Stationary sources:
Number of source categories
Mobile sources:
Number of pollutant categories
85
10
2
2
100
21
4
0
298
23
6
4
C. Cost Estimations and Impact
Control costs are estimated in terms of the initial investment
required to establish control and the continuing annual expenses
related to that investment. The investment cost is the total
expense of purchasing and installing control equipment. The
annual cost is the ultimate yearly charge for capital-related
costs (interest on the investment funds, property taxes where
applicable, insurance premiums, and depreciation charges) plus
operating (labor, utilities, and supplies) and maintenance costs.
The methodology used to estimate the control cost has varied
between the first report and the second and third reports. In the
first report, the levels of control used to make cost estimates
were based on the expected requirements of pollution reduction
in terms of percentages; for the second and third reports, they
were based on selected emission control regulations which are
either identical or similar to comparable types of regulations in
effect in various places in the United States; Appendix II con-
tains a detailed description of the selected regulations for sta-
tionary sources.
[p. 1-2]
Control costs were estimated for the 23 types of stationary
sources in 298 areas. For the purpose of estimating these costs,
the 298 areas were treated as though they had been or will be
designated as air quality control regions (AQCR's) during the
time span covered in this report. Appendix I lists the 298 areas.
Control costs were estimated nationwide for mobile sources.
In this report, Fiscal 1967 (model year 1967 in the case of
motor vehicles) was used as a baseline year. Control costs were
combined for two groups of stationary sources: those that were
operating when the November 1967 amendments to the Clean
Air Act became law and newer sources that have begun opera-
tions since that time or are expected to do so by June 30, 1976.
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GUIDELINES AND REPORTS 2405
This latter group was calculated on the basis of industry pro-
duction and capacity data as well as relevant information on
industry growth patterns. Control costs in the case of mobile
sources are estimated for new cars starting with model year
1967 through model year 1976.
In general, control costs were estimated by calculating the ex-
penditure required to increase the levels of emission control
from an assumed baseline level to the level required for compli-
ance with the selected emission control regulations. This ap-
proach is based on the premise that the costs properly attributa-
ble to the implementation of the Clean Air Act, are those costs
incurred in reaching control levels not commonly being achieved
at the time of the passage of the 1967 amendments to the Act.
The number and type of installations currently controlling
pollutants, the level of efficiency each is achieving, the location
of all sources, their capacity, and other characteristics are bases
for determining the extent and types of control methods needed
to meet the selected standards. This information was derived
from published data, trade association reports, and interviews
with industry contacts. Assumptions, including the set of con-
trol regulations, are identified in this report. Obviously the re-
sults in terms of emissions and control costs that are tabulated
depend on the underlying assumptions. If the assumptions hold,
then the results as estimated will follow.
[p. 1-3]
In addition, this report presents the results of economic analy-
ses on 17 stationary source categories. Price increases are deter-
mined and aggregated to show the price level changes in other
industries and the nation.
D. Report Organization
This report is organized by category with this, the OVER-
VIEW chapter, followed in order by, GOVERNMENTAL PRO-
GRAMS, MOBILE SOURCES, and STATIONARY SOURCES.
The overview includes an introduction to and summary of the
report. The summary follows, in general, the same format as
the report, describing governmental expenditures first, followed
by mobile and stationary sources. Major conclusions of the re-
port can be found in the summary. Further and more detailed
tabulations and narratives are found in the body of the report.
Chapter 2 outlines the probable course, scope, and interrela-
tionships of local, State, regional, and Federal programs. It also
-------
2406 LEGAL COMPILATION—AIR
gives an estimate of expenditures for Fiscal 1972—1976 for
abatement and control efforts to implement the Clean Air Act.
Chapter 3 covers motor vehicles. The addition to the purchase
price of vehicles and the added annual cost of maintaining and
operating the vehicle resulting from control are presented. Such
costs are national for new vehicles and assume compliance to
probable standard through model year 1976.
Chapter 4 covers the three major stationary source categories:
solid waste disposal, fuel combustion, and industrial processes.
For each category, information is given about the total amount
and types of emissions and the average level of control for
facilities operating in the 1967 calendar year in the 298 metro-
politan areas; the number of sources and methods of emission
control; the associated cost estimates for achieving the expected
degree of control required by the assumed regulations; and the
impact of control on selected industries and the nation.
II. SUMMARY
The comprehensive study detailed in this report indicates total
outlay of $15 billion will be necessary over the next five years
[P. 1-4]
(Fiscal 1972-1976) to achieve clean air. Government outlay at
all levels will total $1.2 billion. Control of stationary sources
will require an investment of $6.5 billion. The cost for control-
ling vehicular emissions for model years 1967 through 1976 will
amount to $7.1 billion.
A. Governmental Programs
For the five year period, Fiscal 1972-1976, projected spending
by all levels of government is expected to total $1.176 billion.
The projections cover activities of the National Air Pollution
Control Administration (NAPCA), activities of State and local
governments, and abatement at Federal facilities.
Major activities include:
Measurement of the extent and the effects of air pollution
upon the Nation's population, environment, and economy
and subsequently the development of criteria and stand-
ards. Abatement of air pollution by working with the State
to deal with the problem on a regional basis, providing
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GUIDELINES AND REPORTS 2407
financial and technical assistance to State and local con-
trol agencies, enforcing national control standards on new
motor vehicles, developing control techniques, and develop-
ing manpower.
State, local, and regional agencies have primary responsibility
for abating and preventing air pollution. In Fiscal 1970 these
agencies budgeted $64.4 million for air pollution control activites.
Of this total, $26.0 million was provided by NAPCA.
Executive Order 11507, implementing the intent of Congress,
requires control by polluting Federal facilities of adverse emis-
sions into the air and water. The order is administered by the
Office of Management and Budget.
B. Mobile Sources
National standards are in effect or anticipated for emissions of
hydrocarbons, carbon monoxide, nitrogen oxides, and particulate
matter for motor vehicles. The cost of implementing such stand-
ards for model years 1967 through 1976 totals close to $7.1 billion.
Table 1-2 exhibits the addition to the purchase price of vehicles
resulting from air pollution control. It also exhibits the additional
annual control cost of maintaining and operating the vehicle.
[p. 1-5]
Adverse emissions will decrease substantially through model
year 1976. Hydrocarbon emissions will be reduced to 29 percent of
the potential emissions of that year. Carbon monoxide will be at
40 percent of its potential with nitrogen oxides down to 77 percent
and particulate matter at 84 percent.
One result of the increased combustion efficiency designed to
decrease emissions of hydrocarbons and carbon monoxide is the
savings incurred by the operator. Table 1-2 displays such a sav-
ings (negative cost) for model years 1968 through 1972.
In another part of this report a study of the impact of control-
ling emissions from stationary sources concludes that a significant
amount of control cost for industrial processes is passed on to the
automobile industry through higher prices. These prices will in-
crease the cost of each vehicle in 1975 by $22.50. This cost plus the
cost shown in Table 1-2, when passed on to the consumer could
increase the price of a new car by $262.50 in 1975, with an addi-
tional operating and maintenance cost of $20.70 per year.
-------
2408
LEGAL COMPILATION—Am
TABLE 1-2.—VEHICULAR UNIT CONTROL COST FOR CARS AND LIGHT-DUTY TRUCKS RESULTING FROM THE
IMPLEMENTATION OF THE CLEAN AIR ACT—1967-76 MODEL YEARS
Model year
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
Addition to
purchase price
} 2.00
2.00
7.00
17 00
17.00
42.00
42 00
240 00
240 00
Change in
maintenance and
operating cost
per year
J-5.10
-5.10
-5.10
-2 70
-2.70
7.90
7 90
20 70
20.70
1 Negative values indicate a savings in cost of operation.
[P. 1-6]
C. Stationary Sources
The economic impact of the control of air pollution from sta-
tionary sources has been examined for industrial processes, fuel
combustion, and solid waste disposal in 298 assumed regions. The
examination covered 23 source categories, deriving information
that was aggregated to find the effect of control costs on price
levels within the United States.
The national price level will increase by about 0.14 percent and
employment will show no appreciable change as a result of the
cost of controlling air pollution from industrial processes. Prices
that will increase will rise by less than 2i/£ percent. In general,
7 of 18 industries studied will be able to raise their prices, thus
passing the cost of control to the consumer. These include:
asphalt batching
coal cleaning
elemental phosphorus
phosphate fertilizer
grain milling and handling
iron and steel
kraft pulp
Three of the 18 industries are expected to recover valuable
materials in sufficient quantities to offset all of the annual cost of
control. These include:
petroleum refining
petroleum storage
rubber (tires)
-------
GUIDELINES AND REPORTS 2409
Seven industries will probably absorb part of the cost of control,
reducing their revenue from sales, taxes paid, and net profits.
These include:
cement brick and tile
secondary nonferrous metallurgy lime
varnish primary nonferrous metallurgy
gray iron foundries
[p. 1-7]
The impact on the one remaining industrial process, sulfuric
acid, was not analyzed beyond the cost of control. The total invest-
ment required through Fiscal 1976 to control air pollution for the
18 industries is $3,877 million. The annualized cost for these in-
dustries is $1,095 million. This information is displayed in Table
1-3.
Construction is a key industry affected indirectly by air pollu-
tion control associated with the above 18 industries. The price
level in the construction industry will rise about 0.6 percent an-
nually due to control costs that will be passed on through the line
of consumption. In 1975, for example, this totals $600 million—in-
creasing the average cost per housing unit by $100.
Control of emissions from fuel combustion at stationary sources
will require a total investment of $2,432 million by the end of
Fiscal 1976. The associated annualized cost will be $1,006 million.
Four fuel combustion source categories were studied. Ii. 3 of the
categories—commercial, institutional, and industrial—about 1.2
million sources will share an ultimate annualized cost of $580
million (see Table 1-3). The other category—steam-electric plants
—will pay an ultimate annualized cost of $426 million for control.
This will result in a rate increase for electricity of about 2 percent
which will be diffused into the economy with an insignificant effect
on other price patterns.
In municipalities where solid waste disposal requires air pollu-
tion control, the annual per capita cost of the control will be $0.84.
Control costs are applied to incineration and open burning but not
to other disposal methods such as landfills, ocean dumping, and
composting. Table 1-3 displays an investment expenditure of $201
million through Fiscal 1976 and an ultimate annualized cost of
$113 million. Costs of control of air pollution are in addition to
any control costs during or before 1967. Close to 54 percent of the
cost will be borne by municipal governments and the remaining 46
percent by private individuals and firms.
-------
2410 LEGAL COMPILATION—Am
The total investment expenditure for the 23 source categories of
stationary sources at the end of Fiscal 1976 is $6,510 million, and
the ultimate annualized cost is $2,214 million. This covers the cost
of controlling 6 pollutants: particulate matter, sulfur oxides, car-
bon monoxide, hydrocarbons, fluorides, and lead.
[p. 1-8]
CHAPTER 2: GOVERNMENTAL PROGRAMS
I. INTRODUCTION'
Air pollution research and control activities are a shared re-
sponsibility of Federal, State, and local governmental agencies.
Federal efforts include a national program of research and control
activities conducted under the Clean Air Act and a program to
abate air pollution arising from Federal facilities. State and local
efforts include some 220 air pollution control programs. Each of
the 50 States now has such a program; local efforts include pro-
grams serving either a single city or county, as well as many that
serve two or more jurisdictions.
Section 305 (a) of the Clean Air Act requires, among other
things, an estimate of the cost of governmental programs needed
to carry out the provisions of the Act. As of December 1, 1970,
various proposed amendments to the Act were under consideration
in the Congress. If enacted, the proposed amendments will have a
far-reaching effect not only on Federal air pollution research and
control activities but also on State and local programs. But since
the Congress had not taken final action on the legislation at the
time this report was prepared, the cost estimates presented herein
pertain to continued implementation of the Clean Air Act as it
stood on December 1,1970.
II. NATIONAL PROGRAM
Air pollution research and control activities under the Clean
Air Act are conducted by the National Air Pollution Control Ad-
ministration (NAPCA) of the Environmental Protection Agency;
prior to December 2,1970, NAPCA was located in the Department
of Health, Education, and Welfare. NAPCA's program is divided
into two interrelated categories of activities.
Effects and surveillance activities include research on the health
and welfare hazards of air pollution, research in the areas of
meteorology and atmospheric chemistry, preparation of air qual-
-------
GUIDELINES AND REPORTS 2411
ity criteria documents summarizing available knowledge of the
effects of air pollutants, and air quality surveillance.
[p. 2-1]
Control and compliance activities include overseeing State ac-
tion to deal with air pollution problems on a regional basis, finan-
cial and technical assistance to State and local air pollution control
agencies, establishment and enforcement of national standards for
the control of air pollution from new motor vehicles, research and
development on techniques for preventing and controlling air pol-
lution, and manpower development and training.
In estimating the cost of NAPCA's program during the Fiscal
1972-76 period, it was assumed that the agency's principal activi-
ties would be based on the considerations outlined below:
To insure adequate protection and enhancement of the Nation's
air quality, it would be necessary to designate air quality control
regions encompassing all Standard Metropolitan Statistical Areas,
all other urban areas with a population of at least 25,000, all
potential interstate air pollution problem areas, and a number of
other areas known to have significant air pollution problems.
Thus, air quality control regions would have to be designated in
approximately 298 areas.
States would have to adopt air quality standards and implemen-
tation plans for the 298 air quality control regions for at least the
following pollutants: sulfur oxides, particulate matter, carbon
monoxide, hydrocarbons, photochemical oxidants, nitrogen oxides,
fluorides, and lead. As required by the Clean Air Act, State action
on these pollutants would have been preceded by issuance of air
quality criteria documents and reports on control techniques.
Expansion of air quality surveillance activities would be neces-
sary. NAPCA has estimated that adequate nationwide surveillance
of air quality will require a network of approximately 10,000 air
monitoring stations, most of which would be located in and around
the projected 298 air quality control regions. About 90 percent of
these air monitoring stations would be operated by State and local
agencies. The remainder would be NAPCA-operated in order to
insure standardization of air
[p. 2-2]
quality measurements and to provide a means of verifying State
and local data. The task of setting up this network and that
necessary expansion of NAPCA's analytical and data processing
capabilities would be completed during the Fiscal 1972-76 period.
-------
2412 LEGAL COMPILATION—AIR
Federal enforcement action would have to be undertaken in
those air quality control regions where States fail to follow
through on their plans for implementation of air quality stand-
ards. The extent to which such Federal action will be necessary
would depend on a number of factors, including the adequacy of
funds and manpower available to State and local air pollution
control agencies, the private sector's response to emission control
requirements included in State's implementation plans, the success
of State agencies in formulating and executing emergency action
plans for preventing the occurrence of air pollution levels that
may pose imminent and substantial endangerment to public
health, and so on.
It would be necessary to adopt increasingly stringent national
standards for the control of air pollution from new motor vehicles,
particularly light-duty vehicles (which include passenger cars). A
proposed schedule for application of more stringent standards for
carbon monoxide and hydrocarbon emissions and for initial appli-
cation of standards for nitrogen oxides and particulate emissions
has been published in the Federal Register. New and more accu-
rate testing procedures have been established for initial use in
certification of 1972-model vehicles. During Fiscal 1972-76, new
or improved test procedures would have to be developed for use in
measurement of nitrogen oxides and particulate emissions, reac-
tive hyrocarbon emissions, and diesel odors and smoke, as well as
procedures suitable for use in State motor vehicle inspection pro-
grams. NAPCA's surveillance activities would have to be im-
proved and expanded to permit determination of the extent to
which emission control systems perform as expected during actual
use of motor vehicles.
[p. 2-3]
NAPCA would have to continue its efforts to promote the devel-
opment of low-pollution motor vehicles; these efforts are intended
to stimulate private-sector activity and to insure the availability
of low-pollution engines in the event that private-sector efforts are
not productive. For this purpose, NAPCA is supporting research
and development, primarily through contracts with non-Federal
organizations, and has initiated an incentive program in which
low-emission vehicles developed by the private sector will be eligi-
ble for demonstration-testing and fleet-testing by NAPCA, in co-
operation with other Federal agencies. In both the research and
development activity and the incentive program, major emphasis
is being placed on the development of satisfactory low-pollution
alternatives to the internal combustion engine.
-------
GUIDELINES AND REPORTS 2413
NAPCA involvement in, and support of, efforts to develop and
demonstrate sulfur oxides pollution control processes would have
to continue. This work is focused primarily on processes applica-
ble to fuel-combustion sources. A number of flue-gas cleaning
processes are to be demonstrated during the Fiscal 1972-76 pe-
riod ; generally, these processes remove not only sulfur oxides but
also particulate matter. A process for desulfurizing coal before it
is burned also is to be demonstrated. It is anticipated that some of
these processes will be in commercial use within the next five
years. A continued effort to promote the development of new com-
bustion processes also can be anticipated; included in this category
are fluidized-bed combustion and an advanced power cycle involv-
ing coal-gasification, both of which may offer significant benefits
in terms of sulfur oxides control and efficiency in production of
electric energy.
An increasing effort to promote the development and demon-
stration of nitrogen oxides control techniques would be necessary,
particularly with respect to fuel-combustion sources. Projects to
test the effectiveness of two-stage
[p. 2-4]
combustion combined, possibly, with gas recirculation, as well as
flue-gas cleaning processes can be anticipated.
State and local air pollution control agencies would need in-
creased financial and technical assistance, particularly to enable
them to continue the process of adopting and implementing air
quality standards for the air quality control regions; it should be
noted that the projected 298 regions represent about three times
the number designated by the end of calendar year 1970. State and
local agencies' needs for technical assistance in the development of
implementation plans would be especially great. Their increasing
needs for financial assistance would arise largely from the necess-
ity of recruiting additional manpower and offering sufficiently
high salaries and benefits (particularly opportunities for advanced
training) to attract and retain qualified personnel.
There would be a continuing need for research aimed at provid-
ing improved knowledge of the health and welfare hazards of air
pollution and of the meteorological factors and atmospheric proc-
esses that influence the behavior of pollutants in the air (e.g.,
movement, interaction, decay, etc.). A need also exists for contin-
ued research aimed at the development and standardization of
methods of measuring emissions and air quality. The results of
research in all these areas have a significant bearing on the ability
-------
2414 LEGAL COMPILATION—Am
of air pollution control agencies to establish and enforce meaning-
ful air quality and emission standards.
The scope of NAPCA's activities would depend, of course, on
many other factors. Among the most important will be the extent
to which the private sector accepts responsibility for conducting
and supporting the development and demonstration of air pollu-
tion control techniques. It is not, and never has been, expected that
the Federal Government would be the sole source of support for
needed research and development in the field of air pollution con-
trol.
[p. 2-5]
III. STATE AND LOCAL PROGRAMS
Expenditures of State and local funds for air pollution control
activities have increased steadily over the past several years; in
part, this trend reflects the availability of Federal grant funds
under the Clean Air Act. For Fiscal 1970, it is estimated that
agencies receiving Federal grant support budgeted a total of $64.4
million for air pollution control activities. Of this total, $38.4
million were non-Federal funds; this sum represents a four-fold
increase over non-Federal budgeting for Fiscal 1965.
Nevertheless, further increases in expenditures of State and
local funds will be necessary. Many agencies still do not have the
money and manpower needed to conduct effective programs. Fur-
thermore, as an increasing number of air quality control regions is
designated, State governments' responsibilities for adoption and
implementation of air quality standards will increase.
A detailed discussion of the functions of State and local air
pollution control agencies and their manpower needs was included
in Manpower and Training Needs for Air Pollution Control, a
report submitted to the Congress in June 1970.
IV. FEDERAL FACILITIES
A program for abatement of air pollution from Federal facili-
ties is carried on under Executive Order 11507, issued in Febru-
ary 1970. Executive Order 11507 supplanted Executive Order
11282, which had been in effect since May 1966. The new Order
requires, among other things, that air and water pollution abate-
ment projects be completed or underway no later than December
31,1972, unless a department or agency requests, and the Office of
Management and Budget grants, an extension of time.
-------
GUIDELINES AND REPORTS
2415
No estimate of the cost of air pollution abatement projects to be
initiated under the new Executive Order is included in this report.
It should be noted, however, that the President indicated, in a
statement issued at the time the new Executive Order was pub-
lished, that a program costing $359 million was anticipated; the
program includes both air and water pollution abatement.
[p. 2-6]
The Federal facilities abatement program is administered by
the Office of Management and Budget (formerly Bureau of the
Budget). The National Air Pollution Control Administration pro-
vides technical assistance to the Office of Management and Budget
and to the various departments and agencies.
V. COST ESTIMATES
Estimates of the combined cost of the air pollution research and
control activities discussed above are presented in Table 2-1. The
breakdown by categories (i.e., Effects and Surveillance, Control
and Compliance) reflects the arrangement of NAPCA's program.
The estimated cost of State and local activities is included primar-
ily in the Control and Compliance category; the one exception is
the estimated cost of State and local air quality surveillance,
which is included in the Effects and Surveillance category.
TABLE 2-1.—PROJECTED COST OF FEDERAL, STATE, AND LOCAL AIR POLLUTION CONTROL PROGRAMS
[In millions of dollars]
Fiscal year
1972
1973
1974. .
1975
1976
Totals
Program category
Effects and Control and
surveillance compliance
30.7
36.1
37.4
37.9
42.2
184.3
177.6
185.6
194.6
200.5
232.9
991.2
Total
208.3
221.7
232.0
238.4
275.1
1175.5
[p. 2-7]
CHAPTER 3: MOBILE SOURCES
I. INTRODUCTION
This chapter concerns the costs of complying with current and
projected Federal standards for motor vehicle air pollution emis-
sions and presents estimates of the cost to purchasers and users of
motor vehicles due to air pollution control for Fiscal Years 1967
-------
2416 LEGAL COMPILATION—AIR
through 1976. The estimates are based on current, anticipated
standards and other available data as of July 1970. These stand-
ards cover or will cover emissions of hydrocarbons, carbon monox-
ide, nitrogen oxides, and particulate matters from motor vehicles.
This chapter compares projected emissions under the anticipated
standards with potential emissions which would be expected if no
standards were in effect. The costs of meeting the standards are
expressed in terms of additional initial cost to the consumer, in-
creases in operating and maintenance costs, and an annualized
combination of increased operating and maintenance costs. The
effect of these expenditures on emissions is also indicated. Only
costs associated with control of vehicular emissions are included.
Costs or price increases from controls on supplier industries, such
as steel making, are considered in Chapter 4, Section V. Costs in
the form of government programs are discussed in Chapter 2. The
cost of unleaded gasoline, where required, has been included in
total costs presented in this chapter.
Only gasoline powered automobiles and light and heavy-duty
trucks are covered in the emissions and cost data presented in this
chapter. Within the accuracy of available data and estimating
techniques, the inclusion of buses and diesel trucks would have
little effect on the total emissions and cost figures.
The estimates and projections of emissions contained in this
chapter are based on information available as of July 15, 1970 and
are different from previously published estimates. Either the pre-
vious estimates of hydrocarbon and carbon monoxide emissions
from motor vehicles were low or the methods for measuring these
emissions gave lower readings than those
[p. 3-1]
obtained from vehicles under realistic operating conditions. This
information was released by the Secretary of Health, Education,
and Welfare on July 15, 1970.
The main text of this chapter first presents a synopsis of motor
vehicle control technology through the 1976 models. Estimates of
the growth of vehicle populations and the potential for emissions
without control are discussed next. The costs to purchasers and
users to have vehicles in compliance with standards are included
in the section on costs (Section IV).
-------
GUIDELINES AND REPORTS 2417
II. EMISSIONS
A. Nature and Sources of Emissions
Motor vehicles are a major source of air pollution in the United
States. The four major pollutants from motor vehicles are hydro-
carbons, carbon monoxide, nitrogen oxides, and particulate mat-
ter. Motor vehicles account for approximately one-half of the hy-
drocarbon emissions and two-thirds of the carbon monoxide emis-
sions to the atmosphere in the United States. Motor vehicles also
contribute about one-third of the nitrogen oxides and nine-tenths
of the lead-bearing particulate matter to the total national emis-
sions of these pollutants.
Motor vehicle emissions occur in several ways. Hydrocarbon
emissions come from evaporation from the fuel tanks and carbure-
tors (gasoline powered vehicles), blow-by and leakage from the
engine crankcase, and incomplete combustion. Figure 3-1 illus-
trates the sources and approximate relation of these emissions.
Incomplete combustion also produces carbon monoxide in the ex-
haust gases. In the internal combustion engine, some of the atmos-
pheric oxygen and nitrogen combine to form nitrogen oxides
which are emitted in the exhaust. Unfortunately, conditions which
favor more complete and efficient combustion, thereby reducing
exhaust emissions of hydrocarbons and carbon monoxide, tend to
increase the levels of nitrogen oxides formed.
For present consideration, the source of particulate matter
emitted by motor vehicles is the exhaust. The particulate matter in
exhaust gases from gasoline engines consists of carbonaceous ma-
terial, salts and oxides of iron and lead, and droplets or particles
of hydrocarbon materials. Lead compounds constitute about 80
percent of the particulate matter thus emitted.
[p. 3-2]
[p. 3-3]
Metallic lead is present to the extent of 50 to 60 percent of total
particulate weight. Diesel engines have particulate emissions
which consist almost entirely of small carbon particles. Based on
present knowledge, both the total amount and the nature of the
particulate matter from diesel engines represent much less of an
environmental problem than that from gasoline engines.
-------
2418
LEGAL COMPILATION—Am
FUEL TANK AND
CARBURETOR EVAPORATION
HC 15%
EXHAUST
HC 70%
CO 100%
NO, 100%
CRANKCASE
BLOWBY
HC 15%
FIGURE 3-1.—Approximate distribution of emissions by source for a vehicle
not equipped with any emission control systems.
-------
GUIDELINES AND REPORTS 2419
B. Emission Levels and Effects of Standards
As have been previously noted, discrepancies have been found in
the standards and measurement techniques in effect for the period
FY 1968 through 1971. In the emission estimates reported herein,
corrections have been made for the FY 1968 through 1971 period
so that the data are on a comparable basis for the entire period of
FY 1967 through 1976.
Crankcase emissions were already under control at the begin-
ning of the time frame being considered here. The crankcase con-
tributions of the older cars which are not equipped with blow-by
control devices have been included in the emission estimates pre-
sented here.
1. Potential for Emissions Without Control Under the Clean
Air Act.—Table 3-1 gives the estimated growth of the number
of automobiles and gasoline trucks in use for the period of
Fiscal Years 1967 through 1976. This table also projects the
potential emissions which could be expected if no control regula-
tions were in effect. The total number of vehicles in use shows a
growth of approximately 31 percent. The total potential annual
emissions show an increase of approximately the same magni-
tude.
In making the projections shown in Table 3-1, the vehicle
populations have been projected on the basis of the best infor-
mation on the numbers of vehicles actually in use rather than
the number of vehicle registrations. The registration method is
considered less accurate because it is basically a count of the
number of registration transactions and results in multiple
counting of some vehicles.
The vehicles shown in Table 3-1 are divided into two categor-
ies; the first comprises automobiles and light-duty trucks.
Light-duty trucks are six thousand pounds or less in gross vehi-
cle weight (GVW). The other category, heavy-duty gasoline
trucks, consists of trucks over six thousand pounds GVW. The
vehicle data shown do not include either diesel trucks or buses
of the gasoline or diesel variety. Based on the
[p. 3-4]
-------
2420
LEGAL COMPILATION—Am
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-------
GUIDELINES AND REPORTS 2421
best data available, buses and diesel trucks constitute a small
fraction of the total vehicle population. Also, for the time pe-
riod considered in this chapter, the only anticipated Federal
standards for diesels are for smoke density and cannot be di-
rectly related to the emissions of the other pollutants considered
here. Additional Federal standards may be proposed later. The
State of California, however, is proposing other exhaust emis-
sion standards for diesels.
Table 3-1 also shows the potential emissions of the four
major pollutants from motor vehicles. In addition to showing
estimates for the individual pollutants and the total emissions,
the table expresses total emissions as a percentage of 1967 lev-
els. The estimated total potential emissions in 1976 are about
one and one-third times those in 1967. Table 3-1 further shows
the projected total pollution potential over the entire span of
FY 1967 through 1976.
2. Projected Standards and Emissions with Controls Under
the Act.—Table 3-2 illustrates the effect of anticipated controls
on the emissions for FY 1967 through 1976. In making the
projections shown in Table 3-2, current and anticipated stand-
ards detailed in Table 3-3 were used. These standards either
have been promulgated or are under consideration by the Na-
tional Air Pollution Control Administration. The anticipated
standards for heavy-duty trucks are still under study and devel-
opment.
As shown in Table 3-2, nearly 82 percent of the motor vehi-
cles in use should be controlled by 1976. In projecting the per-
centage of vehicles under control, the age distribution of vehi-
cles in use has been considered with older vehicles being re-
moved from service and new vehicles being added with time.
Age and use distribution within the vehicle population are based
on 1969 data. It is assumed that a comparable distribution will
hold through FY 1976.
It has been assumed in making projections that controlled
vehicles will be maintained in such a manner that their average
emissions will not exceed the level set by Federal standards.
Tests have indicated that vehicles now on the road tend to
increase their emission levels somewhat with age; however, the
new Federal standards and methodologies for manufacturer
qualification of vehicles are intended to insure that vehicles are
capable of remaining below the standard levels through
[p. 3-6]
-------
2422
I
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TABLE 3-2— EFFECTS OF CONTROLS ON MOBILE SOURCE EMISSIONS, Fl
[1967 baseline]
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Autos and light- Heavy-duty Autos and light and heavy- Hydrocarbons Carbon Nitrogen Particulates
Fiscal year duty trucks gasoline trucks duty gasoline trucks monoxide oxides
LE
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GAL COMPILATION — Am
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Fiscal years 1967-76 emission and percent totals 160,300 60 1,030,000 71 66,900 102 3,740
M
i Potential emissions as shown in table 3-1.
» Implementation of hydrocarbon and carbon monoxide controls causes increase in nitrogen oxides emissions until countered by nitrogen oxides control
[p. 8-7]
-------
GUIDELINES AND REPORTS
2423
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[p.*-*]
-------
2424 LEGAL COMPILATION—Am
their useful life. Some method of enforcement or incentive may
be required to assure that owners do maintain vehicles so that
emissions are kept to specified levels.
The projected annual emissions with the anticipated controls
in effect are expressed in weight quantities and as the percentage
of the uncontrolled potential. By 1976 hydrocarbons should be
reduced to about 29 percent of the uncontrolled potential, car-
bon monoxide to 40 percent, nitrogen oxides to 77 percent, and
particulates to about 84 percent of potential.
The nitrogen oxides level with controls is expected to rise
above the uncontrolled level for a portion of this time period.
This is due to the fact that the controls for hydrocarbons and
carbon monoxide, which are implemented earlier than those for
nitrogen oxides, tend to produce an increase in nitrogen oxides
with a reduction of the other pollutants. The first Federal
standards for nitrogen oxides are expected to be effective in FY
1973. With these standards in effect, the levels of nitrogen oxides
emitted will begin to show a decline. However, it is not until the
last two years of the time period that these levels will actually
fall below those expected if hydrocarbons and carbon monoxide
were not being controlled.
In making the emission projections with controls as shown in
Table 3-2, consideration was given not only to the age distribu-
tion within the vehicle populations each year, but to the usage
of various ages of vehicles. Based on total mileage estimates and
the number of cars in use, the average mileage driven per year
is about 10,600 miles; for heavy-duty trucks the average is
about 12,000 miles. Based on Bureau of Public Roads surveys
the trend is for annual mileage to decrease with the age of the
vehicle. Thus, the newer vehicles contribute a significantly
larger portion of the total mileage and fuel consumption than
the older vehicles.
III. STATE-OF-THE-ART OF CONTROL TECHNOLOGY FOR MOBILE
SOURCES
A. Vehicle Controls
The past year has not produced any major advances in either
new technology for the control of the internal combustion engine
or the development
[p. 8-8]
-------
GUIDELINES AND REPORTS 2425
of power sources as alternatives. Some progress has been made
in control techniques and more is anticipated in certain areas,
such as the use of catalytic exhaust reactors. Such changes ap-
pear to be evolutionary rather than of the breakthrough variety.
Most of the progress to date in reducing hydrocarbon and car-
bon monoxide emissions have been made by increasing air-fuel
ratios (AFR) in new engines. Many 1970 model cars are designed
to operate at air-fuel ratios of 14 to 16 parts air to one part fuel,
thus reducing the hydrocarbon and carbon monoxide emissions. It
is an unfortunate fact that nitrogen oxides emissions reach a
maximum in this range (approximately 15.5). Theoretically,
an AFR in the range of 18 to 20 would be the optimum point
for limiting emissions of all gaseous pollutants (hydrocarbons,
carbon monoxide, and nitrogen oxides) in the exhaust. In practice,
however, air-fuel ratios greater than about 17.5 produce rough
engine operation which manufacturers feel would be unacceptable
to most drivers. Automobile manufacturers and carburetor sup-
pliers are continuing their efforts to develop satisfactory produc-
tion models with leaner operating engines; i.e. using a higher
air-to-fuel ratio.
Diesel engines always operate with an excess of air present in
the combustion cylinders. This accounts for the diesel engine's low
emissions of hydrocarbons and carbon monoxide as compared with
the gasoline engine. The AFR is varied by the driver rather than
being fixed by carburetor design as in a gasoline engine. Smoke
from diesel engines is a function of the engine loading, speed, and
the air-fuel ratio. Since these factors are under the control of the
diesel operator, most diesel engines now on the road can meet
smoke standards through FY 1976 if properly maintained and
operated. Minor design changes, such as improved fuel injectors,
are being incorporated into new diesel engines to further improve
the performance in terms of smoke and odor emissions.
Exhaust emission standards for light-duty vehicles can be
met through FY 1972 by minor modifications to current design
engines. Such modifications include carburetion improvements, op-
eration with leaner fuel mixtures, control of engine inlet-air tem-
perature, and changes in the timing of valve and ignition opera-
tion.
The nitrogen oxides standards for exhaust emissions, which be-
come effective in FY 1973, can be met through partial exhaust
gas recirculation to the engine air inlet. Although recirculation
reduces nitrogen oxides
[p. 3-10]
•S26-705 O - 74 - 6
-------
2426 LEGAL COMPILATION—AIR
emissions, it has a slightly adverse effect on the levels of other
emissions. However, it should be possible to meet standards by
this means through FY 1974.
Anticipated standards for evaporative emissions from fuel
tanks and engines of gasoline vehicles can be readily met through
FY 1976. In fact, the ease with which the original standards were
met has resulted in an advancement of the effective date of the
more stringent evaporative standards. Automobile manufacturers
report considerable progress during the last year in simplification
and production engineering of evaporative control devices. These
advances should result in reducing device complexity, maintenance
requirements and initial price.
It should be possible for gasoline engines to achieve FY 1975
standard levels. However, in the opinion of the automobile manu-
facturers, this may be near the limit of what might be expected
with reciprocating internal-combustion engines. In order to meet
FY 1975 standards, some type of exhaust-gas reactor system ap-
pears necessary. Research and development efforts are continuing
on both engine-exhaust manifold-type reactors and catalytic-muf-
fler-type reactors. The current consensus of major U.S. manufac-
turers is toward the use of catalytic-muffler-type units in FY 1975
and FY 1976. Some limited production of single catalyst units may
begin with the 1975 model year. This represents somewhat of a
change in thinking during the last year. The change has been
brought about because of a push toward the reduction or elimina-
tion of lead in gasoline. The presence of lead in gasoline has an
undesirable effect on catalytic-reactor-type units and has been a
major stumbling block in the development of such units. Although
the automotive industry has sought the elimination of lead in
gasoline because of adverse effects on the longevity of exhaust
emission control systems such as catalytic and thermal reactors,
reduction or elimination of lead will also greatly reduce the prob-
lem of particulate emissions in the exhaust.
In order to meet the FY 1975 standards, it is anticipated that
the catalytic-reactor units will be used to reduce nitrogen oxides
as well as carbon monoxide and hydrocarbons. To accomplish this,
tandem catalytic units or dual-catalyst units will probably be re-
quired. In a two-catalyst system such as this, the engine is run
fuel rich to produce the low-oxygen-content exhaust gases re-
quired for a reducing-type reactor. This results in an increase in
fuel consumption. The dual-catalyst units will prol^bly
[P. 3-11]
-------
GUIDELINES AND REPORTS 2427
serve multiple functions in the exhaust system of 1975-76 model
automobiles. The catalytic-reactor units may also serve as con-
ventional mufflers and have provision for trapping particulate
matter.
United States automobile manufacturers are working toward a
lifetime of 50 to 100 thousand miles for the catalytic-muffler
systems. In accord with this goal, manufacturers anticipated that
so-called lifetime exhaust systems will be added to the vehicle. This
means that the other portions of an exhaust system will be made
of a durability comparable to or greater than the catalytic-reactor
units. This is intended to avoid the possibility of damage or re-
quirements for replacement of expensive catalytic units due to
failure of other exhaust components. The increased life of such
exhaust components will be of benefit to the consumer.
The foregoing discussion has been directed largely at automo-
biles. It is anticipated that the technology will be essentially ident-
ical for other light-duty gasoline vehicles. The same technology
will probably be applied in general to the heavy-duty gasoline
vehicles also, but there is a greater potential for the use of ex-
haust-manifold reactors on heavy-duty vehicles. During the period
through FY 1976, however, it is probable that heavy-duty gasoline
trucks will be able to meet the standards through engine modifica-
tions and the addition of some exhaust gas recirculation. It is not
anticipated that particulate control will be required on heavy-duty
vehicles through FY 1976. The technology of evaporative emission
control for heavy-duty vehicles should be quite similar to that for
light-duty vehicles. There may be some differences, however, due
to the presence of multiple fuel tanks on many heavy-duty vehi-
cles.
B. The Outlook for Unleaded Gasoline
Tetraethyl lead was once added only to premium grade gaso-
line. Regular grades were essentially of the same base, but with-
out the lead addition. As a result, the public came to associate
the name "ethyl" with premium quality. This association in the
public mind continues despite the fact that both regular and
premium gasolines today contain lead additives.
Average premium gasolines on the market contain about 2.8
grams of lead per gallon and have a research octane number
(RON) of about 100; average regular grade gasoline has about
2.4 grams of lead per gallon
[p. 3-12]
-------
2428 LEGAL COMPILATION—AIR
and a RON of about 94. The range of octanes varies with time
and sources of petroleum. Regular gasolines may range from 90
to 96 octane; premium from 97 to 100. Some companies retail
three grades of gasoline; others use blending pumps to offer
virtually a continuous spectrum of octanes in the 92 to 100 range.
With current refining processes, the average RON of premium
gas is slightly below 93 without lead added, satisfying the anti-
knock requirements of only about 55 percent of the automobiles
currently in use. Removal of lead from regular gas would result in
a research octane number slightly below 86, satisfying less than
four percent of current automobiles. The combined regular and
premium gasoline base stocks (before addition of lead) constitute
the so-called "pool" for the nation. The "pool" octane thus ob-
tained is about 91 RON.
1. Movement Toward Low Lead and Lead-Free Gasolines.—
Recent months have seen rapid changes in the prospects for
low-lead or unleaded gasoline as the petroleum industry adjusts
to the realities of potential restrictions. United States automo-
bile manufacturers have decided to lower the octane require-
ments of new cars beginning with 1971 models. This removes
some of the arguments against unleaded gasoline. If it is not
necessary to maintain present high octane levels without using
lead, refinery processes will not require extensive changes. This
means that 91 RON unleaded gasoline can be offered at little or
no change in price over present regular grades.
By the end of the 1971 model year, almost all U.S. automobile
production will have engines suitable for operation on 91 re-
search octane gasoline. This is an effort by the manufacturers to
push the production of unleaded gasoline in anticipation of in-
troducing catalytic exhaust reactor units. In the auto industry
there is a general feeling that complete absence of lead in gaso-
line will increase the possibility of valve problems in current
engine designs. Only very low levels of lead content are required
to prevent these problems; however, present experience indi-
cates that catalytic reactors may not tolerate even small concen-
trations of lead in gasoline. Gasoline or oil additives may be
found to prevent valve problems without lead. Newer engines
will be designed to avoid such problems.
[p. 3-13]
2. Progress in Availability of Low-Lead and Lead-Free Gaso-
lines.—Major gasoline producers have recently announced the
immediate or imminent availability of low-lead or unleaded gas-
olines. The products and prices being offered present a mixed
-------
GUIDELINES AND REPORTS 2429
picture. One producer has for a number of years offered an
unleaded premium gasoline, with a price usually somewhat
higher than leaded premiums in the same area. Another major
producer has been offering an unleaded regular in some parts
of the country, with a price above leaded premium. Yet another
offers a low-lead regular (nominal 96 RON) as the middle level
of a three-grade line. This middle grade is retailing for one cent
per gallon above the leaded grade it has replaced. Other com-
panies with three-grade or blending pump lines are offering
their lowest octane product (92 to 94 nominal RON) at one
cent below area prices for leaded regular. Other variations are
in the offing as more suppliers announce their plans.
The variations in approach by producers reflect several influ-
ences. These influences include the company's ability to produce
a given octane with lowered lead content (dependent on the
nature of its crude supply and types of refining equipment) and
judgments concerning financial and marketing strategies. Com-
petitive effects will tend to produce a more uniform price and
product balance as time passes.
Gasoline retailers report that initial consumer response to
new low-lead and unleaded fuels has been disappointing. The
concept that higher octane fuel is inherently better for an auto-
mobile is deeply imbedded in consumer psychology. The major-
ity of U.S. automobile owners use gasoline with octane ratings
(and hence lead content) in excess of their engine's require-
ments. This may result from years of exposure to gasoline ad-
vertisements, the association of the word "premium" with
higher octane ratings, and ignorance. This situation will likely
continue even though new cars will have lower octane require-
ments. Consumer apathy toward unleaded fuels may also reflect
ignorance of the environmental concerns regarding lead.
A major educational campaign will be required to induce the
consumer to accept the lowest octane gasoline which is actually
required by his car. If this is not done, continued public demand
for excessive quantities of high octane fuel could result in unne-
cessarily high prices for unleaded gasoline.
[p. 8-14]
IV. COST ASPECTS OP COMPLIANCE WITH STANDARDS
Tables 3-4 and 3-5 detail the per-vehicle cost of complying with
Federal standards for mobile sources for the 1967-76 model years.
The uncontrolled 1967 model year is a baseline. Tables 3-4 and
8-5 show the emissions controlled for each vehicle model year, the
-------
2430 LEGAL COMPILATION—AIR
anticipated control methods, and the control investment per vehi-
cle. The control investment per vehicle represents an increase in
price to the purchaser of new motor vehicles. Anticipated require-
ments for additional maintenance due to emission controls are also
shown in the tables with the frequency and event cost of such
additional maintenance indicated. It is assumed that legal or war-
ranty requirements will insure that owners obtain the necessary
maintenance. The anticipated additional maintenance costs are
based on current labor costs for procedures comparable to those
anticipated and for estimated costs of replacement items asso-
ciated with emission controls. These anticipated periodic mainte-
nance costs are also shown on an annualized basis. Additional
operating costs incurred as a result of fuel penalties are also
shown. The total additional annual costs per vehicle are the annu-
alized maintenance cost plus the extra operating cost. All cost
figures are based on 1970 dollars.
Since the motor vehicle industry provides products directly to
the consumer public, costs have been expressed in terms of the
owners and users of vehicles. In the automotive industry increased
costs of manufacturers (including research and engineering) are
passed directly to the final consumer by means of increased retail
prices.
For the typical automobile owner and user, concepts of amorti-
zation, annualization, or percentage change in annual costs proba-
bly have little significance. The typical automobile owner will tend
to view his costs largely in terms of the increased price at time of
purchase and increased operating costs in terms of fuel usage. The
depreciation characteristics of vehicles vary widely depending on
the popularity of the individual model involved. For this reason it
would add little to attempt to annualize investment costs accord-
ing to actual vehicle depreciation curves.
The costs of additional maintenance requirements have been
annualized on the basis of the time interval between the required
maintenance events. Thus, a maintenance requirement that must
be met on an average of once every five years has its costs annu-
alized on a five-year basis.
[p. 3-15]
In preparing the cost information shown in Tables 3-4 and 3-5,
consideration has been given to offsetting benefits which may act
to reduce the net cost to purchasers and users of motor vehicles;
e.g., increased gas mileage due to leaner engine operation.
Crankcase emission devices (the PCV valve system) are not
included in pre-1968 costs. These devices were required by law
-------
GUIDELINES AND REPORTS
2431
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-------
2432
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GUIDELINES AND REPORTS 2433
beginning with 1966 models, but have been standard on U. S. cars
beginning with 1963 models.
Controls classified under the category of engine modifications
include changes in compression ratios, valve and ignition timing,
and carburetion and fuel-air inlet design changes. Changes of this
type are commonly used by manufacturers to differentiate engines
of one basic design in order to offer a product line of several
horsepower options with varying fuel requirements. Such changes,
which do not require the addition of any components to engines or
involve any basic concepts not current in the 1967 designs, are
here considered to be ordinary engineering options for the manu-
facturers with negligible effect on retail prices. Where additional
items are added to the basic engine design, such as spark advance
cut-out devices, evaporative traps, or equipment for exhaust gas
recirculation, retail price estimates have been used in computing
the control investment cost per vehicle. In the case of evaporative
emission traps, consideration has been given to engineering ad-
vancements which have permitted reduction of the retail cost of
such units from the $35 level for the prototypes as sold in Califor-
nia in 1970 to approximate $10 for the types that will be in
general use throughout the U.S. in 1971 models. Possible costs for
extensive emission compliance testing of assembly line vehicles
have not been included.
For the 1975 and 1976 model years, the control investment costs
per vehicle include the price of the catalytic-reactor-type muffler
units with a long-life exhaust system, the equipment required for
air injection to the oxidizing reactor, provision for trapping of
particulates, and the evaporative emission traps. As has been pre-
viously stated, it is assumed that unleaded gasoline will be em-
ployed by the 1975 and 1976 model vehicles.For the 1975-76 mod-
els, a credit has been given under maintenance requirements for
reduction in the exhaust system maintenance due to the use of
long-life materials as compared to current exhaust system materi-
als.
As may be seen from the Table 3-4, the slightly improved fuel
consumption with engines being operated under lean conditions
produces an overall benefit or negative total annual cost per vehi-
cle through the 1972 model year.
[p. 3-18]
It has been estimated that the lean operation will produce ap-
proximately two percent improvement in gasoline mileage for
1968 through 1972 models. Theoretically, the use of evaporative
-------
2434 LEGAL COMPILATION—AIR
traps to recover normally lost fuel should result in a fuel saving.
However, in practice, the disturbances in carburetion and the
balance of the air-fuel intake system produced by adding on such
devices will probably tend to offset any gain due to fuel recovery.
Exhaust gas recirculation will probably produce a slight de-
crease in fuel economy, tending to offset the benefits of lean engine
operation. Theoretically, recirculation should have little effect on
engine efficiency, but again in practice, disturbances of carbure-
tion and air-fuel distribution will produce a small loss in engine
efficiency.
For FY 1975-76 fuel-cost penalties are incurred from two
sources. Approximately a five percent fuel penalty is the minimum
which can be expected for 1975-76 model automobiles using a
reducing catalyst system to control nitrogen oxides. The govern-
ment is seeking to have unleaded (and very low-lead) gasoline in
general use by 1974 or 1975. Therefore, it is assumed that un-
leaded gasoline will be used by all automobiles and gasoline trucks
in FY 1975-76. An additional two cents per gallon for unleaded
gasoline is charged only against pre-1971 model vehicles for FY
1975-76. The increased cost for these cars to use unleaded fuel is
based on an assumption of octane requirements similar to 1967
vehicles. It is assumed that there will be no extra cost for the low
octane lead-free fuel used by 1971-76 model engines in FY
1975-76.
Cost estimates for producing unleaded gasoline of octane levels
required by pre-1971 model automobiles have ranged from about
one-half to two and one-half cents per gallon over comparable
leaded fuels. The decision of automobile manufacturers to lower
octane requirements beginning with 1971 models has greatly
changed the fuel cost outlook from earlier projections. Fluctua-
tions in costs of unleaded gasoline versus leaded are to be expected
in the transition period. The price situation should be stabilized by
the time vehicles appear with catalytic exhaust reactors.
Control costs for heavy-duty trucks are anticipated to be gener-
ally comparable to those for automobiles and light-duty trucks
meeting the same standards. However, the differences in imple-
mentation of heavy-duty truck standards shifts the time frame of
the costs. For the heavy-duty
[p. 3-19]
vehicles, higher fuel consumption rates increase the relative im-
portance of fuel penalties and total annual cost.
-------
GUIDELINES AND REPORTS 2435
A summary of the total national economic effects of mobile
source controls through 1976 is given in Table 3-6. The incremen-
tal capital investment given each year is for cost increases due to
meeting the then-current emission standards for new vehicles sold
that year. The incremental capital investment represents the sum-
total of individual cost increases for all vehicles of a model year
corresponding to the fiscal year shown (for practical purposes the
automobile model sales season corresponds closely with a Federal
fiscal year). The additional operating costs shown in Table 3-6
are the total for all vehicles in use which are under any Federal
emission standards. The age and use distributions within the vehi-
cle populations have been considered. Reductions in the potential
emission levels for each year are also shown in Table 3-6.
Table 3-6 also shows the totals of the capital investment and
additional operating costs incurred over the entire period of 1967
through 1976, and the reduction from the potential emission level
achieved. The total of the capital investment and additional opera-
ting costs projected for the period of FY 1967 through 1976 is
approximately 7.1 billion dollars for the nation. It should be
pointed out that the small dollar benefits (negative costs) per
vehicle in the FY 1968 through 1974 period are very sensitive to
variations in data on average vehicle usage and fuel consumption
rates. For this reason, as far as the individual owner is concerned,
costs and benefits will about offset each other in this period. For
the individual private automobile owner, the purchase price dif-
ferences will be the most obvious cost item, although these differ-
ences do not become major until the 1975 model year.
V. CONCLUSION
Based upon information available as of July 15, 1970, air pollu-
tion control costs to be borne by vehicle purchasers and users do
not appear significant through Fiscal Year 1974. Control costs will
climb sharply to meet the anticipated standards in succeeding
[p. 3-20]
-------
2436
LEGAL COMPILATION—Ant
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year increased prices
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(Thousands (Percent)
of tons)
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II
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and mamtenanc
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new vehicles'
(millions of dollars
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a> ^ i
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§ § li
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s due to purchases of new vehicles d
d costs due to controls for all cars an
ntial emissions as shown in Table 3-
ic benefits larger than direct costs to
;s indicate increases (which are resu
nieaded gasoline assumed beginning
|It f~
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Illlll
^ I— CD Q Z )—
[p. 8-21]
-------
GUIDELINES AND REPORTS 2437
years unless presently unforeseen technological advances occur.
Meeting the projected standards through 1976 will, however, pro-
duce significant reductions in mobile source emissions. If imple-
mentation of the standards is accelerated or if the standards are
increased in stringency, it can be expected that control costs will
rise at an accelerated rate.
[p. 3-22]
CHAPTER 4: STATIONARY SOURCES
I. INTRODUCTION
The impact of air pollution controls on 23 categories of station-
ary air pollution sources is discussed in this chapter. The analyses
cover the significant combustion and process steps of each cate-
gory, their emissions by type and quantity, methods of controlling
emissions to comply with the standards selected for this report
(see Appendix II), the expected costs of control, and the economic
impact of these costs for the industrial processes.
The 23 categories of stationary sources are discussed in three
sections—solid waste disposal (Section II), stationary fuel com-
bustion (Section III), and industrial processes (Section IV). The
six pollutants covered in this report are particulates, oxides of
sulfur, carbon monoxide, hydrocarbons, fluorides, and lead. Table
4-1 presents a summary of emissions and control costs for the
three source groupings in 298 metropolitan areas, which are iden-
tified in Appendix I. Control costs shown are the total investment
requirements through Fiscal Year 1976 and the annual costs for
sources estimated to be operating in Fiscal Year 1976. Annual
costs, including both operating and capitalization expenses, are the
result of the assumption that the Clean Air Act will be imple-
mented.
The year 1967 was selected as the data baseline so that costs
and changes in emissions would be those occurring after the pas-
sage of the Clean Air Act and, therefore, are presumed to be
attributable to the economic impact of program implementation.
By using 1967 as a data base, emission and cost estimates for
Fiscal Year 1976 for solid waste, commercial-institutional heating
plants, and residential heating plants were computed on projected
growth and population trends. For all other sources (industrial
boilers, steam-electric and industrial processes) emission and cost
estimates for Fiscal Year 1976 were computed on projected
growth for source production and capacity, respectively since it
-------
2438 LEGAL COMPILATION—AIR
was not possible to determine accurately whether the projected
growth would result from expansion of 1967 plants and installa-
tions or from construction of new facilities. In the absence of
implementation of the standards described in Appendix II, it was
[p. 4-1]
assumed that additional source production would be controlled, at
1967 control levels. The procedure described implicitly assumes
that the purchasing power of the dollar remains at the 1967 level
and that equipment costs and operating expenses remain un-
changed. Within the limits of these assumptions, this approach
provides a reasonable approximation of the increased emissions
and costs associated with economic growth over the period of 1967
to Fiscal Year 1976.
Some of the tables in this chapter include a column headed
"Associated Emission Control Level." The percentages shown in
this column reflect estimates of the extent to which potential emis-
sions are controlled. For example, in Table 4-3, pertaining to fuel
combustion sources, the 1,360,000 tons of particulate emissions
from industrial boilers in 1967 are estimated to be about 38.5
percent of potential emissions of particulate matter. If there had
been no control of particulate emissions, the emission level would
have been 3,550,000 tons. Thus, the associated emission control
level is 61.5 percent (100 percent minus 38.5 percent).
The discussions of solid waste disposal and fuel combustion
(Sections II and III) emphasize the sources and amounts of pollu-
tant emissions and the controls necessary for their abatement.
Section IV contains, in addition to a discussion of emissions and
controls for industrial sources, an extended analysis of the eco-
nomic impact of control costs on each industry or group of indus-
tries studied. Consideration is given to the probable effect on indi-
vidual firms in each industry, potential changes in prices, profits,
and the structure of the industry, and market changes. In Section
V, the analysis of economic impact is carried another step to
consider the aggregate effects of industry changes upon buyer
industries and consumer prices. Section VI contains a summary of
conclusions derived from the analyses.
[p. 4-2]
-------
GUIDELINES AND REPORTS
2439
H-
cr>
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Q
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\ND REDUCED EMISSION LEVELS A
n areas]!
F POTENTIAL I
298 metropolita
S— ESTIMATES 0
I
*RY SOURCE
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TABLE 4-1.-S
Control costs
(millions of dollars)
Quantity of emissions :
(thousands of tons per year)
•
J
Investment Annua 1
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CO CO CO CO (O CO
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Solid waste disposal 1967
Fiscal yea
Fiscal yea
Stationary fuel combustion 1967
Fiscal yea
Fiscal yea
Industrial processes 1967
Fiscal yea
Fiscal yea
CM"
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' Metropolitan areas are defined in Appendix 1.
1 Emission abbreviations are: particulates (Part
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1 Estimates without implementation of the Clea
' Estimates with implementation of the Clean A
I—I
3
-------
2440 LEGAL COMPILATION—AIR
II. SOLID WASTE DISPOSAL
A. General Description of 1967 Practices
It is estimated that a population of 166,882,000 resided in the
298 metropolitan areas in 1967. At an estimated solid waste gener-
ation rate of 10.2 pounds of refuse daily per capita in 1967, a total
of 311 million tons were generated. Of each 10.2 pounds generated
in a metropolitan area, 5.5 pounds were considered to be munici-
pally collected refuse with the remaining 4.7 pounds defined as
nonmunicipally collected refuse. In 1967, only 15 percent of all
solid waste was incinerated, 42 percent was open burned, and 43
percent was disposed of by other means such as landfills, ocean
dumping, and composting. As noted in Table 4-1, total emissions
in the 298 metropolitan areas for 1967 were estimated at 1,110,000
tons of particulates, 3,770,000 tons of carbon monoxide, and
1,400,000 tons of hydrocarbons (measured as methane).
B. Effect of Air Pollution Control Alternatives
By 1976, the population of the 298 metropolitan areas should
reach 186 million. It is also predicted that the per capita genera-
tion of solid waste will increase by approximately three percent
per year. Thus, an estimated 395 million tons of refuse would be
generated in 1976.
For the purpose of estimating control costs, it is assumed that
the following control alternatives would be used: (1) electrostatic
precipitators to control particulate emissions in accordance with
the New York State Particulate Emission Regulation for Refuse
Burning Equipment (see Appendix II) on all municipal and 80
percent of the commercial incinerators onsite in 1967; (2) a suffi-
cient number of new incinerators would be constructed to provide
for incineration of 20 percent of all refuse; and (3) all open
burning would be discontinued in favor of sanitary landfills.
By implementing this plan by Fiscal Year 1976, particulate
emissions would be reduced from a potential of 1,500,000 tons to
185,000 tons, carbon monoxide from 5,450,000 tons to 414,000
tons, and hydrocarbons from 2,020,000 tons to 293,000 tons. The
emissions are therefore reduced by 87.7 percent, 92.4 percent, and
85.5 percent, respectively.
[p. 4-4]
-------
GUIDELINES AND REPORTS 2441
C. Cost of Control
As shown in Table 4-1, the total investment requirement for
implementing this plan would be $201 million and the annual cost,
as of FY 1976, would be $113 million. These costs are in addition
to expenditures for control before 1967.
[p. 4-5]
III. STATIONARY FUEL COMBUSTION
A. Introduction
Stationary fossil fuel (coal, oil, and gas) combustion sources
analyzed in this study are commercial-institutional heating plants,
industrial boilers, residential heating plants, and steam-electric
power plants. As determined from Table 4-1, these four sources
account for about 35 percent of the particulates and 68 percent of
the sulfur oxides emitted in the nation in 1967 by all stationary
sources studied. The other pollutants covered in this report are not
emitted in significant quantities when the combustion equipment is
operating properly. Table 4-2 indicates the amount of particulate
matter and sulfur oxides contributed by each of these four types
of combustion sources in the Nation and in the 298 metropolitan
areas in 1967.
For this study, two standards were selected as the basis of
estimating the cost of controlling emissions from fuel combustion
sources. The first standard is the State of Maryland's combustion
regulation, which limits particulate emissions on a graduated
basis depending upon the heat rating of the boiler. The regulation
sets a maximum limit on the quantity of particulate matter emit-
ted per hour; the requirements increase in stringency with in-
creasing boiler capacity. The second standard used in this study
was for sulfur oxide emissions from fuel combustion sources. This
one limits emissions to 1.46 pounds of sulfur oxides per million
B.t.u. input.
In preparing the second Cost of Clean Air report, it was as-
sumed that the control of particulate and sulfur oxide emissions
from stationary fuel combustion sources could be achieved by
switching fuel, i.e., to use low sulfur oil in place of other fuels.
Further study has indicated that this alternative is still an accept-
able choice for the residential and commercial-institutional heat-
ing plants and for industrial boilers. The availability of low sulfur
oil and natural gas should satisfy the present and future require-
ments of these types of facilities.
[p. 4-6]
526-705 O - 74 - 7
-------
2442 LEGAL COMPILATION—AIR
For steam electric power plants, however, a complete switch
from high sulfur coal and oil to low sulfur oil is not feasible in
light of apparent long term fuels supply and demand requirements
in the United States. Accordingly, a mix of alternatives for the
control of emissions from steam electric power plants was as-
sumed, including dependence to a very large degree on the use of
stack gas cleaning devices for the control of both sulfur oxides and
particulate emissions. Limited fuel switching has been included
for the control of smaller units only.
As previously noted in Table 4-1, the control plan projected in
this study would reduce the total potential Fiscal Year 1976 parti-
culate emissions from 3,867,000 tons to 930,000 tons and sulfur
oxide emissions from 14,447,000 tons to 4,697,000 tons; reductions
of 76.0 percent and 67.5 percent, respectively. Total investment
requirements for this control plan would be $2,432 million and
annual costs as of FY 1976 would be $1,006 million. The impact of
the control plan on each of the four fuel combustion sources is
shown in Table 4-3 and discussed in the following sections.
[p. 4-7]
-------
GUIDELINES AND REPORTS
2443
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2444
LEGAL COMPILATION—Am
TES
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-------
GUIDELINES AND REPORTS 2445
B. Commercial-Institutional Heating Plants
1. Present and Projected Emissions.—In 1967, there were
approximately 952 thousand heating plants in commercial-insti-
tutional establishments (hotels, retail stores, schools, hospitals,
etc.) located within the 298 metropolitan areas. These heating
plants consumed 4.3 million tons of coal, 267 million barrels of
oil, and 1.58 trillion cubic feet of gas in 1967. Table 4-3 indi-
cates that combustion of these fuels resulted in emissions of 127
thousand tons of particulate matter and 940 thousand tons of
sulfur oxides. As also noted in Table 4-3, current emissions
from these plants are under little or no control.
It is assumed thai no additional coal-fired commercial-institu-
tional heating plants were or will be built during the period
from 1967 through Fiscal Year 1976. Consumption of oil and
gas by such heating plants is expected to increase by 417 million
barrels and 3.64 million cubic feet, respectively. The average
value of the sulfur content of the fuel oil is assumed to be one
percent by weight.
Given these fuel use patterns, it is estimated that annual
emissions from commercial-institutional heating plants in the
298 metropolitan areas would reach 152 thousand tons of parti-
culate matter and 1,440 thousand tons of sulfur oxides by Fiscal
Year 1976.
2. Control of Emissions and Estimated Control Costs.—It
appears that control of sulfur oxides and particulate emissions
from commercial-institutional heating plants in the 298 metro-
politan areas can be accomplished by Fiscal Year 1976 by
switching those plants currently using coal as a fuel to the use
of oil.
Through such fuel switching, emissions would be reduced to
135 thousand tons of particulate matter and 1,400 thousand tons
of sulfur oxides. The reductions are rather small because, even
without fuel switching, it is expected, first, that little coal would
be burned in such heating plants in Fiscal Year 1976 and, sec-
ond, that all the oil utilized would meet the standards listed in
Appendix II.
It is estimated that the investment required to change the
estimated 21 thousand existing coal burning heating plants over
to oil will be almost $41.7 million, a unit conversion cost of
$2,000.
[p. 4-10]
-------
2446 LEGAL COMPILATION—Am
The total annual cost, including both the incremental fuel costs
(on a B.t.u. basis) and the annualized cost of the initial invest-
ment, will be $25.1 million per year.
C. Industrial Boilers
1. Present and Projected Emissions.—In 1967, there were an
estimated 307 thousand industrial boilers in the United States,
with an estimated 256 thousand located within the 298 metro-
politan areas. These boilers supply steam for material process-
ing, space heating, and electric-power generation and annually
consume 45 million tons of coal and 162 million barrels of oil, as
well as a significant quantity of natural gas. Emissions from
these boilers, assuming an estimated 61.5 percent control level
for particulates and zero for sulfur oxides, amounted to 1,360
thousand tons of particulates and 2,330 thousand tons of sulfur
oxides (See Table 4-3).
Of the oil consumed, approximately 81 percent is residual oil
with an average sulfur content of 1.5 percent; the remaining 19
percent is distillate oils with a sulfur content averaging 0.5
percent. By Fiscal Year 1976, the annual consumption of coal is
expected to drop about 38 million tons, with the usage of oil in-
creasing to 220 million barrels. It is expected that a significant
percentage of the additional oil will be of an acceptable sulfur
content of not more than 1.38 percent.
By Fiscal Year 1976, without implementation of the Clean
Air Act emissions from industrial boilers within the 298 metro-
politan areas could be expected to reach 1,410 thousand tons of
particulate matter and 2,310 thousand tons of sulfur oxides.
2. Control of Emissions and Estimated Control Costs.—Con-
trol costs were estimated on the basis of switching existing coal
burning boilers to oil as well as the additional fuel costs of
switching from coal and high sulfur fuel oil to oil with a sulfur
content of not more than 1.38 percent. Under this plan emis-
sions would be reduced to 142 thousand tons of particulate mat-
ter and 1,110 thousand tons of sulfur oxides, 99.0 percent and
50.5 percent reductions, respectively.
These controls are estimated to require an investment of
$16,500 per boiler for a total investment of $1,050 million with
a total annualized cost of $555 million.
[p. 4-11]
-------
GUIDELINES AND REPORTS 2447
D. Residential Heating Plants
1. Present and Projected Emissions.—The population of the
298 metropolitan areas in 1967 was approximately 166,882,000.
An estimated 47 million dwelling units housed this population.
For the purposes of residential heating in 1967, 7.6 million tons
of coal, 343 million barrels of distillate oil and 2.5 trillion cubic
feet of natural gas were consumed. As indicated in Table 4-3,
combustion of these fuels resulted in annual emissions of 160
thousand tons of particulates and 776 thousand tons of sulfur
oxides, with only coal burning exceeding the maximum limit of
the selected regulations (See Appendix II).
Recent trends indicate that the use of coal as a home heating
fuel is diminishing dramatically. In the United States in 1967,
an estimated 22 million tons of coal were consumed for this
purpose whereas it is projected that less than 9 million tons will
be consumed in Fiscal Year 1976. There also is predicted dimin-
ishing utilization of distillate oil, although less dramatic than
the reduction in coal usage. The increased use of natural gas
and electrical heating is expected to supplant these fuels and
meet the additional home heating requirements predicted by
Fiscal Year 1976. By that time, emissions will be reduced to 120
thousand tons of particulates and 597 thousand tons of sulfur
oxides.
2. Control of Emissions and Estimated Control Costs.—Be-
cause the utilization of coal for residential heating is decreasing
by "natural attrition" and because all the other modes of home
heating fall well within the emission standards, no control costs
are assigned to this source category.
By Fiscal Year 1976, the emission of particulates and sulfur
oxides will be reduced to 120 thousand tons and 597 thousand
tons, respectively. The source of about 75 percent of each of
these emissions will be the combustion of low sulfur content
distillate oil which currently meets the most stringent combus-
tion standards.
[p. 4-12]
E. Steam-Electric Power Plants
1. Present and Projected Emissions.—In 1967, there were 516
investor and municipally owned (public) fossil fuel steam-elec-
tric power plants of 25 megawatts or greater capacity in the
United States. These plants contained 2,984 steam boilers and
consumed 270 million tons of coal and 6,753 million gallons of
-------
2448 LEGAL COMPILATION—AIR
residual fuel oil. Within the 298 metropolitan areas, there were
387 power plants in which 2,060 boilers were located; this does
not include the Tennessee Valley Authority power plants.
On an annual basis, it is estimated that 1967 particulate and
sulfur oxide emissions from the power plants located in the 298
areas amounted to 1,600 thousand and 7,370 thousand tons,
respectively. In spite of a particulate control level of 78 percent,
these emissions accounted for 49.3 percent of all particulates
and 64.6 percent of all sulfur oxides from fuel combustion
sources in the 298 metropolitan areas in 1967.
Without the implementation of the Clean Air Act, emissions
of particulate matter and sulfur oxides would reach 1,980 thou-
sand tons and 10,100 thousand tons, respectively, by Fiscal Year
1976.
2. Control of Emissions and Estimated Control Costs.—In
power plants utilizing high sulfur coal and/or residual fuel oil,
having a rated capacity in excess of 200 megawatts, and with an
overall plant load factor in excess of 17 percent, it was assumed
that wet limestone injection scrubbing systems would be in-
stalled to provide for the simultaneous control of particulate
matter and sulfur oxides. Depending on the number and size of
individual boilers within each plant, one or more wet limestone
scrubbers would be required; control costs and emission reduc-
tions have been calculated accordingly. For high sulfur coal and
residual oil burning power plants of less than 200 megawatts
capacity or plants operating at less than a 17 percent load
factor, it was assumed that it will be more economical to replace
these fuels with low sulfur fuels. The premiums assigned to the
use of low sulfur fuels were 90 cents per ton of coal and 80
cents per barrel
[p. 4-13]
of oil. Such a fuel switch is consistent with currently projected
availability patterns for low sulfur fuels. With implementation
of the Clean Air Act, the Fiscal Year 1976 emissions of parti-
culates and sulfur oxides would be reduced to 533 thousand
tons and 1,600 thousand tons, respectively.
Based upon the low sulfur fuel price premiums discussed
above, as well as preliminary cost data for wet limestone scrub-
bing systems, control costs by Fiscal Year 1976 for all high
sulfur coal and oil burning plants within the 298 metropolitan
areas were calculated. These are an investment requirement of
-------
GUIDELINES AND REPORTS 2449
$1,340 million and a total annual cost of $426 million. These
costs would increase electric energy costs to the average con-
sumer by 2 percent.
[p. 4-14]
IV. INDUSTRIAL PROCESSES
A. Introduction
This section discusses the impact of the Clean Air Act, as
amended, on 18 industries or industry groups. Data are included
for plants which were in operation during 1967 and estimates
are also given for additional facilities predicted to be built by
the end of Fiscal Year 1976.
Four general tables describing the 18 industries follow. Table
4-4 gives calendar year 1967 statistics on the number of sources,
capacity, production, and value of shipments for the Nation and
for the metropolitan areas. Table 4-5 gives estimates of the
quantities of the six pollutants emitted by the 18 sources in the
Nation and in the 298 metropolitan areas in calendar year 1967.
Thus, these two tables indicate how much of each industry is
concentrated in the 298 metropolitan areas as compared to the
rest of the Nation and their relative contribution to air pollution
in 1967. A comparison of 1967 emissions with Fiscal Year 1976
emissions, with and without implementation of the Clean Air
Act, along with associated costs of controls, given implemen-
tation of the Act, is given in Table 4-6. Table 4-7 presents
ratios to related estimated annualized costs of controlling air
pollution for facilities operating in 1967 to capacity, produc-
tion, and the value of shipments. These ratios are indicative of
the general economic impact of emission control.
This section also provides detailed analyses of the economic
impact of emission controls on 17 of the 18 industries1 or indus-
try groups; petroleum refining is combined with petroleum
products and storage, phosphate fertilizer with elemental phos-
phorus, and primary nonferrous metallurgy with secondary
nonferrous metallurgy because these producers and their mar-
kets overlap. For each industrial category, the annual costs and
investment required to achieve compliance with each of the
emission standards have been estimated. Where the resultant
cost per unit of finished product is significantly large, and for
those industries for which sufficient data on company size, oper-
ation, and financial position were adequate, a model firm (or
-------
2450 LEGAL COMPILATION—AIR
firms) has been constructed to show the potential impact of con-
trol costs on company operations. For all
1 Sulfuric acids is not included because an in-depth analysis is being done under another
NAPCA study.
[p. 4-15]
industries, the total annualized cost to the industry is also shown
and related to production and capacity to show the magnitude
of cost per unit of product. For those industries in which con-
trol costs may be expected to cause pressure for changes in
product prices, the analysis has been carried forward to the
market. The effect of possible price changes has been estimated
in relation to the competitive patterns of the effected industry,
the distribution of market strength among sellers and buyers,
and the trends of prices, production, and capacity through
Fiscal Year 1976. Expected changes in product sales, company
profit, and the number and size of firms in the industry are
presented, as appropriate.
[p. 4-16]
-------
GUIDELINES AND REPORTS
2451
ATISTICS FOR INDUSTRIAL PROCESS SOURCES (NATIONALLY AND IN 298 METROPOLITAN AREAS)'
te
T
7
a
m
f
^
* of shipments
f dollars per yea
5.1
!5
Total number of sources Capacity ' Production J
(millions of units per year) (millions of units per year
nit of measurement
1
i
o
ra
oo
en
United Sta
£
TO
o>
CM
1
en
•o
"E
ID
i
TO
OO
CD
1
1
1
ra
OO
a
to
tn
•o
o in oo ro *j-
co CM in oo 1-4
o in rr> <-• o
m co m CM CM
o o o o
sasa
o o o o m
to
to *t
^jS3'~l>-l»-'tocvJ^* (DNCNJ
ffiJiliipiilSlill
tc.) unless otherwise footnoted.
er year .
ion, million bushels of throughput.
production, billion gallons of gasoline handled.
y is given as input material and production is adjusted to remove effect of a labor strike.
— „-«>§ a %
fill It
fill fi
"* 3 E a 0 T,
= •K s » % =
T, 5 §• s » - .
£ § o S .E S >.
ils-« It*
•= E " - a s s
S s = -s i « =
i The 298 metropolitan are
1 Capacity and production
i Capacity is calculated ass
' * Capacity is in million bu
> Not applicable.
' Capacity is in billion gall
' "Tons" applies to smelte
1 ' Capacity is in millions of
[p. 4--17]
-------
2452
LEGAL COMPILATION—Am
. tO • -tO
»
s
Illl
-T
u
[p. 4-18]
-------
GUIDELINES AND REPORTS
2453
Control Costs
(Millions of Dollars)
Pb Investment Annual
AND ASSOC'ATED COSTS
mission Control Level
[Percent)
HC F
L AND REDUCED EMISSION LEVELS
Areas]!
Associated E
Pb Part SOx CO
-ESTIMATES OF POTENTIA
[298 Metropolitan
ty of Emissions
of Tons per Year)'
) HC F
PROCESS SOURCES
Quant
(Thousand
SOx C(
_j »-
< 5
£ 0-
i
O
z
?
* 1
UJ >-
I
(/
CO- CO CO co
••*«-» CM
«* OO r-« O «S
10 o co o to
: . .oog ..... .Sffig
So oo oooocotototnoooi
OOO) u'ino>O>O)t7>OOOO0>
: : :SS- : : : : : " m °
O O OO ^rOi-tOO^HWl-COCM
2^;^r* SCJ'*to>OtDCgn'tS
^ in °* ""* CM CM "^
Ii Is Is 1* Is
-||s||sl|s||s||
II II 11 1 .1 II
iZ L_ iZ u- iZ iZ iZiZ LL. iZ
i
? I
I I £> i I
03 *- S CO Q.
00 ^ <5 "S- 75
as S S ^ S
5 JK v S 5
& -g I .1 «
< OO O O UJ
o o CM o co in
S^-t oo r- o •*
PI O O CO <-*<
o ^ co o o to
to t^ r<» r-> co o
0 0
mtno>iomo)c4CM^mior«>^H^4ooQOr9o
ooo
OOr-iOO^-OOi-iOOOOOOOOCO
o en c-J r-- «cr tomcMOtoo>to*tcMoomcM
^r>« CMCO P-ICM ^-« •*• m oo i— i »-• CM
o o o o o o o
•^ =C ^. -^ *-v. -^ '^
o><5«32«5c3oj<5c32 w«5S*<5SHSS2§
fS SS S3 3 S S3 S3 S
K K*n trt
-------
2454
LEGAL COMPILATION—ADR
0 -N
CM CM
ID CO
OO
oo oo oi
en en co
r- r- o
(O CD O)
o «•* o
3000 • • •
sss
CM r* CM
o •* r*.
«,o,m
0 0
e S S S S
3 CD (O CO to
Petroleum refineries 196i
Fiscal year 1
Fiscal year 1
Phosphate fertilizer 1967
Fiscal year 1
Fiscal year 1
Primary nonferrous
CM t-*
: :::: : g 8 g ::::::§»«> ::::::
* • •oor--ocr>r>«<0oo(0 • . . . •OP-HCA
• • -^roocsioiOi— i»--tor- • . . . • K ?g oJ
oo>^::::::::: O ^" ^ O
ss ss ss si si ss II ss
in V) tn vt & in MiT tn **- tn tf> lx.li- v> vi
LZ u. LZ iZ iZ LZ iZ LZ LZtZ LZ LZ
3
ii t j I I fl| i
E i % £ l 1
mission levels meet tti
to
I
O
c
m
•a
1
•a
TO
u_
•o
o
G"
¥
A
i
es (SOX), carbon monoxide (CO
or do not exist.
e shown.
hown.
'•s S s ^ 5
g S i < *
i The 298 metropolitan areas are de
' Emissions abbreviated are: particu
cable regulation (Appendix II) or that en
1 Estimates without implementation
' Estimates with implementation of t
' Not available.
[p. 4-19]
-------
GUIDELINES AND REPORTS
2455
g I _ = I
1 til-
1 l"i|
.•= i
'E — 3
I = S|
Us
s = —
i§!
C 0 °
i
= ^ g M £
= „ 1 1 1 1
„- g M N"/ o
> 5
~ c
> ™
:-H 11!
- OO O n"
I*
[Fiscal Year 1
Capacity >
(millions
of units)
nit of measurement
: i
j •
a S
^ 1
h« oo oo co r-«
If) CM CM O O
in o co o in
o o o o r*.
OO ^H O «t- O
S 88 SK
O O O O 1"-
CM i-i m o> co
«-« ^H CM
^H O O O O
oooo^-
CM <£> T-I CM
O O O «D ^t
** O r^ CM o
ssss
oo"
"i" : i
Asphalt batching (tons of pav
Brick and title (brick equivale
Coal cleaning (tons)
Cement (barrels)
Elemental phosphorus (tons).
Grain:
O O (O CO f-« O O i-* ^4<0rO<0-OOO~4O
CO ^ CM
•o to r-. m o o> CM ^H oooofomr^^i-cy)
^^t-Hi__(OCO^-« ^^ rS*r.*~r"
Oio?J2tocM^^cno (0 POC«J
^4 *^ ^H m Of) CM
! •;;=;; ; r
; I = ; s j ; : S
£oS,j='£'c a S "3 (5
O — ^ — J Q- O. O_ Q_ O£(OCO>
£
1—
i
1C
c
oa
s.
2
T3
0
i
-------
2456 LEGAL COMPILATION—AIR
B. Asphalt Batching
1. Introduction.—The road paving material commonly called
asphalt (more technically known as asphalt concrete, and often
referred to as hot mix asphalt paving in the industry) is a
heated mixture of crushed stone aggregate and asphalt. It is
most commonly produced by a batch process with an estimated
average production rate in the range of 150-200 tons per day.
Crushed stone or other aggregate is mixed and dried in a drying
kiln and fed into a pugmill where it is mixed with asphalt. This
hot mix is loaded into trucks for quick delivery to the work site
where it is applied while still hot.
2. Emissions and Costs of Control.—The asphalt batching
process emits pollutant emissions in the form of dust particu-
lates, emitted primarily by the aggregate drier and to a lesser
extent by the conveying, screening, weighing, and mixing equip-
ment. General industry practice is to combine the off gases from
the drier and the emissions from other process points as collected
in a ventline and send the combined gas stream through a cy-
clone dust collector. This results in approximately 80 percent
removal of dust, reducing the estimated average 25 pounds of
dust per ton of asphalt batched to 5 pounds per ton remaining
asuncontrolled emissions. The 1967 industry total of 452,000 tons
of particulate would increase to 571,000 tons in Fiscal Year 1976
at the same level of controls.
To meet the process weight rate standards assumed for this
study (see Appendix II), multiple cyclones have been stipulated
for plants of less than 100 tons per day capacity and veuturi
scrubbers with a 10 inch water gauge pressure drop for all
larger plants. The investment requirement estimated for these
controls is $15.4 million and the annual costs are $12.3 million,
beginning in Fiscal Year 1976.
3. Scope and Limitations of Analysis.—Data on the location
of plants were complete. However, detailed data on plant capac-
ities and production were incomplete; these data were esti-
mated by applying the known distribution of plant sizes in 38
[p. 4-21]
states to the known number of plants in the metropolitan areas.
Financial data by plant or firm were even more fragmentary
and similar estimating procedures were used. As a result, esti-
mated industry costs may be somewhat in error, probably under-
stated to a degree. The figures given are, however, felt to indi-
cate the order of magnitude of industry cost impact and to
-------
GUIDELINES AND REPORTS 2457
reflect a reasonable approximation of the control cost per ton
of product.
4. Industry Structure.—The asphalt batching industry, which
has 1,284 plants in the United States and 1,064 in the 298
metropolitan areas, is characterized by a large number of rela-
tively small firms, many with only one plant and others with
two or three plants. Most of the firms are small in comparison
with the giant firms of some of the other industries in this
study. Sales average close to $500,000 per year per plant. Most
firms are closely held and the profits of a typical firm apparently
support only one or a small number of owner-managers. Firms
are widely dispersed across the country, mostly close to urban
markets. Because of the necessity to deliver hot asphalt paving
to the job site, plants can serve only a very limited geographic
area. As a result, some plants have been "asigned to be mobile,
moving from job to job. Most installations can be shut down
and moved to new locations with relatively small cost. Resources
used in the process (sand, crushed aggregate, and asphalt) are
available almost anywhere.
5. Market.—The market for asphalt paving mixtures is largely
a function of road building and maintenance programs. Most
such projects are contracted on a competitive bid basis. In the
larger metropolitan areas, at least, this results in aggressive
competition among firms and acts as a limiting force on profits.
The degree of competition, size of the market, and growth in
number and size of firms vary considerably across the country
and from year to year, depending upon regional policies and
spending programs.
The chief competitor to asphalt paving is concrete. Asphalt
paving, however, is usually cheaper and simple to install, al-
though
[p. 4-22]
the concrete industry challenges asphalt on the basis of whole-
life cost, including maintenance. In minor markets such as
driveways, ready-mixed concrete firms are reported to have had
some success in competing with asphalt when special promo-
tional campaigns have been undertaken.
6. Trends.—It is expected that capacity and production in as-
phalt batching will grow at the rate of approximately 3.1 per-
cent per year through Fiscal Year 1976, continuing the pattern
of the 1960's. This would reflect a continued growth in govern-
ment expenditures for highway building, although shifts in
526-705 O - 74 - 8
-------
2458 LEGAL COMPILATION—Am
market location may be expected as construction of the inter-
state system slows and the emphasis shifts to secondary and
urban roads and airports.
7. Economic Impact of Control Costs.—This analysis indi-
cates that by Fiscal Year 1976 total annual pollution control
costs to the asphalt batching industry will run at the rate of
$12.3 million per year. For an estimated Fiscal Year 1976 pro-
duction of 227 million tons, this indicates an incremental cost of
only $0.054 per ton. Assuming approximately 800 firms in the
298 metropolitan areas, the estimated annual cost for the aver-
age firm would be $15,375. If a typical firm has sales of
$500,000 per year and profits before taxes of 12 percent of sales,
or $60,000, absorption of the increased cost would reduce profit
by one-third. These firms may be expected, therefore, to try to
raise prices by the full amount of the added cost. In a small
market where sales are almost entirely based on competitive
bidding, these price increases would be difficult to achieve unless
almost all firms are subject to the same cost changes. This
apparently would be true for most of the asphalt industry and
prices may therefore rise $0.05 to $0.06 per ton. Although this
is a small amount per ton of paving material, it does imply an
increase of approximately $12.3 million for the nation as a
whole as an equivalent increase in public expenditures.
[p. 4-23]
It is to be expected that all producers in a region or market
will tend to postpone installation of new equipment as long as
possible so as to avoid incurring this cost before competitors.
When regulatory orders force compliance, most firms will act at
the same time. If this occurs, there is little reason to anticipate
financial difficulties for the firms involved, except for those
whose sources of credit make it difficult to raise the funds for
an investment estimated to average approximately $19,000 per
single plant firm, in the circumstance that this investment will
not increase net profit.
[p. 4-24]
C. Brick and Tile
1. Introduction.—The brick and tile industry, represented by
Standard Industrial Classification (SIC) Code 2251, includes
those establishments primarily engaged in manufacturing brick
and structural clay tile. The processes involved in manufactur-
ing brick and related products include: grinding, screening, and
-------
GUIDELINES AND REPORTS 2459
blending of raw materials; forming; drying or curing; firing;
and cutting. After the clay has been mined, it is transported to
plant storage bins where the clays are blended to produce a
more uniform raw material, control color, and allow raw mate-
rial suitability for manufacturing a variety of units. Prepara-
tion of the raw material to produce brick and tile involves
crushing the clay to remove large chunks, followed by grinding.
The clay is then screened and the forming process begins. Water
is added to the clay in a pugmill, a mixing chamber containing
two or more revolving blades. The clay is then molded. Before
the burning process begins, excess water is evaporated in drier
kilns at temperatures ranging from 100° to 400° F for a period
of 24 to 48 hours, depending on the type of clay. Heat may be
generated primarily for drier kilns but it is commonly supplied
as waste heat from burning kilns. Burning is one of the most
specialized steps and requires 40 to 150 hours depending on kiln
type and other variables. Several types of kilns are used, the
chief types being tunnel and periodical. Natural gas, oil, or coal
is used as fuel, and temperatures up to 2400° F are used in
firing. Dried units are placed in periodical kilns permitting cir-
culation of hot kiln gases. In tunnel kilns, units are loaded on
special cars that pass through various temperature zones as
they travel through the tunnel. Drying occurs in the forward
section of the kiln, utilizing heat from the combustion gases to
preheat and dry the formed clay as it moves toward the firing
section. The heat required per ton of brick produced is 3-4 X
106 B.tu.'s. The cooling period requires 48 to 72 hours.
2. Emissions and Costs of Control.—Particulate emissions in
the brick and tile industry are in the form of dust from the
blending, storage, and grinding operations and
[p. 4-25]
off gases from the tunnel kilns. Particulates from blending,
storage, and grinding are minimized by sufficient moisture and
these emissions are well withir. the limits set by the particulate
standards. Particulates from the kiln are mainly a combustion
product and are a function of the fuel used.
Sulfur dioxide may be emitted if firing temperatures reach
2500° F or more or when using fuel containing sulfur. As stated
previously, firing temperatures do not normally exceed 2500° F.
In general, the fuel used is either oil or natural gas with accept-
able sulfur content. Emissions of sulfur dioxide, therefore, were
considered to be negligible.
-------
2460 LEGAL COMPILATION—AIR
Fluorides, emitted in a gaseous form, result from heating clay
containing fluorides. Data on the fluoride content of clay are
very sketchy. There is evidence that not all clay contains fluor-
ides and where there is no fluoride content, fluoride emissions
are no problem. This may occur on a region wide basis where a
number of plants use clay of similar or the same geologic origin.
In this analysis, in order to assess the impact expected, it is
assumed that clay contains fluorides in proportion to the aver-
age fluoride content of all clays and that fluoride emissions of
1.23 pounds per ton of clay result. At present, it is believed that
fluoride control is not practiced anywhere in the industry. On
this basis, fluoride emissions estimated for the 298 metropolitan
areas for 1967 were 15,600 tons with no controls. At the rate of
growth estimated for the brick industry, these fluoride emis-
sions would reach 20,800 tons in Fiscal Year 1976 without con-
trols.
Fluoride emissions can be reduced to very low levels by scrub-
bing the kiln gases with water. This also serves as a particulate
control method. For the purposes of this report a fluoride con-
trol standard requiring 95 percent removal efficiency is as-
sumed. A single cyclone scrubber can remove fluorides at an
efficiency in excess of 95 percent. This control level would re-
duce Fiscal Year 1976 fluoride emission to 1,000 tons and would
require investment and annual costs of $40.8 million and $11.6
million, respectively.
[p. 4-26]
3. Scope and Limitations of Analysis.—Detailed and accurate
data on firms in this industry and their plant production and
operations were not available during the preparation of this
report. Therefore, some of the statistics used may not be abso-
lutely accurate but it is believed that the analysis is sufficiently
valid to determine the economic impact of air pollution controls.
It was not possible, however, to relate projected costs directly to
the operation of typical firms or to regional market and price
variations.
The question of the fluoride content of the clay used in brick
making in the United States (discussed briefly in the previous
section) casts doubt on the control cost estimates made. It seems
probable that the fluoride emission estimates and the corre-
sponding estimates of control costs are exaggerated. The extent
of the exaggeration will not be known until more data are avail-
-------
GUIDELINES AND REPORTS 2461
able on the fluoride content of the various clays used by the
industry.
It. Industry Structure.—In 1967 there were 469 firms in the
United States with 301 in the 298 metropolitan areas. United
States production was 8,260 million brick and common brick
equivalents having a value of $342.1 million. Production within
the 298 areas was 5,910 million brick equivalents, 72 percent of
the United States total. These firms average about 57 employees
each and on the average produce 17.6 million brick and brick
equivalents having a value of $729,400. However, 120 of these
firms or about 25 percent had fewer than 20 employees indicat-
ing there are a number of marginal firms. Since 1958 85 firms
either have gone out of business or consolidated with other
firms. Consolidation has been the trend in this industry as in
other industries. Value of output in 1967 per production worker
was $15,700, which is low compared to other industries. This
has increased from $10,600 in 1958 and $13,200 in 1963.
Texas has more plants than any other state with 44 plants,
followed by Ohio with 41 plants; Pennsylvania is third with 33
plants.
[p. 4-27]
5. Market.—The construction industry purchases about 97
percent of the output of the brick and tile industry. The per-
formance of the brick and tile industry is therefore closely re-
lated to construction activity and more specifically to residential
construction. Production increases and decreases as residential
building increases or decreases. Even in residential construction
these products are a rather negligible cost. Their use is influ-
enced more by taste and the cost to install than by the cost of
the item itself.
Because of the weight and bulk of brick and tile products,
markets are regional in character rather than national. Intra-
product competition is as much on specialty items, style, fin-
ishes, and color as on price. There are enough firms in most
market areas to assure that prices cannot get out of line.
The major competitor to the industry is other building mate-
rials. Products. such as concrete, wood, aluminum, asbestos,
glass, steel and plastics compete in two ways. First, they com-
pete directly on initial price. Second and more importantly, the
compete on cost in place, a concept that includes both cost of
material and cost of installation labor. Such competition limits
the possibilities for brick and tile price increases.
-------
2462 LEGAL COMPILATION—AIR
6. Trends.—Between 1958 and 1967, the value of new public
and private building construction grew at an annual rate of 5.3
percent. During this same period, brick and tile shipments in-
creased by only 2.8 percent per year. The disparity in these
rates of growth primarily reflects the declining usage of brick.
The principal reason for the decline in the utilization of brick
appears to be the cost of brick-in-place. Between 1958 and 1969,
the cost of brick increased 22 percent compared with the 17
percent increase in the cost of all construction materials. Fur-
thermore, in the same period, the average wage rate for union
bricklayers increased at a rate over twice the rate of increase in
brick prices. Assuming no increase in the productivity of brick-
layers over the last decade (indeed, it is frequently alleged that
union restrictions have
[P. 4-28]
reduced the number of bricks per day a bricklayer can lay), a
cost index for brick-in-place shows about the same rate of
growth as the average wage rate for bricklayers. This results
because labor represents about 75 percent of the cost of brick-
in-place.
Thus, it would appear that any increase in the cost of brick
production which was passed on as a price increase of brick
would aggravate the trend away from the use of brick in new
construction and further limit brick production.
7. Economic Impact of Control Costs.—The analysis indicates
that by Fiscal Year 1976 total annual control cost to the brick
and tile industry in the 298 metropolitan areas will run at the
rate of $11.6 million per year. For an estimated 1976 production
of 6.6 million brick and brick equivalents, an incremental cost of
$1.76 per thousand brick is indicated. For the 301 firms in the
298 metropolitan areas, the estimated annual cost for the aver-
age firm would be $38,500. Few firms in this industry can afford
a cost increase of this nature entirely from profits. At the same
time because of the competitive position of brick among build-
ing materials and its declining market share, it is doubtful that
a cost increase as small as this could be passed on in full to
consumers as a price increase without further loss of markets.
Thus, while prices may be expected to rise, due to the added cost
of air pollution control, above the level they would otherwise
achieve by 1976, the rise is expected to be in the range of $1.00
to $1.10 per thousand brick instead of the full $1.76 average
annual cost.
-------
GUIDELINES AND REPORTS 2463
As with other industries, all the producers in a region or
market will avoid installation of pollution control equipment as
long as possible so as to avoid incurring this cost before compet-
itors. When regulatory orders force compliance, most firms will
act at the same time. When this occurs there is little reason to
anticipate financial difficulties for industry, except for those
firms that are already marginal. These few marginal firms can
be expected to merge with others or close.
[p. 4-29]
D. Coal Cleaning
1. Introduction.—Coal cleaning consists of removing some of
the undesirable materials from raw mine run coal. These mate-
rials consist of sulfur compounds, dirt, clay, rock, shale, and
other inorganic impurities. Both bituminous and anthracite coal
are cleaned. Cleaning improves the quality of coal by increasing
the B.t.u. output per pound and by reducing ash content. It is
accomplished by washing the coal with air or water. Approxi-
mately 21 percent of wet washed coal is thermally dried. Air
cleaning is accomplished by the use of pneumatic cleaners, while
drying is accomplished predominantly with either flash driers or
fluidized-bed driers.
2. Emissions and Costs of Control.—The major air pollutant
in the coal cleaning industry is particulates in the form of dust
from either flash driers, fluidized-bed driers, or pneumatic
cleaners.
Available data on the current level of control indicate that 87
percent of the flash and fluidized-bed driers and 16 percent of
the pneumatic cleaners are controlled at an efficiency of 80 per-
cent. The composite level of control is about 58 percent when the
processes are weighed according to the quantity of coal handled.
Thus, aggregate emissions of particulates in 1967 totaled 64,700
tons. By Fiscal Year 1976, aggregate emissions at 58 percent
controls could be expected to total about 92,300 tons of particu-
lates. To obtain a composite level of 93 percent control in Fiscal
Year 1976, flash driers will have to be controlled to an average
level of 93.2 percent efficiency, fluidized-bed driers to an average
level of 97.8 percent efficiency and pneumatic cleaners to an
average level of 94.5 percent. Aggregate annual emissions of
particulates can then be expected to be reduced to approxi-
mately 14,100 tons in Fiscal Year 1976.
-------
2464 LEGAL COMPILATION—Am
Because of the coal dust content of the off-gases from coal
cleaning, a fire and explosion hazard exists. Because of this
explosion hazard, wet scrubbers constructed of mild steel rather
[p. 4-30]
than baghouses are preferred as control devices. A 15 inch w.g.
venturi scrubber was selected as the control device for the flui-
dized-bed drier and a 10 inch w.g. venturi was assumed for both
the flash drier and the pneumatic cleaner. These pressure drops
will provide the efficiencies required. The investment require-
ment would be $13.1 million and annual costs in Fiscal Year
1976 would be $5.3 million.
3. Scope and Limitations of Analysis.—Although there is a
relatively large number of coal cleaning plants in the United
States, detailed data on plant locations, capacities, and produc-
tion are available. Metropolitan area totals for capacities and
production were obtained from these data. However, it was not
possible to determine the coal cleaning process used in every
case, so average values were applied to the regional production
and capacities to obtain volumes of emissions. Growth estimates
were estimated from past rates of increase in production. Cost
to control was based on cost to control a model plant of average
size. Financial data and market information for the industry
are fairly complete.
4. Industry Structure.—Coal cleaning is a part of the process
of improving the quality of raw coal for market. It is usually
done by the producer, normally close to the mine to avoid trans-
porting waste rock.
In 1967, the 667 coal cleaning plants in the United States had
a capacity of 370 million tons. Production totaled 349.0 million
tons and had a value of shipments of $1.5 billion. Cleaning
plants are located in 20 states with over 90 percent located east
of the Mississippi. Sixty-nine percent of the total plants are
located (in order of importance) in West Virginia, Pennsyl-
vania, and Kentucky. Virginia, Illinois, and Ohio have 35 or
more plants each and with Alabama with 20 plants, make up
more tha 25 percent of the total number of plants.
Only 256 of the 667 plants are in the 298 metropolitan areas,
and they account for only 37.6 percent, 37.5 percent, and 40
percent of total industry capacity, production, and value of ship-
ments, respectively.
[p. 4-31]
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GUIDELINES AND REPORTS 2465
5. Market.—The market for coal and thus the market for coal
cleaning is largely a function of the production of electric power
and the output of blast furnaces and basic steel. Almost 30
percent of the industry output is utilized for generating electric-
ity. Blast furnaces and basic steel production utilize an addi-
tional 22 percent. Exports amount to approximately 2 percent
of output, mostly of metallurgical coal. Besides coal mining,
which purchases 19 percent of coal production, no other indus-
try utilizes as much as four percent of the remaining 27 percent
of industry output.
Even though the electric power industry and the steel indus-
try utilize over half of coal production, coal makes up only about
four percent of the value of inputs into the electric power indus-
try and 2.3 percent of the inputs into steel production. These are
exceeded, but only slightly, by one other industry—the hy-
draulic cement industry—where about 5.5 percent of the input
is coal.
While coal does make up a rather small proportion of the
inputs into these industries, it is a rather important input espe-
cially for steam electric generation. For this reason many of
these industries own coal companies to provide their supplies.
Long term contracts, some as long as 20 years, are also used for
this purpose.
Even though coal companies are owned by other industry or
utilities, most sell at least some of their output in the open
market. This practice, together with the number of independent
coal companies, maintains competition among firms. In addition,
coal is in competition with other fuels—gas, oil, nuclear power,
and electricity (which is often produced from coal). All this
serves to limit profits.
In spite of its bulk, coal moves to a limited extent in the
export market. The United States is a net exporter, but the
extent of foreign trade is not great enough to have a major
impact on domestic supply. However, it does tend to push prices
up, since export prices may be as much as 30-50 percent above
United States prices.
Coal, along with other fuels, is currently enjoying an expand-
ing market. This is placing considerable pressure on production
to meet the growing demand.
[p. 4-32]
6. Trends.—It is expected that capacity and production will
grow through Fiscal Year 1976 at 4.8 percent per year. The
proportion of coal cleaned has also been steadily increasing. In
-------
2466 LEGAL COMPILATION—AIR
1927, the percentage of total coal cleaned was 5.3 percent. By
1952, 49 percent of production was cleaned and by 1965 the
proportion was 65 percent. The rising trend in coal cleaning can
be expected to continue as poorer seams are worked, more strin-
gent sulfur oxide limitations are established, and shipping costs
increase.
7. Economic Impact of Control Costs.—The indicated FY
1976 total annual cost of control to the coal cleaning industry
will run at the rate of $5.3 million per year. For an estimated
Fiscal Year 1976 production of 167 million tons, this indicates
an incremental cost of $0.03 per ton. For the 256 plants in the
cement rock, limestone, clay, shale, and/or other materials,
age plant would be $19,500. Plants of the average size indicated
here (annual production of about 650,000 tons) could be ex-
pected to have no trouble absorbing a cost increase of this size.
