United States
Environmental Protection
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 13
Number 8
October 1987
The Challenge of Ozone Pollution

Traffic on the Long Island
Expressway. Automobiles are
a major source of ozone
                                                                                    ergor, New York Oty Department of fw ;  • •
The Challenge  of  Ozone   Pollution
                             Is it possible for a modern.
                             affluent society to have a
                            clean environment? O/,one
                            pollution—commonly known
                            as smog—is posing that
                            question dramatically for this
                            country. This issue of EPA
                            Journal explores the
                              The issue, begins with an
                            article by HI'A Administrator
                            Lee M.  Thomas spelling out
                            what he believes the nation's
                            future o/one control  strategy
                            should  be. In a /minin!
                            interview. ]. Craig Potter, the
                            Agency's Assistant
                            Administrator for Air and
                            Radiation, answers questions
                            about the o/.one pollution
                            problem and discusses efforts
                            to deal  with it. Then, an
                            article elaborates on the
                            nature of o/.one pollution and
                            its effects, including  its
                            potential health
                              The fact that o/one
                            pollution sources and
                            conditions differ widely is
                            explained in an article
                            focusing on smog situations
                            in such cities as Los Angeles.
                            New York. Houston, and
                            Atlanta. Another article
                            introduces the array of
                            technologies aimed at
                            preventing or controlling this
                            complex  problem. The
                            outlook for alternative fuels
                            for motor vehicles, a
                            potentially major smog
                            control weapon, is presented
                              In a special forum, three
                            leaders outside EPA with
                            diverse viewpoints on the
                            smog problem give their
                            commentaries on how they
                            feel it can best be  solved.
                            And an article explains the
                            legal groundwork for KPA's
                            actions under the Clean Air
                            Act to deal with o/.one
  Two related articles report
on air quality trends in the
U.S. and on the results from
EPA's phasedown of lead in
gasoline. In a different vein, a
bicycler explains why he
enjoys this pollution-free
transportation mode.
  This issue of EPA journal
concludes with two regular
features—Update and
Editor's Note: In this issue
of the maga/ine, ••smog" and
"o/one pollution " are used
interchangeably, because
smog lias become a common
term in American usage.
However, the reader should
understand that technically.
smog includes more
pollutants than just o/.one.
although o/.one is the  major
component of what we
normally think of as smog.

                               United States
                               Environmental Protection
                               Office of
                               Public Affairs (A-107}
                               Washington  DC 20460
                               Volume 13
                               Number 8
                               October 1987
                           SEPA  JOURNAL
                               Lee M. Thomas, Administrator
                               Jennifer Joy Wilson, Assistant Administrator for External Affairs
                               Linda Wilson Reed,  Director, Office of Public Affairs

                               John  Heritage, Editor
                               Karen Flagstad, Assistant Editor
                               Jack  Lewis, Assistant Editor
                               Margherita Pryor, Assistant Editor
EPA is charged by ('.impress to
protect the nation's land. air. and
water systems. Under i\ mandate "I
national environmental laws, the
agency strives In inniiulale and
implement actions which lead to a
Compatible balance between
human activities and the ability of
natural systems to support and
nurture lite.
  The EPA /ourmii is published by
the U.S. Environmental Protection
Agency. The Administrator of KPA
has determined that the
publication ot this periodical is
necessary in the transaction of the
public business required by law of
ibis agency. Use of funds for
printing this periodical lias been
approved by the Director of the
Office of Management and Budget.
Views expressed by authors do not
necessarily reflect KPA policy.
Contributions and inquiries should
be addressed to the Fditor (A-107),
Waterside Mall, 401 M St., S.W.,
Washington, DC 20460. No
permission necessary to reproduce
contents except copyrighted photos
and other materials.
Next Steps
in the  Battle
Against Smog
by Lee M. Thomas  2

Answers about
Ozone Pollution
An Interview
with J. Craig Potter   -5

Smog:  Its Nature
and Effects
by Bob Burke  9

Situation Reports:
From Los Angeles
to Atlanta
by Roy Popkin  12
Finding Technologies
to Control
Ozone Pollution
by Jack Lewis   15

Alternative Fuels:
Their Prospects
for Fighting Smog
by Richard D. Wilson  IB

EPA, Ozone Pollution,
and the Law
by Richard Ossias  20

Solutions to
the Smog Dilemma:
A Forum   22

A Look at
Air Quality Trends
by Bob  Burke  25
Revisting the
Lead Phasedown
by Richard C. Ko/.lowski 28

Look Ma!
No Pollution!
by Hagan Thompson  30

Update  ;{2

Appointments  H2
                               Front Cover: A view of Los
                               Angeles, one of the U.S. cities ivith
                               major smog problems. Photo by
                               Rene Sheret, Folio, Inc.
                                Design (.Yedils:
                                Donna Wasylkiwskyj;
                                Ron Fcirruh;
                                James H. /ngnim.
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                      Next Steps  in the  Battle
                      Against Smog
                      by Lee M.Thomas
This satellite photo shows
the eastern half of North
America while a large
"Bermuda high" hovers off
the coast—a frequent
summertime occurrence that
can affect smog levels over a
large area. Under these
conditions, air currents drive
clouds in a clockwise pattern,
as shown, up the East Coast.
Smog pollutants are  forced
up the coast in the same
pattern, spread north and
northeastward from their
original sources by the
prevailing winds.

                                                                             EPA JOURNAL

                                        Over 60 major urban areas in
                                        every part of the country still
                                        do not attain the national
                                        health standard for ozone.
   Since the Clean Air Act was passed in
   1970, the United States has made
impressive strides toward protecting
and enhancing the quality of its  air.
Stringent air pollution controls are now
required on most large new stationary
facilities, like refineries and chemical
plants. New cars and trucks must limit
their air emissions to meet strict federal
standards. Because of cooperative
federal, state, and local efforts, effective
air pollution controls are now in place
on a host of smaller, widely dispersed
sources such as printing shops and
metal coating facilities.
  This national investment in air
pollution control has paid substantial
dividends. The air in this country is
measurably cleaner than in 1970. The
improvement in air quality has
improved the health and welfare of the
American people, especially those living
in urban areas.
  However, one air quality problem has
proven  particularly intractable. That
problem is ground-level ozone, or, as it
is commonly described,"smog."
  There is little doubt that human
exposure to ozone concentrations at or
above the national health standard is a
serious  concern. According to scientific
studies, ozone concentrations  that may
occur during hot summer days in urban
areas can impair lung functions  in
people with existing respiratory
problems. People in good health can be
affected as well. These effects include
chest pain and shortness of breath. In
addition, it is possible that permanent
lung damage may result from repeated
ozone exposures over a period of years.
  These potential health problems are
especially worrisome because they may
be occurring in so many places.  Over 60
major urban areas in  every part of the
country still do not attain the  national
health standard for ozone.
  The widespread, intractable nature of
the ozone problem has been recognized
for some time. The Clean Air Act
originally required that states develop
plans to attain air quality standards by
the mid to late 1970s. When it became
apparent that the ozone standard would
not be met in many areas by then, the
Clean Air Act Amendments of 1977
called for new plans that would lead to
attainment by December 31, 1982. Areas
with especially serious problems were
given an additional  five years to attain.
But now the final deadline—December
31, 1987—is fast approaching, and it is
clear that many areas are still a long
way from attaining the standard.
  This widespread failure to attain an
important national health
standard—despite the deadline
extensions—is causing concern among
many members of Congress. They are
beginning to look at ways to amend the
act so that the ozone standard will in
fact be attained nationwide at some
future date.
  We at EPA are very concerned about
ozone nonattainment, too. For the last
several months we have been asking
ourselves why this particular air quality
problem  has been so difficult to solve.
Why haven't we met the attainment
deadlines set in the past? What actions
would it take  to meet any new
deadlines set further in the future?
  Probably the most obvious reason for
our past inability to attain the ozone
standard is the nature of the ozone
problem  itself. Unlike most other air
quality problems, ozone is caused by
emissions of an air pollutant—volatile
organic compounds (VOCs)—from a
very wide range of sources. VOCs are
emitted by large stationary sources, like
refineries, and by small stationary
sources, like corner gas stations and
neighborhood dry cleaners. They are
emitted by millions of individual cars
and trucks, and they are emitted when
people use products like paints  and
cleaning solvents  in and around their
homes. In short, our modern society
emits VOCs at work and at play, at
home and on the job, and the enormous
diversity of VOC sources enormously
complicates our efforts to control them.
  For example, because VOC sources
are so diverse, no single control
technology can be applied to more than
a small part of the problem. In fact,
much of the ozone problem is not
amenable to traditional "end-of-pipe"
controls at all. Depending on the source,
a number of different techniques may be
used to control  emissions. Production
processes may have to be altered, or
substitutes may have to be found for
process materials  like adhesives and
solvents,  or people may have to change
their driving habits. In a typical
nonattainment area, some combination
of all these steps—and more—may be
needed to reach attainment.
  To make matters worse, no two
nonattainment areas are exactly  alike.
Emissions inventories, source
characteristics, meteorology, and
geography all vary from area to area,
and those factors will have an effect on
local ozone concentrations. Thus
different techniques have to be
developed to control emissions from
different sources, and different
combinations of techniques have to be

                                       A new deadline is necessary,
                                       but that new deadline should
                                       be realistic and tailored to the
                                       circumstances of individual
                                       nonattainment areas.
developed to attain the standard in
different areas.
  Because VOC emissions are associated
with so many facets of our economic
life, our past progress toward attainment
has been complicated by the economic
growth we have enjoyed.  Since 1970,
the national economy has grown by 44
percent. Over the same period, the U.S.
population has grown by  only 18
percent, but the total vehicle miles
travelled nationwide has climbed by an
astounding 58 percent.
  What happened to VOC emissions
since  1970?  As a result of EPA and state
controls on both mobile and stationary
sources, VOC emissions dropped by 22
percent between 1970 and 1985. Had no
VOC controls been imposed, EPA
estimates that total nationwide VOC
emissions would have grown by 32
  This is an impressive achievement.
VOCs have been controlled  without
impeding the economic growth essential
to the well-being of the United States.
Anticipated  future economic growth, of
course, will  have to be factored in to
any plan that attempts to  attain the
ozone standard by some future date.
  Our past efforts to attain the standard
sometimes failed because  we simply did
not realize all the different kinds of
VOC sources that had to be  controlled.
For example, only recently have sewage
treatment plants  been recognized as a
significant source of VOCs, and only
recently have they begun  to be
controlled. Similarly, hazardous waste
treatment, storage, and disposal
facilities often were not included in
local lists of VOC sources subject to
control. Over the past few years we
have learned a great deal about the
sources of VOCs, and that knowledge
should help  us do a better job planning
for and reaching attainment  in the
  Ground-level ozone is similar, in
some respects, to the acid rain problem.
That is, the pollutant of concern is the
product of atmospheric processes, and
the areas of concern may be affected by
pollutant sources miles away. The
uncertainties associated with
atmospheric transformation and
transportation have complicated past
ozone control efforts in two ways. First,
from a technical perspective, they have
made it very difficult to define with  any
precision how much pollution from
what set of sources has to be controlled
to attain the standard in a particular
area. Second, from a political
perspective,  they have made it more
difficult to reach a consensus  on the
actions needed to solve the problem.
  Our review of past national  efforts to
control ozone has been a valuable
exercise, because it has taught us not
only the root causes of our past failings,
but the necessary ingredients  of our
future success. Based on our past
experience implementing the Clean Air
Act, I believe that any future  ozone
control strategy  should include several
basic components. For example, I
believe a new deadline is necessary, but
that new deadline should be realistic
and tailored  to the circumstances of
individual nonattainment areas.
Furthermore, the strategy should ensure
that the states make steady and
measurable progress toward the overall
goal of attainment.
  The national ozone control strategy
also should contain explicit assurances
that the standard not only will be
attained, but that it will be maintained
in the face of future economic growth.
And the strategy should incorporate
mechanisms for addressing regional
ozone problems when and where they
  Most important of all, the national
strategy should allow the  states
substantial latitude in designing
attainment plans that are  efficient,
effective, and politically acceptable. We
at EPA are committed to the attainment
of the ozone standard  nationwide. But
we recognize that, in some areas,
achieving that goal could  require
extraordinary control actions that may
be costly, socially disruptive, and
politically unpopular. Depending on the
area in question, an ozone control plan
may limit the use of automobiles, or
require the use of alternative,
cleaner-burning fuels, or require the
development of a mass transit system. It
may restrict  the use of certain consumer
products, or it may add to the cost of
basic goods such as bread and gasoline.
Virtually everyone living  in an ozone
nonattainment area contributes directly
to the problem in some way, and
virtually everyone will be affected
directly by the solution.
  Thus it is  essential that the people of
this country understand the health and
environmental values at stake, and that
through their local and state
governments they participate in  the
process of defining local control plans.
In general, the people most directly
affected by local  problems are usually
most capable of formulating effective
solutions. I believe that principle is
especially applicable to the ozone
problem. If people  living  in urban areas
all across the country participate in the
planning and cooperate in the
implementation of local control
programs, I am confident  that we will
move steadily toward our overall goal:
nationwide attainment of  the ozone
health standard,  o

(Thomas is Administrator of EPA.J
                                                                                                        EPA JOURNAL

                                  Answers about  Ozone  Pollution
                                   An Interview with J. Craig Potter
Ozone is not only harmful to human
lungs, but can have an adverse effect on
cash crops. Shown is a soybean field in
To get answers to questions the public-
is asking about ozone pollution and
actions to deal with it, EPA Journal
interviewed /. Craig Potter, EPA's
Assistant Administrator for Air and
Radiation. The text of the interview

\-l We've been hearing a lot about
ozone lately, in the upper atmosphere
and at ground level. What is it?

