United States      Industrial Environmental Research  EPA-600/7-79-050e
Environmental Protection  Laboratory         February 1979
Agency        Research Triangle Park NC 27711
Proceedings of the Third
Stationary Source
Combustion Symposium;
Volume V.

R&D  Program Report


Research reports of the Office of Research and Development, U.S. Environmental
Protection Agency, have been grouped into nine series. These nine broad cate-
gories were established to facilitate further development and application of en-
vironmental technology. Elimination of traditional  grouping was consciously
planned to foster technology transfer and a maximum interface in related fields.
The nine series are:

    1. Environmental Health Effects Research

    2. Environmental Protection Technology

    3. Ecological Research

    4. Environmental Monitoring

    5. Socioeconomic Environmental Studies

    6. Scientific and Technical Assessment Reports  (STAR)

    7. Interagency Energy-Environment Research and Development

    8. "Special" Reports

    9. Miscellaneous Reports

This report has been assigned to the INTERAGENCY ENERGY-ENVIRONMENT
RESEARCH AND DEVELOPMENT series. Reports in this series result from the
effort funded  under the  17-agency  Federal Energy/Environment Research and
Development Program. These studies relate to EPA's mission to protect the public
health and welfare from adverse effects of pollutants associated with energy sys-
tems. The goal of the Program is to assure the rapid development of domestic
energy supplies in an environmentally-compatible manner by providing the nec-
essary environmental data and control technology. Investigations include analy-
ses of the transport of energy-related pollutants and their health and ecological
effects; assessments  of.  and development of, control technologies for energy
systems; and integrated assessments of a wide'range of energy-related environ-
mental  issues.
                       EPA REVIEW NOTICE
This report has been reviewed by the participating Federal Agencies, and approved
for publication. Approval does not signify that the contents necessarily reflect
the views and policies of the Government, nor does mention of trade names or
commercial products constitute endorsement or recommendation for use.

This document is available to the public through the National Technical Informa-
tion Service, Springfield, Virginia 22161.


                                    February 1979
     Proceedings  of the Third
Stationary Source Combustion
       Volume V. Addendum
             Joshua S. Bowen, Symposium Chairman,
             Robert E. Hall. Symposium Vice-chairman

              Environmental Protection Agency
              Office of Research and Development
            Industrial Environmental Research Laboratory
            Research Triangle Park, North Carolina 27711
               Program Element No. EHE624
                   Prepared for

             Office of Research and Development
                Washington, DC 20460

       These proceedings document more than 50 presentations and discussions
presented at the Third Symposium on Stationary Source Combustion held March
5-8, 1979 at the Sheraton Palace Hotel, San Francisco, California.   Sponsored
by the Combustion Research Branch of the EPA's Industrial  Environmental
Research Laboratory - Research Triangle Park, the symposium papers  emphasized
recent results in the area of combustion modification for NOX control.  In
addition, selected papers were also solicited on alternative methods for
NOX control, on environmental assessment, and on the impact of NOX  control
on other pollutants.

       Dr. Joshua S. Bowen, Chief, Combustion Research Branch, was  Symposium
Chairman; Robert E. Hall, Conbustion Research Branch, was Symposium Vice-
Chainnan and Project Officer.  The welcoming address was delivered  by Clyde
B. Eller, Director, Enforcement Division, U.S. EPA, Region IX and the opening
Address was delivered by Dr. Norbert A. Jaworski, Deputy Director of IERL-RTP,

       The symposium consisted of seven sessions:
       Session I:

       Session II:

       Session III:

       Session IV:

       Session V:

       Session VI:

       Session VII:
Small Industrial, Commercial  and Residential  Systems
Robert E. Hall, Session Chairman

Utilities and Large Industrial Boilers
David G. Lachapelle, Session Chairman

Advanced Processes
G. Blair Martin, Session Chairman

Special Topics
Joshua S. Bowen, Session Chairman

Stationary Engines and Industrial Process Combustion
John H. Wasser, Session Chairman

Fundamental Combustion
W. Steven Lanier, Session Chairman

Environmental Assessment
Wade H. Ponder, Session Chairman

                           VOLUME V

                      Table of Contents


Introductory Remarks, J.S.  Bowen 	   1

Welcoming Address, Clyde  B. Eller  	   7

Opening Address, N.A. Jaworski 	   9

"Combustion Modification Concepts for
Stoker-Boiler Application," J.H. Wasser  ,	  13

Luncheon Address, Peter Schwartz 	  21

"EPRI Low Combustion NOx Research,"
Donald P. Teixeira	51

Panel - "Short-Tern NOx Standards,"
R.E. Hall, S.P. Coerr, J.C. Wise,
F. DiGenova, V.A. Mirabella	53

"Towards a Research Plan to Study
Emissions from Small Internal Combustion
Engines," J.W. Murrell, F. Alexander 	 109

List of Attendees	121

               J. S. Bowen, Chief
           Combustion Research Branch
Industrial Environmental Research Laboratory-RTF


                          Introductory Remarks
                           J. S. Bowen, Chief
                      Combustion Research Branch
            Industrial Environmental Research Laboratory-RTP
Good  morning!   It is most encouraging  to see so many of you  here  this
morning.  This Third Symposium on Stationary Source Combustion is one of
the numerous technology transfer activities sponsored by the U.S. Envir-
onmental Protection Agency.  Such meetings provide a medium for exchange
of  the  latest  information  concerning  our  technology development  and
assessment programs  aimed at improved  pollutant  emission  control tech-
niques.  They offer  the opportunity for the  researchers and  investiga-
tors,  the  manufacturers and the  users  of the processes and  equipment,
the policy  makers, the  strategists,  and the regulators to share their
thoughts and their results.   They allow those who  are interested to be
brought  up  to date  on the  current  status of  the  development  and  the
evaluation of those pollution control  techniques presently  available and
those holding promise for  future  application.  So your presence really
reflects the strong interest on the part of the  many sectors  represented
in solving the Nation's environmental  problems.

It has been a year and a half  since our second  symposium in New  Orleans
in September  1977.  Now as  then,  the  primary  emphasis of the  meeting

is on combustion process changes or modifications for controlling nitro-
gen oxides  and  other combustion-generated pollutants from a broad range
of stationary combustion  sources.   In that year  and a half many things
have happened which  impact on our Combustion Modification  and  Nitrogen
Oxides Control  Program  and much important and encouraging  R&D  work  has
been accomplished.   We have  experienced the  aftermath of  the  earlier
"energy crisis."  Prompted by a restricted supply of natural gas and  the
uncertainty of  foreign  supplies of oil, the Nation's  energy plan calls
for the  drastically increased  reliance on coal  in the long term as  a
fuel for many combustion systems which formerly used oil and gas.  There
is  the  added emphasis  on conservation  in  all  energy-related areas  to
permit available fuel  to  go further in meeting our energy requirements.
As an example,  wood is becoming increasingly popular as a fuel, both by
homeowners  and  by a  number of  industrial  companies.   With respect to
regulatory  standards  for  nitrogen  oxides,  we   note  the  trend  toward
relaxation, at  least in the near term,  of  the  standards for automotive
emissions,  and  the trend  toward implementation  of  more rigorous stan-
dards for  stationary sources.   Currently, the development  of  a short-
term ambient standard for nitrogen oxides is in progress.  Many  of these
regulatory  trends  may  necessitate  more  effective  controls as   well  as
controls for a wider variety of stationary sources.

In the Environmental Protection Agency's Office of Research and  Develop-
ment there  has  been an increased emphasis on the consideration  of prob-
lem areas from a broader perspective, with the need for a greater aware-
ness of  the total  impact of the  applications of control  technologies.
Thus, we have  seen  extensions  of  our programs  to include and place

strong  emphasis  on  environmental  assessment  and integrated  assessment
efforts.  These  study  the multimedia impacts  of processes or of  control
technologies  giving comprehensive consideration  to  hundreds of  poten-
tially  hazardous  pollutants rather  than  to the  mere  half-dozen or  so
criteria pollutants  considered  in the not-too-distant  past.   And, also,
there  has  been   greater  involvement  with other government  agencies,
particularly DOE, since we are working in strongly energy related areas.
All  of  these factors have  had  an effect  on our program  as  will  become
more apparent from some of the discussions In  this meeting.   Lastly, the
R&D  results  themselves   have  indicated  the   prospect  for  significant
improvements in NOX  controls  through such approaches as the  utilization
of improved burner  designs, the optimization  of combustion modification
techniques,  and the  application  of advanced processes.   These, however,
are the subjects to be covered in the various  papers  to  be presented and
I am sure we will find them very interesting.

I  would like to  take  this opportunity to  introduce several  people who
have  a  key  role in the  planning and  presentation  of this  symposium.
Most of them  are members  of the staff of the  Combustion Research Branch
of EPA's  Industrial  Environmental Research Laboratory  in Research Tri-
angle Park, North Carolina.  First,  I would like to  introduce Bob Hall,
who is the Vice-Chairman for the Symposium and has had the major  respon-
sibility  for  the  planning and arrangements.   He is  also the  Session
Chairman  for  the  First  Session  on   Small  Industrial,  Commercial,  and
Residential  Systems.  Next, I will introduce Dave Lachapelle, who is the
Session Chairman  for the  Second Session,  which addresses Utility and
Large Industrial  Boilers.   The  Chairman for the Third  Session is Blair
Martin.    The  subject  of  his  Session is  Advanced Processes.   Another

Session Chairman  is  Jack  Wasser.   His Session  will  cover  Stationary
Engines and  Industrial  Process Combustion  Systems.   And also, I would
like  to  introduce Steve Lanier.   He  is  the Session  Chairman for the
Session on Fundamental Combustion Research.   The  Chairman of the Final
Session,  on Environmental Assessment,  is Wade Ponder.  Wade  is  a member
of lERL-RTP's Process Technology Branch.  He is at  another Symposium at
this time but will  be arriving later in the  week and  you will  meet him

Now, let us proceed with  the Symposium Agenda.

                 WELCOMING ADDRESS
              Clyde B.  Ell-er,  Director
      Enforcement Division, U.S. EPA Region IX
A copy of Mr. filler's welcoming address was not received
in time for the publication of this volume.

                OPENING ADDRESS
        N. A. Jaworski, Deputy Director
       Office of Research and Development
Industrial Environmental Research Laboratory-RTF


                            OPENING ADDRESS


                            N. A. JAWORSKI
     On behalf of John K. Burchard, the Director of EPA's Industrial
Environmental Research Laboratory in Research Triangle Park, N. C., and
Steven R. Reznek, the Deputy Assistant Administrator for EPA's Office of
Energy, Minerals and Industry, in Washington, D. C., I welcome you to
the Third Symposium on Stationary Source Combustion.

     Let me begin my opening address by giving you a mini-course on the
EPA's organization.  As many of you know, Douglas Costle is our Administrator,
and Barbara Blum is our Deputy Administrator.  Reporting to them are six
Assistant Administrators for the following areas:


     —Air and Waste Management.

     —Water and Hazardous Materials.

     —Planning and Management.

     —-Toxic Substances.

     —Research and Development.

In addition there are ten Regional Administrators located throughout the

     Our Assistant Administrator for Research and Development is Stephen
J. Gage, who oversees the programs of five principal offices dealing

     —Health Effects.

     —Transport, Fate, and Ecological Effects.

     —Monitoring and Quality Assurance

     —Criteria and Assessment.

     —Environmental Control Technology.

     Most of the field effort under the last heading, Environmental
Control Technology, is being done through two Industrial Environmental
Research Laboratories.  One of those Laboratories — which is sponsoring
this symposium —is located at Research Triangle Park, N. C.  The other,
under the directorship of David Stephan, is located in Cincinnati,

     Within the Industrial Environmental Research Laboratory in N. C.
there are three major Divisions.  The Utilities and Industrial Power
Division, headed up by E. L. Plyler, is responsible for Flue Gas Treatment
including SO , NO , and Particulate Control.  The Industrial Processes
Division, headed up by A. B. Craig, is responsible for environmental
assessment and developing control technology for the Chemical and Metallurgical
Industries. Process measurement techniques used by the entire Laboratory
are developed and recommended by a branch within the Industrial Processes
Division. The third Division within IERL/RTP is the Energy Assessment
and Control Division.  R. P. Hangebrauck is the Division Director.  This
Division is responsible for fuel processing (such as Coal Cleaning, Coal
Gasification, and Liquefaction), and evaluating advanced processes such
as Fluidized Bed Combustion, and for Combustion Research.  This activity,
Combustion Research, is the subject of this meeting.  In addition,
topical issues not within the domain of the three divisions are developed
by the Special Studies Staff under the direction of Gene Tucker.

     Beginning in the late 1960's and extending into the early 1970's,
major thrusts of our Laboratory were in Flue Gas Desulfurization and in
Particulate Control.  However, combustion research is now the single
largest environmental control technology program within EPA.  The focus
on this technology is primarily due to two reasons:  (1) the projected
N02 ambient level is expected to increase significantly over the next 10
years; and  (2) the possibility of a short term NO  standard within the
next year.  These two factors significantly increased EPA's concerted
research effort primarily in the area of combustion modification.

     Within EPA we are very enthusiastic about our combustion modification
program  as  an environmental control for NO  and other pollutants  for
four main  reasons:

     1.  Combustion modification is relatively low in capital costs
         as compared  to  other control systems.

     2.  It is relatively low in operating  and maintenance  costs.

     3.  The  low projected energy penalties and the fact that in  some
         cases there  is  an energy saving.

     4.  The relatively  low impact on other media resulting from  combustion
         modification as contrasted to, for example, FGD, or where
         we create a  solid waste disposal problem.

     In addition, the projected effectiveness of NO  control appears  to
be very promising.

     Within the next  4 days you will be given a chance  to hear  some  of
the  successes of our  research and development effort.   Many of  the
participants  in this  endeavor, both private and cit government institutions,
have done  an  excellent job in this area.  Some of these I would like  to
recognize  are: Acurex, Battelle, Energy and Environmental Research Corporation,
Exxon Research, IGT,  KVB, Massachusetts Institute of Technology,  and
Rockwell International.

     Efforts also have been enhanced by the manufacturers of combustion
equipment.  Some of these that have been very instrumental are Babcock
and Wilcox, Combustion Engineering, Foster Wheeler, and Pratt and Whitney.

     I would also like to recognize the contributions of the electric
utilities both private and public and of the industrial segment who are
also enhancing the results gained from our and other efforts in combustion
modification.  As many of you are well aware, the final proof of this
technology is in the field testing.  Some examples of the fine cooperative
effort include:

     —Exxon Research and Engineering's efforts over the past 8 years
       in testing more than 40 utility boilers, the majority of which
       were coal-fired.  This required very close cooperation with such
       utilities as the Alabama Power Co., Arizona Public Service,
       Georgia Power, Potomac Electric Co., Public Service of Colorado,
       Salt River Project, Southern Electric Generating Co., Tennessee
       Valley Authority, just to name a few.

     —Gulf Power's cooperation on a 2-year field study to determine the
       effect of combustion modification on tubewall corrosion.

     —Field tests performed by Acurex, Combustion Engineering, and
       other contractors have involved utilities throughout the U. S.

     —The close working relationship between EPRI and EPA is another
       example of how industry and government can work together.

     We look forward to continued close cooperation with these and other
organizations in the future.  Such efforts will be beneficial to all of
us.  For example, plans are being made now to field test a new low NO
coal burner design which was funded by EPA.

     It is time for the technical session to begin, so have a good and
productive symposium.  I encourage you all to meet with our IERL/RTP Staff,
talk to the researchers, and have a good stay here in San Francisco.

     Thank you.

    John H. Wasser, IERL-RTP


      A contract effort, now in negotiation, is described.   The program
will apply combustion modification concepts investigated in prior govern-
ment and industry programs to full-scale coal  fired stoker  boilers.   In
Phase I, the contractor will select and negotiate for the utilization
of two representative large industrial spreader stoker systems.   A
comprehensive Operation Plan will be prepared to bring together all
elements of the program in a study that will address the problems in-
volved in applying new technology to stoker systems and including design
of the hardware for applying the combustion modification concepts to the
specific units.  While the plan is under study for EPA approval, the
contractor will conduct the baseline study of the boiler systems.  After
approval of the Operations Plan, the contractor will construct  the
modifications to the system and proceed with the comprehensive  study of
the modified system.

     The program will continue with analysis of the data and preparation
of a thorough evaluation of the environmental  aspects of the applied
modification concepts.  Subsequent to the analysis and evaluation, a
document will be prepared in cooperation with boiler owners and manu-
facturers that will facilitate application of the results of this pro-
gram to new design and retrofit installations.

     In Phase II, the contractor will  apply combustion modifications to
other types of stoker systems.  Boiler systems representative of commer-
cial moving grate and underfeed stokers (about three units) will  be
selected for the program.  This program phase will consist  of the same
series of tasks as the large spreader stoker phase.

     An industrial  review panel  will  be formed to provide practical
guidance for the program and ensure that the results  will  have  the
maximum benefit for the stoker boiler industry.

     This paper will describe a new contract effort now in negotiation.   The
contract will relate to one of several studies of a stoker coal  fired boiler
research, development, and application assessment program.  The  other two
related contracts in the program are:

     EPA 68-02-2627, Battelle-Columbus Laboratories, "Evaluation of
     Emissions and Control Technology for Industrial Stoker Boilers."
     DOE/EPA EF-77-C-01-2609, ABMA/KVB, "A Testing Program to Update
     Equipment Specifications and Design Criteria for Stoker Fired

     The current status of these two contracts was described by  the first two
speakers in this morning's session.  Experimental efforts for these two  contracts
should be completed in the second half of calendar year 1979.

     The contracts now in progress are essentially establishing  the state-of-
the-art for stoker fired boilers: one by applying combustion modification to
smaller scale units and scaling up to a mid-size unit; the other by evaluating
operating modifications on full scale units.  This information will  be the
major background material  for the new contract effort to build on.

     Prior field testing of industrial boilers by KVB in two contract programs,
already completed, also included studies of stoker boilers and served to
establish stoker emission  performance characteristics.  An earlier research
study by Battelle on a small  scale stoker provided valuable information  on
emissions and included a survey of stoker equipment current designs  and  processed
fuels for stoker application.

     Comprehensive sampling and analysis methodology, currently  in  use  and
continuing development, will  be a major factor in this new effort.   It  will
enable an indepth evaluation of the applied technology and will  thus define
the environmental impact/acceptability of new applied emissions  control  tech-
nology for stoker boilers.
                                PROGRAM SCOPE

     The combustion modification stoker program has been divided into  two
phases to differentiate between spreader and non-spreader stokers.   Phase  I
will  study spreader stokers exclusively.   Since they are regarded as the most
significant type of stoker from the standpoint of increased coal  utilization
in the U.S., they will  be considered first.   This is also being  done to coin-
cide with the funding availability:   current funding is  assured;  future fund-
ing is less definite.  The Phase I  work  will involve sequential  modification
and testing of two relatively large [100,000 to 300,000  Ib steam/hr  (45,000 to
136,000 kg steam/hr)] spreader stokers,  each requiring approximately 1 year's

     Phase II will study moving grate and underfeed stokers.   Three  of these
units will be involved  in the program over a 27-month period.  These units are
expected to be substantially smaller than the spreader stoker  boilers  used in
Phase I.  Again, the boilers will  be studied sequentially to complete  work on
a unit by unit basis to minimize adverse effects if funding is restricted.
The total program is expected to require approximately 51 months with  a total
expenditure of nearly $4 million.
                           PROGRAM OPERATION CYCLE

     The program operation cycle will  be followed once for each of  the  five
stoker boiler units to be studied.  Each cycle will  consist of the  same six

Task 1.  Systems and Fuels Selection

     The contractor will  use reported field test results  and R&D  information
on combustion modifications integrated with a perspective of the  stoker boiler
population spectrum in the U.S.,  to select and negotiate  for utilization of a
representative industrial  stoker  system fitting the phase subject.   The unit
selected will be in the representative size range for the type stoker involved
and the existing emissions control  equipment (cyclone,  ESP,  filter,  etc.) will
be considered in the selection process.  Negotiation will be critical  as the
boiler owner/operator will have to be cooperative in permitting modifications,
arranging operation schedules, and purchasing fuels.  Negotiations  will  explore
all possibilities for cost sharing.

