oEPA
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.
Addendum
Interagency
Energy/Environment
R&D Program Report
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RESEARCH REPORTING SERIES
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.
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EPA-600/7-79-050e
February 1979
Proceedings of the Third
Stationary Source Combustion
Symposium;
Volume V. Addendum
Joshua S. Bowen, Symposium Chairman,
and
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
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Research and Development
Washington, DC 20460
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PREFACE
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
Systems
John H. Wasser, Session Chairman
Fundamental Combustion
W. Steven Lanier, Session Chairman
Environmental Assessment
Wade H. Ponder, Session Chairman
n
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VOLUME V
Table of Contents
Page
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
111
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INTRODUCTORY REMARKS
by
J. S. Bowen, Chief
Combustion Research Branch
Industrial Environmental Research Laboratory-RTF
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THIRD SYMPOSIUM ON STATIONARY SOURCE COMBUSTION
Introductory Remarks
by
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
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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
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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
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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
then.
Now, let us proceed with the Symposium Agenda.
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WELCOMING ADDRESS
by
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.
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OPENING ADDRESS
by
N. A. Jaworski, Deputy Director
Office of Research and Development
Industrial Environmental Research Laboratory-RTF
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THIRD SYMPOSIUM ON STATIONARY SOURCE COMBUSTION
OPENING ADDRESS
BY
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:
—Enforcement.
—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
USA.
Our Assistant Administrator for Research and Development is Stephen
J. Gage, who oversees the programs of five principal offices dealing
with:
—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,
Ohio.
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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.
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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.
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COMBUSTION MODIFICATION CONCEPTS
FOR STOKER-BOILER APPLICATION
by
John H. Wasser, IERL-RTP
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ABSTRACT
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.
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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.
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BACKGROUND
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
Boilers."
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.
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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
effort.
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
tasks.
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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.
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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
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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.
INDUSTRIAL ADVISORY COMMITTEE
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.
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LUNCHEON ADDRESS
by
Peter Schwartz
Manager, Future Studies
S.R.I. International
This luncheon address, was recorded and
transcribed for inclusion in this volume,
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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
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familiar with that, and with the Energy Primer. And today
Peter will talk to us about Changing Values and the Environment.
Peter.
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
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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".
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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
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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
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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
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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
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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
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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
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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
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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
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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,
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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
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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
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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
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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
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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.
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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
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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
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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.
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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
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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-
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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
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seems reasonably probable to me. That's my answer to your
question.
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
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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.
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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.
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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
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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.
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EPRI LOW COMBUSTION NOx RESEARCH
by
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.
51
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PANEL
SHORT-TERM NOx STANDARDS
The Panel Discussion on Short-Term MOX standards
was recorded and transcribed for inclusion in
this volume.
53
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CONTENTS
Page
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
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SHORT-TERM NOx STANDARDS PANEL
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
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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
standard.
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-
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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.
Stan?
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
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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
now.
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
promulgate.
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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.
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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
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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
standard.
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
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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
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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
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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.
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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.
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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
limitations.
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
behavior.
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
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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,
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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
each.
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.
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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.
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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
year.
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.
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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
account.
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
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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
1985.
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
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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.
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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
standards.
Thank you.
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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
standard.
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
standard.
* A copy of Mr. Mirabella's slide presentation follows the
Panel Discussion.
75
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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.
76
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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
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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
ton.
The significance of this is that by defining RACT with
ammonia injection, that pretty much sets the stage for all other
78
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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.
79
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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
world.
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.
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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.
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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
strategies.
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.
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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
increments.
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
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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
clarify.
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
84
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required to have 90 percent control for stage two, and that is
not correct.
(A-question and answer period followed, which was not
reported.)
85
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PANEL DISCUSSION
SLIDE PRESENTATION
by
Vincent A. Mirabella
Southern California Edison
87
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SLIDE 1
KEY IMPACTS ON UTILITY INDUSTRY DUE TO THE CAAAs OF 1977
!• EMISSION CONTROL REQUIREMENTS (E-G-, fiACT; RACT, LAER,
BART)
2. SITING CONSTRAINTS (E.G., PROXIMITY TO PSD AREAS)
3. FACILITY DESIGN REQUIREMENTS (E.G., STACK HEIGHT.,
FUEL TYPE)
4. DOLLAR/ENERGY COSTS RESULTING FROM (1) TO (3) ABOVE
-------
SLIDE 2
POTENTIAL AMBIENT AIR QUALITY STANDARDS FOR N02
AVERAGING PERIOD RANGE OF VALUES PROBABLE VALUE
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)
*»
PRESENT ANNUAL PRIMARY N02 STANDARD
CURRENT CALIFORNIA I-HOUR N02 STANDARD
89
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LU
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e
CD
20-
15-
CD
i—t
00
s 10H
LU
X
2 5'
29%
NATIONAL
SCAB
oo
CD
CD
OO
—I
»-—«
^D
2000
GO
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X
1500
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OO
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|-500i
SLIDE 3 NATIONAL AND SOUTH COAST AIR BASIN NOX EMISSION INVENTORIES 1976
-------
AQCR with no or Inadequate data.