Only firms already marginal would be affected. However, be-
cause of the nature of coal as a production factor in other goods
or services, and the current demand for all fuels, a price in-
crease of $0.03 per ton could very easily be passed on to buyers.
The current open market price for coal is $4.40 per ton f.o.b.
the mine. A $0.03 per ton cost is approximately one percent.
This increases the price of steel not more than $0.025 per ton,
which is insignificant compared to a current average price of
$183.00 per ton.
[p. 4-33]
E. Cement
1. Introduction.—Portland cement accounts for approxi-
mately 98 percent of cement production in the United States.
All portland cement is produced in either the wet or dry proc-
ess, the chief difference being whether the prepared ingredients
are introduced into the cement kiln as a dry mixture or as a wet
slurry. The wet process is used to produce approximately 58
percent of the cement. Essentially, cement is made by quarrying
298 metropolitan areas, the estimated annual cost for the aver-
which are finely ground and mixed. The prepared mix is burned
in a long sloping kiln into cement clinker, which is then ground
into a fine powder and sold in bulk or bagged.
2. Emissions and Cost of Control.—Dust arising from crush-
ing, grinding, and materials handling processes is universally
controlled at quite high efficiencies because such controls recover
valuable products. Kilns also emit large amounts of particulates.
-------
GUIDELINES AND REPORTS 2467
These are generally not fully controlled with the exception of
plants built since 1960. Older plants, which account for 76 per-
cent of the capacity of the industry, need additional control
equipment to meet standards for control of particulate emis-
sions. It is estimated that 13 percent of all cement plants will
require completely new systems—either fabric niters or electro-
static precipitators—and that the remaining older plants have
equipment in place that can be improved in efficiency to meet
the control standard. Thus, cement plants have been grouped as
follows: 24 percent for which no additional control is specified
and therefore no additional cost; 63 percent now partially con-
trolled, for which additional equipment and cost are indicated;
and 13 percent for which new control systems are indicated and
for which the incremental control cost will be greatest.
Particulate emissions from kilns in plants within the 298
metropolitan areas are estimated to have totalled 239,000 tons
in 1967, representing an overall control level of 96 percent. This
[p. 4-34]
industrywide control level is based on the assumption of 95
percent control in pre-1960 plants and 99 percent control in all
plants built since 1960. Expanded production in pre-1960 plants
would be estimated to increase total particulate emissions to
280,000 tons by FY 1976 if the same control level were main-
tained. With the installation of new or more efficient fabric
filters for dry process kilns and electrostatic precipitators on
wet process kilns, an industry control level of 99.7 percent may
be achieved, reducing total emissions for Fiscal Year 1976 to
16,100 tons of particulates.
These controls would require an investment of $110 million
and Fiscal Year 1976 annual costs of $30 million.
3. Scope and Limitations of Analysis.—This analysis was
based on data available from government, trade, and financial
reporting sources. Financial data were available only for a lim-
ited number of firms; thus, the financial impact of air pollution
control costs had to be stated in somewhat general terms. Many
firms engage in other business activities, such as the sale of
readymix concrete or cement blocks, or are part of conglomer-
ates. Without more detailed information, it has not been possi-
ble to estimate the portion of revenues, costs, profits, or taxea
attributable to cement alone in such firms. For this and similar
reasons, the relationships assumed for the financial variables
may be open to question.
-------
2468 LEGAL COMPILATION—AIR
4. Industry Structure.—a. Characteristics of the Firms.—The
cement industry is estimated to have been represented by 58
firms and 178 plants in the United States in 1967. Of these, 50
firms and 138 plants are identified as having been in the 298
metropolitan areas. The structure of the cement industry may
be described in several ways. Approximately 40 percent of the
firms in the industry operate more than one plant and ap-
proximately half of those firms have productive capacity of
over 10,000,000 barrels of cement per year. The purpose of
multiple plant operation is, apparently, to achieve
[p. 4-85]
broader market coverage and therefore greater financial sta-
bility by lessening dependence on any one local demand pat-
tern rather than to achieve significant economies of scale.
The trend in recent years has been to larger kilns, computer-
ized operation, and improved integration of raw mill, kiln,
clinker grinding, and associated storage and materials han-
dling equipment. These factors have produced a steady in-
crease in efficiency of operation but have not necessarily been
accomplished in larger plants. Plants built between 1960 and
1967, for instance, ranged in capacity from 1 to 8.5 million
barrels per year. The range of capacities for all plants listed
in operation in 1967 was from 0.4 to 16,000 million barrels
per year, with the average plant having a capacity of ap-
proximately 3 million barrels per year.
Since raw materials for cement production are widely dis-
tributed throughout the country, cement plants tend to be
located close to major markets. Normally, cement is not
shipped more than 200 to 300 miles from the plant, because
transportation costs tend to price a firm out of more distant
markets. In recent years, however, some firms have developed
distribution terminals at locations that combine cheap water
transportation with access to major urban markets. Although
these firms have apparently been successful in thus extending
their marketing territory, most firms continue to sell in rela-
tively small markets. Imports and exports of cement account
for less than 5 percent of the United States market and are
significant only in the markets on the Atlantic Coast.
b. Operating Characteristics.—The statistical summary in
Table 4-4 gives United States capacity for the industry as
515 million barrels per year. The figures given indicate that
the industry operated at 72.6 percent of capacity in 1967. In
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GUIDELINES AND REPORTS 2469
fact, usable capacity was probably 2-3 million barrels less
and utilization slightly higher. Operation at 85-90 percent of
capacity tends to
[p. 4-86]
produce maximum profits, but the industry has tended to
operate at between 70 and 80 percent of capacity over the
past ten years, due to a typical pattern of heavy investment
whenever demand seems to be catching up to supply. Excess
capacity and depressed profits are therefore chronic.
c. Resources.—The raw materials used in manufacturing ce-
ment are abundant and widely distributed throughout the
country. Most companies own their sources of supply and
have ample reserves, thereby stabilizing materials costs. The
costs of fuel, transportation, and labor are the other major
cost variables. The rise in these costs in recent years coupled
with an inability to raise price proportionately accounts for
the generally below average profit performance of this indus-
try.
Large quantities of fuel are used in operating a cement
kiln, a modern installation requiring approximately 950,000
B.t.u.'s per barrel of clinker produced. The fuel may be coal,
oil, or natural gas, with gas providing a small cost advantage
over the other two at present prices. Many plants burn coal
and this use accounts for approximately 5 percent of in-
dustrial use of bituminous coal in the United States.
Transportation is a major cost factor as is typical of all
products with a low value-to-bulk ratio. In the past, cement
manufacturers maintained a basing point pricing system
which tended to eliminate price competition due to freight
costs from different mill-to-market distances. Since the elimi-
nation of this system as a result of Federal antitrust action,
individual firms have continued to absorb transportation costs
in varying degrees in order to meet competitors' prices and
extend their market range. Under such conditions, transpor-
tation costs tend to place a definite limit on market size for
each plant.
Labor accounts for approximately 35 percent of total cost.
Rising wages in recent years have contributed to the adverse
profit position of the industry.
[p. 4-37]
5. Market.—Portland cement is a standardized product and
competition among sellers depends on quite small price differen-
tials within a clearly defined price pattern, plus service. Most
-------
2470 LEGAL COMPILATION—AIR
customers can choose among a number of cement producers and
price shading and partial freight absorption by the producer
may be necessary to clinch a sale. This competitive pressure
tends to hold prices down and puts considerable emphasis on the
firm's ability to deliver quantities to customers at destinations
and on schedules meeting the customers' preferences. Those
firms with newer equipment and most efficient operation may be
able to offer marginal price concessions sufficient to keep sales
at levels near optimum operation. Weaker firms may not be able
to shade prices in order to keep sales volume up without reduc-
ing profit margins significantly. This competitive pressure has
caused many firms to close their less efficient plants or to mod-
ernize them with new equipment and computerized controls.
Cement sales are historically closely related to construction
activity, measured by the value of new construction put in place.
It is anticipated, therefore, that the performance of the con-
struction industry will set the general tone of the performance
of the cement industry.
Cement purchases represent about one percent of the inputs
of the construction industry based on the 1963 input/output
relationship. The distribution of cement sales by purchasers for
1963 were:
Percent
Ready-mixed concrete producers 61
Concrete product manufacturers 13
Highway contractors 10
Building materials dealers 8
Other contractors 4
Miscellaneous users (including government) 4
6. Trends.—a. Capacity and Production.—Over-capacity was
a chronic problem in the cement industry during the early
1960's. It appears that the
[P- 4-88]
industry achieved a somewhat better balance between capacity
and sales in the later 1960's and this is expected to continue
through the 1970's. Capacity is projected to increase at an
average rate of 2 percent per year through 1976. It is antici-
pated that this capacity will be utilized at close to the recent
average of 78 percent, implying a growth rate of 2 percent for
production as well.
It is probable that the present trend toward use of more
economical longer kilns and the addition of computer control
systems will continue. This will lead to the closing of some
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GUIDELINES AND REPORTS 2471
older plants and remodeling of others, resulting in only a very-
gradual change in the industry structure.
b. Price, Sales and Profits.—Prices declined slowly from a
1960 average level of $3.25 per barrel at the mill to $3.15 per
barrel in 1966 but have risen gradually since then. Less than
optimum operating ratios, a slowly growing market and com-
petition with other building materials will probably keep
prices rising at a slow rate through 1975. Sales are expected
to increase at an average rate of 3.5 percent per year. Given
the 2 percent per year increase in production indicated above,
this would indicate a price increase of 11/2 percent per year.
Profits may be expected to be stable, therefore, at or near
their recent levels and somewhat below the average return for
manufacturing firms.
7. Economic Impact of Control Costs.—a. Industry Compos-
ite.—As was noted in paragraph 2 above, plants built since
1960 have, almost without exception, been equipped with high
efficiency control equipment. It is the older plants, therefore,
that are a source of particulate emissions and upon which will
fall the new cost of air pollution control. It is estimated that
by 1967 the cement industry had already undertaken control
costs equal to annual costs of $18 million.
[p. 4-89]
b. Impact on Firm.—The impact of the additional cost of
air pollution control on the normal cost pattern of a firm can
be shown by considering several "model" plants, constructed
to represent typical operating patterns. The firms described
here are not actual plants, but are based on known conditions
in the industry.
Plant A Plant B
Capacity (thousands of barrels per year)
Kilns (number and size)
Construction cost, 1958
Production, 1967 (thousands of barrels per year)
Average mill price per barrel
Sales
Net income before tax
Business income tax
Net income after tax
Profit barrel
Annualized air pollution control cost, total:
If wet process
If dry process
Annualized air pollution control cost, per barrel:
If wet process
If dry process
1,200
1-400 ft.
J12 mil.
871
3.17
2,761,000
414,000
179,000
235,000
0.2698
90,320
78,272
0.1037
0.0899
3,00V
1-550 ft
(12 mil.
2,178
3.17
6,904,000-
1,156,000
500, ooa
656,000
0.3011
210,800
188.680
0.0968
0.0866
-------
2472 LEGAL COMPILATION—AIR
The relationships shown for Plant A and Plant B above
indicate the magnitude of air pollution control costs for a
small and a large plant. There are a large number of single
plant firms in this industry and these figures indicate the
impact which may be expected for such firms.
The costs shown are for firms or plants in the 13 percent of
the industry for which completely new equipment is indi-
cated. That is, they represent the full cost of air pollution
control. Presumably, 24 percent of the plants in the industry
are already absorbing equivalent costs. It appears that these
plants, being newer, are more efficient in their operation and
so able to sell at a competitive price.
[p. 4-40]
The economies of scale appear to accrue at the plant level
rather than as a result of multiple plant operation. Multiple
plant firms may be approximated by multiplying individual
plant costs by the number of plants.
c. Demand Elasticity and Cost Shifting.—To the extent
that the demand for cement is derived from the demand for
public and private construction, which is not highly elastic
with regard to price, the overall demand for cement would
not be very sensitive to small price changes. However, in
recent years cement has had a fairly advantageous price posi-
tion relative to competing building materials. An industry
wide increase in price by the full amount of the control cost
indicated for firms that must install new equipment might be
expected to change the position of cement adversely relative
to substitutes.
An attempt by some firms to raise prices as a means of
shifting control costs would almost certainly lead other firms
to move into the market. The market for any one firm is
usually small geographically. Selective price increases in some
local markets will encourage large firms to expand their sell-
ing radius.
Under these circumstances, it is to be expected that those
firms faced with the full additional cost of control will be
unable to shift more than a small fraction of the added cost
into price. Those firms faced with additional but smaller costs
. may, to the extent that they are larger and more efficient, be
better able to raise prices, but not enough to recoup the entire
increase in costs. •
-------
GUIDELINES AND REPORTS 2473
d. Effect on the Industry.—Since it appears that the added
cost of air pollution control will fall on the older, less efficient
firms, it is expected that the result may be a hastening of the
trend now operating in the industry to replace or rebuild
older plants.
[p. 4-41]
In no case does it appear that these costs alone will
cause a firm to fall. It is probable, however, that the
growth rate of the industry may be slowed slightly and that
profit margins may continue to be somewhat below the aver-
age in manufacturing through Fiscal Year 1976. Of course, a
major change in demand, such as that resulting from large
scale implementation of "Operation Breakthrough" housing
construction using precast concrete, would stimulate produc-
tion and make larger price increases more likely.
[p. 4-42]
F. Elemental Phosphorus and Phosphate Fertilizer
1. Introduction.—a. General.—The production of elemental
phosphorus and the manufacturing of phosphate fertilizer are
normally considered to be two different industries. They are
joined in this analysis because both products are produced
from the same raw material with interrelated processes and
air pollution problems. Some of the firms involved are produc-
ers of both products and the market structures are closely
connected. Each industry is described and analyzed and the
economic impact of control costs is evaluated in terms of the
overlapping market and business structure.
All phosphorus products are derived from phosphate rock.
About 40 million tons of rock were mined in the United States
in 1967. Thirty million tons were processed domestically with
the remainder exported. About 13 percent of the domestic
output appeared as normal superphosphate, 15 percent was
produced as elemental phosphorus, 39 percent was produced
as wet process phosphoric acid, about 3 percent was produced
in the form of animal feed, and the remaining 30 percent of
the rock was treated with wet process phosphoric acid to
produce triple superphosphate.
b. Elemental Phosphorus.—Elemental phosphorus is pro-
duced in this country by smelting a mixture of phosphate
rock, silica and a carbonaceous reducing agent (such as me-
-------
2474 LEGAL COMPILATION—AIR
tallurgical coke) in an electric furnace. Submerged electric
arcs in the furnace produce high temperatures which cause
the reduction of the phosphate rock, releasing phosphorus,
carbon monoxide and other reaction products, including fluor-
ides. These gases emerge from the furnace and pass through
electrostatic precipitators for the removal of dust. The
cleaned furnace gases then discharge ito a condenser, con-
tacting sprays of water
[p. 4-43]
maintained at a temperature above the melting point of phos-
phorus (111°F). Phosphorus is condensed from the gas
stream and collects below a water layer in a pump. The cooled
gases, principally carbon monoxide, are recycled and burned
for heat recovery.
c. Phosphate Fertilizer.—The phosphate fertilizer industry
as denned for this report includes all plants which produce
wet process acid (both regular and concentrated), normal
superphosphate, triple superphosphate, and diammonium
phosphate. Fertilizer plants may produce one or all of these.
The most common process for the production of wet process
acid involves the digestion of ground, calcined phosphate rock
with sulfuric acid. The acid is then separated from the solids
by filtration. Normal superphosphate is produced as a
screened material, either as a continuous or batch process, by
acidulating ground and dried phosphate rock containing 31 to
35 percent P205 with sulfuric acid. Triple superphosphate is
fertilizer produced by the reaction of natural phosphates with
wet process phosphoric acid. The product contains 40 percent
or more of phosphoric acid. Ammonium phosphates are now
the most popular form of phosphate fertilizers because of
high nutrient content and low shipping cost per unit of P205.
All processes for the manufacture of diammonium phosphate
fertilizer from wet process phosphoric acid and ammonia are
essentially the same in principle. Wet process phosphoric acid
of about 40-42 percent P205 equivalent is partially neutral-
ized by anhydrous gaseous ammonia. The resultant slurry is
then fed into an ammoniator-granulator drum where final
ammoniation and granulation take place simultaneously and
additional water is removed. The moist granules are dried,
screened, cooled, and conveyed to bulk storage.
[p. 4-44]
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GUIDELINES AND REPORTS 2475
2, Emissions and Costs of Control.—Particulate or gaseous
fluorides are released in almost all of the processes used in
reducing phosphate rock and manufacturing products from the
rock. Particulates and gaseous fluorides frequently are emitted.
a. Emissions From Phosphorus Production.—There are
three main sources of fluoride emissions in the production of
elemental phosphorus: feed preparation, evolution of gas
from the furnace, and evolution of gas from the molten slag.
Fluorides evolved during the furnace operation are effectively
scrubbed in the spray condensers. Emissions from the prelim-
inary feed preparation and from the molten slag operation
are also controlled to a greater or less extent in each plant by
scrubbing with water. However, it is estimated that, on the
average, these controls achieve only 85 percent removal
efficiency. The remaining uncontrolled emission rate, is 18
pounds of fluoride per ton of phosphorus. For the phosphorus
plants within the 298 metropolitan areas, this results in esti-
mated 1967 emissions of 2,400 tons of fluorides.
By applying additional scrubber capacity to the feed prep-
aration and slag tapping off-gases, the overall control effi-
ciency for fluoride removal can be increased to 98 percent.
By Fiscal Year 1976, without additional scrubber capacity,
emissions within the 298 metropolitan areas would reach
3,340 tons of fluorides. With the additional controls, these
emissions would be reduced to 334 tons.
Particulate emissions occurring during feed preparation
and charging of the furnace are normally controlled to 80
percent by use of dust collectors. Installation of wet scrubbers
following the dust collectors can achieve a control level of
99 percent, meeting the standard adopted for this study.
[p. 4-45]
The emissions of particulates in 1967 are estimated for
plants in the 298 metropolitan areas as 2,400 tons. Growth of
the industry would increase these emissions to 3,340 tons by
FY 1976, which would be reduced to 200 tons of particulates
by installation of controls.
b. Fluorides From Fertilizer Production.—In the produc-
tion of normal superphosphate, there are potential fluoride
emissions from both handling and preparation of the rock
from the aciduation and curing steps. During rock handling
and preparation, fluorides are chemically bound to the dust3
generated. Even during the calcining step, temperatures are
-------
2476 LEGAL COMPILATION—Am
too low to release gaseous fluorides. In almost every case,
dusts are very well controlled, usually with fabric niters and
meet established standards. During the aciduation and curing
steps, gaseous fluorides are emitted. Current control practice
limits these emissions to about one pound of fluoride per ton
of P20S with various forms of wet scrubbers. This is approxi-
mately a 99 percent control level. The standards adopted for
this analysis, however, require a final control level of 99.9
percent for production of superphosphate. Therefore, addi-
tional wet scrubbers, in series, are required. The same situa-
tion occurs in the handling and processing of rock in the
production of wet process phosphoric acid which require addi-
tional controls in the same way. In addition, gaseous fluorides
are evolved in the manufacture and concentration of phos-
phoric acid. Excluding the fluorides emitted from slime ponds,
the industry presently controls fluoride emission from the
digesters, vacuum coolers, and evaporators to a level of about
98 percent, resulting, on the average, in emissions of 0.2
pounds of fluoride per ton of P20,-,. Final controls of approxi-
mately 99.8 percent are required to meet the standard for the
manufacture and concentration of phosphoric acid; therefore,
the installation of additional wet scrubbers is indicated.
[p. 4-46]
Slime ponds serve phosphoric acid plants as storage and
settling sites for solid and liquid effluents. Fluoride emissions
are produced from these ponds. Emissions from the ponds are
highly variable ranging from 0.08 to 0.80 pounds per ton of
P205 per day. At present not enough is known of the factors
contributing to the range of emissions to allow reasonable
control cost estimates to be made for the ponds.
The concentration of wet phosphoric acid in vacuum con-
centrators does not lead to any significant fluoride emissions
due to the automatic absorbtion of these gases in the process
liquids. The emissions of fluoride from the submerged com-
bustion process production of concentrated phosphoric acid
are also minimal.
In the production of triple superphosphate, emission of
fluoride does occur during the chemical reaction and drying
steps. At the current average industrial control level of about
99 percent, an estimated 0.16 pounds of fluoride per ton of
P205 are emitted. To meet the standards, a control level of
-------
GUIDELINES AND REPORTS 2477
99.9 percent will be required. Additional wet scrubbers are
again required to bring the emission level down to 0.016
pounds per ton of P205.
In the production of diammonium phosphate, fluoride emis-
sions occur both during chemical reaction and during drying,
although to a lesser extent than from triple superphosphate
or wet process phosphoric acid. At a current estimated con-
trol level of 96 percent, emissions of about 0.10 pounds of
fluoride per ton of P205 are required. Again, additional wet
scrubbers will be necessary.
Total fluoride emissions in 1967 are estimated to have
amounted to 612 tons for all phosphate fertilizer plants in the
298 metropolitan £ieas. Industrial growth would increase
these emissions to 1,520 tons by FY 1976 at the same level of
control. Installation of the controls specified for this analysis
would reduce FY 1976 emissions to 134 tons.
[p. 4-47]
In summary, for the phosphate fertilizer industry the 1967
level of fluoride control was approximately 98 percent. By
implementing the controls specified, the industrywide control
level will reach 99.8 percent by Fiscal Year 1976.
c. Control Costs.—Total investment in the eight elemental
phosphorus plants located in the 298 metropolitan areas is
estimated at $6,600,000 by Fiscal Year 1976, including allow-
ance for growth in capacity to that date. With full implemen-
tation of controls by Fiscal Year 1976, total annualized cost to
the segment of this industry effected will be approximately
$3,100,000 per year. Equivalent investment and annualized
cost for fertilizer producers by Fiscal Year 1976 are $32,100,-
000 investment and $10,000,000 annually.
3. Scope and Limitations of Analysis.—Producers of elemen-
tal phosphorus and of phosphate fertilizer have been grouped
together for this analysis because all phosphorus producers are
also fertilizer producers. The economic impact is, therefore, not
separable. The technical and cost factors, however, are different
for the two product classes and were analyzed and are reported
as separate industries.
The larger firms in this industry produce many products and
phosphorus and phosphate fertilizer contribute only a small
part of their revenues. It was not possible to determine the role
of these products in the overall product and cost mix of firms
for which data were available. Some small firms apparently
-------
2478 LEGAL COMPILATION—AIR
produce only fertilizer, but no published records were available
for such firms. The analysis of economic impact of control costs
had to be based, therefore, upon the general conditions and
trends of the chemical and fertilizer industries. It does not
appear that more detailed data would cause a change in the
major conclusions reached in this report.
4. Industry Structure.—Production of elemental phosphorus
is concentrated in six private firms, with the Tennessee Valley
Authority also a significant
[p. 4-48]
producer (approximately six percent of industry capacity). One
chemical firm accounts for 35 percent of the industry and the
three largest firms have 75 percent of productive capacity. Each
of the producers of elemental phosphorus is also a producer of
phosphoric acid and one or more of the types of finished ferti-
lizer. All but two of them sell phosphate rock to other users. A
small number of firms produce phosphate rock for sale to other
users, but do not produce phosphorus products themselves.
There are 80 firms, in addition to the producers of elemental
phosphorus, that are producers of phosphate fertilizers, 56 of
them producing normal superphosphate, 18 producing triple
superphosphate, and 44 producing ammonium phosphates. The
production of phosphate fertilizers is not characterized by domi-
nance of one or two firms, although there are very great varia-
tions in firm size ranging from single-plant firms of 15,000-
20,000 tons annual capacity to firms with more than 20 plants
and capacity in excess of 125,000 tons per year.
Given the present pattern of industrial uses of elemental
phosphorus, sales of this product appear to be stable and to
provide an adequate profit to the firms- producing it. Phosphate
fertilizer, on the other hand, has been characterized by below
average returns on investment during the past decade and has
suffered from chronic over-capacity. It has attracted investment
from a number of chemical and petroleum firms that had hoped
fertilizer would provide a profitable outlet for materials such as
sulfuric acid and at the same time provide diversification into
the agricultural sector of the economy. A number of farm coop-
eratives also undertook phosphate fertilizer production in order
to provide a stable and economic supply of one of the ingredi-
ents of the drymixed fertilizers they offer farmers. These farm
cooperatives had rather mixed success and have not always been
a stabilizing influence in the industry.
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GUIDELINES AND REPORTS
2479
Some rationalization of the industry appears to have begun
in the last year or two. Shifting demand from normal superphos-
phate to triple superphosphate and diammonium phosphate have
induced shutdowns of some of the older normal superphosphate
capacity
[p. 4-49]
and some smaller companies have sold out to other firms or left
the industry. Also, more emphasis is being given to marketing
and to solving chronic problems of storage, transportation, and
distribution.
Further statistics for the two industries are shown in Tables
4-8 and 4-9.
TABLE 4-8.—1967 STATISTICAL DATA ON THE ELEMENTAL PHOSPHORUS INDUSTRY
United States Metropolitan Areas
Number of Plants 13 8
Cipacity (thousands of tons) 658 290
Production (thousands of tons) 587 279
Value of shipments (millions of dollars) 200 140
TABLE 4-9.—1967 STATISTICAL DATA ON THE PHOSPHATE FERTILIZER INDUSTRY
United States Metropolitan Areas
Number of plants 179 147
Capacity
Wet process acid (1,000 tons PiOs:
Ortho 5,860 4,830
Super 316 149
Ammonium phosphate (1,000 tons gross weight) 7,430 6,30
Normal superphosphate (1,000 tons gross weight) 4,690 3,840
Triple superphosphate (1,000 tons gross weight) 3,640 3,450
Production:
Fertilizer (thousands of tons) 4,700 4,100
Phosphoric acid (thousands of tons) 5,190 4,200
Value of shipments (millions of dollars):
Fertilizer 976 854
Phosphoric acid 565 455
[p. 4-50]
5. Market and Trends.—Approximately 85 percent of the pro-
duction of elemental phosphorus is sold to industry for a wide
variety of uses. Almost 75 percent of phosphate output is used
for fertilizer and approximately 20 percent goes to industrial
purchasers. Fertilizer production, therefore, is dominant in this
industry. However, industrial uses are increasingly important,
as is shown by the fact that production of phosphate rock has
more than doubled during the 1960's while fertilizer production,
although showing a steady growth, increased only by approxi-
-------
2480 LEGAL COMPILATION—AIR
mately 20 percent. Until 1950, normal superphosphate was al-
most the exclusive source of phosphate in fertilizer. Its use,
however, has declined over the years and amounts to only about
20 percent of the total phosphate market today.
The fertilizer market is quite competitive. Marketing is done
by major producers serving national or regional markets, by
retailers of farm and garden supplies, and by producers of
mixed fertilizers who buy their ingredients from primary pro-
ducers. Increasingly knowledgeable farmers operating large-
scale farms have increased market influence and demand ferti-
lizers that have analyses tailored to their individual needs. This
competition tends to hold prices close to the minimum necessary
to maintain adequate supplies. It also has meant that buyers of
substantial quantities can negotiate significant discounts from
list prices.
Average prices climbed slowly during the 1960's, but dropped
in the last two years of the decade. It is expected that they will
resume their upward trend in the 1970's, rising much more
slowly than other industrial prices. Prices tend to be markedly
higher in the Midwest than on the East Coast, primarily be-
cause of added transportation costs. This has led to extensive
use of triple superphosphate and diammonium phosphate in
most of the major farm areas, since these contain two to three
times as much plant nutrients per ton as normal superphosphate
and therefore incur lower transportation costs per unit of value.
The difference is shown by comparison of the cost to the aver-
age farmer in terms
[p. 4-51]
of nutrients applied to the soil. Government studies have shown
[U.S. Industrial Outlook, 1969. BDSA, p. 142] that a ton of P205
costs a farmer, on the average in 1969, $163 as triple superphos-
phate, $216 as normal superphosphate, and only $149 as am-
monium phosphate. Cost of production at the plant is somewhat
lower for the newer triple superphosphate and diammonium
phosphate processes, but not as much as this differential of ap-
plied cost. The greater share of the differences appear to result
from economies in shipping the more concentrated fertilizers.
6. Economic Impact of Control Costs.—a. Cost Factors.—The
value of investment required to achieve the desired emission
control level for plants producing elemental phosphorus var-
ies in relation to the capacity of each plant. It is estimated
that the average investment per plant subject to these stand-
-------
GUIDELINES AND REPORTS 2481
ards in the 298 metropolitan areas in 1967 would be $585,000.
The annualized cost in 1967, including depreciation, finance,
and operating charges would average $271,000 per plant in
the metropolitan areas, or approximately $7.80 per ton of
phosphorus produced.
Investment requirements and annual costs for fertilizer
plants vary in relation not only to capacity but also to the
type of product produced. The average investment in 1967 for
all plants in the metropolitan areas is estimated at just under
$150,000 each, and total annual costs, including the annu-
alized investment, average approximately $47,000 per plant.
The effect of varying investment and operating expenses in
1967 may be shown by comparing the range of annual cost
for each production process. Annual costs per plant for pro-
duction of normal superphosphate range from $18,000 per
year at 12 tons per day capacity to $440,000 per year at 1,540
tons per day. For triple superphosphate producers, the annual
cost per plant range is from $52,000 per year at 50 tons per
day capacity to $2,000,000 per year at 10,000 tons per day
capacity.
[p. 4-52]
Ammonium phosphate plants show annual costs from
$6,000 per year at 50 tons per day capacity to $375,000
per year at 6,000 tons per day capacity. Finally, annual costs
for phosphoric acid plants are estimated to range from
$13,000 per year at 25 tons per day capacity to $170,000 per
year at 1,000 tons per day capacity.
b. Industry Impact.—It is estimated that an annual cost of
$2,180,000 will be required to control facilities in operation in
1967. This will be equal to approximately $7.80 per ton of
production. This is approximately two percent of the f.o.b.
selling price. The annual cost estimate of $6,910,000 for con-
trol of fertilizer plants, figured on the same basis, averages
approximately $1.70 per ton produced, or just over one per-
cent of producers price. This control cost reflects, insofar as
possible, the annual cost of controlling phosphoric acid pro-
duction which enters into fertilizer manufacture. By Fiscal
Year 1976, it is estimated that the investment requirement
and annual cost for emission controls for the elemental phos-
phorus industry located in the 298 metropolitan areas would
be $6.6 million and $3.1 million. For the phosphate fertilizer
-------
2482 LEGAL COMPILATION—Am
industry, the investment requirement and annual cost are es-
timated at $32.0 million and $10.0 million.
Data were not available to determine the share of revenue
and profit attributable to phosphorus production in the seven
firms in that market, or the role of fertilizer in the total
operations of these fertilizer manufacturers for which finan-
cial information was known. It is believed that in most of the
industrial processes using phosphorus or phosphoric acid,
these inputs would be quite small relative to the total material
cost. With only seven firms to buy from, and with all of them
affected to some extent by the required control cost, it is
expected that buyers would have to accept price increases
sufficient to cover the producers' costs. Since only 44
[p. 4-53]
percent of the United States production would be affected by in-
creased control cost, prices might rise by approximately one
percent, or $3.90 per ton. Sales of elemental phosphorus or
phosphoric acid for industrial use would probably not be re-
duced by a price change of this magnitude.
The average annual control cost per ton of fertilizer pro-
duced is approximately $1.70. Annual control cost for produc-
ers of ammonium phosphate is estimated to be approximately
half the average, while annual control cost for triple super-
phosphate is somewhat above the average.
Since most producers are affected by the increased cost and
since there is no known substitute for phosphate fertilizer,
virtually all of the increased cost may be expected to be re-
flected in price. However, the trend of substitution of high
analysis triple superphosphate and diammonium phosphate
for normal superphosphate may be accelerated. Delivered
price on the farm of P2O5 may be expected to increase by
approximately the same amount whether in the form of nor-
mal or triple superphosphate. This would maintain the value
advantage of the concentrated superphosphate. Ammonium
phosphate may be expected to increase in price by only half
the increase in the other types. The average price increase for
all forms combined may, therefore, be in the range of $0.70 to
$1.00 per ton, depending on the eventual product mix of the
industry.
For producers, this seems to indicate a hastening decline in
production of normal superphosphate. Since much of the ca-
pacity for producing normal superphosphate is older than
-------
GUIDELINES AND REPORTS 2483
that used for the other types and may already be obsolete,
producers may choose to replace it rather than invest in con-
trol equipment. Some small fertilizer producers make only
normal superphosphate. The number of these firms was not
determined for this study. Some of these firms may be forced
to close as return on investment falls below the already poor
rate normal to the industry.
[p. 4-54]
G. Grain Milling and Handling
1. Introduction.—Commercial grain mills process grain into
flour, livestock feeds, cereals, corn syrup, and various bread and
pastry mixes. Because of limited data, this study focuses on
those establishments primarily engaged in manufacturing pre-
pared feeds for livestock. Manufacture of certain feed ingredi-
ents and adjuncts, such as alfalfa meal, feed supplements, and
feed concentrates is also included in these establishments. The
main grain handling operations are performed at terminal and
country elevators which provide storage space and serve as
collection and transfer points. Terminal elevators serve as stor-
age and distribution points and store larger quantities over a
longer period of time. Country elevators are scattered over the
countryside and average storage time is less than for terminal
elevators. The two types of activities involved at both types of
elevators are: (1) intermittent operations such as unloading
and drying and (2) continuous operations such as bin aeration
or turning, cleaning, and loading.
For simplicity, grain handling is assumed to proceed through
the following steps: (1) after harvesting, the grain is taken to
a country elevator; (2) there it is unloaded, weighed, and stored
for varying periods; (3) it is then loaded into a type of convey-
ance and taken to a terminal elevator; and (4) it is unloaded,
weighed again, given a preliminary cleaning, and again stored.
Terminal elevators are usually operated continuously,
whereas country elevators are not. Certain country elevator op-
erations, such as loading and drying, involve 2,000 hours per
year or less. Other operations such as turning and loading are
continuous in most cases.
2. Emissions and Costs of Control.—The principal type of
pollutant emitted during animal feed milling and grain handling
operations is particulates. Dusts, resulting primarily from me-
chanical abrasion of individual grains, are generated in both the
-------
2484 LEGAL COMPILATION—AIK
milling operations in grain mills and the handling and cleaning
processes of the elevators. Terminal
[p. 4-55J
elevators contribute the vast majority of the particulate emis-
sions from the grain milling and handling industry. Although
country elevators are of a smaller scale, most of them perform
basically the same operations as the terminal elevators; there-
fore, country elevators, as well as terminal elevators, require
particulate controls designed for maximum materials handling
capacity.
Particulate emissions from elevators in the 298 metropolitan
areas are estimated to equal 1,400,000 tons in 1967. With indus-
try growth, these would increase to 1,730,000 tons by Fiscal
Year 1976 if the 1967 control level of 35 percent was main-
tained. Installation of controls, yielding a control level of 99
percent, would reduce emissions to 26,100 tons in Fiscal Year
1976. Similarly, feed mill particulate emissions are estimated as
274,000 tons in 1967 and would grow to 347,000 tons by 1976 if
the 1967 control level of 35 percent was maintained. With con-
trols increased to 99 percent, 1976 emissions would be reduced
to 5,410 tons.
Control of dust emitted from livestock feed milling and grain
handling to a required level of 99 percent can be accomplished
with fabric niters. At present, only about 50 percent of terminal
elevators and animal feed mills are assumed to be equipped with
cyclones which remove only 70 percent of the dust conveyed to
them. Costs are calculated on the basis of installing fabric niters
at all mills and elevators.
With the implementation of these controls by Fiscal Year
1976 in the 298 metropolitan areas, it is estimated that the
investment requirement for the grain handling and the animal
feed milling industry will be $436 million and $27 million,
respectively. The annual costs will amount to approximately
$153 million and $11 million, respectively, for each segment of
the industry.
3. Scope and Limitations of Analysis.—Only limited data on
the operation of grain elevators and feed mills were available
for this analysis. So as not to understate the problem, the esti-
mates made of dust emissions and the control cost of reducing
them to acceptable levels are considered high. These estimates
should be interpreted as indicating a level that
[p. 4-56J
-------
GUIDELINES AND REPORTS 2485
probably would not be exceeded and as an indication of the order
of magnitude of the problem and the controls required.
Although the distribution of elevators and feed mills by loca-
tion and size was known, data were not available showing simi-
lar information by firm. Some of the largest firms in this indus-
try are well known publicly held corporations, but the business
structure, pattern of operations and sales, and financial position
of constituent firms were not available. The economic analysis
included in this report is, therefore, necessarily limited to the
general market impact of control costs.
4. Industry Structure.—In 1967, there were 4,098 grain eleva-
tors in the 298 metropolitan areas with a storage capacity of
3.48 billion bushels and a throughput capability of an estimated
9.76 billion bushels. Of this number of grain elevators, 2,898 (71
percent) had a capacity of less than 500,000 bushels and, in
most cases, would be classified as country elevators. The remain-
ing 1,200 elevators (29 percent) are classified as terminals and
provide approximately 83 percent of the storage capacity and
throughput capability. These large elevators include those lo-
cated at major milling plants and terminals and are normally a
part of large corporate producers of livestock and poultry feed,
or a part of large scale shippers, in addition to large elevator
operators. Many small elevator operators also do feed milling
and mixing of custom feeds.
Feed mills in the 298 metropolitan areas in 1967 numbered
2,155. The capacity, production and value of shipments for these
mills are estimated at 55.5 million bushels, 46.2 million bushels
and $3.8 billion. Seventy percent of these feed mills have fewer
than 20 employees.
Both the milling and handling sectors of the industry, there-
fore, are characterized by a wide range of production capacities
and considerable variation of operating patterns. A relatively
small number of large nationally known firms operate a sub-
stantial share of the productive capacity, but there are also a
very large number of independent small- and medium-sized
producers, providing a highly competitive market.
[p. 4-57]
5. Market and Trends.—The market for grain tends to be
dominated by the demand derived from consumption of the final
products made from it, with government price support and pro-
duction controls setting a lower limit on prices. Grain handling
costs make a relatively small contribution to the delivered cost
-------
2486 LEGAL COMPILATION—AIR
of grain and, since these functions are essential and unavoidable
to the rest of the industry, it would appear that demand for
handling services would show little sensitivity to price. Simi-
larly, demand for livestock and poultry feeds is relatively inelas-
tic with regard to price. However, large segments of the mar-
ket, such as f eedlot operators, may choose to reduce the amount
of feed used when a rise in feed prices does not coincide with an
increase in the market price of meats. The price elasticity of
demand for livestock and poultry feed, therefore, depends upon
price trends and price elasticity of the demand for meat and
makes it more difficult for feed mill operators than for elevator
operators to shift increased cost to the buyer.
6. Economic Impact of Control Costs.—The cost of installing
fabric filters on elevators was based upon the distribution of
plants by capacity. It was assumed that the elevators with less
than 500,000 bushels capacity had no effective control in 1967. It
was estimated that the required investment for these elevators
would average approximately $9,000 each. The average invest-
ment would be considerably higher for large terminal elevators
as a result of their larger volume of grain handling and since it
was assumed that most of the grain cleaning and drying is done
there. Average investment for elevators over 500,000 bushels
capacity is estimated at $77,700. Total investment for control of
the elevators in the 298 metropolitan areas is estimated as $436
million through Fiscal Year 1976, including investment for ele-
vators built after 1967.
The investment required for fabric filters to control emissions
from feed mills was estimated in relation to the normal daily
production and ranged from $10,000 for 10 to 100 tons per day
and up to
[p. 4-58]
$144,000 at 2,500 tons per day. Mills with less than 100 tons per
day production predominate in the industry to such an extent
that the average investment per mill is only slightly over
$10,000. Total investment for all feed mills, including capacity
constructed after 1967, is estimated to reach $27.4 million
through Fiscal Year 1976.
Annualized control costs (operating expense plus depreciation
and finance cost) show a similar pattern. Country elevator an-
nual cost averages just under $10,000 per year and terminal
elevators average approximately $78,000 per year. Total annual
costs for all elevators in the 298 metropolitan areas are esti-
-------
GUIDELINES AND REPORTS 2487
mated as $153 million by Fiscal Year 1976. Annual cost for an
average feed mill is estimated to be $4,000 per year and the
total for all feed mills would approximate $11 million by Fiscal
Year 1976.
The annual cost of controlling elevator emissions is equal to
$0.0127 per bushel of grain estimated to be handled in 1976 and
the annual cost per ton of feed production in 1976 is estimated
as $0.187. In view of the relative insensitivity of demand for
grain and feed to price changes suggested in Paragraph 5,
above, it appears that these costs will be largely reflected in
prices. It is unlikely that an added cost of one cent per bushel
for grains priced from $0.70 to $1.70 per bushel will change the
market significantly. Similarly, no market effect is expected
from an additional cost of 19 cents per ton when added to feed
averaging in the vicinity of $85 per ton. Expressed another
way, these costs of control will add approximately $164 million
to the nation's annual food bill by Fiscal Year 1976 or perhaps
$0.75 per person.
[P. 4-59]
H. Gray Iron Foundries
1. Introduction.—Gray iron foundries produce castings, such
as machine and automobile parts, from gray iron, pig and scrap.
To melt iron for casting, the industry utilizes three types of
furnaces: electric arc, electric induction, and cupola furnaces.
The electric arc and electric induction furnaces, which together
account for only seven percent of all castings, emit relatively
small quantities of pollutants and were not included in the anal-
ysis. This report focuses on control of pollutants from cupola
furnaces.
Cupolas are vertical cylindrical furnaces in which the heat for
melting is provided by burning coke in direct contact with the
metal charge. Most foundry emissions emanate from this
metal-melting operation.
2. Emissions and Costs of Controls.—Carbon monoxide and
particulates in the form of dust and smoke are the significant
emissions from cupolas. Particulates arise from fines in the coke
and flux charge, from metal fuming, and from dirt and grease
introduced with the scrap.
In 1967, it is estimated that the industry averaged about 18
percent control of carbon monoxide and 12 percent of particu-
lates. Emissions within the 298 metropolitan areas amounted to
2,220 thousand tons and 166 thousand tons, respectively. With
-------
2488 LEGAL COMPILATION—AIR
industry growth, these emissions would increase to 3,420 thou-
sand tons and 255 thousand tons, respectively, in Fiscal Year
1976. Implementation of controls would result in 209 thousand
tons of carbon monoxide and 29.1 thousand tons of particulates
in Fiscal Year 1976.
Carbon monoxide emissions can be reduced by the use of
afterburners which oxidize carbon monoxide to carbon dioxide.
Afterburners in combination with gas-cleaning equipment, such
as wet scrubbers or fabric filters, can reduce emission levels of
carbon monoxide and particulates from cupolas to achieve com-
pliance with stringent process weight regulations for particu-
lates and a 95 percent removal rate for carbon monoxide.
[p. 4-60]
Of the control equipment presently capable of particulate re-
movals in excess of 90 percent, only high-energy wet scrubbers
have been used on cupolas without difficulty. Several foundries,
especially in the Los Angeles area, are using fabric filter bag-
houses with some degree of success. Fabric filter systems, when
successful, require afterburners, gas-cooling equipment, high-
temperature filtration material, and decreased filtration veloci-
ties. In general, maintenance costs for fabric filters are high and
the costs of using them is greater than for wet scrubbers.
The total investment required to meet the standards by Fiscal
Year 1976 would be $317.3 million. The corresponding annual
cost would be $108.2 million.
3. Scope and Limitations of Analysis.—This report is limited
to control of the melting operations. Nonmelting operations
within foundries are consistently controlled with high efficiency
control equipment and are not included in the analysis.
The analysis of economic impact is limited to jobbing found-
ries, since the financial structure of captive foundries is indis-
tinguishable from that of their parent company. Impact on a
captive foundry cannot therefore be determined and its control
costs are passed on directly to the final product of the parent
company.
4. Industry Structure.—The gray iron foundry industry con-
sists of 1,446 plants that are located in the United States, of
which 77 percent (1,115) are located within the 298 metropoli-
tan areas. United States capacity for the industry in 1967 was
17 million tons of castings per year. In the 298 metropolitan
areas, capacity amounted to 14 million tons of castings per year.
Production was 14.3 million tons per year for the United States
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GUIDELINES AND REPORTS 2489
and 11.8 million tons per year for the 298 metropolitan areas or
about 83 percent of the United States production.
Numerically the gray iron foundry industry consists predomi-
nantly of small establishments. Yet production is dominated by
a few large firms. The four largest companies accounted for
approximately 27
[p. 4-61]
percent of the industry's value of shipments in 1967, while the
eight largest accounted for 37 percent.
There is a definite trend in the foundry industry toward
fewer but larger firms. From 1959 to 1967, the total number of
foundries in the U. S. declined by almost 200, although the
number of large foundries increased.
Many of the largest firms are "production foundries," which
have the capability of economically producing large lots of
closely related castings. Most of the output of these "production
foundries" is captive (owned and controlled by other busi-
nesses). In fact, almost half of all gray iron production comes
from captive plants which do not generally produce for the
highly competitive open market.
Gray iron foundries range from primitive, unmechanized
hand operations to heavily equipped plants in which operators
are assisted by electrical, mechanical, and hydraulic equipment.
Captive plants are more likely to be mechanized and better
equipped with emission control equipment than are noncaptive
plants.
The nature of the gray iron foundry industry is such that
foundries can be found in almost all urban areas. The economies
of scale for the industry do not prohibit the continued existence
of relatively small foundries. Since many foundries are operated
in conjunction with steel-making facilities, they are concen-
trated in the "steel" states: Pennsylvania, Ohio, Michigan, Illi-
nois and Alabama.
5. Market.—a. Com/petition Among Sellers.—The gray iron
foundry industry is characterized by intense competition
among the many small jobbing foundries. This fierce price
competition has spurred a drive for lower operating costs and
higher productivity gains. Casting quality along with engi-
neering design services available to the customers are other
areas of increasing competition. Unfortunately, many found-
ries have had insufficient capital or resources to invest in
cost-saving and quality improvement facilities rather than
52G-705 O - 74 - 10
-------
2490 LEGAL COMPILATION—Am
straight additional capacity. Larger foundries have a compet-
itive advantage in that
[p. 4-62]
they usually can offer the services of better sales engineering
staffs, are more mechnaized, and have more sophisticated
quality control equipment.
The net effect is that many small foundries that cannot
cope with increasing needs for capital, demands for better
quality and service, and rising labor costs are being forced
out of business. The larger and more stable firms are, in
contrast, increasing their capacities in order to reduce unit
costs and absorb the additional demand. Also, an increasing
number of large purchasers of castings are establishing cap-
tive foundries in order to gain a ready supply of quality
castings. However, these additions to capacity have been una-
ble to keep pace with the expansion of demand and the loss of
capacity of closed foundries. As a result users are finding it
increasingly difficult to obtain an adequate supply of specialty
iron castings.
b. Customer Industries.—The major customers of the gray
iron foundry industry are also major constituents of the na-
tional economy. The health of the industry is therefore closely
related to the health of the gross national product (GNP).
The major industrial markets for foundry castings include
motor vehicles, farm machinery, and the industries that build
equipment for the construction, mining, oil, metalworking,
railroad and general industry markets.
These industries are considerably larger and more powerful
than the gray iron foundry industry. The individual customer
firms have many times the assets of the foundries from which
they buy. With their financial strength and generally greater
management expertise, such firms are able to play the many
small foundries against each other to maintain severe price
competition even under conditions of high demand for cast-
ings.
c. Foreign Competition.—Direct imports of castings as well
as the castings in imported machine tools, autos, textile mach-
inery, and internal diesel engine parts do enter the American
market. However, Department of Commerce statistics indi-
cate a volume of only $2.25 million for direct imports in 1967.
This is estimated
[p. 4-63]
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GUIDELINES AND REPORTS 2491
by the industry to be approximately one quarter of the actual
total. Even if a total import volume of $9 million is assumed,
imported castings and component castings are equivalent to
less than one percent of the $2.7 billion value of shipments
in the U.S. that same year.
Imports, therefore, do not constitute a major threat to the
American gray iron casting market. The high cost per ton of
shipping compared to the relatively low cost per ton of pro-
duction is probably the most significant barrier to imports.
6. Trends -The foundry industry expects its market to con-
tinue to grow at the average historical growth rate of its cus-
tomer industries. This rate is expected to average six to seven
percent per year through 1980 but may be somewhat less for the
period of 1970 to Fiscal Year 1976. By 1975, total foundry
production volume will have to increase by 52.9 percent over
1969 just to keep up with demand. For 1980, the projected
increase is 90.2 percent over 1969 volume.
During the period from 1958 to 1967, the price of gray iron
castings rose steadily at a rate of 2 percent per year. At the
same time, the prices of the two major raw materials, pig iron
and scrap iron, have fallen at an annual rate of 2.3 percent.
However, while material costs have declined, labor costs have
advanced more rapidly than the price of castings, keeping con-
tinued upward pressure on price.
7. Economic Impact of Control Costs.—a. Control System
Costs.—Full implementation of controls on all facilities which
existed in 1967 would yield a total annual cost of $69.4 million
and in Fiscal Year 1976 the total annual cost would be about
$108.2 million. As production volume within the 298 metro-
politan areas was 11.8 million tons in 1967 and is estimated to
be 18.0 million tons in Fiscal Year 1976, the average cost of
control per ton would be $5.88 and $6.01, respectively.
No valuable materials, which could serve to compensate for
control costs, are recoverable from foundry emissions.
Currently, air pollution control increases the cost of cast-
ings for large foundries by about 0.7 percent. With small
[p. 4-64]
single cupola foundries, added cost averages about 3 percent
of the production cost. These added costs compare to average
profit rates before tax of 6.8 percent for large foundries and
5.8 percent for small foundries. To small foundries, control
costs represent a reduction in profit margins of over 50 per-
-------
2492 LEGAL COMPILATION—AIR
cent, while margins for larger firms would be reduced only 11
percent if costs could not be passed on to customers. Invest-
ment in air pollution control equipment would equal approxi-
mately 5 percent of the value of capital for the largest firms
and as much as 25 percent for the smallest firms. The evi-
dence of these indicators suggests that the impact of pollution
control is much greater on the small jobbing firms under a
million dollars in value of shipments than on those with
greater shipments. The industry generally can little afford a
reduction in profit rate, as its rate of 6.8 percent return on
investment is already below the all-manufacturing average of
8.1 percent.
The large investment in pollution control equipment, rela-
tive to the book value and profitability of many foundries,
presents a serious problem of financing the investment. The
foundry industry generally is not an attractive investment in
stock or bond markets due to its low rate of return and slow
profit growth. Neither is it a good risk for commercial banks
due to the high ratio of control investment to book value of
many small foundries and the unprofitability of the control
investment. The Small Business Administration is currently
the only source of funds available to many foundries. The
SBA prefers to guarantee loans made by banks but will pay
out funds directly in some cases.
b. Impact on the Industry.—The economic impact of pollu-
tion control costs on an industry varies with the industry's
ability to pass cost on to the consumer in the form of higher
prices. This ability is largely dependent upon elasticity of
demand for the product, the degree to which the volume of
sales declines in response to price increases. Demand for cast-
ings is relatively inelastic, since most castings are inputs for
the production of more complex final products and
[p. 4-65]
constitute a small portion of the cost of the final product.
Also, possible substitute products, such as aluminum, steel,
and other metals, are somewhat more costly than gray iron
and are usually subject to the same upward price pressures
such as rising labor costs and pollution control costs. Thus,
a small price increase due to pollution control will have little
effect on the market for gray iron.
Despite inelastic demand, sharp competition among the
many jobbing foundries will make price adjustments for con-
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GUIDELINES AND REPORTS 2493
trol cost difficult for those foundries that experience higher
than average costs. Large mechanized firms and those smaller
firms that are located outside of the 298 metropolitan areas
will incur lower control costs than will other foundries. These
lower cost foundries will establish price levels that prevent
the less efficient firms from raising prices sufficiently to cover
their control costs. The average price of castings is expected
to increase by about two percent in response to stringent air
pollution control regulations. Such a price increase would
leave approximately one-third of the firms in the industry
with reduced profit margins. These firms would be forced into
marginal or sub-marginal financial positions.
The nonuniformity of control regulations and costs, along
with the lack of investment capital, will force most foundries
to postpone implementation of control for as long as possible.
Many firms, faced with reduced profit margins and an inabil-
ity to raise capital for pollution control will be forced to
merge or go out of business. Some remaining firms will con-
tinue to operate at reduced profit rates. However, the larger,
more stable foundries will increase their capacity to meet
expanding demand, improve efficiency and continue to operate
at reduced profit rates. In effect, pollution control will acceler-
ate the trend toward fewer and larger foundries. It is appar-
ent that the gray iron foundry industry will be among those
industries most severely affected by air pollution control.
[p. 4-66]
I. Iron and Steel
1. Introduction.—The iron and steel industry includes plants
ranging from integrated steel making operations (blast fur-
naces, steel making furnaces, coke ovens, sintering plants, scarf-
ing machines, rolling mills, etc.) to much smaller operations
with a few steel making furnaces producing small quantities of
specialty steels. The first step in the conversion of iron ore into
steel takes place in the blast furnace. The blast furnace pro-
duces a material commonly referred to as pig iron. Steel making
furnaces refine the pig iron and/or steel scrap into steel. Three
types of steel making furnaces are in common use; these are the
open hearth furnace, the basic oxygen furnace and the electric
steel making furnace. Sintering plants are designed to convert
iron ore fines into a product more acceptable for charging into
the blast furnaces. Scarfing is an operation which removes sur-
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2494 LEGAL COMPILATION—Am
face defects from steel. Coking is an operation in which bitumi-
nous coal is converted into coke, the chief fuel used in blast
furnaces. Blast furnaces are always well controlled to prevent
the emissions of particulates; while the gaseous emissions are
fully utilized in the production of process heat. At present, very
little is known about the emissions or present control patterns
for scarfing machines. The full control of coking operations, at
present, is not considered to be technically and economically
feasible. Therefore, this report focuses on the emissions and air
pollution control costs of the sintering and steel making opera-
tions.
2. Emissions and Costs of Control.—This report focuses on
two air pollutants: particulates and fluorides. Carbon monoxide,
a potential emission from basic oxygen furnaces and blast fur-
naces is usually completely controlled. Particulate emissions re-
sult from the sintering operations as well as from all the steel
making furnaces. Based upon the best available data the aver-
age level of particulate control in 1967 is thought to have been
about 55 percent for these unit operations. To comply with the
Clean Air Act by Fiscal Year 1976, an average level of particu-
late control of 97 percent will be required. Therefore, particulate
[p. 4-67]
emissions would be reduced from a potential of 1.460 thousand
tons in Fiscal Year 1976 with the same controls as in 1967 to
93 thousand tons in Fiscal Year 1976 with 97 percent control.
Fluoride emissions occur during steel making operations in
all three furnace types. It is estimated that in 1967 the fluoride
emissions were 26,400 tons and the average level of fluoride
control for the industry was about 30 percent. By Fiscal Year
1976, to comply with the Act, an average level of control of 89
percent will be required. With these controls, fluoride emissions
would be reduced from a potential of 35,200 tons to 5,200 tons.
In order to implement the required increases in air pollution
control levels by Fiscal Year 1976, it is estimated that an invest-
ment of $981 million will be required, and that total annual
cost will be $507 million.
8. Scope and Limitations of Analysis.—This analysis focuses
on integrated basic steel firms. Air pollution emissions that ex-
ceed the standards assumed for this study are produced primar-
ily by the sintering plants and open hearth or basic oxygen
furnaces of basic steel producers. Electric furnaces are also
emission sources to a lesser extent. However, when used by
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GUIDELINES AND REPORTS 2495
secondary steel producers making specialty high alloy steels,
electric furnaces are normally controlled to a high level of
efficiency to avoid loss of valuable alloying metals. Secondary
steel firms, therefore, are not generally faced with additional
control cost.
Data on the operation of the steel industry are more available
than for most industries. Nevertheless, the steel market is com-
plicated by the vast variety of distinct products sold and the
variations of product mix from one company to another. Com-
parison of the impact of a change in the cost of producing raw
steel as it affects different companies is very difficult. Detailed
data on such aspects of financial management is depreciation
policy, net value of investment, pricing policy, and tax account-
ing are also not available, making it especially difficult to esti-
mate profit potential for these firms.
[p. 4-68]
4. Industry Structure.—In 1967 there were 142 steel plants in
the United States, of which 134 were located in the 298 metro-
politan areas. The capacity, production and value of shipments
of these plants in the United States were 165 million tons, 127
million tons and $13.3 billion, respectively. In the metropolitan
areas the capacity of the plants was 61 million tons, production
was 124 million tons, and the value of shipments was approxi-
mately $13.1 billion.
There were 86 steel companies in the United States in 1967.
Twenty one integrated firms accounted for more than 90 per-
cent of the 1967 steel production in the United States. They
include all of the larger firms in the industry, with outputs in
1967 ranging from just under 1 million tons to more than 30
million tons. Sales for these companies varied from approxi-
mately $85 million to more than $4 billion in that year and
profits from a high of $172 million for one firm to a loss of
nearly $7 million for another. The two largest firms produced
approximately 40 percent of the steel produced in 1967 and
eight firms produced over 75 percent of the industry output.
5. The Market.—The steel industry is usually described as an
oligopoly characterized by administered prices and price leader-
ship. Typically, list prices, which are virtually the same for all
firms, remain unchanged for a period of time without reacting
to minor changes in market conditions. Although individual
prices may be shaded through the use of special discounts or
premiums, the primary adjustment of company policy to short
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2496 LEGAL COMPILATION—AIR
term market changes is to vary output. When price changes do
occur they are usually initiated by one of the largest firms and
all other companies quickly change their price lists following
the pattern set by the price leader. Competition emphasizes
product quality and customer service more often than price.
Steel is sold to customers in every major industrial sector of
the economy. The major purchasing industries, however, are
[p. 4-69]
motor vehicles, heavy equipment and machinery, containers, and
appliances. These industries strongly follow the swings of the
business cycle and as a result cyclical changes in the national
economy tend to have a magnified effect on the market for
finished steel. The basic position of steel in the economy also
indicates the probability that the long run trend of the domestic
market for steel will be one of steady expansion and gradually
rising prices.
The steel industry is also subject to significant foreign compe-
tition. Foreign participation in the U. S. steel market increased
during the 1960's and posed a real threat to the market for some
products. The export market for U. S. steel did not balance
imports during those years. This competitive pressure was
eased by the signing of an informal agreement in December,
1968, with the Japanese Iron and Steel Exporters Association
and with the association of Steel Producers of the European
Coal and Steel Community to limit exports to the United States
for the years 1969 to 1971. This agreement, limiting increases in
shipments from the countries involved to not more than 5 per-
cent per year, appears to be effective and may well be extended.
Thus the industry is partially shielded from some foreign com-
petition. There has been a tendency for foreign steel producers
to concentrate on the sale of high priced speciality steels in this
country, but the protection of the agreement has been effective
for basic steel producers.
6. Trends.—Investment in new steel capacity has been heavy
over the last decade and is predicted to continue at a high level.
The trend is away from the older open hearth furnaces in favor
of construction of the more efficient basic oxygen and electric
furnaces.
Prices have been rising following the general inflationary
trend of the economy. It is predicted that prices may rise more
slowly over the years to 1976, but the upward trend is expected
to continue. The trend of profits is difficult to determine because
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GUIDELINES AND REPORTS 2497
net income after taxes for these companies varies substantially
from year to year. Among the factors causing these fluctuations
[p. 4-70]
are very heavy "start up" costs when new facilities are put into
production, the impact of strikes, changes in accounting and tax
practices, and the tendency of firms to change output rather
than price in response to short term market changes.
7. Impact of Control Costs.—The investment requirement and
annual cost of air pollution control for each steel firm will vary
depending on the number and size of its plants and the type and
capacity of its steel making furnaces. Cost estimates are calcu-
lated on the following equipment designations: high energy wet
scrubbers for basic oxygen furnaces; high energy wet scrubbers
for 50 percent of open hearth furnaces and electrostatic precipi-
tators for 50 percent; fabric filters for electric arc furnaces;
medium energy wet scrubbers for sintering machine windboxes
and discharges. Both the investment requirement and the an-
nual costs for each of these control devices varies in relation to
the capacity of the furnace or machine and has been costed on
the basis of data specifying individual capacities in place. The
other major determinant of cost differences among plants and
firms is the number of each type of furnace in use. For example,
an open hearth furnace of 180 tons per heat capacity would
have an annual control cost, for operation, maintenance, and
depreciation, of $249,000 per year, based on 1967 prices. The
equivalent annual cost for an electric arc furnace of 180 tons
per heat capacity would be $490,000 per year and for a basic
oxygen furnace of the same capacity would be $1,040,000 per
year. It should be noted in this comparison that the basic oxy-
gen furnace has a much shorter heat time and therefore a
higher annual capacity than the electric arc furnace, which in
turn has a shorter time per heat than the open hearth furnace.
Thus the cost per ton of steel produced is not in the same
proportion as the annual cost, but depends upon the production
rate for each furnace.
The impact of control costs on firms may be shown by com-
parison of three hypothetical examples designed to show the
range of cost per ton of steel production. A steel company with
total productive
[p. 4-71]
capacity of approximately 9 million tons, producing 6.4 million
tons of finished steel per year in 1967, Vs from basic oxygen
-------
2498 LEGAL COMPILATION—Am
furnaces and % from open hearth furnaces, would incur esti-
mated costs as follows: total annual cost, $8,527,000; annual
cost per ton of raw steel produced, $1.14; annual cost per ton
of finished steel products, $1.33. If this firm does not have to
incur new costs for controlling its sintering machines, as as-
sumed in this estimate, the cost per ton of finished steel could
be as low as $0.90.
Estimated costs for a typical smaller firm having an annual
capacity of 2.24 million tons and production of 1.58 million tons
of finished steel produced entirely with open hearth furnaces
shows a total annual cost of approximately $3,000,000, or $1.91
per ton of finished steel. Similarly, a typical firm producing 1.7
million tons of finished steel in 1967 with a capacity of 2.3
million tons, using only basic oxygen and electric arc furnaces,
would have an estimated annual cost of only $623,000, or $0.37
per ton of finished steel.
Comparison of these cost estimates indicates that the impact
of control costs will probably be least on firms using many
relatively small electric arc furnaces and greatest for firms pro-
ducing primarily with open hearth furnaces. The estimated
costs are relatively small in relation to the price of finished steel
of $170 per ton in 1967, but differentials of the size indicated
may accelerate the existing trend in the industry to retire older
open hearth furnaces.
In the light of the pricing policies of the steel industry as
described in Section 5, above, it is probable that most of the
indicated costs will be reflected in increased prices by 1976. The
firms that normally exercise price leadership in the industry are
among those with substantial open hearth capacity and will
therefore tend to reflect pressure to raise prices to cover the
higher range of control costs. In a period of generally rising
prices, an increase of the magnitude indicated for steel prices
should not produce significant changes in the market position of
the firms.
[p. 4-72]
J. Kraft (Sulfate) Pulp
1. Introduction.—The pulp industry manufacturers pulp from
wood and other materials for use in making paper and related
products. The methods used to produce pulp from wood may be
classified as chemical or mechanical, only the chemical methods
causing significant air pollution problems. Two chemical pulp
-------
GUIDELINES AND REPORTS 2499
production methods, sulfite and sulfate (kraft), account for
approximately 75 percent of the total industry output. Only
kraft pulping, which accounts for approximately 64 percent of
the industry output, is considered in this report. Even though
sulfite pulping is a potentially serious source of sulfur dioxide,
when waste liquor incineration is practiced, the control costs are
more than offset. This is because the sulfur dioxide emissions
from the sulfite process usually are controlled since the value of
recovered heat and process chemicals offset the annual costs of
control.
In the kraft process, woodchips are cooked in a liquor com-
posed of sodium hydroxide and sodium sulfide. This separates
the lignin from the cellulose. Pulp is then produced from the
cellulose. The separated lignin is burned as a fuel in the recov-
ery furnace and the chemicals in the salt cake solution are
recycled.
2. Emissions and Costs of Control.—In kraft pulp mills, four
main processes emit significant quantities of particulates: re-
covery furnaces, smelt dissolving tanks, lime kilns, and bark
boilers. Although there are emissions of sulfur dioxide, these
almost never exceed the 500 p.p.m. standard. Since the econom-
ics of the kraft method depend upon recovery of chemicals,
emissions from the first three processes are controlled to pre-
vent the loss of these chemicals. Particulates from bark boilers
are also controlled, but to an extent which falls short of the
standard adopted for this study. Overall, the average industry
control level for particulates in 1967 was 81 percent. To meet
the standard by Fiscal Year 1976, the average industry control
level
[p. 4-73]
would have to reach 98 percent. Without implementation of the
standard, particulate emissions would reach 847,000 tons for
kraft plants within the 298 metropolitan areas. Assuming im-
plementation, this could be reduced to 120,000 tons.
By Fiscal Year 1976 an investment of $73.0 million will be
required to achieve full implementation for the plants within
the 298 metropolitan areas. This would result, by Fiscal Year
1976, in an annualized cost of $30.3 million.
S. Scope and Limitations of Analysis.—Open market sale of
kraft pulp constitutes a very small part of total production,
making the open market reaction to the cost of air pollution
control a less than ideal indicator of industry impact. In this
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2500 LEGAL COMPILATION—AIR
case, however, it appears that the market for kraft pulp is in
fact a significant supplier of the marginal resource inputs and,
therefore, an integral part of the industry rather than an over-
flow market. On this basis it is assumed that the pulp market
reflects cost changes that will affect the entire kraft paper in-
dustry.
Analysis of the impact of control costs on price and profit is
clouded by the presence in the industry of many firms that
produce nonpaper products, including lumber, metal containers,
and other diverse products.
4. Structure of the Industry.—Kraft pulping is a segment of
the ninth largest manufacturing industry in the United States
—the pulp and paper industry. Most pulp produced by the kraft
process (and the other processes as well) is made by integrated
companies and consumed by them in the production of paper
and paper products. About eight percent of the kraft pulp is
marketed, resulting from independent firms without paper mak-
ing facilities and from integrated firms producing surplus for
market.
The availability of raw materials, level of labor costs, and
nearness of markets are prime determinants of plant location.
The heaviest concentration of kraft plants is in the Southeast-
ern section of the United States. Twenty-four of the 71 South-
eastern plants are not, however, in air quality control regions.
[p. 4-74]
Statistics concerning the kraft (sulfate) pulp industry are
shown in Table 4-10.
TABLE 4-10.—1967 STATISTICS ON THE KRAFT (SULFATE) PULP INDUSTRY
United States 298 Metropolitan
Areas
Number of plants..., .. 116 81
Number of firms ... 72 51*
Capacity (millions of tons) . 32.1 22.5
Production (millions of tons) . .. . 23.9 16.8
Value of shipments (billions of dollars) ... .. . 3.6 2.5
* Forty-three firms have all their plants in the 298 metropolitan areas, 8 firms have some, and 21 firms have none.
5. The Market.—a. The Competitive Pattern.—Production of
kraft pulp in the United States is a direct function of the
market for the paper and paper products produced from it
and it is this market, therefore, that is discussed in this
section. A number of large firms operate in the kraft paper
industry, but they do not have sufficient market power to
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GUIDELINES AND REPORTS 2501
dominate the industry. There are a large number of buyers in
the market, also, from a broad spectrum of industries provid-
ing a highly diversified and competitive market. Prices tend
to react freely to relative changes in supply and demand.
A large share of kraft production goes into containers and
packaging materials, including wrapping paper, bags, corru-
gated boxes, frozen food containers, milk cartons, and other
food packaging. The industry faces strong competition for
these markets from makers of plastic, aluminum, and alumi-
num foil substitutes. The kraft industry appears to be holding
a fairly constant share of this growing market through con-
tinued research and development of products adapted to th&
customers
[p. 4-75]
needs. Maintenance of its price position relative to the prices
of substitutes is essential if it is to maintain its market share.
Foreign competition is primarily in the form of imported
pulp, which amounts to just under 5 percent of U. S. produc-
tion. Canada supplies approximately 90 percent of imported
pulp and has been an important factor in the newsprint and
printing paper market. Kraft pulp and paper are exported
from the U. S., accounting for over half the industry exports.
b. Trends.—The dominant pattern in the industry is the
investment price cycle. Although demand has tended to in-
crease fairly steadily, roughly proportional to population
growth with less than the national average reflection of the
general business cycle, investment in the paper industry tends
to follow a five year cycle. At the beginning of the cycle the
industry invests heavily and competitively to meet actual and
anticipated growth in demand. When new facilities come into
production, the industry as a whole is faced with overcapac-
ity. Prices decline as firms compete for markets, profits are
depressed, and investment is cut back. As demand catches up
to supply, prices increase, profits improve, and new invest-
ment is undertaken. This pattern tends to keep profits gener-
ally below the average of manufacturing firms in general. The
industry appears to be in the rising price phase of the cycle in
1970 and increased investment may be expected in 1971 and
1972, followed by potential excess capacity.
Another important trend of recent years has been to more
highly integrated firms and inclusion of kraft paper firms in
conglomerates. The small percentage of pulp entering the
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2502 LEGAL COMPILATION—Am
open market is a good indicator of the extent of vertical
integration that has occured.
Paper firms have been diversifying, also, using their land
and forest resources to enter the recreation, real estate,
[p. 4-76]
and lumber markets. Conversely, firms formerly in the lumber
and plywood industries have diversified into paper products
as have firms producing competing container products.
6. Economic Impact of Control Costs.—a. Cost for Model
Plants.—In order to illustrate the varying impact of control,
two plant sizes and the associated investment and annualized
cost are shown below.
Mill size
(tons/day)
145
1,000
Investment
$160, 100
862,000
Total annual cost
$ 61 ,420
381,550
Cost of control/to n
pnduced*
J1.24
l.H
'Assuming production at 89 percent of capacity.
These results assume venturi scrubbers were used to con-
trol emissions from the recovery furnaces, lime kilns, and
smelt-dissolving tanks. Redesigned multicyclones were as-
sumed to be used to control emissions from the bark boiler.
The 145 tons/day mill size was assumed to have one recovery
furnace, one lime kiln, one smelt-dissolving tank, and one
bark boiler; the 1,000 tons/day mill size was assumed to have
two of each of these units, with larger operating capacities.
The costs are not directly proportional to the number of
units of equipment to be controlled, but vary according to size
as well. About 45 percent of the United States plants approxi-
mate the 1,000 tons/day mill size and about 16 percent ap-
proximate the 140 ton/day mill size. The costs range from
$1.14 to $1.24 per ton of sulfate pulp. These costs are rela-
tively low when compared to the sales price of market pulp,
which was about $124 per ton in 1968.
[p. 4-77]
b. Impact on the Industry.—Depending primarily on mill
size, location, degree of vertical and horizontal integration,
and financial position, impact will vary across the industry.
The most severe impact will be on the marginal noninte-
•grated firms that have all their plants in air quality control
regions. Most of the firms are vertically integrated and have
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GUIDELINES AND REPORTS 2503
some or all of their plants in air quality control regions.
These facts, along with the increasing demand for pulp and
paper exports, the upward pressure on pulp and paper prices,
and the favorable economic position of customer industries,
should enable nearly all industry firms to apply controls and
pass the control cost on to the customer.
[p. 4-78]
K. Lime
1. Introduction.—The basic processes in the production of
lime are quarrying limestone (high calcium or dolomitic), pre-
paring the limestone for kilns (crushing and sizing), and calcin-
ing the stone. The lime may be processed further by additional
crushing and sizing and hydration. In some cases, clam or oys-
ter shells serve as kiln feed. The products of lime manufactur-
ing are limestone, quicklime, and hydrated lime. The product is
further classified as high-calcium or dolomitic depending on the
percentage of magnesium carbonate present in the raw mate-
rial. High calcium lime is produced from stone containing at
least 95 percent calcium carbonate, while dolomitic lime is pro-
duced from limestone containing 30-45 percent of magnesium
carbonate. Most hydrated lime is packaged in multi-wall paper
bags with very little bulk shipment, while the opposite condition
prevails for quicklime. Quicklime is commercially available in
these forms: lump, pebble, ground, pulverized, and pelletized.
Quicklime is very reactive to water and carbon dioxide and is
generally manufactured as it is needed, with very little stockpil-
ing. One hundred pounds of pure calcium carbonate limestone
will calcine to 56 pounds of quicklime, which when completely
reacted with 18 pounds of water will result in 74 pounds of
hydrated lime. The leading uses of open market lime are as steel
flux, refractory lime, in construction, and in water softening
and treatment. Agricultural lime accounts for approximately
2 percent of sales.
The majority of lime is produced in rotary kilns or shaft
(vertical) kilns; both are fired by coal, oil, or gas. Other types
of calcinators are in use, but the production from them is con-
sidered insignificant compared to the two named above. It is
estimated that rotary kilns account for 80 percent of lime pro-
duced, with the remaining production coming from vertical
kilns. Rotary kilns have the advantages of high production per
manhour and uniform quality production but require higher
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2504 LEGAL COMPILATION—AIR
capital investment and have higher unit fuel costs than most
vertical kilns. The open market industry
[p. 4-79]
trend is toward installation of larger capacity rotaries with a
far higher capacity than vertical kilns.
2. Emissions and Costs of Control.—Particulate emissions in
the form of limestone and lime dust are the main source of
pollution from the lime industry. At almost every step of the
manufacturing process, dust is emitted. The following processes
are involved: drilling holes in the quarry for explosives, blast-
ing, loading stone for transport, transporting the stone (often
over unimproved roads), crushing, pulverizing, and vibrating
for sizing. At the plant site, limestone is usually moved between
operations on open belt conveyors. The lime kiln is probably the
major source of particulate emissions at the plant site; the
estimates of emissions and control cost given here are limited to
kilns, since this is the source for which control is available.
Estimates for rotary kilns place the dust emissions at 5 to 15
percent of the weight of the lime produced, while vertical kiln
emissions are only about 1 percent of the weight of the lime
produced. Combustion of fuels for lime burning is another
source of lime plant pollution.
Particulate emissions from plants in the 298 regions in 1967
are estimated to have been 181,000 tons, allowing for an aver-
age control level of 60 percent for the industry. Predicted
growth of the industry would increase emissions to 253,000 tons
by FY 1976 with the control level unchanged. Installation of
cyclonic scrubbers on vertical kilns and venturi scrubbers on
rotary kilns can achieve 97 percent control of emissions, reduc-
ing the FY 1976 emissions to 20,300 tons of particulates. For
this sector of the industry, the total annual cost of control by
FY 1976 is estimated to be $14.5 million and the investment
requirement is estimated to be $10.6 million.
#. Scope and Limitations of Analysis.—The technical and cost
analysis in this section deals with the entire lime industry ex-
cept plants captive to the paper industry. The analysis of eco-
nomic impact is focused on the firms in the open market, since
it is there that the economic effect is most clearly defined. The
incidence of the incremental cost resulting from air pollution
control in captive plants depends
[p. 4-80}
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GUIDELINES AND REPORTS 2505
upon the accounting conventions and the ownership form fol-
lowed between captive and parent company.
For the United States, 121 firms were identified as selling
lime in the open market. From the data available it was not
possible to determine accurately how many of the plants in-
cluded within the 298 metropolitan areas were captive, but it
may be assumed that the proportion of captive to open market
is approximately the same for the 298 areas as for the United
States, i.e., 42 percent. Data on revenue and profit by firm or
plant was not available.
It. Industry Structure.—Since 1963, the United States Bureau
of Mines has reported the number of active lime plants in the
United States and Puerto Rico which sold lime. These can be
considered the open market commercial plants. In the United
States and Puerto Rico in 1967, there were 121 active plants
which sold lime. There were 185 captive and open market plants
in the United States and 113 in the 298 metropolitan areas.2
The number of plants has declined significantly since early in
the century due to economic changes in the industry, but the
decline has leveled off since the beginning of the 1960's, averag-
ing about 124 plants from 1963 to 1968. There may be further
slight declines as small producers find it less and less profitable
to operate. The opening of new, efficient plants probably will
offset the closures and some existing plants will expand their
capacity.
There are no complete data on plant size for the open market
producers. Examination of available data, primarily Dun and
Bradstreet reports and trade journal articles, indicates that
plants range in size from 1-4 employees to over 200 employees,
with many plants in the 30-70 employee range. Capacity data
for the open market producers are equally scarce. Some of the
larger producers have been covered in articles in the trade jour-
nals and several have reported capacities in the 1000-1500 tons
per day category. The smallest plants are not reported in the
literature but given an employment category of 1-4, it is almost
certain that some plants operate with only a single, small capac-
ity (5-20 tons per day) vertical kiln.
•This does not include lime kilns captive to Kraft (Sulfate) Pulp Plants.
[p. 4-81]
It is reported that open market lime is produced in thirty-
three of the 50 states. In number of commercial plants, Ohio led
the nation in 1967 with 15, followed in order by Pennsylvania
•526-705 O - 74 - 11
-------
2506 LEGAL COMPILATION—AIR
with 14, Virginia and Texas each with 9, and California with 6.
Sufficient data are not available to rank the states by open
market production for 1967, but reports the 1963 ranking as:
(1) Ohio, (2) Missouri, (3) Pennsylvania, (4) Virginia, (5)
Alabama and (6) Texas. The eastern half of the United States
is the location for the majority of producers apparently because
of the quality of the lime deposits found there. Open market
producers are scattered sparsely throughout the western half of
the nation without concentration in any one area except for the
California - Southern Nevada area.
Many firms are multi-plant producers. According to a Na-
tional Lime Association Map, one company had eight plants in
operation in 1967 with some other firms operating from three to
seven plants.
5. Market.—a. Competition Among Sellers.—The lime indus-
try is reported to be intensely competitive. This condition
may exist largely as a result of the threat of captive lime.
Lime producers are constantly faced with the possibility that
the buyers of the product may begin producing lime them-
selves, and many have done so in recent years. About 60
percent of captive production is the inevitable result of the
producers' need for an economical source of carbon dioxide
and, in some cases, the lime itself; for example, the alkali
industry and sugar refineries. Also, much of the captive pro-
duction is done by industries which normally would purchase
lime from a commercial producer, e.g., steel producers and
copper smelters.
The competitive pressure is probably most severe in those
areas with a number of producers supplying essentially a
uniform grade of lime. Additional competitive pressure may
result from the desire of firms to attain the higher profit
[p. 4-82]
margins usually associated with producing nearer optimum
capacity. Quicklime is reactive to atmospheric moisture and
should be used quickly—within a month or two—after manu-
facture. Since any which has been produced and not sold is, of
course, subject to becoming waste, the firm would face some
pressure to dispose of it.
There may be a few plants in the Midwest which experi-
ence little competition in this immediate marketing area due
to the sparseness of producers, but even these would face
some competition on the outer fringes of their market.
-------
GUIDELINES AND REPORTS 2507
b. Economic Position of Customer Industries.—Use as steel
flux is the leading single market for lime at present, with over
a third of open market lime going for this one use. With the
increased use of the basic oxygen furnace (EOF) in the steel
industry, expectations are that as much as 40 percent of open
market production may go for this use by 1975.
Refractory lime (dead-burned dolomite) for the open
hearth steel furnaces, long the leading single use for open
market lime, dropped from first place in the early 1960's with
the steel industry's change over to the basic oxygen process.
The expectation of the industry is that refractory lime will
continue to decline in importance as a market for the product
as the switch to the EOF continues.
Taken as an industry, construction usages are an important
market for lime, with particular promise being held for the
use of lime in soil stabilization in highway, parking lot and
airport runway construction and in foundations for large
buildings. The pulp and paper market continues in impor-
tance to the open market lime producers. Increased usage is
expected in water treatment and softening and in sewage and
trade waste treatment. The calcium carbide and alkalie indus-
tries have been declining markets for lime and are expected to
continue to decline in importance.
[p. 4-83]
The economic position of the lime consumers appears sound
in the immediate future. Optimistic projections prevail for
the steel industry, with estimates of 150 million net tons of
steel production by 1975. This represents a growth in steel
production of approximately 3.9 percent. The pulp and paper
industry should also experience favorable economic conditions
with new and expanded product lines.
c. Foreign Competition and Markets.—United States im-
ports of lime have been declining each year since 1965 when a
decade high of 276 thousand tons were imported. In recent
years virtually all of the imported lime has been from Can-
ada. The reason for the mid 1960's high import tonnage may
have been the sudden demand produced by the steel producers
with the increased production of basic oxygen furnaces. Do-
mestic producers were not able immediately to meet all the
demand with existing capacity and widespread expansion in
the lime industry can be seen following 1965. As United
States capacity began to reach adequate levels to supply the
-------
2508 LEGAL COMPILATION—AIR
steel industry, the need to import lime was reduced. Foreign
competition in lime should not be a problem to the industry in
the early 1970's since the increased capacity of United States
producers appears adequate to supply the known markets.
The only chance of foreign gains would be in the event of the
opening of a sudden, wide market for lime. Some imports can
be expected to continue since there are Canadian producers
closer to certain United States markets than any United
States producer. This is the case in the far Northeast, and
generally along the United States Canadian border. Also,
there are a number of Canadian producers in Ontario who
must be considered competitors in the Ohio-Michigan-Penn-
sylvania marketing area.
The export market for United States lime does not appear
significant. The 1968 data indicate that exports that year
were 69,000 tons, about l/2 percent of United States open
market lime sold. As might be expected, most exports go to
Mexico and Canada; the two countries combined receive
80-90 percent of United States export lime.
[p. 4-84]
6. Trends.—a. Production.—The production of open market
lime in the United States and Puerto Rico increased from
8,190 thousand tons in 1960 to 12,100 thousand tons in 1968,
an increase of about 48 percent. This large increase in pro-
duction was spurred by several new and expanded uses of the
product and follows a decade of rather lacklustre perform-
ance by the industry. In 1967, open market production was
11,500 thousand tons, 40 percent above the 1960 level. The
remarkable growth of the lime industry in the 1960's was a
result of increased use of basic oxygen furnaces in the steel
industry, with the associated higher levels of lime usage per
ton of steel produced. The open hearth furnaces require about
20 pounds of lime for each ton of steel produced, while the
basic oxygen process needs about 150 pounds of lime for each
ton of steel produced. Increased usage of lime was also seen in
soil stabilization, sewage and water treatment, and water
softening. Optimism prevails in the industry and open market
production is expected to continue to grow at a healthy pace
into the seventies.
b. Price.—Price data for open market lime are available in
Bureau of Mines Reports only for 1963-68. During this pe-
riod, the national average f.o.b. plant price of lime without
-------
GUIDELINES AND REPORTS 2509
containers declined from $14.47 per ton to $13.71 per ton, a
drop of 5.3 percent. Although not certain, this depression in
the price level may partially be the results of hard bargaining
by steel firms for lower prices. This trend did not hold in all
areas during the period, however. In Texas, the f.o.b. plant
price of lime rose from $10.94 per ton in 1963 to $12.63 per
ton in 1968, a 15 percent increase. The available data indicate
that a declining price trend existed in a number of major
producing states: Michigan, Ohio, Pennsylvania, and
[P. 4-85]
California. Con.fiTvliq.tion of depressed prices i» unlikely in
the face of rising production costs, however. The average
f.o.b. plant price of lime sold increased marginally between
1967 and 1968, from $13.68 per ton to $13.71 per ton. The
price trend may turn up after initial competition from the
steel business.
Another contributing factor to lower prices in most areas
may have been that a number of new efficient plants went on
line during this period, as well as new capacity at established
firms. There is a definite trend toward larger plants, and the
economies achieved with the newer, higher capacity kilns may
have resulted in downward pressure on prices.
c. Technology.—Technological advances usually come from
outside the industry proper. Sources of advancements are
equipment manufacturers, industrial users of lime, and fel-
lowships supported by the National Lime Association. In the
last category have been research fellowships dealing with
lime use in soils stabilization, asphalt paving, masonry mor-
tars, autoclaved concrete products, steel fluxing, acid neutrali-
zation, trade-waste treatment, and agricultural lining. The
National Lime Association was instrumental in the market
development and promotion of lime as a soils stabilization
agent. This is now one of the most promising markets for the
product. Continued research and development by equipment
manufacturers have led to higher capacity thermally efficient
kilns, both vertical and rotary. Industry spokesmen continue
to stress the need for increased research, development, and
marketing efforts by those in the industry, but without much
effect. Even during relatively prosperous periods, the indus-
try seems unwilling to invest in adequate research to insure
continued vitality; the reluctance has been even more pro-
nounced in the past during less prosperous periods. Low
-------
2510 LEGAL COMPILATION—Am
profit margins have been blamed as the reason for lack of
research.
7. Economic Impact of Control Costs.—a. Control Cost Fac-
tors.—The investment required and the annual cost of control
[p. 4-86]
equipment varies according to the size and type of kiln. In
1967 a typical vertical kiln of approximately 100 tons per day
capacity would require a cyclonic scrubber with an installed
cost of approximately $20,000 and the annual cost, including
depreciation, finance costs, and operating expenses, would be
approximately $7,300 per year. A typical rotary kiln will be
somewhat larger, with a capacity of approximately 400 tons
per day. This would require a venturi scrubber with an in-
stalled cost, in 1967 prices, of just under $30,000 and an
annual cost of approximately $45,000. Overall, for the captive
and open market plants in the 298 metropolitan areas, aver-
age investment is estimated at $67,000 per plant and average
annual cost at $92,000 per plant in 1967.
b. Model Firms, As Examples.—Costs of controlling parti-
culate emissions from lime kilns have been estimated for five
model firms. The model firms were constructed to illustrate
the costs to be encountered by firms with production solely
from vertical kilns, solely from rotary kilns, and a combina-
tion of both types of kilns, with the firms spread over a wide
capacity range.
Model Firm #1—A very small single-plant lime firm
with production entirely from low capacity vertical kilns.
Kilns: 4 vertical kilns rated at 15 tons/day (TPD) capac-
ity each. Plant capacity: 60 TPD. Annual costs of control:
$2,500. Assuming the industry preferred operating rate of
92 percent for FY 1976, and 300 producing days per year,
production of this plant would be 16,550 tons of lime. An-
nual cost per ton of production = $0.15.
Model Firm #2—A medium-sized, single-plant firm with
production entirely from a rotary kiln. Kiln: 1 rotary kiln
rated at 200 TPD capacity. Annual costs of control:
$33,000. Annual production: 55,200 tons. Annual cost per
ton of production: $0.60.
[p. 4-87]
Model Firm #3—A medium-sized, single plant firm with
capacity comparable to Model Firm #2, but utilizing mod-
ern vertical kilns. Kilns: 2 vertical kilns rated at 100 TPD
-------
GUIDELINES AND REPORTS 2511
capacity each. Plant capacity: 200 TPD. Annual costs of
control: $12,600. Annual production: 55,200 tons. Annual
cost per ton of production: $0.23.
Model Firm #4—A large, single-plant firm with produc-
tion from both high capacity rotary kilns and modern verti-
cal kilns. Kilns: 2 rotary kilns rated at 400 TPD capacity
each. 2 vertical kilns rated at 125 TPD capacity each. Plant
capacity: 1,050 TPD. Annual costs of control: $151,800.
Annual production: 289,800 tons. Annual cost per ton of
production: $0.52.
Model Firm #5—A large, multi-plant firm with produc-
tion primarily from high capacity rotary kilns. Kilns:
Plant #1:1 rotary kiln rated at 300 TPD capacity. Plant
#2:1 rotary kiln rated at 350 TPD capacity. 1 rotary kiln
rated at 500 TPD capacity. 2 rotary kilns rated at 250 TPD
capacity each. Plant #3: 6 vertical kilns rated at 50 TPD
capacity each. 1 rotary kiln rated at 400 TPD capacity.
Firm capacity: 2,350 TPD. Annual costs of control:
$355,400. Annual production: 648,600 tons. Annual cost per
ton of capacity = $0.55.
c. Demand Elasticity and Cost Shifting.—Based on availa-
ble information, there seems little reason to believe that costs
of particulate emission control can be passed on to buyers of
lime. The overall market for lime has been increasing in re-
cent years and in most applications there exists no suitable
substitutes at anywhere near comparable prices. Lime has
faced competition or replacement from the
[p. 4-88]
products in a few markets, primarily agricultural and con-
struction users, however, and price increases would almost
certainly weaken lime's competitive position in these markets.
The exceptions to this may be in cases of isolated producers
who are not faced with competition in their immediate mar-
keting areas. Competition in the industry is characterized as
very severe, and it seems unlikely that a producer will in-
crease his price in the face of competition from other pro-
ducers in the marketing area who are not faced with control
costs. This condition of forced absorption of costs is most
likely to occur in those areas with a large number of pro-
ducers, many of whom are not in the 298 metropolitan areas.
Lime is both a raw material input to manufacturing proc-
esses and a final product. It is possible, then, that in the latter
-------
2512 LEGAL COMPILATION—Am
case, some reduced demand may result from a price increase,
aside from the losses due to substitute availability.
It is generally true that costs per ton of production de-
crease as the operating ratio increases, and that economies of
scale usually insure that larger plants have lower unit costs
than smaller plants. It is estimated that for 1964, the range of
manufacturing costs for a short ton of quicklime is from a
minimum of $6.05 to a maximum of $16.25. This would imply
that the profitability range is also quite wide.
Estimates reveal that the highest annual control costs per
unit of production will be experienced by plants with very
small (less than 15 TPD capacity) vertical kilns, but that
plants with larger vertical kilns (15 TPD and over) will
experience the lowest annual control costs per unit of output.
Except at the very low end of the rotary capacity scale
(100-175 TPD), rotary kiln annual control cost per unit of
output is almost constant.
In some marketing areas, the existing competitive structure
may no longer hold, since some firms will not face control at
all and others may find their competitive positions improved
in relation to other controlled firms that experience higher
unit control costs. A firm may find its marketing area ex-
panded or contracted as a result of. the imposition of controls.
[p. 4-89]
d. Effect on the Industry.—The imposition of controls on
particulate emissions may have a number of short-and-long-
range effects on the lime industry.
One immediate effect is likely to be a reduction in industry
capacity as very small vertical kilns facing high control costs
are abandoned. The number of open market firms may be
further reduced by the closure of marginally operating plants
of any size, which cannot absorb the costs of control equip-
ment. To compensate for the loss of this capacity, production
will be increased from the larger kilns and the industry oper-
ating ratio will increase. Firms which had been operating
close to capacity may launch an expansion program as a re-
sult of lost capacity.
A second effect of control may be a renewed interest in the
use of vertical kilns. The lower relative costs associated with
controlling the large vertical kilns coupled with their excel-
lent thermal properties and lower investment costs may make
them more desirable in some applications. It may be that the
-------
GUIDELINES AND REPORTS 2513
trend toward high capacity rotary kilns will be slowed some-
what.
A third effect on the industry could be an increased empha-
sis on applied research in an attempt to recoup the costs of
control by lowering other production costs.
The open market lime industry may benefit somewhat by
the imposition of control costs. Captive lime plants have al-
ways been a problem to open market firms and each year
captive production has increased, representing 35-40 percent
of total lime produced. The added production cost of emission
control may make captive production of lime less desirable for
those industries needing large amounts of lime - most notably
steel and pulp and paper. More of those firms buying open
market lime may continue to do so than would have been the
case before the addition of control costs. Further, a
[p. 4-90]
situation can be hypothesized in which a captive lime producer
may, when faced with control costs, choose to reduce or dis-
continue entirely the manufacture of lime and begin purchas-
ing from open market producers.
Control costs will add momentum to the current trend to-
ward larger plants. Increased costs of labor, fuel and equip-
ment have made it more economical to operate on a large
scale, and the additional burden of controlling emissions will
make economies of scale even more important.
[p. 4-91]
L. Petroleum Refining and Storage
1. Introduction.—Three processes in petroleum refining have
been identified as sources of pollutant emissions. These are stor-
age of crude oil or refined products, combustion processes, and
catalyst regeneration. In addition, significant emissions are re-
leased by certain bulk storage tanks where petroleum products
are stored for distribution. The analysis in this section is lim-
ited to the nature, control, and costs of these four sources.
2. Emissions and Costs of Control.—At a refinery, both crude
oil and refined products, especially gasoline, tend to give off
hydrocarbon emissions due to evaporation while being held in
storage tanks and in transfer. In addition, significant hydrocar-
bon emissions result from the operation of catalytic crackers.
For the 199 refineries identified as being within the 298 metro-
-------
2514 LEGAL COMPILATION—AIR
politan areas in 1967, it is estimated that these hydrocarbon
emissions amounted to approximately 810,000 tons in that year
taking into account existing carbon monoxide boilers on cata-
lytic crackers and assuming that 67 percent of all refinery tanks
were controlled by floating conservation roofs and submerged
fill lines. If this level of control were maintained, it is estimated
that industry growth would cause emissions from this source to
increase to 996,000 tons per year in Fiscal Year 1976. Installa-
tion of floating roofs on all refinery tanks within the 298 metro-
politan areas and installing carbon monoxide boilers where
needed would reduce Fiscal Year 1976 emissions to 529,000 tons,
the maximum control effectiveness (87 percent) feasible with
present technology.
Sulfur oxide emissions from hydrogen sulfide combustion op-
erations in refineries are best controlled by use of sulfur recov-
ery plants. The available data indicate that 67 of the 199 refin-
eries had sulfur plants in 1967. Thus, the 199 plants emitted
1,750,000 tons of sulfur oxides per year and it is estimated that
industry growth would increase this to 2,150,000 tons by Fiscal
Year 1976 with the same 37 percent level of control. Installation
[p. 4-92]
of sulfur plants on all refineries subject to regulation could
reduce the Fiscal Year 1976 emissions of sulfur oxides to
1,270,000 tons per year, which is a 62 percent level of control.
The remaining sulfur oxide emissions result from operations
involving the combustion of natural gas and/or fuel oils for
process purposes. These are not generally amenable to control.
Regeneration of the catalysts used in fluid catalytic cracking
units results in emission of particulates and carbon monoxide.
Catalyst fines are entrained in the off-gasses from the regenera-
tor. Some of these are collected and returned by normal process
equipment, but an estimated 0.10 pounds of particulates per ton
of catalyst processed is emitted in the absence of air pollution
control equipment. Installation of electrostatic precipitators
provides the maximum control now available. In 1967, the rege-
nerators in the refineries in the metropolitan areas emitted an
estimated 80,000 tons of particulates at an average industry
control level of 67 percent. Normal growth of the industry
would increase this to 98,300 tons by Fiscal Year 1976. Installa-
tion of precipitators in all plants would reduce Fiscal Year 1976
emissions to 30,700 tons.
-------
GUIDELINES AND REPORTS 2515
Carbon monoxide in the exit gas of regenerators was con-
trolled by use of a carbon monoxide boiler in 70 refineries in the
298 metropolitan areas in 1967, but there was still an estimated
5,300,000 tons of carbon monoxide emissions in that year (47
percent controlled). The carbon monoxide boiler burns the car-
bon monoxide into carbon dioxide and provides a substantial
source of heat for process use, in addition to controlling pollu-
tion. Installed in all the subject refineries they would control all
but a negligible amount of carbon monoxide emissions. Without
this control, it is estimated that carbon monoxide emissions
would increase to 6,620,000 tons per year in FY 1976.
Within the complex system for wholesale distribution of pe-
troleum products around the country, there are approximately
15,000 storage plants located within the 298 metropolitan areas.
The storage tanks in these plants are potential sources of hydro-
carbon emissions if uncontrolled. All storage tanks in California
and approximately 75 percent of the remainder in the United
States were controlled by use of floating roofs.
[p. 4-93]
Emissions from the uncontrolled tanks in metropolitan areas
were estimated at 600,000 tons of hydrocarbons in 1967, pro-
jected to grow to 738,000 tons per year by Fiscal Year 1976.
Installation of floating roofs on all uncontrolled tanks could
reduce the Fiscal Year 1976 emissions to approximately 320,000
tons per year.
By Fiscal Year 1976, the investment requirement for petro-
leum refining will be $162.0 million and the annual cost will be
$7.1 million. With these expenditures, emission control levels
can be expected to be about 90 percent for particulates, 62
percent for sulfur oxides, 95 percent for carbon monoxide and
87 percent for hydrocarbons.
With the installation of floating roofs that practically elimi-
nate evaporation, the annual cost of the petroleum storage in-
dustry is considered negligible. By fiscal Year 1976, the invest-
ment requirement will be $1,082.0 million. The associated hydro-
carbon emission control levels approximate 63 percent in 1967
and would be about 86 percent in Fiscal Year 1976.
3. Scope and Limitations of Analysis.—Analysis of refinery
emissions and control equipment was, in almost all cases, based
on data for each refinery involved. Control costs have been esti-
mated on a less rigorous basis as indicated below, but are con-
sidered representative of actual cost expectations. Because the
-------
2516 LEGAL COMPILATION—AIR
total annualized cost is not estimated to be large enough to
influence prices, no analysis of market patterns is presented.
4. Industry Structure.—Nearly all bulk storage plants are
owned by producers of petroleum products. Although approxi-
mately 256 firms are listed as petroleum refiners, the bulk of the
industry is concentrated in 30 to 35 firms. Of these, 16 are fully
integrated international corporations making up the so-called
"large majors" of the industry. Another eight firms may be
classed as "small majors" and are also fully integrated. The
remainder of the firms in the industry are somewhat smaller
and either not fully integrated or operate in a limited market.
[p. 4-94]
Petroleum is an oligopolistic industry characterized by sharp
retail competition that usually concentrates on competitive ad-
vertising at the retail level, but experiences frequent price wars
as well. In its purchases of crude oil from independent produc-
ers, it is much less likely to compete on price.
The entire industry is subject to foreign competition, but at
present this is minimized through quotas under the oil import
program. The effect of the quota system is to effectively set a
base price higher than would probably be set were unlimited
imports permitted.