     The contractor will then select additional fuels for use in  the program
operation based on availability and compatability with the stoker system
selected.  Fuels selection, especially cleaned, blended,  or processed coals,
will be limited to those available in sufficient quantity in the  timeframe of
the evaluation program.  Coals selected will be representative of major classes
or regions.

Task 2.  Operations Plan and Modifications Design

     The contractor will  develop  an operations plan to experimentally investigati
the environmental  aspects of combustion modifications applied to  the stoker
system involved with each cycle.   This operation plan will  also include the
design of the hardware modifications that will  be required to implement  the
application of the combustion modification technology.

     Potential combustion modifications for study include reduced excess air,
staged combustion (overfire air jets), improved aerodynamic overbed mixing,
flyash reinjection, zoned primary air control, and any other promising techniques
or combinations of techniques the contractor considers feasible for incorporatioi
in the specific boiler system. Consideration of these modifications will  be
organized into an optimum system  design for determining the best  method for
minimizing emissions from the specific stoker system under study.


     The plan will include requirements for a Level  1  EA (including  Bio-
assay) for each major coal/modification technique combination after  an
optimum configuration is established in the test program based on
criteria pollutant measurements.   Level 2 EA is planned for major  prob-
lem areas that are identified in the Level 1 analysis.   The plan and
design will be submitted to the EPA Project Officer for review and
approval before the work is undertaken.

     The plan will include requirements for determination of corrosion
rates by the ultrasonic probe method to establish if increased rates
will occur in relation to the combustion modifications  technology.

Task 3.  Baseline Systems Study

     As the Operations Plan and Modifications Design are being reviewed
by EPA, the contractor will conduct the baseline experimental program on
the unmodified system.  This part of the program will  involve establish-
ment of procedures and techniques for conducting the required experi-
mental work and cooperative operating procedures with the boiler  owner/
operator personnel, as well as establishment of the baseline emissions
for future comparisons.  The baseline study will include environmental
assessment data collection.

Task 4.  Modification Construction and Test Program

     After completion of the baseline study and EPA approval of the
operations plan/system design, the contractor will construct and  incor-
porate the modification design into the stoker system.   This work  will
be accomplished in full cooperation with the boiler owner/operator and
any construction subcontractors.  After construction completion,  all
parts of the modified system will be checked for proper functioning.
The contractor will conduct the experimental progrcn as described  in the
Operations Plan, systematically studying the comprehensive emissions

characteristics of the modified boiler system for each of the fuel/ modifica-
tion combinations over a range of typical stoker boiler operating conditions.
The study will  include determination of Level 1 Environmental Assessment
pollutant groups and specific Level 2 Environmental Assessment pollutants that
are responsive  to the combustion modification control technology as well as
the criteria  pollutants.

Task 5.  Data Analysis and Assessment

     Based on the results of the experimental program, the contractor will
analyze the data and make an indepth assessment of the pollution control
potential of the modified stoker boiler system.  This evaluation will  relate
the control potential to the overall environmental acceptability of industrial
stoker coal fired boilers.  The impact of this control technology on the
national environmental/energy outlook will be assessed.  Recommendations
concerning the  future application of combustion modification control for
stoker systems  will be made.

Task 6.  Application Guideline Document

     Assuming that the results of study Phases I and  II establish a signifi-
cant improvement in the environmental status of industrial spreader stokers,
the contractor will prepare a guideline document that will permit industrial
application of the successful combustion modification concepts.  A document
will  be prepared at the end of Phase I for spreader stokers; another,  at the
end of Phase II, for the other types of stokers.

     An industrial  advisory committee will be arranged by the contractor to
review plans and progress at each step.   This committee will provide practical
guidance for the program and ensure that the results have the maximum benefit
in the shortest possible time for the stoker boiler industry.  The committee
will be vital in the development of the Application Guideline Document.

              Peter Schwartz
          Manager,  Future  Studies
            S.R.I. International
This luncheon address, was recorded and
transcribed for inclusion in this volume,

     Robert Hall?  Futurists analyze trends and forecast what

may happen ten, twenty, thirty or more years from now.  These

are no blue sky acrobatics.  They specialize in long range

possibilities, base projections on sophistocated work with

economic and social trend lines, mathematical models, the known

and the unknown.  The ability to organize unrelated information

is crucial in this field.  Edward Cornish, president of the 50,000

member World Future Society foresees a growing demand for such

forecasting.   Why?  Because of the lightening -fast change as we

approach the twenty-first century, and new lifestyles, markets,

technology,  politics and many other developments.

     Future  study is a serious concern of business and

government executives.  These people must deal with these

developments or fall behind.  We at this meeting are concerned

with the environment and with energy.  We are very fortunate

today to have with us Peter Schwartz who is the Program

Manager for  Future Studies at S.R.I. International.  This was

formerly the Stanford Research Institute.  He's led studies on

future problems and long term interactions of energy,

environment,  economic and social forces.  Ke is now completing

a major long term study for California energy future.  Peter

is also Vice President of the Portola Institute, which is the

producer of  the Whole Earth Catalogue.  I'm sure you're


familiar with that, and with the Energy Primer.  And today

Peter will talk to us about Changing Values and the Environment.


         PETER SCHWARTZ:  Thank you.  It's a pleasure to be

here.  I always enjoy coming up to the Sheraton Palace for lunch,

If some of you have heard my talk before, or some parts of it,

and I hope I won't bore you.  And the rest of you who have

probably eaten too much, if you want to nod off a little bit

this is probably the least essential part of your program, so

I won't be offended.

     What I want to talk a bit about are some of the long term

forces that are.going to shape our attitudes toward environ-

mental policy, and how those might be changing in the years

ahead.  I want to focus especially on the question of values,

because most of the time forecasters are wrong.  Consistently

wrong.  And we've tried to figure out why people are wrong

when they look at the future.  And it seems to me that the

two reasons we are most often wrong about the future are:

one, we fail to anticipate innovation, that is the new things

on the horizon that are likely to affect us; and secondly,

we fail to adequately consider values, especially our own.

That is, we want the future to turn out a certain way.  We have

a stake in it ourselves.  And so our attitude toward fore-

casting generally is that we want the future  — we want the

particular forecast to fit our own hopes and aspirations.  And

hence, we deliberately, quite unconsciously, blind ourselves

to the realities we see.  So what I want to do is to focus on


those questions of value, in particular as to how those might
be changing and what effect they might have in the long run
on environmental policy.
     I think it's important however to digress for a moment
and give you a sense of the state of the art of the forecasting
profession.  We're not really very good at it.  We're a bit
like economists.  That is we study the past and we study the
present and we generate some models, and out of that we try
and look ahead.  And an incident not long ago will illustrate
the level of competence of the profession.  My wife and I are
backpackers, and we were hiking in the Sierras last summer, and
we were trudging up the trail, coming up to a pass, and up in
the pass we could hear some men in the midst of a debate.
They were arguing.  And as we got closer the shape of their
debate began to come clear to us.  Finally we discerned that
the participants were a doctor, an architect and an economist.
And they were  in the midst of a debate on who's profession
was the oldest.  And they were going around and around for
a long time, and as we got closer we could hear the debate
coming to an end, to denouement.  And finally the doctor said,
"Now look, I've got absolute proof as to who's is the oldest
profession.  One need only look to the Bible and you'll see
there in the first few pages of Genesis that God anesthetizes
Adam — puts him to sleep — operates,  removes a rib, and
creates Eve — clearly the first act of surgery.  Hence medicine
is the oldest profession".

     Well,  the architect says,  "Now look, you want to use that
kind of proof, one need only go a few paragraphs earlier in
Genesis and you'll see that God created the heavens and the
earth out of the chaos — really the first act of architecture.
Hence architecture is the oldest profession".  And the
economist just smiled at them both and said, "So who do you
think created the chaos?"
     So, I suggest you take what I say with a very large
grain of salt, and remember that most of the time we're wrong.
Okay.  Get down to it.
     I'd like to draw an analogy to begin with, and that is
when one thinks about the world there are different levels
at which one can think about it.  And the analogy I want to
draw is to medical diagnosis.   That is, there are many
different ways in which we can diagnose a patient if we were
a doctor.  First of all we could focus on symptoms — the obvious
things, temperature, runny nose, broken arm and so on — symptoms
of disease.  And we can treat those symptoms -- you know, we
can give 'em a decongestant for the nose and we can give 'em
things to reduce temperature and so on.  However we could step
up a level higher and interpret those symptoms as a disease
syndrome.  That is, looking for the causative agents, like
bacteria for example.  And then we might prescribe antibiotics.
But arguing about diagnosis of symptoms doesn't tell you much
about disease.  So that the next level is the disease level.
     We can go one higher level still.  We can wonder why


is this person sick.  How is it that he has come to be ill?

And one might then look at, for example, a breakdown of the

immunity system in the organism — in the person.  And one

might look at how is that to be treated.  What is it that you

can do to particularly bolster that immunity system so as to

prevent future recurrences of the disease.

     Finally one wonders then at the highest level, how is it

that that immunity system itself broke down.  And that's the

level of the sort of psychosomatic causes — basic questions

of lifestyle and way of life.  What is it that the person is

doing, on the whole, that makes them susceptible to have

their immunity system broken down, to become ill, to generate

those symptoms.

     Now I suggest that part of the problem in the environmental

debate, and part of the problem consistently in thinking about

the future, is we are talking about different levels of

diagnosis.  That is we are dealing with different points, we're

dealing with symptoms on the one hand versus the equivalent

of disease syndromes versus the equivalent of immunity systems

breakdown, and finally basic questions of how we choose to live.

It's that last level that I'm going to talk about most of all —

that question of how we choose to live and it's implications.

Because I think that's the level on which ultimately the long

term direction of our society will be decided.   That is, how

each individual in our society chooses to live.

     To do that I want to go backwards in time a bit — want to

go back in history.  This French historian named Ferdnand
Braudel (phonetic spelling:  Brawdell) wrote a remarkable
book called The Mediterranean and the Mediterranean in the Era
of Phillip II.  And what's interesting about Braudel's book
is the kind of history he writes.  Most of us when we studied
history in school studied it in the form of so-and-so killed
so-and-so and this person was elevated to the throne and this
new land was  discovered and a new invention was made and so on
as if that were history,  as if that explained our past.   Well,
Braudel writes such a history,  he writes that first level of
history, the  level of events.  But that doesn't really tell
you much about what's going on.   That only tells you about
what happened.  To understand more about what's going on one
needs to write a second history which places those events in
the context of social and political forces that are of a more
enduring sort.  And so he writes a second history of that
period.  But  that in itself doesn't really tell you the long
term evolution of that situation.  It will allow you to explain
how it came to be that way and what its long range implications
are.  He says one must go a level deeper -- that is, the more
enduring forces of geography/ of resources, of values, culture,
of basic belief systems themselves.  Because when one looks at
those then one begins to see the causative agents behind those
higher levels of history.  And so he writes a third history of
that region at that time.  And that's much longer in scope.
     Well, that's what I want to do, is again focus at that

bottom level historically — just as we want to focus on the

question of basic ways of life.

     When we do that we see that/ at least in our civilization,

we have been on a trend that's at least eight hundred to a

thousand years old.  Various writers have called it different

things.  Robert Heilbroner called it the Great Ascent.  Many

different writers have given it different names.  We prefer to

call it the Modernization Trend.  And it is the trend that

Western civilization has been on for at least the last

millennium, and it has gradually swept over almost the entire

world.  And we wonder whether it's going to continue.

     Now, I want to say a bit about the nature of that trend

and what we really mean by the Modernization Trend.  It has

four aspects in particular.  Number one — the secularization

of values.  By that I mean the source of our personal values

has shifted over time.  At one time our values came from two

places, either from tradition and culture — that is, my father

did it this way, the village always did it this way, the chief

told us to do it this way — or on the other hand, from

imminent religious experiences — that is, I experienced God,

or the Priests told me that they experienced God and here's

how it's going to be.   Gradually we shifted the basis of our

values from such transcendent, imminent and traditional sources

to secular sources.  We sat down and we figured it out.  That's

an important shift, because now the source of values is not

some fixed, divine order permanently and forever etched into


the nature of things,  but is created by man himself.   It is by

the choices and by our intellect that we choose to live.

     Okay.  That was one shift.   The second is the source of

our knowledge.   Originally knowledge came from one primary

place, experience — what happened to me in my life and the

experiences of others.  Gradually knowledge came to be

scientific knowledge.   I suspect most of us in this room are

scientists in one way or another — I'm an engineer by

education — and the power of scientific knowledge has swept

over the world.  And scientific  knowledge has some important

characteristics;  and that is that personal experience matters

relatively little to scientific  knowledge, and empirical

evidence and the shared procedures of a scientific method

and the approval of a larger community matter far more.

So that the basis of knowledge moves away from the individual

and much more toward the methods of a particular culture.

     The third element of the long term modernization trend

is economic rationalization.  The most important of those

secular values was economic efficiency — that is, those values

which would lead to higher levels of production and higher levels

of wealth for all.  And increasingly more and more of our

social activities are governed by economic rationality.

     The final element of that modernization trend was

industrialization — the particular application of scientific

and technological knowledge and  secular values in an economic

sphere.  And that is, more and more of our activities came

to be industrialized — that is, breaking them down into

smaller components so as to make them effective and efficient.

So that now not merely do we produce goods by means of

industrial activity, we are increasingly making services

industrialized as well, so that we have a health care

industry and an education industry.  And when you have an

education industry then you can begin to apply economic

criteria to education; and so you can come up with the notion,

for example, of over-education as if a person could have learned

too much.

     Those are the four elements of the Modernization Trend —

secularization of values, the scientification of knowledge,

the dominance of economic rationality and industrialization

of human activity.  More and more of our lives are governed

by the Modernization Trend.  We wonder if that's going to

continue.  I think the events in recent weeks in Iran are

indicative of the uncertainty with respect to the long term

direction of that trend.  Let me suggest a number of other

aspects that indicate that that trend may be in for some

problems.  Historical studies of times of revolutionary

change have all suggested one important characteristic of

those periods of revolutionary change — that there are some

common indicators that tend to rise rapidly about that time and

then seem to fall thereafter.  Such indicators are rise in

violent crime,  alcoholism, hedonism, alienation and.various

forms of breakdown of the family.  Now all of those are things


that I think we see about us today.  Just as an indicator,

those things seem to have proceeded times of rapid change in

the past,  in almost every culture in history.  They may be

indicative of a similar process at work in our own culture.

     Equally important is that there have been some fundamental

shifts in  our time that separate us from the rest of our

culture not too many years ago.  One, is that we're in the

process of making some important and fundamental changes in

our energy sources.  Every time a society has undergone a shift

in its energy source, both in its quantity and type of a

fundamental source, the basic nature of that society changes.

I mean, it's an old systems axiom that you can't do just one

thing.  When you really alter one fundamental element, like

its basic  energy source, everything else readjusts in the end

to take account of that.  When we moved from a nomadic culture

to an agricultural society, from an agricultural society  to

a wood based society, and then finally to a  fossil, and now

eventually moving away  from fossil fuels again toward something

else in the future.  When those major transitions of the  sort

that we are now in the  first stages of take  place, many other

things change simultaneously.

     Next, the scale of our society is vastly  larger than

any society in human history.  There's just  much, much bigger

society, and vastly more complex.  The U.S.  economy is more

than twice as large as  it was  twenty years ago.  In the decades

ahead  it will double again.  When  that level of activity  and

complexity take place all kinds of new phenomena occur which

were unpredicated — complex system on the past.  Complex

systems generate new phenomena that we are unable to predict

and understand.  Again, when that level of complexity reaches

the point which we have already then we are unable to manage,

understand and predict the nature of our own change.  So it's

quite clear that just out of the scale and complexity alone

there is a force for sudden and turbulent change.  Our

technological power is vastly greater than any civilization

in history.   At its most destructive extreme we can sterilize

the planet if we so choose.  Less destructively we have all the

powers a Faustian superman ever dreamed of.  We can bend rivers,

we can leap  tall buildings, we can do everything that anyone

ever imagined we could do.  Part of the question is what should

we do with that.  We have vastly more people on the planet than

we have ever had before.  Not too many years ago forecasts of

the future focused on global populations of five, six, seven

billion people.  Now we're talking about a minimum in the next

twenty-five  to thirty years of twelve billion people.  That's

vastly more  people then have ever existed on the planet before.

I suggest our condition changes fundamentally when we have that

many people  to cope with.

     And finally, and perhaps most important of all, our

basic belief systems themselves are being challenged.  There

is a fundamental root to human existence, and that is what we

believe the nature of things is — how the world is put together

and what our place in it is.   And until roughly the end of the

last century there was a kind of dominant myth, one that had

changed about the time of the Enlightenment and the time of

what was called the century of genius, the time of Newton, the

time of Descartes, the time of Leibniz and so on, that led to

the modern revolutions of our time — the revolutions that

started this country, the revolutions of France, ultimately

the Marxist revolutions in the Eastern parts of the world.

That world view was based on a scientific world view that

organized our perceptions of how the world is put together.

Long about the turn of the century, that world view began

to crumble.  That is, under the onslaught of quantum

mechanics/ under relativity,  as we began to learn more about

the nature of DNA, as we began to learn more about the nature

of evolutionary processes and so on, we've come to find that

our fundamental scientific world view is itself fragmented.

The basis of our metaphysics, the basis of our human under-

standing of our place in the world is itself now fractured.

And there is nothing to replace it yet.  There are the early

of a coming together of a new unified world view for science,

but it isn't there yet.  And in the face of that, that

fundamental sense of loss and confusion that we see and

underlying our incoherent values is not at all surprising,

because there isn't any fundamental basis upon which to

derive those values.  So I suggest that there  are a number

of indicators that we are in a period of fundamental change,

and those are that those traditional indicators of social

change themselves are shifting, that our change in energy source,

the change in scale and complexity, our technological power,

the numbers of people and the nature of our fundamental world

view itself is shifting.

     Finally, in that respect, the number of social movements

around the country today, taken independently they seem to be

simple fragments, but let me draw you back a few years to the

Chicago Seven trial.  And you all remember what the Chicago

Seven trial was about — those were the folks who ostensibly

conspired to bring us the riots at the Chicago Convention.

There was a problem with the conspiracy trial.  Conspiracy

wasn't seven people.  It was thirty thousand people.  It was

indeed a conspiracy, but it had no single head.  Social

movements have changed.   Social movements no longer are simply

organized the way military operations are organized, with a

commander-in-chief,  with one person at the top, and if you find

that one person you know who' s in charge — nobody' s in charge.

There isn't a single body in charge any longer.  And as a

result, those movements  appear to be chaotic and disorganized.