»v Chemically, ozone is simply a form
of oxygen with three oxygen atoms,
instead of the two found in regular
                                                                     oxygen. This composition makes it very
                                                                     reactive, or unstable, so that it combines
                                                                     with practically every material it comes
                                                                     in contact with. And it's this reactivity
                                                                     that is giving us problems because it
                                                                     tends to break down substances, not just
                                                                     materials, but biological substances such
                                                                     as tissues  and cells as well.
                                                                       This isn't a problem  if the ozone
                                                                     reactions stay in equilibrium. But what
                                                                     we've discovered is  that in the upper
                                                                     atmosphere, where we  need o/one to
                                                                     protect us from ultraviolet radiation, the
                                                                     ozone  is being destroyed by manmade
                                                                     chemicals called chlorofluorocarbons.


And at ground level, where it can be a
harmful pollutant, too much ozone is
being produced by human activities.

U  Is there any difference between
naturally occurring ozone and
manmade ozone?

r\  No, at least not in the sense that
we can tell where they come from.
Chemically, they are the same.
Lightning discharges create some o/one.
but both natural and manmade o/one
are the result of sunlight acting on gases
in the atmosphere. And in fact, the
amount of ozone that occurs naturally is
about the same as the amount of ozone
that occurs from man's activities.
  So where is the problem? The
problem is where the ozone is
concentrated. Manmade ozone is
essentially an urban phenomenon, and
cities are where most of the population
is. People will look  at a map of ozone
nonattainment areas and they see
southern California, they see the East
Coast, they see Chicago and Texas and
other places, and they say "What's the
big deal? Most of the country doesn't
have a problem." The point is that
where there is a problem, that's where
the people an;.

(J  Specifically, what are the health
concerns for ozone?
     Well, as I mentioned earlier, ozone
is highly reactive, meaning that it
chemically combines and recombines
with substances. That reactivity causes
measurable,  physical damage. We've
known for a long time that  it directly
affects the lungs, not only the
mechanical functioning, but also the
mucous membranes leading to the
lungs. We know, too, that ozone causes
tissue damage. And these effects occur
not only to sensitive individuals, but to
healthy  people as well.
  We're also seeing evidence; that
chronic  exposure to o/one also
produces effects. It may interfere with
the autoimmune system. It  may
accelerate aging.
  I  think we tend to forget just how
biologically vulnerable human beings
an;. It sounds dramatic, but you could
say that  we totter on the edge of disaster
all the time just by virtue of the fact that
our bodies run on air, air that may
contain  harmful substances. Ozone is
OIK; of those substances, But our
                                        vulnerability to the air we breathe i.s
                                        one the reasons that EPA i.s so
                                        concerned about air pollution in

                                        vJ.   Are there ozone effects other than
                                        on human health?

                                        A   There are. We have good evidence
                                        that it affects trees and vegetation.
                                        Certainly, we've seen that cash crops
                                        like soybeans  have been  affected. Ozone
                                        also seems to accelerate the aging of
                                        many materials, again as a result of its
                                        chemically reactive nature. For example,
                                        it causes  rubber cracking, dye fading,
                                        paint erosion. Generally,  it has a
                                        tendency to accelerate effects on  other
     How is ozone different from
other major air pollutants that EPA
deals with?

r\  In one basic respect, it's totally
different. O/one is what we call a
secondary pollutant. Unlike sulfur
dioxide or nitrogen oxide or participate
matter, ozone is not emitted directly
from a source. Instead, it's formed
primarily as a result of the  interaction
between hydrocarbons and  nitrogen
dioxide in sunlight.
  So there are no ozone emissions per
se. What is actually emitted are the
hydrocarbons and the nitrogen oxides
and these combine with other
substances in  the atmosphere and the
whole mixture stews in the sun to
produce ozone.

CJ   Is this what makes ozone so
difficult to manage?

r\   Yes, among other reasons. With
sulfur dioxide, for example,  we use
what we call Gaussian modeling, where
we actually measure plumes and predict
how they will disperse in the
atmosphere. Well, we can't  do that with
ozone. We have great  difficulty in
modeling ozone concentrations and
predicting where  it will appear because
it's so dependent on weather conditions
and because hydrocarbon emissions
come from so many sources. Ozone
levels are not so much the result of
emissions from stacks, as they are the
result of things that happen after those
emissions occur.
  So all this casts a lot of uncertainty
into measurements and predictions, and
calls for much more sophisticated
modeling techniques.
{j   Is it possible for EPA to regulate
ozone effectively, given these basic

/\   Well, basically what we have to
work with is the ambient standard itself.
which the Clean Air Act requires  us to
set at levels  protective of human health.
Right now, that standard is set at  0.12
parts per million, but some studies
suggest that  it  may not be protective
  One of the things to realize here is
that  ozone is regulated under the  same
categories we have for all air
pollution—that is. stationary sources
and  mobile sources. But because ozone
is not emitted  directly, we've had to
develop some  pretty complicated
mechanisms for getting at it, such as
requiring inspection and maintenance
for automobiles, or establishing
emissions controls on certain industrial
processes, or even as a last  resort,
prohibiting construction of new
facilities that would emit hydrocarbons.
  There's no question that what we've
done so far has been effective. In  places
like  California, exposures are much  less
than they used to be. The way the law
works, though, is that if you have any
levels above the ambient standard, then
you  are in violation of the law. And in
certain instances—Los Angeles, for
example—we have serious reservations
that  they will ever be able to meet the
  So the real question is not how
effective we  are, but whether this
approach is  working. Do we need  to
consider the possibility that we ought to
be dealing with this air pollutant
differently than the others? In  other
words, is the ambient standard really
the way to go?
  As we begin to understand ozone
better, I think we're going to realize  that
the nature of this stuff is such that we
will  never meet the standard totally  in
some places. We may also find that we
have problems in areas where we  never
expected it. Ozone moves around  the
atmosphere in funny ways, so  that it
can show up in places where there
aren't even any hydrocarbons being
emitted. The name of that headache  is
ozone transport, and it's a real issue,
particularly on  the East Coast,  where
weather conditions routinely push
ozone north  along the coastline. A lot of
places in New England end up coping
                                                                                                          EPA JOURNAL

with an ozone problem that isn't even
theirs, that may have come from as far
away as Washington or Baltimore. But
the law says that they are the ones out
of compliance. How do we deal with

\_1   Right now, we depend on
regulations and technology to control
ozone. How much further can we go
along that  route?

r\  Well,  our proposal to require
equipment on cars to control gasoline
vapors—the so-called onboard vapor
controls—goes pretty far. It's  certainly
the biggest jump we can make right  now
to deal with the problem of emissions
from refueling. We estimate that
onboard controls and other volatility
regulations, along with normal vehicle
turnover, will get us a nationwide ozone
reduction of 10 to  12 percent over the
next 10 years or so.
  And 1 think there is still room for
some technological "fixes." For
example, we're very interested in
alternative  fuels like niethanol, othanol,
and compressed natural gas because
they've already shown they contribute
substantially less  to ozone formation
than conventional  gasoline fuels. And
that's when they're used in engines
really designed to run on gasoline. In
engines designed specifically for them,
the clean air benefits would be
enormous.  Methanol is especially
attractive because it can be produced
from coal, natural gas, and even biomass
materials, and all the alternative fuels
could be readily available. Not only
that, but they have the potential to
reduce carbon monoxide and  participate
emissions as well.
  Aside from improving fuels, of course,
we can also work on other engineering
aspects of automobile technology. And
there are major Improvements we can
make in mass transit technology  and
convenience, too.
  But I think you are right to ask how
far we  can go with technology. There's
probably always a little more we can do
with automobiles, but we have to ask
ourselves what we're gaining for the
cost involved. That's really the question
we're dealing with.
     What other controls are we
talking about? Will future reductions
depend on changes in lifestyle or
personal habits?

r\   Yes, I think ultimately we will be
talking about lifestyle issues. That's a
part of our dilemma here. People who
are concerned about air quality and
environmental problems in general
frequently cite the desire of the
American people  to have a cleaner
environment. True, they do. But the
American people  also want to have cars.
  One of the things we have be honest
about is that Americans tend to want to
drive around in automobiles—alone.
Now we  can control cars, and we  have
controlled them to a very high degree.
But we are going to reach a point  when:
we can't  control them anymore on a
vehicle-by-vehicle basis, and the fact is
that the actual vehicle miles traveled in
this country are increasing at a
substantial rate. And the question then
will be: How do we regulate or deal
with that?
  Places  like southern California  rely
absolutely on the  automobile. They also
get ozone buildup simply from the fact
that it gets trapped by the Santa Monica
Mountains in Los Angeles. It's the
                                        The billows of smoke and steam rising
                                        from this oil refinery may look tike smog
                                        in the making, but the real culprit in
                                        smog formation is volatile organic
                                        compounds (VOCs), which are invisible.
                                        Controls are helping to reduce the
                                        pollution, including VOCs, from
                                        refineries, chemical plants, and other
                                        classical situation of land breezes
                                        during the night, sea breezes during the
                                        day. The air moves off the coast at
                                        night, conies back in during the day,
                                        and this happens day after day after
                                        day. It's always happened in I,us
                                        Angeles, whether people were there or
                                        not. There's only so much we can do
                                        with direct  controls. Ultimately, we're
                                        going  to have to turn to adjustments in
                                        the way people live their  lives.
                                          I suspect  that the same  Americans
                                        who want environmental
                                        protection—from ozone, among other
                                        things—are  not going to like the notion
                                        that they may have to carpool, or even
                                        put up with nondriving days. And those
                                        are the kinds of things we're talking
                                        about, the so-called draconian measures
                                        we may have to take to meet the o/.one
                                        standard.  In my view, these will have to
                                        be decided  at the local and state levels,
                                        not by the federal government. We need
                                        to create a certain amount of flexibility
                                        to adjust the program to local
     How many areas are expected not
to attain the standards by the December
31 deadline?

r\   It varies. This is because some
areas were extension areas and some

were not. But there are over (>(). Let me
explain that we measure attainment
status basically by calculating a
three-year average of exceedances. So
right now, we are working on the basis
of data from 1984 through 19H(>. You
may have  heard people talk about 19K!i
being a terrible year for o/.one. and as
result of averaging the next three years
instead, we've seen several areas go
back into attainment.
  The  point to recogni/.e, though, is  that
the original deadline for attainment was
1975, 12 years ago. That was extended
to 1977. Then the standard was reset,
actually raised, in  1979, at which point
the attainment deadline became 1982.
Some of the areas did not attain in 1982,
either, and they were given five-year
extensions. The 1987 (leadline is not the
first deadline we've come up against.
Many of these areas have been extended
two or three times. So what we're
saying is that it's  not simply a  matter of
not having met the; standards, it's a
matter of not having  met them in some
cases for 12 vears.
     What will EPA do about areas not
meeting the December compliance date?

