TECHNICAL SUPPORT DOCUMENT FOR AGENCY POLICY

    CONCERNING DESIGNATION OF ATTAINMENT,

   UNCLASSIFIABLE, AND NONATTAINMENT AREAS

                  FOR OZONE
    U.S. Environmental  Protection Agency
     Office of Air, Noise and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina  27711
                January 1979

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                      TABLE  OF  CONTENTS
1.0  Introduction	    1

2.0  Present designations  result in comprehensive
     coverage of known volatile  organic  compound
     estimates .	    6

3.0  EPA's ozone designations  do not prejudice
     New Jersey or the Northern  states.	    15

     3.1  New source  review requirements in  areas
          which are presently  designated
          unclassif iable.	    15

     3.2  Implementation of emission control
          programs in unclassif iable areas.	    16

     3.3  Monitoring  in unclassified areas which may
          have a high potential  for violating the
          Ozone NAAQS.-	    17

     3.4  Procedures  to ensure equity in estimated
          control requirements.	    18

4.0  Interpretation of the air quality standards for
     ozone and attendant uncertainties in the
     monitoring area.	"	    20

     4.1  Monitoring  requirements.	    20

          4.1.1    The NAAQS  consists of exposure
                   level  and  exposure time.	    20

          4.1.2    Aircraft data cited  by the
                   State  of New Jersey.	    21

     4.2  Geographic  area  represented by a detected
          violation of the NAAQS.	.	    24

5.0  Chemical and meteorological considerations in
     the formation and transport of  ozone and its
     precursors	    26

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     5.1  Chemistry of ozone formation and
          transport.	    26

          5.1.1     Chemical stability of ozone.	    26

          5.1.2     Chemical stability of ozone
                    precursors.	    30

     5.2  Meteorology of ozone episodes.	    32

6.0  Additional comments submitted by New Jersey.—    36

References

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1.0  INTRODUCTION
     On March 3, 1978,  the Administrator of the Environmental  Protection
Agency (EPA) promulgated air quality designations  for all  areas of the country
specifying whether the  National  Ambient Air Quality Standards  (NAAQS)  required
to have been attained under the  1970 Clean Air Act have been,  in fact, at-
tained.  The Administrator's designations were required by the 1977 Amendments
to the Clean Air Act, Pub. L. No.  95-95, 91  Stat.  685 (August 7, 1977).  Under
Section 107(d) (l)-(2)  of the Amendments, each State was required to assess
the air quality within  its borders and submit a list to the EPA identifying
those areas in the State which attained the National Ambient Air Quality
Standards, those which  had not and those areas which could not be classified.
The Administrator was to review  the State's designations and promulgate his
own list with any modifications  he deemed necessary.  On March 3, 1978, the
Administrator promulgated the designations.  43 Fed. Reg. 8962.

     Even though the designations  were immediately effective,  the EPA solicited
public comments on the  designations.  On September 11, 12, and October 5, 1978,
the Agency published responses to  many of the comments received; in many cases
designations were changed.  See  43 Fed. Reg. 40412, 43 Fed. Reg. 40502, and 43
Fed. Reg. 45993.  The State of New Jersey submitted comments challenging the
Agency's policy for designating  areas as attainment, nonattainment, or un-
classifiable for the ozone standard.  This technical support document responds
to each of the technical comments  submitted by New Jersey and supports the
Agency's March 3, 1978  policy for  ozone designations.

     In the March 3, 1978 promulgation, the Administrator determined that, in
the absence of ambient data to the contrary, all urban areas of the country

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(with a population greater than 200,000) and all  rural  counties with air
quality readings higher than the ozone pollution standard, must be designated
nonattainment areas.  The Administrator also determined that without actual
air quality measurements taken from ground level  monitors, the available
information is not sufficient to require a nonattainment designation in rural
areas in the Eastern portion of the country and that such areas may be designated
as "unclassifiable" under Section 107(d) (1) (D).

     In guidance to the States, the Assistant Administrator for Air, Noise and
Radiation stated that there is scientific evidence that, for many of the areas
in the Eastern portion of the country without ozone monitoring data, ozone
pollution is probably greater than allowed by the national standard.  See
40 C.F.R. 50.  The Assistant Administrator, therefore, encouraged the Eastern
States to list those areas as nonattainment areas for ozone pollution even
though there is no actual monitoring data showing nonattainment.  The State of
New Jersey followed the EPA suggestion and the entire State was designated as
nonattainment for ozone pollution.  See 43 Fed. Reg. 9015.  In contrast, many
other States did not follow the EPA's suggestion and designated areas in their
States without ozone monitoring data as unclassifiable.  Since the Agency
determined that, without actual monitoring data, it is impossible to determine   •
for certain that a rural area is nonattainment, the Agency approved the unclassi-
fiable designations.    .
                                                             12
     In comments submitted on the March 3, 1978 promulgation,  '  the State of
New Jersey contends that the EPA's suggestion to the States to designate rural
areas without monitoring data as nonattainment should have been a requirement
and that  there  is sufficient information to find that in all areas east of the

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 ississippi River ozone pollution  is greater than the national  standard  allows.
 ew  Jersey, therefore, argues  that all areas in the Eastern half  of  the  country
 ust be  designated  nonattainment under .Section 107(d} (1}  (E) of  the Act.   As
 et  forth  in  detail  in the  section below,  the Agency has determined  that the
 .cientific  information relied  upon by New  Jersey is not definitive enough to
 •equire  that  all areas in the  Eastern portion of the country  must be designated
 lonattainment.  Moreover, the  Agency's implementation of the  nonattainment and
 irevention  of significant deterioration  (PSD) provisions of the 1977 Amendments
 should insure that  the national standard for ozone pollution  is attained and
 maintained.

     In  summary, New Jersey's  position is  rejected as both unnecessary and
 jnsupportable for  the following reasons.  First, chemical  stability  of ozone
 and  its  precursors  does  not allow  significant concentrations  of ozone to be
 transported 1000 miles as suggested  by New Jersey.  Ambient concentration of
 ozone can not persist more  than approximately 36 hours  unless fresh  precursor
 emissions occur.   Thus,  under  meteorological conditions  prevailing  on days
with high ozone,  this limits significant transport  to  less than 300-500 miles.
 Since 91 percent of the  major  stationary sources within  500 miles of Trenton,
 New Jersey that cause ozone pollution are  situated  in  areas  designated non-
 attainment, the designation of additional  areas  in  the  Eastern portion of the
 country would have little effect on New  Jersey's ozone problem.  The areas
 that affect the State are,  for the most part,  already  designated nonattainment.
 Assuming that longer range transport were significant,  approximately 79 percent
 of major stationary sources within the Eastern  U.S.  are located in nonattainment
 areas.  Moreover,  the data relied upon by New  Jersey,  specifically aircraft

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flight data, to argue that all areas in the Eastern portion of the country are
nonattainment does not establish New Jersey's position.  There is simply too
poor of a correlation between the aircraft measurements and corresponding
ground level measurements to use aircraft data as a proxy for ground level
moni tors.
     Second, New Jersey  is not prejudiced by the EPA's decision to approve
State designations of rural areas without ozone monitoring data as unclassi-
fiable.  The Administrator's basic guidance to the States on the criteria the
EPA will apply  in determining if nonattainment SIP revisions are approvable
states that, in setting  emission reduction levels for sources in nonattainment
areas, the  States can assume that the air coming across the State borders
meets the standards.  Therefore, a State is required to regulate sources  in
the State only  to the extent that these sources contribute to pollution.  In
other words, a  downwind  State does not have to overregulate to compensate for
pollution caused by  sources  in the upwind State.  See 43 Fed. Reg. 21673,
21674.   It  is also not possible  for a new source to locate in an unclassifi-
able area and avoid  the  Act's requirements for nonattainment areas if air
quality  in  that area is  actually nonattainment.  The PSD regulations specify
that before a source may receive a permit to construct, the Agency can  require
ambient  air monitoring for  up to one year in the unclassified areas  in  which
the proposed facility is to be constructed.  If  the monitoring shows that
ozone  levels are  above  the  standards,  the area will then be redesignated  as a
nonattainment  area  under Section 107(d),  (5)_ and  the new source would have to
comply with the Act's requirements  for new  sources  in  nonattainment  areas.
See 40  C.F.R.  52.21, 43  Fed.  Reg.  26403,  26410.   In short,  the  EPA's ozone

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nonattainment designations  do not harm existing sources in New Jersey by
requiring that New Jersey overregulate as  New Jersey alleges,  nor prejudice
New Jersey by permitting the location of new sources in unclassifiable areas.