But in fact there's an underlying set of values and premises

that cut across many of  the different particular movements

which are organized into what appears a relatively coherent

pattern.  The particular organizations that manifest them

may be unstable and short-lived, but the movement as a whole

is very real.  The environmental movement is a good example of

that phenomenon at work.   There are obviously some long-lived

organizations that are still in business and will be in

business for a long time  to come.  But many short-lived

coalitions tend to be the most significant organizations that

operate in particular issues to affect particular places and

times.  So the nature of  political movements themselves has

shifted.  Well, all of that suggests to me that that long

term trend of Western civilization is up for grabs.  I don't

know whether it's going to go on or not.  It may in itself

be shifting.  Toward what direction remains unclear.  We've

given some thought to that and I want to say a little bit

about that.

     One aspect of it is  a change in the meaning of nature

itself.  Environment literally meant "other" — that thing

which was outside.  And there was the human environment and

there was the natural environment.  And to mediate between

us and the natural environment we developed technology.  To

mediate between us and the human environment we developed

politics as our two particular tools for dealing with our

natural and human environment.

     Well, that conception of environment and nature may be

an outmoded one.  That conception of nature was developed when

the people, the things we had to deal with were saber tooth

tigers.  Last time I had to deal with a saber tooth tiger was

a long  time ago.  My Buick Le Sabre on the other hand is

something that is more of a problem today.  What I suggest is

 that  environment itself has shifted.  Our tools, politics and

 technology  themselves, have now become part of our environment.

 That  is,  they are a new kind of nature.  And that for most

 of us as  individuals, the natural environment we have to begin

 to cope with are things like power plants, dams, highways,

 automobiles, computers, government agencies that spy on you  —

 that's a  part of the natural environment that we are now coping

 with  — and that becomes the more germane environment for most

 people in civilization today.  So the meaning of nature itself -

 one might call it now not Mother Nature but perhaps Stepmother

 Nature — has itself perhaps shifted.  And we have perhaps a

 more  ambivilent relationship to that new kind of natural

 environment.  And we've learned something about that natural

 environment in studying the old nature.  We've learned that  we

 don't have to leave nature exactly as we found it, because

 nature isn't that all that good all the time.  I mean we've

 all suffered under hurricanes, tornadoes, out here we worry

 about earthquakes, nature is not all that benign all the time.

 On the other hand if we change it too much we'll pay the price.

 We've learned that again and again.  And finally we've learned

 that  the  metaphor of conquest is an inappropriate metaphor.

 We never  conquer nature.  My wife is a mountain climber, and

 there aren't many women mountain climbers so she climbs mainly

 with  men. And it's only men who talk about conquering the

 mountain. Women climbers don't tend to talk about conquering

the mountain.   They just want to  be  there  and be open to the

power of the mountain and when they left they have no illusions

about who's in charge.  Well, keeping in mind that shift in

the meaning of nature now, and by the way those arguments

about the meaning of nature are found very eloquently in a

remarkable book called Many Dimensional Man by James Olgivey,

its subtitle is "Decentralizing Self Society and the Sacred"...

     Let me contrast now two very different perspectives on the

environment and on nature.  And what we see then is embedded

in that shift in the long term trend and the breakdown of that

trend is a shift in perspective — from what I'll call

Perspective One toward Perspective Two.  Perspective One sees

nature as primarily a resource, something for us to use.

Perspective Two on the other hand tends to view most of our

natural environment, including our new natural environment,

as reasonably sacred, that is as something to be valued in

itself — having intrinsic value.

     Second, Perspective One sees us as somehow different from

nature — that is we are divided from it.  The Bible even says

we are given dominion over it.  We're not of it, it is a

partition between us and it.  Perspective Two on the other hand

focuses on wholeness — sees us in our context.  Perspective

One talks about dominance over nature — conquest.  Perspective

Two on the other hand focuses on nurture.  Perspective One

focuses on the issue of management  and control — how is that

we can adequately manage the natural environment so as to control

it for our own purposes.  Whereas Perspective Two acknowledges


the unpredicatbility of that environment.  It continually does
rather perverse and unpredicatable things to us.   Perspective
One focuses on efficient use — best use, most efficient use.
Perspective Two on the other hand focuses on the concept of
caring.  Perspective One sees technology as dominant over nature
whereas Perspective Two sees that technology is now included
in our new nature — Our neo-nature as it were.  And finally
Perspective One focuses on the symbols of wealth, once
resources then the symbols of those, dollars.   Now Perspective
Two comes back around to the things of wealth themselves, the
stuff of the ground, the soil, the air, health and so on.
     Now what we suggest is that the Modernization Trend and its
break—the Modernization Trend is associated with Perspective
One and its break may be associated with Perspective Two.
And those issues of environmental values that seem to plague
us so often today are embedded in those two different
perspectives.  And they're not being dealt with at the level
of should it be more or less efficient, should our use be of
this sort or that sort, but at that most fundamental level I
tried to suggest earlier — the level of diagnosis, the level
at which we think one has to look at to see the long term
direction of our society.
     One other factor that one must consider here that's
important in the years ahead, is the impact of what we think
is one of the most important social changes in the next ten,
fifteen years, and that's the impact of the women's revolution.

It's not surprising to me to see predominantly men in this
room.  Ten or fifteen years from now this room will not be
filled predominantly with men.  We men have,  I think, a
misunderstanding about the nature of the women's movement.
I want to draw an analogy to the civil rights movement.   The
civil rights movement in the '50s was by and large an elitist
leadership oriented movement who's primary goal was to get
Blacks accepted into white society — give us a place in your
communities, give us a place at your table,  give us a place at
your jobs and schools and so on.  The real impact of the civil
rights movement in the '50s was not to win that victory.  It
was to awaken in a generation of people a consciousness of
their actual status in society.  The consequence of that change
in consciousness was to create the Black movement of the  '60s
who's primary goal was now to get white society to accept
Blacks as Blacks.  It is you change to accept us for what we
are not force us to change to be a member of your society.
I'm not saying that succeeded, but that was the thrust and
change of that movement.  The women's movement it seems to me
is following a similar pattern.  It began a primarily as an elitist
movement of women who spoke to a relatively small number of other
women who's primary goal was to get accepted into male society.
The real effect of that movement on the other hand was to
awaken in a generation of women young and old consciousness
of their stature in society — of their second rate role as
citizens.  I suggest that there will be a profound consequence

of that because unlike Blacks they're not ten percent of the

population, ther're a majority.  Like it or not, you know, they're

most of us.  We're the minority here.  And they will have their

way, one way or the other.  And there isn't anything we can do

about that.  They're going to have their way.  We have this

misconception see, about men and women.  Most of us have

taken enough mathematics to know that there's a difference

between equality and identity — two things can be equal

without being the same.  Well I think its kind of obvious

when you say it that men and women are different.  And we

try to pretend by and large that they're not different.  But

they are different.  They may be equal, but they're different.

And we have this image, we men, that we're going to unplug

a male module in our office or our company or our government

agency, and we're going to plug in a female module and nothing's

going to change.  Wrong.  It's not going to be like that.

Again, as with energy sources, when you shift the fundamental

sexual roles and the psychological basis upon them, everything

else changes to accomodate.  And it's a pervasive and

fundamental change that I'm suggesting that is going to go

on here.  The values that underly feminine psychology, I suspect,

are very different than the values that underly male

psychology.  And what happens in our particular organizations

and our particular institutions and the goals and values that

those institutions embody and head for will be fundamental, and

the change isn't going to be that easy, because it really is

 as fundamental as I tried to suggest all of these changes are.

 For us,  as men,  it's going to be real hard.  We're going to

 have to  learn new ways to communicate, new sets of goals,

 new sets of perceptions,  new ways to organize our activity.

 And it's going to be a time of great turbulence and difficulty

 for most of us.   It will  make our organizations less efficient

 probably in the  short run.   In the end I hope the change will

 positive.   I  don't  know what  the  outcome of that  is,  or  how

 quickly  it  will proceed.  But it's  underway,  it's inexorable

 and we aren't  going to anything to  stop  it.

     Okay.  I'm just  looking  at my  clock here.  Let  me see if

 I  can summarize where we  are.  We've  been as  a  civilization on

 this pattern  for a  long time  — this  pattern  of modernization.

 The years ahead, I  think, are  a time  of  great uncertainty

 because  the very fundamental  nature of our civilization  itself

 is being challenged.  It's being challenged by the change  in our

 condition, by  the change  in our energy sources, by the change

 in the basis of value, by the  change  of  the people who are

 significant and dominant  in our society,  the  change  in sexual

 roles, all of which argue that the value bases  upon which we

 think about the future make our projections and forecasts

 themselves are very much open  to  question.  I really wonder

whether the future, the next  ten, twenty,  thirty  years are

 going to be very much like at  all most of the conventional

 forecasts that have been made  upon which most of  the economic,

 energy and resource forecasts  that underly policy are made.

I suggest that we are in a time of much greater uncertainty

than any of us have faced.  It makes making policy decisions

very difficult.  It makes allocating resources to research

very difficult and I don't think we are going to escape our

uncertainty very shortly.  We are unable to define or

adequately — there isn't any particular set of scientific

tool that we're going to apply that's going to eliminate this.

This isn't something that's going to go away by more careful

study.  That uncertainty is fundamental to our times, and

isn't going to go away in the next few years.  It's with us

and it's going to stay here for a very, very long time to come.

Okay.  Thank you very much.  And I'll open it up to questions,

challenges or arguments at this point.

         QUESTION:  You might make your projections.  Where

are we headed?  You dodged the uncertain point.  Where do we

go from here?  You're projecting uncertainty.

         MR. SCHWARTZ:  Okay.  I'll give you my opinion.  Nothing

more than that.  Okay, take it as an opinion.  I think the next

ten, fifteen years going to be some pretty crazy times.  If the

'50s were a time of relatively smooth affluence, the '60s were

a time of activism, the '70s have got to be a time of insanity.

Any period that's characterized by Watergate, punk rock,

Jonestown has got to be a pretty insane time.  You know, when

these are the dominant events of the decade it's quite clear

that there's something else going on that we don't really

understand.  So if anything characterizes where we are headed

it is that fragmentation and fracturing of our basic social

and cultural fabric.   What it means is a time of great confusion,

disorder and uncertainty.   I suspect that what that means is

in real terms economic growth slower than one might have

anticipated otherwise.  That progress along many different

fronts, especially in energy, will be much more slow than

anybody imagined, development of coal for example is a good

case in point.  We looked at nuclear energy, and we said

"could you have anticipated the nuclear movement that's arisen

in the last few years?"  And we discovered that you could have

foreseen much of what's occurred in the last five or six years

as early  as  1953,  '54  —  that all  the  seeds were there and

all the information  that  was needed to  forecast it was already

present.  We  think that most of the forecasts  about

development rates for  energy sources are way out of line —

they're exercises in  fantasy.  As  a consequence what it means

is that many  of our projections and programs themselves are

going  to  be considerably  more turbulent and chaotic than we

have ever imagined before.  This is especially true because

the nature of political power itself has changed in our time.

Nietzsche said God was dead.  And  what  he meant by that was

that the  role that God plays in society is dead.  Jay Olgivey

says the  presidency is dead.  And  I suggest that the role that the

presidency plays is the role that  God once played and they're

both dead.  Our image  of  political power is that of a

copplemeister, playing a  tracker-action organ.  A tracker-

action organ  is that great big organ with pipes and keyboard
right, and you sit there at the keyboard and you push this
key  and  the right, through a complex set of linkages big pipe
sounds,  and out comes a note, and another key and another pipe,
and  so the president sits at his keyboard playing his keys
and  a harmonious tune comes out the end — policy, programs,
national thrust and so on.  The trouble is that someone
disconnected  the keys and reconnected them in funny ways.  And
he pushes this key and that note sounds, and pushes this key
and  that note sounds.  And cacaphony results, not harmony.
As a result the ability of executives to implement policy and
have real power work is fundamentally altered.  Power to me
means the ability to realize intention — that is to get what
you want done, done.   Now I suggest the President, and most
corporate executives  and so on have a great deal of impact.
When they do something all kinds of things happen, but it
bears very little  resemblance to what they wanted to have
happen.   And,  now  we  have a tendency with commodities to say
if it went from one place,  where did it go to?  The trouble
it kind of went like  that.   It's like smoke,  and I don't think
it went some place else.   It isn't that somebody else is in
charge,  nobody's  in  charge here.   I don't think anyone is in
charge any longer.  And as a result the ability at a time of
great turbulence  to marshall resources to accomplish particular
ends, like energy  development,  is extremely limited.   And as
a consequence of  that a time of turbulence and economic disorder

seems reasonably probable to me.  That's my answer to your


     Yes sir.

         QUESTION:  Do you expect to see a growth in political

authoritarianism in the West which results in a breakdown in

society?  A perceived breakdown in society (inaudible)

         MR. SCHWARTZ:  I think it's a real danger.  I'm not so

much worried about big brother in the traditional image of a

dictatorship.  Those are relatively easy to recognize, and our

systems are pretty well adapted to trying to prevent those.

Those are fairly unlikely I think.  Far more likely it seems to

me, is the pervasive encroachment of all kinds of constraints

on individual choices.  It is when the institutions become

increasingly distant from the people who give them ligitimacy,

when our choices are increasingly trivialized and our sense of

control over the meaningful decisions in life are increasingly

diminished,  then we're moving into an inherently authoritarian

direction.   I was engaged in a debate not long ago with a man

on energy policy.  And he said one of the great crimes that was

happening in energy policy is that we were going to be

constrained  in our choices of air conditioners and washing

machings and so on.  And I said I don't see very much

authoritarian about that.  I think what they were talking

about when they talked about freedom of choice was with gods

and political systems and economic systems, not washing machines

and breakfast cereals.  And we have too often equated and

sacrificed fundamental freedoms to obtain trivial freedoms —

freedoms of choice of washing machines and breakfast cereals,

when  that didn't seem to be at issue at all in the revolution

that  founded this country.  So I think part of the issue then

is discerning the what the real meaning of free choice and

non-authoritarian decision making amounts to, and finding ways

in which we can begin break up the system a little bit that

begins  to arbitrarily constrain more and more of our choices.

      Yes sir.

         QUESTION:  The comment you had about nuclear energy

being — I mean the results, the effects of it were detectable

as early as '53 (inaudible)    and it was a year or two before

it was  accepted as a viable energy source.  What were the

indicators that were ...

         MR. SCHWARTZ:  What I meant to say was the nuclear

opposition, not the effects of nuclear power plants or anything

like  that, but the nuclear opposition, all right, was the  ...

all of  the- elements of that were in place a long time ago.

What  we looked at were things like many of the scientific

papers  that were published at the time, various organizations

and movements that were already growing at that time, and what

their particular attitudes were,  and what the particular

conditions and structure of the nuclear industry was that was

being created — in particular its vulnerability to government

policy.   That is,  that it required the Price-Anderson Act

and it required the AEC's existence to be a viable entity.

And when you begin to put together some of the long term impact
of such social movements of scientific uncertainty and
dependence  upon government policy you see an industry that is
inherently vulnerable in the long run.
     Yes sir.
         QUESTION:  (inaudible)
         MR. SCHWARTZ:  That's right.
         QUESTION:  (inaudible)
         MR. SCHWARTZ:  Well, here in this state we have a
"gov" who I think would like to be the man on horseback, and
to some extent he is one in our own state.  But he's already
learned, the hard way, last June, what the limits of his own
power were in a state of only twenty million people.  A clear
majority, sixty-four percent of the voters, got up and said
"no, you can't have as much of our money anymore as you used
to get".  And he got that message loud and clear, as everybody's
learned around the country. And so I wouldn't be surprised to
see lots of folks coming along on horseback, but they're going
to be little horses, not big horses.  And they're going to be
more like ponies rather than horses.  And I don't think
they're going to have the impact that ever had before.  They
may try.  I'm not saying that people won't try.  But I don't
think that there's going to be that kind of ability to realize
it.  Perhaps.  I mean that's always a possibility.  I don't
mean to discount it altogether.  It could happen.  I consider
it highly unlikely in our society just because of its complexity.

Maybe somebody at the top — look, a few years ago we talked

about the imperial presidency.  Nixon, whatever one may have

liked or disliked about his politics, tried at one point to

be a reasonably imperial president, and found again and again

that everything that he tried to do was thwarted.  We just

saw recently that the memorandum that he put out on trying to

control PBS, you would think he would be able to do something

small and simple like that, and he couldn't even get away

with that.  The system is just really gotten out of the control

of executives and executive authority.  So he is really unable

to exercise that kind of power despite his own myth and fantasy.

Can anybody master the Civil Service?  I think Jimmy's trying

and ... without much luck.

     Yes sir.

         QUESTION:  Do you suggest that these forecasts are

more or less inevitable, that we cannot be masters of our

destiny?  What do we need to do to effect the kinds of change

that we need?

         MR. SCHWARTZ:  I'think we are in a sense the masters of

our destiny, but I...and forecasts are never inevitable.  There's

always surprise and there" isa't ... and there's also always

misunderstanding.   Our picture is  always incomplete.  There's

things that I've missed.  So there's nothing inevitable, about what

I've said.  More important,  in the study we've been doing for

the California Energy Commission what we have come increasingly

to see that in the long run, in part because of the nature of

the shift in political power,  that if anything, power is moving

away from large scale central  institutions back toward

individuals — a diminished power to be sure/ but a power

nevertheless, and a power to choose how one lives, and have

the consequence of those personal choices about lifestyle,

life way, values and so on ultimately be realized in social,

political and economic structures.  Those are long term

processes and it means that our fantasies of power are just

that — fantasies — that we are unable to realize what we

wanted to at one time.

     Thank you very much.

              Donald P. Teixeira
       Electric  Power Research Institute
A copy of Mr. Teixeira's paper was not received
in time for the publication of this volume.


The Panel Discussion on Short-Term MOX standards
was recorded and transcribed for inclusion in
this volume.



