PROGRESS IN THE PREVENTION AND CONTROL



       OF AIR POLLUTION IN 1983
  ANNUAL REPORT OF THE ADMINISTRATOR



OF THE ENVIRONMENTAL PROTECTION AGENCY



                TO THE



    CONGRESS OF THE UNITED STATES



          IN COMPLIANCE WITH



   SECTIONS 313, 202(b)(4), and 306



                  OF



        42 U.S.C. 7401 ET SEQ.



    THE CLEAN AIR ACT, AS AMENDED

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                                 CONTENTS

                                                                    Page

 PREFACE	   i i i

    I.   INTRODUCTION AND SUMMARY	   1-1

   II.  AIR QUALITY TRENDS, MONITORING, AND MODELING

       A.  National Air Quality and Emission Trends	   II-l
       B.  Ambient Air Monitoring	   H-3
       C.  Ai r Quality Modeling	   II.6
       D.  Integration of Air Data Systems	   II-8

  III.  AIR POLLUTION RESEARCH PROGRAMS

       A.  Oxidants	   I II-l
       B.  Hazardous Air Pollutants	   III-3
       C.  Gases and Particles	   III-5
       0.  Mobile Sources	   III-8
       E.  Acid Deposition	   III-9

   IV.  DEVELOPMENT OF NATIONAL AMBIENT AIR QUALITY STANDARDS	   IV-1

   V.  REGULATORY ASSESSMENT OF TOXIC AIR POLLUTANTS	   V-l

  VI.  STATUS OF AIR QUALITY MANAGEMENT PROGRAMS

       A.  Development of'Policy and Regulations	   VI-1
       B.  Prevention of Significant Deterioration and
           Nonattainment New Source Review Activities	   VI-4
       C.  Implementation Overview and Assistance	   VI-6
       D.  Air Pollution Training Programs	   VI-11

 VII.  CONTROL OF STATIONARY SOURCE EMISSIONS

       A.  New Source Performance Standards  (NSPS)	  VII-1
       B.  National  Emission Standards for Hazardous  Air
           Pollutants (NESHAP)	  VII-1
       C.  Delegation of NSPS and NESHAP	  VII-2
       D.  BACT/LAER Clearinghouse	  VII-2

VIII.  STATIONARY SOURCE COMPLIANCE

       A.  General	  VIII-1
       B.  Post-1982 Enforcement Policy	  VIII-2
       C.  Enforcement  of  National  Emission  Standards  for
           Hazardous  Air Pollutants	  VIII-3
       D.  Steel  Industry  Compliance  Extension  Act  and
           Associated Enforcement Actions	  VIII-3
       E.  Other Civil  Litigation	  VIII-4
       F.  Compliance by  Federal  Facilities	  VIII-4
       G.  List  of  Violating  Facilities	  VIII-4

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IX.  CONTROL OF MOBILE SOURCE EMISSIONS

     A.  Introduction	   IX-1
     B.  Standard Setting	   IX-2
     C.  Preproduction Compliance	   IX-4
     D.  Inspection/Maintenance	   IX-4
     E.  Alternative Compliance Measures	   IX-4
     F.  Mobile Source Enforcement	   IX-5
     G.  Imports.	   IX-6

 X.  LITIGATION

     A.  Introduction	   X-l
     8.  Mobi ie Source Cases	   X-l
     C.  Sulfur Oxides Control	   X-3
     0.  Prevention of Significant Deterioration	   X-3
     E.  Other Appellate Decisions	   X-4
     F.  Other Litigation	   X-4

XI.  REFERENCES	   XI-1
                                  11

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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 governments.  EPA's role is to conduct  research and development
programs, set national  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
on measures taken toward implementing the purpose  and intent  of the Act.
This report covers the  period January 1  to December 31,  1983, 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 during
that time.  In addition, this report also includes two other  EPA reports
to Congress required under the Clean Air Act,  as amended:

     1.  Section 306 report on Federal  procurement and violating facilities
(Chapter VIII), and

     2.  Section 202(b)(4) report on measures  taken in relation to motor
vehicle emissions control  (Chapter IX).
                                  i 1 i

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                       I.  INTRODUCTION AND SUMMARY
A.   OVERVIEW
     This report describes the progress that the Environmental  Protection
Agency (EPA) has made in the prevention and control  of air pollution
during 1983.  The following paragraphs summarize the contents  of the
remaining chapters of this report, especially insofar as  those  chapters
illuminate current understanding of air quality problems, controls, and
administrative apparatus.  Since it takes  approximately one year to
assemble, analyze, and report air quality  and emissions data on a national
basis, the latest air quality and emissions data available for  this
report is for the year 1982.

8.   AIR QUALITY TRENDS, MONITORING,  AND MODELING

     With the exception of nitrogen dioxide, data trends  between 1975  and
1982 show continuing improvements across the country in ambient air
quality and total pollutant emissions.  For example:

     0 Annual  average ambient total  suspended particulate (TSP) levels
       decreased 15 percent from 1975 to 1982 while  TSP emissions  decreased
       27 percent.
       Annual  average ambient  levels  of  sulfur  dioxide  (SOg) decreased 33
       percent between 1975 and  1982  and  total  S02  emissions decreased 17
       percent.

       Ambient carbon monoxide  (CO) levels decreased 31 percent between
       1975 and 1982.   Total CO  emitted during  this time decreased 11
       percent.

       Average ambient nitrogen  dioxide  (N02) levels in 1982 were
       equivalent  to  the  1975 levels  so that no  long-term change was
       observed.   After increasing between 1975  and 1979, ambient N02
       levels  decreased by  7 percent  between 1979 and 1982.

       Average ambient ozone (03) levels  decreased  18 percent between
       1975 and 1982  due  to a combination of emission reductions and a
       change  in the  way  the monitoring instrument was calibrated.  Total
       emissions of volatile organic  compounds  (VOC's), which are ozone
       precursors, declined approximately 13 percent during this same
       period.

       Ambient  lead levels  measured at 53 urban  sites decreased 54 percent
       between  1975 and 1982.  This is consistent with a reduction in
       lead consumption in  gasoline of 69 percent in this period".

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                                   1-2
     EPA promulgated regulations in 1979 which required States to establish
and operate air monitoring networks and to report the data to EPA.   Two
types of permanent stations are provided for in the regulations:   State
and Local Air Monitoring Stations (SLAMS) and National  Air Monitoring
Stations (NAMS).  The SLAMS, which were designed to meet the overall
monitoring requirements of State Implementation Plan activities,  were
required to meet all provisions of the regulations by January 1,  1983.
Through December 1983, there were 4,682 SLAMS monitors  out of a total
planned network of 4,888 monitors that met all requirements of the regula-
tions.  The NAMS, which are a subset of the SLAMS network, are designed
to provide a national monitoring network as required by Section 319 of
the Act.  Through December 1983, there were 1,351 NAMS monitors out of a
total planned network of 1,362 monitors that met all requirements of the
regulations.

     During 1983, EPA continued its program to evaluate several categories
of models.  The evaluation of urban models was completed and the results
reaffirmed that these models are reasonably reliable in estimating the
magnitude of the highest concentrations occurring within an area.  The
evaluation of complex terrain models was initiated and will be completed
in 1984.  Efforts to incorporate a more current chemical mechanism in
ozone models used in regulatory applications were successful.  During
1984, computer software and documentation will be developed to facilitate
use of this procedure by the regulatory community.  Work continued on
developing techniques to calculate the effect of model  uncertainty on air
pollution control decisions.  Efforts to improve guidance on air quality
models and to ensure consistency in their use were continued as were
efforts  in the area of  receptor model development and application.

C.   AIR POLLUTION  RESEARCH PROGRAMS

     EPA's air pollution  research program was divided into four major
categories in 1983: Oxidants, Hazardous Air Pollutants, Gases and Particles,
and Mobile Sources.  The  research in each of  these areas was planned by a
Research Committee  composed of  EPA research managers and  representatives
from EPA's program  offices.  Each Research Committee planned the full range
of research for the pollutants  covered by that Committee.  The research
covered  scientific  assessments, monitoring systems and quality assurance,
health effects, environmental engineering and technology, and environmental
processes and effects.

      In  the oxidants area  in 1983, major efforts  included the convening
of national workshops to  collect data and to  discuss scientific  issues
necessary for revising  the  criteria document  for  ozone and other
photochemical oxidants, completion of the San Diego  Oxidant  Transport
Study, and  initiation of  an oxidant transport and impact  study in the
Ventura, California, area.   In  addition, several  controlled  human studies
on the health effects of  ozone  were completed as  were several studies on
animals  that investigated  various health effects  of  ozone and rritrogen
dioxide.  A number  of  research  projects  that  focused on reducing emissions

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                                   1-3
of volatile organic compounds and oxides of nitrogen from industrial
processes were undertaken.  Also, air quality models for use in developing
ozone abatement strategies were developed and tested and studies were
undertaken to assess the national impacts of ozone on major agronomic
crops grown in the United States.

     Research efforts related to hazardous air pollutants in 1983 included
development of comprehensive health assessment documents for a number of
different chemicals and compounds, gathering dose-response data on various
pollutants, and studying the mutagenic activity of organic emissions  from
combustion sources.  In addition, research in the hazardous air pollutants
area included studies of the atmospheric transport and fate of hazardous
volatile organic compounds in the atmosphere.

     Research in the gases and particles area in 1983 focused on air
pollution problems associated with particulate matter, sulfur dioxide,
lead, and the interactive effects of combining sulfur dioxide with
particles and other pollutants.  Research efforts included operating  an
inhalable particulate monitorin'g network, performing complex clinical
studies of the pulmonary response of asthmatics exposed to sulfur dioxide,
and performing animal toxicology studies of the effects of chronic
exposures to gases and particles.  Projects aimed at reducing sulfur
dioxide and particulate emissions from power plants and other sources
were undertaken.  Air quality models concerned with the transport and
rate of sulfur dioxide and particles were investigated.

     In the mobile sources area in 1983, research efforts emphasized
reviewing key studies included in the Agency's last criteria document  for
carbon monoxide, monitoring population exposures to carbon monoxide,  and
developing a bioassay system for testing of fuels, fuel additives, and
their emissions.  In addition, research efforts included characterizing
the gaseous and particulate emissions from in-use gasoline and diesel-
powered motor vehicles.

     Research efforts related to acid deposition continued to be a high
priority with EPA in 1983.  The Agency, in cooperation with the Interagency
Task Force on Acid Precipitation, conducted research in a number of areas
including the relationship between emissions and deposition, dose-response
functions and extent of potential impacts, and the costs and benefits  of
possible mitigation strategies.

0.   DEVELOPMENT OF NATIONAL AMBIENT AIR QUALITY STANDARDS

     The 1977 Clean Air Act Amendments require EPA to review and, if
necessary, revise the national ambient air quality standards (NAAQS)  on a
five-year basis.  Reviews of all  existing NAAQS were in progress in 1983.
One review resulted in revocation of the hydrocarbon (HC) NAAQS on the
basis that it was no longer appropriate and because more sophisticated
techniques are now available for designing ozone control  strategies.

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                                   1-4
     EPA continued to review the NAAQS for carbon monoxide, nitrogen
oxides, participate matter, and sulfur oxides.  Proposal of revised
standards for nitrogen oxides and particulate matter are scheduled for
1984.  Proposal of revised or reaffirmed standards for sulfur oxides is
scheduled for 1985.  In addition, work on revising the criteria documents
for lead and ozone continued in 1983 and the first external review draft
of the lead criteria document was released.

E.   REGULATOKY ASSESSMENT OF TOXIC AIR POLLUTANTS

     Assessments of the need to regulate a number of potential air toxics,
including polycyclic organic matter, acrylonitrile, toluene, carbon
tetrachloride, and five chlorinated organic solvents were in progress in .
1983.  An air toxics information clearinghouse was initiated by EPA in
order to assist State and local  control agencies in dealing with toxic
air pollutants.  Work continued to integrate toxics activities across the
various media and a system for screening and ranking potentially toxic
air pollutants was developed and applied in 1983.

F.   STATUS OF AIR QUALITY MANAGEMENT PROGRAMS

     A major accomplishment in the air quality management area in 1983
was the development of a policy  for dealing with those areas of the
country that had not attained applicable ambient air quality standards by
December 31, 1982, and were therefore liable for the imposition of various
sanctions under the Act.  This policy established a basic framework for
air quality management in the 1980's and beyond.

     Other accomplishments in 1983 included work leading toward the
development of revised regulations and guidance documents for State
implementation of the revised particulate matter national ambient air
quality standard and negotiation of a settlement agreement  with the
Environmental Defense Fund on a  suit that had been filed to compel EPA to
promulgate plans for protection  of visibility for States that had not
developed visibility plans.

     The Agency made considerable progress in 1983 in carrying out its
responsibilities under the Act regarding the preconstruction review of
new and modified stationary sources.  Part of this progress was reflected
in the increased number of States that assumed  responsibility for
implementation of the prevention of significant deterioration (PSD)
program.  In addition,  EPA entered into a settlement  agreement with
industry petitioners in the suit filed by the Chemica-1  Manufacturers
Association which challenged  the Agency's PSD and nonattainment new source
review programs.  This  agreement required that  EPA propose  certain regulatory
changes and the Agency  satisfied an important part of this  requirement  in
1983.

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                                   1-5
     One of EPA's most important air quality management initiatives
undertaken in 1983 was the development, in partnership with State and
local air pollution control agencies, of the National  Air Audit System.
This system was developed to contribute to the existence of nationally
consistent State and local programs that would pursue attainment of the
various objectives of the Clean Air Act.

     In 1983, EPA and the Natural Resources Defense Council (NRDC)  negotiated
a settlement agreement regarding EPA's actions in regard to State plans
implementing the national ambient air quality standard for lead.  The
agreement, which was entered by the court in July 1983. established
various schedules for obtaining State implementation plans (SIP's)  for
States that had not yet submitted them and for acting on State submissions
on which EPA had not taken final action.

     EPA continued to support various emissions trading activities  in
1983.  One group of such activities included bubble trades which allow
existing plants or groups of plants to treat all  of their emission  points
as though they wer^ under a giant bubble and thereby minimize control
costs by controlling the more cost-effective sources first.-  A second
such activity was emissions reduction banking which allows firms to get
credit for surplus emission reductions and to store them in a legally
protected manner.

     In 1983, EPA continued to provide technical  training in the abatanent
and control of air pollution.  Through classroom presentations, self-study
courses, graduate programs, and technical assistance to State training
efforts, 1766 individuals received training in a  variety of topics  during
1983.

G.   CONTROL OF STATIONARY SOURCE EMISSIONS

     In the area of stationary source controls, work progressed on  the
development of emissions standards for those major source categories not
yet regulated under new source performance standards (NSPS).  NSPS  for
five new categories were promulgated in 1983 and  existing NSPS for  two
categories were revised.  Ten promulgations are planned for 1984.  Control
techniques guidance documents for three source categories also were
published in 1983.

     Section 112 of the Act authorizes EPA to establish national emission
standards for hazardous air pollutants (NESHAP).   Regulations under this
section limiting coke oven emissions and benzene  emissions from a number
of sources in the chemical and petroleum industries were in preparation
in 1983 as were regulations governing asbestos emissions and arsenic
emissions from several sources.

     Also in 1983, EPA continued to make progress in delegating responsibility
for implementing NSPS and NESHAP programs to the  State and local air
pollution control agencies.  EPA also continued to maintain the best

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                                   1-6
available control  technology/lowest achievable emission rate (BACT/LAER)
Clearinghouse in order to assist State and local  agencies in their BACT
and LAER determinations.

H.   STATIONARY SOURCE COMPLIANCE

     As of the end of 1983, approximately 89 percent of the stationary
sources in the country were reported as achieving compliance with applicable
air pollution control regulations and an additional  3 percent were in
compliance with schedules to install controls.  Whereas past enforcement
efforts have focused on sources of particulate matter and sulfur dioxide,
future efforts will be also directed toward other problems of significance
such as volatile organic compounds.

     EPA also made considerable progress in the first 21  months of the
significant violator program.  An initial list of 482 sources was established
and an additional  340 sources were identified after the initial list was
established.  In this same period, 484 sources (representing the vast
majority of the original list)  were brought into compliance or placed on
an acceptable compliance schedule.

     In 1983, EPA developed a compliance strategy for stationary sources
of air pollution wnich will serve as the basis of the compliance program
for the immediate future.  The strategy emphasizes resolving violations
by significant violators.  It places emphasis on allowing the States more
flexibility in implementing inspection programs, increasing the use of
continuous emission monitoring  and similar techniques, and emphasizing
compliance by sources that violate VOC provisions of tne SIP's.

     In 1982, EPA issued a policy on enforcement against  sources in
primary nonattainment areas (other than areas that had received an attain-
ment date extension) not in compliance with the Clean Air Act on or after
December 31, 1S82.  Of the 226  sources initially subject  to the policy,
140 sources had been brought into final compliance or had been placed on
Federal or State compliance schedules by the end of 1983.  The remaining
sources on the list generally had some type of Federal or State action
pending or in process that would resolve the violation.

     EPA directed a considerable portion of its air enforcment efforts in
1983 toward compliance with NESHAP.  Two cases were settled and eleven
cases were filed regarding the  vinyl chloride NESHAP while two cases were
filed to enforce the asbestos NESHAP.

     Under the Steel Industry Compliance Extension Act (SICEA), EPA was
given authority to extend, for  eligible corporations, deadlines for
meeting air pollution requirements.  During 1983, EPA's air enforcement
program completed action on all applications submitted under SICEA by
filing implementing decrees for those companies found to be eligible
under the Act and by pursuing enforcement actions against those companies
found not to oe eligible.

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                                   1-7
I.   CONTROL OF MOBILE SOURCE EMISSIONS

     In 1983, EPA undertook a number of standard setting activities
related to various vehicle categories.  One action was the promulgation
of final rules for 1984 and later model year light-duty vehicles and
trucks that implement the provisions of Section 206 of the Act related to
compliance with national emission standards regardless of altitude.  In
addition, EPA promulgated a final rule allowing manufacturers to demonstrate
compliance with diesel particulate emission standards on a fleetwide
average basis.  Other regulatory activities included promulgation of a
new standard for evaporative emissions from heavy-duty trucks with gasoline
engines, modification of useful  life definitions for light-duty trucks
and heavy-duty engines, and revision of the hydrocarbon and carbon monoxide
standards from 1985 and later model  year heavy-duty trucks.