     Finally, the Agency is taking action  to determine if the  rural  areas
designated unclassifiable are actually attainment or nonattainment.   The
Assistant Administrator has directed the EPA's Regional Offices to review the
areas designated unclassifiable and determine where there is a high  probability
that the ozone standard may be violated.  The States may then  be required
either to conduct monitoring in the areas  or require "reasonably available
control technology" (RACT)  on existing sources in the areas.  The Agency is
also conducting scientific studies to identify more accurately the area repre-
sented by ozone monitor readings.  At present, it is scientifically unclear
just how large a geographic area a monitor reading represents.  Until the EPA
studies are completed, it is the EPA policy that ozone monitors will determine
air quality for the entire county where they are located.

     Accordingly, the EPA has determined that New Jersey has not submitted
information which requires a change in the EPA designation policy in ozone and
previous designations are affirmed.

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2.0  PRESENT DESIGNATIONS RESULT IN.COMPREHENSIVE COVERAGE OF KNOWN
     VOLATILE ORGANIC COMPOUND ESTIMATES
     As is explained in Section 5.0. below, ozone pollution is controlled by
reducing emissions of volatile organic compounds (VOC) from stationary sources
and motor vehicle emissions.  Evidence compiled from the U.S. EPA's National
Emission Data System (NEDS) establishes that there is only a small  fraction of
volatile organic compound (VOC) emissions within 500 miles or more of Trenton
that are not situated in areas designated nonattainment.  The small percentage
of VOC emissions within 500 miles of Trenton and located in unclassifiable
areas are unlikely to significantly contribute to New Jersey's ozone problem.
     Table 1 sets forth the fraction of total volatile organic emissions
within designated nonattainment areas in each State in the continental
United States and within each EPA Region.  The table reflects attainment/non-
attainment designations as of August 1978 and emission data from the EPA's
National Emission Data System (NEDS) as of June 1978.  If States in EPA
Regions I-V [i.e., see Table 1)_ are loosely interpreted as the "Eastern part
of the Country," it can be seen that 71 percent of the organic emissions in
the Eastern part of the United States are within designated nonattainment
areas.  This inventory includes an aggregate of stationary and motor vehicle
emissions.  Since mobile source emissions constitute a significant fraction of
"nonpoint source" emissions and are subject to controls regardless  of an
area's attainment status, it is most pertinent to evaluate the fraction of
stationary point source emissions included within designated nonattainment

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TABLE  1.   Volatile Organic Compounds  (VOC) Emissions in Counties
             Designated  Honattainment for Ozone:   By EPA Region and  State
                   EPA  Region/State
                   Connecticut
                   Maine
                   Massachusetts
                   New Hampshire
                   Rhode  Island

                   Region II

                   New Jersey
                   New York

                   Region III
VOC Emissions
Unclassified
Counties (TPY)

   13,726
    9,251

    4,475
                   Delaware
                   District of  Columbia
                   Maryland
                   Pennsylvania
                   Virginia              407,289
                   West Virginia          169,343
  668,915

   27,738

   64,545
                   Region rv

                   Alabama
                   Florida
                   Georgia
                   Kentucky
                   Mississippi
                   North Carolina
                   South Carolina
                   Tennessee

                   Region V

                   Illinois
                   Indiana
                   Michigan
                   Minnesota
                   Ohio
                   Wisconsin
                   .Region VI

                   Arkansas
                   Louisiana
                   New Mexico
                   Oklahoma
                   Texas

                   Region VII

                   Iowa
                   Kansas
                   Missouri
                   Nebraska

                   Region VIII

                   Colorado
                   Montana
                   North Dakota
                   South Dakota
                   Utah
                   Wyoming

                   Region IX

                   Arizona
                   California
                   Nevada
                   Idaho
                   Oregon
                   Washington

                   Regions I-V Totals

                   National Totals:
2,935,727

  346,152
  382,858
  375,122
  297,755
  302,411
  681,273
  282,080
  268,076

1,414,799

  225,034
  460,047
  108,859
  231,130
  106,346
  283,383

X, 885,666

  217,348
  273,898
  122,958
  273,917
  997,545

  977,255

  305,401
  232,721
  282,779
  156,354

  458,089

    79,938
  109,796
    66,849
    88,499
    41,570
    71,437

  256,269

    82,781
  148,364
    25,124

  563,739

  168,276
  141,205
  254,258

  5,033,167

 9,174,185
    VOC Emissions
Nonattaining Counties
      (TPY)

   1,393,895

     309,563
     137,537
     682,275
     102,120
     112,630

   2,591,904

     985,131
   1,606,773

   2,045,785

      64,052
      79,090
     467,305
   1,228,220
     207,118
   1,651,580

     182,047
     558,171
     189,699
     220,336

      72,132
      99,215
     329,980

   4,873,430

   1,205,346
     318,160
   1,219,350
     337,748
   1,370,662
     453,278

   2,425,818

      38,952
     584,172
      33,253
     168,903
   1,600,538

     690,081 .

      95,153
     193,811
     337,250
      63,867

     324,683

     212,852
      17,827
        6,229

      87,775
    2,659,926

      168,902
    2,444,671
       46,353

      370,271
      189,919
      180,352

    12,556,594

   19,027.373
% VOC Emissions
in Nonattaining
    Counties


       11

      100
       94
      100
       96
      100

      100
      100
      100

       75_

       70
      100
       88
      100
       34
        0

       3_6_

       34
       59
       34
       43
        0
       10
        9
       55

       Zi

       84
       41
       92
       59
       93
       62

       56_

       15
       68
       21
       38
       62

       li

       24
       45
       54
       29

       li

       73
       14
         9
         0
       68
         0

       21

       67
       94
       65

       4_0

         0
       57
       41

       71
                                                                                        67
                   Source:  National Emissions Data  System (NEDS)- June, 1978

                                           7

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     In the NEDS data base, a point source is a stationary source which emits
100 tons per year (TRY) or more of any pollutant.   For example, if a source
emitted 1 TRY of organics and 100 TRY of sulfur dioxide, it would be classi-
fied as a "point source of organic emissions."  Therefore, the term "point
sources" includes a number of stationary sources emitting less than 100 TRY of
organic emissions.  Table 2 depicts point source emissions included within
areas designated nonattainment and unclassified for each State and EPA Region.
Seventy-nine (79) percent of the point source emissions of organic compounds
in the Eastern United States are situated in areas designated nonattainment.
Figure 1 shows that, nationwide, nearly all counties either already have been
designated nonattainment or are not believed to have significant VOC emissions.*

     Most relevant  to New Jersey's concerns is the fraction of point source
emissions within about 36 hours travel time of New Jersey under meteorological
conditions conducive to high ozone concentrations.  As discussed in Section 5.0
below, a parcel of  air is not likely  to travel more than about 300-500 miles
in a 36  hour period under such atmospheric conditions.  Table 3 categorizes
VOC point source emissions within 300-500 miles of Trenton, New Jersey ac-
cording  to whether  or  not the emissions occur within a designated nonattain-
ment area.  According  to the NEDS inventory, over 95 percent of the point
source emissions  in the United States within 300 miles of Trenton  (Table 3)
are within areas  designated nonattainment.  Within 500 miles, greater  than
 *   Since  Figure 1  was prepared,  the  State of Virginia reclassified a number
    of  counties  from "nonattainment"  to  "unclassifiable."  While Figure 1 has
    not been  modified, the information in Tables  1-4 has been adjusted to
    consider  the reclassifications.