AQCR with maximum annual average
less than 80
AQCR with maximum annual average
between 80 and 100
SLIDE 4. STATUS OF COMPLIANCE WITH ANNUAL NC STANDARDS
-------
• 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
SLIDE 5, STATUS OF COMPLIANCE WITH 1-HOUR STANDARDS
-------
120-
100-
80-
OJ
60-
20-
ANNUAL
i<
30UG/M
ANNUAL
36,000
J-HOIJK
$ 105,900
100
470 UG/M-
1-HOUR
31,000
910 UG/M
SLIDE 6 INSTALLED MEGAWATT CAPACITY LO.CATED IN POTENTIAL NONATTAINHENT AREAS FOR fJ09 (1975-7C)
-------
CO
I-
I-
25-
20-
££ 15
-------
SLIDE 8
EMISSION CONTROL REQUIREMENTS FOR NEW OR EXISTING
EMISSION SOURCES LOCATED IN NONATTAINMENT AREAS
NEW OR
REQUIREMENT* MODIFIED SOURCE EXISTING SOURCE
RACT (LOCAL) X
LAER (NATIONAL) X
BART (LOCAL/FEDERAL) X
BACT (LOCAL)
RACT - REASONABLY AVAILABLE CONTROL TECHNOLOGY: REQUIRED OF
EXISTING SOURCES AND IS DEFINED AS THAT CONTROL REQUIRED OF
EXISTING SOURCES TO ROLLBACK AMBIENT LEVELS TO THE NAAQS
BY DECEMBER 31, 1982.
LAER - LOWEST ACHIEVABLE EMISSION RATE: LOWEST ACHIEVABLE
NATIONALLY EITHER IN AN SIP OR IN PRACTICE-
BART - BEST AVAILABLE RETROFIT TECHNOLOGY: REQUIRED OF
EXISTING SOURCES LESS THAN 15 YEARS OLD; FOR VISIBILITY
PROTECTION-
BACT - BEST AVAILABLE CONTROL TECHNOLOGY: APPLIES TO ALL
NEW OR MODIFIED SOURCES LOCATED IN PSD AREASj HOWEVER. BACT
CAN UTIMATELY AFFECT LAER AND VICE VERSA-
95
-------
SLIDE 9
NOx EMISSION CONTROL TECHNOLOGY AS APPLIED TO UTILITY BOILERS
COMBUSTION MODIFICATIONS
DEGREE OF
CONTROL (%)
CONTROL COST
U/TON-NOx)
***
LOW EXCESS AIR, FLUE GAS
RECIRCULATION, WATER OR
STEAM INJECTION/ REDUCED
AIR PREHEAT/ AND OFF~
STOICHIOMETRIC COMBUSTION
10-50*
100-1000
**
FLUE GAS TREATMENT
AMMONIA INJECTION
SELECTIVE CATALYTIC
REDUCTION
40-50
90
2000-4000
4500-9000+
* HIGHER CONTROL REFLECTS COMBINATIONS OF CONTROL TECHNIQUES
**
RACT MEASURES IN THE CALIFORNIA SIP: MEASURES PROVIDE BASIS
FOR SETTING BACT, LAER, RACT, AND BART FOR NOX-
CONTROL COSTS WILL VARY WIDELY FOR INDIVIDUAL UNITS
DEPENDING ON UNIT SIZE AND CAPACITY FACTORS
96
-------
SLIDE ID
PROVISIONS OF THE SCAQMD RULE 475-1
(REDUCTION OF POWER PLANT NOx EMISSIONS)
FINAL ADOPTION: JANUARY 22, 1979
IMPLEMENTATION
STAGE
PROVISIONS
MILESTONE DATE
A) APRIL 1, 1979
B) JULY 1, 1979
c) DECEMBER 31, 1982
INSTALLATION OF 50% NOx CONTROL,
SYSTEM-WIDE AVERAGE ON ALL
UNITS IN SCAB
A) CONTROL PLAN
B) CONSTRUCTION CONTRACTS
c) COMPLIANCE DEMONSTRATION
INSTALLATION OF A DEMONSTRATION
UNIT, GREATER THAN 100MW, CAP-
ABLE OF DEMONSTRATING 90% NOx
CONTROL
A) COMPLIANCE DEMONSTRATION A) JANUARY 1, 1982
II
INSTALLATION OF CONTROL EQUIPMENT
TO EFFECT 90% OF NOx REDUCTION
SUBJECT TO REVIEW BY REGULATORY
AGENCIES
A) CONTROL PLAN
B) COMPLIANCE DEMONSTRATION
A) JULY 1, 1983
B) JANUARY 1, 1990
97
-------
SLIDE 11
NOX EMISSION STANDARDS FOR
UTILITY BOILERS
(LB/105 BTU)
COAL OIL
PRESENT NSPS 0,7 0,3
PROPOSED NSPS 0,5, 0,6 0,3
SCAB
EXISTING UNITS 0,3 0,3
NEW AND EXISTING
UNITS (AFTER 1981) 0,15 0,15
NEW AND EXISTING
UNITS (AFTER 1989) 0,03 0,03
98
-------
TOO
NATIONAL
(0
cr
c
O
co
o
o
Stationary Sources/ //////
/ / / , , ////////.