• ^  Well, we want to encourage
compliance as much as we can. The
problem is. most of the large stationary
sources arc already controlled and now
we're facing controls on smaller sources,
including  places like auto body shops,
dry cleaners, even  bakeries. Pollution
controls for those sources will be very.
very expensive. And also, a .significant
amount of hydrocarbons are emitted just
from everyday consumer
products —tilings like paints,
deodorants, household  cleaners.
  As far as mobile  sources, we talked
before about equipment controls for
cars. Then: may  be other things we can
do. such as establish some general
standard to enhance inspection and
maintenance (I/M)  programs. Basically,
though, it  we want to attain the o/.one
standard by the deadline, it's going to
require drastic measures in many  urban
areas. Under the Clean  Air Act,  this
could include banning  new construction
and cutting off funds for highway  and
sewage treatment plant construction.
The most extreme action we could take
would be to step in and impose our own
transportation controls  at the local level.
We can guess how  popular that  would
  To answer your question specifically,
though, right now we are in the process
of developing what we call a "post-87"
strategy. A lot of it will involve state
implementation plan (SIP) procedures
because those are the mechanisms that
govern our interactions with states and
local communities. For example, we've
already notified certain areas that,
because they have not implemented
their SIPs in a timely fashion, we may
have to disapprove them.
  These disapprovals and  sanctions are
something EPA will have to deal with,
whether or not Congress takes any
action. And Congress is part of it. too.
We are talking with them about how we
might change or adjust the law to deal
more effectively with ozone.

 v-t  Somebody could look at this
history of extensions you've recited and
conclude that EPA is not really serious
about attaining the ozone  standard.
How would you answer that?

 r*  It's very much a misinterpretation
of what has happened to say that we're
not serious. Bill Ruckelshaus used to
warn us not to set ourselves up for
failure in this business. And to some
extent. I think that's  the question we're
asking here. Have we set ourselves up to
fail with a standard that we can't meet?
Not because of any efforts we make  or
don't make, but simply because there
are circumstances beyond  our control?
  Los Angeles,  again, is my example.
The Indians for years called it the
"Valley of Ten Thousand Smokes."
Smoke and smog  have always collected
there because of its natural conditions,
because of the tendency for inversion
layers to form.
  So I  don't think it's accurate to say we
haven't tried to meet the requirements
of the law. I do think there are more
things  we can do. There's  always more
you can do. But to translate that into
saying we really have not  made an effort
is wrong. With  ozone, we're dealing
with something we're going to have to
face with every other pollutant, too,
We're trying to balance the need for
environmental protection against the
need for some kind  of economic growth.
The standards set 15 years ago never
considered how we would deal with
growth. So the issue in this generation
of pollution problems is: "How  can  we
have it both ways? How can we protect
the environment,  while enjoying the
economic growth we depend on?"
\-l  We've talked about institutional
and government changes. What can
individuals do? How are they involved
in the ozone problem?

r\  First of all, I think people need to
be aware of what the cause of the
problem is. It's in large part these
hydrocarbon emissions. And putting gas
in your lawnmower, or painting your
house with oil-based paint, or stripping
a piece of furniture—those simple.
everyday operations have the potential
to create ozone because they involve the
evaporation of volatile  organic:
compounds into the air. But you have
some substitutes. You can use
water-based paints, for example. People
can minimize their contributions to
o/.one.  I wouldn't want to overstate it. ot
course, but they can do something.
  But the  biggest contribution is to
improve the way we use  automobiles.  If
you can use a car to go somewhere with
six people in  it,  presumably that
removes five cars from the road. That's
five cars that would have been emitting
hydrocarbons, carbon monoxide, and
particulates. Carpooling and using cars
more efficiently  is  bound to have  an
impact on the ozone problem. But you
can see that we're talking about
planning our lives  to minimize
pollution, we're talking about major
lifestyle changes.

\-i  But do you think people will
change? Is it possible that we will just
have to live with ozone?

*»  In some  areas, I think  that  may be
the case.  But there may be ways to get
around it. Our basic responsibility at
EPA is to  protect health.  That means we
want to limit  people's exposure to
ozone.  It's important to realize that
ozone is not a year-round problem. For
the most  part,  it's a five-month, summer
phenomenon. It  occurs during the
period  when people are more likely to
be outside. Well, maybe people will be
willing to live with temporary
inconveniences. Maybe we  can adjust
living patterns so that people won't be
exposed to ozone during the worst
times. There's a  lot people can do. n
                                                                                                          EPA JOURNAL

                                         Its  Nature  and
                                                  by Bob Burke
    Oy.one or "smog" is just one of six
    major air pollutants that EPA
regulates, but it i.s by far the most
complex, intractable, and pervasive. It is
also an extremely difficult pollutant to
regulate effectively.
  Many more Americans live in  areas
that suffer unhealthy levels of ozone
than are affected by any other air
pollutant. Adverse health effects have
been observed in tesl animals  and  in
Ijumans even at exposure levels  only
slightly higher than federal  health
standards for o/.one. hi fact.
concentrations of the pollutant are often
far  higher than federal standards in
many urban  areas of the country.
Permanent damage to respiratory
systems and  other adverse health effects
are  known to occur from repeated
exposure to o/.one at such high levels.
  O/.one  is difficult to control because
of the extremely large  number of
individual sources that can  contribute to
its formation, and because much of the
pollution these sources produce  may be
transported to areas long distances

Ozone is Pervasive

One way to put (he unique problems of
ozone into perspective is by comparing
the  number of Americans experiencing
unhealthy levels of the major air

Metropolitan Area Populations Subject
to Air Pollution Levels above Federal
Health Standards in 1985

  Ozone	76.4 million
  Particulate matter	47.5 million
  Carbon monoxide	39.6 million
  Nitrogen dioxide	  7.5 million
  Lead	  4.5 million
  Sulfur dioxide . .        2.2 million
  While these comparative figures are
important indicators of the magnitude of
ozone pollution, they actually
understate the relative public health
impact of ozone. Some of the pollutants
(such as lead and carbon monoxide) are
highly  localized. For example, they tend
to concentrate only along roadways, as a
 Being measured on a spirometer are the
 volumes of air that can be moved in
 and out of the lungs following exposure
 to low levels of air pollution. Ozone
 pollution impairs normal lung
 functioning and  reduces the ability to
 perform physical exercise.
consequence of motor vehicle traffic, or
near other specific sources that emit
them. Therefore, if the standards for
these pollutants are exceeded in a
county containing a million or more
people, the number of county residents
who actually experience such excess
exposure levels may be only a fraction
of this total population.
  By comparison, if o/.one standards are
exceeded in the same county, it is  likely
that  all, or almost all, county residents
will  experience significant ozone
exposure. High concentrations of o/.one
tend to pervade an entire county or
region, and may extend to areas far

Ozone is Elusive

Unlike the other major air pollutants,
ozone is not emitted directly by specific
sources. Instead, it is  formed in the air
by chemical reactions from nitrogen
oxides and  volatile organic, compounds
(VC)Cs).  In each area,  the sources of
o/.one may  consist of  literally thousands
of large and small stationary sources in
addition to  motor vehicles—the major
mobile source  contributor. Sources of
VOCs include  (t) products of
combustion from motor vehicle engines
and other machinery: (2] vapors of
gasoline emitted by motor vehicles,
service station  pumps, gasoline refineries
and  petroleum storage tanks: and
(3) chemical solvent vapors emitted by  a
host  of commercial and industrial
sources such as dry cleaning
establishments, solid waste facilities,
and metal surface  paints.

Ozone Transport

Effective controls are also hampered by
the phenomenon of o/.one transport.
This also accounts for much of the
pollutant's pervasiveness  and presents a
range of practical  difficulties to

                                       Scientists in EPA's laboratory in
                                       Corvallis, Oregon, inspect pine seedlings
                                       for ozone damage.
                                                                                                       EPA JOURNAL

  Most of the other pollutants that EPA
regulates tend to concentrate in the air
in some proximity to the sources that
emit them. Not so with ozone.
Emissions of VOCs are, in  fact, often
carried distances of hundreds of miles
from these sources, resulting in high
concentrations over large regions.

The Effects of Sunlight

The reactions that form ozone are
stimulated by sunlight, so  that  ozone
reaches peak levels in most of the
country during the summer
months—particularly when air is
stagnant for extended periods. This type
of pollution first gained public attention
in the 1940s as Los Angeles "smog." The
highest concentrations have long been
found in  that city, but very high
concentrations also began to develop  in
other areas as motor vehicle travel
increased following World War II.
Ozone generally affects all areas that
have extended periods of abundant
sunlight coupled with high emissions
from motor vehicles—a major source  of
both VOCs and nitrogen oxides.

Health Effects

Ozone severely irritates the mucous
membranes of the nose and throat,
impairs normal functioning of the lungs,
and reduces the ability to perform
physical exercise. In general, the
pollutant's adverse health  effects
depend on a combination of factors: the
amount of ozone in the air, and the
frequency and duration of exposure.
However, the effects of ozone at any
concentration are felt most by people
with asthma, chronic obstructive lung
disease (such as emphysema), or
allergies, and by persons who regularly
perform strenuous exercise outdoors.
Sensitive individuals may  experience
adverse health effects from even
relatively low concentrations of the
pollutant. It also appears that ozone in
combination with other pollutants
presents greater potential respiratory
effects than any single air  pollutant
  The health effects of ozone have been
confirmed in closely controlled and
monitored laboratory testing programs
and in epidemiological surveys of
population groups that are routinely
exposed to high concentrations of the
pollutant. When  ozone levels are up,
Adverse health  effects have
been observed in test animals
and in humans even at
exposure levels only slightly
higher than federal health
standards for ozone.
hospital admissions go up, there is more
sickness generally, and physical activity
becomes difficult even for healthy
individuals. The most vulnerable suffer
extreme discomfort and distress.
  Under closely monitored exposure
conditions, people with perfectly
healthy respiratory systems have been
found to suffer adverse effects and
reduced physical  capacities in response
to even relatively low concentrations of
ozone. Chest pains, coughing, wheezing,
pulmonary and nasal congestion, labored
breathing, sore throat, nausea, and other
disfunctions begin to occur when ozone
reaches higher levels. Invariably, the
higher the ozone level, the more severe
the symptoms are.
  The duration of exposure directly
influences how long an individual feels
the effects of ozone pollution—i.e., the
longer the period  of exposure, the
longer it takes to get back  to normal
once an individual is removed from the
polluted environment.
  Animal toxicology studies have
shown that ozone can interfere with the
body's immune system. This contributes
to lowering the body's resistance to
infection and increases its susceptibility
to acute respiratory infection. Animal
test data also show that there is a "point
of no return,"  after which  adverse
effects of ozone cease to be reversible.
These study results show that exposure
to high levels of ozone—on repeated
occasions that span a long period of
time—can cause or contribute to
permanent damage to the lungs.

Effects on Agriculture and Forests

In addition to  a growing body of
evidence about the health  effects of
ozone, there are recent findings about
ozone's adverse effects on  cash crops,
forests, and other forms of vegetation.
Since the late 1970s, EPA has conducted
extensive field surveys of ozone's effects
on agriculture  through the National Crop
Loss Assessment Network  (NCLAN)
study. This study puts the agricultural
loss from ozone pollution  at between $2
and $3 billion each year. One set
of studies showed that  even levels of
ozone below the health standard can
reduce several major cash crops by as
much as 10 percent a year. Additional
studies conclude that higher ozone
levels have reduced plant yield in
tomatoes by 33 percent, beans by 26
percent, soybeans by 20 percent, and
snapbeans by up to 22 percent.
  Conclusive statements about the role
of ozone  and other air pollutants in
damage to forests are not possible  at
present because data are limited. Many
scientists, however, think ozone is a
major contributor to the decline in
growth of many species of trees. The
existing data, though limited, do suggest
strongly that ozone pollution has played
a role in  the loss of at least some forests.
One study in the San Bernardino
Mountains of California concluded that
ozone was the cause of foliar injury,
premature leaf drop, decreased radial
growth and photosynthetic capacity,
and death by bark beetles in ponderosa
and Jeffrey pine. Repeated ozone peaks
near the standards have been implicated
in damage to white pine in the eastern
United States and Canada, and reduced
growth rates for the red spruce at
numerous high elevation sites in the
Appalachian Mountains.

Ozone: the Twentieth-Century Pollutant

Ozone has been and will continue to be
the nation's major air pollution
challenge in the foreseeable future. It
adversely affects far more people than
does any other kind of air pollution,
and very specific health effects have
been well documented in both humans
and laboratory animals. Long-term
exposure to high concentrations of
ozone is  particularly threatening to
certain vulnerable portions of the
nation's population. It is also clear that
even relatively modest  concentrations
can damage forests and diminish the
quantity  and quality of several
agricultural crops.
  All air pollutants are at least in  part
products of modern industrial society,
but ozone is truly a twentieth-century
pollutant since it  is essentially a
byproduct of the massive and dispersed
transportation and industrial systems
that have emerged in this nation over
the past several decades. It also seems
likely that it will take what's left of this
century to bring ozone  pollution under
full control, o

(Burke is on the staff of EPA's Office of
Public Affairs.)