Statistics concerning the petroleum industry will be found in
Tables 4-11 and 4-12.
TABLE 4-11.—1967 STATISTICS ON THE PETROLEUM REFINING INDUSTRY
United States Metropolitan
areas
Number of plants 256 199
Capacity (millions of barrels) 4,210 3,620
Production (millions of barrels) 3,580 2,720
Value of shipments (millions of dollars) 20.29 15.41
TABLE 4-12—1967 STATISTICS ON THE PETROLEUM PRODUCTS AND STORAGE INDUSTRY
United States Metropolitan
areas
Number of plants 29,664 14,998
Capacity (millions of barrels) 182 129
Production (throughput—millions of barrels) 1,840 1,290
Value of shipments (billions of dollars) 22.50 15.80
[p. 4-95]
5. Economic Impact of Control Costs.—a. Cost Factors.—
Floating roofs for refinery tanks are estimated to require an
investment of approximately $53,000 each, based on a typical
-------
GUIDELINES AND REPORTS 2517
tank size assumed to be 80,000 barrels capacity. Since this
control reduces vapor loss by more than 90 percent, it results
in preventing the loss of a valuable product. This saving more
than offsets the total annualized cost of control. The same is
true for distributor's storage tanks, except that the invest-
ment per tank is calculated to be only $16,000 for a typical
tank of 6,900 barrels capacity.
Sulfur recovery plants vary in cost depending upon size,
which is a function of the daily quantity and sulfur content of
crude oil refined. For those refineries not listed as having
sulfur recovery plants in 1967, this cost was calculated on the
basis of plant size necessary for the listed capacity of the
refinery and its estimated sulfur oxide emissions. Sulfur re-
covery plants of four tons per day capacity or larger were
considered economically feasible, requiring investment rang-
ing from slightly over $100,000 for four tons capacity to
approximately $630,000 at 100 tons capacity. Annual cost for
sulfur recovery plants was estimated as 20 percent of invest-
ment after allowance for the value of sulfur produced. The
market value of sulfur is, of course, subject to change if large
additional supplies are marketed. However, since it appears
that the sulfur recovery plants now in use at petroleum refin-
eries are operated at or above the breakeven point, it is as-
sumed for this analysis that additional plants could produce
revenues at least equal to annual operating costs.
Electrostatic precipitators for control of particulate emis-
sions from catalyst regenerators on fluid catalytic cracking
units vary in cost depending on size. It is estimated that the
average refinery would invest approximately $565,000 for
each precipitator. The total annualized cost per precipitator is
estimated to average $92,500.
[p. 4-96]
Carbon monoxide boilers to control carbon monoxide and
hydrocarbon emissions from catalyst regenerators were esti-
mated on the basis of the heat content of the gas stream for
each affected refinery and the price of boilers. The average
investment required would be approximately $3 million per
boiler, of which 50 percent is charged to air pollution control,
since the steam generated may also be considered a part of
the normal operating process of the refinery. Similarly, the
-------
2518 LEGAL COMPILATION—AIR
annualized cost may properly be considered to be production
cost rather than cost of pollution control.
b. Aggregate Industry Costs.—For the petroleum industry
as a whole, installation of the controls specified in this analy-
sis would require, by the end of Fiscal Year 1976, a total
investment of approximately $1,242 million. Given the as-
sumptions stated above, annual cost to the industry would,
however, amount to only an estimated $7 million per year
upon completion of installation of controls in Fiscal Year
1976.
c. Two Model Firms as Examples of Economic Impact of
Control Costs.—Two hypothetical petroleum companies may
be used to illustrate the impact of the investment require-
ments and annual costs described above.
Model Firm A
Description: A fully integrated national producer, opera-
ting ten refineries, of which eight are within 298 metropolitan
areas. Total crude oil refining capacity, 877,000 b/cd. Gaso-
line production, 52.6 percent of crude oil. Capacity utilization,
88.6 percent. Gross revenue, 1967, $7,860 million. Net income,
1967, $640 million.
[p. 4-97]
AIR POLLUTION CONTROL
Equipment Number Investment Annual cost
At refinery:
Carbon monoxide boiler
Storage tank roof s
Electrostatic precipitators
At distribution points: Storage tank roofs
Total
4
5
53
. . .. 4
2,924
6,000 000
1 310 000
2,810,000
2,260,000
46,800,000 .
59,180 000
262 000
370,000
632,000
Model Firm B
Description: A small independent partially integrated firm,
operating one refinery located in a metropolitan area. Total
crude oil refining capacity, 53,000 b/cd. Gasoline production,
51 percent of crude oil. Capacity utilization, 85 percent. Gross
revenue, 1967, $57 million. Net income, 1967, $11 million.
-------
GUIDELINES AND REPORTS
2519
AIR POLLUTION CONTROL
Equipment
Number
Investment Annual cost
At refinery:
Carbon monoxide boiler
Sulfur plant .
Storage tank roofs .
Electrostatic precipitators
At distribution points: Storage tank roofs
Total
. . 1
1
. .. . 18
1
160
$1,500,000
140,000
288,000
565,000
2,560,000
5,053,000
$28,000
92,500
120,500
d. Impact on the Industry.—If the total annualized cost of
air pollution control for the petroleum industry, as estimated
here, were added to the price of the estimated gasoline pro-
duction in Fiscal Year 1976, it would increase that price by
approximately $0.0021 per barrel ($7 million -=- 3,300 million
barrels). Costs of this magnitude are not likely to have a
visible effect upon the final prices of petroleum products, nor
are they large enough to significantly reduce the profits of the
199 refiners involved. Much more significant is the magnitude
of the
[p. 4-98]
investment involved. It appears that this industry will be
required to invest $1.2 billion by Fiscal Year 1976. At the
same time, it appears that there will be a substantial excess
of demand for petroleum products and producers will be
under pressure to expand their exploration expenditures and
increase production capacity. Some companies may find it
difficult to raise the capital essential to their total investment
program.
[p. 4-99]
M. Primary and Secondary Nonferrous Metallurgy
1. Introduction.—This section deals with firms engaged in the
production of four nonferrous metals—aluminum, copper, lead,
and zinc—by primary reduction from the ore and by secondary
scrap processing. These might be considered as four separate
industries except that many of the firms produce more than one
metal and the products are directly competitive for many uses.
Until recently, the primary aluminum industry has been almost
entirely separate from the others, but the last few years have
seen the beginning of what appears to be a trend towards fur-
ther integration of the sectors of this industry group.
-------
2520 LEGAL COMPILATION—AIR
Engineering, market, and cost data are discussed separately
where appropriate, and the economic impact of control costs on
firms and the industry analyzed within the interconnected eco-
nomic framework of the industry.
2. Sources of Emissions.—The smelting and refining proc-
esses used in the primary production of all four metals involve
emissions of particulates, sulfur oxides, and lead. In addition,
fluorides are emitted by the electrolytic cells used to reduce
alumina; control of this pollutant to the specified standard re-
sults in control of the other pollutants to levels exceeding the
stipulated standards in primary aluminum production. The
melting of scrap and refining and alloying processes employed
by secondary producers are sources of particulate emissions.
These result primarily from the various contaminants in the
scrap, such as paint, insulation, oil, and dirt.
3. Emissions and Costs of Control.—a. Primary Aluminum
Emissions and Controls.—It is estimated that emissions from
primary aluminum plants at a 90 percent level of control in
1967 were 6,000 tons of particulates and 8,200 tons of fluor-
ide, both gaseous and particulate. At the same level of con-
trols, there would be 8,900 tons of particulates and 12,200
tons of fluorides by Fiscal Year 1976.
There are three types of electrolytic cells used in producing
aluminum: prebaked, vertical spike soderberg, and horizontal
[p. 4-100]
spike soderberg. It has been determined that the control tech-
nique utilized by the industry in 1967 was to vent individual
cell emissions to primary cyclones and simple wet scrubbers,
yielding overall control efficiencies of 90 percent for both par-
ticulates and fluorides. To meet the applicable standards (Ap-
pendix II) a combination of control systems utilizing more
efficient individual cell control systems plus new cell-room
control systems was assumed. Engineering analysis indicates
that the most effective cell control equipment would be that
shown in Table 4-13.
TABLE 4-13.—CELL CONTROL EQUIPMENT
Cell type Control equipment Removal efficiency
Prebaked Fabric filter-precoated with alumina . 94 percent; gaseous f
>99 percent; all particulates.
Vertical spike soderberg Electrostatic precipitator +2 scrubbers in series >99 percent; gaseous f
>99 percent; all particulates.
Horizontal spike soderberg... Floating bed scrubbers 95 pecrent; total F
99 percent; all -particulates.
-------
GUIDELINES AND REPORTS 2521
Design of the new control system assumed herein would
include new and more effective hoods for each cell. Approxi-
mately 90 percent of the total pollutant emissions can ba
captured with improved hoods and ducted to the new control
equipment specified. It is assumed that 10 percent of the emis-
sions will still escape into the cell room and be carried by the
cell room ventilation system to a wet scrubber, where 90
percent removal will be accomplished. The overall efficiency of
the combined system would be 98 percent removal of both
particulates and fluorides, which meets applicable standards
(Appendix II). Resultant estimates of the FY 1976 annual
[p. 4-101]
emissions for the aluminum industry with these controls in
place are 1,700 tons of particulates and 2,300 tons of fluor-
ides.
b. Primary Copper Emissions and Controls.—The 1967
level of control for sulfur oxide emissions from primary cop-
per smelters is estimated to have been 25 percent, resulting in
release of an estimated total of 2,140,000 tons of sulfur oxides
for the 298 metropolitan areas. By Fiscal Year 1976, this
would rise to 2,380,000 tons if no further controls were ap-
plied. Analysis indicates that the addition of an acid plant in
smelters not now operating them, and the addition of lime
scrubbers on the tail gas from all acid plants, would achieve
the maximum removal of sulfur oxides from smelter gases
practical with present technology. This would reduce emis-
sions for Fiscal Year 1976 to an estimated 227,000 tons for
the copper smelters in the metropolitan areas subject to con-
trol, equal to 94 percent removal efficiency.
c. Primary Lead Emissions and Controls.—Primary lead
smelters in the 298 metropolitan areas were estimated to have
emitted 200,000 tons of sulfur oxides in 1967, representing
control of 32 percent of potential emissions. In addition, 5,540
tons of lead was emitted with a level of control of 96 percent.
Estimated growth of production would increase sulfur oxide
emissions to 269,500 tons and lead emissions to 7,900 tons by
Fiscal Year 1976 without further controls. Addition of acid
plants at refineries not now having them and at new refineries
could reduce the Fiscal Year 1976 emissions to 17,200 tons of
sulfur oxides and 7,900 tons of lead, equal to 96 percent con-
trol.
-------
2522 LEGAL COMPILATION—AIR
d. Primary Zinc.—The pattern for primary zinc smelters is
similar to that of lead. As a result of high level controls
effective in smelters using acid plants in 1967, it is estimated
that 51 percent of the potential sulfur oxide emissions were
controlled. The remaining smelters emitted an estimated
416,000 tons of
[p. 4-102]
sulfur oxides and this would increase to 508,000 tons by
Fiscal Year 1976 if the same level of control were maintained.
If all lead smelters in the metropolitan areas treated their
smelter gases in acid plants, sulfur oxide emissions in Fiscal
Year 1976 would be 76,700 tons, a 93 percent level of control.
Further reduction of these emissions would be prohibitively
expensive and impractical.
e. Secondary Nonferrous Emissions and Controls.—Second-
ary producers of aluminum, copper, lead, and zinc in the 298
metropolitan areas are estimated to have emitted 9,800 tons
of particulates and 14,500 tons of lead in 1967, with approxi-
mately half the plants controlled effectively at 95 percent, the
average control for the industry therefore being about 48
percent. At this same control level, emissions would grow to
14,800 tons of particulates and 22,000 tons of lead by Fiscal
Year 1976. High energy wet scrubbers, electrostatic precipita-
tors, and fabric niters were used, where appropriate, in this
industry analysis, with all three methods achieving 95 percent
or better control. Installation of equivalent procedures in the
uncontrolled plants would reduce emissions to 2,900 tons of
particulates and 2,200 tons of lead in Fiscal Year 1976.
f. Control Costs.—Implementation of the control plans dis-
cussed above would result in a total investment requirement
of $393.1 million; primary aluminum, copper, lead, and zinc
requirements would be 223.3, 87.0, 16.2, and 4.7 million dol-
lars, respectively, and secondary nonferrous would be $61.9
million. Annual costs in Fiscal Year 1976 would be as fol-
lows: primary aluminum, $75.8 million; primary copper,
$42.0 million; primary lead, $7.1 million; primary zinc, $2.2
million; and secondary nonferrous, $21.8 million—a total an-
nual cost of $148.9 million.
[p. 4-103]
-------
GUIDELINES AND REPORTS 2523
It. Scope and Limitations of Analysis.—The engineering
and control cost data summarized elsewhere in this report
give a firm basis for estimating the costs of control for indi-
vidual firms and the total industry. Adequate financial data
on which to base the discussion of the impact of these costs on
firms and the markets are also available. However, because
relatively few firms are involved, hypothetical model firms
have not been used to illustrate cost impact. To avoid the
impression of specifying costs for actual individual firms, a
procedure which may involve factors not considered in this
study, such as the overall financing program of the firm and
the intricacies of its tax position, the impact is discussed in
relation to general trends and patterns which may be ex-
pected within the industry and the markets involved.
5. Industry Structure.—The primary nonferrous metals in-
dustries are highly concentrated, with three or four firms
producing more than half of the annual production of each
metal. There were only eight primary aluminum, 11 primary
copper, six primary lead, and seven primary zinc firms identi-
fied in the United States in 1967. The companies are large,
stable, and in most years very profitable. Their market power
is limited to some extent by vigorous foreign competition and,
for some firms at least, by substantial competition from inde-
pendent fabricators of finished industrial products and con-
sumer goods. A large share of the market for these metals is
also found among the giant manufacturing firms, such as the
automobile companies, whose buying strength offsets any
monopolistic power among producer firms.
The secondary nonferrous industry, on the other hand, is
composed of a large number of firms, over half of them with
fewer than 20 employees. It is estimated that perhaps as
many as 10 percent of secondary nonferrous firms are oper-
ated very close to the breakeven level. The presence of large
numbers of marginal and near-marginal firms weakens the
market strength of the industry. Pricing and production,
therefore, are closely related to trends in the primary nonfer-
rous metals industry.
Tables 4-14 and 4-15 provide statistical data for these
industries.
[p. 4-104]
-------
2524 LEGAL COMPILATION—Am
TABLE 4-14.—1967 STATISTICS FOR PRIMARY NONFERROUS METALLURGICAL SOURCES
Aluminum
Number of plants
Capacity (millions of tons)
Production (millions of tons) .
Value of shipments (billions of dollars) .
United
States
. . 24
3.5
3.3
1.6
298
areas
14
2.0
1.9
0.9
United
States
19
i9.3
1.7
1.1
Copper
298
areas
10
i6.5
0.9
0.8
United
States
6
il.7
0.4
0.1
Lead
298
areas
4
il 2
0.2
0.1
United
States
15
1.3
0.9
0.3
Zinc
298
areas
9
2 0 6
!0.4
'0.2
i Ore concentrate.
' At this time, data are not available on two plants.
TABLE 4-15.—1967 STATISTICS FOR SECONDARY NONFERROUS METALLURGICAL SOURCES
United States
Number of plants
Capacity (millions of tons)
Produc'ion (millions of tons)
Value of shipments (billions of dollars) .
Aluminum
170
0.90
0.82
0.39
Copper
117
0.50
0.40
0.46
Brass and
Bronze
117
0.52
0.48
0.56
Lead
442
0.63
0.55
0.16
Zinc
159
0.08
0.07
0.03
Total
United
States
<627
2.63
2.32
1.60
298
areas
'583
1.93
1.71
1.17
1 A number of plants produce more than one metal.
[p. 4-105]
6. Market.—a. Aluminum.—Market growth for aluminum has
resulted from the development of new aluminum-using prod-
ucts and intensive competition to replace other metals in tra-
ditional uses. However, aluminum faces strong competition
from various plastics in some uses. A major factor in the
sales growth of aluminum has been its ability to deliver a
fully satisfactory substitute for copper or steel at a signifi-
cant cost reduction.
Within the industry, prices tend to be very similar from
firm to firm, since four firms in the United States and Canada
control approximately 65 percent of the world's output and
there is only a total of eight firms in the United States.
The relationship of aluminum sales to growth in the auto-
mobile and construction industries is discussed in Section V.
Also important are the electrical products, consumer dura-
bles, and container markets. In each of these industries, alu-
minum has significant advantages in cost and technical fac-
tors for certain uses, but seldom holds sufficient advantage to
forestall effective competition from other materials. There-
fore, despite its concentration, the industry faces a highly
competitive market with substantial price sensitivity.
Exports account for approximately six percent of sales of
aluminum and this market is not expected to grow in the next
five years. Aluminum ingots are imported, but not in signifi-
-------
GUIDELINES AND REPORTS 2525
cantly large quantities. The tariff of one cent per pound on
primary aluminum and two cents per pound on fabricated
shapes appears to provide significant protection to the United
States industry.
b. Copper.—The market for United States copper produc-
tion is very sensitive to the world's supply and demand for
copper and to military use in the war in Vietnam. World
capacity has
[p. 4-106]
been rising faster than world demand and it appears that
this trend may continue, although conditions determining
actual supply in any year are sufficiently unpredictable to
make long range market forecasts very dependable. The effect
of the industry nationalization in Zambia, completed in Au-
gust, cannot be analyzed at this time, for instance. Although
private management is under contract to operate Zambia's
copper industry, the extent of government pressure for
changed policies remains to be determined.
The other market unknown—copper demand resulting from
military procurement—is estimated to decline substantially
by Fiscal Year 1976. Thus, both of the factors mentioned
indicate that oversupply, or at least overcapacity, may tend to
affect the market over the next five years.
A very large part of copper production goes into copper
wire, which is used in transmission of electricity and in elec-
trical equipment of many kinds. In parts of these markets,
copper faces sharp competition from aluminum, which also
has excellent electrical properties. Substitution of aluminum
wire for copper wire depends primarily on price, although
aluminum may have an important weight advantage, partially
offset in some uses by its greater bulk.
The copper used in automobiles, mostly for wiring and
radiators, may decline. There is talk of reducing the use of
copper wire so that when scrapped auto bodies are melted
down the resultant scrap metal will not contain copper, which
is difficult to remove. New aluminum technology seems to
have overcome the difficulties in manufacturing aluminum ra-
diators and copper may lose a part of this market as well.
The prospect, therefore, seems to be one of possible over-
supply of copper and stiffer competition, which may be ad-
justed by changes in the relative prices of copper and alumi-
num. If pollution control costs ultimately prove to be signifi-
-------
2526 LEGAL COMPILATION—AIR
cantly different for these two metals, there may be further
changes in the market relationship.
[p. 4-107]
c. Lead.—Six firms are engaged in primary smelting of lead
in the United States; four plants are in the metropolitan
areas. These firms also operate refineries and produce refined
lead in addition to selling lead bullion to a small number of
refiners who do not mine and smelt their own supplies. Smelt-
ing is the most concentrated segment of the industry. The
industry is more competitive than this number might seem to
indicate, however, since smelters and refiners must deal with
a larger number of mining firms and distribute semifinished
and finished products in competition with a much larger num-
ber of firms processing refined lead. Another competitive force
is foreign sellers who operate extensively in the United States
market. Lead prices appear to be very flexible, reacting
quickly to changes in supply or demand. Supply is relatively
inelastic relative to price due to the very heavy investment
required in mining, smelting, and refining.
For these integrated lead producers, smelting is only one
part of the productive process, contributing only a fraction of
their total profit.
d. Zinc.—Of the seven firms engaged in zinc smelting in the
United States in 1967, six are also engaged in production of
one or more of the other nonferrous metals covered in this
analysis. The combination of lead and zinc is especially to be
expected since the two metals frequently occur in the same
ore. Unlike lead, zince smelting is carried out through a wide
variety of processing combinations and as a result production
costs are more variable. Much of what has been said about the
competitiveness of lead production applies to zinc as well,
however. The industry is characterized by competitive pric-
ing, moderate profit on investment, and relatively inelastic
domestic supply.
[p. 4-108]
7. Production and Price Trends.—It is estimated that pri-
mary production of aluminum, copper, and zinc in the United
States will increase at the following annual rates through
Fiscal Year 1976: aluminum, 5.8 percent; copper, 1.3 per-
cent; and zinc, 2.6 percent. This implies some increase in
utilization of productive capacities, since the annual growth
-------
GUIDELINES AND REPORTS 2527
rates in capacity through Fiscal Year 1976 are estimated as:
aluminum, 4.4 percent; copper, 0.2 percent; and zinc, 1.4 per-
cent. The estimated rate of growth in both capacity and pro-
duction of primary lead plants between 1967 and 1976 is 4.1
percent. This growth rate for the primary lead industry re-
flects the actual growth for the years 1967 to 1970 and as-
sumes that they will approach zero after 1970 as the market
for tetraethyl lead gasoline additives declines sharply.
Secondary producers of nonferrous metals, whose produc-
tion rates depend in part on the supply of scrap and therefore
on the consumption of primary production, are expected to
increase production at a rate of 6.1 percent per year through
Fiscal Year 1976, while increasing capacity at 6.6 percent per
year.
The relative changes in the prices of metals explain in part
the expected relative growth patterns. The rise of the index
of copper prices from 110 in 1965 to 146 in 1968, compared to
the index for aluminum prices which stood at 97 in 1965 and
rose only to 102 in 1968, indicates the increased price advan-
tage gained for aluminum over those years.
Aluminum prices should be firm through Fiscal Year 1976
as demand continues to grow, with increased growth in the
container field being especially important. Even without alu-
minum's disadvantage of a higher control cost, copper proba-
bly will continue to lose ground to aluminum in the electrical
field and in some other industries, for example automobile
radiators. Most brass and bronze markets will probably
change little. It is unlikely, therefore, that copper prices
would continue the upward trend of the last few years.
Prices of lead and zinc may be expected to remain fairly
steady through Fiscal Year 1976. Uses of lead alloys have
been growing in a wide variety of applications, but lead for
batteries has grown
[p. 4-109]
more slowly than automobile production. This reflects in-
creased battery life, although most of the improved tech-
nology in this field appears to have been introduced and the
trends of automobile and battery production may move more
closely for some years. Elimination of tetraethyl lead in gas-
oline, however, would eliminate one-third or more of the
United States lead market. If this occurs, lead prices may
decline sharply and a sizeable segment of the secondary lead
industry particularly may feel the impact.
-------
2528 LEGAL COMPILATION—AIR
The zinc market prospects are for slow steady growth and
stable prices.
g. Economc Impact of Control Costs.—a. Control System
Costs.
(1) Aluminum.—Annual control costs for the primary
aluminum industry differ depending upon the production
process with average costs as follows: (a) prebaked,
$25.32/ton ($0.013/lb. of capacity); (b) horizontal spike
soderberg, $31.31/ton ($0.016/lb. of capacity) ; (c) Verti-
cal spike soderberg, $21.14/ton ($0.011/lb. of capacity).
The average prebaked process plant in the areas designated
for control for purposes of this study had a capacity of just
over 150,000 tons per year in 1967. The annual cost in 1967
dollars for such a plant would be approximately $4,000,000,
reflecting the annualized cost of an investment of
$13,000,000 plus the annual operating and maintenance
cost. A similar plant using the horizontal spike soderberg
process would require a total investment in control equip-
ment of 1.2 times that for prebaked and would have total
annual costs 1.2 times as great. Such a plant using the
vertical spike soderberg process, on the other hand, would
require only three-fourths of the investment outlay and
four-fifths of the annual cost of the prebaked process plant.
An adequate level of control would be achieved in all three
plants.
[p. 4^110]
The annual costs given above make no allowance for the
recovery of materials through the control systems. Since
these systems have not yet been widely employed, calcula-
tion of the value of recovered products is purely hypotheti-
cal at this time. It appears, however, that for the prebaked
and vertical spike soderberg processes, substantial amounts
of alumina and cryolite would be recovered in usable form.
A conservative estimate of the value of recovered product
might be $1,000,000 worth per 100,000 tons of production
for the prebaked process and approximately half that for
the vertical spike soderberg process. No significant recov-
ery of materials appears possible with the floating bed
scrubber indicated for the horizontal spike soderberg proc-
ess. If recoveries of this magnitude prove feasible, the re-
sult would be that plants using prebaked cells would reduce
total operating costs by adopting air pollution control.
-------
GUIDELINES AND REPORTS 2529
Plants using vertical spike soderberg cells would incur little
or no net cost for control and plants using horizontal spike
soderberg cells would be at a disadvantage amounting to
approximately one-half cent per pound of aluminum pro-
duced. Since it appears that the vertical spike soderberg
process may be the most efficient, by a small margin, of the
three processes, such a cost differential could significantly
affect profits for firms dependent on the horizontal spike
soderberg process. Such a firm may have to absorb the
added cost since its competitors would have no motivation
to raise prices as a result of pollution control requirements.
Producers of secondary aluminum, in turn, face the prob-
ability of annual control costs equal to $0.0032 per pound,
or $82,500 per year for a typical plant of just over 4,000
tons annual capacity installing the anticipated controls, as
noted in Section 3.e. Firms
[p. 4-111]
operating secondary aluminum production plants sell in
competition with primary producers in many markets and
it is unlikely that the price of secondary aluminum could
rise against an unchanged price for the primary metal. It
appears that some secondary producers, now operating at
a smaller scale and higher costs than the average indicated,
may be forced out of aluminum by merger, shift to other
metals, or by going out of business. More detailed data
would be necessary to estimate how many firms may be
affected in this way.
(2) Copper, Lead, and Zinc.—Air pollution control costs
for lead and zinc smelters have been calculated as the cost
of installing and operating a sulfuric acid plant in which
the sulfur oxide emissions are captured and turned into a
saleable by-product. In addition to adding a sulfuric acid
plant, copper smelters have also been assumed to require a
wet line scrubber system which does not yield a saleable
by-product. Industry sources indicate that at present (1970)
four of the 19 copper smelters in the United States operate
acid plants, as do two of the six lead smelters and nine of
the 15 zinc smelters. That these plants are generally opera-
ting acid plants in locations where they are not subject to
sulfur oxide emission limitations which would make strict
control mandatory is conclusive evidence that recovery and
sale of sulfuric acid is economically advantageous for them.
-------
2530 LEGAL COMPILATION—AIR
For a copper smelting plant, it is estimated that maxi-
mum feasible control of sulfur oxide emissions will require
the installation of a contact acid plant plus a lime scrubber.
This would require an investment of approximately
$12,300,000 for the typical plant and total annual cost, in-
cluding depreciation and interest, of $4,500,000. Assuming
that the acid plant can produce up to 180,000 tons of sul-
furic acid and that this can be sold at a price of $14 per
ton, f.o.b. the smelter (a price
[p. 4-112]
in line with the current market), by-product revenue would
approximate $2,500,000 per year. Net annual control cost
would then be approximately $1,650,000 for this plant, or
$23.57 per ton ($0.012/lb.) for 70,000 tons capacity.
For a copper smelting plant with an acid plant already in
operation, maximum control would require the addition of
a secondary scrubber. It is estimated that this would re-
quire an investment of $2,300,000 and total annual cost of
$1,370,000, with no additional production of saleable by-
products. For a 500,000 ton capacity plant, this would mean
an estimated annual cost of $19.57 per ton ($0.0098/lb.).
Those lead and zinc smelting plants already operating
acid plants would not require further control of emissions.
Since they are presumably operating at or above breakeven
in their acid production, there is therefore no net cost of
control. Construction of a new acid plant at the smelters
not now controlling sulfur oxide emissions would involve
investment of approximately $5,500,000 and total annual
cost of $2,500,000 for an average sized zinc plant of ap-
proximately 100,000 tons annual capacity. Sale of acid at
$14 per ton would yield revenue approximately equal to
annual cost, indicating zero net control cost.
The assumption has been made in estimating these net
control costs for copper, lead, and zinc smelters that the
sulfuric acid produced would find a market at $14 per ton.
Recently published studies of the potential market for
smelter acid indicate that this assumption is almost cer-
tainly not valid. The volume of smelter acid involved and
its location relative to its potential market make it improb-
able that more than a small fraction of the potential supply
could be sold at any price in Fiscal Year 1976.
[p. 4r-113]
-------
GUIDELINES AND REPORTS 2531
The market for sulfuric acid is primarily for use in pro-
duction of fertilizer with smaller amounts used for leaching
copper ore and for processing uranium. It should also be
noted that sulfuric acid is required in the electrolytic disso-
lution process for refining zinc, explaining why so many
zinc plants produce sulfuric acid. The studies cited above
indicated that less than 40 percent of the potential new acid
production of smelters located west of the Mississippi could
find a market at a price of $4 per ton, the minimum esti-
mated production cost. The problems and cost of shipping
acid to more distant markets would be prohibitive, it was
indicated. It may be concluded, therefore, that primary
smelters will install acid plants only to the extent that
projected revenues from the sale of acid result in a net
control cost less than that of alternative control systems.
Assuming that the annual cost of lime scrubbing alone,
without an accompanying acid plant, is approximately half
the gross annual cost of the system specified in this analy-
sis, annual cost for an average copper smelter might be
approximately $3,250,000 and for a lead or zinc smelter
$1,250,000 ($0.003/lb. for copper; $0.0063/lb. for zinc;
$0.0018/Ib. for lead).
Air pollution control costs as of 1967 for secondary cop-
per, lead, and zinc producers have been estimated by the
Department of Commerce. The cost estimate for a typical
secondary copper (and brass and bronze) producer with an
annual capacity of 7,340 tons was that an investment of
$140,000 would be required and that total annual cost
would be $54,400 or $7.41 per ton ($0.0037/lb.) of capac-
ity. Equivalent figures for a secondary lead producer with
1,420 tons capacity were investment of $14,500 and annual
cost of $5,300 or $3.74 per ton ($0.0019/lb.). For a second-
ary zinc plant of 268 tons capacity, the required investment
was calculated as $5,200 and annual cost as $1,700 or $6.27
per ton ($0.0031/lb.).
[p. 4-114]
The added costs indicated by this analysis for some pri-
mary producers of copper, lead, and zinc, and the increased
costs for secondary producers suggest that some upward
pressure on prices may occur. However, foreign competi-
tion, competition from plants not subject to control regula-
tions, and those already meeting emission standards, plus
-------
2532 LEGAL COMPILATION—AIR
the realistic possibility of excess capacity by Fiscal Year
1976, make it probable that little if any price increase will
eventuate as a result of these cost pressures.
b. Impact on the Industry.—Table 4-6 summarizes the ag-
gregate annual costs for primary and secondary nonferrous
metals producers. The impact of net cost on any one primary
producer is more difficult to determine. This will depend upon
its product mix, degree of horizontal and vertical integration,
the amount of metal purchased from other producers, the
percentage of their plants subject to control regulations, the
control cost for the specific production pr<. messes used, the
productivity of the processes, the firm's market and financial
strength, and many other factors. No analysis of the impact
on actual firms is given in this report. Any attempt to do so
would imply much more detailed knowledge of the variables
involved than would generally be available to an outside ob-
server. This section is intended to suggest the range of possi-
ble effects which may be felt by some firms and the industry
as a whole.
For primary producers of aluminum, it appears that the
industry will be required to invest approximately $223.3 mil-
lion in the years between calendar year 1967 and Fiscal Year
1976. By Fiscal Year 1976, the industry will be incurring
total annual costs for control of approximately $75.8 million
in addition to an estimated $7.0 million now being spent an-
nually for control instituted before 1967. It is probable, how-
ever, that most of this cost is and will be offset by the recov-
ery of valuable materials. Only the firms operating horizontal
spike soderberg cells appear to face significant net control
[p. 4-115]
costs. The aggregate estimated annual control cost for this
sector of the industry will be approximately $26.2 million in
1976. It may be expected, therefore, that use of this produc-
tion process will tend to decline in the long run unless new
technology can offset its economic disadvantage. Some shift-
ing into alternative product lines or change in individual mar-
ket shares may occur, but the primary aluminum industry is
not expected to show any fundamental change in response to
new control costs, nor is the market price likely to increase.
The impact of control costs on primary producers of cop-
per, lead, and zinc depends primarily on the amounts of these
(and other) metals they are smelting, since it is the smelting
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GUIDELINES AND REPORTS 2533
process for these three metals that will require new or addi-
tional emission controls. How many of a company's plants are
already partially or completely controlled and how many are
located in metropolitan areas where additional controls will
be required will also affect the impact on a particular com-
pany. The other prime determinant of the cost for a firm will
be the marketability of sulfuruc acid from its existing or
newly required acid plants as more smelter acid enters the
market.
Among them, the 23 firms smelting copper, lead, and zinc
may invest an estimated $107.9 million by Fiscal Year 1976 in
additional control equipment. The annualized cost of control
by that year is estimated at $51.3 million. Offsets to this
annual cost reflecting the value of the sulfuric acid produced
could be as high as $31 million, leaving a net estimated con-
trol cost of approximately $20 million, almost entirely the
cost of secondary scrubbing in copper smelters. If the value of
acid output is assumed to be only half that used in these
estimates and if world and domestic productive capacity re-
main reasonably in balance with demand, some upward pres-
sure on price may occur. Adjustments per pound to this pres-
sure by Fiscal Year 1976 would probably not exceed $.012 for
copper, $0.001 for lead, and $0.003 for zinc. Price variations
of this magnitude would not be enough to cause any signifi-
cant shifts in market shares or production.
[p. 4-116]
Secondary nonferrous producers face a more difficult situa-
tion. Overall, by Fiscal Year 1976, they may be required to
invest a total of approximately $61.9 million and by that year
annual costs for control for these firms are estimated to total
approximately $21.8 million. These producers will have no
saleable by-product with which to offset these costs. If the
assumption is correct that the price of the secondary output
cannot change significantly relative to the primary price
when there are adequate supplies available in the primary
market, it is probable that some marginal secondary produc-
ers will be unable to continue without change. This impact
would be most severe on firms handling copper scrap and
much less for lead and zinc firms. Some firms may drop out of
the copper market and concentrate on handling larger vol-
umes of other metals. Considering the expanding market for
secondary metals, some very small firms may merge to gain
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2534 LEGAL COMPILATION—AIR
economies of larger scale operations. This latter course is
probably in line with a trend toward fewer and larger firms
in the industry anyway, to which air pollution control costs
will provide greater impetus.
[p. 4^117]
N. Rubber (Tires)
1. Introduction.—The industrial classification considered in
this section includes the manufacture of tires and tubes of all
types for all kinds of vehicles, the bulk of which are for automo-
biles, trucks, and buses. Tubes are included because no distinc-
tion is made between tires and tubes in statistical data.
2. Emissions and Costs of Control.—Air pollution emissions
come from only two tire manufacturing processes, i.e. the tire
cord dipping operation, and the mixer which blends carbon
black into the tread material.
Hydrocarbon emissions have been reported in the offgases
from the tire and dipping process. The amounts of these emis-
sions have not been determined although they are believed to be
in such quantities as to require control. Controls are predicated
upon industry practice and experience under the regulations of
the State of California. It is reported that a direct gas-fired
afterburner provides fully adequate control of these hydrocar-
bon emissions. These have been assumed to be required in all
plants outside of California.
Approximately 80 percent of the tire plants reported use fab-
ric filters to control emissions of carbon black particulates at a
control level of better than 99 percent. Carbon black is a costly
material and the plants controlling these emissions do so be-
cause the value of the material recovered more than offsets the
annual cost of control. For the 20 percent of the industry which
was not controlling particulate emissions in 1967, it is estimated
that 1,230 tons of particulates per year were emitted. Predicted
growth of the industry would increase this amount to an esti-
mated 1,670 tons per year in Fiscal Year 1976. Installation of
fabric filters in these plants would reduce the estimated Fiscal
Year 1976 emissions to negligible amounts of particulates by
Fiscal Year 1976.
Installation of these controls would require an investment of
$1.92 million and a Fiscal Year 1976 annual cost of $1.35 mil-
lion for the plants located in the 298 metropolitan areas.
[p. 4-118]
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GUIDELINES AND REPORTS 2535
3. Scope and Limitations of Analysis.—The data necessary
for detailed analysis of emissions and control costs were not
available for this analysis. Industry experience has been used,
however, to estimate the control systems appropriate to the air
pollution problems associated with the production of tires and
tubes. The magnitude of the costs involved appears, even after
allowance for substantial possible error, not to be large enough
relative to the size of the industry and its member firms to
warrant more extensive analysis at this time. Therefore, the
discussion is limited to the estimated cost of control. Since this
cost is relatively small and is not expected to affect price or
profit significantly, no analysis of the industry's market has
been made.
4. Structure of the Industry.—The rubber tire and the tube
industry consists of 60 plants that are located in the United
States and represents 16 firms. Fifty-four of the 60 plants, or 90
percent, are located within the 298 metropolitan areas—repre-
sentative of 15 firms. United States capacity for the industry
was 1,080,000 tires and tubes per day. In the 298 areas, capacity
amounted to 1,000,000 units per day—93 percent of the United
States total. Production was 213 million units per year for the
United States and 196 million units per year for the 298 metro-
politan areas or 92 percent of United States production. Three
major firms accounted for 59 percent of United States capacity,
with all but one of their plants within the designated control
regions.
5. Economic Impact of Control Costs.—Control costs were
estimated, as of 1967, for a model plant representative of the
industry. This plant was described as employing 350 persons
and producing 825 thousand tires and 206 thousand tubes per
year. Although many plants do not produce tubes or have a
different product mix than this, it appears that costs for the
model plant represent an approximate average for the industry.
Installation of only an afterburner in a model plant of this
size would require an investment of $25,000, for which the total
annual cost would be $26,400. Investment in the fabric filter
system in
[p. 4-119]
addition to an afterburner for a model plant of this size
would add approximately $18,000. It appears that recovery
of carbon black will more than offset the annual cost of the
fabric filter. Therefore, no additional annual cost has been esti-
-------
2536 LEGAL COMPILATION—AIR
mated. Investment in the 80 percent of the plants adding after-
burners will be approximately $25,000, and in the 20 percent
adding fabric niters and afterburners it will be $43,000. The
annual cost of $1,350,000 for these controls will be slightly more
than $0.005 for each of the 266 million tires and tubes estimated
to be produced in the metropolitan areas in Fiscal Year 1976.
Investment and annual costs of the indicated magnitude can be
absorbed within the normal operation of the firms.
[p. 4-120]
0. Sulfuric Acid3
1. Introduction.—Sulfuric acid is a strong, economically
priced inorganic acid that is utilized in the production of phos-
phate fertilizers and other industrial chemicals, in the purifica-
tion of petroleum, in the dyeing of fabrics, and in the pickling
of steel. Greater than 90 percent of all sulfuric acid produced is
by the contact process. In this process, sulfur or pyrite is
burned to form sulfur dioxide (S02) which is then catylyzed to
sulfur trioxide (S03). The S03 is then absorbed in weak sul-
furic acid to form the concentrated products.
2. Emissions and Costs-of-Control.—Sulfur dioxide that re-
mains unconverted and acid mist particulates that escape from
the acid absorption tower are the pollutants for which control
costs have been developed. With only a single absorption stage,
approximately a 96 percent conversion of S02 to S03 can be
expected. To comply with the S02 standard, a conversion
efficiency of 99.5 percent is required. This is equivalent to an
overall 86 percent removal efficiency. To accomplish this, it is
assumed that plants will install a secondary absorption tower
with appropriate addition of heat to facilitate more complete
conversion of S02. Although most plants do control acid mist
particulates to some extent, the average industry control level of
46 percent does not meet the particulate standard. An overall
industry removal efficiency of 67 percent will be required. To
meet this standard, it is assumed that more efficient acid mist
eliminators will be installed. By Fiscal Year 1976, if these con-
trol measures are not adopted, emissions of sulfur oxides and
particulates will reach 921 thousand tons and 90.1 thousand
tons, respectively. With the specified controls, these will be re-
duced to 129 thousand tons and 55.1 thousand tons, respectively.
The investment required to implement the controls by Fiscal
Year 1976 will reach $176 million and the annual cost is esti-
mated as $41 million. This annual cost does not take into ac-
-------
GUIDELINES AND REPORTS 2537
count the slightly increased yield of sulfuric acid which will
occur.
8 An economic impact analysis for this industry is not included in this report. A comprehensive
study is currently in preparation by NAPCA.
[p. 4-121]
3. Industry Structure.—In 1967 there were 213 plants with a
total capacity of 38.7 million tons of sulfuric acid in the United
States. Production amounted to 28.8 million tons. Within the
298 metropolitan areas there were 180 plants with a total capac-
ity of 32.9 million tons. These plants produced 24.5 million tons
of sulfuric acid.
[p. 4-122]
P. Varnish
1. Introduction.—Varnish is one product group produced by
the paint industry. This industry also manufactures and distrib-
utes paints (in paste and ready-mixed form), lacquers, enamels,
and shellac; putties and caulking compounds; wood fillers and
sealers; paint and varnish removers; paint brush cleaners, and
allied paint products.
Technical and statistical literature dealing with the paint in-
dustry is often not clear as to the technical definition of "var-
nish" as opposed to other product classifications. Generally, var-
nish is an unpigmented protective coating of natural or syn-
thetic resins dissolved in a volatile oil for use on wood or some-
times metal. Like almost all paint industry products, varnish is
manufactured using a process where the proper amounts of
ingredients are mixed together in a batch and then packaged.
Varnish is unique in that it is cooked in the manufacturing
process. However, like paint, varnish cures through polymeriza-
tion by reaction of the binder with oxygen in the air after
evaporation of the solvent. In contrast, lacquers cure merely by
evaporation of the solvent, forming the film. While varnish is
usually unpigmented, producing a clear coating, it may also be
pigmented. It may also be used occasionally as a base in making
paint.
2. Emissions and Costs of Control.—Varnish must be cooked
during production, which results in the evaporative emission of
hydrocarbons. Air pollution control to 90-95 percent efficiency
can be attained using direct-fired afterburners.
526-705 O - 74 - 13
-------
2538 LEGAL COMPILATION—AIR
All varnish plants in California were assumed to be con-
trolled, while only about 20 percent of the plants located else-
where were assumed to be controlled. The overall national level
of controls was estimated to be 18 percent. Emissions for 1967
were estimated by using an emission factor of four percent of
throughput. Hydrocarbon emissions were thus estimated to be
2,200 tons per year for 1967 in the 298 metropolitan areas.
Implementation of the Clean Air Act would require an initial
investment of $790,000 and an annual cost of $0.95 million.
Emissions would be reduced to approximately 300 tons per year
in Fiscal Year 1976.
[p. 4-123]
8. Scope and Limitations of Analysis.—Because of the large
number of small firms producing varnish, data on plant location
is incomplete. Detailed data on plant capacities and production
are also incomplete and were estimated from industry totals by
applying- known relationships to data on employment by plant
and industry totals. Statistics on varnish or resins produced by
heat reaction in 1967 (or any other year) apparently do not
exist either among government or industrial sources. The prob-
lem is further compounded by the fact that some products that
are called varnish are not varnish (although they may have
been in the past) but are more properly called lacquers. Electri-
cal insulating varnish is an example of a major product of this
type.
Financial data by plant or firm are even more fragmentary
and, therefore, estimated industry costs may be somewhat in
error. However, the estimates given are felt to indicate the
order of magnitude of industry cost impact and to reflect a
reasonable approximation of the control cost per gallon of prod-
uct.
4- Industry Structure.—One statistical source indicates that
there were 220 plants producing varnish in the United States in
1967 and 216 of these plants were located in the 298 metropoli-
tan areas. Estimated capacity was 23 million gallons for the U.S.
and 22 million gallons for the metropolitan areas. Production
by United States and metropolitan area plants was estimated at
10 million and 9.6 million gallons in 1967, respectively.
5. Markets.—The market for varnish is largely a function of
building and building maintenance activity; competition for
sales is keen. This results from the large number of firms that
produce varnishes, large unused production capacity, low invest-
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GUIDELINES AND REPORTS 2539
ment requirements, a well-known technology, and a number of
very competitive substitutes.
[p. 4-124]
Varnish, like other paint industry products is distributed
through two district channels; industry and trade. Industrial
sales are made directly by the manufacturers to industrial users
for use either in production or for maintenance. Trade sales are
those made to wholesalers and other middlemen for resale to the
general public, contractors, and other commercial accounts.
Industry sources indicate that varnish products move almost
entirely in trade sales channels. They have been almost entirely
replaced in industrial markets by other types of finishes with
superior characteristics such as faster drying and greater dura-
bility. A similar trend is taking place in trade sales, where
varnish is receiving stiff competition from lacquer, urethane,
and epoxy finishes because of drying and durability properties.
In addition, increasing use of "prefinished" products are reduc-
ing demand for on-site finishing and finishes.
Paint industry products are generally not important in world
trade since they are expensive to ship and easily produced lo-
cally. International licensing agreements and foreign joint ven-
tures are common and U.S. industries are leading participants.
In 1967, paint industry exports were 10.2 million gallons val-
ued at $42.7 million, or 1.7 percent of all U. S. dollar shipments.
Trade sales products account for about 60 percent of the total
shipped on a volume basis. Imports were $1.6 million and in-
cluded some distempers, water pigments, stamping foils, and
dyes.
6. Trends.—For the decade ending in 1967, paint sales (dol-
lars) increased at an average annual rate of 4.7 percent as
compared to 6.3 percent for GNP and 1.4 percent for popula-
tion. Volumes of sales (gallons) increased by an average of 3.4
percent per year. Future growth in the paint industry should
approximate the volume rate.
The factors limiting long-term growth in the paint industry
and sales of varnish are increasing use of products that require
no paint or less paint, and the improvement of paint products
themselves. Products that require no paint include such materi-
als as stainless steel, aluminum, glass, stone and brick, Fiber-
glass reinforced plastics,
[p. 4-126]
-------
2540 LEGAL COMPILATION—ADR
laminates, extruded or molded plastics and such surfacing mate-
rials as wall paper, plastic films, porcelain enamels, and electro-
plated, phosphated or oxidized metal films. To meet such com-
petition, the paint industry has developed more durable and
easily applied coatings resulting in lower costs per unit of sur-
face covered.
Factory finished building materials are replacing on-site
painting which is becoming increasingly expensive. Labor now
accounts for as much as 80 percent of the total cost of on-site
finishing. Since prefinishers generally use specially formulated
industrial finishes, the trend towards prefinishing in building
products is at the expense of trade sales products such as var-
nish.
Varnish is not expected to share in the growth of paint indus-
try sales because of the competition from substitute materials,
from prefinishing, and from other coatings. Instead, varnish is
expected eventually to be largely replaced by competitive fin-
ishes and materials among trade customers as it has among
industrial customers. Because habits and customs are slow to
change, varnish sales and production are expected to remain
approximately at present levels through fiscal year 1976.
7. Economic Impact of Control Costs.—Assuming approxi-
mately 220 firms producing varnish with production of 23 mil-
lion gallons, this analysis indicates that for the average firm an
initial capital investment of $3,600 or $0.036 per gallon of ca-
pacity would be required. Because of the large unused capacity,
investment per gallon of product would be almost $0.08.
The total annual cost to control the varnish producing seg-
ment of the paint industry would be $950,000 per year by Fiscal
Year 1976. This cost includes allowances for recovery of invest-
ment, interest, taxes, fuel, labor, maintenance, and other ex-
penses of owning and operating the air pollution control equip-
ment. For an estimated Fiscal Year 1976 production of 10 mil-
lion gallons, this gives an incremental cost of almost $0.10 per
gallon.
Considering the nature of competition among producers and
by substitute materials, few firms can afford cost increases of
this sort from profits nor will they be able to completely shift
[p. 4r-126]
the $0.10 per gallon increase to the consumer through price
increases. It is expected that about half this increase can be
shifted; thus, prices may be expected to rise by about $0.05 per
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GUIDELINES AND REPORTS 2541
gallon above the level they would otherwise achieve by 1976.
It is expected that all producers in a region or market will
tend to postpone installation of control equipment as long as
possible so as to avoid incurring this cost. When regulatory
orders force compliance, most firms will act at the same time.
The action taken by firms will depend on their evaluation of
their own varnish sales, their share of the varnish market, and
the firm's expectation of customers reaction to a price increase.
Marginal varnish producers will discontinue production and will
either drop varnish from their product line or contract to buy
varnish for resale under their own label.
Any price increase will cause some buyers to switch to the
wide variety of substitutes available, hastening present trends
to other products. Since use of varnish is already declining and
a price increase will cause a further decline, the firms that
install air pollution control equipment will do so only on equip-
ment they anticipate will be used regularly enough so that they
can recover their investment. As a result, the present unused
capacity may be scrapped to the maximum extent possible, and
some of the currently used capacity may also be scrapped.
If this pattern occurs, there is little reason to anticipate finan-
cial difficulties except for those firms that are already marginal.
The paint industry as a whole is basically healthy.
[p. 4-127]
V. IMPACT OF THE COST OF EMISSION CONTROLS ON THE PRICE
LEVEL OF THE U. S. ECONOMY
A. INTRODUCTION
In previous sections, the annual costs of air pollution control
were estimated for each of the 18 industrial process sources
studied and increases in the prices of the output were projected.
These projections were based on the structure of each industry
and the demand for each industry's product. Estimates are
made of the impact of the price increases on the economy's
overall price level in order to gain further insight as to the
effect of air pollution control on the standard of living, as re-
flected in the level of prices. This section also examines sepa-
rately the impact of those price increases on two industries,
construction and automobiles, because they consume significant
portions of the output of industries studied and because of their
importance to the economy.
-------
2542 LEGAL COMPILATION—Am
In order to develop estimates of the impact of the costs of
emission control on the price level of the U. S. economy, it was
assumed that the price increases projected for the industries
studied will be passed along by all firms purchasing the output
of these industries to the final purchasers and that the pattern
of inputs for any purchasing industry will not be affected. It
was assumed also that as a result of the costs of emission con-
trol, imports are not increased nor is production outside the
metropolitan areas encouraged relative to the production of the
firms inside the metropolitan areas. Finally, it was assumed that
the distribution of the gross national product (GNP) in calen-
dar year 1975 will be similar to the historical distribution.
B. IMPACT ON THE PRICE LEVEL FOR SPECIFIC INDUSTRIES
Using input-output relationships, it is possible to estimate the
impact of the projected subject industry price increases on the
general level of prices and on the prices of other industries in
the economy. Input-output is a method for analyzing the inter-
dependence among the industries or sectors of an economy. In-
put-output analysis uses a table or matrix which shows for a
specific point in time the distribution of sales and purchases by
each industry. The basic table of transactions can be mathemati-
cally transformed into a table of coefficients which show the
direct and indirect output of every industry required to deliver
a dollar's worth of output of any other industry to final demand.
Knowledge
[p. 4-128]
of the structure of the United States economy as represented
by the input-output table may be used to evaluate the impact
of the projected increases in the prices of products of the in-
dustries in question because it identifies the industries which
purchase the affected products and provides a basis for esti-
mating the price increases necessary to maintain profit levels.
The U. S. Department of Commerce has published three input-
output tables of the U. S. economy; the most recent table, for
the year 1963, was just released. This table was expanded more
than fourfold from the previous table (1958) to about 370 sepa-
rate industries which permitted identification of most of the
subject industries.
The 370 sector table, however, was found too unwieldy in this
application so it was reduced to a smaller table based on the
1958 table's classification of industries. However, the integrity
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GUIDELINES AND REPORTS 2543
of the subject industries was preserved. The result, therefore,
was a table which shows the subject industries in detail and the
rest of the sectors in a more aggregated form. Finally, the
major purchasers of the output of the subject industries were
identified as the industries that consumed one percent or more
of the intermediate output of each of the subject industries.
There were 72 such industries. The increase in the price level
for each affected industry was calculated based on the signifi-
cance of the output of the industries studied to the input re-
quirement of the 72 industries affected.
In order to estimate the impact of the projected price in-
creases on the general price level of the U. S. economy, each of
the 72 industry's historical contribution to gross national prod-
uct (GNP) was determined. Table 4-16 summarizes the impact
on the price level by presenting it for the nine major industry
classifications. As the table shows, it is estimated that the price
level of the economy will be increased about 0.14 percent due to
the price increases caused by the costs of emission control. This
estimate is expressed in terms of the increase in the implicit
price deflator for gross national product, an index similar to the
consumer price index.
[p. 4-129]
Table J^-16.—Estimated Impact of the Costs of Emission Control on the Price Level
Estimated
Industry increase in the
price level1
Agriculture, forestry and fisheries
Mining
Construction -.. 0.0006
Manufacturing .0004
Transportation, communication,
electric, gas and sanitary services .0003
Wholesale and retail trade .0000
Finance, insurance and real estate .0000
Services . 0001
Government enterprises .0000
Total 2 .0014
1 Implicit price deflator for GNP.
2 Or 0.14 percent.
The primary reason for the small price increase is that only
nine of the study industries are projected to increase their
prices over one percent, and none of the increases exceed three
percent. Of these nine, four have less than 55 percent of their
capacity in the 298 metropolitan areas which further reduces
the impact of the price increases.
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2544 LEGAL COMPILATION—Am
The industry most affected is construction, which accounts for
43 percent of the 0.14 percent increase. The primary contributor
to the increase in construction costs is the price increase pro-
jected for steel. Nine percent of the steel output is purchased by
the construction industry where it accounts for two percent of
construction industry's inputs. Also contributing to the pro-
jected increase in construction costs are price increases by the
gray iron foundries, steam-electric power plants and the brick
and tile industry.
[p. 4-130]
Manufacturing is expected to contribute 29 percent of the 0.14
percent increase largely as a result of price increases in the
motor vehicle industry due to higher prices for steel, gray iron
castings and steam-electric power; other transportation equip-
ment industries due to higher steel and gray iron casting prices;
and food and kindred products industries due to higher electric
and coal prices.
Transportation, communication, electric, gas and sanitary
services price increases contribute 21 percent of the projected
0.14 percent price increase as a result of higher electric and
coal prices.
Services account for the smallest portion of the 0.14 percent
increase—7 percent, due to higher electricity prices.
C. Key Industries
Due to the interdependence of the economy and the specific
interrelationships between the subject industries and other in-
dustries as shown for example in the input-output table, the
effects of the projected price increases tend to cluster in a few
industries. Two of these industries have been singled out for
analysis below because of their significance. These are the con-
struction and motor vehicle industries which consume large per-
centages of the output of several of the 18 industries studied and
are important contributors to the level of GNP.
1. Construction.—The following of the industries studied sell
over one percent of their intermediate output directly to the
construction industry:
-------
GUIDELINES AND REPORTS 2545
Percent
Varnish 49
Petroleum refining 7
Asphalt batching 90
Rubber (tires and inner tubes) 4
Cement 42
Brick and tile 97
Lime 10
Iron and steel 10
Steam-electric power plants 2
[p. 4-131]
The value of new construction put in place in 1969 was a
record $91 billion, even though new housing units started, which
are a major component of construction activity, were less than
1.5 million units for the year. Both the trend toward larger
structures and the general increases in the cost of new construc-
tion caused by inflation contributed to the record level.
The construction industry is currently characterized by rising
costs arid a strong underlying demand held in check by the cost
of credit.
The share of gross national product (GNP) represented by
construction has been declining since the mid 1950's when it
was 12 percent of GNP to 10 percent in 1967. Through the
1970's, construction is expected to maintain its share of GNP at
about the present 10 percent level. This would imply an increase
in construction activity to $197.4 billion by 1975 from the 1967
level of $76.2 billion, both measured in 1967 dollars.
Using the input-output analysis, it was estimated above that
the price level in construction will be increased about 0.6 per-
cent higher annually than otherwise due to price increases
caused by the extra costs to the study industries for emission
control. While the percentage increase is small, in dollar terms
the amount is fairly large—$600 million in 1975. Assuming
approximately 25 percent of this increase was allocated to 1.5
million housing units started in calendar year 1975, the average
increase per housing unit would be $100.
2. Motor Vehicles.—The following study industries sell over
one percent of their intermediate output directly to the motor
vehicle industry:
-------
2546 LEGAL COMPILATION—AIR
Percent
Petroleum refining 6
Rubber (tires and tubes) 24
Iron and steel 11
Primary lead _ 1
Steam-electric power plants 1
Gray iron foundries 25
[p. 4-132]
Motor vehicle production currently accounts for about four
percent of gross national product (GNP) with an annual output
of about ten million vehicles (all types). This industry has a
pervasive influence on the U. S. economy not only due to its
share of GNP but also because of its linkages with the rest of
the economy. Assuming that gross auto production continues its
historical relationship to GNP of four percent, the 1975 gross
auto production will be about $44.2 billion, up from $28.9 billion
in 1967, both measured in 1967 dollars. The increase in the price
level of the motor vehicle industry was estimated at 0.5 percent.
This percentage translates into an absolute dollar amount in
1975 of $225 million, or $22.50 per vehicle if 10 million cars and
trucks are produced.
[p. 4-133]
VI. CONCLUSIONS
A. GENERAL ECONOMIC IMPACT OF AIR POLLUTION CONTROL
The foregoing analyses indicate that control of air pollution
emissions from solid waste disposal, stationary fuel combustion,
and industrial processes will require an investment of approxi-
mately $6.510 billion to control the capacity estimated to be in
existence in the 298 metropolitan areas in Fiscal Year 1976.
This estimate is based on projected industrial and population
growth, which will substantially increase the sources of pollu-
tion and required investment in control equipment over that
required for 1967. The total estimated annual cost of these con-
trols, including depreciation, finance, and operating expenses,
would then amount to approximately $2.214 billion per year by
Fiscal Year 1976.
These figures are large in absolute amounts; however, their
significance can be shown more clearly by comparing them with
the related figures for the national economy. The $6.510 billion
investment in air pollution control equipment is less than 5
-------
GUIDELINES AND REPORTS 2547
percent of the $126 billion of gross private investment in the
United States for the year 1968. Similarly, if the gross national
product (GNP) of the United States in Fiscal Year 1976 is $1.2
trillion, the annual cost of $2.214 billion in that year will take
less than 0.2 percent of the nation's gross output.
The investment requirements and annual costs estimated are
for controls that would substantially reduce air pollution emis-
sions in the United States. The effects of the controls on emis-
sions are summarized in Table 4-17.
Analysis of the economic impact of projected requirements for
air pollution control was concentrated on seventeen industrial
process sources and only an analysis of direct costs and emission
reductions was made for solid waste disposal and stationary
fuel combustion. Some indication of the economic significance of
the projected costs in the latter two sectors has become appar-
ent, however.
[p. 4-134J
TABLE 4-17.—ESTIMATED EMISSIONS FROM ALL STATIONARY SOURCES, FY 1976
[293 metropolitan areas]
Emissions
Eslimaled emissions with 1967 control levels (thousands of tons).
Emissions in compliance with assumed standards (thousands of
to.is)
Reduction of pollutants (thousands of tons)
Percentage reduction
Part.
11,420
1,568
9,852
86.2
SOx
20,676
6,417
14,259
68.9
CO
15,490
953
14,537
93.8
HC
3,756
1,142
2,614
69.6
F
73
9
64
87.7
Pb
30
10
20
66.7
B. SOLID WASTE DISPOSAL
Solid waste disposal in the 298 metropolitan areas will require
an estimated total investment of $201 million by Fiscal Year
1976 and an annual cost that will amount to $113 million. Ap-
proximately 46 percent of these amounts will be borne by pri-
vate individuals and businesses and 54 percent by municipal
government. The costs borne by the municipal government may
be passed on to the population within the 298 metropolitan
areas or just to those people residing in an area where solid
waste collection is being municipally provided. The range of
possible per capita costs can be illustrated as follows:
• If the municipal costs were shared equally by the 186 million
people estimated in the 298 metropolitan areas in Fiscal Year
1976, the per capita burden would be $0.58 for investment
and $0.33 per year for annual costs. Both of these costs would
presumably be financed out of local government taxes.
-------
2548 LEGAL COMPILATION—AIR
• Since only 39 percent of municipally collected waste is dis-
posed of by methods requiring new or additional air pollution
control, it might be postulated that only 39 percent of the
population of these areas would have to pay the added costs.
Using this assumption, the per capita costs would be $1.49 for
investment and $0.84 per year for annual costs.
[p. 4-135]
C. STATIONARY FUEL COMBUSTION
The investment requirements and annual costs of air pollution
control of heat and power production in commercial, institutional,
and industrial establishments will be broadly spread throughout
the economy. More than $1 billion of investment may be required
of these firms and institutions by Fiscal Year 1976 and annual
costs will be approximately $580 million by that year. These costs
will be shared by approximately 1.2 million sources. The amount
required of each establishment will depend upon its size and its
need for steam for its operating processes. Without detailed
knowledge of these factors, it is not possible to estimate the eco-
nomic impact of the projected control requirements.
Steam-electric power plants will have investment requirements
and annual costs almost equal to the other stationary combustion
sources combined. When these costs are worked into the rate base
structure of the industry, it is estimated that they will provide
justification for an increase of approximately 2 percent in the
average price of electricity. This cost will be diffused into the
entire economy, making a small marginal contribution to many
other cost patterns.
D. INDUSTRIAL PROCESSES
Analysis of the impact of annual control costs on the industries
affected indicates that:
• Firms in seven of the 17 industries studied will be able to pass
these added costs on to their customers in the form of higher
prices. These are the asphalt batching, coal cleaning, elemen-
tal phosphorus, phosphate fertilizer, grain milling and han-
dling, iron and steel, and kraft pulp industries.
• Firms in three industries are expected to recover sufficient
quantities of valuable materials in controlling emissions to
offset the entire annual cost of control. This is the case for
-------
GUIDELINES AND REPORTS 2549
petroleum refining, petroleum storage, and rubber (tires).
Primary aluminum
[p. 4-136]
producers also fall into this category although the rest of the
nonferrous metallurgical industry does not.
• Firms in the other seven industries will probably have to
absorb all or part of the control costs, which will reduce their
revenue from sales, taxes paid, and net profits. In four of
these industries—cement, secondary nonferrous metallurgy,
varnish, and gray iron foundries—firms may find that less
than half their annual control costs can be recovered by in-
creasing prices. The brick and tile, lime, and primary nonfer-
rous metallurgical industries will recover a larger share of
control cost, but probably not the entire amount.
• Those prices that are increased will not rise by more than
approximately 2 1/2 percent as a result of air pollution control
costs. Those increases which may exceed 2 percent are for
brick and tile, elemental phosphorus, gray iron, and primary
zinc.
• Increases in the cost of materials used by the automobile and
construction industries, which use many of the products in-
cluded in this study, may lead to an increase in the price of an
automobile of about $22.50 and in the cost of a new home of
about $100, assuming 25 percent of the construction costs are
for new housing units.
• The aggregate effect of price increases induced by air pollu-
tion control costs will increase the national price level by
approximately 0.14 percent.
• A number of marginal firms may be forced to close or to enter
different product lines. This effect will apparently be confined
primarily to the secondary nonferrous metallurgical, varnish,
and gray iron industries. Some brick and tile and cement
plants may become submarginal, also.
• No appreciable effect is predicted for the general level of
employment or for employment in specific occupations.
[p. 4-137]
APPENDIX I
SELECTION OF 298 METROPOLITAN AREAS
The Clean Air Act, as amended, specified a plan for control of air pollution
on a regional basis. In brief, after the U. S. Government has issued air quality
criteria and a report on control techniques for a specific type of air pollutant,
-------
2550 LEGAL COMPILATION—AIR
State governments are expected to adopt and implement air quality standards
for that pollutant applicable to the air quality control regions (AQCR's)
designated.
Estimates of cost are presented for stationary source controls in 298 metro-
politan areas arbitrarily selected as regions. The 298 metropolitan areas
reflect the anticipated number of AQCR's for the 5-year period covered by this
report. All standard metropolitan statistical areas (SMSA's) are included as
a part of a region. Two or more adjacent SMSA's appearing to have a mutual
problem were combined into one region. Non-SMSA based regions were cen-
tered upon a community of 25,000 population, contiguous communities showing
a common problem, communities containing known major point sources, or
central communities within a large air shed. Selection and compilation of
these regions does not necessarily imply intentions on the part of NAPCA to
designate or not to designate them as AQCR's. Table 1-1 was compiled on the
basis of information available as of June 1, 1970. Information pertaining to
the designation of AQCR's after that date has not been considered in this
report.
[P. 1-1]
TABLE 1-1—List of 298 metropolitan areas
1. Aberdeen (S. Dak.).
2. Aberdeen-Hoquiam (Wash.).
3. Abilene (Tex.).
4. Alamogordo (N. Hex.).
5. Alamosa (Colo.).
6. Albany (Ga.).
7. Albany-Schnectady-Troy-Amsterdam (N.Y.).
8. Albuquerque (N. Mex.).
9. Allentown-Easton-Phillipsburg (N.J., Penn.).
10. Amarillo (Tex.).
11. Anchorage (Alaska).
12. Ann Arbor-Jackson (Mich.).
13. Asheville (N.C.).
14. Astoria (Oreg.).
15. Athens (Ga.).
16. Atlanta (Ga.).
17. Atlantic City-Southeast New Jersey (N.J.)
18. Augusta-Aiken (Ga., S.C.).
19. Augusta-Waterville-Skowhegan (Maine).
20. Austin (Tex.).
21. Bakersfield (Calif.).
22. Baltimore (Md.).
23. Bangor (Maine).
24. Bay City-Saginaw-Midland (Mich.).
25. Bellingham (Wash.).
26. Berlin-Rumford (N.H., Maine).
27. Big Spring (Tex.).
28. Billings (Mont.)
29. Binghamton (N.Y., Penn.).
30. Birmingham (Ala.).
-------
GUIDELINES AND REPORTS 2551
81. Bismark-Mandan (N. Dak.).
32. Bloomington (Ind.).
33. Bloomington (111.).
TABLE 1-1.—List of 298 metropolitan areas (continued)
34. Bluefield-Princeton (W. Va.).
35. Blytheville (Ark., Mo., Tenn.).
36. Boise (Idaho).
37. Boston (Mass.).
38. Bowling Green (Ky.).
39. Bozeman (Mont.).
40. Bristol-Johnson City-Kingsport (Tenn., W. Va.).
41. Brunswick (Ga.).
42. Bryan (Tex.).
43. Butte-Anaconda (Mont.).
44. Cape Girardeau-Caruthersville (Mo-.).
45. Carbondale-Marion-Harrisburg (111.).
46. Casper (Wyo.).
47. Cedar Rapids-Iowa City (Iowa).
48. Champaign-Urban-Danville (111.).
49. Champlain Valley (N.Y.,Vt.).
50. Charleston (S.C.).
51. Charleston (W. Va.).
52. Charleston-Matton (111.).
53. Charlotte (N.C., S.C.).
54. Charlottesville (Va.).
55. Chattanooga (Ga., Tenn.).
56. Cheyenne (Wyo.).
57. Chicago (111., Ind.).
58. Chico-Oroville (Calif.).
59. Cincinnati (Ind., Ky., Ohio).
60. Clarksburg-Fairmont-Morgantown (W. Va.).
61. Cleveland (Ohio).
62. Clovis (N. Mex.).
63. Colorado Springs (Colo.).
64. Columbia (S.C.).
65. Columbia-Jefferson City (Mo.).
66. Columbus-Newark (Ohio).
67. Columbus-Phoenix City (Ala., Ga.).
68. Corpus Christi (Tex.).
TABLE 1-1.—List of 298 metropolitan areas (continued)
69. Cumberland-Keyser (Md., W. Va.).
70. Dallas-Fort Worth (Tex.).
71. Dayton (Ohio).
72. Davenport-Rock Island-Moline (111., Iowa).
[p. 1-2]
[p. 1-3]
-------
2552 LEGAL COMPILATION—Am
73. Danville (N.C., Va.).
74. Decatur (111.).
75. Denver (Colo.).
76. Des Moines-Ames (Iowa).
77. Detroit-Port Huron (Mich.).
78. Dothan (Ala.).
79. Douglas-Lordsburg (Ariz., N. Hex.).
80. Dover (Del.).
81. Dubuque (111., Iowa, Wis.).
82. Duluth-Superior (Minn., Wis.).
83. Eau Claire (Wis.).
84. El Centro-Brawley (Calif.).
85. El Dorado (Ark., La.).
86. Elmira-Corning-Ithaca (N.Y.).
87. El Paso (N. Mex., Tex.).
88. Enid (Okla.).
89. Eureka (Calif.).
90. Evansville-Owensboro-Henderson (Ind., Ky.).
91. Fairbanks (Alaska).
92. Fargo-Moorhead (Minn., N. Dak.).
93. Fayetteville (N.C.).
94. Flagstaff (Ariz.).
95. Flint (Mich.).
96. Florence-Corinth (Ala., Miss., Tenn.).
97. Florence (S.C.).
98. Fort Collins (Colo.).
99. Fort Dodge (Iowa).
100. Fort Myers (Fla.).
101. Fort Pierce-Vero Beach (Fla.).
TABLE 1-1.—List of 298 metropolitan areas (continued)
102. Fort Smith-Muskogee (Ark., Okla.).
103. Fort Wayne (Ind.).
104. Four Corners (Ariz., Colo., N. Mex., Utah).
105. Fresno (Calif.).
106. Gadsden-Anniston (Ala.).
107. Gainesville (Fla.).
108. Gainesville (Ga.).
109. Galesburg (111.).
110. Grand Fork (Minn., N. Dak.).
111. Grand Island (Nebr.).
112. Grand Junction (Colo.).
113. Grand Rapids-Muskegon (Mich.).
114. Grants Pass-Medford (Oreg.).
115. Great Falls (Mont).
116. Green Bay-Fond du Lac (Wis.).
117. Greenville (Miss.).
118. Greenville-Spartanburg-Anderson (S.C.).
119. Hagerstown (Md., Penn., W. Va.).
[P.
-------
GUIDELINES AND REPORTS 2553
120. Harrisburg-Lebanon (Penn.).
121. Hartford-Springfield-New Haven (Conn., Mass.).
122. All of Hawaii (Hawaii).
123. Helena (Mont.).
124. Hennepin-Ottawa (111.).
125. Hot Springs (Ark.).
126. Houlton-Caribou (Maine).
127. Houston-Galveston (Tex.).
128. Huntington-Ashland-Portsmouth (Ky., Ohio., W. Va.).
129. Huntsville (Ala.).
130. Hutchinson (Kans.).
131. Indianapolis (Ind.).
132. Jackson (Miss.).
133. Jackson (Tenn.).
134. Jacksonville (Fla.).
135. Jamestown (N.Y.).
136. Johnstown-Altoona (Penn.).
[p.1-6]
TABLE 1-1.—List of 298 metropolitan areas (continued)
137. Joplin-N.E. Okla.-Fayetteville (Ark., Kans., Mo., Okla.).
138. Kalamazoo-Battle Creek (Mich.).
139. Kalispell-Flathead Lake (Mont.).
140. Kankakee (111.).
141. Kansas City (Kans., Mo.).
142. Keokuk (111., Iowa., Mo.).
143. Klamath Falls (Oreg.).
144. Kokomo-Marion (Ind.).
145. Knoxville (Tenn.).
146. La Crosse-Winona (Minn., Wis.).
147. LaFayette (Ind.).
148. Lancaster (Penn.).
149. Lansing (Mich.)
150. Laredo-Eagle Pass (Tex.).
151. Las Vegas-Kingman (Ariz., Nev.).
152. Laurel-Hattiesburg (Miss.).
153. Lawrence-Lowell-Manchester (Mass., N.H.).
154. Lawton (Okla.).
155. Lewiston-Moscow-Clarkston (Idaho, Wash.).
156. Lexington (Ky.).
157. Lima-Findlay (Ohio).
158. Lincoln (Nebr.).
159. Little Rock (Ark.).
160. Logan (Utah).
161. Los Angeles (Calif.).
162. Louisville (Ind., Ky.).
163. Lower Eio Grande Valley (Tex.).
164. Lubbock (Tex.).
165. Lufkin-Nacogdoches (Tex.).
526-705 O - 74 - 14
-------
2554 LEGAL COMPILATION—AIR
166. Lynchburg (Va.).
167. Macon (Ga.).
168. Madison (Wis.).
169. Manitowoc-Sheboygan (Wis.).
170. Mankato-New Ulm (Minn.).
TABLE 1-1.—List of 298 metropolitan areas (continued)
171. Mansfield (Ohio).
172. Marion (Ohio).
173. Mason City (Iowa).
174. Memphis (Ark., Miss., Tenn.).
175. Menominee-Escanaba-Marinette (Mich., Wis.).
176. Meridian (Miss.).
177. Miama (Fla.).
178. Midland-Odessa (Tex.).
179. Milwaukee (Wis.).
180. Minot (N. Dak.).
181. Minneapolis-St. Paul (Minn.).
182. Missoula (Mont.).
183. Mobile-Pennsacola-Biloxi-Gulfport (Ala., Fla., La., Miss.).
184. Modesto-Merced (Calif.).
185. Montgomery (Ala.).
186. Montpelier-Barre (Vt.).
187. Muncie-Anderson (Ind.).
188. Nashville (Tenn.).
189. Natchez (La., Miss.).
190. National Capital Area (D.C., Md., Va.).
191. Newburgh-Poughkeepsie-Kingston (N.Y.).
192. New London (Conn.).
193. New York-New Jersey-Connecticut (Conn., N.J., N.Y.).
194. Niagara Frontier (N.Y.).
195. Norfolk-Elizabeth City (N.C., Vir.).
196. Northeast Louisiana-Vicksburg (La., Miss.).
197. Oklahoma City (Okla.).
198. Omaha (Iowa, Nebr.).
199. Orlando (Fla.).
200. Ottumwa (Iowa).
201. Paduca-Metropolis-Cairo (111., Ky.).
202. Parkersburg-Marietta (Ohio, W. Va.).
203. Pendleton (Oreg.).
TABLE 1-1.—List of 298 metropolitan areas (continued)
204. Peoria (111.).
205. Philadelphia (Penn.).
206. Phoenix-Tucson (Ariz.).
207. Pine Bluff (Ark.).
[P. 1-6]
[p. 1-7]
-------
GUIDELINES AND REPORTS 2555
208. Pittsburgh (Penn.).
209. Pittsfield (Mass.).
210. Pocatello-Idaho Falls (Idaho).
211. Portland (Oreg.).
212. Portland-Lewiston-Auburn (Maine).
213. Prescott (Ariz.).
214. Providence (Conn., R.I.).
215. Pueblo (Colo.).
216. Puerto Rico (Puerto Rico).
217. Puget Sound (Wash.).
218. Quincy (111., Mo.).
219. Raleigh-Durham (N.C.).
220. Rapid City (Iowa).
221. Reading (Penn.).
222. Redding-Red Bluff (Calif.).
223. Reno-Carson City (Calif., Nev.).
224. Richland-Kennewick-Pasco (Wash.).
225. Richmond (Ind.).
226. Richmond-Petersburg (Va.).
227. Roanoke-Radford-Pulaski (Va.).
228. Rochester (N.Y.).
229. Rochester-Austin-Albert-Owato (Minn.).
230. Rochester-Dover-Portsmouth (N.H.).
231. Rockford-Janesville-Beloit (111., Wis.).
232. Rocky Mount-Goldsboro-Kinston (N.C.).
233. Rome (Ga.).
234. Roswell-Carlsbad-Hobbs-Pecos (N. Mex.).
235. Sacramento (Calif.).
TABLE 1-1.—List of 298 metropolitan areas (continued)
236. Salina (Kans.).
237. Salinas-Monterey-Santa Cruz (Calif.).
238. San Angelo (Tex.).
239. San Antonio (Tex.).
240. San Diego (Calif.).
241. Sandusky (Ohio).
242. Santa Fe (N. Mex.).
243. San Francisco Bay Area (Calif.).
244. San Luis Obispo (Calif.).
245. Sarasota (Fla.).
246. SaultSte. Marie (Mich.).
247. Savannah-Beaufort (Ga., S.C.).
248. Scranton-Wilkes Barre-Hazelton (Penn.).
249. Sehna (Ala.).
250. Sequatchie River Valley (Miss., Tenn.).
251. Shenandoah Valley (W. Va.).
252. Sherman-Denison (Tex.).
253. Sioux City (Iowa, Nebr.).
254. Sioux Falls (Iowa., S. Dak.).
[p. 1-8]
-------
2556 LEGAL COMPILATION—AIR
255. Southern Lousiana-Texas (La., Tex.).
256. South Bend-Elkhart-Benton Harbor (Ind., Mich.).
257. Spokane-Coeur d'Alene (Idaho, Wash.).
258. Springfield (111.).
259. Springfield (Mo.).
260. St. Cloud (Minn.).
261. St. Louis (111., Mo.).
262. Sterling (Colo.).
263. Steubenville-Weirton-Wheeling (Ohio, W. Va.).
264. Stockton (Calif).
265. Syracuse-Auburn (N.Y.).
266. Tallahassee (Fla.).
267. Tampa-St. Petersburg-Lakeland (Fla.).
TABLE 1-1.—List of 298 metropolitan areas (continued)
268. Terre Haute (Ind.).
269. Texarkana-Shreveport (Ark., La., Tex.).
270. Toledo (Mich., Ohio).
271. Topeka-Lawrence (Kans.).
272. Tulsa (Okla.).
273. Twin Falls (Idaho).
274. Tyler (Tex.).
275. Utica-Rome (N.Y.).
276. Valdosta (Ga.).
277. Victoria (Tex.).
278. Virgin Islands (Virgin Islands).
279. Visalia (Calif.).
280. Waco-Temple-Killeen (Tex.).
281. Walla Walla (Wash.).
282. Wasatch Front-Salt Lake City (Utah).
283. Waterbury-Torrington (Conn.).
284. Waterloo (Iowa).
285. Watertown (N.Y.).
286. Wausau (Wis.).
287. Wichita (Kans.).
288. Wichita Falls (Tex.).
289. Willimantic (Conn.).
290. Williamsport-Sanbury (Penn.).
291. Wilmington (N.C.).
292. Winston-Salem-Greensboro-High Point (N.C.).
293. Worchester-Fitchburg-Leominster (Mass.).
294. Yakima (Wash.).
295. York (Penn.).
296. Youngstown-Erie (Ohio, Penn.).
297. Yuma (Ariz.).
298. Zanesville-Cambridge (Ohio).
[P. 1-9]
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GUIDELINES AND REPORTS 2557
APPENDIX II
Assumed Emission Standards
A. Introduction
Under the Clean Air Act, as amended, air quality standards will be adopted
for Air Quality Control Regions (AQCR's), then plans for implementation of
the standards will be adopted. Ordinarily, implementation plans must include
emission standards intended to permit a region to attain and maintain its
established air quality standards. For this report, emission standards were
selected without going through the above steps, which would have required
many assumptions about air quality standards and a massive computational
effort to derive appropriate emission standards for all the 298 metropolitan
areas. The emission standards selected for this report are representative of
those now used throughout the Nation.
B. Standards for Partieulates
For industrial process sources, the process weight rate regulation of the
San Francisco Bay Area Pollution Control District (Table II-l) was used as
the basis of control cost estimates. This regulation limits the weight of
particulate emissions per hour as a function of the total weight of raw
materials introduced into a process operation.
For incinerators, the New York State Incinerator Standard for new units
was used. This standard limits total particulate emissions on the basis of mass
rate (pounds/hour), rather than concentration. Several areas have adopted a
variation of this; the New York State standard for new installation (Figure
II-l) was used to determine the control efficiency of incinerators. For fuel-
burning equipment, the combustion regulation of the State of Maryland was
used (Figure II-2).
C. Standards for Sulfur Oxides
For fuel-burning equipment, a regulation based on mass emission rate per
million B.t.u. input was used. It allows an emission rate of 1.46 pounds of
sulfur dioxide per million B.t.u. input; this limit is based on an equivalent
sulfur content of 1.0 percent by weight in coal (1.38 percent by weight
[p. II-l]
in oil). For process sources, a concentration standard of 500 parts per million
of sulfur dioxide was used.
D. Standards for Hydrocarbons
For process sources, cost estimates were based on treatment of all exhaust
gases to remove organic material by 90 percent (or more) by weight. For
petroleum products storage, it was assumed that all stationary tanks, reser-
voirs, and containers with more than a 40,000-gallon capacity and a vapor
pressure of 1.5 pounds per square inch absolute (or greater) must be equipped
with floating roofs, vapor recovery systems, or other equally efficient devices.
In addition, it was assumed that submerged filling inlets must be installed on
all gasoline storage tanks with a capacity of 250 gallons or more.
E. Standards for Carbon Monoxide
Cost estimates were based on treatment of all exhaust gases to remove or
reduce the weight of carbon monoxide emissions by at least 95 percent.
-------
2558 LEGAL COMPILATION—Am
F. Standards for Fluorides
Three fluoride emission standards were utilized in this study. For the
phosphate fertilizer and elemental phosphorus industries a standard of 0.2
pounds of total fluoride (gaseous and particulate) per ton of P206 was
applied. For the aluminum industry a standard of 0.06 pounds of total fluoride
per reduction cell per hour up to a maximum of 40 pounds per hour was
applied. For the iron and steel and brick and tile industries emission stand-
ards were applied separately to the gaseous and particulate fluoride fractions.
For the gaseous fraction a standard of 95 percent removal was assumed. The
standard for fluoride particulates requires that the quantity of total particu-
late emissions, including fluoride, meet the "process weight rate" standard.
G. Standard for Lead Particulates
The standard for lead particulates requires that the quantity of total
particulate emission, including lead, meet the "process weight rate" standard.
[P. n-2]
TABLE 11-1—ALLOWABLE RATE OF PARTICULATE EMISSION BASED ON PROCESS WEIGHT RATE'
Process weight
rate
Lbs./hr. Tons/hr.
100
200
400
600
800
1,000
1,500
2,000
2,500
3,000
3,500
4,000
5,000
6,000
7,000
8,000
9,000
10,000
12,000
0.05
0.10
0.20
0.30
0.40
0.50
0.75
1.00
1.25
1.50
1.75
2.00
2.50
3.00
3.50
4.00
4.50
5.00
6.00
Rate of
emission
Lbs./hr.
0.551
0.877
1.40
1.83
2.22
2.58
3.38
4.10
4.76
5.38
5.96
6.52
7.58
8.56
9.49
10.4
11.2
12.0
13.6
Process weight
Lbs./hr.
16.000
18,000
20,000
30,000
40,000
50,000
60,000
70,000
80,000
90,000
100,000
120,000
140,000
160,000
200,000
1,000,000
2,000,000
6,000,000
rate
Tons/hr.
8.00
9.00
10.00
15.00
20.00
25.00
30.00
35.00
40.00
45.00
50.00
60.00
70.00
80.00
100.00
500.00
1,000.00
3,000.00
Rate of
— emission
Lbs./hr.
16.5
17.9
19.2
25.2
30.5
35.4
40.0
41.3
42.5
43.6
44.6
46.3
47.8
49.0
51.2
69.0
77.6
92.7
' Data in this table can be interpolated for process weight rates up to 60,000 Ibs/hr by using equation E=4.10P».«and
can be interpolated and extrapolated for process weight rates in excess of 60,000 Ibs/hr by using equation E=55.0p.u—40
(E = rate of emission in Ibs/h r; P = process weight rate in tons/hr).
[p. H-3]
-------
GUIDELINES AND REPORTS
2559
50 100 500 1,000 5,000 10,000 50,000 100,000
REFUSE CHARGED (pounds/hour)
FIGURE 2-1.—New York State particulate emission regulation for
refuse burning equipment.
[P. H-4]
-------
2560
LEGAL COMPILATION—AIR
0.19
0.12
10 10= 10' 104
EQUIPMENT CAPACITY RATING (10° Ibs/hr)
FIGURE 2-2.—Maryland participate emission standards for
fuel burning installations.
[p. II-5]
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GUIDELINES AND REPORTS 2561
4.1b "PROGRESS IN THE PREVENTION AND CONTROL
OF AIR POLLUTION"
Report to Congress by the Administrator of the Environmental Protection
Agency, January 1971.
PREFACE
The Clean Air Act authorizes a national program of air pollu-
tion research and control activities. This program is conducted by
the Air Pollution Control Office (APCO) of the Environmental
Protection Agency. APCO formerly was known as the National
Air Pollution Control Administration and until December 2, 1970,
was an agency of the Department of Health, Education, and Wel-
fare.
For the past three years, the Secretary of Health, Education,
and Welfare has submitted to the Congress an annual report on
progress under the Clean Air Act. This report, covering activities
during calendar year 1970, is the first one submitted by the Ad-
ministrator of the Environmental Protection Agency.
This report is submitted annually in accordance with section
313 of the Clean Air Act, which reads as follows :
"Sec. 313. Not later than six months after the effective date of
this section and not later than January 10 of each calendar year
beginning after such date, the Administrator shall report to the
Congress on measures taken toward implementing the purpose
and intent of this Act including but not limited to (1) the prog-
ress and problems associated with control of automotive exhaust
emissions and the research efforts related thereto; (2) the devel-
opment of air quality criteria and recommended emission control
requirements; (3)the status of enforcement actions taken pur-
suant to this Act; (4) the status of State ambient air standards
setting; including such plans for implementation and enforcement
as have been developed; (5) the extent of development and expan-
sion of air pollution monitoring systems; (6) progress and prob-
lems related to development of new and improved control tech-
niques; (7) the development of quantitative and qualitative in-
strumentation to monitor emissions and air quality; (8)
standards set or under consideration pursuant to title II of this
Act; (9) the Status of State, interstate, and local pollution control
programs established pursuant to and assisted by this Act; and
(10) the reports and recommendations made by the President's
Air Quality Advisory Board."
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2562 LEGAL COMPILATION—AIR
It should be noted that this report reflects activities conducted
under the provisions of the Clean Air Act in effect through De-
cember 30, 1970. On December 31, 1970, the President signed into
law a bill amending the Act; generally, the amendments were not
taken into account in the preparation of this report.
SUMMARY
The Clean Air Act authorizes the Environmental Protection
Agency (EPA) to carry on a national program of air pollution
research and control activities. EPA's Air Pollution Control Office
has the principal operational responsibility for this program.
Among the principal accomplishments of this program during
the calendar year 1970, the following were particularly signifi-
cant:
• The machinery for adoption and implementation of air quality
standards had been set in motion in 100 air quality control
regions, three-fourths of which were designated during the
past year. These 100 regions contain about 140 million per-
sons, about 70 percent of the Nation's population.
• Air quality criteria for carbon monoxide, hydrocarbons, and
photochemical oxidants were issued. Reports on control tech-
niques for these pollutants and for nitrogen oxides also were
issued.
• Funds budgeted for State and local air pollution control activ-
ities reached $64 million, including both Federal and non-Fed-
eral funds.
• Three large-scale control technology demonstration projects
were initiated with joint government-industry support. Two
of them deal with the important problem of sulfur oxides
pollution.
• New procedures for determining whether motor vehicles will
comply with applicable national standards were established.
• An intensified effort to insure the development and demon-
stration of low-pollution motor vehicles was initiated.
PROGRESS IN THE PREVENTION AND CONTROL OF
AIR POLLUTION
CHAPTER I. EFFECTS AND SURVEILLANCE
This chapter covers those activities by which the Air Pollution
Control Office (APCO) seeks to define and document the adverse
effects of air pollution on public health and welfare and the nature
-------
GUIDELINES AND REPORTS 2563
and magnitude of air pollution problems affecting the Nation.
Effects of air pollution are identified through research. APCO's
research is divided into two principal areas—studies of the effects
of air pollution on human health and studies of economic and
esthetic effects, especially damage to materials and vegetation.
Knowledge derived from such research (whether conducted by
APCO or other groups) is summarized in air quality criteria docu-
ments, which define the health and welfare factors that State
governments must consider in setting air quality standards for air
quality control regions. Data on the nature and magnitude of the
Nation's air pollution problems and on air quality trends are de-
rived from air quality monitoring activities, including APCO's
own monitoring network and those operated by State and local
agencies. Also covered in this chapter are APCO's efforts to gain
an improved understanding of the interactions between air pollu-
tion and environmental factors. The totality of knowledge derived
from Effects and Surveillance activities is a vital element in evalu-
ating the Nation's needs for prevention and control of air pollu-
tion and in planning and carrying out programs capable of meet-
ing those needs.
A. To develop and publish air quality criteria documents reflecting
the latest available scientific knowledge of the health and welfare
hazards of air pollution
Air quality criteria documents summarize available scientific
knowledge of the relationship between concentrations of pollu-
tants in the air and their adverse effects on public health and
welfare. APCO prepares air quality criteria documents with the
assistance of consultants and contractors. Through arrangements
made during the past year, the National Academy of Sciences is
now contributing to the preparation of such documents. Prior to
publication, air quality criteria documents are reviewed by gov-
ernmental and non-governmental scientists, Federal agencies and
the National Air Quality Advisory Committee.
Three air quality criteria documents were issued during the
past year. They deal with carbon monoxide, hydrocarbons, and
photochemical oxidants. The previous year, documents on sulfur
oxides and particulate matter had been issued.
A number of additional air quality criteria documents were in
preparation during 1970; they will deal with nitrogen oxides, fluor-
ides, polycyclic organic matter, and lead; the National Academy of
Sciences is contributing to the preparation of the documents deal-
ing with all of these pollutants except nitrogen oxides.
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2564 LEGAL COMPILATION—AIR
The role being played by the National Academy of Sciences
(NAS) involves the preparation of state-of-the-art reports re-
viewing and evaluating the latest available scientific knowledge of
the health and welfare hazards of pollutants. These reports pro-
vide a basis for preparation of the actual air quality criteria
documents. In addition, the National Academy is conducting a
special study to determine the need for, and feasibility of, interim
steps to reduce public exposure to asbestos.
B. To identify and, interpret the risk to health resulting from
exposure to air pollutants
APCO's health effects research program includes individual lab-
oratory and field studies of the effects of specific air pollutants and
combinations of pollutants as well as a broader effort to establish
and maintain surveillance of people's health in relation to their
exposure to air pollution.
One epidemiological study conducted by APCO in the Chatta-
nooga region has provided, for the first time, evidence that am-
bient air levels of nitrogen dioxide are associated with adverse
health effects (beyond the effects resulting from the involvement
of nitrogen oxides in formation of photochemical smog). Within
the Chattanooga region, the occurrence of respiratory illness was
studied in areas of differing nitrogen dioxide levels. In the area
with higher nitrogen dioxide levels, there was a higher rate of
respiratory illness during an A2/Hong Kong influenza epidemic
and during the period between the A2 epidemic and a subsequent
influenza B epidemic. The rate was higher among second-grade
school children included in the study, their brothers and sisters,
and their parents. The rate was nearly 19 percent higher in the
area of higher nitrogen dioxide levels. In that area, the second-
grade school children also produced significantly poor results on
tests of ventilatory performance.
In another area, an APCO study showed a consistent relation-
ship between sulfur dioxide levels and the rate of asthma attacks
among members of the group studied. The rate increased progres-
sively from 33.0 attacks per 100 persons on days with a 24-hour
mean level of 0.03 parts per million or less to 46.9 attacks per 100
persons on days with levels higher than. 0.09 parts per million.
A laboratory study demonstrated that animals repeatedly ex-
posed to ozone and nitrogen dioxide develop some degree of toler-
ance to these pollutants but that the tolerance is limited. It was
found that while direct injury to lung tissue becomes less acute
after repeated exposure, the occurrence of subtle alterations in
-------
GUIDELINES AND REPORTS 2565
cellular chemistry and morphology, which are associated with ex-
posure to nitrogen dioxide, does not subside.
About two years ago, APCO initiated a major air pollution-
and-health surveillance effort—a coordinated series of epidemic-
logical studies designed to document the relationship between com-
munity health and changes in air quality. Over the past year, this
program has been expanded to include three cities in the south-
eastern United States, three in the New York area, four communi-
ties in Utah, and five communities in Montana and Idaho. Within
each of these four groupings of communities, there is to be a
continuing program of data-gathering on selected health indica-
tors known to be sensitive to variations in air pollution (for exam-
ple, rates of acute and chronic respiratory diseases, occurrence of
asthma attacks, and pulmonary functioning), coupled with moni-
toring of air pollution levels. For the most part, this project is
conducted through contracts with State and local health agencies.
It is anticipated that this program will provide, among other
things, evidence of the benefits to be derived from improvements
in air quality.
C. To identify and quantify the economic and esthetic effects of air
'pollution
A number of studies completed during the past year helped
provide an improved basis for assessing the economic and esthetic
impact of air pollution.
A systems ayalysis of the effects of air pollution on materials
indicated that deterioration of materials as a result of exposure to
polluted air is costing the Nation about $4 billion annually. Af-
fected materials include structural materials, such as steel and
concrete, rubber and leather products, fabrics, and so on.
A separate assessment of the effects of air pollution on rubber
products indicated that damage and deterioration resulting from
air pollution, plus measures taken by manufacturers to retard
such deterioration, cost consumers about $500 million annually.
Ozone and nitrogen oxides are the types of air pollutants that are
primarily responsible for deterioration of rubber products.
A field study of the effects of air pollution on dyed fabrics
showed that air pollution is a significant cause of fading. A total
of 67 dye-fabric combinations was exposed at seven locations
across the Nation. In four instances, fabric samples were placed
not only in an urban area but also, for purposes of comparison, in
a contiguous rural area. There was a significant urban-rural dif-
ference in fading at all four sites.
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2566 LEGAL COMPILATION—Am
An inquiry into the economic effects of air pollution on electrical
contacts produced an estimate of annual losses amounting to $64
million. The impact is greatest with respect to computer and in-
strumentation circuits. A large part of the estimated loss is asso-
ciated with the use of special techniques and special materials to
minimize exposure to polluted air and/or to minimize the effects
of air pollution on exposed materials.
D. To maintain nation-wide surveillance of air quality and emis-
sions and to facilitatie access to, and use of, air quality and emis-
sions data
The evolution of APCO's air quality and emissions surveillance
activities entered a new and very significant phase during the past
year with the formulation of plans for, and initial steps toward
implementation of, a National Aerometric Data Information Serv-
ice (NADIS). NADIS, when it is fully operational, will gather,
process, and disseminate data on air quality, emissions, and meteo-
rological factors in all parts of the Nation. A great deal of the
data, particularly with respect to air quality, will be derived
from State and local air monitoring activities; State and local
agencies, in turn, will be able to look to NADIS for data evaluation
services.
NADIS has evolved from, but will go well beyond, APCO's
earlier work on creation of a national air data bank and on devel-
opment of a system for .storage and retrieval of aerometric data.
Through NADIS, data will be available for a variety of purposes,
including assessment of progress toward attainment of air quality
standards, evaluation of emission control strategies, and imple-
mentation of plans for prevention of high-air pollution episodes.
APCO's current air quality surveillance network includes sta-
tions in more than 300 places. It includes approximately 300 high-
volume samplers for collection of particulate matter suspended in
the air and approximately 200 mechanized instruments for meas-
urement of sulfur dioxide and nitrogen dioxide concentrations;
each of these instruments is used to take a 24-hour sample on a
bi-weekly schedule. Also included in the network are 57 membrane
filter samplers, which permit measurement of ambient air levels of
asbestos and certain other materials that cannot be measured
through the use of high-volume samplers. In addition, APCO as-
sumed responsibility during the past year for operation of a 70-
station network equipped to measure radioactivity in the atmos-
phere.
-------
GUIDELINES AND REPORTS 2567
For the most part, needed servicing of APCO's air monitoring
stations (e.g., removing filters, mailing them to APCO's laborato-
ries, and inserting new filters) is performed on a voluntary basis.
In some instances, the persons involved work for State and local
air pollution control agencies, but in many cases they are teachers,
firemen, police and so on.
E. To develop and evaluate new and improved techniques and
instrumentation for sampling and analysis of pollutants in the
ambient air and in effluent streams from air pollution sources
During the past year, there has been significant further prog-
ress in APCO's work on the development of air pollution measure-
ment techniques and instrumentation, particularly with respect to
measurement of air pollutants which are coming under control
through State implementation of air quality standards or Federal
enforcement of emission standards for new motor vehicles.
Techniques originally developed for measurement of nitrogen
oxides levels in the ambient air have been adapted for possible use
in measuring nitrogen oxides emissions from stationary and mo-
bile sources. One such technique, based on a light-producing reac-
tion between ozone and nitric oxide, is under intensive evaluation
as a candidate method for use in assessing compliance with pro-
jected future national standards applicable to nitrogen oxides
emissions from new motor vehicles.
A major effort is underway to develop a technique for measur-
ing particulate emissions from motor vehicles; it is anticipated
that particulate emission standards applicable to new motor vehi-
cles also will be placed in effect within the next few years. A
prototype instrument designed for the measurement of particulate
matter in the ambient air has been assembled and is being evalu-
ated not only for this use but also for possible application to the
motor vehicle situation.
An instrument developed for the purposes of identifying and
measuring odorous sulfur compounds has been employed in two
studies of emissions from pulp and paper mills. In these studies,
this instrument helped identify those processes within the mills
which were the predominant sources of hydrogen sulfide, a partic-
ularly odorous and toxic compound.
New or improved instruments for measurement of sulfur ox-
ides, ozone (a constituent of photochemical smog), and hydrocar-
bons also were evaluated. The ozone and hydrocarbon instruments
are now commercially available.
-------
2568 LEGAL COMPILATION—AIR
F. To define the ways in which atmospheric processes, including
meteorological and chemical processes, alter or are altered by air
pollutants
APCO's research in the areas of meteorology and atmospheric
chemistry is designed not only to produce needed knowledge of
interactions between air pollutants and atmospheric processes but
also to permit the development of techniques that permit forecast-
ing of the extent to which such interactions will affect community
air pollution levels.
