PROGRESS IN THE PREVENTION AND
CONTROL OF AIR POLLUTION IN 1977
ANNUAL REPORT OF THE ADMINISTRATOR
OF THE ENVIRONMENTAL PROTECTION AGENCY
to the
CONGRESS OF THE UNITED STATES
in Compliance with
SECTIONS 313, 202 and 306(e)
of
PUBLIC LAW 91-604
THE CLEAN AIR ACT, AS AMENDED
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CONTENTS
LIST OF TABLES " 111
LIST OF FIGURES iv
PREFACE v
I. INTRODUCTION AND SUMMARY 1
II. AIR QUALITY TRENDS 7
Air Quality Trends 7
A1r Monitoring Strategy 11
III. DEVELOPMENT OF AIR QUALITY CRITERIA AND STANDARDS .... 13
Introduction 13
Health Effects Research 13
Terrestrial Ecology Effects of Air Pollution 19
IV. STATUS OF STATE IMPLEMENTATION PLANS (SIPs) 23
Designation of Non-Attainment Areas 23
Review of New and Modified Sources 24
National Ambient Air Quality Standard for Lead 25
Transportation Control Measures 25
Inspection/Maintenance 27
Indirect Source Review . . - 28
Emergency Episode Reporting 29
Permit Fee Regulations 29
V. INTERGOVERNMENTAL RELATIONS 30
Federal Support of State and Local Programs 30
Interagency Cooperation 37
International Collaboration in Control 39
VI. CONTROL OF STATIONARY SOURCES 42
New Source Performance Standards 42
National Emission Standards for Hazardous Air
Pollutants (NESHAP) 52
Development of New and Improved Air Pollution Control
Techniques for Stationary Sources 52
VII. CONTROL OF MOBILE SOURCE EMISSIONS 59
Introduction 59
Measures Taken to Implement Mandated Title II
Emission Standards 59
Motor Vehicle Emission Regulations-Actions Taken in 1977 . 65
Emissions from Vehicles in Use 68
Assessment of Mobile Source Technology 70
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CONTENTS (continued)
VIII. RESEARCH IN MONITORING INSTRUMENTATION AND QUALITY
ASSURANCE ' ". 75
Monitoring Developments 75
Quality Assurance 77
Federal Reference and Equivalent Methods 78
IX. ENFORCEMENT 81
Stationary Source Enforcement 81
Mobile Source Enforcement 94
The List of Violating Facilities 102
Compliance by Federal Facilities 102
X. LITIGATION IN 1977 104
Prevention of Significant Deterioration 104
Timeliness of Challenges to EPA Regulations 104
Hazardous Air Pollutants 105
Transportation Control Measures 105
Pre-Enforcement Review '...-.• 106
Tall Stacks and Supplementary Control Systems 106
Use of Modeling in the Promulgation of SIPs 107
References 108
11
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LIST OF TABLES
Table Page
*v
II-1. Oxidant/Ozone Trends in the 90th Percentile of the
Annual Hourly Observations 1970-1976 10
V-l. Types of State and Local Organizations Receiving
Federal Funds 31
V-2. State and Local Control Agencies Estimated 1975, 1976,
and 1977 Expenditures 32
V-3. Estimated Man-Years of Effort Employed by State and
Local Air Pollution Control Agencies 34
V-4. Estimated Distribution of Resources Devoted to Air
Pollution Control Activities of National Priority
by State and Local Agencies in FYs 75-77 35
V-5. Attendance at Short-Term Technical Training Courses
and Workshops 36
VI-1. New Source Performance Standards 43
VI-2. Status ;of Section 111 Regulations 44
VI-3. Control Techniques Guidelines for Volatile Organic
Compounds Issued in -1977 and Scheduled to be
Issued 50
VII-1. Emission Standards for Motor Vehicle Classes (Light
Duty Passenger and Trucks) 60
VII-2. Emission Standards for Motor Vehicle Classes (Heavy
Duty Trucks and Motorcycles) 61
VII-3. Mean Emission (G/MI) and Percentage of Vehicles
Failing to Meet Standards, by Test Point and
Pollutant 69
VII1-1. Stationary Source Measurement Methods 76
VIII-2. Ambient Air Quality Measurement Methods 78
VIII-3. List of Reference and Equivalent Methods Established
or Revised in FY 1977 79
IX-1. Compliance Status of Major Emitters (by EPA Region). 83
IX-2. Delegation of NESHAP and NSPS Authority to State
and Local Governments 92
111
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LIST OF FIGURES
Figure Page
IX-1. Enforcement Actions Initiated by EPA Regional Offices . 84
IX-2. Enforcement Actions Initiated by States 85
IX-3. Inspections Conducted by EPA Regional Offices 86
IX-4. State Conducted Inspections 87
1v
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PREFACE
The Clean Air Act, as amended, authorizes a national program of air
pollution research, regulation, and enforcement activities. This program
is directed at the Federal level by the U.S. Environmental Protection Agency
(EPA). However, primary responsibility for the prevention and control of
air pollution at its source continues to rest with state and local govern-
ments. EPA's role is to conduct research and development programs, set
national goals (via standards and regulations), provide technical and
financial assistance to the states, and, where necessary, supplement state
implementation programs.
Section 313 of the Clean Air Act requires the Administrator to report
yearly on measures taken toward implementing the purpose and intent of the
Act. This report covers the period January 1 to December 31, 1977, and
describes the issues involved in the prevention and control of air pollution
and the major elements of progress toward that goal that have been made since
the last report. In addition, this report also includes two other EPA
reports to Congress required under the Clean Air Act, as amended:
1. Section 202 report on measures taken in relation to motor vehicle
emission control (Chapter VII); and
2. Section 306(e) report on Federal procurement and violating facilities
(in Chapter IX).
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I. INTRODUCTION AND SUMMARY
AIR QUALITY TRENDS
In many areas of the country the general downward trend in total
suspended particulate (TSP) levels tn the early 1970s was followed by an
upturn in 1976. In many cases these increases can be attributed to
meteorological conditions.
National trends for sulfur dioxide ISOgJ are stable now, compared to
the downward trend of the early 1970s; violations of the SOo standard are
generally confined to the areas around a few specific sources.
The nationwide data base for monitoring carbon monoxide (CO) continued
to expand in 1976. Over half of the 1975 sites showed improvement in 1976.
Photochemical oxidants (0Y) are one of the most serious air pollution
A
problems in the country. California monitoring sites are nearly equally
distributed between increased oxidant levels, reduced oxidant levels, and
no change; sites in other states have a slightly greater tendency towards
increasing levels.
Except for the California sites, nitrogen dioxide (NOo) monitoring
sites showed almost twice as many sites with up than down patterns (145
to 77). These sites, however, had only three years of data so long-range
trends cannot be shown. Uf the 42 California sites, 19 showed decreases
and 19 showed increases in N02 concentrations.
The Standing Air Monitoring Work Group (SAMWG) continued its evalua-
tion of ambient air monitoring requirements. The major recommendations
included:
1. a network of State and Local Air Monitoring Stations (SLAMS)
determined by state and local air pollution control agencies to
meet tneir needs.
2. a small core of National Air Quality Trend Stations (NAQTS) to
meet national needs for air quality trend and SIP evaluations.
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3. a plan for Special Purpose Monitoring (SPM) to augment data from
NAQTS and SLAMS.
DEVELOPMENT OF AIR QUALITY CRITERIA AND STANDARDS ..
Air quality criteria documents were issued for particulate matter,
sulfur oxides, hydrocarbons, photochemical oxidants, carbon monoxide, and
nitrogen oxides from 1969 to 1971; primary and secondary standards for
these pollutants were established on April 30, 1971. In December, 1977,
EPA proposed a national ambient air quality standard for lead.
EPA has continued to support research which provides a current basis
of revaluation of the present criteria and ambient air quality standards.
The health effects research program includes studies in four areas: criteria
pollutants, non-criteria pollutants, transportation-related pollutants, and
non-pesticide organic and inorganic substances found in the air.
Research on ecological effects have focused on the effects of S02 on
crop yields; the effects of acid rain; the synergistic effects of sulfur
dioxide and ozone; and pnotochemical oxidants.
In September, 1977, EPA published the first draft of the updated Air
Quality Criteria for Photochemical Oxidants and Oxidant Precursors.
STATUS OF STATE IMPLEMENTATION PLANS (SIPs)
The Clean Air Act Amendments of 1977 require the states to designate
the attainment status of areas within their boundaries by December 5, 1977.
EPA must evaluate tnese designations and publish a list of area designations
by February 3, 1978.
A SIP revision must be submitted for nonattainment areas by January 1,
1979, and it must show attainment by December 31, 1982. An extension until
December 31, 1987, is possible for photochemical oxidants and caroon monoxide.
The 1977 Clean Air Act Amendments reinforce the December 21, 1976,
Interpretative Ruling on new source review. This ruling allows major sources
to locate or modify existing operations in non-attainment 'etreas but only
after restrictive emission controls have been applied and more .than equiva-
^
lent offsetting emission reductions from existing sources have been made.
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INTERGOVERNMENTAL RELATIONS
In 1977, 55 state and territorial agencies and 230 local agencies
expended approximately $174 million and over 7000 man-years to carry out the
major portions of the regulatory and enforcement aspects of the national
air pollution control effort. EPA provided financial assistance to 54
state agencies and 116 local agencies.
The Clean Air Act Amendments of 1977 require greater interagency
coordination, both between state, local, and Federal officials and between
EPA and other Federal agencies. In particular, close coordination is called
for between EPA and the Departments of Housing and Urban Development (HUD)
and Transportation (DOT). Federal land managers are also heavily involved
in the prevention of significant deterioration.
EPA continued its international environmental involvement in 1977.
EPA participated in international organizations such as the Economic
Commission for Europe, the Organization for Economic Cooperation and
Development, the World Health Organization, and NATO on .topics including
long-range transport, flue gas desulfurization and chlorofluorocarbon
emissions. EPA has also entered into bilateral air pollution projects
with Canada, Mexico, Japan, Germany, USSR, Egypt, Poland, and Yugoslavia.
CONTROL OF STATIONARY SOURCES
Through 1977, 83 new source performance standards have been published
for 22 source categories and 63 affected facilities.
A great deal of emphasis in 1977 was given to the preparation of
guidance materials which reflect reasonable available control technology
(RACT) for volatile organic chemicals.
Amendments to both the vinyl chloride and asbestos NESHAPS were
prepared in 1977 and benzene was listed as a hazardous pollutant.
Research efforts for improved air pollution control techniques have
emphasized flue gas desulfurization, both regenerable and nonregenerable
systems; other systems to reduce SO emissions, including the fluidized
A
bed combustion process; combustion modification for control of NO emis-
^\
sions; and fine particulate control.
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CONTROL OF MOBILE SOURCE EMISSIONS
The major element of the program for the control of motor vehicle
emissions is EPA's Federal Motor Vehicle Control Program (FMVCP). During
1977 EPA tested for certification the 1978 model year vehicles. This
required testing vehicles from 50 manufacturers and involved conducting
2200 emission tests. EPA also tested approximately 900 vehicles to
determine their fuel economy rates.
EPA promulgated regulations prescribing more stringent gaseous emis-
sion standards for heavy-duty gasoline and diesel-powered vehicles for the
1979 and later model years. Standards for motorcycle emissions of hydro-
carbons and carbon monoxide were published in January, 1977.
The Restorative Maintenance Evaluation Project, designed to determine
why many in-use automobiles do not meet emission standards, was completed
in 1977. The project indicated that idle mixture maladjustments are
largely responsible for failure to meet the hydrocarbon and caroon monoxide
standards, and that improved emission performance does not harm fuel
economy.
Three-way catalyst systems have begun appearing on certified vehicles
in growing quantities and appear to be the systems considered most seriously
for future applications. All-electronic control systems for future automo-
biles is another area of accelerated research.
RESEARCH IN MONITORING INSTRUMENTATION AND QUALITY ASSURANCE
Reference methods pertaining to new source performance standards were
revised on August 18, 1977. Methods and instrumentation were developed to
measure emissions of polychlorinated biphenyls (PCBs), hydrogen sulfides,
fluorides, as well as other pollutants. For mobile sources, a reference
procedure capable of measuring individual hydrocarbons in diesel-powered
vehicle emissions' was developed, as well as-improvement of procedures for
measuring hydrogen cyanide. Ambient measuring methods were developed in
1977 for lead, PCBs, ozone, and asbestos.
A five-year quality assurance plan was published in July, 1977.
A new Federal reference method for N02 was promulgated on December 1,
1976. A short-term continuous NO- standard measurement method was also
developed.
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ENFORCEMENT
X
Stationary Source Enforcement
Enforcement of standards at stationary sources has focused on the 23,000
major emitters which account for about 85 percent of all air pollution from
stationary sources. As of October, 1977, over 20,000 were operating in
final compliance and nearly 1,300 more were on enforceable compliance
schedules or orders, representing a compliance level of 94 percent.
From October 1, 1976, to September 30, 1977, EPA conducted over
2,300 plant inspections and 662 formal enforcement actions; the states
were responsible for 26,000 field inspections and the initiation of
over 15,600 enforcement actions.
Despite this enforcement activity, more than 1,200 major sources
remain in violation of emission standards or compliance schedules.
Mobile Source Enforcement
EPA conducted 85 inspections and investigations of auto manufacturers
and 71 investigations of tampering with vehicle emission control systems
which resulted in 34 prosecution referrals. As a result of EPA investiga-
*
tions, manufacturers have initiated recalls of 5.6 million vehicles. There
were 40 investigations of alleged illegal importations.
In FY 1977, there were 29,847 service station inspections for lead
content in fuels. As a result, 747 complaints were filed and $226,865
in civil penalties were assessed.
The List of Violating Facilities
Consent agreements were reached with three facilities in 1977 after
the process of designating them as violating facilities ineligible for
Federal contracts was begun. These facilities were Kaiser Steel Corpora-
tion, Fontana, California; U.S. Steel South Works, Chicago; and Interlake
Steel, Chicago.
Compliance by Federal Facilities
As of November 1, 1977, 68 (17 percent) of the 393 major Federal
facilities were out of compliance with emission limitations. Forty-
five of these non-complying facilities are on approved compliance
schedules.
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LITIGATION IN 1977
Decisions are pending on the use of dispersion techniques as opposed
to constant controls systems, on the legality of EPA regulations requiring
states to implement measures to reduce air pollution from private vehicles
using public roads and on the use of air quality dispersion modeling as a
basis for regulation.
Among the important court decisions in 1977 was a decision by the
U.S. Court of Appeals for the Second Circuit that a state and its sub-
divisions can be required to implement transportation control measures
<
in a SIP, at least when the measures had been adopted by the state itself.
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II. AIR QUALITY TRENDS
AIR QUALITY TRENDS
Total Suspended Particulate (TSP)
During the 1970s there has been nationwide improvement in TSP concen-
trations. Many areas continued to improve in 1976. Of the TSP trend,sites
with complete 1975 and 1976 data, 54 percent of the sites that were above
the primary TSP standard in 1975 continued to show improvement in 1976..
The general pattern for 1970-1976 shows stability for the lower con-
centration sites and more pronounced improvement for the higher concentra-
tion sites. During this time period the overall rate of improvement was
slightly less than four .percent per year with more marked improvement in
the Northeast and Great Lake regions.
There was fairly consistent improvement from 1970 to 1976 with 72
percent of the sites having decreases in ambient TSP levels. Because a>r
pollution control strategies are designed to reduce levels at locations
exceeding the National Ambient Air Quality Standards, more pronounced
improvement would be expected for the sites with higher concentrations.
For those sites with 1970-1973 averages above the annual primary standard,
81 percent showed improvement.
Although all areas had improved TSP levels in the 1970-76 time period,
trends in the western areas of the country were generally less pronounced.
In many cases this geographical variation is attributable to a difference
in the nature of TSP problems. Windblown dust is an important component
of TSP levels in the West and is more difficult to control than emissions
from traditional sources.
The general downward trend in TSP levels in the early 1970s was fol-
lowed by a reversal in 1976 in many areas of the country. Based upon
changes between comparable quarters in 1975 and 1976 for these TSP trend
sites, 53 percent of these comparisons showed increases. Over half the
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states had more increases than decreases between 1975 and 1976. There
^ •
were distinct geographical differences—the Southeast, Midwest, and toest
generally recorded increases.
The widespread pattern of these increases suggests that some common
factor was involved. Because no general increases in particulate emissions
throughout these areas occurred in 1976 and there were no widespread changes
in sailing methodology, meteorological conditions would be the likely can-
didate for explaining these increases. Many state agencies ranging from the
Midwest to Washington and California have cited meteorology as the main
reason for-these TSP increases in 1976. Large areas of the country ex-
perienced drought during 1976 and these extremely dry soil conditions
increase the likelihood of wind blown dust contributing to ambient TSP
levels. Dry soil conditions did, in fact, exist in these general areas
that had TSP increases.
Sulfur Dioxide (SO?)
The entire sulfur dioxide picture has changed in the 1970s. The early
1970s saw dramatic decreases in ambient sulfur dioxide levels in the nation's
urbanized areas. Since then the national trends have been much more stable
and violations of the sulfur dioxide standard are generally confined to
local areas around specific sources.
In comparing changes between 1970-1973 and 1974-1976, 64 percent of the
sites remained below 26 ug/m3 throughout. For the other sites, 51 percent
showed improvement and 23 percent reported increases. In contrast to TSP,
levels between 1975 and 1976 are relatively stable with 11 percent of the
sites increasing, 12 percent decreasing, and 76 percent either showing no
3
change or remaining below 26 ug/m .
As in the case of TSP, meteorology is likely to have an effect on
short-term changes. For sulfur dioxide, heating degree days are an
important meteorological parameter and reflect fuel usage for space
heating. Therefore, short-term increases may be due to changes in emis-
sions associated with varying meteorology. This type of effect was seen
in Minnesota where fall quarter sulfur dioxide levels in 1976 were 17
percent higher than the corresponding quarterly averages for 1973-1975; at
the same time, heating degree days increased 23 percent due to colder weather,
8
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Urban sulfur dioxide levels have traditionally been higher in the
Northeast and Great Lakes areas due to emissions associated with space
heating. However, New England had no violations of the sulfur dioxide
standards in 1976. In Michigan, only four counties-reported violations
of the sulfur dioxide standards. In Illinois, 1976 was the first year
in the history of the Illinois E>A that no site violated the sulfur
dioxide annual primary standard.
The general improvement in sulfur dioxide levels is indicative of
trends in urban areas. At the present time, the remaining problem with
attainment of the sulfur dioxide standard is primarily associated with
specific sources impacting their surrounding areas. The EPA has not yet
taken action to control ambient sulfate levels or acid rain.
Carbon Monoxide (CO)
There has been general improvement in carbon monoxide levels through
1976. The historical data base for CO is very limited compared to TSP
and sulfur dioxide. However, the nationwide data base continues to ex-
pand as a result of the increased monitoring activities of state and
local agencies during the 1970s.' For example, in 1975, 102 sites had
three or more years of data while 202 sites met the criteria in 1976.
California, with its well established monitoring program, remains the
major contributor to the CO data base with 59 sites qualifying as
trends sites.
During the 1970-1976 period, approximately three-fourths of the CO
sites showed improvement. In comparing 1975 and 1976 values, 52 percent
of the sites showed improvement, 39 percent had increases, and 9 percent
were unchanged. Forty-nine percent of the sites reported their all time
low value in 1976.
Photochemical Oxidants (Oj
^
Photochemical oxidants are one of the most serious and pervasive air
pollution problems in the country. In 1975 86 percent (356 of 416) of
the oxidant sites reporting to the National Aerometric Data Bank exceeded
o
the National Ambient Air Quality Standard (NAAQS) of 160 ug/m not to be
exceeded more than one hour per year.
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The amount of oxidant trend data available remains limited for most
areas due to the absence of data prior to 1972 or 1973. The overall data
picture is getting better with the number of trend sites steadily increasing
nationwide.
For example, last year there were about 20 trend sites outside of
California; there are now 112 sites meeting EPA criteria. In total, 174
sites representing 34 states qualified for the trend analysis - 62 of these
in California together with the 112 sites in other states. Almost one-half
of the California sites were located in the immediate Los Angeles (15 sites)
and San Francisco (8 sites) metropolitan areas.
Table II-l shows the distribution of 3 categories of trend direction
(down, no change, up) by California and other state sites. The overall
picture obtained from the California sites is one of a steady unchanging
pattern of oxidant concentrations from 1970-1976. The sites outside
California show a little more tendency for increasing patterns—55 sites
with "up" patterns and 46 sites with "down" patterns. Eleven sites showed
"no change" patterns. For the most part, these sites represent only three
years of data. Therefore, assessing the significance of these patterns
is difficult.
Table II-l. OXIDANT/OZONE TRENDS IN THE 90th PERCENTILE OF THE ANNUAL
HOURLY OBSERVATIONS 1970-76
Direction
of Trend
Down
No Change
Up
Total
California
Sites
24
16
22
62
( 39%)
( 26%)
( 35%)
(100%)
Other State
Sites
46
11
55
112
( 41%)
( 10%)
( 49%)
(100%)
Total
70
27
77
174
( 40%)
( 16%)
( 44%)
(100%)
Nitrogen Dioxide (N00)
•«KBBB__>^Bw^_v«_v*^B«i^Mm_MB^v._£
Trends in the annual mean concentrations of nitrogen dioxide are avail-
able for 276 sites throughout the country for the period 1970-1976. Forty-
two of these sites were located in California.
10
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Among the 42 California sites, 19 showed decreases and 19 reflected
increases in concentration. Other states, however, show almost twice as
many sites (145 to 77) with up then down patterns. Most of these sites
(228 out of the 234), however, had only three years, of data so that it is
impossible now to draw any definite conclusions from these findings.