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TABLE  2.  Volatile Organic  Compounds (VOC)  Point  Source Emissions in  Counties
           Designated Honattainment  for Ozone:  By EPA  Region  and State
                          VOC Point Source  VOC Point Source
                              Emissions         Emissions
                                Total      Nonattaining Counties
EPA Region/State
Region I
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Region II
New Jersey
New York
Region III
Delaware
District of Columbia
Maryland
Pennsylvania
Virginia
West Virginia
Region IV
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Region V
Illinois
Indiana
Michigan"
Minnesota
Ohio
Wisconsin
Region VI
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Region -VII
Iowa
Kansas
Missouri
Nebraska
Region -vnr
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Region IX
Arizona
California
Nevada
Region X
Idaho
Oregon
Washington
Heoions I— V Totals
National Totals;
(TPY»
195,394
15,944
49,339
84,177
23,813
17,136
4,985
401,704
275,334
126,370
391,528
13,987
775
131,591
103,505
130,849
10,820
550,878
43,186
28,363
7,451
201,741
37,792
80,989
38,760
112,596
1,108,649
235,009
154,046
220,141
118,608
184,638
196,207
1,878,826
14,070
467,012
40,022
73,075
1,284,647
358,471
62,316
143,585
107,851
44,719
65,576
12,503
18,769
1,984
5,741
8,505
19,074
322,002
11,431
305,371
5,200
76,762
5,241
28,688
42,833
2,643,153
5,349,790
Source: National Emissions Data System
(TPY)
193,081
15,944
47,761
84,177
23,078
17,136
4,985
401,704
275,334
. 126,370
278,985
13,279
775
130,863
103,506
30,919
0
245,041
37,816
15,274
806
94,964
0
5,292
16,955
73,934
966,736
228,790
64,523
215,910
88,110
179,394
190,009
1,286,340
1,643
386,958
246
10,619
886,874
156,603
1,523
96,710
43,877
14,493
22,443
5,631
8,864
343
0
7,605
0
300,315
7,060
289,380
3,875
32,205
0
18 , 015
14,190
2,085.547
3,883,453
(NEDS) - June, 197
% Point Source
Emissions in
Nonattaining
  Counties


     21

    100
     97
    100
     97
    100
    100

    100

    100
    100

     71

     95
    100
     99
    100
     24
      0

     44

     88
     54
     11
     47
      0
      7
     44
     66

     21

     97
     42
     98
     74
     97
     97

     68

     12
     83
      1
     15
     69
                                                                        2
                                                                        67
                                                                        41
                                                                        32

                                                                        li

                                                                        45
                                                                        47
                                                                        17
                                                                        0
                                                                        39
                                                                        0

                                                                        11

                                                                        62
                                                                        95
                                                                        75-

                                                                        11

                                                                        0
                                                                        63
                                                                        33
                                                                        79

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 LEGEND:
 HENonattainment or VOC point source emission less than 100 TRY
FIGURE 1.   Nonattainment Counties  or Counties With VOC Point Source Emissions Less Than 100 TRY

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         TABLE 3.   Volatile  Organic  Compounds  (VOC)  Point  Source Emissions  Within

                   Specified Distances  of Trenton,  New  Jersey*


                                                    Distance
Emissions in
Nonattainment Counties

Emissions in Attainment
  or Unclassified Counties


                     TOTAL
<_ 300 mi.



 880,330


  38,972
                                                                     Within EPA
                                           <_ 400 ml.     ^500 ml.    Regions I-V
1,045,939    1,210,709    2,085,547
   68,662
124,719      562,606
 919,302     1,114,601     1,335,428    2,648,153
% VOC Point Source
Emissions Not Within
Designated Nonattainment Areas     4.2
                   6.2
                   9.3
                  21
*  Source:   NEDS Data Base, June 1978
                                   11

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90 percent of the United States' point source emissions are situated in areas
designated nonattainment (See Figure 2).
     New Jersey has questioned  the completeness of the data base within the
EPA's NEDS emission data system and therefore implies that the information
presented in Tables 1-3 is misleading.  Although States are required to
provide the appropriate information to keep NEDS complete and current,  it is
likely that there are omissions in the data base.  However such omissions, as
there are, are likely to occur  for both designated and unclassified areas and
the percentage values of Tables 1-3 are reasonably accurate.  This assumption
is supported by using population data as a surrogate for emissions data.  As
Table 4 establishes, 75 percent of the population of EPA Regions I-V live in
areas designated nonattainment. This percentage closely approximates the
corresponding percentages  of 71 percent and 79 percent for total and point
source emissions presented in Tables 1 and 2, respectively.
                                      12

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                                                    300 mile radius
                                                    ^
                                                    400 mile radius
FIGURE 2.   Counties within  a  specified radius of Trenton, N.J.
                                  13

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TABLE  4.    Fraction  of Population Within  Counties  Designated
               as Honattainment  for  the Ozone HAAQS
                    EPA  Region/State

                    Region  I
                    Connecticut
                    Maine
                    Massachusetts
                    New Hampshire
                    Rhode  Island
                    Vermont
                    New Jersey
                    New York

                    Region  III

                    Delaware
                    District of Columbia
                    Maryland
                    Pennsylvania
                    Virginia
                    West Virginia
                    Alabama
                    Florida
                    Georgia
                    Kentucky
                    Mississippi
                    North Carolina
                    South Carolina
                    Tennessee
                    Illinois
                    Indiana
                    Michigan
                    Minnesota
                    Ohio
                    Wisconsin
                    Arkansas
                    Louisiana
                    New Mexico
                    Oklahoma
                    Texas

                    Region VII

                    Iowa
                    Kansas
                    Missouri
                    Nebraska

                    Region VIII

                    Colorado
                    Montana
                    North Dakota
                    South Dakota
                    Utah
                    Wyoming
                    Arizona
                    California
                    Nevada
                    Region X

                    Idaho
                    Oregon
                    Washington
                    Regions I-V Total
                    Na11onal  Totals:
Population
  Total

11.203.696

 3.031,709
   992,048
 5,051,203
   737,681
   946,725
   444,330

25.358.904

 7,168,164
18.190.740

22.276,794

   548,104
   756,510
 3.922,399
11,793,909
 3,511,644
 1,744,237

31.854.934

 3,444,165
 6,789,440
 4,589,575
 3,218,706
 2,216,912
 5,082,059
 2,590,516
 3,923,561

44.057.447

11,113,976
 5,193,669
 8,875.083
 3,804.971
10,652,017
 4,417,731

20,381,560

 1,923,295
 3,641.306
 1.061,000
 2,559,229
11,196.730

11.230,948

 2,824,376
 2,246,578
 4,676,501
. 1.483,493

 5.576.561

 2,207,259
    694,345
    617,761
    665,507
  1,059,273
    332,416

 22.212.772

 1,770,900
19,953,134
    488,738

  6,213,12]