     In 1983, EPA extended a pilot program allowing alternative methods
in determining the durability of emission control  systems in light-duty
vehicles and trucks.  EPA also proceeded with a study whose goal is to
identify the most efficient ways to  achieve in-use vehicle compliance
with emissions standards.  In addition, the Agency also took steps to
assure that inspection maintenance (I/M) programs  were implemented in
each locality where they are required.  By the end of 1983, 20 areas in
31 States nad initiated 1/M programs.

     EPA undertook in 1983 a number  of actions related to enforcement of
motor vehicle emissions standards and fuel regulations. .These included
requiring the recall of vehicles with emissions problems, issuing decisions
on requests from automobile manufacturers for waiver of NOX standards for
diesel  engine Cowered automobiles, and conducting  inspections to measure
the lead content of fuels.  In addition, EPA promoted the initiation of
State and local  programs aimed at deterring tampering with vehicle emissions
control systems, developed guidelines for State and local  anti-tampering
and anti-fuel  switching programs, and modified its program to deal  with
imported vehicles to make the process work more smoothly and efficiently.

J.   LITIGATION

     The U.S.  Courts of Appeals  decided lb cases under the Clean Air Act
in 1983.  The most important case decided in 1983  was Small  Refiner Lead
Phase-Down Task  Force v. EPA in  which the O.C. Circuit upheld most aspects
of EPA's decision to reformulate its lead-in-gasoline regulations in a way
that would increase their stringency over time and modify certain provisions
related to small  refiners.

     Four other decisions related to various aspects of EPA's motor
vehicles control  program.  Other decisions in 1983 related to the areas of
sulfur oxides control, prevention of significant deterioration, the system
for attaining air quality standards, and EPA's regulations for assessing
penalties under Section 120 of the Act.

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            II.  AIR QUALITY TRENDS, MONITORING, AND MODELING


      This  chapter describes current trends in ambient air quality levels
 (the  concentration of  a given pollutant in the atmosphere) as well as
 trends  in  the estimated emissions into the air of the various pollutants,
 In  addition, the chapter discusses the topics of air quality monitoring
 and air quality modeling.  Data on ambient air quality  levels and
 emissions  are through  1982, the latest year for which EPA has complete
 statistics.

 A.  NATIONAL AIR QUALITY AND EMISSION TRENDS*

    National long-term (1975 through 1982) improvements can be seen for
 sulfur  dioxide (SOg), carbon monoxide (CO), and lead (Pb).  Improvements
 can also be seen for ozone (03) and nitrogen dioxide (N02) in the period
 1979  through 1982 and  for total suspended particulate (TSP) between
 1978  and 1982.

      In the case of 03, a major drop in ambient concentration levels
 occurred between 1978 and 1979 largely due to a change in the 03 cali-
 bration procedure.  Therefore, special  attention is given to the 1979
 through 1982 period because the change in the calibration procedure is
 not a factor during this time.

      All of the ambient air quality trend analyses  which follow are
 based on monitoring sites which recorded at least 6 of the 8 years of
 data  in the period 1975 through 1982.   In each of these years,  annual   •
 data  completeness criteria also had to be met.  As  a result of  these
 criteria, only a subset of the total  number of existing sites  are used
 for trends purposes.

    Total  Suspended Particulate (TSP)  -  Annual  average TSP levels
 measured at 1768 sites decreased 15 percent from 1975  to 1982.   This
 corresponds to a 27 percent decrease in estimated TSP  emissions  during
 this period.  TSP air quality  levels  generally do not  improve  in  direct
 proportion to estimated emission reductions because air quality  levels
 are influenced by factors such as  wind  blown  dust  and  reentrained
 street dust which are not included in  the emission  estimates.   Most of
 the air quality improvement occurred  during the  last several years, and
was due not only to reductions in  TSP  emissions,  but also to more
 favorable meteorology in  1982.   An analysis of meteorological conditions
 for 19"82 indicated a potential  for lower TSP  concentrations  due  to
abnormally high precipitation.

Sulfur Dioxide (SO?)  -  Annual  average  $03 levels measured  at 351
sites  with continuous S02 monitors decreased  33  percent  from  1975 to
1982.   A comparable decrease of  39 percent was observed  in  the trend  in
the composite  average of  the second maximum 24-hour  averages.- An even

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greater improvement was observed in the estimated number of exceedances
of the 24-hour standard, which decreased 91 percent.  Correspondingly,
there was a 17 percent drop in sulfur oxide emissions during this period.
The difference between emissions and air quality trends is believed to
arise because the use of high sulfur fuels was shifted from power
plants in urban areas, where most of the monitors are, to power plants
in rural areas which have fewer monitors.  Further, the residential and
commercial areas, where the monitors are located, have shown sulfur
oxide emission decreases comparable to SOg air quality improvements.
These decreases in sulfur oxide emissions are due to a combination of
energy conservation measures and the use of cleaner fuels in the residential
and commercial areas.

     Carbon Monoxide (CO) - Nationally, the second highest nonoverlapping
8-hour average ambient CO air quality levels at 196 sites decreased at
a rate of approximately 5 percent per year, with an overall  reduction
of 31 percent between 1975 and 1982.  An even greater improvement was
observed in the estimated number of exceedances, which decreased 87
percent.  CO-emissions decreased 11  percent during the same period.
Because CO monitors are typically located to identify potential  problems,
they are likely to be placed in traffic saturated areas that may not
experience significant increases in vehicle miles of travel.  As a result,
the air quality levels at these locations are expected to improve at a
rate faster than the nationwide improvement in emissions.

     Nitrogen Dioxide (N02) -  Annual  average N02 levels, measured at
276 sites, increased from 1975 to 1979 and then began declining.  The
1982 ambient N02 levels are equivalent to the 1975 levels, so that
there is no long-term change.  The trend pattern in the estimated nation-
wide emissions of nitrogen oxides is similar to the N02 air  quality
trend pattern, with nitrogen oxides  emissions increasing only by a total
of 5 percent between 1975 and 1982.   Between 1979 and 1982 both  ambient
N02 levels and nitrogen oxide emissions showed reductions of 7 and 5
percent, respectively.

     Ozone (03) -  Nationally, the composite average of the  second-
highest daily maximum 1-hour 03 values, recorded at 193 sites, decreased
18 percent between 1975 and 1982.  An  even greater improvement was
observed in the estimated number of  exceedances in the ozone season
(July-September), which decreased 49 percent.  Volatile organic  compound
(VOC) emissions decreased 13 percent during the same time period.   The
greater improvement observed in ozone  levels than emissions  may  be due,
in part,  to the non-linear relationship between VGC emissions  and  ambient
ozone levels, and also to the change in the calibration procedure  which
took  place between 1978 and 1979.  To  eliminate the influence  of the
calibration change, trends were examined for the 1979-1982 time  period.
Ozone levels improved by 9 percent  from 1979 to 1982,  a period which
was not influenced by the calibration  change.

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                                  II-3
     Lead (Pb) - The composite maximum quarterly average of ambient
     air quality levels, recorded at 53 urban sites, decreased 64 percent
between 1975 and 1982.  This sample of sites satisfied a minimum of 6
years of data in the 1975-82 time period and were heavily weighted by
sites in Texas (51  percent) and Pennsylvania (23 percent).  In all  a
total of only six States were represented in the sample.  In order to
increase the number of sites and their geographical  representativeness
lead trends were studied again over the 1979-82 time period.  A total
of 214 urban sites from 21  states satisfied the minimum data requirement
of at least 3 out of the 4 years of data.  An improvement in ambient
lead concentrations of 43 percent was observed at these sites as compared
with an improvement of 54 percent for the 46 sites mentioned above over
this same 1979-82 period.  Even this larger group of sites was
disproportionately weighted by sites in California,  Pennsylvania, Texas,
Arizona, Illinois, and Minnesota.  These six states  accounted for almost
79 percent of the 214 sites represented.  Contributing to the decrease
in national ambient lead levels was the fact that lead consumed in
gasoline dropped 69 percent from 1975-82, primarily  due to the use of
unleaded gasoline in catalyst-equipped cars and the  reduced lead content
of leaded gasoline.

B.   AMBIENT AIR MONITORING

     General

     Section 110(a)(2)(C) of the Clean Air Act requires State Implementation
Plans to include provisions for establishment and operation of systems
for monitoring ambient air quality.  In addition, Section 319 of the
Act requires the development of uniform air quality  monitoring criteria
and methods and the establishment of an air quality  monitoring system
throughout the United States which uses uniform monitoring criteria and
methods.  To satisfy these requirements EPA promulgated regulations in
1979 which required States to establish and operate  air monitoring
stations and to report the data to EPA?.  The two principal types of
stations in the State networks are State and Local Air Monitoring
Stations (SLAMS) and National Air Monitoring Stations (NAMS).  The moni-
toring stations of the SLAMS and NAMS must adhere to the uniform moni-
toring criteria described in the regulation.  These  criteria cover quality
assurance, monitoring methods, network design, and probe siting.
January 1, 1981 was the deadline by which all NAMS were to meet all of
the requirements in the regulations.  The SLAMS had  until January 1,
1983 to meet all of the provisions in the regulations.

     Overall, State and local progress in meeting the requirements of the
regulations has been excellent.  Tables 1 and 2 summarize the SLAMS and
NAMS status through December 1983.  Table 3 lists, by pollutant, the number
Of SLAMS and NAMS.

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                                  II-4
                Table 1.   SLAMS Status  through  December 1983


                                                 Number of       Percent  of
                                                  Monitors         Network

Total  planned network*                              4888            100

Monitors operational                                 4763             97

Monitors in operation meeting all  require-          4682             96
  ments of the regulations

 *  Includes NAMS monitors
                Table 2.  NAMS Status through December 1983


                                               Number of        Percent of
                                                Monitors          Network


Total planned network                             1362             100

Monitors operational                              1351              99

Monitors in operation meeting all                 1351              99
   requirements of the regulations


     Table  1 shows  a total of 4888 planned SLAMS monitors of which 4763 or
97 percent  were in  operation.  This number is about the maximum expected
since monitoring station  shutdowns routinely occur because of lost leases,
urban renewal projects, and changing ambient air monitoring priorities.
Of these 4763 operating monitors, 4682 or 96 percent of the total monitors
are meeting all requirements of the regulations.  The remaining operating
monitors should meet the  requirements with some small changes in monitor
siting  and  improvements in the standard operating procedures.

     Table  2 shows  that of the 1362 planned NAMS, 1351 or 99 percent were
in operation and were meeting all requirements of the regulations through
December 1983.

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                                      II-5
        Table 3.  National Summary of Planned Air Monitorinq Stations
Pollutant
TSP
S02
N02
CO
03
Pb
SLAMS
(including NAMS)
2574
583
298
450
612
371
NAMS
644
222
58
115
216
107
TOTAL 4888 1362
     Particulate Monitoring

     As discussed in Chapter IV of this report, EPA plans to propose revisions
to the national ambient air quality standards for particulate matter in  1984.
One change considered is the establishment of standards for that fraction of
particulate matter that is composed of particles that are nominally 10 micro-
meters or  less in size
     During 1983, data collected during 198U and 1981 in the 120 site
National Inhalable Particulate Monitoring Network were used to develop  a
procedure to use total suspended particulate (TSP) data to estimate the
likelihood that a monitoring site would violate specified national  ambient
air quality standards (NAAQS) for PM^Q.  Since very little PM^g air quality
data are available, the methodology is expected to be useful  in establishing
PM^Q monitoring and control  priorities, should a PMjo NAAQS be promulgated.
Additional  efforts were underway to examine TSP-PM^o relationships  in the
Inhalable Particulate network to see whether they are affected appreciably
by geographic location, microscale differences, or other factors.   The
methodology was used to examine 1980-82 TSP data at approximately  2000
sites for which TSP data were reported to EPA in order to estimate each
site's  likelihood of violating prospective PM^o NAAQS.  Data from  sites
judged most likely to violate prospective NAAQS were reviewed with  the  EPA
Regional Offices to rule out natural events, temporary construction
activities, and spurious data as reasons for the estimated high probability
of violation.

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                                    II-6
C.   AIR QUALITY MODELING

     An air quality model is a set of mathematical equations that describe
the atmospheric transport, dispersion, and transformation of Pollutant
emissions   By means of these equations, a model can be used to calculate
or "edfct the air quality impacts of emissions from proposed new sources,
emissions from existing sources, or changes In emissions J™ «'^r °'
these source categories.  These models are of great utility because they
provide a means whereby the effectiveness of air pollution controls can
be estimated before action is taken.

     During  1983,  a major EPA program to evaluate several categories of models
was continued.  This program was developed in response to recommendations
of  the  American Meteorological  Society  (AMS) under  its cooperative agree-
ment with  EPA. 3   The evaluation of urban models was complied.   The
evaluation  of  complex  terrain models was  initiated  and will be completed
 in  1984   A test  evaluation of  two short-term,  long-range transport models
was  completed;5 this will  serve as the  basis for  a  more  complete evaluat  on
of  6-8 such models during 1984-85.   The evaluation  of mobile  source models
will  also  be initiated in 1984.   Guidance  was completed  for the  use of
 a newer chemical  mechanism in  the EKMA  model widely used in State
 Implementation Plans  for ozone.   During 1984,  computer  software  and
 documentation will be  developed which will  facilitate  the  use of  newer
 chemical  mechanisms by the regulatory community.

      The evaluation of urban  models  reaffirmed  that these models are  reason-
 ably reliable in  estimating the magnitude of the highest concentrations
 occurring within an area.  For long-tern, models there was little bias and
 the estimates were generally  quite good.  For short-term models there was
 somewhat greater variability in estimating the maximum concentrations and
 poor ability (as expected) in accurately estimating concentrations that
 occur  at a specific time and site.

      The rural6-7 and urbanS models were also subjected to peer scientific
  reviews through  a cooperative agreement with the American Meteoro ogical
  Society    The reviewers  found all the models considered to be basically
  sim far', with common  deficiencies in the extent to which they represent
  the current state-of-the-art.  Recommendations for improvement were
  provided!   While some concern was expressed about  poor model performance
  when  pairings  in space  and time are considered   it was  recognized that
  good  agreement may be impossible to  attain with  current models  and
  data  bases.   Agreement  with observations  at the  upper percent!les,
  as  has already been demonstrated, may  be  all that  can be expected for
  the  present.   A  peer  scientific  review of complex  terrain models  TS
  planned  for 1984.

       Work continued  on  the explicit  consideration  of model uncertainty
  in decision-making.   A  preliminary  technique to  directly .calculate the
  effect of model  uncertainty  on air  pollution  control  decisions  «as
  developed.9  During  1984 demonstration of this technique  for typical

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                                    II-7
applications and analysis of its sensitivity to various factors should
be possible.  As a result, a quantitative assessment of the effects of
model performance on effective and reliable control regulations for air
pollution sources may eventually become available for use by decision-
makers.

     Efforts to improve guidance on air quality models^ and to ensure
consistency in their use have also continued.  Additional  efforts were
undertaken to promote consistency between modeling applied in national
regulatory impact analyses for automotive pollutants and in State
Implementation Plans.  These efforts led to guidance regarding ozone
modeling and closer scrutiny of design values and growth rates assumed in
analyses for 03, CO, and N02-  In addition, ozone modeling analyses
submitted in connection with 1982 SIP's were scrutinized more carefully
than ever before for technical  accuracy.  The Air Quality Model Clearing-
house activities were continued to ensure that use of nonguideline techniques
does not lead to inconsistent regulatory decisions.  A workshop was held
with modeling contacts in EPA's ten Regional Offices to improve communi-
cations on the use of models and to resolve problems common to several
Regions.  Guidance on such problems was expanded and circulated to these
offices.  In addition, draft revisions to the "Guideline on Air Quality
Models" were completed.  Based on the results of the cooperative agreement
with the American Meteorological Society, other contacts with the technical
community, and extensive in-house analyses, guidance on models and associated
data bases for specific regulatory programs was improved.   A preliminary
draft of the guideline was circulated to selected Federal  and State
governmental  agencies; their comments have been incorporated.  In 1984
the revised guideline will be subjected to a public hearing and comment.
The hearing will be conducted in conjunction with the Conference on Air
Quality Modeling (Third) which is required at three year intervals by
Section 320 of the Clean Air Act.  The guideline will  be incorporated by
reference in the PSD regulations, with final promulgation  pxpected in
1985.

     Work also continued in the area of receptor model  development and
application.   A receptor model  is an analytical  procedure  which begins
with monitored air quality data and attempts to draw inferences about
sources causing observed high ambient concentrations of pollutants.
These methods require some knowledge of the characteristics of ambient
and source samples which can be gained through chemical  analysis and/or
analysis of individual particles [as in the case of particulate matter(PM)].
Receptor models are likely to be utilized in performing source apportionment
studies in areas which fail  to meet prospective national  ambient air
quality standards for PM^Q.   To assist the States in preparing control
strategies, guidance on the application of receptor models will  be included
as a part of  the guidance to be developed for PM^g State Implementation
Plan (SIP) preparation.  In  addition to guidance concerning the use of receptor
models in SIP's, several  reports describing the uses,  capabilities, and
limitations of several specific receptor models have been  issued.i*»12
These reports are part of an ongoing series of descriptive documents for
specific receptor modeling approaches.

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                                   II-8
D.   INTEGRATION OF AIR DATA SYSTEMS

     The Aerometric Information Reporting System (AIRS) is a new integrated
data system being developed by EPA to replace entirely the existing data
bases, files, and software now used by the Agency for storing and retrieving
ambient air quality data, stationary source and emissions  data,  and
source compliance data.  The AIRS project was fully approved by  senior
EPA management in December 1980 after the earlier comprehensive  feasibility
study revealed the advantages of a truly integrated data system.  Detailed
performance specifications were completed in 1981-82 which defined the
overall structure of AIRS.  AIRS will be composed of two relatively
separate components (air quality and facility data) but will  use common
sets of geographical and other codes and draw upon a state of the art
data base management system.