Los  Angeles to
by Roy Popkin
    People who think of traffic
    and traffic-related  pollution  as
a strictly modern irritation might do
well to consider New York City in 1894.
Half a million horses and their
associated carts and carriages jostled for
space with pedestrians. Not only were
the streets littered with tons of ripe
manure, but the methane gas generated
as it rotted was literally making people
sick—in today's terms, a case of solid
waste disposal problems complicated by
volatile organic compounds (VOCs) in
the air. The solution back then was
straightforward. The city set up the
"\Yhite Wings"—a corps of
white-uniformed street sweepers whose
special function was to rid New York of
the equine public health menace. But
controlling transportation-related
pollution is not so simple anymore.
Today. New York and scores of other
major metropolitan areas face the
problem of ground-level ozone caused
 Some changes in life styles may be
 necessary in certain areas to control
     us pollution. For example, more
 people may use computers at home to
 do their jobs instead of driving to offices

 Carl Lewis, Lane 5, wins the men's
 100-meter dash at the 1984 Los Angeles
 Olympics. The city took special
     ures that reduced smog so that it
 would not hamper athletes'
 performance durino, the Olympics. A
 12 percent drop in ozone levels was
     ,ured during that time.
                                                                                            EPA JOURNAL

mostly by cars, and it will take a lot
more than brooms and shovels to
eliminate it.
  Ozone is the principal ingredient of
smog, and has been shown to seriously
affect the human respiratory system, as
well as damage crops, forests, and
manmade materials. It's usually not
emitted directly into the air from any
individual source: instead, it is
produced in the atmosphere by complex
chemical reactions between VOCs and
nitrogen oxides. These reactions  are
stimulated by sunlight and temperature,
so that peak ozone levels typically occur
in warmer climates and  during warmer
times of the year. Although ozone has
been regulated since  1971, 62 areas.
mostly major cities, have not yet
attained the national  standards for
ozone levels, and most are not expected
to meet them by the statutory deadline
of December 31, 1987.
  Unfortunately, reducing ozone levels
is a lot harder than sweeping up manure
piles. Because the atmospheric reactions
that produce ozone take time, it can
often appear many miles from the YOC
and nitrogen oxide emissions that create
it. In addition, these  "precursor"
emissions come from hundreds ot
different  sources, including dry
cleaners, bakeries, auto body paint
shops, household consumer products,
the burning  of fossil fuels, and most
importantly, the automobile. One-third
to one-half of all VOC and nitrogen
oxide emissions come just from using.
fueling, and maintaining our motor
vehicles. It may take  extraordinary
changes in cars and car-centered
lifestyles to  reduce ozone concentrations
to the 0.12 parts per million level
mandated by the Clean Air Act, not
only in typical pollution centers such as
Now York, l.os Angeles. Houston, and
Atlanta, but also in areas like North
Carolina, where new development is
increasingly fouling the  air.
  According to  Tom  Helms of EI'A's
Office of Air Quality Planning and
Standards, many areas will have to
implement a variety of innovative
strategies over the next 20 years.
Programs already in place, such as
stationary source controls, inspection
and maintenance (I'M) for cars, and
changes in industrial processes, are only
the beginning. At the very least, the use
of cars must be sharply reduced in
metropolitan areas, and  Helms does not
scofl. for example, at such suggestions
as New York City's proposal to charge
commuters a daily $10 fee for bringing
autos into lower Manhattan.
  New York City's ozone problem  is not
its alone, of course. William Baker, chief
of EPA Region 2's Air Programs branch,
sees the city as  a victim  ol "o/.oiie
precursor transport" whose efforts  to
further reduce ozone levels are
frustrated by its own huge population,
by its position in the urbanized
Northeast corridor, and by atmospheric
pollution from upwind states. These
and other problems have resulted in a
41-percent shortfall in the ozone
reductions anticipated by the area's state
implementation plan (SIP). Thousands
of tons of VOCs annually reach the air
over the  New York-New  Jersey
metropolitan area from such everyday
sources as cars, gasoline  pumps, paints
and coatings, dry cleaners,  and
consumer/commercial products, as well
as from noncomplying industrial
stationary sources.(SIP)
  New York and New Jersey have 1 M
programs that exceed  federal
requirements by including strict
emissions limits, heavy-duty gasoline
vehicles, and state-wide inspection for
tampering. Even the ubiquitous New
York City taxis  are inspected three times
a year. Even so, the additional ozone
reductions needed in order to meet the
ozone health standard are still several
years away, and they are unlikely to be
greater than originally anticipated. It's
possible  that controlling  YOC emissions
from sewage treatment plants will help
reduce ozone levels, but according to
Baker, automobiles still cause about half
the ozone problem even though more
than 80 percent of New York commuters
already use mass transit.  Ratcheting
down on mobile sources  would perhaps
mean higher gasoline taxes.
automobile-free zones, and  odd even
driving days in the city. "Solutions that
involve people  or businesses leaving the
city will  be painful," he says, "but
someone has to bite the bullet."
  Biting  the bullet is something l.os
Angeles has been facing for a  long  time.
Year-round sunshine,  a car-centered
lifestyle,  and a  geographic location
favorable to air  inversions all combine
to help Los Angeles violate the ozone
standards 140 times a  year. Still, says
David Calkins of EPA  Region 9. this is
an improvement over the past, when
there were days so smoggy that  people
on City Hall's twenty-second floor
couldn't  see the street below them, lie
credits state and local efforts, as well as
EPA's, for bringing the number of
exceedance days down from over 301) in
the 1970s to the present 140. "The
number of such days  and the size ol
thi! population  involved  is continuing
to decrease." he says, "but not enough.
They've been doing things for 10 years

that are far ahead of the rest of the
country. For example, they have nozzle
controls on gas pumps that catch at
least 84 percent of the VOC emissions
from gas stations, and the nozzles are
capped as soon as someone reports
them to be defective. The state's
inspection and maintenance program
enforces extremely high standards.
Finally, Los Angeles is trying to
encourage use of mass transit by
allowing smaller parking areas for new
buildings if the owners provide bus
service or tokens so the tenants can use
public transportation."
  Nevertheless, it will take drastic
changes in the southern California
lifestyle to reduce ozone to acceptable
levels. There are some 12 million
people and 7 million cars in and around
Los Angeles, but even with all the cars
removed, the problem would still  be
only partially solved. Los Angeles
would still fall victim to its sunlight
and continued population  and
industrial  growth. Planners expect the
area to grow by three million people in
the next 10 years  alone; the places they
work and the products they use will be
new sources of emissions that turn into
urban smog. "If the growth in the
numbers of cars and population is not
offset," warns Calkins, "the ozone levels
may start to increase again, rather than
continue to drop." Among his
suggestions are alternative fuels, such as
methanol or ethanol (the city is already
trying these on some buses); greater use
of mass transit; and a massive lifestyle
switch to teleconferencing and working
at home with computers rather than
going to an office.
  Joanne Aplet, a planner for the South
Coast Air Quality District,  agrees with
Calkins that the solution has to come
from improved technology and lifestyle
changes. She looks for technology to
produce practical electric cars, electric
motors to replace small
gasoline-combustion engines, and
emission-free coatings and solvents for
the workplace.  "In the short-term," she
says, "we are going to ratchet down on
everything we already are doing. What
we will have to do is find  ways to
tighten our control over emissions from
the many small businesses and
industries that keep proliferating around
here. If this makes living here more
expensive and more difficult, perhaps
the reaction may force the  technological
advances we need over the next 20
  Although its industrial emissions are
more of a problem than its cars,
Houston like Los Angeles suffers from a
surplus of sunshine and hot weather.
According to Becky Caldwell of EPA's
Region 6, Houston has been a
nonattainment area ever since Texas
began monitoring its air. Nonetheless,
there has been considerable progress
towards the VOC emissions reductions
called for in the Texas SIP. The Texas
Air Control Board says that Harris
County, where Houston is located, has
reduced VOC emissions by 45.8 percent,
and that peak ozone concentrations
have dropped by 21 percent since 1980.
  Even so, says Caldwell, controls on
industrial emissions will have to be
tightened further; there is need to
improve enforcement of anti-tampering
and inspection and maintenance
programs, as well as improve the city's
rapid transit system. Mandated use of
alternative fuels would have a
significant impact in terms of cleaner
air. Until then, she adds,  respiratory
ailments will continue to increase as
ozone levels rise during the Gulf Coast's
overheated afternoons.
  Atlanta is another sunbelt city whose
ozone problems are among the  nation's
worst. As elsewhere, more people mean
more cars, and Atlanta's population has
boomed. In fact, some Atlantans wryly
joke that Atlanta's cars alone throw
more pollution into the air than did
General Sherman's fires when he
burned the city during the Civil War.
Still, the new Atlanta subway system is
attracting a significant number  of riders,
and Tom Lyttle of EPA Region  4
believes that expanded use of public
transportation and an improved I/M
program may ultimately bring Atlanta
within desired ozone limits.
  Less optimistic, however, is the
Atlanta Constitution. In a July 24
editorial, the paper said:

     ...Ozone pollution is a
     serious problem in these
     parts. The feds say it
     sometimes hits hazardous
     levels in metro Atlanta. It can
     cause respiratory problems in
     humans. Yet every time the
     EPA moves toward specific
     fixes, the dodging
     begins...Meanwhile, sigh,  the
     great majority of metro
     Atlantans...who have
     everything to gain from
     strong ozone pollution
     controls continue to wait.
  Even areas not typically associated
with urban congestion and pollution are
starting to feel the ozone problem as
booming industrial growth and
residential development create more
local VOC emissions. The
Raleigh-Durham area, for example, is an
ozone problem waiting to  happen.
According to EPA's Tom Helms,  whose
office is right in the middle of the
region, ozone has already joined  carbon
monoxide as an increasingly serious
concern.  "We hear a lot about the West
and the Sunbelt," he says, "but ozone is
also going to get worse in  places  like
this. When I came here, the main road
was easy to travel. It's now choked with
a 100- to 125-percent traffic increase,
and they're going to have to double its
width. One firm alone is planning to
bring 1,500 new employees into the
area. That means more cars, more use of
VOC-emitting household and other
products. North Carolina better start
doing something now about the cars,
and their refueling and gasoline
  In  the meantime, cities big and small
continue their battles not only against
ozone, but also against the December 31,
1987, attainment deadline. The hope is
that Congress will realize that the
original deadline did not sufficiently
consider variations in  local meteorology
and unanticipated growth  and
development patterns. Although
deadline extensions of  three to 13 years
are being considered, a Los Angeles
air-pollution official recently expressed
the hope that the city would have clean
air by the year 2020. Tom  Helms also
hopes that revised EPA ozone policies
and Congressional actions  will provide
enough flexibility to sustain cities
through a long,  hard effort. "EPA has no
silver bullet," he says, "no guidelines
that say you do these five  things  and
you'll be OK. Some hard decisions will
have to made, perhaps  millions of
people will have to live, work, and
travel in  ways far different from the  way
they do today. It will probably be
expensive. But if they don't change,  the
price they pay may be their lungs, or
even their lives."  o

(Popkin is a writer/editor in EPA's
Office of Public Affairs.)
                                                                                                         EPA JOURNAL

                                     Finding  Technologies to
                                     Control  Ozone  Pollution
                                     by Jack Lewis
EPA has proposed that auto
manufacturers be required to install
onboard equipment on new
gasoline-powered vehicles to control
VOC emissions that occur during
refueling. Pictured is a diagram of an
onboard control system. During
refueling, vapors from the gas tank are
routed through a hose at the top of the
fill neck into a carbon canister for
collection and recycling into the engine,
thus avoiding their release to the air
through the fill  neck.
   The Clean Air Act of 1970 required
   EPA to set National Ambient Air
Quality Standards (NAAQS) for various
pollutants, including ozone. Ambient
standards are "health-based," which
means they have to be set at a level
sufficient to protect public health with
an adequate margin of safety.
  EPA, founded in 1970. set its  first
ozone standard in 1971. Health  data
available at that time indicated that the
maximum amount of ozone to be
permitted for one hour one time daily
should h<: 0.08 parts per million (ppm).
New health data, gathered through
scientific research, led to a revised
ambient standard of 0.12 ppm in 1979.
  The setting of the first and second
NAAQS defined what 'nonattainmenf"
of health-based ozone standards meant
on a nationwide basis. Then it was  up
to EPA and to state governments to
decide what needed to be done, in
general, to improve air quality and what
specific; technological steps might he
taken to reduce ozone-related emissions
and increase attainment levels.
  Both NAAQS were targeted tor
achievement through the application of
controls on stationary and mobile
sources of ozone-generating smog
"precursors." These precursors an1
volatile organic: compounds (YOCs),
                                     Onboard Vapor Control System
which combine with other pollutants
under solar influence to create
ozone-containing smog, a  major
pollution problem in many heavily
populated urban areas.
  In general,  the stationary sources of
VOQs—which vary considerably from
area to area—are under the control of
state governments. Mobile sources, such
as cars, trucks, and other vehicles
requiring uniform levels of nationwide
control, are the regulatory responsibility
of EPA.
  EPA also has responsibility for
stratospheric  ozone, a valuable global
resource not to be confused with its
troublesome earthboimd counterpart. It
is ironic that  an excess of  o/one close to
the surface of the earth is  responsible
for one environmental
problem—namely, smog-  while a  dearth
of the same substance in the upper
atmosphere is currently the source of
international  concern, tor altogether
different reasons.
  It should be noted that the actual
chemistry of smog formation is
extremely complicated. There are
variations according to temperature
level, quantity of sunshine, and wind
patterns. Also, substances  otiier than
YCXIs play a role in the photochemical
reaction that generates  o/one. Prominent