    712.567
 2,091,385
  3,409,169
134.751.775
200.366,737
Population
Nonattaining
Counties
11 ,076.942
3,031.709
899,535
5,051,203
703.390
946,725
444,330
25,358,904
7,168,164
18,190,740
18.270,734
385.856
756.510
3,463,395
11 ,793,909
1 ,871 ,064
12,097,122
1 ,271 ,539
4,430,796
1,689,270
1,346,305
499,712
711,945
2.147,555
33,669,423
9,293,771
2,251,436
7,754,871
2,238,944
9,328,650
2,301,751
10,248,022
287,189
2.163,271
315,774
1,010,307
6,471,481
4,582,144
678,992
813.133
2.636.868
453,151
2.560.161
1,651,105
87.367
821 ,689
21 ,332.775
1,319,189
19,596.880
416,706
3,035,989
1,339,875
1 ,696,114
100,473,125
142,232,216
f> Population in
Nonattaining
Counties
2i
100
91
100
95
100
100
100
100
100
82
70
100
88
100
53
38
37
65
37
42
10
27
55
76
84
43
87
59
92
52
50
15
59
30
39
58
41_
24
36
56
31
46
75
13
78
96
74
98
85
49. :
64
50
75
71
                    Source:  1970 Census of Population
                                            14

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3.0  EPA's OZONE DESIGNATIONS DO  NOT PREJUDICE NEW JERSEY
     OR THE NORTHEASTERN STATES
     3.1   New Source Review Requirements in Areas Which are Presently
          Designated Unclassified
          In unclassified or attainment areas, prevention  of significant
deterioration (PSD) regulations require that all  planned major VOC
sources with emissions greater than or equal to 50 tons/year after
control can be required to include in their PSD application up to one
year's worth of continuous air quality monitoring data including monitoring
for ozone levels.  If the monitoring shows levels above the ozone standard,
the new source would have to comply with new source requirements for sources
locating in nonattainment areas.   Thus, the data collected under the PSD
program will be used to further examine whether an area is meeting the
current ozone standard.  See 40 C.F.R. 52.21(e) and (n).  Moreover, if the
monitoring data establish that violations exist, the area  must be designated
nonattainment and a revision to the State Implementation Plan (SIP) must be
submitted within nine months.  If the State fails to submit the revised plan
the sanctions against further industrial growth in the area required by
Section 110(a)(2)(I) will apply.  Thus, if New Jersey's allegations
concerning widespread nonattainment of the ozone standard are true, the un-
classifiable designations adopted by some States will not result in competi-
tive  advantages  for attracting new industry to those States.

           If an  area is determined to be nonattainment, the new source would
be required to  install  Lowest Achievable Emission Rate  (LAER) control techno
and major  existing  sources would  be required  to install RACT.  If the area  i
determined  to be an attainment area, the proposed new source would be requir
to apply  best available control  technology  which  is determined on a case-by-
                               15

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basis.  Therefore, in both attainment and nonattainment areas, all new point
sources of emissions of VOC will be controlled.

     3.2  Implementation of Emission Control Programs in Unclassifiable Areas
          Despite the designation of an area as  unclassifiable some VOC emis-
sion controls are required in these areas.  Specifically, controls on motor
vehicles and new sources are proceeding within such areas.  This fact, together
with the information set forth above establishing that the vast majority of
existing VOC emissions are situated in areas designated nonattainment, supports
the conclusion there will be little environmental impact on New Jersey due to
the EPA's designation of rural areas without monitoring data as unclassifiable.

          The Federal Motor Vehicle Control Program plays a vital part in the
strategy to attain the ozone standard everywhere since approximately 40 percent
of the country's VOC emissions result from motor vehicle emissions in both
                      4
rural and urban areas.   That program will result in emission reduction to all
areas of the country regardless of an area's designation and.will be a major
factor, along with controls in urban areas, to insure attainment of the ozone
standard throughout the country.

          Further, the area designation, whether nonattainment, attainment or
unclassifiable, does not necessarily in and of itself dictate the applicable
new or existing stationary source control requirements.  There are essentially
three reasons for  this.

          First,  because air  pollution emissions are transported  from one area
to another,  the sources that  cause or contribute to a NAAQS violation, or
affect an area with clean air may actually  be outside the designated nonattainment
                                16

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or attainment area, respectively.   Therefore,  the specific control  requirements
which a source must meet are not necessarily dependent upon the designation of
the area in which it is located, but rather the designation of the area which
will be impacted by the source's emissions.

          Second, many States are choosing to impose requirements over a
broader geographic area than the designated nonattainment area for reasons of
equity, simplicity of administration or added assurance that all sources which
affect the nonattainment area are controlled and are making their revised
emission limitations applicable Statewide.

          Finally, Section 107(d). of the Act requires that attainment/non-
attainment designations be made within a very short time period, and that
these are to be composed of air quality control regions Cor portions thereof),
which are often based on State, county, or other political jurisdictional
boundaries.  This  process is bound to include pockets where the air quality
does not necessarily correspond to the specific designation of the area.
However, these anomalies will be taken into account during the detailed process
of  State Implementation Plan development for the given nonattainment area  and
in  the  issuance of individual new source permits which, as already mentioned,
are based upon the source's area of  impact  rather than its physical location.

     3.3  Monitoring  in Unclassified Areas which May  Have  a High Potential
          for Violating the Ozone NAAQS
          The EPA  has  encouraged but not required Statewide nonattainment
designations  and  the  development of  Statewide  controls of  volatile organic
compounds.  Additionally, the EPA  is reviewing  and analyzing  existing  scien-
 tific  data  to determine whether broader nonattainment designations are appropriate.
                                      17

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However, the existing data base may be insufficient to allow for a complete
evaluation.5  Therefore, the EPA Regional Administrators have been requested
by the Assistant Administrator on October 12, 1978 to identify those areas
designated unclassified which do not have monitoring data and have a high
potential to exceed the standards.   Once these areas are identified, the EPA
has recommended that the States require, in the 1979 SIP revisions, the appli-
cation of RACT on most major sources of VOC emissions.  RACT would be required
for sources with VOC emissions greater than 100 tons/year potential and for
which the EPA has issued a CTG (Control Techniques Guideline) by January 1978.
The SIP revisions would have to include a commitment by the State to adopt
additional regulations annually beginning in January 1980 for those sources
for which the EPA has published CTGs in the preceding year.  If States do not
comply with this recommendation for their SIP revisions, they may be required
to conduct monitoring for photochemical oxidants in the identified counties
during the next year.  If the new monitoring data shows violations of the
ozone standard,  the counties will be redesignated as nonattainment areas and a
SIP will be required.