Introductory Remarks - Robert E.  Hall, EPA                  55

Stanton P. Coerr, EPA OAQPS                                 57

John C. Wise - EPA Region IX                                63

Frank DiGenova - California Air Resources Board             69

Vincent A. Mirabella - Southern California Edison           75

          MR.  ROBERT E. HALL:  The last event of the day, the
last official  event of the day.  I think we are very fortunate
today to have  what I am sure is going to be a very interesting
panel discussion.   I feel like this is one of the key special
features of the meeting and, as it turns out, a very appropriate
topic for this meeting.
          We have arranged a panel discussion on the short-term
NOx standards  and, as you well know, depending on what level is
finally selected,  this may or may not have quite an effect on
the work that  everyone in this room is involved with.
          We are fortunate to have with us today four distin-
guished members on the panel and, I think, a pretty good cross
section to give us an overall view of short-term NOx standards.
          Stan Coerr represents the Environmental Protection
Agency.  Stan  is in the Strategies and Air Standards Division of
the Office of  Air Quality Planning and Standards of EPA.  That is
located in the Research Triangle Park area in North Carolina.
Those offices  are actually in Durham.
          Stan is the national program manager for the NO2
National Ambient Air Quality Standards, and has also worked on
the lead ambient standard.  Stan has been with EPA for the past
seven years.  He has a masters in public affairs from Princeton
in economics and public policy, and a bachelor's degree in
economics from Williams College.
          Our  second panel member is John Wise.  John represents
the EPA Region IX office, which is located here in San Francisco,
and he will discuss the standard as it affects the Region in

coordination with the state agencies.  John is the Chief of the
Planning Branch of the Air Hazardous Materials Division of EPA
Region  IX.
          He got a BS from the University of Colorado in civil
engineering and business administration, and from Stanford he
received a master's in engineering economic planning.  He has
been with EPA since 1971 in the Water Quality Management Planning
area, the construction of waste water treatment facilities, and
air quality management planning.  The air quality management
planning is the most recent area.
          Our third member of the panel is Frank DiGenova, who
is with the California Air Resources Board, and California has
had a short-term NC>2 standard for some time, and Frank can give
us some input about their experiences and, depending on what EPA
comes up with for standards, this may or may not affect the state
          Frank received his BS in physics from the State
University of New York, and his master's in environmental science,
specializing in air resources, from Rutgers University.  He has
also taken courses in atmospheric science at the University of
California at Davis.
          Prior to working with the California Air Resources
Board he worked for three and a half years for the State of
New Jersey in the Bureau of Air Pollution Control, Planning and
Evaluation Section.  He joined the Air Resources Board about two
years ago, and since then worked in the area of control strategy
development for stationary energy sources.  In particular, he
has worked with SOx, NOx, mainly related to power plants and
refineries.  He has been heavily involved with the development
of NOx  control strategies in the LA basin, especially systemwide
control of power plant NOx emissions, and today will discuss the
EPA standard versus the California standard as it relates to
their experience.
          The fourth member of the panel, to give an overall
perspective, and not have it completely overloaded with govern-

ment and regulatory people, we have asked Vincent Mirabella to
represent industry.  He is with Southern California Edison
Company in Rosemead, and is the supervising research scientist
in the R&D Department.
          He received a BS in meteorology from Florida State,
and an MS in meteorology from Penn State.  His present responsi-
bilities involve air quality impact analysis on new and existent
power plants, and evaluation of proposed rule making.
          At this time I would like to turn the panel over to
Stan Coerr, who will chair the panel, and the plan is to allow
each speaker to go through his presentation withoutquestions,
mainly because a lot of the questions for one speaker may be
answered by another, so we would like each of the speakers to
give his presentation, and then we will open, after each of the
four have given their presentation, we will open it up for
general discussion.
          I would like to point out, since we wanted this panel
discussion to be up to date to the minute as much as possible,
we did not attempt to put it in the preprint.  For that reason
we have a stenographer who is recording and taking notes on the
panel discussion, but in order to avoid creating any problems
with discussion, or holding anyone back from open discussion at
the end of the presentations, she will not record the questions
and answers.
          MR. STANTON P. COERR:  Thank you, Bob.
          First of all, the national ambient air quality stan-
dards are denominated as nitrogen dioxide.  The control of
ambient NOx, as far as the standards themselves, are described
as nitrogen dioxide.
           (The following part of the presentation was accom-
panied by slides.)
          MR. COERR:  I want to run briefly through the status
of our program to consider a short-term ambient air quality
standard, and also to consider revisions of the long-term
standards.  What we are doing here is following instructions

from the Clean Air Act, so I am going to go through each of the
principal provisions of the Act which are controlling what we
are doing.
          I will also talk about our schedule and touch on a
couple of the many issues that are involved in the standard-
setting; on what the law requires for the standard and on the
impact of the standard large point sources.
          I won't ask you to read all the small print, but I
would like to point out that what seems to be controlling our
efforts in preparing these standards is four or five provisions
of the Act.
          First of all, the Act is very specific that the Agency
should create scientific criteria to serve as the basis for the
standard.  The regulatory side of the Agency can't move ahead to
propose or promulgate the standards until the research side is
finished with criteria documents.  They are in that phase right
          The Act is specific that we should develop criteria for
a short-term standard, and it also mentions that we should be
periodically revising our criteria for long-term standards.
          For the NC>2 standards we have combined these two exer-
cises into a single criteria document, and this may have added
to some of the confusion in reviewing various drafts of criteria
documents.  We originally had a document describing only criteria
for a short-term standard, but the current external review draft
is a combined document.
          Following development of air quality criteria, section
109 of the Act directs the regulatory side of EPA, to go ahead
and set a short-term standard.  With a sort of curious turn of
phrase, it says that we are to do this unless the Administrator
finds there is no significant evidence that such a standard for
such a period is requisite to protect public health.
          The key point here is that, in sort of this negative-
finding kind of way, if we have health information that a short-
term standard is required, then we are to proceed to propose and


          You might notice there are some dates in the Act.  We
are not going to make those dates, and I will get to them again
in a minute.  There is a list of reasons why we are not on the
congressional schedule.  One is that there are a lot of things in
the Clean Air Act of 1977, and we are sort of starting at one end
and getting to the other, but we can't do them all on schedule.
          Section 109(d) also asks the EPA to look at all of our
existing ambient standards on a five-year cycle, and so, as we
were considering the short-term standard, we were overrun with
the requirement to review the existing annual standards set in
1971, so now we are doing both at the same time.
          Section 109 also took from EPA what we used to run as
an internal EPA science review group The Science Advisory Board,
and established a Scientific Review Committee, with a congres-
sional mandate.  So, one of the things we are going through now
is to review both the criteria documents and some of the other
documentation we are developing, with this new scientific review
group.  I think some of the people in this room have had an
opportunity to testify or to observe those meetings of the Clean
Air Scientific Advisory Committee.
          A very key point, when we are talking about the impact
of an ambient standard, is the division of responsibility that
Congress came up with.  My office is responsible for developing
a national standard, which we present to the administrator in the
form of alternatives which he has decisions on.  But under the
Clean Air Act the implementation of the standard is delegated to
the states.  Their plans have to be approved by EPA, but it is a
little hard, as we develop the standard itself, to know what
plans will be forthcoming from the states, and exactly what kind
of impacts they will have.
          There is a great deal of discretion in this SIP process,
which I think is something that the panel members will discuss,
and this allows some latitude in what kind of impact the standard
may have on power plants because of how they are treated in the
SIP process.

          The last point, once again, is that the single focus,
or the basis for the level of the standards, is health effects.
This is not to say that the standard setting is simple, because
the health information is complicated and not always definitive,
but we are not, under the law, to use either economic or techni-
cal feasibility as a primary criterion for the standards.
          We do however get into discussing what might be the
impact of a proposed standard.  We are required to prepare
economic impact statements and environmental impact statements.
We do this, but we are not setting up an array of costs and
benefits and choosing the standard in that sense.  We are con-
strained in terms of the health information presented in the
criteria documents, one of the reasons why that process of the
development of criteria documents gets so much scrutiny from
industry and ourselves.
          This is the current schedule for the NO2 standards.
          We put out a criteria document draft the end of '78.
This draft was reviewed by the Scientific Review Committee on
January 30 and 31, 1979.  The Committee asked that certain por-
tions of the document be revised, and that is now being done.
We expect that these revisions will be complete by the end of
May, 1979.
          Using that document as a basis, we are then going to
proceed to develop proposed regulatory decisions on the short-
term and long-term standards, and we hope to have this in propo-
sal form by October, 1979.  We normally run about six months
between proposal and promulgation, and so, barring unforeseen
delay, we would be promulgating in March or April, 1980.
          It is important to point out that we have not yet
formally made any finding as to whether a short-term standard is
necessary, or whether a revision of the long-term standard is
necessary.  I have my opinions, and other people have other
opinions.  It simply hasn't yet been elevated to the senior
management of the Agency.
          I am not going to discuss here the considerable number
of issues in the health effects information, simply to say that

it is an issue, and we are getting a good deal of comments, and
we expect to get some more.
          The process for us is to identify what we consider to
be the adverse health effects associated with ambient, or poten-
tially ambient, levels of N02-  There are two effects of concern.
One is the reduction of pulmonary function, similar to ozone, and,
again like ozone, a decreased resistance to respiratory infection.
          We are concerned in this not to necessarily protect
the most sensitive individuals, or esoteric group, in the popula-
tion, but we do look for general subgroups within the population
that are particularly sensitive:  asthmatics; children; the
elderly; people with a preexisting respiratory condition.
          We will also be trying to find any information from
clinical studies or epidemiological studies about what kind of
period of exposure is significant.  This is particularly impor-
tant to NC>2 because Congress left us the latitude to set a
short-term standard of one to three hours.  From our initial
examination it is going to be difficult to find information
that would tell us which of those, the one or the three hours,
would be the best way to go.  This point does have an impact on
point source modeling.
          The last fuzzy area in the health area is the concept
of margin of safety and acceptable risk, and there are plenty of
issues in this; I am sure that these issues will be discussed as
we get the final criteria document and start looking at the
          As I have stated before publicly, our general range of
consideration for the N02 short-term standard is in the range of
.1 to .5 ppm.  This is where the center of attention is.  A few
associations have advocated a standard as low as 0.15 ppm.
Representatives from industry have stated publicly that they
believe that there aren't really any serious effects under .5.
There is a polarization of scientific opinion on this.
          Our second big issue in this particular standard is
that it is a complicated standard from an air pollution control
point of view.  Control of N02 must be directed at control of

the precursor NOx, which turns into NO2-  There are quite a
number of things that affect how this conversion happens, no
one of which seem to be consistently the controlling factor for
all parts of the country or even within the same area on the
same day.
          There are variable rates for the transformation, and
then you have the time lapse between the emission and the impact
complicating things.  We have had made a couple of different
approaches as to how we might unscramble the relationship be-
tween emission control and the ambient level, and these are
described in our draft environmental impact statement and other
documents that we have available, and anyone who wants to know
what we have done so far can talk to me afterwards, or write to
us and we will send them what we have.
          One particular point is that we are going to have a
very interesting problem in allocating — we are not going to
have the problem; the states in developing their plans will have
the problem — allocating existing NC>2 level back to the several
different sources which might be contributing;  point sources:
automobile traffic, and general area sources.
          Again, these contributions are probably going to be
variable, and depending on a number of factors.  We are also
concerned that control measures to achieve the oxidant standard
will affect what we are trying to do to attain the NO2 standard,
and, where we start controlling NOx, there is an impact on the
oxidant control program.
          Another range of issues is not so much the impact of the
primary standard itself, but what kind of concerns the indirect
impact of the standard on other regulatory programs such as new
source review for nonattainment areas, and prevention of signifi-
cant deterioration.
          I can state fairly categorically that we haven't bitten
the bullet on how we are going to handle the PDS approach to NC>2 •
We have been thinking that we would not necessarily adopt the
increment approach as we did for SO2 or TSP.  This is an area in

which comments would be very welcomed by the Agency/ if anybody
wishes to offer them.
          Again, when we get right down to what do these ambient
standards mean for large point sources, such as power plants,
I want to point out very strongly that the impact is a dual
function of the level of the standard, the SIP regulations/ the
guidelines we will propose, and finally the SIP plans that we
developed by the states.  There does tend to be, in my experience,
a good deal of discretion in that process, which allows you to
proceed to achieve a standard with varying degrees of economic
impact.  We are always very interested in being able to achieve
whatever standard we come up with with the least possible eco-
nomic dislocation/ and we would welcome comments on the guidelines
and the regulations on the SIP process as much as we would on
the standard itself, particularly, I think/ in the area of point
source modeling, where we are dealing with a kinetic pollutant.
We would also appreciate any empirical information you have on
air quality data.
          This concludes my remarks.  We will save questions
until the end, and now I will hand it over to John Wise/ from
EPA's regional office.
          MR. JOHN C. WISE:  Thank you, Stan.
          Is everyone in the audience able to hear me okay?
I am always intimidated by a room this vast, and a speaker system
that projects outward is always welcome.
          As Bob Hall and Stan have indicated, I am from the
regional office of EPA here in San Francisco, and I bring to the
panel a perspective not only of the regional office as opposed to
headquarters, for example, but also a perspective — some may say
bias — of the planning aspects of the Clean Air Act.
          In San Francisco, I am personally responsible for
managing the state and local planning process that leads to the
development, adoption and implementation  of control strategies
in  the  state implementation plan to attain any national standards.
          Now, many of you may be from this end of the country,
but it  is always interesting to point out that Region IX, with

our office here in San Francisco, actually manages a rather vast
geographic area, including the mainland states of California,
Arizona and Nevada, and the Pacific Island states and territories
of Hawaii, Samoa, Guam, and the Marianas Trust Territory, of
limited diversity of activity, but of course a short-term NC>2
standard may or may not affect all of these particular areas.
          The current activities in our regional office are
almost entirely preempted at the moment with the review, evalua-
tion or approval of the '79 revisions of the State Implementation
Plan.  Many of you may be aware that the Clean Air Act of 1977
mandated there be a planning process for areas that were desig-
nated non-attainment, that plans to demonstrate such attainment
of the national standards were due to be submitted by the state
by January 1, 1979, reviewed and approved by EPA by July of 1979,
with a demonstration of attainment of the standards by no later
than December of 1982 and, for certain circumstances, an exten-
sion of up to five years, to 1987.
          In any case, that work load, as a priority matter, has
virtually occupied 150 percent of our time in the regional office,
and accordingly, we have watched the progress of Stan's group in
OAQPS headquarters with the development of standards almost with
one eye over our shoulder.
          Stan provided some statutory rules on health effects
information, as well as highlighting a few issues.  The purpose
of my remarks will be to bring a regional perspective to the
short-term NO2 standard, and to give you a generalized assessment
of potential problems in the region and a sense of the implemen-
tation scheme that we will operate under.
          First of all, just as a reference point, it may be
useful to consider the existing annual standard for NO2.  In
Region IX there are only two areas that are currently classified
as a non-attainment for nitrogen dioxide.  These are the Los
Angeles area  (sometimes known as the South Coast Air Basin), and
the San Diego area.
          For those particular areas, a revision to the state
implementation plan is now under way, and those who are from L.A.


will recognize that as the AQMP, Air Quality Management Plan,
which has been very much in the press and very much in the
public view.  The Air Quality Management Plan will attempt to
demonstrate attainment of the ambient standard of NC>2 by 1982,
which/ of course, is the statutory due date.
          Because of the nature of the problem, which in L.A.
is largely related to mobile source emissions, and certainly
stationary sources as well, attainment by 1982 is going to be
exceedingly difficult/ if not impossible.  Now, this may have
some ramifications for a short-term standard, and we will get
into that in a moment.
          Looking now at the potential short-term national
ambient air quality standard for nitrogen dioxide, assuming, of
course, that we do have one, and assuming that it sets a level
within the range that Stan gave/ we have gone back and reviewed
all of our data records, ambient monitoring data, for the 1976-77
period/ and assumming a midrange point of about .25 parts per
million for NO2/ it appears that the following areas may have
some problems:  Phoenix, Arizona; Los Angeles, continually;
San Diego; San Francisco; and San Jose, which is actually part of
the San Francisco metropolitan area/ but occupies the air basin
south of the Bay proper.
          The problems, of course, are potential, and based upon
a very cursory review of the ambient data/ it would be premature
to make any firm conclusions about the nature of the problem, but
I think that we can generalize to the point of saying that those
areas that are likely to have short-term NC>2 problems may be
characterized by, number one, large urban areas with a variety
of NOx sources and a large hydrocarbon emission rate.  This would
characterize most of the major metropolitan areas, at least in
this region.
          Another general characterization may be areas with
major NOx stationary sources, such as power plants, which also
have high ambient ozone concentrations.

          The many urban areas  in  Region  IX and, of course,
 elsewhere throughout the country have  high  levels of oxidants,
 or ozone, as we  now commonly  call  it,  based upon our new revised
 standard.  Many  of our areas  do have high or elevated  levels of
 ozone, which contribute to  the  NO2 problem  by the reaction
 kinetics and the chemistry  of the  situation.
          In Region IX, and especially in southern California,
 the problem, as  I indicated,  is predominantly mobile source
 related, although major power plants and  other stationary sources
 are contributing factors.
          The application of  reasonably available control tech-
 nology, which we call RACT, which  applies to existing  stationary
 sources, the application of pre-construction review and issuance
 of a permit for  new sources,  and the benefits which will ulti-
 mately be realized from the federal motor vehicle emission
1 control program, may all play a part in controlling emissions to
 attain the short-term standard. However, there are multiple
 uncertainties involved in that.
          To the extent that  mobile sources are involved, we can
 anticipate that  we are going  to need some long lead times which
 are necessary to phase in a fleet  of cars which meet emission
          We are also going to  need some  relatively long time
 frames to develop and implement transportation control measures,
 which may change the vehicle  use patterns,  and vehicle driver
          Now, of course, in  California —  and this only applies
 to California — we do have emission limitations more  stringent
 than the federal, significantly more stringent, and this will
 lead to an accelerated schedule of compliance.
          The problem of NC>2  attainment,  however, with all the
 uncertainties already given,  is further complicated, as Stan
 indicated and, I am sure, other speakers  will also elaborate on,
 is further complicated by the chemistry of  the situation.  NOx is
 a very important precursor  to ozone formation, but reducing NOx

as an independent control strategy may actually increase ozone
concentration, if the ratio of reactive hydrocarbons to NOx is
relatively low.
          Now, you will notice the generalities in that state-
ment.  I can't be more specific as to what the exact ratio is or
should be to prevent this unfortunate Catch-22 for control strat-
egies.  It is an area which warrants considerable further inves-
tigation, and will definitely be needed if and when we actually
move into an aggressive implementation plan within the short-
term NC>2 standard.
          The characterization of the problem is necessarily
general, primarily because of the press of other work, and the
schedule for developing the new standard.  We really haven't done
a thorough investigation of the real impact on the region.
          In any case, if and when we do select a standard, we
will go through the process of a formal proposal in the Federal
Register, solicitation of public comment, normally over a period
of 60 to 90 days, thereafter considering the public comments,
making the appropriate revisions, and ultimately, if necessary,
promulgating a new national ambient air quality standard.
          Now, once the new national ambient air quality standard
is promulgated, this triggers a whole series of events, which is
where I become involved, and that is, once the promulgation
occurs, the state, which has the principal responsibility for
developing the state implementation plan, now has nine months
to prepare a SIP revision which will demonstrate attainment and
maintenance of the new national ambient air quality standard.
Nine months is not a lot of time, of course.
          But to further complicate the issue, once the state
submits the revision of the state implementation plan, and EPA
approves it, then there is a period of three calendar years,
within which time we must demonstrate attainment with, the new
national standard.
          So the trigger point is promulgation of the standard.
We then move into an accelerated planning process, which will
result in a revision of the SIP, or state implementation plan,

 with then a  three-year period following to demonstrate attainment
 and maintenance.
           Now, the regional office is engaged in a whole variety
 of planning  activities which will support this effort, if and
 when the  national standard is actually promulgated.  We will
 be providing grant assistance to the state air pollution control
 agencies  and local air pollution control districts.  To give you
 a  sense of what we had already programmed for 1979 — and of
 course this  schedule demonstrates that most of this will now
 occur in  1980 — for Arizona we budgeted a nominal fee of $22,000
 for NOx control strategy development, emission inventory work.
 In California we budgeted almost $100,000, $60,000 of which is
 allocated to the South Coast Air Basin.  For Nevada we budgeted
 a minor sum of $8,000, and for Guam and Hawaii, $2,000 and $5,000
          Now, clearly,  this is not a lot of money, but we
 anticipated that it would provide seed funding for the beginnings
 of an NOx control program, which would ultimately, if everything
 happens on schedule,  result in a SIP revision for  the new stan-
 dard.  Clearly,  in 1980,  which is federal fiscal year 1980, we
will be programming more resources to help state and local
 governments deal with the new standard.
          In addition to that, assistance will also be provided
 for monitoring assistance, the siting of the monitors, the tech-
 nical requirements of the monitors, the reference methods, the
 site, location,  quality assurance and all of those associated
 activities.  At a minimum, we will try to locate two monitors in
 each of the areas, although in many cases we may need more to get
 an  accurate description of the ambient situation.
          We will also be developing, refining and, hopefully,
 applying our modeling expertise to assist state and local govern-
 ments to make that translation between emissions on the one hand
 and ambient  impacts on the other.  Of course, it is going to be
 exceedingly  complicated by the hydrocarbon-NOx ratio that we
 referred  to  earlier.