AIR MONITORING STRATEGY
In September, 1977, EPA published the final report, "Air Monitoring
Strategy for State Implementation Plans," which was prepared by the Standing
Air Monitoring Work Group (SAMWG), composed of EPA and state and local
control agency personnel. The SAMWG identified several areas where
monitoring deficiencies exist. The major areas of concern included:
(1) In some cases, more monitoring stations are being reported to the
national data bank than are necessary.
(2) Existing regulations do not allow states sufficient flexibility
for short term studies.
(3) Resource constraints and diversity of data needs frequently result
in untimely or incomplete reporting of air quality data.
(4) Lack of uniformity in station location and probe siting, sampling
methodology, quality assurance practices and data handling pro-
cedures have resulted in data of unknown quality and comparability.
The SAMWG prepared a set of recommendations which are being adopted by
EPA. The recommendations include:
(1) An expanded quality assurance program.
(2) A modification to existing monitoring regulations to provide for:
a. A carefully planned network of State and Local Air Monitoring
Stations (SLAMS) whose size and distribution is largely
determined by the needs of state and local air pollution
control agencies.
b. A small but well-defined core of National Air Quality Trend
Stations (NAQTS) to minimally meet national needs for trend
and SIP evaluations.
c. A plan for Special Purpose Monitoring (SPM) tailored to augment
data from NAQTS and SLAMS.
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(3) A revision to existing ambient reporting regulations which
would limit the data being submitted to the National Air Data
Bank to that which is necessary for national assessment of
trends and development and evaluation of national control
policies.
During FY 1978 the EPA Regional Offices and the states will cooperatively
develop state plans for implementing SAMWG's major ambient air monitoring
recommendations. Since some agencies will require significant changes
in their air quality surveillance activities, full implementation of the
above accomplishments may require 3-5 years.
New requirements of the Clean Air Act are also being added to the
ambient monitoring regulations which will require the states to report
to the public on the daily air quality in all major urban areas through
the use of uniform air quality criteria and methodology and a uniform
air quality index. The revised regulation's proposed index is the
Pollutant Standards Index which was developed through the efforts of
the Federal Task Force on Air Quality Indicators.
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III. DEVELOPMENT OF AIR QUALITY CRITERIA AND STANDARDS
INTRODUCTION
Air quality criteria documents were issued for particulate matter,
sulfur oxides, hydrocarbons, photochemical oxidants, carbon monoxide, and
nitrogen oxides in the period from January, 1969, through January, 1971.
On April 30, 1971, subsequent to issuance of the criteria, EPA established
primary and secondary National Ambient Air Quality Standards (NAAQS) for
these pollutants.
On September 14, 1973, EPA revised the standards by revoking the annual
secondary standard for sulfur dioxide and revising the Air Quality Criteria
for Sulfur Oxides. The maximum 24-hour concentration published as a guide
for implementation plan development purposes was deleted. EPA also pro-
posed an ambient standard for lead in December, 1977.
These revisions have been the only changes to the Federal criteria and
standards to date. Reevaluation of the criteria and the NAAQS was mandated
by the 1977 Clean Air Act Amendments, and EPA has developed a schedule for
complying with this requirement. The 1977 Clean Air Act Amendments require
EPA to set a short-term N02 standard, if warranted, by August 8, 1978.
HEALTH EFFECTS RESEARCH
Research Approach
Research on health effects is fundamental to the Agency's responsi-
bility and ability to develop criteria and to promulgate and enforce stand-
ards and guidelines. EPA health effects research is specifically designed
to identify pollutants which may pose a risk to health, to quantify the
relationship between exposure to those pollutants and their effects on
health, and to document the benefits of reducing or eliminating human
exposure through pollution control.
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In the health effects research program, data bases are developed for
determining whether restricting exposure to particular pollutants is neces-
sary to protect public health and, if so, to what degree exposure should be
restricted. To do this, a combination of research approaches is used:
toxicological studies which utilize animal models, controlled human studies,
and epidemiological studies of human populations in their actual environ-
mental settings. Each of these study areas provides an important set of
data to assess possible adverse health effects that might result if humans
are exposed to air pollutants.
In the toxicologic studies, animals are exposed to both high and low .
concentrations of selected pollutants and combinations of; pollutants under
various experimental conditions. These results provide indications of
whether there is likely to be an acute and/or chronic adverse effect if
people are exposed to the pollutants. The laboratories use and are
developing new rapid and less expensive screening techniques to identify
those compounds that are important candidates for whole animal toxicologic
studies.
For those pollutants that can be tested on human subjects (the Agency
has been and continues to be extremely conservative in any human testing
programs), the toxicologic results are used to help design the human
studies. The toxicologic studies will indicate how, where, and at what
concentrations humans are likely to show responses to the pollutant exposure
With the toxicologic and controlled human studies, dose-response curves can
be constructed that are important for establishing safe ambient air levels
of human exposure to the pollutant(s) under study.
The epidemiologic study area provides important data for health
effects-based air standards. Here, real world data are obtained, whereas
in the laboratory real world conditions are only simulated. However, the
many compounding variables such as smoking, occupation and diet present in
the real world make the results obtained from epidemiologic studies semi-
quantitative at best. By having good toxicologic. and controlled human
exposure health effects data, the epideraiologic studies can be designed to
focus on those biological indicators that are sensitive to variations in
the concentration of the pollutant of interest.
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The health effects research program is divided into four pollutant
areas: studies on criteria pollutants, non-criteria pollutants, pollutants
associated with transportation activities, and non-pesticide organic and
inorganic substances found in air.
Criteria Pollutants
Criteria pollutants are those for which. National Ambient Air Quality
Standards (NAAQS) have been set under §109 or have been listed under §108:
carbon monoxide (CO), sulfur dioxide (S02)» nitrogen dioxide (NOo),
particulates (TSP), hydrocarbons (HC), photochemical oxidants (0 ), and
rt
lead (Pb). The Agency is continuing to obtain health effects information
on these pollutants in several areas, such as exposure averaging times
(i.e., short-term, high-concentration exposure versus long-term, low-level
exposure), the adequacy of existing safety margins, the health benefits
of meeting the standards, and the health risks of exceeding the standards.
Thus, the research in this area is basically directed toward expanding the
health data base for those pollutants for which NAAQS have been promulgated
and refining the criteria on which those standards are based.
Recent investigations indicate that exposure to 1200 ug/m (0.6 ppm)
ozone for 2 hours, coupled with moderate exercise, produces significant
pulmonary complaints as well as significant decrements in pulmonary functions.
Most subjects exposed to ozone complained of cough, substernal chest pain,
shortness of breath, and a decreased ability to maximally inspire. A few
subjects continued with symptoms several hours post-exposure.
Animal toxicologic studies were conducted on N0~ to evaluate whether
the mode of exposure might play an important role in the toxicological
effect of NO-. Investigators used continuous and intermittent animal
exposure studies to determine the relationship between biological response
and length of exposure to various concentrations of N02- When a constant
dose level was employed, exposure to a high concentration administered over
a short period produced a greater effect than exposure to a lower concentra-
tion administered over a longer period. Results of these studies indicate
that the frequency and amplitude of short-term peaks are of significance
even though the exposure is interrupted with periods of zero concentration
of N02.
In the area of carbon monoxide health effects all projected tasks
dealing with human behavior have been completed and performance data
15
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analyzed. These EPA studies were factored into a comprehensive literature
review and critique indicating ambient CO concentrations do not significantly
impair human behavior and task performance.
The Dallas Traffic Study, designed to determine- the relationship
between automobile traffic density and the body burden of lead and to
determine the effects of varying traffic conditions on air lead levels,
is completed. Statistically significant relationships between traffic
density and airborne lead levels were observed. (Additional discussion
of research dealing with lead is included in the section on inorganic
and organic substances below.)
Non-Criteria Pollutants
Non-criteria pollutants are those for which no NAAQS have been
established. Health effects research is also directed toward developing
data on these pollutants, e.g., sulfates, nitrates, and respirable particu-
lates. Some existing evidence associates these pollutants with harmful
effects on human health. Questions being posed in this regard include
determination of exposure-response relationships for these pollutants, both
by themselves and in combination with other pollutants. Most of the researcn
effort has focused on sulfates.
This work includes developing and obtaining data from oiological
screening systems, determining the metabolic pathways and target organs,
understanding responses and mechanisms, and establishing dose-response
data. Within each area, consideration was given-to the various sulfate
compounds and their relative toxicities, cation-anion relationships •
(positively and negatively charged ions), compound physical characteristics
such as size and bioavailability, concentration and time duration of exposure,
and combined or synergistic effects with other pollutants.
Tentative results indicate that the cation is an important contributor
to compound toxic effects because the cation may enhance the absorption of
the sulfate ion into the cells of the lung. Other data indicate that the
irritant effects of sulfuric acid are associated with the submicron sulfuric
acid particles. Further data indicate that the deposition location of
sulfuric acid in the lungs is similar to that region of the lung where
irritation from deposited material results in coughing, bronchitis, and
asthma.
16
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A series of animal toxicology projects studied the effects of the
sulfuric acid (H2$04) alone and in combination with other substances on the
host's defense mechanism. Combinations were studied because they sometimes
have additive or synergistic adverse health effects .worse than might be
predicted from the study of either substance alone.
Animals exposed sequentially to ozone (03) and H^O^ and then to an
aerosol of micro-organisms suffered an increase in mortality although
neither pollutant alone caused an increase. Long-term exposure to H2S04
adsorbed onto carbon resulted in increased susceptibility to infectious
disease. In a study aimed at understanding carcinogenic effects, lung
tissue exposed to S02 in combination with benzo(a)pyrene (a hydrocarbon)
showed that benzo(a)pyrene changed to end-products which differed from those
found when lung tissue was exposed to benzo(a)pyrene alone. This result is
being pursued.
In-house studies on sulfuric acid aerosols evaluated the effects on
humans of a range of particle sizes and concentrations. Extramural work
extended the range of particles studied to provide a data base which more
closely resembles conditions found in the ambient air.
In support of obtaining accurate measurements of what the individual
study population subjects are exposed to, instrumentation for in situ sulfur
particulate measurement and species characterization was evaluated. The
fraction of respirable sulfates was determined by comparison of 24 hour
sulfate samples from high volume samplers with samples from the CHAMP
(Community Health Air Monitoring Program) respirable sampler. Human
exposure models are being developed for sulfates and other pollutants to
estimate the variability in exposure due to mobility and time spent
indoors and outdoors. Work is continuing to develop biological indices for
quantifying specific human health effects from exposure to sulfur-containing
atmospheric pollutants. Potential sites for sulfate epidemiological studies
are being reviewed to identify areas where sulfate levels and human health
effects can be quantitatively related.
When this groundwork is completed, the study populations will be
selected. Using biological indicators that are sensitive to sulfate pol-
lutant exposure, the epidemiologists will attempt to relate ambient sulfate
levels and adverse health effects, if there is any relationship.
17
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Transportation-Associated Pollutants
The purpose of the research program on transportation-associated pol-
lutants is to develop a comprehensive data base to evaluate the public
health consequences of non-regulated poliutants from mobile sources. The
principal effort in 1977 focused on sulfuric acid emissions from oxidative
catalyst control devices. Animal toxicologic studies were conducted to
develop information on the effects that were observed at various concentra-
tions of inhaled sulfuric acid. The effects studied included increased
susceptibility to pulmonary bacterial infection. Animals were also
exposed to dilute exhaust from a catalyst-equipped light duty engine.
The pulmonary effects of inhaled combinations of sulfuric acid and metal
sulfates were studied and sulfuric acid mist concentrations in the lung
were measured.
The second annual Catalyst Research Program Report was completed and
represents a comprehensive compilation of information obtained by the
research program on mooile source emissions. The work includes data on
emission characterization, atmospheric chemistry, and physics of mobile
emission products with consideration given to meteorology and other atmos-
pheric factors; air quality modeling; analytical instrumentation develop-
ment; animal toxicology; and human population effects. Pollutants of
concern include sulfuric acid, platinum, and palladium. The data obtained
is being provided to appropriate sectors of the Agency to indicate the
public health implications of non-regulated mobile source pollutants.
Inorganic and Organic Substances
Research is being conducted to determine the threat to human health
from exposure to heavy metals including lead, copper, zinc, and other
substances not classified as pesticides. An attempt is being made to
identify the population-at-risk and specific health effects. The present
empnasis of this program is to identify high exposure populations preceding
extensive nealth effects studies. This is being accomplished oy relating
the human body ourdens of inorganic metals to environmental exposure of
individuals living in areas of high traffic density or residing near lead,
copper, or zinc smelters.
IS
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An assessment of exposure-effects relationships is being made using
laboratory animals. These studies involve heavy metals or other nonpesti-
cide substances which have been identified as potentially harmful to human
health. Emphasis is on chronic, low-level exposure of animals through
several generations to assess the teratologic, reproductive, and behavioral
effects of the stresser. In addition, whole-oody retention, organ distri-
bution, and in vitro investigations complement these dose-effects studies.
TERRESTRIAL ECOLOGY EFFECTS OF AIR POLLUTION
With increased national dependence on fossil fuels, agricultural pro-
duction could suffer severe yield losses if air quality standards continue
to be established on tne basis of constant non-variable S02 concentration
experiments. Extensive and repeated experimentation on the yield response
of agricultural crops to non-variable S02 concentrations within the range
of 0 to 0.15 ppm showed no yield reduction. However, within the same
range of median concentrations (0-0.15 ppm) naturally varying season long
S02 exposures produced yield losses in excess of 50% in the most sensitive
species. These relationships of crop yield to a range of median S02
concentrations will be useful in (a) setting realistic air quality standards,
(b) developing regional air pollution diffusion models for predicting
environmental impact, and (c) assessing economic impact of S02 on a regional
or area basis as a prelude to establishing regional air quality standards.
In SO^ experiments using variable S02 concentration exposures, two
onion varieties (whice and yellow) were either severely stunted in growth
(less than 10% the weight of controls) or killed by'a median bO^ concentra-
tion of 0.15 ppm. Growth reductions of the two onion varieties were 40
ana 16% respectively, when exposed continuously during the full growth
period to a median S02 concentration of 0.08 ppm. Exposure to an atmos-
pnere with a median S02 concentration of 0.15 ppm reduced radish top and
root growth by 40 and 60% and alfalfa top and root growth Dy 30 and 60%,
respectively, compared to controls. Root and top growth of beet, a
resistant species, was not affected by exposure to the above S02 concen-
trations..
In further efforts to support the establishment of a long term (chronic)
secondary air quality standard, alfalfa plants were exposed to various
median concentrations of S02, (0, 0.02, 0.06, 0.15, 0.20, 0.30 ppm) for
68 days. The threshold for significant effects on growth and symoiotic
19
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nitrogen fixation was 0.02 ppm S02; at 0.06 ppm they were reduced 50 and
402 respectively and the reductions increased to 95 and 90% respectively
at a median S02 concentration of 0.3U ppm. Growth reductions were also
associated with significant increases in total sul.fur in the plant. These
results suggest that the present secondary air quality standard for SO,,
may not adequately protect public welfare.
On a strategy level, the above research will provide a basis for
establishing more realistic air quality standards for S02 which would
focus regulation activities on source strength rather than ground level
concentration. This possibility exists because median S02 concentration
in the ambient atmosphere is directly related to source strength and
median SOg concentration is also one of the best predictors of expected
crop yield losses.
Another major environmental problem associated with the increased
utilization of coal is the acidification of precipitation. Effects
research in this araa of concern is providing support for the development
of air pollution control strategies related to sulfate emissions. Controlled
field studies using pH values typical of rainfall acidities occurring and
expected in the U.S. are yielding preliminary significant results related
to soil litter decomposition, nutrient cycling and plant growth. Initiation
of expanded research on whole ecosystem effects of acid precipitation is
planned for FY 78.
Recent studies concerning interactive, synergistic effects of sulfur
dioxide (502) and ozone (0.) applied as gas mixtures at low concentration
levels nave demonstrated the need to reassess existing single pollutant
standards to more realistically reflect amDient air pollution stress'.
Alfalfa, broccoli, cabbage, radish, tomato, and tobacco plants were
exposed to 03 (0.05-0.1 ppm), S02 (0.1-0.5 ppm) or a combination of S02
and 03 for up to 4 hours and foliar necrosis was measured. Foliar injury
(percent leaf area injured) from exposure to U3 was generally less than
20%; from SO- exposures it was generally less than 10%. All combinations
of S02 and 03 caused foliar injury (5 to 60%) while many of the individual
concentrations of either S02 or 03 did not. Approximately 50% of the
interaction exposures caused more injury than would be expected from the
sum of the separate effects of S02 and 03.
In another experiment, alfalfa, radish, soybean, and tobacco plants
were exposed 4 to 6 weeks to 03 (0.05 ppm), S02 ^0.05 ppm) or a combination
20
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of SOo and 03 and yields (oven dry weight topsj were measured. Yield
reductions in the test species ranged from 0-50% for 03, 0-zO% for S02
and 0-55% for the combination of S02 and 03. The effects on radish and
soybean were additive while the effects on alfalfa-and tobacco were
greater than additive.
A major effort in terrestrial ecology during FY 77 resulted in a
significant contribution to the Agency's first draft of the updated Air
Quality criteria for Photochemical Oxidants and Oxidant Precursors, dated
September 1977. Scheduled for completion early in 1978, this document
includes two chapters related to vegetation and ecological effects of
photochemical oxidants. Also included are approximately 70 scientific
publication citations resulting from research conducted or supported by
the EPA research and development program in terrestrial ecology effects
of air pollution. Cited results on effects of .05 ppm 03, 5 hr/day for
68 days in reducing alfalfa growth (45%) and symbiotic nitrogen fixation
(40%) suggest that current secondary air quality standards may not
adequately protect public welfare.
In another study, ponderosa pine seedlings were exposed to ozone at
a concentration of 10 pphm 6h/day, 7 days/week for variable periods up to
22 weeks. Significant reductions were observed in stem (21.3%) and root
(26.3%} dry weight of plants exposed for full term. Measurements of
metabolic pools (amino acids, soluble sugars, starch and phenols) witnin
top and root tissue showed significant decreases in these metabolites, in
roots as early as 12 weeks following initiation of exposure. This evidence
suggests that ponderosa pine and other ozone sensitive tree species undergo
an invisiole reduction in vigor when exposed to chronic low levels of
photochemical oxidants. This pollution stress likely results in
predisposing affected trees to other natural environmental stresses
including insects, diseases, drought, and freeze injury.
Extended studies of biogenic emission rates of reactive hydrocaroons
from selected plant species suggest that vegetation may be a significant
source of photochemical oxidant precursors. Data from oak indicate that
during daylight hours isoprene production rates can range from 30-80
ug/dm2/hr. During mid-day hours, isoprene emissions from live oak were
o
extrapolated to be approximately 14.3 Kg/Km /hr.
2V
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Production of ethylene by plants under air pollution stress has
»
proven to be a sensitive bioassay (indicator) for evaluating the
•coxicity of various criteria and non-criteria pollutants. Pine,
eucalyptus, soybean, lupine, tomato, wheat, lily,-rhododendron, corn,
holly, and marigold were exposed to 02 (0.1-1.0 ppm), S02 (0.5-4 ppm),
S0« +• 03 and C12 (O.i-l.O ppm) for 2 hours. Measured increase in stress
ethylene production was 20-80%. The increase occurred before visual
injury, but was correlated with it. Stress ethylene measurements were
less, variable and more reproducible than foliar injury estimates.
22
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IV. STATUS OF STATE IMPLEMENTATION PLANS (SIPs)
DESIGNATION OF NONATTAINMENT AREAS
The Clean Air Act Amendments of 1977 were signed into law by President
Carter on August 7, 1977. They require that states designate the attain-
ment status of all areas within 120 days of the signing of the amendments.
EPA must then evaluate these state designations and publish a list of
area designations by February 3, 1978. Should EPA disagree with the state
on a designation, the state must be given an opportunity to refute any EPA
findings before the list is published.
This list is significant because of the state implementation plan
(SIP) requirements for nonattainment AQCRs. The designation as a non-
attainment area carries with it the requirement for submittal of a SIP
revision for that area by January 1, 1979, with the use of all reasonably
available control measures demonstrating that attainment will be achieved
by December 31, 1982. In the case of photochemical oxidants (Ox) and
carbon monoxide (CO), an extension up to December 31, 1987, is possible
if attainment by 1982 is demonstrated to be impossible and if certain
conditions are met. In addition, a nonattainment designation required
the application of the December 21, 1976, Interpretative Ruling on new
source review (emission offset policy) until July 1, 1979, for that area.
(See "Review of New and Modified Sources" following in this chapter.)
There are four possible designations for an area for the criteria
pollutants of total suspended particulates (TSP) and sulfur dioxide (SOg):
nonattainment of primary standards, nonattainment of secondary standards,
unclassifiable, and attainment. The "unclassifiable" designation is to be
used for those areas where insufficient data exists to permit a judgment
to be made. For carbon monoxide (CO), oxides of nitrogen (NOX) and hydro-
carbons (HC), the possible classifications are nonattainment of primary
standards, attainment, or unclassified.
23
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REVIEW OF NEW AND MODIFIED SOURCES
One of the major mechanisms available to control potential increases
in stationary source emissions is new source review (NSR). Through various
forms of NSR, states can control and/or condition-the location and amount
of pollutant emissions generated by new or modified industrial sources of
air pollution. Regulations generally take the form of both emission limi-
tations and ambient constraints. The latter involves safeguarding ambient
air quality standards—both the primary and secondary NAAQS and the air
quality increments established to prevent significant deterioration of air
quality (PSD). Many of these review programs are implemented by different
agencies.
Sources subject to these regulations are required to obtain approval
prior to construction. Upon application, the reviewing agency is required
to conduct an extensive analysis of the meteorology, topography, indus-
trial process, and pollutant characteristics of each major source. From
this analysis, predictions can be made of the potential impact that the
proposed source may have on local, and in some cases distant, air quality.