     3.4  Procedures  to Ensure Equity  in Estimated Control Requirements
          A major concern expressed by the State of Mew Jersey  is  that States
which are downwind of unclassifiable areas will have  to control emissions more
stringently than would otherwise  be necessary.  This concern is unfounded.
Procedures developed  by  the  EPA  allow  States which are downwind of areas not
attaining  the  ozone NAAQS  to "take credit" for controls that would have  to  be
adopted  to attain  the standards  in upwind  States.  This provision  avoids the
problem of  the downwind  States  having  to overregulate to  compensate  for  pol-
lution  originating  in another State.
                                      18

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          The EPA has provided guidance to the States for establishing organic
emission control  requirements to meet the oxidant standard in nonattainment
      789
areas.  ' '   Specifically, the guidance allows a downwind State to assume a
reduced ozone design value prior to calculating control  requirements.   The
rationale for this guidance is that upwind States are required to meet the air
quality standard for ozone.  Therefore, the downwind States may assume that
ozone contributed by upwind sources of precursors will be reduced to levels of
the standard or below.  For example, if the second high hourly ozone concentra-
tion recorded in New Jersey during a year is .24 ppm ozone, and ozone trans-
ported into that State from upwind States is estimated to be .14 ppm ozone,
New Jersey would be allowed to reduce the .24 ppm ozone value by an amount
commensurate with the reduction of transport into the State to the ozone
standard.  The resulting reduced ozone design value would then be used
to estimate organic emission control requirements in New Jersey.  Thus, down-
wind States, such as New Jersey, are allowed to take credit for controls
required in upwind States.  The EPA believes that such a procedure eliminates
any inequity attributable to transport of pollution from upwind States.
                               19

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4JO  INTERPRETATION OF THE AIR QUALITY STANDARDS FOR OZONE AND ATTENDANT
     UNCERTAINTIES IN THE MONITORING DATA

     4.1  Monitoring Requirements
          The past National Ambient Air Quality Standard (_NAAQS) for photo-
chemical oxidants was 160 micro.grams per cubic meter (or .08 parts per million
[ppm]) maximum one hour concentration not to be exceeded .more than once per
year.    Much of the evidence used by New Jersey to indicate widespread vio-
lations of the NAAQS is based on aircraft data.  Determining through aircraft
data whether air quality ozone levels at ground level are being exceeded is
not a straight-forward exercise.  In fact, the Agency has determined that, at
present, aircraft data can only be used qualitatively to evaluate air quality
and not to require nonattainment designations for the national standard.

          4.1.1  The NAAQS Consists of Exposure Level and Exposure Time
               The national ozone standard consists both of an ambient exposure
level and an exposure time.   In addition, the standard applies at locations to
which the general public has  access.  Aircraft data are of short duration and
obviously are not collected at ground level.  Moreover, the national ozone
standard was set at or below  observed threshold levels corresponding with
adverse effects on health.  The standard is designed to provide some factor of
safety  in order to protect sensitive members of the population and to protect
against synergistic effects arising from simultaneous exposure to a number of
.pollutants.

               Aircraft measurements are of short duration and are spatially
integrated average concentrations observed over short periods.  For example,
assuming an  aircraft were  traveling 120 miles  per hour and each ozone reading
                                      20

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represented a five minute integrated  average  concentration,  the recorded ozone
concentration would have been sampled over a  ten mile path several  hundreds  of
feet above the earth's surface.   There are scientific uncertainties in relating
such data to the national standard and it can not be claimed, as New Jersey
does, that aircraft recordings of ozone levels higher than the ozone standard
is clear evidence of widespread violations of the standard without having
first documented that such measurements establish that ozone levels at ground
level are exceeding the exposure level stated by the standard for an hour or
more.  Such documentation does not exist.  While the EPA is examining this
issue at the present time, there is no definitive scientific guidance available.
Moreover, the evidence that is available suggests that aircraft data are a
limited proxy for ground level monitoring data.

          4.1.2  Aircraft Data Cited by the State of New Jersey
               The aircraft data cited by the State of New Jersey in Reference 2
as supporting .the need for Statewide nonattainment designations are generally
not  good indications of  ozone concentration levels observed concurrently at or
near the ground.  For example, in only 30 percent of the instances in which
ozone concentrations greater  than .08 ppm were observed aloft did concurrent
hourly ozone concentrations observed at ground level approximately beneath the
flight track exceed  .08  ppm.  Using data cited by the State of New Jersey,
Tables 5 and 6  illustrate the difficulties of using aircraft data as an  indi-
                         ,                            2
cator of ozone  concentrations observed at the ground.   As shown in Table 5,
12 of the  21 aircraft flights cited by New Jersey indicated ozone concentrations
aloft in excess  of  .08 ppm.   Fewer than half of  these indicated a corresponding
concentration of .08  ppm or more at or near the  ground.
                                     21

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TABLE 5.  Comparability of Aircraft and Ground Level
          Data Provided tty ther State of New Jersey
       Concentrations
            > .08 ppm
             Observed
x\ Aloft
Concentratioiisx.
> .08 ppm Observed.
at the Ground x^
Yes
No
Total Number
of
Observations
Fraction of
"Correct"
Indications
YES • NO
5 : 1
7 8
12 , 9
I
5/12 ! 8/9
j
TOTAL
-
— !
i
21
1 3/21
                         22

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TABLE 6.  Comparability of Aircraft and Continuously
          Measured Ground Level  Data Provided by the State
          of New Jersey
\v Concentrations
x. > .08 ppm
^ Observed
X. Aloft
Concentrati ons\v
> .08 ppm Observed^
at the Ground - x^
Yes
No
i
Total Number
of
Observations
i
Fraction of
"Correct
YES .NO TOTAL
3> 1 ! _ -
7 6 1
1 10 ; 7 i 17
i ;
j i
| • |
i i
i
i i
       Indications
3/10
6/7
9/17
                          23

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               Table 6 differs from Table 5 in that only flights for which
continuous ground level data are available beneath the flight track are con-
sidered.  In these latter comparisons, in only 30 percent of the cases where
ozone concentrations exceeding .0,8 ppm were observed aloft were correspondingly
high concentrations observed with the continuous monitors.  It is likely that
a number of these discrepancies can be explained by the presence of local
sinks for ozone near the continuous monitor Ce.g., sources of nitric oxide
emissions) or by the time of day or prevailing meteorological conditions under
which the measurements were made.
               Regardless, the conditions under which ozone concentrations
measured aloft are good indicators of concentrations at ground level have not
been scientifically established.  The EPA is studying the question at present
but until those studies are completed, the EPA will only use aircraft data to
make qualitative assessments of air quality.  Accordingly, aircraft measure-
ments were  used by the EPA as one reason for encouraging States in the Eastern
portion of  the country to make Statewide nonattainment designations for ozone
pollution.  However, the Agency does not believe  that aircraft data constitute
sufficient  bases for mandatory Statewide nonattainment designations.
     4.2  Geographic Area Represented by a Detected Violation of the  NAAQS
          There  is considerable uncertainty over  the geographic area  repre-
sented  by a recorded violation of the ozone standard at an individual ground
level monitor.  As Reference  11 suggests,  the area represented by  an  ozone
monitor depends  on  the site characteristics  (e.g., the environment immediately
surrounding the  monitor}.   However, unlike CO and TSP for which observed
violations  frequently  appear  to  be  the  result of  localized problems,  violations
                                      24

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of the ozone standard appear to be more widespread.   Consequently, the Agency
has strongly suggested that designated nonattainment areas for the ozone
standard be at least as large as a county.   In most cases, a county represents
the smallest geographical  or jurisdictional  boundary for which most control
programs will  be centered. .As the EPA develops more scientific guidance on
the area represented by specific ozone monitors, designation areas will  be
modified as appropriate.
                                    .25

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5.0  CHEMICAL AND METEOROLOGICAL CONSIDERATIONS IN THE FORMATION AND
     TRANSPORT OF OZONE AND ITS PRECURSORS
     Ozone (03) is a "secondary pollutant" which is a pollutant not emitted
directly by a source of pollution.  Instead, secondary pollutants arise from
chemical reactions among other pollutants (_i.e., precursors 1 which themselves
may or may not be directly emitted by sources.  Because ozone is a secondary
pollutant, highest concentrations do not necessarily occur in the immediate
vicinity of the sources which emit the precursors.  For a significant amount
of ozone to be formed, two conditions must occur.  First, organic precursors
and oxides of nitrogen (NO ) must both be present in sufficient concentrations;
and second, ultraviolet radiation from sunlight must be sufficient to enable
photodissociation of nitrogen dioxide (_N021 to sustain the sequence of reactions
leading to ozone formation.  Because the chemical lifetimes of ozone and most
of its precursors appear to be limited, and because of the impact of continual
dilution, there are geographical  limits to significant transport of ozone
unless high concentrations can be sustained by interaction with fresh precursor
emissions.