     In 1983, work progressed on the air quality component of AIRS.  This
segment is expected to be fully available for use by the States  by late
1985 with pilot installations at the State level  in 1986.

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                     III.  AIR POLLUTION RESEARCH PROGRAMS


     EPA's Office of Research and Development (ORD) provided extensive technical
support to EPA's air pollution control  activities in 1983.  ORD's air research
program is divided into four major categories:   Oxidants, Hazardous Air Pollutants,
Gases and Particles, and Mobile Sources.  The research in each of these areas
is planned by a Research Committee composed of  ORO managers and representatives
from EPA's program offices.  Each Research Committee plans the full range of
research for the pollutants covered by  that Committee.  The research covers
the areas of scientific assessments, monitoring systems and quality assurance,
health effects, environmental engineering and technology, and environmental
processes and effects.  The discussion  of 1983  research accomplishments is
organized along these lines.  In addition to the discussions of the four major
air research programs, a discussion of  ORD's research program on acid deposition
is included.

A.   OXIDANTS

     The oxidants research program focused on air pollution problems associated
with ozone, nitrogen dioxide, and volatile organic compounds (VOC's).

     Scientific Assessments

     National workshops were convened to collect data and discuss scientific
issues necessary for revising the criteria document for ozone and other photo-
chemical oxidants.  The external review draft of the criteria document is
scheduled to be completed in 1984 and the final  document published in
1985.

     Monitoring

     Two additional  standard ultraviolet spectrophotometers were delivered
to EPA by the National Bureau of Standards.  These units, in addition to
those to be delivered in the 1984 to 1986 timeframe, will oe used by the
EPA Regional Offices as standards to calibrate  field units utilized in
measuring ozone.  The National  Atmospheric Background Network was terminated,
and a final report is being prepared.  This network provided background
data on ozone concentrations in remote  National  Forests for use in determining
trends throughout the United States.  Research  continued on the development
of a cryogenic system for trapping and  measuring VOC's and non-methane
organic hydrocarbons.  The San Diego Oxidant Transport Study1 was completed
and the first phase  of an oxidant transport and  impact study was initiated
in the Ventura, California, area.

     Health Effects

     Several controlled human studies of the effects of ozone were completed.
These studies describe changes  in pulmonary structure and function, blood
chemistry, and host  defense mechanisms  following inhalation of'ozone at various

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                                  III-2
concentrations.  Data was collected on three potentially susceptible sub-
populations: persons with naturally-occurring respiratory infections,
individuals with allergic rhinitis ("hay fever"), and children.  Data from
these studies are being analyzed.  Two other studies of potentially
sensitive groups were continued.  The first is a study of asthmatics to
determine if they are more or less sensitive to ozone than a normal
population, and the second is a study that compares the sensitivity of
various health groups (blacks, whites, males and females) to ozone.

     A study was completed which further defined effects seen previously in
guinea pigs, namely, that vitamin C deficiency enhances the pulmonary
toxicity of nitrogen dioxide.  Several studies of ozone toxicity were
performed on animals with health conditions similar to human ones, such  .
as respiratory infection and asthma.  Some of the animals were exposed to
ozone in a manner similar to the pattern of exposure for humans wnile
others were exposed chronically to determine if there are long-term
effects of ozone exposure.

     A workshop, sponsored by -the Ayency, was held to identify extrapolation
research needs for EPA.  This workshop, which was .attended Dy experts from all
over the country, provided a forum for discussing the current state-of-the-
art, and a basis upon which to formulate an extrapolation research strategy
for cne future.2
     Environmental Engineering and Technology
     Research activities focused on reducing emissions of VOC's and
oxides of nitrogen (NOX) from industrial processes.

     In the VOC area, research focused on the usefulness of carbon adsorption,
thermal and cata'iytic oxidation, and safety relief systems.  Pilot-scale
testing was initiated to investigate the design, cost, and performance of
the carbon adsorption technology, and catalytic oxidation was field
evaluated at six sites.  Other studies demonstrated that the cost of
controlling VOC emissions for paint bake ovens can be substantially
reduced Dy the use of a microprocessor.3

     In the NOX area, a prototype heavy-oil, low-NOx burner was fabricated
for evaluation on an enhanced oil-recovery steam generator.*  The dilution of
primary combustion air with inert gas (vitiation) was identified for a cement
kiln as one of the most effective combustion modification techniques for NOX
control.^ Initial tests on a coal-fired, dry-rotary cement kiln have
shown that vitiation can reduce NOX emissions by approximately 40 percent.
Effective NOX reduction approaches were also identified for applica-
tion to spark-ignited, gas-fired and diesel engines.6  Tests of a gas-
fired internal combustion engine equipped with a nonselective reducing
catalyst showed NOX reductions of 7(J percent; tests are undrway to evaluate
tne effectiveness of a selective catalyst.  Small pilot-scale tests of
in-furnace NOX reduction via secondary fuel injection using natural gas
(reburning technology) have shown reductions as much as 6(J percent whereas

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                                   III-3
smaller-scale coal-fired tests achieved 50 percent reductions.  Natural
draft  staging-air  systems were evaluated for refinery process heaters.7
NOX reductions of  approximately 50 percent with a gain in thermal efficiency
of approximately 2.5 percent were achieved for gas firing.  Correlations
useful  in predicting NOX emissions for specific fuels were developed as a
function of coal properties using experimental data from 46 coals.

     Environmental  Processes and Effects

     The primary focus of the research in this area is the development and
testing of air quality models for use by the States in the development of State
Implementation Plans (SIP's) ror ozone abatement strategies.  Smog chamber
studies, which simulate atmospheric reactions, were conducted to determine
the role of VOC's  in producing elevated levels of ozone.  Studies on perchloro-
ethylene indicated  that this compound may not be as important in producing
ambient ozone as previously thought.8  The scientific data base obtained from
the smog chamber studies will be used in future studies to develop and test
improved ozone chemical mechanisms for use in air quality models.

     Evaluation studies of a first generation regional model were conducted
and the preliminary results of the model's predictive capability were successful
Wnen verified, it  will be used to calculate the extent of long-range transport
of ozone and its precursors from one urban area to another.

     In the air ecology program, research focused on the development of scien-
tific data to assess the national  impacts of ozone on major agronomic crops
grown  in the United States.  Studies to determine the effects of ozone on
thii yield of major crops through a national  network of field research
sites were conducted.  Experimental  results were integrated to develop a
dose/yield response data base and economic and crop yield assessment
techniques were developed for use in a preliminary national  assessment of
ozone  impacts.  This assessment is scheduled to be completed in 1984.  To
improve the accuracy of the assessment,  sources of uncertainty such  as
soil  moisture relationships, the effects of differing air quality conditions,
and the evaluation of the impacts  of ozone on hay crops are being assessed.

B.   HAZARDOUS AIR POLLUTANTS

     The pollutants covered by the hazardous air pollutants research
program are those air pollutants that  are either currently  regulated or are
potential  candidates for being regulated under the Clean Air Act or  other
appropriate legislation.

     Scientific Assessments

     Efforts to develop comprehensive  health assessment documents for
chlorinated benzenes, dioxins,  hexachlorocyclopentadiene,  cadmium, mercury,
beryllium,  and vinyl chloride were initiated.  Peer review  workshops were
held  for draft  documents on chloroform,  chlorinated benzenes,  chromium,
dioxins, epichlorohydrin,  ethylene dichloride,  and ethylene ox'ide.

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                                  III-4
Several documents were released for public review and comment in 1983 or
early 1984  as follows:  carbon tetrachloride 9 nickel,10 cadmium H
manganese,12 chromium,13 vinylidene chloride,14 epichlorohydrin iS
trichloroethylene,15 tetrachloroethylene 17 methylene chloride,18 asbestos,19
hexachlorocyclopentadiene,^0 chloroform,21 ethylene dichloride,22 and
ethylene oxide.23 Following EPA Science Advisory Board review, documents on
toluene,24 acrylonitrile,25 chlorofluorocarbon CFC-113,26 coke oven emissions,27
methyl chloroform,2° and inorganic arsenic29 were published.

     Health Effects

     Major accomplishments were achieved in gathering dose-response data for
various hazardous air pollutants.  A mammalian cell  study was completed which
showed 1-nitropyrene emissions to be mutagenic.  Further work will  be done to
determine the comparative potency of these emissions.  Behavioral  and electro-
physiological changes were measured in animals exposed to toluene.   Data from
this study were scheduled to be analyzed in 1984.   Nickel, manganese, and
cadmium compounds were administered to animals and xenobiotic metabolism
was studied.  Alterations in biochemical mechanisms  were found,  but the
significance of these changes will not be known until the data are  analyzed
in 1984.  Respiratory infectivity was studied in animals exposed to 2.5
parts per million (ppm) ethylene trichloride, 1.0 ppm toluene, or 75.0
ppm chlorobenzene.  The results show no significant  increase in  susceptibility
to respiratory infection.

     Preliminary studies were completed on the kinetics of toluene  following
acute exposures in animals, and the data are being analyzed.  Further develop-
ment and validation of a test battery will  proceed when the studies are published.
Mutagenic activity of organic emissions from combustion sources  was compared
using cellular bioassays.  Extractable organics were found to be fairly inactive
(within two orders of magnitude),  whereas particle-bound organics varied by as
much as five orders of magnitude.

     Monitoring

     Two journal  articles on reduced temperature preconcentration of volatile
organics for gas chromatographic analysis were submitted.30  A draft report on
the Background Phase of Arsenic Monitoring near cotton gins was  completed.
Trace elements and benzo-a-pyrene were analyzed in filter samples from the
national  network.   Field tests of source methods for vinyl  chloride,  arsenic,
asbestos,  and hexavalent chromium were carried out.   Reference materials for
benzene,  tetrachloroethylene,  and other organic vapors were issued  by the
National  Bureau of Standards.

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                                  III-5
Environmental  Processes and Effects

     The overall goal of this program is to develop a data base of information
on the atmospheric levels of potential  hazardous air pollutants,  their
lifetimes in the atmosphere, and their fate.   In particular,  the  program
focuses on the atmospheric transport and fate of YOC's.   In 1983,  a report
was prepared which identifies existing air quality data  bases obtained
through a variety of previously conducted studies on potentially  hazardous
YOC's in the atmosphere and assesses the scientific quality and applicability
of these data bases.31  The information will  be useful  to the Agency in
preparing overall assessments on the importance of specific VOC's  in the
atmosphere.

     Also in 1983, a final report was prepared on an ambient characterization
field study  in which the atmospheric concentrations and  transformation
products of approximately 45 potentially toxic air pollutants were determined
for ten urban areas of the United States.32  This work will  provide useful
information  on the temporal and spatial  distribution of  toxic air  pollutants
in urban atmospheres.

C.   GASES AND PARTICLES

     The Gases and Particles research program focuses on air pollution problems
associated with particulate matter, sulfur dioxide (S02), and lead, and the
interactive  effects of combining 302 an^ particles with  other pollutants such
as ozone and nitrogen dioxide.

     Scientific Assessments

     National  workshops were convened to collect data and discuss  scientific
issues pertinent to revising the criteria document for  lead.33 The external
review draft was completed and  released.  The final  document  is scheduled to
be completed and published in 1985.

     Monitoring

     In 1983,  the 130-station Inhalable Particulate (IP)  Network was operated
successfully.   Twenty stations  will remain operational  for Federal  data-
collection efforts and the remainder of the equipment is being refurbished
for distribution to the States  for their use  in operating particulate
monitoring sites.

     A wind  tunnel was designed and constructed.   The tunnel  is being operated
to test the  operational  characteristics  of various devices under simulated
environmental  conditions for different kinds  of particulates  and different
particulate  loadings.

     A study was initiated to document the visibility impairment caused
by plumes from sources in Ventura, California, as these  plumes moved over
the nearby mountains into adjoining areas.

     Quality assurance activities continued for the National  Air Monitoring
Sites/State  and Local Air Monitoring Sites (NAMS/SLAMS)  and IP networks.

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                                   III-6
      Health  Effects

      A  research  strategy  for quantitative extrapolations was developed by
 EPA  scientists,  witn  input from outside experts.  This strategy provides
 a  broad framework  for performing dosimetry and sensitivity  studies to
 develop improved risk assessments.  As part of the Agency's extrapolation
 efforts,  tne lung  structure of adult and infant humans and  several species
 of animals were  compared  as a preliminary step in determining species
 sensitivity  to gases.

      Complex clinical studies of the pulmonary response of  asthmatics
 exposed to $03 were completed.  The data have been analyzed and the
 studies were scheduled to be reported  in 1984.  These studies describe
 group responses  as functions of both S02 concentrations and length of
 exposure, and describe individual responses to SC>2 to determine bronchial
 sensitivity  to S0;>.  Another clinical study measured the acute physiological
 response  of  normal people rollowing inhalation of gases and particles,
 alone and in  combination.

      To complement the clinical work, animal  toxicology studies were done
 of chronic exposures to gases and particles,  alone and in combination,
 measuring changes  in pulmonary physiology, immunology, and  lung morphology.
 Both  normal   and  emphysemic rats were exposed.  In another study of gases
 and  particles, two groups of animals were shown to have increased suscep-
 tibility to  bacterial lung infection following a total  exposure of 103
 days.   Intratracheal  instillation was used in a study of the comparative
 potency of several  coarse mode particles in animals.  In this study,  animals
 were  exposed  to  ferric oxide, calcium carbonate, and sodium feldspar,
 which have been thought to be benign.  They were also exposed to silica
 dust, which  is known to cause immunological  decrements.  All or the
 particles were found to be roughly equivalent in potency, indicating  that
 some coarse mode particles may be more toxic  than previously thought.

     Environmental  Engineering and Technology

     A  co-sponsored full  scale demonstration  program at the Louisville Gas
 and Electric Company's Cane Run Facility in 1983 verified that  the dual
 alkali  process is a reliable flue gas desulfurization alternative.  The
 program demonstrated that high S02 removal  efficiency (over 90  percent)  can
be sustained at a high reliability (less than 10 percent shutdown) 34
Another system assessed was  the use  of  adipic acid which was tested at
 the TVA Shawnee Power Station near Paducah, Kentucky.  Sulfur dioxide
 removal  efficiencies in excess  of 90 percent, and  reliable  scrubber
operation were achieved.35  The addition of adipic acid  to  a wet limestone
 flue gas desulfurization  system was  also evaluated at the Rickenbacker Air
 National Guard Base near  Columbus,  Ohio.36  The efficiency  of  sulfur  dioxide
removal  was  raised  from 55 percent  to  over  90 percent in a  30-day  test
period.

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                                   III-7
      In cooperation with the Electric Power Research  Institute and tht
Southern Company Services Utility Company, EPA has developed and demonstrated
that  adding amounts of sodium to coal feed can increase performance of coal
burning power plants equipped with "hot side" electrostatic precipitators
(ESP's).37  These results were obtained with a 195 Megawatt (MW) coal-fired
unit.  Sodium conditioning reduced particulate emissions by 9(J percent.

      Two concepts of using two-stage ESP's for new power plants using low
sulfur coals were evaluated.  The two-stage precipitators were developed
for pilot unit demonstrations at the TVA Bull Run Station and Public
Service of Colorado's Valmont Station.  Results indicate that two-stage
precipitators substantially improve the performance of ESP's when low
sulfur coal is burned.38

      Tne use of fabric filters (baghouses) to remove particles from gas
streams is of growing importance.  Conventional  fabric filter design does
not consider tne electrical properties of eitn^r the dust or the fabric.
Research has shown tnat electrostatic forces influence the way in which
the particles interact with cite fabric and other particles.  An electro-
statically augmented fabric filter (ESFF) was developed and installed on
several pilot-scale baghouses including an industrial boiler site at the
DuPont Company Plant in Waynesboro, Virginia, and at a Southwestern
Public Service Company facility in Amarillo, Texas.  Results show that
the ESFF bayhouse has significant advantages over conventional  baghouses.3^
The primary effect is a 50 percent reduction in  pressure drop  across the
filter bags, and greater operating staoility and reliability.

     An evaluation of conventional  fabric filter baghouses for particulate
control in electric utility applications was completed and tne data made
available to support the review of the utility  boiler new source  performance
standards.  Additionally  field assessments of  the performance of baghouses
in conjunction with spray dryers  for combined sulfur dioxide and  particle
capture were conducted to ascertain the reliability of tnis tecnnology and
the time in compliance of this  technology.

     Environmental  Processes  and  Effects

     Research  in the gases  and  particles area focused on the development
and validation of air quality models concerned witn the transport and
fate of SOg and  particles,  particularly  inhalable-sized particles with
diameters of ten micrometers  (urn)  or less, as well  as their effects on
agricultural  crops,  materials,  and  visibility.

     Urban, mesoscale,  and  regional  particulate  air quality models  are
required  by the  Regions,  States,  and local  governments  and  industry  to
support anticipated  revisions of  State Implementation Plans (SIP's)  for
particulate matter.   EPA plans  to  develop  improved  models  that  will
predict concentration values  of total  fine (less  than 2.5  urn)  and coarse
(greater  than  2.5 urn)  particle  mass  and  chemical  composition.   In 1983,
the development  and  validation  or  urban  ^articulate models  resulted  in
the completion of the Particulate  Episodic Model  (PEM)  and  user's  guide.40

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                                  1II-8
     Regional scale participate matter modeling research continued to
study prolonged elevated pollutant episodes and the planetary boundary
layer resulting in the development of a model  to determine the time-varying
mixing depth and transport flow in the planetary boundary layer.  Additionally,
the Cross Appalachian Tracer Experiment (CAPTEX) was conducted during
September, October, and November 1983 jointly with the Department of
Energy, the Electric Power Research Institute, and Canada to study regional
scale transport and uispersion mechanisms to validate regional scale
transport models.

     Research continued on the development of improved S02 air quality
dispersion models for use in complex terrain,  particularly in the mountainous
West where energy development is increasing.  Data from the Small Hill
Impaction Study #2 field study conducted in 1982 and earlier field studies
were utilized  in the continuing development of the Complex Terrain Dispersion
Mode! (CTDM).  Research in the Green River Ambient Model  Assessment
(GRAMA) program resulted in improved locdl-scaie and mesoscale air quality
models for Western Colorado and Eastern Utah.