                                       Various new technologies,
                                       most notably the catalytic
                                       converter, have led since the
                                       mid-1970s to major reductions
                                       in tailpipe emissions of VOCs.
among these are nitrogen oxides. EPA
has determined, however, that VOCs
should be the principal target of efforts
to control ozone-containing smog in
most cases.
  Also exceedingly complex is the
synergy between regulatory efforts to
control emissions and  trends in the
world of  technology and engineering. In
some cases, the emission standards EPA
sets are "technology-forcing." In other
words, the standards set are so stringent
that technological innovation is
necessary for them  to be achieved.
  Such was the impact upon the auto
industry  of ambitious Clean Air Act
goals set  in 1970: Congress called for a
reduction in automotive carbon
monoxide and  hydrocarbons (including
VOCs)  by over 90 percent from
uncontrolled levels, and reductions  in
nitrogen  oxides by  75 percent. This, and
other goals set  in later years, virtually
forced the development of the catalytic
converter and other automotive
  All these strenuous efforts have
brought substantial improvements in air
quality. From 1970 to 1985, VOC
emissions fell by 48 percent. But the
urban smog problem continues to
frustrate  the  experts. As of October
1987, EPA estimates that over 60 major
metropolitan areas  are still not in
compliance with the federal standard
for ozone. Furthermore, the Agency
predicts that more than 35 of these areas
will probably still fall  short of
attainment by the end  of 1987.
Mobile Source Controls

The fumes from internal combustion
engines contain many VOCs that, when
released into the atmosphere, interact
with other gases  in the presence of
sunlight to generate the ozone
components of urban smog.
  Various new technologies, most
notably the catalytic converter, have led
since the mid-1970s to major reductions
in tailpipe emissions of VOCs, as well
as the nitrogen oxides also linked to the
smog problem. In fact, the use of the
catalytic converter on passenger cars
and light trucks became virtually
universal by the early 1980s as the auto
industry scrambled to meet new EPA
regulatory deadlines. Unfortunately, its
effectiveness has in many cases been
undermined by motorists who fouled
the devices with  leaded gasoline or by
mechanics who illegally removed them.
  Another step toward VOC control also
dates back to the mid-1970s. EPA (and
states to which EPA has  delegated
primary enforcement responsibility)
ordered companies responsible for bulk
transfers of gasoline to put control
equipment on storage tanks and other
equipment used in  such  transfers to
control evaporative losses.
  More recently,  1980s technological
advances have led to the introduction of
sophisticated computer-controlled
emissions reduction and fuel delivery
systems. In particular, there have been
dramatic improvements in fuel injection
systems over the  past few years.
  A few states also have required
service-station owners to install vapor
recovery systems on gasoline pumps.
These are the  somewhat  unwieldy but
by now familiar devices that keep VOC
fumes from escaping as individuals
refuel their vehicles in some
communities. Their use will continue
for a time in certain areas.
  The objective vapor recovery systems
were intended to meet will most likely
be achieved nationwide through a new
method of VOC control recently
proposed by EPA. The Agency's
proposal  would require automobile
manufacturers to install onboard
equipment on all new vehicles to
control VOC emissions that  occur
during vehicle refueling. This
equipment would be a modification of
onboard canisters that have  been used
since the early 1970s to control other
types of evaporative emissions from fuel
tanks and carburetor systems.  Redesign
of existing canisters will permit control
of refueling emissions from  individual
mobile sources without any
inconvenience to consumers at the
  EPA  estimates that these new onboard
controls will add about $19  to the cost
of new vehicles, but will save  drivers
approximately $5  over the lifetime of
the vehicle in the form of recovered fuel
vapors. Thus, the  net cost per  vehicle
owner will be about $14: a small price
to pay for urban air less saturated with
  Another EPA initiative will  also help
to alleviate the smog problem. The
Agency is planning to force  a rollback
                                                                                                       EPA JOURNAL

                                        Other companies have found
                                        that they can significantly
                                        reduce  VOC emissions by
                                        using more efficient spray
                                        painting machines.
on the volatility of American gasoline.
U.S. gasoline refineries have affected
automotive evaporative-emissions
control equipment by gradually
changing the mix  of gasoline. The
addition of butane, for instance, leads to
higher octane fuel that can be marketed
at reduced prices. Unfortunately, this
practice increases urban smog problems,
especially during  the warmer summer
months, by subjecting VOC control
equipment to levels of fuel volatility
they were not designed to handle. The
controls recently proposed by EPA
should gradually rectify this problem
over the next five years by placing
limits on the summertime volatility of
  EPA is also considering other
weapons in  the war on mobile sources
of VOCs. One is stricter requirements on
state and local vehicle inspection and
maintenance (1/M) programs. 1/M
programs currently exist in 60
urbanized areas in 32 states. By
ensuring better maintenance and
deterring tampering with emission
controls, I/M programs help to assure
that the most benefit is derived from the
technology built into vehicles. EPA is
also evaluating the benefits available
through the  use of alternative fuels and
tighter emissions standards for light

Stationary Source Controls

Mobile sources—all motor vehicles,
passenger and transport, used
nationwide—fall directly under the
purview of federal regulators. EPA sets
standards that apply nationwide, though
some  states  further strengthen federal
standards by enacting even stricter laws
of their own.
  Stationary VOC sources, on the other
hand, come more frequently under the
direct control of state and local laws.
This makes sense because patterns of
urban and industrial development vary
so much from community to
community. However, there are two
federally set emissions standards for
stationary VOC sources: new source
performance standards and control
technique guidelines. These apply
nationwide in nonattainment areas,
though they are sometimes made stricter
by state statutes. According to current
estimates, stationary sources account for
roughly 50 to 70 percent of current VOC
emissions in most U.S. urban areas.
What sort  of stationary sources are we
talking about, and what is being done to
control them?
  The chemical and petroleum refining
industries emit  large quantities of VOCs
into  the atmosphere, as do companies
that apply paint or coatings to cans,
cars, and other products.
  Two methods are currently in  use  for
the control of ozone precursors from
stationary  sources:

• Process  changes: The introduction of
new  raw materials or processing
equipment can often lead to significant
reductions in quantities of VOCs
generated  by stationary sources.  For
example, conversion to new paints or
other coatings that contain  lower
quantities  of VOC-containing solvents
has made  it possible for many
spray-painting installations to come into
compliance with EPA's VOC standards.
Other companies have found that they
 can significantly reduce VOC emissions
 by using more efficient spray painting

 •  End-o/-process changes: Abatement
 devices on vents from industrial
 processes can reduce part of the VOC
 emissions that come from stationary
 sources. Many advances are being made
 in this sphere of technology as
 government and business scientists seek
 to put a lid on a host of atmospheric
 problems: not just ozone-containing
 smog, but also acid  rain, radon, etc.
   There is also another category of
 stationary source that is a growing
 concern to air pollution experts:
 hazardous waste treatment, storage, and
 handling facilities as well as
 public and industrial wastewater
 treatment facilities.  For
 example, even when covered with earth,
 such facilities can—by diffusion through
 the soil  and later evaporation—emit
 quantities of pollutants, including
 VOCs. The role of these facilities in the
 overall ozone pollution is now being
 studied  by EPA, which will formulate
 regulatory strategies to deal with this
 increasingly important aspect of the
 smog problem.
  The decline of smokestack industries
 in the United States could contribute to
 some reduction in the overall problem,
 but as long as Americans continue their
 mass migration to rapidly expanding
 cities...drive vehicles frequently in
 urban environments...and make
 extensive use of VOC-containing
 products that must someday be
 discarded, U.S. government and
 industry will have their hands full,not
 just reaching ozone compliance but
 sustaining it as well, o

 (Lewis is an assistant editor of EPA

Their   Prospects
for  Fighting
by Richard D. Wilson
  Interest in alternative motor vehicle
  fuels lias cotno full circle. The first
serious research into alternative fuels in
the late 1900s was motivated by the
reali/.ation that gasoline and diesel
vehicles were responsible for a large
portion of urban air pollution. In the
1970s, the focus shifted to energy
supplies and prices as the U.S. economy
suffered through two oil crises featuring
gasoline; lines, price shocks, and,
ultimately, cvcles of inflation and
recession. Today, environmental
concerns have again taken center stage,
with Clean Air Act deadlines rapidly
approaching and EPA and state agencies
alike examining every opportunity for
additional pollution control strategies.
  In July, the President's Task Force on
Regulatory Relief, supported by KPA
and other federal agencies, released a
series of reports and recommendations
that may stimulate state initiatives with
alternative fuels. Recent tension in the
Persian Gulf and concern about our
growing dependence on foreign oil are
factors behind the new push for
alternative fuels. A primary driving
force, however, is the realization that
alternative fuels  can play a key role in
assuring that our air quality goals are

The Alternatives

Alternative fuels can be divided into
two distinct groups: those that could
completely replace gasoline and those
that can be low-level additives to
gasoline. The three primary replacement
fuels of interest are methanol, ethanol.
and compressed  natural gas (CNG).
  Methanol, ethanol, and CNG all have
the potential to significantly reduce the
contribution of motor vehicles to ozone
formation. This is not so much because
these fuels produce fewer hydrocarbon
emissions compared to gasoline, but
rather because their hydrocarbon
emissions have been  shown to be far
less photochemically reactive than those
of gasoline. We have known for quite
some time that methane emissions, the
primary hydrocarbon in GNG vehicle
exhaust, are very, very slow to react in
the atmosphere. More recently, we have
learned that methanol emissions also
have a low photochemical reactivity,
and ethanol has a higher, but stili
relatively low, reactivity.
  Methanol is an excellent engine fuel
that can be produced from  natural gas,
coal, or biomass. It is currently priced at
a level fairly close  to gasoline on an
energy basis. Presently some 1,000
methanol vehicles  are operating in
California, and these  vehicles use
engines very similar to those; in today's
gasoline vehicles. We project that
emissions from current methanol
vehicles create 20 to 50 percent less
ozone than comparable gasoline
                                                                                                  EPA JOURNAL

vehicles. Cold startability and
formaldehyde emissions  are two areas of
  It is important to recognize that
current engine designs have been highly
optimized for gasoline. We have only
recently begun to investigate the
potential for engines to take full
advantage of methanol's  superior fuel
characteristics. We believe that engines
optimized for methanol could be much
cleaner and more efficient than current
methanol vehicles. A few prototype
vehicles have been tested, and we
project that in the future, advanced
methanol vehicles could reduce the
ozone potential of vehicles by 80 to 90
percent and would also yield much
lower carbon monoxide emissions.
  Ethanol is produced in the U.S.
primarily by fermenting grains such as
corn. To date, few vehicles here have
been  designed to operate on pure
ethanol, although Brazil's transportation
system runs predominantly on ethanol.
We believe  that the use of pure ethanol
as a motor vehicle fuel would offer
emissions benefits somewhat lower but
still comparable to methanol. The
primary issues associated with ethanol's
use are supply and cost.
  Most of the vehicles currently
operating on CNG use conversion kits to
allow the vehicle to operate on either
CNG or gasoline. We estimate that such
vehicles, when operated  on CNG, would
contribute  40 to 80 percent less to ozone
than  gasoline vehicles. If properly
performed  and maintained, conversions
typically provide carbon monoxide
emissions reductions as well.
Drawbacks  associated with CNG
conversions include generally higher
nitrogen oxides emissions and poorer
vehicle performance, due to reduced
engine power and increased weight
from the pressurized CNG cylinders. As
with methanol, we believe CNG is best
suited for engines designed specifically
for its use. Such vehicles would likely
achieve 80- to 90-percent reduction in
ozone-producing potential  and very low
carbon monoxide emissions.  Whether
 Methanol-fueled buses are being used
 in San Rafael, a San Francisco suburb.
 EPA believes that in the future, vehicles
 using advanced methanol technology
 could reduce their ozone pollution by 80
 to 90 percent as well as lowering carbon
 monoxide emissions.
the nitrogen oxides emissions and
performance problems can be solved
remains to be seen. Other issues that
must be addressed with CNG include
the economic impacts of distributing
and compressing a gaseous fuel.
  A related benefit from the use of
methanol, ethanol, and CNG as pure
fuels is that in large truck ami bus
engines, they would essentially
eliminate  the particulate or smoke that
is characteristic of diesel engines. In
certain central city areas, buses and
trucks contribute significantly to high
particulate levels. EPA's Office of
Mobile Sources (OMS) has been very
supportive of methanol bus programs
ongoing or planned in San Francisco.
Jacksonville, Seattle, Riverside. Los
Angeles, and Denver, all sponsored by
the Urban Mass Transportation
Administration (UMTA). OMS and
Region 2 have organized a methanol bus
demonstration project in New York City
involving General Motors, the Natural
Resources Defense Council, the Center
for Auto Safety, and Celanese. This
unique project involves a significant
research and development effort by GM:
the first six methanol buses are planned
to begin operation in New York City  in
December. Two CNG buses will also
begin operating shortly, which will
permit a comparison between methanol
and CNG  technologies. It currently
appears that alternative fuel bus engines
may be an attractive option for
complying with our stringent H)<) 1 bus
engine emission standards.
  In the longer term, there is still
significant interest in two other fuels
that could nearly eliminate mobile
source pollution in urban
areas—electricity and hydrogen.
Unfortunately, there is little hope for
either of these options until well into
the twenty-first century.