APCO's meteorology research is conducted by personnel on as-
signment from the National Oceanic and Atmospheric Adminis-
tration of the Department of Commerce. Efforts to develop new
diffusion models and to improve and refine existing models are a
continuing part of the meteorology research program; atmos-
pheric diffusion models simulate the diffusion and transport of
pollutants in the air and therefore can be used to predict the
impact of new sources of air pollution or the effects of reductions
in emissions from sources already in existence. A computerized
multiple source dispersion model has been developed and vali-
dated. A model for predicting the concentration distribution of
carbon monoxide from motor vehicles in urban areas has been
developed and is being evaluated.
A comprehensive effort to assess the environmental efforts of
effluents from large electric generating plants is continuing. This
effort involves studies by APCO and contractors of the chemical
transformation and ultimate fate in the atmosphere of sulfur com-
pounds emitted from fossil fuel-burning electric generating plants.
This project includes studies on the dilution efficiency of tall (800
feet) stacks, the washout of power plant effluents by natural
precipitation, and the effects on local climate and weather of large
amounts of water vapor and heat from cooling towers.
Because atmospheric temperature gradients (differences in tem-
perature with increasing altitude) are among the factors that
influence the transport and dispersion of air pollutants, and be-
cause of the limitations of conventional means of obtaining atmos-
pheric temperature profiles, APCO has been supporting the devel-
opment of remote sensing techniques. In this regard, a prototype
radiometer for measuring vertical temperature profiles has been
developed and successfully tested. APCO also is supporting the
development and demonstration of ground-based acoustic and
laser techniques for measuring atmospheric turbulence and wind.
-------
GUIDELINES AND REPORTS 2569
In the area of atmospheric chemistry, studies of various aspects
of the formation of photochemical smog are continuing. One of the
purposes of such studies is to determine the photochemical reactiv-
ity of various substances present in the air. One such study helped
establish that aldehydes, which are present in emissions from com-
bustion processes (including emissions from motor vehicles), are
about as reactive as the corresponding olefinic hydrocarbons, the
reactivity of which was already well known. Another study, still
in progress, has indicated that vapors from certain oxygenated
solvents are reactive and therefore can be involved in smog forma-
tion, but that many commonly used solvents have only slight reac-
tivity.
Other studies are underway to define the chemical and physical
reactions involved in the formation of sulfates and nitrates, which
have been shown to account for a substantial portion of the partie-
ulate matter that affects visibility. There is evidence that sulfates
and nitrates are the end products of atmospheric reactions involv-
ing gaseous sulfur oxides and nitrogen oxides emitted by station-
ary and mobile sources of air pollution.
G. To provide grant support of research projects related to the
Air Pollution Control Office's program objectives
Through awards of research grants, primarily to colleges and
universities, APCO supports efforts to expand the frontiers of
scientific knowledge relating to various aspects of air pollution
and its prevention and control. Most research grants are in the
Effects and Surveillance category of APCO's programs; i.e., they
contribute mainly to defining the nature, magnitude, and effects of
air pollution.
In Fiscal 1970, APCO supported 280 research grant projects
through awards amounting to some $7.1 million. A breakdown of
these projects by subject matter follows:
1. Effects of air pollution on human health 35
2. Agricultural effects 35
3. Economic and social studies 11
4. Physico-chemical investigations 73
5. Development of analytical methods and equipment 34
6. Meteorology 26
7. Nature and control of air pollution sources 58
8. Communications 8
In May 1970, APCO published the first edition of Highlights of
Selected Air Pollution Research Grants, which provides more de-
tailed information on many APCO-supported projects. A second
edition is being prepared for publication in the near future.
-------
2570 LEGAL COMPILATION—AIR
A symposium sponsored by the National Air Pollution Research
Grants Advisory Committee held in June 1969 at the annual
meeting of the Air Pollution Control Association led to the publi-
cation of Recognition of Air Pollution Injury to Vegetation: A
Pictorial Atlas. A number of the contributors to this publication
were scientists whose research was supported in part by APCO
grants.
CHAPTER II. CONTROL AND COMPLIANCE
This chapter covers APCO's research and development and reg-
ulatory activities. These activities have two basic purposes: first,
to insure the application of available techniques, as needed, to
prevent and control air pollution, and, second, to identify and help
meet needs for new or improved techniques. Under the Clean Air
Act, control of air pollution from stationary sources is primarily a
responsibility of State and local governments, while the Federal
Government has a corresponding responsibility with respect to
motor vehicles. APCO conducts and supports research and devel-
opment activities and demonstration projects relating to control
techniques for both stationary and mobile sources. APCO also
furnishes State and local agencies financial and technical assist-
ance to help them fulfill their responsibilities in the field of air
pollution control.
A. To insure that air pollution problems are attacked on a regional
basis through the adoption and implementation of air quality
standards
In November 1967, in amendments to the Clean Air Act, the
Congress set up a mechanism for adoption and implementation of
air quality standards as the principal means of providing for
prevention and control of air pollution. In accordance with the
express intent of the legislation, APCO has been devoting a sub-
stantial share of its efforts and energy to putting this mechanism
into action. The following is a summary of the status of tnis
activity as of December 1, 1970:
Air quality control regions had been designated in 100 areas.
This total included one or more areas in every State. It included 29
interstate areas earmarked for designation in accordance with the
President's Message on Environment, which was transmitted to
the Congress on February 10, 1970, as well as 24 other interstate
areas previously identified as candidates for designation. Also in-
cluded were several areas designated at the request of State
officials.
-------
GUIDELINES AND REPORTS 2571
In addition, APCO had held consultations with State and local
officials with respect to designation of an additional 22 air quality
control regions; in each instance, APCO's action was taken at the
request of State officials. A number of States had asked that their
entire land area be divided into air quality control regions.
The issuance of air quality criteria documents is the signal for
States to begin adopting air quality standards and implementation
plans for air quality control regions. In March 1970, air quality
criteria for carbon monoxide, hydrocarbons, and photochemical
oxidants were issued. A year earlier, air quality criteria had been
issued with respect to sulfur oxides and particulate matter. In
each instance, reports on applicable control techniques have been
issued simultaneously with the air quality criteria documents.
In accordance with the timetable set forth in the Clean Air Act,
States had adopted air quality standards for sulfur oxides and
particulate matter for more than 20 air quality control regions
and were in the process of doing so for many other regions. Of
those submitted for review, most had been found consistent with
the corresponding air quality criteria. State plans for implementa-
tion of these standards had been or were being formulated.
For the air quality control regions already designated, nearly all
the States involved had signified their intention of adopting air
quality standards for carbon monoxide, hydrocarbons, and photo-
chemical oxidants. Adoption of the first such standards was due to
be completed by the States by mid-December 1970. Formulation of
implementation plans will follow.
Thus far, the principal difficulties encountered in this process
have been related to the development of State implementation
plans. Largely because the development of implementation plans
designed to insure attainment of specific air quality standards is a
procedure that had not previously been widely employed, many
States do not have sufficient air quality and emission data and
have had limited experience with techniques for formulating and
evaluating emission control strategies.
APCO has taken a number of steps to help States overcome
these difficulties. Formats for the preparation of implementation
plans have been made available to the States. Two computer pro-
grams have been devised to assist States in employing diffusion
modeling (a technique for relating emissions to air quality) and in
assessing the costs and effectiveness of various emission control
strategies. APCO has made arrangements that permit States to
enlist the expertise of several non-Federal organizations, on a
contractual basis, to assist in the formulation of implementation
-------
2572 LEGAL COMPILATION—AIR
plans. In December 1969 and January 1970, APCO held three
workshops to familiarize State officials with the requirements of
the Clean Air Act insofar as implementation plans are concerned;
these workshops were a follow-up to Guidelines for the Develop-
ment of Air Quality Standards and Implementation Plans, which
was issued by APCO in May 1969. More recently, APCO had a
series of meetings with State officials in every part of the Nation
to discuss problems of mutual interest, including problems relat-
ing to the formulation of implementation plans. Finally, because
there have been particular difficulties with the formulation of
plans for preventing high-air pollution episodes, a special seminar
on this matter was held early in December 1970.
B. To furnish the public information on the nature and effects of
air pollution and to encourage public involvement in air pollution
control effort
Over the past year, there has been a continued high level of
public participation in State hearings on air quality standards.
Under the Clean Air Act, States are required to hold such hear-
ings before adopting air quality standards for an air quality con-
trol region. APCO has continued its program of assistance to
persons and groups interested in participating in such hearings;
this assistance consists primarily of providing technical informa-
tion on, and evaluation of, air pollution problems and their effects
on public health and welfare and air quality standards proposed
for adoption by State governments.
A large number of national, regional, and local groups have
requested and received assistance from APCO in formulating and
carrying on programs to stimulate public awareness of the threat
of air pollution and public involvement in control efforts. These
groups include the National Tuberculosis and Respiratory Disease
Association and other health-oriented organizations, the League of
Women Voters, various labor organizations, the Conservation
Foundation, and the General Federation of Women's Clubs.
The past year also has been one of continued increases in re-
quests for information and publications, including requests from
the news media and the general public. Publications distributed by
APCO totalled nearly two million items, twice that of the previous
year. APCO also received about 5,000 requests for films on air
pollution. In addition, assistance was given to about 150 persons
or groups involved in preparation of films, books, articles, and
other audiovisual materials.
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GUIDELINES AND REPORTS 2573
C. To assist State, local, and regional agencies in preventing and
controlling air pollution by furnishing them financial and techni-
cal support
Over the past several years, there has been a steady increase in
State and local expenditures for air pollution control activities. In
large measure, this trend reflects the effect of Federal matching
grants made available under the Clean Air Act. Table I shows the
history of Federal and non-Federal (i.e., State and local) spending
for air pollution control programs since Fiscal 1965, the first year
in which Federal grants were available.
TABLE 1.—BUDGETING FOR AIR POLLUTION CONTROL PROGRAM"
[In millions of dollars]
Fiscal year
1965
1966
1967
1968
1969
1970
Federal
4.1
5.5
7.6
18.6
22.9
26.0
Non-Federal
9.6
11.8
18.1
28.9
34.4
38.4
Total
13.7
17.3
25.7
47.5
57.3
64.4
Over the same period, the number of air pollution control agen-
cies in operation increased from 92 to 220. Of the 220 agencies in
operation at the end of Fiscal 1970, Federal grant support was
being provided to 202, including 12 that had not previously re-
ceived such support.
In the 39 State legislatures that had sessions during 1970, some
800 bills dealing with air pollution and related environmental
problems were introduced. About 100 were enacted. Among them
was an air pollution control law enacted in South Dakota. With
the enactment of the South Dakota law, all 50 States, plus the
territories of Puerto Rico and the Virgin Islands, have basic legis-
lation dealing with air pollution.
In addition, State, local, and regional air pollution control agen-
cies were active in strengthening many previously adopted regula-
tions and in promulgating new regulations, particularly with re-
spect to sulfur oxides and particulate emissions and open burning.
There also was continued progress in enforcement activities in a
number of places. Examples of accomplishments include:
• Stringent particulate emission standards for large new elec-
tric generating plants were adopted by the States of Arizona,
New Mexico, and Nevada.
• Sulfur oxides emission standards for primary non-ferrous
smelters were adopted by the States of Arizona, Montana,
-------
2574 LEGAL COMPILATION—AIR
and Washington; these standards are the first regulations of
their kind.
• Enforcement action in St. Louis resulted in shut-down of 375
small incinerators and upgrading of about 40 others.
• Compliance with regulations governing the sulfur content of
fuels produced significant reductions in sulfur oxides levels in
the New York-northern New Jersey metropolitan area.
• In New York City, 780 small incinerators were upgraded and
1,000 were shut down. Three municipal incinerators also were
shut down. Emission control systems are being tested at four
municipal incinerators.
In response to requests during the past year, APCO furnished
State, local, and regional agencies a great deal of technical aid in
the development of regulations, evaluation of specific air pollution
problems, planning of air monitoring systems and emission inven-
tories and so on.
D. To assist State, local, and regional agencies in recruiting and
training personnel for work in air pollution control programs
A number of significant changes were made in APCO's man-
power development and training activities during the past year.
To provide immediate help to State agencies, APCO initiated a
program under which qualified personnel are employed by APCO
and assigned to State agencies for periods of up to two years. It is
anticipated that many of these personnel, at the end of their
service as APCO assignees, will be employed by the State agencies.
A total of 105 personnel will be detailed to State agencies dur-
ing the first year of this program; it is expected that all of them
will have been recruited and assigned by December 31, 1970. The
great majority will be recent college and university graduates
with B.S. degrees in engineering. A few will have M.S. degrees.
Practically none of them will have had any previous experience in
air pollution control.
State response to this program has been enthusiastic. Nearly all
State air pollution control agencies have requested assignment of
one or more persons.
As another means of responding to State, local, and regional air
pollution control agencies' manpower needs, APCO has begun re-
directing its training-grants activity. Training grants to educa-
tional institutions will be primarily for programs leading to B.S.
and M.S. degrees and for technician-training programs; support
of training beyond the M.S. level will be limited.
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GUIDELINES AND REPORTS 2575
This shift in the training-grants activity reflects findings re-
ported to the Congress in June 1970 in Manpower and Training
Needs for Air Pollution Control. Very briefly, APCO found that
air pollution control agencies are most in need of personnel who
have a basic education in occupational categories such as engineer-
ing, chemistry, and meteorology, as well as technicians, who can
be trained on-the-job to perform the specific functions involved in
air pollution control programs.
During the summer, APCO conducted the first of a projected
annual series of 12-week training-work programs for undergrad-
uate students interested in air pollution control. Each such pro-
gram will include six weeks of classroom instruction, followed by
six weeks of on-the-job training and work experience with State
or local air pollution control agencies. The first such program was
conducted in Houston, Texas, in cooperation with the University
of Houston, the University of Texas, and several State and local
agencies in the Southwest. Thirty-five students participated; in-
cluded among them were students in engineering and other techni-
cal fields as well as in economics and social sciences. A number of
the students indicated that they would be interested, after gradua-
tion, in full-time employment with air pollution control agencies;
some are continuing part-time work with the agencies to which
they were assigned during the summer program.
Also for the purpose of stimulating students' interest in careers
in air pollution control, APCO sponsored three workshops for
college students. They were held in Idyllwild, California, New
Braunfels, Texas, and Pawling, New York. In each case, several
colleges and universities were involved. A total of 217 students
participated.
To facilitate the recruiting process, APCO is taking steps to-
ward setting up a national recruitment and placement service. In
effect, this service will be a clearinghouse for persons interested in
employment with air pollution control agencies and for agencies in
need of qualified personnel. It is expected that this service will
begin operation in the coming year.
APCO's short-course training program is being expanded; this
program is designed primarily as a supplement to on-the-job
training of air pollution control agency personnel. Though such
courses always have been offered at various locations around the
country, scheduling was on an ad hoc basis. Now, short-course
training centers have been set up at six sites, and schedules have
been established for course offerings at each one. In addition,
many courses still will be offered at APCO's facilities in the Re-
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2576 LEGAL COMPILATION—Am
search Triangle area in North Carolina. Several new courses are
being developed and will be added to the curriculum in the near
future.
With APCO sponsorship, two university consortia on air pollu-
tion have been established. One includes three institutions in the
Research Triangle area of North Carolina, and the other includes
seven institutions in the New England area. It is anticipated that
similar consortia will be set up in other parts of the country. The
consortium arrangement is designed to facilitate pooling of re-
search and training resources and to foster interdisciplinary work
relating to air pollution control.
E. To take Federal action, where appropriate, for the purpose of
abating interstate and intrastate air pollution problems
Though adoption and implementation of air quality standards is
the principal mechanism for dealing with air pollution problems
under the provisions of the Clean Air Act, the Act also authorizes
a three-step Federal abatement procedure. Thus far, this abate-
ment procedure has been employed in ten areas.
The first case in which abatement proceedings were initiated
involved odors from a rendering plant in Bishop, Maryland. This
case, which had been initiated in November 1965, was concluded
in June 1970, when the plant was closed in accordance with a
court order. Previously, after failing to comply with recommenda-
tions arising from an abatement conference and a public hearing,
the owners of the plant had taken the case to the U. S. Supreme
Court, which declined to hear it.
In response to recommendations arising from an abatement con-
ference held in July 1969, the Ohio Edison Company has agreed to
shut down seven small boilers at its Toronto electric generating
plant by December 31, 1970; the boilers would be reactivated only
in the event of emergency. Particulate emission control equipment
is being installed on the three largest boilers at the Toronto plant.
APCO previously had rejected several company proposals to keep
the seven small boilers in service for extended periods of time.
In the Parkersburg, West Virginia-Marietta, Ohio area, where
an abatement conference had led to recommendations for abate-
ment of emissions from several industrial sources, nearly all the
companies involved are making progress toward abating particu-
late emissions. Thus far, however, no progress has been made
toward abatement of sulfur oxides emissions from the Union Car-
bide plant in the area. In mid-November, Union Carbide was given
three weeks to submit an abatement plan; this step followed rejec-
tion of a previously submitted plan, under which the Federal Gov-
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GUIDELINES AND REPORTS 2577
ernment was asked to pay one-half of the abatement cost. A re-
vised plan was submitted in December and was being reviewed at
the time this report was being prepared.
In the other areas where abatement action had been initiated,
APCO has continued to monitor the progress of abatement efforts.
In some areas, substantial progress has been made, e.g., significant
reductions of sulfur oxides emissions in the New York-northern
New Jersey and National Capital metropolitan areas, substantial
reductions of fluorides emissions in the Garrison, Montana, area.
In several instances, the areas covered by abatement proceedings
have since been included in air quality control regions.
F. To 'prevent the occurrence of high-air pollution episodes
Section 108 (k) of the Clean Air Act authorizes direct Federal
action to abate air pollution in order to prevent substantial endan-
germent to the health of persons. This provision of the Act is
primarily aimed at preventing the occurrence of air pollution epi-
sodes like those that have caused widespread illness and death in
places such as London, New York, and Donora.
State and local agencies in the area where such an episode is
occurring or is expected to occur are in the best position to initiate
necessary action on short notice, but Federal support, and, in some
instances, direct Federal action, will be required. Accordingly,
APCO has set up an Emergency Operations Control Center
(EOCC) to perform the functions involved not only in providing
such Federal support but also in taking direct Federal action.
EOCC, located at the APCO Technical Center in the Raleigh-
Durham area of North Carolina, is responsible for maintaining
continuous nation-wide surveillance of meteorological conditions
and air quality and of the actions taken by State and local agen-
cies during all phases of actual and potential air pollution epi-
sodes. Air quality data are received daily from more than 25
places around the country. If and when forecasts of meteorological
conditions indicate that an episode may occur, data-gathering is
stepped up, and EOCC establishes contact with the cognizant
State and local agencies in order to advise and assist them and to
determine whether they are taking adequate steps to prevent sub-
stantial endangerment to persons' health. Federal action can be
taken under section 108 (k) only where State and local agencies
have not initiated appropriate action.
APCO also is preparing to issue guides to physicians and health
agencies to assist them in dealing with air pollution episodes.
These documents will provide advice on caring for persons who
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2578 LEGAL COMPILATION—AIR
may be particularly sensitive to high levels of air pollution and on
gathering data for the purpose of documenting the impact of
episodes. It is anticipated that the guides will be issued early next
year.
G. To assist Federal departments and agencies in preventing and
controlling air pollution arising from their activities
All the departments and agencies of the Executive Branch of
the Federal Government are responsible for preventing and con-
trolling air pollution arising from their facilities. Their air pollu-
tion control activities now are planned and conducted in accord-
ance with Executive Order 11507, issued February 4, 1970. This
new Executive Order superseded one that had been in effect since
May 1966.
The new Executive Order requires, among other things, that air
pollution abatement projects actions necessary to comply with reg-
ulations previously promulgated by the Secretary of Health, Edu-
cation, and Welfare must be underway or completed by December
31, 1972 unless a specific exception is requested and granted. The
order also requires that all facilities which are built in the future
must be designed to be in compliance with applicable Federal air
quality standards and implementation plans, budget requests for
new facilities must include all necessary funds for air pollution
control. It should be noted that the Executive Order contains simi-
lar provisions pertaining to water pollution control.
Primary responsibility for administering the Executive Order is
assigned to the Office of Management and Budget (OMB), and the
Environmental Protection Agency has standard-setting powers.
APCO provides technical assistance not only to OMB but also the
various departments and agencies, all of which must submit abate-
ment plans and progress reports annually. A detailed report on
progress in the Federal facilities air pollution abatement program
is submitted separately to the Congress each year.
One noteworthy development during the past year was the ini-
tial success of an interdepartmental effort to insure effective con-
trol of air pollution from electric generating plants built and oper-
ated by private firms under land-lease or water-use agreements
with the Bureau of Reclamation of the Department of the Inte-
rior. Through this effort, initiated by APCO, plans are being made
to provide the best available particulate emission control technol-
ogy for more than 15,000 megawatts of electric generating capac-
ity in New Mexico, Arizona, Nevada, Utah, and Colorado. APCO
now is attempting to carry this interdepartmental effort a step
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GUIDELINES AND REPORTS 2579
further to include control of sulfur oxides and nitrogen oxides
emissions, as well.
H. To identify needs for new or improved control techniques for
stationary sources of air pollution and to participate in developing
and demonstrating such techniques
APCO's success in enlisting the participation of several non-
governmental organizations in conducting and supporting large-
scale demonstrations of sulfur oxides and particulate emission
control techniques was a particularly significant accomplishment
during the past year. Three projects were initiated with joint
government-industry support. They represent a breakthrough in
private-sector reluctance to participate in cost-sharing projects,
which are specifically authorized and encouraged by section 104
of the Clean Air Act.
Two of the projects involve demonstrations of privately devel-
oped flue gas desulfurization processes, both of which result in
recovery of sulfuric acid. The magnesium oxide wet scrubbing
process, developed by the Chemico Corporation, is to be demon-
strated at an oil-fired electric generating plant operated by the
Boston Edison Company; testing is expected to begin late in 1971.
The catalytic oxidation process, developed by the Monsanto Com-
pany, is to be demonstrated at a coal-fired electric generating
plant operated by the Illinois Power Company; testing is expected
to begin mid-1972. These two processes are known to be techni-
cally feasible; the projects now underway will demonstrate the
reliability economics of the processes on a large scale.
Another sulfur oxides control process, one developed by APCO
and the Tennessee Valley Authority, is already undergoing large-
scale demonstration testing at a TVA electric generating plant;
this process is known as dry limestone injection. Following com-
pletion of the dry limestone project, demonstration of a second
process, the limestone injection-and-wet scrubbing process, will be
undertaken at the same plant. Though these processes do not yield
a by-product now considered usable, they are relatively close to
commercial applicability. It is anticipated that limestone injec-
tion-and-wet scrubbing will be capable of achieving better than 90
percent removal of sulfur oxides, that it will also remove particu-
late matter, and that its costs will be reasonable.
Through a demonstration grant to the city of Key West, Flor-
ida, APCO is supporting another demonstration of limestone
injection-and-wet scrubbing at an electric generating facility. Be-
cause of the availability of a local supply of limestone (derived
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2580 LEGAL COMPILATION—AIR
from coral), an ample low-cost water supply, and inexpensive
waste treatment in a diked lagoon, the Key West facility provides
a unique opportunity to demonstrate the economic and technical
feasibility of the wet limestone process.
Among the processes described above, it is anticipated that one
or more will go into commercial use within the next few years,
particularly at electric generating plants, which are major sources
of sulfur oxides pollution. But it is not expected that these proc-
esses will provide a full solution to the sulfur oxides problem.
Accordingly, APCO is supporting pilot-scale investigations of sev-
eral other processes; the purpose is to identify processes that may
have a higher sulfur oxides control efficiency, have more favorable
economics, produce elemental sulfur rather than sulfuric acid as a
by-product, and simultaneously remove more than one pollutant.
Four such processes currently are under investigation: the West-
vaco regenerable char process, which produces elemental sulfur
(easier and cheaper to store and ship than is sulfuric acid) ; the
Tyco modified chamber process to remove sulfur oxides, nitrogen
oxides, and particulate matter, with production of sulfuric and
nitric acids as by-products; Atomics International's molten car-
bonate process, which produces elemental sulfur; and the ammo-
nia scrubbing process, which can be made to produce sulfuric acid.
Among electric generating plants, as. well as other fuel burning
facilities, the use of fuels having a naturally low sulfur content or
fuels from which some of the sulfur has been removed is another
means of reducing sulfur oxides emissions. APCO has been sup-
porting projects aimed at identifying coals amenable to a signifi-
cant degree of desulfurization; through these projects, it has been
found, thus far, that about 40 million tons of the Nation's annual
coal production can be cleaned to a level of one percent sulfur;
additional amounts can be cleaned to a level of 1.5 to 2.0 percent
sulfur. APCO is also supporting work on the design of a prototype
plant to demonstrate optimum coal-cleaning techniques applicable
to various types of coals and is seeking a commitment from pri-
vate firms to share the cost of constructing such a plant.
In recognition of a need for techniques that are capable not only
of reducing sulfur oxides emissions but also are more compatible
with the Nation's long-range interests in efficient use of fuels and
other natural resources, APCO also is supporting research and
development dealing with new combustion concepts, including flui-
dized bed combustion and fuel conversion, particularly coal gasifi-
cation. APCO is planning to support research and development on
advanced power cycles, including one with a projected energy
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GUIDELINES AND REPORTS 2581
conversion efficiency of about 50 percent, versus 37 percent for
conventional electric generating plants and 30 to 35 percent for
nuclear plants. These techniques are considered to be a number of
years away from commercial application.
APCO's research and development in the area of stationary
source pollution control also includes work on pollutants other
than sulfur oxides. One of the three cost-sharing projects initiated
during the past year involves a technique for reducing particulate
emissions from coke-charging operations at steel mills. This tech-
nique is being demonstrated at a Jones and Laughlin coke-oven
Lattery in Pittsburgh. The American Iron and Steel Institute is
sharing the cost.
A comprehensive study of the nature and extent of nitrogen
oxides emissions from stationary sources has been completed. A
major objective of the study was to assess the state-of-the-art of
nitrogen oxides control and identify needed research and develop-
ment projects. It is anticipated that several such projects will be
underway in the near future.
I. To establish national standards for the control of air "pollution
from new motor vehicles and to insure compliance with the
standards
A significant step toward improved control of motor vehicle
pollution was taken in November 1970 with the promulgation of
revised emission standards and testing regulations applicable to
passenger cars and light-duty trucks. The new emission standards
and testing regulations take effect in the 1972 model year.
One of the major objectives of the revision is to insure that new
light-duty vehicles are, in fact, designed and equipped to achieve
the degree of emission reduction that the emission standards are
intended to produce. APCO has found that the new test proce-
dures and emission measurement methods more accurately reflect
the total amounts of hydrocarbons and carbon monoxide emitted
by light-duty vehicles.
The revised regulations prescribe a driving cycle (combination
of the various modes of operation, e.g., start, idle, acceleration,
deceleration, cruising) that is more representative of urban driv-
ing patterns. New and more accurate emission measurement meth-
ods are to be employed, and emissions are to be measured through-
out the driving cycle.
The revised emission standards are 3.4 grams per vehicle mile
for hydrocarbons and 39 grams per vehicle mile for carbon mon-
oxide. While in strictly numerical terms, these values are higher
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2582 LEGAL COMPILATION—Am
than those previously in effect, when the new test procedures are
employed, the net effect is to reduce the allowable emissions well
below those of 1970-1971 light-duty vehicles.
The new emission standards and testing regulations, as pub-
lished in the Federal Register on November 10, 1970, incorporate
many other changes. Among them is a tightening of the standard
applicable to evaporation of hydrocarbons from fuel tanks and
carburetors. The revised standard is two grams per test, as com-
pared to the previous requirement of six grams per test.
A separate revision of the motor vehicle regulations, promul-
gated earlier in the year, requires labelling of all light-duty vehi-
cles. Each label must contain, among other things, the engine
tuneup specifications and adjustments recommended by the manu-
facturer.
There were several significant developments bearing on the use
of lead additives in gasoline. These developments reflected grow-
ing concern about the potential public health hazards associated
with continued use of lead additives and about the likelihood that
the use of lead additives would impose serious limitations on the
techniques that could be used to reduce emissions of other pollu-
tants from motor vehicles.
By direction of the President, the Administrator of General
Services issued a regulation under which new contracts for pro-
curement of gasoline for use by Federal departments and agencies
within the 50 States generally must provide for procurement of
low-lead (no more than 0.5 grams per gallon) or lead-free gaso-
line.
On request from APCO, the Department of Commerce Technical
Advisory Board (CTAB) established a special panel to undertake
a study of the implications of discontinuing the use of lead addi-
tives in gasoline. In June 1970, the panel made an interim report
which recommended, among other things, that legislation be en-
acted to authorize Federal regulation of the use of fuel additives
and that the agency charged with implementing such legislation
begin taking steps toward insuring wide availability of unleaded
gasoline by July 1974 and wide availability of low-lead gasoline by
the end of calendar year 1972. The panel also recommended that
Federal tax or subsidy policies be employed to complement regula-
tions dealing with production and distribution of unleaded and
low-lead gasoline.
Legislation conforming to the panel's recommendations had
been proposed by the President in February 1970. The Clean Air
Act amendments passed in December 1970 reflected this proposal.
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GUIDELINES AND REPORTS 2583
A separate proposal to impose a tax on lead used as an additive to
gasolir.e was submitted subsequently, but action on it was deferred
by the Congress.
J. To insure the development and demonstration of low-pollution
motor vehicles
On February 10, 1970, in his Message on Environment, the
President announced the start of an intensified Federal effort to
find solutions to the problem of motor vehicle pollution:
"I am inaugurating a program to marshal both government and
private research with the goal of producing an unconventionally
powered, virtually pollution-free automobile within five years.
"I have ordered the start of an extensive Federal research and
development program in unconventional vehicles, to be conducted
under the general direction of the Council on Environmental Qual-
ity.
"As an incentive to private developers, I have ordered that the
Federal Government should undertake the purchase of privately
produced unconventional vehicles for testing and evaluation."
In accordance with the President's directives, APCO has
stepped up its support of research and development activities re-
lating to alternatives to the conventional internal combustion en-
gine and has initiated a program involving demonstration-testing
and fleet-testing of privately produced low-pollution vehicles.
In the research and development program, emphasis is being
placed on those engine systems which appear to have the greatest
potential for becoming viable alternatives to the conventional in-
ternal combustion engine.
One promising alternative is the gas turbine engine, which has
been the subject of a great deal of research and development over
the past several years; in fact, one automobile manufacturer has
built and tested a substantial number of experimental turbine-
powered passenger cars. A number of problems remain to be
solved, however, before the turbine engine can be considered prac-
tical for general use in passenger cars. The relatively high level of
nitrogen oxides emissions from turbine engines is one of the
major problems. Another one is the cost of manufacturing turbine
engines, which has been indicated to be relatively high. APCO has
initiated a study of the prospective manufacturing costs and ways
of reducing them.
A heat-electric hybrid engine is another candidate. A hybrid
engine is one which consists of more than one type of propulsion
system. In a heat-electric hybrid, a small heat engine (which can
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2584 LEGAL COMPILATION—AIR
be a turbine, Rankine cycle, or internal combustion engine) is
combined with a battery energy source. Such a combination may
offer advantages that cannot be derived from either propulsion
system operating separately.
The Rankine cycle engine is still another prospective alternative
to the internal combustion engine. A steam engine is one type of
Rankine engine. In a steam engine, water is heated and converted
to steam, which is used to drive pistons or turbines. But the
Rankine engine also can be designed to use fluids other than
water; one reason for using other fluids is to get around the
freezing problem.
With respect to both heat-electric hybrids and Rankine engines,
a great many technical problems remain to be solved. APCO cur-
rently is supporting a number of research and development proj-
ects relating to Rankine engines and is considering projects nec-
essary for further development of heat-electric hybrids. In addi-
tion, attention is being given to various other types of propulsion
systems that may be adaptable for general use in passenger cars,
including flywheel, stratified-charge, and diesel engines.
In keeping with the President's directives that this research and
development program be conducted under the general direction of
the Council on Environmental Quality (CEQ), the CEQ has
formed a technical advisory committee composed of several non-
governmental experts. This group has been working closely with
APCO in examining prospective low-pollution engines and in iden-
tifying needed research and development.
A parallel program to provide incentives for private-sector re-
search and development was formally launched in August 1970.
This program involves evaluation of vehicles purchased or leased
from private developers. Those types of vehicles which show
promise in preliminary testing would be obtained in quantities of
up to 500 for fleet-testing. The objective is to promote the develop-
ment of motor vehicles that are satisfactory not only from the
standpoint of air pollution control but also with respect to cost,
road performance and safety. Many private firms already have
expressed interest in participating in this program.
APCO is conducting and supporting other research and develop-
ment relating not only to motor vehicles but also to other mobile
sources of air pollution. This work is increasingly focused on
meeting needs associated with regulatory activities (e.g., defining
the nature and amounts of emissions from various types of mobile
sources, developing emission testing procedures, assessing the
state-of-the-art of emission control, and so on).
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GUIDELINES AND REPORTS 2585
K. To develop and implement procedures for the registration of
fuel additives, with initial emphasis on motor vehicle fuel
additives
Under the Clean Air Act, manufacturers of fuels and fuel addi-
tives may be required to register any additive used in a fuel sold
in interstate commerce. Registration is solely for the purpose of
gathering information; no regulatory activity is involved.
On June 13, 1970, "motor gasoline, excluding aviation gasoline"
was designated as the first fuel to be covered. On the same day,
regulations for registration of motor vehicle fuel additives were
published in the Federal Register.
Producers of the designated fuel had 90 days to notify APCO of
the names of additives used in the fuel, the purpose and range of
concentration of each such additive, and the additive manufactur-
er's name and address. They also were expected to provide summa-
ries of available information on the emission products resulting
from the use of the additive and on the toxicity of such emission
products.
Additive manufacturers then are required to furnish informa-
tion on the recommended purposes and concentrations of all addi-
tives identified by fuel producers, and on the chemical composition
and structure of the additives. They also are required to furnish
summaries of available information on emission products and
their toxicity.
On December 15, 1970, 226 additives, including lead additives,
were registered. Notifications of such registration were sent to the
35 companies which manufacture these additives and to the 98
fuel manufacturers which had reported use or anticipated use of
them. After January 9, 1971, no fuel manufacturer or processor
may use an additive in motor gasoline (with the exception of
aviation gasoline) introduced into interstate commerce unless the
additive is registered and the manufacturer has complied with
registration requirements.
L. To encourage the application of the best available control tech-
niques for dealing with air pollution from aircraft
Following a meeting in January 1970 with the Secretary of
Health, Education, and Welfare and the Secretary of Transporta-
tion, virtually all of the Nation's airlines agreed to initiate a
program to reduce smoke emissions from about 3,300 jet aircraft
engines. The program involves installation of new types of com-
bustors in JT8D engines. New combustors are to be installed dur-
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2586 LEGAL COMPILATION—AIR
ing routine overhauls of such engines; on the average, such en-
gines undergo routine overhaul after every 5,000 hours of opera-
tion. As of November 15, 1970, the new combustors had been
installed on nearly 10 percent of the engine?, and production of
additional new combustors was reported to be on schedule. The
program is to be completed by December 31, 1972.
In October 1970, after learning that jet aircraft ordinarily dis-
charge into the air the fuel that seeps from engines during stops,
APCO asked the airlines to take steps to curtail this practice.
APCO estimated that such fuel dumping may result in release of
about 110 tons of fuel per year in the vicinity of National Airport
in Washington, D.C., and that nationally, the total may be in
excess of 7,700 tons (two million gallons) annually. The airlines
indicated that they are interested in developing a long-range solu-
tion to this problem and that they would submit a proposal to
APCO by February 1,1971.
M. To encourage and participate in international efforts to deal
with air pollution
With the creation of the Committee on the Challenges of Mod-
ern Society (CCMS) in November 1969, the North Atlantic
Treaty Organization inaugurated a significant new international
effort to deal with problems of air pollution. A study of air pollu-
tion involving the United States, Turkey, and West Germany is
one of eight pilot studies that comprise the CCMS program. As the
U.S. participant in the air pollution study, APCO has been work-
ing with officials in Turkey and West Germany in a project to
demonstrate how existing knowledge can be used to formulate
long-range air pollution control programs for urban areas. The
urban areas selected as examples for the purpose of the study are
St. Louis, Ankara, and Frankfurt.
APCO's international activities also include participation in the
air pollution-related programs of the World Health Organization
(WHO), the Organization for Economic Cooperation and Develop-
ment, the Economic Commission of Europe, and the World Meteo-
rological Organization; support of research in the United King-
dom, Poland, Yugoslavia, and Israel; and bi-lateral cooperative
projects with Japan, Germany, and France. In 1970, APCO was
designated a WHO International Reference Center and assigned
the functions of advising WHO on air pollution matters, particu-
larly with regard to establishment of reference analytical methods
and the development of air quality guides.
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GUIDELINES AND REPORTS 2587
4.1c "DEVELOPMENT OF SYSTEMS TO ATTAIN ESTAB-
LISHED MOTOR VEHICLE AND ENGINE EMISSION
STANDARDS"
Report to Congress by the Administrator of the Environmental Protection
Agency, February 1972.
CHAPTER I: INTRODUCTION
A. Summary
The Clean Air Act as amended charges the Administrator of the
Environmental Protection Agency with major responsibilities for
the control of motor vehicle emissions. These duties include: estab-
lishing emission standards for pollutants which endanger public
health and welfare; administrating a number of related activities
concerned with vehicle testing, certification and enforcement; reg-
ulating the content of fuels; demonstrating the feasibility of low-
emission vehicles; monitoring the development of improved de-
vices to control emissions from internal combustion engines; and
directing research and development activities related to alterna-
tive power systems.
In addition Sections 202 (b) (1) (A) and 202 (b) (1) (B) require
that:
(1) 1975 automobiles achieve a 90% reduction in the emissions
of hydrocarbons (HC) and carbon monoxide (CO) which were
allowable in 1970, and
(2) 1976 automobiles achieve a 90% reduction in the emissions
of oxides of nitrogen (NOX) from the average levels measured on
1971 automobiles which were not subjected to any Federal or State
NOX emission standards.
Under Section 202 (b) (5) (D) the Administrator is permitted to
suspend the 1975 and 1976 standards for up to one year, only if he
determines that:
"(i) such suspension is essential to the public interest or the
public health and welfare of the United States,
"(ii) all good faith efforts have been made to meet the stand-
ards established by this subsection,
"(iii) the applicant has established that effective control tech-
nology, processes, operating methods or other alternatives are not
available or have not been available for a sufficient period of time
to achieve compliance prior to the effective date of such standards,
and
"(iv) the study and investigation of the National Academy of
Sciences conducted pursuant to subsection (c) and other informa-
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2588 LEGAL COMPILATION—AIR
tion available to him has not indicated that technology, processes
or other alternatives are available to meet such standards."
Since the establishment of the Environmental Protection
Agency on December 2, 1970, EPA has completed a number of
actions related to the control of emissions from motor vehicles. An
initial contract has been signed with the National Academy of
Sciences to identify the resources necessary to study the techno-
logical feasibility of attaining the 1975 and 1976 standards.
EPA has published an advance notice of proposed rulemaking
indicating its intention to control or prohibit the use of alkyl lead
in motor vehicle gasoline. Detailed studies of scientific, medical,
economic, and technological data concerning this matter are cur-
rently under review.
In February, the Administrator sent a letter to all domestic and
foreign auto manufacturers requesting information about re-
search and testing activities related to the development of emis-
sion control systems designed to meet the 1975 and 1976 stand-
ards. EPA also conducted two days of public hearings on this
subject during May of 1971. Twenty-one representatives of the
automotive and related industries, of the academic and scientific
communities, and of public interest organizations and groups pre-
sented statements and responded to questions.
EPA has published certification test results for 1971 model vehi-
cles and engines. National ambient air quality standards have
been promulgated which include motor vehicle related pollutants.
Regulations have been proposed defining the useful life of vehicles
and requiring the inclusion in owners' manuals of maintenance
instructions for emission control systems. Specific numerical
standards and test procedures have been established for 1975 and
1976 emissions of HC, CO and NCv
Demonstration programs relating to low-emission vehicles have
been initiated. Three contracts have been signed under the Federal
Clean Car Incentive Program whereby manufacturers provide
prototype vehicles for government testing and evaluation.
The Low-Emission Vehicle Certification Board prescribed by
Section 212 of the Act has been established. The Board held its
first meeting in June, 1971, and adopted procedural regulations
related to the preferential purchase of low-emission vehicles for
use in government fleets.
EPA is also directing a research and development program for
low-emission vehicular power systems other than the internal com-
bustion engine.
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GUIDELINES AND REPORTS 2589
Chapter 2 of this report includes a brief history of Federal and
State emission control standards and test procedures. It also con-
tains a more elaborate explanation of EPA's initial accomplish-
ments. Chapter 3 provides an overview of all of EPA's programs
and activities related to the control of motor vehicle emissions.
While the industry is giving prime attention to the development of
add-on devices to enable the internal combustion engine to meet
the emission standards prescribed in the law, EPA is also direct-
ing research and development programs concerning alternative
power systems.
Chapter 4 deals with the health and welfare effects of motor
vehicle related pollutants. While vehicular emissions are important
sources of pollution, especially in congested urban areas, they are
not the only sources of these contaminants. In discussing health
and welfare impacts it is important to note that it is ambient air
quality, the composition of a local air mass, rather than emission
levels from particular sources, which is the significant factor al-
though the two are clearly related.
It is difficult to generalize about the relative importance of var-
ious contributions of the same air contaminants to ambient air
quality because most air masses undergo lateral movements. Thus
relative impacts must be looked at in terms of specific localities
reflecting differences in geography, meteorological conditions,
traffic patterns and the size and locations of all sources of the
same pollutants.
A detailed discussion of the progress reported by industry is
contained in Chapter 5. This material describes a number of con-
trol devices under development and outlines some of the technical
problems facing the industry. This material also reiterates a num-
ber of concerns expressed by the manufacturers in their communi-
cations with EPA.
The final section of this report, Chapter 6, deals with the costs
associated with motor vehicle emission control. It is not yet possi-
ble to provide precise estimates of the cost per vehicle of attaining
the 1975 and 1976 standards established in the Act. The total cost
to the public will, however, include the initial cost of the control
system, its maintenance after warranty, and expected increases in
fuel consumption and reductions in vehicle performance.
Neither the final control system needed to achieve the 1975
standards noV the technology for attaining the 1976 standards,
have yet been identified. Thus, the cost figures contained in Chap-
ter 6 must be considered preliminary and include informal indus-
try estimates of initial costs ranging from $80 to $600 per car for
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2590 LEGAL COMPILATION—AIR
1975. However, it appears clear that the costs associated with
1975 and 1976 standards will be considerably greater than those
experienced in reaching Federal emission standards through 1974.
Information provided to EPA by auto manufacturers revealed a
significant increase in emission control systems research and de-
velopment activity since the passage of the 1970 amendments to
the Clean Air Act. During the first six months of accelerated
development, industry laboratories have reported the attainment
of reduced emission levels. While there are many problems to be
overcome to convert laboratory results into reduced emission lev-
els from mass-produced autos, the added industry effort should
improve prospects for significant technological improvements.
B. Conclusions
During the recent public hearings industry spokesmen ex-
pressed major reservations about the technological feasibility of
achieving the statutory emission standards within the time limits
prescribed by law. The manufacturers were unanimous in assert-
ing that the levels of reduction required for 1975/76 precluded the
substitution of alternative power systems, making it essential that
emission control be achieved through an improved internal com-
bustion engine. Industry representatives consistently stated that
reaching the 1976 NOX emission levels goes beyond the limits of
current knowledge and will require some major technological
breakthrough early enough to permit mass production of 1976
models. They also expressed concern about the high cost of attain-
ing the low levels of emissions required by the statute.
At these same hearings representatives of public interest orga-
nizations were skeptical of industry statements about their inabil-
ity to develop the necessary technology to reduce emissions to the
required levels. These witnesses pointed to previous instances of
resistance by the industrial community to deadlines which were
ultimately achieved. Suspicion was also voiced about the vigor of
government enforcement concerning interim standards and test
procedures. This climate of mistrust makes it important that, to
the degree possible, matters related to motor vehicle emission con-
trol be given full public exposure.
Motor vehicle emissions are important sources of HC, CO, and
NOX pollutants especially in congested urban areas. However, they
are not the only sources of these contaminants. The specific contri-
bution of vehicle emissions to the degradation of ambient air qual-
ity is a complex matter and varies from place to place. These
variations are attributable to differences in geography, meteoro-
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GUIDELINES AND REPORTS 2591
logical conditions, traffic patterns, and the size and location of
other sources of these pollutants. More information on these mat-
ters is expected with the completion of State implementation plans
required under the legislation. These plans are also expected to
include a variety of alternative abatement strategies. With addi-
tional information about the costs and effectiveness of emission
control from all types of sources, it should be possible to under-
take detailed cost-effectiveness analyses in order to insure that the
ambient air quality standards are achieved at the most reasonable
cost to the American people.
One of the unfortunate aspects of motor vehicle emission control
is that reducing levels of hydrocarbons and carbon monoxide,
which is done primarily through increasing the efficiency of com-
bustion, tends to make more difficult the control of oxides of nitro-
gen, whose formation is largely a function of the heat of combus-
tion. Thus, a major technological challenge faces the Nation's auto
industry in meeting these emission standards.
EPA is moderately optimistic that the 1975 standards can be
attained especially since it is expected that unleaded gasoline will
be generally available at that time. We are also hopeful that tech-
nological developments will enable the manufacturers to reach the
1976 standards. However, the costs associated with achieving
these standards may be high. Therefore, the Agency is not recom-
mending any legislative changes at this time, although they may
be needed in the future.
CHAPTER 2: BACKGROUND
A. History of State and Federal Standards
The control of motor vehicle emissions was initiated in the State
of California in 1959 with the adoption of standards to control
exhaust hydrocarbons and carbon monoxide. This was supple-
mented in 1960 with standards to control emissions resulting from
crankcase blowby. The early generations of California standards
were goals requiring the demonstration of feasible technology be-
fore the establishment of implementation deadlines. Such schedul-
ing was contingent upon the availability and certification of de-
vices, systems, or modifications which would enable motor vehicles
to meet the standards. In 1963, California adopted diesel smoke
standards; however, as with the previous standards, there was no
immediate implementation schedule. As a result of the certifica-
tion of appropriate devices and systems, California required a first
level of crankcase emission control effective with the 1963 models,
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2592 LEGAL COMPILATION—AIR
improved crankcase emission control for 1964, and control of ex-
haust hydrocarbons and carbon monoxide in 1966.
The 1965 Amendments to the Federal Clean Air Act gave the
Secretary of the Department of Health, Education and Welfare,
the authority to control emissions from motor vehicles. Accord-
ingly, on March 30, 1966, the initial Federal motor vehicle emis-
sion standards were adopted to become applicable with the 1968
models. The standards and procedures were similar to those which
had been employed by California and required some control of
exhaust hydrocarbons and carbon monoxide from light-duty vehi-
cles and one hundred percent control of crankcase emissions from
gasoline-fueled cars, buses, and trucks. The term light-duty vehicle
refers to self-propelled vehicles designed for street or highway
use, which weigh less than 6,000 pounds and carry no more than
twelve passengers. Thus, the vehicle population is divided into two
groups, light and heavy-duty, which generally correspond to cars
as opposed to buses and trucks.
On June 4, 1968, revised Federal standards were published
which required more stringent control of hydrocarbons and carbon
monoxide from light-duty vehicles, of evaporative emissions from
the fuel tanks and carburetors of light-duty vehicles, of exhaust
hydrocarbon and carbon monoxide emissions from gasoline-fueled
engines for heavy-duty vehicles, and of smoke emissions from
diesel engines for heavy-duty vehicles. The fuel evaporative emis-
sion standards became fully effective with model-year 1971. The
other standards applied to 1970 model year vehicles and engines.
Thus, with the introduction of 1970 models, the industry had re-
duced hydrocarbon emissions by almost three-quarters and carbon
monoxide emissions by about two-thirds.
On November 10, 1970, standards were published applicable to
1972 model light and heavy-duty vehicles and heavy-duty engines.
The significant modification in these standards pertained to the
method of evaluating the exhaust hydrocarbon and carbon monox-
ide emissions from light-duty vehicles. Improved methods of test
operation, exhaust sampling and gas analysis had been developed
so that emissions measurements would be more representative of
actual discharges from in-use vehicles.
B. Testing Procedures
Testing procedures are complicated and require some added ex-
planation. Numerical emission standards are meaningful only
when related to the specific test procedure employed. As with
many other aspects of auto pollution control, test and analytical
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GUIDELINES AND REPORTS 2593
procedures have undergone modifications and improvements over
the years. The initial testing in California and at the Federal level
used a 7-mode 7-cycle test procedure. During this type of testing, a
vehicle is run through seven driving conditions or modes such as
low and high speed acceleration. The resulting emission measure-
ments are representative of the rate of emission during these
particular driving conditions, but do not measure total emissions.
In 1970, the Federal Government adopted a Constant Volume
Sample or CVS procedure during which the vehicle is run through
a test cycle designed to simulate urban driving. The characteris-
tics of the standard test drive were based on an elaborate study of
Los Angeles traffic patterns in 1965. All emissions from ignition
key-on after a 12-hour storage period to the end of the test cycle
are collected and analyzed. The CVS procedures result in measure-
ments which are considered more representative of actual emis-
sions from vehicles as used in urban areas. However, the resulting
numerical standards are different from those revealed by earlier
test procedures.
EPA has recently announced a further refinement in test proce-
dures to include both a cold start (after a 12-hour storage) and a
hot start (after a 10-minute wait) and the computation of a
weighted average as a basis for 1975 and 1976 numerical stand-
ards. These changes, as well as certain minor modifications in
analytical techniques, are intended to make test results more rep-
resentative of emissions from in-use vehicles. The new test proce-
dures are also expected to be used in connection with the proposed
1973 emission standards.
C. Significant EPA Actions
(1) On January 30,1971, the Environmental Protection Agency
published an advance notice of proposed rule-making concerning
its intention to promulgate controls or prohibitions on the addition
of alkyl lead to gasoline fuels for motor vehicles at the earliest
possible date. In accordance with the requirements of Section 211
of the Act, EPA is considering relevant, scientific, medical, eco-
nomic, and technological data prior to final rule-making in this
area. Systems designed to control NOX emissions to meet stand-
ards applicable to 1973 model year cars may require that a low
lead gasoline be generally available in late 1972 and the probable
use of catalytic converters to achieve the 1975 HC-CO standards
makes it imperative that unleaded gasoline be generally available
by that time. These developments underscore the need for imple-
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2594 LEGAL COMPILATION—Am
menting the President's request for a tax on lead in gasoline to
insure that unleaded gasoline will be competitively priced.
(2) On February 26, 1971, all domestic and foreign auto
manufacturers were requested by the Administrator to furnish
EPA with the following information:
1. A description of the basic techniques being explored as a
means of meeting the emission standards required under Section
202(b)(l).
2. With respect to the techniques identified and described:
(a) An indication of the current state of development and
testing, including durability testing of each one.
(b) A summary of the emission data derived from any
such testing.
(c) An assessment of the prospects for perfecting each one
to a point at which it could be used on production-line motor
vehicles.
(d) A description of the major problems that remain to be
solved in order to perfect each type of unit.
(e) An identification of all other companies participating
in the development and testing.
(f) A summary of the resources in dollars and profession-
al-technical man years applied during calendar year 1970 and
expected to be applied during 1971 to the development and
testing of the various units.
(3) On April 7, 1971, a notice of proposed rule-making was
published concerning the requirement for the preparation of State
implementation plans necessary to achieve national ambient air
quality standards. Under Sections 109 and 110 of the Act, EPA is
required to publish national ambient air quality standards and
States are required to prepare specific implementation documents
detailing how they propose to attain the prescribed ambient stand-
ards. In this notice, attention was called to the potential need to
develop af termarket strategies to control motor vehicle emissions,
which might include vehicle inspection programs, mandatory
maintenance, and/or retrofit control systems for the existing auto
population. The technology for periodic inspection is being devel-
oped and will be evaluated in terms of benefits, costs, and effec-
tiveness.
(4) On April 10, 1971, the Federal certification test results for
1971 model year motor vehicles and engines were published.
(5) On April 30, 1971, national primary and secondary ambient
air quality standards were published as final rule-making, includ-
ing standards for hydrocarbons, carbon monoxide, and oxides of
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GUIDELINES AND REPORTS 2595
nitrogen. These pollutants are associated with motor vehicle emis-
sions.
(6) Also on April 30,1971, The State of California was granted
waiver of Federal preemption for motor vehicle emission stand-
ards more stringent than those currently in effect by Federal
regulation. These pertain to:
(a) Auto emission standards and test procedures for the
1972 model year.
(b) Auto assembly line standards and test procedures for
the 1972 model year.
(c) Prohibition of the sale of automobiles that require
gasoline of research octane greater than 91 effective with the
1973 model year.
(d) Gasoline powered truck emission standards and test
procedures for the 1973 model year and more stringent stand-
ards for the 1975 model year.
(e) Diesel powered truck emission standards and test proce-
dures for the 1973 model year and more stringent standards
for the 1975 model year.
The waiver was granted on the basis of testimony presented at
a hearing held in Los Angeles, California, on January 26 and 27,
1971, additional material provided prior to February 22, 1971, and
other related information available to the Environmental Protec-
tion Agency. Additional waiver requests were denied at that time
but are under review within EPA.
The legal basis for granting this waiver is contained in Section
209 of the statute which concerns Federal preemption of State and
local emission standards. However, the law also permits EPA to
issue waivers to California if, after public hearing, the Adminis-
trator finds that State standards more stringent than the Federal
requirements are necessary to meet compelling and extraordinary
local conditions.
(7) On May 6 and 7, 1971, hearings were held in Washington,
D. C. to supplement the industry responses to the Administrator's
letter of February 26, 1971. Twenty-one representatives of the
automotive and related industries, of the academic and scientific
communities, and of public interest groups and organizations pre-
sented statements and responded to questions related to meeting
the 1975-76 emission standards.
In his introductory comments, the Administrator stated:
"The law itself does not permit traditional conceptions of satis-
factory driving performance to stand in the way of whatever
changes in vehicle design and power system are needed to control
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2596 LEGAL COMPILATION—Am
emissions. The same is true with regard to vehicle cost. This
hearing is part of the continuing effort by the Environmental
Protection Agency to find out just what sacrifices might be needed
in cost, in fuel economy, in power, in acceleration and in other
historic yardsticks of vehicle performance to produce an automo-
bile that we can live with as a people.
"The low emission car of the future may be a more expensive
car. It may not equal today's car in road performance, but this is a
price that may be necessary if we are to have and preserve a
healthy environment for ourselves and our families."
"As a consequence, we cannot and will not accept anything less
than a wide open research and developmant effort to meet the
actual requirements. We will not, for example, find acceptable a
manufacturer's decision not to explore innovative designs or power
systems on the grounds that a vehicle so designed or so powered
would be more costly or would not meet traditional performance
criteria. We must develop and apply whatever technology is
needed to achieve the degree of emission control required by the
Act and we must be willing to accept any necessary sacrifices in
other areas of vehicle performance."
He further stated a second point concerning,
"The specific power conferred upon me by the Clean Air Act to
suspend the effective date of an emission standard for one year.
Exercise of this power is carefully circumscribed by law. I am
required to make a determination relating to good faith and two
separate determinations concerning the technological feasibility of
meeting the statutory standards.
"I have given serious considerations to the proper construction
of the statutory provision for suspension. It is my present judg-
ment that the required determinations relating to technological
feasibility do not permit me to suspend an emission standard in
favor of a single applicant or a group of applicants if technical
knowledge exists, in the industry or elsewhere, which would ena-
ble any member of the industry to mass produce a light-duty
vehicle in compliance with the Act.
"It is important that all of the implications of this construction
of the law be well understood at the earliest possible time. It
means that if any member of the industry could meet the Act's
deadlines for compliance, all applications for extension will be
denied.
"Any other construction of the suspension provision would be
incompatible with the clear intent of the law to require whatever
changes in design or power systems are needed to control emis-
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GUIDELINES AND REPORTS 2597
sions. Where some manufacturers meet the statutory deadlines by
making major changes which substantially increase the cost of the
vehicles or which require major sacrifices in vehicle performance,
I do not believe that Congress intended to subject such manufac-
turers to competition from cars produced by other manufacturers
who are required to meet a less stringent standard.
"As I read the law, the separate determination concerning good
faith becomes applicable where it is not technologically possible
for any member of the industry to comply with the Act's require-
ments. In that event, suspensions for one year would be granted
only to applicants who can establish that they made a good faith
effort to meet the statutory deadlines for compliance. Here, on the
separate issue of good faith, the specific problems which may face
a particular manufacturer appear to be pertinent.
(8) On May 11, 1971, The proposed definition of useful life for
vehicles and requirements for the inclusion of maintenance in-
structions for emission control systems in owner's manuals were
published to implement Sections 202 (d) and 207 of the Act.
(9) In May, 1971, three contracts were awarded to provide
prototype cars for government testing and evaluation under the
Federal Clean Car Incentive Program.
(10) On June 18, 1971, the Low-Emission Vehicle Certification
Board held its initial meeting and approved procedural regulations
concerning preferential purchasing of low-emission vehicles for
use in government fleets. These activities are prescribed in Section
212 of the Act.
(11) On June 29, 1971, the first Federal standards were issued
requiring control of oxides of nitrogen emissions and prescribing
measurement techniques for this pollutant applicable to 1973
model light-duty motor vehicles.
(12) On June 29, 1971, standards were promulgated to pre-
scribe the 1975 exhaust hydrocarbon and carbon monoxide emis-
sion requirements, and 1976 oxides of nitrogen emission require-
ments applicable to light-duty vehicles as required by Sections
202 (b) (1) (A) and 202 (b) (1) (B). In addition, modifications in
test and analytical procedures were included as described in Sec-
tion B of this Chapter.
In addition, EPA has entered into an initial contract with the
National Academy of Sciences to study the technological feasibil-
ity of meeting the 1975 and 1976 standards in accordance with the
provisions of Section 202c of the Act.
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2598 LEGAL COMPILATION—Am
CHAPTER 3: RELATED EPA PROGRAMS AND ACTIVITIES
A. Introduction
The Environmental Protection Agency has been assigned re-
sponsibility for a number of programs and activities designed to
abate pollution emanating from motor vehicles. Regulations estab-
lishing standards, testing procedures, and enforcement practices
have been developed and promulgated to guide future actions.
Staff and contract personnel from the National Academy of Sci-
ences are assessing the technological feasibility of attaining the
1975 and 1976 standards established in the legislation. EPA is
expanding its capability to monitor industry progress which is
primarily focused upon add-on devices to clean up the internal
combustion engine. Demonstration programs have been initiated
concerning the feasibility of low-emission vehicles. EPA is also
directing a research and development program for alternative
power systems.
B. Establishing Standards
The Clean Air Act as amended establishes specific emission re-
quirements for hydrocarbons, carbon monoxide, and oxides of ni-
trogen for 1975 and 1976. However, EPA was required to convert
these parameters into specific numerical standards related to 1970
and 1971 emission levels. This work has been completed, and the
standards for 1975 and 1976 have been published.
In addition, EPA also has responsibility under Section
202 (a) (1) of the Act for promulgating emission standards for
other exhaust pollutants if they are found to endanger public
health and welfare. Due consideration must be given to the availa-
bility of appropriate control technology and the cost of compli-
ance. These responsibilities carry EPA into analysis of exhaust
materials, research concerning health and welfare impacts of pol-
lutants, assessment of available control technology and studies of
the economic impact of alternative abatement strategies.
C. Testing and Enforcement
The enabling legislation assigns EPA responsibility for testing,
certification, and enforcement activities concerning emission con-
trols for new motor vehicles and engines. At present these pro-
grams generally follow the procedures outlined below: A quantifi-
able emission standard is promulgated to be met by a set deadline.
Manufacturers develop and test prototype vehicles, with some con-
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GUIDELINES AND REPORTS 2599
firmatory testing by EPA. If the prototype design is found to
comply with the standard, the group of vehicles represented by
that unit is certified for production and sale. In-use vehicles are
later tested to determine whether production vehicles continue to
meet the standards.
EPA's testing and enforcement procedures require the certifica-
tion of manufacturers' vehicle and engine product lines based on
the satisfactory testing of prototype designs. In formal application
for certification, the manufacturer is required to delineate perti-
nent mechanical characteristics of the vehicles or engines and
emission control systems, and the projected sales of each configu-
ration. This information provides the basis for EPA selection of
configurations to be tested for establishing eligibility for certifica-
tion. The actual testing program involves two groups of vehicles
or engines. One group is tested to determine emission levels after
engine break-in. The second group consists of vehicles or engines
which are operated for extended periods with limited mainte-
nance to simulate the rate of emissions degradation with normal
usage. The certificability of a group or engine family is established
if the emission value of each engine tested, adjusted by the appro-
priate deterioration factor, is in compliance with the standards.
Surveillance testing of vehicles in routine service has shown
that production vehicles in use do not consistently display the low
emission levels indicated in prototype certification testing. Proce-
dures for assembly line testing are under development but they
require solutions to serious problems. High volume testing dictates
the need for quick test procedures which can be consistently re-
lated to the certification test results. Such procedures should
ideally provide diagnostic information so that appropriate repairs
can be made at minimum expense and with minimum loss of time.
An effective quick test procedure could also be useful in expanding
the present surveillance programs to determine when manufactur-
ers should institute recall programs. An extensive program is
being conducted by EPA to identify appropriate equipment and
procedures.
To implement Section 207, manufacturers of new motor vehicles
and engines will be required to warrant to the ultimate purchaser
that the vehicle or engine is designed, built, and equipped to con-
form with applicable emission standards, and is free from defects
in materials and workmanship which might result in failure to
conform to appropriate regulations during its useful life. Surveil-
lance studies will be strengthened and regulations will be promul-
gated requiring manufacturers to recall vehicles which are found
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2600 LEGAL COMPILATION—AIR
to be out of conformity with standards during the warranty pe-
riod.
The testing of heavy-duty vehicles entails the application of
substantially different procedures than those associated with
light-duty vehicles. Heavy-duty engines, both gasoline-fueled and
diesel, have a broad range of uses in vehicles larger than 6000
pounds. Present procedures, therefore, involve engine testing as
opposed to vehicle testing. EPA is currently reevaluating the
heavy-duty testing procedures with the objective of assuring that
they reflect, as much as possible, the emissions from such vehicles
in actual use.
Another important feature of EPA's testing program concerns
the verification of new control devices developed by non-automo-
bile manufacturers. Section 206 provides for the testing of any
emission control system incorporated in a motor vehicle or motor
vehicle engine submitted to the Administrator by any person. If it
is determined that the vehicle or engine conforms to appropriate
standards, the Administrator shall issue a verification of compli-
ance with emission standards for the system. The manufacturers
and the National Academy of Sciences shall be informed of these
results which shall also be made available to the public. Hopefully
these provisions will accelerate the pace of development of new
emission control devices.
D. Monitoring Technological Developments
In order to carry out EPA responsibilities concerning the 1975
and 1976 emission standards for light-duty vehicles, we are ex-
panding our capability to monitor the development of appropriate
control technology both within and without the auto industry. As
described in Chapter 2 the Administrator has requested specific
information from the auto manufacturers and has held public
hearings on these subjects. The results of our initial contacts are
reflected in Chapter 5.
E. National Academy of Sciences Contract
Section 202(c)(l) of the Act directs that the Administrator
"enter into appropriate arrangements with the National Academy
of Sciences to conduct a comprehensive study and investigation of
the technological feasibility of meeting the emission standards
required to be prescribed by the Administrator" (for 1975 and
1976 light-duty motor vehicles). In addition, the Administrator is
directed to request the National Academy of Sciences to submit
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GUIDELINES AND REPORTS 2601
semi-annual reports on its progress to the Administrator and to
Congress beginning on July 1, 1971.
Shortly after the passage of the Act, EPA contacted the staff of
the Academy concerning this work. A preliminary contract was
awarded to the Academy to allow them to assemble the necessary
resources, and develop specific plans and budgets for carrying out
the work. The involvement of the National Academy of Sciences
will provide the Congress and the Administrator with an inde-
pendent assessment of technological feasibility of meeting the
1975 and 1976 standards.
F. Regulation of Fuel Content
The fuel additive which has received most attention related to
auto emissions is lead. It has been well documented that catalytic
converters, which are among the devices being developed to re-
move carbon monoxide, hydrocarbons, and nitrogen oxides from
vehicle exhaust, deteriorate rapidly when exposed to fuels contain-
ing lead compounds. Lead additives have also been shown by sev-
eral investigators to contribute to fouling of exhaust gas recircula-
tion systems used for nitrogen oxides control.
As directed in Chapter 4, the health effects of lead emissions are
now under serious review. Studies are also being sponsored by
EPA to evaluate the economic impact of curtailing or eliminating
the use of lead in gasoline. A comprehensive report concerning
this matter is expected later this year which will serve as a basis
for further discussion and eventual rulemaking.
G. Alternative Power System
In order to meet the 1975-76 standards, the automobile indus-
try is concentrating its efforts on modifications of the conventional
internal combustion engine. There is serious question, however,
about the ability of the conventional engine to meet long term
health and welfare needs of the nation as now perceived. Accord-
ingly, the Environmental Protection Agency has embarked on a
program of federally sponsored research and development of alter-
native engine systems which are inherently cleaner than the con-
ventional engine. This development activity is embodied in the
Advanced Automotive Power System Program (AAPSP).
Five types of power systems initially were part of the program
when it began in July of 1970. These include Rankine cycle, the
gas turbine, heat engine/electric hybrid, heat engine/flywheel hy-
brid, and all-electric. Two additional systems, the stratified charge
engine and the advanced design diesel engine, have been added to
52(5-705 O - 74 - 17
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2602 LEGAL COMPILATION—AIR
the program. Limited privately sponsored research has been un-
derway for some time on all of those systems.
Each candidate system was at a different stage of development
when the program began and, depending on technical develop-
ments, may enter the hardware phase at a different time. The first
18-month phase of the program is intended to be a period of
evaluation wherein complete systems are designed, critical compo-
nents bench tested, and decisions made on whether to proceed to
first generation system hardware.
In the Rankine Cycle Engine, there is an external combustor
and an enclosed working fluid which is heated, expanded to do
work, then condensed into a liquid, with the fluid being continu-
ously recycled. Three types of Rankine systems are presently in
the design and component test phase. Two systems use organic
working fluids, one with a reciprocating expander, the other with a
turbine expander. The third Rankine system is the steam engine.
The technical problems confronting the successful development of
the Rankine cycle system are understood and are being studied.
Major problems appear in the inefficiency of components, and com-
plexity of the control systems. Parallel research and development
of components for all three types of engines is currently under-
way. The first prototype engines are expected to be available for
testing in 1972.
More work has been conducted by the domestic auto manufac-
turers on the gas turbine engine than on any other candidate.
EPA sponsored research efforts are being focused on solving spe-
cific problems which have made the gas turbine unattractive for
use in cars. These problems include the need for reducing the
nitrogen oxide emissions in the exhaust, developing manufactur-
ing techniques for mass producing turbines inexpensively, and
increasing system reliability. As solutions to these problems be-
come available, it is anticipated that industry will apply them to
their own turbine designs.
The hybrid engine candidates include the heat engine/electric
and the heat engine/flywheel. The heat engine/electric hybrid
consists of a small size low-powered engine (80-100 hp) and an
array of batteries. The hybrid system is designed to extract power
from the engine alone, or from both engine and battery at the
same time. The basic system is compatible with either a conven-
tional internal combustion engine or a small gas turbine. In either
configuration the system operates best by running the heat engine
at a constant speed with additional power for acceleration sup-
plied from the battery system.
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GUIDELINES AND REPORTS 2603
This hybrid concept offers potential advantages. The engine
speed range is relatively small with an attendant ease of control of
exhaust emissions under such conditions. Good road performance
for a standard size American automobile can be obtained with a
relatively small and inexpensive heat engine. The basic problems
of this system are its relative complexity, higher cost, and the
greater space required for the two sources. Development of im-
proved lead-acid batteries to accommodate the rapid charge-dis-
charge characteristics needed for this hybrid mode of operation is
now underway.
The heat engine/flywheel system would function in a manner
similar to the heat engine/electric with the battery replaced by a
mechanical storage device, a spinning flywheel. Research has pro-
gressed from the analysis of practical flywheel materials to the
design and fabrication of specific flywheels for cars.
The all-electric car engine development has been underway for
more than a year at Argonne National Laboratories. It is antici-
pated that "proof-of-principle" for a high temperature lithium-
sulfur system will be demonstrated within the next 8 months.
Once proof-of-principle has been achieved, the study will move
into a development phase, first with a goal of a 2 kilowatt (kw)
battery, then a 5 kw battery and then a 20 kw battery system.
Development of the all-electric system will not be completed early
enough to meet 1975 standards because the project is still in the
fundamental research stage. Moreover, an environmental cost/
benefit analysis is yet to be undertaken which would indicate
whether there would be a net gain from the environmental view-
point given the added burdens such a system might place on elec-
tric power generation requirements. However, such a low emission
vehicle might be highly desirable for conjested urban areas.
The stratified charge engine is a gasoline-fueled internal com-
bustion engine with many hardware characteristics of the conven-
tional engine. Differences appear mainly in the combustion cham-
ber design and the use of fuel injection. Much of the initial work
on this engine was sponsored by the U.S. Army Tank-Automotive
Command. The measured exhaust emission levels for an experi-
mental stratified charge engine installed in a small military vehi-
cle and employing a catalytic muffler are below the standards for
hydrocarbons and carbon monoxide set for 1975. Further work
must be conducted to reduce the nitrogen oxide emissions to attain
the 1976 standards. Several generations of development have been
funded by the Army with some assistance by HEW. EPA's work
on this engine has emphasized the reduction of nitrogen oxide
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2604 LEGAL COMPILATION—Am
emissions. Testing of this system in a fleet of vehicles is now being
contemplated. However, there are many problems to overcome to
convert experimental engines into mass produced vehicles with
similar emission characteristics.
The diesel engine is not commonly used in American made auto-
mobiles because it is heavier and more expensive than the conven-
tional automobile engine. Emphasis is being directed toward the
development of a low compression diesel with high-swirl injection
and a modified prechamber design. Exhaust emission levels for
hydrocarbons and carbon monoxide lower than the 1975 standards
have been shown for this type of engine without the need for a
catalytic converter. The measured nitrogen oxide levels of the first
generation engine are relatively low although above the 1976
standards. Studies are concentrating on nitrogen oxides reduction
and on performance, durability and drivability testing.
H. Federal Clean Car Incentive Program
The Federal Clean Car Incentive Program (FCCIP) is designed
to foster private development of new types of low emission vehi-
cles related to the 1975 and 1976 emission standards. In the first
stage of the program the developer leases to the government a
candidate prototype vehicle which is subjected to rigorous evalua-
tion. After successfully passing stringent emissions and perform-
ance testing on the leased prototype car, 10 additional vehicles
may be purchased for more comprehensive testing. The govern-
ment may later buy up to 100 vehicles for further evaluation. If
the low emission levels are maintained and road performance is
found to be satisfactory, the car is then eligible for certification as
a low-pollution vehicle under the program described in the next
section of this report.
This program began in January, 1971, with approximately 20
initial proposals from industry. Ten different vehicle systems have
been accepted into the program. In May of this year three con-
tracts were approved to provide prototype cars for testing. The
Incentive Program is expected to provide valuable information
about the feasibility of reaching the 1975-76 emission standards.
I. Low-Emission Vehicles Purchase Program
Section 212 of the Act provides for the creation of a Low-Emis-
sion Vehicle Certification Board (LEVCB). EPA initially certifies
vehicles which discharge significantly less pollutants than required
by current Federal regulations. The LEVCB identifies the class of
vehicle for which the selected cars are considered suitable substi-
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GUIDELINES AND REPORTS
2605
tutes taking into consideration factors such as performance and
cost of maintenance. Certified vehicles may be purchased for use
in government fleets at premiums of up to 100% over the prices
normally paid by the government for equivalent vehicles. The
non-statutory members of the Board have been named by the
President and its first meeting was held on June 18, 1971. At that
time the board adopted initial procedural regulations.
CHAPTER 4: HEALTH AND WELFARE EFFECTS
A. Emission Levels and Ambient Air Quality
Motor vehicle emissions are important sources of air pollutants
especially in our congested urban areas. The following figures
indicate EPA's estimate of the relative contribution of vehicle
emissions of HC, CO, and NOX.
PERCENT OF NATIONAL EMISSIONS IN 1969
Motor vehicles .
Source
Other forms of transportation . ,
Fuel combustion in stationary sources .
Industrial processes
Solid waste disposal ..
Miscellaneous.
Total .
CO
. .. 64.7
. . 9.0
1.2
7.9
. . .. 5.2
12.0
100.0
HC
45.7
7.2
2.4
14.7
5.3
24.7
100.0
NOx
36.6
10.5
42.0
.8
1.7
8.4
100.0
In addition, emissions of HC and NOX from motor vehicles and
other sources undergo complex chemical reactions in the atmos-
phere and contribute to the formation of photochemical oxidants
associated with urban smog.
While the proportions indicated above hold true nationally, the
relative contributions of vehicle emissions to ambient air quality
varies among communities. These variations result from differ-
ences in geography, meteorological conditions, traffic patterns, and
the size and location of other sources of the same pollutants. Thus
in discussing health and welfare impacts the key factors are am-
bient air concentrations resulting from emissions from all sources,
rather than emissions from any particular source.
In accordance with Section 109 of the Clean Air Act, EPA has
published national primary and secondary ambient air quality
standards for a variety of air pollutants. Primary standards define
levels of air quality which the Administrator judges to be neces-
sary, with an adequate margin of safety, to protect public health.
Secondary standards reflect concentrations judged necessary to
-------
2606 LEGAL COMPILATION—AIR
protect public welfare from any known or anticipated adverse
effects. Of interest to a discussion of motor vehicle emissions are
the ambient air quality standards for photochemical oxidants, hy-
drocarbons, nitrogen dioxide, and carbon monoxide which are
shown in Table 1.
TABLE 1.—NATIONAL PRIMARY AND SECONDARY AMBIENT AIR QUALITY STANDARDS—
FOR MOTOR VEHICLE RELATED POLLUTANTS
[Concentrations not to be exceeded more than once per year]
Pollutant
Photochemical oxidants
Hydrocarbons (methane free)
Nitrogen dioxide
Carbon monoxide
Concentration limit
t
Micrograms per
cubic meter
160
160
(')
10,000
40,000
Parts per
million
0.8
.24
W
9.0
35.0
\veraging time
(hours)
1
3
8
1
For the above pollutants, adverse welfare effects have not been observed to occur at levels below those judged neces-
sary to protect the public health. Accordingly, the secondary standard has been set at the same level. Pursuant to the Act,
primary ambhnt air quality standards must generally be achieved by June 1,1975.
'Standards for short-term exposure rates for nitrogen dioxide have not been promulgated. EPA has established safe
annual exposure rates of lOO^g/m3 or 0.05 p.p.m.
Related to the establishment of national ambient air quality
standards are the provisions of Section 110 of the legislation,
which require that States prepare implementation plans indicating
how they will attain the national ambient standards within their
boundaries by 1975. These documents, which are to be submitted
to EPA by January 30, 1972, will indicate the relative contribu-
tion of motor vehicle emissions to ambient air quality for com-
munities in many parts of the Nation. They are also expected to
include a variety of abatement strategies and contribute greatly to
our understanding of the significance of motor vehicle emissions
control.
B. Photochemical Oxidants, Hydrocarbons, Carbon Monoxide, and
Oxides of Nitrogen
Detailed discussions of the effects of photochemical oxidants,
hydrocarbons, nitrogen oxides, and carbon monoxide may be found
in their respective Air Quality Criteria Documents. The following
is a summary of the more important effects of these pollutants in
ambient air masses coming from all sources and not just motor
vehicles.
Photochemical oxidants result from a complex series of atmos-
pheric reactions initiated by sunlight. When reactive organic sub-
stances and nitrogen oxides accumulate in the atmosphere and are
-------
GUIDELINES AND REPORTS 2607
exposed to the ultraviolet components of sunlight, the formation
of new compounds, including ozone and peroxyacyl nitrates, takes
place.
Photochemical oxidants may adversely affect vegetation, human
health, animals, and certain man-made materials. They can cause
injury to many important species of plants such as beans, tobacco,
petunias, peanuts, and pine trees. Injury to sensitive species has
occurred after exposure of 4 hours to 0.05 ppm of photochemical
oxidants. In southern California hundreds of acres of ponderosa
pine forest have been affected by photochemical oxidants.
The principal human effect associated with photochemical oxi-
dants include impairment of athletic performance and an increase
in attacks among asthmatics, the latter effect having been ob-
served when oxidant levels reached 0.15 ppm for one hour. Al-
though eye irritation has been associated with oxidant levels of
0.10 ppm in Southern California, it has not been shown conclu-
sively that any particular species of photochemical oxidants is
responsible.
Rubber, fabrics and dyes are particularly sensitive to photo-
chemical oxidants as evidenced by rubber cracking, reduced
strength in cellulose fabrics, and the fading of certain dyes after
exposure.
Hydrocarbons represent the major class of reactive organic
matter in the atmosphere that is responsible for photochemical
smog. Through their reaction intermediates and photochemical ox-
idation products, they are directly responsible for the eye irrita-
tion associated with photochemical smog and much of the charac-
teristic vegetation damage. Hydrocarbon oxidation products are
also believed to be important contributors to the atmospheric aero-
sols responsible for the reduced visibility associated with photo-
chemical smog. In addition, ethylene, a specific hydrocarbon, is
directly responsible for certain forms of plant injury—orchids are
especially sensitive.
The presence of nitrogen oxides in the atmosphere is essential
to the photo-oxidation of hydrocarbons and the development of
photochemical oxidants. Sufficiently reduced levels of either NOX
or HC alone in the air tend to alleviate the formation of photo-
chemical oxidants, but the exact relationships are extremely com-
plex.
Nitrogen dioxide, a type of oxide of nitrogen, is also a specific
air pollutant associated with increased incidences of acute bron-
chitis in infants and school children and acute respiratory disease
in the entire family group. Nitrogen dioxide has also been asso-
-------
2608 LEGAL COMPILATION—Am
ciated with damage to vegetation and corrosion of electronic com-
ponents. Increases in the incidence of respiratory disease were
associated with nitrogen dioxide levels ranging from 0.06 ppm to
0.08 ppm over a 6-month period.
Carbon monoxide is well known for its poisonous effects at high
concentrations. It is absorbed through the lungs and reacts pri-
marily with the hemoglobin of red blood cells. As an air pollutant,
carbon monoxide represents a potential danger to human health
and safety. It decreases the oxygen carrying capacity of the blood
and reduces the availability of oxygen transported to vital tissues
by the blood. Carbon monoxide concentrations of 10 ppm produce
blood carboxyhemoglobin levels of 2% in non-smokers. This car-
boxyhemoglobin level has been associated with impaired time in-
terval discrimination.
Carbon monoxide concentrations of 30 ppm for 8 to 12 houra
have been associated with impaired psychomotor performance and
reduced visual acuity in normal subjects and with increased phys-
iological stress to patients with heart disease.
C. Other Pollutants
1. Lead.—Evaluations of available evidence are presently un-
derway to determine the specific health effects of lead particu-
late matter emanating from auto emissions. These evaluations
should be completed in the near future. It is already known that
lead is a biologically nonessential metallic element which is
clearly toxic under conditions of prolonged and excessive expo-
sure (e.g., ingestion of paint containing lead). Furthermore,
lead accumulates in persons exposed to high atmospheric con-
centrations. Lead is absorbed primarily through the gastrointes-
tinal and respiratory tracts.
As noted in Chapter 3, in addition to health effects, lead in
gasoline has been found to greatly reduce the effectiveness of
catalysts and therefore the availability of unleaded gasoline is
needed if these devices are to be used on production vehicles.
Since about 96 percent of the lead particulate matter found in
the atmosphere results from gasoline-fueled engines, the reduc-
tion or elimination of lead from gasoline should significantly
reduce the incidence of lead particulate matter in the future.
2. Other Substances.—The significance of the relationship be-
tween auto emissions of the materials listed below and the
health or welfare dangers has not been established. Medical and
biological investigations of the following items are underway:
-------
GUIDELINES AND REPORTS 2609
(a) Particulate materials—both organic and inorganic.
(b) Aldehydes and other carbonyl compounds.
(c) Nitrogen compounds other than nitrogen oxides, such
as ammonia.
(d) Miscellaneous organic materials, such as polynuclear
aromatic hydrocarbons.
CHAPTER 5: INDUSTRY PROGRESS
A. Basic Technology
The gasoline-fueled internal combustion engine is the best un-
derstood and most reliable propulsion system currently available.
The auto industry maintains that it is also the only prospect for
mass production in 1975-76. Unfortunately, it is also an inher-
ently high-emission propulsion system. These high emissions are
caused, to a major degree, by the fuel itself and relate to the
difficulty in supplying thermodynamically ideal air and fuel
charges to the cylinders and bringing about complete combustion
over the full range of vehicle operating requirements.
The problem is maximized at low engine start-up temperatures
and when the humidity and temperature of the air supply vary
widely. Additionally, variability in fuel density and viscosity are
factors which inhibit precise metering of the fuel. Gasoline in the
liquid state will not burn and thus the higher boiling point hydro-
carbons do not vaporize and burn when the engine is cold. Cold
engine starts require extra amounts of gasoline to produce enough
vaporized fuel to provide a combustible mixture at the spark plug.
The excess non-vaporized portions then pass through the engine
unburned. The problem is reduced as the volatility of the gasoline
is increased and the boiling range reduced. The importance of the
fuel volatility factor is dramatized by the emission performance of
the internal combustion engines when operated on natural gas or
liquified petroleum gas (LPG). Typically, such changes in fuels
result in lower emissions of HC and CO.
While efforts aimed at leaner air-fuel mixtures tend to reduce
hydrocarbons and carbon monoxide, they tend to increase emis-
sions of nitrogen oxides. This occurs because improved combustion
results in higher temperatures which in turn promote the union of
nitrogen and oxygen. Efforts to control nitrogen oxides to high
levels within the engine tend to negate the improvement gained in
HC and CO control. Thus NOX control will probably require other
measures to reduce peak combustion chamber temperatures and/
or the addition of an external control system.
-------
2610 LEGAL COMPILATION—AIR
B. Typical Control Concepts and Devices
Engine modifications designed to reduce emissions during the
combustion process represent the principal approach used for
compliance with motor vehicle exhaust emission standards now in
effect. Such modifications, refined to promote even more efficient
combustion, will continue to be a fundamental part of the systems
approach leading to compliance with future standards. However,
add-on devices such as thermal reactors and catalytic converters
will most likely be required to complete the system.
Modification in gasoline composition, such as the elimination of
lead and, possibly, changes in volatility characteristics, may also
be required in order to facilitate the use of certain control tech-
niques and optimize the potential of others. A review of the emis-
sion control techniques, components and concepts, known to be
under development by industry for gasoline fueled motor vehicles
follows:
1. Modification of Combustion Chamber Design.—A major
source of hydrocarbon emissions from automobiles is unreacted
fuel-air mixtures expelled through the tailpipe. This occurs pri-
marily because the very thin layer of gaseous mixture which
makes contact with the relatively cool combustion chamber sur-
faces does not burn. By modifying the combustion chamber de-
sign to reduce the surface-to-volume ratio and by minimizing
crevices, more nearly complete combustion of the full cylinder
charge is promoted.
2. Modification of Induction System.—Carbon monoxide in the
exhaust results from insufficient oxygen in the fuel-air mixture
and consequent incomplete combustion. Incomplete combustion
is also an important source of hydrocarbons. Leaner air-fuel
mixtures to assure more complete combustion can be accom-
plished by converting more of the liquid gasoline into the vapor
form and by providing for improved fuel-air mixing and distri-
bution among the cylinders. Air-fuel induction systems can be
adapted to provide heated intake air for more uniform carbu-
retor inlet temperatures thus allowing leaner fuel-air mixtures
to be used. Air temperature can be maintained by a thermo-
statically controlled mixing valve in the air cleaner. Intake man-
ifold heating tends to provide more uniform fuel distribution.
Intake ports can also be re-designed to give improved induction
turbulence and mixing. More uniform distribution of the fuel-
air mixture to the cylinders can likewise be accomplished
through design changes. Unfortunately, modification of indue-
-------
GUIDELINES AND REPORTS 2611
tion systems which improve combustion and reduce HC and CO
emissions also raise temperatures and worsen NOX control.
3. Carburetor Modifications.—The carburetor is a key element
in effective emission control by virtue of its role in metering the
fuel in proper proportion to inlet air. Precise fuel metering, in
accordance with changing engine requirements, makes possible
operation with lean air-fuel mixtures. Carburetors can be de-
signed with stronger fuel metering signals and closer calibra-
tion tolerances to assure better fuel mixing preparation. Fuel
injection systems can provide more accurate metering and de-
liver fuel under pressure for maximum atomization. Electronic
fuel metering could also allow for altitude compensation and
more precise mixture control.
4. Choke Modifications.—Gasoline in liquid form does not
burn. Consequently, when an engine is started cold, an extra
amount of gasoline is needed in order to obtain enough vapor-
ized hydrocarbons to mix with air and provide a combustible
mixture at the sparkplug. The function of the carburetor choke
is to supply the added fuel. However, the unvaporized hydrocar-
bons pass through the engine unburned. By tailoring choke ac-
tion to car requirements, enrichment during starting and
warm-up can be made compatible with satisfactory drivability
over a wide temperature range. Modification of the fuel to
achieve greater vaporization could obviate the need for the
choke or drastically reduce its periods of actuation.
5. Ignition System Modifications.—Ignition systems optimized
to initiate combustion in accordance with engine operation and
emission control requirements, support improvements in fuel
metering and mixture control. Spark retardation can be em-
ployed to reduce emissions of hydrocarbons and nitrogen oxides.
Electronic ignition systems have been developed which will im-
prove control of spark timing at all engine operating conditions,
greatly facilitate adjustments of spark timing on vehicles in
consumer use, and improve system reliability. Retarding igni-
tion timing results in more fuel being burned during the ex-
haust phase of the combustion cycle. Accordingly, some loss in
power and fuel economy results and demands on the engine
cooling system are increased.
6. Lower Compression Ratio.—The use of high compression
ratios improves engine efficiency and results in more power
output for a given amount of fuel. Combustion temperatures are
high, however, causing high emission of nitrogen oxides. The
octane requirements of high compression ratio engines are high,
-------
2612 LEGAL COMPILATION—AIR
necessitating the use of lead or expensive fuel modification. The
presence of lead in gasoline severely limits the effectiveness of
catalytic converters and reduces the life of other emission con-
trol system components. For these reasons, compression ratios
of new cars are being reduced to curtail NOX emissions and
promote the removal of lead additives.
7. Air Injection.—Exhaust port air injection is one of the
oldest concepts used for controlling motor vehicle exhaust emis-
sions. Increased oxidation of hydrocarbons and carbon monox-
ide is achieved by pumping air into the exhaust ports and mani-
fold. Major revisions to the cylinder head and exhaust manifold
are required. Since NOZ control during the combustion process
has tended to increase HC and CO emissions, interest in exhaust
port air injection is reviving. Air injection pumps are also help-
ful for effective operation of catalytic converters and thermal
reactors.
8. Exhaust Gas Recirculation.—Recirculation of a portion of
the exhaust gas into the air-fuel mixture causes a reduction in
the peak combustion temperature and a reduction in the forma-
tion of oxides of nitrogen. Dilution of the fuel charge with inert
gases has the secondary effect of reducing engine octane require-
ments, but with some loss in power. Extreme dilution causes
misfiring and deterioration in drivability. This can be compen-
sated for by increased throttle openings and providing richer
carburetion mixtures, but with some loss of fuel economy.
Improved systems provide for proportioning the recirculated
exhaust gas to the air flow demanded by the engine. Sensitive
induction system components can be corroded and plugged by
acid condensate and dirt in the recycled exhaust. The removal
of lead and associated scavengers from gasoline is expected
to moderate these problems.
9. Thermal Reactors.—A thermal reactor functions as a com-
bustion chamber outside the engine and normally appears in the
form of an oversized exhaust manifold. Thermal reactors receive
the hot exhaust gas from the engine, retaining as much heat
as possible with insulation. Additional heat is generated by
oxidation of carbon monoxide in the exhaust gases. High car-
bon monoxide concentrations are obtained by operating the
engine with rich fuel mixtures. Such reactors are known as
"rich thermal reactors." Supplementary air is required and it
is necessary to create appropriate mixing and provide adequate
residence time for the combustibles present to react with the
-------
GUIDELINES AND REPORTS 2613
oxygen. When designed for rich fuel-air mixtures to promote
NOX control, there is a substantial fuel penalty. In a "lean
thermal reactor" system the carburetion is set lean so that the
exhaust is inherently oxidizing and a secondary air pump is
not required. Emissions are generally higher than from "rich"
reactors.
Because of the extremely high temperatures that can be
reached, the selection of suitable materials to give satisfactory
durability is a major challenge. Special protective systems will
be needed to prevent overheating which could damage the en-
gine or create a general safety hazard for the vehicle occupants.
10. Afterburner.—The afterburner is designed to oxidize un-
burned hydrocarbons and carbon monoxide in the exhaust gas.
It includes a precombustion chamber in which secondary air
and fuel are spark ignited to provide thermal energy for the
associated reaction chamber. Over-temperature problems pre-
sent a serious handicap to its use.
11. Catalytic Converters.—Catalytic converters are devices
designed to receive exhaust gases and foster chemical changes
associated with reducing levels of undesired pollutants. The
catalyst bed generally consists of an inert support material on
which the active material is deposited in a thin layer. Alumina
is the most common support whereas platinum, or platinum
group metals, and transition metal oxides are the most common
active materials. Catalysis may be used for oxidizing the hydro-
carbons and carbon monoxide for reducing nitric oxide. The
basic construction of reducing catalysts is similar to that for
oxidizing catalysts. Reasonable effectiveness can be obtained for
both reactions with identical catalysts under ideal conditions.
The catalytic converter is a relatively low-temperature device
and need not be located in the engine compartment with atten-
dant space problems. Underbody modifications may be required,
however, for heat insulation and adequate ground clearance. It
has a high heat capacity, requiring a relatively long time to
reach activation temperature, but by the same token, it remains
warm longer. A catalyst and thermal reactor combination rep-
resents an attractive system for controlling vehicle emissions.
The thermal reactor increases the exhaust gas and catalyst tem-
peratures and provides improved control during cold-start and
warm-up. Deterioration tends to occur as a result of cyclic
exposure to a high temperature environment. As with thermal
reactors, fail-safe over-temperature controls are required to
-------
2614 LEGAL COMPILATION—AIR
prevent permanent damage resulting from unit or engine mal-
function.
Oxidizing and reducing catalysts may be used in combination
but some mixture enrichment is needed to provide the necessary
reducing atmosphere in the reducing stage, and supplemental
air may be required for the oxidation stage. Warm-up problems
in the second stage are accentuated in "dual catalytic convert-
ers." Good drivability and minimal economy loss is possible
with this concept. However, reducing catalysts with good endur-
ance are not yet available.
C. Industry Concerns
Various industry representatives have expressed a number of
concerns about the prospect of meeting the 1975 and 1976 stand-
ards. While no one speaks for "the industry," there is enough
commonality in content to identify a number of major concerns
shared by many of the manufacturers. It has been asserted that
the proposed standards cannot be attained with available technol-
ogy, would be far too expensive compared to their effectiveness on
air quality and include deadlines that provide the industry with
insufficient lead time. A number of manufacturers have also ex-
pressed concern over increases in costs and reductions in fuel
economy and drivability after modification to meet the 1975 and
1976 standards.
Various manufacturers have pointed out that the law requires
them to solve two very different technical problems almost simul-
taneously. Hydrocarbon and carbon monoxide controls needed for
the 1975 standards dictate more complete combustion in an oxida-
tion atmosphere while controlling oxides of nitrogen necessitates
lower combustion temperatures and/or a reduction atmosphere to
convert these emissions to nitrogen and oxygen gases.
A number of officials of both domestic and foreign producers
indicated that achieving the 1976 NOX standards takes them be-
yond existing knowledge and will require some technological
breakthrough.
D. Exchange of Technical Information
Several manufacturers have complained about present limita-
tions on exchange of technical information concerning vehicle
emission control. These problems relate to the civil antitrust ac-
tion brought by the Department of Justice in early 1969. The
Government's complaint alleged that the Automobile Manufactur-
ers Association and the four major United States manufacturers
of motor vehicles, conspired to eliminate competition among them-
-------
GUIDELINES AND REPORTS 2615
selves in the development and installation of motor vehicle air
pollution control equipment. The Government charged specifically
that the defendants had agreed to restrict public knowledge of
research and development efforts related to control of motor vehi-
cle emissions, that the defendants had delayed installation of con-
trol equipment, and that the defendants had deliberately misin-
formed California regulatory officials about the technical feasibil-
ity of reducing motor vehicle emissions. On September 11, 1969,
the defendants, without admitting the truth of these allegations,
entered into a consent decree which, among other things, prohibits
each defendant from agreeing with any other defendant, or with
any manufacturer of motor vehicles, to exchange unpublished
technical information for developing, improving or lowering the
cost of motor vehicle air pollution control equipment.
The consent decree expressly permits the defendants to continue
to exchange "basic research," as distinguished from "applied re-
search," and defines "basic research" to include "theories of con-
trol of motor vehicle emissions . . ., "as well as information perti-
nent to gaining a fuller knowledge or understanding of the pres-
ence, nature, amount, causes, sources, (or) effects ... of motor
vehicle emissions in the atmosphere." The decree also permits the
defendants to exchange information that relates primarily to the
"testing or measurement" of control equipment and information
that results from testing or measuring "advanced stage" produc-
tion prototypes. In addition, the decree expressly permits the de-
fendants to exchange information that is made public through
disclosure to news media or at meetings where persons other than
employees of motor vehicle manufacturers are permitted to be
present.
The decree contains other provisions which specifically allow the
defendants to purchase from each other or from other motor vehi-
cle manufacturers "specific commercial products," "specific exist-
ing patent rights," and "specific existing. . ." information or "en-
gineering services" related to vehicle emission control. Finally, the
decree does not prohibit any defendent from entering into or per-
forming an agreement to which the Department of Justice con-
sents in writing.
A number of manufacturers of motor vehicles, including most
foreign manufacturers who sell motor vehicles in the United
States, contend that progress in emission control technology is
best achieved through unrestricted information sharing. The
smallest of the major United States manufacturers claims that
exchange of technical information is essential to permit it to de-
-------
2616 LEGAL COMPILATION—AIR
sign engine systems that are compatible with components that it
must continue to purchase from other manufacturers. In general,
the smaller manufacturers contend that their resources are inade-
quate to support an independent research and development pro-
gram which encompasses more than a few areas of technological
promise. They contend that only the large vehicle manufacturers
are able to seek answers simultaneously to all of the interdepend-
ent engineering and scientific challenges that are encountered in
attempting to mass produce vehicles that perform adequately and
meet statutory emission standards.
While industry-wide research programs have been effectively
deterred by restrictions imposed on the major United States man-
ufacturers through the consent decree, the Department of Justice
has approved certain limited arrangements involving specific re-
search projects in which participation from related industries is
regarded as particularly important or involving vehicle manufac-
turers who must purchase essential engine components from other
manufacturers. Pursuant to the decree, the Department has con-
sented to annual renewals of an interindustry research program
which includes the Ford Motor Company, certain foreign vehicle
manufacturers, and a group of oil companies.
The "Inter-Industry Emission Control Project" is specifically
limited to five or six defined research topics, and it is understood
that the vehicle manufacturers participating in the project under-
take substantial research and development activity independent of
the project. Foreign participants are: Fiat, S.P.A., Mitsubishi
Heavy Industries, Ltd., Nissan Motor Company, and Toyo Kogyo
Company, Ltd. In addition, Volkswagenwerk A.G. and Toyoto
Motor Company, Ltd., have more recently purchased rights of
access to the project's technical work. However, these two addi-
tional foreign manufacturers are not full participants in that they
do not themselves provide the other project members with techni-
cal information. The Justice Department has also permitted
American Motors to purchase certain emission control engineering
services from General Motors.
In general, the Environmental Protection Agency agrees with
the Department of Justice that technological progress in automo-
bile emission control is best assured through primary reliance on
competition and independence in research and development efforts
conducted by manufacturers. At the same time, it must be recog-
nized that the emission reductions required by law present a tech-
nological challenge that may severely strain the resources of
smaller manufacturers and may raise special problems in the case
526-705 O - 74 - 18
-------
GUIDELINES AND REPORTS 2617
of manufacturers who must continue to purchase major engine
components from other manufacturers.
It is also possible that a vehicle emission control system or
device could be independently discovered which, if not generally
known to members of the industry in time to make necessary
modifications in production facilities, could radically affect exist-
ing competitive relationships in the industry and could signifi-
cantly reduce the number of independent manufacturers. The pos-
sibility that severe competitive dislocation could result from inde-
pendent research and development activity is a matter of major
concern. The compulsory licensing provisions contained in Section
308 of the Act may not obviate this problem because it applies
only to patented devices. The Environmental Protection Agency
will closely monitor research and development activities conducted
by each member of the industry. In addition, the Agency will urge
the Department of Justice to continue to approve limited arrange-
ments between particular manufacturers that may be needed to
meet special problems.
CHAPTER 6: COSTS
A. Cost of Attaining the 1975 and 1976 Standards
Precise estimates of the cost of attaining the 90 % reductions in
HC, CO, and NOX required by the Clean Air Act amendments of
1970 cannot be made at this time. The total cost to the public will,
however, include the initial cost of the control system, its mainte-
nance after warranty, and expected increases in fuel consumption
and reductions in vehicle performance.
Preliminary estimates of the cost of the 1975 HC and CO con-
trol systems have been made by the manufacturers. However, no
final decision on the control system to be used has yet been made.