          Beyond that, there is a whole series of control
strategy developments, as I indicated:  new source review,
reasonably available control technology for existing sources,
tail pipe emission controls, transportation control measures,
a whole variety and mix of strategies which, hopefully, will
result in attainment, and then finally culminating in the process
of submitting of the SIP to EPA.
          That is the generalized framework, and without being
more specific, it is then perhaps most appropriately summarized
by the following time sequence.  The standards being formulated
in Stan Coerr's group will eventually be proposed, go through a
series of public comments, be promulgated.  That in turn will
trigger a process on the state and local levels of revising the
SIP, developing control strategies and, hopefully, three years
later will result in attainment of standards.
          Clearly, for the short-term standard, we are in for a
long-term process.
          Thank you.
          MR. FRANK DiGENOVA:  First of all, I appreciate the
opportunity to be here today.  I am here on behalf  of the staff
of the Air Resources Board, and I would like to try to describe
to you —  Well, the topic of my paper is the California standard
compared to the federal standard, and I would particularly like
to talk about the L.A. Basin experience, what it has been and
what it appears the future is going to be,  firstly because that
is where the problem appears to be the most severe and secondly
because that is the area I am most knowledgeable about.
          The areas that I plan to discuss  include a review of
the national and California standard  and comparing L.A. air
quality with those standards; an examination of the source of
NOx emission in L.A.; and  some consideration of what the Air
Resources Board views as being allowable NOx emission.  Finally,
I will try and describe the control strategy approach  that the
Air Resources Board  is taking, and has taken.

          To begin with, air quality standards/ the national
primary and secondary ambient air quality standards for NC>2 are
the same, an annual arithmetic mean of 100 micrograms per cubic
meter, .05 parts per million, which is not to be exceeded in any
          The California standard is a maximum one-hour standard
of .25 parts per million, which is 470 micrograms per cubic meter,
not to be equalled or exceeded.  I would point out that it is
unlike the federal ambient air quality maximum hour standards,
which may be exceeded once per year.
          The California NC>2 standard was adopted by the Air
Resources Board in 1969, along with ambient air quality standards
for oxidants, carbon monoxide, SC>2, H2S, visibility-reducing
particles and total suspended particulates in the Bay Area and
the South Coast Area.
          You have heard considerable discussion in the past
couple of days about the cost and problems of controlling NOx
emissions, and I think  it is appropriate, in the case of Los
Angeles, to talk a little bit about what the air quality there is
and has been.
          The national  and California ambient air quality stan-
dards for NC>2 have been exceeded at many sites, and by wide
margins, in recent years.  For example, in 1977, 12 of the 15
monitoring stations in the basin violated the national standard,
with annual averages of NO2 ranging from about  .06 to .09 parts
per million, which is almost double the standard.
          Also in 1977 the same 12 stations, plus a thirteenth,
violated the California standard, with maximum one-hour concen-
trations ranging from .27 parts per million to  .6 parts per
million in downtown Los Angeles, more than twice the standard.
          Also, these violations of the California standard have
been quite frequent at  some sites.  For example, in 1977 the
downtown Los Angeles site, over a period of 11 months, exceeded
the California standard on 1973 hours over a period of 54 days,
on the average about every sixth day.

          I am really interested in talking about NOx as a
precursor to N02, but I do want to say something about the NOx
contribution to nitrates in passing, and also oxidants.  In case
you are not aware, and those of you who are not from California
may not be, the total suspended particulate matter federal and
state standards are also violated by a wide margin in the South
Coast Air Basin.  For example, in 1977 the highest site,
Riverside, measured 508 micrograms per cubic meter on a 24-hour
basis, and the highest annual site, 146 micrograms per cubic meter
as an annual geometric mean measured in Chino.  That is more than
twice the primary standard.
          With respect to oxidants, I would like to comment that
the Air Resources Board has received some modeling studies which
suggest that NOx reduction will result in widespread ozone
increase.  It is our opinion that the data we have received to
date is inconclusive/ because large hydrocarbon reductions which,
in effect, would accompany the NOx reductions were not taken into
          I would like to review a little bit what the sources
of NOx emissions are in the South Coast Air Basin.  First of all,
there are no significant natural sources.  We are primarily
talking about anthropogenic, mostly combustion-related, sources,
and the total emission rate appears to be about 1,300 tons per
day in 1975.  You might want to keep that number of 1,300 in mind.
          About two thirds of that for 1975 was mobile sources.
The remaining third was stationary sources, and power plants
represented about 13 percent of the total, with other stationary
sources representing about 20 percent of the total.
          Because of the projected increases in NOx emissions by
1985, the Air Resources Board in July, 1977 adopted the light-
duty motor vehicle standard of .4 grams per mile that you have
already heard about for 1982 and later model year vehicles.
          With the effect of this motor vehicle standard we
expect the contribution for mobile sources to decline from about
870 tons per day in 1975 to about 690 tons per day in 1985.
However, this reduction would be largely offset by the increase

in stationary source emission growth, from about 420 tons per
day in 1975, about 33 percent of the total, to 540 tons per day
in 1985, about 44 percent of the total.
          Recognition of th'is fact led the staff to the conclu-
sion that further stationary source reductions are necessary,
particularly for power plants, which are projected to increase
thier emissions from 160 tons per day, again 13 percent of the
total in 1975, to 230 tons per day,19 percent of the total, in
          Just how much reduction is needed?  The issue of NOx
control and oxidant control was addressed in a special ARE con-
ference and staff report in January of 1977, one of the conclu-
sions being that there was a need for stringent further mobile
and stationary source control.
          In that conference, the monitoring station at Pasadena
was identified as a site having a representative mix of mobile
and stationary source control, a representative mix of contribu-
tions from mobile and stationary sources, and therefore the staff
has used Pasadena as the site to design a control strategy, even
though  this is not the site that has the worst NC>2 air problem.
Far from it.
          Using a modified rollback that applies credit for
expected hydrocarbon reduction, the staff has estimated that the
corresponding allowable emissions for the state standard would
be 770  tons per day.
          There are two points to recall.  First, we did not use
the highest hour as, strictly speaking, the standards would
require, but used the second highest hour.  Secondly, we did not
consider the worst site.  We used Pasadena.  The worst site
would result in a much lower allowable level.
          The overall reduction that would be required in either
case is about a 40 percent reduction or, for stationary sources,
about 85 percent reduction.  In the case of the Los Angeles Basin,
it appears to us that the difference is academic since, as has
already been noted, we have some pessimism about our ability to
achieve either level in the short term.  Therefore, it is our goal


to achieve the maximum emission reduction that we can, which
brings us to the point of what has been done and what we foresee.
          All the significant NOx sources are considered as
candidates for control.  We note that substantial NOx reductions
have already been achieved by power plants in the L.A. Basin.
Primarily through combustion modifications, reductions on the
order of roughly 10 to 70 percent have been achieved at some of
the larger power plants.  Other smaller power plants have not
reached those levels thus far.
          If I can go back to the January, '77 conference
recommending more stringent mobile and stationary source control,
I would recall to you that in the summer of 1977 the Air Resources
Board adopted a .4 grams-per-mile limit for 1982 and later model
year vehicles.
          More recently, about a year ago, the South Coast Air
Quality Management District adopted stringent rules for existing
and new power plants, requiring 90 percent control of existing
units by 1985, and also stringent controls for new units.  The
ARB staff concurred with the South Coast Air Quality Management
District on the need for this kind of control, and the feasibility
of it.
          Shortly after adoption of that standard the Air
Resources Board was petitioned by two utilities in the South Coast
Air Basin to review the district's rule, and the ARB modified
that rule to provide a couple additions, and I will just touch on
that briefly.
          First of all is the sytem concept.  The ARB adopted
the approach of systemwide control, something akin to what you
may have heard EPA talk about as the bubble concept, except in
our case we view the bubble as an electric utility system.
          Secondly, the ARB approach requires the use of least
NOx dispatch, that is, loading the system  in such a way that
low NOx-emitting units come on line first  and remain on the
longest, and the very dirty NOx units do not come on unless the
load reaches the very maximum.

          In addition, the ARE modified the rule to provide for
two stages of control.  The first is essentially 50 percent
reduction required by 1982, and part of that would be demon-
strating technology to reduce emissions by 90 percent by 1982.
          The second stage is 90 percent control by 1990.
          I might add that the demonstration of technology for
100-megowatt equivalent units was for the purpose of identifying
precisely what reductions could be achieved, precisely what the
problems would be, to identify if there were any problems that
we weren't aware of, and primarily to get a good handle on how
controls would operate prior to requiring widescale implementation
of that technology.
          Both the staff and the Air Resources Board do concur
with the observation made by David Mobley of EPA and with the
observation of the South Coast Air Quality Management District
that selective catalytic reduction has been demonstrated to be
feasible and commercially available for gas and oil fired power
plants.  Electric utilities in the South Coast Air Basin, and
there are five of them, have now begun plans to comply with the
first stage of emission reduction, using thermal DeNOx, selective
catalytic reduction, and other combustion modification techniques.
          Other stationary sources that are also being considered
for further NOx control include, among other sources, boilers
and heaters, including CO boilers, stationary engines, glass
plants, residential heaters, to name a few.
          To summarize, then, both state and federal NO2 stan-
dards are exceeded by wide margins, and frequently, in the L.A.
Basin, and without further controls of NOx we expect the situa-
tion to worsen.  Both stringent mobile and stationary source
controls will be needed to approach either the national or the
state NO2 standards.
          The South Coast Air Quality Management District and
the Air Resources Board have adopted,  and continue to consider,
further NOx controls to promote meeting the national*and state
          Thank you.

          MR. COERR:  Vince Mirabella.
          MR. VINCENT A. MIRABELLA:  Unfortunately, I am in the
position of having to go over a lot of the material that has
already been presented, so please bear with me.
          The Clean Air Act Amendments of 1977 represent a
reaffirmation of Congress1 mandate to accomplish the nation's
air quality goals according to a legislated time schedule.
          Of the many provisions contained within the Amendments,
the key ones deal with non-attainment, PSD, review of ambient
air quality standards and new source performance standards,
regulation of hazardous substances, and establishment of a
short-term N02 standard.
          The impact of these provisions on the utility industry
will be felt in various ways, as shown on the first slide.*
          The impacts would be associated with requirements
dealing with emission controls, such as best available control
technology; RACT, which is reasonably available control tech-
nology; LAER, lowest achievable emission rate; and BART, which
is defined as best available retrofit technology.
          Other impacts will deal with siting constraints, such
as proximity to PSD areas, and also facility design constraints,
such as stack height limitations and fuel types.  Also, there
are dollar and energy costs resulting from the above impacts.
          The processes by which these requirements will impact
the industry are indeed complex, as the components of many of
the requirements are interrelated and reinforcing.  It is my
intent today to briefly outline the nature of these processes as
I see them.  For this purpose I will make references to the
present regulatory situation here in California since, as was
previously mentioned, the State currently has a one-hour NO2
          Examination of the California situation provides a
ready-made example of possible future directions of regulatory
processes across the country, brought about by this short-term
*  A copy of Mr. Mirabella's slide presentation follows the
   Panel Discussion.

          As you previously heard, EPA is presently reviewing the
annual NO£ standard, and is preparing to promulgate a short-term
N02 standard, and I have indicated in slide 2 what the ranges of
possible values are.  In terms of the short-term, the one-hour
value that has been most frequently mentioned has been in the
range of .1 to .50 ppra.  Again, the State of California has a
.25 ppra one-hour standard.
          As far as the annual standard is concerned, the most
probable value will be about 100 micrograms per cubic meter.  I
have also considered 80 micrograms per cubic meter as a "what if"
kind of situation, to illustrate what the impacts could be should
welfare effects dictate a lower annual secondary standard.
          To set the problem in perspective for the discussion
that follows, we will discuss first the indicated sources of
NOx emissions.  Now, as shown in slide 3, I have a nationwide
inventory and the South Coast Air Basin inventory.
          On a national basis, mobile sources comprise approxi-
mately 44 percent, power plants 29 percent, with other various
sources the remainder.  Compare this with the South Coast Air
Basin.  I guess my numbers differ a little bit from what Frank's
numbers are, but mobile sources are roughly about two thirds,
with power plants somewhere around nine or ten percent, and other
stationary sources the balance.
          With this in mind, it is instructive to next examine
the current attainment status of each air quality control region
across the country as shown in slide 4.  Now, what this map
depicts are all the air quality control regions, and the annual
average NC>2 compliance status as of 1975-1976 data.
          Of the initial non-attainment designations by EPA,
such areas were located in California and Chicago.  Based upon
the 1975-76 data, eight air quality control regions may exceed
the annual 100-microgram-per-cubic-meter number, and 25 may exceed
the 80-microgram-per-cubic-meter number.  As you can also see,
there are a number AQCR's which do not have sufficient informa-
tion from which a determination can be made.

          Shown in slide 5 is the attainment status of two one-
hour N02 standards, the .25 and the .5 ppm levels.  Seventy-seven
AQCR's I have, been able to find out had continuous, adequate data
from which an assessment can be made of compliance.
          For the .25 ppm case, 28 of these AQCR's, or 36 percent,
have levels in excess of .25 ppm.  For the half-a-part-per-
million case, nine AQCR's, or 12 percent of the total, have
levels in excess of .5 ppm.
          Now, not shown here is an assessment for the .1 ppm
case, and that shows that 57, or 74 percent of the AQCR's had
levels in excess of .1 ppm for one or more hours.
          The majority of the non-attainment areas, for the most
part, are located in the metropolitan urban areas.  I would also
add from this slide that there are a significant number of AQCR's
which do not have adequate continuous monitoring data from which
the compliance can be determined, so there is a possibility of
additional AQCR's which could be non-attainment.
          Now, for those areas identified in these slides as
non-attainment, existing megawatt capacity located in such areas
is shown here in slide 6.  The limiting standard apparently is
the .25 ppm number, and that shows that over 100,000 megawatts of
existing generating capacity are located in potential non-
attainment areas.  This comprises approximately 30 percent of
the total fossil-fuel capacity of the country.
          I might also add at this point that a review of planned
generating capacity during the period of 1978 to 1989, as shown
in slide 7, indicates that up to 38 percent, or 64,000 megawatts
of a total of 170,000, could be located in the potential non-
attainment areas.
          Now, the significance of this review of non-attainment
areas lies in the specification of emission control requirements
for new and existing stationary sources located in such areas.
          This is kind of a busy slide (slide 8), but the degree
of control will be dependent upon whether the source is new or
existing.  In terms of existing sources, the requirement is for
reasonably available control technology, which is defined as

that control required of existing sources to roll back to
national levels, national ambient air quality standards.
          For new sources located in non-attainment areas, LAER,
lowest achievable "emission rate, is required.  This is the lowest
achievable emission rate nationally, either in SIP or in practice,
and the significance of this point I will clean up a little later.
          BART stands for best available retrofit technology,
and is required for existing sources less than 15 years old,
primarily for visibility protection.
          BART, although it is not required for sources in non-
attaining areas, can ultimately be affected by LAER, and vice
versa.  These are the so-called reinforcing parts of the Clean
Air Act Amendments.
          Slide 9 depicted here describes the NOx emission control
technology as applied to utility boilers and they consist pri-
marily, at this time, of combustion modifications, such things
as low excess air, flue gas recirculation, water or steam injec-
tion, and so forth.  They are widely considered reasonably avail-
able, and have been demonstrated, at least in the Edison system,
to produce emission control reductions on the order of 10 to 50-
plus percent.
          The costs as shown here are costs for the Edison system
only, and are based on somewhere between $100 and $1,000 a ton,
depending on such things as individual unit size, capacity factors,
what the starting level of the reduction was.
          The second class of control technology deals with flue
gas treatment,  and two are identified here, ammonia injection and
selective catalytic reduction.  I might add that the ammonia
injection is identified in the California SIP as a RACT measure.
          I show here that cost can vary anywhere between $2,000
and $4,000 per ton removed for the injection system, and for the
catalytic system it is anywhere from $4,500 to $9,000 plus, per
          The significance of this is that by defining RACT with
ammonia injection, that pretty much sets the stage for all other

non-attainment areas to classify this as reasonably available
control technology along with the selective catalytic treatment.
          As to the nature of these RACT measures, I would like
to very briefly touch on their basis.  The next slide (slide 10)
provides provisions of so-called Rule 475.1, which Frank alluded
to earlier.  This was adopted, final adoption, in January, 1979,
and it is a two-stage implementation plan, whereby 50 percent
NOx control is required on a systemwide average of all the units
in the South Coast area.  These are retrofit plans, and as you
can see, require a 50 percent systemwide average, which means
certain units will have to operate at higher control, and others
lower.  It also applies throughout the entire load "range as well.
          Compliance demonstration is scheduled for December 31,
1982, with construction probably to begin sometime this year.
It also requires the installation of a demonstration unit,
capable of demonstrating 90 percent control also by 1982.
          Now, providing the demonstration project proves out,
then all of the existing capacity of the South Coast Air Basin
would have to be retrofitted, and this control efficiency of
90 percent in effect represents selective catalytic reduction.
          Slide 11 provides a comparison of NOx emission stan-
dards for utility purposes/ indicating the present new source
performance standards for coal and oil, the proposed new source
performance standards, and what standards there are presently in
the South Coast Air Basin.
          As you can see, the existing units must comply with
.3 Ibs. per million BTU.  After 1981 they have to comply with
.15, and after 1989, .03 Ibs. per million BTU is used.
          Now, suffice it to say our company has objected
strenuously to the promulgation of such emission standards,
because of the lack of a technical basis.  No full-scale utility
boiler in the range of 200 to 750 megawatts has ever been retro-
fitted with the ammonia injection process that achieved 50 percent
average NOx removal efficiency, and no retrofitted oil- or coal-
fired utility boiler has ever achieved 90 percent removal effi-
ciency with the catalytic process.

          Both processes are within the realm of theoretical or
experimental technology which is neither available now nor in
practice anywhere in the country or, for the most part, in the
          Furthermore, the compatability of the two systems,
which must be installed in tandem in order to demonstrate the
final control, has not even been experimentally verified.
          Now, as to cost for this Rule 475 implementation, we
estimate that, in 1978 dollars, the annualized cost for the
ammonia injection system for our 6,000-megawatt in-basin system
will be $92,000,000 to remove 50 tons per day, on that order.
That represents capital of $160,000,000, outage cost of
$25,000,000 in order to install the equipment, and annual opera-
tion and maintenance costs of $49,000,000.
          For the catalytic retrofit system, we estimate the
cost of capital at $1.2 billion, outage cost of $100,000,000,
and annual operation and maintenance costs of $275,000,000.  And
that is in 1978 dollars.  Of course, the cost will be considerably
higher in the future.
          Now, in view of these considerations, it is of interest
at this point to examine relative effectiveness of reducing NOx
emissions from various sources in achieving a national ambient
air quality standard for NO2-
          To accomplish this task, a methodology was developed to
estimate concentration and emission factors for various source
categories.  This next slide (slide 12) shows the basis for these
concentrations of emission factors.
          The methodology makes use of the fact that each emission
source category has a unique sulfur dioxide-carbon monoxide
emission ratio.   With this method, SO2 can be used as a tracer
for stationary-source impacts on NO2, and CO as a tracer for
mobile-source impacts on NO2.
          As you can see, mobile sources have their ratio some-
where around .01, whereas stationary sources are in the range of
one to 50.