Gasoline  Additives

 The second group of fuels that could
reduce motor vehicle emissions include
those composed primarily «i  gasoline
with low  levels of additives. Four
blends have been approved by EPA:
gasohol, which contains 10 percent
ethanol; DuPont, which includes ">
percent methanol and 2.5 percent
ethanol; Oxinol, which contains 5
percent methanol and 5 percent tertiary
butyl alcohol, and MTBE, which can be
blended up to 11 percent with gasoline.
Currently gasohol accounts for 7 percent
of all gasoline sales and MTBE blends
for approximately another 10 percent.
DuPont and Oxinol blends are currently
not marketed.
  The primary emission benefit of these
additives is lower carbon monoxide
emissions from increased air/fuel  ratio.
Our analysis shows that gasohol,
DuPont, and Oxinol blends reduce
fleet-wide carbon monoxide emissions
by around  22 percent. MTBE, which
contains less oxygen, would reduce
emissions by 12 percent. The magnitude
of these reductions will decrease
somewhat in the future as new cars
with computer controls displace older
  The one emissions concern with
oxygenated blends is that the addition
of ethanol and or methanol to gasoline
increases the volatility  of gasoline. This
in turn increases the amount of
evaporative hydrocarbon emissions.
Using oxygenated blonds could thus
increase tin; ozone-producing potential
of motor vehicles unless their use is
limited to the winter months when
carbon monoxide is typically high and
ozone low, or the base gasoline is
modified to provide oxygenated blends
with the same overall volatility as
straight gasoline.
  OMS and Region 8 have been working
very closely with the State of Colorado
in its planning for a mandatory
oxygenated fuels program in Denver.

The Outlook

 The relevant question  is not whether
we  ultimately will  move to alternative
fuels, bill how to do so. There is
considerable inertia in  the existing
petroleum-based transportation system,
and it is not clear how  to begin the
transition to alternative fuels.
  Left to market forces alone, the
transition will ultimately occur, but
probably not quickly. The current crude
oil surplus and  low prices have
temporarily lessened tin; energy and
economic arguments for alternative
fuels. However, the non-crisis
atmosphere offers a window of
opportunity for sound and creative
planning for the post-petroleum period.
The list; of  alternative fuels may well be
.: cost-effective urban air quality strategy
that, at tilt; same time, would help lay
thi>  foundation for a longer-term
nationwide transition. In this case, good
environmental policy today can lead to
significant environmental,  energy,
national security, and economic benefits
tomorrow,  c

(Wilson is Director of EPA's Office of
Mobile Sources.)

EPA,  Ozone
Pollution,  and
the  Law
by Richard Ossias
   There; hits been much speculation
   throughout tin; country about what
miglil happen lo cities whose air does
not attain KFA's standards for o/.one
and carbon monoxide by December 3!,
1987. Th.it is live attainment (lute
inserted into the Clean Air Act when
Congress amended the la\v in 1977.
  The law authori/es, and in some cases
requires, KI'A to apj)ly certain types of
sanctions in some areas,  including bans
on certain construction and on funding
tor air-pollution control planning and
construction of highways and facilities
for sewage treatment. In some cases the
law may also require EPA to step in and
create its own federal plan to bring
about attainment of the standards. As
explained below, these potential
outcomes are not universally


Some members of the public believe
that the full array of sanctions will
automatically apply at the; end of the
ye;ar to all areas that still have not
attained the ox.one and carbon
monoxide standards. Some have
suggested, for example, that  KI'A  will
have no choice but to ban in all of those
cities the construction of certain large
projects that would contribute to o/.one
in carbon monoxide pollution (e.g.,
chemical and auto manufacturing
Highway construction could be limited
in a number of areas if EPA finds that a
state has not fulfilled the planning
requirements of the 1977 Clean Air Act
Amendments and is not making
"reasonable efforts" to do so. Urban
areas also face a possible construction
ban if they have not submitted
approvable air quality plans to control
ozone and carbon monoxide.
                                                                                                EPA JOURNAL

                                        Some members of the public
                                        believe that the full array of
                                        sanctions will automatically
                                        apply at  the end of the year to
                                        an areas that still have not
                                        attained  the standards.
 plants, which emit large amounts of
 volatile organic compounds responsible
 in part for ozone). This interpretation
 would thus apply to the many major
 metropolitan areas which will not meet
 both standards by the end of the year.
   EPA does not agree. The Clean Air
 Act does  provide for a construction ban
 under some circumstances. But the
 Agency has long held that the law does
 not require EPA to impose a ban in
 every area that fails to attain the air
 quality standards by the Clean Air Act
 target date. Instead, EPA  believes that
 the ban is automatic only in areas
 whose formal plans to meet the
 standards have not received the
 Agency's  approval. The Agency put this
 interpretation into a  regulation in
 November 1983  after almost a year of
 reviewing the issue with  the public and
 the Congress, and the regulation  is still
 in effect today.
  This means that only the few areas
 without approved air-quality plans will
 automatically face such a construction
 ban. That includes Los Angeles,
 Chicago, and a dozen or so other areas.
 (EPA proposed on July 14, 1987, to
 disapprove the plans for most of these
 areas and to impose the ban in them.)
   The ban will  not apply automatically
 to many other areas with  approved
 plans, but which, for various reasons,
 will not attain the standards by the end
 of the year. However, this second group
 of cities will become subject to a ban
 if EPA finds that they are not
 implementing their approved  plans.
 This would include,  for example, failure
 to submit an adequate state
 implementation  plan (SIP) in  response
 to an EPA call for SIP revision.
  Where EPA does impose a ban, it will
 be removed as soon as the Agency fully
 approves a corrective plan for the area—
 even if the area's air quality has not yet
 met the standards. Again, this is
 because EPA views the ban as a prod to
 get the states to produce good plans, not
as a punishment for failing to meet
air-quality standards.
  EPA has other sanctions available at
its discretion. But, again, the Agency
does not believe they can be imposed in
an area just because the area's air
quality does not meet the ozone and
carbon monoxide standards at the end
of the year. Instead, these sanctions
come into play only when an area fails
to do diligent planning or to carry out
its approved plan.
  For example,  EPA and the Department
of Transportation must cut off certain
federal funds for state air-pollution
control planning and highway
construction if EPA finds that the  state
never fulfilled the planning
requirements in the 1977 Clean Air Act
Amendments and is not making
"reasonable efforts" to do so. Because
the judgment about whether an area's
efforts are "reasonable" is so subjective,
EPA has  much discretion in deciding
whether to impose these sanctions.
  The Agency has found a lack of
"reasonable efforts" only for a small
number of cities through the years, and
imposing highway funding sanctions
has generally been effective in getting
the area's planning efforts back on track.
This is because  highway construction is
popular in many cities, and the public
usually is willing to accept the
necessary pollution controls (e.g.,
programs for inspecting tailpipe
emissions from cars) when highway
construction is at stake. The Agency
intends to continue to  apply these
sanctions selectively in the future.
  Similarly, the Clean  Air Act allows
EPA to cut certain funds for
constructing sewage treatment works in
areas that either do not submit
approvable plans to attain air quality
standards or do  not implement those
plans. Historically, the Agency has used
this tool only as a last resort, in cases
where other forms of inducement have
failed to spark better planning.

Federal Air Quality Plans

Where a state has failed to submit an
approvable plan to meet the ozone and
carbon monoxide standards, EPA must
sometimes step in and do the job.
Indeed, one federal court recently
ordered the Agency to create a plan to
attain the carbon monoxide standards in
Phoenix and Tucson.
  Since ozone and carbon monoxide
pollution  is caused partly (and in some
cases mostly) by pollution from
vehicles, most major metropolitan areas
will have  to control driving habits to
meet the standards. Although  some of
them  were later overturned  in court, in
the mid-1970s EPA created
transportation-control plans that
provoked  enormous public opposition
because they would have rationed
gasoline sales, restricted downtown
parking, and imposed other limitations
on vehicle use. Congress ultimately
reacted  by amending the Act in 1977 to
trigger a new round of state  planning
under threat of the same sanctions.
  EPA is now beginning to consider
how to produce plans to attain the
carbon monoxide standard in Arizona
without causing a rerun of the severe
adverse  public reaction it sparked in the
1970s effort. In the final analysis, the
Agency  believes that the attainment of
the ozone  and carbon monoxide
standards  depends largely on the
public's acceptance of the controls
needed to  meet those standards. And
the public will accept these  limitations
only if they are based on careful thought
and communication  about the
alternative paths to clean air. D
                                       (Ossias is an attorney in the Air and
                                       Radiation Division of EPA's Office of
                                       General Counsel.]

to  the
A  Forum

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       ironmental t-ruup: 
Richard Ayres

Americans want air quality
that protects their health,
their aesthetic experiences,
and the integrity of the
natural environment. In poll
after poll, they say
overwhelmingly they want
better air quality, believe it
can be attained, and are
prepared to pay for it. Hut
tens of millions of Americans
still live in areas with
chronic smog  problems.
Though the compliance
deadline is upon us, the
cleanup effort has been
inadequate. Some in
government are already
lamenting that all the
"reasonable"  pollution
control measures have been
exhausted. But to the
American people, it seems
too many public: officials
have not taken the law
seriously. EPA has not taken
the lead, and all too often
state and local officials have
failed to pick  up the mantle
of responsibility.
  The deadlines in the law,
put there to encourage action
and assure accountability,
mostly get a wink. Potential
emission reductions have
been turned into property
rights for emitters through
the "bubble" and new source
policies. The Agency has
eschewed improvements in
public transportation systems
called  for by the Clean Air
Act. EPA guidance on control
techniques has all but dried
up. and aggressive
implementation plans have
fallen by the wayside.
  In short,  perhaps our most
sweeping public health
program is  in shambles.
  To make it effective again
will take structural changes.
to be sure.  But  perhaps more
important,  policy-makers
must first change their habit
of thinking of reasons why
Americans  cannot have clean
air. Government agencies and
Congress must  adopt a
positive approach that
matches the public's desire
for  healthy air.
  The  issue is not how to
extend deadlines, but how to
apply available, sensible
pollution controls to achieve
healthful air quality as soon
as possible.
  It is remarkable that EPA
has not come forward with a
call for Congressional
direction, a laundry list of
"must" provisions, or a
comprehensive bill of its
own. Instead, the Agency
proposes by administrative
fiat to eliminate the
deadlines in the law and
authorize another multi-year
planning exercise as  a
substitute for further cleanup
measures. While offering
little of its own, the Agency
rejects efforts by members of
Congress to revitalize the
  In truth, there is a host of
sensible control measures
that can drastically reduce
Americans' exposure to
health-threatening levels of
"smog" and other urban
pollutants. The costs of these
measures are reasonable.
None  of them are free; but
few things worth  having are.
We have heard  these
measures characterized as
"Draconian." But  are the
following "Draconian?"
• Tightening new car
standards to the state of the
art already achieved by a
majority of the  latest models.
• Improving assembly-line
monitoring, warranties, and
state inspection systems to
assure that auto emissions
control devices actually
perform up to their
• Requiring existing
uncontrolled industrial
polluters to adopt reasonably
available control technology.
• Eliminating the various
EPA "bubble" and "offset"
rules  that have  become a
system to award perpetual
easements in pollution.
• Imposing emission fens to
induce industries to find
cost-effective ways to achieve
emission reductions.

• Converting local vehicle
fleets (e.g.. buses, taxis,
delivery vans] to natural gas
or other clean fuels.