Since the technology for achieving the desired levels of NOX con-
trol for 1976 is not now available, estimates of the related costs
are even more speculative. However, it appears that costs asso-
ciated with 1975 and 1976 standards will be considerably greater
than those experienced in achieving Federal emission standards
through 1974.
A variety of control systems are under development for meeting
the 1975 HC and CO standards. Figure 1 indicates the estimated
cost per car of achieving control standards through 1975. Costs
through 1974 are derived from estimates published in EPA's Cost
of Clean Air report of March 1971. Estimates of the cost of 1975
vehicles were provided informally by manufacturers and range
-------
2618
LEGAL COMPILATION—Am
INITIAL COST PER CAR
OF EMISSION
CONTROL SYSTEMS
DOES NOT INCLUDE THE COST OF
MAINTENANCE AFTER WARRANTY AND
_ POSSIBLE REDUCTIONS IN FUEL
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S*f
- x/
<^7
_, &) * .-
Q ' .'"* .-••'*
— ^'Nl^^iMATE
I 1 j |LO\N t ! |
69/70 71/72 73/74 75 7
MODEL YEAR
% REDUCTIONS OF POLLUTANTS REQUIRED
BY FEDERAL STANDARDS COMPARED
TO UNCONTROLLED VEHICLES
70/71 72/74 75 76
73
62
0
80
60
25
98
97
25
98
97
90
FIGURE l
-------
GUIDELINES AND REPORTS 2619
from 80 to 600 dollars per car. Thus far, EPA has not been able to
develop an independent estimate for 1975 costs. As indicated
above, precise cost estimates cannot be made for 1976 standards.
Also included on Figure 1 is a table showing the percent reduc-
tions in emissions for the various model years compared to those
emanating from uncontrolled vehicles. As explained in Chapter 1,
the legislation requires that 1975 vehicles include a 90% reduction
in HC and CO emissions compared to the levels permissible in
1970, and that 1976 vehicles include a 90% reduction of NOX from
the levels observed in 1971 uncontrolled autos. Since the 1970
baseline vehicles included some emission controls of HC and CO,
the 1975 standards for these emissions require very high levels
of control when measured against uncontrolled vehicles. It should
also be noted that the cost per car indicated in Figure 1 covers
only the initial production costs and does not reflect any costs for
maintenance after warranty or increases in fuel consumption or
reductions or vehicle performance.
Figure 2 was prepared by the Department of Commerce on the
basis of informal information obtained from automobile industry
sources. This graph depicts the estimated increases in production
costs per car in the 1976 model year of controlling HC, CO, and
NOX at various levels of emission reduction—assuming that all
three pollutants would be controlled at the same level. Since all
three pollutants will not be reduced by the same amount from the
baseline of uncontrolled vehicles, this graph is merely illustrative
of the principle that costs of control are expected to rise steeply as
emission reductions move beyond some point. The thrust of this
illustration is that the last 5-10 % is likely to be much more costly
to remove than the first 5-10%, but these figures are not known
with certainty.
B. Cost-Effectiveness of Motor Vehicle Emission Control
Under Section 312 (a) of the Act, the Administrator of EPA is
required to report to Congress on January 10 of each year con-
cerning the economic impact of achieving air quality standards.
Among other things, that report is intended to provide a basis for
evaluating the program and costs for achieving air quality stand-
ards. Accordingly, future reports submitted under Section 312 (a)
will address some of the key economic issues involved. In the
public interest, ambient air quality standards should be achieved
at the least cost possible. Since knowledge of effects of air pollu-
tion and of technology for controlling emissions is constantly im-
proving, it will be necessary to periodically review the effective-
ness and costs associated with alternative approaches of meeting
-------
2620
LEGAL COMPILATION—AIR
ESTIMATED COST PRICE PER CAR
TO CONTROL AUTO EMISSIONS
COST (price) PER CAR
$600
500 -
400 -
300 -
200 -
100 -
10 20 30 40 50 60 70 80 90 100
FIGURE 2.—Percent auto emission control, June 1971.
-------
GUIDELINES AND REPORTS
2621
OXIDES OF NITROGEN EMISSIONS FROM
MOTOR VEHICLES IN THE UNITED STATES
on
<§. 5
g a
8 *
i £
LU o
10.0
8.0
6.0
S § 4-°
2.0
1965-1990
1965 1970 1975 1980 1985 1990
MODEL YEAR
FIGURE 3.—Projections based on achieving all Federal emission standards.
-------
2622
LEGAL COMPILATION—AIR
HYDROCARBON EMISSIONS FROM
MOTOR VEHICLES IN THE UNITED STATES
2
c/>
CO
20.0
^—N
<
LU
> 16.0
12.0
O
4.0
1965-1990
1965 1970 1975 1980 1985 1990
MODEL YEAR
FIGURE 4.—Projections based on achieving all Federal emission standards.
-------
GUIDELINES AND REPORTS
2623
tr
V) uj
Z >-
*
< z
fe 2
O j
CARBON MONOXIDE EMISSIONS FROM
MOTOR VEHICLES IN THE UNITED STATES
100
80
60
40
20
1965-1990
1965 1970 1975 1980 1985 1990
MODEL YEAR
FIGURE 5.—Projections based on achieving all Federal emission standards.
-------
2624 LEGAL COMPILATION—AIR
ambient air quality standards and thus protecting the Nation's
health and welfare.
As indicated in Chapter 4, the control of auto emissions is an
important element in achieving the ambient air standards for HC,
CO, NOX, and photochemical oxidants. However, the relationships
between automobile emissions control and the achievement of na-
tional ambient air quality standards is extremely complex. For
example:
(a) Motor vehicles are not the only important sources of HC,
CO, and NOX. Other sources are identified in the table on page
4-1.
(b) The significance of auto emissions upon ambient air quality
varies from place to place, and therefore so does the effectiveness
of auto emission controls compared to controls over other sources.
(c) The cose of HC, CO, and NOX control for motor vehicles are
interrelated since some types of HC and CO control make it more
difficult to reduce emissions of NOX.
(d) Meeting the 1975/76 standards will have a cumulative im-
pact over time on air quality as new controlled vehicles replace
older models in the automobile fleet. This can be seen on Figures 3,
4, and 5, which depict EPA estimates of future national levels of
NOX, HC and CO emissions from gasoline-fueled motor vehicles
assuming all future Federal standards are achieved. The graphs
do not reflect the possible impact of modifying used vehicles to
attain emission reductions.
Considerations such as these are particularly important in at-
tempting to find the least cost means of achieving ambient air
quality standards, since the impact of achieving various reduc-
tions in automobile emissions will influence the costs of reducing
pollutants from other sources. Other sources of particular pollu-
tants (e.g., NOX from power plants) may be so important in some
areas that the reduction of automobile emissions will contribute
relatively little to meeting ambient standards in that area.
C. The Relationships between Costs and Effectiveness in Reducing
Air F Dilution
As suggested earlier in this chapter, many of the relationships
between costs and effectiveness are not yet well understood. All of
these factors require further study to ensure that desirable levels
of air quality are achieved at the most reasonable level of costs to
the American people. Knowledge today is simply not adequate to
identify specific numerical values for costs and benefits.
However, even without the specific data, some conclusions can
be drawn. Beyond some point, costs will increase more rapidly as
-------
GUIDELINES AND REPORTS 2625
successively greater reductions in emissions are achieved. How-
ever, in some situations, the last increment of impurity in the air
will be less important to remove than the earlier increments. Thus
it will be important to consider both the cost and value of incre-
mental improvements in air quality.
A great deal of the knowledge required to assess the cost-effec-
tiveness of various alternative pollution control strategies is ex-
pected from the review of State implementation plans which must
be prepared during the coming months. These implementation
plans will provide considerable information on the sources and
amounts of emissions. This knowledge will increase further as
monitoring and surveillance programs are improved and ex-
panded. In addition, EPA's research programs are designed to
improve knowledge of the health and other effects of various pol-
lutants. This information, together with economic analyses that
will be carried out or supported by EPA, should provide an im-
proved basis for future program decisions.
D. Industry Sponsored Research and Development
In response to the Administrator's letter of February 26, 1971,
the industry supplied EPA with information concerning their ex-
penditures for developing and testing emission control systems.
These responses indicated industry-wide costs of nearly $250 mil-
lion in 1970 with a one-third increase projected for 1971. This
information also revealed that about six thousand professional and
technical personnel were engaged in emission control research and
development programs for the manufacturers in 1970, with a simi-
lar one-third expansion projected for 1971. Thus, there has been a
significant increase in industry resources devoted to emission con-
trol programs since the passage of the 1970 amendments to the
Act.
The information supplied by the industry appears to lack total
comparability due to the variations in definitions and allocations
of cost figures. In addition, much of this information furnished
was indicated as being confidential by the manufacturers who
alleged that it related to "trade secrets." Section 208 of the Act
allows the Administrator to keep information confidential if he
finds that it does in fact relate to "trade secrets." EPA does not
agree that all of the information so indicated relates to "trade
secrets." Work is underway to develop appropriate protocols to
permit the collection of data on the magnitude of the industry's
emission control efforts on a fairly consistent basis. This informa-
tion should be available for public distribution at some time in the
future.
-------
2626 LEGAL COMPILATION—Am
4.1d "PROGRESS IN PREVENTION AND CONTROL OF
AIR POLLUTION"
Report to Congress by the Administrator of the Environmental Protection
Agency, February 1972.
PREFACE
The Clean Air Act, as amended, authorizes a national program
of air pollution research and control activities. This program is
conducted by the Environmental Protection Agency.
This report describes progress the Environmental Protection
Agency has made in 1971 toward the prevention and control of air
pollution.
It is submitted annually in accordance with Section 313 of the
Clean Air Act, which reads as follows:
"Section 313. Not later than six months after the effective date
of this section and not later than January 10 of each calendar year
beginning after such date, the Administrator shall report to the
Congress on measures taken toward implementing the purpose
and intent of this Act including but not limited to (1) the prog-
ress and problems associated with control of automotive exhaust
emissions and the research efforts related thereto; (2) the devel-
opment of air quality criteria and recommended emission control
requirements; (3) the status of enforcement actions taken pur-
suant to this Act; (4) the status of State ambient air standards
setting, including such plans for implementation and enforcement
as have been developed; (5) the extent of development and expan-
sion of air pollution monitoring systems; (6) progress and prob-
lems related to development of new and improved control tech-
niques; (7) the development of quantitative and qualitative in-
strumentation to monitor emissions and air quality; (8) standards
set or under consideration pursuant to Title II of this Act; (9) the
status of State, interstate, and local pollution control programs
established pursuant to and assisted by this Act; and (10) the
reports and recommendations made by the President's Air Quality
Advisory Board."
SUMMARY
The Clean Air Act, as amended, authorizes the Environmental
Protection Agency (EPA) to carry on a national program of air
pollution research and control activities. Among the principal ac-
complishments of this program during the calendar year 1971, the
following were especially significant:
-------
GUIDELINES AND REPORTS 2627
A prototype automobile engine that meets EPA's 1976 emis-
sion standards in initial tests has been developed.
Proposed emission standards have been published for three
hazardous air pollutants.
New source performance standards have been promulgated
for five types of industrial sources of air pollution.
EPA invoked emergency powers under the Clean Air Act to
restrain industry in Birmingham, Alabama, to abate air pollu-
tion in that city. This was the first time EPA has taken en-
forcement action under the emergency powers of the Act.
National ambient air quality standards have been published
for six common classes of pollutants.
Guidelines to assist States in developing plans to achieve the
air quality standards have been published.
Several demonstrations of techniques for controlling sulfur
oxides emissions are underway.
Regulations by which 1975 and 1976 model cars will be
judged for their compliance with the Clean Air Act have been
promulgated.
Portions of 21 regional air pollution control plans for sulfur
oxides and particulate matter have been approved.
EPA started operation this year of the first Federal laboratory
specifically designed for motor vehicle pollution control activities.
The laboratory, in Ann Arbor, Michigan, is expected to play a
vital role in the Federal Government's efforts to insure a non-pol-
luting automobile by 1975 and in making the tests that are neces-
sary before engines used in automobiles, trucks, and buses can be
certified as meeting Federal air pollution control emission stand-
ards.
The EPA has published final regulations under which it will be
determined whether a motor vehicle qualifies as a "low emission
vehicle" for possible purchase by the Federal Government at a
premium price. Under the Clean Air Act, the Government must
purchase certified low emission vehicles if their cost does not ex-
ceed 150 percent of the cost of the vehicles for which they are to
substitute. The new regulations, which initially apply to 1973 and
1974 model year vehicles, establish the emission limitations which
must be met, require that the vehicle may not emit any dangerous
pollutant not emitted by the vehicles it would replace, and estab-
lish the emission test method as that which will become effective
for the 1975 model year.
Beginning in May of this year, EPA conducted public hearings
at which domestic and foreign automobile manufacturers were
-------
2628 LEGAL COMPILATION—AIR
requested to describe their efforts to develop systems to reduce
automobile emissions. The results of these hearings are described
in EPA's report to Congress of July 9,1971 on the development of
systems to reduce automobile emissions and are intended to pro-
vide information to assist in determining the feasibility of produc-
ing low emission vehicles by 1975.
2. The Development of Air Quality Criteria and Recommended
Emission Control Requirements (for Stationary Sources)
Proposed emission standards have been published for three haz-
ardous air pollutants. The hazardous pollutants—asbestos, beryl-
lium, and mercury—are the first to be identified as such under the
1970 Clean Air Amendments. The proposed standards would apply
to various types of facilities producing, manufacturing, or using
these substances or products containing them. Both existing and
new plants would be covered.
Hearings on the proposed standards are scheduled for January
and February, 1972. The standard for each pollutant will be made
final by June, 1972, unless it is determined on the basis of the
information presented at the hearings that the pollutant is clearly
not a hazardous air pollutant.
Performance standards have been promulgated for steam gener-
ators, sulfuric and nitric acid plants, cement plants, and municipal
incinerators. The standards are based on capabilities of the best
adequately demonstrated emission reduction systems, taking into
account the costs. The standards apply primarily to new plants,
but also to existing plants which are modified in such a way as to
increase or alter the nature of their emissions. In developing these
standards, EPA conducted tests of existing sources, consulted in-
dustry experts, studied published reports, and considered available
information on industrial practices in the United States and
abroad.
3. The Status of Enforcement Actions Taken Pursuant to this Act
EPA, on November 18, 1971, invoked the emergency powers
provided under Section 303 of the Clean Air Act to require indus-
try in Birmingham, Alabama to abate air pollution in that city.
This was the first time that EPA has taken enforcement action
under emergency powers of the Act. The Agency obtained re-
straining orders in U.S. District Court in Birmingham to curtail
the emission of air pollutants by 23 industries. The move was
taken after it was determined that levels of particulate matter
presented an imminent and substantial endangerment to the
health of persons in the area. The situation resulted from a combi-
-------
GUIDELINES AND REPORTS 2629
nation of the normally heavy volume of pollution from industrial
sources, and stagnant weather conditions that allowed the pollu-
tion to build up over a period of several days. Appropriate State
and local authorities had diligently attempted to decrease the par-
ticulate levels in the atmosphere. However, many sources contin-
ued to discharge particulate matter in significant quantities, and it
was necessary, finally, for EPA to use the emergency powers
granted under the Act.
Under the Clean Air Act, all trucks sold in the United States
must have a valid certificate attesting that the engines meet appli-
cable air pollution control standards. Automobiles are subject to a
similar requirement. In January 1971, EPA revoked the condi-
tional certification for two heavy duty trucks manufactured by the
Ford Motor Company which did not meet the applicable hydrocar-
bon emission standards. This revocation was the first such action
since exhaust testing was required of trucks in 1970. Pending
certification of the engines, Ford was required to stop sales of the
engines and modify any still in its hands before they could be sold.
Within one month of the revocation of certification, Ford com-
pleted appropriate modification of the engines enabling them to
meet the applicable standards and qualify for certification.
The EPA requested the Department of Justice to sue an auto-
mobile manufacturer for delivering on consignment some 1972
model cars and light duty trucks to dealers before required emis-
sion tests were completed. The tests are required to obtain certifi-
cation that new motor vehicles are in conformity with applicable
Federal emission standards. While the manufacturer took steps to
minimize the danger that uncertified vehicles would be driven or
sold, the company's shipment of automobiles and trucks to dealers
before certification makes enforcement of Federal standards much
more difficult inasmuch as the shipment was made prior to any
judgment as to probable compliance. The Department of Justice's
action resulted in the filing of a consent decree by which Ford was
permanently enjoined from shipping prior to certification, and a
payment of a civil penalty of $10,000.00.
The Clean Air Act provides that any person may commence a
civil action against the EPA Administrator when there is alleged
a failure to perform any non-discretionary act or duty prescribed
in the Act. At least 60 days advance notice must be given to the
Administrator at the EPA headquarters in Washington before
such suits are filed. In 1971, the EPA published rules for giving
notice of civil suits against alleged violators of standards and
abatement orders under the Act. The guidelines provide for the
-------
2630 LEGAL COMPILATION—Am
service of notice of lawsuits to individual states, alleged violators,
the Administrator, and appropriate EPA regional administrators.
The guidelines say that such notices must identify the complainant
and describe with reasonable specificity the act or failure to act, or
in the case of alleged violators, the violation, the location and the
dates of such violations.
A Federal interstate air pollution abatement conference con-
cerning pollution in the Mt. Storm and Keyser, West Virginia, and
Gorman and Luke, Maryland, area was held in May of this year.
The Conference was called under the Clean Air Act, as amended,
which calls for EPA to take such action at the request of any
State whose Governor alleges that residents of his State are ad-
versely affected by pollution originating in another State. In this
case, Maryland's Governor requested a conference because of ef-
fects on evergreen tree farms in Maryland of pollution alleged to
originate from a power plant in Mt. Storm, West Virginia. Also,
the Governor of West Virginia requested that the conference con-
sider other possible sources of air pollution in the area, specifically
a pulp and paper plant at Luke, Maryland.
Recommendations for the control of interstate pollution in the
area involved were issued by EPA in October 1971 as a conse-
quence of the May conference. The recommendations were effec-
tive immediately, and call for reduction of emissions of sulfur
oxides and particulate matter from the power and paper plants,
reduction of emissions of odorous sulfur compounds from the pulp
and paper plant, and provision for abating emissions of particu-
late matter from several small sources in the area. As prescribed
by the Clean Air Act, EPA must allow a period of at least six
months for action to be taken on these recommendations.
4. The Status of National Ambient Air Standards Setting, Includ-
ing Such Plans for Implementation and Enforcement as Have
Been Developed
The Clean Air Act requires EPA to set national ambient air
quality standards. In 1971 EPA promulgated final national air
quality standards for six common classes of pollutants: sulfur
oxides, particulate matter, carbon monoxide, photochemical oxi-
dants, nitrogen oxides, and hydrocarbons. As required under the
law, two types of standards have been set: primary standards to
protect the public health, and secondary standards to protect
against adverse effects on property, animals, vegetation, materials,
visibility, and personal comfort and well being.
-------
GUIDELINES AND REPORTS 2631
Under the Clean Air Act, The States must, by the end of Janu-
ary, 1972, submit plans to achieve the national air quality stand-
ards. During-1971, EPA promulgated guidelines to be followed by
the States in developing these plans. The guidelines require States
to provide for attainment and maintenance of the national stand-
ards through the development of air pollution control strategies
which could include the development of source emission limitations
or other measures, such as land-use and transportation control
measures.
State implementation plans also must include emergency action
plans designed to prevent significant harm to the health of persons
during high air pollution episodes. EPA has defined, for five of the
most common air contaminants, the levels at which significant
harm to the health of persons can be expected to occur. The five
pollutants are sulfur dioxide, particulate matter, carbon monoxide,
photochemical oxidants, and nitrogen dioxide. State plans must
provide for action needed to assure that the significant-harm levels
never are reached.
In addition, EPA has listed seven specific kinds of legislative
authority that will be needed by State air pollution control agen-
cies to meet the requirements of the Clean Air Act. The State air
pollution control officials must have authority to:
(1) Adopt emission standards and limitations and any other
measures necessary for attainment and maintenance of national
standards.
(2) Enforce applicable laws, regulations, and standards, and
seek injunctive relief.
(3) Abate pollutant emissions on an emergency basis to prevent
substantial endangerment to the health of persons, i.e., authority
comparable to that available to the Administrator under Section
303 of the Act.
(4) Prevent construction, modification, or operation of any sta-
tionary source at any location where emissions from such source
will prevent the attainment or maintenance of a national stand-
ard.
(5) Obtain information necessary to determine whether air pol-
lution sources are in compliance with applicable laws, regulations,
and standards, including authority to require recordkeeping and
to make inspections and conduct tests of air pollution sources.
(6) Require owners or operators of stationary sources to in-
stall, maintain, and use emission monitoring devices and to make
periodic reports to the State on the nature and amounts of emis-
sions from such stationary sources; also authority for the State to
-------
2632 LEGAL COMPILATION—AIR
make such data available to the public as reported and as corre-
lated with any applicable emission standards or limitations.
(7) Where a plan sets forth a control strategy that provides for
application of (1) inspection and testing of motor vehicles and/or
other transportation control measures other than those referred to
in (4), such plan shall set forth the State's timetable for obtaining
such legal authority as may be necessary to carry out such meas-
ures.
During 1971 EPA approved portions of 21 regional air pollution
control plans for sulfur oxides and particulate matter. The plans
were prepared by State governments prior to the Clean Air Act
Amendments of 1970. However, the approved portions include reg-
ulations for attainment and maintenance of national primary
(health-related) air quality standards for particulate matter of
sulfur oxides or both. In some instances the plans also provide for
the achievement of the national secondary standards for these
pollutants. None of the State plans submitted for approval meets
all the requirements of the 1970 Clean Air Amendments.
It has been recognized that a number of States do not have the
resources to devise adequate implementation plans by the required
deadline. EPA accordingly contracted with ten consulting firms,
one serving each of the ten EPA regions, to assist States in pre-
paring plans on an on-call basis. These companies were capable of
completing all phases of implementation plans, from emission
source inventory to recommending abatement schedules. Many
States took advantage of this source to assist them in meeting the
requirements of the 1970 Amendments.
5. The Extent of Development and Expansion of Air Pollution
Monitoring Systems
Weather stations at ten U.S. cities have been designated "re-
gional air pollution monitoring stations" in a network that eventu-
ally will keep tabs on worldwide air quality.
The National Weather Service, a component of the Commerce
Department's National Oceanic and Atmospheric Administration,
and the Air Pollution Control Office of the Environmental Protec-
tion Agency will cooperate in the measurement and analysis of
atmospheric turbidity (particles in the air) and precipitation
chemistry (atmospheric impurities in rain or snow). NOAA's En-
vironmental Data Service will store the information and dissemi-
nate it in this country and abroad.
To determine current levels of air pollution so that meaningful
control strategies can be developed that will result in the national
-------
GUIDELINES AND REPORTS 2633
ambient air quality standards being met, it is necessary to have a
broad base of data on air quality. Gathering and evaluating these
data are tasks that require a joint Federal-State-local effort. To
this end, EPA operates its own air monitoring network, and also
provides extensive support to State and local monitoring activities.
State and local governments have the primary responsibility for
maintaining surveillance of air quality in their areas of jurisdic-
tion. Establishment and operation of air monitoring networks are
among the purposes for which program grant funds provided by
EPA can be used by State and local agencies.
On August 14, 1971, EPA promulgated requirements to be fol-
lowed by the States in the preparation, adoption, and submittal of
implementation plans. One section of these requirements specifies
the minimum requirements that must be met by State air quality
surveillance systems as part of their implementation plans. Such
systems must be completed and in operation not later than two
years after EPA approves the plan. EPA has worked with the
State and local agencies to evaluate their present systems and to
develop plans and schedules for modifying and augmenting them
where necessary. Once implementation plans have been submitted
and adopted, States during 1972 are expected to be able to acceler-
ate expansion of their monitoring activities.
6. Progress and Problems Related to Development of New and
Improved Control Techniques
During 1971, the research and development program for sta-
tionary source air pollution control moved forward on a broad
front, toward the goal of developing and demonstrating technol-
ogy in support of the EPA objective of meeting, establishing, or
enhancing pollution standards in an economic and timely manner.
A major part of this effort was devoted to continuing work on
the large scale demonstrations of sulfur oxides stack gas cleaning
processes. The test program on dry limestone injection has been in
operation since mid-1970, on a 140 megawatt boiler at the Shaw-
nee power plant of TVA, and will be completed early in 1972. The
wet limestone scrubbing project, also at Shawnee, is near ing com-
pletion of the construction phase, and the two year test operations
phase will begin in March, 1972; various combinations of three
different scrubber configurations along with three different reac-
tant injection modes will be evaluated. Three other demonstrations
are presently under construction and are expected to begin opera-
tion in mid 1972. These consist of a wet scrubbing system using
-------
2634 LEGAL COMPILATION—Am
coral marl, a magnesium oxide scrubbing process, and a catalytic
oxidation process.
Work in advance processes has continued in the development of
fluidized bed combustion of coal in limestone as a means of provid-
ing low-pollution, low-cost power. A 630 kilowatt high pressure
integrated plant has been designed with construction to begin
shortly; contract tests have been run in England on a 0.6 mega-
watt unit at similar conditions. Another system, the CAFB resid-
ual oil gasifier/desulfurizer, was operated with sulfur removal
close to 100 percent. Progress is also being made in the planning
and laboratory testing of several other advanced systems. These
systems, which are at an earlier stage of development than the
previously mentioned ones, include a process to provide low-Btu,
pollution free gas from bituminous coal, and a molten iron sub-
merged coal gasification process.
Progress in the area of pollutant control by fuel processing has
also been made. The program on physical desulfurization and de-
ashing of coal has reached the point where overall potential has
been reasonably well established. Major follow-on will be to finish
the washability testing already over 50 percent complete and un-
dertake pilot and demonstration activities on a promising new
approach uncovered in the work sponsored at the USBM for desul-
furization and cleaning of fine coal. A program has been initiated
to interface with other Federally sponsored fuel conversion proj-
ects to undertake pollutant control evaluation and optimization. A
new technique for chemical desulfurization of coal was established
and work initiated on the problem of hazardous pollutants con-
tained in fossil fuel.
In the industrial process area, progress has been made in sev-
eral areas. In the iron and steel industry, the primary problem of
controlling pollution from slot-type coke ovens is nearer solution
because of the AISI-EPA Smokeless Coke Charging system dem-
onstration, which is scheduled to go into operation in the Spring
of 1972. Available demonstration approaches for controlling coke
pushing emissions have been identified, evaluated, and selected.
Other industrial process demonstrations are in the contract nego-
tiation or development stage, including control of sinter plants,
Kraft pulping operations, iron foundries, and secondary aluminum
furnaces.
An R&D program to develop combustion modification techniques
and technology to control nitrogen oxides emissions was planned
and initiated. Although the program is only in its infancy, prelim-
inary results from field testing of utility boilers and in-house stud-
-------
GUIDELINES AND REPORTS 2635
ies show that combustion modification is a generally applicable
method to significantly reduce NOX emissions. Major emphasis is
on coal combustion, but the program is designed to develop tech-
nology applicable to all fuels and boiler classifications.
A small but increasingly active portion of the R&D program
was initiated in 1971; this activity is concerned with air pollution
aspects of urban and transportation planning. Recent legislation
in several areas has stressed the importance of environmental
considerations in the planning process, and a concerted effort is
being mounted to provide the necessary tools. Particularly impor-
tant at this point in time is the providing of guidelines to the
States for the development of their air quality implementation
plans, with regard to such items as traffic operations and highway
design and location.
7. The Development of Quantitative and Qualitative Instrumenta-
tion to Monitor Emissions and Air Quality
EPA's instrument development program has grown considera-
bly. The availability of the resulting instruments enhances the
ability of States and local agencies to maintain their surveillance
of air quality, with demonstrated assurance that the data gener-
ated will be representative of the concentrations of the pollutants
measured.
An EPA-developed instrument for measuring ozone, an impor-
tant constituent of photochemical smog, has come into general use.
Because of its ability to operate for long periods without any need
for maintenance or recalibration, this instrument has grown rap-
idly in popularity, until it is now made and sold by a half-dozen
domestic manufacturers and at least one overseas.
A second instrument that has emerged from EPA's laboratories
measures nitric oxide (an important smog-forming gas found in
automobile and other exhaust) by electronically sensing the faint
light generated in its reaction with ozone. Five manufacturers
now offer nitric oxide analyzers sufficiently sensitive to respond
reliably even to low levels of this important pollutant.
EPA's instrument development group has further modified its
nitric oxide analyzer by adding a catalytic converter that changes
nitrogen dioxide into nitric oxide, thus making possible the meas-
urement of "NOX", jargon for the sum of the concentrations of
the two gases. Parallel measurements of NO and NOX, subtracting
the one from the other, provide the analyst with the ability to
measure nitrogen dioxide, which is generally thought to be more
important from the health aspect.
-------
2636 LEGAL COMPILATION—AIR
Following the enactment of the Clean Air Act Amendments of
1970, with its shift of emphasis toward the measurement and
control of pollutants at their sources, there has come an increasing
awareness that at least for some time to come most source meas-
urements will be made by adapting existing instruments, such as
those described above, to the task. Because the levels of pollutants
to be measured at sources are thousands of times higher than
those for which the instruments were designed, a reliable dilution
system was required. One such system, with the added advantages
of totally removing solids such as soot or fly ash and of operating
without moving parts, was invented by an EPA scientist and is
being evaluated both by EPA and by several instrument makers.
Through an interagency agreement with the Atomic Energy
Commission, EPA is funding the development of an X-ray instru-
ment that will permit the rapid measurement of a large number of
trace metals occurring in airborne particles. This research will
eventually result in field instruments that will permit detailed
studies of the occurrence of many metallic and non-metallic ele-
ments in polluted air.
EPA is also supporting an effort at the National Bureau of
Standards in air pollution measurement technology. For example,
NBS has worked with EPA to develop a method for certification
of sulfur dioxide permeation tubes for on-site calibration of moni-
toring devices. Similar calibration devices for carbon monoxide,
nitrogen oxides, and ozone are planned with EPA support.
In fulfilling its mission of recommending measurement methods
and instruments to the States and local agencies, EPA has under-
taken a major program of methods standardization. An important
segment of this program involves the establishment of a labora-
tory or instrumental method as being "equivalent to", that is,
producing the same analytical result when examining the same
sample, as a specified standard method.
8. Standards Set or Under Consideration Pursuant to Title 11
(Emission Standards for Moving Sources) of This Act
Final regulations by which 1975 and 1976 model cars will be
judged for their compliance with the Clean Air Act of 1970 were
promulgated this year.
Major provisions include:
—Standards for carbon monoxide and hydrocarbons beginning
with the 1975 model year. These would limit emissions to 3.4
grams of carbon monoxide and 0.41 grams of hydrocarbons
-------
GUIDELINES AND REPORTS 2637
per vehicle mile. By comparison, allowable emissions from
1970 automobiles were 34.0 grams of carbon monoxide and
4.1 grams of hydrocarbons per vehicle mile. The 90% reduc-
tion in permissible levels is called for in the Clean Air Act.
—A new exhaust emission standard for nitrogen oxides, which
will limit emissions to 3.0 grams per vehicle mile beginning
with the 1973 model year. This will be the first Federal limit
placed on emissions of nitrogen oxides from motor vehicles.
By comparison, emissions from 1971 cars that are not
equipped with nitrogen oxides control systems are 4.0 grams
per vehicle mile.
—A further reduction in the nitrogen oxides limit to 0.4 grams
per vehicle mile beginning with the 1976 model year.
—Changes in the present EPA testing procedure, beginning
with the 1975 model year, which will more accurately reflect
the driving experience of the motor vehicle population in
major urban areas.
The standards announced provide for a 90% reduction in the
levels of auto emissions, as required by the Clean Air Act.
The EPA has also issued final regulations to require auto mak-
ers to provide instructions for the proper maintenance of air pol-
lution control systems. The regulations, which were originally pro-
posed on May 11, 1971, would begin to take effect in the 1972
model year, although their main provisions would not be effective
until the 1973 model year.
The Clean Air Act authorizes EPA to ensure that motor vehi-
cles remain in compliance with Federal emission standards
throughout the vehicle's useful life.
The new regulations define "useful life" as follows:
—For light-duty vehicles, five years or 50,000 miles.
—For heavy-duty gasoline engines, five years or 50,000 miles.
—For heavy-duty diesel engines, five years or 100,000 miles.
The regulations applicable to maintenance instructions would
require manufacturers to provide information on the maintenance
of exhaust, crankcase, and evaporative-emission control systems,
and on ways to identify and correct malfunctions in those systems.
9. The Status of State, Interstate, and Local Pollution Control
Programs Established Pursuant to and Assisted by This Act
EPA provides technical assistance to States in the adoption and
submittal of plans to implement national ambient air quality
standards as authorized by the Clean Air Act Amendments of
-------
2638 LEGAL COMPILATION—Am
1970. EPA provides direct technical assistance to control agencies,
including assistance in development of air quality monitoring sys-
tems, emissions inventories, plans for effective enforcement of
standards, land use and transportation controls, control regula-
tions, and emergency episode plans. In the third quarter of Fiscal
Year 1972, after all implementation plans have been submitted,
emphasis will shift to insuring that States carry out the plans.
EPA also provides financial support to State and local control
agency programs. Table I summarizes this support for Fiscal
Years 1971 and 1972. Totals for each State reflect grants awarded
to State and local agencies.
The Environmental Protection Agency, in cooperation with
State and local air pollution control agencies, has begun a study in
more than 30 urban air quality control regions to determine exist-
ing levels of automobile-related air pollutants.
The study is intended to provide base data for the design of
State plans to achieve the national air quality standards for car-
bon monoxide, photochemical oxidant (ozone), and nitrogen diox-
ide, as required by the Clean Air Act.
The study, involving the use of more than $500,000 worth of
new instruments operated by special trained local technicians,
began on July 1, 1971. Air quality data are transmitted daily to a
centralized collection point where they are validated, computer-
summarized, and returned to cooperating State agencies.
Regions in the study are urban areas where complete measure-
ments are not routinely being made by the EPA, or State or local
pollution control agencies.
10. The Reports and Recommendations Made by the President's
Air Quality Advisory Board
The President's Air Quality Advisory Board met twice during
1971, on February 1 and on July 8-9. The Board advised the
Administrator at the February 1 meeting, the first meeting of the
Board since the establishment of EPA, on the advisory functions
of the Board, public information policies of EPA, voluntary com-
pliance by polluters, and public participation in the meetings of
the Board. In a letter to the EPA Administrator, as a result of the
deliberations at the July 8-9 meeting and the discussion with him
at that meeting, the Board recommended the following: (a) the
expansion and emphasis of the EPA health effects research pro-
gram for better scientific and public knowledge and for appropri-
ate and timely revision of regulatory standards; (b) the encour-
-------
GUIDELINES AND REPORTS 2639
agement and funding within EPA of the efforts to quantify the
benefits of air pollution control in relation to air pollution dam-
ages and costs of control as an aid to presenting future decisions
concerned with supporting control activities and paying for the
costs of control; and (c) the maintenance of EPA public informa-
tion and community support activities to provide knowledge and
understanding of air pollution control problems.
TABLE 1-SUMMARY OF GRANTS FOR STATE AND LOCAL CONTROL AGENCY PROGRAMS
Air
State or Territory 1971 1972
Alabama $43,203 $405,926
Alaska 55,466 61,387
Arizona 347,500 347,500
Arkansas 90,152 269,884
California 2,870,044 4,134,262
Colorado 522,000 522,000
Connecticut 530,869 770,512
Delaware 205,112 231,932
District of Columbia 234,134 234,134
Florida 949,918 1,113,975
Georgia 552,829 801,798
Hawaii 27,605 60,695
Idaho 64,937 127,634
Illinois 1,468,457 2,337,857
Indiana 512,615 1,142,721
Iowa 215,112 470,426
Kansas 141,324 296,999
Kentucky 535,614 670,413
Louisiana 183,916 487,649
Maine 74,093 202,273
Maryland 1,426,251 1,426,251
Masswhusetts 698,009 1,129,922
Michigan 1,533,572 2,150,442
Minnesota 447,798 648,428
Mississippi 95,359 290,416
Missouri 772,226 956,945
Montana 135,086 186,985
Nebraska 133,408 211,694
Nevada 163,000 163,000
New Hampshire 55,869 130,409
NewJersey 1,587,669 2,053,369
New Mexico 257,558 257,558
New York 2,836,675 4,178,741
North Carolina 620,180 965,362
North Dakota 21,456 65,343
Ohio 1,257,189 2,199,387
Oklahoma 236,877 344,004
Oregon 567,650 639,403
Pennsylvania 2,562,671 3,005,808
Rhode Island 106,473 188.675
-------
2640 LEGAL COMPILATION—Am
TABLE 1-Conttnued
South Carolina
South ilakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
American Samoa
Guam
Puerto Rico
Virgin Islands
Total
345,623
33,441
801,281
1,426,216
101,551
59,920
478,067
1,125,000
256,462
199,494
33,536
219
10,823
149,310
39,181
530,200,000
516,948
64,441
881,045
2,038,558
133,944
84,302
722,294
1,125,000
376,631
701,071
53,041
3,005
21,272
254,850
41,479
142,900,000
4.2 CRITERIA AND CONTROL TECHNIQUES DOCUMENTS
AND SUMMARIES
4.2a CRITERIA
4.2a(l) "CRITERIA FOR CARBON MONOXIDE"
National Air Pollution Control Administration, March 1970
CRITERIA FOR CARBON MONOXIDE
(Summary of "Air Quality Criteria for Carbon Monoxide," pub-
lished by the National Air Pollution Control Administration in
March 1970)
A. OCCURRENCE, PROPERTIES, AND FATE OF
ATMOSPHERIC CARBON MONOXIDE
Because of its origin from the incomplete combustion of organic
materials, carbon monoxide (CO) is emitted to the atmosphere in
greater quantities than any other urban air pollutant. The largest
sources of CO in the urban environment may be classified as tech-
nological. Several geophysical and biological sources of this pollu-
tant have been identified, but their contribution to urban atmos-
pheric concentrations is thought to be small. Background concen-
trations of CO (arising from both natural and technological
-------
GUIDELINES AND REPORTS 2641
sources) are presently estimated to range from 0.029 to 1.15 milli-
grams per cubic meter (mg/m3), i.e., 0.025 to 1.00 part per mil-
lion (ppm).
Carbon monoxide is a colorless, odorless, tasteless gas. Oxida-
tion of CO to carbon dioxide (C02) does occur in the atmosphere,
but the rate of the known reactions have been shown to be very
slow. The mean residence time of atmospheric CO has been esti-
mated to be between 1 month and 5 years.
Removal processes for atmospheric CO have been postulated to
include: the migration of CO to the upper atmosphere, the binding
of CO to porphyrin compounds in plants and animals, and unde-
termined interactions between CO and ocean water, and the ad-
sorption and oxidation of CO on various surfaces. Some of these
removal processes are, however, highly speculative.
B. FORMATION OF CARBON MONOXIDE
CO arises primarily from incomplete or inefficient combustion
of carbonaceous fuels. Oxygen concentration, flame temperature,
gas residence time, and combustion chamber turbulence are impor-
tant variables that affect the exhaust concentrations of CO.
C. ESTIMATION OF CARBON MONOXIDE EMISSIONS
An estimated 92 x 109 kilograms (102 million tons) of CO were
emitted in the United States in 1968. This amounts to 50 percent
by weight of all major air pollutant emissions that year. Fuel
combustion in mobile sources utilizing the internal combustion
engine is the principal source category of CO (58 percent). Mis-
cellaneous combustion sources, principally forest fires, and in-
dustrial process sources are the second (17 percent) and third (11
percent) largest categories, respectively. Disposal of solid wastes
is the fourth (8 percent) greatest source category of CO emis-
sions, and stationary fuel combustion is the fifth (2 percent).
Emission estimates were derived by the use of emission factors
and activity levels. A summary of the method of estimation ap-
plied to each source category is presented. Estimates indicate that
no further increase in magnitude of CO vehicular emissions above
the 1968 value of 59 million tons would be expected before about
2000.
D. MEASUREMENT OF CARBON MONOXIDE
CONCENTRATIONS IN AMBIENT AIR
Nondispersive infrared (NDIR) analyzers are the most com-
monly used continuous, automated devices for measuring atmos-
-------
2642 LEGAL COMPILATION—Am
pheric CO concentrations and are generally accepted as the most
reliable reference method. Measuring ranges usually extend from
1 to 58 mg/m3 (1 to 50 ppm) CO or from 1 to 115 mg/m3 (1 to
100 ppm) CO. Water vapor and C02 interfere in the determina-
tion of CO by NDIR techniques. Filter cells and treatment of the
incoming gas stream are techniques used to minimize these inter-
ferences.
Galvanic and coulometric analyzers are two other instruments
commercially available for continuously measuring CO concentra-
tions. The function of both instruments depends on the oxidation
of CO by iodine pentoxide (I205). These instruments are flow-and
temperature-dependent and suffer from multiple interferences;
consequently, they have not been widely used.
A mercury vapor analyzer, which depends on the liberation of
mercury vapor when CO is passed over hot mercuric oxide, has
been used as a portable, continuous-monitoring analyzer. Though
especially adaptable for measuring low CO concentrations [0.29
mg/m3 (0.25 ppm)], this instrument does not appear suitable for
routine air monitoring because of numerous interferences and
electronic instability.
A recently developed automated gas chromatographic system
operates by quantitatively converting CO to methane (CH4),
which is subsequently semi-continuously measured by a flame ioni-
zation detector. This arrangement shows considerable promise as
a monitoring device. Concentrations of from 0.1 to 1,150 mg/m3
(0.1 to 1,000 ppm) may be determined, and instrument output
over this range is linear for both CO and CH4.
Another principle for determination of atmospheric CO concen-
trations is based on the catalytic conversion, using Hopcalite, of
CO to C02 with a measurement of the resulting temperature rise.
These systems are widely used in enclosed spaces, but their applic-
ability for ambient air monitoring is limited because they function
best at high ambient concentrations.
Intermittent samples may be collected in the field and later
analyzed in the laboratory by NDIR, gas chromatographic, or
infrared spectrophotometric methods of analysis. Colorimetric
techniques, generally based on the reduction of a metallic salt,
have been used for rapid, relatively gross estimates of CO concen-
trations.
Accurately prepared standard samples are necessary for the
calibration of any instrument used to measure CO concentrations.
Gas samples may be standardized by volumetric, gravimetric, and
chemical techniques.
-------
GUIDELINES AND REPORTS 2643
E. ATMOSPHERIC CARBON MONOXIDE
CONCENTRATIONS
Diurnal, weekly, and seasonal variations in CO concentrations
can be observed. Diurnal and weekly variations correlate best with
community traffic patterns; seasonal variations are most depend-
ent on meteorologic variables.
Both macro- and micrometeorological factors play a role in the
rate of dispersion of CO emissions. Micrometeorological factors,
such as mechanical turbulence produced by automobiles and air-
flow around buildings, become important in determining street-
side exposures. Macrometeorological factors can lead to air stag-
nation, which causes high community CO levels.
The concepts of averaging time and frequency of occurrence are
important when describing ambient pollutant measurements. Be-
cause of physiological considerations, the averaging time of most
interest for CO is 8 hours. Aerometric data from the Continuous
Air Monitoring Program, the State of California, and Los Angeles
County were analyzed for the 8-hour-averaging-time; CO concen-
tration exceeded 0.1 percent of the time at each available site.
These values ranged from approximately 12 to 46 mg/m3 (10 to
40 ppm).
To aid in analyzing aerometric data, a statistical model has been
developed. While year-to-year mean and peak CO values may vary
markedly within a community, the model can be used to calculate,
based on any averaging time, a statistically probable annual maxi-
mum concentration.
Within a community, CO concentrations vary markedly with
location. Calculated annual maximum concentrations in the most
polluted 5 percent of the locations incorporated in a recent sample
of a variety of sites showed that CO concentrations predicted
inside the passenger compartment of motor vehicles in downtown
traffic were almost 3 times those predicted in central urban areas
and 5 times those expected in residential areas. Occupants of vehi-
cles traveling on expressways and arterial routes were found to
have CO exposures somewhere between those in central urban
areas and in downtown traffic.
Concentrations exceeding 100 mg/m3 (87 ppm) have been
measured in underground garages, in tunnels, and in buildings
constructed over highways.
Using emission and meteorological data, diffusion models can be
used to estimate community air quality under a variety of condi-
tions.
-------
2644 LEGAL COMPILATION—Am
F. EFFECTS OF CARBON MONOXIDE ON VEGETATION
AND MICROORGANISMS
Plants are relatively insensitive to CO at the lower levels of
concentrations that have been found to be toxic for animals. CO
has not been shown to produce detrimental effects on certain
higher plants at concentrations below 115 mg/m3 (100 ppm)
when exposed for from 1 to 3 weeks. Nitrogen fixation by Rhizo-
bium trifolii inoculated into red clover plants has been reduced
by about 20 percent, however, after exposure to 115 mg/m3 (100
ppm) CO for 1 month.
G. TOXICOLOGICAL APPRAISAL OF ATMOSPHERIC
CARBON MONOXIDE
CO is absorbed by the lung and reacts primarily with hemopro-
teins and most notably with the hemoglobin of the circulating
blood. The absorption of CO is associated with a reduction in the
oxygen-carrying capacity of blood and in the readiness with which
the blood gives up its available oxygen to the tissues. The affinity
of hemoglobin for CO is over 200 times that for oxygen, indicating
that carboxyhemoglobin (COHb) is a more stable compound than
oxyhemoglobin (02Hb). About 20 percent of an absorbed dose of
CO is found outside of the vascular system, presumably in combi-
nation with myoglobin and heme-containing enzymes. The magni-
tude of absorption of CO increases with the concentration, the
duration of exposure, and the ventilatory rate. With fixed concen-
trations and with exposures of sufficient duration, an equilibrium
is reached; the equilibrium is reasonably predictable from par-
tial-pressure ratios of oxygen to CO.
Long-term exposures of animals to sufficiently high CO concen-
trations can produce structural changes in the heart and brain. It
has not been shown that ordinary ambient exposures will produce
this. The lowest exposure producing any such changes has been 58
mg/m3 (50 ppm) continuously for 6 weeks.
The normal or "background" concentration of COHb in non-
smokers is about 0.5 percent and is attributed to endogenous
sources such as heme catabolism. The body's uptake of exogenous
CO increases blood COHb according to the concentration and
length of exposure to CO as well as the respiratory rate of the
individual.
In human exposure studies, continuous exposure to 35 mg/m3
(30 ppm) CO has led to 80 percent of the equilibrium value of 5
percent COHb being approached in 4 hours, and the remaining 20
-------
GUIDELINES AND REPORTS 2645
percent approached slowly over the next 8 hours. Theoretical cal-
culations indicate a COHb equilibrium value of about 3.7 percent
after continuous exposure to 23 mg/m3 (20 ppm) and about 2
percent after continuous exposure to 12 mg/m3 (10 ppm). The
equilibrium values are generally reached after about 8 or more
hours of exposure, although physical activity can shorten this time
period.
Interference with the accurate estimation of time intervals has
been demonstrated in nonsmokers with exposures to as low as 58
mg/m3 (50 ppm) CO for 90 minutes. Such an exposure is likely
to lead to COHb levels in the range of 2.5 percent. At a blood level
of about 3 percent COHb, estimated by expired air analysis after
exposure of nonsmokers to 58 mg/m3 (50 ppm) CO for 50 min-
nutes, significant changes in relative brightness threshold and vis-
ual acuity have been observed. Evidence of impairment in per-
formance of other psychomotor tests has been associated with
COHb levels of 5 percent in some instances. Experimental expo-
sures of human subjects to CO leading to blood COHb levels above
5 percent have been associated with impairment in the oxidative
metabolism of the myocardium in subjects with pulmonary em-
physema and coronary heart disease. Persons in the latter group
are unable to compensate for CO exposures by increasing coronary
blood flow and are, therefore, particularly vulnerable. Persons
with veno-arterial shunts in the circulation are also probably vul-
nerable, as are those with respiratory impairment. From physio-
logic considerations CO would be expected to have a greater effect
with increasing altitude.
There is evidence that CO exposure increases the hematocrit of
the blood and probably the circulating blood volume, although the
significance of these changes is not clear. There is evidence that
prolonged exposure to relatively high concentrations of CO in-
creases the deposition of lipids in the major blood vessels of rab-
bits, and this could be a factor in the pathogenesis of arterioscle-
rosis.
Thus, in summary it may be stated that: (1) no human health
effects have been demonstrated for COHb levels below 1 percent,
since endogenous CO production makes this a physiological range;
(2) the following effects on the central nervous system occur
above 2 percent COHb: (a) at about 2.5 percent COHb in non-
smokers (from exposure to 58 mg/m3 for 90 minutes), an impair-
ment in time-interval discrimination has been documented, (b) at
about 3 percent COHb in nonsmokers (from exposure to 58 mg/
m3 for 50 minutes), an impairment in visual acuity and relative
-------
2646 LEGAL COMPILATION—Am
brightness threshold has been observed, (c) at about 5 percent
COHb there is an impairment in performance of certain other
pyschomotor tests; (3) cardiovascular changes have been shown
to occur at exposure sufficient to produce over 5 percent COHb;
they include increased cardiac output, increased arterial-venous
oxygen difference, increased coronary blood flow in patients with-
out coronary disease, decreased coronary sinus blood P02 in pa-
tients with coronary heart disease, impaired oxidative metabolism
of the myocardium, and other related effects; these changes have
been demonstrated to produce an exceptional burden on some
patients with heart disease; and (4) adaptation to CO may occur
through increasing blood volume, among other mechanisms.
H. EPIDEMIOLOGICAL APPRAISAL OF
CARBON MONOXIDE
Those segments of the population most susceptible to the ad-
verse effects associated with atmospheric CO can be predicted on a
physiologic basis to include those people most sensitive to a de-
creased oxygen supply. These susceptible groups include, then,
individuals with anemia, cardiovascular disease, abnormal meta-
bolic states such as thyrotoxicosis or fever, and chronic pulmonary
disease and the developing fetus.
A major source of CO exposure is cigarette smoke; cigarette
smokers generally have a COHb with a median value of 5 percent,
whereas nonsmokers are usually found to have about 0.5 percent
COHb. Community exposures of people who are cigarette smokers
and already have an elevated COHb will either lead to an increase
in COHb or will slow down the excretion of CO during intervals
between cigarette smoking, depending upon the initial COHb level
in the smoker and the magnitude and duration of the ambient CO
exposure. Exposure of traffic policemen, in Paris, for 5 hours to
between 12 and 14 mg/m3 (10 and 12 ppm) has increased COHb
levels in nonsmokers by about 0.7 percent. The extent of human
CO exposure from sources other than smoking or the ambient
outdoor air has not been well documented.
Several effects of long-term exposure to CO have been impli-
cated. Recent data suggest that the mortality from myocardial
infarction may be increased by exposure to average weekly CO
concentrations of from 9 to 16 mg/m3 (8 to 14 ppm), although
these results are not conclusive and require replication. The proba-
bility of involvement in motor vehicle accidents may also be asso-
ciated with CO exposure. This could be related to the influence of
-------
GUIDELINES AND REPORTS 2647
CO exposure on visual acuity, estimation of time intervals, or
other psychomotor parameters.
I. AREAS FOR FUTURE RESEARCH
Review of this document reveals many areas where additional
research is necessary to fill the gaps in our present knowledge of
the behavior and effects of ambient CO.
The atmospheric reactions and fate of ambient CO are only
vaguely understood and therefore require further study. Improve-
ments are needed in instrument-measuring methods, particularly
with a view to eliminating interferences and to making the instru-
ments less cumbersome. Associated with this is the need to meas-
ure the influence of outdoor CO levels on indoor CO concentra-
tions.
Reasearch on the physiology of CO in the human body has
provided considerable information on both endogenous CO produc-
tion and on the effects of CO at various cellular and microcellular
levels. Our knowledge of the effects of CO on enzyme systems and
tissue oxygenation, however, is far from complete. In addition,
mechanisms of CO catabolism in the body remain undefined. The
uptake of CO during varying time periods and with changes in
activity must be further documented.
Studies of the effects of CO on human behavior and perform-
ance need both clarification and replication. Definition and sophis-
tication of parameters sensitive to changes in blood carboxyhemo-
globin merit considerable attention as a prerequisite to better de-
fining the influence of CO on human performance.
Epidemiological information is urgently needed on the possible
effects of CO on several segments of the population which theoret-
ically at least are at great risk to CO exposure. In addition, many
questions have been raised concerning the relationship between
CO exposure and the development and/or progression of cardio-
vascular disease, and our present state of knowledge is far from
complete on this subject.
The relationship between CO exposure from smoking and CO
exposure from the ambient air is not clear at the present time.
While both exposures produce increases in blood COHb, the asso-
ciated effects are not identical. Whether or not some method of
adaptation to CO exposure exists is a debatable issue at the pres-
ent time.
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2648 LEGAL COMPILATION—Am
J. CONCLUSIONS
Derived from a careful evaluation of the studies cited in this
document, the conclusions given below represent the National Air
Pollution Control Administration's best judgment of the effects
that may occur when various levels of pollution are reached in the
ambient air. Additional information from which the conclusions
were derived, and qualifications that may enter into consideration
of these data, can be found in the appropriate chapter of this
document.
1. Experimental exposure of nonsmokers to a concentration of
35 mg/m3 (30 ppm) for 8 to 12 hours has shown that an equilib-
rium value of 5 percent COHb is approached in this time; about
80 percent of this equilibrium value, i.e., 4 percent COHb, is pres-
ent after only 4 hours of exposure. These experimental data verify
formulas used for estimating the equilibrium values of COHb
after exposure to low concentrations of CO. These formulas indi-
cate that continuous exposure of nonsmoking sedentary individu-
als to 23 mg/m3 (20 ppm) will result in a blood COHb level of
about 3.7 percent, and an exposure to 12 mg/m3 (10 ppm) will
result in a blood level of about 2 percent (Chapter 8, Sections D
and K).
2. Experimental exposure of nonsmokers to 58 mg/m3 (50
ppm) for 90 minutes has been associated with impairment in
time-interval discrimination. (See Chapter 8, Section E). This ex-
posure will produce an increase of about 2 percent COHb in the
blood. This same increase in blood COHb will occur with continu-
ous exposure to 12 to 17 mg/m3 (10 to 15 ppm) for 8 or more
hours. (See Chapter 8, Sections D and E).
3. Experimental exposure to CO concentrations sufficient to pro-
duce blood COHb levels of about 5 percent (a level producible by
exposure to about 35 mg/m3 for 8 or more hours) has provided in
some instances evidence of impaired performance on certain other
psychomotor tests, and an impairment in visual discrimination
(Chapter 8, Section E).
4. Experimental exposure to CO concentrations sufficient to pro-
duce blood COHb levels above 5 percent (a level producible by
exposure to 35 mg/m3 or more for 8 or more hours) has provided
evidence of physiologic stress in patients with heart disease
(Chapters, Section F).
Table 10-1 presents these conclusions in tabular form.
«b-.05 O - 74 - 20
-------
GUIDELINES AND REPORTS 2649
K. RESUME
An exposure of 8 or more hours to a carbon monoxide concen-
tration of 12 to 17 mg/m3 (10 to 15 ppm) will produce a blood
carboxyhemoglobin level of 2.0 to 2.5 percent in nonsmokers. This
level of blood carboxyhemoglobin has been associated with adverse
health effects as manifested by impaired time interval discrimina-
tion. Evidence also indicates that an exposure of 8 or more hours
to a CO concentration of 35 mg/m3 (30 ppm) will produce blood
carboxyhemoglobin levels of about 5 percent in nonsmokers. Ad-
verse health effects as manifested by impaired performance on
certain other psychomotor tests have been associated with this
blood carboxyhemoglobin level, and above this level there is evi-
dence of physiologic stress in patients with heart disease.
There is some epidemiological evidence that suggests an associa-
tion between increased fatality rates in hospitalized myocardial
infarction patients and exposure to weekly average CO concentra-
tions of the order of 9 to 16 mg/m3 (8 to 14 ppm).
Evidence from other studies of the effects of CO does not cur-
rently demonstrate an association between existing ambient levels
of CO and adverse effects on vegetation, materials, or other as-
pects of human welfare.
It is reasonable and prudent to conclude that, when promulgat-
ing air quality standards, consideration should be given to require-
ments for margins of safety that would take into account possible
effects on health that might occur below the lowest of the above
levels.
-------
2650
LEGAL COMPILATION—Am
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GUIDELINES AND REPORTS 2651
4.2a(2) "CRITERIA FOR HYDROCARBONS"
National Air Pollution Control Administration, March 1970
CRITERIA FOR HYDROCARBONS
(Summary of "Air Quality Criteria for Hydrocarbons," pub-
lished by the National Air Pollution Control Administration in
March 1970)
A. INTRODUCTION
This document focuses on gas-phase hydrocarbons and certain
of their oxidation products, particularly aldehydes, that are asso-
ciated with the manifestations of photochemical air pollution. Par-
ticulate hydrocarbons, and more specifically polynuclear hydrocar-
bons, are not treated in this document. It is important to recognize
that the criteria for hydrocarbons rest almost entirely on their
role as precursors of other compounds formed in the atmospheric
photochemical system and not upon direct effects of the hydrocar-
bons themselves. A companion document, AP-63, Air Quality Cri-
teria for Photochemical Oxidants, covers the effects of a class of
photochemical reaction products not treated in this document.
B. SOURCES, NATURE, AND PRINCIPLES OF CONTROL
OF ATMOSPHERIC HYDROCARBONS
Most natural sources of hydrocarbon emissions are biological in
nature. A conservative estimate made for the worldwide natural
production rate of methane is 3 x 10s tons per year. A similar
estimate of 4.4 x 10s tons per year has been made for volatile
terpenes and isoprenes. It appears that nonurban air contains
from 0.7 to 1.0 mg/m3 (1.0 to 1.5 ppm) methane and less than 0.1
ppm each of other hydrocarbons.
Total nationwide technological emissions of hydrocarbons and
related organic compounds for the year 1968 were estimated to be
32 x 106 tons. Transportation represented the largest source cate-
gory and accounted for 52 percent of this estimate. The miscella-
neous source category—principally organic solvent evaporation—
was the second largest and represented 27 percent of the total
emissions. Industrial processes (14 percent) was third; solid
waste disposal (5 percent) was fourth; and fuel combustion in
stationary sources (2 percent) was fifth.
Local emission estimates for 22 metropolitan areas ranged from
about 0.05 to 1.3 million tons per year. Transportation sources
-------
2652 LEGAL COMPILATION—AIR
accounted for from 37 to 99 percent of local emissions, and process
losses accounted for from 1 to 63 percent. Hydrocarbon emissions,
therefore, originate primarily from the inefficient combustion of
volatile fuels and from their use as process raw materials.
The control of hydrocarbon emissions rests upon the basic prin-
ciples of: (1) combustion process optimization, (2) recovery by
mass transfer principles, (3) restriction of evaporative loss, and
(4) process material and fuel substitution. The first three princi-
ples are all applied with varying degrees of success in the control
of automobile emissions.
C. ATMOSPHERIC LEVELS OF HYDROCARBONS AND
THEIR RELATED PRODUCTS
Yearly averages of monthly maximum 1-hour average hydrocar-
bon concentrations including methane, recorded continuously in
various stations of the Continuous Air Monitoring Projects, have
reached maximum hourly values of 8 to 17 ppm (as carbon), but
at least half of this amount is probably the photochemically un-
reactive methane component in all cases.
In a series of 200 samples taken in one urban location, average
concentrations of the most abundant hydrocarbons were as follows
(in ppm as carbon) : methane, 3.22; toluene, 0.37; n-butane, 0.26;
i-pentane, 0.21; ethane, 0.20; benzene, 0.19; w-pentane, 0.18; pro-
pane, 0.15; and ethylene, 0.12. Among classes of hydrocarbons, the
alkanes predominate, even if methane is excluded. They are fol-
lowed by the aromatics, olefms, acetylenes, and alicyclics.
The diurnal variation of hydrocarbon concentrations resembles
that of carbon monoxide (at stations in the Los Angeles area) in
having a pronounced maximum appearing usually between 6:00
and 8:00 a.m.
For nonoxidant photochemical secondary contaminants, availa-
ble information is limited to results of special studies on aldehydes
in the Los Angeles area. These show that yearly maximum 1-hour
average total aldehyde concentrations range from 0.20 to 1.30 ppm
and that the analogous formaldehyde concentrations range from
60 to 150 /u.g/m3 (0.05 to 0.12 ppm). Hourly average acrolein
concentrations range from 10 to 270 /^g/m3 (0.004 to 0.010 ppm)
in various studies. The ratio of formaldehyde to the "total" alde-
hyde index has been reported at from about 10 to 90 percent; it is
likely that an appreciable part of the variation is caused by the
use of different analytical methods or procedures in the different
investigations.
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GUIDELINES AND REPORTS 2653
D. SAMPLING AND STANDARDIZATION METHODS FOR
MEASUREMENT OF HYDROCARBONS
With few exceptions, atmospheric hydrocarbon measurements
are made with relatively complex instruments that operate contin-
uously. Continuous instrumentation demands dynamic calibration
techniques. Standard gases for this purpose are available or may
be generated by permeation tubes or dilution systems, or prepared
in large containers.
Flame ionization analyzers are sensitive and reliable and are
suitable for the continuous measurement of total hydrocarbons.
They are generally accepted as the method of choice by NAPCA.
They cannot, however, give the specific detailed information re-
quired for a thorough understanding of the atmospheric photo-
chemical problem. Attempts to further define the hydrocarbon
mixture by using pretreatment columns to measure only methane
or various reactive classes have met with some success but limited
application.
Spectrometric techniques both for total and specific analysis are
complex and generally insensitive.
Gas chromatographic analysis provides the requisite sensitivity
and specificity for the quantitation of individual hydrocarbons.
Difficulties in qualitative analysis and data handling have limited
the application of GC to short-term studies for the most part, and
no continuous data are available.
Carbonyl compounds, specifically aldehydes and ketones, can be
measured by several manual colorimetric techniques, but very lit-
tle actual data are available.
E. RELATIONSHIP OF ATMOSPHERIC HYDROCARBONS
TO PHOTOCHEMICAL AIR POLLUTION LEVELS
The development of a model to relate emission rates of hydro-
carbons to ambient air quality and thence to the secondary prod-
ucts of photochemical reactions has proved to be an elusive prob-
lem. Because of this lack of an appropriate model, the relationship
between hydrocarbon emissions and subsequent maximum daily
oxidant levels has been approached empirically by a comparison of
6:00 to 9:00 a.m. average hydrocarbon values with hourly maxi-
mum oxidant values attained later in the day. This approach has
validity only because of the dominating influence of the macro-me-
teorological variables on both the concentrations of precursors and
photochemical products. Furthermore, this approach can only
yield useful information when a large number of days are consid-
-------
2654 LEGAL COMPILATION—AIR
ered, thus guaranteeing the inclusion of all possible combinations
of emission rates, meteorological dilution and dispersion variables,
sunlight intensity, and ratios of precursor emissions. When maxi-
mum daily oxidant values from such an unrestricted data base are
plotted as a function of the early morning hydrocarbons, a com-
plete range of oxidant values starting near zsro and ranging up to
a finite and limiting value is observed. Given data for a sufficient
number of days, it becomes apparent that the maximum values of
attainable oxidant are a direct function of the early morning hy-
drocarbon concentration. This upper limit of the maximum daily
oxidant concentration is dependent on the metropolitan geographi-
cal area only to the extent that differences in meteorological varia-
bles exist between these areas. Thus the data from all cities can be
plotted on one graph when defining the oxidant upper limit as a
function of early morning hydrocarbon concentrations.
In defining this oxidant upper limit all available data relating
directly measured nonmethane hydrocarbon concentrations to
maximum daily oxidant concentrations have been used. Direct ob-
servation of this limit in the vicinity of 200 /*g/m3 (0.1 ppm)
daily maximum 1-hour average oxidant concentration shows that
in order to keep the oxidant below this value, the 6:00 to 9:00 a.m.
average nonmethane hydrocarbon concentration must be less than
200 /ig/m3 (0.3 ppm C). This maximum oxidant concentration
potential may be expected to occur on about 1 percent of the days.
F. EFFECTS OF HYDROCARBONS AND CERTAIN
ALDEHYDES ON VEGETATION
Hydrocarbons were first recognized as phytotoxic air pollutants
about the turn of the century as a result of complaints of injury to
greenhouse plants from illuminating gas. Ethylene was shown to
be the injurious component. Renewed interest in hydrocarbons,
and ethylene in particular, occurred in the mid-1950's when ethyl-
ene was found to be one of the primary pollutants in the photo-
chemical smog complex. Research on several unsaturated and satu-
rated hydrocarbons proved that only ethylene had adverse effects
at known ambient concentrations. Acetylene and propylene more
nearly approach the activity of ethylene than do other similar
gases, but 60 to 500 times the concentration is needed for compa-
rable effects.
In the absence of any other symptom, the principal effect of
ethylene is to inhibit growth of plants. Unfortunately, this effect
does not characterize ethylene because other pollutants at suble-
-------
GUIDELINES AND REPORTS 2655
thai dosages, as well as some disease and environmental factors,
will also inhibit growth.
Epinasty of leaves and abscission of leaves, flower buds, and
flowers are somewhat more typical of the effects of ethylene, but
the same effects may be associated with nutritional imbalance,
disease, or early senescence. Perhaps the most characteristic ethyl-
ene effects are the dry sepal wilt of orchids and the closing of
carnation flowers. Injury to sensitive plants has been reported at
ethylene concentrations of 1.15 to 575 /^g/m3 (0.001 to 0.5 ppm)
during time periods of 8 to 24 hours.
G. TOXICOLOGICAL APPRAISAL OF HYDROCARBONS
AND ALDEHYDES
Hydrocarbon air pollutants enter into and promote the forma-
tion of photochemical smog and thus contribute to the develop-
ment of eye irritation and other manifestations. They are inti-
mately involved in the formation of formaldehyde and other alde-
hydes and ketones, and of various oxidants, including peroxyacetyl
nitrate. In developing air quality criteria, there must be due con-
sideration of the potential of the hydrocarbons under certain at-
mospheric conditions to form more hazardous derivatives.
Experimental data resulting from the exposure of animals and
humans to various hydrocarbon compounds indicate that:
1. The aliphatic and alicyclic hydrocarbons are generally bio-
chemically inert, though not biologically inert, and are only re-
active at concentrations of 102 to 103 higher than those levels
found in the ambient atmosphere. No effects have been reported
at levels below 500 ppm.
2. The aromatic hydrocarbons are biochemically and biologically
active. The vapors are more irritating to the mucous membranes
than equivalent concentrations of the aliphatic or alicyclic groups.
Systemic injury can result from the inhalation of vapors of the
aromatic compounds; no effects, however, have been reported at
levels below 25 ppm.
Pulmonary function and eye irritation have been evaluated by
the exposure of experimental animals and humans to various
mixed atmospheres that had the characteristic of providing the
milieu necessary for hydrocarbon reactivity. Experimental data
indicate:
1. Exposure of guinea pigs to ambient Los Angeles photochemi-
cal smog produces a temporary increase in pulmonary airflow
resistance. Exposure of guinea pigs to laboratory-irradiated auto
-------
2656 LEGAL COMPILATION—AIR
exhaust causes an increased tidal volume, minute volume, and flow
resistance, with a decrease in the respiratory rate. These parame-
ters return to normal immediately following exposure.
2. The precursors of the eye irritants are hydrocarbons (as well
as other organic compounds) in combination with oxides of nitro-
gen; the alkylbenzenes and olefins are more effective precursors
than paraffins, benzene, and acetylenes. The products of photo-
chemical reactions that have been identified as effective eye irri-
tants are formaldehyde, acrolein, peroxyacyl nitrates, and peroxy-
benzoyl nitrate. In general, the most characteristic and important
effect of aldehydes for both humans and animals is primary irrita-
tion of the eyes, upper respiratory tract, and skin. The unsatur-
ated aldehydes are several times more toxic than the correspond-
ing aliphatic aldehydes, and toxicity generally decreases with in-
creasing molecular weight within the unsaturated and aliphatic
aldehyde ssries. Animal experiments have shown that aldehydes
can affect respiratory functions, causing such effects as an in-
crease in flow resistance and tidal volume and a decrease in the
respiratory rate. Animal populations, although many of the effects
attributed to photochemical smog are indirectly related to ambient
levels of these hydrocarbons.
Experimental data on specific aldehydes have indicated:
1. Aldehyde concentrations have been correlated with the inten-
sity of eye irritation during natural and laboratory-produced pho-
tochemical smog. Formaldehyde appears to be detectable by odor
or physiological response (optical chronaxy) at concentrations in
the order of 70 /*g/m3 (0.06 ppm). The threshold for eye irrita-
tion by formaldehyde has been estimated by various investigators
to be between 12 and 1,230 /*g/m3 (0.01 to 1.0 ppm). Acrolein can
be detected by both odor and eye irritation at concentrations as
low as 600 /tg/m3 (0.25 ppm), but the threshold for opical chron-
axy is reported as 1,750 /ug/m3 (0.75 ppm).
2. Formaldehyde at a concentration of 2,460 ju.g/m3 (2 ppm)
has been associated with a doubling of the total expiratory resist-
ance of guinea pigs exposed to irradiated atmospheres of automo-
bile exhaust gases.
3. Acetaldehyde is much less irritating than formaldehyde; its
irritant threshold appears at concentrations of about 10,000 p.g/
m3 (50 ppm). No physiological effects are known at levels that
may be anticipated to occur in the ambient atmosphere.
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GUIDELINES AND REPOKTS 2657
H. CONCLUSIONS
The conclusions that follow are derived from a careful evalua-
tion of the studies cited in this document, representing the Na-
tional Air Pollution Control Administration's best judgment of the
effects that may occur when various levels of hydrocarbons are
reached in the ambient air. Additional information from which
the conclusions were derived, and qualifications that may enter
into consideration of these data, can be found in the appropriate
chapters of this document.
1. Our present state of knowledge does not demonstrate any
direct health effects of the gaseous hydrocarbons in the ambient
air on populations, although many of the effects attributed to
photochemical smog are indirectly related to ambient levels of
these hydrocarbons.
2. Injury to sensitive plants has been reported in association
with ethylene concentrations of from 1.15 to 575 /«g/m3 (0.001 to
0.5 ppm) over a time period of 8 to 24 hours (Chapter 6).
3. Examination of air quality data indicates that an early morn-
ing (6:00 to 9:00 a.m.) concentration of 200 p.g/m3 (0.3 ppm C)
nonmethane hydrocarbon can be expected to produce a maximum
hourly average oxidant concentration of up to 200 /tg/m3 (0.1
ppm) (Chapter 5).
I. RESUME
Studies conducted thus far of the effects of ambient air concen-
trations of gaseous hydrocarbons have not demonstrated direct
adverse effects from this class of pollution on human health. How-
ever, it has been demonstrated that ambient levels of photochemi-
cal oxidant, which do have adverse effects on health, are a direct
function of gaseous hydrocarbon concentrations; and when pro-
mulgating air quality standards for hydrocarbons, their contribu-
tion to the formation of oxidant should be taken into account.
An analysis of 3 years of data collected in three American cities
shows that on those several days a year when meteorological con-
ditions were most conducive to the formation of photochemical
oxidant, nonmethane hydrocarbon concentrations of 200 jug/m3
(0.3 ppm C) for the 3-hour period from 6:00 to 9:00 a.m. might
produce an average 1-hour photochemical oxidant concentration of
up to 200 /*g/m3 (0.10 ppm) 2 to 4 hours later. The hydrocarbon
measurements were confined to 200 /u.g/m3 (0.3 ppm C), or above,
because of instrumentation limitations. However, if the functional
relationship between the hydrocarbon and photochemical oxidant
-------
2658 LEGAL COMPILATION—AIR
measurements were extended to include the lowest levels at which
photochemical oxidant has been observed to adversely affect
human health, the corresponding hydrocarbon concentration
would be approximately 100 /ig/m3 (0.15 ppm C).
4.2a(3) "CRITERIA FOR PARTICULATE MATTER"
National Air Pollution Control Administration, January 1969
CRITERIA FOR PARTICULATE MATTER
(Summary from "Air Quality Criteria for Particulate Matter"
published by the National Air Pollution Control Administration in
January 1969)
A. SUMMARY
1. General
The particulate matter commonly found dispersed in the atmos-
phere is composed of a large variety of substances. Some of these
—fluorides, beryllium, lead, asbestos, for example—are known to
be directly toxic, although not necessarily at levels routinely found
in the atmosphere today. The evidence suggests that there may
very well be others whose toxic effects have not yet been recog-
nized. To evaluate fully the effects on health and welfare of the
presence of each of these substances in the air requires that they
be given individual attention, or attention as classes of similar
substances. Such evaluations will be made in separate documents.
This document considers the effects on man and his environment
of undifferentiated particulate matter. These effects oftentimes
are produced by a combination of particulate and gaseous pollu-
tants, the contributions of which are difficult to distinguish. More-
over, laboratory studies have shown that a combination of particu-
lates and gases may produce an effect that is greater than the sum
of the effects caused by these pollutants individually.
Particles in the atmosphere, whatever their individual charac-
teristics, exhibit a number of similar properties, which are for the
most part dependent on the particle size. Most of the available
studies on the effects of particulate air pollution, however, do not
specify particle size, and this document is limited to treating par-
ticulate matter as a whole, and to considering the effects which are
generally associated with the presence of particles in the air.
Particulate air pollution, as used in this document, refers to any
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GUIDELINES AND REPORTS 2659
matter dispersed in the air, whether solid or liquid, in which the
individual particles are larger than small molecules but smaller in
diameter than 500/t. (One /* in one millionth of a meter.) Particles
in this size range stay in the air anywhere from a few seconds to
several months.
Generally speaking, particles smaller than 1 /j. in diameter origi-
nate in the atmosphere principally through condensation and com-
bustion, while larger particles, with the exception of rain, snow,
hail, and sleet, arise principally from comminution. Particles
larger than 10 /* in diameter result from mechanical processes
such as wind erosion, grinding and spraying, and the pulverizing
of materials by vehicles and pedestrians. Particles between 1 /*
and 10 /* in diameter usually include local soil, process dusts and
combustion products from local industries, and, for maritime loca-
tions, sea salt. Combustion products and photochemical aerosols
make up a large fraction of the particles in the range 0.1 p to 1 /*
in diameter, and, although particles below 0.1 ^ in diameter have
not been extensively identified chemically, the typical urban in-
crease over natural levels of particles in this size range seems to
be entirely due to combustion.
Particles of a size less than 0.1 /n in diameter are characterized
by random motions produced by collisions with gas molecules.
They are highly concentrated, move rapidly, collide frequently,
and through sorption and nucleation of gas molecules and adhe-
sion with other particles grow larger quickly. Particles larger than
1 yu. have significant settling velocities, and their motions may
deviate significantly from the motion of the air.
Measurements of dustfall are commonly used to indicate the
mass concentration of the settleable portion of particulate air pol-
lution. Typical values for cities are 10 to 100 tons/mile2-month;
as high as 2,000 tons/mile2-month have been measured in the
vicinity of especially offensive sources. Levels of dustfall have
apparently declined in some American cities, and dustfall meas-
urements are probably not useful as an index of overall particu-
late air pollution. However, dustfall itself constitutes a nuisance,
and its measurement can be used as an index of the dirtiness of
air pollution.
Several methods are available for measuring suspended particu-
late concentrations. The most commonly used device is the high-
volume sampler, which consists essentially of a blower and a filter,
and which is usually operated in a standard shelter to collect a
24-hour sample. The sample is weighed to determine concentra-
tion, and is usually analyzed chemically. The hi-vol is considered a
-------
2660 LEGAL COMPILATION—AIR
reliable instrument for measuring the weight of total particulate
matter. Chemical analysis of the hi-vol sample, however, may be
limited: the filter material may contaminate the sample; different
substances in the sample may react with each other; and loss?s
may occur through volatilization of material. Tape samplers,
which collect suspended particulate matter on filters and analyze
the sample optically, are also in common use. While these samplers
are inexpensive and rugged, they yield data which cannot always
be easily interpreted in terms of particulate mass concentration.
Other techniques available for measuring particulate pollution in-
clude optical systems, which provide an indication of concentra-
tion without requiring that a sample be taken.
The averaging time used for measuring suspended particulates
is not as significant a factor as it is for gaseous pollutants. The
basic unit of time is 24 hours. Values taken over this period may
be combined into weekly, monthly, seasonal, and annual means as
required. The relationships between daily and other longer time
periods in the United States is known with some degree of preci-
sion, as data exist for a 10-year period.
Most of the data on mass concentrations of suspended particu-
lates come from the National Air Surveillance Networks,
(NASN), which uses the high-volume sampler. NASN currently
operates some 200 urban and 300 nonurban stations, and is supple-
mented by State and local networks. From the NASN data, the
annual geometric mean concentrations of suspended particulate
matter in urban areas range from 60 jug/m3 to about 200 pg/m3.
The maximum 24-hour average concentration is about three times
the annual mean, but values of seven times the annual mean do
occur. Mean particulate concentrations correlate, in general, with
urban population class, but the range of concentrations for any
class is broad, and many smaller communities have higher concen-
trations than larger ones. For nonurban areas the annual geomet-
ric mean is typically between 10 /*g/m3 and 60 jug/m3.
2. Effects on Health
For the most part, the effects of particulate air pollution on
health are related to injury to the surfaces of the respiratory
system. Such injury may be permanent or temporary. It may be
confined to the surface, or it may extend beyond, sometimes pro-
ducing functional or other alterations. Particulate material in the
respiratory tract may produce injury itself, or it may act in con-
junction with gases, altering their sites or their modes of action.
Laboratory studies of man and other animals show clearly that
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GUIDELINES AND REPORTS 2661
the deposition, clearance, and retention of inhaled particles is a
very complex process, which is only beginning to be understood.
Particles cleared from the respiratory tract by transfer to the
lymph, blood, or gastrointestinal tract may exert effects elsewhere.
Few studies have investigated the possibility of eye injury by
particles in the air; only transient eye irritation from large dust
particles presently is known to be a problem.
The available data from laboratory experiments do not provide
suitable quantitative relationships for establishing air quality cri-
teria for particulates. The constancy of population exposure, the
constancy of temperature and humidity, the use of young, normal,
healthy animals, and the primary focus on short-term exposures in
many laboratory studies make extrapolation from these studies of
limited value for the general population, and singularly risky for
special risk groups within the population. These studies do, how-
ever, provide valuable information on some of the bioenviron-
mental relationships that may be involved in the effects of particu-
late air pollution on health. The data they provide on synergistic
effects show very clearly that information derived from single-
substance exposures should be applied to ambient air situations
only with great caution.
Epidemiological studies do not have the precision of laboratory
studies, but they have the advantage of being carried out under
ambient air conditions. In most epidemiological studies, indices of
air pollution level are obtained by measuring selected pollutants,
most commonly particulates and sulfur compounds. To use these
same studies to establish criteria for individual pollutants is justi-
fied by the experimental data on interaction of pollutants. How-
ever, in reviewing the results of epidemiological investigations it
should always be remembered that the specific pollutant under
discussion is being used an an index of pollution, not as a physico-
chemical entity.
In epidemiological studies consistency of results at different
times and places is important in determining the significance of
observations. However, while polluted air has many similarities
from place to place and from time to time, it is not identical in all
communities or at all times, and complete consistency between
epidemiological studies should not be expected. There are not a
large number of suitable epidemiological studies available at pres-
ent, but those that are available show some consistency in the
levels at which effects were observed to occur.
Considerable data have been presented on a number of air pollu-
tion episodes in London and in New York City. In reviewing these
-------
2662 LEGAL COMPILATION—AIR
data it should be remembered that British air pollution measure-
ments are not entirely comparable with American measurements.
The only published comparison indicates that the British method
of measuring particulates tends to give somewhat lower readings
than American methods.
Excess deaths and a considerable increase in illness have been
observed in London at smoke levels above 750 /ig/m3 and in New
York at a smokeshade index of 5-6 cohs. Sulfur oxides pollution
levels were also high in both cases. These unusual short-term,
massive exposures result in immediately apparent pathologic ef-
fects, and they represent the upper limits of the observed dose-re-
sponse relationship between particulates and adverse effects on
health.
Daily averages of smoke above 300 jug/m3 to 400 /xg/m3 have
been associated with acute worsening of chronic bronchitis pa-
tients in England. No comparable data are available in this coun-
try. Studies of British workmen found that increased absences due
to illness occurred when smoke levels exceeded 200 /j.g/m3.
Two recent British studies showed increases in selected respira-
tory illness in children to be associated with annual mean smoke
levels above 120 ^g/m3. Additional health changes were asso-
ciated with higher levels. These effects may be of substantial sig-
nificance in the natural history of chronic bronchitis. Changes
beginning in young children may culminate in bronchitis several
decades later.
The lowest particulate levels at which health effects appear to
have occurred in this country are reported in studies of Buffalo
and Nashville. The Buffalo study clearly shows increased death
rates from selected causes in males and females 50 to 69 years old
at annual geometric means of 100 /xg/m3 and over. The study
suggests that increased mortality may have been associated with
residence in areas with 2-year geometric means of 80 /*.g/m3 to
100 /ig/m3. The Nashville study suggests increased death rates
for selected causes at levels above 1.1 cohs. Sulfur oxides pollution
was also present during the periods studied. In neither study were
the smoking habits of the decedents known.
Corroborating information is supplied from Fletcher's study of
West London workers between the ages of 30 and 59. The data
indicate that with a decrease of smoke pollution (yearly mean)
from 140 /^g/m3 to 60 /ug/m3, there was an associated decrease in
mean sputum volume. Fletcher noted that there may have been
changes in the tar composition of cigarettes during the period
studied; such a change could affect the findings. This study pro-
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GUIDELINES AND REPORTS 2663
vides one of the rare opportunities to examine the apparent im-
provement in health that followed an improvement in the quality
of the air.
3. Effects on Climate Near the Ground
Particles suspended in the air scatter and absorb sunlight, re-
ducing the amount of solar energy reaching the earth, producing
hazes, and reducing visibility. Suspended particulate matter plays
a significant role in bringing about precipitation, and there is
some evidence that rainfall in cities has increased as the cities
have developed industrially.
Suspended particulate matter, in the concentrations routinely
found in urban areas, considerably reduces the transmission of
solar radiation to the ground, creating an increased demand for
artificial light. The effect is more pronounced in the winter than in
the summer, when particulate pollution loadings are higher, and
sunlight must penetrate more air to reach the ground. For similar
reasons the effect is also more pronounced during the workweek
than on weekends, during industrial booms, and in higher lati-
tudes. For a typical urban area in the United States, with a geo-
metric mean annual particulate concentration of roughly 100 jug/
m3, the total sunlight, including that received directly from the
sun and that reflected by the sky, is reduced five percent for every
doubling of particle concentration. The reduction is most pro-
nounced on ultraviolet radiation.
For urban areas in the middle and high latitudes, particulate air
pollution may reduce direct sunlight by as much as one-third in
the summer and as much as two-thirds in the winter. This effect
may have implications for the delicate heat balance of the earth's
atmospheric system. In spite of an increase in the carbon dioxide
content of the atmosphere over the past several decades, which
would presumably bring about an increase in atmospheric temper-
ature, mean worldwide temperatures have been decreasing since
the 1940's. Increased reflection of solar radiation back to outer
space, brought about by increased concentrations of particulate
air pollution, may be more than cancelling out the climatic effect
of the increased carbon dioxide. That worldwide particulate air
pollution has been increasing is evidenced by the fact that in the
United States and in other countries, turbidity, a phenomenon
produced by the back-scattering of direct sunlight by particles in
the air, has increased significantly over the last several decades.
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2664 LEGAL COMPILATION — AIK
4. Effects on Visibility
Particles suspended in the air reduce visibility, or visual range,
by scattering and absorbing light coming from both an object and
its background, thereby reducing the contrast between them.
Moreover, suspended particles scatter light into the line of sight,
illuminating the air between, to further degrade the contrast be-
tween an object and its background.
The scattering of light into and out of the line of viewing by
particles in the narrow range of 0.1 ^ to 1 p. in radius has the
greatest effect on visibility. Certain characteristics of behavior of
these particles make it possible to formulate a useful approximate
relationship between visual range and concentrations of particu-
late matter :
T A x 103
— -
where G' = particle concentration
Lv = equivalent visual range, and
A = 1.2 Q g for Lv expressed in kilometers and 0.75 J gg
for Lv expressed in miles
The value 1.2 for A is the mid-range value empirically obtained
from observations in a variety of air pollution situations. The data
indicate that the range 0.6 to 2.4 covers virtually all cases studied.
The relationship does not hold at relative humidities above 70
percent, nor does it apply to fresh plumes from stacks, and it may
not hold for the products of photochemical reactions. A companion
document, Air Quality Criteria For Sulfur Oxides, discusses a
relationship between levels of sulfur dioxide and visual range at
various relative humidities.
Within the limitations prescribed, the relationship provides a
useful means of estimating approximate visual range from partic-
ulate concentrations. In addition to aesthetic degradation of the
environment, reduced visibility has serious implications for safe
operation of aircraft and motor vehicles. At a visual range of less
than 5 miles, operations are slowed at airports because of the need
to maintain larger distances between aircraft. Federal Aviation
Administration restrictions on aircraft operations become increas-
ingly severe as the visual range decreases below 5 miles. Using the
upper and lower bounds of the relationship described above, visi-
bility could be 5 miles at a particulate loading as high as 300
jug/m3 or as low as 75 //.g/m3. However, on the average, visibility
can be expected to be reduced to approximately 5 miles at a parti-
ulate concentration of 150 /*g/m3. At a level of 100
-------
GUIDELINES AND REPORTS 2665
visibility is reduced to 7y% miles. This limited distance, however,
may be related to particulate concentrations as low as 50 jug/m3
and as high as 200 /xg/m3.
5. Effects on Materials
Particulate air pollution causes a wide range of damage to
materials. Particulate matter may chemically attack materials
through its own instrinsic corrosivity, or through the corrosivity
of substances absorbed or adsorbed on it. Merely by soiling mate-
rials, and thereby causing their more frequent cleaning, particu-
lates can accelerate deterioration.
Laboratory and field studies underscore the importance of the
combination of particulate matter and corrosive gases in the dete-
rioration of materials. On the basis of present knowledge, it is
difficult to evaluate precisely the relative contribution of each of
the two classes of pollution; however, some general conclusions
may be drawn.
Particulates play a role in the corrosion of metals. In laboratory
studies, steel test panels that were dusted with a number of active
hygroscopic particles commonly found in the atmosphere corroded
even in clean air. Corrosion rates were low below a relative hu-
midity of 70 percent; they increased at relative humidities above
70 percent ; and they greatly increased when traces of sulfur diox-
ide were added to the laboratory air.
It is apparent that the accelerated corrosion rates of various
metals in urban and industrial atmospheres are largely the result
of relatively higher levels of particulate pollution and sulfur ox-
ides pollution. High humidity and temperature also play an impor-
tant synergistic part in this corrosion reaction. Studies show in-
creased corrosion rates in industrial areas where air pollution
levels, including sulfur oxides and particulates, are higher. Fur-
ther, corrosion rates are higher during the fall and winter seasons
when particulate and sulfur oxides pollution is more severe, due to
a greater consumption of fuel for heating.
Steel samples corroded 3.1 times faster in the spring of the year
in New York City, where annual particulate concentrations aver-
age 176 jug/m3, than did similar samples in State College, Penn-
sylvania, where the average concentrations were estimated to
range from 60 /xg/m3 to 65 ^g/m3. In the fall of the year, when
particulate and sulfur oxide concentrations in New York were
considerably higher than in the spring, the steel samples in New
York corroded six times faster than the samples at State College.
526-705 O - 74 - 21
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2666 LEGAL COMPILATION—Am
Similar findings were reported for zinc samples. Moisture may
have contributed to the corrosion.
In Chicago and St. Louis, steel panels were exposed at a number
of sites, and measurements taken of corrosion rates and of levels
of sulfur dioxide and particulates. In St. Louis, except for one
exceptionally polluted site, corrosion losses correlated well with
sulfur dioxide levels, averaging 30 percent to 80 percent higher
than losses measured in nonurban locations. Sulfation rates in St.
Louis, measured by lead peroxide candle, also correlated well with
weight loss due to corrosion. Measurements of dustfall in St.
Louis, however, did not correlate significantly with corrosion
rates. Over a 12-month period in Chicago, the corrosion rate at the
most corrosive site (mean SO2 level of 0.12 ppm) was about 50
percent higher than at the least corrosive site (mean S02 level of
0.03 ppm). Although suspended particulate levels measured in
Chicago with high-volume samplers also correlated with corrosion
rates, a covariance analysis indicated that sulfur dioxide concen-
trations were the dominant influence on corrosion. Based on these
data, it appears that considerable corrosion may take place (i.e.,
from 11 percent to 17 percent weight loss in steel panels) at
annual average sulfur dioxide concentrations in the range of 0.03
ppm to 0.12 ppm, and although high particulate levels tend to
accompany high sulfur dioxide levels, the sulfur dioxide concen-
tration appears to have the more important influence.
Particulate air pollution damages electrical equipment of all
kinds. Oily or tarry particles, commonly found in urban and in-
dustrial areas, contribute to the corrosion and failure of electrical
contacts and connectors. Dusts can interfere with contact closure,
and can abrade contact surfaces. Hygroscopic dusts will absorb
water and form thin electrolytic films which are corrosive.
Particulates soil and damage buildings, statuary, and other sur-
faces. The effects are especially severe in urban areas where large
quantities of coal and sulfur-bearing fuel oils are burned. Particles
may act as reservoirs of acids, and thereby sustain a chemical
attack that will deteriorate even the more resistant kinds of ma-
sonry. Particles stick to surfaces, forming a film of tarry soot
and grit which oftentimes is not washed away by rain. Considera-
ble money and effort have been spent in many cities to sandblast
the sooty layers that accumulate on buildings. Water-soluble salts,
commonly found in urban atmospheres, can blister paint. Other
particles may settle on newly painted surfaces, causing imperfec-
tions, thereby increasing the frequency with which a surface must
be painted.
-------
GUIDELINES AND REPORTS 2667
The soiling of textiles by the deposition of dust and soot on
fabric fibers not only makes them unattractive, and thereby dimin-
ishes their use, but results in abrasive wear of the fabric when it
is cleaned. Vegetable fibers, such as cotton and linen, and synthetic
nylons are particularly susceptible to chemical attack by acid com-
ponents of airborne particles.
6. Economic Effects of Atmospheric Participate Matter
It is not possible at the present stage of knowledge to provide
accurate measures of all the costs imposed on society by particu-
late air pollution. Selected categories of effects can be quantified;
it is obvious that these estimates represent a significant under-
statement of the total cost.
7. Effects on Vegetation
Relatively little research has been carried out on the effects of
particulate air pollution on vegetation, and much of the work that
has been performed has dealt with specific dusts, rather than the
conglomerate mixture normally encountered in the atmosphere.
This document reports briefly on some of these specific particulate
studies only to illustrate the possible mechanisms through which
particulate matter may affect vegetation. This information is not
presented for the purpose of establishing air quality standards on
these specific pollutants.
There is considerable evidence that cement-kiln dusts can dam-
age plants. A marked reduction in the growth of poplar trees 1
mile from a cement plant was observed after cement production
was more than doubled. Plugging of stomates by the dust may
have prevented the exchange of gases in leaf tissue that is neces-
sary for growth and development. Moderate damage to bean
plants occurred when the plant leaves were dusted at the rate of
0.47 mg/cm2-day (400 tons/m2-month) for 2 days and then ex-
posed to natural dew. The mechanism through which the leaves
are damaged is not entirely understood, but direct alkaline damage
to tissues beneath the crust formed by the dust and moisture has
been observed. The deposits may also plug stomates and block
light needed for photosynthesis. Cement-kiln dusts may change the
alkalinity of soils to benefit or harm vegetation, depending on the
species.
Dust deposits may also eliminate predators, and thereby bring
on increased insect injury to plants; they may interfere with pol-
len germination; and they may make plants more susceptible to
pathogens.
-------
2668 LEGAL COMPILATION—AIK
Fluoride dusts apparently have a difficult time penetrating leaf
tissue in physiologically active form, and they are much less dam-
aging to vegetation than is gaseous fluoride. Soluble fluoride dusts
may be absorbed by the plant, but the amount is relatively small
compared to that which can enter the plant in gaseous form. The
evidence suggests that there is little effect on vegetation at fluor-
ide particulate concentrations below 2 /xg/m3. Concentrations of
this magnitude and above can sometimes be found in the immedi-
ate vicinity of sources of fluoride particulate pollution; they are
rarely found in urban atmospheres.
Ingestion of particles deposited on -plants can be harmful to
animal health. Fluorosis and arsenic poisoning have been brought
on through this medium.
Soot may clog stomates and may produce necrotic spotting if it
carries with it a soluble toxicant, such as one with excess acidity.
Magnesium oxide deposits on soils have been shown to reduce
plant growth, while iron oxide deposits on soils have been shown
to reduce plant growth, while iron oxide deposits appear to have
no harmful effects, and may be beneficial.
8. Effects on Public Concern
Several studies indicate that there is a relationship between
levels of particulate pollution, used as an index of air pollution,
and levels of public concern over the problem. A study conducted
in 1963 in the St. Louis metropolitan region found a direct linear
relationship between the fraction of a community's population
who said air pollution was a nuisance, and the annual mean con-
centration of particulate air pollution in the community. The rela-
tionship, which was derived from data on communities in the St.
Louis area whose annual concentrations ranged from 50 jug/m3 to
200 ,«g/in3, was formulated as:
y = 0.3x-14
where y = population fraction (%) concerned, and
x = annual geometric mean particle concentration (/ig/m3).
It is thought that the reaction to suspended particulates as a
nuisance probably occurs at peak concentrations, and not necessar-
ily at the values representing annual means. However, the rela-
tionship provides a useful example of how the nuisance effect of
air pollution relates to concentrations. Approximately 10 percent
of the study population considered air pollution a nuisance in
areas with suspended particulates at an annual geometric mean
concentration of 80 /tg/m3. At this same level of pollution, 30
-------
GUIDELINES AND REPORTS 2669
percent of the study population was "aware of" air pollution. In
areas with 120 /xg/m3( annual geometric mean), 20 percent were
"bothered by" and 50 percent were "aware of" air pollution; in
areas with an annual geometric mean of 160 /xg/m3, one-third of
the population interviewed were "bothered by" and three-fourths
were "aware of" air pollution.
Although data from other studies do not readily lend themselves
to quantitative formulation, they do, in general, support the rela-
tionship reported by the St. Louis study. A study of communities
in the Nashville, Tennessee, metropolitan area in 1957 found that
at least 10 percent of the population expressed concern about the
nuisance of air pollution at dustfall levels exceeding 10 tons/mi2-
month.
9. Suspended Particles as a Source of Odor
*
Particulate air pollution is not ordinarily considered a signifi-
cant source of odors. However, there is evidence that liquid and
even solid particles of some substances may be volatile enough to
vaporize in the nasal cavity, and produce sufficient gaseous mate-
rial to stimulate the sense of smell. Further, particles may carry
absorbed odorants into the nasal cavity, and there transfer them
to olfactory receptors. A survey of State and local air pollution
control officials revealed that approximately one-fourth of the
most frequently reported odors are those which are known to be,
or are suspected to be, associated with particulate air pollution.
The sources of these odorous particles are diverse, including diesel
and gasoline engine exhausts, coffee-roasting operations, paint
spraying, street paving, and the burning of trash.
B. CONCLUSIONS
The conclusions which follow are derived from a careful evalua-
tion by the National Air Pollution Control Administration of the
foreign and American studies cited in previous chapters of this
document. They represent the Administration's best judgment of
the effects that may occur when various levels of pollution are
reached in the atmosphere. The data from which the conclusions
were derived, and the qualifications which should be considered in
using the data, are identified by chapter reference in each case.
1. Effects on Health
Analyses of numerous epidemiological studies clearly indicate
an association between air pollution, as measured by particulate
-------
2670 LEGAL COMPILATION—Am
matter accompanied by sulfur dioxide, and health effects of vary-
ing severity. This association is most firm for the short-term air
pollution episodes.
There are probably no communities which do not contain indi-
viduals with impaired health who are particularly susceptible to
the adverse effects of elevated levels of particulate matter and
sulfur oxides. However, to show small changes in deaths asso-
ciated with coincident higher levels of air pollutants requires ex-
tremely large populations. In small cities, these changes are diffi-
cult to detect statistically.
The epidemiologic studies concerned with increased mortality
also show increased morbidity. Again, increases in morbidity as
measured, for example, by increases in hospital admissions or
emergency clinic visits, are most easily demonstrated in major
urban areas.
For the large urban communities which are routinely exposed to
relatively high levels of pollution, sound statistical analysis can
show with confidence the small changes in daily mortality which
are associated with fluctuation in pollution concentrations. Such
analysis has thus far been attempted only in London and in New
York.
The association between longer-term community exposures to
particulate matter and respiratory disease incidence and preva-
lence rates is conservatively believed to be intermediate in its relia-
bility. Because of the reenforcing nature of the studies conducted
to date, the conclusions to be drawn from this type of study can be
characterized as probable.
The association between long-term residence in a polluted area
and chronic disease morbidity and mortality is somewhat more
conjectural. However, in the absence of other explanations, the
findings of increased morbidity and of increased death rates for
selected causes, independent of economic status must still be con-
sidered consequential.