CM
.05 -
,005-S
,OOL
//// //// * * ' * ' ' * '
Jiff I / n / Industrial Processes A
>:• Mobile Sources
Vehicles jj^^^^^gj^
L
1
1
1
1
Ranges of Typical (S0?/C0) Emission Ratios in Various
Source Categories.
SLIDE 12
99
SCAB
SCAB
NATIONAL
SCAB
NATIONAL
SCAB
NATIONAL
SCAB
NATIONAL
-------
100
80
IK:
60
PQ
UJ
C£
LLJ
Q_
40'
20-
NOX
EMISSIONS
NOX
AIR OUALITY
N02
AIR OUALITY
2%
OTHER
STATIONARY
70%
68%
2%
OTHER
STATIONARY
!P,P!
71%
69%
3%
OTHER
'STATIONARY
60%
57%
SLIDE 13 CONTRIBUTION OF NOX EMISSION SOURCE TYPES TO NOX EMISSIONS, AMBIENT NOX LEVELS, AND
AMBIENT N02 LEVELS AT DOWNTOWN LOS ANGELES ON ALL DAYS (1971-1976)
-------
SLIDE
EMISSION SOURCE CONTRIBUTIONS TO ANNUAL AVERAGE AND SHORT-TERM N02 CONCENTRATIONS IN THE SCAB
HIGHEST ANNUAL N02 SOURCE AVERAGE 1-HR. N02 N02 SOURCE
AVERAGE CONCENTRATION CONTRIBUTION (UG/M^) ON IlAYS OF HIGHEST CONTRIBUTION
SITE 1974-1977 (UG/M^) MOBILE P»P OTHER N02* 1974-1977 (UG/M!) MOBILE P.P OTHER
DOWNTOWN
S IDS ANGELES
80
57
126 7 55
WHITTIER 135
100 15 20
225
176 18 31
* DAYS WHEN A I-HOUR AVERAGE N02 EXCEEDED 470
-------
in
6
o
ro
«D
o
SLIDE 15
OZONE ISOPLETH SET FOR JUNE 27, 1974
0.25
0.50
FEDERAL
STANDARD
N02
STATE NO2
STANDARD
o.oe
0.10
0.75
1.00
1.25
1.50
1.75
2.00
2.25
NO NOX CONTROLS
FROM 197^1 LEVELS
1974 : 0.51 ppm
50
0.15-
0.35-
-0.30
-0.25
0.20
-0.15—
.00
0.25 0.90
olrs
1.00 1.25 1.50
» r r N*»
1.75 2.00
2.25
in
"o
in
"o
10
m
r-
"o
Ol
O
2.50
-------
SLIDE 1G
POSSIBLE PSD INCREMENTS FOR N02
ALLOWABLE INCREMENTS
AVERAGING
PERIOD POSSIBLE STANDARD CLASS I (21) CLASS II (252) CLASS HI (50%)
ANNUAL 80 UG/n3 2 20 40
2 25 50
HOUR 470 UG/M^ 10 117 235
940 UG/M3 20 235 470
103
-------
1 Handatory Clan I PSO treat
• DUcrptlonary Clatt I PSO areas
• Planned Fossil Furl-Fired Power
Puerto Rico,
Virgin Islands
200 wiles
SLIDE 17 RELATIONSHIP OF SCHtOULEO FOSSIL FUFL POWER PLANTS TO MANDATORY AKO DISCRETIONARY CLASS I PSD AREAS
-------
SLIDE 13
DISTANCES BETWEEN
SCHEDULED POWER PLANTS AND
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
SOURCE: FLOW RESOURCES CORP, 1979
105
-------
SLIDE 19
CONCLUSIONS
• THE PROMULGATION OF A SHORT-TERM *IU2 STANDARD AND THE
POSSIBLE REVISION OF THE ANNUAL N02 STANDARD COULD HAVE
SUBSTANTIAL IMPACTS ON THE UTILITY INDUSTRY IN TERMS OF
EMISSION CONTROL REQUIREMENTS FOR NEW AND EXISTING POWER
PLANTS-
• OVER 100/000 HM OF EXISTING POWER PLANTS OR 30Z OF EXIST-
ING FOSSIL CAPACITY ARE LOCATED IN 29 POTENTIAL NONAT"
TAINMENT AQCRS-
• REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) is REQUIRED
Of EXISTING SOURCES LOCATED IN NONATTAINHENT AREAS; USING
THE CALIFORNIA SIP AS AN EXAMPLE, RACT NAY REQUIRE UP TO 50-
90Z REDUCTION OF EXISTING UTILITY EMISSIONS* RETROFIT OF