• Improving the quality and
availability of public

  Most of the concern about
"Draconian" measures relates
to the handful of urban areas
where local  authorities say
that continued unfettered  use
of the private car is
incompatible with  attaining
health standards, yet tht'iv
are a myriad of incentive
measures that could  improve
both the quality  of life nixl
the air by altering the
transportation mix between
cars and  public
  For those  who observe
with a sympathetic eve the
efforts of federal and state
officials to deal with Ilie
smog  problem, it is sad
indeed to see a debate in
which such  sensible
pollution control measures
are ignored. In 1070, this
nation set ,111 example for the
world with its commitment
to vigorous air-pollution
control—a commitment that
has paid  handsome
dividends in better health. It
is time to revivify that effort
and reclaim that leadership.
                                                                                           Continued to next page

Michael R. Barr

 Tim business community saw
 flii'  1H77 Clean Air Act '
 Amendments as a good
 news/bad news joke without
 the good news:Congress
 lold us \vi; won't be able to
 build  in dirty-air areas
 because they're dirty and
 we won't be able to build in
 clean-air areas because
 they're clean.
  Now, tb(: regulatory  and
 legislative proposals so far
 advanced to deal  with  the
 "post-1 987 ozone,
 nonaltainment problem"
 may finish oft lite
 American  economy. Existing
 industry won't be able to
 continue operating in  our
 major industrial areas  (most
 of which do not attain the
 o/.one standard) and still
 won't Ins able to relocate
 anywhere  else in America.
   Most of  these proposals am
 loaded with more commands,
 more controls, more
 prescriptions, and various
 extraordinary  nostrums. They
 all suffer one fundamental
 flaw: they  fail to ask what
 problem they aim to solve.
 More specifically, they ignore
 the substantial progress  we
 have made in o/.one
 attainment in  America since
 1070. They fail to ask  \vhal
 has worked in cleaning our
 aii1,  what hasn't, and why.
 They ignore our incredibly
 rich o/one databases and
 characterize all
 nonattainment areas with a
 single number (the notorious
 "design value").
  Xot surprisingly, 17 or
more years of air quality
control has had an effect. The
effect is illustrated by ozone
exposure maps prepared for
the San P'rancisco Bay Area
for 1969-1983-1980. they
show that a widespread,
general ozone  nonattainment
problem in 1969 yielded *o a
decade of careful air quality
planning and comprehensive
control. By 1983. the problem
was much reduced in
geographic scope and
frequency. By  1986, the
ozone problem had all but
vanished by comparison to
1909. Peak ozone levels were
down, the geographic extent
of ozone exceeclances was
limited, and the duration of
excess ozone periods was
slashed. Public health had
improved dramatically
compared to levels in the
1960s and  1970s.
   Yet, the San Francisco Bay
Area—like most ozone
nonattainment areas in
1987—still gets a failing
grade for ozone attainment
based on the "design value"
   EPA should  discard this
"pass-fail" system. We need
more realistic  measures of air
quality—"Bs," "Cs", and
"Ds"—which express the
severity of ozone
nonattainment. When graded
fairly, most of the  remaining
o/.one nonattainment areas
show substantial progress  in
achieving the o/.one
attainment goal. Indeed,
almost all areas have
achieved actual ozone
attainment an overwhelming
proportion of the time
(typically greater than 99
percent) almost everywhere
for almost everyone. Because
we have come so far in
attaining the ozone standard,
we now have an opportunity
to plan our remaining o/.one
attainment efforts in a
rational manner on a
reasonable schedule. Fov
example, EPA should:
• Help the states update
their emission inventories to
ensure that the contribution
of all sources to the residual
nonattainment problem  is
clearly understood before
drastic new controls are
• Help the states refine  their
ozone monitoring systems
and develop photochemical
models to improve their
accuracy in predicting air
quality levels.
• Evaluate each
nonattainment State
Implementation Plan to  see
what worked, what didn't,
and why. Existing measures
which are either ineffective
or not cost-effective should
be identified.
• Work with Congress to
obtain authority to set new
attainment date targets to
reflect the severity of each
areas's ozone problems and
not penalize areas which are
making good-faith efforts to
control ozone.
  Very importantly, new
source development
commensurate with air
quality goals should be
encouraged, not squashed.
The construction ban  is
counter-productive because it
prevents modernization of
industrial sources which will
result in air quality
improvements. Instead,  EPA
should refine and preserve
the mechanisms of air
permitting that facilitate the
modernization of existing
industrial and commercial
facilities. Finally. EPA's
mission has always included
informing a  concerned public
about environmental  matters.
Americans art: receiving
distorted and incomplete
information  about their
remaining o/.one problems.
EPA can help by continuing
to publicize the great
progress we have made, the
limited  scope of our
remaining problems, and the
environmental and economic
choices  we face in managing
our remaining ozone
problems, n
 : \
                                                                                                          EPA JOURNAL

 A  Look  at
Air  Quality
 by Bob Burke
 The "brown cloud" over Denver is an
 example of the challenges that remain
 in the nation's air quality cleanup. Much
 of the cloud is particulates. Actions are
 being taken to deal with Denver's air
  In addition to ozone, EPA regulates and
  reports on lead, carbon monoxide.
suspended participate matter, nitrogen
dioxide, and sulfur dioxide, air pollutants
which, like ozone, are known or
suspected causes of illness or disease.
They all still occur in some places in
concentrations that are above health
standards set  by EPA.
  The latest EPA report that charts the
nation's progress in reducing these
pollutants is X'citional Air Qualify and
Emissions Trends for 1985, which
includes data spanning  a 10-year period
for ozone and the five other major air
pollutants. In most respects, the report's
data for the past decade are
encouraging: levels for the five air
pollutants were lower in 1985 than in
1976, some considerably so.
  Here, in summary, is  what the  1985
air trends report has to  say:


Lead additives in gasoline are the major
source of lead emissions in the United
States, but the overall share from this
source has dropped significantly
because of federal programs to
reduce and  phase out lead in gasoline
(See article on page 28). Non-ferrous
smelters and battery plants
are other major sources  of lead
emissions. The adverse health effects of
lead  poisoning have been
well-documented, particularly the
permanent damage lead can cause to the
central nervous systems of infants and
• iVationo! Trends in Lead
Concentrations, 1976-1985. There was a
dramatic 79-percent  decrease in lead
concentrations in the air over the
decade. Almost all of the improvement
resulted from federal actions aimed at
leaded gasoline. In addition, the  lead
content of what leaded fuel remains in
use is down sharply  to about a tenth of
what it was in 1976.
• National Trends in Lend /•.'missions.
197()-7985. Complementing the rediu ed
ambient air lead levels are the statistics
for lead emissions. They show a
tremendous decline of 86 percent over
the  10-year period.

Carbon Monoxide (CO)

Carbon monoxide  is  a colorless,
odorless, and poisonous gas produced
by the incomplete burning of carbons in
fuels. As much as  95 pin-cent of the
carbon monoxide in  the air in some
areas comes from automobiles. While
ozone Ithe other major pollutant from
motor vehicles) is  a pervasive, area-wide
phenomenon, excessive  carbon
monoxide is highly specific to
areas where there is a lot of traffic and
congestion. Carbon monoxide reduces
the amount of oxygen delivered to all
tissues of the bodv. and. even at


                                                                                                 EPA JOURNAL

relatively low concentrations, disrupts
mental functions, reduces alertness, and
impairs vision. It is particularly
harmful—even life-threatening—to
people with severe heart disease,
anemia, emphysema, and other lung
• National Trends in Carbon Monoxide
Concentrations, 1976-7985. Carbon
monoxide levels decreased by 3(5
percent. Most of this improvement was
brought about by federal emissions
standards on newer vehicles, but some
is due also to traffic flow programs
designed to relieve congestion and to
local  weather conditions that
encouraged reduced CO  levels.

• National Trends in Carbon Monoxide
Emissions. J976-1985.  Total carbon
monoxide emissions were 21 percent
lower in 1985 than in 1976 because of
federal emissions standards, even though
there  was a 26-percent increase in
vehicle miles travelled. Reported
concentration reductions are higher than
emissions reductions because of traffic
flow patterns in urban  areas where the
concentrations art: monitored. The
number of vehicles and the miles they
travel are  relatively constant in city

Total  Suspended Particulates (TSP)

Particulate matter found  in the
atmosphere comes mainly from
industrial processes,  but a significant
amount is produced from solid waste,
fuel combustion, and transportation
sources. Some particulates are visible as
soot or smoke; others are detectable
only with an electronic microscope and
pose particularly serious health threats
because they can  penetrate the most
sensitive parts of the respiratory tract.
[-"articulate matter may seriously irritate
the respiratory tract: prolonged
inhalation of certain typos increases the
number of chronic; respiratory cases as
well as their severitv.
• National Trends in Particulate
Concentrations,  1976-1985. Average
annual concentrations of total
suspended particulate matter decreased
24 percent, largely because of emission
controls on a variety of industrial
processes. Weather conditions and
reduced industrial activity in some
areas may also be a  factor.
* National Trends in Particulate
Emissions, 1976-1985. There was also a
24 percent reduction  in particulate
emissions. Particulate levels in the air
do not always improve in direct
proportion to estimated emissions
reductions because concentration levels
may include pollution from street dust,
construction, etc.. which are not part of
an emissions "inventory." Nevertheless.
most of the reductions in both
emissions and concentrations are duo to
industrial and public utility pollution

Nitrogen Dioxide (NO2)

The major source of nitrogen dioxide
pollution  is emissions from high
temperature automotive and stationary
fuel combustion processes. Nitrogen
dioxide plays a major role in the
atmospheric reactions that produce
photochemical smog,  and  can irritate
the lungs  and cause bronchitis and
pneumonia. It can also lower resistance
to respiratory infections such as
• National Trends in Nitrogen  Dioxide
Concentrations,  197IM985. There; was
an average 11-percent decrease in
nitrogen dioxide concentrations over the
decade. Although they increased  from
1976 to 1979, concentrations
subsequently decreased each year from
1980 through 1985.  The trends  in
nitrogen dioxide levels correspond
closely to emissions trends from both
transportation and stationary sources.
• National Trends in Emissions of
Nitrogen Dioxide, !97(i-19«5.
A series of gradual decreases
interspersed with more modest
increases in estimated emissions wore
recorded from both transportation and
stationary sources which contribute
about 95 percent of all nitrogen dioxide
emissions. Since there was a
26-percent increase  in vehicle miles
travelled,  it is clear that the decrease in
nitrogen dioxide emissions from motor
vehicles was significant.
Sulfur Dioxide (SO2)

Sulfur dioxide enters the air primarily
from the burning of coal and  oil, and
from various other industrial  processes.
Studies of serious air pollution episodes
have found an increase in death rates
among people with existing heart and
lung disease when high sulfur dioxide
concentrations are present in
combination with high concentrations of
certain particulate matter.

• National Trends in Sulfur  Dioxide
Concentrations, 1976-1985. Average
national sulfur dioxide levels dropped
42 percent over the 10-year period. This
was mainly  due to reductions in average
sulfur content of fuels consumed;
installation of flue gas control
equipment at  coal-fired electric, stations;
reduced emissions from industrial
processing facilities such as smelters
and sulfuric acid manufacturing plants;
and use of clear fuels in residential and
commercial  areas. These downward
trends occurred even though  some
sources switched from low-sulfur oil to
coal for energy conservation purposes.

• National Trends in Sulfur Dioxide
Emissions, 1976-1985. Sulfur
dioxide emissions declined 21
percent in the decade. The difference
between this figure and that for
concentration  trends reflects tin; fact
that monitoring stations are mostly in
urban areas that have almost universally
shifted to low-sulfur fuel. Rural power
plants which are a major source of
sulfur emissions aren't generally
covered by this monitoring system.
Significant improvement in emissions
levels is due to the same factors related
to concentration trends, a
A Skipjack—a sailboat traditional to
Chesapeake Bay—out on a clear day.
Clean air is a national goal.

Revisiting the  Lead
by Richard G. Kozlowski

                        i i i v.y (.4 i i i •>.
                  How: A simple  blood test
               Wbfl         f ^d Poisoning
                                  inters, and
A child has blood drawn for tests.
Children are particularly vulnerable to
physical or mental impairments caused
by high lead levels. Lead in gasoline has
been reduced by 95 percent since 1970.
At the same time, the U.S. Department
of Health and Human Services has
reported a trend of decreasing lead
levels in the blood of Americans.
                                            EPA JOURNAL

                                         This chart shows the drop in lead
                                         concentrations in the nation's air from
                                         1976 to 1985, the period covered by the
                                         latest available figures. Ug m3 stands for
                                         micrograms per cubic meter.
    The sharp decrease in lead in the air
    we breathe is one of EPA's  most
significant success stories. Two EPA
programs initiated during the past 15
vears have led to a 95-percent redm tion
in the use of lead in gasoline. This, in
turn, has contributed to an overall
79-percent reduction in lead in ambient
air, and the Department of Health and
Human Services is finding decreasing
lead levels in  the blood of Americans.
(See article on page  25  for the latest
report on air pollution trends.)
  Two EPA efforts an: responsible for
this success. The lead phasedown
program sharply reduced the
permissible amount  of lead  in Jeuded
gasoline. The  now car emission
standards have led automakers  to use
engine technology requiring unleaded
gasoline; as newer vehicles replace the
older fleet, the demand for leaded
gasoline decreases.
  Lead  has long been used in gasoline
as a cheap way to increase octane levels
to avoid engine knocking. EPA's  initial
moves to reduce amounts of lead
allowed in gasoline  were greeted with
skepticism by refiners,  but refinery
equipment has been upgraded to
produce gasolines of suitable octanes
either with low lead levels or no lead at
all, so that most vehicles can run
properly while emitting very little lead.
  The EPA lead  phasedown program
began with the Clean Air Act, which
authorized the Agency  to control or
prohibit any fuel or  additive which
could reasonably be considered a danger
to the public health  or welfare.  To EPA,
lead in  gasoline  was an obvious target.
Gasoline load  is  a major source'oi lead
exposure, accounting for 90  percent of
total airborne  lead emissions. H
contributes significantly to non-air
pathways of exposure, such  as  ingestion
of dust  and dirt  lead. EPA research
found a strong correlation between lead
in gasoline and levels of lead in the
bloodstream of the population,  with
 Maximum Quarterly
 Lead Average Concentration (ug m3)
       Typical average (or more poll,.''
 Typical average lor less polluted locatio
blood lead levels following seasonal
gasoline use fluctuations as well as
long-term trends, other variables
  People are exposed to lead from
gasoline in many ways:
• When leaded  gasoline is burned in an
engine, small amounts of lead remain in
the engine and exhaust system, but most
of it is emitted from the; tailpipe to (he
air, where it stays suspended for a time
before settling to the ground.
• Some exposure occurs through direct
inhalation of the emitted lead as it
comes from the  exhaust system.