     Research  in the Source Apportionment Methods (SAM) program to develop
receptor models for apportioning suspended particulate mass  to components
from emission sources resulted in a project report on the second receptor
modeling workshop (Quail Roost 11) held in 1982,4i a preliminary report on
results of the 1982 Denver Winter Haze Study,42 anc| reports  on residential
heating43 and the application of SAM to various data sets 44

     Research continued on the development of  new dispersion techniques
for air quality dispersion models, wnich are necessary to account for
changes in the dispersion properties of the atmosphere with  height.
Reports were published on the comparison of several  dispersion schemes4^
and on a workgroup summary for preparing meteorological  data for routine
dispersion calculations.4°  The User's Network for Applied Modeling of Air
Pollution (UNAMAP) published version 5 of UNAMAP for distribution to the
model user community.47

     In the welfare effects area,  research addressed ecological  and  material
damage.  The ecological  program focused on the effects of air pollutant
combinations (S02, ozone,  and nitrogen dioxide).  A workshop was held to
evaluate che effects of pollutant  combinations associated with ambient
environments and to develop a research approach to evaluate  this  problem.
Research involving material  damage concentrated on the development of an
atmospheric corrosion monitor to be used as  a  proxy  for material  damage
caused by SU2 and  particles.

D.   MOBILE SOURCES

     Scientific Assessment£

     A panel  of experts was  convened to review in-depth  key  studies
reported by the Agency  in  the  last  criteria  document  for  carbon monoxide
(CO).48  Additional  studies  appearing  in the literature  since publication

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                                  III-9
of the criteria document were also reviewed.   Based on these reviews, an
addendum to the criteria document was prepared and an external  review
draft was completed.  The final  draft of the  addendum was scheduled to be
completed and published in 1984.
     Two large scale field studies of population exposures to CO were
completed using the newly developed miniaturized CO personal  exposure
monitors.  In Denver, Colorado, the CO exposure profiles of 454 persons
were obtained for two-day periods, giving 908 person-days of data.  In
Washington, D.C., the 24-hour CO exposure profiles for 712 persons were
obtained.  In both studies, diaries were filled out, allowing the CO
exposures to be related to individual activities and locations, and CO
breath samples were obtained to allow blood carboxyhemoglobin to be
estimated.  Initial data analyses, including CO exposure-dose modeling,
were begun on this large data base.  Also, a microenvi ronmental field study
was completed of CO exposures on various roadways and in buildings in
Washington, D.C.   Initial steps' were taken to construct a model of CO
exposures, sources, and microenvi ronments.

     Health _Ef f _ect_s

     A tier-testing bioassay system for in vitro and in vivo testing of
fuels, fuel additives, and their emissions was developed and a report
published.  Mutagenicity and carcinogenicity were the primary endpoints.
In addition, a study was initiated to study alterations in the cardiac
function of both normal human subjects and those with coronary artery
disease following exposure to CO wnile at rest and exercising.

     Environmental Processes and Effects

     In 1983, research in this program focused on characterizing the gaseous
and particulate emissions from in-use gasoline and diesel -powered motor
vehicles.  Emissions from 41 in-use gasoline-powered passenger cars were
analyzed for hydrocarbons, aldehydes, and organic particulates.  Additionally,
the factors responsible for the sensitivity of emissions to varying
average speed conditions was determined.  Research to characterize emissions
from heavy-duty trucks and buses was scheduled to be completed in 1984.

£.   ACID DEPOSITION

     Research on the sources, effects, and possible mitigation strategies
for controlling acid deposition continues to be a high priority for EPA.
During 1983, the Agency worked closely with the other members of the
Interagency Task Force on Acid Precipitation to more clearly establish
and verify the relationship between emissions and deposition, determine
the dose-response  functions and the extent of potential impacts, and
assess the relative costs and benefits of possible mitigation strategies.
Research on acid deposition is organized by the following Task Force

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                                   111-10
sub-groups:  Natural Sources, Man-Made Sources, Atmospheric Processes,
Deposition Monitoring, Aquatic Effects, Terrestrial Effects, Effects on
Materials and Cultural Sources, and Assessments and Policy Analysis.  EPA
contributed  significantly  to the following major accomplishments achieved
by  the Task  Force in 1983  as described below.

     Natural Sources

     Measurements of natural sulfur compounds in the ocean suggest emissions
from marine  sources may contribute significantly to the production of acid
precursors.

     Man-Made Sources

     A comprehensive emission inventory data base for 1980 was being
developed and the final version was expected to be available to modelers
in  1984.  Models to predict the cost and emissions changes from utilities
and industries based on various possible control strategies were developed
and are being validated.

     Atmospheric Processes

     A major field experiment was performed to track the movement of tracer
gases released in the Midwest and Canada over hundreds of miles.  In addition
studies of the role of clouds in processing sulfur dioxide into acidic sulfates
were performed.   The development of a major Eulerian model for long-range
transport was initiated.

     Deposition Monitoring

     Three research sites were established to test improved methods of monitoring
wet and dry deposition, precipitation in chemistry data were analyzed,  and acid
deposition maps for North America were produced.  The National  Trends Network
became fully functional and the first annual  report of wet deposition data was
prepared.

     Aquatic Effects

     A preliminary,  qualitative map of the nation  indicating regions where
surface waters are likely to be most sensitive to  acidification was produced,
and a preliminary survey of drinking water in the  Northeast was completed.   In
addition, long-term monitoring of aquatic  resources (chemistry  and  biota)  in
key sensitive regions continued.   The planning for a major survey of lakes was
undertaken.

     Terrestrial  Effects

     Extensive long-term studies  continued to investigate  whether acid
deposition has caused changes  in  the rate  of  growth and species composition.
An analysis  of tree  ring data  indicated a  possible  synergistic  effect between
deposition and other stress factors.   Agricultural  experiments  using simulated
acid rain were also  continued.

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                                  111-11
     Effects on Materials and Cultural Resources

     Operations at TOUT field sites continued, and the site selection process
for additional stations in the U.S.' and in Canada was initiated.  Prototype
movable covers that separate the effects of wet from dry ae^osition were field
tested.  Chamber studies to determine the role of moisture in air pollution
began.  Collection of service life and life cycle cost data was initiated.
Work on assembling inventories of common materials and cultural  properties  also
began.

     Assessments and Pol icy Analysis

     The Critical  Assessment Review Papers detailing the current state  of
knowledge about acid deposition  and its effects were completed  and  distributed
for public comment.49  Investigations into the methodology of conducting integrated
assessments, which bring togetner the various scientific and economic aspects
or the program, have continued.   A framework  for coordinating the activities  of
tne individual tasn groups for che 198b Assessment was completed.

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        IV.  DEVELOPMENT OF NATIONAL AMBIENT AIR QUALITY STANDARDS


     The 1977 Clean Air Act Amendments require EPA to review regularly
and revise, if necessary, all  of the national  ambient air quality standards
(NAAQS).  Reviews of all  existing NAAQS were in progress during 1983.

     In 1983, EPA revoked the existing NAAQS for hydrocarbons (which was
originally established as a guide for attaining the NAAQS for photochemical
oxidants) on the basis that it was no longer appropriate and because
there are now much more sophisticated techniques available for designing
control strategies for photochemical oxidants  (ozone). 1

     During 1983, work continued on finalizing EPA's proposal of August
18, 1980, to revise the NAAQS for carbon monoxide (CO).2  Additional
review and comment from the public and by the  Clean Air Scientific Advisory
Committee (CASAC) was conducted in 1983 on several new issues that were
raised since proposal.3  A draft Addendum to the revised criteria
document tor CO4 and a new draft staff paper^  which interprets the
critical studies cited in the criteria document for standard-setting
purposes were reviewed and concurred on by CASAC.

     The revision 50 the criteria document for nitrogen oxides (NO^) was
completed in 1982.°  The NOX staff paper,' which interprets the critical
studies in the criteria document for use in the standard-setting process
and provides a range of values which the staff feels is most appropriate
for selecting the level of the air quality standard, was reviewed and
concurred on by CASAC in ly83.  Proposal of standards is scheduled ror
1984.

     CASAC concurrence on the scientific accuracy and completeness of the
staff paper for particulate matter was received in January 1982.b  Work
on the regulatory support documents was nearly completed in 1983 and
proposal of a revised particulate matter NAAQS is scheduled for early 1984.

     In 1983, CASAC submitted a closure letter on the staff paper^ for
sulfur oxides (SOX).  The staff presented their recommendations to the
Assistant Administrator on either reaffirming or revising the current
standards.  A proposal to reaffirm or revise the standards is scheduled
for 198b.

     Work on revising the criteria documents for ozone and lead was
initiated in late 1981, with initial drafts of chapters for the documents
completed in 1982.  Public workshops on the draft criteria document
chapters were held in 1983.  Work on the regulatory support documents was
initiated in 1982 and continued in 1983.  Release of the first external
review draft of the lead criteria document10 occured in the fall of 1983 and
release of the first external review draft of the ozone document is
scheduled for 1984.

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                                   IV-2
     Also in 1983, the Agency  continued  its  efforts  to  develop  methodologies
for using risk assessment in  setting  NAAQS,  as  has  been suggested  by  a
number of groups, including the National  Commission  on  Air Quality.   The
CASAC has set up a subcommittee to assist and  advise EPA in applying  risk
assessment to the lead NAAQS review.

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             V.   REGULATORY ASSESSMENT  OF  TOXIC AIR  POLLUTANTS


      In  1983,  recommendations on whether  to regulate polycyclic organic
matter and  acrylonitrile  under  the Clean  Air Act were developed, with
proposal  of  the  Agency's  decision anticipated in early  1984.  Regulatory
recommendations  ror  toluene  also were  completed  in  19b3 and are expected
to be published  in 1984.  Assessments  containing information on the
sources,  emissions,  public exposure, current control, and possible control
improvements were completed  for acrylonitrile, carbon tetrachloride,
toluene,  and five chlorinated organic  solvents.  This information is used
in conjunction with  the health  assessment documents discussed in Chapter
III of this  report in order  to make recommendations on  the need for
control of these chemicals and  the appropriate regulatory mechanism to be
used.

     Efforts to  assist State and local air pollution control offices in
dealing witn toxic air pollutants also increased significantly in 1983.
Workshops were held-  in tnree EPA Regional Offices for the States in those
Regions,  and a substantial effort began to develop an Air Toxics Information
Clearinghouse.   In the latter effort,  EPA worked closely with States
and local air pollution control  agencies to facilitate the voluntary
exchange  or  information relating to substances that are toxic or may be
found to  be toxic.   Full   implementation of the clearinynouse is planned
in late 1984 or early 1985.

     Work continued within the Agency  to  integrate properly toxics activities
across the various media.   Of principal interest was the activity on the
Toxic Integration Task Force chartered by the Deputy Administrator in 1983
and scheduled for completion in  early  1984.  Subgroups on  risk management,
risk assessment, high visibility chemicals, intermedia  inconsistencies, and
interagency coordination  were established to evaluate and  recommend  improved
policies  and procedures.

     A system* for screening and ranking a large number of potentially  toxic
air pollutants for further more  detailed assessment was  developed and applied
in 1983.   This system uses readily  available data that provides  an  indication
of the potential  for adverse health  effects and  public exposure.   Using
appropriate weighting factors, the  system provides  a quantitative  ranking
which is  then used for setting  future priorities  for additional  work.

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              VI.  STATUS OF AIR QUALITY MANAGEMENT PROGRAMS


A.   DEVELOPMENT OF POLICY AND REGULATIONS

     Post-1982 Attainment Policy

     Part D of the Clean Air Act requires that primary national  ambient
air quality standards (NAAQS) for particulate matter,  sulfur dioxide,
nitrogen dioxide, carbon monoxide, and ozone be attained no later than
December 31, 1982.  State Implementation Plan (SIP) revisions providing
for attainment of these standards were to have been submitted to EPA by
January 1, 1979.  Extensions of the attainment date up to 1987 were authorized
under prescribed conditions for the carbon monoxide and ozone air quality
standards.  One condition was the submission to EPA of an additional  SIP
revision by July 1, 1982 which demonstrated attainment of these standards
not later than December 31, 198-7.  On February 3, 1983, EPA published two
rulemaking proposals relating to implementation of the primary national
ambient air quality standards under the Clean Air Act.l»2  Tne first
notice proposed to disapprove State Implementation Plans and impose a
moratorium on major stationary source construction or  modification in
nonattainment areas that were required to attain the standards by December 3i,
1982, but were still experiencing violations.  This notice also proposed
to disapprove plans and impose construction moratoriums in nonattainment
areas that had not received full EPA approval for plan revisions due in
1979.  The second notice, depending upon the circumstances, either proposed
approval or disapproval of implementation plans submitted in 1982 by
States with nonattainment areas that had obtained extensions of the 1982
deadline for the carbon monoxide or ozone standards.  In this notice, EPA
proposed to impose construction moratoriums in all areas where it was
proposing to disapprove 1982 plan submissions.  In addition, the notice
requested comment on the appropriateness of additional  restrictions,
including the withholding of air program and highway funds.

     After evaluating the comments submitted in response to its  proposals,
EPA revised its interpretation of the Act's legal consequences of a failure
to meet the 1982 attainment deadline and published a notice on November 2,
1983, taking final action on portions of the first notice described
above.3 EPA did not take any action on the proposals in the second notice,
but it did describe its revised policy for dealing with nonattainment areas
that had attainment date extensions.  As discussed later in this chapter,
action on the proposals in the second notice were published as individual
Federal Register notices in early 1984.

     Under the policy announced on November 2, 1983, EPA gave States
an opportunity either to show that their State Implementation Plans were
not deficient or to remedy their deficiencies before any of the.various
sanctions provided by the Clean Air Act would apply.  States could show
that their plans were not deficient by requesting redesignation  to attain-
ment under Section 107(d) of the Act.  States could remedy deficiencies

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                                   VI-2
by either implementing any undone portions of their existing plans or
else by revising their existing plans.  EPA prepared comprehensive guidance
to be made available in early 1984 for areas that needed to implement or
revise their plans.

     Implementation Guidance for Revised Particulate Matter Standards

     As discussed in Chapter IV of this report, EPA plans to propose
revisions to the national ambient air quality standards for particulate
matter in 1984.  One change being considered is the establishment of
standards for that fraction of particulate matter that is composed of
particles that are nominally 10 micrometers or less in size (PM^o).  In
recognition of the administrative and technical impacts of such a change,.
in 1983 EPA prepared draft revisions to regulations and to guidance
documents applicable to implementing the revised standards.  The drafted
regulations would revise both 40 CFR 51, "Requirements for Preparation,
Adoption, and Submittal of Implementation Plans"; and 40 CFR 52, "Approval
and Promulgation of Implementation Plans" to specify PM^g requirements
for the prevention of significant deterioration and for the review of new
sources in nonattainment areas and to make the technical amendments
needed to accommodate a PM^o air quality standard.  Drafts of new guidance
documents and revisions to existing documents deal with (1) interim methods
for measuring source emissions of PM^y; (2) dispersion and receptor models
which can be used for PM^y and the input data required; (3) source-specific
emission ractors developed through a multi-year EPA research program that
are needed to prepare PM^y emissions inventories; (4) new network and data
reporting requirements applicable to monitoring the levels of PM^g in tne
ambient air; (b) interim PSD monitoring methods ror measuring ambient Pf-l^g
levels before reference methods are approved and a phase-in program tor
operating new PM^g monitors for PSD; and (6) a method for using existing
air quality data, wnich is not specific to PM^g  to assess PM^y air quality
and to assist in implementation plan preparation.  The revisions to the
regulations and to the technical guidance will be announced in the Federal
Register shortly after the proposal to revise the air quality standard'
and will be made available for public comment.

     V^ijjbility Protection

     Section 169A of the Clean Air Act establishes as a national goal
"the prevention of any future, and the remedying of any existing, impairment
of visibility in mandatory Class I Federal areas which impairment results
Trom manmade air pollution."  On December 2, 1980, EPA promulgated regula-
tions implementing this section.^  All States which contained mandatory
Class I Federal areas were to develop and submit SIP revisions to EPA which
implemented these regulations.

     On December 20, 1982, a number of petitioners filed suit in the
United States District Court for the Northern District of California
seeking to compel EPA to promulgate State plans for visibility-protection
under Section 110(c) of the Clean Air Act for those States which had not

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                                    VI-3
 submitted  such  plans.   During  1983,  EPA  and  the  Environmental  Defense
 Fund negotiated and  signed  a settlement  agreement  which  was  then  submitted
 to the Court.   The agreement provides  for  EPA  to complete  the  requested
 promulgation within  forty months  of  finalization of  the  agreement.   Court
 acceptance of the agreement as  settlement  of the suit was  pending at
 year's end.

      A Visibility Task  Force was  formed  in 1983 to develop recommendations
 on a long-range strategy for dealing with  visibility impairment from
 pollution-derived regional  haze.   The  group  is charged with  defining
 goals, research needs,  and  regulatory  options  and  serves to  integrate
 regional haze issues  in mandatory  Class  I  Federal  areas  with more general
 visibility protection considerations under the national  ambient air
 quality  standards and with  related aspects of  other  air  pollution control
 programs that affect  visibility.   The  task force will involve through
 membership or consultation  several EPA offices, other Federal agencies,
 concerned  States, environmental organizations, and industry.  The major
 task force output will be a report, currently  scheduled  for  late 1984,
 containing its  findings and recommendations and a  summary  of supporting
 material and analyses.  The group will also issue  interim  research and
 analytical  recommendations.

      Tall  Stacks and Other Dispersion  Techniques^

      Section 123 of the Clean Air Act  requires that stationary sources
 of air pollution not be allowed to take credit for having  stacks that are
 higher than that defined by "good engineering practice"  (GEP) and thereby
 evade  more stringent emissions   limitations.  In addition,  Section 123,
 except for specified exemptions, does  not allow sources to take credit
 for  any other type of air pollution dispersion technique.  On February 8,
 1982,  EPA  promulgated regulations to implement Section  123.5  Subsequently,
 the  Sierra Club, Natural Resources Defense Council, and the Commonwealth  of
 Pennsylvania challenged those regulations  in  court.  On October 11,  1983,
 the  U.S. Court of Appeals for the District of Columbia  Circuit ordered
 EPA  to reconsider portions  of the regulations.   The Court provided very
 detailed instructions to guide  the Agency's thinking  on remand.  EPA
 started preparation  of a response to the Court  by the end of 1983 and
 held a public meeting in December to discuss  options  available to the
 Agency.

