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Toxic Substances: Status of EPA's
Efforts to Reduce Toxic Releases

Source: Letter Report, 09/22/94,
GAO/RCED-94-207



To get industry to identify and voluntarily reduce the amounts of toxic
substances released into the air, ground, and water, the Environmental
Protection Agency (EPA) has undertaken several initiatives. The Toxic
Release Inventory records the releases of more than 3000 toxic chemicals
reported to EPA and to the state in which a releasing facility is
located. Under the 33/50 Program, EPA has encouraged industry to reduce
releases of 17 toxic chemicals by 33 percent before the end of 1992 and
by 50 percent before the end of 1995. The Early Reductions Program seeks
to reduce emissions into the air before EPA proposes emission standards
by giving industry a six-year extension for meeting the standards as
they are developed during a 10-year period. This report determines (1)
the validity of the reductions in releases of toxic substances reported
in the Toxic Release Inventory, (2) the progress of the 33/50 Program in
meeting its targets for reductions in toxic releases, and (3) the status
of participation in the Early Reductions Program.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-94-207
     TITLE:  Toxic Substances: Status of EPA's Efforts to Reduce Toxic 
             Releases
      DATE:  09/22/94
   SUBJECT:  Toxic substances
             Environmental monitoring
             Industrial pollution
             Air pollution control
             Water pollution control
             Pollution monitoring
             Data bases
             Data integrity
             Reporting requirements
             Safety standards
IDENTIFIER:  EPA Toxics Release Inventory Program
             EPA Early Reductions Program
             EPA 33/50 Program
             
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Cover
================================================================ COVER


Report to the Chairman, Environment, Energy, and Natural Resources
Subcommittee, Committee on Government Operations, House of
Representatives

September 1994

TOXIC SUBSTANCES - STATUS OF EPA'S
EFFORTS TO REDUCE TOXIC RELEASES

GAO/RCED-94-207

Efforts to Reduce Toxic Releases


Abbreviations
=============================================================== ABBREV

  EPA -
  GAO -
  MACT -
  NESHAP -
  STAPPA/ALAPCO -
  TRI -

Letter
=============================================================== LETTER


B-257222

September 22, 1994

The Honorable Mike Synar
Chairman, Environment, Energy,
 and Natural Resources Subcommittee
Committee on Government Operations
House of Representatives

Dear Mr.  Chairman: 

In efforts to get industry to identify and voluntarily reduce the
amounts of toxic substances released into the air, ground, and water,
the Environmental Protection Agency (EPA) has

  established a Toxic Release Inventory to record the releases of
     over 300 toxic chemicals reported to EPA and to the state in
     which a releasing facility is located;

  instituted a voluntary initiative called the 33/50 Program, in
     which EPA, beginning in 1991, encouraged industry to reduce
     releases of 17 toxic chemicals by 33 percent before the end of
     1992 and 50 percent before the end of 1995; and

  established an Early Reductions Program, which encouraged industry
     to reduce emissions into the air before EPA proposes emission
     standards by giving industry a 6-year extension for meeting the
     standards as they are developed over a 10-year period. 

Concerned about whether these efforts have been effective in reducing
toxic releases, you requested that we determine (1) the validity of
the reductions in releases of toxic substances reported in the Toxic
Release Inventory, (2) the progress of the 33/50 Program in meeting
its targets for reductions in toxic releases, and (3) the status of
participation in the Early Reductions Program. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

While EPA's Toxic Release Inventory shows that the volume of toxic
substances released into the environment has been reduced by 1.7
billion pounds since 1988, it is difficult to determine whether these
reductions are valid and permanent.  Neither EPA nor the states are
required to determine the validity of the reductions reported by
industry.  Also, some of the reported reductions have been temporary
reductions, caused by changes in production levels, or "paper"
reductions, resulting from changes in the instructions and guidance
on reporting on specific chemicals and changes in estimating methods. 