SIP new source review regulations require disapproval of any new or
modified air pollution sources which would either fail to meet an emission
limit or interfere with attainment and maintenance of the NAAQS. All but
five states now have regulations completely approved as part of their SIPs
to conduct preconstruction NAAQS reviews for new sources. However, since
the NAAQS attainment date (1975) has passed without attainment, some ques-
tions arose in 1976 concerning the legality of any new source construction
in such nonattainment areas.
EPA published a formal interpretation of Section 110 of the Clean Air
Act on December 21, 1976, to allow major point sources to locate or modify
existing operations in non-attainment areas but only after restrictive
emission controls have been applied and more than equivalent offsetting
emission reductions from existing sources have been made in order to
accomplish reasonable progress toward attainment.
The Clean Air Act Amendments of 1977 indicated that the December 21,
1976, Interpretative Ruling (with certain modifications) remains in
effect until the states submit and EPA approves an implementation plan
revision which meets the new requirements of Part D of the Act. The
modifications to the Interpretative Ruling will be proposed in early 1978.
24
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The 1977 Amendments did, however, provide a waiver to the Interpreta-
tive Ruling. To date only Texas has requested a waiver from the offset
requirements. However, on or after July, 1979, approval of new or modified
sources may be granted only if the permits are in conformity with the 1977
Amendments.
The 1977 Amendments also made changes with respect to the Agency's
prevention of significant deterioration (PSD) regulations. The new statu-
tory strategy, which is generally more comprehensive and restrictive than
EPA's regulatory program, was not to be fully effective until the state
and/or EPA undertake further rulemaking activities. Such rulemaking
activities began with a proposal on November 3, 1977, to change the
Agency's current regulations regarding PSD and to establish requirements
for the preparation, adoption and submittal of State Implementation Plans
for PSD. Public comments have been requested on the proposed regulations
and a final promulgation is expected by March of 1978.
NATIONAL AMBIENT AIR QUALITY STANDARD FOR LEAD
EPA proposed a national ambient air quality standard for lead in
December, 1977, under authority of Section 109 of the Clean Air Act
pursuant to a court order in NRDC et al vs Train.
Lead exposure is not solely through air but through a combination of
sources including food and water. The aggregate contribution of lead from
all these sources poses a significant threat to health. EPA had previously
determined that the most appropriate approach to controlling airborne lead
was reduction of lead in gasoline via Section 211 of the Clean Air Act and
control of selected stationary sources under Section 111 of the Act. Even
though this strategy was being implemented, the Court decision on March 1,
1976, in NRDC et al vs Train required EPA to list lead as a criteria pollu-
tant in accordance with Section 108 of the Act. The criteria document and
the proposed standard were issued in December, 1977.
TRANSPORTATION CONTROL MEASURES
The Clean Air Act, as amended, specifically requires the use of
transportation control measures where necessary to meet national ambient
25
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air quality standards for carbon monoxide and photochemical oxidants. EPA
has approved or promulgated transportation control plans in 31 demonstrably
deficient areas; 9 additional areas are developing transportation control
plans as a result of more recent air quality data.
Although no entire transportation control plan has been implemented
to date, many metropolitan areas have made good faith efforts to adopt and
implement transportation control measures. These measures include both
transportation control strategies, such as inspection/maintenance, transit
improvements, employer incentives, traffic management/restraints, and
parking management/restrictions, and stationary source control measures
such as vapor recovery for gasoline marketing.
Some of the problems associated with transportation control planning
should be remedied by the Clean Air Act Amendments of 1977. The amend-
ments call for publication of a number of information documents related
to transportation control strategies. EPA has begun compiling these docu-
ments which will analyze the environmental, energy, and economic impact
of various transportation control, strategies and, thus, should be of great
help to state and local governments as they develop their new or revised
state implementation plans. In addition,'the amended Act calls for the
publication of planning process guidelines which will aid state and local
officials in developing necessary institutional arrangements so that inte-
grated transportation/air quality planning procedures may evolve. Finally,
the Clean Air Act Amendments authorize appropriate financial and program-
matic sanctions which can be used against states who are not following
their implementation plans.
In spite of the problems hindering the implementation of transporta-
tion control plans, progress has been made in implementing individual
transportation control measures. For example, five California cities as
well as Portland, Oregon and Seattle, Washington are developing parking
management plans. Commuter parking restrictions have been successfully
implemented in Washington, D. C. and Arlington, Virginia. 'Several cities,
such as Philadelphia, Washington, D.C., Los Angeles, and San Francisco,
have inaugurated new bus lanes or priority bus/carpool lanes to provide
better mass transit service, while other cities, such as Newark and
Seattle, are instituting "parking freeze areas" to discourage the use of
automobiles in center city areas. Still other cities, such as San Diego,
26
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are well advanced toward full implementation of gasoline recovery regula-
tions. In areas where employer mass transit incentive regulations are in
effect, numerous large industries, have submitted information describing
their plans for reducing single occupancy auto commuter trips by their
employees. Finally, transportation control plans have been developed for
several Texas cities.
INSPECTION/MAINTENANCE
Inspection/maintenance (I/M) programs require the testing of motor
vehicle emissions with respect to certain standards and the subsequent
maintenance and retest of vehicles that fall.
State legislative activity on I/M has increased in 1977. Colorado
passed a bill requiring inspection of all 1977 and later model year
vehicles of gross vehicle weight (GVW) of 8500 pounds or less in 9 "Front
Range" counties, including Denver and other major cities. Testing is to
begin on January 1, 1980. Nevada passed a mandatory I/M bill for Clark
County (Las Vegas) and Washoe County (Reno). There currently is an I/M
program in Clark County for vehicles undergoing change of ownership. The
new legislation expands this program to fully mandatory I/M by July 1,
1979, in both counties.
Additional legislative efforts in other states are expected in 1978,
such as Connecticut, Kentucky and Minnesota. In addition, Missouri and
other states will likely consider I/M systems appropriate for their
jurisdictions.
Rhode Island was expected to start implementing a private garage-
based program in November, 1977. Inspections will be required while main-
tenance will be voluntary until January, 1979, when maintenance will be
mandatory also.
California made a significant step toward mandatory I/M for the entire
six-county Los Angeles metropolitan area. On June 30, 1977, the state
awarded a contract to Hamilton Test Systems of Windsor Locks, Connecticut
to run a change-of-ownership I/M system. Testing is scheduled to begin
on January 1, 1979.
Following a November, 1976, statewide referendum approving the pro-
gram, Arizona implemented fully mandatory I/M in January, 1977. Maricopa
and Pima Counties, encompassing Phoenix and Tucscon and a majority of the
state's automobiles, are included.
27
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The passage of the Clean Air Act Amendments of 1977 could signal the
beginning of substantial new progress in the implementation of I/M programs.
The Act states that for nooattainment areas states have until December 31,
1982, to provide for the attainment and maintenance of the National Ambient
Air Quality Standards. States must submit State Implementation Plan (SIP)
revisions by January 1, 1979, which accomplish this goal. If attainment
of Ox and CO standards cannot be reached in 1982, states may have an exten-
sion to December 31, 1987, if they make a demonstration to that effect and
they include SIP revisions for the implementation of all reasonable mea-
sures including a schedule for the implementation of I/M. This Congressional
endorsement of I/M as a viable control strategy should do much to encour-
age the establishment of I/M programs.
INDIRECT SOURCE REVIEW
The Clean Air Act Amendments of 1977 clarify two issues concerning
indirect source review. An indirect source review program is defined as
facility-by-facility review of such sources. Review programs include
measures that are necessary to assure, or assist in assuring, that pollu-
tants emitted from mobile sources associated with the source do not result
in or contribute to air pollutant concentrations exceeding a national
ambient air quality standard.
The first issue affects the regulatory requirements for an indirect
source review (ISR) program as a part of a state implementation plan (SIP).
The Administrator may no longer require an indirect source review program
as a condition for approval of a plan. Although an indirect source-review
program is no longer a condition for approval of a SIP, a state may still
adopt and submit such a program to the EPA as part of its plan. Fourteen
states or territories currently have indirect source review programs
approved as a part of their SIPs.
The second issue dealt with by the amendments concerns the authority
of the Administrator to promulgate, implement and enforce indirect source
review regulations. This authority is applicable only to indirect sources
which are Federally assisted, owned or operated. The Administrator has
not made a decision to proceed with regulations and the rulemaking process
under this authority.
28
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EMERGENCY EPISODE REPORTING
The 1977 Amendments to the Clean Air Act will require the reporting
of the following information on emergency episodes in the annual report to
Congress:
1. The status of plan revisions providing for episode contingency
plans or providing for necessary legal authority to enforce
contingency plans.
2. An accounting of states failing to develop contingency plans.
3. The number of emergency episodes by location, date, pollution
source, and duration.
4. Contingency plan measures taken and an evaluation of their
effectiveness.
5. An accounting of any episodes during which no contingency
plan actions were taken-and an explanation of why no actions
were taken.
This information will be included in this report next year.
PERMIT FEE REGULATIONS
The newly amended Act also requires that owners of major stationary
sources will be required to pay fees sufficient to cover the costs of
reviewing any application for a permit.
Currently, only a few states collect fees for air pollution permits.
In many cases the program is a county or city function. The new permit
fee program will have to reflect the intent of the Act to cover reasonable
costs incurred by the states related to significant deterioration and **
visibility protection.
29
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V. INTERGOVERNMENTAL RELATIONS
FEDERAL SUPPORT OF STATE AND LOCAL PROGRAMS
Status of State, Interstate and Local Pollution Control Agencies Funding
The EPA administers and coordinates the Federal environmental programs
with state and local levels of government to assure the most effective
partnership arrangement for the solution of common environmental problems.
As part of the Federal, state and local government sharing of responsibil-
ity, the Federal government provides support through assignment of person-
nel , special contractual arrangements, and grants.
In 1977, 55 state and territorial agencies and 230 local agencies,
working in coordination with the states, expended approximately $174
million and 7270 man-years to carry out the national air pollution control
effort. Tables V-l and V-2 illustrate the extent of Federal support to
state and local agencies by organizational location of the agency within
the state and local governmental structures and by jurisdictional areas
served by these agencies. The figures show an increased level of total
expenditures with an increased state and local funding and expenditure of
monies by the various levels of government that resulted in a small .change
of man-years of effort.
Federal Financial Assistance to Air Pollution Control Agencies
In 1977 EPA provided financial assistance to 54 state agencies (all
except American Samoa) and 116 local agencies. In addition, 39 local
agencies received Federal monies through specified provisions of state
grants or special contractual assistance. The total expenditures of
these 209 agencies represented approximately 89 percent of all expendi-
tures for the 285 agencies having some air pollution control responsibil-
ities. The support provided to the agencies was in the form of grants
for planning, developing, establishing, improving or maintaining control
30
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Table V-l. TYPES OF STATE AND LOCAL ORGANIZATIONS RECEIVING FEDERAL FUNDS
Types of
Organizations
Environmental
Health
Air Pollution
Natural Resources
Other
.1
Total
1975
Total
43
132
94
7
15
291
No. receiving
Federal funds
State Local
22 13
17 87
6 52
7
2 10
54 162
No. operating
without
Federal funds
8
28
36
-
3
75
1976
Total
46
- 120
99
8
17
290
No. receiving
Federal funds
State Local
22 16
15 74
7 54
8
1 8
53 152
No. operating
without
Federal funds
8
31
38
-
8
85
1977
Total
49
110
106
8
12
285
No. receiving
Federal funds
State Local
23 18
16 71
5 63
8
2 2
54 152
No. operating
without
Federal funds
8
23
38
-
8
77 .
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Table V-2. STATE AND LOCAL CONTROL AGENCIES
ESTIMATED 1975, 1976 AND 1977 EXPENDITURES
(Dollars in Thousands)
1
1975 Expenditures
Number agencies
Total dollars
Federal dollars
State/local dollars
1976 Expenditures
Number agencies
Total dollars
Federal dollars
State/local dollars
1976 TQ Expenditures
Number agencies
Total dollars
Federal dollars
State/local dollars
1977 Expenditures
Number agencies
Total dollars
Federal dollars
State/local dollars
Jurisdictional category"
Local
Cities
44
$19,400
5,900
13,500
44
$21 ,400
5,800
15,600
11
$ 1,300
650
650
36
$16,800
5,900
• 10,900
Counties
91
$31 ,300
10,400
20,900
79
$20,600
8,400
12,200
47
$ 2,100
1,300
800
91
$20,800
7,500
13,300
MUltl-
county
27
$12,100
3,100
9,000
29
$25,000
6,700
18,300
' 20
$ 1 ,500
1,000
500
28
$30,300
7,000
23,300
Subtotal
162
$62,800
19,400
43,400
152
$67,000
20,900
46,100
78
$ 4,900
2,950
1,950
155
$67,900
20,400
47,500
Subtotal
state
agency
54
$81 ,000
33,200
47,800
53
$83,000
34,400
48,600
43
$13,600
7,400
6,200
54
$91,600
36,300
55,300
Total2
216
$143,800
52,600
91 ,200
205
$150,000
55,300
94,700
121
$ 18,500
10,350
8,150
209
$159,500
56,700
102,800
Total number of agencies receiving Federal monies for air pollution control work
either directly or by designation in grant to state agency. Direct grants approxi-
mate 182 for 1975 and 169 for 1976 and 1977.
2In 1977, 77 agencies did not receive Federal funds. These agencies and state
contributions to related air pollution activities accounted for approximately $15
million in air pollution work, making the total estimated expenditures $174
..million in 1977.
A number of agencies were provided a three-month funding (transition quarter—TQ)
during either 1976 or 1977 to change the Federal grant period from a July 1 to
June 30 fiscal year to a Federal fiscal year of October 1 to September 30.
32
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programs. This support also included temporary Federal assignees, special
contractual assistance and demonstration grants.
Resources of State and Local Air Pollution Control Agencies
Total expenditures (Federal, state, local) for the support of air
pollution have grown from $13 million in Fiscal Year 1965 (FY 65) to an
estimated $174 million (including agencies not receiving any Federal
support) in FY 77. The growth rate for Federally-funded agencies in FY 77
was approximately 6 percent over the FY 76 level and 11 percent for all
agencies.
The increase in the number of employees of state and local control
agencies is an indicator of the nation's growing commitment to controlling
air pollution. Table V-3 shows that control agency staff has almost
doubled in the last six years. The 1977 on-board positions represent
approximately 7270 equivalent full-time man-years of effort.
Resources increased by approximately 150 man-years and $9.5 million
between June, 1976 and October, 1977. The state and local fund increase
of approximately nine percent ($8.1 million) represented a significant
increase over the 1976 level. Federal support of these agencies increased
by approximately three percent ($1.4 million). Although the monetary
increases represent an increasing growth rate over 1976, the growth in
positions and man-years was less than previous years, thus reflecting
inflationary costs of salaries and agency operations.
The focus of Federal support to state and local control agencies has
been on the implementation of SIPs and the associated national priorities.
In FY 77 control agencies reviewed their strategies and made changes to
operational and procedural methods to improve enforcement actions for
achieving standards. Their resources were devoted not only to traditional
monitoring and enforcement programs but also to developing increasingly
complex control programs constrained by energy trade-offs, social and
economic considerations, and analysis and studies pertaining to attainment
and maintenance of standards.
The estimated percentage of resources committed to various aspects of
these national efforts to attain and maintain the standards is shown in
Table V-4.
33
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Table V-3. ESTIMATED MAN-YEARS OF EFFORT EMPLOYED BY
STATE AND LOCAL AIR POLLUTION CONTROL AGENCIES*
State
Fiscal
year
1969
1971
1973
1974
1975
1976
1977C
Positions
1000
1540
2930
3970
4030
4140
4420
Man-
years
920b
1420b
2760
3490
3500
3770
3840
Local
Positions
1840
2630
3270 '
3270
4010
4170
3970
Man-
years
1660b
2370b
2990
3000
3300
3340
3430
Total state/local
Positions
2840
4170
6200
7240
8030
8310
8390
Man-
years
2580b
3790b
5750
6490
6800
7110
7270
Agencies receiving funds directly or through "pass through" provision
in state grant for all years. Also includes estimates for non-funded
agencies for 1975, 1976 and 1977.
Estimated from position information using man-year/position ratios from
1973 and 1974.
C1977 estimates based on preliminary information.
34
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Table V-4. ESTIMATED DISTRIBUTION OF RESOURCES DEVOTED TO
AIR POLLUTION CONTROL ACTIVITIES OF NATIONAL PRIORITY
BY STATE AND LOCAL CONTROL AGENCIES3 IN FYs 75-77
Activity
Compliance with State Implementa-
tion Plan Regulations0
Development and Implementation
of Revisions to and Completion
of SIPs
Transportation Control Plans and
Mobile Source Inspection and
Investigation
Ambient Air Quality Monitoring
Network Operation and Com-
pletion
Supportive Activities (Manage-
ment, data and policy review,
environmental impact state-
ments, training, etc.)
Estimated oercentaqe of resources L
FY 75
44
6
7
18
25
FY 76
40
8
7
22
23
FY77 (Prelim.)"
44
10
6
19
21
Estimates are based on a total estimated expenditure of $143 million for
FY 75 , $150 million for FY 76, and $159 million for FY 77.
Outputs changed in 1977 to place emphasis on maintaining standards and
performing attainment and maintenance analyses. It 1s estimated that
approximately six percent of supportive activities were devoted to these
attainment and maintenance studies.
Majority of activities 1n this category deal with stationary source
control although some transportation control activities are included.
35
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Federal Assistance in Training Air Pollution Manpower
To assist and improve operations of state and local air pollution
control agencies, EPA's own operating programs, other Federal agencies,
and the private sector in their performance in implementing the Clean Air
Act, EPA conducts short-term technical training courses and workshops.
During 1977, a total of 86 training courses of 3 to 10 days duration were
conducted on 23 different subjects. Thirteen workshops were conducted on
seven different subjects. A total of 2345 students participated in 8590
student-days of training in short courses and workshops. In addition to
these courses, 170 students were awarded certificates for completion of
self-instructional courses on 4 different subjects. The students attending
the short-term training courses and workshops represented a variety of
agencies and private entities, as indicated in Table V-5.
Table V-5. ATTENDANCE AT SHORT-TERM TECHNICAL TRAINING
COURSES AND WORKSHOPS
Number of students
Employer Training courses Workshops
EPA
Other Federal agencies
State governments
Local governments
Consulting firms
Industry
Foreign countries
Others
Total
438
70
619
342
47
314
56
20
1,906
no
n
119
106
20
44
6
23
439
A series of training course materials was prepared on the maintenance
of emission control systems on motor vehicles. These materials can be
used by vocational schools and other organizations in the training of
auto mechanics, which 1s an essential element in the success of motor
vehicle emission inspection/maintenance programs. In addition, technical
and training assistance was provided to many organizations on the estab-
lishment of mechanic training programs for low emission engine maintenance.
36
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EPA provides funds for university training of employees of state and
local governmental air pollution control agencies and others as a means
of assisting agencies in improving the efficiency and effectiveness of
their operations and to augment recruitment and retention capabilities.
The funds are provided as fellowships to individuals and as grants to
universities. During 1977, EPA provided fellowships to 89 control agency
employees for part-time studies, for 27 control agency employees for full-
time study, and for 10 other individuals for full-time study. Recipients
of the training benefits came from 22 state and 30 local air pollution
control agencies. Collectively, the fellows were attending 55 different
universities. Graduate level training grants to 13 universities included
direct support for 52 students and provided modest support to the univer-
sities in their programs of teaching in the air pollution field. Many
other students not directly supported by EPA took the courses supported
by the grants.
Grants were also made to 3 universities to support special programs
in training of about 60 students in environmental management, to provide
summer internships in air pollution work for 25 students, and to provide
assistance in the use of a computer simulation training exercise.
Federal Assistance in the Utilization of Technical Literature
EPA provides assistance to state and local governmental air pollution
control agencies (as well as to commercial enterprises, consulting firms,
universities and others) in their use of information contained in the
technical literature. In 1977, more than 400 computerized literature
searches for state and local agencies and other organizations were con-
ducted and more than 37,000 copies of technical publications were provided
in response to about 14,000 requests from a wide variety of individuals
and organizations. In addition, about 1,400 computerized searches were
made of the EPA air pollution technical information file which is acces-
sible through a commercial system under a contract with EPA.
INTERAGENCY COOPERATION
The Clean Air Act Amendments of 1977 provide for interagency
cooperation in several areas. They require greater consultation and
37
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coordination on planning and implementation between state air pollution
control agencies and local governments as well as Federal land managers.
This includes the organizations responsible for comprehensive planning,
transportation planning, and other related programs such as water quality
management. At the same time, the Act requires that other Federal plans
and programs support air quality planning and not approve, present or
support any program which is contrary to an approved plan.
Specifically, the Act calls for consultation with the Department of
Housing and Urban Development (HUD) and the Department of Transportation
(DOT) on the development of planning process guidelines for non-attainment
areas and for cooperation with DOT in publishing information on transporta-
tion control measures.
Federal land managers, which includes the Department of the Interior,
the Department of Agriculture and other Federal agencies, are heavily
involved in the prevention of significant deterioration and review any
new source permit which may affect a Class I area.
The Department of the Interior, working with other affected agencies,
is also required to identify all mandatory Class I areas where visibility
is an important value. Stationary sources in these areas are subject to
retrofitting to improve visibility.
The requirements of the new amendments will augment earlier actions
taken by EPA to consult with other Federal agencies and coordinate or
integrate related programs. These include efforts to integrate air quality
planning with the 3C transportation planning process through the inclusion
of air quality related measures 1n the annual Transportation System•
Management (TSM) element required by DOT from metropolitan planning
organizations and through the annual 109(j) consistency determination
between proposed highway plans and transportation control plans.
In 1977 EPA and HUD signed an interagency agreement which addresses
coordination between air quality planning and the "701" comprehensive
planning program. Regulations issued by HUD make it a condition of
approval of such plans that they be consistent with state air quality
implementation plans.