SUCH CONTROLS MILL BE EXTREMELY EXPENSIVE, AMOUNTING TO
POTENTIALLY BILLIONS OF DOLLARS* MOREOVER, IN SOME NONAT-
TAINHENT AREAS SUCH POWER PLANT CONTROLS ARE UNLIKELY TO
SUBSTANTIALLY AFFECT AMBIENT N02 LEVELS IN ACHIEVING
THE MAAQSS*
• THE CALIFORNIA RACT MEASURES HILL ULTIMATELY SET THE BASIS
FOR LAER AND 6ACT REQUIREMENTS*
• UP TO 38Z OF PLANNED CAPACITY HILL BE LOCATED IN POTEN-
TIAL NONATTAINMENT AREAS AND SUBJECT TO LAER.
• CONTROL OF MOx EMISSIONS IN MEETING 1102 STANDARDS MUST
BE JUDGED IN LIGHT OF POTENTIAL IMPACTS ON URBAN OZONE
LEVELS*
• UNLESS EMISSION OFFSETS CAN BE ACQUIRED IN POS AREAS,
ABOUT ONE-HALF OF ALL NEH FOSSIL-FUEL POHER PLANTS COULD
REQUIRE EMISSIONS CONTROLS MORE STRINGENT THAN THE RECENT
NSPS AS PROPOSED,
t ABOUT 25X OF ALL MEN POHER PLANT CAPACITY HILL BE LOCATED
CLOSE ENOUGH TO POSSIBLE PSD CLASS I AREAS TO BE POTENTI-
ALLY IMPACTED BY RELATED EMISSION REQUIREMENTS*
• NOX HAY REPLACE S0£ AS THE POLLUTANT CONTROLLING
FACILITY AND SITE SUITABILITY*
106
-------
TOWARDS
A RESEARCH PLAN TO
STUDY EMISSIONS
FROM SMALL
INTERNAL COMBUSTION ENGINES
By:
James W. Murrell and Frankie Alexander
Systems Research and Development Corporation
10 Park Plaza (P.O. Box 12221)
Research Triangle Park, NC 27709
107
-------
Abstract
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
Include:
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.
108
-------
I. INTRODUCTION
BACKGROUND:
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
-hydrocarbons
-carbon monoxide
-oxides of nitrogen
-particulates.
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
animals.
109
-------
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.
Purpose:
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
are:
-age of engine
-carburetor setting
-revolutions per minute
-mode (or load).
110
-------
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.
Ill
-------
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
112
-------
could be directly derived from engine specifications. Such
information would include:
-cy.de or stroke (two or four)
-carburetor specifications
-horsepower
-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.
113
-------
Taxonomic Dimension
Sampling
Performance
Elements
Method
Volume
Maximum Temperature Input
Collection Efficiency
Accuracy
Reproducibility
Linearity
Noise
Log Time
Retention Time
Fall Time
Zero Drift
Span Drift
Operation
Ambient Temperature Range
Temperature Compensation
Relative Humidity Range
Procedure
Unattended Period
Maintenance
Requirements
Power
Weight
Dimensions
Features
Output
Training for Operation
Cost
114
-------
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-
ness.