Based on the above guidelines the following conclusions are
listed in order of reliability, with the more reliable conclusions
first. Refer to Chapter 11 for cautions to be taken in comparing
British and American air quality measurement data.
a. AT CONCENTRATIONS OF 750 p.g/ms and higher for
particulates on a 24-hour average, accompanied by sulfur dioxide
concentrations of 715 /ig/m3 and higher, excess deaths and a
considerable increase in illness may occur. (British data; see
Chapter 11, Section C-l)
-------
GUIDELINES AND REPORTS 2671
b. A DECREASE FROM HO p.g/m! to 60 pg/m' (annual
mean) in particulate concentrations may be accompanied by a
decrease in mean sputum volume in industrial workers. (British
data; see Chapter 11, Section C-4)
c. IF CONCENTRATIONS ABOVE 300 g/m» for particu-
lates persist on a 24-hour average and are accompanied by sulfur
dioxide concentrations exceeding 630 fig/m3 over the same aver-
age period, chronic bronchitis patients will likely suffer acute
worsening of symptoms. (British data; see Chapter 11, Section
C-3)
d. AT CONCENTRATIONS OVER 200 ^g/ms for particulates
on a 24-hour average, accompanied by concentrations of sulfur
dioxide exceeding 250 j«g/m3 over the same average period, in-
creased absence of industrial workers due to illness may occur.
(British data; see Chapter 11, Section C-5)
e. WHERE CONCENTRATIONS RANGE FROM 100 ^g/ms
to 130 /j.g/ms and above for particulates (annual mean) with
sulfur dioxide concentrations (annual mean) greater than 120
/ig/m3, children residing in such areas are likely to experience
increased incidence of certain respiratory diseases.
f. AT CONCENTRATIONS ABOVE 100 ^g/ms for particu-
lates (annual geometric mean) with sulfation levels above 30
mg/cm2-mo., increased death rates for persons over 50 years of
age are likely. (American data; see Chapter 11, Section C-2)
g. WHERE CONCENTRATIONS RANGE FROM 80 t>.g/m3 to
100 p.g/ms for particulates (annual geometric mean) with sulfa-
tion levels of about 30 mg/cm2-mo., increased death rates for
persons over 50 years of age may occur. (American data; see
Chapter 11, Section C-2)
2. Effects on Direct Sunlight
AT CONCENTRATIONS RANGING FROM 100 ^.g/m3 to 150
lj.g/ms for particulates, where large smoke turbidity factors per-
sist, in middle and high latitudes direct sunlight is reduced up to
one-third in summer and two-thirds in winter. (American data;
see Chapter 2, Section C-2)
3. Effects on Visibility
AT CONCENTRATIONS OF ABOUT 150 ^g/m3 for particu-
lates, where the predominant particle size ranges from 0.2 ^ to 1.0
P. and relative humidity is less than 70 percent, visibility is re-
duced to as low as 5 miies. (American data ; see Chapter 3, Section
-------
2672 LEGAL COMPILATION—Am
4. Effects on Materials
AT CONCENTRATIONS RANGING FROM 60 pg/m* (annual
geometric mean), to 180 pg/m3 for particulates (annual geomet-
ric mean), in the presence of sulfur dioxide and moisture, corro-
sion of steel and zinc panels occurs at an accelerated rate. (Ameri-
can data; see Chapter 4, Section B)
5. Effects on Public Concern
AT CONCENTRATIONS OF APPROXIMATELY 70 ^g/vn"
for particulates (annual geometric mean), in the presence of other
pollutants, public awareness and/or concern for air pollution may
become evident and increase proportionately up to and above con-
centrations of 200 /*g/m3 for particulates. (See Chapter 7, Sec-
tion B-l)
C. RESUME
In addition to health considerations, the economic and aesthetic
benefits to be obtained from low ambient concentrations of partic-
ulate matter as related to visibility, soiling, corrosion, and other
effects should be considered by organizations responsible for pro-
mulgating ambient air quality standards. Under the conditions
prevailing in areas where the studies were conducted, adverse
health effects were noted when the annual geometric mean level of
particulate matter exceeded 80 /xg/m3. Visibility reduction to about
5 miles was observed at 150 /tg/rn3, and adverse effects on materi-
als were observed at an annual mean exceeding 60 /*g/m8. It is
reasonable and prudent to conclude that, when promulgating am-
bient air quality standards, consideration should be given to re-
quirements for margins of safety which take into account long-
term effects on health and materials occurring below the above
levels.
4.2a(4) "CRITERIA FOR PHOTOCHEMICAL OXIDANTS"
National Air Pollution Control Administration, March 1970
CRITERIA FOR PHOTOCHEMICAL OXIDANTS
(Summary of "Air Quality Criteria for Photochemical Oxidants,"
published by the National Air Pollution Control Administration in
March 1970
A. INTRODUCTION
This document is a consolidation and assessment of the current
state of knowledge on the origin and effects of the group of air
-------
GUIDELINES AND REPORTS 2673
pollutants known as photochemical oxidants on health, vegetation,
and materials. The purpose of this chapter is to provide a concise
picture of the information contained in this document, including
conclusions which are believed reasonable to consider in evaluat-
ing concentrations of photochemical oxidants which are known to
have an effect on either health or welfare. Although nitrogen
dioxide is considered one of the photochemical oxidants, it is to be
the subject of a separate report. Consequently, nitrogen dioxide is
discussed in this document only to the extent that it participates
in the formation and reactions of other photochemical oxidants.
The information and data contained in this document comprise the
best available bases, and provide the rationale for development of
specific levels of standards of photochemical oxidants in the am-
bient air for protection of public health and man's environment.
B. NATURE OF PHOTOCHEMICAL OXIDANTS
Photochemical oxidants result from a complex series of atmos-
pheric reactions initiated by sunlight. When reactive organic sub-
stances and nitrogen oxides accumulate in the atmosphere and are
exposed to the ultraviolet component of sunlight, the formation of
new compounds, including ozone and peroxyacyl nitrates, takes
place.
Absorption of ultraviolet light energy by nitrogen dioxide re-
sults in its dissociation into nitric oxide and an oxygen atom.
These oxygen atoms for the most part react with air oxygen to
form ozone. A small portion of the oxygen atoms and ozone react
also with certain hydrocarbons to form free radical intermediates
and various products. In some complex manner, the free radical
intermediates and ozone react with the nitric oxide produced ini-
tially. One result of these reactions is the very rapid oxidation of
the nitric oxide to nitrogen dioxide and an increased concentration
of ozone.
The photochemical system generally is capable of duplication in
the laboratory. For various reasons, however, laboratory results
cannot be quantitatively extrapolated to the atmosphere. Theoreti-
cally generation of an atmospheric simulation model should be
feasible, enabling the prediction of ambient oxidant concentrations
from a knowledge of emission and meteorological data. The devel-
opment of such a model, however, is dependent on the acquisition
of more reliable and applicable quantitative information derived
from direct atmospheric observations, as well as on the refinement
of results obtained from irradiation chamber studies.
-------
2674 LEGAL COMPILATION—AIR
C. ATMOSPHERIC PHOTOCHEMICAL OXIDANT
CONCENTRATIONS
The presence of photochemically formed oxidants has been indi-
cated in all of the major U.S. cities for which aerometric data
have been examined. On a concentration basis, ozone has been
identified as the major component of the oxidant levels observed.
Difficulties arise, however, in interpreting data obtained by the
most commonly used oxidant measuring method; this method is
nonspecific and subject to several interferences. Adjusted oxidant
concentrations, obtained by correcting potassium iodide oxidan1"
measurements for known interferences, have been found to be
relatively close to concurrent measurements of ozone alone.
Since photochemical oxidants are the products of atmospheric
chemical reactions, the relationship between precursor emissions
and atmospheric oxidant concentrations is much less direct than is
the case for primary pollutants. A further complicating situation
is the dependence of these photochemical reactions on intensity
and duration of sunlight, and on temperature.
In an analysis of oxidant concentration data for 4 years and 12
stations, the daily maximum 1-hour average concentration was
equal to or exceeded 290 jug/m3(0.15 ppm) up to 41 percent of the
time; maximum 1-hour average concentrations ranged from 250 to
1,140 ^g/m3(0.13 to 0.58 ppm) ; short-term peaks were as high as
1,310 /ig/m3(0.67 ppm). Yearly averages, commonly applied to
other pollutants, are not representative of air quality with respect
to oxidant pollution, because 1-hour average ozone concentrations
will necessarily be at or about zero for approximately 75 percent
of the time when photochemical reactions are minimal.
Peroxyacyl nitrates, though not routinely measured, have been
identified in the atmosphere of several cities. These compounds
may be assumed to be present whenever oxidant levels are ele-
vated.
D. NATURAL SOURCES OF OZONE
Ozone can be formed naturally in the atmosphere by electrical
discharge, and in the stratosphere by solar radiation, by processes
which are not capable of producing significant urban concentra-
tions of this pollutant. Maximum instantaneous ozone levels of
from 20 to 100 //.g/m3(0.01 to 0.05 ppm) have been recorded in
nonurban areas.
-------
GUIDELINES AND REPORTS 2675
E. MEASUREMENT OF PHOTOCHEMICAL OXIDANTS
The most widely used technique for the analysis of atmospheric
total oxidants is based on the reaction of these compounds with
potassium iodide to release iodine. The iodine may then be meas-
ured by either colorimetric or coulometric methods. Calibrating
the oxidant measurement method used against a known quantity
of ozone provides a measurement of the net oxidizing properties of
the atmosphere in terms of an equivalent concentration of ozone.
Most oxidant measurements are currently being made by the col-
orimetric method, although coulometric analyzers are used in a
number of laboratory and field studies.
In order to generate comparable data, it is essential that all
measurements be made by techniques which have been calibrated
against the same standard or reference method. Since at the pres-
ent time there is no standard method for the determination of
total oxidants, the National Air Pollution Control Administration
recommends use of the neutral-buffered 1 percent potassium iodide
colorimetric technique as the method against which all instru-
ments and other methods should be compared. In addition to serv-
ing as a manual procedure for determining oxidants, the reference
method may be used in conjunction with a "dynamic calibration"
technique for instrumental methods.
Reducing agents such as sulfur dioxide produce a negative in-
terference in oxidant determination. Such interference can be re-
duced, however, by passing the air stream through a chromium
trioxide scrubber prior to measurement. Unfortunately, a portion
of the nitric oxide which may be present in the air stream is
oxidized to nitrogen dioxide by the scrubber. This results in an
apparent increase in the oxidant measurement of about 11 percent
of the concentration of nitric oxide. Moreover, a portion of the
atmospheric nitrogen dioxide concentration will also contribute to
the oxidant measurement. Peroxyacyl nitrate concentrations are
usually small and contribute only a very slight amount to the
oxidant reading.
There are several means for the specific measurement of atmos-
pheric ozone. Instrumental methods include chemiluminescent
analysis based on the reaction of ozone with Rhodamine B, gas
phase olefm titration, and ultraviolet and infrared spectroscopy. A
semiquantitative method for ozone measurement is based on its
ability to produce cracks in stretched rubber. Peroxyacyl nitrates
can be measured in the atmosphere by gas chromatography with
the use of an electron-capture detector.
-------
2676 LEGAL COMPILATION—Am
For a better evaluation of the results of research on the effects
of photochemical oxidants, it is essential that data be obtained for
individual oxidants such as nitrogen dioxide, ozone, PAN, formal-
dehyde, acrolein, and organic peroxides. These data would either
replace or complement data on total oxidants. Instrumentation
currently available permits the accurate measurement of atmos-
pheric ozone, nitrogen dioxide, and PAN. There exists, however, a
further need to develop instruments capable of measuring other
individual gaseous pollutants which have the properties of oxi-
dants. Photochemical reactions and problems derived from oxi-
dants can be much better denned using specific methods for meas-
urement in preference to the traditional total oxidants determina-
tion.
F. EFFECTS OF PHOTOCHEMICAL OXIDANTS ON
VEGETATION AND MICROORGANISMS
Injury to vegetation is one of the earliest manifestations of
photochemical air pollution, and sensitive plants are useful biolog-
ical indicators of this type of pollution. The visible symptoms of
photochemical oxidant produced injury to plants may be classified
as; (1) acute injury, identified by cell collapse with subsequent
development of necrotic patterns; (2) chronic injury, identified by
necrotic patterns with or without chlorotic or other pigmented
patterns; and, (3) physiological effects, identified by growth alter-
ations, reduced yields, and changes in the quality of plant prod-
ucts. The acute symptoms are generally characteristic of a specific
pollutant; though highly characteristic, chronic injury patterns
are not. Ozone injury to leaves is identified as a stippling or
flecking. Such injury has occurred experimentally in the most
sensitive cities after exposure to 60 jug/ms(0.03 ppm) ozone for 8
hours. Injury will occur in shorter time periods when low levels
of sulfur dioxide are present. PAN-produced injury is character-
ized by an under-surface glazing or bronzing of the leaf. Such
injury has occurred experimentally in the most sensitive species
after exposure to 50 /ig/m3(0.01 ppm) PAN for 5 hours. Leaf
injury has occurred in certain sensitive species after a 4-hour
exposure to 100 /*g/m3 (0.05 ppm) total oxidant. Ozone appears
to be the most important phytotoxicant in the photochemical com-
plex.
There are a number of factors affecting the response of vegeta-
tion to photochemical air pollutants. Variability in response is
known to exist between species of a given genus and between
-------
GUIDELINES AND REPORTS 2677
varieties within a given species; varietal variations have been
most extensively studied with tobacco. The influence of light inten-
sity on the sensitivity of plants to damage during growth appears
to depend on the phytotoxicant. Plants are more sensitive to PAN
when grown under high light intensities, but are more sensitive to
ozone when grown under low light intensities. Reported findings
are in general agrement that sensitivity of greenhouse-grown
plants to oxidants increases with temperature, from 10° to 38°
C(40° to 100° F), but this positive correlation may result from
the overriding influence of light intensity on sensitivity. The ef-
fects of humidity on the sensitivity of plants has not been well
documented. General trends indicate that plants grown and/or
exposed under high humidities are more sensitive than those
grown at low humidities. There has been little research in this
direction, but there are indications that soil factors such as
drought and total fertility influence the sensitivity of plants to
phytotoxic air pollutants. The age of the leaf under exposure is
important in determining its sensitivity to air pollutants.
There is some evidence that oxidant or ozone injury may be
reduced by pretreatment with the toxicant.
Identification of injury to a plant as being caused by air pollu-
tion is a difficult undertaking. Even when the markings on the
leaves of a plant may be identified with an air pollutant, there is
the further difficulty of evaluating the injury in terms of its effect
on the intact plant. Additional problems arise in trying to evaluate
the economic impact of air pollution damage to a plant.
The interrelations of time and concentration (dose) as they
affect injury to plants are essential to air quality criteria. There
are, however, only scant data relating concentrations and length
of photochemical oxidant exposure to chronic inj ury and effects on
reduction of plant growth, yield, or quality. There is also a dearth
of information relating concentrations to acute injury. A larger
body of information exists on the acute effects of ozone, but even
in this instance, the information is far from complete. Sufficient
data do exist, however, to tabularly present ozone concentrations
which will produce 5 percent injury to sensitive, intermediate, and
resistant plants after a given short-term exposure, as shown in
Table 10-1. Information available lists 20 species and/or varieties
as sensitive, 55 as intermediate in sensitivity, and 64 as relatively
resistant.
Bacteriostatic and bacteriocidal properties of photochemical oxi-
dants in general have been demonstrated. The growth suppression
of microorganisms by ozone is a well-known phenomenon, al-
-------
2678 LEGAL COMPILATION—AIR
though the ozone concentrations for this activity are undesirable
from a human standpoint. The bacteriocidal activity of ozone var-
ies with its concentration, the relative humidity, and the species of
bacteria.
G. EFFECT OF OZONE ON MATERIALS
The detailed, quantitative extent of damage to materials caused
by atmospheric levels of ozone is unknown, but generally any
organic material is adversely affected by concentrated ozone.
Many polymers are extremely sensitive to even very small concen-
trations of ozone, this sensitivity increasing with the number of
double bonds in the structure of the polymer.
Economically, rubber is probably the most important material
sensitive to ozone attack, particularly styrene-butadiene, natural,
polybutadiene, and synthetic polyisoprene. Antiozonant additives
have been developed and are capable of protecting elastomers
from ozone degradation; synthetic rubbers with inherent resist-
ance to ozone are also available. These additives are expensive,
however, and add to the cost of the end product; in addition,
increasing amounts of antiozonants are required as the amount of
ozone which is to be encountered increases, and sometimes only
temporary protection is provided.
Ozone attacks the cellulose in fabrics through both a free radi-
cal chain mechanism and an electrophilic attack on double bonds;
light and humidity appear necessary for appreciable alterations to
occur. The relative susceptibility of different fibers to ozone attack
appears to be, in increasing order, cotton, acetate, nylon, and
polyester.
TABLE 10-1.-PROJECTED OZONE CONCENTRATIONS WHICH WILL PRODUCE, FOR SHORT-TERM EXPOSURES,
5 PERCENT INJURY TO ECONOMICALLY IMPORTANT VEGETATION GROWN UNDER SENSITIVE CONDITIONS
0.2
0.5
1.0
2.0
4.0
8.0
Ozone concentrations producing injury in three types of plants, ppm
Sensitive
0.35-0.75
0.15-0.30
0.10-0.25
0.07-0.20
0.05-0.15
0.03-0.10
Intermediate
0.70-1.00
0.25-0.60
0.20-0.40
0.15-0.30
0.10-0.25
0.08-0.20
Resistant
0.90 and up.
0.50 and up.
0.35 and up.
0.25 and up.
0.20 and up.
0.15 and up.
Certain dyes are susceptible to fading during exposure to ozone.
The rate and extent of fading is also dependent upon other envi-
ronmental factors such as relative humidity and the presence of
air pollutants other than ozone, as well as the length and concen-
tration of ozone exposure and the type of material exposed.
-------
GUIDELINES AND REPORTS 2679
H. TOXICOLOGICAL STUDIES OF PHOTOCHEMICAL
OXIDANTS
1. Effects of Ozone in Animals
The major physiological effects of ozone are on the respiratory
system. Inhalation of ozone at concentrations greater than about
5,900 /xg/m3(3 ppm) for several hours produces hemorrhage and
edema in the lungs. This reaction can be fatal to animals. Rats and
mice appear to be more sensitive than rabbits, cats, and guinea
pigs. The toxicity is greater for young animals and for exercising
animals. It is abated by intermittency of exposure, by prophylactic
administration of chemical reducing agents, or by introducing
agents into the diet which reduce the activity of the thyroid gland.
At exposures less than those which produce edema in the lungs,
changes in the mechanical properties of the lung occur. These are
accompanied by increased breathing rates and increased oxygen
consumption. Repeated non-fatal exposures to concentrations
greater than 15,700 /xg/m3(8 ppm) for 30 minutes have produced
fibrosis in the respiratory tract of rabbits, with the damage in-
creasing in severity over the length of the respiratory tract from
the trachea to the bronchioles.
Short-term exposures to ozone also produce chemical changes in
the lung tissue elements of animals. A study conducted on a small
number of rabbits showed that inhalation of 1,960 to 9,800 ^g/
m3(l to 5 ppm) ozone for 1 hour can produce denaturation of the
structural lung proteins. Ozone also appears to oxidize the sulfhy-
dryl groups of amino acids in the lung.
Short-term exposures to ozone also produce changes in organs
other than the lung. Concentrations of 5,900 ^g/m3 (3 ppm) for
20 hours can stimulate some adaptive liver enzymes. Inhalation of
390 to 490 Aig/m3(0.2 to 0.25 ppm) ozone for 30 to 60 minutes
makes the red blood cells of mice, rabbits, rats, and man more
sensitive to the shape-altering effects of irradiation. Exposure of
blood to ozone in vitro produces interference with the release of
oxygen from red blood cells; this suggests that ozone exposure
could impair the delivery of oxygen to the tissues. Ozone expo-
sures at concentrations from 1,310 to 7,800 /<.g/m3( 0.67 to 4.0
ppm) have been shown to reduce the in vitro phagocytic abilities
of the pulmonary alveolar macrophages. A 3-hour exposure to
9,800 /*g/m3(5 ppm) ozone has been shown to reduce the activity
of bactericidal enzyme, presumably due to in vivo oxidation of the
enzyme.
Ozone inhalation increases the vulnerability of animals to other
-------
2680 LEGAL COMPILATION—Am
agents. A single exposure to ozone at a concentration of 160
m3(0.08 ppm) for 3 hours has increased the mortality among
mice from inhalation of pathogenic bacteria. This occurred when
the bacteria were administered both before and after exposure to
ozone. Ozone also increases the toxicity of histamine in guinea
pigs.
Long-term effects of ozone exposure include, in some species, the
development of tolerance to biological effects of ozone, production
of fibrotic changes in the lungs, and a possible increase in the rate
of aging. While tolerance has been shown in rodents, it has not
been shown in chickens, and it is not certain whether or not it
occurs in man. In species where tolerance to ozone exposure has
been demonstrated, information is not available concerning the
duration and mechanism of tolerance following repeated exposure.
The aging may be similar to the changes produced by exposure
to free radicals or by irradiation.
2. Effects of Ozone in Humans
Some studies of human exposures to ozone have focused on the
determination of the threshold level at which odor can be detected,
and on the occurrence of changes in pulmonary function. Nine out
of 10 subjects exposed to 40 /xg/ms(0.02 ppm) ozone were able to
detect the odor immediately, and it persisted for an average of 5
minutes. Thirteen of 14 subjects exposed to 100 fig/in3 (0.05 ppm)
ozone indicated the odor is considerably stronger at this concen-
tration, and the odor persisted for an average of 13 minutes.
Occupational exposure of humans to ozone concentrations of up
to 490 /Ag/m3 (0.25 ppm) has not produced detectable changes in
pulmonary function. Respiratory symptoms and a decrease in vital
capacity in three out of seven smokers who had been occupation-
ally exposed to ozone have occurred at concentrations greater than
590/ig/m3 (0.3 ppm).
Experimental exposures of humans have been carried out at
concentrations ranging from 200 to 7,800 /j.g/m3 (0.1 to about 4
ppm) for periods of up to 2 hours. Exposure to 390 jug/m3(0.2
ppm) for 3 hours daily, 6 days a week, for 12 weeks has not
produced any change in ventilatory function tests. Similar expo-
sure to 980 jug/m3(0.5 ppm) produced a decrease in the forced
expiratory volume during the last 4 weeks of exposure, with re-
covery taking place in a subsequent 6-week period. In each of 11
subjects, exposure to 1,180 to 1,570 j«g/m3(0.6 to 0.8 ppm) for 2
hours resulted in an impairment of the diffusing capacity of the
lung. Small decreases in vital capacity and forced expiratory vol-
526-705 O - 74 - 22
-------
GUIDELINES AND REPORTS 2681
ume were observed in some of these subjects. Resistance to flow of
air in the respiratory tract increased slightly in some subjects
after exposure to 200 to 1,180 ^g/m3(0.1 to 0.6 ppm) for 1 hour,
and increased consistently in each of four subjects after exposure
to 1,960 ng/m3(l ppm) for 1 hour.
Data obtained from animal experimentation cannot be used di-
rectly to define the ozone concentrations above which human
health will be affected. Animal mortality studies, however, can be
useful in determining the factors involved in toxicity. While the
concentrations of ozone used in the determination of short-term
non-fatal effects in animals are rarely found in ambient air, the
changes in pulmonary function observed during and after expo-
sure to these concentrations call attention to the possibility that
similar effects may be observed in humans.
When interpreting the research conducted thus far using human
subjects, it must be noted that occupational exposures differ from
experimental exposures, because it is difficult in an occupational
environment to define the exact nature and dose of the pollutants
present.
3. Effects of Peroxyacetyl Nitrate
Experimental studies with peroxyacetyl nitrate (PAN) in ani-
mals indicate that mortality may be delayed for 7 to 14 days after
exposure; however, the exposure levels required to produce this
mortality never occur in ambient atmospheres.
A single experimental study of healthy human subjects exposed
to 1,485 ^g/ma (0.3 ppm) peroxyacetyl nitrate indicated only
that there may be a small increase in oxygen uptake with exercise.
Sensitive pulmonary function tests were not obtained.
The data from animal and human studies are sparse and inade-
quate for determining the toxicological potential of peroxyacetyl
nitrate. It would appear, however, that at the concentrations of
this compound known to occur in ambient atmospheres, PAN does
not present any recognized health hazard.
4. Effects of Mixtures Containing Photochemical Oxidants on Animals
Studies have been conducted on animals exposed to both syn-
thetic and natural photochemical smog. Synthetic smog has been
produced by the irradiation of diluted motor vehicle exhaust or by
irradiation of air mixtures containing nitrogen oxides and certain
hydrocarbons. Exposures to irradiated motor vehicle exhaust are
complicated by the simultaneous presence of carbon monoxide and
-------
2682 LEGAL COMPILATION — AIR
other non-oxidant substances which include high concentrations of
formaldehyde. Guinea pigs show increased respiratory volume
during a four-hour exposure to irradiated exhaust containing
1,570 fig/m3 (0.8 ppm) total oxidant.
Exposure of mice to both natural and synthetic smog for 3
hours, at concentrations greater than 780 /xg/m3(0.4 ppm) oxi-
dants have produced changes in the fine structure of the lung. The
nature and extent of the damage was the same after exposure to
either type of smog with the same oxidant levels. The severity of
the damage increased with age and became irreversible at age 21
months.
Chronic exposure of guinea pigs to ambient air with an average
oxidant concentration of from 40 to 140 /xg/m3 (0.02 to 0.07
ppm) leads to a significant increase in flow resistance when the
peak oxidant concentrations exceed 980 /xg/m3 (0.5 ppm) .
When male mice, prior to mating, were given long-term expo-
sures to irradiated auto exhaust containing from 200 to 1,960
/xg/m3 (0.1 to 1.0 ppm) oxidant, a decrease in fertility and an
increase in neonatal mortality of their offspring resulted ; the irra-
diated mixture also contained varying concentrations of carbon
monoxide, nitrogen oxides, and hydrocarbons. Similar exposures
also cause a reduction in spontaneous running activity, which re-
sults in an adaptation response.
Thus a number of experimental studies have demonstrated that
changes in lung tissue or lung function occur when animals are
exposed for several hours to photo-oxidized mixtures containing
980 jug/m3 (0.5 ppm) or more of oxidants.
5. Effects of Mixtures Containing Photochemical Oxidants on Humans
Laboratory studies of human exposure to photochemical smog
have involved primarily the measurement of eye irritation. Based
on the existing data, it appears that: (1) the effective eye irri-
tants are the products of photochemical reactions; (2) although
oxidant concentrations may correlate with the severity of eye irri-
tation, a direct cause-effect relationship has not been demonstrated
since ozone, the principal contributor to ambient oxidant levels is
not an eye irritant; (3) the precursors of the eye irritants are
organic compounds in combination with oxides of nitrogen, the
most potent being aromatic hydrocarbons; (4) the chemical iden-
tities of the effective irritants in synthetic systems are known as
being formaldehyde, peroxybenzoyl nitrate (PBzN), peroxyacetyl
nitrate (PAN) , and acrolein, although the latter two contribute to
-------
GUIDELINES AND REPORTS 2683
only a minor extent; and (5) the substances causing eye irritation
in the atmosphere have not been completely denned.
I. EPIDEMIOLOGICAL STUDIES OF PHOTOCHEMICAL
OXIDANTS
Several studies have examined daily mortality rates in localities
where photochemical air pollution occurs, to determine if a rela-
tionship exists with increased levels of oxidant. Such an associa-
tion has not been shown. These studies, however, pose a number of
unresolved questions. One of these is, what is the effect of temper-
ature, either alone or in combination with oxidants? In some of
the most severe episodes, there has been an associated increase in
environmental temperature, sufficient to cause excess mortality by
itself. Several studies of mortality among residents in nursing
homes in Los Angeles showed such excess mortality. In recent heat
wave and air pollution episodes, however, large proportions of the
elderly and ill persons in nursing homes have been protected by
air conditioning.
Evidence of increased morbidity has been sought through study
of general hospital admissions, but no unequivocal association be-
tween photochemical air pollution and increased morbidity has
been shown. Additional studies are indicated for improved defini-
tion. Peak oxidant values of 250 /xg/m3 (0.13 ppm), which might
be expected in relation to maximum hourly average levels of 100
to 120 ^g/m3 (0.05 to 0.06 ppm), have been associated with
aggravation of asthma. No association between ambient oxidant
concentrations and changes in respiratory symptoms or function
was shown, however, in two separate studies of subjects with
preexisting chronic respiratory disease. Non-smoking subjects
with chronic respiratory disease did, however, demonstrate less
airway resistance when they were studied in a room where the
ambient air of Los Angeles was filtered before entry. No acute or
chronic effects of oxidant pollution on ventilatory performance of
elementary schoolchildren were demonstrated in a study conducted
in two communities within the Los Angeles basin.
Impairment of performance by high school athletes has been
observed when photochemical oxidants ranged from 60 to 590
/tg/m3 (0.03 to 0.3 ppm) for 1 hour immediately prior to the
start of activities. Significantly, more automobile accidents have
also occurred on days of high oxidant concentrations, but no
threshold level for this effect could be determined from the analy-
sis.
-------
2684 LEGAL COMPILATION—AIR
Among the general community, eye irritation is a major effect
of photochemical air pollution. In Southern California, it has af-
fected more than three-fourths of the population. Eye irritation
under conditions prevalent in Los Angeles is likely to occur in a
large fraction of the population when oxidant concentrations in
ambient air increases to about 200 ^g/m3 (0.10 ppm). This oxi-
dant value might be expected to be associated with a maximum
hourly average oxidant concentration of 50 to 100 ^g/m3 (0.025
to 0.50 ppm), depending on localized conditions. According to sur-
vey data gathered in 1956, asthma, cough, and nose and throat
complaints were more frequent in Los Angeles, Orange, and San
Diego counties than in the San Francisco Bay area or in the rest
of the State.
Casual reports of the presence of the symptoms of eye irritation
have been recorded in many cities in the United States. Epidemio-
logic studies have been inadequate, however, to relate these symp-
toms clearly to measured exposures to photochemical oxidants. In
fact, one of the major photochemical oxidants, ozone, is not an eye
irritant. That eye irritation is experienced whenever the oxidant
level exceeds a certain value is an indication that oxidant concen-
trations correlate well with other aspects of the photochemical
complex; oxidant levels are probably a measure of the photochemi-
cal activity which produces the eye irritants. On the other hand, it
must be recognized that reactions of ozone with hydrocarbons do
lead to hydrocarbon fragments which are eye irritants. Nor can
the possibility be discounted that ozone in the photochemical com-
plex may exert a synergistic effect on eye irritation. Because the
oxidant reading measured only the net oxidizing property of the
atmosphere, however, the same amount of eye irritation experi-
enced in two different geographical locations from identical irri-
tants could be associated with different levels of oxidant, if other
pollutants differed in their concentration.
J. AREAS FOR FUTURE RESEARCH
1. Environmental Aspects of Photochemical Oxidants
1. Research should be conducted to further identify the sub-
stance (s) which cause eye irritation.
2. The nature of the photochemical aerosol, its behavior at dif-
ferent pressures of water vapor, and the nature of the surface
layer of the particulates remains to be determined.
3. The role of sulfur dioxide in the formation of photochemical
aerosols and in the impairment of visibility should be investigated.
-------
GUIDELINES AND REPORTS 2685
4. Mechanisms of photochemical oxidant formation should be
explained.
2. Toxicity of Ozone, Photochemical Oxidants, and Peroxyacyl Nitrates
1. The effect of ozone and PAN in combination with other pollu-
stance(s) which cause eye irritation.
information is available on the separate effects of ozone, nitrogen
dioxide, and sulfur dioxide, but data on the combined effects of
defined concentrations of these gases are sparse. The effect of
particulates (dust, saline droplets, oil, soots, etc.) should be deter-
mined alone and in combination with the gases. Additional varia-
bles such as humidity and temperature should be controlled and
recorded. These experiments should be carried out with materials,
vegetation, animals, and, under appropriate conditions, in man.
2. Experiments with human exposures to gas mixtures should
include a comparison between the respiratory effects shown in
healthy subjects and those shown in patients with chronic respira-
tory disease, care being taken to respect the rights of experimen-
tal subjects.
3. Existing data demonstrate that tolerance occurs only in ro-
dents. Indices other than mortality are required to demonstrate
tolerance in animals. If such indices can be developed, then a study
is needed to see if a similar phenomenon occurs in man.
4. The mechanisms of systemic effects of ozone (headache, fa-
tigue, impaired oxygen transport by hemoglobin, inability to con-
centrate, etc.) have yet to be explained.
5. The rate and site of uptake of ozone and its fate following
uptake should be determined in vegetation and animals.
6. The mechanism for the production of ozone-induced pulmo-
nary edema remains unexplained.
7. Additional research is needed to define the role of peroxyacyl
nitrates in the production of eye irritation.
3. Epidemiology of Photochemical Oxidants
1. Of high priority is the need to study eye and respiratory
irritation in metropolitan areas outside of California. Studies
should be supplemented by pulmonary function tests.
2. Although the effects of episodes of high pollution levels have
been studied with respect to mortality, morbidity, impairment of
performance, etc., additional studies are needed at different sites
and for different effects. These should include congenital malfor-
-------
2686 LEGAL COMPILATION—Am
mations, stillbirths, hospital admissions for miscarriage, and al-
terations in the sex ratio of newborns.
3. The examination of children has received insufficient atten-
tion in epidemiologic studies of the health effects of air pollution.
This should be undertaken with respect to the effects of photo-
chemical oxidants using simple pulmonary function tests. Empha-
sis should be placed on further studies of the incidence of asthma
attacks during episodes of high pollution.
K. CONCLUSIONS
Derived from a careful evaluation of the studies cited in this
document, the conclusions given below represent the best judg-
ment of the scientific staff of the National Air Pollution Control
Administration of the effects that may occur when various levels
of photochemical oxidants are reached in the ambient air. The
more detailed information from which the conclusions were de-
rived, and the qualifications that entered into the consideration of
these data, can be found in the appropriate chapter of this docu-
ment.
1. Human Exposure
a. Ozone
(1) Long-term exposure of human subjects.
(a) Exposure to a concentration of up to 390 /j.g/m3 (0.2 ppm)
for 3 hours a day, 6 days a week, for 12 weeks, has not produced
any apparent effects (Chapter 8, section B.2.)
(b) Exposure to a concentration of 980 jug/m3(0.5 ppm) for 3
hours a day, 6 days a week, has caused a decrease in the 1-second
forced expiratory volume (FEVi.0) after 8 weeks (Chapter 8,
section B.2.)
(2) Short-term exposure of human subjects.
(a) Exposure to a concentration of 40 ,ixg/m3(0.02 ppm) was
detected immediately by 9 of 10 subjects. After an average of 5
minutes exposure, subjects could no longer detect ozone (Chapter
8, section E.2).
(b) Exposure to a concentration of 590 jug/m3 (0.3 ppm) for 8
hours appears to be the threshold for nasal and throat irritation
(Chapter 8, section E.2.)
(c) Exposure to concentrations of from 1,180 to 1,960 jug/
m3(0.6 to 1.0 ppm) for 1 to 2 hours may impair pulmonary func-
tion by causing increased airway resistance, decreased carbon
monoxide diffusing capacity, decreased total capacity, and de-
-------
GUIDELINES AND REPORTS 2687
creased forced expiratory volume (Chapter 8, section B.2.)
(d) Exposure to concentrations of from 1,960 to 5,900 ^g/
m3(1.0 to 3.0 ppm) for 10 to 30 minutes is intolerable to some
people (Chapter 5, section B.2.)
(e) Exposure to a concentration of 17,600 /tg/m3 (9.0 ppm)
produces severe illness (Chapter 5, section B.2.)
b.Oxidants
(1) Long-term exposure of human subjects.
Exposure to ambient air containing an oxidant concentration of
about 250 /ng/m3(0.13 ppm) (maximum daily value) has caused
an increase in the number of asthmatic attacks in about 5 percent
of a group of asthmatic patients. Such a peak value would be
expected to be associated with a maximum hourly average concen-
tration of 100 to 120 jug/m3 (0.05 to 0.06 ppm) (Chapter 9,
section B.3.)
(2) Short-term exposure of human subjects.
(a) Exposure to an atmosphere with peak oxidant concentra-
tions of 200 ,ug/m3(0.1 ppm) and above has been associated with
eye irritation. Such a peak concentration would be expected to be
associated with a maximum hourly average concentration of 50 to
100 /jg/m3 (0.025 to 0.05 ppm) (Chapter 9, section B.3.)
(b) Exposure to an atmosphere with average hourly oxidant
concentrations ranging from 60 to 590 yug/m3(0.03 to 0.30 ppm)
has been associated with impairment of performance of student
athletes (Chapter 9, section B.4.)
2. Other Exposures
a. Photochemical Oxidants
(1) Effects on vegetation and laboratory animals.
(a) Exposure to concentrations of about 60 /*g/m3 (0.03 ppm)
ozone for 8 hours or to 0.01 ppm peroxyacetyl nitrate for 5 hours
has been associated with the occurrence of leaf lesions in the most
sensitive species, under laboratory conditions (Chapter 6, Section
E.)
(b) Exposure to ambient air containing oxidant concentrations
of about 100 /xg/m3(0.05 ppm) for 4 hours has been associated
with leaf injury to the most sensitive species (Chapter 6, Section
E.)
(c) Experimental exposures of laboratory animals to ozone con-
centrations of from 160 to 2,550 ju.g/m3(0.08 to 1.30 ppm) for 3
hours has resulted in increased susceptibility to bacterial infection
(Chapter 8, section B.I.)
-------
2688 LEGAL COMPILATION—AIR
b. Ozone Effects on Susceptible Materials
(1) Polymers.
(a) Many polymers, especially rubber, are extremely sensitive
to very small concentrations. To provide protection, antiozonant
additives are used, but are expensive and add to the cost of the
end product (Chapter 7).
(2) Cellulose and dyes.
(a) The cellulose in fabrics is attacked by ozone, with subse-
quent weakening of the fabric. Similarly, certain dyes are suscep-
tible to fading during exposure to ozone (Chapter 7). Tables 10-2
and 10-3 present these conclusions in tabular form. (Table 10-3
omitted.)
-------
GUIDELINES AND REPORTS
2689
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-------
2690 LEGAL COMPILATION—AIR
L. RESUME
Under the conditions prevailing in the areas where studies were
conducted, adverse health effects, as shown by impairment of per-
formance of student athletes, occurred over a range of hourly av-
erage oxidant concentration from 60 to 590 /ug/m3 (0.03 to 0.3
ppm). An increased frequency of asthma attacks in a small pro-
portion of subjects with this disease was shown on days when
oxidant concentrations exceeded peak values of 250 p.g/m? (0.13
ppm), a level that would be associated with an hourly average
concentration ranging from 100 to 120 ^g/m3 (0.05 to 0.06 ppm).
Adverse health effects, as manifested by eye irritation, were re-
ported by subjects in several studies when photochemical oxidant
concentrations reached instantaneous levels of about 200 jug/m3
(0.10 ppm), a level that would be associated with an hourly aver-
age concentration ranging from 60 to 100 jug/m3 (0.03 to 0.05
ppm).
Adverse effects on sensitive vegetation were observed from ex-
posure to photochemical oxidant concentrations of about 100 jug/
m3 (0.05 ppm) for 4 hours. Adverse effects on materials from
exposure to photochemical oxidants have not been precisely quan-
tified, but have been observed at the levels presently occurring in
many urban atmospheres.
It is reasonable and prudent to conclude that, when promulgat-
ing ambient air quality standards, consideration should be given
to requirements for margins of safety that would take into ac-
count possible effects on health, vegetation, and materials that
might occur below the lowest of the above levels.
4.2a(5) "CRITERIA FOR SULFUR OXIDES"
National Air Pollution Control Administration, January 1969
CRITERIA FOR SULFUR OXIDES
(Summary from "Air Quality Criteria for Sulfur Oxides" pub-
lished by the National Air Pollution Control Administration in
January 1969)
A. SUMMARY
1. General
This document presents criteria of air quality in terms of the
effects empirically obtained and published for various concentra-
tions of one family of pollutants, the sulfur oxides, their acids and
acid salts. These effects do not, for the most part, derive solely
-------
GUIDELINES AND REPORTS 2691
from the presence of sulfur oxides in the atmosphere. They are the
effects that have been observed when various concentrations of
sulfur oxides, along with other pollutants, have been present in the
atmosphere. Many of these effects are produced by a combination
of sulfur oxides pollution and undifferentiated particulate matter;
the contributions of each class are difficult to distinguish. More-
over, laboratory studies have shown that a combination of sulfur
oxides and particulates may produce an effect that is greater than
the sum of the effects caused by these pollutant classes individu-
ally. Because of the interactions between pollutants, and the reac-
tions of pollutants with oxygen and with water in the atmosphere,
and because of the influence of sunlight and temperature on these
reactions, the criteria for sulfur oxides can not be presented as
exact expressions of cause and effect that have been replicated
from laboratory to laboratory. They are presented as useful state-
ments of the effects that can be predicted when sulfur oxides are
present in the atmosphere; they are derived from a careful evalua-
tion of what has so far been reported.
The sulfur oxides are common atmospheric pollutants which
arise mainly from the combustion of fuels. Solid and liquid fossil
fuels contain sulfur, usually in the form of inorganic sulfides or
sulfur-containing organic compounds. Combustion of the fuel
forms about 25 to 30 parts of sulfur dioxide to 1 part of sulfur
trioxide.
Sulfur dioxide is a non-flammable, non-explosive colorless gas
that most people can taste at concentrations from 0.3 ppm to 1
ppm (about 0.9 mg/m3 to 3 mg/m3) in air. At concentrations
above 3 ppm (about 8.6 mg/m3), the gas has a pungent, irritat-
ing odor. In the atmosphere, sulfur dioxide is partly converted to
sulfur trioxide or to sulfuric acid and its salts by photochemical or
catalytic processes. Sulfur trioxide is immediately converted to
sulfuric acid in the presence of moisture. The degree of oxidation
of sulfur dioxide in the atmosphere is dependent on a number of
factors, including residence time, amount of moisture present, and
the intensity and duration of sunlight and its spectral distribution.
The amounts of catalytic material, hydrocarbons and nitrogen ox-
ides, and the amounts of sorptive and alkaline materials present,
also affect the oxidation process.
In the United States, sulfur dioxide is most commonly measured
by the colorimetric West-Gaeke (pararosaniline) and the conduc-
tometric methods. The West-Gaeke method is specific for sulfur
dioxide and sulfite salts. The method has been modified to compen-
sate for interferences produced by the presence of nitrogen oxides,
-------
2692 LEGAL COMPILATION—AIR
ozone, or heavy metal salts in the sample, and the modified method
is the method of choice of the National Air Pollution Control
Administration. Conductometric methods measure sulfur dioxide
concentrations as a function of change in the electroconductivity
of a solution. These methods are general, in that they react to
changes in electroconductivity brought on by other soluble gases,
as well as by sulfur dioxide, and the indicated values for sulfur
are sometimes very approximate.
The technique most frequently used in Europe to measure sulfur
dioxide is the hydrogen peroxide acid titration method, or an
automated conductometric version of the same technique. The
presence of other acidic or alkaline gases in the sample may affect
the results.
The lead peroxide candle is a widely used technique which deter-
mines a "sulfation rate." The method gives integrated values for
relatively long periods, but provides no indication of short-term
fluctuations. It provides only a rough indication of sulfur dioxide
concentrations.
Recently, two long-path spectroscopic techniques have been in-
troduced that sense sulfur dioxide concentrations remotely. Al-
though these techniques are complex and expensive, they may
eventually be developed to provide a sulfur dioxide "pollution con-
tour" for large areas of a city, as well as pollution concentrations
at different elevations.
Sulfuric acid aerosol in suspended particulate material may be
measured by titration or by controlled decomposition to sulfur
dioxide. The sulfur dioxide can be measured by a number of meth-
ods, including spectrophotometry, coulometry, and flame photome-
try. Particulate sulfate may be analyzed by spectrophotometric or
turbidimetric methods.
Each method of measuring sulfur oxides pollution is unique in
terms of measuring time resolution, operating costs and skills,
time required for analysis, and the specificity of the technique. A
single program may make use of both general and specific meth-
ods. In selecting the methods to be used in a sampling program, it
is especially important to consider the degree to which data ob-
tained from one method can be compared to data obtained from
another.
An estimated 28.6 million tons of sulfur dioxide were emitted to
the atmosphere of the United States in 1966, as compared with an
estimated 23.4 million tons emitted in 1963. The principal share,
58.2 percent, of the 1966 tonnage came from the combustion of
coal, primarily for the generation of electric power and for space
-------
GUIDELINES AND REPORTS 2693
heating. The combustion of residual fuel oil and other petroleum
products, also primarily for power generation and space heating,
accounted for 19.6 percent of the total, while the remainder came
from the refining of petroleum (5.5 percent), the smelting of
sulfur-containing ores (12.2 percent), the manufacturing of sul-
furic acid (1.9 percent), the burning of refuse (0.4 percent), and
the burning of coal refuse banks (0.4 percent). Paper-making and
other industrial operations also contributed minor amounts to the
total.
The National Air Pollution Control Administration operates
two nationwide programs for surveying sulfur oxides pollution
levels in the United States. The National Air Surveillance Net-
work (NASN) takes 24-hour samples of sulfur dioxide from
about 100 sites 26 times a year, and the Continuous Air Monitor-
ing Project (CAMP) records 5-minute average concentrations of
sulfur dioxide continuously in six large cities—Washington, Phila-
delphia, Cincinnati, Chicago, St. Louis, and Denver. The NASN
program employs the colorimetric, West-Gaeke method of analysis,
while the CAMP program uses the electroconductivity technique.
Recently, continuous, colorimetric West-Gaeke monitoring devices
were installed at the six CAMP locations.
Levels recorded in the CAMP cities over a 6-year period show
mean annual concentrations ranging from 0.01 ppm, in San Fran-
cisco, to 0.18 ppm, in Chicago, with the averages exceeding, for 1
percent of the time, a concentration between 0.09 ppm and 0.68
ppm. The NASN annual average concentrations ranged from
0.002 ppm, in Kansas City, Missouri, to 0.17 ppm, in New York
City. The highest 24-hour average concentration was 0.38 ppm,
also in New York City, while the lowest 24-hour averages were
below the minimum detectable range of the instruments—below
approximately 0.001 ppm. Geographically, the highest values were
recorded in the northeastern part of the United States, especially
east of the Mississippi River and north of the Ohio River, where
large quantities of sulfur-bearing fossil fuels are burned.
2. Relationship of Maximum Concentrations to Average Concentrations
Although it is convenient to discuss the various effects of sulfur
dioxide in connection with the average concentrations of the gas
over a long period, such as a year, some effects are thought to be
associated with the peak concentrations that may occur during the
period and to better define the kind and extent of effects that may
be occurring in a given community, it is useful to know what these
peak values may be.
-------
2694 LEGAL COMPILATION—AIR
For a given averaging time, measurements of sulfur dioxide
concentrations follow a log-normal frequency distribution. The
two statistical parameters used to describe this distribution are
the geometric mean and the standard geometric deviation, which
is an index of the deviation of the samples from the mean.
Once sufficient sampling data have been gathered, the geometric
mean and the standard geometric deviation can be used to calcu-
late the expected maximum concentration, the minimum concen-
tration, and the concentration at any percentile, provided that the
averaging time is 1 hour or greater. Further, it is possible to
calculate expected maxima for one averaging time from data ob-
tained at another averaging time.
For a given typical, multiple source urban area, a fairly good
approximation of the frequency distribution of hourly average
concentrations for a year at a given station can be obtained from
measurements taken for 24-hour periods on about 26 randomly
selected days. The accuracy of the approximation will depend on
the number of samples taken, compared to the total number of
samples that could have been taken if air sampling had been
continuous.
The CAMP data for various years in the period 1962 to 1967
appear to be fairly representative of the distribution of sulfur
dioxide concentrations for large U.S. metropolitan areas. The
range of standard geometric deviations for the CAMP cities is
roughly from 2 to 2.5. These values correspond to hourly maxima
that range from 10 to 20 times the annual mean, respectively.
Similarly, the 8-hour maximum ranges from about 6 to 10 times
the annual mean, and the 1-day maximum is between 4 and 7
times the annual mean.
The ratio of the maximum sulfur dioxide concentration to the
average values may be greater for measurements made near a
single point source than for a city as a whole. For averaging
periods from 4 to 54 minutes, for example, the maximum concen-
trations encountered near a point source were, respectively, 30 to
160 times the 6-month average value.
3. Effects on Health
The current scientific literature indicates that, for the most
part, the effects of the oxides of sulfur on health are related to
irritation of the respiratory system. Such injury may be tempo-
rary or permanent.
Laboratory studies show that sulfur dioxide can produce bron-
choconstriction in experimental animals such as the guinea pig,
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GUIDELINES AND REPORTS 2695
the dog, and the cat. Dose-response curves have been established
for the guinea pig, the most susceptible laboratory animal studied
to date. They relate the concentration of sulfur dioxide to the
observed increase in pulmonary flow resistance produced by 1-
hour exposures. Slight increases in resistance are detectable at
0.16 ppm (460 //.g/ni3) and the changes are readily reversible.
Sulfuric acid and some, but not all, particulate sulfates also
produce bronchoconstriction in the guinea pig. The response is
highly dependent on particle size, with the smallest particles show-
ing the greatest irritant potency. In this animal, as in man, sul-
furic acid and irritant particulate sulfates have a greater irritant
potency at a given concentration than does sulfur dioxide alone.
The potentiation by particulate matter of toxic responses to
sulfur dioxide (synergism) has been observed under conditions
which would promote the conversion of sulfur dioxide to sulfuric
acid. The degree of potentiation is related to the concentration of
particulate matter. A threefold to fourfold potentiation of the
irritant response to sulfur dioxide is observed in the presence of
particulate matter capable of oxidizing sulfur dioxide to sulfuric
acid. Aerosols of soluble salts of ferrous iron, manganese, and
vanadium have been observed to produce this potentiation, al-
though the concentrations used (0.7 mg/m3 to 1.0 mg/m3) were
considerably greater than any levels of the metals reported in
urban air.
Generally speaking, the laboratory work that has been per-
formed to date with animals has only partial relevance for air
quality criteria. In most of the studies, the laboratory environment
has not simulated very closely the actual environment. Exposures
have been to high and constant concentrations, rather than to the
low and fluctuating levels commonly found in the atmosphere.
Other normally occurring stresses, such as fluctuating tempera-
ture, have not, in general, been applied. These studies do, however,
provide valuable information on some of the bioenvironmental
relationships that may be involved in the effects of the sulfur
oxides on health. The data they provide on synergistic effects show
very clearly that information derived from single substance expo-
sures should be applied to ambient air situations only with great
caution.
The response of bronchoconstriction in man may be assessed in
terms of a slight increase in airway resistance. Normal individu-
als, exposed to sulfur dioxide via the mouth, exhibit small changes
in airway resistance, which are often insufficient to produce any
respiratory symptoms. The effects may be even smaller when the
-------
2696 LEGAL COMPILATION—AIR
subject breathes through his nose. As in animals, sulfuric acid is a
much more potent irritant in man than is sulfur dioxide. Again,
the irritant effect is highly dependent on particle size.
Laboratory observations of respiratory irritations suggest that
most individuals will show a response to sulfur dioxide when ex-
posed for 30 minutes to concentrations of 5 ppm (about 14 mg/
m3) and above. Exposure of certain sensitive individuals to 1 ppm
(about 3 mg/m3) can produce detectable changes in pulmonary
function. Similar exposure of these same individuals has, in some
instances, produced severe bronchospasm. In most of the studies
discussed, an increase in pulmonary flow resistance was the indi-
cator of response employed.
Epidemiologic studies do not have the precision of laboratory
studies, but they have the advantage of being carried out under
ambient air conditions. In most epidemiologic studies, indices of
air pollution level are obtained by measuring selected pollutants,
most commonly particulates and sulfur compounds. To use these
same studies to establish criteria for individual pollutants is justi-
fied by the experimental data on interaction of pollutants. How-
ever, in reviewing the results of epidemiologic investigations it
should always be remembered that the specific pollutant under
discussion is being used as an index of pollution, not as a physico-
chemical entity.
It has been suggested that industrial experience with sulfur
oxides exposures may be relevant to ambient air quality criteria.
In the absence of epidemiologic evidence, one might, as a rough
approximation, select some fraction of the concentrations reported
for industrial exposures. In selecting such a fraction, several fac-
tors should be taken into consideration. Industrial exposure, for
example, is not continuous, and it may not include the synergistic
effects which result from the presence of more than one class of
pollutant. Further, the exposed population may not include the
segments most susceptible to the effects.
From the epidemiologic studies available, it is easy to conclude
that there is an effect of the oxides of sulfur in the ambient
atmosphere on the health of the population, and that the degree of
effect is related to the degree of pollution. Episodes of acute eleva-
tion of oxides of sulfur and other pollutant concentrations have
been associated with a larger number of deaths than expected.
Those predominantly affected were individuals with chronic pul-
monary disease or cardiac disorders, or very young or old individ-
uals. However, the general population has also been involved.
Studies of episodes occurring in London suggest that a rise in
-------
GUIDELINES AND REPORTS 2697
the daily death rate occurred when the concentrations of sulfur
dioxide rose abruptly to levels at or about 715 jug/m3 (0.25 ppm)
(as measured by the hydrogen peroxide titrimetric method) in the
presence of smoke at 750 jug/m3. A more distinct rise in deaths
has been noted generally when sulfur dioxide exceeded 1000 /*g/
m3 (0.35 ppm) for one day, and particulate matter reached about
1200 /xg/m3 (measured by the British reflectometer method).
Daily concentrations of sulfur dioxide in excess of 1500 jug/m3
for one day (0.52 ppm) in conjunction with levels of suspended
particles exceeding 2000 /xg/m3 appear to have been associated
with an increase in the death rate of 20 percent or more over base
line levels. This same effect has been observed at lower sulfur
dioxide levels when the maximum pollution levels lasted for a
longer period.
Air pollution episodes in New York City have been associated
with exposures similar to those of the London episodes. In one
case, for example, excess deaths were detected in New York fol-
lowing a 24-hour period during which sulfur dioxide concentra-
tions exceeded 1500 ^g/m3 (>0.5 ppm) (as measured by the
hydrogen peroxide titrimetric method) and suspended particulate
matter was measured as a soiling index of 6 cohs or greater.
For Rotterdam, there have been indications of a positive asso-
ciation between total mortality and exposure for a few days to
24-hour mean concentrations of 500 jug/m3 (0.19 ppm) sulfur
dioxide. Further, it has been reported that: "There is a faint
indication that this will happen somewhere between 300 and 500
p.g S02 per m3 per 24 hours" (0.11 ppm and 0.19 ppm).
A survey of emergency clinics at major New York City hospi-
tals revealed a rise in visits for upper respiratory infections and
cardiac diseases in both children and adults in all 4 hospital stud-
ies during a 10-day period of elevated pollution levels. Sulfur
dioxide ranged between 200 *ig/m3 and 2460 /xg/m3 (0.07 ppm to
0.86 ppm) during the period studied; hospital admissions were
clearly elevated at a time when concentrations had not yet ex-
ceeded 715 ttg/m3 (0.25 ppm). Smoke shade was close to 3 coh
units.
In London, a one-day exposure to a daily average level of 600
/xg/m3 of sulfur dioxide (0.20 ppm) caused accentuation of symp-
toms in persons with chronic respiratory disease on the day fol-
lowing the high sulfur dioxide level if particulate matter at a
substantial concentration was also a pollutant.
This finding in London was also observed in a Chicago study.
The Chicago study noted a sharp rise in illness rates on the day
526-701) O - 74 - 23
-------
2698 LEGAL COMPILATION — AIR
following a one-day exposure to 715 ^g/m3 (0.25 ppm) of sulfur
dioxide or more for patients 55 years of age and over with severe
bronchitis. Particulate matter was also present.
Effects at lower levels of sulfur dioxides have also been noted.
In Rotterdam, during a few days in which sulfur dioxide concen-
trations rose from about 300 to 500 /xg/m3 (0.11 ppm to 0.19
ppm), the number of hospital admissions for irritations of the
respiratory system rose, particularly for older persons. Absentee-
ism from work under such conditions increased substantially, es-
pecially for those 45 years old and over.
" The lowest levels at which effects are reported for short-time
periods are those reported for the Ruhr area. An effect was noted
on "functional disturbance" at an estimated daily indoor mean of
270 jug/m3 (0.10 ppm) for 4 days and an increase in "symptoms,
illnesses, or diseases" (breathlessness, throat and eye irritation,
and "depression and apathy without further specification") was
noted at a daily indoor mean of about 540 ^g/m3 (0.20 ppm) .
Longer term exposure to lower levels than those found during
an air pollution episode has also been associated with demonstra-
ble health effects. It is for this reason that it must be emphasized
that the levels of a pollutant at which effects are detected are not
the concentrations at which the pollutant may begin to have an
effect on health. The initiation of the deleterious effects presuma-
bly must take place before, and at a lower concentration, than that
at which the existence of a strong association is accepted for
statistical reasons. Repeated respiratory infections in early child-
hood, for example, which in one study appeared to be related to air
pollution, may have contributed to the later development of the
chronic bronchitis syndrome in the adult.
A major British study has found an association between mortal-
ity from bronchitis and lung cancer and levels of air pollu'ion,
after taking into consideration differences in age, smoking habits,
social class, and occupational exposure. The sulfur dioxide values
for a year averaged 116 /^g/m3 (0.040 ppm) for the polluted area,
and 75 ^g/m3 (0.026 ppm) for the cleaner area. Corresponding
smoke values were 160 ^g/m3 and 80 /ug/m3, respectively. It was
not possible to separate the effects of sulfur dioxide from the
effects of comparable amounts of smoke which were present. This
is consistent with other British studies, which indicate an associa-
tion of bronchitis death rates with air pollution concentrations
that is apparently independent of social class differences, but
which can not specify the specific role played by sulfur oxides.
Children and housewives appear to represent the most suitable
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GUIDELINES AND REPORTS 2699
subjects for determining the health effects of long-term exposures
to rout'ne levels of air pollution. A study in Genoa, Italy, included
housewives 65 or more years of age, who were non-smokers: and
who had lived for a long period in the same area without having
any industrial experience. Sulfur dioxide was monitored for 10
years at 19 sites by a technique analagous to the volumetric
method of the British. An increased frequency of cough, sputum,
dyspnea, and bronchitis was noted in the moderately polluted area
as compared to the relatively clean area. Differences were noted in
the summer prevalence of respiratory diseases in the industrial
area, with an annual mean of 265 /*g/m3 S02 (0.093 ppm) when
compared to the middle [annual mean of 105 ^g/m3 S02 (0.037
ppm)] and low [annual mean of 80 ^g/m3 S02 (0.028 ppm)]
pollution areas. The study also showed a very significant correla-
tion between the frequency of bronchitis and the annual mean of
sulfur dioxide levels for the seven districts of the city, whereas the
correlation between the frequency of bronchitis and suspended
matter and dustfall was not significant.
Another morbidity study which has included housewives is that
conducted in Nashville. This showed a direct correlation between
illnesses for all causes for housekeeping white females, 15 to 64
years of age, and sulfur dioxide levels. It also showed that the
cardiovascular morbidity in the 55 and older age group, for both
sexes, was twice as high in the most polluted area as compared
with the least. Cigarette smoking was not taken into account, and
the adjustment made for socioeconomic status may not have been
wholly adequate.
Differences in respiratory symptoms have also been found in
areas which had long-term values of 95 /ug/m3 sulfur dioxide
(0.034 ppm) and 25 /ig/m3 (0.009 ppm) measured by hydrogen
peroxide absorption, sulfuric acid titrations. The study is unusual
in that the source of pollution was the single stack of a smelter,
and daily averages were up to 17 times the annual mean. However,
the findings that respiratory symptoms disappeared when pollu-
tion was locally reduced through installation of a higher stack,
would appear to confirm an effect of sulfur dioxide at the concen-
trations originally measured, provided that no other change took
place which could account for the disappearance of symptoms.
Studies of schoolchildren in Great Britain have indicated that
increased frequency and severity of respiratory diseases occurred
when long-term pollution levels exceeded averages of about 120
/tg/m3 (0.046 ppm) sulfur dioxide and 100 jug/m3 for smoke.
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2700 LEGAL COMPILATION—AIR
4. Effects on Visibility
Particles suspended in the air reduce visibility, or visual range,
by scattering and absorbing light coming from both an object and
its background, thereby reducing the contrast between them.
Moreover, suspended particles scatter light into the line of sight,
illuminating the air between, to further degrade the contrast be-
tween an object and its background. This phenomenon is described
in detail in a companion document, Air Quality Criteria for Partic-
ulate Matter.
The scattering of light into and out of the line of viewing by
particles in the narrow range of 0.1 /*, to 1 p. in radius has the
greatest effect on visibility. Of the total suspended particulate
matter in urban air, commonly from 5 percent to 20 percent con-
sists of sulf uric acid and other sulf ates, and of these, 80 percent or
more by weight are smaller than 1 ^ in radius. Consequently,
suspended sulf ates in the air can contribute significantly to reduc-
tion in visibility.
Characteristic behavior of suspended particles in the size range
mentioned makes it possible to relate visual range to concentra-
tions of overall particulate matter. Since sulfur dioxide levels, in
general, correlate with levels of overall suspended particulate mat-
ter, and since the ratio of sulfur dioxide to suspended sulf ate can
be estimated, given the relative humidity, it is possible to estimate
visibility for various relative humidities from sulfur dioxide con-
centration. Using such data as appear in Chapter 1, Figure 1-5,
we can estimate that at a concentration of 285 /*g/m3 (0.10 ppm)
of sulfur dioxide and with a relative humidity of 50 percent,
visibility in New York City would typically be reduced to about 5
miles. At a visual range of less than 5 miles, operations are slowed
at airports because of the need to maintain larger distances be-
tween aircraft. Federal Aviation Administration restrictions on
aircraft operations become increasingly severe as the visual range
decreases below 5 miles.
5. Effects on Materials
Laboratory and field studies underscore the importance of the
combination of particulate and sulfur oxides pollution in a wide
range of damage to materials. On the basis of present knowledge,
it is difficult to evaluate precisely the relative contribution of each
of the two classes of pollution; however, some general conclusions
may be drawn.
Steel test panels, dusted with a number of active hygroscopic
-------
GUIDELINES AND REPORTS 2701
particles commonly found in polluted atmospheres, corroded at a
low rate in clean air at relative humidities below 70 percent. The
corrosion rate was higher at relative humidities above 70 percent.
It greatly increased when traces of sulfur dioxide were added to
the laboratory air.
It is apparent that corrosion rates of various metals are higher
in urban and industrial atmospheres with relatively high levels of
both particulate and sulfur oxides than they are in rural and other
areas of low pollution. High humidity and temperature also play
an important synergistic part in this corrosion reaction. Studies
show increased corrosion rates in industrial areas where air pollu-
tion levels, including sulfur oxides and particulates, are higher.
Further, corrosion rates are higher during the fall and winter
seasons when particulate and sulfur oxides pollution is more se-
vere, due to a greater consumption of fuel for heating. Depending
on the kind of metal exposed as well as location and duration of
exposure, corrosion rates were l1/^ to 5 times greater in polluted
atmospheres than in rural environments.
In Chicago and St. Louis, where steel panels were exposed at a
number of sites, high correlations were found in each city between
corrosion rates, as measured by weight loss, and sulfur dioxide
concentrations, as measured by the West-Gaeke method. In St.
Louis, except for one exceptionally polluted site, corrosion losses
were 30 percent to 80 percent higher than losses measured in
non-urban locations. Sulfation rates in St. Louis, measured by lead
peroxide candle, also correlated well with weight loss due to corro-
sion. Measurements of dustfall in St. Louis, however, did not cor-
relate significantly with corrosion rates. Over a 12-month period
in Chicago, the corrosion rate at the most corrosive site (mean
S02 level of 0.12 ppm) was about 50 percent higher than at the
least corrosive site (mean S02 level of 0.03 ppm). Although sus-
pended particulate levels measured in Chicago with high-volume
samplers also correlated with corrosion rates, a co-variance analy-
sis indicated that sulfur dioxide concentrations were the dominant
influence on corrosion. Based on these data, it appears that consid-
erable corrosion may take place (i.e., from 11 percent to 17 per-
cent weight loss in steel panels) at annual average sulfur dioxide
concentrations in the range of 0.03 ppm to 0.12 ppm, and although
high particulate levels tend to accompany high sulfur dioxide lev-
els, the sulfur dioxide concentration appears to have the more
important influence.
Sulfur oxides pollution contributes to the damage of electrical
equipment of all kinds. Studies have reported a one-third reduc-
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2702 LEGAL COMPILATION—Am
tion in the life of overhead power line hardware and guy wires in
heavily polluted areas. In some areas it has been found necessary
to use more expensive, less corrodible metals, such as gold, for
electrical contacts.
Sulfur oxides pollution attacks a wide variety of building mate-
rials—limestone, marble, roofing slate, and mortar—as well as
statuary and other works of art, causing discoloration and deterio-
ration. Certain textile fibers—such as cotton, rayon, and nylon—
are harmed by atmospheric sulfur oxides. Dyed fabrics may fade
in atmospheres containing sulfur oxides and other pollutants. Se-
vere fading was noted for some dyes in fabrics exposed in Chi-
cago, where annual average sulfur dioxide levels were 0.09 ppm.
Leather exposed to sulfur oxides may lose much of its strength,
and paper may become discolored and brittle.
Concentrations of 1 ppm sulfur dioxide can increase the drying
time of some oil-based paints by 50 percent to 100 percent. Some
films become softer and others more brittle, both developments
adversely affecting durability. Sulfur dioxide also appears to ren-
der some paint films water sensitive, consequently reducing the
film gloss. Under certain conditions sulfur dioxide levels of 0.1
ppm to 0.2 ppm cause the bluing of Brunswick green, and in the
presence of ammonia produce a troublesome defect called crystal-
line bloom brought about by the formation of very small ammo-
nium sulfate crystals.
6. Effects on Vegetation
Sulfur dioxide may cause acute or chronic leaf injury to plants.
Acute injury, produced by high concentrations for relatively short
periods, usually results in injured tissue drying to an ivory color;
it sometimes results in a darkening of the tissue to a reddish-
brown. Chronic injury, which results from lower concentrations
over a number of days or weeks, leads to pigmentation of leaf
tissue, or leads to a gradual yellowing, or chlorosis, in which the
chlorophyll-making mechanism is impeded. Both acute and chronic
injury may be accompanied by the suppression of growth and
yield.
Acute injury apparently affects the plant's ability to transform
absorbed sulfur dioxide into sulfuric acid, and then into sulfates.
At high rates of absorption, sulfite is thought to accumulate, re-
sulting in the formation of sulfurous acid, which attacks the cells.
The amount of acute injury depends on the absorption rate which
is a function of the concentration. A given amount of gas at a high
-------
GUIDELINES AND REPORTS 2703
concentration will be absorbed in a shorter period and will cause
more leaf destruction than the same amount of gas at a lower
concentration. Mathematical expressions have been worked out
which, for some plant species, relate concentration, time of expo-
sure, and amount of damage.
Different varieties of plants vary widely in their susceptibility
to acute sulfur dioxide injury. The threshold response of alfalfa to
acute injury is 1.25 ppm over 1 hour, whereas privet requires 15
times this concentration for the same amount of injury to develop.
Some species of trees and shrubs have shown injury at exposures
of 0.5 ppm for 7 hours, while injury has been produced in other
species at 3-hour sulfur dioxide exposures of 0.54 ppm and, in still
others, at 8-hour exposures of 0.3 ppm. From such studies, it
appears that acute symptoms will not occur if the 8-hour average
concentration does not exceed 0.3 ppm. (From the data on the
CAMP cities, a maximum 8-hour concentration of 0.3 ppm would
correspond to a yearly average concentration of between 0.03 ppm
and 0.05 ppm). However, sulfur dioxide concentrations from 0.05
to 0.25 ppm may react synergistically with either ozone or nitro-
gen dioxide in short-term exposures (e.g., 4 hours) to produce
moderate-to-severe injury to certain sensitive plants.
Chronic plant injury results from the gradual accumulation of
excessive amounts of sulfate in leaf tissue. Sulfate formed in the
leaf is additive to sulfate absorbed through the roots, and when
sufficiently high levels accumulate, chronic symptoms, accompa-
nied by leaf drop, may occur. Chronic symptoms and excessive leaf
drop have been reported in locations where the mean annual con-
centration is below approximately 0.03 ppm.
It has been suggested that sulfur dioxide might suppress growth
and yield without causing visible injury. One investigator reported
that yields of rye grass grown in unfiltered air were significantly
lower than similar yields of plants grown in filtered air. No visible
symptoms of injury were observed. Sulfur dioxide levels in the
unfiltered air ranged from 0.01 ppm to 0.06 ppm, with exposure
periods ranging from 46 to 81 days; other gaseous pollutants may
have also been present. Usually, the suppression of growth and
yield is accompanied by visible symptoms of injury—a linear rela-
tionship has been derived, for example, between the yield of al-
falfa and the total area destroyed by acute symptoms, or the area
covered by chlorosis.
Sulfuric acid mist, which may occur in polluted fogs and mists,
also damages leaves. The acid droplets may cause a spotted injury
to wet leaves at concentrations of 0.1 mg/m3.
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2704 LEGAL COMPILATION—Am
B. CONCLUSION
The conclusions which follow are derived from a careful evalua-
tion by the National Air Pollution Control Administration of the
foreign and American studies cited in previous chapters of this
document. They represent the Administration's best judgment of
the effects that may occur when various levels of pollution are
reached in the atmosphere. The data from which the conclusions
were derived, and qualifications which should be considered in
using the data, are identified by chapter reference in each case.
1. Effects on Health
Analyses of numerous epidemiological studies clearly indicate
an association between air pollution, as measured by sulfur diox-
ide, accompanied by particulate matter, and health effects of vary-
ing severity. This association is most firm for the short-term air
pollution episodes.
There are probably no communities which do not contain indi-
viduals with impaired health who are particularly susceptible to
the adverse effects of elevated levels of sulfur oxides and particu-
late matter. However, to show small changes in deaths associated
with coincident higher levels of air pollutants requires extremely
large populations. In small cities, these changes are difficult to
detect statistically.
The epidemiologic studies concerned with increased mortality
also show increased morbidity. Again, increases in morbidity as
measured, for example, by increases in hospital admissions or
emergency clinic visits, are most easily detected in major urban
areas.
It is believed that, for the large urban communities which are
routinely exposed to relatively high levels of pollution, sound sta-
tistical analysis can detect with confidence the small changes in
daily mortality which are associated with fluctuation in pollution
concentrations. Such analysis has thus far been attempted only in
London and in New York.
The association between long-term community exposures to air
pollution and respiratory disease incidence and prevalence rates is
conservatively believed to be intermediate in its reliability. Be-
cause of the reenforcing nature of the studies conducted to date,
the conclusions to be drawn from this type of study can be charac-
terized as probable.
The association between long-term residence in a polluted area
and chronic disease morbidity and mortality is somewhat more
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GUIDELINES AND REPORTS 2Y05
conjectural. However, in the absence of other explanations, the
findings of increased morbidity and of increased death rates for
selected causes, independent of economic status must still be con-
sidered consequential.
Based on the above guidelines the following conclusions are
listed in order of reliability, with the more reliable conclusions
first.
As discussed in Chapter 2, the sulfur oxides measurement sys-
tems used by American and foreign agencies are not always the
same. However, for the most part, data derived from one measure-
ment system can be converted to other systems.
a. AT CONCENTRATIONS OF ABOUT 1500 pg/m? (0.52
ppm) of sulfur dioxide (24-hour average), and suspended particu-
late matter measured as a soiling index of 6 cohs or greater,
increased mortality may occur. (American data; see Chapter 9,
Section C-la.)
b. AT CONCENTRATIONS OF ABOUT 715 p.g/ms (0.25
ppm) of sulfur dioxide and higher (24-hour mean), accompanied
by smoke at a concentration of 750 j«,g/m3, increased daily death
rate may occur. (British data; see Chapter 9, Section C-la.)
c. AT CONCENTRATIONS OF ABOUT 500 ^g/m3 (0.19
ppm) of sulfur dioxide (24-hour mean), with low particulate lev-
els, increased mortality rates may occur. (Dutch data; see Chapter
9, Section C-la.)
d. AT CONCENTRATIONS RANGING FROM 300 ^g/m? to
500 /x0/m3 (0.11 ppm to 0.19 ppm) of sulfur dioxide (24-hour
mean), with low particulate levels, increased hospital admissions
of older persons for respiratory disease may occur; absenteeism
from work, particularly with older persons, may also occur.
(Dutch data; see Chapter 9, Section C-lb.)
e. AT CONCENTRATIONS OF ABOUT 715 ,*.g/m? (0.25
ppm) of sulfur dioxide (24-hour mean), accompanied by particu-
late matter, a sharp rise in illness rates for patients over age 54
with severe bronchitis may occur. (American data; see Chapter 9,
Section C-5.)
f. AT CONCENTRATIONS OF ABOUT 600 g/m? (about
0.21 ppm) of sulfur dioxide (24-hour mean), with smoke concen-
trations of about 300 /xg/m3, patients with chronic lung disease
may experience accentuation of symptoms. (British data; see
Chapter 9, Section C-5.)
g. AT CONCENTRATIONS RANGING FROM 105 ^g/m? to
265 t*,g/m3 (0.037 ppm to 0.092 ppm) of sulfur dioxide (annual
mean), accompanied by smoke concentrations of about 185
-------
2706 LEGAL COMPILATION—AIR
m3, increased frequency of respiratory symptoms and lung disease
may occur. (Italian data; see Chapter 9, Section C-2.)
h. AT CONCENTRATIONS OF ABOUT 120 pg/m* (0.046
ppm) of sulfur dioxide (annual mean), accompanied by smoke
concentrations of about 100 /xg/m3, increased frequency and se-
verity of respiratory diseases in schoolchildren may occur. (Brit-
ish data; see Chapter 9, Section C-3.)
i. AT CONCENTRATIONS OF ABOUT 115 ^g/m? (0.040
ppm) of sulfur dioxide (annual mean), accompanied by smoke
concentrations of about 160 /ug/m3, increase in mortality from
bronchitis and from lung cancer may occur. (British data; see
Chapter 9, Section C-2.)
2. Effects on Visibility
AT A CONCENTRATION OF 285 ^g/ma (0.10 ppm) of sulfur
dioxide, with comparable concentration of particulate matter and
relative humidity of 50 percent, visibility may be reduced to about
Five miles. (American data; see Chapter 1, Figure 1-3.)
3. Effects on Materials
AT A MEAN SULFUR DIOXIDE LEVEL OF 345 i^g/m*
(0.12 ppm), accompanied by high particulate levels, the corrosion
rate, for steel panels may be increased by 50 percent. (American
data; see Chapter 4, Section C.)
4. Effects on Vegetation
a. AT A CONCENTRATION OF ABOUT 85 p.g/ms (0.03
ppm) of sulfur dioxide (annual mean), chronic plant injury and
excessive leaf drop may occur. (Canadian data; see Chapter 5,
Section C.)
b. AFTER EXPOSURE TO ABOUT 860 ^g/m? (0.3 ppm) of
sulfur dioxide for 8 hours, some species of trees and shrubs show
injury. (American data; see Chapter 5, Section C.)
c. AT CONCENTRATIONS OF ABOUT 145 ^g/m? to 715
nff/m3 (0.05 ppm to 0.25 ppm), sulfur dioxide may react syner-
gistically with either ozone or nitrogen dioxide in short-term expo-
sures (e.g., 4 hours) to produce moderate to severe injury to
sensitive plants. (American data; see Chapter 5, Section E.)
C. RESUME
In addition to health considerations, the economic and aesthetic
benefits to be obtained from low ambient concentrations of sulfur
-------
GUIDELINES AND REPORTS 2707
oxides as related to visibility, soiling, corrosion, and other effects
should be considered by organizations responsible for promulgat-
ing ambient air quality standards. Under the conditions prevailing
in areas where the studies were conducted, adverse health effects
were noted when 24-hour average levels of sulfur dioxide exceeded
300 /Lig/m3 (0.11 ppm) for 3 to 4 days. Adverse health effects
were also noted when the annual mean level of sulfur dioxide
exceeded 115 /ig/m3 (0.04 ppm). Visibility reduction to about 5
miles was observed at 285 /ug/m3 (0.10 ppm) ; adverse effects on
materials were observed at an annual mean of 345 jug/m3 (0.12
ppm) ; and adverse effects on vegetation were observed at an an-
nual mean of 85 /xg/m3 (0.03 ppm). It is reasonable and prudent
to conclude that, when promulgating ambient air quality stand-
ards, consideration should be given to requirements for margins of
safety which take into account long-term effects on health, vegeta-
tion, and materials occurring below the above levels.
4.2a(6) "CRITERIA FOR NITROGEN OXIDES"
Environmental Protection Agency, January 1971
SUMMARY
A. INTRODUCTION
This document contains a consolidation and an assessment of
the current state of knowledge regarding the group of air pollu-
tants known as the oxides of nitrogen. This chapter provides a
concise presentation of that information, including reasonable con-
clusions for evaluating the concentrations of nitrogen oxides
(NOX) and the accompanying situations that have an effect on
either health or welfare. The studies and data cited comprise the
best available basis for developing specific standards for NOX in
the ambient air, aimed at protecting public health and the environ-
ment.
Although the essential role of NOX in the production of photo-
chemical oxidants is treated from the physical-chemical standpoint
in this document, little research has been done to demonstrate the
significance of the indirect effects of NOX on health, vegetation,
and materials through the photochemical reaction mechanism;
thus, only the direct effects of NOX are treated here. APCO publi-
cation AP-63, Air Quality Criteria for Photochemical Oxidants,
provides a comprehensive review of photochemical oxidant effects.
Units of pollution concentration used in this document are ex-
pressed as both mass per unit volume (e.g., micrograms per cubic
-------
2708 LEGAL COMPILATION—AIR
meter, /tg/ms) and as volume-ratios (e.g., parts per million,
ppm). Conversion between these units requires a knowledge of the
gas density, which varies with temperature and pressure measure-
ment. In this document 25°C (77° F) has been taken as standard
temperature, and 760 mm Hg (atmospheric pressure at sea level)
as standard pressure. All references to NOX are expressed in
terms of NO2 mass per unit volume on the basis of the conversion
formula: ppm x 1880 = p.g/m3 at 25° C, 760 mm Hg, unless
otherwise specified. Similarly, hydrocarbons and oxidant concen-
trations are expressed as mass of methane and ozone per unit
volume, respectively.
B. PROPERTIES OF NITROGEN OXIDES AND
PHYSICAL EFFECTS ON LIGHT TRANSMISSION
Of the oxides of nitrogen known to exist, only two, nitric oxide
(NO) and nitrogen dioxide (N02) are emitted to the atmosphere
in significant quantities. Nitric oxide is formed during all atmos-
pheric combustion processes in a spontaneous chemical reaction
between the nitrogen and oxygen in the air. The amount formed
depends on the combustion temperature, the concentration of both
reactants and products, and the length of time favorable condi-
tions persist for the reaction.
Both NO and N02 are formed when combustion temperatures
exceed approximately 1093° C (2000° F), but usually less than 0.5
percent is N02. More N02 is formed when atmospheric oxygen
(O2) reacts with NO, but at the dilute concentrations of NO
characteristically found in ambient atmospheres, this reaction pro-
ceeds very slowly. During the initial phases of exhaust gas dilu-
tion, however, the concentration of NO is high, and forces the
reaction to proceed more rapidly until the exhaust has been suffi-
ciently diluted (to 1 ppm or less). At that time the major process
for converting NO to N02 reverts to the photochemical cycle.
Visibility reduction is common in polluted atmospheres. Scatter-
ing and absorption of light rays by particles and gases reduce the
brightness and contrast of distant objects. The degree of reduction
depends on the concentration and properties of the pollutants.
Nitrogen dioxide absorbs light energy over the entire visible spec-
trum, although primarily in the shorter, blue-wavelength regions;
thus, N02 can by itself reduce visibility. At present, however,
under most ambient conditions, aerosols make the major contribu-
tions to visibility reduction.
-------
GUIDELINES AND REPORTS 2709
C. SOURCES AND CONTROL OF ATMOSPHERIC
NITROGEN OXIDES
On a global basis, the total amount of nitrogen oxides generated
by natural sources exceeds the amount from man-made, technolog-
ical sources. Natural scavenging processes keep background levels
in nonurban areas low, on the order of 8 /*g/m3 (4 ppb) N02 and
2 yitg/m3 (2 ppb) NO. In urban areas, however, where 60 percent
of the technological sources are located, the levels are frequently
higher because pollutants are added faster than scavenging proc-
esses control them.
Fuel combustion is the major source of technological NOX air
pollution. Chemical processing is responsible for high, but local-
ized emissions.
Control of NOX emissions has been directed at both combustion
sources and chemical processes. For stationary combustion
sources, the control principle has been based on reducing either
the flame temperature or the availability of oxygen, to prevent NO
formation. Similar principles of control are applicable to motor
vehicles. Catalytic principles, which have been applied to reduce
NOX emissions from chemical processes, are also being investi-
gated for possible use in control of NOX in motor-vehicle exhaust.
D. CHEMICAL INTERACTIONS OF NITROGEN OXIDES
IN THE ATMOSPHERE
The role of NOX in the generation of photochemical oxidants is
a complex function of the interaction of certain hydrocarbons
(HC) with the N02 photolytic cycle, which is discussed here as
well as in the document AP-63, Air Quality Criteria for Photo-
chemical Oxidants and the document AP-64., Air Quality Criteria
for Hydrocarbons.
In order to fully describe the HC-NOX-OX interrelationship a
comprehensive simulation model that takes into account emission
rates, chemical reactions, and atmospheric dispersion factors, is
required. In the absence of such an applicable model an observa-
tion-based model was developed and applied to ambient aerometric
data. This latter model is restricted to defining the maximum daily
oxidant that may be reached from a given early-morning precur-
sor level and, therefore, the model results in definition of the
upper-level oxidant curve, as a function of precursor concentra-
tions. The model for the NOX-OX relationship indicates that an
NOX 6- to 9-a.m. value of 80 /xg/m3 (0.04 ppm) is associated with
-------
2710 LEGAL COMPILATION — Am
the reference concentration of 200 ^g/m3 (0.1 ppm) maximum
daily 1-hour-average oxidant.
The reference concentration of 200 /*g/m3 OX used here was
selected on the basis of convenience and does not represent the
lowest health-related value (130 /xg/m3 OX) expressed in APCO
publication AP-63, Air Quality Criteria for Photochemical Oxi-
dants.
Application of the observation-based model to ambient NOX,
HC, and oxidant interrelationships showed that the peak oxidant
level is dependent on the concentration of both reactants. Analysis
of data from three urban areas indicates that a reference concen-
tration of 200 jug/m3 (0.1 ppm) maximum daily 1-hour-average
oxidant is associated with an HC range of 200 to 930 /*g/m3 (0.3
to 1.4 ppm C) 6- to 9-a.m. nonmethane hydrocarbon, when the 6-
to 9-a.m. average NOX, expressed as N0_>, was below 80 /*g/m3
(0.04 ppm). Similarly, observation of the 200 /*g/m3 (0.3 ppm
C) nonmethane HC level showed NOX in the range of 80 to 320
/xg/m3 (0.04 to 0.16 ppm), expressed as NO2. These conclusions
are supported by the predominance of weekend data near the
low-concentration end of the upper-limit oxidant curve, which re-
flects the lower oxidant values from lower emissions on weekends.
E. METHODS FOR MEASURING NITROGEN OXIDES
Research is still needed to develop and thoroughly evaluate more
sensitive, reliable, and practical methods for measuring ambient
levels of NO, N02, and NOX. All of the field techniques in use at
present can measure only N02 directly; NO must be oxidized to
N02, then measured. NOX can be determined either by summing
NO and N02 concentrations that have been measured independ-
ently or by oxidizing NO to N02, then measuring the total as
N02.
Any method used for measuring N02 in the ambient air should
be calibrated against atmospheres containing known amounLs of
N02. The use of permeation tubes to generate the test atmos-
pheres is recommended.
Two techniques are currently used in atmospheric monitoring
programs. For sampling periods of 30 minutes or less, the most
suitable currently available method for measuring N02 is the col-
orimetric Griess-Saltzman method. This method can also be auto-
mated for continuous measurement. The Jacobs-Hochheiser
method is the most suitable of the available methods for long-term
(up to 24 hours) sampling, or for situations requiring a delay of
-------
GUIDELINES AND REPORTS 2711
the analysis for more than 4 hours after sampling. The Griess-
Saltzman and Jacobs-Hochheiser methods are not interchangeable,
can yield different results, and must be chosen carefully, according
to the purposes of the sampling to be done.
When used in conjunction with an oxidizing prescrubber to
convert NO to N02, the continuous Griess-Saltzman method can
be used to measure NO in ambient air in either a series or parallel
mode, with the same or separate samples of air. Problems exist in
obtaining complete NO to N02 oxidation, and researchers disa-
gree as to which of the two modes is more satisfactory.
F. ATMOSPHERIC LEVELS OF NITROGEN OXIDES
Continuous measurement of the oxides of nitrogen by various
monitoring networks has made it possible to compile tables of
mean concentrations averaged over different time periods and to
relate various temporal patterns to photochemical and meteorolog-
ical parameters.
Both NO and N02 concentrations display distinct diurnal varia-
tions dependent on both the intensity of the solar ultraviolet en-
ergy and the amount of atmospheric mixing. In many sampling
areas, these variations are also associated with the traffic pat-
terns.
Nitric oxide shows an additional seasonal variation, with higher
values occurring during the late fall and winter months. Nitrogen
dioxide, however, does not display any distinct seasonal patterns.
The effect of meteorological parameters on NO and N03 concen-
trations has been reasonably well documented. As might be ex-
pected, periods of stagnation and high traffic volume in urban
areas have resulted in high peak levels of NOK.
Continuous measurement has indicated that peak values of NO
above 1.2 mg/m3 (1 ppm) are widespread, but NO2 concentra-
tions have rarely been measured at this level. Peak concentrations
of N02 in urban areas rarely exceed 0.94 mg/m3 (0.5 ppm).
Considerable differences were found among N02 data collected
at the same site, at the same time, but by different methods. The
methods of NO, N02, and NOX measurement are still in need of
refining and must be judged accordingly.
G. EFFECTS OF NITROGEN OXIDES ON MATERIALS
Significant effects of NOX have been observed and studied on
three classes of materials: textile dyes and additives, natural and
synthetic textile fibers, and metals.
-------
2712 LEGAL COMPILATION—AIR
The most pronounced problem is associated with textile dyes
and additives. Fading of sensitive disperse dyes used on cellulose
acetate fibers has been attributed to N02 levels below 188 mg/m3
(<100 ppm). Loss of color, particularly in blue- and green-dyed
cotton and viscose rayon, has occurred in gas dryers where NOX
concentrations range from 1.1 to 3.7 mg/m3 (0.6 to 2 ppm).
Yellow discoloration in undyed white and pastel-colored fabrics
has recently been attributed to NOX by controlled laboratory ex-
periments.
Laboratory and field observations have shown that cotton and
nylon textile fibers can be deteriorated by the presence of NO,,
but specific reactants and threshold levels are undetermined at
this time.
Failure of nickel-brass wire springs on relays has been related
to high particulate nitrate levels. This type of stress corrosion has
been observed when surface concentrations of particulate nitrates
have exceeded 2.4 /xg/cni2 and relative humidity was greater than
50 percent. Another type of this corrosion has been associated
with annual average particulate nitrate concentrations of 3.0 and
3.4 /*g/m3 with corresponding NOX levels of 124 and 158 /u,g/m3
(0.066 and 0.084 ppm).
H. EFFECTS OF NITROGEN OXIDES ON VEGETATION
The degree of injury occurring with the lower concentrations of
N02 present in the atmosphere remains to be determined. Expo-
sure of many kinds of plants to concentrations of N02 above 47
mg/m3 (25 ppm) for any extended period causes acute necrotic
leaf injury. Such lesions are usually characteristic for each plant,
but their nonspecific character in relation to other toxicants ren-
ders these symptoms of little value in diagnosing NO2 damage in
the field.
The 1-hour visible-injury-threshold value for N02 can be
achieved by exposing plants to 18.8 to 28.2 mg/m3 (10 to 15
ppm). Increasing the exposure time, however, obviates the thresh-
old level; 4.3 to 6.6 mg/m3 (2.3 to 3.5 ppm) N02 administered
for 8 to 21 hours and 1.9 mg/m3 (1 ppm) N02 for 48 hours cause
equivalent leaf injury. Continuous fumigation with 940 fig/m3
(0.5 ppm) NO2 for 35 days resulted in leaf drop and chlorosis in
citrus, but no actual necrotic lesions developed.
The effects of exposure to low levels of N02 for extended peri-
ods are less evident. Recently completed studies suggested that 470
/xg/m3 (0.25 ppm) or less of N02, supplied continuously for 8
526-705 O - 74 - 24
-------
GUIDELINES AND REPORTS 2713
months will cause increased leaf drop and reduced yield in navel
oranges.
The mechanism (s) by which NOX causes direct injury to plants
can only be postulated at this time. Evidence of diurnal fluctuation
in sensitivity to N02 has been presented, and could indicate that
the pollutant is reacting with a particular plant metabolite, which
only accumulates at certain periods during the day. The absence of
a protective metabolite within the plant at certain periods would
also cause a diurnal sensitivity.
Limited information regarding the effect of nitric oxide on pho-
tosynthesis indicates that NO would reduce the growth of plants if
concentrations in the range of 3.8 to 7.5 mg/m3 (2.0 to 4.0 ppm)
persisted continuously.
I. TOXICOLOGICAL EFFECTS OF NITROGEN OXIDES
Both of the prominent oxides of nitrogen present in ambient air
are potential health hazards. At ambient concentrations, NO pre-
sents no direct threat to general health; N02 does, however. Ef-
fects of N02 determined in extensive studies are summarized in
Table 11-1.
The toxicology of nitrous oxide (N20) and other oxides of
nitrogen does not appear to be relevant to the problems of ambient
air pollution at the present time.
1. Nitric Oxide
NO is not an irritant and is not considered to have adverse
health effects at concentrations found in the atmosphere. Its great-
est toxic potential at ambient concentrations is related to its tend-
ency to undergo oxidation to N02. A 12-minute exposure to 3,075
mg/m3 (2,500 ppm) NO has proved lethal to mice. In addition,
NO has been observed to inhibit bacterial hydrogenase activity at
lower concentrations—24.6 mg/m3 (20 ppm). This inhibition was
reversible, however, until the exposure reached about 12,300 mg/
m3 (10,000 ppm).
2. Nitrogen Dioxide
N02 exerts its primary toxic effect on the lungs. High concen-
trations, greater than 188 mg/m3 (100 ppm), are lethal to most
animal species; 90 percent of the deaths are caused by pulmonary
edema.
-------
2714
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GUIDELINES AND REPORTS 2715
The concentration time product determines nonlethal morbidity
effects of N02 exposures. At 940 ^g/m3 (0.5 ppm) for 4 hours or
1.9 mg/m3 (1.0 ppm) for 1 hour, mast cells of rat lungs became
degranulated, possibly signifying the onset of an acute inflamma-
tory reaction. These cells returned to normal 24 hours after expo-
sure was terminated. Lung proteins, collagen and elastin, were
found to be altered structurally in rabbits exposed to 1.9 mg/m3
(1 ppm) N02 for 1 to 4 hours. The condition was also reversible
within 24 hours. Similar changes were observed in rabbits exposed
to 470 fig/m3 (0.25 ppm) N02, 4 hours a day for 6 days, except
that recovery was delayed and some denaturation was still appar-
ent 7 days after the final exposure. Denaturation of collagen and
elastin associated with repeated exposure to N02 has been sug-
gested as a possible factor in the pathogenesis of pulmonary em-
physema.
Early pulmonary emphysema-type lesions have been observed in
dogs exposed continuously to 47.0 mg/m3 (25 ppm) for 6 months.
In lung tissue from monkeys exposed to 18.8 to 94.0 mg/m3 (10
to 50 ppm) N02 for 2 hours, alveoli were expanded and had thin
septal walls. This response involved increasing numbers of alveoli
as the N02 concentration was increased. Hyperplasia has been
observed in respiratory bronchiolar epithelium of hamsters ex-
posed to 94.0 mg/m3 (50 ppm) for 10 weeks, and a similar re-
sponse was noted in major bronchi and distal portions of the
respiratory tract of hamsters exposed to 18.8 mg/m3 (100 ppm)
for 6 hours.
Long-term exposures to N02 concentrations that do not produce
acute inflammatory responses have a cumulative, sustained effect,
suggestive of a pre-emphysematous condition. Examination of
lung bissue from rats exposed to 3.8 mg/m3 (2 ppm) for their
natural lifetimes showed loss of cilia; decreased bronchiolar bleb-
bing; and intercellular, crystalloid, rod-shaped, inclusion bodies.
Similar effects have been seen in lungs of rats continuously ex-
posed to 1.5 mg/m3 (0.8 ppm). Alveoli in lungs of mice exposed
to 940 jug/m3 (0.5 ppm) for 3 to 12 months on 6-, 18-, and
24-hour daily schedules have shown increase in size from disten-
sion rather than from septal breakage. The accompanying inflam-
mation of the bronchiolar epithelium and reduction in distal air-
way size suggested the development of early focal emphysema.
Rats chronically exposed to 18.8 to 47.0 mg/m3 (10 to 25 ppm)
N02 developed compensatory changes, such as polycythemia and
thoracic kyphosis, with lateral flaring of the ribs.
-------
2716 LEGAL COMPILATION—AIR
Since certain pathological changes seen in animals after experi-
mental N02 exposure are similar to changes that occur in the
pathogenesis of chronic obstructive pulmonary disease in man, it
is suggested that long-term, low-level exposures to N02 may play
a significant role in the development of chronic lung disease.
Exposure of mice, hamsters, and squirrel monkeys to N02 in-
creased susceptibility to bacterial pneumonia and influenza infec-
tion. The susceptibility has been demonstrated by a significantly
increased mortality, decreased survival time, and a reduction in
ability to clear infectious agents from the lungs. In mice, threshold
for increased susceptibility to Klebsiella pneumoniae occurred
after exposure to 6.6 mg/m3 (3.5 ppm) N02 for 2 hours, if the
infectious challenge was given within 1 hour after the N02 expo-
sure. Squirrel monkeys exposed to 18.8 mg/m3 (10 ppm) N02 for
2 hours and then challenged with K. pneumonia aerosol retained
the infectious agent in their lungs for extended periods of time.
In long-term studies of mice, significantly increased susceptibil-
ity to infection occurred after continuous daily exposure to 940
/xg/m3 (0.5 ppm) N02 for 3 months, and after 6- and 18-hour
daily exposures for 6 months. A significant increase in susceptibil-
ity to influenza virus or K. pneumoniae was also seen in squirrel
monkeys continuously exposed to 18.8 and 9.4 mg/m3 (10 and 5
ppm) N02 for 1 and 2 months, respectively. In addition, inter-
feron formation has been impaired and resistance to viral infec-
tion has decreased following exposure of rabbits to 47.0 mg/ms
(25 ppm) N02 for 3 hours. Researchers conjecture that such
increased susceptibility to infection may also be significant in the
pathogenesis of human lung disease.
Inhalation of N02 can produce other systemic effects, although
these are generally secondary to the effects on the lungs. In mon-
keys exposed to 28.2 to 94.0 mg/ms (15 to 50 ppm) N02 for 2
hours, cellular changes appeared in heart, liver, and kidney tissue.
A circulating substance, possibly a lung antibody, has been de-
tected in the blood of guinea pigs exposed to 9.4 mg/ms (5.0
ppm) for 4 hours daily, 5 days per week for 5.5 months. Rats and
monkeys continuously exposed to 3.8 mg/m3 (2.0 ppm) N02 for 3
weeks developed marked polycythemia. Methemoglobin has been
detected in the blood of several species exposed to N02 concentra-
tions greater than 122 mg/m3 (70 ppm) for 1 hour.
The small amount of information available concerning the toxi-
cological effects of the oxides of nitrogen in man pertains to levels
higher than those found in ambient air. Experimental exposure of
volunteer subjects to 9.4 mg/ms (5 ppm) N02 for 10 minutes has
-------
GUIDELINES AND REPORTS 2717
produced a substantial, but transient, increase in airway resist-
ance. Other data, derived from occupational exposure to high-con-
centration mixtures of NO and N02, are complicated by the pres-
ence of other pollutants. Impaired pulmonary function, evidenced
by reduced maximal breathing capacity, increased expiratory re-
sistance, and occasional decreased vital capacity has been observed
in patients accidentally exposed to high concentrations of nitrous
fumes for a few minutes. Such evidence has persisted for more
than 2 years after the exposure, in some cases. In one case, occu-
pational exposure to 169 mg/m3 (90 ppm) N02 for 30 minutes
produced pulmonary edema and a vital capacity 50 percent lower
than expected 18 hours later. Exposure to very high concentra-
tions for about 5 minutes has produced death within 2 days to 5
weeks.
The threshold for odor perception of N02 is about 225 ^g/m3
(0.12 ppm).
J. EPIDEMIOLOGICAL APPRAISAL OF
NITROGEN OXIDES
Nitrogen dioxide, the only oxide of nitrogen examined in epide-
miological surveys, can be significantly correlated with increased
respiratory disease at mean 24-hour concentrations between 117
and 205 ^.g/m3 (0.062 and 0.109 ppm).
Effects of community exposure to N02 were studied in four
residential areas of greater Chattanooga. The ventilatory per-
formance (FEVo.75) of children in a high-N02 area was signi-
cantly reduced, when compared to the performance of children in
control areas. In addition, an 18.8 percent relative excess of res-
piratory illness occurred among families exposed to high N02
concentrations. A 10.4 percent excess occurred among families in
an elevated-particulate area. The increased incidence of acute res-
piratory disease was observed when the mean 24-hour N02 con-
centration, measured over a 6-month period, was between 117 and
205 jug/m3 (0.062 and 0.109 ppm) and the mean suspended ni-
trate level was 3.8 /*g/m3 or greater.