     Section 123 prohibits  the  use of dispersion  techniques unless  such
 techniques  were  implemented  before December 31, 197U.  One  technique,
 known  as an intermittent control system,  varies the rate  of pollutant
emissions according  to meteorological  conditions.   The  Agency drafted
 regulations in  1983  which,  when finalized,  will define  the  requirements
of an implemented system.

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                                   VI-4


     Restructuring SIP Preparation Regulations

     A major EPA goal in 1983 was to improve government regulations.  The
SIP preparation regulations (40 CFR 51) were selected for revision.
Since promulgating the regulations in 1971, EPA had made many revisions.
For example, EPA added and amended requirements pertaining to transportation
control strategies, maintenance of the national ambient air quality
standards, air quality monitoring, new source review, data reporting, and
prevention of significant deterioration.  These additions tended to make
the regulations long and difficult to follow.

     On October 11, 1983, EPA published in the Federal Register proposed
changes to 40 CFR 51.  The proposal would delete obsolete provisions and
rewrite the regulations in a new format which is shorter and better
organized.  States using the proposed regulations to prepare SIP's will
find them current and easier to follow.  The proposed regulations also
have a flexible structure into which future requirements can be more
easily included.

B.   PREVENTION OF SIGNIFICANT DETERIORATION AND NONATTAINMENT
     NEU SOURCE REVIEW ACTIVITIES

     The Agency made significant progress in 1983 in carrying out its
responsibilities under the Act regarding the preconstruction review of
new and modified stationary sources.  Major 1983 activities  are described
below.

     PSD Program Transfer

     EPA continued its progress in transferring implementation of the
prevention of significant deterioration (PSD) program to State and local
agencies.  The majority of PSD permits  are now issued by these agencies.
As of the end of 1983, 37 State and local  agencies  had either full  delegation
of the PSD program or a PSD SIP (compared to 26 a year earlier)  and 11
more had partial  responsibility for the PSD program.

     Chemical  Manufacturers Association v. EPA

     The Agency's PSD and nonattainment new source  review  regulations were
challenged by a variety of entities.   These challenges were  consolidated
as Chemical  Manufacturers Association v.  EPA (CMA),  D.C. Cir.  No.  7y-1112.
On February  22, 1982,  EPA entered into  a  litigation  settlement with the
industry petitioners  in which  it agreed to propose  certain regulatory
changes.  An important part of the settlement agreement  was  satisfied
by EPA's Federal  Register proposal  of August 25, 1983.6   That  proposal
addressed the topics  of fugitive emissions in new source review  applicability
determinations, Federal  enforceabi1ity  of various emissions  reductions,
"buffer zones"  around  Class I  areas,  review of secondary emissions, and
offset credit for past source  shutdowns.

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                                   VI-5
     Another significant provision of the settlement deals with the means
by which emissions reductions can be credited so that a source can avoid
new source review of a modification or create an offset.  The Clean Air
Act is not specific regarding the type of system (e.g.. actual or allowable
emissions) to be used in granting such credits to sources, and there is
risk that sources could adversely affect air quality by avoiding review
through too liberal a computation of credits.  Work on this portion of
the settlement was on hold at the end of 1983 pending resolution of
certain problems with industry petitioners.

     A third aspect of the settlement involves the decision whether to
propose interim and long-term relaxation of PSD increments for particulate
matter in anticipation of new national ambient air quality standards for .
particulate matter based on fine particles.  EPA's position on this
matter was prepared in 1983 and will be proposed for comment when the
revised particulata matter air quality standard is proposed.

     The remaining part of the litigation settlement resulted in the
Federal Register promulgation of June 25, 1982, in which vessel  emissions
were excluded from the review of marine terminals.?  EPA was challenged
on this rulemaking by the State of California and the Natural Resources
Defense Council.  On January 17, 1984, the D.C. Circuit Court of Appeals
vacated this rulemaking in part and remanded it to the Agency for further
action.

     An important matter of controversy nas been the definition of "source"
for the purposes of nonattainment new source review.  The-Clean-Air Act is
not clear in this area.  In 1980, EPA promulgated a dual source definition
that minimized the opportunity for modifications to sources to avoid
review in nonattainment areas.  This was challenged by industry in the
CMA suit, but was not of primary concern in the settlement because the
Agency replaced it with a "plantwide" definition in its rulemaking of
October 14, 1981.8  The Natural Resources Defense Council  claimed that
the plantwide definition is inconsistent with the Act and, on August 17,
1982, the D.C.  Circuit Court of Appeals ruled in their favor.  EPA and
industry appealed this ruling and it is now before the Supreme Court.
Tne uncertainty over source definition has caused difficulty for the
nonattainment program, especially with respect to the development of
SIP'S.

     In its August 25, 1983, proposal mentioned above, EPA did not require
that fugitive emissions from surface mining operations be  included  in PSD
applicability determinations.  The Sierra Club sued EPA on this point and
on August 26, 1983, the D.C. Circuit Court of Appeals remanded this
matter to the Agency for explanation of its position.  EPA replied in
January 1984 that it would coordinate a proposal  to list surface mines
with its final action on the August 25 proposal.

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                                   VI-6



C.   IMPLEMENTATION OVERVIEW AND ASSISTANCE

     National  Air Audit System

     One of EPA's most important air quality management initiatives
undertaken during 1983 was the development, in partnership with State and
local air pollution control agencies, of the National  Air Audit System
(NAAS).  The need for the NAAS developed as State and  local air pollution
control agencies assumed responsibility for an increasing number of
delegated programs under the Clean Air Act.  While EPA provided oversight
of State and local air pollution control programs for  many years, the
Agency never developed guidelines to ensure national  consistency in the
evaluation of these programs.  Officials of State and  local agencies
pointed out that EPA audits varied in frequency, depth, and procedure,
and also were inconsistent from Region to Region and  State to State.
Representatives of State and Territorial Air Pollution Program Administrators
(STAPPA) and Association of Local Air Pollution Control Officials (ALAPCO)
recommended that EPA develop evaluation criteria for  conducting audits of
State and local air pollution control agencies that would be used by all
Regional Offices.  EPA responded to the concerns of STAPPA and ALAPCO
members and agreed to participate in a STAPPA/ALAPCO/EPA workgroup charged
with developing an auditing system that would ensure  national  consistency
and confirm that State and local air pollution control programs were
consistent with the national objectives of the Clean Air Act.

     Standardized audit guidelines were written in 1983 by four subcommittees
of the workgroup.  The program areas selected by the workgroup for
development of audit guidelines were:  (a) air quality planning and State
Implementation Plan (SIP) activity, (b) new source review, (c) compliance
assurance, and (d) air monitoring.  The subcommittees  were chaired by
State agency personnel with EPA staff serving as expeditors.  All State
agencies, local agencies, EPA Regional Offices, and EPA Headquarters offices
were provided an opportunity to comment on a draft version of  the audit
guidelines.  The system will be implemented in 1984 when the guidelines
will be used to audit all State agencies and key local agencies.

     The primary goals of the NAAS are to identify any obstacles that are
preventing State and local agencies from implementing  an effective air
quality management program and to provide EPA with quantitative information
for use in defining more effective and meaningful national programs.
The objectives of the NAAS are to provide audit guidelines that EPA,
State, and local  agencies can use to:  (1) meet statutory requirements;
(2) assist in developing an acceptable level of program quality; (3)
account for the achievements and needs of SIP programs to Congress and
the public; (4) identify programs that need further technical  support or
other assistance; and (5) effectively manage available Federal, State,
and local resources so that the national ambient air quality standards
may be attained and maintained as expeditiously as possible.

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                                  VI-7
     Status of Nonattainment Areas

     The following table lists those areas of the country that were not
in attainment with air quality standards as of the end of 1983.  Note
that totals are not shown since the same area may be nonattainment for
more than one pollutant.

     Pollutant                                Number of Nonattainment Areas

     Particulate Matter (primary standard)                 172
     Particulate Matter (secondary  standard)               148
     Sulfur Oxides (primary standard)                       61
     Sulfur Oxides (secondary standard)                      8
     Nitrogen Oxides                                         5
     Carbon Monoxide                                       148*
     Ozone                                                 448**

      *97 areas received an extension until 12/31/87
     **154 areas received an extension until 12/31/87

     1982 SIP Revisions for Ozone and Carbon Monoxide

     As discussed earlier in this chapter, certain areas of the country
that demonstrated that the primary  NAAQS tor ozone (03) or carbon monoxide
(CO) could not be attained by December 31, 1982, even with the application
of all reasonably available control measures, were granted an extension of
the attainment date until no later  than December 31, 1987.  A total of 31
States requested and were granted compliance date extensions and were
therefore required to submit revised SIP's.  In an action taken on
February 3, 1983, EPA proposed to disapprove SIP's for 17 of the 31
States.  The major deficiencies cited included failure to demonstrate
attainment by 1987, lack of an approvable Inspection and Maintenance
(I/M) program, and failure to adopt regulations requiring reasonably
available control technology (RACT) for stationary sources of volatile
organic compounds (VOC's).

     Many States subsequently revised their SIP's and many of the plans
previously proposed for disapproval were reproposed for approval.  During
1983, EPA witnessed significant State progress toward implementation of
required I/M programs.  Additionally, many States committed to the adoption
of additional stationary source and transportation control measures
necessary for attainment of 03/CO standards.  As of January 31, 1984, EPA
had proposed action on all 1982 03/CO SIP's (including reproposals in many
cases) and had published final approvals for eight States.  The Agency is
on a schedule leading to final actions on all 1982 03/CO SIP's by September
1984.

     Lead SIP's

     In October 1978, EPA published a national ambient air quality standard
for airborne lead under Section 109 of the Clean Air Act.9  Section 110
of the Act required each State to adopt and submit to EPA within nine

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                                  VI-8
months a plan to implement that standard.  The Act further required EPA
to approve or disapprove these SIP's within four additional  months and to
promulgate SIP's within two additional  months beyond that for States that
did not meet the requirements specified in the Act.  In 1982, the Natural
Resources Defense Council (NRDC) and other parties filed suit in the U.S.
District Court for the District of Columbia to require EPA to promulgate
lead SIP's for those States that had not yet submitted them and to approve
or disapprove lead SIP's that had been submitted but on which EPA had not
taken final rulemaking.  The Lead Industries Association and St. Joe
Minerals Corporation intervened in the suit on behalf of EPA.

     The EPA and NRDC negotiated a Settlement Agreement which was entered
by the court on July 26, 1983.  The agreement allowed States additional
time to prepare and submit lead SIP's before EPA must prepare a Federal
plan and established different schedules for different categories of
States.  For States that had already submitted SIP's before EPA reached
agreement with NRDC, the agreement required EPA to publish final approval
or proposed disapprovals by November 1983.  With the exception of one
extension requested of the court, EPA acnieved this objective.  For
States with either major sources of lead or recent violations of the lead
standard but which nad not yet submitted lead SIP's, the agreement set a
date of August 1, 1983, for submission of SIP's.  The agreement required
EPA to propose rulemaking on these SIP's oy January 3, 1984.  EPA received
draft or final plans frum all such States except tor one area, and published
proposed rulemaking on these plans on or  before January 3,  1984.  Tne
agreement established further dates in 1984 and 1985 for completing
rulemaking on the problem States and for action on the other States that
ao not have any known problems.  For the 56 States and Territories at the
end of 1983, 27 have submitted complete SIP's on which EPA published
final rulemaking; 22 have submitted draft or final SIP's that cover
complete States, but on which EPA has not yet completed rulemaking; and 7
had not submitted draft or final SIP's that cover complete States.

     Processing of SIP Revisions

     During 1982, efforts were focused on changes in the SIP review process
tnat would accelerate review of routine and noncontroversial SIP actions
and reduce the duplication of efforts between the States, Regional Offices,
and Headquarters.  These efforts consisted of the full implementation of
three improved SIP processing procedures developed and tested in late
1981.  These procedures resulted in a reduction of 93 percent of the SIP
backlog by July 1, 1982.  In addition, the new procedures allowed EPA to
process SIP actions at about the same rate as received.

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                                   VI-9
      In 1983, continuing efforts were made to process SIP revisions at a
 rate that would avoid future backlogs.  The major emphasis in 1983 was
 placed on improving the internal operating procedures of the SIP review
 process.  These efforts consisted of developing modified procedures for
 processing,  tracking, and accounting for SIP revisions.  Computer programs
 were revised to improve tracking efficiency and provide an early warning
 system for packages nearing deadlines.  A Standing SIP Review Committee
 was established to meet at regular intervals to resolve controversial
 issues and problems arising in SIP packages.  A SIP Policy Committee was
 also established to meet as needed to review actions  involving major
 national issues and to resolve conflicts.  The changes which were made
 should further improve the existing SIP review process and result in a
 further decrease in review time, a workable method to identify and resolve
 problems,  and improve communication and cooperation between  the various
 review offices.

      —iULLPJ1 s Trading

      Emissions trading includes  several  alternatives  to traditional
 regulation.   These alternatives  do not  alter existing  air  quality require-
 ments but  simply give States  and industry more flexibility to  meet  these
 requirements.  Bubble trades  and emissions  reduction  banking are  two of
 th* major  emissions trading concepts  being  promoted by EPA.

      Bubble  trades  allow existing  plants  (or  groups of plants)  to treat  all
 of  their emission  points as though  they were  under  a  giant bubble and  reduce
 or  eliminate.pollution  controls  where costs  are high,  in exchange tor
 compensating  increased  control at  emission  sources  where control  costs are
 low.   They give  firms  increased  compliance  flexibility, meet current or
 future  pollution control requirements more  quickly, make innovative control
 approaches profitable,  and  can result  in  significant savings over the costs
 of  conventional  controls.   In  1982, EPA issued d proposed emissions trading
 policy  to  replace  the original bubble policy  and to streamline procedures,
 giving  States  and  industry more  opportunities  to use bubbles in many more
 circumstances  and geographic areas.  Since that time,   EPA has reviewed
 numerous formal comments on its  policy and developed alternatives to respond
 to  specific issues  raised by the commenters.   In 1983, EPA proposed the
 alternatives  for public  review and additional comment.  EPA plans to issue
 the policy in  final form after considering all of the  comments that were
 submitted on  the Hroposals.  As of December 31, 1983,   EPA approved or proposed
 to  approve 43 buobles saving their users an estimated  5205 million over the
 cost of conventional pollution controls, with many producing energy savings
 and greater emission reductions than traditional  regulation.   Over 69
 other bubbles averaging $3 million each in savings were under review at the
 State or Federal level and an additional 30 bubbles were under development
by  industry sources.

     Bubbles can be approved by the States without case-by-case EPA review
 if evaluated  unaer EPA-approved State generic trading  rules that assure
that no oubble will interfere with timely  attainment and maintenance of

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                                   VI-10
ambient air quality standards.  As of December 31, 1983, EPA had approved
generic trading rules for eight States which allow these States to approve
bubbles without prior Federal approval.  In addition, 17 generic rules were
under State development.  Another 14 bubbles had been approved by States
under generic trading rules and at least 29 others were under review.

     Emissions Reduction Banking

     Emissions reduction banking allows firms to get credit for surplus
emission reductions and store such emission reduction credits (EKC's) in a
legally-protected manner.  ERC's can be "banked" (stored) and used in bubble
applications to meet control requirements for existing plants more flexibly
and efficiently, as offsets to support economic growth in areas not meeting
air quality standards, or in "netting" to exempt certain expansions or
modernizations from new source review.  Banking rules can speed trades
between firms, expand opportunities for bubbles, and encourage the production
of cheap ERC's at optimal times.  Banking systems also provide the certainty
needed for firms to invest in ERC's when meeting other control  requirements,
creating a pool of readily available credits that makes trading easier and
speeds permit issuance while assuring progress toward clean air.   As  of
December 31, 1983, EPA had approved Statewide banking rules in Oregon and
Rhode Island and had proposed to approve a  Statewide rule in Kentucky.
Another 13 States had adopted banking rules but had not received  EPA
approval.

     VOC RACT Clearinghouse

     The EPA has specified that the SIP revisions for areas designated as
not attaining photochemical  oxidant standards should  contain,  as  a  minimum,
regulations for controlling volatile organic compound (VOC) emissions from
stationary sources.  These regulations must provide for the implementation
of reasonably available control  technology  (RACT).   To assist  the  States  in
defining RACT, EPA prepared a series of documents,  referred to  as  control
techniques guidelines (CTG's),  which address various  control  options  for  a
variety of individual  stationary sources.   Since EPA  cannot publish  CTG's
for all  affected VOC source categories,  States may  have to  develop  regula-
tions using information sources  other than  CTG's.   The purpose  of  the VOC
RACT clearinghouse is to provide a  means  by which  State and local  air
pollution control  agencies  can  exchange  technical  information,  minimize
duplication of effort and resources,  and  provide guidance regarding  VOC
controls  for various  sources.   The  VOC RACT Clearinghouse is a  cooperative
effort with the State and Territorial  Air Pollution Program Administrators
(STAPPA),  the Association of Local  Air Pollution  Control  Officials  (ALAPCO),
and EPA.

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                                   VI-11
     Emission Factors

     In 1983, the Agency continued its efforts to provide technical guidance
on how to estimate air pollutant emissions from various sources.  Such
information is used by EPA  the States, the private sector, and others in
development of State Implementation Plans, permitting of sources under the
prevention of significant deterioration (PSD) program, emission trading
(offset/bubbles), environmental impact statements, and other applications.
A vehicle for transmitting such technical  information is Compilation of Air
Pollutant Emission Factors.10  In 1983, guidance was prepared TF'wIs""in the
process of being prepared"for estimation of emissions for specific pollutants
of current interest such as particuiates by particle size, nlcxel, acrylo-
nitrile, chloroform, carbon tetrachloride, formaldehyde, ethylenedichloride,
and others.  Release of documents on these and other pollutants is scheduled
tor 1984 pending completion of responses and any modifications resulting
from public review and comment on the documents.