          Now, provided NO2, CO, and SO2 can be monitored con-
currently, and also provided the relative strengths of the
sources affecting a monitoring station are known, the relative
abundance of CO and SO2 should provide a clue as to the types of
sources affecting that station.
          By the use of this concept, the contributions of
various NOx emission sources to the ambient NO2 level at downtown
Los Angeles, which typically has the highest N02 short-term
levels, are indicated in slide 13.  This is considering all days
during the period 1974 to 1976.
          As you can see, power plants contributed only three
percent to the N02 air quality at downtown Los Angeles, whereas
mobile sources contributed 57 percent, and the balance by other
area sources.
          A similar analysis was completed for other locations in
the South Coast Air Basin.  The results were essentially the
same.  Mobile sources continued to be the dominant source of the
N02 problem in the South Coast Air Basin.
          Now, taking these emission source factors, we computed
the contribution of various sources to the NO2 annual average and
the average one-hour NO2 on days of highest NO2, as shown in
slide 14.  Taking the annual, for instance, Los Angeles showed a
141-microgram-per-cubic-meter highest annual average between the
years of 1974 and '77.
          The NO2 source contributions indicate that 80 micro-
grams were being contributed by mobile sources, four micrograms
by power plants, and 57 micrograms by other area sources.  We
have also looked at figures with respect to both mobile and sta-
tionary sources in other areas of the SCAB, with the results you
see there.
          The same kind of thing shows up when you look at
source contribution for N02 in other areas of the country.
Mobile sources clearly dominate the NO2 background.
          What this boils down to is that maximum controls on
power plants will not significantly influence the N02 levels.
Yet, costly controls on power plants are mandated requirements.

          Finally, this next figure, slide 15, deals with the
effects of NOx controls in urban areas on attainment of the
ozone standard.  Now, this next slide provides the South Coast
Air Quality Management Plan analysis of the actual hydrocarbons
and NOx controls necessary to meet the federal ozone standard.
It may be kind of difficult to see, but the bottom line of this
is that, if you do not control NOx emissions from their levels
of 1974, just control hydrocarbons according to their current
control strategies, you would achieve the standards with much
greater ease than you would with a combination of hydrocarbon and
NOx controls.
          Now, this is a rather simplified analysis, this ozone
isopleth technique.  We have also conducted extensive model
studies which Frank alluded to earlier, which indicate to us that
there will be substantial increases in ozone levels down wind of
the power plants when such power plants are controlled of NOx
emissions.  The effects of NOx control on ozone must be taken
into account when developing integrated NO2 and ozone control
          My last area of discussion will focus on PSD require-
ments.  As indicated in the Clean Air Act Amendments, these areas
meeting air quality standards are designated as attainment and
subject to PSD requirements.
          It is impossible to presently give PSD increments for
NO2-  In fact, formulation of PSD is not firm by any means,
although for the sake of discussion I have looked at it, follow-
ing the House of Representatives technique for estimating PSD
increments for the various standards.
          These levels are exceptionally low, as you might be
able to see from slide 16.  Class 1 was defined as two percent
of the standard. Class 2 as 25 percent, and Class 3 as 50 percent.
In these areas, BACT will be required, which may possibly require
controls up to 50 to 90 percent.
          Looking at proposed power plants in the attainemnt
areas, we have been able to locate 51 new plants in identifiable
attainment areas for both the annual and one-hour standards.

Projecting NOx emissions to 1989 in each attainment area where
new plants were located, it was determined that 14 of the desig-
nated 51 plants, or nearly 50 percent of the megawatt capacity,
may require NOx control in excess of the proposed new source
performance standard in order to meet Class 2 increments.
          The next two slides (slides 17 and 18)  show the loca-
tion of power plants, planned power plants, in relation to PSD
Class 1 areas.  The red dots indicate the location of the power
plants.  The yellow indicates discretionary Class 1 areas, which
are presently Class 2, but could be Class 1 in the future.  And
the green areas are shown as mandatory Class 1 areas at the time
of the Clean Air Act Amendments.
          Of the total number of planned plants,  188 have loca-
tion information.  Of these, 27 plants, or 26,000 megawatts, are
located within 50 kilometers of a Class 1 area or potential
Class 1 area, and therefore could be influenced by the PSD
          In conclusion, I would like to show the following
figures (slide 19).  The promulgation of the proposed N02 stan-
dards, on an annual and short-term basis, could have a substantial
impact on the utility industry, because of the nature of the
control requirements for new and existing power plants.
          Over 100,000 megawatts of existing power plants, or
30 percent of existing fossil fuel power capacity, are located
in 29 potential non-attainment areas.  Reasonably available
control technology is required of existing sources located in
non-attainment areas.
          Using the California SIP as an example, RACT may
require up to 50 to 90 percent reduction of existing utility
emissions.  Retrofit of this control can be extremely expensive,
amounting to billions of dollars.
          Moreover, in some non-attainment areas, this control
is unlikely to substantially affect ambient NO2 levels.
          The California RACT measures will ultimately affect
the basis for LAER and BART requirements.  Up to 38 percent of
the planned capacity will be located in potential non-attainment

areas and subject to LAER requirements.
          Control of NOx emissions and meeting the NO2 standards
must be judged in light of potential urban ozone levels.  Now,
unless emission offsets are required in PSD areas, about one-half
of all the plants could require emission controls more stringent
than the proposed NSPS.
          Finally, NOx may replace SC>2 as a pollutant controlling
facility and site suitability, and that is the bottom line.
          Thank you.
          MR. COERR:  Thank you, Vince.
          I would like to take some questions from the floor, but
before that, we will see if the panel members have any clarifica-
tions they want to make before we get into that.
          MR. DiGENOVA:  I have one point I would like to
          I tried to describe a little bit in my presentation
the 475.1 systemwide concept, and I think it would be helpful if
I went back for a moment and gave you a little bit of the history,
just to clarify one point.
          Last summer, when the Air Resources Board first pub-
lished a modification to the South Coast Air Quality Management
District rule, we considered a one-stage rule that required 90
percent control.
          In response to substantial testimony that we got from
control equipment manufacturers and from the utilities themselves,
that rule was modified to a two-stage rule, but again, the con-
cept of systemwide control was retained.
          The effect of systemwide control was that base-loaded
units, for example larger units with longer remaining lifetime,
can utilize a greater degree of control, and older units that
have a shorter remaining lifetime, percentage-wise, that is, can
utilize a lesser degree of control.
          The amount of control required is equivalent, for
stage one, to all existing units getting 50 percent.  I think
there were some comments made by Vince, that all units will be

required to have 90 percent control for stage two, and that is
not correct.
          (A-question and answer period followed, which was not


  Vincent A. Mirabella
Southern California Edison

                          SLIDE 1





                             SLIDE 2

                           UG/M5 (PPM)               UG/M^ (PPM)

  ANNUAL                     80 - 100                    100*

                         (0-04) - (0-05)               (0-05)

  I-HOUR                    188 - 940                    470

                          (0.1) - (0.50)               (0.25)



 s  10H

 2   5'







                                                                    AQCR with no or Inadequate data.

                                                                    AQCR with maximum annual average
                                                                     less than 80
                                                                    AQCR with maximum annual average
                                                                     between 80 and 100

                                                              •	 I  • AQCR with no or Inadequate data.
                                                                   • AQCR with annual second
                                                                     concentration lets than 470
                                                                          1th annual second
                                                                     concentration between
                                                                          Hh annual second
                                                                     concentration larger

                                                                   $ 105,900
470 UG/M-
910 UG/M

££  15
                            SLIDE 8

                             NEW OR
RACT  (LOCAL)                                            X

LAER  (NATIONAL)                X

BART  (LOCAL/FEDERAL)                                   X

   BY DECEMBER 31, 1982.



                            SLIDE  9



                           SLIDE ID

              PROVISIONS  OF THE  SCAQMD  RULE 475-1
              FINAL  ADOPTION:   JANUARY  22,  1979
                                             A)   APRIL  1,  1979
                                             B)   JULY 1, 1979
                                             c)   DECEMBER  31, 1982


              A)   COMPLIANCE DEMONSTRATION    A)   JANUARY  1,  1982

                                              A)  JULY 1,  1983
                                              B)  JANUARY  1,  1990

                      SLIDE 11

                  UTILITY BOILERS
                   (LB/105 BTU)
                              COAL           OIL

PRESENT  NSPS                  0,7           0,3

PROPOSED NSPS               0,5, 0,6         0,3
   EXISTING UNITS              0,3           0,3
    UNITS (AFTER 1981)         0,15          0,15
    UNITS (AFTER 1989)         0,03          0,03


                                 Stationary Sources/ //////
                                 /  / /  ,  ,  ////////.
    .05 -
          //// //// * * ' * '  ' *  '
         Jiff I / n / Industrial Processes   A
                             >:• Mobile Sources
                                      Vehicles  jj^^^^^gj^
                Ranges of Typical  (S0?/C0) Emission Ratios in Various
                Source Categories.

                                 SLIDE  12





                      AIR OUALITY
                    AIR OUALITY

                 AMBIENT N02 LEVELS AT DOWNTOWN  LOS ANGELES ON ALL DAYS   (1971-1976)

                 HIGHEST ANNUAL          N02 SOURCE           AVERAGE 1-HR. N02              N02 SOURCE
        SITE    1974-1977 (UG/M^)      MOBILE  P»P   OTHER      N02* 1974-1977 (UG/M!)      MOBILE  P.P   OTHER
126     7      55
        WHITTIER      135
100     15     20
176    18      31

                                                    SLIDE 15
                                    OZONE  ISOPLETH SET FOR JUNE  27,  1974
           STATE NO2
                                                                           NO NOX  CONTROLS

                                                                           FROM 197^1 LEVELS
                                                                   1974 :  0.51 ppm
                 0.25     0.90
1.00     1.25     1.50
          » r r N*»
1.75     2.00



                               SLIDE 1G

                      POSSIBLE PSD INCREMENTS FOR N02
                                       ALLOWABLE INCREMENTS
ANNUAL         80 UG/n3           2              20             40

                                 2              25             50
HOUR        470 UG/M^          10             117             235
              940 UG/M3          20             235             470

                                                                                             1 Handatory Clan I PSO treat

                                                                                           • DUcrptlonary Clatt I PSO areas

                                                                                            •  Planned Fossil Furl-Fired Power
                                                                                     Puerto Rico,
                                                                                     Virgin Islands
                                                                                                                    200 wiles

                       SLIDE 13

                  DISTANCES BETWEEN
                   PSD CLASS I AREAS
                         MANDATORY AND DISCRETIONARY
                                CLASS I AREAS

  DISTANCE                        CAPACITY
    (KM)                          MW     CUM %

     10                         6,000      5.8

     30                        15,500     15,0

     50                        26,300     25,2

     70                        37,300     36,1

                         SLIDE 19








             A RESEARCH PLAN TO
               STUDY EMISSIONS
                 FROM SMALL
   James W. Murrell  and Frankie Alexander
Systems Research and Development Corporation
        10 Park Plaza (P.O.  Box 12221)
     Research Triangle Park, NC   27709


This paper examines some of the requirements for investigating
environmental status of small internal combustion engines.  These
engines range in size form 1% hp to 15 hp and power a variety
of equipment by home owners and Industrial members.

With the general growing concern in EPA of identifying sources
of potentially carcinogenic emissions, there exists a possibility
that these small internal combustion engines are a problem source.
Research to characterize emissions from the source has largely
been limited to critical pollutants, even though the small internal
combustion Is an iincomplete combustion; therefore, some carcinogens
and other hazardous compounds are probable.

The basic requirements addressed for an Integrated research design
         a)  analytical equipment
         b)  experimental systems design
         c)  statistical experimental design.

Work on this paper was performed with the support from EPA
Contract No. 68-02-3113 under the direction of Mr. Jack Wasser,
Project Officer.

Over the past decade, population and energy consumption by way
of the internal combustion engine have increased dramatically.
Concomitant with these increases has been a dramatic increase
in the nation's air pollution problem.  An elevated awareness
of the hazardous aspects of emissions from these engines has
been developed.  Most of the research and the ensuing legis-
lation has been aimed at the gasoline powered automobile, and
rightfully so.  Recently, diesel engines have been given greater
attention because of their ever increasing numbers.  However,
relatively little attention has been focused on the small
internal  combustion engines in spite of their wide spread usage.
Here "small" is defined as 15 horsepower or less and includes
engines used to power equipment such as garden tractors, motor
tillers,  lawn mowers, chain saws and other recreational, indust-
rial and agricultural equipment.  General growing concern to
identify sources of sources of potentially carcinogenic emissions,
has caused the EPA to explore the possibility internal
combustion engines are a problem source.   These engines are
incomplete combustors, therefore there is a high probability that
carcinogens and hazardous compounds are emitted.

Among  the more prominent emissions
     -carbon monoxide
     -oxides of nitrogen
Some detrimental health effects of these compounds are  well known.
Unburned  hydrocarbons have an objectionable odor, contribute to
photochemical  smog and are possibly carcinogenic.  Hydrocarbons
may also  show up as particulate matter.  Studies have shown that
high molecular weight hydrocarbons have been carcinogenic in

The toxicity of carbon monoxide has been well documented.   It
occurs because blood hemoglobin has a higher affinity for  carbon
monoxide than for oxygen.  After approximately one hour of
exposure to carbon monoxide at 600 ppm, humans go into coma.
Death usually occurs after one hour of exposure at 800 ppm.
There is epidemiological data suggesting increased incidence  of
mortality from myocardial infarction after continual  average
weekly exposure to carbon monoxide concentrations of 8 to  14  ppm.

Oxides of nitrogen have a tendency to combine with lung moisture
to form dilute nitric acid.  This may cause respiratory problems
over extended periods of time.  Oxides of nitrogen are also known
to settle on blood hemoglobin.

Partlculates come from  lead additives, hydrocarbons and sulfur
dioxide. For the most part, their effects on health are related
to injuries to the surface of the respiratory system.  However,
particulate materials in the respiratory tract may produce internal
injury.  Eye-injury  is  another possible detrimental effect.

The purpose of designing a comprehensive research plan is  to  allow
emissions form these small internal combustion engines to  be
characterized.  This characterization would account for the inter-
active  impact of several factors on determining the acceptability
of projected ambient concentrations of various emission compounds.
As was  stated earlier,  the primary compounds are:  hydrocarbons,
carbon monoxide, oxides of nitrogen, and particulates.  The
central factors which may cause significant variations in  emissions
           -age of engine
           -carburetor  setting
           -revolutions per minute
           -mode (or load).

The design of a comprehensive research plan involves the  com-
pletion of four tasks:
       1.   An information search and assessment
       2.   An analytical equipment design
       3.   An experimental system design
       4.   A statistical experimental design.

I  shall briefly touch upon each of these tasks.

TASK 1:  Information Search and Assessment
The first  objective of this task is to provide information needed
to complete an environmental assessment arid impact evaluation.
This requires mass emissions data based on an  assumed operating
cycle.   A  knowledge of the current distribution of these  engines
by size and other characteristics is necessary for extending
available  data to the entire population of these engines.   An
estimation of national impact will depend on:
       -emission rates
       -engine population, and
       -average annual usage.
Each of these variables presents its own special measurement
problem.   Average annual usage presents a bias problem since
the use of this variable masks the effects of  its inherent
variability.  This problem is relatively dramatic in exposure
computation since the individual who is periodically expose-d to
emissions  from his three horsepower lawnmower  is given the same
weight  as  the individual who operates a chain  saw, which  has an
identical  engine, on a daily basis for extended periods of time.

In spite of these obvious kinds of problems, developing a literary
information base will yield the best proxies.

This part  of the currently ongoing project has been completed.
The information has been abstracted and placed into these categories:
technical, commercial, and health effects.

From a technical standpoint, It was possible to abstract a good
deal of Information from studies on large engines and their
emissions.  Though these are non-stationary sources with vastly
different operating cycles, much of their technology coincides
with the technology of small 1C engines.

The most comprehensive study we found that dealt directly with
emissions from small 1C engines was made during 1973, by the
Southwest Research Institute.  Researchers there conducted a
series of experiments on "Exhaust Emissions from Uncontrolled
Vehicles and Related Equipment Using Internal Combustion Engines".
Part Four of the series concentrated on small, air-cooled, spark
ignition, utility engines.  The exhaust products measured Included
total hydrocarbons, CO, C02» NO and 0~.  An appendix to the report
Included raw emissions data based on several factors.  To my
knowledge, this data has not been subjected to a statistical
analysis.  Such analysis could assess the Impact of the numerous
control factors (I.e., node, speed, power, temperature) on the
level of emissions.  This assessment could reduce the complexity
of future statistical experiments.  A part of the summary from
the small 1C engine section of the final report stated:
       "If it Is decided that small engine emissions may
       become significant in the national picture, it seems
       obvious that further research would be required to
       establish a more reliable baseline.  It would be necess-
       ary to first test additional engines of various sizes
       and types, preferably a statistical sampling of in-services
       units or long-term tests on new units.  Other very weak
       points in the current status of information are number
       of engines In use, operating patterns, and annual usage."
The commercial  abstracting consisted of reviewing small engine
and engine driven equipment catalogs in addition to Interviewing
local  dealers (who probably are not representative) and requesting
information from various manufacturers of small  engines.  We had
hoped that this information would allow estimations of numbers,
distribution and usage patterns.   Additional  useful information

could be directly derived from engine specifications.   Such
information would include:
        -cy.de or stroke (two or four)
        -carburetor specifications
        -tank design
        -tank size.

Tank size may seem insignificant as a variable at first glance;
however, directly related to frequency of refueling are emissions
by spillage and evaporation which may be significant.

Needless to say, much of this information is lacking both in
terms of quantity and quality.  A more precise estimate of
numbers, distribution, and usage patterns could be obtained
from a carefully designed sample survey.

There exists a literary void relating to the health effects  of
emissions from small 1C  engines.  We may, or course,  extrapolate
our knowledge of known compounds and their impact on health  to
the quantity and distribution of these compounds attributable
to small 1C engines.

TASK 2:  Analytical Equipment Sampling
The area of Analytical Equipment is one of rapidly developing
technology.  It is important to know what equipment is available
with which characteristics and at what cost.  Thus, this phase
involved a compilation of the kinds of equipment available for
sampling and an analysis of the proposed compounds.  For current
purposes, I shall describe the elements of a taxonomy  of desirable
information characteristics.

Taxonomic Dimension

Maximum Temperature Input
Collection Efficiency

Log Time
Retention Time
Fall Time
Zero Drift
Span Drift
Ambient Temperature Range
Temperature Compensation
Relative Humidity Range
Unattended Period
Training for Operation

Elements of this taxonomy were filled by reviewing technical
literature and equipment catalogues.  This kind of information
will allow the selection of equipment with optimal cost-effective-

TASK 3:  Experimental System Design
The Experimental System Design phase of the project is currently
under way.  The operational nature of these small engines makes
the task of specifying the design of an experimental system
which simulates various operating conditions quite difficult.
Quasi stack and chamber techniques are currently being investigated.
Upon completion, this system will include fuel monitoring and a
means of containment of the exhaust from small engines with a
variable conditioned dilution rate for primary and secondary
emission evaluation.  The system should be able to simulate
environmental  conditions typical of those in which the various
small engines are used.

