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