38
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A committee was established in 1977 with membership from the Department
of Interior, the Department of Agriculture and EPA. The committee has
developed a list of mandatory Class I areas where visibility is an impor-
tant value and is also identifying potential Class I areas. The committee
will also establish criteria for determining whether a proposed facility
will have an adverse impact on air quality related values.
INTERNATIONAL COLLABORATION IN CONTROL OF AIR POLLUTION
Air pollution control was an important international environmental
theme in 1977, both bilaterally and multilaterally.
The Economic Commission for Europe (ECE) held the first meeting of
its Steering Body for the ECE Cooperative Program to Monitor and Evaluate
Long-range Transmission of Air Pollutants. The Steering Body established
Eastern and Western coordinating centers for the program in Norway and
the Soviet Union, respectively, which became operational by the end of the
year. Sulfur dioxide monitoring sites were selected, as well as the types
of measurements to be made. The Steering Body meeting and start-up of the
program represented important steps in the international examination of
sources and transport of air pollution.
Complementing ECE's effort, the Air Management Group of the Organi-
zation for Economic Cooperation and Development (OECD) analyzed potential
strategies to effectively control the long-range transport problem. OECD
also spent 1977 examining techniques and strategies to control photochemi-
cal oxidants through its precursors and for control of NO in its own right.
A
As the WHO Collaborating Center for Environmental Pollution Control,
EPA continued to operate the data bank for the WHO/Global Environmental
Monitoring System (GEMS) air quality monitoring project. A similar service
was provided to the World Meteorological Organization for its Atmospheric
Turbidity and Precipitation Chemistry networks. This year, too, EPA
assisted WHO in producing its GEMS report, "Air Quality in Selected Urban
Areas, 1975."
NATO's Committee on the Challenges of Modern Society (CCMS) approved
a new project on flue gas desulfurization, at the United States' suggestion.
For the first phase of the study, twelve separate flue gas desulfurization
processes were examined in terms of performance, capital and operating
costs, residuals and general applicability.
39
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Perhaps the single most significant multilateral event associated
with air pollution ,was,the International Meeting on Regulation of Chloro-
fluorocarbons, April 26-28, 1977, sponsored by the United States. Held
at EPA's initiative, the meeting was a response to concern over the strato-
spheric ozone depletion threat posed by chlorofluorocarbon emissions.
Twelve governments and four international organizations met to review the
science of the problem, the economic impacts of possible regulation, and
the status of national and international plans to control fluorocarbons.
A number of air pollution activities took place in 1977 on a
bilateral basis. EPA continued to cooperate with Canada and Mexico in
monitoring air pollution, conducting research into control strategy
mechanisms, and in negotiating specific control devices and procedures for
individual industrial sources of pollution.. Concern regarding possible
increased air pollution as a result of U.S. conversion to coal has been
expressed by Canada; efforts are being made to coordinate air programs
between the two countries. U.S. and Canadian experts held initial discus-
sions on the desirability of establishing a program of cooperative research
on the problem of long-range transport of air pollutants and their effects
on human health and welfare.
Under the International Joint Commission, whose function it is to
help resolve potentially contentious issues between the United States and
Canada, the Air Advisory Board and the special Ontario-Michigan Air Board
have been actively addressing major air pollution issues along the
northern border.
Cooperative surveillance and monitoring programs have begun to"be
established along the southern border between U.S. and Mexico on a case-
by-base basis. The programs coordinate local, state and Federal projects.
Under the U.S.-Japan Environmental Agreement there are three active
projects: photochemical air pollution, air pollution-related meteorology,
and stationary source pollution control technology. Exchanges are also
taking place within the U.S.-Federal Republic of Germany Agreement on
flue gas.desulfurization, air quality planning and maintenance, and air
pollution from coal-fired installations.
Air pollution projects under the U.S.-U.S.S.R. Environmental Agree-
ment include Air Pollution Modeling and Standard Setting; Instrumentation
40
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and Measurement Methodology; Process Improvement and Modification; Ferrous
Metallurgy Pollution Control Technology, Gaseous Emission Abatement Tech-
nology; Particulate Abatement Technology; Transportation Source Control;
and Effects of Atmospheric Pollution on Climate. -Research work continued
to be carried on to develop industrial processes which will produce less
air pollution: desulfurization and demetallization of fuel oils, dry
quenching of coke, and flotation desulfurization of coal.
Cooperative research with other countries is also conducted under
the provisions of the Agricultural Trade Development and Assistance Act
of 1954, as amended. In the area of air pollution abatement and control,
EPA is presently cooperating with three countries: Egypt, Poland, and
Yugoslavia. These projects encompass practically all environmental
aspects of air pollution, including identification of specific pollutants,
development of control technologies to be used by industry, procedures for
monitoring ambient air conditions, and assessment of health-related
problems. For example, in Egypt studies are being made to assess the
biological effects of inhaling high concentrations of air borne particu-
lates; Polish investigators are examining the complex relationships between
increases in air pollution toxicity and changes in elevation; also in
Poland investigations are being carried out to determine industrial
influences in particulate pollution in the atmosphere; and a project in
Yugoslavia is directed toward the control and abatement of air pollution
in the granular fertilizer industry. .
41
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VI. CONTROL OF STATIONARY SOURCES
NEW SOURCE PERFORMANCE STANDARDS
The Clean Air Act, as adopted in 1970, requires the Administrator
to establish national standards of performance for source categories
that "may contribute significantly to air pollution which causes or
contributes to the endangerment of public health or welfare." The 1977
Amendments to the Act reinforced this requirement and established a sched-
ule for the promulgation of standards of performance for remaining source
categories. Future reports will reflect the Administrator's progress in
meeting this new schedule. This report will contain a summary of accom-
plishments from 1970 through 1977.
Table VI-1 provides a listing of the source categories for which
standards of performance have been promulgated. It also shows the affected
facilities regulated in each source category and the number of applicable
standards. Generally, an affected facility is that process within a source
category for which a new source standard has been promulgated. In some
cases, standards are established for multiple pollutants from the same
facility.
Table VI-1 also provides a listing of the source categories for which
standards of performance have been published for comment in the Federal
Register. These proposed standards are applicable to all sources con-
structed after the date of proposal, but they are not effective until
promulgated. Through calendar year 1977, 83 standards have been published
for 22 source categories and 63 affected facilities.
Details as to the affected facilities, pollutants, and dates of
proposal .and promulgation are provided in Table VI-2.
Through calendar year 1977, litigation has occurred for five standards;
of these, two have been decided in favor of the Administrator and two are
under remand. Opinions upholding the regulations have been rendered by
42
-------
TABLE VI-1
NEW SOURCE PERFORMANCE STANDARDS
(As of October, 1977)
Promulgated NSPS
Steam Generators >250 MM Btu/hr
(Gas, Oil, Coal-Fired)
Municipal Incinerators >50 TPD
Portland Cement Plants
Nitric Acid Plants
Sulfuric Acid Plants
Asphalt Concrete Plants
Petroleum Refineries
Petroleum Storage Tanks (>40,000 gal)
Secondary Lead Smelters
Secondary Brass & Bronze Refining
Iron and Steel Mills
Sewage Treatment Plants
Primary Copper Smelters
Primary Zinc Smelters
Primary Lead Smelters
Primary Aluminum Reduction
Coal Cleaning Plants
Phosphate Fertilizer Plants
Ferroalloy Production
SUBTOTAL
Proposed NSPS
Kraft Pulp Mills
Petroleum Refineries
Steam Generators >250 MM Btu/hr
(Lignite-Fired)
Grain Elevators
Lime Plants
Gas Turbines
No. of Affected
Facilities
1
2
1
1
1
2
3
3
3
2
1
4
2
6
2
2
5
1
^^•^HHI
45
8
1
1
5
2
1
No. of Source/
Pollutant
Combinations*
1
2
1
2
1
3
3
3
3
2
1
5
4
7
4
2
5
2
^^^^^*IM
60
11
2
2
5
1
2
SUBTOTAL
18
23
TOTAL
63
83
*0pacity standards not counted separately if there are particulate
standards for that facility.
43
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TABLE VI-2
STATUS OF SECTION 111 REGULATIONS
(As of October, 1977)
SOURCE
Steam Generators
[>250 million Btu/hr]
Municipal Incinerators
[>50 tons per day]
Portland Cement Plants
Nitric Add Plants
Sulfur 1c Acid Plants
Asphalt Concrete
Plants
AFFECTED FACILITY
Coal, oil, 4 gas-fifed boilers
Coal and oil-fired boilers
Coal, oil. & gas-fired boilers
Incinerator
Kiln, clinker cooler
Process equipment
Process equipment
Process equipment
POLLUTANT
Particulata
S0x
N0x
Particulate
Participate
N0x
SO
X
Acid Hist
Particulate
OPACITY
REGULATION
/
/
/
/
j
PROMULGATION
DATE
12/23/71
12/23/71
12/23/71
12/23/71
12/23/71
12/23/71
3/8/74
REMARKS
Under remand.
8/17/71- Proposed
Judicial review decided
In favor of EPA - 5/22/75.
Under remand.
NAPA & Warren Bros. Co.
suit decided in favor of
EPA by US Court of Appeals
7/21/76.
t
-------
STATUS OF SECTION 111 REGULATIONS
SOURCE
Petroleum Refineries
Petroleum Storage
Secondary Lead Smelters
and Refineries
•
Secondary Brass and
Bronze Refining
Facilities
Iron and Steel Hills
Sewage Treatment Plants
Primary Copper Smelters
AFFECTED FACILITY
Process gas combustion
Catalytic regenerators
Gasoline, crude oil. and
distillate storage tanks
>40,000 gallons capacity
Blast and reverberatory
furnaces
Pot furnaces
Reverberatory furnaces
Electric and Cupola
Basic oxygen furnace
Sludge Incenerators
Roaster, smelting furnace,
converter
POLLUTANT
S0x
Parti cul ate
CO
Hydrocarbons
a
Parti cul ate
Participate
Partlculate
Participate
S0x
OPACITY
REGULATION
/
/
/
/
/
/
J
PROMULGATION
DATE
3/8/74*
3/8/74*
3/8/74*
3/8/74*
3/8/74*
3/8/74*
3/8/74*
3/8/74*
1/15/76
REMARKS
8/30/76 - Proposed
opacity standard revision.
•
11/18/75 - Proposed
opacity revaluation.
11/18/75 - Proposed
opacity revaluation.
3/2/77 - Proposed opacity
amendments t
Proposed 10/16/74
•Proposed 6/11/73.
-------
STATUS OF SECTION 111 REGULATIONS
SOURCE
Primary Zinc Smelters
Primary Lead Smelters
Primary Aluminum
Reduction Plants
Coal Cleaning Plants
'••
Phosphate Fertilizer
Plants
Iron and Steel Hills
Ferroalloy Production
AFFECTED FACILITY
Roaster
Sinter-Ing machine
Sintering machine, electric
smelting furnace, converter
Blast or reberberotory furnace,
sintering machine discharge
end
Pot lines
Anode Bake Plants
Air Tables
Thermal dryers
Wet Process Phosphoric
Superphosphoric acid
Diamnonlum phosphate
Triple superphosphate prod.
Triple superphosphate stor.
Electric arc furnaces
Specific furnaces
t
POLLUTANT
S0x
Partlculate
S0x
Partlculate
Fluorides
Fluorides
Partlculate
Partlculate
Fluorides
Fluorides
Fluorides
Fluorides
Fluorides
Partlculate
Partlculate
CO
OPACITY
REGULATION
/
/
/
/
i
1
J
/
/
/
PROMULGATION
DATE
1/15/76
1/16/76
•
1/26/76
1/15/76
8/6/75
9/23/75
6/4/76
REMARKS
Proposed 10/16/74
Proposed 10/16/74
Proposed 10/23/74
In litigation.
Proposed 10/24/74
;
Proposed 10/21/74
er>
-------
STATUS OF SECTION 111 REGULATIONS
SOURCE
AFFECTED FACILITY
POLLUTANT
OPACITY
REGULATION
PROMULGATION
DATE
REMARKS
Phosphate Fertilizer
Plant 111(d)
Kraft Pulp Hills
Sulfur Recovery In
Petroleum Refineries
Petroleum Refineries
Reevaluatlon of
Opacity Standards
Lignite Fired Steam
Generators
Met process phosphoric
Superphosphorlc acid
01 ammonium phosphate
Triple superphosphate prod.
Triple superphosphate stor.
Fluorides
Fluorides
Fluorides
Fluorides
Fluorides
Standards In Preparation for Promulgation
Digesters, lime kiln, recovery
furnace, washer, evaporator,
strippers, smelt & BLO tanks
Recovery furnace, lime kiln,
smelt tank
Sulfur recovery plants
Process gas combustion
Catalytic regenerators
Lignite-fired boilers
Total reduced sulfur
(TRS)
Partlculate
so2
Sulfldes
Partlculate
/ (recovery
furnace)
3/1/77
Proposed 5/12/76
Proposed 9/24/76
Proposed 10/4/76
Proposed 8/30/76
Proposed 12/22/76
-------
STATUS OF SECTION 111 REGULATIONS
SOURCE
Sulfurlc Acid Plants
in(d)
Grain Elevators
Lime Plants
Gas Turbines
Continuous Monitoring
General Provisions
Section 111(d) •:..
Regulations (General
Provisions)
AFFECTED FACILITY
Existing process equipment
Receiving, conveying,
cleaning, drying, and
shipping facilities
Rotary kiln, hydrator
Turbine
POLLUTANT
Acid Mist
Partlculate
Participate
NOX
OPACITY
REGULATION
'
•
•V • i.
PROMULGATION
DATE
IP/6/75
11/17/75
REMARKS
Proposed 11/4/76
Proposed 1/13/77
Suspended 6/24/77
Proposed 5/3/77
Proposed 10/3/77
Proposed 9/11/74
Proposed 10/7/71
i
(General Provisions)
Reference Methods 1-8
Amendments
(Test Methods)
Reference Method 11
Revision (Test Method)
Reference Methods 13A
and B Amendments
(Test Methods)
8/18/77
Proposed 6/8/76
Proposed 5/23/77
-------
the U.S. District Court of Appeals for the District of Columbia in National
Asphalt Pavement Association et al vs. Trafn (9/21/76) and the National
Portland Cement Association et al vs. Ruckelshaus (5/22/75). Final opin-
ions concerning standards of performance for steam generators and sulfuric
acid plants are imminent; litigation on primary aluminum plants is cur-
rently active.
During 1977 a major portion of the resources committed to new source
performance standards was used for technical studies of additional source
categories. Studies are underway for sulfur recovery plants in oil and
natural gas fields, iron and steel mill sintering plants, stationary
internal combustion engines, dry cleaning plants, organic solvent de-
greasing, lead battery manufacturing, iron ore beneficiation, auto and
light truck surface coating, selected industrial surface coating opera-
tions, non-metallic minerals mining, crushing and screening, industrial
boilers, and glass manufacturing. In addition, a major effort was Initiated
in 1977 to gather data to review the new source performance standards for
coal-fired steam generators.
Control of Volatile Organic Chemicals
During 1977 emphasis was placed on the preparation of guidance
materials which reflect reasonable available control technology (RACT)
for volatile organic chemicals emitted from a source category. The pur-
pose of the RACT guidance documents is to provide a technical data base to
be used by the states to develop specific regulatory requirements in non-
attainment air quality control regions. Table VI-3 provides a listing of
the documents issued in 1977 and those scheduled to be issued in the
future.
Section 111(d) Standards
During 1977 guidelines for the control of sulfuric acid mist from
sulfuric acid plants were finalized. This action initiated the develop-
ment and submission of state plans for the control of acid mist from
existing plants. A similar action was also finalized for the control of
fluoride emissions from five types of phosphate fertilizer plants.
49
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Table VI-3. CONTROL TECHNIQUES GUIDELINES FOR VOLATILE ORGANIC
COMPOUNDS ISSUED IN 1977 AND SCHEDULED TO BE ISSUED -'
NATIONWIDE EMISSIONS,
SOURCE CATEGORY 1,000 metric tons/yr
Issued in 1977
Large Appliance Manufacture 35
Magnet Wire Insulation 10
Gasoline Bulk Plants 150
Metal Furniture Manufacture 100
Petroleum Liquid Storage,
Fixed Roof Tanks 700
Degreasing 700
Bulk Gasoline Terminals . 250
Petroleum Refinery Vacuum Systems
Wastewater Separators and Process
Unit Turnaround 700
Cutback Asphalt Paving 700
Surface Coating of Automobiles,
Cans, Metal Coils, Paper and
Fabric Products 900
Service Stations, Stage I 400
To Be Issued in Future
Petroleum Refinery Fugitive
Emissions (Leaks) 150
Surface Coating of Other Metal
Products - Industrial 200
Pharmaceutical Manufacture 50
Rubber Products Manufacture 150
Paint Manufacture 25
Vegetable Oil Processing 15
Graphic Arts (Printing) 400
Flat Wood Products 50
Service Stations, Stage II 500
Petroleum Liquid Storage,
Floating Roof Tanks 150
50
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Table VI-3 (continued). CONTROL TECHNIQUES GUIDELINES FOR VOLATILE
ORGANIC COMPOUNDS ISSUED IN 1977 AND SCHEDULED TO BE ISSUED -'
SOURCE CATEGORY
NATIONWIDE EMISSIONS,
1,000 metric tons/yr
Ship and Barge Transport of
Gasoline and Crude Oil
Organic Chemical Manufacture
Process Streams
Fugitive (Leaks)
Dry Cleaning
Wood Furniture Manufacture
Architectural and Miscellaneous
Coatings
Organic Chemical Manufacture
Waste Disposal
Storage and Handling
Natural Gas and Crude Oil
Production
Natural Gas and Natural
Gasoline Plants
Adhesives
Other Industrial Surface
Coatings
Auto Refinishing
Other Solvent Usage
Metals Manufacture
Other Manufacturing
Fuel Combustion
Forest, Agricultural and
Other Open Burning
Solid Waste Disposal
TOTAL STATIONARY SOURCES
TOTAL TRANSPORTATION SOURCES
60
450
600
250
200
300
150
300
200
150
200
300
150
3,000
} 4,000
16,700,000 metric tons per year
10,600,000 metric tons per year
— This inventory was developed from national production and consumption
information using average emission factors. The technique necessarily
requires assumptions that cannot be confirmed in every case. We
anticipate that the figures will change as better information is
developed and generalized categories such as "other solvent usage" are
more clearly defined. 51
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NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP}
On November 16, 1976, the Environmental Defense Fund petitioned the
court for review of the vinyl chloride standards. As a result of this
petition, amendments were proposed on June 2, 1977. The basic thrust of
the proposal was to tighten the standards.
In 1977 it was determined that some decorative sprays contained
significant quantities of asbestos which presented a hazard to building
occupants. An amendment to the existing NESHAP on asbestos to prohibit
the use of such sprays was proposed on March 2, 1977. Promulgation is
expected shortly. In addition, the writing of a guidance document on ways
to remove asbestos coatings from buildings was initiated. This document
also contains information on the possibility of treating existing coatings
to prevent the release of asbestos to the environment. Additional studies
are underway concerning the control of asbestos from rock crushing and
handling and the beneficiation of iron ore.
During 1977, benzene was listed as a hazardous air pollutant. Regu-
lations for several source categories are under development. Because of
the complex array of benzene sources, the NESHAP will be issued in a
phased program starting in mid-1978 and continuing into 1982.
Studies are also underway to prepare regulations for coke oven emis-
sions and arsenic emissions from primary copper smelters if they are
listed as hazardous air pollutants.
DEVELOPMENT OF NEW AND IMPROVED AIR POLLUTION CONTROL TECHNIQUES FOR
STATIONARY SOURCES
One of EPA's most important tasks is the development and demonstra-
tion of air pollution control technologies for stationary sources. The
Agency's goals in developing stationary source controls include:
Describing at least one environmentally sound method of
control for each major source of pollution, including develop-
ment and demonstration, if necessary,
Providing a technical base for the Agency's enforcement
activities;
Establishing technical and economic data to support New
Source Performance Standards (NSPS); and
52
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Providing information upon which to base an environ-
mentally sound energy development policy.
Sulfur Oxides (SOX)
The Agency has directed much of its research and development effort
in the sulfur dioxide (SOg) control area toward demonstrating flue gas
desulfurization (FGD) technology, in which SO^ is removed from the gas
stream emitted after a fuel is burned. Flue gas desulfurization technol-
ogy is the only near-term technological approach to utilizing plentiful
high-sulfur coal supplies without excessive deleterious SCL emissions.
FGD technology development and assessment, therefore, have a high priority.
FGD technology has progressed rapidly over the past four years. Sev-
eral commercial FGD installations are achieving high SOg removal efficiency
with good reliability. EPA believes that lime and limestone FGD processes
can now be considered demonstrated technology, capable of being confidently
applied to full-scale utility boilers. However, more work remains to be
done in the FGD technology area, including the development of a cost-
effective and environmentally acceptable disposal technology for the large
quantities of sludge produced from lime and limestone systems, the develop-
ment and demonstration of improved lime and limestone process variations
which will minimize cost and energy usage and improve sludge properties,
and the development and demonstration of economically viable regenerable
FGD systems producing sulfur and sulfuric acid instead of sludge.
For the last eight years, EPA has been conducting a comprehensive
FGD development and technology transfer program which has been instrumental
in accelerating the commercial viability of FGD technology. This program
has aimed at demonstrating reliable and cost-effective FGD processes,
yielding both nonregenerable (throwaway) products and regenerable (or
salable) sulfur products.
EPA's major program in the nonregenerable area is the lime/limestone
prototype test program operating in cooperation with the Tennessee Valley
Authority at the Tatter's Shawnee Steam Plant. This program has been
Instrumental in identifying reliable, cost-effective process variations
for both lime and limestone scrubbing systems.
53
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Also in the nonregenerable FGD area, EPA has initiated a comprehen-
sive program aimed at identifying environmental problems associated with
scrubber sludge disposal, along with development and evaluation of appro-
priate control practices. In order to provide a~nonregenerable alternative
to lime/limestone systems, EPA is now undertaking the demonstration of the
double-alkali scrubbing process on a full-scale coal-fired boiler.