TASK 4:  Statistical Experimental Design
The objective of the Statistical Design is to maximize the
information for emissions assessment while minimizing the number
of individual  experiments.   To illustrate the importance of this
task, let us consider the factors by which engine emissions may
vary significantly.  As stated earlier, these factors are:
age of engine, carburetor setting, revolutions per minute and mode.
The stated level of interest of these factors are as follows:
         -age:  0 and 5 years
         -carburetor setting:  manufacture rated, fuel  lean
          and fuel  rich
         -rmp:  2,600 and 3,600
         -mode;  0%, 50%, and 100%

If a full factoral  ANOVA model  is used, then the number of test
runs would be:

        3 (carburetor) X 3 (modes) X 2 (rpm) X 2 (age)
          X 3 (engines) = 108 test runs.

This number of runs would be unreasonable in view of the time
necessary in setting up an engine for testing.  To compound the
problem, particulate phase polynuclear aromatic and vapor phase
polynuclear aromatic are both desirable and. expensive to measure.
Several incomplete factoral designs are under consideration as
possible alternatives.  To some the final statistical design
extent will, depend on the final configuration of the experimental
design.  The greatest issue then becomes the obvious tradeoff
between cost and precision.  Precision, in any statistical exper-
iment, is a direct function of sample size.  With an appropriate
design, we could retain sufficient sample size, yet reduce the
number of required runs by deleting cells that are less important
or informative.  In conjunction with or in lieu of deleting less,
informative cells, we may choose to reduce the number of replic-
ates in any given cell.  There are several possible ways of
making a cell elimination decision.  One would require analysis
of existing data that would result in elimination based on least
significant factors in a statistical sense,  A more straightforward
solution would Involve making a judgment on defining the most
"typical" cells corresponding to observed operational practices.
Then emphasis could be placed on making runs which would produce
maximum information in cells that best approximate the level of
factors generally encountered during normal operations.

It is hoped that completion of this structured approach will
provide a cost effective mechanism for the assessment of emissions
of these important sources.


 1.   Adams,  J.,  Selection  and  Evaluation  of  Sorbent  Resins  for  the
     Collection  of Urganic Compounds,  EPA-600/7-77-044,  April  1977.

 2.   Bowen,  Joshua S,,  Hall,  Robert E,  Proceedings of the Third
     Stationary  Source Combustion Symposium; Vol. I  Utility,
     Industrial, Commercial,  and Residential Systems,  EPA-600/7-79-050a,
     February 1979.

 3.   Bowen,  Joshua S.,  Hall,  Robert E,  Proceedings of the Third
     Stationary  Source Combustion Symposium; Vol  II  Advanced
     Processes and Special Topics, EPA-600/7-79-050b,  February  1979.

 4.   Bowen,  Joshua S.,  Hall,  Robert E,  Proceedings of the Third
     Stationary  Source Combustion Symposium; Vol. III.  Stationary
     Engine  and  Industrial Process Combustion Systems,  EPA-
     600/7-79-050C,  February  1979.

 5.   Bowen,  Joshua S.,  Hall,  Robert E,  Proceedings of the Third
     Stationary  Source Combustion Symposium; Vol. IV Fundamental
     Combustion  Research and  Environmental  Assessment,  EPA-
     600/7-79-050d,  February  1979.

 6.   Cushing, K.M. et  al,  Particulate  Sampling Support:   1977
     Annual  Report,  EPA-600/7-78-009,  January, 1978.

 7.   Duke,  K.M.  et al, IERL-RTP Procedures  Manual:   Level  1
     Environmental Assessment  Biological  Tests for Pilot Studies,
     EPA-600/7-77-043, April  1977.

 8.   Gallant, R.F. et  al,  characterization  of Sorbent  Resins  for
     use in  Environmental  Sampling,  March 1978.

 9.   Hamersma, S.I.  et al, IERL-RTP  Procedures Manual:   Level  1
     Environmental Assessment, EPA-600/2-76-160a, June  1976

10.   Hare,  Charles T,  Springer, Karl J.,  Exhaust  Emissions  from
     Uncontrolled Vehicles and Related Equipment  Using  Internal
     Combustion  Engines:  Part 2 Outboard Motors, APTD-1491,
     January 1973

11.   Hare,  Charles T,  Springer, Karl J.,  Exhaust  Emissions  from
     Uncontrolled Vehicles and Related Equipment  Using  Internal
     Combustion  Engines:  Part 4 Small Air-Cooled Spark  Ignition
     Utility Engines,  APTD-1493, May 1973

12.   Jaye,  Fredric C., Monitoring Instrumentation for  the  Measurement
     of Sulfur Dioxide In  Stationary Source  Emissions,  EPA-R2-73-163,
     February 1973.

13.   Kalika, P.W. et al , Development of Procedures for  the  Measure-
     ment of Fugitive  Emissions, EPA-600/2-76-284,  December 1976.

    References Page -2-

14.  Kolnsberg, H.J. Technical  Manual  for the Measurement  of
     Fugitive Emissions:   Quasi-Stack  Sampling Method  for
     Industrial Fugitive  Emissions,  May 1976.

15.  McAlevy, Robert F. Ill, Cole,  Richard B., Nitric-Oxide
     Measurement in a Simulated Spark-Ignition Engine,  APTD-1498,
     January 1973.

16.  Lilienfeld, Pedro et al, Design,  Development,  and  Demonstration
     of a Fine Particulate Measuring Device,  EPA-600/2-77-077,
     April  1977.

17.  Smith,  E.M.,  Little, Arthur D., Sensitized Flourescence for
     the Detection  of Polycyclic Aromatic Hydrocarbons,  September  1978.

18.  Springer, George, Engine Emissions,  Chapter 1,  "Engine  Exhaust

                 LIST OF ATTENDEES
             San Francisco, California
              March 5 - March  8,  1979

                              LIST OF ATTENDEES


                          San Francisco, California
                           March 5 - March 8, 1979
James D. Abercrombie
Monterey Bay Unified Air Pollution
Control  District
1270 Natividad Road
Room 105
Salinas, CA 93901

Gregory M. Adams
County Sanitation Districts of
Los Angeles County
P.O. Box 4998
Whittier, CA 90607

Bob Adrian
P.O. Box 2815
Sacramento, CA 95812

Manjit Ahuja
P.O. Box 2815
Sacramento, CA 95812

Don Ames
P.O. Box 2815
Sacramento, CA 95812

John E. Anderson
Union Carbide Corp., Linde Division
Old Saw Mill River Road
Tarrytown, NY 10591

Leonard C. Angelic
Electric Power Research Institute
P.O. Box 10412
Palo Alto, CA 94303

Richard E. Barrett
Battelle - Columbus
505 King Avenue
Columbus, OH 43201

Stephen B. Baruch
P.O. Box  10412
Palo Alto, CA 94304
J.A. Barsin
Babcock & Wilcox
20 S. Van Buren Avenue
Barberton, OH 44203

Arthur E. Axworthy
Rockwell International
Rocketdyne Division
6633 Canoga Avenue
Canoga Park, CA 91304

Dana R. Becker
EPA. Region IX
215 Fremont Street (Mail Code E-4-3)
San Francisco, CA 94105

M. Becker
Mobil Research & Development Corp.
Research Department
Paulsboro, NJ 08066

Janos M. Beer
Dept. of Chemical Engineering
Massachusetts Institute of Technology
Cambridge, MA 02139

Frank E. Belles
American Gas Association Labs
8501 E.  Pleasant Valley Road
Cleveland, CH 44131

Colin T. Bell
C.E.A.  Inc.
C.E.A.  Ltd.
Portchester Hants. England

Arthur  A.  Boni
Science Applications,  Inc.
1200 Prospect Street
La  Jolla,  CA 92037

Daniel  Bienstock
4800 Forbes Avenue
Pittsburg, PA 15213

David Birlingmair
Ames Laboratory
Iowa State University
Ames, IA 50011

Daniel B. Bentley
Air Correction Div. UOP
Tokeneke Road
Darien, CT 06820

William S. Blazowski
Exxon Research & Engineering Co.
P.O. Box 8
Linden, NJ 07036

Stephen G. Borleske
E.I. DuPont de Nemours
3019 Ridgevale Road
Wilmington, DE 19808

Joshua S. Bowen
U.S. EPA MD-65
Research Triangle Park, NC 27711

Hadi Bozorgmanesh
Science Applications, Inc.
1257 Tasman Drive
Sunnyvale, CA 94086

Rene A. Brand!igt
12723 E. Edgefield Street
Cerritos, CA 90701

Charles B. Bray
Occidental Oil Shale Inc.
P.O. Box 2687
Grand Junction, CO 81501

James E. Broadwell
One Space Park
Redondo Beach, CA  90274

Richard A. Brown
Acurex Corporation
485 Clyde Avenue
Mountain View, CA 94042

Larry Broz
Acurex Corporation
Southeast Operations
3203 Woman's  Club Drive
Suite 220
Raleigh, NC 27612
Jack Burke
Radian Corporation
P.O. Box 9948
Austin, TX 78766

Hartwell F. Calcote
AeroChem Research Laboratories, Inc.
P.O. Box 12
Princeton, NJ 08540

E.J. Campobenedetto
Babcock X Wilcox Co.
20 S. Van Buren Avenue
Barberton, OH 44203

Carlo Castaldini
Acurex Corporation
485 Clyde Avenue
Mountain View, CA 94042

Dean P. Chaffe
Riley Stoker Corporation
P.O. Box 547
Worcester, MA 01613

John Chehaske
Engineering Science
7903 Westpark Drive
McClean, VA 22102

John P. Chiaravalloti
Shell Oil Company
P.O. Box 92047 Worldway Center
Los Angeles, CA 90009

Ed Chu
Acurex Corporation
485 Clyde Avenue
Mountain  View, CA 94042

Hung Ben Chu
L.A. Dept. of Water  & Power
111 N. Hope Street
Los Angeles, CA 90051

J.  Edward Cichanowicz
3412 Hill view Avenue
Palo Alto, CA 94303

Bill Coe
CEA Combustion, Inc.
6300 Hi 11 croft, Suite 616
Houston, TX 77077

Thomas A. Collins
Atlantic Richfield Company
Harvey Technical Center
400 East Sibley Boulevard
Harvey, IL 60426

Cherie Cotter
P.O. Box 13222
Building 2001, Dept. 9860
Sacramento, CA 95813

Stanley T. Cuffe
Environmental Protection Agency
Research Triagle Park, NC 27711

Craig R. Cummings
Science Applications, Inc.
1200 Prospect Street
 P.O. Box 2351
La Jolla, CA 92038

J.L. Cunningham
Standard Oil Co. of California
555 Market Street
San Francisco, CA 94105

C.L. Dai ley
TRW Defense & Space Systems
1 Space Park
Redondo Beach, CA 90278

Dr. P. Davids
c/o VGB - Geschaffsstelle
Klinke Str. 27/31, (D4300)
Essen, W. Germany

Robert L. Derham
Energy Resources Co. Inc.
185 Alewife Brook Parkway
Cambridge, MA 02138

Dr. E A DeZubay PE
Westinghouse Electric Corporation
1310 Beulah Road
Pittsburgh, PA 15235

Frank DiGeneva
State of California Air Resources
P.O. Box 2815
Sacramento, CA 95812

Joseph S. Dock
The Aerospace Corporation
20030 Century Blvd.
Germantown, MD 20767
K. E. Doolin
Phillips Petroleum
10 Phillips Bldg.
Bartlesville, OK 74004

Arthur C. Doumas
Dow Chemical U.S.A.
Energy Systems Technical Services
Building B-101 A
Freeport, TX 77541

Robert I. Downey
Babcock & Wilcox Company
20 S. Van Buren Avenue
Barberton, OH 44203

Denis Drapeau
Dow Chemical
P.O. Box 1398
Pittsburg, CA 94565

Geoffrey D. Drissel
Box 5888
Denver, CO 80217

Robert Duthie
Bechtel National Inc.
50 Beale Street
San Francisco, CA  94106

Alan C. Eckbreth
United Technologies Research Center
Silver Lane
East Hartford, CT 06108

Clyde Eller
EPA, Region IX
215 Fremont Street
San Francisco, CA 94105

Glenn C.  England
Energy & Environmental Research
8001 Irvine Blvd.
Santa Ana, CA 92705

Dr. Victor S. Engleman
Science Applications, Inc.
P.O. Box 2351
La Jolla, CA 92038

R. J. Fletcher
Peabody Engineering Corporation
39 Maple Tree Avenue
Stamford, CT 06906

Mr. J. D. Flowers
Dow Chemical USA
Inorganic Chemicals, TS&D
2020 Dow Center
Midland, MI 48640

Blair A. Folsom
Energy & Environmental Research Corp.
8001 Irvine Blvd.
Santa Ana, CA 92705

Craig Fong
Acurex Corporation
485 Clyde Avenue
Mountain View, CA 94042

Donald L. Fox
university of North Carolina
Sch. of Pub. Health Environmental
Science & Engineering
Chapel Hill, NC 27514

Harry M. Freeman
Cincinnati, OH 45268

Warren Fujimoto
Pacific Gas & Electric Company
77 Beale Street Rm. 2626
San Francisco, CA 94106

James E. Gabriel son, P.E.
KVB, Inc.
6176 Olson Memorial Highway
Minneapolis, MN 55422

Barry Garelick
Science Applications, Inc.
3730 Mt. Diablo Blvd.
Lafayette, CA 94549

Robert H. Gaunt
Air Correction Division of UOP
Tokeneke Road
Darien, CT 06820

Robert D. Giammar
Battene-Columbus Laboratories
505 King Avenue
Columbus, OH 43201

Lee K. Gilmer
Texaco Inc.
P.O. Box 1608
Port Arthur, TX 77640
Martin E. Gluckstein
Ethyl Corporation
1600 W 8 Mile Road
Ferndale, MI 48220

Jim Gotterba
Acurex Corporation
485 Clyde Avenue
Mountain View, CA 94042

Doug Grandy
P.O. Box 2815
Sacramento, CA 95812

N. Wayne Green
BSP Division
1 Davis Drive
Belmont, CA 94002

Robert E. Griffith
Peabody Eng. Corporation
39 Maple Tree Avenue
Stamford, CT. 06906

Kenneth B. Gross, Ph.D.
General Motors Research Laboratories
Biomedical Science Department-RBL
GM Technical Center
Warren, MI 48090

F. H. Guenther
Northern Indiana Public Service Co.
5265 Hohrnan Avenue
Hammond, IN 46325

John C. Haas
Envirotech Corporation
1 Davis Drive
Belmont, CA 94002

Robert E. Hall
Combustion Research Branch (MD-65)
Research Triangle Park, NC 27711

Geoffrey M.  Halley
Kewanee Boiler Corporation
101 Franklin Street
Kewanee, IL 61443

Dr. J. Warren Hamersma
Defense & Space Systems Group of TRW
Building 0-1, Room 2020
One Space Park
Redondo Beach, CA 90278

Edward L. Hand!
Montana Power Company
40 East Broadway
Butte, MT 59701

Robert P. Hangebrauck
Environmental Protection Agency
Industrial Environmental Research
Lab (MD-61)
Research Triangle Park, NC 27711

Simon Hanson
77 Massachusetts Avenue
Cambridge, MA 02139

Dean W. Hardy
Tennessee Gas Pipeline
P.O. Box 2511
Houston, TX 77001

James F. Harkee
Lawrence-Allison West
1000 S. Grand
Santa Ana, CA 92705

Elliot H. Harris
So. Calif. Gas Company
810 So. Flower Street
Los Angeles, CA 90017

M. P. Heap
Energy & Environmental Research Corp.
8001 Irvine Blvd.
Santa Ana, CA 92705

Clifford A. Hauenstein
Energy Systems Group
Rockwell International
8900 DeSoto Avenue
Canoga Park, CA 91304

William H. Healy Jr.
El Paso Natural Gas Company
P.O. Box 1492
El Paso, TX 79912

Thomas E. Hensel
Power Systems Division, UTC
1690 New Britain Avenue
Farmington, CT 06032
Brent Higginbotham
Acurex Corporation
485 Clyde Avenue
Mountain View, CA 94042

John Hines
Union Oil Company
P.O. Box 76
Brea, CA 92621

Franklin I. Honea
Grand Forks Energy Tech. Center
Grand Forks, ND.  58202

H. Hornberg
Klinke Str. 27/31,  (D4300)
Essen, W. Germany

Donald E. Hoyt
Southern California Gas Company
810 South Flower Street
Los Angeles, CA 90017

Keh-Hsien Hsiao
Pullman Kellogg
16200 Park Row, Industrial Park Ten
Houston, TX 77084

Hann S. Huang
Argonne National Lab.
9700 S. Cass Avenue
Argonne, IL 60439

S.C. Hunter
KVB, Inc.
17332 Irvine Blvd.
Tustin, CA 92680

David Ipps
California Air Resources Board
P.O. Box 2815
Sacramento, CA 95812

Dr. Jacobs
Klinke Str. 27/31,  (D4300)
Essen, W. Germany

Norbert A. Jaworski
Environmental Protection Agency
Research Triangle Park, NC  27711

Dean P. Johnson
Panhandle Eastern Pipe Line Co.
P.O. Box 1348
Kansas City, MO  64141

Dr. Robert H. Johnson
G.E. Gas Turbine Division
General Electric Company
1  River Road
Bldg. 53-322
Schenectady, NY  12345

Stephen A. Johnson
Babcock & Wilcox Research
1562 Beeson Street
Alliance, OH  44601

Alfred W. Joensen
Dept. of Mechanical Engineering
Iowa State University
Ames, IA  50011

Gary D. Jones
Radian Corporation
Box 9948
Austin, TX  78766

Mr. M. Karschner
Klinke Str. 27/31, (D4300)
Essen, W. Germany

Chung-jen Kau
EER Corporation
2400 Michel son Drive
Irvine, CA  92714

Ben F. Kee
Tennessee Valley Authority
470 Commerce Union Bank Building
Chattanooga, TN  37401

John Kelly
Acurex  Corporation
485 Clyde Avenue
Mountain  View, CA  94042
Fred S. Kemp
United Technologies Corporation
Power Systems Division
P.O. Box 109
South Windsor, CT  06074

Dr. Robert Kendall
Acurex Corporation
485 Clyde Avenue
Mountain View, CA  94042

Jeffrey M. Kennedy
Acurex Corporation
P.O. Box 12796
Research Triangle Park, NC  27709

Gus L. Keolanui
Brown & Root, Inc
One Market Plaza
San Francisco, CA  94119

Bill Kerler
Coen Co.
1510 Rollins Rd.
Burlingame, CA  94010

John Kesselring
Acurex Corporation
485 Clyde Avenue
Mountain View, CA  94042

Dr. Arthur S. Kesten
United Technologies Res. Center
400 Main Street
East Hartford, CT 06108
James A. Kezerle
One Space Park  (01-1230)
Redondo Beach,  CA  90278

John S. Kinsey
AeroVironment,  Inc.
145 Vista Avenue, Suite 106
Pasadena, CA  91107

Alfred E. Kober
Apollo Chemical  Corp.
35 S.  Jefferson  Road
Whippany, NJ   07981

James Kolar
MN Pollution Control Agency
1935 West County Rd. B-2
Roseville, MN  55113

James 0. Kolb
Oak Ridge National Laboratory
Bldg 3550, Rm 12
P.O. Box X
Oak Ridge. TN  37830