In a retrospective study of the same Chattanooga area, exposure
to intermediate and high levels of N02 in ambient air was asso-
ciated with a significant increase in the frequency of acute bron-
chitis among infants exposed for 3 years and school children ex-
posed for 2 and 3 years. When increase was observed, the mean
24-hour N02 concentration, measured over a 6-month period, had
ranged between 118 and 156 /ig/m3 (0.063 and 0.083 ppm) and
-------
2718 LEGAL COMPILATION—Am
the mean suspended nitrate level had been 2.6 ^g/m3 or greater.
A report from Czechoslovakia indicates that NOX has produced
several alterations in the peripheral blood. Increased levels of
methemoglobin were observed in school children residing in a
town that had relatively high ambient levels of nitrogen oxides.
The findings in that report require further clarifying investiga-
tion, however, before conclusions can be drawn.
The Chattanooga studies have several implications in regard to
respiratory illness—implications that can be extended to other
cities. Since N02 does not exhibit marked seasonal variations (See
discussion chapter 6, Section B,2), direct comparison of the
NASN yearly averages with the lower limit at which health effects
were noted in the Chattanooga studies is, therefore, possible. Any
site that exhibits a concentration of 113 fj.g/ms (0.06 ppm) or
greater exceeds the Chattanooga health-effect-related N02 value.
Ten percent of cities with populations of less than 50,000 show a
yearly average equal to or exceeding 113 jug/m3 (0.06 ppm). In
the population range from 50,000 to 500,000, 54 percent of the
cities in the United States equal or exceed a yearly average of 113
/xg/m3 (0.06 ppm) N02. In the over-500,000 population class, 85
percent of the cities equal or exceed 113 ^g/m3 (0.06 ppm) N02
on a yearly average.
K. AREAS FOR FUTURE RESEARCH
1. Environmental Aspects of Oxides of Nitrogen
The fate of as much as 50 percent of the nitrogen oxides that
become incorporated into the photochemical complex is still unde-
termined, for many of the nitrogen oxide end products remain
unidentified.
Even for the identified nitrogen oxides the relationship between
emissions and air quality needs further definition through im-
proved instrumentation, expansion of the number of monitoring
stations, and more accurate determination of the location and dis-
tribution of sources.
A model for predicting upper limits of photochemical oxidant
pollutants from observed HC and NOX levels has been presented,
but needs further definition, sophistication, and revision before it
can be applied on a practical basis.
2. Effects on Vegetation and Materials
a. Materials
Further research is needed to define reliable dose-response rela-
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GUIDELINES AND REPORTS 2719
tionships for vulnerable materials. The effects of variables such as
temperature, relative humidity, sunlight, and other pollutants on
the damage potential of the nitrogen oxides must also be deter-
mined.
6. Vegetation
The biochemical, enzymatic, and other metabolic responses of
plants to ambient levels of the nitrogen oxides are in need of
research-based delineation. Evidence of diurnal variations in sen-
sitivity suggests the existence of either extra-sensitive or protec-
tive metabolites in some plants. Evidence of synergistic effects of
NOX in mixtures containing other air pollutants should be investi-
gated further.
3. Toxicity of Oxides of Nitrogen
In order to ascribe toxicity to a specific concentration range of
NOX, the relation of metabolic tissue changes to N02 concentra-
tion-time responses and the relative importance of low-concentra-
tion, long-time exposures versus short-time, peak ambient concen-
trations should be studied. The interactions of the oxides of nitro-
gen with particulate pollutants in relation to biochemical, biophys-
ical, infectious, immunological, and ultrastructural response par-
ameters require further research aimed at elucidating possible
synergistic damage or protection. Tolerance to N02 in the pres-
ence of oxidant pollutants has been suggested as a result of explo-
ratory studies, but the biologic importance of such protection
needs to be defined.
Further examination of in vivo biochemical and biophysical ef-
fects of exposure to typical ambient concentrations of the oxides
of nitrogen relative to: (1) oxidation of fatty acid double bonds in
lung surfactants; and (2) denaturation or alteration of lung pro-
teins (collagen and elastin, enzymes, and cellular membranes) is
needed before optimal treatment for, or protection from exposures
can be developed.
4. Epidemiology of Oxides of Nitrogen
In order to determine the effect of NOX on the health of the
general population, epidemiological research must be expanded to
include: (1) studies to determine which segments of the popula-
tion are most susceptible to the oxides of nitrogen; (2) studies to
precisely delineate the relationship between methemoglobin levels,
peripheral blood alterations, and nitrogen oxide concentrations;
(3) replication of studies of the enhanced susceptibility to respira-
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2720 LEGAL COMPILATION—AIR
tory infection that occurs with exposure to ambient levels of NOX;
and (4) studies to determine the relationship between other pollu-
tants and the oxides of nitrogen and their material effect on
human health.
L. CONCLUSIONS
Derived from a careful evaluation of the studies cited in this
document, the conclusions given below represent the best judg-
ment of the scientific staff of the Air Pollution Control Office of
EPA regarding the effects that may occur when various levels of
nitrogen oxides are reached in the ambient air. More detailed
information from which the conclusions were derived, and the
qualifications that entered into the considerations of these data,
can be found in appropriate chapters of this document.
1. Nitric Oxide
a. Effects on Humans
No evidence shows that NO produces significant adverse health
effects at the ambient atmospheric concentrations thus far meas-
ured (chapter 9, section B).
6. Effects on Materials and Vegetation
Damaging effects to materials at ambient pollutant levels of
nitrogen oxides have been observed; however, concentrations of
NO producing these effects have not been precisely determined
(chapter 7, sections C and D).
When beans were exposed to concentrations of 12.3 mg/m8 (10
ppm), apparent photosynthesis was reduced 50 to 70 percent;
when exposed to 4.9 mg/m3 (4 ppm), a 10 percent reduction
occurred (chapter 8, section B).
c. Effects on Laboratory Animals
A concentration of 3,075 mg/m3 (2,500 ppm) is lethal to mice
after a 12-minute exposure. Fully reversible inhibition of bac-
terial hydrogenase activity occurs at a concentration of 24.6 mg/
m3 (20 ppm) (chapter 9, sectionB).
2. Nitrogen Dioxide
a. Effects on Humans
(1) Short-Term Exposure. Limited studies show that exposure
to N02 for less than 24 hours continuously can have several con-
centration-dependent effects.
1. The olfactory threshold value of N02 is about 225
(0.12 ppm) (chapter 9, section C.2.a.l).
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GUIDELINES AND REPORTS 2721
2. Exposure to 9.4 mg/m3 (5 ppm) for 10 minutes has pro-
duced transient increase in airway resistance (chapter 9, section
C.2a.2).
3. Occupational exposure to 162.2 mg/m3 (90 ppm) for 30
minutes has produced pulmonary edema 18 hours later, accompa-
nied by an observed vital capacity that was 50 percent of the value
predicted for normal function (chapter 9, section C.2.b).
(2) Long-Term Exposure. An increased incidence of acute res-
piratory disease was observed in family groups when the mean
range of 24-hour N02 concentrations, measured over a 6-month
period, was between 117 and 205 /*g/m3 (0.062 and 0.109 ppm)
and the mean suspended nitrate level during the same period was
3.8 jug/m3 or greater.
The frequency of acute bronchitis increased among infants and
school children when the range of mean 24-hour NO2 concentra-
tions, measured over a 6-month period, was between 118 and 156
/xg/m3 (0.063 and 0.083 ppm) and the mean suspended nitrate
level during the same period was 2.6 /ug/m3 or greater (chapter
10, section C.I).
Yearly average N02 concentrations exceed the Chattanooga
health-effect-related value of 113 /xg/m3 (0.06 ppm) in 10 percent
of cities in the United States with populations of less than 50,000,
54 percent of cities with populations between 50,000 and 500,000,
and 85 percent of cities with populations over 500,000 (chapter
10, section d.).
6. Effects on Materials and Vegetation
Although damage to materials has been attributed to the oxides
of nitrogen in ambient atmospheres, the precise air-concentrations
producing these effects have not been determined (chapter 7, sec-
tions C and D).
Crops and ornamental plants can be classified into three groups
with respect to NOX sensitivity: sensitive, low sensitive, and resis-
tant. Several characteristic effects have been observed among the
sensitive plants studied with regard to direct N02 exposure.
1. Exposure to 470 /ug/m3 (0.25 ppm) of N02 for 8 months
caused leaf abscission and decreased yield among navel oranges
(chapter 8, section G).
2. Exposure to N02 concentrations of 940 ng/ms (0.5 ppm) for
35 days resulted in leaf abscission and chlorosis on citrus fruit
trees (chapter 8, section G).
3. Exposure to N02 concentrations of 1.9 mg/m3 (1 ppm) for 1
day can cause overt leaf injury to sensitive plants (chapter 8,
section G).
-------
2722 LEGAL COMPILATION—AIR
c. Effects on Laboratory Animals
(1) Short-Term Exposure. Short-term effects of N02 on ani-
mals can be summarized by the analyses of five salient experi-
ments.
1. Exposure of rats to either 940 ^g/m3 (0.5 ppm) for 4 hours,
or 1.9 mg/m3 (1.0 ppm) for 1 hour has produced degranulation
of lung mast cells (chapter 9, section C.l.b.3).
2. Structural changes in collagen were observed in rabbits ex-
posed to 1.9 mg/m3 (1.0 ppm) for 1 hour (chapter 9, section
C.l.b.2).
3. The threshold for increased susceptibility of mice to respira-
tory infection by K. pneumoniae is 6.6 mg/m3 (3.5 ppm) for 2
hours (chapter 9, section C.l.d).
4. Exposure of monkeys to 28.2 to 94.0 mg/m3 (15 to 50 ppm)
for 2 hours has produced damage to their lungs, heart, liver, and
kidneys and pulmonary changes that resemble those seen in
human emphysema (chapter 9, sections C.l.b.3 and C.l.c.l).
5. In rabbits exposed to 47.0 mg/m3 (25 ppm) for 3 hours
interferon formation and resistance to viral infection decreased
(chapter 9, section C.l.d).
(2) Long-Term Exposure. Long-term exposure to N02 altered
several functions in animal circulatory and respiratory systems.
1. Structural changes were found in lung tissue collagen from
rabbits exposed to 470 /*g/m3 (0.25 ppm) 4 hours a day for 6
days (chapter 9, section C.l.b.2).
2. Enhanced susceptibility of mice to respiratory infection by K.
pneumoniae was observed after 3 months of continuous exposure
to 940 ju,g/m3 (0.5 ppm) (chapter 9, section C.l.d).
3. Polycythemia has been reported in rats and monkeys exposed
continuously to 3.8 mg/m3 (2.0 ppm) for 3 weeks (chapter 9,
section C.l.c.3).
4. Changes resembling those seen in human emphysema were
reported in the following: mice exposed 6 to 24 hours daily, for a
period of 3 to 12 months to 940 /tg/m3 (0.5 ppm) (chapter 9,
section C.l.b.3) ; rats continuously exposed to 18.8 to 47.0 mg/m3
(10 to 25 ppm) for 4 to 12 months (chapter 9, section C.l.b.3) ;
and dogs continuously exposed to 47.0 mg/m3 (25 ppm) for 6
months (chapter 9, section C.l.b.3).
3. Other Nitrogen Oxide Effects
a. Photochemical Relationships
An observation-based model applied to ambient NOX, HC, and
oxidant interrelationships showed that peak oxidant yield was de-
-------
GUIDELINES AND REPORTS 2723
pendent on the concentration of both reactants. Analysis of data
from three urban areas indicated that a reference concentration of
200 /ig/m3 (0.1 ppm) maximum daily 1-hour-average OX could
be associated with a hydrocarbon range of 200 to 930 /xg/m3 (0.3
to 1.4 ppm C) 6- to 9-a.m. nonmethane hydrocarbon, expressed as
methane, when the 6- to 9-a.m. average NOX, expressed as N02,
was below 80 /xg/ms (0.04 ppm). A similar observation related an
NOX range of 80 to 320 /xg/m3 (0.04 to 0.16 ppm), expressed as
N02, with 200 /xg/m3 (0.3 ppm C) nonmethane hydrocarbon.
b. Stress Corrosion
Nitrogen oxide reaction products have been associated with cor-
rosion and failure of electrical components. In two cities where
this problem has been observed, the 1965 average airborne parti-
culate nitrate concentration were 3.0 and 3.4 /xg/m3 with asso-
ciated average NOX levels of 124 and 158 /*g/m3 (0.066 to 0.084
ppm).
M. RESUME
Adverse health effects, as evidenced by a greater incidence of
acute bronchitis among infants and school children, have been
observed, under the conditions prevailing in the areas where stud-
ies were conducted, when the mean 24-hour N02 concentration,
measured by the Jacobs-Hochheiser method, over a 6-month pe-
riod, varied from 118 to 156 /xg/m3 (0.063 to 0.083 ppm). On an
annual basis, a maximum 24-hour average as low as 284 iig/m3
(0.15 ppm) would be expected to be associated with a 6-month
mean of 118 /xg/m3. Adverse health effects, as evidenced by an
increased incidence of acute respiratory disease, have been ob-
served in family groups when the mean 24-hour NO2 concentra-
tion measured over a 6-month period was between 117 and 205
/xg/m3 (0.062 and 0.109 ppm) and the mean suspended nitrate
level was 3.8 ju.g/m3 or greater.
An analysis of 3 years of data collected in three American cities
shows that on those several days a year when meteorological con-
ditions are most conducive to the formation of photochemical oxi-
dant, and the 6- to 9-a.m. nonmethane hydrocarbon concentration
is 200 /Ag/m3 (0.3 ppm C), a 6- to 9-a.m. NO* concentration
(measured by the continuous Saltzman Method and expressed as
N02) that ranges between 80 and 320 ftg/m3 (0.04 and 0.16
ppm) would be expected to produce a 1-hour photochemical oxi-
dant level of 200 iig/m3 (0.1 ppm) 2 to 4 hours later. If this same
functional relationship exists at the lowest levels at which photo-
-------
2724 LEGAL COMPILATION—Am
chemical oxidant has been observed to adversely affect human
health, the corresponding nonmethane hydrocarbon concentration
would be approximately 130 /xg/m3 (0.2 ppm C) and the 6- to
9-a.m. NOX level would be as high as 214 ,ug/ni3 (0.11 ppm).
Adverse effects on vegetation such as leaf abscission and de-
creased yield of navel oranges have been observed during fumiga-
tion studies when the N02 concentration (measured by the contin-
uous Saltzman Method) was 470 ^g/m3 (0.25 ppm) during an
8-month period.
Nitrate compounds have been identified with corrosion and fail-
ure of electrical components. In two cities where these effects were
observed, the average airborne nitrate particulate concentrations
were 3.0 and 3.4 /ig/m3 with associated average NOX levels of 124
and 158 //.g/m3 (0.066 and 0.084 ppm).
It is reasonable and prudent to conclude that, when promulgat-
ing ambient air quality standards, consideration should be given
to requirements for margins of safety that would take into ac-
count possible effects on health, vegetation, and materials that
might occur below the lowest of the above levels.
N. REFERENCES
1. Air Quality Criteria for Photochemical Oxidants. National
Air Pollution Control Administration. Washington, D.C. Publica-
tion No. AP-63. March 1970.
2. Shy, et al. The Chattanooga School Study: Effects of Commu-
nity Exposure to Nitrogen Dioxide. Incidence of Acute Respira-
tory Illness. To be published in J. Air Pollut. Contr. Ass., 1970.
3. Pearlman, M. E., et al. Nitrogen Dioxide and Lower Respira-
tory Illness. Submitted to Pediatrics, 1970.
4. Henschler, P., et al. Olfactory Threshold of Some Important
Irritant Gases and Manifestations in Man by Low Concentrations.
Arch. Gewerbepathol. Gewerbehgy., Berlin, 17: 547-570, 1960.
5. Mueller, P. K. and M. Hitchcock. Air Quality Criteria-Toxi-
cological Appraisal for Oxidants, Nitrogen Oxides, and Hydrocar-
bons. J. Air Pollut. Control Ass., 19: 670-676, 1969.
6. Thompson, C. R., et al. Effects of Continuous Exposure of
Navel Oranges to N02. Atmos. Environ. In Press, 1970.
7. Thomas, H. V., P. K. Mueller, and G. Wright. Response of
Rat Lung Mast Cells to Nitrogen Dioxide Inhalation. J. Air Pollut.
Contr. Ass., 17: 33-35, 1967.
8. Blair, W. H., M. C. Henry, and R. Ehrlich. Chronic Toxicity
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GUIDELINES AND REPORTS 2725
of Nitrogen Dioxide: II. Effects on Histopathology of Lung Tis-
sue. Arch. Environ. Health, 18: 186-192, 1969.
9. Ehrlich, R. and M. C. Henry. Chronic Toxicity of Nitrogen
Dioxide: I. Effects on Resistance to Bacterial Pneumonia. Arch.
Environ. Health, 17: 860-865, 1968.
10. Freeman, G., N. J. Furiosi and G. B. Haydon. Effects of
Continuous Exposure to 0.8 ppm N02 on Respiration of Rats.
Arch. Environ. Health, 13: 454-456, 1966.
11. Freeman, G. and G. B. Haydon. Emphysema After Low-
Level Exposure to N02. Arch. Environ. Health, 8: 125-128, 1964.
12. Buell, G. C., Y. Tokiwa, and P. K. Mueller. Lung Collagen
and Elastin Denaturation In vivo Following Inhalation of Nitro-
gen Dioxide. California State Dept. of Public Health. (Presented
at the Annual Air Pollution Control Association Meeting.) San
Francisco. Paper No. 66-7, June 1966.
13. Heck., W. W. Plant Injury Induced by Photochemical Reac-
tion Products of Propylene-Nitrogen Dioxide Mixtures. J. Air Pol-
lut. Contr. Ass., 14: 255-261, July 1964.
14. Freeman, G., et al. The Subacute Nitrogen Dioxide - Induced
Lesion of the Rat Lung. Arch. Environ. Health, 18: 609-612, 1969.
15. Abe, M. Effects of Mixed N02 - S02 Gas on Human Pulmon-
ary Functions. Bull. Tokyo Med. Dent. Univ., 14: 415-433, 1967.
16. Henry, M. C., R. Ehrlich, and W. H. Blair. Effects of Nitro-
gen Dioxide on Resistance of Squirrel Monkeys to Klebsiella pneu-
moniae Infection. Arch. Environ. Health, 18: 580-587, 1969.
4.2b CONTROL TECHNIQUES
4.2b(l) "CONTROL TECHNIQUES FOR CARBON MONOXIDE
FROM STATIONARY SOURCES"
National Air Pollution Control Administration, March 1970
CONTROL TECHNIQUES FOR CARBON MONOXIDE FROM
STATIONARY SOURCES
(Summary of "Control Techniques for Carbon Monoxide Emis-
sions from Stationary Sources," published by the National Air
Pollution Control Administration in March 1970)
Carbon monoxide (CO) is a colorless, odorless, tasteless gas,
about 97 percent as heavy as air. It is a major pollutant, by
quantity, having a current annual emission rate within the United
States of about 100 million tons.
Carbon monoxide is formed when carbonaceous fuels are burned
with insufficient oxygen to form carbon dioxide (C02). It is also
-------
2726 LEGAL COMPILATION—AIR
copiously formed from C02 at high temperatures under reducing
conditions. It is the first product in the oxidation of the carbon in
a fuel. Even if there is sufficient oxygen for complete reaction to
form C02 the latter may still break down to form CO, owing to
the dissociation brought about by high temperatures. Dissociation
of C02 to CO for the temperatures cited are listed in Table 1.
Some CO can, therefore, form in high-temperature furnaces, even
from C02 itself. If the equilibrium, C02 *=? CO + O, is "frozen" by
rapid cooling, some of the CO does not have time to recombine and
persists. Low cooling rates reduce CO emissions. Lean fuel-air
mixtures favor low CO concentrations. CO emissions would be
increased, however, by recycling cold flue gas to lean mixtures.
Table 1 .—Dissociation of C02 to CO
Temperature, °F
1,340.._ .
2,060____
2,780
2,960
3,140
3,495
Percentage
dissociation
2X10~5
.. . 1.5X10-2
5 5X10-1
1.0
1.8
5.0
Table 2.—Estimated CO Emissions in the United States During 1968 (10e tons)
Source Emissions
Transportation 63.8
Fuel combustion in stationary sources 1.8
Solid waste burning 7.8
Industrial processes 9.7
Forest and structural fires 5.0
Prescribed agricultural and forest burning 10.7
Coal refuse fires 1.2
Total 100.0
SOURCES OF CARBON MONOXIDE
Estimated emissions of CO within the United States during
1968 are given in Table 2.
Table 2 does not include estimates of emissions from use of explo-
sives and some relatively small sources such as the electrochemical
and electrometallurgical industries.
By far the greatest source of CO emissions is the automobile.
Automobile emissions are covered in detail in a companion docu-
ment, AP-66, Control Techniques for Carbon Monoxide, Nitrogen
Oxide, and Hydrocarbon Emissions from Mobile Sources.
Major emissions include forest fires, structural fires, and burn-
ing banks of coal refuse. Industrial sources include foundries,
-------
GUIDELINES AND REPORTS 2727
petroleum refineries, and kraft pulp mills. Burning of solid waste
produces more CO than all the conventional stationary fuel com-
bustion sources. Tables 3 and 4 are summaries of the methods
employed for controlling CO emissions.
4.2b(2) "CONTROL TECHNIQUES FOR CARBON
MONOXIDE, NITROGEN OXIDE AND HYDROCARBONS
FROM MOBILE SOURCES"
National Air Pollution Control Administration, March 1970, AP-66
CONTROL TECHNIQUES FOR CARBON MONOXIDE, NI-
TROGEN OXIDE, AND HYDROCARBONS FROM MOBILE
SOURCES \
(Summary of "Control Techniques for Carbon Monoxide, Nitro-
gen Oxide, and Hydrocarbon Emissions from Mobile Sources,"
published by the National Air Pollution Control\Administration in
March 19 70)
\
This document considers the techniques for the control and pre-
vention of the emission of carbon monoxide (CO), nitrogen oxides
(NOX), and hydrocarbons (HC) from all types of vehicles. This
approach has been pursued because measures taken to reduce
emissions of one contaminant may affect emissions of another.
Although these mobile sources emit other contaminants, the dis-
cussion in this document is restricted to those cited above.
Transportation in general is a major source of CO, NOX, and
HC. In 1968 estimated emissions from vehicles in the United
States were 64 million tons of CO, 8 million tons of NOX, and 17
million tons of hydrocarbons. The primary mobile source of these
emissions is the gasoline-powered motor vehicle. Other significant
sources are diesel-powered vehicles and aircraft. Lesser sources
are vessels and boats operating on inland waterways, off-road
utility and recreational vehicles, construction equipment, motorcy-
cles, power lawn mowers, and other utility tools.
Emissions from a gasoline-powered vehicle without any emis-
sion control systems originate from the fuel tank, carburetor,
crank-case, and engine exhaust. The exhaust is the source of al-
most all CO and NOX and more than half of the HC. Formation of
the three in the combustion chamber is influenced by such factors
as air-fuel ratio, ignition timing and quality, intake-manifold vac-
uum, engine compression ratio, engine speed and load, fuel distri-
bution between cylinders and within a cylinder, coolant tempera-
ture, and combustion chamber configuration and deposits. Emis-
-------
2728 LEGAL COMPILATION—AIR
sion constituents can react chemically after release into the atmos-
phere. Several reactivity indexes have been proposed and are used
to evaluate and quantify the tendency of certain HC to react
photochemically.
LEGISLATIVE PROGRESS
The Clean Air Act, as amended, is the legislative basis for the
Federal air pollution control program for new motor vehicles;
however, California pioneered with legislation in this area in
1947. Initial legislation by the Federal Government was in 1955
with the enactment of the Air Pollution Control Act. Subsequent
legislation resulted in mandatory installation of crankcase controls
on all new cars sold in California beginning in 1963, and on new
cars sold nationwide beginning with the 1968 models. The automo-
bile manufacturers, however, had voluntarily installed these de-
vices on all new cars sold in California beginning with the 1961
models and on new cars sold nationwide beginning with the 1963
models. Exhaust emission standards for HC and CO, applicable to
new cars sold in California, became effective with the 1966 model
year. Federal regulations prescribed the same standards for new
light-duty vehicles sold nationally beginning with the 1968 models,
and more stringent standards beginning with the 1970 models.
Federal regulations also prescribe standards for evaporative HC
emissions beginning with the 1971 models.
Federal standards for new vehicles will cause a decrease in HC
and CO emissions beyond 1980 in spite of the increase in vehicle
population. Nitrogen oxide emissions, however, will continue to
increase at a rate augmented by efforts to control CO and HC
emissions, unless NOX emissions are specifically controlled. Prior
to 1970, exhaust emission regulations for light-duty vehicles were
expressed in terms of concentrations, but beginning with the 1970
standards, mass units, considered to be more equitable for various
vehicle sizes, are being used.
Although the Federal Government has specifically preempted
the authority to set emission standards for new vehicles, a special
waiver provision permits the State of California to establish and
enforce more restrictive standards and procedures than the na-
tional standards. California has already established standards for
NOX beginning with 1971 models, becoming more stringent in
1972, and still more stringent in 1974. The California standards
for HC in 1972 are also more strict than existing Federal stand-
-------
GUIDELINES AND REPORTS 2729
ards. State standards for evaporative emissions became effective
in California beginning with 1970 models.
Automobile manufacturers may request that prototype new ve-
hicles be certified as complying with established emission stand-
ards, before production vehicles of substantially the same con-
struction are sold. The National Air Pollution Control Administra-
tion (NAPCA) maintains its principal laboratory for this purpose
in Ypsilanti, Michigan, where prototype new vehicles can be certi-
fied and vehicles in public use are checked to determine the dura-
bility or continued effectiveness of control devices and systems in
service. A surveillance program conducted by the State of Califor-
nia indicates that the effectiveness of control systems for HC and
CO decreases in service, but that they are becoming generally
more effective with succeeding years (although not significantly
for HC in 1968 and 1969) even though applicable CO and HC
emission standards have not changed for the vehicles surveyed.
STATE EMISSION CONTROL PROGRAMS
Federal authority for the control of vehicular emissions ends
with the sale of new vehicles. States should be encouraged to take
action to ensure the continued operation and efficiency of emission
control systems and other automotive systems that affect emis-
sions. Reduced effectiveness of control systems after they leave the
manufacturer may be due to a number of causes, including gross
malfunction, improper adjustment, and deliberate removal or in-
activation.
A state may determine that its air quality in certain areas is
such that a state control program for vehicle emissions is neces-
sary to augment the degree of control provided by the Federal
standards for new cars sold since 1968. Options available to the
states, such as inspection and maintenance programs may reduce
CO and HC exhaust emissions.
Other methods are available to check crankcase control devices
and may be considered in addition to exhaust inspection. Future
vehicles will be equipped with evaporative control systems. Inspec-
tion and maintenance of these may be desirable, but little informa-
tion on possible programs is currently available.
States should select methods for reducing vehicular emissions
for both the control of existing air pollution and the prevention of
future air pollution. Many practical difficulties may arise in imple-
menting a statewide inspection and a maintenance system, but
experience now being obtained by several states should be of as-
sistance.
526-705 O - 74 - 25
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2730 LEGAL COMPILATION—AIR
Five programs of the Coordinating Research Council, which are
concerned with surveillance, maintenance, and inspection, are of
particular significance to this document, even though the bulk of
information generated by them will not be available until 1971 or
1972. These are Cooperative Air Pollution Engineering (CAPE)
Projects 14 through 18.
Although it has been shown that various inspection and mainte-
nance programs can reduce emissions of CO and HC, additional
data are needed to demonstrate the cost and cost-effectiveness of
such programs in practice.
In addition to inspection and maintenance of vehicles, other
actions that may assist in reducing emissions from motor vehicles
include the following:
1. Substitution of public transportation, in part, for the
private automobile in urban areas.
2. Application of exhaust emission control devices (which,
reportedly, will be available soon) to pre-1968 (pre-exhaust-
controlled) light-duty vehicles.
3. Planning of freeways and traffic control systems to mini-
mize stop- and go-driving and thus affect emissions.
States may wish to consider long-range planning with respect to
vehicle emissions. Some options of this type are listed below:
1. Planning for emergency actions to reduce vehicular emis-
sions during periods when unfavorable weather conditions
create an air pollution emergency.
2. Planning for governmental certification of maintenance
and inspection personnel to protect the public from mechanics
who inadvertently cause an increase in vehicular emissions
through maladjustment or improper maintenance of engine
components.
As an aid in estimating the quantity of vehicle emissions in a
certain region, a procedure developed by the National Air Pollu-
tion Control Administration is available for use by states or com-
munities. It requires only information concerning vehicle registra-
tions or vehicle miles to arrive at estimated emissions.
EMISSION CONTROL SYSTEMS
Emission control systems in use on current-model motor vehi-
cles include positive crankcase ventilation systems (in which va-
pors are routed to the fuel induction system) and exhaust emis-
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GUIDELINES AND REPORTS 2731
sion control systems (and evaporative controls in California be-
ginning with 1970 models). The exhaust controls are of two gen-
eral types and reduce emissions either by oxidizing CO and un-
burned HC in the exhaust system or by minimizing their quanti-
ties emanating from the engine cylinders. The air injection sys-
tem was used on some 1968 and 1969 domestic models and consists
of employment of an air pump to inject air into the exhaust
manifold at each exhaust valve. The second commonly used ap-
proach for controlling exhaust CO and HC is currently more prev-
alent and consists of engine modifications to minimize formation
of contaminants in the cylinders. This approach consists of design-
ing engines with improved air-fuel mixing and distribution sys-
tems and tailoring ignition characteristics for optimum emission
control.
Evaporative controls, required on new cars in California begin-
ning with 1970 models and nationally in 1971, collect vapors from
the fuel tank and carburetor and vent them either to the crankcase
or to an activated-carbon canister. In either case, the collected
vapors are eventually returned to the fuel induction system and
burned in the engine.
Control systems for NOX emissions are under development.
Some of the technical approaches being considered are exhaust gas
recirculation and catalytic reduction. Since systems incorporating
these approaches have not been produced in large numbers, accu-
rate data on costs are not available.
FUEL MODIFICATION
It is sometimes possible to alter emissions of CO, NOS, and HC
by modifying the volatility of the fuel, its constituent hydrocarbon
types, or its additive content.
The use of liquefied petroleum gas (LPG), liquefied natural gas
(LNG), and compressed natural gas (CNG) as fuels for conven-
tional vehicle engines is being considered and appears promising.
Use of these fuels, however, involves problems of fuel distribution
and fuel storage and fairly high installation and engine modifica-
tion costs. Supplies of these fuels are also very limited compared
to currently used vehicle fuels.
State governments may wish to encourage use of specific mobile
power sources known for their low emissions. These include the
automotive gas turbine, the steam engine, electric drives, the
free-piston engine, the Stirling engine, and the stratified-charge
engine.
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2732 LEGAL COMPILATION—Am
4.2b(3) "CONTROL TECHNIQUES FOR HYDROCARBONS
AND ORGANIC SOLVENTS FROM STATIONARY
SOURCES"
National Air Pollution Control Administration, March 1970
CONTROL TECHNIQUES FOR HYDROCARBONS AND OR-
GANIC SOLVENTS FROM STATIONARY SOURCES
(Summary of 'Control Techniques for Hydrocarbon and Or-
ganic Solvent Emissions from Stationary Sources,"published by
the National Air Pollution Control Administration in March
1970)
The effects of hydrocarbon and organic solvent emissions are of
two types, direct and indirect. Direct effects are caused by the
original, unaltered emissions, and indirect effects are caused by
substances formed by photochemical reactions of the original emis-
sions with other substances in the atmosphere. The purpose of this
document is to make information available on techniques for the
control of organic emissions from stationary sources.
STATIONARY SOURCES OF HYDROCARBON AND
ORGANIC SOLVENT EMISSIONS
Sources of hydrocarbon emissions include petroleum mining,
gasoline distribution and marketing, chemical manufacturing coal
coking, fuel burning, waste disposal, and food processing. Sources
of organic solvent emissions include manufacture and application
of protective coatings, manufacture of rubber and plastic prod-
ucts, degreasing and cleaning of metal parts, dry cleaning opera-
tions, printing, and manufacture of chemicals.
CONTROL TECHNIQUES AND EQUIPMENT
Methods used to control hydrocarbon and organic solvent emis-
sions are (1) operational or process changes, (2) substitution of
materials, and (3) installation of control equipment. The tech-
niques used in control devices are of four classifications: incinera-
tion, adsorption, absorption, and condensation.
Incineration devices are of two types, direct-flame afterburners
and catalytic afterburners. Direct-flame afterburners utilize a
flame to complete oxidation of the organic emissions. Flame cover-
age, turbulence, effluent residence time, and temperature are im-
portant in the design of an afterburner. Temperatures of 1200
degrees to 1400 degrees F and residence times of 0.3 to 0.6 second
-------
GUIDELINES AND REPORTS 2733
are usually required. Removal efficiencies of direct-flame afterbur-
ners can be high; organic particulates are removed effectively;
and no secondary disposal problems are encountered. Operational
costs are high unless heat-recovery equipment is installed.
Catalytic afterburners utilize a catalyst so that emissions can be
oxidized at a lower temperature than could otherwise be done.
Fuel costs are thus lower, but removal efficiencies are also lower.
Catalysts are subject to poisoning and deactivation from the heat
present.
Activated-carbon adsorbers collect organic vapors in the capil-
lary surface of the solid adsorbent. After the carbon bed has
adsorbed the optimum amount of organic material, the gas stream
is stopped and the carbon bed is steam stripped to remove the
organic material. The carbon bed is then ready for reuse. The
steam and organic material are condensed, and the organic is
recovered by decantation or distillation. Two or more carbon-con-
taining vessels are used, one adsorbing while the other is desorb-
ing.
Costs of adsorbing systems and their operations are high, but
recovery of valuable materials enhances the feasibility of such
operations. High removal efficiencies are possible. Streams con-
taining resin-forming gases cannot be handled by carbon adsor-
bers because the resins plug the carbon beds.
Absorption is the transfer of a soluble component of a gas phase
into a relatively nonvolatile liquid absorbent. Common absorbents
are water, mineral oil, nonvolatile hydrocarbons, and aqueous so-
lutions such as solutions of oxidizing agents or alkalis. Contact
between gas and liquid is provided in bubble-plate columns, packed
towers, jet scrubbers, spray towers, and venturi scrubbers.
Absorbers are widely used when gas and vapor concentrations
are high; however, such equipment is usually classified as produc-
tion equipment, and not as emission control equipment. Absorbers
are not widely used when concentrations are low since large and
expensive equipment would be required to achieve good removal
efficiencies.
Condensers collect organic emissions by lowering the tempera-
ture of the gaseous stream to the condensation point of that mate-
rial. Condensers are of two types, contact and surface. In contact
condensers, the gaseous stream is brought into direct contact with
the cooling liquid, the condensed material mixing with the coolant.
In a surface condenser, the vapor to be condensed and the cooling
fluid are separated by a metal wall.
-------
2734 LEGAL COMPILATION—AIR
Condensers used in the petroleum and chemical industries to
condense concentrated vapors are classified as production equip-
ment. High removal efficiency cannot be achieved with low concen-
trations; condensers are, therefore, useful as preliminary devices
to be followed by a more efficient device such as an afterburner or
adsorber.
Use of Less Photochemically Reactive Materials
Collection of organic emissions from the painting of buildings
and structures is impractical. In operations whatever collection is
possible but is not financially feasible the solution of less reactive
materials is a possible control technique.
Los Angeles County limits the emissions from organic solvents
by Rule 66. All the normally used solvents are divided into two
groups, those classified as photochemically reactive and those not
photochemically reactive. Emissions from the reactive group are
restricted, but emissions from the nonreactive group are not lim-
ited, except when flame contact, baking, or heat-curing is involved.
Many solvents with more than the allowed amount of reactive
materials have been reformulated by the manufacturer with mate-
rials in the nonreactive group.
The San Francisco Bay Area Pollution Control District limits
emission of only very reactive compounds. These are defined as
olefins, substituted aromatics, and aldehydes.
Control Systems for Industrial Processes
Petroleum Refining
Evaporation losses during storage are minimized "by use of float-
ing roof tanks, pressure tanks, and vapor conservation or recovery
systems. Hydrocarbons from catalyst regenerators can be con-
trolled by waste heat boilers. Leakage from valves, pumps, and
compressors can be reduced by systematic maintenance of connec-
tions and seals. Waste water separators can be controlled by en-
closing the evaporator tanks. Vapor recovery systems or smokeless
flows are utilized to control hydrocarbon vapors from blowdown
systems. Stripping gases from acid treating, doctor treating, and
caustic treating and air-blowing effluents can be controlled by
incineration.
Gasoline Distribution Systems
Vapors emitted during the loading of gasoline tank trucks can
be collected and delivered to a vapor disposal system. The collec-
tion system consists of a tight fitting hatch and a vapor delivery
line. For top-loading tanks, the vapor delivery line is an annular
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GUIDELINES AND REPORTS 2735
space around the gasoline delivery line. For bottom-loading tanks,
the vapor line is a separate line connected at the top of the tank.
Vapors can be delivered to a gas-blanketed vapor holder and used
as fuel in boilers and heaters where the load rack is adjacent to
the refinery. For storage and loading facilities at other locations,
packaged vapor recovery units have been developed in which the
vapors are compressed and reabsorbed in gasoline.
Chemical Plants
The principal raw materials for synthetic organic products are
derived mostly from petroleum and to a lesser extent from the
by-products of the coking of coal. These materials are processed
through the following types of collections; alkylation, hydrogena-
tion, dehydrogenation, esterification, halogenation and dehalogena-
tion, oxidation, nitration, and polymerization.
Waste gases from processing units can be collected and deliv-
ered to a burner, to a gas holder, or into a fuel header system.
Waste gases from units producing chlorinated hydrocarbons can
be processed to recover by-product hydrochloric acid. Direct flame
and catalytic afterburners are used to eliminate organic vapors
and mists from many off-gases.
Paint, Lacquer, and Varnish Manufacture
Emissions from paint and lacquer manufacture occur during
mixing, grinding, and thinning operations. Varnish ingredients
must be "cooked" to promote such reactions as depolymerization,
esterification, isomerization, melting, and bodying. Emissions con-
tain fatty acids, aldehydes, acrolein, glycerol, acetic acid, formic
acid, and complex residues of thermal decomposition. Control sys-
tems consist of condensers, scrubbers, and afterburners.
Rubber and Plastic Products Manufacture
Emissions from rubber product manufacture occur during heat
plasticization, chemical plasticization, and vulcanization. Control
techniques include carbon adsorption, direct-flame and catalytic
incineration, and reformulation to nonphotochemically reactive
materials. In plastic products manufacture, emissions can occur
from curing ovens, particularly when dioctyl phthalate is used as
a plasticizer. Such mists can be controlled with high-energy scrub-
bers or with afterburners.
Surface Coating Applications
Emissions of hydrocarbons from the application of paint, var-
nish, and similar coatings are due to the evaporation of the sol-
vents, diluents, and thinners. Where controls are required, refor-
mulation with nonphotochemically reactive solvents is a method of
-------
2736 LEGAL COMPILATION—AIR
control. Afterburners have been used to control emissions from
paint bake ovens. These ovens can sometimes be redesigned to
reduce the volume of gases to be handled, effecting considerable
savings. Heat recovery systems can lower operating costs by re-
ducing fuel requirements.
Degreasing Operations
Most vapor-phase degreasers use chlorinated hydrocarbon sol-
vents, principally trichloroethylene. Less photochemically reactive
1,1,1,-trichloroethane (methyl chloroform) and perchloroethylene
can be substituted. Activated-carbon adsorbers can be used to con-
trol emissions in some applications. Solvent emissions can be mini-
mized by elimination of drafts, good drainage of work items, con-
trolled speed of work entering and leaving work zone, and cover-
ing of tank whenever possible.
Dry Cleaning
Dry cleaning is done by two processes: those using petroleum
solvents and those using perchloroethylene or other halogenated
solvents. In plants using perchloroethylene, vapor is recovered by
water-cooled condensers, which may be followed by activated-car-
bon adsorbers. The value of the solvent makes recovery economi-
cally feasible. Plants using petroleum solvents can be controlled, if
necessary, by using solvents reformulated to be nonphotochem-
ically reactive. Control by activated carbon may be feasible.
Stationary Fuel Combustion
Hydrocarbons may be emitted if combustion is not complete.
When properly designed and operated, stationary fuel combustion
equipment is not a serious source of organic emissions.
Metallurgical Coke Plants
The hydrocarbons from the coking of coal are collected to re-
cover by-products. Emissions occur during charging operations
and from improperly fitting doors and other leaks. Emissions dur-
ing charging can be reduced by steam-jet aspirators in the collec-
tion pipes. Self-sealing doors and good maintenance programs can
reduce emissions.
Sewage Treatment Plants
Primary sewage plants emit hydrocarbons from the screening
and grit chambers, and from the settling tanks. Activated-sludge
plants emit gas from the aeration tanks. Trickling filter plants
emit organic gas from the filters, the clarifiers, and from the
sludge-digestion tanks. Control of emissions can be accomplished
by covering or enclosing the various treating units and oxidizing
or combusting the effluent gases.
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GUIDELINES AND REPORTS 2737
Waste Disposal
Burning of waste materials can cause emissions of hydrocar-
bons. Open burning and inefficient incinerators are the predomi-
nant sources of such emissions. Control can be achieved by the use
of multiple-chamber incinerators or by disposing of the waste in
sanitary landfills.
Miscellaneous Operations
Emissions from deep fat fryers and coffee roasters can be con-
trolled by afterburners. Fish cookers can be controlled by condens-
ers. Evaporators of liquids from fish processing can be controlled
by condensers and scrubbers, and fish meal driers by scrubbing
with chlorinated water. Non-condensible gases from charcoal man-
ufacturing can be burned.
ECONOMICS
Economic considerations in air pollution control include: (1)
the selection of control techniques and equipment; (2) the assess-
ment of the impact of control on product prices, profits, invest-
ments, and value added to the product; and (3) the identification
of the many direct and indirect costs of installing and operating
air pollution control equipment. Process alterations or substitu-
tions are usually considered first in selecting a control technique.
If control equipment is necessary, the required emission reduction,
process stream characteristics, and plant facilities are evaluated
in order to select the system that will optimize costs and benefits.
Value of recovered materials may be a significant cost offset.
4.2b(4) "CONTROL TECHNIQUES FOR NITROGEN OXIDES
EMISSIONS FROM STATIONARY SOURCES"
National Air Pollution Control Administration, March 1970
CONTROL TECHNIQUES FOR NITROGEN OXIDES FROM
STATIONARY SOURCES
(Summary of "Control Techniques for Nitrogen Oxide Emissions
from Stationary Sources," published by the National Air Pollution
Control Administration in March 1970)
DEFINITION
In this document, the term "nitrogen oxides" or "NOX" refers
to either or both of two gaseous oxides of nitrogen, nitric oxide
(NO) and nitrogen dioxide (NOa). These substances are impor-
-------
2738 LEGAL COMPILATION—AIR
tant in air pollution control because they are involved in photo-
chemical reactions in the atmosphere and because, by themselves,
they have undesirable physiological effects.
FACTORS INFLUENCING NOX FORMATION
Chemical Equilibrium
Under proper conditions, nitrogen and oxygen tend to combine
in accordance with the following equation:
N2 + 02 ±5 2 NO
The equilibrium concentration of NO varies with temperature; it
is negligible below 1,000°F but quite significant above 3,000°F. In
addition, it is influenced by gas composition; at a given tempera-
ture, for example, the equilibrium concentration of NO in air
exceeds that of NO in a flue gas of 3 percent oxygen content by a
factor of approximately 3.
Nitric oxide tends to react with oxygen as follows:
NO + 1/2 02 ** N02
This equation implies the coexistence of NO and N02. Calculated
equilibria indicate that the stability of N02 decreases with in-
creasing temperature. Nevertheless, from an equilibrium stand-
point, the absolute concentration of N02 increases with tempera-
ture while the ratio of its concentration to that of NO decreases
with increasing temperature.
Chemical equilibria depend only on the initial and final states
and not at all on reaction mechanisms or intermediate reaction
steps. Equilibrium concentrations are obtained after the lapse of
sufficient reaction time; therefore, they are not necessarily ob-
served experimentally. Because of the simplicity of the molecules
involved in the foregoing equations, their thermodynamic proper-
ties are accurately known and equilibrium calculations are made
easily. Such calculations serve as an estimate for emission quanti-
ties and as a guide in equipment design.
Rates of Formation
Rates of formation can be calculated by kinetic equations that
depend heavily on experimental measurements. The products ob-
tained depend in large measure on the relative speeds of the reac-
tions that actually occur. The rate of oxidation of nitrogen to NO
is highly temperature-dependent; it is very slow at 500°F, but fast
-------
GUIDELINES AND REPORTS 2739
at 4,000°F. The underlying reason is that a high level of energy is
needed to break the N-N bond of molecular nitrogen so that oxy-
gen can react. Conversely, a smaller but still relatively great
amount of energy is needed to break the N-0 bond to permit
decomposition of nitric oxide into its elements. This means that
high temperatures are required to form NO; once formed, it res-
ists any breakdown into its elements. Breakdown becomes more
and more unlikely as temperature decreases, because the energy
available for thermal breakdown diminishes rapidly with decreas-
ing temperature. Thus, an initially high temperature followed by
quick cooling, even to a relatively high temperature level, produces
large amounts of NO.
At temperatures above 2,000 °F, both NO and N02 are formed,
but the amount of N02 is usually well under 0.5 percent of the
total NOX. The oxidation of NO to N02 by oxygen, however, is
peculiar in that its rate of formation decreases with increasing
temperature. This is one of the few known reactions that exhibit
such a decrease. The resultant slow oxidation rate at high temper-
atures accounts in part for the negligible amounts of N02 fre-
quently found in hot combustion gases. Another characteristic of
the oxidation of NO to N02 by oxygen only, is the fact that the
rate varies with the square of the NO concentration. The rate of
oxidation of NO by oxygen in air falls off rapidly, therefore, with
dilution of the NO. A long period of time may be required to
oxidize trace quantities of NO by this mechanism, but photochemi-
cal reaction in sunlight accomplishes such oxidation in a much
shorter time.
As in all chemical reactions, the rates of formation and decom-
position for NO and N02 can be hastened by means of catalysts.
Attainable theoretical equilibrium concentrations are not changed
by catalysts; only the time of attainment is changed. With or
without a catalyst, equilibrium concentrations may be approached
when either a high or low NOX concentration is present.
SOURCES
Mobile sources, the largest single source category, contribute
over 40 percent of all the man-made NOX emitted in the United
States. Current knowledge on methods of control is covered in
detail in AP-66, Control Techniques for Carbon Monoxide, Nitro-
gen Oxide, and Hydrocarbon Emissions from Mobile Sources. The
next largest source is electric power generation, which is responsi-
ble for nearly 20 percent of all man-made NOX. About 40 percent
-------
2740 LEGAL COMPILATION—AIR
of NO* emitted from stationary installations is attributed to elec-
tric-generating power plants.
About 1 percent of the total man-made NOX emitted to the
ambient air of the United States is formed by chemical sources,
mainly related to the manufacture and use of nitric acid. Concen-
trations from these sources are, however, usually much greater
than those from noncombustion sources, and, therefore, often give
rise to a highly visible, brown-red gas.
CONTROL TECHNIQUES—COMMERCIALLY
DEMONSTRATED
Combustion Modifications
Two-stage combustion in oil- and gas-fired boilers has reduced
NOX emissions from power plant boilers by 30 to 50 percent.
Low-excess-air operation has reduced NOX emissions from oil-and
gas-fired power plant boilers by 30 to 60 percent, depending upon
the percentage of excess air, the design of the boiler, and the type
of firing. By changing the firing of power plant boilers from
front-wall, or opposed, firing to tangential firing, NOX has been
reduced from 30 to 40 percent.
A modified two-stage combustion technique, combined with
low-excess-air firing has reduced the stack-gas NOX concentration
emitted by two 750-megawatt gas-fired power-plant boilers from
1,500 to 175 parts per million (ppm). Nominal costs were reported
by the company with no decrease in generating capacity.
All of the above approaches are based on considerations of
chemical equilibrium and reaction rate. They involve reduction of
peak gas temperatures, trends away from oxidizing and toward
reducing atmospheres, and changes in the time-temperature his-
tory of the combustion gases. These approaches are all commer-
cially demonstrated for large oil- and gas-fired boilers, but are yet
to be demonstrated for large coal-fired boilers.
Changes in Fuel or Energy Source
Generation of electricity through the use of nuclear energy is
projected to grow in the future. Essentially, no nitrogen oxides
are emitted since this source of energy does not depend on the
combustion of fossil fuels. In 1968, 12 billion kilowatt-hours of
electric power generated from nuclear energy was reported in the
United States; reliable sources project 3,000 billion kilowatt-hours
by 1990.
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GUIDELINES AND REPORTS 2741
Waste Disposal
Substitution of sanitary landfills for open burning has proved to
be a commercially demonstrated control technique in certain areas
of the country.
Chemical Sources
Chemical vent gases normally are much more highly concen-
trated than combustion gases, and the NO content can be more
quickly oxidized by oxygen in air. If uncontrolled, these streams of
NOX may create air pollution problems when relatively high
ground-level concentrations occur.
Nitrogen oxides from chemical sources may be decolorized by
catalytic reduction using fuels, such as natural gas or hydrogen.
Such reactions are exothermic and much heat is generated. Be-
cause of practical considerations, such as catalyst life and the
temperature limitations of structural materials, only the process
of decolorization by reduction to NO has been uniformly success-
ful.
Catalytic reduction of N02 to NO is not a true control tech-
nique; it merely decolorizes the stack gas. Stack velocities and
normal atmospheric turbulence contribute to rapid dilution, with
increasingly slow rates of oxidation of NO by air. Photochemical
reactions in the atmosphere can, however, oxidize these small NO
concentrations to N02.
CONTROL TECHNIQUES—VARIED COMMERCIAL
SUCCESS
Energy Substitution
Industrial, commercial, and household thermal requirements
contribute to above-average NOX concentrations in urban areas.
These thermal requirements may be met in part by central elec-
tric-power stations with adequate NOX emission controls. Emis-
sions of NOX are easier to control from such a large centrally
located complex. The efficiency of a heating system, however, is
lower when conversion of fuel to electricity to heat is required
than it is when the system is designed to convert fuel to heat
directly.
Source Relocation
Relocation of a pollutant source is a means of reducing the
exposure of a densely populated area to NO* emissions. Such a
-------
2742 LEGAL COMPILATION—AIR
plan entails retirement of the old urban electricity-generating sta-
tions and the building of new, more efficient, power-generating
stations at remote locations. Economic feasibility may be affected,
however, by the cost of long-distance power transmission.
Catalytic Abatement
Catalytic abatement is similar to catalytic decolorization, but
the NOX is reduced completely to elemental nitrogen. In catalytic
abatement of NOX, sufficient fuel is used to give complete oxygen
burnout, followed by reduction of NOX to elemental nitrogen. Dif-
ficulties in applying this principle in commercial practice have
included short catalyst life and high-temperature problems. Low
initial oxygen content in the gas to be treated is recommended.
Caustic Scrubbing
Solutions or suspensions of caustic or calcium hydroxide react
with N02 and with equimolar ratios of NO and N02. The latter
mixtures are absorbed to form nitrites, just as if they were the
actual anhydride of nitrous acid, N203. It follows that scrubers
can be designed for a high degree of removal of NOX from chemi-
cal vent streams. When scrubbers are used, a solution of nitrate
and nitrite is formed. If no use is made of the solution on site, it
can create a waste-disposal problem. Also, the nitrite can decom-
pose to regenerate NOX if the waste is dispersed into a lower-pH
environment. NOX removal by means of scrubbers may not, there-
fore, be desirable.
Nitrogen Oxide Incineration
Nitrogen oxide incineration involves reduction of NOX to ele-
mental nitrogen by burnout with a gaseous fuel. This differs from
catalytic abatement in that no catalyst is used. At least 10 percent
more fuel than required for reaction with oxygen and NOX is
added to the vent gas stream to reduce N0r to nitrogen. NOX
reductions of 75 to 90 percent have been obtained. Because of the
reducing (fuel rich) conditions employed, CO and HC may be
present in the exit gas, and more air and second reactor may be
required to control these pollutants.
The NOX incineration method might be useful for treatment of
nitric acid absorber tail gas following commercial nitration opera-
tions.
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GUIDELINES AND REPORTS 2743
Urea Inhibition of Nitrogen Oxides
In some cases where strong nitric acid solutions are used, urea
can be added to inhibit or prevent release of NOX. This method
has been used in metal pickling, in phosphate rock acidulation, and
in some nitrations.
CONTROL TECHNIQUES (SPECULATIVE)
Steam and Water Injection
A potential control technique, steam and water injection, is
based on lowering the boiler peak flame temperature and diluting
the combustion gases, as in flue-gas recirculation. This method
requires development and may involve loss in efficiency, but it has
been found to reduce NOX emissions from internal combustion
engines.
Flue-Gas Recirculation
Laboratory results of the flue-gas recirculation technique show
sizable reductions in NOX emissions, particularly in combination
with low-excess-air firing, but tests on boiler emissions are incon-
clusive. The recirculated flue gases should be injected directly into
the flame zone.
Stack-Gas Treatment
Several treatments are under development for removal of sulfur
oxides from flue-gases, and some of these techniques also remove a
part of the NO* content simultaneously. These treatments are
described in AP-52, Control Techniques for Sulfur Oxide Air Pol-
lutants. Difficulties have been encountered in operating most of
these processes.
A disadvantage of flue-gas treatment of large gas volumes is
that scrubbing with water cools the gases to as low as perhaps
125° F, and thereby creates a visible plume with poor buoyancy.
Selective Catalytic Reduction of NO*
This process uses ammonia in the presence of oxygen to reduce
NOX. Limited commercial experience in three plants ranged from
unsatisfactory to partially successful.
Adsorption on Molecular Sieves
Molecular sieves are solid chemical structures that can adsorb
NOX from very low concentrations in a gas stream. The adsorbed
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2744 LEGAL COMPILATION—Am
NOX can be desorbed with hot air or steam, and the NOX exit
concentration is greatly raised over that of the entering tail-gas
stream. Process units involving adsorption and desorption of NO*
on molecular sieves are offered commercially, and the degree of
removal of NOX is guaranteed. No reports of their use in an
actual plant are available. Limited evidence indicates that adsorp-
tion is quite satisfactory from a well-dried gas. Some user, such as
a nitric acid plant, must be located nearby to accept the concen-
trated NOX gas stream resulting from the desorption step.
4.2b(5) "CONTROL TECHNIQUES FOR PARTICIPATES"
National Air Pollution Control Administration, January 1969
CONTROL TECHNIQUES FOR PARTICULATES
(Summary of "Control Techniques for Particulate Air Pollutants,"
published by the National Air Pollution Control Administration in
January 1969)
PARTICULATE SOURCES
Particulate material found in ambient air originates from both
stationary and mobile sources. Of the 11.5 million tons of particu-
late pollution produced by industrial, commercial, and domestic
sources in 1966, 6 million tons were emitted from industrial
sources, including industrial fuel burning; 5 million tons from
power generation, incineration, and space heating; and 0.5 million
ton from mobile sources.
The following techniques are in use for controlling the source or
reducing the effects of particulate pollution:
1. Gas cleaning
2. Source relocation
3. Fuel substitution
4. Process changes
5. Good operating practice
6. Source shutdown
7. Dispersion
Internal Combustion Engines
Although particulate emissions from internal combustion en-
gines are estimated to contribute only 4 percent of the total parti-
culate emissions on a nationwide basis, they do contribute as much
as 38 percent in certain urban areas. The relative percentages of
particulate emissions for this and other source categories differ
526-705 O - 74 - 26
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GUIDELINES AND REPORTS
2745
from one area to another depending on automobile density, degree
of stationary source control, and types of sources present in the
area.
For each 1000 gallons of fuel consumed, diesel-fueled engines
produce about 110 pounds of particulate matter. Gasoline-fueled
engines produce about 12 pounds per 1000 gallons of fuel con-
sumed.
Gasoline engine-produced particulate matter emanates from the
crankcase and exhaust gases. It consists of carbon, metallic ash,
aerosol hydrocarbons, and metallic particles.
The particulate matter emitted from a diesel engine comprises
carbon and hydrocarbon aerosols. Control of diesel engine emis-
sions effects reduction in smoke.
Stationary Combustion Sources
In the United States more than 29 million stationary combus-
tion sources are currently in operation. About 2 percent are fired
with coal, 61 percent are fired with gas, and 37 percent are fired
with fuel oil. The relative usage of fuels on a Btu basis shows coal
to be 32 percent, natural gas 49 percent, and fuel oil 19 percent.
Types of gas cleaning devices currently being used for station-
ary combustion sources are listed in Table 1. Newer control sys-
tems are now being installed which will be used to control both
particulate matter and sulfur oxides.
TABLE 1.—TYPICAL PRESSURE DROPS AND EFFICIENCY RANGES FOR GAS CLEANING DEVICES USED FOR
STATIONARY COMBUSTION SOURCES
Unit
Settling chambers
Large-diameter cyclones . .
Small-diameter cyclones
Electrostatic precipitator
Pressure drop,
in. H20
0.5
0.5-4.0
2-8
0.1-0.5
Efficiency,
percent
20-60
30-65
70-90
75-99.5
Industrial Sources
Industrial processes, including industrial fuel burning, dis-
charged an estimated 6.0 million tons of particulate materials in
1966. This amounts to more than 50 percent of the total particu-
late pollution on a nationwide basis. Major pollutants are dusts,
fumes, oils, smoke, and mists.
Table 2 presents a summary of important industries, their pol-
lutant sources, particulate pollutants, and air cleaning techniques
(equipment) presently in use.
-------
2746
LEGAL COMPILATION—Ant
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-------
GUIDELINES AND REPORTS 2747
Construction and Demolition
The principal demolition, construction, and related operations
that generate participate air pollution are:
1. Demolition of masonry
2. Open burning
3. Movement of vehicles on unpaved roads
4. Grading of earth
5. Paving of roads and parking lots
6. Handling and batching of paving materials
7. Sandblasting of buildings
8. Spray painting
Control of the above operations is accomplished by various
means which include hooding and venting to air pollution control
equipment, wetting down working surfaces with water or oil, and
using sanitary landfill.
Solid Waste Disposal
Although solid waste disposal by incineration accounts for less
than 10 percent of the total particulate pollution (1 million tons in
1966), it does, however, inspire many complaints about air pollu-
tion. Of the 190 million tons of solid wastes collected in 1967, 86
percent went into land disposal sites, 8 percent was burned in
municipal incinerators, and 6 percent was disposed of in sanitary
landfills. Since open burning is practiced at three-fourths of the
land disposal sites, particulate emissions from these sites contrib-
ute significantly to air pollution arising from the disposal of solid
waste.
Over 70 percent of existing municipal incinerators were in-
stalled before I960, and lack adequate provisions for eliminating
particulate emissions.
An obvious means of reducing the air pollution resulting from
solid waste disposals is to use such non-incineration methods for
disposal as follows:
1. Sanitary landfill
2. Composting
3. Shredding and grinding
4. Dispersion (hauling to another locale)
These methods contribute little to air pollution problems.
It is estimated that measures to upgrade existing land disposal
sites, and thus do away with open burning, will cost as much as
$230 million per year for 5 years.
Where incineration is used for solid waste disposal, the princi-
-------
2748 LEGAL COMPILATION—AIR
pal particulate pollutant emitted is fly ash. Its removal from ef-
fluent gas streams is accomplished by low pressure drop (0.5 inch
H20) scrubbers, or settling chambers.
The estimated cost of upgrading or replacing existing inade-
quate municipal incinerators is $225 million, of which $75 million
would be for air pollution control equipment.
GAS CLEANING DEVICES
It has been estimated that total expenditures in 1966 on in-
dustrial air pollution control equipment in the United States were
about $235 million. Value of shipments of the industrial gas clean-
ing equipment industry in 1967 was double the 1963 figure, and
the backlog of orders recently nearly equalled a year's productive
output. Undoubtedly legislative pressure and local pollution con-
trol regulations have supplied the impetus for such rapid growth
in this industry.
The selection of gas cleaning equipment is far from an exact
science and must be based on characteristics of particle and car-
rier gas, and process, operation, construction, and economic fac-
tors. Information on particle size gradation in the inlet gas stream
is important in the proper selection of gas cleaning equipment.
Particles larger than 50 microns may be removed satisfactorily in
inertial and cyclone separators and simple, low-energy wet scrub-
bers. Particles smaller than 1 micron can be arrested effectively by
electrostatic precipitators, high-energy scrubbers, and fabric fil-
ters.
Table 3 lists advantages and disadvantages in applicability of
each of the general types of air cleaners to given situations.
EMISSION FACTORS
Emission factors may be used to estimate emissions from
sources for which accurate stack test results are unavailable.
Process emission factors for some selected source types are pre-
sented in Table 4.
ECONOMICS
Air pollution control is viewed not only from the standpoint of
available technology but also with respect to the economic feasibil-
ity of control methods and/or equipment.
Among the cost elements relevant to an air pollution control
problem are:
-------
GUIDELINES AND REPORTS 2749
1. Capital costs of control equipment.
2. Depreciation of all control equipment.
3. Overhead costs including taxes, insurance, and interest for
control equipment.
4. Operation and maintenance costs.
5. Collected waste material disposal costs.
6. Other capital expenditures for research and development,
land, and engineering studies to determine and design
optimum control system.
Many of these elements differ from one installation to another.
Table 5 lists major collector types and their approximate installed
costs for operational air flow rates. The installed costs (purchase
cost, transportation, and preparation for on line operation) are
average costs for typical control equipment.
Table 6 presents generalized operating and maintenance cost
equations for various types of control equipment.
BIBLIOGRAPHY
A list of references follows each section of this document. Other
references relating to control technology for generic sources of
particulate air pollutants are cited in the bibliography, which com-
prises the final section. Although all of the articles cited in the
bibliography do not necessarily reflect the most modern control
practices, they do provide useful background material on the con-
trol technology for particulate air pollutants.
-------
2750
LEGAL COMPILATION—AIR
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-------
GUIDELINES AND REPORTS
2751
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-------
2752
LEGAL COMPILATION—AIR
+
x
+
-------
GUIDELINES AND REPORTS 2753
Where:
-G = annual costs, dollars, for operating and maintenance
S = design capacity of the unit, actual cubic feet per minute (acfm)
P = pressure drop, inches of water
H = hours of operation annually
K = cost of electricity; dollars per kilowatt-hour
E = fan efficiency expressed as decimal
M = maintenance cost per acfm, dollars per cfm
F = fuel cost, dollars per acfm per hour
W = make-up liquid rate in gallons per hour per acfm
L = cost of liquid in dollars per gallon
Z = total power input required for a specified scrubbing efficiency, horse-
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J = kilowatts of electricity per acfm
h = elevation for pumping of liquor in circulation system for collector,
feet
Q = water circulation, gallons per acfm
4.2b(6) "CONTROL TECHNIQUES FOR SULFUR OXIDE"
National Air Pollution Control Administration, January 1969
CONTROL TECHNIQUES FOR SULFUR OXIDE
(Summary of "Control Techniques for Sulfur Oxide," published
by the National Air Pollution Control Administration January
1969)
SOURCES OF SULFUR OXIDES
Approximately three-fourths of the 28.6 million tons of sulfur
oxides, largely sulfur dioxide (SO2), emitted into the atmosphere
of the United States in 1966 resulted from the combustion of
sulfur-bearing fuels. Coal combustion accounted for the largest
part of this total. Industrial processes, mainly smelting and petro-
leum refining, accounted for the remaining sulfur oxide emissions.
The quantity of sulfur oxides emitted varies widely from area to
area, depending on the type and quantity of fuel consumed and on
the industrial processes.
Combustion Processes
The rapid growth of the economy of this country has been due,
in part, to the ready supply of naturally occurring fossil fuels
(coal, oil, and gas). These fuels currently supply about 95 percent
of the 57 quadrillion (57 x 1015) Btu consumed in the United
States annually. Nuclear energy currently supplies only a small
fraction of total energy, but its contribution is expected to grow
rapidly.
-------
2754 LEGAL COMPILATION—AIR
One of the best existing methods for reducing sulfur oxide emis-
sions from fuel combustion sources is the use of low-sulfur fuels,
such as natural gas, low-sulfur fuel oil, and low-sulfur coal; or by
converting to another source of power such as hydropower or
nuclear energy. Many economic and social factors would, however,
be involved in any massive switch to low-sulfur fuels. Careful
planning which takes into consideration the cost and availability
of these fuels, as well as the levels and effects of emitted S02> can
minimize these problems. Using low^sulfur fuels on a short-term
basis during periods of severe air pollution may also be feasible.
Coal is by far our most abundant fossil fuel. Low-sulfur sup-
plfes of this fuel do exist, but they have not been fully developed
nor are they very widely distributed. It is estimated that over 40
percent of the high-rank coals found east of the Mississippi River
contain less than 1 percent sulfur (i.e., 95 billion tons). Approxi-
mately 50 percent of this 95 billion tons of coal should be recovera-
ble. A premium price is usually paid for high-rank, low-sulfur
coal. For areas not adjacent to low-sulfur coal supplies, additional
transportation costs will constitute an increasing part of the deliv-
ered price.
Coal cleaning processes are capable of removing some of the
pyrite sulfur in coal. Cleaning processes that include crushing to
l!/2 inches or less and flotation separation tend to remove more
pyrite material. Because the degree to which a particular coal can
be cleaned varies widely and depends on the amount and distribu-
tion of the pyrite sulfur in the coal, quantitative statements about
coal cleanability, its cost, and the amount of cleanable coal availa-
ble cannot be made.
Though under active research, none of the more elaborate coal
processing schemes, such as gasification and liquefaction, are pres-
ently in full-scale operation. The current state of development of
these processes is described in the Appendix.
Approximately 600 billion barrels of residual fuel oil (grades 5
and 6) are burned annually in the United States. More than 80
percent of this fuel contains at least 2 percent sulfur. The east-
coast regions burn about 50 percent of this fuel oil, most of which
is imported from South America. Due to the nature of petroleum
refining processes, sulfur present in crude oil tends to be concen-
trated in the residual oil fraction.
Lighter fuel oils (grades 1 and 2) are currently being consumed
at a rate of about 500 million barrels per year. The lighter oils
generally contain between 0.04 and 0.6 percent sulfur, and burn-
-------
GUIDELINES AND REPORTS 2755
ing them does not produce as much sulfur oxides as does burning
residual oil. Because of the higher cost of this fuel it is not gener-
ally burned by large consumers such as utilities and large in-
dustrial plants.
Various refinery process schemes that can produce a residual
fuel oil with sulfur content of 1.0 percent or less are currently
being installed and some are in operation. These schemes use de-
layed coking, solvent de-asphalting, and hydrogen treating proc-
esses. Their principal product is low-sulfur distillate oil, which is
blended with heavy oil fractions to produce a low-sulfur residual
fuel oil. Desulfurizing to 1.0 percent costs about $ .25 to $ .75 per
barrel ($ .04 to $ .12 per million Btu) ; however, the price of
1.0-percent-sulfur-content residual fuel oil is influenced by many
factors, and prices to date have not in general increased greatly.
Desulfurizing to less than 1.0 percent will become more feasible as
these schemes are further improved.
Natural gas is now available in all parts of the country, and
production has increased to about 18 trillion cubic feet per year.
Sulfur compounds contained in natural gas are for the most part
removed before marketing. This fuel, therefore, burns with negli-
gible sulfur oxide emissions and is widely used. While new re-
serves of natural gas are being found, the domestic supply of this
fuel at current prices will probably become limited before the turn
of the century because of increased production costs.
Fuel costs vary widely and depend, among other things, on the
consumer's location and demand. Fuel-cost data are presented in
this report for industrial users in 50 Standard Metropolitan Sta-
tistical Areas for coal and oil of various sulfur contents, and
natural gas. When calculating the various costs involved in fuel
substitution schemes and the effect of the schemes on sulfur oxides
emissions, the following steps must be taken:
1. Determine heating requirements in Btu per hour, of unit
in question.
2- Select the various fuels that may be burned and determine
their costs.
3. For the various fuels determine the cost of boiler modifi-
cations and operating expense.
4. Annualize the costs.
5. Determine the extent of sulfur dioxide emissions from
combustion of the alternative fuels.
In areas where the cost of low-sulfur fuels is high and the
supply limited, fuel substitution may not be an economically feasi-
ble method of reducing sulfur oxide emissions. This is especially
-------
2756 LEGAL COMPILATION—AIR
true in the case of large fuel consumers, such as electrical generat-
ing .stations. Increased attention has, therefore, been recently fo-
cused on methods for removing sulfur oxides from the flue gas
before it enters the atmosphere. No flue gas desulfurization proc-
esses are presently in widespread use, but several methods such as
alkalized alumina sorption, limestone-dolomite injection, and cata-
lytic oxidation are currently under active investigation.
The limestone-dolomite injection process is the simplest method
currently being developed for the control of SO2 emissions from
large combustion sources. In this process, limestone injected into
the furnace reacts with the sulfur oxides to form calcium sulfate,
a solid, which is removed by dust-collecting equipment. The degree
of reaction can be increased by placing a scrubber on the system,
since the limestone, which calcines to quicklime in the furnace,
reacts fully in the scrubber due to increased contact and retention
time. Sulfur oxide removal efficiencies in excess of 80 percent are
obtainable when the scrubbing system is used. The primary disad-
vantage of this system is the large amount of waste material
(calcium sulfate and sulfite, unreacted limestone, and fly ash)
which must be disposed of. Flue gas reheating may be required
when the scrubber is used.
Estimated costs for an 800-megawatt, coal fired power plant,
operating at a load factor of 90 per cent are tabulated below.
-------
o _.
2 5
11
GUIDELINES AND REPORTS
2757
-------
2758 LEGAL COMPILATION—AIR
Three full-scale installations of the limestone-dolomite wet-
scrubbing process are presently under way on coal-burning power
plants in the 125- to 420-megawatt range, and one of these is now
in the preliminary steps of operation. Two TVA power plants are
also currently being modified for the dry limestone injection proc-
ess.
The alkalized alumina process uses a dry sodium-aluminate
metal oxide to contact and react with the sulfur dioxide in a
special reactor. The reacted sorbent is then regenerated with a
reducing gas and the sulfur reclaimed. This process, though more
complicated than the limestone injection process, does produce a
saleable byproduct in the form of sulfur. Sulfur dioxide removal
efficiencies in excess of 90 percent have been obtained on pilot-
scale plants.
Because of the large amount of equipment that must be installed
for this process, it appears to be more adaptable to new installa-
tions. The cost of this system, although speculative at present, is
estimated at $8.6 million capital investment for an 800-megawatt
plant. Operating costs vary with the market for recovered sulfur.
Development of full-scale alkalized alumina process installations
is dependent on additional pilot-scale work.
The catalytic oxidation process converts sulfur oxides in the flue
gas to weak (75 to 80 percent) sulfuric acid by passing the gas
stream through a vanadium pentoxide catalyst and a series of
condensers. This process has advanced through the pilot-plant
stage and is available from the developer.
For a new 800-megawatt plant the catalytic oxidation system
would require an investment of between $16 million and $24 mil-
lion. Operating costs would depend largely on the price obtained
for sulfuric acid in that particular area. Transportation of this
weak acid over long distances would not be economical.
Other flue-gas desulfurization processes are also being actively
studied both here and abroad. These include the Beckwell scrub-
bing system, char sorption, and scrubbing with molten metallic
salts.
The following table summarizes S02 control techniques for com-
bustion processes.
-------
GUIDELINES AND REPORTS 2759
4.3 SELECTED REPORTS
4.3a SEMIANNUAL REPORT
Prepared by the Committee on Motor Vehicle Emissions of the National
Academy of Sciences, January 1, 1972
The study reported herein was undertaken under the aegis of
the National Academy of Sciences and its National Research
Council with the express approval of the Council of the Academy.
Such approval indicated that the Council considered that the prob-
lem is of national significance; that solution of the problem re-
quired scientific or technical competence and that the resources of
the NAS were particularly suitable to the conduct of the project.
The institutional responsibilities of the Academy were then dis-
charged in the following manner:
The members of the study committee were selected for their
individual scholarly competence and judgment with due considera-
tion for the balance and breadth of disciplines. Responsibility for
all aspects of this report rests with the study committee, to whom
sincere appreciation is expressed.
Although the reports of study committees are not submitted for
approval to the Academy membership or to the Council, each re-
port is reviewed by a second group of scientists according to
procedures established and monitored by the Academy's Report
Review Committee. Such reviews are intended to determine, inter
alia, whether the major questions and relevant points of view have
been addressed and whether the reported findings, conclusions and
recommendations arose from the available data and information.
Distribution of the report is permitted only after satisfactory
completion of this review process.
-------
2760 LEGAL COMPILATION—AIR
CONTENTS
Page
1. INTRODUCTION 1
2. STANDARDS AND TESTING 6
2.1 Introduction 6
2.2 Testing for the Certificate of Conformity 7
2.3 Production-Line Testing 7
2.4 Surveillance Testing of Used Vehicles 9
2.5 State and Local Inspection of Used Vehicles 9
3. EMISSION-CONTROL TECHNOLOGY 10
3.1 Background 10
3.2 Proposed 1975 Emission-Control System 14
3.2.a Exhaust-Gas Recycle 15
3.2.b Secondary Air System 15
3.2.c Thermal Reactor 15
3.2.d Oxidizing Catalytic Converter 16
3.2.e Major Engine Modifications 16
3.2.f Control-System Integration 17
3.3 Current Stage of Development 18
3.3.a Emissions at Low Accumulated Mileage 18
3.3.b System Durability 22
3.4 System Compatibility with 1976 NOX Standard 26
3.5 Effects of Emission-Control System on Vehicle Performance 29
3.6 Developments Required to Meet 1975 Standards 30
3.7 Stratified-Charge and Wankel Engines 32
4. MAINTENANCE 35
5. MANUFACTURING 37
6. COSTS OF MEETING 1975 EMISSION REQUIREMENTS 40
7. THE CONSEQUENCES OF A ONE-YEAR SUSPENSION OF
1975 STANDARDS 44
8. CONCLUDING STATEMENT 49
9. FUTURE PLANS 50
-------
GUIDELINES AND REPORTS 2761
APPENDIXES
Page
A Committee on Motor Vehicle Emissions 51
B Statement of Work 53
C Panels of Consultants 54
D List of Questions Sent to Foreign and Domestic Automobile
Manufacturers; Recipients of Questionnaire and List of At-
tendees at CMVE meeting on October 25-27, 1971 56
E Letter Requesting Information from Public 68
F Emissions at Low Mileage from Each Automobile Manufac-
turer's Best Vehicle 69
G Emissions as Function of Miles for Durability Tests on Different
Catalysts and Vehicles 70
H Panel Estimate of Sticker Prices of Likely Emissions Hardware _ 71
I Data Used to Calculate Emissions from Light-Duty Motor
Vehicles 75
TABLES
Page
1.1 Panels of the Committee on Motor Vehicle Emissions 3
3.1 Federal Emission-Control Requirements for Light-Duty Vehicles _ 13
3.2 Low-Mileage Emission Targets and Measurements 20
3.3 Deterioration in Emission Control Over 50,000 miles 25
3.4 Best Low-Mileage Emissions from Thermal-Reactor Systems 27
5.1 Scheduling and Lead Times for 'Mass Production 38
6.1 Typical Pattern of Installation of Automotive Emission Hardware _ 41
6.2 Summary of Cost for Likely Emission Hardware Based on Panel
Estimates 43
FIGURES
Page
3,1 Percentage Reduction in Exhaust Emissions Represented by the
Federal Standards 12
7.1 United States Nationwide Hydrocarbon Emissions 46
7.2 United States Nationwide Carbon Monoxide Emissions 47
526-705 O - 74 - 27
-------
2762 LEGAL COMPILATION—AIR
1. INTRODUCTION
In adopting the Clean Air Amendments of 1970 (Public Law
91-604), which established exhaust emission standards for 1975
and 1976, light-duty vehicles and engines, Congress directed the
Administrator of the Environmental Protection Agency (EPA)
"to enter into appropriate arrangements with the National Acad-
emy of Sciences (NAS) to conduct a comprehensive study and
investigation of the technological feasibility of meeting the emis-
sions standards" promulgated in the legislation. The results of this
study are to be made available both to EPA and to Congress, with
semiannual interim reports and with a final report to be submitted
at the completion of the project. Although the Academy's study
and investigation is intended to provide information and expert
judgment about the full range of technologically related issues
pertinent to the automobile emission standards, Congress also con-
templated that the Academy's interim reports would play a major
role in helping the Administrator exercise his discretion to post-
pone or not to postpone the applicable deadline if such postpone-
ment be requested. In this latter respect, the Administrator, pur-
suant to Section 202 (b) (5) (D), may grant a one-year suspension
only if he determines, among other things, that "the study and
investigation of the NAS. . . and other information available to
him has not indicated that technology, processes or other alterna-
tives are available to meet (the established) standards."
As a result of the Clean Air Amendments, signed December 31,
1970, discussions were held between EPA and NAS for the pur-
pose of exploring the character of and the most effective way of
conducting the study called for in Section 202 (c). Pursuant to a
contract between EPA and NAS, signed March 10, 1971, and
retroactive to February 1, 1971, a strategy committee was formed
by NAS in March 1971 to develop a proposed work statement and
to suggest members for the Committee on Motor Vehicle Emis-
sions. The initial Committee membership was selected by the Na-
tional Academy of Sciences in April 1971, with other members
added in later months. Committee membership is listed in Appen-
dix A along with the members of the Committee staff. A work
statement and contract proposal were submitted by the Academy
to EPA in May 1971. A contract for $612,175 was signed by EPA
on August 2, 1971. The first meeting of the Committee took place
June 16, 1971 and subsequent meetings were held monthly.
According to the work statement, (Appendix B) the Committee
on Motor Vehicle Emissions is to conduct a many-faceted study of
-------
GUIDELINES AND REPORTS 2763
the technological feasibility of meeting the motor-vehicle emission
standards prescribed by the Administrator of EPA, as required by
Section 202 of the Clean Air Act, as amended. Technological feasi-
bility as denned in the work statement, "includes the ability
within the automobile industry or elsewhere to:
1. Design an engine, control system, or device capable of
meeting the statutory emission standards using fuels that are
or could be available;
2. Mass produce such an engine, control system, or device;
3. Maintain such an engine, control system, or device so
that it will continue to meet the statutory emission standards
with safety for a period of five years or 50,000 miles of
operation, whichever is shorter."
It was agreed that the study of technological feasibility will
include an investigation of the anticipated costs to be incurred and
the estimated time for the design, development, and mass produc-
tion of an engine, control system, or device capable of meeting the
standards. Also to be included is a study of the estimated annual
costs incurred in maintaining such an engine, control system, or
device so that it will meet the emission standards for five years or
50,000 miles, whichever is shorter. Finally, should the Committee
conclude that the attainment of emission standards on the sched-
ule provided in Section 202 (b) (1) of the Clean Air Act is not
technologically feasible, the Committee is to determine technologi-
cally feasible interim emission levels to assist the Administrator in
exercising his responsibilities under Section 202 (b) (5) of the Act.
It was decided by the Committee early in its deliberations that,
in order to obtain the necessary technical information upon which
to base a responsible judgment, it would be necessary to form a
series of panels of consultants dealing with principal topical areas
and composed of recognized experts in the relevant fields. Seven
Panels have been formed as shown in Table 1.1. Membership of
the Panels is given in Appendix C.
Under the Clean Air Amendments, at any time after January 1,
1972, any manufacturer may file with the Administrator an appli-
cation requesting the suspension for one year of the regulations
applicable to emissions of carbon monoxide and hydrocarbons
from light-duty vehicles for the 1975 model year. At any time
after January 1, 1973, requests can be made for a similar one-year
suspension of the regulations applicable to oxides of nitrogen for
1976 model year light-duty vehicles.
In order to provide maximum assistance to the Administrator in
the possible exercise of his discretion to suspend for one year the
-------
2764 LEGAL COMPILATION—AIR
deadline date for meeting the 1975 standards, and in view of the
limited time available from the formation of the Committee to the
January 1, 1972, interim report date, it was decided to concentrate
the initial work of the Committee and the Panels on issues per-
taining to the technological feasibility of meeting the standards
applicable to 1975 model year cars. It is recognized that emission-
control systems for 1975 vehicles cannot be completely divorced
from those that must be provided for vehicles that will have to
meet the 1976 standards (see Section 3.4). Some degree of com-
patibility between the two must be provided. Nevertheless, be-
cause a decision on the technological feasibility of meeting the
1975 standards may have to be made within 60 days of January 1,
1972, the main emphasis of this report will be on the technological
feasibility of the emission standards applicable to 1975 model year
vehicles.
Table 1.1—Panels of the Committee on Motor Vehicle Emissions
Panel 1 Emission standards.
Panel 2 Testing, inspection, and maintenance.
Panel 3 Emission control systems (for spark-ignition internal-com-
bustion engines).
Panel 4 Alternate power sources.
Panel 5 Manufacturing and producibility.
Panel 6 Driveability.
Panel 7 Atmospheric chemistry.
The first Panels in operation were Emission Standards; Test-
ing, Inspection, and Maintenance; Emission Control Systems (for
spark-ignition internal-combustion engines) ; Driveability; and
Manufacturing and Producibility.
The five Panels mentioned above began operation in July 1971,
and have been active since that time. Many of the Panelists have
devoted virtually full-time effort to the work of the Committee
since July. Panel visits have been made to all the domestic automo-
bile manufacturers, to EPA laboratories in Ann Arbor, Ypsilanti,
and Research Triangle Park, to the U. S. Army Tank-Automotive
Command, many catalyst suppliers, manufacturers of various test-
ing equipment, the California Air Resources Board, and to other
groups engaged in emission-control research and development.
Extensive information has been obtained from a questionnaire
sent on September 27, 1971, to all five domestic automobile manu-
facturers and to all sixteen foreign automobile manufacturers ex-
porting a significant number of cars into the United States. A
copy of this questionnaire and lists of those to whom it was sent
and those who responded are included in Appendix D. The high
-------
GUIDELINES AND REPORTS 2765
degree of detail of the replies was very gratifying. Most of these
documents were received in time for the Committee and pertinent
Panel members to read them prior to a further meeting held in
Washington, D. C., on October 25-27, 1971, between the Commit-
tee and the manufacturers. (Those who attended are so designated
in Appendix D). At this meeting the Committee and Panel mem-
bers questioned the manufacturers individually with respect to
their responses to the questionnaire and sought the latest informa-
tion with regard to the technological feasibility of meeting the
requirements of the Clean Air Act of 1970. In addition, many
Committee and Panel members made personal contacts with the
automobile manufacturers and others in order to clarify points
they felt could be important in making their evaluation. Further,
the Committee issued a statement (Appendix E) on September 21,
1971, inviting the submission of information on behalf of the
public concerning the technological feasibility of meeting the re-
quirements of the Act. This statement was sent to over 700 orga-
nizations and individuals, including major newspapers, wire serv-
ices, general science magazines, engineering and industry publica-
tions, and environmental groups and publications. The statement
was also placed in the Federal Register of December 3, 1971. But,
as yet, the number of direct responses has been disappointingly
small.
In the limited time that the Committee has had available since
its creation in the summer of 1971, all possible efforts have been
made to secure the material and information needed to reach the
judgments called for in the legislation. Perforce most of the perti-
nent data required were in the possession of the various concerned
manufacturers, primarily the automobile companies. Necessarily,
therefore, the analyses to follow rest primarily upon the informa-
tion received from those sources.
However, recognizing the possible bias that this might introduce
the Committee has endeavored, in various ways, to ensure that the
information obtained from the companies is complete, accurate
and timely. Members of the Committee and its Panels, along with
special consultants, have interrogated working-level company
technicians and engineers, have personally examined laboratories
and testing facilities and have reviewed intensively the techniques
employed by the companies in analyzing their experiments and
data. In addition, the Committee has utilized certain information
provided by EPA as well as data gathered in the hearings con-
ducted by EPA in May 1971.
The Committee's work in all of these respects will continue in
-------
2766 LEGAL COMPILATION—Am
the coming year, but, as of now, it is the judgment of the members
that the information it has received is sufficiently reliable and
comprehensive as to constitute an appropriate basis for the judg-
ments it has reached and which are set forth in this report. In the
coming months, the Committee will continue its investigation so as
to ensure that the most complete and sound scientific information
is available both for its own purposes and for the use of EPA and
the Congress.
The emphasis in this report is on the 1975 standards, for the
reasons noted earlier. The Committee's study and investigation
will continue as it expands its inquiry into areas pertinent to the
1976 standards.
2. STANDARDS AND TESTING
2.1 Introduction
According to Section 202 of the Clean Air Amendments of 1970,
the Administrator of EPA is required to prescribe emission stand-
ards for light-duty motor vehicles and measurement techniques on
which such standards are based. Pursuant to Section 202 (b) (1)
(A) such standards require that the emissions of carbon monoxide
and hydrocarbons from light-duty vehicles manufactured during
or after model year 1975 shall be reduced by 90 percent from those
required of 1970 vehicles; also, emissions of oxides of nitrogen
from light-duty motor vehicles manufactured during or after
model year 1976 are to be 90 percent below the average of those
actually measured from 1971 model year light-duty vehicles.
Standards and test procedures were promulgated by EPA and
are contained in the Federal Registers of November 10, 1970, and
July 2, 1971. The 1975 model year standards are:
0.41 grams per vehicle mile for hydrocarbons,
3.4 grams per vehicle mile for carbon monoxide, and
3.0 grams per vehicle mile for oxides of nitrogen.
For 1976 model year vehicles, exhaust emission standards are:
0.41 grams per vehicle mile for hydrocarbons,
3.4 grams per vehicle mile for carbon monoxide, and
0.4 grams per vehicle mile for oxides of nitrogen.
The Clean Air Act Amendments further call for vehicle compli-
ance with these standards for the useful life of the vehicle, defined
in the Law as five years or 50,000 miles, whichever occurs first.
Testing to ensure compliance with these standards is to be con-
ducted in three stages. First, prototype models of each engine
class are to be tested prior to issuing a "certificate of conformity."
-------
GUIDELINES AND REPORTS 2767
Next, production-line testing is contemplated to ascertain whether
production models conform with the regulations with respect to
which a certificate has been issued. Finally, provision is made for
testing emissions and for continuing compliance while a vehicle is
in actual use.
2.2 Testing for the Certificate of Conformity
The test procedure for determining whether a certificate of con-
formity may be issued for 1975 and later model year vehicles
consists of emission and 50,000-mile durability tests with a limited
amount of maintenance on a fleet of vehicles representing each
engine class for each vehicle manufacturer. As now defined by
EPA this procedure permits one engine tuneup but no emission-
control system replacements during the 50,000-mile durability test
and requires that emissions be less than the standard for 50,000
miles.
The emission test, as described in the Federal Register of July
2, 1971, is designed to determine hydrocarbon, carbon monoxide
and oxides of nitrogen mass emissions while simulating an aver-
age trip of 7.5 miles in an urban area. Each emission test consists
of a twelve-hour wait at 70 degrees F, a cold-engine startup, a
continuous sequence of different driving modes similar to actual
driving over a 23-minute route and a 10-minute shutdown fol-
lowed by a hot-engine restart and a repeat of the first 505 seconds
of the 23-minute cycle. Diluted exhaust emissions are collected
continuously using a constant volume sampler. Emissions collected
during the first 505 seconds from cold start are collected in one
bag, those from the remainder of the 23-minute cycle in a second
bag, and the emissions from the hot-restart phase collected in a
third bag. The contents of the three bags are then analyzed and
weighted in accordance with the EPA test procedure to attain the
final mass emissions, in grams per mile.
The technology of testing according to the prescribed proce-
dures requires expensive equipment and instruments. At ths pres-
ent, the equipment and procedures are more characteristic of a
laboratory than of an industrial production line or state inspection
station. The estimated cost of equipping a single test cell with the
necessary equipment to perform a complete vehicle test according
to the prescribed procedure is approximately $100,000. This in-
cludes the dynamometer, constant volume sampling equipment,
instrumentation for analyzing the sample bags for the three pollu-
tants, and the other required equipment. Such a test would require
-------
2768 LEGAL COMPILATION—AIR
two people per cell and would consume approximately one hour,
following the twelve-hour wait at 70 degrees F. The time required
and equipment needed for this test make it difficult to conceive of
its use for production testing of every vehicle or for service test-
ing or vehicle-inspection programs for vehicles in use.
2.3 Production-Line Testing
To satisfy the requirements of Section 206, testing procedures
for new production-line vehicles will be needed. Consideration of
possible effective procedures immediately raises three significant
questions:
(1) How many vehicles should be tested?
(2) What test procedures should be used?
(3) Should every vehicle tested meet the prescribed emis-
sion standards ?
While these questions are not independent, we shall discuss them
in sequence.
1 Constant volume sampling test described previously.
Given the large number of vehicles produced, testing a sample
of new vehicles by the full cold-hot CVS1 test can determine the
emission characteristics of the vehicle population as precisely as is
necessary. Sample testing and statistical analysis for quality-con-
trol purposes is a thoroughly developed and accepted procedure in
industrial operations. There is no reason why testing of samples of
new vehicles according to the certification procedure cannot be
used to establish with sufficient accuracy the average emission
characteristics and the probability of occurrence of vehicles hav-
ing high emissions. A simple test on all vehicles may make possible
the detection of some individual improperly manufactured cars
that are very high emitters. Unfortunately, no such short test is
available at present that correlates well with the complete test.
As will be described, the technology of emission-control systems
for conventional reciprocating spark-ignition internal-combustion
engines is complex. Control of the quality of manufacturer and
assembly of the components will have to be thorough if these
systems are to function effectively for an extended period. Labora-
tory models of the systems that are being developed are con-
structed and maintained to their highest level of performance by
highly qualified personnel; variations from the optimum configu-
ration tend to lead to degraded performance and increased emis-
-------
GUIDELINES AND REPOKTS 2769
sions. Not only will the production quality of the emission-control
systems need to be precisely controlled, but also new diagnostic
techniques for detecting and correcting the occasional defective
production vehicle must be developed. These are the responsibil-
ities of the manufacturer, but strict enforcement of the produc-
tion-line tests and standards will be necessary. Production-line
emission-control testing should therefore be concerned with assur-
ing that the manufacturer has met his responsibility to produce an
effective emission-control system on his new vehicles.
Due to the nature of mass-production processes, emission-con-
trol systems will not be precisely identical. As far as contribution
to air pollution is concerned, it is the total emissions from all
emitting vehicles that are of consequence. In other words, it is the
average emissions that affect air quality, where average emissions
refer to the total emissions divided by the number of vehicles.
Therefore, the Committee believes it necessary that the averaged
emissions from all vehicles meet the emission standards over the
vehicle lifetimes.
As discussed below, it is likely that periodic inspection of emis-
sion-control systems in used vehicles may be instituted, and the
purchaser of a new vehicle must be assured that it is not so
defective as to be incapable of passing such tests as are likely to be
used. Therefore, new vehicles whose emissions are significantly
higher than the standards must be corrected by the manufacturer
prior to sale, even though their contributions to total emissions
may be minor. It will therefore be necessary, through statistical
quality control and diagnostic testing on all new vehicles, to put
limits on vehicle emissions.
2.4 Surveillance Testing of Used Vehicles
It is contemplated that there will be emission testing of a sam-
ple of vehicles in service, as maintained by their owners, to deter-
mine their emissions. The results will be compared with the stand-
ards and the durability tests run during compliance. The responsi-
bility for correcting vehicle emissions, if found necessary, will lie
with the manufacturer, provided the owner has complied with the
terms of a legally acceptable warranty concerning maintenance of
the emission-control system.
2.5 State and Local Inspection of Used Vehicles
Under the Law EPA is to encourage state periodic inspections
of used vehicles where necessary and feasible if the Administrator
-------
2770 LEGAL COMPILATION—Am
of EPA finds that a suitable test is available. New Jersey and
California are about to begin inspections with a simple idle test
that correlates well with the 7-mode test currently used for vehicle
certification; this idle test does not, however, correlate with the
EPA test procedure to be used for 1975 model year vehicles. De-
scriptions of the various test procedures are given in Table 3.1.
In 1975 and later model year cars, one of the primary modes of
emission-test failure is expected to be associated with the cold-
start portion of the test; this would not be caught by present idle
tests. The presently available emission performance inspection
tests do not correlate well enough with the CVS-CH test required
for certification of 1975-1976 vehicles to show great promise.
Until a suitable test is available, a functional inspection to deter-
mine whether the control system is present and operational would
have to be used.
3. EMISSION-CONTROL TECHNOLOGY
B.I Background
The vast majority of the engines used in the 1975 model year
vehicles will inevitably be conventional reciprocating spark-igni-
tion internal combustion engines. Wankel rotary combustion and
stratified-charge spark-ignition engines2 may eventually have a
place in the automotive market, as may alternative types of power
plants. However, for 1975 production, the lead times of two years
or more required to design, erect and equip modern mass-produc-
tion facilities, as described in Section 5, are such that irreversible
decisions on the basic engine and control system must be made by
mid-1972. These alternatives to the conventional engine are at an
early stage of development and need extensive testing and evalua-
tion before rational decisions can be made. As a result, the Com-
mittee, in evaluating the technology available to meet the 1975
emission standards, has decided to concentrate on the reciprocat-
ing spark-ignition engine, deferring its studies of alternate power
sources to the future (see Section 9). Though engine modifications
to reduce emissions are likely to be incorporated, the basic geome-
try and operation of the engine will be similar to what it is today.
Emissions from uncontrolled automobiles, as manufactured
prior to 1968, came from the crankcase blowby gases, fuel evapo-
ration from the fuel tank and carburetor, and the engine exhaust.
The crankcase and evaporative losses have now been controlled.
The emissions from the engine exhaust are a consequence of the
-------
GUIDELINES AND REPORTS 2771
details of the combustion process occurring inside the engine cyl-
inder. Hydrocarbons (HC) and carbon monoxide (CO) result
from incomplete combustion of the fuel-air mixture; oxides of
nitrogen (NOX) form in the high-temperature burnt gases as the
combustion process proceeds. Indeed, it was due to this fact that
when 1968 standards were set for CO and HC in California, the
NOX levels in the atmosphere rose because of the adjustments
made to reduce only CO and HC.
As a result of the Federal Emission Control Program, commenc-
ing in 1968, considerable emission control on new vehicles has
already been achieved by engine modifications and improvements
in engine design (Table 3.1). It is unfortunate that the automobile
industry did not seriously undertake such a program on its own
volition until subject to this governmental pressure and general
recognition of the role of automobile emissions in the generation
of smog in California. This long lag period together with the
growth in automobile sales gave rise to the sense of urgency ex-
pressed in the Clean Air Amendments.
* Described in Section 8.7
Exhaust-emission standards measured in grams of pollutant per
mile of vehicle travel were first introduced for HC and CO on 1968
model year vehicles and have since been progressively tightened.
As understanding of factors affecting vehicle emissions has in-
creased, the test procedure has been changed to determine more
accurately the automobile's contribution to total urban emissions.
The different test procedures used are described briefly in Table
3.1. Note that each emission standard is associated with a particu-
lar test procedure and that, though standards for 1972 are stricter
than those for 1970, the values are higher as a consequence of the
different tests used.
Figure 3.1 shows the percentage reduction in exhaust emissions
represented by these standards. The exhaust-emission standards
are compared with average exhaust emissions from uncontrolled
vehicles measured with the 1972 test procedure. This figure shows
that for 1972 model year vehicles, about 80-percent control of HC
and 70-percent control of CO are now required.3 With control of
crankcase emissions and fuel evaporation included, about 85-per-
cent reduction in total HC emissions is being achieved. Federal
NOX standards start in 1973, and about 50-percent control will be
required. In California, about 30-percent control of NOX is now
required on new vehicles sold there.
-------
2772
LEGAL COMPILATION—AIR
UNCONTROLLED VEHICLE PRE1968
17 G/MILE
nrARRnws i , ,
0
125 G/MILE
CARBON
0 ' '
6 G/MILE
NITROGEN
nxinrs . , ,
0
1968 1970 1972
59 73 80
PERCENT CONTROL
1968 1970
42 ' 62 69
PERCENT CONTROL
1975
97 100
1975
| |
96 100
1973 1976
' ' 50 ' ' ' '
93 100
PERCENT CONTROL
a Blowby HC emissions (about 4 g/mile) have been 100-percent
controlled since 1963; evaporative HC emissions (about 3
g/mile) will be 95-percent controlled with 1972 model year
cars
"All standards have been converted to values corresponding to
CVS-C Test.
FIGURE 3.1.—Percentage reduction in exhaust emissions represented
by the Federal standards."
-------
GUIDELINES AND REPORTS 2773
The substantial reductions in HC and CO exhaust emissions
already achieved have resulted from engine-design modifications
and changes in engine-operating conditions. These include adjust-
ments to the carburetor to provide leaner fuel-air mixtures and
improved mixture uniformity, controlled heating of the intake air,
increased idle speed, retarded spark timing, reduced engine com-
pression ratio, and improved cylinder head design. In some sys-
tems, air injection into the exhaust manifold has been used to
burn up a fraction of the HC and CO emissions in the exhaust.
The federal emission standards for NOX in 1973 and 1976, and
lor HC and CO in 1975 given in Table 3.1 will require new control
techniques. Control of HC and CO emissions to the 1975 standard
levels appears to be unattainable through engine modifications of
the type used to date. With conventional engines, HC and CO
emissions from the engine itself are much higher than the 1975
standards under all practical operating modes. Special reactors or
converters located in the exhaust system will be required to burn
up the emissions from the engine. NOX control to below 3 g/mile
will require some exhaust-gas recycling to the engine intake to
reduce peak burnt gas temperatures. Both these new control tech-
niques have a substantial impact on engine operation and per-
formance.