In the regenerable FGD area, EPA has pursued an aggressive program
aimed at identifying cost-effective processes with wide applicability
producing salable sulfur products. EPA is working with the Department of
the Interior in developing sodium citrate scrubbing, a promising regenerable
system. Other regenerable processes which have proven to be promising are
being evaluated on full-scale coal-fired utility boilers as part of EPA's
FGD demonstration program: Wellman-Lord (producing sulfur), magnesium
oxide (producing sulfuric acid), and tteaqueous carbonate process (produ-
cing sulfur).
EPA is also studying a number of other approaches for reducing sulfur
oxide emissions. One such approach is to "clean" a fuel (to remove the
sulfur and other contaminants) before the fuel is burned. This pretreat-
ment method is especially suited to sources smaller than electric utilities,
e.g., industrial boilers and commercial fuel-burning equipment. One tech-
nique involves physically and/or chemically cleaning coal with moderate
sulfur content so that it can be burned in conformance with clean air
standards.
The Agency is also studying the use of clean liquid and gaseous syn-
thetic fuels derived from coal. A program on residual oil processing and
utilization aims at defining better means of removing sulfur and other
pollutants in producing a clean synthetic fuel.
Another approach to reducing SO emissions is to adsorb the gas during
^\
the combustion process. The Agency's efforts in combustion modification
have involved primarily the Fluidized Bed Combustion Process (FBC). These
efforts have contributed to the National Fluidized Bed Combustion Program,
an interagency program coordinated by the Department of Energy. EPA's
contributions to the interagency program consist of environmental assess-
ments of FBC systems—which control SO , NO , fine particles, and other
A ^
pollutants—and continued testing of its small (0.53 megawatt) FBC
54
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mini -pilot plant. The Agency also conducts independent research to deter-
mine the implications of alternative designs and of alternative uses of
fluidized bed combustors.
Nitrogen Oxides (NO )
A
The development of the technology needed to control NO focuses on
A
the combustion process itself, where NO pollution starts. No emissions
/\ A
from combustion can be reduced by as much as 75 percent by "combustion
modification" (lowering the combustion temperature, limiting the amount of
oxygen available and regulating the way the fuel and air mix). Fundamental
research into the basic chemical and aerodynamic mechanisms involved in
combustion is increasing understanding of the factors that cause formation
of NO and of methods for controlling NO without increasing emissions of
^ A
other pollutants. Along with fundamental research, EPA also sponsors
advanced research into new low-NO designs for combustion equipment, alter-
rt
nate fuels, and advanced combustion concepts.
Another major component of the NO control program is pilot-scale
j ^\
testing. Here, a wide variety of combustion modification techniques have
been evaluated under controlled conditions in the laboratory.
Field demonstrations are the last—and in many ways the most important-
step in EPA's combustion modification control program. This is where tech-
niques that appear promising in the laboratory are evaluated on full-scale
equipment to ensure they can do the job under actual working conditions.
The result is reliable control technology that equipment manufacturers and
users can count on.
The Agency has underway more than 30 separate programs to develop
effective and economical ways of controlling NO . They cover all the major
A
types of stationary .sources in the United States, from small home furnaces
to large utility boilers.
EPA has already taken some important steps toward developing NO
A
control technology. Promising accomplishments over the last two years
include the following research:
0 Combustion modification techniques for coal-fired utility
and large industry boilers that reduce NO emissions by 40 to
^
50 percent with no adverse side effects.
55
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0 Pilot-scale test of advanced pulverized coal burners for
utility and large industrial boilers that lower NO emis-
^
sions by 70 to 80 percent.
0 A residual oil burner for small industrial boilers that
cuts NO emissions by 65 to 70 percent from heavy oils
A
with high nitrogen content.
0 An oil-fired home furnace that reduces NO emissions by
A
70 percent without increasing carbon monoxide, hydro-
carbons, or smoke.
0 Field tests proving that NO emissions from small industrial
^
boilers can be lowered significantly by combustion modifica-
tion techniques and by firing methanol instead of natural
gas or heavy oils.
0 Pilot-scale tests of an advanced catalytic combustion
system capable of reducing emissions of NO , carbon
A
monoxide, and hydrocarbons by as much as 95 percent.
Another important part of the Agency's program is the NOX flue gas
treatment (FGT) program. The FGT program has two main elements: strategy/
technology assessment and experimental projects.
The strategy and technology assessment element is designed to produce
a detailed state-of-the-art technology assessment, an assessment of the
extent to which FGT could be used in an optimized control strategy for
stationary sources, and information concerning the economic, energy, and
environmental aspects of commercial application of FGT technology. The
experimental projects element will provide the development and demonstration
of FGT technology for removal of NO with both high and low SO concentra-
A A
tions and for simultaneous removal of both NO and SO .
A A
Particulates
The Agency's program for particulate control 1s conducted to establish
engineering design techniques and performance models and to improve the
collectability and economics of control devices for particulate matter.
Attainment of the current primary standard for particulates in some
cases will be difficult and expensive with existing technology; attainment
of the secondary standard appears impossible without improved technology.
56
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There are two basic causes for this: particulate control technology has
limited control capability, in many cases even for coarse particulates;
and technical and economic factors often prevent control technology from
being feasible in specific industrial applications.
EPA is placing increased emphasis on the control of fine particulates
which persist in the atmosphere, comprise a variety of known toxic sub-
stances, and are major contributors to atmospheric haze and visibility
problems. The objective is the development and demonstration of control
technologies capable of effectively removing large fractions of the under-
3-micron size particles from effluents. The technical approach is to
identify capabilities of existing equipment (electrostatic precipitators
(ESPs), filters, scrubbers, and proprietary devices), to determine defi-
ciencies in present design and operating procedures, and to pursue remedies
for the deficiencies through research and development. New concepts are
applied as discovered and successful advancements in removal technology
will be demonstrated.
Actual source tests have shown that both ESPs and baghouses should be
capable of controlling fine particulates from a limited number of sources
emitting fly ash. It is quite-possible that the applicability of ESPs to
fine particulate control over a broad range of sources can be extended by
developing dust conditioning techniques and by modifying the design of
charging sections and collecting electrodes. Recently, a complete mathe-
matical model for the design of ESPs was greatly improved; this will allow
cost-effective design for specific particulate control technology applica-
tions. Also completed was the demonstration on actual sources at a pilot
scale of a charged droplet scrubber, a high throughput fabric filter, and
a flux force/condensation scrubber. In addition, a major effort was
initiated to find solutions to the particulate emission problems associated
with the burning of, or switching to, low-sulfur coal by a number of
electric utilities.
Other Pollutants
"Other" pollutants include those pollutants for which no ambient air
quality standards have been established and those pollutants for which no
National Emissions Standards for Hazardous Air Pollutants (NESHAPS) now
57
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exist. Control technology research efforts are underway for a number of
these pollutants, including trace metals, polycyclic organic matter (POM),
miscellaneous hydrocarbons, fluorides, and odors.
To assess the emission levels of these pollutants, several tasks are
underway for the field testing of coal-fired utility and industrial boilers
and for limited source characterization of gas- and oil-fired units. A
field testing program is underway for residential and commercial heating
units.
Source assessments are also undertaken for certain chemical processing
industries. This program is conducted to assess the environmental impact
of sources of toxic and potentially hazardous emission from organic mate-
rials, inorganic materials, combustion and open source categories, and to
determine the need for control technology development for given source
types. Sources under assessment include petroleum refining, petrochemicals,
nitrogen fertilizer operations, phosphate fertilizer operations, and pesti-
cides manufacturing.
Control technology for ferrous metallurgical industries is under con-
tinuing development. EPA has completed projects directed toward the con-
trol of emissions from cokemaking, blast furnace tapping, and charging of
basic oxygen furnaces. Efforts are being made to develop full control of
emissions from the sintering of iron ore. Extensive efforts are also
underway to assess, and ultimately to bring under control, fugitive emis-
sions from all significant sources in the production of metallurgical pro-
ducts. The combining into a multimedia program of the previously separated
ferrous metallurgical air and water research and development programs should
result 1n optimum control of all discharges from these industries.
58
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VII. CONTROL OF MOBILE SOURCE EMISSIONS
INTRODUCTION
Title II of the Clean Air Act,as amended in 1970, mandated at least
90 percent reductions in carbon monoxide (CO), hydrocarbons (HC), and
oxides of nitrogen (NOX) emissions from light-duty vehicles and delegated
authority to the Administrator to prescribe certain other emission standards
for automobiles, trucks, aircraft, and motorcycles.
MEASURES TAKEN TO IMPLEMENT MANDATED TITLE II EMISSION STANDARDS
Clean Air Act Amendments of 1977
The Clean Air Act Amendments signed into law on August 7, 1977, deal,
in part, with questions of mobile source emission standards for the 1978
model year and beyond. Under the former law, final standards governing
the three major pollutants from the tailpipe were to be met by model year
(MY) 1978. These standards in grams per vehicle mile were HC, 0.41; CO,
3.4; and NOX, 0.4. Congress determined, however, that it was not possible
for the auto industry to meet these standards by MY 1978 and established a
revised schedule of emission standards. The emission standards currently
applicable for passenger cars, light- and heavy-duty trucks, and motorcycles
are outlined in Tables VII-1 and VII-2.
The 1977 Clean Air Act Amendments also require that EPA promulgate
heavy-duty truck (HOT) regulations requiring a 90 percent reduction in HC
and CO emissions for MY 1983 and a 75 percent reduction in NOX emissions
for MY 1985. These standards are to be derived from baseline emissions of
1969 MY gasoline heavy-duty engines. Interim standards for these emissions
are required, reflecting the available technology with consideration given
to cost, noise, energy and safety factors. Standards have been promulgated
by EPA for the interim years. (See Table VII-2)
59
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Table V1I-1. EMISSION STANDARDS FOR MOTOR VEHICLE CLASSES
(Light Duty Passenger and Trucks)
Motor vehicle class
Light duty passenger
(Emissions expressed
in grains per mile)
National
California I
California II9
1978
HC CO
•
1.5a 15
.41d -9
NOx
2.0
1.5
•
1979
HC CO NOx
1.5tt 15 2.0
.41d 9 1.5
19001
HC CO NOx
.41" 7 2.0
.41e 9 1.0 (1.5f)
.
HC
.41"
.41"
.41h
198)'
CO
3.4b
3.4
7
1
NOx
1.0C
1.0 (1
0.7
.5f)
Light duty trucks
(Emissions expressed
en In grams per mile)
° National 2.0 20 3.4 1.7 18 2.3 1.7 18 2.3 1.7 18 2.3
(0-6000 GVH for 1978)
(0-8500 GVW for 1979 +)
California Standards vary depending upon weight and purpose.
?Total hydrocarbon standard without methane correction factor.
°Ha1verable to 7.0 (to 1983).
•jUaiverable to 1.5 for dlesels or for Innovative technology (dlesel waiver expires In 1984).
Total hydrocarbon standard with methane correction factor.
tTotal hydrocarbon standard with methane correction factor. Standard Is .39 If non-methane instrumentation Is used.
If certified by the CAR8, optional 100.000 mile durability procedure.
^Second set of standards Is optional - to be selected for a two-year period by manufacturer.
jTotal hydrocarbon standard without methane correction factor. Standard Is .39 if non-methane Instrumentation Is used.
California waiver request for 1980 and later model year light duty truck (LOT) and medium duty vehicles (MDV) has not yet
been approved by the Administrator.
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Table VII-2. EMISSION STANDARDS FOR MOTOR VEHICLE CLASSES
(Heavy Duty Trucks and Motorcycles)
Motor vehicle class
Heavy duty trucks
(Emissions expressed
In grams per
horsepower-hour)
National
HOT (I)a
HOT II)br
HOT (III)C
Heavy duty trucks
California
HDT (I)
HOT (II)
(Optional )c
Motorcyles
(Emissions expressed
1n g/km)
National and
California
0 - 170cc
170 - 750
750+
1970
HC CO HC+IWx Smoke
J
40 16 15/20/50°
HC CO NOx HC+NOx Smoke
j
1.0 25 7.5 15/20/50°
25 5.0 15/20/50°
HC CO
5g f 17
5-14T 17
14 17
HC CO
1.5 25
1.0 25
25
HC CO NOx
-
1.5 25 7.5
25
HC
5 f
5-14r
14
1979
HC+tlOx Smoke
A
10 15/20/50°
9.5 15/20/50°
5.0 15/20/50°
HC+MOx Smoke
j
15/20/50°.
5 15/20/50°
CO
17
17
17
HC
1.5
HC
1.0
HC
59
50
5g
1980
CO HC+tlOx Smoke
J
25 10 15/20/50°
A
25 5.0 15/20/50
CO HC+NOx Smoke
j
25 6 15/20/50°
25 5 15/20/50°
CO
12g
I2g
120
HC
1.5
HC
1.0
HC
59
5q
59
19B1
CO HC+tlOx
25 10
25 5.0
CO HC+NOx
25 6
25 5
CO
I2g
I2g
12g
Smoke
.
A
15/20/50°
A
15/20/50°
Smoke
j
15/20/50°
15/20/50°
.New test procedures and Instrumentation.
Existing test procedures and Instrumentation due to Insufficient lead time. Small volume (less than 2000) manufacturers may continue to use options
of their choice.
Store stringent levels which may be enacted by those states which apply to EPA and receive approval.
Diesel only; lugging/acceleration/peak.
Option available for combined IIC+NOx standard of 5 gram/brake horsepower/hr 1980 and beyond California HO standards may be enacted by those states
.which apply to EPA and receive approval.
Linear relationship expressed by the equation: 5.0 + .0155 (D-170). D = size In cc.
-------
The amendments define heavy-duty vehicles as those over 6,000 pounds.
Therefore, these more stringent statutory standards also apply to the EPA
light-duty truck class which is currently defined as trucks up to 8500
pounds. The amendments also require that test procedures for measuring
evaporative emissions from heavy-duty trucks be developed by EPA for the
earliest feasible model year.
The amendments also deal with particulate emissions by requiring that
particulate regulations based upon best available technology be implemented
effective with the 1981 model year. Regulations will be promulgated during
1978 so that manufacturers will have sufficient lead time to comply with the
standard.
In addition to the standard setting requirements, the amendments require
various studies and reports:
1. Continuing pollutant studies are required by EPA concerning the
effects of each pollutant emitted from heavy-duty vehicles and other mobile
sources, beginning in June, 1978, and each three-year period thereafter.
2. Particulate studies are also called for. Within 18 months of
enactment, a report to Congress is due on health effects of particulates,
including an assessment of the technology for controlling such particulate
matter. The amendments also require a characterization study of mobile
source particulates, including an analysis of relationship to fuel and fuel
additives and consideration of particulates unrelated to engine emission
(tire debris, asbestos from brake lining, and others).
3. The amendments require a continuing contractual arrangement with
the National Academy of Sciences (NAS) to study the technological feasibility
of emission control.
4. In order to continue to examine NOX emissions and their control,
EPA is required by the amendments to study the public health needs for
development of a 0.4 g/m standard for NOX and the cost and technological
capabilities of attaining such a standard. Congress also established as a
research objective the development of automotive technologies which would
achieve 90 percent reductions in the NOX levels from MY 1971 vehicles (i.e.,
0.4 g/m NOx). To achieve this, the Administrator is to promulgate regula-
•
tions requiring manufacturers to submit low NOX research vehicles to EPA '
beginning with the 1979 model year.
62
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5. The amendments also address the associated problems of fuel economy
and require that EPA submit a report to Congress detailing the relationship
between fuel economy and the emission standard compliance of vehicles of the
immediately preceding year.
6. EPA is required to study the feasibility"and desirability of on-
board hydrocarbon control technology for vapor control at refueling as
opposed to on-site gasoline vapor recovery systems. Regulations for onboard
hydrocarbon control are to be promulgated, after consultation with the
Department of Transportation (DOT), if technology is proven to be feasible
and desirable.
7. A study and report to Congress shall be prepared by January 1, 1979,
on the effects on public health and welfare of odors or odorous emissions,
the source of such emissions, and the available technology and associated
costs for the control of such emissions. A study and report of CO intrusion
into sustained use vehicles will be prepared including an analysis of the
source and levels of CO in the passenger area, the effects of CO upon the
passenger, and the available technologies for monitoring.
8. A study and report on the emissions of sulfur bearing compounds from
motor vehicles and aircraft will be prepared by August, 1978, and will in-
clude public health effects and costs and benefits of alternatives to re-
duce such emissions.
9. A study and report of emissions of air pollutants from locomotives
and locomotive engines will be prepared, including the effect of such emis-
sions upon air quality within air quality control regions, the available
technology to control these emissions, and the status of proposed state
and local regulations affecting such emissions.
Finally, the amendments specifically provide that EPA, prior to issuing
a certificate of conformity, ensure that no harmful pollutants are emitted.
Although manufacturers have long been required by EPA regulation to ensure
that emission control systems would not result in hazardous conditions,
EPA may now require manufacturers to conduct specific testing and analyses
to ensure that harmful levels of unregulated pollutants are not being
emitted and that no unreasonable safety risk is caused by the emission
control system.
63
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Certification Testing
Certification of new passenger cars for compliance with Federal
emission standards began with 1968 model year vehicles. The program in-
cludes testing of prototype vehicles that represent all new major vehicles
sold in the United States.
The manufacturer is required by EPA to submit data from two types of
tests which evaluate vehicle conformance to Federal emission standards.
First, through the Durability Fleet Test, fleets are tested at 5000 mile
intervals up to 50,000 miles to determine the deterioration of the emission
control system. Second, through the Emissions Fleet Test, prototype fleets
are tested at 4000 miles to determine their emissions at close to the "break
in" point. To check manufacturers' data, EPA requires that a vehicle being
tested by the manufacturer for durability be brought periodically to the EPA
laboratory in Ann Arbor, Michigan, for confirmatory tests. All emission
data vehicles are tested in the EPA laboratory.
During the past year, certification of most 1978 model year light-duty
vehicles, light-duty trucks, and heavy-duty engines was completed and certi-
fication of 1979 models began. The certification program for.the 1978 model
year involved monitoring the test program of approximately 50 manufacturers,
reviewing durability data from approximately 500 vehicles and engines, and
reviewing emission data from almost 1000 vehicles and engines. To reach
this level of certification, EPA conducted approximately 2200 emission tests
on 1978 light-duty vehicles and light-duty trucks.
In addition to the requirements for certification of motor vehicles and
engines prior to mass production, EPA has regulations governing changes to
vehicles and engines during production. Approximately 1500 running change
applications were processed during the past calendar year to determine
emission compliance of modified versions of certified vehicles.
Since the 1971 model year, emission test results have been published
in the Federal Register. Beginning with the 1973 model year, fuel consump-
tion during the emission test has also been determined and published in the
Federal Register. Beginning with the 1974 model year, a "Gas Mileage Guide"
listing the comparative fuel economy of all new model vehicles has been
prepared by EPA and distributed by the Federal Energy Administration (FEA -
now the Department of Energy) for consumer use. During 1977, EPA tested
about 900 vehicles to determine their fuel economy rates. Three figures
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were obtained for each vehicle: a cold-start city mileage figure, a highway
mileage figure, and a combined city-highway mileage figure. EPA thus pro-
vides emission test results and a broad picture of fuel economy test results
for consumers who are concerned with both air quality and fuel economy.
Fuel economy over the last several model years has increased signifi-
cantly. The estimated average fuel economy of all cars in the 1974 model
year was 13.9 miles per gallon (mpg). In 1975, the average increased to
15.6 mpg. In 1976 it was 17.6 mpg and in 1977 it was 18.6 mpg. In 1978
cars are expected to average 19.4 mpg. The 1978 estimate represents a 40
percent increase over 1974 models. The increase is due primarily to shifts
to lighter weight vehicles and, to a lesser degree, to changes in engine
calibration made possible by the use of catalytic emission controls.
MOTOR VEHICLE EMISSION REGULATIONS — ACTIONS. TAKEN IN 1977
Light-Duty Vehicles and Light-Duty Trucks; Emission Control Regulations
Currently, to determine compliance with emission standards in certi-
fying new vehicles for sale, EPA tests vehicles with their various adjust-
able parameters (e.g., air/fuel mixture, ignition timing) set to manu-
facturer's specifications. However, data indicate that significant numbers
of these vehicles, are exceeding the standards in actual use due to malad-
justments.*
On October 21, 1977, a rulemaking was proposed to amend the procedures
by which light-duty vehicles (LDVs) and light-duty trucks (LDTs) are tested
for the purposes of determining compliance with applicable Federal regula-
tions established under the Clean Air Act. Specifically, this action would
permit EPA to test these .vehicles with their engines adjusted to any setting
within the physically adjustable range, rather than set precisely to the
manufacturer's specifications. The goal of this amendment"is to require
these vehicles to meet the standards even when maladjusted or, more realis-
tically, to motivate manufacturers to effectively reduce the feasibility of
maladjustment.
*Copies of this study, "Automobile Exhaust Emission Surveillance Analysis
of the FY 1974 Program-EPA-460/3-76-019," 460-76-019 (September 1976) may
be obtained from the National Technical Information Service, 5285 Port Royal
Road, Springfield, Virginia 22161.
65
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Inspection/maintenance programs are being established in many states
as a transportation control measure to comply with ambient air quality
standards. Section 207(b) of the Clean Air Act provides for manufacturer
payment of repair for failed vehicles if the vehicle was properly maintained
and used and if it was tested by a test which correlates with the Federal
Test Procedure used in certification and assembly line testing.
To implement Section 207(b), a Notice of Proposed Rulemaking was
published in May, 1977, to establish short test methods and procedures for
ascertaining whether a vehicle complies with the emission standard which
can be correlated with the Federal Test Procedure. Public hearings'were
held on the proposal in New York, Chicago, and Portland in September, 1977,
Heavy-Duty Engines: Emission Control Regulations
In September, 1977, EPA promulgated regulations prescribing more
stringent gaseous emission standards for heavy-duty gasoline and diesel
engines for the 1979 and later model years. The promulgated standards are
listed in Table VII-2. Optional use of the existing test procedures and
instrumentation will be allowed for 1979 only, due to insufficient lead time
for procurement of the improved instrumentation.