Prof. H. Kraemer
Klinke Str. 27/31, (D4300)
Essen, W. Germany

Wayne Krill
Acurex Corporation
485 Clyde Avenue
Mountain View, CA  94042

Joe David Kuebler
Flow Resources Corp
91 Larkspur Street
San Rafael, CA  94901
William B. Kuykendal
Research Triangle Park, NC
David G. Lachapelle
Environmental Protection Agency
Hail Drop 65
Research Triangle Park, NC  27711

Howard B. Lange
17332 Irvine Boulevard
Tustin, CA  92680

Stephen Lanier
U.S. E.P.A.
Research Triangle Park, NC  27711

Dennis H. Larson
Institute of Gas Technology
3424 South State Street
Chicago, Illinois  60616
C.C. Larson
Air Resources Engineer
P.O. Box 2815
Sacramento, CA  95812

Albert D. LaRue
Babcock & Wilcox
20 S. Van Buren
Barberton, Ohio  44203

James A. Latty, Ph. D.
Dresser Industries
1702 McGaw, P.O. Box 19566
Irvine, CA  92713

Song Soo Lee
Occidental Research Corporation
P.O. Box 19601
Irvine, CA  92713

Y.C. Lee
Eneron Corporation
P.O. Box 7655, 4101 Westerly Place
Newport Beach, CA  92660

S.A. Lefton
NUS Corporation/Western Operations
Suite 624, Two Palo Alto Square
Palo Alto, CA  94304

Paul P. Leo
Aerospace Corporation
P.O. Box 92957
Los Angeles, CA  90274

Ken Lim
Acurex Corporation
485 Clyde Avenue
Mountain View, CA  94042

Howard W. Linnard
P.O. Box 2815
Sacramento, CA 95812

Harold Lips
Acurex Corporation
485 Clyde Avenue
Mountain View, CA  94042

Dr. Roy Littlewood
Steel Company of Canada, Ltd.
Stelco Tower, 100 King Street
Hamilton, Ontario, L8N3T1, Canada

David W. Lock!in
BatteHe-Columbus Laboratories
505 King Avenue
Columbus, Ohio  43201

Luis A. Lombana
BSP Division of Envirotech
One Davis Drive
Belmont, CA  94002

Steve Londerville
Coen Co.
1510 Rollins Road
Burlingame, CA  94010

E. H. Manny
Exxon Research & Engineering Co.
P.O. Box 8
Linden, NJ  07036

Robert P. Mattis
Institute of Gas Technology
3424 South State Street
Chicago, IL  60616

C. McComis
Energy & Environmental Research
8001 Irvine Blvd.
Santa Ana, CA  92705

Michael S. McCartney
Combustion Engineering
1000 Prospect Hill Road
Windsor, CT  06002
Darryl A. McDuel
Southern California Gas
810 South Flower Street
Los Angeles, CA  90017

W. J. McLean
Sandia Laboratories
Livermore, CA  94550

Andrej Macek
National Bureau of Stds.
Washington, D.C.  20234

Timothy Machold
Air Resources Board
ARB, 2941 Telegraph Ave.
Berkeley, CA  94705
Dr. Ken Maloney
KVB Inc.
17332 Irvine Blvd.
Tustin, CA  92680

M. N. Mansour
So. Calif. Edison Co.
P.O. Box 800
Rosemead, CA  91770

Dr. H. Markus
Klinke -St* 27/31, (D4300)
Essen, W. Germany

G. Blair Martin
U.S. EPA (MD-65)
Research Triangle Park, NC  27711

Howard Mason
Acurex Corporation
485 Clyde Avenue
Mountain View, CA  94042

John G. Meier
Solar Turbines International
2200 Pacific Highway
San Diego, CA  92138

A. M. Mellor
Purdue University
School of Mechanical Engineering
West Lafayette, Indiana  47907

Ellen Merrick
Acurex Corporation
485 Clyde Avenue
Mountain View, CA  94042

Austin H. Merrill
A.H. Merrill Engineering Co.
24 California Street
San Francisco, CA  94111

Michael J. Miller
Pacific Gas & Electric Co.
77 Beale Street
San Francisco, CA  94106

Vincent Mirabel!a
Southern Cal. Edison
P.O.  Box 800
Rosemead, CA   91770

Masaki Mi.yazawa
Mitsubishi Heavy Ind., Its.
c/o Combustion Engineering, Inc.
100 Prospect Hill Road
Windsor, a  06095

J. David Mobley
U.S. Environmental Protection Agency
Research Triangle Park, NC  27711

John E. Monacelli
Babcock & Wilcox Co.
20 South Van Buren Avenue
Barberton, Ohio  44203

Berkley Moore
Illinois EPA
2200 Churchill Road
Springfield, Illinois  62706

William J. Norton
E. Keeler Co.
238 West Street
Williamsport, PA  17701

Stanley A. Hosier
Pratt & Whitney Aircraft Group
P.O. Box 2691
West Palm Beach, FL  33402

John F. Mullen
Curtiss Wright Corp.
1 Passaic Street
Woodridge, NO  07075

Robert J. Mulligan
Acurex Corporation
485 Clyde Avenue
Mountain View, CA  94042

James W. Murrell
Systems Res. & Development Corp.
10 Park Plaza, P.O. Box 12221
Research Triangle Park, NC  27709

Dr. Larry Muzio
KVB, Inc.
17332 Irvine Blvd.
Tustin, CA  92680

Paul S. Natanson
Exxon Research & Engineering Co.
P.O. Box 8
Linden, NJ  07036
Toshio Nishizaka
Nippon Mining Co.
2 Chome,  Ushio-dori, Kurashiki
Okayama-ken, 712 Japan

F. Stuart Nolte
4500 Cherry Creek Drive
Denver, CO  80217

W. H. Nurick
EER Corp.
8001 Irvine Blvd.
Santa Ana, CA  92705

Alan Okuda
Rockwell International
6633 Canoga Ave.
Canoga Park, CA  91304

Henry H. Osborn
C-E Air Preheater Co.
Wellsvilie, NY   14895

Peter C. Owzarski
Battelle, Pacific N.W. Laboratory
P.O. Box 999
Rich!and, WA  99352

H. Hunter Paalman
Dow Chemical USA
P.O. Box 1398 Research Dept.
Pittsburg,  CA  94565

G. E.  (Ernie) Palomino
Salt River  Project
P.O. Box 1980
Phoenix, AR 85001

L.J. Parker
Sandia Laboratory
Livermore,  CA  94550

Richard  Parker
A.P.T.  Inc.
4901 Morena Blvd.
San  Diego,  CA  92117
Robert E. Paterson
Chevron  Research Co.
576  Standard Ave.
Richmond, CA   94802

J. L. Pease
Standard Oil Co. of California
555 Market Street
San Francisco, CA  94105

Dallas T. Pence
Science Applications, Inc.
4030 Sorrento Valley Blvd.
San Diego, CA  92121

James H. Peregoy
Pacific Gas & Electric
77 Beale St., Room 2652
San Francisco, CA  94549

A. R. Peters
Chevron Research Co.
P.O. Box 1627
Richmond, CA  94802

D. B. Peterson
University of San Diego
Alcala  Park
San  Diego,  CA   92110

Gary D.  Peterson
D. 0. E.
1333 Broadway
Oakland,  CA  94612

David W.  Pershing
Dept. of Chemical Engineering
University  of Utah
Salt Lake  City,  Utah  84112

Robert  M.  Pierce
Pratt & Whitney Aircraft
P.O. Box 2697
West Palm Beach, FL  33458

John T. Pogson
Acurex  Corporation
485 Clyde Avenue
Mountain View,  CA  94042
 John H. Pnhl
 Sandia Laboratories
 Combustion  Research Div.
 Livermore, CA  94550
 Wade  H.  Ponder
 U.S.  EPA  (MD-61)  (IERL-RTP)
 Research Triangle  Park,  NC  27711

 C.L.  Proctor
 Purdue  University
 School  of Mechanical  Engineering
 West  Lafayette,  Indiana  47907

 Prof. R.  Quack
 c/o VGB-Geschaftsstelle
 Klinke  Str. 27/31
 (D4300)   Essen,  W.  Germany

 Les Radak
 So. Calif. Edison
 P.O. Box  800
 Rosemead,  CA   91770

 J. E. Radway
 Enerchem  Inc.
 P.O. Box  45246
 Cleveland, Ohio  44145

 Dee P. Rees
 8001 Irvine Blvd.
 Santa Ana, CA  92705

 Ron Reese
 State of Calif Air  Resources Board
 P.O. Box 2815
 Sacramento, CA  95812

 Ricardo B. (Ding) Reyes
 Dow Chemical  USA
2800 Mitchell  Drive
Walnut Creek,  CA  94598

 R. A.  Reidlinger
 c/o VGB-Gerchaftsstelle
Klinke Str. 27/31
 (D4300)   Essen, W.   Germany

Joe Robert
Environment Canada
12th Fl. PVM,  351 St. Joseph Blvd.
Ottawa,  Ontario, K1A 1C8

Ernest B. Robison, W250
The Mitre Corp.
1820 Do!ley Madison Blvd.
McLean, VA  22102

Craii p A. Roderick
California Air Resources Engineer
1131 S Street
Sacramento, CA  95814

Douglas Roeck
GCA/Technology Div.
Burlington Road
Bedford, MA  01730

Jack Roehr
Wahlco Inc.
3600 W. Segerstrom Ave.
Santa Ana, CA  92705

Gerald Roffe
General Applied Science Labs
Merrick and Stewart Avenues
Westbury, NY  11590

Richard Rolfe
Western Precipitation
4565 Colorado Blvd.
Los Angeles, CA  90039

H. L. Rollans
Southern California Gas Co.
P.O. Box 3249
Terminal Annex
Los Angeles, CA 90051

David Rosen!of
State of Calif. Air Resources Board
P.O. Box 2815
Sacramento, CA  95812

N. C. Samish
Shell Development Co.
P.O. Box 1380
Houston, TX  77001

G. Scott Samuel sen
Mechanical & Env. Engineering
University of California
Irvine, CA  92717
A. F. Sarofim
11 Stella Road
Belmont, MA  02178

Robert Schefer
Lawrence Berleley Lab
1 Cyclotrom Rd.
Berkeley, CA  94720

Jay R. Schnitzer
Bay Area Air Pollution Control Dist.
939 Ellis St.
San Francisco, CA  94109

Walter F. Schoen
ARCO Petroleum  Products Co.
400 East Sibley Blvd.
Harvey, IL  60426

R. Kent Schreiber
U.S. Fish and Wildlife Service
National Power Plant Team
2929 Plymouth Road, RM. 206
Ann Arbor, MI  48105

Thomas J. Schultz
Midland-Ross Corp.
Thermal Systems Technical Center
900 N. Westwood / P.O. Box 985
Toledo, OH  43696

Herbert Schuster
Deutsche Babcock AG
Duisburgerstrabe 375
D4200 Oberhausen W. Germany

J. G. Seebold
Standard Oil Co. of California
555 Market Street
San Francisco, CA  94105

John B. Siemak
Dow Chemical USA
P.O. Box 1398
Pittsburg, CA  94565

Richard Schreiber
Acurex Corporation
485 Clyde Avenue
Mountain View, CA  94042

Dean Simeroth
P.O. Box 2815
Sacramento, CA
Richard Smith
S.D. County Air Pollution Control Dist,
9150 Chesapeake Drive
San Diego, CA  92123

Dr. Yih H. Song
Exxon Research & Engineering
P.O. Box 8
Linden, NJ  07036

Todd M. Somrner
Babcock & Wilcox
20 S. Van Buren Ave.
Barberton, OH  44203
John E. Stadig
129 Touchstone
West Sacramento, CA
Edward Stanton
Institute of Gas Technology
3424 South State Street
Chicago, IL  60616

Robert M. Statnick
401 M. Street, S.W.  (RD-681)
Washington, D.C,  20460

J. Martin Stewart
Exxon Co. USA
P.O. Box 3950
Baytown, TX  77521

C.C. Sunwoo
Tosco Corporation
10100 Santa Monica Blvd.
Los Angeles, CA  90067

S. Keith Swanson
Econics Corporation
10950 North Tantau Avenue
Cupertino, CA  95014

Louis Sybert
Bechtel National Inc.
50 Beale Street
San Francisco, CA  94105
Donald P. Teixeira
3412 Hi 11 view Avenue
Palo Alto, CA  94304

Andree Tamony
Dow Chemical Co.
Loveridge Rd.
Pittsburg, CA  94565

Terry VI. Tarkington
TVA-Emission Control Dev. Proj.
Muscle Shoals, Alabama  35660

Dr. Owen J. Tasslcker
3412 Hill view Ave., P.O. Box 10412
Palo Alto, CA  94303

R. Toloeken
c/o VGB-Geschaffsstelle
Kline Str. 27/31
(D4300) Essen, W. Germany

Bobby R. Tempi in
US Army Env. Hygiene Agency
APG(EA) MD  21010

Dr. K. Than
c/o VGB-Geschaffsstelle
Kline Str. 27/31
(D4300) Essen, W. Germany

Richard E. Thompson
KVB Inc.
17332 Irvine Blvd.
Tustin, CA  92680

Susan Thomas
Babcock & Wilcox
P.O. Box 835
Alliance, OH  44602

William E. Thompson
Research Triangle Institute
P.O. Box 12194
Research Triangle Park, NC  27709

Dr. Henry Tong
Acurex Corporation
485 Clyde Avenue
Mountain View, CA 94042

Steve Travis
Arizona Public Service Co.
P.O. Box 21666
Phoenix, AZ  85036

Michael A. Trykoski
Edison Elec. Inst.
1140 Connecticut Ave., NW
Washington, DC  22180

Arthur Y. Tso
Mobil Research & Development Corp.
P.O. Box 1026
Princeton, NJ  08540

Ray Tuvell
State Air Resources Board
Stationary Source Control Division
P.O. Box 2815
Sacramento. CA  95812

Thomas J. Tyson
EER Corporation
2400 Michel son Drive
Irvine, CA  92715

R.I. Van Hook
Oak Ridge National Laboratory
Bldg. 1505, P.O. Box X
Oak Ridge, TN  37830

Joel Vatsky
Foster Wheeler Energy Corp.
9 Peach Tree Hill Road
Livingston, NJ  07039

G.M. Varga, Jr.
Exxon Research & Engineering Co.
P.O. Box 8
Linden, NJ  07036

Don Vinson
Colorado Interstate Gas
P.O. Box 1087
Colorado Springs, CO  80944

Stan Vitt
Kaiser Steel Corporation
P.O. Box 217
Fontana, CA  92335
Chester A. Vogel
US EPA (MD-65)
Research Triangle Park, NC 27711

Byron Von Klock
Texaco Inc.
P.O. Box 1608
Port Arthur, TX  77640

Alexander Vranos
Silver Lane
East Hartford, CT  06108

Richard T. Wai be!
Institute of Gas Technology
3424 South State Street
Chicago, IL  60616

Peter J. Ware
Waste Management, Inc.
900 Jorie Boulevard
Oak Brook, IL  60521

John H. Wasser
EPA (MD-65)
Environmental Research Center
Research Triangle Park, NC 27711

Larry Waterland
Acurex Corporation
485 Clyde Avenue
Mt. View, CA  94042

Fred W. Weidner, P.E.
United States Coast Guard
Research & Development
400 Seventh Street, S.W.
Washington, D.C.  20590

James Weiss
Arizona Public Service Co.
P.O. Box 21666
Phoenix, AZ  85036

David J. White
Research Staff Specialist
Solar Turbines International
2200 Pacific Highway
San Diego, CA  92138

Dr. Alan Whitehead
General Electric
1100 Western Avenue
Lynn, MA  01910

Colin Wllkes
General Electric Co.
Bldg. 53, Room 322
1 River Road
Schenectady, NY  12345

A.L. Wilson
Engineering Science
150 N. Santa Anita Avenue
Arcadia, CA  91006

Richard J. Wilson
Texaco Inc.
2101 E. Pacific Coast Highway
Wilmington, CA  90744

Robert P. Wilson
Arthur D. Little Inc.
Acorn Park
Cambridge, MA  02140
             Dennis M.  Zallen
             EER Corporation
             2400 Michel son Drive
             Irvine, CA  92715

             W.  Zwiacher
             South Coast Air Quality Mgt.  District
             9150 Flair Drive
             El  Monte,  CA  91731
Eugene A. Winkler
American Air Filter Co.
1930 Bishop Lane
Louisville, KY  40277
John Wise
EPA Region IX
315 Fremont
San Francisco, CA  94707

Brian A. Wolfe
Babcock & Wilcox
P.O. Box 835
Alliance, OH  44601

Tony Xavier
State of Calif. Air Resources Board
P.O. Box 2815
Sacramento, CA  95812

Chuch Youngson
Dow Chemical Co.
Loveridge Road
Plttsburg, CA  94565

                               TECHNICAL REPORT DATA
                         (Please read Instructions on the reverse before completing)
                                                    3. RECIPIENT'S ACCESSION-NO.
4.T.TLEANDSUBT.TLE proceedings of the Third Stationary
Source Combustion Symposium; Volume  V.  Addendum
                               B. REPORT DATE
                                February 1979
                                                    6. PERFORMING ORGANIZATION CODE
         Joshua S. Bowen, Symposium Chairman, and
Robert E.  Hall, Symposium Vice-chairman
                               B. PERFORMING ORGANIZATION REPORT NO.
See Block 12.
                               10. PROGRAM ELEMENT NO.
                               E HE 62 4
                                                     11. CONTRACT/GRANT NO.

                                                     NA (Inhouse)
 EPA, Office of Research and Development
 Industrial Environmental Research Laboratory
 Research Triangle Park, NC 27711
                               13. TYPE OF REPORT AND PI
                               Proceedings: 3/79
                                                                     PERIOD COVERED
                               14. SPONSORING AGENCY CODE
is. SUPPLEMENTARY NOTES JERL-RTP project officer is Robert E. Hall. MD-65, 919/541-
2477.  EPA-600/7-77-073a thru-073e and EPA-600/2-76-152a thru -152c are pro-
ceedings of earlier symposiums on the same theme.	
is. ABSTRACT The proceedings document the approximately 50 presentations made during
the symposium, March 5-8, 1979, in San Francisco. Sponsored by the Combustion
Research Branch of EPA's  Industrial Environmental Research Laboratory-RTP,
the symposium dealt with subjects relating both to developing improved combustion
technology for the reduction of air pollutant emissions from stationary sources,
and to improving equipment efficiency. The symposium was in seven parts, and
the proceedings are in five  volumes: I. Utility, Industrial,  Commercial, and Resi-
dential Systems; n. Advanced Processes and Special Topics;  El. Stationary Engine
and Industrial Process Combustion Systems; IV. Fundamental Combustion Research
and Environmental Assessment; and V. Addendum.  The symposium provided contra-
ctor, industrial, and government representatives with the latest information on EPA
inhouse and contract combustion research projects relating to pollution control,
with emphasis on reducing  NOx while controlling other emissions and improving
                            KEY WORDS AND DOCUMENT ANALYSIS
                                         b.lDENTIFIERS/OPEN ENDED TERMS
                                           c. COSATI Field/Group
 Air Pollution
 Field Tests
 Combustion Control
 Fossil Fuels
Gas Turbines
Nitrogen Oxides
Industrial Pro-
Air Pollution Control
Stationary Sources
Environmental Assess-
Combustion Modification
Trace Species
Fuel Nitrogen	
                   19. SECURITY CLASS (ThisReport)
                        21. NO. OF PAGES
                   2O. SECURITY CLASS (Thispage)
                                           22. PRICE
EPA Form 2220-1 (»-73)