D.   AIR POLLUTION TRAINING PROGRAMS

     In 1983. EPA continued to provide technical training in the abatement
and control of air pollution.  Tnis training included short course presentations
(three to five days in length), self-study courses, technical  assistance to
others who conduct training,  and the support of traineeships and fellowships
for graduate air pollution training.

     During 1983, EPA conducted 26 short courses in 14 different subject areas
for a total of 639 students.   These courses were presented in  locations across
trie U.S. by 7 universities designated as area training centers.  Technical
assistance was provided to States and EPA  Regional  Offices for the conduct of
2U additional  courses reaching a total of  388 students.

     In support of the delegation of more  air quality management responsibili-
ties to the States, EPA continued emphasis on self-study courses as a  means of
providing training to more air pollution personnel.  During 1983,  b68  students
applied for the 16 self-study courses presently available.  At  the end of 1983
over 125 applications had been received for two new courses scheduled  for
release early  in 1984.

     As an additional  means of developing  qualified personnel,  EPA supported
27 graduate traineeships/fellowships to employees  of State and  local air
pollution control  agencies.  These awards  are for  both part-time and full-
time graduate scudy in  the field of air pollution  control.

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                 VII.   CONTROL OF  STATIONARY  SOURCE  EMISSIONS


 A.    NEW  SOURCE  PERFORMANCE  STANDARDS  (NSfS)

      During  1983,  NSPS were  promulgated  for  five  new  categories:   the
 pressure  sensitive tape and  label  surface  coating industry,! Synthetic
 Organic Chemical Manufacturing  Industry  (SOCMI) equipment  leaks of  volatile
 organic compounds  (VOC's),2  the graphic  arts  industry,3 bulk gasoline
 terminals,4  and  the beverage can  surface coating  industry. 5   The existing
 NSPS  for  automobile and light-duty  truck surface  coating operations  [inno-
 vative technology  waiver],5  and four phosphate fertilizer  processes7 were
 revised.   Standards were proposed  for  eight new categories:   SOCMI  - VOC
 emissions rrom air oxidation unit  processes ,8 SOCMI -  VOC  emissions  from
 disti Nation  unit  operations,9  VOC  fugitive emission  sources  in petroiuem
 refineries,10 flexible vinyl  coating and printing operations,11 rubber tire
 manufacturing industry,12  nonmetallic  mineral processing plants, 1;i  light-
 weight aggregate,13 gypsum,13 perlite,13 and glass manufacturing plants.14
 A revision to the  averaging  time provisions of the NSPS for  fossil-fuel-
 fired steam generators  was proposed.15 The reviews of NSPS  for Kraft pulp
 mills, gas turbines, and  Claus  sulfur  recovery plants were completed.  A
 nitrogen  oxides  (NUX)  control technology document was published as were
 two control techniques  guideline (CTG) documents; one for plants that produce
 high  density  polyethylene, polypropylene, and polystyrene resins, and one
 for petroleum solvent  dry  cleaning  operations.  Standards development
 programs  now  underway  are  planned to result in the promulgation of 10
 standards, the proposal  of 8 standards, completion of reviews tor 6
 existing  NSPS, and  publication  of 5 CTG's for volatile organic compound
 sources in 1984.

 B.    NATIONAL EMISSION  STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)

      0  Arsenic --  During  iy83, NESHAP were proposed for three arsenic
 sources (high arsenic  feedstock primary copper smelters, low arsenic
 feedstock primary copper smelters, and glass manufacturing  plants).16
 Promulgation  of standards for all  of these sources is  scheduled for 1984.
            ltos. " Revisions to the asbestos standard to reinstate work
practices and to reorganize the NESHAP for clarity were proposed in 1983
and are scheduled for promulgation in 1984.  The work practices were
promulgated under the Clean Air Act, as amended in 1970.  The Supreme
Court held that work practices were not emission standards and were not
authorized under the 1970 Act.  The 1977 Clean Air Act Amendments allowed
work practices to be used when emission standards are not feasible, hence,
the proposed revisions.  A revision of the demolition and renovation
standards for asbestos is also scheduled for proposal in 1984.

     0  Benzene -- Standards development work continued in 1983 for major
benzene emission sources in the chemicals and petroleum industries.  A
proposed NESHAP for benzene emissions  from coke oven  by-product -pi ants is
planned in 1984.  A NESHAP for fugitive leaks of benzene in  petroleum and
chemical plants is scheduled for promulgation in 1984.  A proposal  to

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                                    VII-2
withdraw proposed regulations for control of benzene emissions in maleic
anhydride plants, ethylbenzene/styrene plants, and benzene storage facilities
is scheduled to be published in 1984.  The withdrawal is based on the Tact
that public health risks for these sources were determined not to be significant.

     0  Coke Oven Emissions -- Standards development work continued in 1983
for coke oven emissTons sources in the iron and steel industry.  A proposed
NESHAP for coke oven emissions (wet charging and topside leaks) is planned for
1984.

C.   DELEGATION OF NSPS ANO NESHAP

     EPA continued to make progress in 1983 in delegating responsibility .
for implementing the NSPS and NESHAP programs to the State and local  air
pollution control agencies.  At the beginning of 1983, 31 States or local
agencies had accepted delegation of all  applicable NSPS and 45 had accepted
delegation of all applicable NESHAP.  Tne number of applicable NSPS and
NESHAP vary for each State or local agency depending on the types of source
catgories that either exist or'are likely to be built in the future.  At
the end of 1983, these delegations increased to 42 for NSPS and 47 for
NESHAP.  These numbers represent delegation of approximately 95 percent of
applicable NSPS and 95 percent of applicable NESHAP nationwide.

0.   BACT/LAER CLEARINGHOUSE

     New or modified facilities that are to be constructed in areas of the
country that are currently attaining the national  ambient air quality
standards are required by the Clean Air Act to install oest available
control technology (BACT).  In those areas of the  country that have not yet
achieved compliance with the air quality standards, new or modified facilities
are required to meet the lowest achievable emission rate (LAER) for that
particular type of source.  Permits to construct new or modified sources are
issued oy State and local  agencies only  after the  sources agree to comply
with either SALT or LAER requirements.  Orten an air pollution control
agency will  need to establish BACT or LAER requirements either for a source
type completely new to them or for a source type with which they have had
only minimal  experience.  In these cases, the permitting agency may not be
knowledgable of the more recent advances in control technology for such
sources and it is extremely nelptul if the agency  can refer to BACT or LAER
determinations made by other control  agencies.

     EPA established the BACT/LAER Clearinghouse several  years ago in order
to assist State and local  air pollution  control  agencies by promoting the
sharing of air pollution control  technology information.  The primary
output or the Clearinghouse is an annual  report of information about BACT/
LAER determinations made by the various  control  agencies.  The most recent
report contains over SOU BACT/LAER determinations.1**  An updated compilation
containing approximately 950 determinations is scheduled to be distributed
in 1984.  The report is available in hard copy and through  an automated
system.  The automated data base can be  accessed by both the public and the
private sectors.

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                   VIII.  STATIONARY SOURCE COMPLIANCE
A.  GENERAL
    The goal of the Clean Air Act is to protect public health and welfare
and enhance the quality of the nation's air.  The stationary source
compliance program is designed to assure compliance with air emission
standards by stationary sources of air pollution, including such major
facilities as power plants, steel mills, smelters, and refineries.  In
addition to ensuring compliance with emission limitations contained in
State Implementation Plans (SIP's), EPA and delegated States are responsible
for ensuring that sources comply with new source performance standards
(NSPS) and national emission standards for hazardous air pollutants
(NESHAP).

    Through the combined efforts of industry, States, and the Federal
government, as of the end of 19B3 approximately 89 percent of the sources
in the country were reported as achieving initial compliance and an
additional 3 percent were in compliance with schedules to install  controls.
These efforts have largely been focused on sources which emit particulates
and sulfur dioxide; now, however, the program is directing increased
attention toward other problems of significance, most notably the control
of volatile organic compounds (VOC's).

    Beginning in 1983, EPA initiated a major effort working with States
to improve the compliance data base and initiate enforcement actions
relating to VOC sources.  These sources are major contributors to the
ozone nonattainment problem and may emit compounds which are highly toxic
in nature which may be reduced through an aggressive program to enforce
VOC standards.  Generally speaking, widescale regulation of VOC was
initiated by the SIP's which were developed in response to that part of
the 1977 Clean Air Act Amendments that pertain to areas that had not
attained the national  ambient air quality standards.  As part of those
SIP's, many States adopted regulations requiring sources to comply with
applicable regulations on or before December 31, 1982.  It was the relatively
recent passage of these compliance dates which created the need to increase
the attention devoted to compliance efforts for VOC sources.

    Another major component of the stationary source compliance program
is the effort to return to compliance those sources meeting the definition
of a "significant violator."  The universe of sources covered by the
program includes sources that are in violation of NESHAPs and NSPS regula-
tions and sources in violation of a SIP if the source is of sufficient
size (presumptively 250 tons/year potential  emissions or 100 tons/year
actual  emissions of any pollutant) and is located in or impacts on a
nonattainment area for the pollutant for which the source is in violation.

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                                  VIII-2
     In the first 21 months of the significant violator program, considerable
progress was made.  An initial list of 482 sources was established and an
additional 340 sources were identified after the initial list was established.
In  this same period, 484 sources (representing the vast majority of the
original list) were brought into compliance or placed on an acceptable
compliance schedule.

     EPA developed during 1983 a compliance strategy for stationary sources
of  air pollution which defines in one document the major thrusts of the
stationary source compliance program.  Implementation of this strategy
will be the principal focus of the compliance program in the next few
years.  The strategy continues the emphasis on resolving violations by
sources meeting the definition of a significant violator.   The strategy
reaffirms that the present program is sound and should be continued in
the  future.

     This strategy does suggest three significant changes that will  receive
increasing emphasis, beginning in 1984 and continuing into 1985.  The
first suggested change will allow States more flexibility in carrying out
their inspection programs.   The second change will  increase the use of
continuous emission monitoring and similar techniques within the compliance
and  enforcement program.   The third change will  emphasize the compliance
of  sources violating the VOC provisions of the SIPs.   The strategy  also
outlines additional  guidance that will  be developed during 1984 concerning
specific aspects of the compliance program, including a more comprehensive
approach to assuring compliance on a more continuous  basis.

B.   POST-1982 ENFORCEMENT POLICY.

     On September 20, 1982,  EPA issued a policy on enforcement against
sources in primary nonattainment areas  {other than  areas which received
an  attainment date extension in accordance with  the provisions of the
1977 Amendments to the Act) not in compliance with  the Clean Air Act  on
or  after December 31, 1982.  The policy recognized  that courts have
jurisdiction to fashion relief that allows a  source to continue operating
in  violation beyond 1982  while taking steps to come into compliance
expeditiously.   The policy  also set forth criteria  to  determine the
relief the Agency should  seek in each case, particularly whether a  compliance
schedule with  civil  penalties would be  appropriate  or  whether the Agency
should seek closure of the  source.*

    As a part of the Agency's implementation  of  the Post-1982 Enforcement
Policy,  a separate tracking system was  established  for the  226 sources
subject to the policy as  of the end of  1982.   By  the  end of  1983, of
*NOTE:  On January 11,  1984,  the Deputy Administrator modified  some
 procedural  aspects of  the policy.   The Agency  can  now enter  into  consent
 decrees, rather than stipulations,  to settle enforcement actions  provided
 that they are consistent with  the  policy.

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                                  VIII-3
these 226 sources, 140 sources had been brought into final compliance or
been placed on Federal or State compliance schedules.  Of the remaining
86 sources on the list, 35 sources had a Federal or State civil  action
proceeding and 12 were subject to SIP revisions which appear to be approvable
and would bring the source into compliance.  The remaining 39 sources
generally had some form of Federal or State action pending which should
resolve the violation.  Progress also was good in identifying and resolving
new violators subject to the policy.

C.   ENFORCEMENT OF NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS

     EPA directed much of its air enforcement effort in 1983 toward
compliance with the National Emission Standards for Hazardous Air Pollutants,
particularly vinyl chloride.  During the year, the government settled two
and filed eleven cases to enforce the standard for vinyl  chloride.   In
addition, the government filed two cases to enforce the standard for
asbestos.  Consent decrees were lodged in both of these cases in 1983.
EPA expects to place greater emphasis on enforcement of the asbestos
standard following repromulgation, which is now planned for 1934, and on
all aspects of the vinyl  chloride standard.

D.   STEEL INDUSTRY COMPLIANCE EXTENSION ACT AND ASSOCIATED ENFORCEMENT
     ACTIONS

     During 1983, the air enforcement program completed action on all
applications submitted under the Steel  Industry Compliance Extension Act
(SICEA) by filing implementing decrees for those companies found to be
eligible under the Act and by pursuing enforcement actions against  those
companies found not to be eligible.   Under SICEA,  Congress gave  the EPA
Administrator authority to extend, for eligible corporations, deadlines
for meeting air pollution requirements for up to three years if  the
company agreed to invest an amount at least equal  to the  deferred cost of
pollution control equipment in modernization to improve the efficiency
and productivity of its steel  making facilities,   the terms of an extension,
offsetting modernization requirements,  and compliance schedules  were to
be set forth in consent decrees.

     In 1983,  consent decrees implementing favorable findings under SICEA
were entered for the Sharon Steel  Corporation,  the United States Steel
Corporation,  and the Wheeling-Pittsburgh Steel  Corporation.   (Relief had
previously been granted to Ford Motor Company and  Alabama By-Products
Corporation.)

     Three contempt actions were filed against the Jones  and Laugh!in
Steel  Corporation on January 6-7,  1983,  based upon judicial  decree  violations
at its plants  located in  the States  of Pennsylvania,  Ohio,  and Indiana.
A contempt action was filed on April  21,  1983,  against the National  Steel
Corporation based upon judicial  decree  violations  at National's  Granite
City Steel  Division in Illinois.   National  Steel had withdrawn -its  SICEA
application,  and Jones and Laugh!in  Steel's application had been denied
by EPA.

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                                  VIII-4
    Enforcement actions previously  initiated  against  National  Steel's
facilities in West Virginia and Michigan  were resolved  in  1983.   A  consent
decree resolving violations at National's Weirton  (West Virginia) Steel
Division was entered on July 5, 1983.   On May 23,  1983, a  judicial  decision
resolved the government's enforcement  action  against  National's  Great
Lakes (Michigan) Steel  Division by  requiring  compliance "forthwith"  and
assessing significant stipulated penalties.   A judgment order  resolving
consent decree violations by the Inland Steel  Corporation  was  entered  on
June 28, 1983, and a contempt action against  the Kaiser Steel  Corporation
for violations of a consent decree  covering the corporation's  coke  batteries
was resolved in January 1983 through entry of an amended decree.  (Both
Inland Steel and Kaiser Steel had withdrawn their  SICEA applications.)

    The Agency had additional steel-related enforcement actions  pending
at the end of 1983, including cases  against Kaiser Steel (blast  furnaces),
3ethlehem Steel, Republic Steel, Chattanooga  Coke  and Chemical Company,
and Bayou Steel Corporation.

E.   OTHER CIVIL LITIGATION

    During 1983, there were 62 stationary air cases filed  in the U.S.
District Courts.  In addition, 33 civil actions were  concluded by consent
decrees or judgment orders.

F.   COMPLIANCE BY FEDERAL FACILITIES

    During 1983, Federal facilities  demonstrated a good record of compliance
with applicable air pollution regulations.  As of  the end  of 1983,  315
(92 percent) of the 341 significant  Federal facilities  met applicable
emissions limitations.   Of the 26 remaining facilities, 18 (5  percent)
are meeting compliance schedules that  will bring them into compliance.

G.   LIST OF VIOLATING FACILITIES

    The list of violating facilities,  under Section 306 of the Clean Air
Act, is designed to prevent the Federal government from subsidizing  certain
Clean Air Act violators with contract,  grant,  or loan monies.  No violators
were listed under Section 306 of the Act  in 1983.

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                 IX.  CONTROL OF MOBILE SOURCE EMISSIONS
A.   INTRODUCTION

     Control of motor vehicle emissions has been a Federal  responsibility
since 1968. The requirements of the Clean Air Act (CAA) relating to
mobile sources have been subsequently refined several times, most recently
in 1977.  The Clean Air Act Amendments of 1977 established  an ambitious
regulatory program which addressed remaining problems in the motor vehicle
emissions control program and bolstered efforts to attain and maintain
the national ambient air quality standards for carbon monoxide (CO) and
ozone (03).  Below are listed some of the the mobile source provisions
of the 1977 Act.

     - A schedule was established for implementation of stringent emissions
       standards for automobiles--0.41 grams per mile (gpm) for hydrocarbons
       (HC), 3.4 gpm for CO, and 1.0 gpm for oxides of nitrogen (NOX).
       The table below displays the level of control mandated by the
       standards:

                New Light-Duty Vehicle Emissions

                           Without       1977 CAA    Percent
                           Control       Standard    Reduction

      Hydrocarbons          8.8 gpm       .41 gpm      95%

      Carbon Monoxide      87.0 gpm      3.40 gpm      96%

      Oxides of Nitrogen    3.6 gpm      1.00 gpm      72%


     - Similarly, the amendments tightened standards for emissions of the
       above mentioned pollutants from heavy-duty engines.

     - Standards for the control of particulate emissions from diesel
       engines were legislated.

     - Areas not meeting CO and 03 ambient air quality standards were
       required to implement motor vehicle inspection and maintenance
       (I/M) programs.

     Since the enactment of the 1977 Amendments, the Environmental Protection
Agency has made steady progress toward achieving the Act's-goals, even
while addressing the economic problems that the automotive industry has
faced in recent years.  The Agency has made a number of modifications to
its motor vehicle emissions standards in order to assure that they attain
the goal of cleaner air as effectively and efficiently as possible.  In
1983, EPA made significant progress toward the implementation of this
program.

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                                    IX-2
B.   STANDARD SETTING

     Light-Duty Vehicles

     During 1933, the primary focus of EPA in the regulation of light-duty
vehicles (LDV's) and light-duty trucks (LDT's) was the control of emissions
from vehicles in high altitude areas and the control of diesel particulate
emissions.