Stricter emission standards for heavy-duty vehicles were necessitated.
by the inability of some air quality control regions (AQCRs) to meet national
ambient air quality standards without further control of HC, CO, and NOX.
Although the heavy-duty vehicle population accounts for only approximately
five percent of all registered motor vehicles (21 percent of total vehicle
miles travelled in 1975), the levels of HC, CO, and NOX that it is responsi-
ble for is significant.
This action is forecast to result in urban air quality improvements of
two to five percent for oxidants, one percent for CO, and one to two percent
for NOX.
Motorcycle Emi ssions
Motorcycles are one of many small but significant sources of emissions.
The average uncontrolled motorcycle presently emits about twice as much CO
and about six times as much HC as permitted by 1977 automobile standards.
A final rulemaking was published in January, 1977, adopting standards
as outlined in Table VII-2. No standards for oxides of nitrogen have been
66
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promulgated because an air quality analysis indicates that the motorcycle
contribution to.motor vehicle NOX emissions is negligible, estimated to be
less than one half of one percent in 1990.
The 1978 standard will result in an average 34 percent reduction in HC
and an average 36 percent reduction in CO emissions compared to the uncon-
trolled motorcycles. For the 1980 standards these percent reductions are 54
and 49 respectively.
Fuel Economy Regulations
During 1977 EPA promulgated several regulations affecting the ongoing
fuel economy program. The rules for the testing and calculation of passen-
ger automobile manufacturer's average fuel economy, which was originally
published in 1976 as a combined Notice of Proposed Rulemaking and Interim
Final Rulemaking, were published as final on September 12, 1977. These
rules set forth the procedures to be used to calculate the corporate average
fuel economy of passenger auto manufacturers for compliance with the 1978
fuel economy standards.
Similarly, on September 13, 1977, Interim Final Regulations were
published establishing procedures for calculating a manufacturer's average
fuel economy for non-passenger automobiles (light trucks and vans) effective
in 1979 and later model years.
Some minor changes were made by EPA in the fuel economy labeling pro-
gram to make the information which appears on the fuel economy labels more
useful to the consumer. Regulations were promulgated as final on September 12,
1977, affecting the way some cars are classified for fuel economy ranking
purposes. For example, the regulations provide for division of the sub-
compact class into two smaller classes to distinguish the extremely small
subcompacts from the subcompacts which approach the compacts in size. This
rulemaking also eliminated the practice of specific labeling, which gives
the fuel economy of individual vehicle configuration (i.e., specific axle
ratio, inertia weight) as opposed to general labeling which gives the fuel
economy of a model type. EPA considers that specific labeling practices
may represent consumer deception and foster reduced consumer confidence in
the fuel economy labeling program.
Another regulation promulgated as an interim rule in July, 1977,
established a new set of requirements for the format and content of the fuel
economy labels for the 1978 and later model years. This action is intended
67
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to improve the impact of the labels by highlighting the pertinent informa-
tion on the label and directing the consumer to the EPA/FEA Gas Mileage
Guide for details. A single format for labeling will be used in 1979 and
subsequent model year automobiles.
EPA also published Interim Final Regulations "in August, 1977, for
retrofit device testing. These regulations establish evaluation criteria
and test procedures for evaluating the fuel economy improvement claims and
effects on emissions for devices that may be retrofitted on new or in-use
vehicles.
Finally, in December, 1977, a Notice of Proposed Rulemaking was published
to establish a valid and standardized methodology for calculation of cargo
volume, an element used in determination of vehicle class.
EMISSIONS FROM VEHICLES IN USE
Emission Factor and Restorative Maintenance Programs
EPA began an Emission .Factor Program in 1971 to determine the emission
performance levels of in-use vehicles at varying mileage and age intervals
after such vehicles are subjected to actual owner use and maintenance. The
p f •
collected emission data are critical to various air quality models used by
Federal, state, and local agencies to predict ambient air quality. Each
year emission data are gathered from a random sample of approximately 2000
in-use vehicles in approximately 6 U.S. cities. The vehicles are all tested
in an as-received condition, i.e., as maintained by their owners upon de-
livery for testing.
The study completed in 1976 (termed the FY 74 Emission Factor Program)
tested vehicles in Chicago, Houston, Los Angeles, St. Louis, Washington, D.C.,
Denver, and Phoenix. It'was also the first monitoring of in-use 1975 model
year cars, of which 70 percent utilized catalyst technology to control emis-
sions. Of the 1975 model year vehicles tested in the 5 low altitude, non-
California cities, 70 percent passed the 1975 HC standard, 51 percent
passed the CO standard, 79 percent passed the NOX standard, and only 37
percent passed all three standards.
This pattern of failure of relatively new cars to meet the standards
for which they had been certified made necessary a major effort to pinpoint
the cause of these failures. For that purpose, EPA initiated an effort
known as the Restorative Maintenance Evaluation Project. This project,
68
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initiated in the fall of 1976 and completed during 1977, was designed to
test 100 randomly-selected vehicles of MY 75/76 in each of four metropolitan
areas (Washington, D.C., Chicago, Detroit, and San Francisco), following a
four-step procedure with each car proceeding to the next step only if it
still failed to meet emission standards. The procedural steps were as
follows: (1) an initial emission test of the vehicles in an as-received
condition, (2) a test after correction of any obvious and visible signs of
disablement of emission controls which may be detected, (3) a test after
carburetor check and adjustment if necessary, and (4) a final test after
extensive diagnostics, tune-up, and repair, as necessary. The purpose was
to yield data on whether cars- will continue to meet emission standards after
certification, if properly maintained.
Testing was recently completed on all non-California vehicles. The
results in percent of vehicles failing to meet standards and mean emissions
from all vehicles are presented in Table VII-3.
Table VI1-3. MEAN EMISSION (G/MI) AND PERCENTAGE OF VEHICLES
FAILING TO MEET STANDARDS, BY TEST POINT AND POLLUTANT
HC
CO
NOX
HC or CO
Any of
HC/CO/NO¥
rt
Fuel Economy
(mpg city)
Test 1
28.0%
1.32 g/mi
38.7%
20.27 g/mi
28.0%
2.82 g/mi
40.0%
57.7%
13.74
Test 2
25.0%
1.25 g/mi
35.3%
18.44 g/mi
20.3%
2.65 g/m1
36.7%
51.0%
13.75
Test 3
7.3%
0.90 g/mi
8.3%
8.13 g/mi
17.0%
2.69 g/mi
11.3%
27.0%
13.98
Test 4
4.3%
0.89 g/mi
5.0%
7.65 g/mi
12.3%
2.55 g/mi
7.0%
18.7%
13.95
69
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Even though approximately 58 percent of all vehicles tested failed to meet
all three emission standards in their as-received condition, the mean emis-
sion for all vehicles for HC and NOX was below the standard. Significant
reductions in CO and minor reductions in NOX occurred as the test series
# *
progressed. The mean emission for CO dropped well below the standard when
idle mixture settings were restored to specification between tests 2 and
3. These tests confirm the earlier suspicion that idle mixture maladjust-
ments are largely responsible for failure for HC and CO, as shown by the
large drop in mean emissions and in percentage failing between tests 2 and
3. Finally, the slight improvement in fuel economy over the four-test series
suggests that improved emission performance does not harm fuel economy per-
formance.
ASSESSMENT OF MOBILE SOURCE TECHNOLOGY
Motor Vehicles - Current Technology and Future Trends
Most cars to date have been equipped with a type of emission control
device known as an oxidation catalyst. This device is designed to achieve
more complete oxidation of hydrocarbons and carbon monoxide into water and
carbon dioxide, respectively. In addition, the employment of oxidation
catalysts allows the carburetor and distributor to be recalibrated for more
optimal fuel economy.
More recently, three-way catalyst systems, first introduced by Volvo
in 1976, have begun to appear on certified vehicles in growing quantities
and appear to be the systems that are being considered most seriously for
future applications. The three-way catalyst has been specifically formu-
lated for control of HC, CO and NOX simultaneously in one catalyst bed.
It provides excellent fuel economy performance with low sulfuric acid
emissions.
Turbocharging has also been used on a number of recently certified
vehicles. Basically, this technique employs a turbine in the exhaust flow
to drive a compressor regulating the intake charge to the cylinders. This
results in combustion of more air fuel charge in a given amount of time,
thus generating more power. Turbocharging does not appear to have either a
positive or a negative impact on emissions at this point, although more
•data .on vehicles targeted to meet future, more stringent standards are needed,
70
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The use of diesel engines in passenger automobiles continues to increase
as a result of intensive ongoing research by manufacturers. General Motors
has introduced a diesel for the 1978 model year in some passenger vehicles
and light-duty trucks. This currently developed engine meets .9 g/m HC,
3.4 g/m CO, and 2.0 g/m NOX emission levels.
Other engine designs under study include: Rotary, Stirling, Gas Turbine,
Variable Displacement, Staged Combustion 3-Valve Prechamber and Direct In-
jection Stratified Charged Engines. Alternative fuels such as hydrogen and
methanol continue to receive active attention.
Improved warm-up emission control devices and heat conservation tech-
niques are two additional areas of emission control development. Warm-up
emission control is an important area of concern because a disproportionate
amount of HC and CO is emitted during a cold start. Improvements are being
made presently in start-up fuel metering and in the use of start catalysts.
Heat conservation techniques include port liners, low conductivity coatings,
and thermal reactors. Their primary benefit is that they help maintain higher
exhaust gas temperatures in the exhaust systems to promote more rapid light-
off of catalysts or reactors and additional oxidation of HC and CO during
warmed-up catalyst or reactor operation.
The general area of improved fuel metering has been one that has always
received great interest and emphasis. Precise control of such parameters as
degree of atomization, air/fuel ratio over the range of engine speeds and
cylinder to cylinder distribution of fuel can greatly impact pollutant
emissions, fuel economy and driveability. Presently, the bulk of the fuel
metering system development appears to be concentrated on systems with feed-
back control of air/fuel metering using an exhaust gas oxygen sensor. The
proper exhaust gas oxygen level is necessary for systems that use three-way
catalysts. The emphasis on the part of domestic manufacturers seems to be
on feedback carburetion as opposed to feedback fuel injection systems.
Another area of accelerated research has been the development of all-
electronic control systems for future automobiles. Some components that
can be classified as electronic are already being used on vehicles today.
Ignition systems, the Electronic Fuel injection (EFI) system, and General
Motors' programmed air injection are a few examples. All-electronic control
or integration of virtually all variable engine parameters could be expected
to permit significant improvement in emission reductions, fuel economy and
-------
performance over current, mechanically controlled systems. These control
units could also be used to.generate quick and accurate data when hooked
up to diagnostic instruments, with potential benefits to the public in terms
of maintenance quality and costs. Major unsolved problems include the de-
velopment of inexpensive, precise sensors and activators that will withstand
the hostile automotive environment and the development of an appropriate
failure mode which would activate an associated interim operational mode.
Finally, Nissan Corporation has demonstrated that further advances in
the control of the basic engine emissions are still possible. By employing
a twin spark plug cylinder head they have achieved low mileage NOX results
below the 0.4 NOx level, without catalytic control of NOX. Whether such
results will hold for all classes of vehicles remains to be seen, but it
seems to be a potentially promising technique.
Characterization of Currently Unregulated Emissions
Oxidation and three-way catalyst systems have the potential of producing
many unregulated pollutants, especially under malfunction conditions such as
misfire or rich operation. Such unregulated catalytic pollutants as platinum,
nickel compounds, benzene, nitrogen compounds (ammonia, hydrogen cyanide, etc.),
sulfur compounds including sulfuric acid, and polyaromatics were first empha-
sized as potential problems in 1972 and continue to be studied in 1977.
A new study was initiated this year to characterize regulated and un-
regulated emissions from low NOx catalysts under malfunctioning conditions.
This study extends previous work in this area to include testing of three-
way catalyst vehicles and, to a limited degree, dual catalyst vehicles.
Studies undertaken in 1976 to study HCN emissions from three way and dual
catalysts continue on a low priority basis as work in 1977 has confirmed
that HCN emissions are, in effect, no problem, although continued measure-
ment is recommended.
Since the discovery in 1972 of sulfuric acid as an exhaust pollutant
from certain prototype catalyst-equipped cars, EPA and others have extensively
investigated these emissions. Work during the past year confirmed earlier
studies showing that exhaust oxygen levels are the most important single
parameter affecting sulfuric acid emissions. However, low exhaust oxygen
levels, such as those found with three-way catalyst vehicles or with
oxidation catalyst vehicles without air pumps, result in negligible
72
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sulfuric acid emission levels — levels which are equivalent to those found
in non-catalyst cars. In addition, limited test results have shown that
higher mileage oxidation catalyst/air pump vehicles have lower sulfuric
acid emission levels than the same vehicles have at lower mileages. Ongoing
studies of vehicle sulfuric acid emission rates, ambient exposures produced
by those emissions and possible adverse health effects of sulfuric acid at
various levels are expected to provide the necessary data to determine the
need for a motor vehicle sulfuric acid emission standard.
In addition to unregulated pollutants from catalyst vehicles, particulate
emissions from light- and heavy-duty diesels are being investigated. The
vast majority of these particles consists of elemental carbon and large
quantities of adsorbed materials including organic compounds, polynuclear
aromatics (PNAs) and sulfates. These particulates are less than one micron
in size, which allows deep penetration into the respiratory tract with
possible deleterious health effects. Characterization studies of diesel
engine exhaust particulates initiated in 1976 are continuing in 1977 so that
appropriate standards can be proposed. A light- and heavy-duty truck
standard for particulates is required for the 1981 model year.
In addition to particulates, diesels also produce crankcase emissions
which are currently being characterized. Earlier work indicated that
nitrosamines might be present at extremely low levels as engine blow-by
emissions. Many nitrosamine compounds, such as DMN, are considered to be
carcinogenic.
Various fuel and lubricant additives can have deleterious effects on
emission control systems, especially catalytic systems. Studies on a
variety of additives (e.g., manganese octane improver additive, barium smoke
suppressant, molybdenum sulfide oil additive) continue in an effort to de-
termine their effects on emission control systems. For example, previous
studies of manganese octane improver additive (MMT) indicated impairment of
emission control system performance and durability at the standard level of
0.125 grams per gallon. The Clean Air Act Amendments have, in response to
these studies, severely limited the use of MMT as of November, 1977, and
have prohibited its use after September, 1978. If it is found, however,
that certain percentages of MMT will not cause or contribute to a failure
of any emission control system or device, then a waiver may be granted by
EPA. . Major test programs are currently being conducted to evaluate identical
emission control systems with and without MMT.
73
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Aircraft
Studies are continuing on the emissions of CO, HC, NOX, and smoke from
commercial and private aircraft. Current efforts are concentrated in the
following areas:
1. Improvement of the precision of the emission sampling and measure-
ment techniques., specified in the EPA regulations;
2. Assessment of progress by private industry and other government
agencies in development of techniques for reducing emissions from turbine-
powered aircraft; and
3. Development of a new regulation to amend the emission standards for
turbine aircraft engines originally promulgated in July, 1973.
In conducting the above programs, maximum advantage is taken of ongoing
efforts by other Federal agencies active in the aircraft, emission area.
These are principally the National Aeronautics and Space Administration, the
United States Air Force, and the Federal Aviation Administration (FAA).
In particular, the FAA is continuing their High Altitude Pollution
Program (HAPP) to investigate the unique emission effects which high-flying
aircraft may have when operating in the stratosphere. EPA is participating
in an advisory role in this work and will assess from the experimental
findings whether aircraft regulations already promulgated require modifica-
tion to respond to upper atmosphere problems.
74
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VIII. RESEARCH IN MONITORING INSTRUMENTATION AND QUALITY ASSURANCE
Measurement systems to quantitatively detect pollutants in emissions
from sources and in the atmosphere are critical to EPA's abatement and
control programs. Initially, methods are needed to determine the extent
and causes of a pollution problem and to investigate the health and welfare
effects of the pollutants. When regulations, standards, and implementation
plans are promulgated, reliable reference measurement methods must also be
promulgated to accurately monitor the achievement and maintenance of the
standards. The quality assurance program must ensure that the monitoring
data EPA uses are sufficiently accurate, precise, and reliable to meet
Agency needs at reasonable cost.
MONITORING DEVELOPMENTS
Stationary Source Emissions Measurement
A major effort during 1977 resulted in the revision of Reference
Methods 1-8'pertaining to Standards of Performance for New Stationary Sources,
The development of methods and instruments for precise and rapid identifi-
cation and measurement of pollutants from stationary source emissions in-
cluded many additional accomplishments in 1977. A tentative method for
measuring emissions of polychlorinated biphenyls (PCBs) was developed and
is undergoing testing. Instrumentation was developed and performance speci-
fications were prepared for hydrogen sulfide monitoring systems. An im-
proved remote optical sensing system, with a newly installed Fourier trans-
form spectrometer, capable of measuring gaseous fluoride emissions was de-
veloped.
A transmissometer system was developed that measures the opacity of
source emissions containing condensed water; this can provide continuous
monitoring of emissions from sources with wet scrubber control systems. A
mass emission rate monitor for sulfur dioxide for concentrations in excess
of 150 ppm was developed. Techniques were developed for measuring sulfur
75
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species in emissions from combustion sources to include (a) sul fates by
modification of EPA Reference Method 6,.(b) gas phase sulfuric acid by
controlled condensation and by dewpoint monitoring system, and (c) sulfuric
acid on collected particulate by a microdiffusion technique.
Table VIII-1 (Stationary Source Measurement Methods) lists the methods
for which testing was completed in FY 77 and those which were still being
evaluated at the end of the year.
Mobile Source Emissions Measurement
Mobile source emissions research resulted in the development of a
reference procedure capable of measuring individual hydrocarbons in diesel-
powered vehicle emissions. These procedures include all hydrocarbon
emissions whether they be gaseous, liquid or bound to particles and will be
used to evaluate candidate certification procedures for passenger cars. Two
new improved procedures to measure hydrogen cyanide were developed: one
procedure provides for real-time analysis while the other technique dis-
tinguishes gaseous cyanide compounds.
Table VIII-1. STATIONARY SOURCE MEASUREMENT METHODS
Metncds Tested in FY 77
In Process
Source
Pollutant
(EPA Method Number)
Source
Pollutant
EPA Method Number)
Petroleum
Refineries
Phosphate
Fertilizer
Plants
Aluminum
Reduction
Plants
Various
Sources
H2S (11 modified)
Fluorides (13)
Fluorides (13)
PCBs
Vinyl Chloride
Production & PVC
Fabricating Plant
Sewage Sludge
Incinerators
Battery Manufac-
turing Plants
Copper Smelters
Sulfuric Acid
Plants
Various Sources
Sinter Plants
Vinyl Chloride (106)
(to be collaboratively
tested)
Mercury (105)
Lead
Arsenic
S02/S03-H2S04 Mist
(8 revised)
Benzene
Condensable organic
emissions
-------
Ambient Air Measurement
The decision to make lead a criteria pollutant required that a new
reference method be developed for measuring airborne lead. A tentative
reference method (using atomic-absorption spectrometry to analyze the lead
contained in particulate matter collected over a 24-hour period) was de-
veloped.
A method for measuring ambient levels of PCBs was developed. The
method is not yet standardized but is being evaluated.
Efforts were made to replace the current calibration procedure for
measuring ozone. It is expected that a method involving either improved
ultraviolet spectrometry or gas phase titration will be selected in 1978.
New developments to measure ambient air pollutants included an optimum
method for measuring atmospheric concentrations of asbestos. A provisional
methodology based on collection on nucleopore filters and electron micro-
scope analysis is now available. A method of time integrated collection
and analysis of atmospheric ammonia was developed; concentrations as low as
1 ppb can be assayed. A new virtual impactor design will improve the per-
formance and fabrication costs of the dichotomous sampler used to sample par-
ticulate matter by segregating the particles into two size ranges — res-
pi rable and non-respirable.
Other developments in 1977 include the application of a proton elastic
scattering technique for analyzing light elements (lithium through silicon)
in atmospheric aerosols; a technique to estimate the submicron size distri-
bution of atmospheric aerosols; and a prototype photometer for laboratory
use in calibrating ozone generators, to serve as EPA's primary reference
instrument. A gas chromatograph has been coupled to an optical-acoustic
detector and successfully used to measure specific trace gases (e.g., Freon
11 and 12) in the atmosphere; this system has the.potential for detecting a
large number of gases and vapors.
Table VIII-2 (Ambient Air Quality Measurement Methods) lists the methods
tested in FY 77 and those still being evaluated at year's end.
QUALITY ASSURANCE
A five-year quality assurance plan was published in July, 1977. The
planning document described the program, summarized the current status of
EPA's quality assurance efforts and delineated the resources and approaches
77
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required to develop and carry out an adequate Agencywide program to ensure
scientifically valid environmental measurements.
Table VIII - 2
AMBIENT AIR QUALITY MEASUREMENT METHODS
Tested in FY-77 In Process
Pollutant
. N03
Method
Colorimetric
_
Pollutant
Oxidant
S04
S04
Lead
PCB
Method
Ch emi 1 umin e s c en t
Colorimetric
(automated)
Turbi dome trie
Atomic Absorption
(tentative reference method)
Gas Chromatographic
FEDERAL REFERENCE AND EQUIVALENT METHODS
A new Federal reference method for N02, operating on the principle of
chemiluminescence, was promulgated in the December 1, 1976, Federal Register.
A short-term continuous NOg standard measurement method was also developed.
Improvements in the S02 pararosaniline method were also developed.
Measurement'methods (for ambient air) that have been approved as reference
or equivalent are listed in Table VIII-3.