• Additional exposure results from
ingestion  or inhalation of
lead-contaminated dust.
• Lead from  gasoline is also deposited
on food crops which are later eaten.

  In tin; early 1970s, (lie preponderance
of scientific evidence about the capacity'
of lead to impair the physical and
mental health of human  beings,
particularly children, led EPA to embark
on  its lead reduction or lead phasedown
program.  Most recently, on March 7.
1985, EPA reduced the lead content  of
leaded gasoline from the standard then
in effect, 1.10 grams per  leaded gallon
(gplg), to 0.50 gplg. effective July t,
1985, and 0.10 gplg. effective January 1.
1986. A subsequent rule  allowed
refiners who used  less lead than the
standard in 1985 to use correspondingly
more through 1987, thus allowing a
smoother transition to the stringent 0,10
gplg standard.
  The decrease in  the use of lead in
gasoline was also fostered by EPA's
unleaded gasoline  program. After the
automakers chose  the catalytic: converter
as their primary emission control
device, and because; the catalyst  is
"poisoned" by lead. EPA promulgated
regulations requiring (he general
availability of unloaded gasoline by July
1. 1974. Most gasoline-power, light-duty
vehicles since 197"), and  all since  1980.
have boon certified for unleaded
gasoline only. Some motorcycles ami
some heavy-duty engines continue to be
certified for leaded fuel;  however.  EPA
is currently finalizing a rulemaking
which will prohibit new  vehicle and
engine certification using leaded fuel,
starting in the 1990 model year.    As a
result, the demand for leaded gasoline
has steadily decreased. Currently, it is
approximately 25 percent of the  market,
compared to 37 percent in 1985.
  However, total lead use has not
decreased as quickly as had been
projected, primarily because of
misfueling  the use of leaded fuel in
vehicles designed  tor unleaded. The
major incentive tor mislueling has been
the lower retail price of leaded gasoline.
but (ho cost of producing regular H8-H9
octane leaded gasoline will ultimately
exceed that of the  regular 87 octane
unleaded gasoline, and the wholesale
price of regular leaded gasoline is now
greater than that of regular unleaded.
  Unfortunately, traditional marketing
practices have kept the retail price of
leaded gasoline lower than unleaded in

                                                                              Look  Ma!
                                                                             No  Pollution!
                                                                             by Hagan Thompson
 many areas. But as the price differential
 narrowed, misfueling dropped from a
 rate of 16 percent in 1984 to 10 percent
 in 1986. When regular leaded gasoline
 begins to retail at a higher price than
 regular unleaded, misfueling should all
 but disappear.
  By 1989 or 1990, the leaded gasoline
 demand should be approximately 15
 percent of the market. At that point,
 EPA expects leaded gasoline to become
 a specialty item available only in some
 markets. While  reducing the lead in
 gasoline has important health benefits,
 it has caused considerable concern in
 the agricultural community because of
 problems with older engines that use
 lead to lubricate exhaust valve seats.
 Without lead, the exhaust valve seats
 recede into the  cylinder; if this causes
 enough leakage, an expensive valve job
 is necessary.
  And while most vehicles will not
 have any problem using unleaded gas,
 some engines—primarily in  tractors and
 other farm  equipment—designed for
 leaded gasoline might have difficulties
 if used at high engine speeds or under
 very heavy loads. While most newer
 tractors have diesel engines, many
 pieces of farm equipment are
 gasoline-powered and used for
 heavy-duty purposes in harvest seasons.
  In response to the concern of farmers
 and agricultural leaders, the Congress
 required EPA and the U.S. Department
 of Agriculture to analyze the potential
 for mechanical  problems associated
 with the use of other fuels in
 agricultural engines designed for leaded
 gasoline. The study found that the
 engines performed satisfactorily on
 low-lead gasoline at the  0.10 gplg level,
 but high-speed  engines under moderate
 to heavy loads will experience excessive
 valve-seat wear if operated on unleaded
gasoline, and that non-lead alternative
valve lubricating additives do reduce
valve-seat wear. EPA is continuing the
  Farmers are also concerned about the
continuing availability of leaded
gasoline, because some refiners are
discontinuing sale of leaded gasoline
and introducing a third grade of
unleaded gasoline, particularly in urban
areas. This has contributed to the
widespread misconception that EPA has
banned leaded gasoline effective January
1, 1988. However, independent refiners
and distributors have indicated that
they will fill the "leaded" void left by

Whether EPA bans lead or
not, the 95-percent  reduction
of lead in gasoline  already
attained stands  out as one of
the great achievements of the

the majors in markets with strong
demand, which should take care of the
farmers' needs.
  While EPA had considered banning
lead in gasoline completely, we have no
present plans to do so. Future actions
depend on the availability of
alternatives for those engines that need
lead, the newer health data on the
effects of lead, and the future level of
fuel switching. In any event, the
95-percent reduction of lead in gasoline
already attained stands out as one of  the
great achievements of the Agency and
one of its major contributions to the
health of the nation, o

(JCozJowski is Director  of the Field
Operations and Support  Division in
BPA's Office of Mobile Sources.]
    Do you want to feel good, look good,
    and make friends? Then get a
bicycle and start pedaling.
  Of course I'm talking about a bicycle
that moves from one place to another as
you move your feet, not one that stays
in one spot in your rec room.
  The stationary variety is good, but
you need to get out into the country and
see the sights, smell the scents, meet the
people, and feel the wind at your back
and in your face.
  Let's get serious,  folks. There's
nothing like it. I've been cycling for
almost  10 years. During most of that
time, I've ridden with my colleagues in
Atlanta's Southern  Bicycle League.
There are some 2,000 of us, and we'll
ride anywhere. Last year, we went to
northern California. This fall, we'll  do
the "Tour de Vermont, New Hampshire,
and New York." Some of our pedal
pushers flew to Ireland this summer to
  Whoa! Wait a minute! I've just read
what I've written. There may be too
many of us already. California is full of
cyclists. So is Washington, D.C.
Gainesville, Florida, is another hotbed
(or hot  seat).
  People in Washington even ride to
work on bikes. Can you believe it?
Dodging all these government workers
and tourists trying to get around those
monuments. But  hey, it's healthy. Burn
those calories. Push those pedals. It's an
endless cycle. Come on, give it a break,
it's a good line.
  What are the questions asked most
often, you ask? Why do you wear those
skin-tight pants?  For comfort, believe it
or not. They don't ride up on you. No
pun there.
  Doesn't leaning over the handlebars
hurt your back? No.
  Aren't automobiles a problem? Yes, if
you let them. You must be alert and
courteous. Don't  assume anything.
Bumping with another bicycle is a
bigger concern, or should be.
                                                                                                     EPA JOURNAL

                                                                                  Isn't that little saddle hard on your
                                                                                fanny? You'll toughen up in a hurry. No
                                                                                  How can you ride in hot weather like
                                                                                this? You wear skin-light pants and not
                                                                                much more, and you drink lots of water
                                                                                from the bottle on your bike.
                                                                                  How can you ride in cold weather
                                                                                like this?  You wear skin-tight pants and
                                                                                more, and you don't drink as much
                                                                                water from your bike bottle.
                                                                                  What do you do when  a tire goes flat
                                                                                or you have some other failure out in
                                                                                the middle of nowhere? You always ride
                                                                                with people who can deal with such
                                                                                things --those people who were horn to
                                                                                fix, who get impatient with your clumsy
                                                                                (fake) attempts at repairs: "Let me do
                                                                                that," they say, "so we can get going
                                                                                  Still interested? You should be. It's
                                                                                wonderful exercise. It's kind to your
                                                                                limbs. And bicycles don't in,ike smog.
                                                                                  You meet a lot of nice  people. Like
                                                                                the man 1 met several years ago in  a
                                                                                little community in Alabama.
                                                                                somewhere between Antala and Dothan.
                                                                                It was the middle of ]uly on the third
                                                                                day of a ride from  Atlanta to Panama
                                                                                City. Florida. My partner and 1 were
                                                                                parched. We're talking hot. I had just
                                                                                poured a live-pound sack ol cracked ice
                                                                                over my head when ! looked up and
                                                                                saw tin's gentleman eyeing me
                                                                                quizzically.  "Is  there any shade in this
                                                                                town?" 1 asked.
                                                                                  "The last we had was about  March."
                                                                                hi; answered. -

                                                                                [Thompson is (,'biet ol (lie Public Atlmrs
                                                                                Bmncli in h'PA's Hegion •! Office.)
                                                                                Hagan Thompson contemplates the
                                                                                view over San Francisco Bay as ho rests
                                                                                during the first day  of a 500-mile, 10-day
                                                                                bike trip in northern California.
                                                                                Thompson is a member of Atlanta's
                                                                                Southern  Bicycle League.

A review of recent major EPA activities and developments in the pollution control program areas
Fuel Economy Estimates

For the second consecutive
year, a Chevrolet Sprint
model has received the
highest mileage ranking from
  The minicompacl Sprint
Metro, which is made tor
Chevrolet by Su/.uki.  is rated
at 54  miles per gallon (mpg)
for city driving and 58 mpg
on the highway, the same
           mileage estimate given last
           year's Sprint KR.
            Other high-mileage
           vehicles include the Honda
           Civic CRX HF. Pontiac
           Firefly, Suzuki Forsa, and
           another Sprint model.

           Radon Brochure

           EPA has released a now
           booklet, "Radon  Reduction in
           New Construction," that
           describes construction

 Kcithy Petruccelli has been
 appointed Director of the
 Management and
 Organi/ation Division  in the
 (illii c dl Administration.
   She brings a wide range  of
 national and international
 experience to this position.
 She previously worked for
 the Department of Navy from
 HI70 to li)7.r> and
 subsequently spent three
 years in Italy working lor the
 I 'nited Nations. She has been
 with  EPA since t<)7H,  and
 has most recently served as
 Chief of Personnel Policies
 and Programs Branch.
   Petruccelli received  her
 bachelor of arts degree in
 H)7l  from the University of
          Sallyanne Harper lias been
          appointed to the position ot
          Associate Director for
          Procurement Operations.
            I larper has recently been in
          the Agency's Procurement
          and Contracts Management
          Division. She previously
          worked as a Contract
          Specialist for the Department
          of Navy in  Philadelphia and
          as a Contracting Officer for
          the Naval Air Systems
          Command in Washington,
            She received  a bachelor of
          arts degree from EaSalfe
          University and  recently her
          master's degree in business
          administration from George
          Washington University.
methods homebuilders can
use to reduce the chances
that new homes will have
high indoor radon levels.
  The new booklet describes
simple and inexpensive
construction methods to
"linimi/e radon entry into
new homes and help in its
removal after construction is
  EPA developed the booklet
in cooperation with the
National Association of
Home Builders Research
Foundation, a non-profit
organization, and other
federal agencies.
  The new  booklet  is
available free from state
radiation protection offices,
homebuilders' associations,
and EPA regional offices.

Pesticide Blockade
EPA has begun an
investigation to determine
the cause of poisoning
incidents involving Hart/
Mountain Corporation's
"Blockade," which is used to
control fleas and  ticks on
clogs and cats.
  EPA will require additional
toxicity testing by the
company. While  these tests
are being conducted. Hart/,
agreed to the following
additional label statements:

• Do not use Blockade Cat
Flea and  Tick Repellent on
young (less that one  year old)
or pregnant cats or young
(loss than 3 months old)

• Apply  lightly.  Do  not
saturate animal's  coat.
• Do not apply more often
than every seven clays.

• Some animals may be
sensitive to ingredients in
this or similar  pesticide
products. If salivation.
tremors, or vomiting occur
after treatment, pet should
immediately be bathed with a
non-pesticidal  shampoo.
wrapped in a towel to
prevent chilling, and  taken to
a veterinarian along with the
product container.

• Do not use this or any
pesticide on  sick, old, or
debilitated pets.

  During the period of
January 1 through August 29,
1987, a total  of 201 cat and
dog incidents (animal
reactions), including 26
deaths, connected with the
use of Hartz  Blockade Cat
Flea and Tick Repellent and
Blockade Dog Flea and Tick
Repellent were reported to

Cyhexatin Voluntarily

EPA announced that Dow
Chemical Co. has requested
voluntary cancellation of its
registration for the pesticide
cyhexatin. to become;
effective on December 31,
  The action was taken after
recent studies showed that
cyhexatin causes birth
defects in rabbits and may
pose a  risk to the unborn
children of women exposed
to this  pesticide.
  Dr. Jack Moore, EPA's
Assistant Administrator for
Pesticides and  Toxic
Substances, stated: "Women
of childbearing age are our
primary concern... We are
encouraged by  the prompt
efforts  to voluntarily remove
this pesticide from the
channels of trade."

                                                                                                       EPA JOURNAL


   Savoring an outdoor pastime with a
   cast into the Atlantic surf.
Back Cover: Going for an autumn
walk. Photo by Kahnweiler/Johnson,
Folio, Inc.