     - Section 206(f)(l) of the Clean Air Act requires that 1984 and
       later model year LOV's comply with national emission standards
       regardless of the altitude at which they are sold. In 1983 EPA
       promulgated final rules for 1984 and later model year LDV's and
       LDT's implementing this section. In addition, the Agency modified
       existing regulations concerning earlier model year vehicles to
       allow the sale of low altitude vehicles in high altitude areas
       that already conform to national ambient air quality standards.1

     r In 1983 EPA also promulgated a final  rule allowing manufacturers
       to demonstrate compliance with diesel  particulate emission standards
       on a fleetwide average rather than for each vehicle.2  This inno-
       vation will permit manufacturers to select the most cost-effective
       technologies while attaining the same  overall reduction in controlling
       particulate emissions.

     Heavy-Duty Vehicles

     With the achievement of effective reductions of passenger car emissions,
EPA has increasingly turned its  regulatory focus toward the development
of parallel  standards for heavy-duty trucks  and other commercial  vehicles.
Projections  indicate that these  vehicles  will  contribute an ever-increasing
percentage of the mobile source  emissions generated for the rest  of this
century.  It  is  therefore important to establish standards for  these
vehicles  to  help insure better air quality.   Accomplishments in this  area
during 1983  include the following:

     - EPA promulgated  a new standard for evaporative emissions from
       heavy-duty trucks with gasoline engines.3  This  regulation  will
       reduce  non-methane hydrocarbon emissions from these vehicles by
       92 percent over  uncontrolled  levels.

     - The  Agency also  proposed  to modify  the  full-life useful  life
       definition and the half-life  useful  life definition for  LDT's  and
       heavy-duty engines.4  These new definitions  reflect real-life
       conditions more  closely.   They will enable  EPA to more  accurately
       evaluate  the effectiveness  of  various emission  control  systems
       over  the  life of  these vehicles.

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                               IX-3
 - tPA  revised HC and CO standards for  emissions  from  1985  and  later
  model year heavy-duty trucks.5  This  regulation  established  a  new
  transient test procedure and more  realistic useful  life  provisions.
  It also  included a modification of the standards, delaying imple-
  mentation of them from  1984 to 1985,  and further revising standards
  for  model year 1987  in  order to enable manufacturers to  avoid  the
  cost of  developing catalytic converter technology for  larger
  engines.  This adaptation will cause  virtually no delay  in achieving
  ambient  air quality  standards for  geographical areas not currently
  meeting  those standards.

 - EPA  also moved forward  in its development of standards for particulate
  and  NOX  emissions for heavy-duty diesel engines.  Proposed regulations
  are  scheduled to be  published in 1984.

 0th e r_V e h_i_cj_e_ _Cat e g p_r_i_e s

 - EPA  promulgated several  changes in HC, CO, and visible smoke
  standards for jet engines in 1983, enhancing the enforceaoiIity of
  these standards in light of advances  in technology. These changes
  more accurately reflect the performance characteristics of modern
  jet  engines.

 - EPA  also made modifications to its rules concerning evaporative
  emissions from motorcycles.5  Previous regulations required  motor-
  cycles to meet standards that applied to automobiles and trucks
  and were physically  impossible for them to comply with by design.

 - The Agency also moved forward in its study of railroad emissions,
  due to be published  in Iy84.

Fuel_s_

 - In October 1982,  EPA published a rule revising the standards
  applicable to lead  in gasoline.   This rulemaking, expected to
  reduce airoorne lead 34  percent  more by 1990 than under the  rule
  previously in effect, was challenged by several  refiners.  In  1983,
  EPA promulgated an  amended  definition of small  refinery to allow
  small refiners  more time to  comply  with the  new regulation.1

- EPA continued to  process applications for  fuel  additive waivers,
  primarily for methanol blends,  in  1983.

- The Agency also promulgated  rules  substituting  antiknock  index  for
  research octane number in rating unleaded  gasoline in  1983.8   Tnis
  change  brings EPA  into conformity with industry standards of
  measurement.

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                                    IX-4
 C.    PREPRODUCTION COMPLIANCE

      One of EPA's long-standing  techniques  for  assuring  compliance with
 motor vehicle  emissions  standards  is  the  preproduction certification
 review program.   Initiated in  1968, the program entails  engineering
 review by EPA  staff of engine  families representing  new  vehicles  to be
 sold in the United States.   Steps  in  the  process  include submission by
 manufacturers  of  technical  data  about respective  vehicles, emissions
 testing of prototypes  by manufacturers, review  of engineering data and
 test results by EPA, and,  in certain  cases, confirmatory testing  of
 prototypes at  EPA's laboratory facility in  Ann  Arbor, Michigan.

      In 1983 EPA  extended  a  pilot  program allowing alternative methods in
 determining the durability  of  emission control  systems in LDV's and
 LDT's.9  This  ruling reduces the cost of certification of vehicles
 without weakening emission  control standards.   The Agency continues to
 develop other  refinements  to the certification  process in order to enhance
 its  effectiveness,  reduce  its  burden  on EPA and manufacturers, and assure
 its  consistency with new developments in vehicle  technology.

 D.    INSPECTION/MAINTENANCE

      A  strategy for dealing directly  with in-use  emissions problems is
 the  encouragement of motor  vehicle inspection and maintenance (I/M)
 programs.   EPA's  basic approach in this area was  determined by the 1977
 amendments  to  the Clean Air Act.   Urban areas of  the country which obtained
 an extension in the deadline for attaining the  ambient air quality standards
 for  automotive-related pollutants beyond 1982 are required by the Act tc
 implement  an I/M  program.   In  August  1983, EPA  issued a  policy statement
 reaffirming  its commitment to  I/M as  a vital component of pollution control
 plans in non-attainment areas.10  In  the statement,  it reinforced its
 position on  funding restrictions and construction moratoriums in areas
 which have  not implemented I/M programs in the  time  mandated by  'the Act.
 Consistent with this guidance,  EPA took steps to assure  implementation
 of an I/M  program  in each locality where it is  required by the Clean  Air
 Act.  By the end  of 1983, 20 areas in  31  States had  initiated I/M programs.

 E.   ALTERNATIVE  COMPLIANCE MEASURES

      In recent years, increasing  attention has focused on the problem  of
 excessive emissions from in-use vehicles.   This emphasis  has  resulted
 from the perception that the Nation's  considerable investment in vehicle
 emissions control  technology can  be squandered if for any reason the
 equipment does  not perform as anticipated  in actual  use.

     EPA is now proceeding with a study whose  goal is to  identify  the
most efficient  way or ways to achieve  in-use vehicle  compliance  with
emissions standards.  It  is possible that  an alternative  approach  could
entail an expanded role for emissions  averaging.  An  ongoing  in-use
vehicle testing effort  is aimed at  generating  data for this  study.
 Interim findings will  be  issued in  1984.

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                                   IX-5
F.   MOBILE SOURCE ENFORCEMENT

     The EPA mobile source enforcement program is directed primarily
toward achieving compliance with motor vehicle emissions standards and
fuel regulations as required by the Clean Air Act.  The major goals and
objectives are to  (1) assure that both new and in-use vehicles meet
emissions standards; (2) assure that emissions control systems are not
removed or rendered inoperative: (3) assure that harmful additives are
not present in gasoline; (4) administer statutory and California emissions
standards waivers; and (5) administer the statutory emissions warranties.

     RecalJ.

     Section 207(c) of the Clean Air Act authorizes EPA to order the
recall of vehicles if a substantial number of any class of vehicles do
not conform to emissions standards in actual  use.  During 1983, 2,441,000
vehicles were recalled either by direct order of EPA or as a result of an
EPA investigation.  In the same period, manufacturers voluntarily recalled
1,090,000 vehicles to correct emissions problems.  EPA conducted a total  of
25 recall investigations in 1983, and performed 634 tests of in-use
vehicles at laboratory facilities in Springfield. Virginia and Ann Arbor,
Michigan.  In order to assure that emissions  control  systems operate
properly throughout their useful lives, EPA has focused increasingly on
testing and investigation of high mileage vehicles.  However, a December
1983 decision of a panel  of the U.S.  Court of Appeals curtailed EPA's
authority to recall high mileage vehicles.  EPA has sought review of this
decision by the full  Court of Appeals.

     Em i s s ions Standards Waivers

     During 1933, EPA issued decisions on 5 requests  from automobile
manufacturers for waiver of the 1981-1984 model year  oxides  of nitrogen
(NOX) emissions standard for diesel engine powered automobiles.  This
enabled manufacturers to continue to make and sell diesel  engines while .
developing technology capable of meeting stricter standards.

     Selective Enforcement Audi ting
                                •
     In order to assure that production vehicles are  made in accordance
with emissions standards, EPA conducts Selective Enforcement Audit (SEA)
test programs at manufacturers'  facilities.  EPA has  found that the SEA
program encounters few failures, because automobile manufacturers routinely
test on a voluntary basis many more vehicles  than are strictly required
through SEA orders.  Therefore,  beginning in  1981, EPA changed its SEA
policy to place greater reliance on manufacturer testing programs and
less on EPA-mandated audits.  In 1983, EPA conducted  17 SEA  test programs,
including four at foreign manufacturers' facilities.

     Unleaded Gasoline Enforcement Program

     EPA has responsibility for enforcing Section 211 of the Clean Air
Act, relating to the regulation  of fuels and  fuel  additives.  One of the
regulations under this section of the Act is  aimed at protecting the
catalytic converters  on 1975 and later model  year cars.

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                                    es,
                                     s
IX-6
     EPA has established a nationwide fuels enforcement program to ensure
that affected retail  outlets comply with these regulations.  This program
includes sampling of  the fuel  at retail  outlets by Regional EPA field
inspectors and private or State inpectors under EPA contract, in order to
measure the fuel's lead content.  EPA conducted 14,360 inspections under
this program during 1983.

     As mentioned before in a related area, EPA developed new enforcement
procedures for the revised lead phasedown program, aimed at controlling
the lead content of gasoline at the refinery level.  The result was a 10
percent reduction of  lead use in 1983.

     Tampering/Fuel Switching

     EPA is also responsible for carrying out programs designed to deter
tampering with vehicle emissions control systems or using leaded fuel  in
vehicles which require unleaded fuel.  Surveys undertaken by EPA nave
shown tampering and fuel switching to be continuing serious problems
which undermine the emissions control performance of many in-use vehicle
The latest survey indicates that about 17 percent of the vehicle fleet i
subject to gross tampering, and about 12 percent to fuel switching.

     Federal efforts  alone cannot effectively address these problems.
Consequently, EPA has promoted the implementation of State and local
antitampering enforcement programs. In 1983, six local antitampering
programs were set up  as a result of this initiative.

     EPA also has prepared a document developing guidelines for State and
local antitampering ana anti-fuel switching enforcement programs.  This
document determines the impact of tampering and fuels programs on HC, CO,
and NOX nonattainment areas, evaluating them as part of state implementation
programs for those areas.

G.   IMPORTS

     The control of emissions from imported vehicles has become a major
issue in recent years.  Due to various reasons, vehicle imports have
vastly increased their share of the U.S. auto market. Correspondingly,there
has been a significant increase in the number of independent auto importers
bringing cars into this country for resale.  This has created several
problems in regulating the emissions from these cars.  In 1983 EPA received
6,000 applications and 22,000 inquiries concerning the importation of
nonconforming autos into the U.S.  In response, the Agency has modified
its imports program to handle this increase in demand, and is revising
its regulations to make the process work more smoothly and efficiently.
Workshops were held in November and December 1983 to discuss the impact
of the regulations and listen to public recommendations on changing them.

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                           X.  LITIGATION
A.   INTRODUCTION
     The United States Courts of Appeals decided 15 cases under the Clean
Air Act in 1983.  The most important single decision sustained  new EPA
controls on the lead content of gasoline.  Four more cases fell  in a
somewhat related field, involving challenges to EPA regulations implementing
portions of the control scheme for mobile sources of air pollution under
Title II of the Act.

     Five of the cases decided in 1983 involved EPA practice in controlling
emissions of sulfur oxides under the Clean Air Act.  Three of these
involved challenges to EPA practice in approving relaxations of control
requirements for sulfur oxides contained in State Implementation Plans
(SIP's).  One involved the grounds on which EPA could permissibly tighten
these requirements.  The remaining decision reviewed EPA's rules for
determining the extent to which' sources would be allowed to take credit
for the dispersion effects of "tall  stacks" in calculating the  degree of
emission reduction needed to meet air quality standards.

     Two of the remaining five cases involved various features  of the
Act's prevention of significant deterioration (PSD) system, and two
involved the system for attaining air quality standards.  The last upheld
EPA's regulations for assessing penalties under Section 120 of  the Clean
Air Act.

     EPA was a party to all  but two of these cases.  It won eight of them
and lost four while, in the  remaining case, the decision was too mixed to
characterize one way or the  other.

B.   MOBILE SOURCE CASES

     Lea_d_in Gasoline

     In Small  Refiner Lead Phase-Down Task Force v. EPA, 705 F.2d. 506,
the D.C." Circuit upheld" most aspects of EPA's decision to reformulate its
lead-in-gasoline regulations in a way that would increase their stringency
over time, eliminate separate more lenient lead-in-gasoline standards for
small refiners after a transition period, and tighten the definition of
small refiners entitled to separate treatment even  during this  transition
period.

     The court upheld these  regulations almost in their entirety.  It
found that EPA was justified in finding that airborne lead remained a
topic of health concern, that no special  standard for small refiners was
required by the Clean Air Act, and that the exact standard chosen was, on
the whole, adequately explained and justified by the record.

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                                   X-2
     The court invalidated EPA's establishment of a new transitional
standard for small  refiners tighter than the existing standard, holding,
in language of some potential  importance for administrative law generally,
that adequate notice of the proposed tightening of the standard had not
been given.

     Motor Vehicle Emission Controls

     In the first of three cases reviewing aspects of the emissions
warranty for new motor vehicles cases to be decided, Motor Vehicle Manu-
facturers Ass'n v. Ruckelshaus, 719 F.2d.  1159, the O.C. Circuit considered
whethe'r EPA had properly found that "short tests" of vehicle emissions
performance had been developed that correlated reasonably with results
obtained on the longer and more elaborate Federal Test Procedure used to
measure prototype compliance with emissions standards.  The court had
little difficulty in rejecting industry arguments that EPA could not
compensate for the lack of perfect correlation between the two tests  by
adjusting upward the emission levels at which a vehicle would fail the
short test, thus resolving any uncertainties in correlation by passing
the vehicles that fell in the gray area.

     In Automotive Parts Rebuilders Ass'n v. EPA, 720 F.2d. 142, the  same
court considered rules established by EPA to implement the extended
emissions warranty manufacturers are required to offer for new cars.   The
court agreed with EPA that for the first two years or 24,000 miles after
a new car is sold, manufacturers are responsible for repairing any part
of the car that causes failure of a "short test," not just those parts
typically associated with emission controls.  The court also accepted
EPA's view that a vehicle manufacturer must honor a warranty claim even
when another company's defective part causes the "short test" failure,
provided the part was certified for emissions equivalency under EPA's
part certification program.

     .However, the court concluded that EPA had to provide a mechanism for
auto manufacturers to be reimbursed for warranty costs by the manufacturers
of the defective part.  And, in Specialty Equipment Market Ass'n v.
Ruckelshaus, 720 F.2d, 124, the court found EPA's reimbursement scheme to
be inadequate, and remanded to EPA to develop a more effective scheme.
The court also concluded that EPA had failed to articulate a reasoned
basis for its decision to exclude "specialty parts" -- mostly parts
designed to enhance fuel economy or performance -- from the parts certi-
fication program.

     Finally, in General Motors Corp. v. Ruckelshaus, the court, by a
vote of two to one, held that EPA could not require the recall for repair
of vehicles that had exceeded the "useful life" of five years or 50,000
miles during which emissions standards apply at the time they came in for
repair, even if they had been within their useful lives when they first
began to violate standards.  One of the judges dissented vigorously and

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                                   X-3
agreed with EPA that the Agency may require manufacturers to repair, at
any time, vehicles that were within their "useful lives"
when they first failed to meet the standards.

     EPA nas requested the court to rehear this case en bane.

C.   SULFUR OXIDES CONTROL

     In 1983, the Sixth and Seventh Circuits both upheld EPA's present
policy on approving relaxations of sulfur oxides (S02) SIP requirements
without detailed consideration of the long-range impact of any resulting
SOg increases.  They accepted EPA's position that the rapid drop-off of
S02 concentrations with distance from the source strongly indicates that •
long-range effects of these emissions are likely to be minimal, and that
evaluating the transformation of S02 into particulates, particularly over
long distances, presents technical and scientific problems that the Agency
has not yet successfully resolved and therefore should not be compelled
to deal with in the regulatory context.  New York v. EPA, 710 F.2d. 1210
(6th Cir.  1933), New York v.  'EPA, 716 F.2d. 440 (7th C'ir. 1983).*
these decisions probably terminate litigation of this question for the
immediate future.

     In Wisconsin Electric Power Co. v. Costle, 715 F.2d. 323 (7th Cir.
1983), the court" upheld both TPA's decision to use  running averages
rather than block averages to conclude that a given area was not meeting
the air quality standard for S02 and to rely on modeling results, rather
than monitoring data, to reject a subsequent petition to redesignate the
area back to attainment again.

      Finally, in S_ierra_Club_v_._EPAt [719 F.2d 436], the O.C.  Circuit
reviewed and, in major part, invalidated EPA's regulations prescribing
the degree to which sources could take credit for the dispersion effects
of a "tall stack" in calculating the degree of emission reduction needed to
meet air quality standards.

0.   PREVENTION OF SIGNIFICANT DETERIORATION

     Two cases decided in 1983 involved the Act's prevention of
significant deterioration system.

     In Sierra Club v. EPA, [715 F.2d 653] the D.C. Circuit remanded to
EPA for reconsideration its decision not to include surface mines in the
list of sources whose fugitive emissions will be counted in determining
whether they are major emitters of air pollution for purposes of new
source review under the Clean Air Act.  The court found the reasons EPA
gave for not including surface mines inconsistent with the reasons it had
given for including certain other sources.
*In a third suit, the Sixth Circuit  decided in EPA's  favor in  an
 unpublished order.  New York vs.  EPA,  No.  32-3426 (order  issued
 August 12, 1983).