78
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Table VHI-b. LIST OF REFERENCE AND EQUIVALENT METHODS ESTABLISHED OR REVISED IN FY 1977
to
0
DESIGNATION
NUMBER .
EQSA-1275-005
EQSA-0276-009
EQSA-0676-010
EQSA-0876-OH
EQSA-0876-013
EQSA-0877-024
*
OA-1076-014
OA-1076-015
OA-1076-016
OA-1176-017
IDENTIFICATION
Lear Siegler Model SM1000
S02 Ambient Monitor
Thermo Electron Model 43
Pulsed Fluorescent S0_
Analyzer
Philips PW9755
S02 Analyzer
Philips PW9700
SO. Analyzer
Monitor Labs Model 8450
Sulfur Monitor
ASARCO Model 500
Sulfur Dioxide Monitor
MEC Model 1100-1, 1100-2, or 1100-3
Ozone Meter
Monitor Labs Model 8410E
Ozone Analyzer
^^•^^^•^^•^^^^••V^^H^V^H^^H*-
REF. OR
EQUIV.
Equlv.
Equlv.
Equiv.
Equiv.
Equiv.
Equiv.
Ref.
Ref.
i . -
FED. REGISTER NOTICE
VOL.
41
42
41
42
41
42
41
41
42
41
42
41
PAGE
- 3893
13044
8531
20490
26252
28571
34105
36245
44264
466747
30235
53684
DATE
1/27/76
3/08/77
2/27/76
4/20/77
6/25/76
6/03/77
8/12/76
8/27/76
i
9/02/77
10/22/76
6/13/77
12/08/76
-------
Table VIII-3 (continued). LIST OF REFERENCE AND EQUIVALENT METHODS ESTABLISHED OR REVISED IN FY 1977
CD
O
DESIGNATION
NUMBER
EQOA-0577-019
RFOA-057 7-020
EQOA-0777-023
RFCA-0876-012
RFCA-0177-018
RFNA-0677-021
»
RFNA-0777-022
IDENTIFICATION
Daslbl Model 1003-AH
Ozone Analyzer
Beckroan Model 950A
Ozone Analyzer
Philips PW9771
0- Analyzer
Beckman Model 866
Ambient CO Monitoring System
LIRA Model 202S
Carbon Monoxide Analyzer System
Monitor Labs Model 8440ft
Nitrogen Oxides Analyzer
Bendix Model 8101-C
Oxides of Nitrogen Analyzer
REF. OR
EQUIV.
Equiv.
Ref.
Equiv.
Ref.
Ref.
1
Ref.
Ref.
FED. REGISTER NOTICE
VOL.
42
42
42
41
42
42
42
PAGE
28571
28571
38931
36245
5748
37434
37435
DATE
6/3/77
6/3/77
8/1/77
8/27/76
1/31/77
7/21/77
7/21/V7
-------
IX. ENFORCEMENT
STATIONARY SOURCE ENFORCEMENT
Section 110 — State Implementation Plans (SIPs)
The highest priority task of the EPA Stationary Source Enforcement
Program is attainment and maintenance of the National Ambient Air Quality
Standards (NAAQS) for particulate matter (TSP), sulfur oxides (SO ), and
^
photochemical oxidants (0 ). Under Section 110 of the Clean Air Act,
A
states were required to develop implementation plans for achieving the
ambient standards for these pollutants. The date by which these standards
were to be met was May, 1975, for all but the 16 states which were granted
extensions until May, 1977.
The responsibility for'ensuring that stationary sources comply with
SIP emission limitations so that target levels of air quality are met is
shared by the states and EPA. The states have primary responsibility for
achieving clean air within their jurisdictions; however, the Act requires
that EPA take independent action when states fail to do so. EPA contri-
butes to state air enforcement efforts through state control agency grants
and contractual assistance. Direct enforcement by EPA is also necessary
to assist states with source'compliance where the state is unable or
unwilling to take the appropriate action to assure compliance.
SIP Compliance Status
It is estimated that over 200,000 stationary sources are now subject
to SIP emission limitations. Approximately 23,000 of these are "major"
sources (i.e., facilities individually capable of emitting more than 100
tons of a pollutant per year). Because these major sources account for
about 85 percent of all air pollution from stationary sources, enforcement
81
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efforts have centered on bringing these polluters into compliance to
achieve the greatest emission reductions possible.
As of October, 1977, EPA and the states had identified 23,033 major
sources subject to SIP.emission limitations. Of these sources, 21,634
were operating in final compliance and another 1,225 were meeting incre-
mental clean-up dates in compliance schedules or orders, representing a
compliance level of 94 percent (Table IX-1).
EPA conducted 2,369 plant inspections and 662 formal enforcement
actions while the states were responsible for 25,960 field inspections and
initiated 15,646 enforcement actions. These actions were instrumental in
bringing many of these sources into compliance. Figures IX-1, IX-2, IX-3
and IX-4 give a breakdown of these figures by EPA regions.
The Task Ahead
The number of sources complying with SIP standards has shown a steady
improvement over the last year. However, EPA still has a difficult task
ahead as 1,225 major sources remain in violation of emission standards or
compliance schedules and the compliance status of 174 major sources is
• *
still in doubt. Unfortunately most of these 1,399 sources are located in
areas which are not meeting National Ambient Air Quality Standards. To
make EPA's and the states' task even more difficult, these offenders are
often large sources such as power plants and steel mills which have a
history of reluctance to comply with the standards.
In the past, enforcement efforts have mainly concentrated on achieving
standards for particulates and SOg. It is now apparent that considerable
effort will also be needed to reduce levels of photochemical oxidants as
most AQCRs are not attaining ambient standards for this pollutant. Toward
this end, an increased focus will be on reducing levels of hydrocarbon
emissions through vigorous enforcement of existing emission standards and
assisting in the development ;of enforceable emission limits in those non-
attaining AQCRs where regulations are lacking. "
An essential part of EPA's enforcement program deals with assuring
continued compliance by -sources already meeting the SIP standards. A
large number of surveillance investigations must be conducted by EPA and
82
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Table IX-1. COMPLIANCE STATUS OF MAJOR EMITTERS (BY EPA REGION)
(Oct 1977)
EPA
Region
I
II
III
IV
V
VI
VII
VIII
IX
X
Total
Total Class A
Sources Identified
1201
1971
2657
4762
4404
2584
1802
650
2153
839
23033
Compliance Status
Sources Complying
With Standards Or
Schedules
1171
1764
2451
4542
4046
2443
1691
618
2093
815
21634
Sources violating
Standards or Schedules
28
155
202
194
355
90
92
26
59
24
1225
Sources of Unknown
Compliance Status
10
56
4
26
1
51
19
6
1
0
174
00
ui
-------
00
Figure IX-1. ENFORCEMENT ACTIONS INITIATED BY EPA REGIONAL OFFICES
October 1, 1976 - September 30, 1977
81
105
42
134
122
18
Total =662
83
17
37
23
Regions I II
III IV
V VI
VII VIII
IX
-------
Figure IX-2 ENFORCEMENT ACTIONS INITIATED BY STATES
(by EPA Region)
October 1, 1976 - September 30, 1977
Total = 15,646
00
in
1269
3898
1406
894
1207
944
538
83
Regions I II III iv
VI
4744
VII VIII IX
663
-------
Figure IX-3. INSPECTIONS CONDUCTED BY EPA REGIONAL OFFICES
•
October 1, 1976 - September 30, 1977
Total 2,369
r «•> -i
324
295
260
241
CO
189
164
141
129
123
Regions I
II
III
IV
VI
VII
VIII
IX
-------
OQ
Figure IX-4. STATE CONDUCTED INSPECTIONS
(by EPA Region)
October 1, 1976 - September 30, 1977
4682
3428
931 1945
Total = 25,960
3703
3453
3260
1688
575
1295
Regions I II III IV V VI VII VIII IX
-------
the states to monitor the compliance status of these sources. The incor-
poration of continuous monitoring programs into SIPs will substantially
aid this enforcement effort.
•»
New Source Review (NSR)
All SIPs must contain regulations requiring preconstruction review of
proposed sources and disapproval of new or modified air pollution sources
which would interfere with the attainment or maintenance of a National
Ambient Air Quality Standard (NAAQS). EPA enforcement activities concerning
Mew Source Review include assessing state NSR programs to determine their
adequacy, assisting states in instituting effective programs, and initiating
enforcement actions against non-complying sources.
Problem Major Source Categories Regulated Under §110
EPA and the states have identified several categories of major sources
which lag behind in achieving compliance with emission standards. Among
these sources are coal and oil fired power plants, integrated iron and
steel manufacturing plants, and primary smelters. Control of sulfur oxide
and particulate emissions from these sources is essential if the NAAQS are
to be attained. For this reason, EPA has taken special efforts to bring
about compliance by these sources.
Power Plants
Coal and oil fired power plants emit nearly two-thirds of the total
national emissions of sulfur oxides. In addition, they are responsible
for heavy concentrations of particulates in the ambient air.
Of the nation's 623 large coal and oil fired power plants, approxi-
mately 71 percent are operating in full compliance with SOX emission
limitations. An additional 16 percent are in violation of the standards
and the remaining 13 percent are under EPA review. Included in the latter
category are 69 plants 1n Indiana and Ohio where SIP SO standards have
A
only recently been promulgated (Indiana) or are being challenged (Ohio).
The 76 enforcement actions initiated by EPA during the past year, as well
as state enforcement efforts, were responsible for improved compliance
status by many of these sources.
-------
The major approaches to reducing SOg emissions from power plants have
been the use of low-sulfur fuel or flue gas desulfurization (FGD) systems.
At this time, 125 FGD units have been installed, are under construction, or
are in various stages of planning. Advances in technology associated with
these systems have resulted in the development of new regenerable systems
that reduce the waste disposal burden and are capable of achieving 90-
percent or better efficiency.
During the upcoming year, state and Federal enforcement agencies will
be faced with the difficult task of maintaining SO standards in the iridst
^
of increasing numbers of Department of Energy (DOE)-ordered coal conver-
sions. Activities will include monitoring compliance of these sources,
setting and enforcing interim emission limitations, and coordinating with
DOE to identify potential coal conversion sources.
In addition to violating SO standards, power plants are also heavy
A
contributors to particulate loadings in the ambient air. At this time,
the compliance level for particulate matter is worse than that for SO ,
A
with only 62 percent of the 623 large plants in final compliance. Particu-
late control is readily available and of relatively little expense when
compared to SO control; therefore, compliance status with the standards
A
is expected to improve in the near future.
Primary Non-Ferrous Smelters
Though small in number, the nation's 27 primary copper, lead, and
zinc smelters account for about 10 percent of the total sulfur oxides
emitted by stationary sources and are at least partially responsible for
exceeding NAAQS in many areas.
Five primary smelters are now operating in full compliance with SIP
SO standards or compliance schedules. Three sources are operating in
A
violation of standards, schedules, or orders. There are 16 smelters
located in areas where there is no applicable SIP in effect or where the
SIP is inadequate and SO standards are needed. EPA and state enforcement
^^
efforts will continue to be directed towards developing adequate SIP
standards in several states and pursuing actions against violators.
The Clean Air Act Amendments of 1977 provide for issuance of orders
specifying final compliance dates for smelters. It is expected that the
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majority of sources will apply for such orders during the next year.
Enforcement agency resources will be required to evaluate requests for
these orders and monitor compliance with the terms of the orders.
—•
Iron and Steel Mills/Coke Plants
There are 53 integrated iron and steel plants which produce, in the
aggregate, about 90 percent of total U.S. raw steel production. These
plants consist of 591 sources of air pollution including coke plants,
sinter plants, blast furnace shops, and steelmaking shops (open hearth,
electric arc, or basic oxygen furnace). Approximately 15 percent of these
sources are operating in final compliance and 26 percent are on strict
schedules leading to compliance in the near future. Ten percent (10%)
are of unknown compliance status.
Although 49 percent of all integrated steel processes are in violation
of applicable standards, considerable progress is being made to bring about
compliance by this industry. During the past year, 43 enforcement actions
were initiated by EPA. These actions included civil/criminal actions,
notices of.violation, and administrative orders. It should be noted that
the compliance levels quoted above refer to fugitive as well as stack
emissions,
. v • — —
Impact of Fugitive Emissions
Fugitive process emissions are pollutants formed during an industrial
process which escape to the air without being vented to a stack. Generally,
these emissions are difficult to capture and therefore difficult to control.
The steel industry argues that the cost of controlling fugitive pro-
cess emissions is excessive and that the impact of fugitive emissions on
air quality is negligible. However, a number of studies have been con-
ducted which show that fugitive emissions from iron and steel plants are
large in terms of mass and have a major impact on ambient air quality.
Despite the reluctance of the steel industry to control fugitive
emissions, there have been some improvements in this area. As an example,
seven plants have installed equipment for controlling emissions from
charging and tapping operations at basic oxygen furnaces during the past
year. Prior to this time, there were no controls for emissions from this
source in the U.S. Further increases in the number of coke batteries
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controlling emissions from pushing operations and advances in the control
of coke quenching processes have also boosted the control system program
for this industry.
Section 111 — New Source Performance Standards (NSPS)
There are currently 646 new sources in 19 source categories subject to
NSPS. Of these, approximately 82 percent are operating in full compliance
with applicable regulations. Standards have also been proposed for regu-
lations for another six categories and are expected to be promulgated
within the next year. A requirement of the Clean Air Act Amendments of
1977 is the evaluation by EPA of existing NSPS and designation of additional
categories of sources emitting pollutants which adversely affect public
health or welfare. As more NSPS are promulgated and as older manufacturing
plants are replaced by new, more efficient plants, NSPS will play a greater
role in achieving and maintaining NAAQS.
Delegation of enforcement authority to state and local governments
is crucial to this program. Progress in this area has increased the num-
ber of delegations from 20 states and 18 localities in September, 1976,
to 34 states and 27 localities by November, 1977. (Table IX-2)
Section 112 — National Emission Standards for Hazardous Air Pollutants (NESHAPS)
As of October, 1977, 1162 air pollution sources were subject to the
NESHAP standards regulating emissions of asbestos, beryllium, mercury, and
vinyl chloride. Of these, approximately 95 percent were operating in full
compliance with the standards.
On October 21, 1976, vinyl chloride standards were promulgated which
applied to 59 existing sources and all new sources. A major effort was
required by EPA to inspect these sources and evaluate the large number of
applications for compliance waivers. To date, nearly all sources have been
inspected and about 50 compliance waivers issued. Sources operating under
waivers must be monitored by EPA to ensure timely installation of control
equipment and compliance with interim emission limitations. All sources
**
with compliance waivers must be in final compliance by October 21, 1978.
As the scope of the NESHAPs regulations widens, EPA is strongly urging
state and local agencies to request enforcement authority. In the past
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Table IX-2. 'DELEGATION OF NESHAP AND NSPS AUTHORITY TO STATE AND LOCAL
GOVERNMENTS (November 22, 1977)
ID
fNS
EPA
Reqion
I
II
III
IV
V
VI
VII
VIII
IX
X
Totals
Number of Delegations NESHAPs
States
5
4
3
5
4
0
0
3
2
2
_— — — — — — — — — — — —
28
Localities
0
0
1
2
0
0
0
0
22.
0
•. ..—.... — -
25
Number of Delegations NSPS
States
4
4
2
5
5
0
2
6
3
3
"
34
Localities
0
0
1
2
0
0
0
n
24
r . _ _i i . . . — . - —
27
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year, authority was delegated to 13 state and 22 local governments which
brought the total to 28 states and 25 localities (Table IX-2). EPA is
actively sponsoring programs designed to assist states in requesting and
obtaining delegation of NESHAPs authority.
Energy
The Energy Supply and Environmental Coordination Act (ESECA) of 1974
provides a mechanism to require the use of coal by major fuel consumers in
order to conserve oil and natural gas reserves. Under the provisions of
the Act, the Department of Energy (DOE) shall prohibit certain power
plants and may prohibit other major,fuel burning installations from
burning natural gas or petroleum products.
In June, 1975, the Federal Energy Administration issued prohibition
orders to 32 utilities consisting of 74 generating units. A second round
of prohibition orders issued in June, 1977, affects an additional 46 units
at 25 power plants and other major fuel burning installations. EPA is
required to notify DOE which of these plants can burn coal and comply with
applicable standards immediately. For those sources unable to comply
immediately, EPA will certify the earliest date by which coal may be
burned and applicable standards met. All ESECA notifications and certi-
fications made after passage of the Clean Air Act Amendments of 1977 must
have the prior written consent of the Governor of the state in which the
source is located.
Under Section 113(d)(5) of the Clean Air Act, as amended in 1977,
delayed compliance orders (DCOs) may be issued to certain coal conversion
sources that cannot immediately comply with standards and whose emissions
will not cause NAAQS to be exceeded. (This provision is in lieu of a
similar compliance date extension mechanism contained in Section 119 of
the Clean Air Act in effect prior to the 1977 Amendments. It provides
for issuance of DCOs in appropriate cases where conversion to coal is
required under new or amended energy legislation.)
Section 110(f) of the Act was amended in 1977 to provide a mechanism
for temporary suspension of applicable SIP requirements where such action
is necessary to respond to a national or regional energy emergency declared
by the President. Prior to the 1977 Amendments, the authority for such
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general suspensions did not exist and enforcement discretion was used in
handling most emergency situations. (This provision may be superseded by
a provision in the proposed National Energy Act.)
Section 125 was added to the Act by the 1977-Amendments and provides
that a major fuel burning stationary source may be prohibited from using
fuels other than locally or regionally available coal if it is determined
that such action is necessary to prevent or alleviate significant local or
regional economic disruption or unemployment which results from the use
by that source of petroleum products, natural gas, or coal obtained from
another region or locale. (It is expected that this provision will be
amended when the proposed National Energy Act becomes law.)
MOBILE SOURCE ENFORCEMENT
The Mobile Source Enforcement program is directed primarily toward
achieving compliance with vehicle emission standards, fuel regulations, and
mobile source related aspects of state implementation plans promulgated by
EPA under the Clean Air Act. The activities of the program include pre-
venting introduction of uncertified new domestic and imported vehicles
into commerce; auditing certification procedures of domestic and foreign
automobile manufacturers; enforcing vehicle assembly line emission test
activity and the recall, warranty, anti-tampering, and imports provisions
of the Act; developing and enforcing Federal regulations for the removal
of lead from gasoline; and ensuring compliance with transportation control
plans, mobile source related vapor recovery regulations, and inspection
and maintenance programs.
Inspection/Investigation Program
Section 206(c) of the Clean Air Act authorizes the enforcement activi-
ties related to emission requirements for "new" motor vehicles or engines,
I.e., motor vehicles or engines which have not yet been sold to the ulti-
mate purchaser. This authority includes right of entry for the purpose
of conducting tests of vehicles in the hands of the manufacturer and for
inspecting records and facilities used by the manufacturer in complying
with the Act. Section 208 of the Act authorizes written inquiries by EPA
1n order to determine whether a manufacturer is or has been acting in
accordance with the Act.
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During FY 1977 Mobile Source Enforcement personnel have conducted 85
inspections of domestic' and foreign motor vehicle manufacturers. Such
inspections include detailed audits of procedures and records and visual
inspection of facilities and vehicles in order to"determine whether manu-
facturers are and have been acting in compliance with the Clean Air Act
and its regulations.
A total of 11 vehicle manufacturer investigations have been conducted
during FY 1977, some of which arose from inspections. These investigations
consist of a search of vehicle manufacturer records and documents and
interrogation of individuals to determine whether violations of the Clean
Air Act and its regulations have occurred. Issuance of requests for pro-
duction of information pursuant to Section 208 of the Act frequently accom-
pany such requests, including requiring the manufacturer to develop emis-
sion test data where violations may be accompanied by effects of emission
performance. During FY 1977, 12 Section 208 letters have been issued.
Final action was also taken on two cases which were previously referred
to the Department of Justice. The U.S. District Court in Washington, D.C.
ruled that EPA did not have the legal authority to bring suit against
Chrysler Corporation for -introducing into commerce 9,185 vehicles that
were materially different from the vehicles Chrysler submitted to EPA for
certification testing. The Agency believed the applicable certificate
was void ab initio since Chrysler installed a different emission component
in a prototype test vehicle than that described to EPA in the Corporation's
Application for Certification and actually installed in production vehicles.
The Court stated that fraud on the part of the Corporation must first be
proven under the existing regulations before certificates can be declared
void, and there was no such evidence in this case.
In a second case against Chrysler, the same Court ruled that the
Corporation did introduce into commerce certain misbuilt 1974 model year
vehicles not covered by certificates of conformity. These vehicles were
assembled with incorrect carburetors, distributors, exhaust gas recircula-
tion valves and orifice spark advance control valves at the Hamtramck,
Michigan Assembly Plant. Unlike the previous case, in this instance the
prototype vehicles were tested with the correct emission parts but pro-
duction vehicles were assembled with components different from the test
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vehicle and those described in the Application for Certification. Of
significant importance to the Agency was the Court's ruling that, as a
matter of law, a vehicle is not covered by a certificate of conformity if
it contains parts different from those described 'in the Application and
reasonably expected to affect emissions even though the vehicle may, in
fact, meet emission standards.
Recall Program
Section 207(c) of the Clean Air Act authorizes EPA to order recall of
vehicles if they do not conform to emission standards. EPA has resolved
eight investigations since September 30, 1976, and initiated an additional
ten investigations since that date. Thirty vehicle classes are presently
under investigation. For the period September, 1976, to September, 1977,
manufacturers have initiated recalls on approximately 5.6 million vehicles
as a result of EPA investigations. These recalls are being monitored by EPA.
One recall order has been contested to date. Chrysler Corporation
requested a hearing to contest the Administrator's December 8, 1976, order
which involved approximately 208,000 1975 Chrysler vehicles. The hearing,
which under EPA regulations is a formal adjudicatory hearing on the record
before an Administrative Law Judge, has recently been completed (November 9,
1977). The major issues in the litigation include the Agency's interpreta-
tion of the terms "properly maintained and used" and "substantial number"
as they are used in the Act, the type of data which EPA may rely on to
support a recall order, general manufacturer liability under the Act for
foreseeable 1n-use conditions, and specific manufacturer liability for
acts of its authorized dealerships insofar as emission control related
maintenance is concerned. A decision is expected early in 1978. Both
parties have appeal rights.