      5.1  Chemistry of Ozone Formation and Transport

          5.1.1  Chemical Stability of Ozone
               The chemical stability of ozone and its precursors is important
in estimating  geographical distances of significant of ozone transport.  If
these pollutants decay away to negligible amounts within a few hours, their
impact  at remote  locations will  be small.   If, on the other hand, they are
chemically  stable,  then under adverse meteorological conditions their impact
could be  significant  at remote sites.
                                      26

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               The bulk of available evidence suggests  that in  the absence
of fresh precursor emissions,  the lifetime of ozone in  the atmosphere is
limited.14'19'20'36  The chemical stability of ozone and other  pollutants  is
frequently expressed in terms  of their half lives  (j-e., the time it would take
a pollutant to decay to one half of its original  concentration)..   The lifetime
of ozone in the atmosphere depends on the extent  to which prevailing meteoro-
logical conditions enable the  ozone to come into  contact with scavengers  and
the earth's surface.  Scavengers such as airborne aerosols, some naturally
emitted organic pollutants (e.g., terpenes). and nitric  oxide (NO) as well  as
surface deposition all act to  limit the lifetime  of ozone in the atmosphere.
In the absence of fresh precursor emissions, it is unlikely that significant
concentrations of ozone can persist near the earth's surface for greater than
about 36 hours.  Therefore, emissions from sources within 36 hours of New Jersey
would be most likely to impact on ozone levels in New Jersey.  As discussed
above, within 36 hours travel  time of New Jersey, almost all sources of pol-
lution causing ozone are situated in areas designated nonattainment.

               The 36 hour transport estimate is  based on available infor-
mation on  the stability of ozone under different conditions.  It has been
                                                                        12 13
clearly demonstrated that ozone  trapped aloft overnight is quite stable.  '
Ozone which is transported over water also appears to have a long lifetime of
several days.  '   »I5>'  >ia  Trajectories-over water could therefore present a
special case  in which  transport  from very  remote sources could be significant.
 For  example,  it has been demonstrated that ozone transport from the Northeastern
                                      18
 U.S.  impacts  on the coast of Virginia.    A review of rural diurnal ozone
                                                        14 19
 concentration patterns  reported in several field studies   '   suggests that
                                      27

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the half life of ozone in rural areas near the earth's surface at night is in
the order of 5-12 hours.  Nighttime half life of ozone within an urban plume
                                                       14 19
near the earth's surface appears to be about 2-3 hours.   '
               It is much more difficult to determine daytime half life of
ozone over land because fresh ozone is being synthesized as new precursor
emissions are injected into the air parcel.  Thus, data reflecting the buildup
of ozone during the day may be the result of new ozone being synthesized more
rapidly than the depletion of "aged ozone" resulting from remote sources.
However, recent modeling of the stability of ozone to simulate daytime con-
ditions in a mixture of carbon monoxide, methane and water vapor exposed to
sunlight suggests that the daytime half life of ozone in such a system is 5-
        20
7 hours.    Such a mixture consists of naturally occurring stable compounds.
As such, there is likely to be slower destruction of ozone under such conditions.
Therefore, the modeling exercise suggests that daytime half life of ozone over
land is likely to be less than seven hours.

               By combining the estimated daytime and nighttime half lives of
ozone, the EPA estimates that 36 hours after a significant amount of ozone is
formed, only 25 percent remains in the atmosphere (see Table 7)_.  Furthermore,
the 36 hour estimate is a conservative one for several reasons.  The estimate
ignores any impact of dilution, assumes ozone does not decay at all overnight,
assumes the daytime half life of ozone is six hours, and assumes transport
begins at 6:00 p.m. —  the most conservative possible assumption in this
scenario.
                                      28

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TABLE 7.   SCENARIO ILLUSTRATING OZONE TRANSPORT
Elapsed
Time, hr
0
6
12
18
24
30
36
Day
1
1
2
2
2
2
3
Time of
Day
6 p.m.
Midnight
6 a.m.
Noon
6 p.m.
Midnight
6 a.m.
Percent of
Initial Ozone
Remaining
100
100
100
50
25
25
25
                                                  Ozone
                                                  Concentration, ppm
                                                       .16
                                                       .16
                                                       .16
                                                       .08
                                                       .04
                                                       .04
                                                       .04
                      29

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          5.1.2  Chemical Stability of Ozone Precursors



               There are two classes of ozone precursors:   volatile organic



compounds (VOC) and oxides of nitrogen (NO ).  There is information which
                                          A


implies that long range transport of N0x is not significant.14'15'19'21'22'23



There is greater uncertainty about the transport of volatile organic pre-



cursors; however, the available information suggests that the half lives of


                                                       24 25
most volatile organic compounds are less than 24 hours.  '





               Theoretical and limited monitoring data suggest rapid daytime

                                                                  p£ pc pc

decay of most volatile organic compounds during the summer months.  ''



Organic compounds appear to be somewhat more persistent at night.  Low con-



centrations of slow reacting compounds could survive for several days; how-



ever, modeling studies suggest that these low concentrations do not contribute



significantly to ambient ozone concentrations, particularly when compared with


                          23
fresh precursor emissions.





               Numerous  field studies of urban plumes have failed to detect



elevated levels of reactive pollutants greater than one travel day away from


                       14 20 23 26 27
the source of emission.   ''''    In studies described in Reference 25,



organic  pollutants and ozone were sampled at a site approximately 100 km from



St. Louis.  When  the  urban  plume impacted the site during the day, elevated



ozone was observed, but  organic pollutants  (with the exception of nonreactive



halogenated compounds^ were not above background levels.  At night however,



organic  pollutants were  found  to be  higher  than background levels and ozone



was depressed.  Occasionally,  transport  from a city  (Chicago), about 270  km



away could be  detected using halogenated compounds as  tracers.   No significant



buildup  in organic  pollutants  or  in  ozone could be detected  in  these-cases.
                                      30

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               These observations  are consistent with  the theoretical  findings
summarized in Reference 25 which suggest that rapid  decay of most organic
compounds occurs  during summer days (the ozone pollution season), with  the
decay being slower at night.   Half lives of most volatile organic compounds
are probably less than 24 hours.  See References 24, 25, 26 and 36.  Additional
support comes from monitoring studies conducted in rural, remote areas in
                                                                         20
which ambient levels of organic compounds are typically .10 ppmC or less.
Such data could be presumed to be a conservative representation of cases where
the monitoring site is not impacted upon by significant sources within a day
or two of travel  time.
               Several simulations have been conducted with chemical kinetics
models to estimate the impact of organic precursors transported from afar as
                                            23
compared with emissions of fresh precursors.    In scenarios in which concentra-
tions of VOC of  .10 ppmC  (about the level seen at remote sites), were added to
the model, negligible  impacts on peak ozone concentrations  (y  .006 ppm) were
typically observed.