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                                   X-4
     In Kerr-McGee Chemical  Corporation v. Interior Dept.,  709 F.2d. 597
(9th Cir. 1983), a case to which EPA was not a party, the  court rejected
a company's claim that the Interior Department had to meet  certain sub-
stantive and procedural requirements before recommending to a State that
it provide additional air quality protection to a national  monument.
It found no justifiable injury had occurred because, under  the statute, the
decision whether to actually provide this protection is reserved to the
State, and the State had not acted.

E.   OTHER APPELLATE DECISIONS

     In Duquesne Light Co. v. EPA. 698 F.2d. 456, the D.C.   Circuit upheld
in virtually all respects EPA's regulations under Section  120 of the
Clean Air Act for assessing administrative penalties against sources that
delay compliance with emissions standards.  In particular,  the court
upheld the details of the mathematical model used to calculate these
penalties.

     In Bethlehem Steel v. EPA,' [723 F.2d 1303] the court  ruled that
only a State, not EPA, can now change the designation of an area as
"attainment," "nonattainment," or "unclassifiable" under Section 107 of
the Clean Ai r Act.

     In Sierra Club v. Indiana-Kentucky Electric Corp., 716 F.2d. 1145
(1933), a case to which EPA was not a party', the Seventh Circuit ruled
that a State Implementation Plan that has been invalidated  as State law
by the State courts cannot be enforced as Federal  law either.

F.   OTHER LITIGATION

     In 1983, the Supreme Court granted certiorari to review the D.C.
Circuit's decision in NRDC v. Gorsuch, 685 F.2d. 718 (1982).   The case
was largely briefed in 1983 and is scheduled for oral argument and decision
in 1984.

     Two district court cases in 1983 split on whether the  present emissions
standards under Section 112 of the Act for vinyl  chloride contain "work
practice" requirements of a sort that would require further rulemaking to
be validly promulgated.

Compare United States v.  Borden. Inc., 572 F.  Supp. 684 (D. Mass.) (no
such defect)  with United  States v. Ethyl  Corp.  [No. 83-3537  (N.D. LA,
July 6, 1983)] (standard  contains work practice requirements).

     Finally, in another  of  the numerous  schedule suits that  mark the
history of the Clean Air  Act, EPA was ordered  to propose hazardous emissions
standards for arsenic.  New York v.  Gorsuch, 554 F. Supp. 1060 (S.D.N.Y.).

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                               XI.  REFERENCES
 Chapter II
 1.   "National  Air Quality  and  Emissions  Trends Report,  1982  " EPA-450/4-84-
     002,  Marcn 1984.

 2.   44 Federal  Register  275b8  (May  10, 1979).

 3.   D.  Fox,  "Judging  Air Quality Model Performance," Bulletin of the American
     Meteorological  Society, 62(5).599-609,  1981.     	

 4.   R.  Londergan,  et  al.,  "Evaluation of Urban Air Quality Simulation
     Models," EPA-450/4-83-U20,  1983.

 5.   A.  Policastro,  et a!., "Evaluation of Two Short-Term Long-Range Transport
     Models With Field Data," Presented at APCA Conference on the Meteorology
     of  Acidic  Deposition,  Hartford, CT,  1983.

 6.   R.  Londergan,  et al.,  "Evaluation of Rural Air Quality Simulation Models "
     EPA-45U/4-83-003, 1983.

 7.   American Meteorological Society, "Synthesis of the Rural  Model  Review "
     EPA-60U/3-83-1U8, 1983.

 8.   American Meteorological Society, "Review of the Attributes and  Performance
     of  Six Urban Diffusion Models," Report Prepared by  the American Meteoro-
     logical Society Under a Cooperative Agreement with  EPA. Research Trianale
     Park, N.C., 1983.                                                     y

 9.   A  Thrall,  T. Stockenius  and C. Burton,  "Consideration of the 'Bootstrap1
     Technique for use in Evaluating the Effect of Modeling Uncertainty  on
     the Determination of Emission Limits,"  EPA Contract No. 68-02-3b82
     Research Triangle Park, N.C., 1983.

 10   "Guideline on Air Quality  Models,"  EPA  450/2-78-027, 1978.

 11.  "Receptor Model Technical  Series Volume  III:   User's Manual  for Chemical
    Mass Balance Model,"  EPA-45U/4-83-014, July  1983.

 12. "Receptor Model Technical  Services  Volume IV:   Summary  of Particle
     Identification Techniques," EPA-450/4-83-018,  June  1983.

Chapter III

 1.   J. L. McElroy, et al,  1982.  "Airborne  Downward Looking  LIDAR  Measurements
     During  the South  Coast Air Basin/Southeast Desert  Oxidant Transport
     Study:   Operations and Data Report," T.S.-AMD-82133.

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                                    XI-2
     J. L.  McElroy,  et  al ,  1983.   "Airborne Downward  Looking  LIDAR
     Measurements During the San  Diego Oxidant Transport  Study:   Operations
     and Data Report,"  T.S.-AMD-83612.

2.   Workshop on Fundamental Approaches to Extrapolation  Modeling of  Inhaled
     Toxicants:   Ozone  and  Nitrogen Dioxide.   June 27-29, 1983;  Wasnington, D.C,

3.   Chemical Coaters Association.   "Environmental  and  Energy Benefits  of
     Microprocessors Used  for Oven  Air Flows  From  Metal  Painting Operations,"
     EPA-600-S-7-83-037; NTIS PB83-225250, October 1983.

4.   G. England, et  a I.  "Evaluation  and Demonstration  of Low NOX Burner
     Systems for TEOR Steam Generators - Test Report:   Preliminary  Evaluation
     of Commercial Prototype Burner," EPA-600/7-83-061;  NTIS  PB84-128727,
     January 1984.

5.   R. J.  Tidona, et al.   "Evaluation of Combustion  Variable Effects on
     NOX Emissions From Mineral Kilns," EPA-60U/7-83-045; NTIS
     PB83-2by6bb, August 1983.'

6.   C. Castaldini and  L.  R. Waterland.  "Environmental  Assessment  of a
     Reciprocating Engine  Retrofitted with Non-Selective  Catalytic  Reduction,"
     Accurex Draft Report,  April  1984.

7.   K. J.  Tidona, et ai.   "Refinery  Process  Heater NOX  Reduccion Using
     Staged Combustion  Air  Lances," EPA-600-7-83-022; NTIS PBS3-193946,
     March  1983. •

8.   "Photochemical  Reactivity of Perchloroethylene," EPA-600-3-83-OU1,
     January 1983.

9.   Health Assessment  Document for Carbon Tetrachloride, March  1983,
     EPA-600-8-82-001.   (revised  draft)

10.  Health Assessment  Document  for Nickel, May 1983, EPA-600/8-83-U12.
     (Draft)

11.  Updated Mutagenicity  and Carcinogenicity of Cadmium. June 1983,
     EPA-600/8-83-025A.  (Draft)

12.  Health Assessment  Document for Manganese (Parts  1  and 2), June 1983,
     EPA-60U/8-83-014A.  (Draft)

13.  Health Assessment  Document for Chromium, June 1983
     EPA-60U/8-83-014A.  (Draft)

14   Health Assessment  Document for Vinylidene Chloride,  October 1983,
     EPA-600/8-83-031A.  (Draft)

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                                    XI-3
15.  Health Assessment Document for Epichlorihydrin, October 1983,
     EPA-6UO/8-83-032A.  (Draft)

16.  Health Assessment Document for Trichloroethylene, December 1983,
     EPA-600/8-82-006B.  (Draft)

17.  Health Assessment Document for Tetrachloroethylene.  (Perchloro-
     ethylene), December 1983, EPA-bUO/8-82-U058.  (Draft)

18.  Health Assessment Document for Dichloromethane (Methylene Chloride),
     December 1983, EPA-600/8-82-004B.  (Draft)

19.  Asbestos Health Assessment Update, February 1984, EPA-600/8-84-003A.
     (Draft)

20.  Health Assessment Document for Hexachlorocyclopentadiene, February
     1984, EPA-6UU/8-84-001A.  (Draft)

21.  Health Assessment Document for Chloroform (Parts  1  and 2), March
     1984, EPA-600/8-84-004A.  (Draft)

22.  Health Assessment Document for Ethylene Dichloride,  April  1984
     EPA-6UO/8-83-006A.  (Draft)

2J.  Health Assessment Document for Ethylene Oxide, April  1984
     EPA-600/8-84-009A.  (Draft)

24.  Healtn Assessment Document for Toluene, August 1983
     EPA-60U/8-82-008F; NTIS PB84-100056.

25.  Health Assessment Document for AcrylonitriIe,  October 1983,
     EPA-600-8-82-007F; NTIS PB84-149152.

26.  Health Assessment Document for 1,1,2-Trichloro-l,2,2-Trifluoro-
     etnane (Chlorofluorocarbon CFC-113),  September 1983,
     EPA-600/8-82-002F; NTIS PB84-118843.

27.  Carcinogen Assessment  of Coke Oven Emissions,  February 1984,
     EPA-600/6-82-003F; NTIS PB84-170182.

28.  Health Assessment Document for 1,1,1-Trichlorethane  (Methyl
     Chloroform),  February  1984, EPA-600/8-82-003F;  NTIS  number
     not yet available.

29.  Health Assessment Document for Inorganic Arsenic,  March 1984,
     EPA-600/8-83-021F; NTIS number not yet  available.

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                                    XI-4


 30.   J.  0.  Pleil, W. A. McClenn,,.  "Reduced Temperature Preconcentration
      and Gas Chromatographic Analysis of Ambient Vapor Phase Organic
      Compounds:  Systems Automation,"  Submitted to Analytical Chemistry,
      (in press), 1984.                                                 J

      M.  V.  Holdren, R. N. Smith, W. A. McClenny.  "Reduced Temperature
      Preconcentration and Gas Chromatographic Analysis of Ambient Vapor
      Phase  Organic Compounds"  Systems Performance," Submitted to Analytical
      Chemistry, (in press) 1984.

 31.   "Volatile Organic Chemicals in the Atmosphere   An Assessment of
      Available Data," EPA-600/3-83-027A, April ly83.

 32.   "Measurement of Hazardous Organic Chemicals in Ambient Atmosphere "
      EPA-600/3-83-002, January 1983.

 33.   Air Quality Criteria for Lead, Volumes, I, II, III,  and IV,  August and
      October 1983, EPA-6UO/8-83-028A  (draft).

 34.   R.  P.  VanNess, L. R. Woodland, and E. D.  Gibson.   "Kull-Scale Dual
      Alkali FGD Demonstration at Louisville Gas and Electric Company "
      EPA-6UO/7-83-03y; NTIS PB83-241  364,  August 1983.

 35.   "Capsule Report:   Adipic Acid-Enhanced Lime/Limestone Test Results at
      the EPA Alkali Scrubbing Test Facility "  EPA-62V2-82-029, April  1982.

      "Adipic Acid Enhanced Lime and Limestone  Testing  at  the EPA  Alkali
      Scrubbing Test Facility,"  Vol. I, Sasic Report:   EPA-6UO/7-82-010
      NTIS PB82-23U 6^4;  Vol.  II, Appendices:  EPA-6uOU/7-82-UlUB
      PB82-230632,  March  1982.

 36.   P. A.  Clarke,  R.  W.  Gerstle, D.  S.  Henzel,  K.  W.  Mason,  and
      S. R.  Sabatini.   "The Adipic Acid Enhanced  Flue Gas  Desulfurization
      Process for Industrial  Boilers,"  Volume I,  Field  Test Results-
     EPA-6UO/7-82-U65A;  NTIS  PB83-144  774,  November  1982.

     G. P.  Behrens  and 0.  W.  Hargrove.  "The Adipic Acid  Enhanced  Flue Gas
     Desulfurization  Process  for Industrial  Boilers,"  Volume  2, Technical
     Assessment:   Radian  68-02-3171  T35; NTIS  PB83-144782.

37.  "A Study  of  Sodium  for  Improved Hot Side  ESP Performance," Journal
     of the Air  Pollution  Control  Association.  Volume  31,  #3  (March  1981).

38.  The results of work  at Bull  Run are in  the  final  report  "Pilot  Evaluaiton
     of Fine Particle  High Resistivity Electrostatic Precipitator."   (An
     EPA number  has not been  assigned  to the report.)

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                                    XI-5


3y.   "Electrostatic Augmentation of Fabric Filtration:  Pulse-Jet Pilot
      Unit Experience," EPA-600/7-82-062.

40.   "Pollution Episodic Model User's Guide," EPA-600/8-84-008,
      March  1984.

41.   R. K.  Stevens and T. Pace, 1984.  "Status of Source Apportionment
      Methods:  Quail Roost II," EPA-600/0-83-022.

42.   C. Lewis and R. K. Stevens, 1983.  "Comparison of Factors Influencing
      Visual Air Quality During the Winter in Denver from Measurements Made
      by General Motors and Motor Vehicle Manufacturers in 1978 and EPA in
      1982," Submitted to Coloroado Air Quality Commission, December 1983;

43.   R. K.  Stevens.  "Analytical Measurements for Use in Source Apportionment
      Studies to Determine the Impact of WoodDurning on Air Quality," (in
      press), Environment International.

44.   T. G.  Dzubay, R. K. Stevens, and P. L.. Haayenson, 1984.  "Composition
      and Origin of Aerosols at a Forested Mountain in Sovient Georgia," (in
      press), Atmospheric Environment.

        - R. K. Stevens, T. G. Dzubay, C. W.  Lewis, and R. W. Shaw, 1984
          "Source Apportionment Methods Applied to the Determination of the
          Origin of Ambient Aerosols that Affect Visibility in Forested
          Areas," Volume 18,  Page 261-272, Atmospheric Environment.

46.   Irwin, J. S., 1983.  "Estimating Plume Dispersion - A comparison of
      Several Sigma Scheme," Journal  of Climate and Applied Meteorology,
      22,99-114.	2i-

        - Irwin, J. S., 1984.  "Site-to-Site Variation in Performance of
          Dispersion Parameter Estimation Schemes," pp.  605-616,  Air
          Pollution Modeling  and Its Application, III, (C. De Wis"peTaere,
          Ed ) Plenum Publication,  Corporation, N.Y.

46.   Irwin, J. S. 1983.  "Preparing  Meteorological  Data  for Use in Routine
      Dispersion Calculations  - Work  Group Summary Report."
      NOAA-TR-ERL/AKL-122.

47.   "Users Network for Applied Modeling of Air Pollution (UNAMAP)
      [Version s], Magnetic  Tape and  Users  Guides,"  NTIS  PB83-244368.

48.   Revised Evaluation of  Health Effects  Associated  with Carbon  Monoxide
      Exposure, August 1983, EPA-60U/8-83-033A.  (Draft)

49. "The Acidic Deposition  Phenomena and  Its  Effects:  Critical Assessment
    Review Papers," EPA-600/8-83-016U,  May 1983.

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                                    XI-6
Chapter IV

1.  48 Federal  Register 628 (January  5,  1983).
2.  45 Federal  Register 55066 (August 18,  1980).
3.  48 Federal  Register 41608 (September 16,  1983).
4.  "Revised Evaluation of Health Effect
Chapter VI
 1,
 2.
 3.
 4.
 5.
 6.
 7.
 8.
 9.
10.
   Federal
   Federal
           Register
           Register
48
48
48
45
47
48
47
46
43	
"Compilation of Air
supplements 1-15,  U
   Federal Register
   Federal Register
   Federal Register
   Federal Register
   Federal Register
   Federal Register
   Federal Register
 4972  (February  3,  1983).
 5022  (February  3,  1983).
 5U686 (November 2,  1983).
 80084 (December 2,  1980).
 5864  (February  8,  1982).
 38742 (August 25,  1983).
 27bD4 (June 25,  1982).
 50766 (October  14,  1981 ).
 46246 (October  5,  1978).
 Pollution Emission  Factors
,S.  EPA,  Research Trianyle
Chapter VII
 1.
 2.
 3.
 4.
 5.
 fa.
 7.
 8.
 9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
           Register
48 Federal
48 Federal
48 Federal 	
48 Federal Register
48 Federal Register
48 Federal Register
48 Federal
48 Federaj
48 Federal Register
48 Federal Register
48 Federal Register
48 Federal  	^_ _
48 Federal Register
48 Federal
48
48
           Register
           Register
           Register
           Register
           Register
           Register
           Register
           Register
                                              ."  AP-42.
                                              Park,  NC,
                                                        including
                                                        January  1984.
 48368  (Octooer  18, 1983).
 48328  (October  18, 1983).
 !0b6 (January 10, 1983).
 37578  (August 18, 1983).
 387za  (August 25, 1983).
 5452 (February  4, 1983).
 7128 (February  17, 1983).
 48932  (October  31, 1983).
 57533  (December 30  1983).
 279 (January 4, 1983).
 2276 (January 18, 1983).
 2676 (January 20, 1983)
 39566  (August 31 , 1983).
 50671  (November 2, 1983).
 48960  (October  21 , 1983).
        (July 20,  1983).
   Federal
   Federal  Register 333112
48 Federal  Register 32126 (July  13.  1983)
"3ACT/LAER Clearinghouse - A  Compilation  of  Control  Technology
Determination"  (April  1983).

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                                   XI-7
Chapter IX
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
48
48
48
48
48
48
48
48
48
48
Federal
Federal
Federal
Federal
Federal
Federal
Federal
Federal
Federal
Federal
Regi
kegi
Regi
kegi
Regi
Regi
kegi
kegi
kegi
kegi
ster
ster
ster
ster
ster
ster
ster
ster
ster
ster
                        41296 {September 14, 1983)
                        33456 (July 21, 1983).
                        1430 (January 12, 1983).
                        1472 (January 12, 1983).
                        52170 (November 16, 1983).
                        29692 (June 28, 1983).
                        50482 (November 1, 1983).
                        4286 (January 31, 1983).
                        22546 (May 19, 1933).
                        35312 (August 3, 1983).

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