According to EPA's data, the 33/50 Program has exceeded its interim
target, having achieved a 40-percent reduction in toxic chemical
releases and transfers\1 in 1992.  Based on the progress reported
thus far, EPA officials expect to realize a reduction of more than 50
percent by 1995.  However, not all the reductions can be directly
attributed to the program:  26 percent of these reductions were
reported by companies not participating in the program, and 40
percent of the reductions took place before the program was
established. 

As of September 1994, EPA was reviewing and processing 40
applications for the Early Reductions Program--representing fewer
than 10 percent of those facilities eligible to participate in the
program--according to agency officials.  Industry representatives say
that participation has been limited because the 6-year grace period
participants are given to comply with the emission standards is an
insufficient incentive in view of (1) the cost and difficulty of
documenting historical emissions data, (2) uncertainty about whether
state and federal pollution control requirements will be consistent,
(3) EPA's delays in promulgating the final emission standards, and
(4) concern about making large outlays for pollution control
equipment before the definitive requirements are known. 


--------------------
\1 The 33/50 Program measures both the amounts of toxic chemicals
released on site into the air, water, and land and the amounts of
toxic chemicals transferred off site for treatment and disposal. 


   BACKGROUND
------------------------------------------------------------ Letter :2

In 1988, releases of toxic substances from chemical plants,
refineries, and other manufacturing facilities amounted to over 4.8
billion pounds, according to EPA's Toxic Release Inventory (TRI). 
Under the 1986 Emergency Planning and Community Right-to-Know Act,
these facilities were required to report releases of over 300 toxic
chemicals to both EPA and the state in which a facility is located. 
With the passage of the Pollution Prevention Act of 1990, EPA
expanded the data that facilities are required to report to include
the quantity of chemicals recycled or burned for their energy value
and the activities initiated to reduce pollution at its source. 

In 1991, EPA established the 33/50 Program to encourage companies to
reduce releases and transfers of 17 toxic chemicals that together
accounted for 25 percent of the total toxic pollutants reported to
have been released in 1990.  (Releases of these 17 chemicals are
predominately into the air.) The program aims to reduce the amounts
of these chemicals released by 33 percent from the 1988 level before
the end of 1992 and by 50 percent before the end of 1995.  Data from
the TRI are used to measure the program's progress. 

Under the Clean Air Act amendments of 1990, EPA is developing maximum
achievable control technology (MACT) standards that specify the
allowable emission levels for 189 toxic pollutants.  After a MACT
standard is promulgated, companies will generally have up to 3 years
to bring their facilities into compliance.  Recognizing that EPA
would need up to 10 years to complete the development of the
standards, the Congress established the Early Reductions Program to
achieve reductions more quickly.  According to EPA, the objective of
this program is to reduce the toxic air emissions that will
ultimately be regulated by the MACT standards earlier than the
standards would require.  Under the Early Reductions Program,
facilities that voluntarily reduce their emissions\2 by 90 to 95
percent from 1987 levels before the MACT standard is proposed may be
granted an additional 6 years to comply with the standard. 


--------------------
\2 The Early Reductions Program targets the emissions of hazardous
air pollutants. 


   ACCURACY OF DATA IN THE TRI IS
   UNCERTAIN
------------------------------------------------------------ Letter :3

On the basis of data in the TRI, EPA reported that toxic releases
were reduced by about 1.7 billion pounds, or 35 percent, from 1988 to
1992.  Over 40 percent of the reductions reported were concentrated
in three states--Louisiana, Texas and Virginia--and more than half of
the net reduction involved four chemicals--acetone, ammonium sulfate,
chlorine, and hydrochloric acid.  The companies themselves report
these reductions, which are not verified by EPA or the states. 

Although the data in the TRI are not verified to determine the
validity of the reported reductions, state officials responsible for
the TRI and voluntary reduction programs in Texas, Louisiana, and
Virginia told us that, according to follow-up inquiries, a number of
facilities have made environmental improvements.  State officials
said, for example, that one facility indicated that it had decreased
chlorine releases into the air by 27 million pounds by installing new
reduction burners.  In two other instances these officials said, one
facility reported that it had reduced underground injections of
hydrochloric acid by 152 million pounds, and another facility claimed
to have decreased underground injections of hydrochloric acid by 10
million pounds by converting the acid to a nontoxic material. 