Warranties and Aftermarket Parts Program
The warranty provisions of the Clean Air Act are designed to help
assure that manufacturers develop and produce vehicles that meet emission
standards throughout their useful lives. There are two separate warranties,
one which has been in effect since the 1972 model year (Section 207(a) of
the Act), and one which will not be implemented until the Agency publishes
96
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regulations doing so (Section 207(b) of the Act, now scheduled for promul-
gation for the 1979 model year and beyond). In conjunction with these pro-
visions EPA is also developing a program for certification of after-market
parts (i.e., those produced by business concerns which are independent from
the vehicle manufacturers) in order to alleviate potential anticompetitive
problems stemming from the presence of warranty coverage for a 5 year/50,000
mile period. Under the Clean Air Act as amended in August, 1977, the pro-
gram is required to be in effect by August, 1979.
The Section 207(a) or "production" warranty provision requires that
manufacturers warrant all regulated vehicles and engines to be designed,
built, and equipped to meet emission standards at the time of sale and to
be free of defects in material or workmanship which cause the vehicle or
engine to fail to conform to standards for a period of 5 years or 50,000
miles, whichever first occurs. The Agency believes that this warranty has
proved to beof little utility to date since owners rarely know which com-
ponents and failure modes are covered by it, and, even when claims are made,
owners are often unable to show that their problem is one causing emissions
to exceed standards. To overcome these difficulties, the Agency intends
ultimately to promulgate regulations defining the coverage of this provi-
sion, and has taken the first step in this regard by publishing an Advance
Notice of Rulemaking on November 16, 1976. The 1977 Clean Air Act Amend-
ments have strengthened the Section 207(a) warranty by providing that an
improper claim dishonor by a manufacturer shall be treated as a prohibited
act (Section 203(a)(4)(D)) with a potential $10,000 fine. EPA will be
employing this increased authority to assure that owners are treated fairly
when bringing emission production warranty claims.
The Section 207(b) or "performance" warranty, when implemented, will
require a manufacturer to repair vehicles which, although properly main-
tained, still fail a state or local emission inspection program employing
an EPA-approved short test. Promulgation of this warranty has been delayed
to date because of technical difficulty in identifying relatively quick
and inexpensive short tests which "are reasonably capable of being corre-
lated" with the sophisticated test used on prototype vehicles, as Section
207(b) requires. However, EPA has now developed tests which it believes
may satisfy the requirements of the Act and proposed them on May 25, 1977,
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along with proposed performance warranty regulations. Due to changes in
various aspects of the Section 207(b) warranty coverage made by the 1977
Clean Air Act. Amendments, the warranty regulations will be reproposed.
However, final promulgation in time for the 1979 model year is still
anticipated.
Certification for after-market parts has for some time been considered
the optimum solution to potential anticompetitive problems raised by the
emission warranties. In passing the 1977 Clean Air Act Amendments, Congress
settled on this method by directing EPA to establish such a program within
the next two years» EPA and the after-market industry have anticipated this
need and have been involved during the past few years in development of
technical criteria and standards by which such emissions certification may
be approached. EPA has published an Advance Notice regarding the goals and
requirements which such a program might entail.
The program would enable after-market manufacturers to qualify their
parts for use in maintenance under the emission warranties and thus elimi-
nate any fear on the part of owners that use of aftermarket products would
void emission warranty coverage. This will probably require some testing
by the aftermarket manufacturers and a willingness to warrant their pro-
ducts in a similar fashion as vehicle manufacturers are required to do.
Selective Enforcement Audit Program
On July 28, 1976, regulations were published establishing a program
for testing new production vehicles at the assembly line in order to assure
that they comply with emission standards. The program is called Selective
Enforcement Auditing (SEA) and Involves the testing, pursuant to an admini-
strative order and in accordance with the Federal Test Procedure, of a
statistically representative sample of production vehicles from a speci-
fied configuration. If nonconformity is established, EPA may suspend or
revoke the certificate of conformity.
The program was run on a trial basis until December 31, 1976. Test
orders were issued but no enforcement sanctions were to be imposed as the
result of vehicles failing to meet emission standards. One trial audit
each was run for American Motors, Chrysler, Ford, and General Motors.
Starting January 1, 1977, the SEA regulations became fully effective.
Two audit teams have conducted a total of twenty-one audits for model year
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1977. One manufacturer failed an audit and, as a result, made an engi-
neering change to bring the vehicles into compliance.
The Clean Air Act Amendments of August, 1977, require EPA to promul-
gate regulations by August, 1978, for assessing h'eavy-duty vehicle and
engine manufacturers nonconformance penalties for failure to meet the
standards. Additionally, EPA must promulgate regulations for testing
heavy-duty vehicles and engines at the assembly line to prevent the sale
of vehicles and engines which exceed the standards by more than the
permissible amount.
Anti-Tampering Program
Section 203(a)(3)(A) prohibits any person from removing or rendering
inoperative a vehicle or engine's emission control system prior to sale
and delivery to the ultimate purchaser. It also prohibits any manufacturer
or dealer from knowingly tampering with such systems after sale and delivery
to the ultimate purchaser. Section 203(a)(3)(B) was added in the 1977
Amendments and expands the prohibition after sale and delivery to include
persons engaged in the business of repairing, servicing, selling, leasing,
or trading motor vehicles or motor vehicle engines, or persons operating
fleets of motor vehicles. During 1977, 71 tampering inspections and inter-
views were conducted. Thirty-four cases were referred to the Department
of Justice for litigation. A total of 30 cases are currently under inves-
tigation. Civil penalties totalling $8,500 were collected for 5 cases
settled during this fiscal year.
Imports Program
Section 203 of the Act gives EPA and the U.S. Customs Service joint
responsibility for enforcing the prohibition against importation of non-
conforming motor vehicles. Over the past year, EPA has monitored the im-
portation of all motor vehicles entered into the commerce of the United
States. Of these, 1400 vehicles were imported under bond pending a demon-
stration of conformity. Administrative sanctions were imposed against 245
importers for noncompliance with the regulations.
EPA has conducted 40 investigations of alleged illegal importations.
Four cases were referred to the Department of Justice for action.
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Unleaded Enforcement Program
EPA has responsibility for enforcing Section 211 CO(I) of the Clean
Air Act relating to the regulation of fuels and fuel additives. On
January 1C, 1974, EPA promulgated regulations requiring the general avail-
ability of unleaded gasoline by July 1, 1974, for use in 1975 and later
model cars equipped with catalytic emission" control systems..
EPA has established a nationwide Fuels Enforcement Program for ensuring
that affected retail outlets are in compliance with these regulations. This
program includes sampling of the fuel at retail outlets by regional EPA
field inspectors, private and state inspectors under EPA contract, and the
analysis of the samples for lead content.
From October 1, 1976, to September 30, 1977, EPA has conducted approxi-
mately 29,847 inspections of service stations to ensure compliance with
the unleaded fuel regulations. At the stations, 25,109 gasoline samples
were taken, of which about 1.38 percent were found-to be contaminated
with lead. Enforcement has issued 747 complaints and has collected
$226,865 in penalties during this, period.
Lead Phasedown Program
On December 6, 1973, EPA issued regulations controlling the amount of
lead additives used in gasoline. The original lead reduction schedule
limited the average amount of lead in gasoline to a maximum of 1.4 grams
per gallon (gpg) in 1976, 1.0 in 1977, 0.8 in 1978, and finally to 0.5 by
1979.
Because of studies indicating that gasoline shortages would result if
the original schedule were enforced, EPA amended the regulations in
September, 1976. The amended regulations retain the 0.5 gram per gallon
standard, but extend the period for compliance with that standard from
January 1 to October 1, 1979, in order to allow sufficient time for re-
finers to install the equipment necessary to meet the reduced lead level
without causing a gasoline shortage. The January 1, 1978, standard of
0.8 gram per gallon also remains in effect but will be suspended if a
refiner can show that he has taken, and is continuing to take, sufficient
actions in procuring and installing equipment to ensure the achievement
of the 0.5 gram per gallon standard by October, 1979, or before.
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Requests for suspension of the 0.8 gpg lead standard have been received
from 58 refiners for 115 refineries. As of December 28, 1977, 47 suspensions
have been granted. The Clean Air Act Amendments of 1977 mandate separate
treatment for small refineries (50,000 barrels per day or less crude capa-
city and owned by a refiner with crude capacity of 137,500 barrels per day
or less) with regard to lead level requirements.
Stage II Vapor Recovery
Regulations requiring the control of vapors emitted during transfer
operations in the gasoline marketing chain have been promulgated under
Section 110 of the Clean Air Act. Stage I involves the recovering of
vapors emitted during the filling of delivery trucks and the subsequent
filling of underground storage tanks. EPA has promulgated Stage I vapor
recovery regulations in 13 air quality control regions. From October 1,
1976, to September 30, 1977, EPA has conducted 2,533 inspections of service
stations to ensure compliance with the Stage I vapor recovery regulations.
Regulations to control gasoline vapors during vehicle refueling (Stage
II vapor recovery regulations) were promulgated in the original State
Implementation Plans in late 1973 and early 1974. These regulations speci-
fied that 90 percent of gasoline vapors emitted during vehicle refueling
must be recovered, but did not include a test procedure for evaluating a
system's performance. In October, 1975, revisions were proposed to the
regulations. The revisions included establishing a mass emission standard
rather than the 90 percent recovery requirement and proposed several test
procedures which could be used to certify system performance prior to in-
stallation but which, because of complexity, were not useful to monitor
performance in the field.
Based on the development of a short test that can be used to test
the performance of Stage II equipment in the field, the Stage II vapor
recovery regulations were reproposed in November, 1976. The new proposal
abandoned the earlier system certification approach and adopted in-use
field enforcement as the primary means for assuring compliance with the
requirements. The new proposal also allows small marketers more time than
the major oil companies to meet regulatory requirements.
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Several of the 1977 Clean Air Act Amendments impact upon these regula-
tions. Provisions dealing with onboard hydrocarbon technology, fill-pipe
standards, cost of emission control for vapor recovery and applicability
of vapor recovery regulations are being evaluated"in conjunction with the
public comments which have been received since the November, 1976, proposal.
THE LIST OF VIOLATING FACILITIES
The List of Violating Facilities is designed to prevent the Federal
Government from subsidizing pollution law violators with contract, grant
or loan monies. In 1977 the List began to be integrated into EPA's
stationary source enforcement activities. While no additional Clean Air
Act violators were listed, in several instances listing investigations
led to prompt settlement of cases against major violators who had been out
of compliance for several years. In these cases, a consent decree including
a mutually acceptable compliance plan was worked out, which resolved the
Federal court case and removed the threat of listing. Sources to which
this scenario applied in 1977 included Kaiser Steel Corporation, Fontana,
California; U.S. Steel South Works, Chicago; and Interlake Steel, Chicago.
Also, in 1977 the Office of Federal Activities (OFA) made use of the
regulations whereby Federal agencies must withhold awarding contracts to
a facility for up to 15 days if the facility is under consideration for
listing.
There were two challenges in 1977 in Federal District Courts to the
validity of the Listing regulation with respect to air violators. In
both cases EPA prevailed. U.S. vs. U.S. Steel, May 6, 1977 10 ERC 1751
(N.D. 111. 1977) and U.S'. v. Interlake, 432 F. Supp. 987 (N.D. 111.'1977).
COMPLIANCE BY FEDERAL FACILITIES
It is the policy of the Federal government that Federal agencies shall
provide leadership in the prevention, control, and abatement of air pollu-
tion through the compliance of their facilities with applicable air quality
standards and emission limitations established pursuant to the Clean Air
Act.
The 1977 Amendments expanded the responsibilities of the Federal
agencies to comply with applicable requirements. In addition to complying
with substantive air pollution control standards, Federal facilities must
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now comply with procedural requirements, including recordkeeping, reporting,
etc. The President has also been given the discretionary power to exempt,
in the interest of national security, certain kinds of Armed Forces prop-
erty which are uniquely military in nature.
Compliance Status
As of November 1, 1977, 68 (17 percent) of the 393 major Federal facil-
ities subject to the Clean Air Act were out of compliance with air quality
standards or emission limitations because of operational and maintenance
problems, construction delays, delays in testing for final compliance, and
delays, deferrals, or failures to identify needs relating to budgeting for
pollution abatement projects. Of those noncomplying facilities, 45 (66
percent) are on an approved construction schedule; however, 24 (35 percent)
of the noncomplying facilities are not currently anticipated to be in com-
pliance by the July 1, 1979, statutory deadline.
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X. LITIGATION IN 1977
PREVENTION OF SIGNIFICANT DETERIORATION (PSD)
EPA promulgated regulations for PSD in December, 1974. The PSD
regulations are designed to protect air which is cleaner than the
minimum ambient standards in many areas of the country. The PSD regula-
tions were challenged in court by many parties, including both industrial
and environmental groups. In August, 1976, the U.S. Court of Appeals
for the District of Columbia Circuit upheld the PSD regulations against
arguments that they were unauthorized and arguments that they were not
sufficiently stringent. ]_/ The Supreme Court granted petitions for
certiorari on April 4, 1977.
Because the 1977 Clean Air Act Amendments contain detailed PSD
requirements and specifically provide that EPA's 1974 regulations will
remain in effect, EPA asked the Supreme Court to dismiss the cases. On
October 3, 1977, the Court granted EPA's request.
TIMELINESS OF CHALLENGES TO EPA REGULATIONS
The courts have continued to rule that Section 307 of the Act bars
challenges to the validity of EPA regulations, including its approval of
state implementation plans, if such challenges are not filed within the
time specified by Section 307. 2/ In a case involving enforcement of
certain transportation control measures applicable to New York City, for
example, the U.S. Court of Appeals for the Second Circuit held that
Section 307 barred belated challenges to EPA's original approval of the
measures, and the Supreme Court has declined to review the decision. 3/
In another case, the U.S. Court of Appeals for the Eighth Circuit held
that this limitation on review is constitutional in the context of a
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civil action. 4/ Whether the limitation applies in the context of
criminal enforcement actions as well, as held by the U.S. Court of
Appeals for the Sixth Circuit, is expected to be decided by the Supreme
Court this term. 5/
HAZARDOUS AIR POLLUTANTS
In a 1976 case, the U.S. Court of Appeals for the Sixth Circuit
upheld a criminal indictment against a demolition company for violation
of the national emission standard for asbestos. 6/ The company had
argued that the standard, as applied to demolition operations, specified
a "work practice" rule rather than a numerical limitation on emissions
and was accordingly beyond EPA's authority to promulgate under Section 112
of the Act. Although the Court of Appeals found that review of the rule
was precluded by Section 307 of the Act, 1t observed that it saw nothing
inconsistent with the purposes of the Act 1n EPA's promulgation of such a
rule. The case was appealed to the Supreme Court and is now pending
decision. TJ
In the interim, EPA's authority to promulgate "work practice" rules
has been made explicit by the T977 amendments to the Act, and certain
amendments to the asbestos standard have been upheld by the U.S. Court
of Appeals for the District of Columbia Circuit. 8/
TRANSPORTATION CONTROL MEASURES
EPA has not as yet obtained a final judicial ruling on the legality,
under the Clean Air Act and the constitution, of EPA's regulations
requiring states to implement measures to reduce pollution from private
vehicles using public roads. As noted 1n the 1976 report, the circuits
are split on this subject, with the U.S. Court of Appeals for the Third
Circuit upholding EPA's regulations, 9_/ the Fourth and Ninth Circuits
striking them down or declaring them unenforceable, JO/ and the D.C.
Circuit upholding certain regulations but not others. 11/ EPA sought
Supreme Court review of the latter three decisions. In May, 1977, the
Supreme Court remanded those cases back to the Courts of Appeals for
further consideration. VI] In November, 1977, the Court of Appeals in
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the District of Columbia remanded the regulations for the National Capitol
area to the Agency for reconsideration in the light of the recent Clean
Air Act amendments and other developments, 13/ and in December, 1977, the
Court of Appeals in California invalidated the regulations for that state
as being beyond the Agency's authority under the Clean Air Act. 14/ It
is hoped that further Agency and court proceedings will resolve these
issues surrounding EPA's authority to require states to establish trans-
portation control programs.
In another 1977 decision, the U.S. Court of Appeals for the Second
Circuit held, over statutory and constitutional objections, that a state
and its subdivisions can be required to implement transportation control
measures in a SIP—at least where the measures had been adopted by the
state itself. In a 1976 case described in last year's report, the Second
Circuit affirmed the right of citizens to sue a state or local government
for compliance with transportation control measures and other SIP require-
ments. 15/ But the district court held on remand that compelling a state
or city to implement transportation control measures by controlling the
conduct of others is unauthorized under the Act, and perhaps the
constitution. 16/ The Court of Appeals reversed, and the Supreme Court
declined to review the Court of Appeals' decision. 17/ EPA supported the
position of the citizen group in this litigation.
PRE-ENFORCEMENT REVIEW
In the case of Fry Roofing Co., v. EPA, 18/ the Eighth Circuit,
affirming a holding of a U.S. District Court in Missouri, held that the
Clean Air Act bars pre-enforcement review of enforcement orders issued
under Section 113(a).
TALL STACKS AND SUPPLEMENTARY CONTROL SYSTEMS
Two cases involving the use of dispersion techniques as opposed to
constant controls systems are now pending in the Ninth Circuit. In
Bunker Hill v. EPA, 1_9_/ the Court held that EPA could only require the
use of constant controls to the extent economically and technologically
feasible, and has remanded the SIP regulations at issue to the Agency
for reconsideration of their feasibility. EPA has petitioned the Court
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to reconsider its holding in light of the Clean Air Act Amendments of 1977,
which make clear that dispersion techniques are not permissible substitutes
for constant controls required in SIPs. In Kennecott Copper Corporation v.
Costle 20/, on appeal from a ruling of a U.S. District Court in Nevada that
constant controls (as opposed to dispersion techniques) could not be
required in a SIP if economically infeasible, the Ninth Circuit has requested
and the Agency has provided a post-argument brief explaining the impact
of the Bunker Hill decision and the 1977 Amendments on the case.
USE OF MODELING IN THE PROMULGATION OF SIPs
As a result of the state's failure to submit a SIP for SOp, EPA
promulgated a SIP for Ohio in August, 1976. In large part, the SIP was
based on sophisticated air quality dispersion modeling. Because of the
number of sources involved, the modeling was the most extensive used to
date. Thirty-five petitions challenging the SIP were filed with the
United States Court of Appeals for the Sixth Circuit. 21/
In November, 1976, the Sixth Circuit, while considering motions for
a stay pending appeal sua sponte, remanded the regulations to EPA to take
additional comments for sixty days. EPA's response to the comments was
filed with the court on May 31, 1977. In June, 1977, the court denied
motions for a prehearing conference and to consider the need for a
further stay and required expeditious briefing and argument of the
merits. Oral argument was held on October 21, 1977. The decisions of the
Court will not only be important to the Agency's regulatory effort in
Ohio, but will also be looked to as a strong indication of the judiciary's
willingness to accept modeling as a major regulatory tool.
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REFERENCES
1. Sierra Club v. EPA. 540 F.2d 1114 (D.C. Cir. 1976).
2. E.g., National Association of Demolition Contractors v. Costle,
Nos. 74-1545 et §J_. (D.C. Cir. Oct. 13, 1977); Lloyd A. Fry Roofing
Co. v. EPA, 10 ERC 1082, No. 76-1731 (8th Cir. May 11, 1977);
Friends of the Earth v. Carey, 552 F.2d 25 (2d Cir. 1977), cert.
denied, No. 76-1718 et al_. (Oct. 17, 1977); U.S. v. Adamo Wrecking
Co., 545 F.2d 1 (6th Cir. 1976), cert, granted, No. 96-911 (argued
Oct. 11, 1977).
3, Friends of the Earth v. Carey, supra.
4. Lloyd A. Fry Roofing Co. v. EPA, supra.
5. U.S. v. Adamo Wrecking Co., supra.
6. U.S. v. Adamo Wrecking Co., supra.
7. Adamo Wrecking Co. v. United States, Sup. Ct. No. 76-911, argued
October 11, 1977.
8. National Association of Demolition Contractors, Inc. v. Costle,
supra.
9. Pennsylvania v. EPA, 500 F.2d 246, 256, 261 (3d Cir. 1974).
10. Maryland v. EPA, 530 F.2d 215, 226-27 (4th Cir. 1975), vacated
sub nom. EPA v. Brown, 97 S.Ct. 1635 (1977); Brown v. EPA, 521 F.2d
827, 831 (9th Cir. 1975), vacated 97 S. Ct. 1635 (1977).
11. District of Columbia v. Train, 521 F.2d 971, (D.C. Cir. 1975)
vacated sub nom. EPA v. Brown, 97 S.Ct. 1635 (1977).
12. EPA v. Brown, 431 U.S.'99 (1977). ,
13. District of Columbia v. Costle, Nos. 74-1013 et. al_. (D.C. Cir., •
November 10, 1977).
14. Brown v. EPA, Nos. 73-3306 et al_. (9thC1r.t December 73, 1977).
15. Friends of the Earth v. Carey, 535 F.2d 165 (2d Cir. 1976).
16. Friends of the Earth v. Carey, 442 F.Supp. 638 (S.D.N.Y. 1976).
^
17. Friends of the Earth v. Carey, 552 F.2d 25 (2d Cir.), cert.
denied 46 U.S.L.W. 3261 (Oct. 17, 1977).
18. 554 F.2d 885 (1977).
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19. F.2d , 10 ERC 1401 (No. 75-3670).
20. No. 77-1359.
21. Cincinnati Gas & Electric Co. et al., v. EPA-,- Nos. 79-2090 et seq.
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