               To summarize, most  organic precursors decay  or  are  diluted  to
very low concentrations before  they are  transported over great distances.  The
modeling exercises  imply  that these low  levels are not  significant in ozone
formation far downwind when  compared  to  the  impact of locally  generated  pre-
cursors.  In short, because  of  dilution  and  instability of  most  precursors,
long range  transport  of ozone precursors does  not appear to significantly
contribute  to  local ozone concentrations in  the urban areas of the Northeast.
 In  addition, unless long  range  transport of  ozone is supplemented  by  more
 locally  emitted  precursors (which, as shown  earlier, are subject to controls
                                      31

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in the case of New Jersey), the chemical lifetime of ozone,  as  a  rule,  is
insufficient to sustain high concentrations for more than about  36  hours.

     5.2  Meteorology of Ozone Episodes
          Ozone episodes are typically characterized by light  and variable
winds.  Since pollutants are borne by the winds, the distances over which
transport of pollutants is significant is limited to 3QO-500 miles  which  is
the distance pollutants could travel within about 36 hours  with  light and
variable winds.  This information suggests that New Jersey's concerns about
significant adverse environmental impacts from ozone generated from unregu-
lated sources more than about 500 miles away from New Jersey is  unwarranted.

          As New Jersey has commented, highest concentrations  of ozone in  the
Midwest appear  to occur in the presence of stagnating or,  more generally,
slow-moving high pressure systems.  Highest ozone concentrations within such
high  pressure systems usually occur in the western or back side. In general,
 :emperatures are warmer on the back side of the system, and it is possible
 bhat  air within that sector may  have  been within the system somewhat longer
than  air further east.  However, simply analyzing the movement of weather
systems from the Midwest  to the  East  does  not establish that pollution gener-
ated  in the Midwest is  transported  to the  East.

          As several investigators  have pointed out, pollutants are trans-
                                              14 28
ported by  the wind, not by  the weather system.   '    Therefore, while a parcel
of air may  remain within  the  same weather  system for up to a few days, it  is
not correct  to  think of a high  pressure system  as a self-contained mass of air
which migrates  intact  toward  the East Coast from points west or south.  Rather,
                                      32

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it is more accurate to compare air parcel  trajectories during high ozone
weather conditions with trajectories observed on other days.   Comparisons of
this nature have been done at rural  and urban sites in the Midwest and the
South (see References 14 and 19)_.   Such comparisons show that, over a 36-hour
period, the area covered by an air parcel  in the lowest 300 meters of the
atmosphere is generally rather limited (usually < 300 miles), on days observing
high ozone.
          There are several factors associated with transport and buildup of
ozone that make it unlikely that ozone transport over extended distances
(greater than 300-500 miles) is significant.  These factors are the following:
               1.   High ozone buildup generally occurs in high pressure
systems migrating from west to east.  However, pollutants emitted into such
systems do not move with the system itself but are transported by the wind
circulating about the system.  Hence, an air parcel into which ozone or pre-
cursors are injected will  usually take a more circuitous route than the
system itself.
               2.   There  is no assurance that an air parcel will remain
within a high pressure system over  an extended travel distance.   Parcels do
not travel within such systems indefinitely  but  exit or "spin off" within
hours or days and are  replaced by other parcels  entering the system.   It has
been estimated that  the  range for retention  of an air parcel within a  slow
moving high pressure  system  depends on the  speed with which  the system mi-
 grates  across  the  country and  varies  from  less  than  one  to as  many  as  six
      19
 days.    Therefore, as  travel  distance  increases,  it becomes less probable
 that a  specific  air parcel  in  a  high  pressure system will stay in that system.
                                      33

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               3.   Ozone buildup is associated with relatively light and
variable winds.  Assuming that in such a system the transport wind averages
ten miles per hour or less, an air parcel would travel  at most only 200-300
miles over a day's time.  At this wind speed it would take three-to-five days
or more to traverse more than 1,000 miles.  The chemical  instability of ozone
would make survival of ozone over such long distances highly improbable.  If
wind speeds were much greater, dilution would be correspondingly greater and
ozone concentration buildup would be unlikely.  Therefore, the limit for
significant contribution of precursor sources to ozone concentration is probably
no more than about 300-500 miles.  Beyond those distances, the relative contri-
bution would decline considerably.  It would be difficult to determine a
precise distance beyond which contribution becomes negligible.  However,
significant transport from remote precursor source areas as far as 1,000 miles
away appears to  be highly unlikely.

          In short, there are numerous studies14'15'19'21'22'23 which have
demonstrated that  precursor and  ozone transport over tens to a few hundred
miles is  important to the buildup of high ozone concentrations.  The EPA
participated in  some of these studies and acknowledges that such transport and
subsequent  impact  does  occur.  However,  the EPA differs with New Jersey on the
range over which significant  transport and  impact may occur.  Supporting
                 i? ?Q  "*r\  "31  i?  n
technical studies1^'""30"31 »•»*»•"  submitted  by New Jersey, which have  been
conducted by the Interstate Sanitation Commission  (.ISC), argue that significant
transport on some  occasions  from source  areas  as far as the Texas-Louisiana
Gulf Coast  and parts of the Midwest can  impact on  New Jersey.  Some of  these
areas represent a  transport  distance of  over  1,000  miles.
                                      34

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          The 'EPA is not able to accept the conclusions  reached by these
studies.   Much of the bases for the ISC analyses  are trajectory estimates
which indicate the probable flow of air and buildup of ozone observed in the
general  area of the trajectory over a period of days.  Such analyses do not
establish transport distances since the air flow does  not necessarily demon-
strate that a reactive pollutant like ozone can survive  for a period of time
required for travel over such a great distance.  The ISC studies contain some
questionable assumptions in their attempts to justify very long distance
transport at sustained high ozone levels.  In multiday transport cases, they
assumed that ozone is regenerated on the day(js)_ after initial formation even
without addition of new precursors.  The ISC authors rely on smog chamber
studies that were subject to chamber wall interferences.  In shorter duration
transport over long distances, they assumed mean transport wind speeds on the
order of 45 miles per hour which would cause considerable dilution of pre-
cursor injections into an air mass as well as considerable dilution of ozone
or precursors within an air mass.  Regardless of the validity of these assump-
tions, it is  very difficult to conclusively demonstrate very long range  trans-
port toward  the Northeast because of the ambiguities introduced by considerable
potential for fresh precursor  emissions along the way.
                                      35

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6.0  ADDITIONAL COMMENTS SUBMITTED BY NEW JERSEY
     New Jersey has also commented that the EPA did not use certain data
available to it in making the designations.  Specifically, New Jersey has
alleged that certain rural monitoring data were excluded in designating non-
attainment areas.  The air quality data base utilized by the Agency is the
most complete one which was available at the time of the designations.  In an
effort to ensure that erroneous designations based on faulty data were not
made, only those data collected using appropriate quality assurance procedures
were used to make nonattainment designations.

     In addition to regularly reported data, rural data collected by the EPA
in special field studies or additional data certified as valid by the EPA
Regional Offices were used to make designations.  In addition the EPA, through
a contract study, reviewed privately collected ozone data at rural sites in
the Western United States for assessing ambient ozone levels.  After completion
of the contract  study,  the EPA  Regional Offices were contacted to determine
whether specific privately collected data were considered valid.  Only those
data in the  report which  the appropriate Regional Office could assert were
valid were  included  in  SAROAD  (j.e., the EPA's computerized air  quality data
base).
                                      36

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References Cited

 1.   Letter from Rocco  D.  Ricci  to  Douglas  M.  Costle,  dated April  28,  1978
     with attachments.

 2.   Letter from Paul  D.  Arbesman  to  Ronald C.  Hausmann,  dated  July  7,  1978
     with attachments.

 3.   38 FR 20,  834-20,835, paragraph  51.7 (August 3,  1973).

