THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                  Statutes and Legislative History
                                 Executive Orders
                                      Regulations
                          Guidelines  and Reports
                               I
                                              \
                                               ID

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THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                   Statutes and Legislative History
                                  Executive Orders
                                       Regulations
                           Guidelines and Reports
                                                \
                                                 Ul
                                                i
                                      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
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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

                                                                       Page
                  (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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xiv                             CONTENTS

                                                                       Page
                  (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-

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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

-------
              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

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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.

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             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]

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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

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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

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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-

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                      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-

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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.

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                      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

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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

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                      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.

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                      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

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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

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                      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

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                                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)

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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."

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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

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                     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

-------
                   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.

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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)

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                   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.

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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
3
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[1967 baseline]
UU
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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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Office of Secretary of Health, Education,
> Based on one control system per
                                 [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
LEGAL COMPILATION—Am








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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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|It f~
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                                                   [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-
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TABLE 4-1.-S
Control costs
(millions of dollars)



Quantity of emissions :
(thousands of tons per year)


•

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Investment Annua 1

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Solid waste disposal 	 1967 	
Fiscal yea
Fiscal yea
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Fiscal yea
Fiscal yea
Industrial processes 	 1967 	
Fiscal yea
Fiscal yea
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' Metropolitan areas are defined in Appendix 1.
1 Emission abbreviations are: particulates (Part
applicable regulation (Appendix II) or that emission
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
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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
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f


^
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f dollars per yea
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(millions of units per year) (millions of units per year
nit of measurement
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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
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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

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                                            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
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(Thousand
SOx C(
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< 5
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-------
2454
LEGAL COMPILATION—ADR
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' 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|
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= ^ g M £
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Brick and title (brick equivale
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-------
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]

-------
                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.

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                 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.

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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

-------
                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

-------
              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]

-------
                 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-

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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-

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              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

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                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-

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                 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

-------
                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-

-------
                 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-

-------
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

-------
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

-------
                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

-------
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

-------
              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

-------
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

-------
                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

-------
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.

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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.

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             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.

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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

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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

-------
              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

-------
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]

-------
                 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-

-------
                 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

-------
                    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.

-------
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]

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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.

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                    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

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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]

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                    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]

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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]

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               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]

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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

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                   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.

-------
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

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                   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.

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                   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.

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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.

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                   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.

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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

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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,

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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

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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

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                   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:

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                  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.

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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

cr

u
Od
LJ
Q_
i__
r^
C/3
O
o


bUU
500

400

300

200

100
o
ECONOMY AND PERFORMANCE J^"'
— £y
<*/,
_ g'
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

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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.

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                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.

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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

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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-

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                   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.

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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

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                  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

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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-

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                         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

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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

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                  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-

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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.

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                  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.

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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

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                   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

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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

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                  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

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                  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.

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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

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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-

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                  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

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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

-------
                   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

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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

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                   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.

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                   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.

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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

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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

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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

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                   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.

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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.

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                  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.

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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

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                   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-

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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.

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                   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

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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

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                   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

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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

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                  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.

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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.)

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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

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                   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,

-------
                   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

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                   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

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                  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

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                  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

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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.

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                  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.

-------
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LEGAL COMPILATION—Ant
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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-

-------
                   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-

-------
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).

-------
                  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).

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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-

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                  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

-------
                  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

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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-

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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-

-------
                  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

-------
                  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.

-------
                  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.

-------
                  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

-------
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

-------
                   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
                 +
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                 +

-------
                   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
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          feet
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 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

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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

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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.

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                  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

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                  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

-------
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

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               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

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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

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                  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.

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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?

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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.

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                     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.

-------
                     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

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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.

-------
2818
LEGAL COMPILATION—AIR


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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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