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:
115
-------
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.
116
-------
References
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.
117
-------
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
Emission".
118
-------
LIST OF ATTENDEES
EPA THIRD SYMPOSIUM ON STATIONARY SOURCE COMBUSTION
INDUSTRIAL ENVIRONMENTAL RESEARCH LABORATORY-RTP
San Francisco, California
March 5 - March 8, 1979
119
-------
LIST OF ATTENDEES
EPA THIRD SYMPOSIUM ON STATIONARY SOURCE COMBUSTION
INDUSTRIAL ENVIRONMENTAL RESEARCH LABORATORY-RTP
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
CARB
P.O. Box 2815
Sacramento, CA 95812
Manjit Ahuja
CARB
P.O. Box 2815
Sacramento, CA 95812
Don Ames
CARB
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
EPRI
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
MIT
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
U.S. DOE
4800 Forbes Avenue
Pittsburg, PA 15213
120
-------
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
EDO
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
TRW
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
EPRI
3412 Hill view Avenue
Palo Alto, CA 94303
Bill Coe
CEA Combustion, Inc.
6300 Hi 11 croft, Suite 616
Houston, TX 77077
121
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Thomas A. Collins
Atlantic Richfield Company
Harvey Technical Center
400 East Sibley Boulevard
Harvey, IL 60426
Cherie Cotter
AECC
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
Board
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
Steams-Roger
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
122
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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
EPA
IERL
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
CARB
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
U.S. EPA, IERL-RTP
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
123
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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
M.I.T.
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
U.S. DOE
Grand Forks Energy Tech. Center
Grand Forks, ND. 58202
H. Hornberg
VGB-Geschaftsstelle
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
VGB-Geschaftsstelle
Klinke Str. 27/31, (D4300)
Essen, W. Germany
124
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Norbert A. Jaworski
Environmental Protection Agency
IERL-RTP (MD-60)
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
VGB-Geschaftsstelle
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
TRW DSSG, Inc.
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
125
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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
VGB-Geschaftsstelle
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
EPA - IERL
Research Triangle Park, NC
27711
David G. Lachapelle
Environmental Protection Agency
Hail Drop 65
Research Triangle Park, NC 27711
Howard B. Lange
KVB
17332 Irvine Boulevard
Tustin, CA 92680
Stephen Lanier
U.S. E.P.A.
IERL-RTP (MD-65)
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
CARB
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
126
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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
Co.
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
VGB-Geschaftssetel1e
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
127
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Masaki Mi.yazawa
Mitsubishi Heavy Ind., Its.
c/o Combustion Engineering, Inc.
100 Prospect Hill Road
Windsor, a 06095
J. David Mobley
IERL - RTF
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
Steams-Roger
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
128
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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
8353
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
EER
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
129
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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
M.I.T.
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
130
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Dean Simeroth
GARB
P.O. Box 2815
Sacramento, CA
95812
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
Consultant
129 Touchstone
West Sacramento, CA
95691
Edward Stanton
Institute of Gas Technology
3424 South State Street
Chicago, IL 60616
Robert M. Statnick
U.S. EPA
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
EPRI
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.
OSWHA
Muscle Shoals, Alabama 35660
Dr. Owen J. Tasslcker
EPRI
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
USAEHA/APED
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
131
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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)
IERL-RTP
Research Triangle Park, NC 27711
Byron Von Klock
Texaco Inc.
P.O. Box 1608
Port Arthur, TX 77640
Alexander Vranos
U.T.R.C.
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
132
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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
Inc.
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
133
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
i. REPORT NO.
EPA-600/7-79-050e
2.
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
7. AUTHOR(S)
Joshua S. Bowen, Symposium Chairman, and
Robert E. Hall, Symposium Vice-chairman
B. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
See Block 12.
10. PROGRAM ELEMENT NO.
E HE 62 4
11. CONTRACT/GRANT NO.
NA (Inhouse)
12. SPONSORING AGENCY NAME AND ADDRESS
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
EPA/600/13
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
efficiency.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air Pollution
Combustion
Field Tests
Assessments
Combustion Control
Fossil Fuels
Boilers
Gas Turbines
Nitrogen Oxides
Efficiency
Utilities
Industrial Pro-
cesses
Hydrocarbons
Air Pollution Control
Stationary Sources
Environmental Assess-
ment
Combustion Modification
Trace Species
Fuel Nitrogen
13B
21B
14B
21D
13A
13G
07B
13H
07C
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
137
2O. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (»-73)
134
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