3 80-percent control requires a five-fold reduction in emissions; 70-percent control about a
three-fold reduction.
-------
2774
LEGAL COMPILATION—AIR
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-------
GUIDELINES AND REPORTS 2775
The effectiveness of these new control systems depends to a
large extent on how well the individual components in the system
have been integrated. It must be remembered that typical vehicle
driving is a continuous sequence of different operating modes—en-
gine startup, idle, acceleration, cruise, deceleration, and so forth.
To obtain satisfactory engine and vehicle performance over this
wide range of modes, the air flow into the engine, the air-fuel
ratio, and spark timing are all varied as engine loads and speeds
change. The engine must also start and operate satisfactorily over
the complete range of ambient temperatures, humidity, and alti-
tude (which affects air density and hence fuel metering) found
throughout the United States.
The federal emissions test that has been promulgated by EPA to
certify prototypes of the 1975 production vehicles, as described in
Section 2 and Table 3.1, incorporates a driving cycle that includes
the common driving modes. The overall emission-control system
must be optimized to operate effectively over the entire range of
engine conditions covered in the test to achieve average HC and
CO emissions below the 1975 standards.
The cold-engine start and first few minutes of the test before
the engine fully warms up prove to be especially important. In
current automobile engines, a choke is used to enrich the fuel-air
mixture when the intake manifold is cold and fuel vaporization is
poor. This enrichment is necessary to ensure that enough fuel is
vaporized to provide a combustible mixture near the spark plug
and achieve safe and satisfactory vehicle operation. It results in
high engine HC and CO emissions during the warm-up phase
because not all this fuel can be fully burnt. Moreover, the reactors
in the exhaust, which are provided to burn up the HC and CO
emissions from the engine itself, also must warm up before they
become effective for typical 1975 control systems. It turns out that
HC and CO emissions during the first two minutes of the test are
greater than HC and CO emissions during the last 21 minutes.
Thus, the importance of adequate emission control during the
warm-up phase is obvioua.
3.2 Proposed 1975 Emission-Control System
Although many possibilities exist, in principle, for reducing
emissions from a reciprocating engine and for removing such
emissions prior to the exhaust gas entering the air, the Committee
finds that most manufacturers have selected systems and compo-
nents that are similar to each other. In reviewing the available
-------
2776 LEGAL COMPILATION—Am
technology for reduction of emissions, the Committee and its
Panels, after considerable study of the alternatives, believe that
the basic choice of components made by the manufacturers
throughout the world is reasonable, and that no other concepts
have been proposed that offer greater potential for meeting the
1975 requirements in 1975.
Further, the basic configurations needed for the 1975 systems
must reach final design stage by mid-1972 to permit system test-
ing, endurance testing of components, modifications and correc-
tions, and to assure that the final systems are acceptable to the
public.
As will be discussed in the subsequent sections of this report,
numerous advances in emission controls have been suggested and
tested. To make our discussion more coherent, we shall describe
the principal components of the suggested systems and comment
on their state of development and reliability.
3.2.a Exhaust-Gas Recycle
Exhaust gas recycle (EGR) will be used to diminish NOX emis-
sions. The recycling of 10-20 percent of the exhaust flow to the
intake manifold is used to dilute the fresh fuel-air mixture enter-
ing the engine with a largely inert gas. The additional thermal
capacity of the recycled exhaust lowers peak burnt gas tempera-
tures inside the cylinder, which reduces the formation of nitrogen
oxides. Some losses in vehicle performance result. The fraction of
the exhaust recycled must be carefully matched to engine condi-
tions, otherwise serious degradation in vehicle-performance char-
acteristics, such as engine stall, stumble, and rough operation, can
occur. A valve activated by the intake-manifold vacuum or throttle
position is proposed to control the recycled flow. The use of EGR
generally requires that the fuel-air mixture be enriched to main-
tain satisfactory engine operation. This enrichment increases the
HC and CO emissions from the engine, which must then be burnt
up in a thermal reactor or catalytic converter, and it increases the
fuel consumption.
3.2.b Secondary Air System
The use of EGR and richer fuel-air mixtures requires the addi-
tion of air to the exhaust flow before the engine HC and CO
emissions can be burnt up in a reactor or converter. An engine-
driven air pump drives this air through a distribution manifold
into the exhaust ports.
526-705 O - 74 - 28
-------
GUIDELINES AND REPORTS 2777
3.2.C Thermal Reactor
A thermal reactor is an enlarged exhaust manifold that bolts
directly onto the cylinder head. Its function is to promote rapid
mixing of the hot exhaust gas with the secondary air and retain the
gases at a high enough temperature for sufficient time to burn up
most of the HC and CO. To achieve rapid warm-up after engine
start, a thin steel liner acts as the core of the reactor inside a cast
iron outer casing with heat losses held to a minimum. The fuel-air
mixture in this case is enriched so that the chemical energy re-
leased inside the reactor in the burn-up process holds the core at
temperatures of 1600-1800 degrees F.
3.2.d Oxidizing Catalytic Converter
Oxidation of the HC and CO in the exhaust gas can be accom-
plished by means of catalysts at temperatures lower than those in
a thermal reactor. A catalytic converter can be placed farther
from the engine than a thermal reactor, and can maintain its
effectiveness without mixture enrichment to increase the chemical
energy in the exhaust. As a consequence, the fuel-economy penalty
is lower. The catalyst used is made up of a small mass of active
material such as noble metal or a combination of transition and
non-transition metals, deposited on thermally stable support mate-
rials such as alumina. To prevent loss in catalytic activity due to
mechanical damage, small spherical pellets or a honeycomb (mon-
olithic structure) have been found the most suitable geometries.
The catalyst is contained in a metal casing designed to direct the
exhaust flow through the catalyst bed.
For high conversion efficiency throughout the test cycle, the
catalyst must attain its "light-off" temperature4 as soon as possi-
ble after engine startup. Considerable development work has
therefore been done to reduce the density of the support material
and increase the surface area of the active components. To main-
tain high catalytic activity, the fuels employed need to be low in
concentration of various catalyst poisons such as lead, phosphor-
us, and sulphur. For most catalysts, the relative conversion effici-
ency is independent of exhaust-gas compositions over a wide range
of HC and CO concentrations.
3.2.e Major Engine Modifications
More precise fuel metering following changing engine condi-
tions is required to maintain effective emission control. Fuel-air
-------
2778 LEGAL COMPILATION—AIR
mixture preparation during the engine warm-up phase is espe-
cially important. The exhaust-gas composition and temperature at
entry to the thermal reactor or catalytic converter must be
matched to reactor or converter performance, which requires more
accurate fuel-air-ratio control. Fuel and air distribution between
different cylinders of the engine must be made more uniform. The
use of EGR further complicates the problem of mixture prepara-
tion. Good mixing and distribution are required to maintain ade-
quate vehicle performance. Improved carburetors are being devel-
* The temperature at which the catalyst effectively oxidizes HC and CO emissions.
oped to satisfy these requirements. Alternative fuel-metering con-
cepts, such as fuel injection, that may offer better control are also
being explored. Compensation for air-density changes with alti-
tude will probably be required. Greater metering accuracy during
engine startup and warm-up is also necessary. Power chokes have
been incorporated to make choke operation more reliable. The
choke is being released earlier in the engine warm-up phase to
reduce HC and CO emissions. Intake manifolds are being rede-
signed to improve fuel, air, and recycled exhaust-gas distribution
between cylinders. Quick heat intake manifolds are also being
developed to reduce emissions during the engine warm-up phase.
A part of the intake with low thermal inertia is directly heated by
the exhaust gas to achieve good fuel vaporization before the en-
gine is fully warmed up. As a consequence, the fuel-air mixture
can be leaned out sooner after engine startup.
Ignition-system malfunction due to wear and inadequate main-
tenance is a common cause of increased HC emissions in current
vehicles. For 1975 vehicles, electronic and inductive ignition sys-
tems have been developed that will improve reliability in customer
use. Control of spark timing can be made more easily and will be
used to reduce HC and NOX emissions. Spark-retard during en-
gine warm-up will also be used to increase exhaust-gas tempera-
tures and hence reduce the time required for reactor and con-
verter to become effective.
Cylinder-head modifications are made primarily to maintain ad-
equate vehicle driveability when EGR is used to reduce NOX emis-
sions. While optimized surface-to-volume ratio gives some reduc-
tion in HC emissions, the major gain is improved combustion
characteristics. For systems using a catalytic converter, exhaust
ports and manifolds and exhaust pipes are being modified to pro-
mote rapid mixing of exhaust gas and secondary air, and to reduce
heat losses to a minimum.
-------
GUIDELINES AND REPORTS 2779
3.2.f Control-System Integration
Most of the complete emission-control systems that show some
promise of approaching the 1975 emission standards require the
following: improved carburetor performance, fast-acting and
more accurate choke, inductive or electronic ignition system with
modified timing, exhaust-gas recycle, secondary air pump with air
injection into the exhaust ports or manifolds, and an oxidizing
catalytic converter to complete the burn-up of HC and CO. When
its performance is optimized, this system can achieve very low HC
and CO emissions once the catalyst attains its light-off tempera-
ture. However, unless additional controls are used, the catalytic
converter warms up too slowly to adequately control emissions
when the engine is cold. The rich fuel-air mixtures used while the
engine is warming up result in high exhaust HC and CO emis-
sions.
Two main approaches are being developed with the objective of
achieving greater emission control during the engine-warm-up
phase. In one approach, the conventional exhaust manifold is re-
placed with a small-volume thermal reactor located upstream of
the catalytic converter. The reactor is designed so that, very
quickly after engine start, it will reach temperatures at which HC
and CO will be burnt up. The combustion of the HC and CO raises
the temperature of the gas leaving the reactor. Consequently, the
catalyst bed heats up more rapidly. Once the catalyst reaches its
operating temperature, the reactor and catalyst share the burn-up
duty, with the catalyst bed playing the major role.
The other approach attempts to lean out the fuel-air mixture
earlier in the engine warm-up phase by modifying the intake
manifold. A quick heat manifold design is used, in which part of
the intake is heated rapidly by the exhaust gases to obtain better
fuel vaporization. The need for fuel-rich mixtures is obviated dur-
ing the period a conventional intake would take to warm up, and
HC and CO emissions are substantially reduced. Once the catalyst
is warmed up, HC and CO emissions are brought down to very low
levels.
Emission-control systems must also be designed to withstand
types of vehicle operation other than those included in the emis-
sion test cycle. High-speed cruise, maximum acceleration, long-du-
ration descent along a downgrade, and operation with a vehicle
overload may place extra demands upon the emission-control sys-
tem. Some manufacturers plan to install cut-out devices that will
bypass some or all the control-system components in these opera-
-------
2780 LEGAL COMPILATION—Am
tional modes in order to preserve the system's functional integrity
during normal urban driving conditions. Thus a great variety of
vehicle uses, and even abuses, must be withstood without damage
to the emission-control system if it is to function successfully
throughout the lifetime of the vehicle.
3.3 Current Stage of Development
3.3.a Emissions at Low Accumulated Mileage
The emission-control systems described in Section 3.2 have been
under intensive development on experimental vehicles. This devel-
opment includes both improvement in performance and durability
of individual components, and optimization of the interaction be-
tween the many components to achieve the most effective overall
emission control. To allow for degradation in control-system effec-
tiveness (especially catalyst deterioration), and for slippage in
emission control when moving from experimental to production
vehicles, most manufacturers have set low-mileage emission tar-
gets for their experimental vehicles that are below the standards.
Furthermore, even these targets are based on the assumption by
manufacturers that standards need to be met only on the average,
and not by each vehicle. In the past, system deterioration and
slippage in the transfer to production vehicles have been signifi-
cant. Manufacturers' development efforts are concentrated first on
achieving low-mileage emission targets with systems having
mass-production potential and subsequently on testing the durabil-
ity of system components over extended mileage.
A number of uncertainties still exist concerning the definition of
compliance with the law, which affect the choice of values of these
low-mileage emission targets. These uncertainties are allowable
maintenance during the 50,000-mile certification procedure, the
testing of vehicles at the end of the assembly line, and whether all
vehicle emissions or only the average of vehicle emissions, as de-
fined in Section 2.3, must meet the standards during the vehicle's
useful life.
The present durability-testing procedure is to allow mainte-
nance comparable to the average that vehicles receive in custom-
ers' hands. The question whether catalyst replacement can be re-
garded as part of this normal maintenance is particularly impor-
tant since, as will be described in more detail later, catalyst deteri-
oration is a major problem with the contemplated 1975 emission-
control systems.
If the full recommended customer maintenance is not allowed
-------
GUIDELINES AND REPORTS 2781
during the certification procedure, then deterioration in emission
control over the 50,000 miles will be greater. EPA has not yet
determined whether this option is open to manufacturers.
An end-of-assembly-line emissions test, as distinct from a test
intended to ensure effective manufacture and assembly, might re-
quire a further lowering of these low-mileage emission targets.
The combination of production tolerances on piece parts and sub-
assemblies will inevitably result in a distribution of emissions
about the mean, some vehicles emitting more than the mean value,
some less. The requirement that emissions from all, or almost all,
production vehicles be below the standard would be a much more
severe requirement than the requirement that only the average
emissions of all production vehicles be below the standard.
Typical manufacturers' low-mileage emission targets are shown
in Table 3.2. Values vary somewhat depending on manufacturers'
past experience and judgment. These targets are currently being
set at about 50 to 60 percent below the emission standards to allow
for a 10-20 percent increase in emissions as the control system is
transferred from experimental to production vehicles, for a factor
of about 2 deterioration in HC and CO emission control over
50,000 miles (primarily from the decreasing effectiveness of the
catalyst), and for deterioration in the EGR system due to plug-
ging of the line and valve with deposits. The low-mileage emission
targets set at about 50 to 60 percent below the standards are based
on the assumption that only the average emissions of production
vehicles must meet the standards, and that recommended customer
maintenance (including catalyst replacement if necessary) will be
allowed during the 50,000-mile certification testing.
Table 3.2 presents a summary of data on the best emissions
results attained to date5 supplied to the Committee by the automo-
bile-manufacturing industry. The emissions measurements sum-
marized in the table were done on vehicles equipped with the
prototype versions of each manufacturer's 1975 control system.
They represent the average of several tests on each vehicle. The
mileage accumulated on these vehicles and systems is a few thou-
sand miles at most. Appendix F gives the emissions measured
from each manufacturer's best car. The data from Appendix F
were used to compile Table 3.2. These results show that, at the
present stage of development, most manufacturers have been able
to achieve emission levels close to the 1975 standards on labora-
tory-engineered vehicles at low mileage. However, it will be shown
in Section 3.3.b that vehicle emissions increase steadily with
-------
2782 LEGAL COMPILATION—AIR
accumulated mileage, the main reason being the deterioration of
catalyst performance.
5 October 15, 1971.
TABLE 3.2—LOW-MILEAGE EMISSION TARGETS AND MEASUREMENTS 1
Emissions, grams/mile
HC CO NO,.
1975 Standards
Low-mileage targets1. . . . ...
Major U.S Manufacturers'
Single best car (car C from Appendix F) ... .
Average of each manufacturer's best car (average of cars A, B,
C, D, E from Appendix f)
Range of best-car emissions
Range of emissions from one manufacturer's development fleet «
Foreign Manufacturers'
Average of each manufacturer's best car
Range of best-car emissions
0.41
0.19
0.13
0.21
0.13-0.31
0.2-0.9
0.33
0.10-0.63
3.4
1.5
1.9
2.8
1.9-3.7
3-12
3.7
2.4-5.8
3.0(1.5)!
1.9(0.9)
1.3
2.2
1.2-4.5
0.9-1.4
1.7
0.6-2.5
1 The data are as of October 15, 1971. The emission data are the average of several tests on laboratory-engineered
vehicles at low mileage using the 1975 test procedure except where indicated in Appendix F. More detailed data are given
in Appendix F
* Values in parentheses are applied to proposed California 1975 standards.
* These are typical values, targets vary between manufacturers depending on past experience and judgment Certain
assumptions about production vehicles affect these targets.
4 Typical development fleets contain 5-10 vehicles, with different-size engines and different drive transmissions. Con-
trol systems are at different stages of development.
One U.S. manufacturer with one vehicle has come close to the
listed low-mileage emission targets. The major U.S. manufactur-
ers each have one or a few vehicles with emissions between these
targets and the standards. Better HC-emission control has been
achieved than CO-emission control; the average of United States
manufacturers' best vehicles shows HC low-mileage emissions 49
percent below the 1975 standard and CO low-mileage emissions 18
percent below the 1975 standard.
Table 3.2 also shows the range in emissions in one U.S. manu-
facturer's 1975 development fleet. These fleets are typically five to
ten cars, each equipped with the basic elements in the 1975 emis-
sion-control system. These vehicles are usually different models in
the manufacturer's product line, with different engines and drive
trains. Other manufacturers' fleets show a similar range in emis-
sions. These results indicate that the same emission-control system
applied to vehicles with different engines and drive trains shows a
spread in low-mileage emissions of a factor of 2 to 3 above and
below the mean. This spread is due both to the different stages of
development of each of the experimental vehicles and to different
individual vehicle reactions to the control-system components.
The emission levels achieved by foreign automobile manufactur-
-------
GUIDELINES AND REPORTS 2783
ers shown in Table 3.2 also indicate that considerable progress has
been made. The magnitude of their emissions research and devel-
opment efforts is generally less than that of U.S. manufacturers
and appears to depend on the importance placed on retaining their
share of the U.S. market. Availability of test equipment and
trained manpower have also been stated to be limitations on the
programs of foreign manufacturers. The averages of emissions
from each manufacturer's best-effort vehicles are higher than the
corresponding averages of U.S. manufacturers' best efforts. The
spread in emissions from these best-effort vehicles is also greater.
It is clear that some of these manufacturers have not progressed
to a stage at which they can evaluate their position in relation to
the 1975 standards with any confidence. In general, the Committee
judges that foreign manufacturers have not achieved the degree of
emission control achieved by the major United States manufactur-
ers.
The results summarized in Table 3.2 also show that the NOX
emission control required by federal standards in 1975 (3 g/mile)
appears to be within the capability of these laboratory control
8 This standard is for all production vehicles and not just the average emission.
systems. However, the proposed California NOX 1975 standard of
1.5 g/mile6 may not be feasible and may affect manufacturers'
ability to hold HC and CO emissions at levels close to the 1975
federal standards. The potential of these control systems to
achieve greater NOX reductions is explored more fully in Section
3.4.
At this point, it must be stressed that emissions measurements
on a single vehicle should be interpreted with caution. There is a
significant variation in results when the same vehicle is tested
several times with the same test equipment, due to changes in
control-system performance and errors and inadvertent variations
in the test procedure. Variations in emissions of ± 50 percent
about the average value are not uncommon. Thus, conclusions can
be drawn only from the average of several tests on any one vehi-
cle. Currently available data are also insufficient for determination
of whether excellent performance with the control system on one
vehicle can be achieved on another vehicle with different weight,
engine, and drive train. The effectiveness of a given system on a
manufacturer's entire product line can, at present, only be in-
ferred.
Data submitted to the Committee and its Panels by research and
-------
2784 LEGAL COMPILATION—AIR
development groups outside the automobile industry attempting to
achieve emission control to the 1975 standards with reciprocating
spark-ignition engines have not indicated the achievement of bet-
ter emissions control. Moreover, few of these groups have at-
tempted to test and demonstrate the durability of their systems
over extended mileage.
3.3.b System Durability
Before these laboratory-built and controlled systems can be con-
sidered suitable for production, the reliability and durability of
the system and its components over extended mileage must be
demonstrated. The performance of the catalyst is especially impor-
tant. Since accumulation of 50,000 miles on a vehicle simulating
typical customer use takes at least four months, and since few
systems have yet reached the low-mileage emission targets, such
durability data are sparse. Though more durability da*a are avail-
able on some of the system components, these must be used with
caution since the laboratory conditions under which durability was
tested are far different from the conditions that will be experi-
enced with the complete 1975 system. This is especially true of
catalyst tests performed with 1970 or 1971 production automo-
biles. Engines in these production vehicles operate with a leaner
carburetor setting than is expected in 1975 model year vehicles,
and hence with a lower HC and CO loading on the catalytic con-
verter.
Deterioration in catalyst effectiveness is the greatest problem
with all these systems. It causes vehicle emissions to rise steadily
with accumulated mileage. This deterioration results in part from
poisoning of the active catalyst material, and in part from damage
to the catalyst surface structure caused by overheating. Both these
effects reduce the activity of the catalyst when fully warmed up;
they also raise the bed temperature required for the catalyst to
become fully effective. Emission control in both the cold-start and
warm-engine phases is impaired.
It is well known that the lead compounds resulting from com-
bustion of antiknock additives in commercial gasoline (present in
amounts up to 3 grams lead alkyls per gallon) rapidly poison the
active catalyst materials being used. Vehicles with catalytic con-
verters must therefore be operated with "lead-free" fuel. How-
ever, today's "lead-free" gasoline still contains trace quantities of
lead as well as other elements such as phosphorus and sulphur. All
have been found to increase catalyst deterioration significantly.
-------
GUIDELINES AND REPORTS 2785
The concentrations of these elements in currently available "lead-
free" gasoline are high enough to be of concern. Also lubricants,
and detergent and dispersant additives, may contain small
amounts of these and other elements that contaminate the catalyst
material.
There is therefore a need for federal action to ensure wide
availability of lead-free fuel at the time vehicles with catalytic
converters come onto the road. Action is also required to control
the amounts of catalyst poisons in the fuel. Some manufacturers'
data suggest that fuel with less than about 0.03 gram lead alkyls
per gallon, and less than about 0.01 percent sulphur and 0.005
percent phosphorus, may be required. It is also essential that the
automotive and petroleum industries devise techniques for ensur-
ing that vehicles that must use lead-free gasoline cannot have
their fuel tanks filled with conventional leaded gasoline.
Catalyst damage due to overheating in vehicle use is not ade-
quately understood. Certain vehicle-operating modes result in high
exhaust-gas temperatures and high HC and CO concentrations.
When these emissions are burnt up in the catalytic converter, the
heat released in the oxidation process can raise bed temperatures
to 1600 °F or more and cause physical damage to the catalyst
surface structure. Examples of detrimental vehicle-operation
modes are sustained operation at high engine power and descent
down long hills. The driving schedule used to accumulate mileage
rapidly during driveability tests, while typical of average cus-
tomer use, does not include several of these operating modes in
which overheating can occur. Also, any engine failures, such as
spark-plug misfire, which substantially increase HC and CO emis-
sions, are likely to result in severe overheating and catalyst dam-
age. While recent developments in catalyst technology have im-
proved the structural properties of catalysts at high temperatures,
there will probably still be a need for a catalytic converter by-pass
system to prevent permanent damage to the catalyst in those
modes in which overheating is likely. The by-pass system must
seal tightly during normal use to prevent excessive emissions. It
would be operated by signals from sensors measuring catalyst-bed
or exhaust-gas temperature. Such systems are under development,
but satisfactory performance has not yet been obtained.
Most of the oxidation catalysts tested on vehicles show an initial
loss of activity, especially in CO-conversion efficiency, over the
first few thousand miles of vehicle operation followed by a more
gradual loss in activity over the subsequent tens of thousands of
miles.
-------
2786 LEGAL COMPILATION—AIR
Data in Appendix G illustrate these points. Variations in emis-
sions during engine startup at the beginning of the test and
changes in carburetor settings as well as catalyst deterioration
affect the emission results.
Few of the catalysts with the high initial activity required to
achieve emissions close to the 1975 standards have yet been tested
over extended mileage. Not all the tests made were conducted with
HC and CO loadings on the converter comparable to those ex-
pected with the complete 1975 system. For example, exhaust-gas
recirculation to control NOX emissions was not always used. Since
this requires enrichment of the fuel-air mixture to maintain ade-
quate vehicle driveability, HC and CO emissions from the engine
itself increase. Increasing the load on the converter appears to
result in faster catalyst deterioration.
Only a few of the automobile manufacturers have carried out
durability tests with their 1975 emission-control systems over suf-
ficient mileage to allow estimates of deterioration over 50,000
miles. The best results available to date with catalytic converters
in emission-control systems similar to those being developed for
1975 model year vehicles are summarized in Table 3.3. The emis-
sions measured at low mileages were not always below the 1975
HC and CO standards. The 50,000-mile deterioration factor is the
ratio of emissions measured at 50,000 miles to emissions measured
at 4,000 miles. Smoothing of the data is required to obtain this
factor because the scatter can be up to ± 50 percent about the
average, due to variation in control-system performance and test
procedure. The best measured or projected increase in emissions
over 50,000 miles is by a factor of 2.5 or more when low-mileage
emissions were below the 1975 HC or CO standard. While lower
deterioration factors have been measured when initial emissions
levels were above the 1975 HC or CO standards, it is not clear that
this improved performance can be retained as the activity of the
catalyst is increased to reduce emission levels below the standards.
At this time, automobile manufacturers do not have adequate data
to assess the durability of their catalytic converters over extended
mileage. Their experimental vehicles with promising low-mileage
emissions have exceeded one or both of the 1975 HC and CO
standards early in the durability tests. Catalyst replacement dur-
ing the 50,000-mile durability test would improve this situation.
Whether emissions after catalyst replacement would be close to
the values achieved at low mileage would depend on the deteriora-
tion of engine adjustments and other components in the system
that affect emission control.
-------
GUIDELINES AND REPORTS 2787
TABLE 3.3-DETERIORATION IN EMISSION CONTROL OVER 50,000 MILES '
A-Base metal,
B-Base metal,
Catalyst type
pellets
pellets .
C-Platinum, monolith « .
D-Base metal,
pellet
Emission (g/mile)
at 4,000 miles
HC
CO
... . HC
CO
HC
CO
.... HC
CO
0.6
10
0.243
5.4»
0.19
4.2
0.8
9.5*
50,000-Mile
deterioration
factor «
2.8
2.4
2.5
1.6
2.5
2.5
1.5
1 Examples of best results obtained to date over 50,000-mile durability tests by automobile manufacturers with control
systems similar to those being developed for 1975 vehicles. CVS-C test procedure used (see Table 3.1) except where noted.
Data supplied to Panel on Emission Control Systems.
2 Deterioration factor as used by EPA is emissions at 50,000 miles divided by emissions at 4,000 miles. A straight line
is drawn through the emissions data plotted against mileage to obtain this ratio. The scatter in the data about this line
is about *50 percent.
* These emissions measured with 1975 test procedure at zero miles.
* No EGR used with this vehicle. When EGR is used to reduce NOx emissions below 3 g/mile, HC and CO emissions from
engine will rise.
» Average value. CO emissions varied over the range 6.5-14 g/mlle. Not possible to determine a deterioration factor.
The durability of other components in the emission-control sys-
tem has not yet been adequately demonstrated. EGR systems show
deterioration with mileage due to plugging of the recycle line and
control valve with deposits. While the manifold reactors used by
some manufacturers have shown promise of extended mileage dur-
ability under normal operating conditions, their ability to with-
stand higher temperatures during extreme operating conditions is
open to question. Quick heat intake manifolds are a new develop-
ment and their durability has not been adequately assessed.
It is also essential that new production carburetor and choke
designs, and quick heat manifolds, be thoroughly proven in field-
testing before they are placed on customer cars. Proper fuel-air
mixture preparation is a critical element in assuring adequate and
safe vehicle operation and the effectiveness of the emission-control
system.
In view of these problems it should be asked whether systems
with a catalytic converter as the major HC and CO burn-up device
are the best choice. The alternative is a system with a manifold
thermal reactor. The best low-mileage emissions results reported
to date with two different thermal-reactor concepts are given in
Table 3.4. The best results obtained with a proposed 1975 catalytic
converter system are included for comparison. The thermal-reac-
tor system includes EGR and fuel-rich carburetion to control NOX.
It also requires this rich carburetion to provide enough chemical
energy in the engine exhaust to hold the reactor core at high
enough temperatures for burn-up to be effective.
-------
2788
LEGAL COMPILATION—AIR
The main problems with the thermal-reactor system are: sub-
stantial fuel-economy penalty (e.g., 17-22 percent for reactor B);
inadequate CO-emission control; inability to control NOX emis-
sions to the 1976 standard (the thermal reactor bolts directly onto
the cylinder head and does not provide the proper reducing atmos-
phere for an NO* catalyst) ; need for over-temperature protection,
and high emissions in the event of failure. At present, the Com-
mittee judges that the oxidizing-catalytic-converter approach of-
fers more promise of meeting the 1975 standards and better po-
tential, with a reducing catalyst, of meeting 1976 NOX levels (the
oxidation catalyst can be located downstream of the NOX cata-
lyst).
3.4 System Compatibility with 1976 NOX Standard
An important consideration is the potential of the 1975 control
systems, with further development, to meet the 1976 NCvemis-
sion standard of 0.4 g/mile. Almost all manufacturers have
focused their development efforts on control systems that can
achieve much lower NOX emissions than are required in 1975.
NOX control to below 3 g/mile in the systems proposed for 1975
model year vehicles is achieved with EGR, fuel-air mixture enrich-
ment, and adjustments in spark timing. The best NOX control
achieved in experimental vehicles by using increased amounts of
EGR and richer mixtures is 0.8-1.0 g/mile. A fuel-economy
penalty of 20 percent or more results, and the HC and CO loading
on the catalyst is increased. Attempts at greater NOX control with
these approaches lead to higher HC and CO emissions, an in-
creased fuel-economy penalty, and poor vehicle driveability. The
TABLE 3.4-BEST LOW-MILEAGE EMISSIONS FROM THERMAL-REACTOR SYSTEMS'
Emissions, grams/miles
Thermal-Reactor Concept A
Thermal-Reactor Concept B
Best 1975 Catalytic-Converter system.
HC
0.05
0.1
0.13
CO
9.2
4.0
1.9
NO,
0.51
0.7
1.3
i As of November 1, 1971
1975 proposed California NOX standard of 1.5 g/mile may even
be beyond the capabilities of some of the systems being developed
to meet the federal 1975 HC and CO standards (see Table 3.2).
While EGR with fuel-air mixture enrichment is effective in
reducing NOX emissions to levels approaching 1.5 g/mile, it is not
a satisfactory method of achieving the very low NOX emissions
-------
GUIDELINES AND REPORTS 2789
required in 1976. Large amounts of EGR (about 20 percent) de-
grade engine performance and fuel economy and significantly in-
crease the difficulty of HC- and CO-emission control. The use of
rich mixtures results in high engine HC and CO emissions. The
increased thermal load on the catalytic converter makes damage
from overheating more likely; in the event of catalyst failure, the
vehicle emissions would be greater than those from current new
vehicles.
The basic 1975 emission-control systems now being developed
will require either the addition of a high-performance N0x-reduc-
ing catalyst in addition to an oxidation catalyst, or an effective
three-way catalyst (which controls NOX, HC, and CO emissions)
to achieve NOX control to the level of the 1976 standards. In the
first approach, the additional NOX catalyst bed would be placed in
the exhaust system upstream of the HC- and CO-oxidizing cata-
lyst. Recalibration of the carburetor to a richer setting to provide
a reducing exhaust-gas stream would be required. Some EGR
would probably be retained to reduce the NOX levels entering the
NOX catalyst bed. The secondary air would be added downstream
of the NOX catalyst once the system was warmed up. During the
warm-up phase, secondary air would be added in the exhaust man-
ifold and the NOX catalyst would act as an oxidizing catalyst to
control HC and CO emissions. If a three-way catalyst were to
prove practicable, all three pollutants could be controlled in one
converter and a simpler system would result. For both these ap-
proaches, the carburetor setting used for the 1975 systems would
need recalibration. The measures taken to control emissions in the
1975 system while the engine warms up may not be as effective in
these 1976 systems and additional development of the system to
adequately control HC and CO emissions during the engine and
catalyst bed warm-up phases would then be required.
Laboratory-engineered systems of this type are now being eval-
uated, but the technology of suitable N0x-reducing catalysts or
three-way catalysts is not nearly as advanced as the technology of
oxidation catalysts. Although N0x-emissions reductions to levels
approaching the 1976 standard of 0.4 g/mile have been achieved
on a few experimental vehicles, the catalyst durability is poor, and
the mass-production potential of these systems cannot yet be es-
tablished. Contacts between the Committee and catalyst manufac-
turers have indicated optimism among the catalyst manufacturers
that a three-way catalyst system can be developed. Efforts in this
area during the next year will be monitored very closely by the
Committee.
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2790 LEGAL COMPILATION—AIR
The techniques proposed to control NOX emissions make it
harder to achieve HC- and CO-emission control to the levels re-
quired by the 1975 standards. The use of EGR as explained above
requires mixture enrichment to maintain vehicle driveability and
increases the engine's HC and CO emissions. The inclusion of an
N0x-reduction catalyst adds extra mass upstream of the oxidation
catalyst and, therefore, slows down the warm-up of this HC and
CO converter during the cold-start portion of the test. The use of
an NOX catalyst also requires some mixture enrichment to provide
the correct composition of gases entering the catalyst chamber.
3.5 Effects of Emission-Control System on Vehicle Performance
Three areas of vehicle performance are likely to be adversely
affected by the 1975 emission-control systems. These are fuel econ-
omy, vehicle-acceleration capability, and vehicle driveability (or
ability to perform adequately in all normal operating modes and
ambient conditions).
Reductions in compression ratios for 1971 and later model year
vehicles, to enable these engines to burn 91-octane gasoline, have
already resulted in losses in fuel economy and acceleration capabil-
ity for engines of given displacements. The use of EGR to control
NOS emissions is the primary cause of the expected additional
performance losses in 1975 model year vehicles. Because EGR
slows down the combustion process inside the engine, the fuel-air
mixture must be enriched to maintain flame speeds and retain
adequate driveability. Spark retard is also used and has a similar
effect. Data from the automobile manufacturers indicates that
these changes are expected to result in a direct fuel-economy pen-
alty of 3 to 12 percent compared with 1973 prototype vehicles,
depending on engine size, axle ratio, vehicle weight, and details of
the emission-control system.
Again because EGR is used, the power output for a given engine
displacement, engine speed, and throttle setting is reduced. Be-
cause the fresh mixture is now diluted, less fuel and air enter the
cylinder, and the effective size of the engine is decreased. The
resulting loss in acceleration capability can be offset by increasing
engine displacement (which results in a further fuel-economy pen-
alty) and by cutting out EGR at wide-open throttle. The precise
performance loss is difficult to estimate at this stage, since it also
depends on details of engine size, vehicle weight, and the emis-
sion-control system. It is likely that some of the smaller engines
now available in some model lines will have to be discontinued, due
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GUIDELINES AND REPORTS 2791
to the reduction in performance of such engines to unacceptable
levels when operated with EGR.
The effects of emission controls on vehicle driveability are diffi-
cult to quantify. Driveability after a cold-engine start, and espe-
cially with cold ambient conditions, is likely to be impaired. To
reduce HC and CO emissions during engine warm-up, the choke is
set to release quickly, and the fuel-air mixture is leaned out as
early as possible after engine startup. Under these conditions,
problems of engine stall, and vehicle stumble and hesitation on
rapid acceleration, have been prevalent. Vehicle stall and stumble
are safety hazards in some traffic situations. Similar problems
during startup and drive-away after a hot-engine restart have been
experienced. By careful tailoring of the fuel-air mixture control,
such problems have in the past generally been resolved, though
there has been a deterioration in driveability in 1971 and 1972
model year vehicles. The impact of more stringent air-fuel ratio
control for 1975 model year vehicles on vehicle driveability can-
not yet be accurately established, because these 1975 prototype
systems have not been tested under a wide range of ambient con-
ditions. The use of EGR affects driveability. Adequate vehicle
performance depends on good mixture preparation and distribu-
tion between the different engine cylinders to avoid engine mis-
fire. Exhaust gas is one more component to be mixed with the
fresh mixture in the intake manifold. It makes this problem more
critical because it reduces the tolerable cylinder-to-cylinder fuel-
air variation.
The successful resolution of many of these driveability problems
depends on extensive field-testing of production prototypes. The
vehicles need to be tested under as complete a range of vehicle-op-
erating modes and ambient conditions as possible. This is an es-
sential stage in the development process if the engine and emis-
sion-control system are to perform safely and reliably in the cus-
tomer's hands. Severe driveability problems could have significant
safety implications.
3.6 Developments Required to Meet 1975 Standards
From the data reviewed in Section 3.3, it is clear that no major
manufacturer has yet demonstrated the technology needed to meet
the requirements of the 1970 Clean Air Act Amendments of 1975
model year vehicles. However, both the automobile and catalyst
manufacturers have intensive development efforts under way.
Thus, there remains some possibility that a control system can be
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2792 LEGAL COMPILATION—AIR
developed in time to permit the mass production of vehicles that
will meet the 1975 standards.
It must be stressed that the major automobile manufacturers
are at different stages in this deve opment. Also although the
control systems being proposed for 1975 by most manufacturers
are similar in concept, the details of the system components differ
significantly among them and the integrated systems have been
optimized for different engine-operating conditions. Fuel-air ra-
tios used and mixture preparation are two important differences.
Thus, although one or perhaps two manufacturers have shown on
a few of their vehicles that their systems have the potential of
meeting the low-mileage emission targets, it is not clear that the
ocher manufacturers' systems, in their present forms, have this
potential. Especially important are the variations in catalyst dura-
bility obtained by different automobile manufacturers using cata-
lysts that, according to laboratory tests, should have similar prop-
erties. The different HC and CO loadings on these catalytic con-
verters appear to be significant.
Most manufacturers evaluate the low-mileage emissions per-
formance of their systems in relation to emission targets, which,
as shown in Table 3.2, are substantially below the 1975 standards.
Intensive durability testing commences only when the system
shows promise of reaching these targets. It must, therefore, be
asked whether these targets are realistic or unduly stringent. This
depends in part on decisions the Administrator of EPA has yet to
make. One decision is whether only the average emissions of pro-
duction-line vehicles, or all or almost all vehicle emissions, must be
below the standard (Section 2). The second is what maintenance
procedures are allowed during the 50,000-mile certification test.
The question of catalyst replacement at more frequent intervals
than 50,000 miles is crucial. The targets listed in Table 3.2 as-
sumed that only the average of production-line vehicle emissions
must be below the standards for the vehicle's useful life, that pro-
vision is made for catalyst replacement and other maintenance
during the certification procedure, and that fuels with sufficiently
low levels of catalyst poisons will be widely available. Available
catalyst durability data and a reasonable assessment of improve-
ments likely over the next year or so suggest that, without catalyst
replacement, these low-mileage targets are optimistic. If catalyst
replacement at 20,000 - 30,000 mile intervals is to be allowed, and
if these anticipated improvements in catalyst performance are
realized, then these targets represent a reasonable judgment of
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GUIDELINES AND REPORTS 2793
necessary low-mileage performance of the emission-control sys-
tem.
The developments required to enable most major manufacturers
to meet the 1975 standards in 1975 model year vehicles can now be
laid out. First, an experimental version of the control system must
be shown capable of meeting the necessary low-mileage emission
targets. One or two manufacturers have reached this stage with
HC emissions and are approaching this stage with CO emissions
provided the assumptions about averaging, catalyst replacement
and maintenance already described can be applied. Second, the
durability not only of the catalyst but of the entire experimental
systems must then be demonstrated under conditions typical of
both normal and extreme customer usage. Better built-in control
of engine adjustments than in present engines will be essential.
Catalysts with initial activity equal to that of the best materials
now available, but with improved durability, will be required. It
appears now that catalyst replacement within 50,000 miles will be
necessary to prevent deterioration in HC- and CO-emission control
by more than a factor of 2 and, hence, to retain low-mileage
emission targets at 50 to 60 percent below the standards.
For those manufacturers who are close to meeting their low-
mileage goals and who have already demonstrated catalyst dura-
bility approaching what will eventually be required, these develop-
ments are extrapolations of their current technology. The develop-
ment effort required to realize these improvements in time for
1975 model year production may be such that only the larger
manufacturers have sufficient resources.
A critical factor in this development process is the need for
extended reliability and durability testing, not only of the engine
and emission-control system, but also of other vehicle components
whose design must be changed as a result of emission control.
Examples of such changes are redesign of parts of the vehicle
frame to obtain extra space for enlarged exhaust manifolds and
catalytic converters, and modifications to power steering and
brakes as EGR changes the intake-manifold vacuum. Most of these
additional problems can be solved with standard engineering tech-
niques ; there will be many such changes, however, and each new
component must be adequately tested before mass production.
Historically, the automobile manufacturers have introduced new
components only after extensive testing on a small part of their
total production. The reasons for this are sound; customers use
their vehicles in a wide variety of ways and expect reliable, safe,
and satisfactory performance. Adequate design data become avail-
526-705 O - 74 - 29
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2794 LEGAL COMPILATION—AIR
able only after customer field experience has been obtained. This
process can be accelerated by increasing development effort, but
time constraints for 1975 model production are such that many
engineering decisions may be made during the next two years
without benefit of adequate information.
3.7 Stratified-Charge and Wankel Engines
Two alternative spark-ignition engine concepts have received
considerable attention of late. These are the stratified-charge and
the Wankel rotary-combustion engines. Neither of these concepts
is new. The stratified-charge principle was first suggested in the
early 1920's; the Wankel engine in its current form dates back to
1957. Emission control is one of the several reasons for the re-
newed interest in these alternative approaches. These engines
would represent a less radical change than other low-emission
alternatives such as gas turbines and Rankine cycle engines. Their
low-emission potential relative to conventional spark-ignition en-
gines, and the time scale required to realize that potential, are
important considerations.
Several different stratified-charge engine concepts are now
being explored at the research stage. In each of these, fuel is
injected directly into the engine cylinder. The engine geometry,
timing of fuel injection, fuel and air-flow patterns, spark-plug
position, and spark timing are all carefully adjusted so that com-
bustion of the stratified fuel-air mixture inside the cylinder takes
place under conditions that minimize pollutant formation. With
precise control of mixture preparation and combustion over the
entire engine speed and load range, the basic engine emissions are
considerably below those of conventional engines. The emissions
are not at this stage low enough to meet the 1975 or 1976 stand-
ards without additional control devices such as EGR and a cata-
lytic converter.
The two most advanced versions of the stratified-charge concept
are being developed for the U. S. Army Tank-Automotive Com-
mand's M151 military jeep. The engine for this vehicle is a four-
cylinder engine nominally rated at 70 horsepower. The version of
this engine developed by the Ford Motor Company was tested
recently by EPA and gave emissions at low-vehicle mileage below
the 1975 and 1976 standards.
However, this engine is far from ready for mass production. It
is known that tolerances on engine adjustments to maintain this
low-emissions performance are narrow; no data are yet available
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GUIDELINES AND REPORTS 2795
on the durability of these adjustments over extended mileage.
Components such as the fuel injector and spark plugs are labora-
tory prototypes, and designs suitable for mass production need to
be developed. The low-emissions results were obtained in a low-
powered military vehicle with driving characteristics different
from those of a normal passenger car. The low-emissions potential
of the system on larger engines in full-size vehicles is only now
beginning to be explored.
Another type of stratified-charge engine is being developed with
a divided chamber or prechamber design. Fuel-air stratification is
obtained by injecting fuel into a precombustion chamber. The
resulting fuel-air mixture is sparked, and burning gases then
enter the main chamber above the piston where they mix with
excess air and burn to completion. This concept is still in the
research stage though it also appears to have inherent low-emis-
sions characteristics.
The low emissions of these existing experimental stratified-
charge engines may make this engine attractive in the longer
term. This engine may also offer a fuel-economy advantage com-
pared with emission controlled conventional engines. However, its
potential for the mass automotive market cannot yet be accurately
assessed. It represents a more radical departure from current
technology than might appear at first sight. The cylinder head,
piston, intake port and intake manifold geometries are all differ-
ent from those of a conventional engine and designs have not yet
been fully optimized. The fuel injector and nozzle must provide
better spray control than is achieved in diesel engines. The spark
plugs extend into the cylinder and require a different electrode
configuration. All these changes present new design and durability
problems. Several manufacturers now have development programs
to explore the potential for the stratified-charge engine; only when
results from these programs become available can sound judg-
ments as to its future be made. Even with the most optimistic
development schedule practicable, 1978 is the earliest date at
which this engine could be introduced into a substantial fraction
of any manufacturer's product line.
Wankel engine technology is further advanced. Though NSU's
early experience with limited production of this engine in Germany
was not encouraging, Toyo Kogyo in Japan have successfully mar-
keted Wankel engines for the last three years. A major problem
has been rotor apex seal wear, but acceptable solutions now ap-
pear to have been found. The claimed advantages of the engine
are: lighter weight, smaller size, smoother and quieter operation,
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2796 LEGAL COMPILATION—AIR
and fewer moving parts. It is therefore claimed that it would be
cheaper to manufacturer.
The emission characteristics of the engine have not been ex-
plored as extensively as have those of the conventional engine.
There are variations in geometry between different Wankel engine
designs that appear to affect emissions significantly. In current
production Wankel engines, HC emissions from the engine itself
appear higher, CO emissions are about the same, and NOX emis-
sions are lower than emissions from a comparable reciprocating
engine. The lower NOX emissions appear to be a significant advan-
tage. Much of the emission-control technology being developed for
conventional engines can be applied to the Wankel engine. How-
ever, the optimization of the engine design for low emissions and
integration with other control devices, such as thermal reactors
and catalytic converters, is at an earlier stage of development.
The claimed advantages of the Wankel engine lie primarily in
areas other than emissions. Thus, while a small fraction of 1975
model year vehicles may use Wankel engines, the HC- and CO-
emission-control problem will not be substantially different.
4. MAINTENANCE
The emission-control systems necessary to meet the 1975 and
1976 model year standards are complex systems that must be
carefully controlled and maintained to enable a vehicle to continue
to meet the standards for 50,000 miles, and have very low emis-
sions for their entire life. For example, more precise fuel metering
will be required. Control of the air-fuel ratio will have to be
maintained to within narrower limits than heretofore has been
required or possible. To try to obviate the difficulties of ensuring
adequate and proper maintenance, there will have to be an in-
creased tendency to replace rather than repair or readjust defec-
tive parts, e.g., sealed, electronic ignition systems. This will in-
volve, in many cases, an increase of maintenance costs.
A critical item in the 1975 emission-control system is the cata-
lyst. As discussed previously, whereas some manufacturers have
attained results below the 1975 emission standards on experimen-
tal vehicles, no one has yet been able to do this for 50,000 miles,
catalyst durability being a critical problem. According to the fed-
erally prescribed emission-test procedure relating to durability, a
major engine tuneup is allowed at 24,000 miles with replacement
of spark plugs, condenser, breaker points, etc. The lack of a
catalyst of proven durability may require that replacement of
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GUIDELINES AND REPORTS 2797
the catalyst at specified intervals be permitted in the federal
emission-test procedure and also become part of the standard
maintenance procedure indicated in manufacturers' warranties.
The problem of maintenance of emission-control systems is
made more difficult by the fact that devices such as manifold
thermal reactors and catalysts may fail without the motorist even
becoming aware of it. As discussed previously, the inadvertent use
of leaded gasoline or the failure to replace a misfiring spark plug
may well cause irreversible damage to the catalyst. Under these
conditions it is possible for the vehicle actually to emit as much or
even more pollutant material than the vehicle without a catalyst
and EGR, because of the richer carburetor setting required by the
emission-control system.
Further, the motorist will have no natural incentive to have
maintenance performed on his vehicle. The EGR system, for ex-
ample, carries a loss of performance and increases fuel consump-
tion. There is an apparent advantage to the individual motorist in
allowing this system to plug up, or even purposely to disable it.
The additional maintenance cost of a 1975 or 1976 model year
car is difficult to estimate, since even experimental vehicles have
not exhibited satisfactory 50,000-mile durability. Accurate cost
estimates cannot be made until such vehicles have been in service
in the hands of customers. Many motorists will not voluntarily pay
the necessary costs to maintain their cars at low emission levels,
with poorer performance and impaired driveability as the penalty.
If the additional emission control is to be realized in service, it is
necessary that adequate maintenance be required for the life of
the vehicle. Procedures to ensure such maintenance might include
state or local laws prohibiting deactivation of emission-control
systems and requiring that they be maintained, state or local
inspection requiring correction of cars with excessive emissions,
and required replacement of certain components at specified inter-
vals. Since some of the emission-control systems are not yet com-
pletely developed, failure modes are not well enough known to
determine the best method of enforcement at this time. The prob-
lems of developing enforceable procedures, including the provision
of economically feasible test equipment and personnel training,
have not as yet been attacked by either the automotive industry or
public bodies.
5. MANUFACTURING
In order to prepare for production of 1975 model year vehicles,
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2798 LEGAL COMPILATION—Am
new production facilities will have to be made available for such
items as air pumps, catalytic-converter housings, catalysts and
their carriers, and a multiplicity of valves, regulators, and safety
devices. New or extensively modified production facilities will
have to be provided for new carburetion and ignition systems, new
exhaust and intake manifolds, and new engine heads. Final assem-
bly-line and subassembly-line additions and modifications will be
necessary. The task of providing facilities for meeting the 1975
values is a large one.
Long lead times are required to design, erect, and equip modern
mass-production facilities. The design of some manufacturing
equipment has already been detailed and irreversible decisions will
have to be made by mid-1972 if the industry is to be ready for
August 1974, full-scale production. A typical example of the time
schedule for critical equipment construction is shown in Table 5.1.
Compared with normal practice in the automobile industry this is
an accelerated schedule. The most undesirable features of the
schedule are the inadequate time allowed for gaining sufficient
experience with production vehicles in customers' hands and the
very limited time available to correct and adjust production equip-
ment, processes and procedures.
Some of the tooling will be more sophisticated than has been
previously made for the automobile industry. For instance, car-
buretors will have to be inspected and adjusted by advanced mod-
ern electronic techniques before installation. In turn, machined
parts will have to be made on machines capable of correcting any
dimensional errors that might develop.
Most automobile companies purchase many component parts
from vendors. The rapidly fluctuating thinking about design cri-
teria for items such as catalytic converters so retards decision-
making that vendors cannot commence the construction of produc-
tion facilities and assume amortization of their own investment
until firm commitments are made.
It has become apparent that if engines are designed and manu-
factured to close dimensional tolerances, the emission characteris-
tics of the vehicles will be much more consistent. It will be costly
and require much change in management techniques for the auto-
mobile industry to acquire expertise and equipment for adequate
quality control. It will also be difficult to arrange for similar
control of vendors' products, although the techniques of quality
control are well known in other industries and can be acquired.
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GUIDELINES AND REPORTS 2799
Table 5.1—Scheduling and Lead Times for Mass Production
January 1, 1971 Accelerate design of heavy machine tools. Make pre-
liminary designs of emission-control systems. Accelerate
emission testing on vehicles. Make preliminary designs
for most tooling.
July 1, 1971 Approve design for large machines and make layouts for
new factories and major modifications. Select tentative
design for emission-control system.
January 1, 1972 Prepare materials for requesting bids. Start final phase
of obtaining facilities approvals.
April 1, 1972 Finalize design of emission-control system for production.
July 1, 1972 Make contracts for vendor-manufactured items. Make
contracts for equipment. Make contracts for production
tooling. Start accelerated testing program of hand-
made vehicles.
January 1, 1973 Order materials. Finish design of minor tooling and
factory rearrangements. Redesign to meet change re-
quirements.
July 1, 1973 Start production tests from partial tooling. Start certi-
fication runs. Accelerate production plans. Start ex-
tensive field tests of vehicles.
January 1, 1974 Complete component-production facilities and start pro-
duction. Start intensive preparation of equipment for
making pilot production on mass-production equipment.
July 1, 1974 Start production of automobiles. For the entire industry,
this is at a rate of approximately 10 million vehicles
per year.
January 1, 1975 Evaluate field behavior of mass-produced vehicles and
introduce minor modifications.
The emission values are critically associated with configuration
and dimension control. The closer the dimensions approach the
values specified for a particular configuration, the closer the emis-
sion values will be to those required by the Act.
The Committee was sympathetic to all these difficulties. Never-
theless, based on information provided by a Committee Panel and
based on the evaluation of the Committee, it is the opinion of the
Committee that the automobile manufacturers have the experience
and capability to arrange to mass produce the type of hardware
indicated in Section 3 that would be necessary to meet the 1975
standards in sufficient time. However, as was discussed in Section
3, data presented to the Committee (Appendixes F and G) show
that, at present, not even experimental vehicles are available that
can satisfy the complete requirements of the 1975 standards.
Thus, even though the hardware for the 1975 model year vehicle
can be outlined, improvement and optimization of the emission-
control systems will be necessary in order to provide the necessary
reliability and durability to achieve the 1975 requirements in serv-
ice.
Likewise, as a result of panel visits to catalyst manufacturers,
the Committee has been informed that, within one year after
receipt of a firm purchase order, the catalyst manufacturers could
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2800 LEGAL COMPILATION—Ant
install sufficient capacity to supply the projected needs of the
automobile manufacturers, once an acceptable catalyst is devel-
oped or identified. The Committee emphasizes that according to
the data provided to it by both the automobile manufacturers and
the catalyst suppliers, as shown in Appendix G, there has, as yet,
been no demonstration of an adequate oxidation catalyst of suffi-
cient durability to satisfy the 1975 requirements.
6. COSTS OF MEETING 1975 EMISSION REQUIREMENTS
The designs for the emission-control systems for vehicles to
meet the 1975 requirements are now definite enough so that the
initial cost to the customer can be estimated. Estimates of the
range of additional initial costs to the ultimate customer for meet-
ing the 1975 requirements over the 1970 requirements were re-
quested of foreign and domestic automobile manufacturers in
Question 17 of the questionnaire. Replies were based on the as-
sumption that only the average emissions of vehicles need meet
the standards, and that a 100-percent assembly-line test will not
be required; 50,000-mile warranty costs are not included. Several
of the foreign manufacturers indicated that the state of develop-
ment of their 1975 emission-control systems was such that they
could not now give a realistic estimate of additional costs. Of the
seven foreign manufacturers that did reply positively to the ques-
tion, estimates ranged from $200 to $500.
Of the five American manufacturers, two submitted estimates of
about $250 while the others were of the order of $500. The higher
estimates reflected the proposed use of a thermal reactor as well as
a catalyst in the emission-control system.
To provide substantiation of the manufacturing estimates, the
Panel on Manufacturing and Producibility has made an independ-
ent study of these costs. The system used for the Panel estimates
was one that in light of the results of Section 3 of the report,
appeared most promising. The cost effectiveness of the thermal
reactor and associated hardware was so poor that this item was
not included in the system.
Table 6.1 shows, on a year-by-year basis, the items that have
been added to current vehicles for emission-control and also those
that will be added for a promising system for 1973, 1974, and 1975
model year vehicles. In estimating the cost of these items, the
Panel assumed that all vehicles in the certification fleet will per-
form within the 1975 standards for 50,000 miles with no more
than one catalyst change allowable, that automobile manufactur-
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GUIDELINES AND REPORTS 2801
ers will substantially increase their in-house testing and quality
control of major components so that no additional end-of-the-line
rework will be necessary, that a short end-of-the-line test will be
used to identify grossly malfunctioning vehicles with the full
CVS-CH test done only on a small statistical sample by engine
family, and that only the average emissions of customer vehicles
must satisfy the federal standards.
Table 6.1—Typical Pattern of Installation of Automotive Emission Hardware
Model year added Item
1966 PCV valve
1968 fuel-evaporation-control system
1970 (a) retarded ignition timing
(b) decreased compression ratio
(c) change of fuel/air ratio
(d) transmission control system
1972 (a) anti-dieseling solenoid valve
(b) thermostatic air valve
(c) choke-heat by-pass
1973 ' (a) exhaust-gas recirculation
(b) air-injection reactor
(c) induction hardened valve seats
(d) spark-advance control
(e) air pump
1974 l precision cams, bores, and pistons
1975 l (a) proportional exhaust-gas recirculation
(b) carburetor with altitude compensation
(c) advanced air-injection control
(d) air/fuel preheater
(e) electric choke
(f) electronic distributor (pointless)
(g) improved timing control (±1)
(h) catalytic (oxidizing) converter
(i) catalyst pellet charge
(j) cooling-system changes
(k) improved underhood materials
(1) body revisions
1 Hardware listed for 1973,1974, and 1975 model years is for a system deemed by
the Panel to be promising.
For the Panel estimates, the cost of a component was based on
such factors as the typical cost per pound of worked or machined
metal and the actual price charged by parts dealers in California
for similar components already used in California cars. Tooling
and equipment were amortized over three years, dealer margin
was taken as 22 percent of the sticker price, profit as 10 percent of
the list price, and excise tax 5 percent of the sticker price. Excise
tax was included in both the Panel and the manufacturers' esti-
mates. Details of the Panel's estimates are given in Appendix H
and results shown in Table 6.2. The Panel estimate shows an
increase of initial cost of $288 for the 1975 model year projected
system over the 1970 model year system, and an increase of $214
for the 1975 system over the 1973 system.
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2802 LEGAL COMPILATION—AIR
The increased dollar cost of a vehicle to the customer at the time
of purchase is only part of the true cost to the user. According to
the manufacturers' estimates the reduction in fuel economy to
achieve the 1975 values will increase fuel consumption by 3 to 12
percent. The Committee anticipates that the cost of routine main-
tenance may increase by several times present costs depending on
inspection procedures that are prescribed and enforced. There will
be some deterioration in vehicle driveability.
Whether these costs are justified by the benefits to be gained is
outside the scope of this interim report. But it should be noted
that many who have concerned themselves with restoration of the
quality of the environment have indicated that this process must
necessarily be expensive and would probably include the necessity
to forego certain material advantages made possible by a less
regulated industrial technology. The present instance would ap-
pear to be a significant case in point.
TABLE 6.2-SUMMARY OF COST FOR LIKELY EMISSION HARDWARE BASED ON PANEL ESTIMATES
Year Yearly cost Accumulated cost
1966 $3.00 J3.00
1968 15.00 18.00
1970 8.00 26.00
1971-72 14.00 40.00
1973 60.00 100.00
1974 20.60 120.60
1975 193.40 314.00
7. THE CONSEQUENCES OF A ONE-YEAR SUSPENSION OF
1975 STANDARDS
The current state of the art of emission-control technology, as
presented in this report, strongly suggests the likelihood that
some, if not all, of the automobile manufacturers will request that
the Administrator grant a one-year suspension, of the emission
standards applicable to 1975 model year light-duty vehicles. At
this point, it is useful to discuss the possible consequences of the
granting of such a suspension.
At present, not even experimental vehicles have been shown to
satisfy the 1975 emission standards for 50,000 miles. Certainly,
developmental work is still required to further reduce emissions at
low mileage and to provide the required durability. Durability
testing is expensive and time-consuming; three to four months are
required for a 50,000-mile test. Each major change in the basic
system configuration or operating conditions will require new dur-
ability tests on components such as the catalytic converter. Cata-
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GUIDELINES AND REPORTS 2803
lyst technology for automotive emission control is relatively new,
and some of the failure modes now being experienced are not well
understood.
One important advantage of a one-year suspension, therefore, is
that it would allow an additional year's work on development of
the complete emission-control system before major design details
of components must be "frozen" for production. Systems may need
significant modifications before they can achieve both emission
levels close to their low-mileage targets and improved catalyst life.
The basic system configuration must shortly be fixed if the engine
and control system are to be in mass production in 1974. Most
manufacturers do not at this stage have adequate information to
make many of the major engineering decisions that would be
required over the next six months.
Furthermore, uncertainties in the definition of compliance need
to be resolved by EPA before major commitments to production of
the control systems are made. If decisions made on the concept of
averaging emissions and on allowable maintenance during certifi-
cation increase the difficulties of meeting the requirements of the
Act, then further improvements in emission reduction beyond the
best results achieved to date will be required.
As has been explained, many engine modifications are required
in these prototype 1975 vehicles. With such a large number of
modifications, there is considerable question of the overall system
reliability in the hands of customers. Approximately 10,000,000
new vehicles will be purchased in 1975 by customers with a wide
variety of driving habits. Conditions to which an emission-control
system would be exposed by the driving public are more variable
and extreme than those to which it would be exposed during the
emission test. Extensive road testing under the ambient conditions
experienced throughout the United States is essential to give the
manufacturer an understanding of problems and failure modes
that will occur in practice. For the 1975 model year, the time scale
is so short that many new production items will not be adequately
proven. An example of such a critical item is the new carburetor
design many manufacturers intend to use. Normal field testing
and durability testing of production samples of such components
may not be completed before these components are installed on
assembly-line vehicles. Problems may therefore occur in customer
use that did not show up in the limited test period now available.
The public may be buying vehicles whose components are more
likely to malfunction and whose driveability and reliability may
not be satisfactory. A year's suspension would give more nearly
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2804 LEGAL COMPILATION—AIR
adequate time for component durability and system reliability
testing and thus would give the customer added assurance that the
additional expenditure in emission control is indeed effective in
improving air quality.
An essential requirement for effective emission control over ex-
tended mileage for vehicles with catalytic converters is wide avail-
ability of fuel of sufficiently low lead, sulphur, and phosphorus
content. Not only must there be sufficient production of such fuel;
there must also be available pumps, storage tanks, and transfer
equipment that are free of contaminants. A year's delay in the
imposition of the standards would help to ensure the nationwide
availability of such fuel and facilities.
The necessity for adequate maintenance of emission-control sys-
tems has been discussed. Enforced inspection and maintenance
procedures will be required to assure that the owner will pay the
cost involved in adequately maintaining his vehicle's emission-con-
trol system. An extra year would again help the development of
inspection programs and ensure the availability of inspection fa-
cilities in areas in which they will be required.
One of the more important factors that needs to be considered
in the decision of whether or not to grant a suspension is the effect
on total automobile emissions and overall air quality. A simple
way to estimate the effect of the suspension is to calculate the
change in total emissions from all automobiles in the late 1970's
and 1980's if meeting the 1975 standards is delayed for one year.
The ratio of total emissions at some future date to emissions now
will be a measure of the improvement in air quality likely to be
achieved. Figures 7.1 and 7.2 have been prepared for the purpose
of evaluating these effects, and show the results of a one-year
delay in implementing the 1975 emission standards for hydrocar-
bons and carbon monoxide. These curves take into account such
factors as the vehicle-age distribution among all automobiles, the
decrease in vehicle miles driven per year per car as vehicle age
increases, the predicted nationwide growth in vehicle miles driven
each year, the emission reduction achieved through crankcase
blowby and evaporative-loss control, the effect of federal exhaust
emission standards, and deterioration with mileage of emission
controls from 1968 to 1974 model year cars. This deterioration is
estimated from California Air Resources Board field surveillance
data. Deterioration is not allowed for in post-1974 model year
vehicles since no reliable estimate of its magnitude can now be
made. Further details of the calculations are given in Appendix I.
For any given calendar year, the figures show total HC and CO
-------
GUIDELINES AND REPORTS
2805
UNITED STATES
NATIONWIDE HYDROCARBON EMISSIONS
16
14
< 12
uj *•*•
o"
10
CO
I 8
co
CO
UJ
O 6
PRESENT CONTROLS
1975 STANDARDS
ONE YEAR SUSPENSION
PRE 1968
MODEL YEAR
VEHICLES
1960
1970
1980
1990
FIGURE 7.1
-------
2806
LEGAL COMPILATION—Am
8
UNITED STATES
NATIONWIDE CARBON MONOXIDE EMISSIONS
90
80
70
<
£ 60
6 50
30
20
10
°1960
PRESENT CONTROLS
— 1975 STANDARDS
----- ONE YEAR SUSPENSION
MODEL YEAR
VEHICLES
1970
FIGURE 7.2
1980
1990
-------
GUIDELINES AND REPORTS 2807
emissions from (1) pre-1968 uncontrolled vehicles, (2) all vehi-
cles, with the 1975 standards for HC and CO met in 1975 and
subsequent model year vehicles, (3) all vehicles, with 1975 HC and
CO standards met in 1976 and subsequent model year vehicles—a
one-year suspension with the 1973 standard maintained, and (4)
all vehicles with present standards only. It can be seen that the
rate of decrease in emissions until about 1980 depends primarily
on the retirement of pre-1968 uncontrolled vehicles from use.
Thus the effect on total emissions of a one-year suspension with no
additional interim standards appears to be small. The effect is not
more significant because the emission reduction now required of
model year 1974 vehicles, as compared with uncontrolled vehicles
(80 percent for HC and 69 percent for CO), is already so substan-
tial.
8. CONCLUDING STATEMENT
The Clean Air Amendments of 1970 have had the effect of
accelerating progress by automobile manufacturers in emission
control. Experimental vehicles have been built and operated that,
at low mileage, exhibit levels of emissions less than those specified
for 1975 model year vehicles. However, information establishing
the sustained effectiveness, durability, and reliability of prototype
1975 vehicle systems during typical consumer mileage accumula-
tion is not available. The Committee finds that the technology
necessary to meet the requirements of the Clean Air Amendments
for 1975 model year light-duty motor vehicles is not available at
this time.
While there is no certainty today that any 1975 model year
vehicles will meet the requirements of the Act, the status of devel-
opment and rate of progress make it possible that the larger
manufacturers will be able to produce vehicles that will qualify,
provided that provisions are made for catalyst replacement and
other maintenance, for averaging emissions of production vehicles,
and for the general availability of fuel containing suitably low
levels of catalyst poisons. Conversely, if the above provisions are
not deemed acceptable by EPA, it appears most unlikely that any
manufacturer will be able to meet the requirements of the Act.
The Committee believes that the emission levels required in the
Clean Air Amendments will not be achieved in service, in any
event, unless regular, periodic maintenance of the emission-control
system is required of the owner.
The estimated costs to the consumer of meeting the require-
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2808 LEGAL COMPILATION—AIR
ments of the Act for 1975 vehicles, in comparison with those for
1973 vehicles, include an increase in sticker price of about $200, 3
to 12 percent increase in fuel consumption, an increase in mainte-
nance cost, and a deterioration in driveability of the car.
If enforcement of the requirements of the Act for 1975 vehicles
were deferred for one year, the opportunity thus provided for
further development and field testing would enable manufacturers
to significantly improve the performance and reliability of vehicles
equipped to meet the requirements in the hands of the customer.
The Committee finds that the technology necessary to meet 1976
standards in 1976 model year cars is not currently available. The
technology of catalysts suitable for NOX reduction is not nearly as
advanced as that of oxidation catalysts. The level of current re-
search and development on reduction catalysts for NOX control is
not commensurate with the importance of this problem.
9. FUTURE PLANS
The results of the investigations of the Committee to date indi-
cate several areas in which work should be continued or intensified
and several areas in which studies should be initiated.
The Committee will study in depth the technological feasibility
of meeting the standards of the Clean Air Amendments applicable
to emissions of oxides of nitrogen from light-duty vehicles manu-
factured during or after model year 1976. Investigation of the
technological feasibility of meeting the standards applicable to
1975 model year vehicles will continue, with monitoring of new
developments in this regard.
As emission systems are designed and put into production, the
problems of inspection and maintenance will continue to be of
interest to the Committee.
Extensive investigations will be initiated into the state of tech-
nology of alternate power systems and the potential they offer for
emissions reductions over that of conventional engines. This study
will consider cost, producibility, and maintainability of such alter-
nate power sources.
Finally, an extensive study will be made of the consequences to
the nation of achieving or failing to achieve the emissions stand-
ards of the 1970 Clean Air Amendments. This study will assist the
Committee as it attempts to determine suitable interim emission
levels as called for in the Work Statement of the Committee.
526-705 O - 74 - 30
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GUIDELINES AND REPORTS 2809
APPENDIX A
Committee on Motor Vehicle Emissions
E. L. Ginzton, chairman, Varian Associates, chairman.
J. A. Hutcheson, Vice President, Westinghouse Electric Corp. (retired), vice
chairman.
Sidney W. Benson, Chairman Department of Thermochemistry and Kinetics,
Stanford Research Institute.
Robert W. Cairns, Deputy Assistant Secretary for Science and Technology,
U.S. Department of Commerce.
Charles H. Elmendorf III, Assistant Vice President, American Telephone and
Telegraph Co.
James A. Fay, Professor of Mechanical Engineering, Department of Mechani-
cal Engineering, Massachusetts Institute of Technology.
Richard L. Garwin, IBM Fellow, Thomas J. Watson Research Center.
Irvin Classman, Professor of Aerospace and Mechanical Sciences, Department
of Aerospace and Mechanical Sciences, Princeton University.
A. J. Haagen-Smit, Professor of Biochemistry, Division of Biology, California
Institute of Technology.
Harold S. Johnston, Professor of Chemistry, Department of Chemistry, Univ-
ersity of California.
Arthur R. Kantrowitz, Director, AVCO-Everett Research Laboratory.
J. Ross Macdonald, Vice President of Corporate Research and Engineering,
Texas Instruments Inc.
M. Eugene Merchant, Director of Research Planning, Cincinnati Milacron,
Inc.
Glenn C. Williams, Professor of Chemical Engineering, Department of Chemi-
cal Engineering, Massachusetts Institute of Technology.
James E. A. John, Executive Director, Committee on Motor Vehicle Emis-
sions, National Research Council.
John E. Nolan, Assistant Executive Director, Committee on Motor Vehicle
Emissions, National Research Council.
Miss E. Gaspard-Michel, Administrative Assistant to the Chairman, Commit-
tee on Motor Vehicle Emissions, National Research Council.
Richard Barber, Legal Counsel, Committee on Motor Vehicle Emissions, Na-
tional Research Council.
APPENDIX B
Statement of Work
The Contractor shall conduct a many-faceted study of the technological
feasibility of meeting the motor vehicle emission standards prescribed by the
Administrator of the Environmental Protection Agency, as required by Sec-
tion 202 (b) of the Clean Air Act, as amended.
For the purposes of this study the term "technological feasibility" includes
the ability within the automobile industry or elsewhere to:
1. Design an engine, control system or device capable of meeting the
statutory emission standards using fuels which are or could be available.
2. Mass produce such an engine, control system or device.
3. Maintain such an engine, control system or device so that it will
continue to meet the statutory emission standards with safety for a
period of five years or 50,000 miles of operation, whichever is shorter.
-------
2810 LEGAL COMPILATION—Am
The study of technological feasibility as defined shall include a study em-
phasizing the technical aspects of the reported costs expected to be incurred in
and the estimated time for the design, development and mass production of an
engine, control system or device capable of meeting the statutory emission
standards.
The study of technological feasibility shall include a study emphasizing the
technical aspects of the reported estimates of extra cost incurred in maintain-
ing such an engine, control system or device so that it will meet the statutory
emission standards for a period of five years or 50,000 miles, whichever is
shorter.
Should the Contractor conclude that the attainment of emission standards
on the schedule provided by Section 202(b)(l) of the Clean Air Act is not
technologically feasible, the Contractor shall specifically determine technologi-
cally feasible interim emission levels to assist the Administrator in exercising
his responsibilities under Section 202(b) (5) of the Act.
APPENDIX C
Panels of Consultants
Emission Standards
Arthur C. Stern, Environmental Science and Engineering, School of Public
Health, University of North Carolina, Panel Chairman.
Leslie A. Chambers, School of Public Health, University of Texas at Houston.
James Fitzpatrick, Environmental Analysts, Inc.
John A. Maga, Air Resources Board, State of California.
Testing, Inspection and Maintenance of Vehicles
John N. Pattison, Civil Engineering Department, University of Cincinnati,
Panel Chairman.
Marian Chew, Chagrin Falls, Ohio.
G. C. Hass, Air Resources Board, State of California.
William Scott, Scott Research Laboratories.
Emission Control Systems (for spark ignition internal combustion engines)
John B. Heywood, Department of Mechanical Engineering, Massachusetts
Institute of Technology, Panel Chairman.
J, A. Bolt, Department of Mechanical Engineering, University of Michigan.
Ernest Jost, Materials and Electronic Controls Group, Texas Instruments,
Inc.
Henry K. Newhall, Department of Mechanical Engineering, University of
Wisconsin.
William A. Sirignano, Guggenheim Laboratories, Department of Aerospace
and Mechanical Sciences, Princeton University.
Henry Wise, Stanford Research Institute.
David Wulfhorst, Cummins Engine Co., Inc.
Alternate Power Sources
John Bjerklie, Consulting Engineer Thermal Systems, Mechanical Technology,
Inc., Panel Chairman.
Henry Korp, Engines, Fuels and Lubricants Division, Southwest Research
Institute.
Charles Tobias, Department of Chemical Engineering, University of Califor-
nia.
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GUIDELINES AND REPORTS 2811
David G. Wilson, Department of Mechanical Engineering, Massachusetts In-
stitute of Technology.
Clarence Zener, University Professor, Carnegie-Mellon University.
Driveability
King D. Bird, Vehicle Research Department, Cornell Aeronautical Labs.
Leonard Segel, Highway Safety Research Institute, University of Michigan.
Manufacturing and Producibility
Maurice Nelles, La Jolla, Calif., Panel Chairman.
Donald Bartlett, A. T. Kearney & Co., Inc.
George D. Clayton, George D. Clayton and Associates.
Merrill L. Ebner, College of Engineering, Boston University.
Leroy H. Lindgren, Rath and Strong, Inc.
Atmospheric Chemistry
Edward Stephens, Statewide Air Pollution Research Center, University of
California.
Lowell Wayne, Los Angeles, Calif.
APPENDIX D
List of Questions Sent to Foreign and Domestic Automobile Manufacturers;
Recipients of Questionnaire and List of Attendees at CMVE meeting on
October 25-27,1971.
1. Do you expect to meet the federal and California emission standards with
1975 model year vehicles? Explain any factors which qualify your
answers.
2. What emission controls, and engine modifications which reduce emissions,
do you expect to be using in your 1975 model year automobiles?
3. What are the best emissions results you have obtained with these control
systems to date? Explain any factors you feel qualify these emissions
measurements and their relation to the emission standards.
4. What are your engineering emissions goals for 1975 model experimental
vehicles so that the production vehicles will meet the requirements of
the 1970 Clean Air Act Amendments?
Explain how possible requirements that
(a) assembly line vehicles pass a short emissions test,
(b) a certain fraction of assembly line vehicles pass the full fed-
eral emissions test,
(c) a certain fraction of vehicles in customer use pass the full
federal emissions test,
affect these engineering emission goals and hence affect your ability to
meet the 1975 emissions standards.
5. What major development problems do you have to solve before you can
meet these experimental vehicle emission goals?
6. At what date do you expect to meet these experimental vehicle emission
goals?
7. What changes in vehicle performance, driving characteristics, and fuel
consumption do you anticipate with these systems in your 1975 model
year production vehicles?
8. If you do not expect to meet the 1975 Federal Emission Standards with
1975 model year vehicles, what emission levels do you anticipate achiev-
ing with production vehicles?
-------
2812 LEGAL COMPILATION—Am
9. Do your 1975 model year emission control systems have the potential with
further development of meeting the 1976 emission standards? If not,
what emissions reduction from 1975 levels do you anticipate achieving?
10. What is the degree of statistical reproducibility of the test procedure
results as applied to your 1975-type cars? Explain.
(a) What combination of maintenance and inspection will be re-
quired for your 1975 vehicles in order to meet federal require-
ments for 1975 used vehicles? What inspection systems will be
needed, if any?
(b) What do you expect the average annual maintenance and
inspection costs will be? If there are compensating savings in
fuel or other costs, show these. Explain your reply.
11. Have you the capability of producing automobiles to meet the federal
1975 model requirements? If not how must your capabilities be aug-
mented?
12. Are you executing plans to acquire capabilities and items from others to
enable you to produce vehicles to meet the 1975 requirements? What
are the major items you must acquire, including machinery?
13. What is the maximum decrease in HC, CO and NO* exhaust content you
could achieve with the use of your normal production capabilities dur-
ing the next three years? Base decrease on 1960 emissions.
14. Provide PERT, GANTT or similar charts indicating plans for meeting
the 1975 emission standards. The end point may be the time you have
chosen to meet the 1975 standards. Events and times should be labeled.
15. What advantage would there be to you if the date 1975 standards would
be effective were delayed one year?
16. Approximately, what will the extra cost be to prepare to produce medium
weight vehicles to meet the 1975 standards? What are the chief items
of cost?
17. What will the range of additional costs to the ultimate customer be for
meeting- the 1975 requirements over the 1970 requirements, if you find
it necessary to meet the requirement for the 1975 model? For the 1976
model?
18. Construct the following curves using your best available data and judg-
ment.
(a) Cost to customer $ vs % of CO eliminated (based on 1960
emissions including crank case and evaporation).
(b) Cost to customer $ vs % of HC eliminated (based on 1960
emissions including crank case and evaporation).
(c) Cost to customer $ vs % of NO* eliminated (based on 1960
emissions including crank case and evaporation).
(d) Cost to customer $ vs equal % of HC and NO* eliminated
(based on 1960 emissions including crank case and evapora-
tion).
(e) Cost to customer $ vs equal % of HC, CO, Nd eliminated
(based on 1970 emissions).
(f) Any other similar type curve which will show the cost to the
customer for various amounts of pollution eliminated.
19. Will warranty costs be increased to cover the guarantees required by the
Amendment? If increased, how much?
20. Do you expect to meet the Federal Emission Standards for 1976 model
year vehicles? Explain any factors which qualify your answer.
-------
GUIDELINES AND REPORTS 2813
21. What additional or alternative control systems are you investigating for
spark-ignition engines to meet the 1976 model year emission standards
which promise greater NO* emission control ?
22. What are the best emissions results you have obtained with the different
systems you are developing to meet the 1976 emission standards? List
any factors you feel qualify these emission measurements and their
relation to the emission standards.
23. What are the major development problems to be solved for each of these
systems before you meet your 1976 emission goals with these different
approaches?
24. How much time do you anticipate you will require to resolve these devel-
opment problems for the 1976 Federal Emission Standards?
25. What changes in vehicle performance penalties, driving characteristics,
and fuel consumption do you anticipate for the different 1976 emission
control approaches you are considering?
26. If you do not expect to meet the 1976 emission standards for 1976 model
year vehicles, what emission levels do you anticipate achieving with
production vehicles?
27. (a) Do you anticipate using the Wankel rotating combustion engine in
any of your 1975 or 1976 production vehicles?
(b) If you are evaluating Wankel engines for possible future production,
what are the best emissions results you have achieved to date, and
with what additional emissions controls?
(c) Do you feel the Wankel engine has any special emissions advantages
for achieving emissions levels that would satisfy the 1975 or 1976
emission standards?
(d) What is the magnitude of your research and development effort to
reduce emissions from Wankel engine?
28. (a) Do you anticipate using the stratified charge engine in any of your
1976 production vehicles?
(b) Do you feel the stratified charge engine (open chamber type, or
divided or precombustion chamber type) has any special advantages
for achieving emissions levels that would satisfy the 1975 or 1976
emission standards?
(c) What is your estimate of the potential for emissions reduction with
the stratified charge engine when used with other emission controls?
(d) What are the major development problems to be overcome with the
stratified charge engine?
(e) What is the magnitude of your research and development effort on
stratified charge engines?
(f) What is your estimate of the earliest date at which the stratified
charge engine could be used in a substantial fraction of your produc-
tion vehicles?
29. (a) Do you feel that the gas turbine is a promising automotive power
plant? List its advantages and disadvantages in relation to current
engines.
(b) What is your estimate of the low emissions potential of the automo-
tive gas turbine?
(c) What are the major development problems to be overcome before the
automotive gas turbine is a viable mass production engine?
(d) What is the magnitude of your research and development effort on
automotive gas turbines?
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2814 LEGAL COMPILATION—AIR
(e) What is your estimate of the earliest date at which the gas turbine
could be used in a substantial fraction of your production automo-
biles?
30. Which of all the emission control approaches you have investigated (or
other approaches) is most attractive with respect to vehicle perform-
ance, fuel economy, and cost, and which with further development has
the potential of meeting the 1976 emission standards with production
vehicles at some time during the period 1977-1982?
31. If this approach is different from your basic 1975 or 1976 model year
control systems, what major development problems have to be overcome
to make these alternative approaches attractive for production vehicles,
and what is your estimate of the time and effort which would be
required?
Recipients of Questionnaire
Domestic Manufacturers
American Motors, 14250 Plymouth Rd., Detroit, Mich., Attn: John F. Adam-
son, Vice President—Engineering and Research.
Chrysler Corp., Materials Engineering, Engineering and Research Office,
12800 Oakland Ave., Detroit, Mich. Attn: Charles M. Heinen, Executive
Engineer.
Ford Motor Co., Automotive Emissions Office Engineering Staff, The Ameri-
can Road, Dearborn, Mich. Attn: Donald A. Jensen, Director.
General Motors Corp., General Motors Technical Center, Warren, Mich. Attn:
Ernest S. Starkman, Vice President, Environmental Activities Staff.
International Harvester Co., Motor Truck Engineering Department, P.O. Box
1109, Fort Wayne, Ind. Attn: Mark Sherbinski, Staff Engineer, Vehicle
Emission.
Jeep Corp., 940 North Cove Blvd., Toledo, Ohio. Attn: Frederick A. Stewart,
Vice President, Engineering.
U.S. Army Tank-Automotive Command, Headquarters, Warren, Mich. Attn:
Ernest Petrick, Chief Scientist.
White Motor Corp., Advanced Products Division, 3201 Lomita Blvd., Torrance,
Calif. Attn: John McLean.
Foreign Manufacturers
Alfa Romeo - S.p.A., Via Gattanelata 45, 20149 Milano, Italy. Attn: O. Satta,
General Manager.
Alfa Romeo, 215 Douglas Street, El Segundo, Calif. Attn: Michael Pokorny,
Service Manager.
Audi, NSU Motorenwerke, General Series Design and Development, Aktien-
gesselschaft, 7107 Neckarsulm, Germany. Attn: P. A. Praxl.
Bayerische Motoren Werke A.G., 8 Munchen 13, Lerchenauer Str. 76, W.
Germany. Attn: W. Stork.
British Leyland Motors, Inc., 600 Willow Tree Rd., Leonia, N.J. Attn: G. W.
Gardner.
Daimler-Benz A.G., Stuttgart-Underturkheim, Germany. Attn: The President.
Mercedes Benz, 815 Connecticut Avenue, N.W., Washington, D.C. Attn: Jerry
Sanosky.
FIAT S.p.A., 375 Park Ave., New York, N.Y. Attn: Alberto Negro, Liaison
Engineer, Technical Development.
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GUIDELINES AND REPORTS 2815
FIAT S.p.A., Strada del Drosso 145, 10135 Torino, Italy. Attn: Carlo Pollone,
Direzione ricerca.
Fuji Heavy Industries Ltd., Sabaru Building, 7-2, 1-chone, nishishinjuku,
Tokyo, Japan. Attn: Nobuko Sakata, Managing Director.
Mitsubishi Company, 33-8, 5-Chome, Siba, Minato-Ku, Tokyo, Japan. Attn:
Yuji Satoh, President.
Mitsubishi International Corporation, 606 South Hill Street, Los Angeles,
California Attn: K. Hirota, Machinery Division.
Mitsubishi Motors, Trowell Bldg., Suite 410, 24681 Northwestern Highway,
Southfield, Mich. Attn: Yasuta Kiso, General Manager, Detroit Liaison
Office.
Mitsubishi Motors Corporation, 1 Tatsumi-Cho, Uzumasa, Ukyo-ku, Kyoto,
Japan Attn: Yasuo Kaneko, Chief of Research Section.
Nissan Motor Company, Ltd., 6-1, Daikokucho, Tsurumi-Ku, Yokohama, Japan
Attn: Hiroshi Takahashi, Director and Manager, Design Department.
Nissan Motor Corporation in U.S.A., 137 East Alondra Boulevard, Gardena,
Calif. Attn: Noboru Hayakawa, Factory Representative.
Nissan Motor Corporation of the U.S.A., 400 County Ave., Secaucus, N.J.,
Attn: Tadaaki Yukawa, Chief Representative.
Peugeot, Inc., 300 Kuller Road, Clifton, N.J., Attn: Michael Rossman, Engi-
neering Advisor.
Porsche Audi, 600 Sylvan Avenue, Englewood Cliffs, N.J. Attn: Normann
Roethlein, Product Planning Department.
Renault, Inc., 100 Sylvan Avenue, Englewood Cliffs, N.J. Attn: Francois
Louis, National Manager, Service and Parts Division.
Regie Nationale des Usines Renault, 10, Avenue Emile Zola, 92 Billancourt,
France Attn: Pierre Vernay, Engineer, Research for Export Department.
SAAB U.S.A., Inc., 100 Waterfront Street, New Haven, Conn. Attn: Don
Tayler, President.
SAAB-Scania Automotive Group, S-461 01, Trollhattan, Sweden Attn: Hen-
rik Gustavsson, Technical Director.
Toyo Kogyo Company, Ltd., 6047 Suchu-Machi, Aki-gun, Hiroshima, Japan
Attn: Eisuke Niguma, Manager, Export Vehicle Engineering Department.
Toyota Motor Company, Ltd., 1 Toyota-Cho, Toyota-Shi, Aichi-Ken, Japan.
Attn; Masaaki Noguchi, Executive Managing Director.
Toyota Motor Sales U.S.A., Inc., 2055 W. 190th Street, P. O. Box 2991,
Torrance, Calif. Attn: Dan N. Koda, Manager, Technical Services.
VW of America, Inc., Product Development Engineering, Englewood Cliffs,
N.J. Attn: Bernard R. Patok.
VW of America, Inc., 818 Sylvan Avenue, Englewood Cliffs, N.J. Attn: G.
Stobeck, Product Planning Manager.
AB Volvo, Car Engine Department, S-405 08, Gothenberg, Sweden. Attn: G.
Zackrisson, Chief Engineer.
Volvo, Inc., Rockleigh, N.J. Attn: Charles J. Simerlein, Special Assistant,
Federal Regulations.
Responses were received from all recipients of questionnaires.
Attendees at CMVE Meeting, October 25-27,1971
October S3
1:00 - 2:30 — General Motors Corp., F. W. Bowditch, Director of Automotive
-------
2816 LEGAL COMPILATION—AIR
Emissions Control; W. C. Chapman, International Government Relations
Staff; David Milne, Manufacturing Development Staff; J. C. Salrin, Finan-
cial Staff; and Ernest S. Starkman, Vice President.
2:30 - 4:00—Toyota Motor Co., Ltd., Keitaro Nakajima, Director, General
Manager, Factory Representative Office; Kuniyasu Onoda, Staff Engineer,
Factory Representative Office; and Hidemasa Takagi, Staff Engineer, Fac-
tory Representative Office.
8:00 -9:00—Renault, Inc., Francois Louis, Manager.
October 26
9:00 - 10:30—International Harvester Co., Rodger Ringham, Vice President
of Engineering; and Mark Sherbinsky, Staff Engineer, Vehicle Emissions.
10:30 - 12:00—Chrysler Corp., Charles M. Heinen, Executive Engineer, Mate-
rials Engineering; George Lacy, Chief, Emissions Control; and S. L. Terry,
Vice President for Environmental and Safety Relations.
1:00 - 2:30—American Motors, John F. Adamson, Vice President, Engineer-
ing and Research; Carl E. Burke, Assistant Chief Engineer of Advanced
Engineering and Research; Albert R. Ebi, Executive Director, Product
Planning; Daniel L. Hittler, Manager, Development Department, Engineer-
ing and Research; and Robert A. Petersen, Chief Engineer of Advanced
Engineering and Research.
2:30 - 4:00—U. S. Army Tank-Automotive Command, Wayne Anderson,
Chief, Propulsion Systems Division; Bruce Hildebrand, Chief, Environmen-
tal Control Office, U. S. Army Materiel Command; and Ernest Petrick,
Chief Scientist.
4:00 - 5:30—Nissan Motor Co., Ltd., L. Raymond, Engineering Consultant; Y.
Tamuchi, Engineering Representative; T. Tanuma, Senior Engineer; and T.
Yukawa, Chief Representative.
8:00 - 9:00—Mitsubishi Motors Corp., Y. Kiso, General Manager, Detroit
Liaison Office; Hachiro Ursumi, Project Manager, Emissions Control Sys-
tems; and K. Wada, Engineer.
October 27
9:00 - 10:30—Volkswagen, Karl H. Neumann, Staff Engineer, Emissions
Control, Volkswagenwerke, A. G.; Gerhard Reichel, Attorney, Legal Depart-
ment; and Hans Weisbarth, Technical Development Liaison Engineer, Volk-
swagen of America, Inc.
10:30 - 12:00—Ford Motor Co., G. C. Gagliardi, Principal, Research Engi-
neering, Product Division Group; D. A. Jensen, Director, Automotive Emis-
sions Office; J. M. MacNee, Office of the General Counsel; Herbert L. Misch,
Vice President, Engineering and Manufacturing; H. A. Poling, Comptroller,
Product Development; R. Ronzi, Emission Planning Association; and R. E.
Taylor, Chief Engineer, Engineering and Foundry Division.
1:00 - 2:30—Volvo, Inc., Douglas Jarman, Vice President, National Sales,
U.S.; and Magnus Straakander, Engine Division.
APPENDIX E
Letter Requesting Information from Public
The Clean Air Act Amendments of 1970 (PL 91-604) call for the National
Academy of Sciences to conduct "a comprehensive study and investigation of
the technological feasibility of meeting" the auto-emission standard prescribed
by the law. These standards, in general, are designed to achieve a reduction
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GUIDELINES AND REPORTS 2817
compared with 1970 of 90 percent by 1975 in automobile emissions of carbon
monoxide and hydrocarbons and by 1976 in oxides of nitrogen.
In its study the Academy is concerned solely with the "technological feasi-
bility" of meeting these standards by the specified model years. Intensive
scientific and engineering work is being conducted by a special Academy
committee. The most immediate concern of the committee is with the 1975
standards for carbon monoxide and hydrocarbons, since in these respects the
automobile manufacturers are entitled by law to seek a suspension in the
effective date of one year on or after January 1, 1972, from the Environmen-
tal Protection Agency. In acting on such a request the Administrator is
obligated to consider the Academy's findings with respect to technological
feasibility.
In order to assist it in its work and to elicit as wide as possible a range of
technical opinion, the committee invites organizations and others possessing
technical competence to submit in writing any materials or information di-
rectly relevant to the "technological feasibility" of meeting the 1975 Clean Air
Act Auto Emissions Standards. It should be emphasized that the following
matters are beyond the scope of the NAS present undertaking: (1) public
health consequences of air pollution, (2) emissions other than carbon monox-
ide and hydrocarbons and, (3) new power sources which cannot be mass
produced by 1975.
All materials submitted in response to this invitation must be received by
the Academy not later than October 20,1971.
Submissions should be addressed to—National Academy of Sciences, Com-
mittee on Motor Vehicle Emissions, Attn: Public Comments, Washington,
D. C. 20418.
APPENDIX F-EMISSIONS AT LOW MILEAGE FROM EACH AUTOMOBILE MANUFACTURER'S BEST VEHICLE'
Emissions, grams/mile«
Manufacturer
HC CO NOx
United States:
A
B
C
D
E
Foreign":
F
G
H
1
J
K
L
M
N
0 . .
P
Q
R
0.21
0.15
0.13
0.31
0.24
0.11
0.3
0.26
0.4
0.25
0.26
0.6
0.62
0.2
0 63
0.3
0.1
0.3
3.5
2.4
1.9
2.3
3.7
3.7
3.0
3.1
4.7
3.0
2.4
3.5
5.7
4.4
5.8
3.1
2.5
3.2
1.2
2.1
1.3
1.7
4.5
2.2
0.6
1.1
2.1
2.5
1.0
2.3
2.2
1.9
1.0
1.5
1 Data obtained from visits of Emission Control Systems Panel to manufacturers and manufacturers' responses to
Committee questionnaire dated September 27,1971.
: As of October 15,1971. Usually average of several tests. 1975 CVS-CH test procedure used except for manufacturers
A, D, N, 0, R, which employed the 1972 CVS-C test procedure.
' Some of these results are with research systems at very low mileage which do not have mass production potential
in their current form.
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2818
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GUIDELINES AND REPORTS
2819
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2820
LEGAL COMPILATION—Ant
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GUIDELINES AND REPORTS
2821
APPENDIX I
Data Used to Calculate Emissions from Light Duty Motor Vehicles
Tables II to 14 summarize the data used to calculate emissions as a function of
calendar year for Figures 7.1 and 7.2.
Table 1-1—Percent of Annual Vehicle Miles Traveled by Different Age Groups
Vehicle Age (years)
9
10
11
12
13
14. I...
more than 14
Source: United States Department of Commerce.
Percent of total
annual vehicle
miles
15.73
13.64
12.02
10.07
9.35
8.18
7.5
6.6
5.3
4.3
2.8
1.7
0.8
0.4
1.6
TABLE I-2.-ASSUMED NEW CAR EMISSIONS AS FUNCTION OF MODEL YEAR
Emissions, grams/mile >
Model year
pre-1963
1963-1967
1968-1969
1970-1971
1972-1974
1975-1990
Exhaust
17
17
7.0
4.6
3.4
0.45
Hydrocarbons
Blowby
4.08
0.82
0
0
0
0
Garb
Evaporation
2.77
2.77
2.77
2.77
0.14
0.14
on monoxide
125
125
71
47
39
4.7
i Corresponds to CVS-C (1972) test procedure.
Source for conversion factors: Environmental Protection Agency.
Since test procedure corresponds to summer, annual emissions are obtained by multiplying g/mile values in above
table by 1.12 (urban) and 1.0 (rural) for HC, and by 1.085 (urban) and 0.92 (rural) for CO.
TABLE I-3.-EXAMPLES OF AVERAGE VEHICLE EMISSIONS DETERIORATION FACTORS
Deterioration factor >
Vehicle age (years)
HC
CO
1
5
10
15
1.063
1.252
1.296
1.302
1.055
1.195
1.201
1.203
1 Based on California Air Resources Board field surveillance data. Deterioration above the standards in 1975 and later
model year vehicles is not allowed for.
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2822 LEGAL COMPILATION—Am
TABLE 1-4.—ANNUAL TOTAL LIGHT-DUTY VEHICLE-MILES OF TRAVEL IN UNITED STATES
Percent
1963
1970
1980
1990
655.5
898.5
1,208.0
1,437.0
Urban
0.50
0.53
0.57
0.61
Rural
0.50
0.47
0.43
0.39
1 To allow for higher average speed in rural driving, emissions in grams/rural mile are values given in Table G-2
multiplied by 0.552 for HC and 0.466 for CO.
Source: United States Department of Transportation.
4.4 INTERAGENCY AGREEMENTS
4.4a Interagency Agreement Between Environmental Protection
Agency and Department of Transportation National Highway
Traffic Safety Administration
INTERAGENCY AGREEMENT
BETWEEN
ENVIRONMENTAL PROTECTION AGENCY
AND
DEPARTMENT OF TRANSPORTATION
NATIONAL HIGHWAY TRAFFIC
SAFETY ADMINISTRATION
Purpose
The Federal Clean Car Incentive Program (FCCIP) is intended
to stimulate the development by private researchers of light-duty
motor vehicles which meet the 1976 Federal emission standards.
It is also intended that these vehicles comply with Federal Motor
Vehicle Safety Standards (FMVSS), and simultaneously demon-
strate acceptable performance, reliability, and resources utiliza-
tion.
Low-emission vehicles entered in the FCCIP are, generally,
mass produced conventional vehicles which have been modified
with respect to the propulsion system. It is intended that vehicle
modifications not affect the ability of the vehicles to meet FMVSS,
and that the vehicles not be degraded with respect to safety and
safety-related aspects such as vehicle handling. To ensure these
requirements, it is necessary to demonstrate safety adequacy by
means of analysis and/or testing the complete vehicle as well
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GUIDELINES AND REPORTS 2823
as the advanced propulsion system unique to each FCCIP con-
tractor.
The purpose of this agreement is to implement the required
vehicle analysis and testing by utilizing the vehicle safety capabili-
ties of the Department of Transportation, National Highway
Traffic Safety Administration (NHTSA).
Requirements
1. The NHTSA shall develop FCCIP vehicle safety require-
ments including the following:
a. Review, and as appropriate, recommend changes to vehicle
test plans to ensure their capability of providing adequate
safety data for each vehicle.
b. Review, and as appropriate, recommend changes to vehicle
safety analysis guidelines.
2. The NHTSA shall evaluate contracts which are established
between the EPA and NHTSA specified organizations that are
providing vehicle safety evaluation services on prototype (Phase
I) vehicles. These evaluation services may include limited test-
ing for the purpose of verifying the adequacy of the vehicle
contractor's design and safety analysis.
3. The NHTSA shall evaluate contracts which are established
between the EPA and NHTSA specified organizations that are
providing vehicle safety evaluation services on demonstration
(Phase II) vehicles. These evaluation services will include a
determination of the safety adequacy of design changes from
prototype vehicles, and will establish appropriate testing re-
quirements for the purpose of verifying the safety adequacy of
Phase II vehicles.
4. The NHTSA shall evaluate contracts which are established
between the EPA and NHTSA specified organizations that are
providing vehicle safety evaluation services on fleet (Phase III)
vehicles. These evaluation services will include a determina-
tion of the safety adequacy of design changes from demon-
stration vehicles, and will establish appropriate testing require-
ments for the purpose of verifying the safety adequacy of Phase
III vehicles.
Statutory Authority
This agreement is established under the authority of the Clean
Air Act, Section 102, subsection (b), and the Economy Act of
1932, as amended (31 USC 686).
Project Officers
The Project Officer for this program of the Environmental
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2824 LEGAL COMPILATION—Am
Protection Agency is Mr. Graham Hagey, Chief, Special Vehicle
Programs Branch, at (313) 761-5230, in Ann Arbor, Michigan.
The Project Officer for this program of the National Highway
Traffic Safety Administration is Mr. Roger B. Compton, Director,
Engineering Systems Staff, (202) 426-1767, in Washington, D. C.
Date, June 22, 1972
WILLIAM D. RUCKELSHAUS
Administrator, Environmental Protection Agency
Date, July 21, 1972
JOHN A. VOLPE
Secretary, Department of Transportation
•*•£ DUE
U.S. GOVERNMENT PRINT ING OFFICE 1974 o -
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