 4.   U.S. EPA,  MDAD,  National  Air  Quality,  Monitoring and Emission Trends
     Report. 1977, EPA-450/2-78-052 (December 1978).~

 5.   Letter from Ronald C. Hausmann to Richard M. Hluchan,  dated September  15,  1978
     with attachments.

 6.   Letter from David G. Hawkins  to  EPA Regional Administrators, Regions  I-X
     dated October 7, 1977, subject:   Mailed letter reporting States designation
     of attainment status, with attachment.

 7.   U.S. EPA,  Workshops on Requirements for Nonattainment Area Plans—Compilation
     of Presentations (Revised Edition), April 1978.

 8.   U.S. EPA,  Office of Air Quality  Planning and Standards,  Uses, Limitations
     and Technical Basis of Procedures for Quantifying Relationships between
     Photochemical Oxidants and Precursors. EPA-450/2-77-021a (November 1977).

 9.   Memorandum from Richard G. Rhoads to Director, Air and Hazardous Materials
     Division,  Region I, III-X and Director Environmental Programs Division,
     Region II, subject:  "Clarification of Attainment/Nonattainment Evaluation
     Guidance," dated August 16, 1978 with enclosure.

10.  Federal Register 36 No. 228,  paragraph 50.9, (November 23, 1971), page 22,335.

11.  Ludwig, F. L., et_al_., Site Selection for the Monitoring of Photochemical
     Air  Pollutants.  EPA-50/3-78-013 (April 1978).

12.  Wolff, G.  T. and P. J. Lioy,  "Ozone Concentration Patterns Associated With
     the  July 1977 Eastern U.S. Heat Wave."  Presented at 71st Annual Meeting
     APCA,  Paper #78-30.4, Houston, Texas  (June  1978).

13.  Decker, C. E., J. E. Sickles, II, W.  D. Bach, F. M. Vukovich, and
     J.  J.  B. Worth, Project Da Vinci II:  Data  Analysis and Interpretation,
     EPA-450/3-78-028  (June 1978).

14.  Decker, C. E.,  et al., Formation and  Transport of Oxidants Along Gulf Coast
     and  in Northern United States, EPA-450/3-76-033  (August 1976).

15.  Spicer, C. W.,  et al., The Transport  of Oxidant  Beyond Urban Areas
     EPA-600/3-76-018~TFebruary 1976).

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16.  Cox, R. A., A. E. J. Eggleton, R. G. Derwent, J.  E.  Lovelock and
     D. H. Pack, "Long-Range Transport of Photochemical  Ozone in Northwestern
     Europe," Nature 225 (No. 55404)., pages 118-121 (1975).

17.  DeMarrais, G. A.., The Ozone Problem in the Norfolk, Virginia Area,
     EPA-600/4-78-006 (January 1978).

18.  Salop, J. and G. F. Maier, "A Study of Ozone Levels in  a Maritime and
     Land Environment," J. Air Pollution Control Association 28 (December 1978).

19.  Research Triangle Institute, Investigation of Rural  Oxidant Levels as
     Related to Urban Hydrocarbon Control Strategies,  EPA-450/3-75-036
     (March 1975)..        :

20.  Bufalini, J. J. and W.  A. Lonneman, "Ozone Formation from Rural Hydrocarbons,"
     paper presented at CRC Air Pollution Symposium, New Orleans, Louisiana
     (May 1978)..

21.  U.S. EPA, Office of Air Quality  Planning and Standards, Effectiveness of
     Organic Emission Control Programs as a Function of Geographic Location
     (April 1977)..

22.  Westberg, H., et al., Studies of Oxidant Transport Beyond Urban Areas,
     final report.  EPA Contract No.  68-02-2239, Washington State University
     (1977).

23.  U.S. EPA, Office of Air Quality  Planning and Standards, Procedures for
     Quantifying  Relationships between Photochemical Oxidants and Precursors:
     Supporting Documentation, EPA-450/2-77-021 b  (February 1978).           ~

24.  Pitts, J. N.  Jr., A. M. Winer,  K. R. Darnall, A.  C. Lloyd and G. J. Doyle,
     "Hydrocarbon  Reactivity and the  Role of Hydrocarbons, Oxides of Nitrogen,
     and Aged Smog  in  the Production  of  Photochemical  Oxidants,"
     EPA-600/3-77-001b,  page 687 (January 1977)..

25.  Altshuller,  A.  P.,  "Formation and Removal of  S02 and Oxidants from the
     Atmosphere,"  Fate  of Pollutants  in  the Air and Water Environment.  Part H,
     I.  M.  Suffet (Edl.  (.1977)..

26.  Rasmussen, R.  A.,  R. Chatfield  and  M. Holdren, Hydrocarbon and Oxidant
     Chemistry Observed  at a Site  Near St. Louis,  EPA-600/7-77-056  (June 1977).

27.  Lonneman, W.  A.,  "Ozone and Hydrocarbon Measurements in Recent Oxidant
     Transport Studies,"  EPA-600/3-77-001a, page  211  (January  1977).

28.  Pack,  D.  H., E.  Robinson  and  F.  Vukovich,  International Conference on
     Oxidants,  1976 - Analysis  of  Evidence and  Viewpoints, Part V.  The'
      Issue  of Oxidant Transport, EPA-600/3-77-117 (November  1977).

29.  Wolff,  G.  T., P.  J.  Lioy,  G.  D.  Wight, R.  E.  Meyers and R. T.  Cedar-wall,
      "An Investigation of Long-range Transport  of Ozone  Across  the  Midwestern
     and Eastern  U.S.," Atmospheric  Environment 11:797   (1977).

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30.  Wolff,  G.  T. ,  P.  J.  Lioy, G.  D.  Wight,  R.  E.  Meyers,  and R.  T.  Cedar-wall,
     "Transport of  Ozone  Associated with  an  Air Mass,"  In:   Proceedings To
     Annual  Meeting APCA, Paper #77-20.3, Toronto, Canada  (June 1977).

31.  Wight,  G.  0. ,  G.  T.  Wolff, P.  J.  Lioy,  R.  E.  Meyers,  and R.  T.  Cedarwall,
     "Formation and Transport of Ozone in the Northeastern Quadrant of  the
     U.S.,"  In:  Proceedings ASTM Symposium  Air Quality and Atmospheric
     Ozone,  Boulder, Colorado (August 1977).

32.  Wolff,  G.  T.,  P.  J.  Lioy, and G.  D.  Wight, "An Overview of the Current
     Ozone Problem in the Northeastern and Midwestern U.S.," In:   Proceedings
     Mid-Atlantic States  APCA Conference  on  Hydrocarbon Control Feasibility,
     page 98, New York, New York (April 1977).

33.  Lioy, P. J. and P. J. Samson, "Ozone Concentration Patterns  Observed
     During the 1976-77 Long-range Transport Study."  Presented at Coordinating
     Research Council  Symposium, New  Orleans, Louisiana (May 1978).

34.  PEDCo Environmental, Incorporated, Compilation and Evaluation of Privately
     Collected Ambient Ozone Data West of tne Mississippi  River,  Contract
     No. 68-02-1899, Task Order 4 (April  1977).

35.  Memorandum from Robert E, Neligan to Directors, Surveillance and Analysis
     Division, Regions V-X and Directors, Air and Hazardous Materials Division,
     Regions V-X, subject:  "Compilation  and Evaluation of Privately Collected
     Ambient Ozone Data West of the Mississippi River," dated August 23, 1977.

36.  U.S. EPA, ORD, Air Quality Criteria  for Ozone and Other Photochemical
     Qxidants,  (Volume I  - Preprint), EPA-600/8-78-004 (April 1978).

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