According to EPA, however, a significant portion of the reported
reductions were due not to environmental improvements but to (1)
changes in the way the agency instructed facilities to report the
releases of specific chemicals, (2) changes in the way the releases
were estimated, or (3) decreases in production levels.  For example,
in 1989 the agency revised the instructions and guidance for
reporting on ammonium sulfate to allow facilities to report it as
ammonia.  EPA officials told us that the instructions were changed
because the ammonia, not the sulfate, is the substance of concern. 
This change resulted in a very large one-time reduction in reported
releases of ammonium sulfate, from over 600 million pounds in 1988 to
17.7 million pounds in 1990.  Over the same period, releases of
ammonia were reported to increase by about 190 million pounds.  This
net "paper" reduction of about 400 million pounds represents over 27
percent of the total reduction in toxic releases reported for
1988-91. 

According to EPA officials in the Office of Pollution Prevention and
Toxics, changes in estimating methods have also affected the volume
of releases reported because, while reporting facilities are
instructed to use the best method available to estimate releases,
they can change their estimating method from year to year at their
discretion.  An EPA-funded study of changes in reports to the TRI
between 1989 and 1990 showed that 24 percent of the facilities in the
sample had changed their estimating method.  Some of the changes
caused increases in reported releases, while others caused decreases. 
The net change appears to have been a 27-percent decrease in the
releases. 

In one such "paper" reduction, a Virginia facility reported a drop in
releases of methanol from 6.1 million pounds in 1988 to 2.4 million
pounds in 1989.  However, the state officials who investigated the
reduction said the reduction resulted from a change in estimating
methods, rather than a change in the quantity of methanol released. 
State officials in Virginia also provided data on 23 facilities that
reported significant reductions; 9 of these had changed their method
of estimating releases.  These nine facilities reported a total
reduction of nearly 7.5 million pounds. 

In a report analyzing the reasons for changes between 1990 and 1991
in the quantities of pollutants released into the air in Louisiana,
the Louisiana Chemical Manufacturers Association identified 19
facilities that had based their reported changes solely or partly on
changes in their estimating methods.  Of these facilities, 11
reported decreases in releases and 8 reported increases.  However,
the association reported that for many facilities, only part of the
change resulted from the change in estimating methods.  We were not
able to quantify the reductions associated solely with such changes. 

Changes in facilities' production levels, rather than pollution
controls or other strategies to reduce releases, also affect the
amounts of toxic substances released.  In a sample of reports to the
TRI for 1989-90, EPA found that reporting facilities most frequently
cited a change in production levels as the reason for the change in
the amounts of releases they reported; nearly 70 percent of the
facilities in the sample cited this as one of the factors influencing
changes in reported releases.  Decreases in production levels
exceeded increases, resulting in a net decrease of 18 percent in
reported releases. 

In our review of data submitted to the TRI by 23 facilities reporting
large volumes of toxic releases in Virginia, we found that 4 of the
23 facilities attributed some portion of their decrease in releases
to a reduction in production levels.  In fact, one facility stated
that its 474,000-pound decrease in releases of acetone in 1989 was
due solely to reduced production. 

In addition, some reported decreases in releases resulted when
facilities were closed.  For example, in Virginia more than half of
the 60-million-pound reduction in air releases reported for 1988-91
occurred when the state forced one facility to cease operation.  This
facility's releases of carbon disulfide went from 34 million pounds
to zero. 

In their reports to EPA, facilities are required to indicate changes
in their production levels.  However, EPA does not currently use
these data to determine the overall impact of changes in production
levels on the reported changes in releases. 

According to EPA officials, the agency does not have adequate
resources to analyze year-to-year changes in releases of toxic
substances to determine how changes in the production levels or
estimation methods have affected the reported reductions.  EPA
officials acknowledge that they need to do more to determine the
validity of reported reductions, but they are constrained by limited
resources.  To help address concerns about the validity of data in
the TRI, the agency plans to ask the states to validate large
increases and decreases in reported releases and inform EPA of the
results. 


   EPA REPORTS ACHIEVEMENTS IN THE
   33/50 PROGRAM
------------------------------------------------------------ Letter :4

According to EPA, which reports the achievements of the 33/50 Program
as part of its annual report on the TRI, the program exceeded its
interim goal of a 33-percent reduction, achieving a 40-percent
reduction, and is expected to exceed its goal of a 50-percent
reduction by 1995.  Reported releases and transfers dropped from
about 1.49 billion pounds in 1988 to 890 million pounds in 1992.\3
However, as discussed earlier, these reductions are based on
unverified data in the TRI.  Furthermore, the reported achievements
of this program need to be tempered by the information that (1) about
40 percent of the reductions claimed took place before the program
was formally established and (2) 26 percent of the reductions can be
attributed to companies not participating in the program. 

EPA included reductions achieved before the 33/50 Program was
established because it wanted to recognize accomplishments that
companies had made on their own before the program's February 1991
inception.  According to EPA officials, the agency used 1988 as the
base year from which it measured reductions because at the time the
program was established, the data for 1988 were the most accurate and
current base-year data available.  From 1988 to 1990, a 16-percent
reduction was reported in releases and transfers of the 17 chemicals
selected for the 33/50 Program.  However, in its 1992 report on the
TRI, the agency pointed out that in 1991 and 1992, after the program
was in place, a 29-percent reduction in releases and transfers was
reported for the 17 targeted chemicals. 

EPA recognizes that a considerable portion of the reductions reported
by the program were achieved by firms not formally participating in
the program, but the agency believes the program's presence
influenced some of these firms to reduce toxic releases.  Of the
reduction in releases of 596 million pounds of chemicals reported
from 1988 to 1992, 26 percent was achieved by firms not participating
in the program.  Although the 1,200 firms participating in the
program represent most of the largest facilities (responsible for
over 60 percent of releases of the 17 targeted chemicals), over 6,800
firms, or about 85 percent of those contacted, chose not to join the
program. 

EPA has highlighted the 33/50 Program as its major voluntary effort
for achieving pollution prevention through source reduction under the
Pollution Prevention Act of 1990.\4 However, this act requires
companies to report to the TRI only whether source reduction was used
to achieve reductions in toxic releases; they do not have to report
how much of the reduction was achieved through source reduction. 
Thus, while EPA promotes source reduction as the preferred means of
reducing releases, it cannot determine the amount of the reduction
that results from source reduction activities. 

In 1991, EPA intended to request information on the extent to which
facilities reporting to the TRI had used source reduction.  However,
under the Paperwork Reduction Act, the Office of Management and
Budget was required to review EPA's proposal to request this
information.  The Office of Management and Budget would not allow EPA
to do so, citing an absence of specific authority in the legislation
and the burden such a request would impose on industry. 

At our request, in December 1993 state officials in Texas surveyed a
sample of facilities about how they had achieved their reductions in
releases.  Over 81 percent of the facilities responding said they had
used source reduction or pollution prevention methods to achieve
their reported reductions of over 20 million pounds.  Among the 23
companies we reviewed in Virginia, we found 11 cases in which source
reduction efforts reportedly resulted in significant decreases in
releases.  For example, one company in Virginia said it had reduced
releases of dichloromethane from 646,000 pounds in 1988 to zero in
1990 by switching to a nontoxic substance.  An EPA-funded survey of
over 1,200 firms reporting to the TRI in 1989 and 1990 showed that 40
percent used source reduction measures to achieve reductions in toxic
releases. 

A public interest group recently issued a report critical of the
33/50 Program,\5 primarily for its failure to identify the extent to
which reported reductions could be attributed to pollution
prevention, or source reduction, measures.  EPA responded by pointing
out that the 33/50 Program encouraged but did not require pollution
prevention.  According to EPA, the program's goal was to reduce
releases and transfers of high-priority toxic chemicals; while its
preferred method was source reduction, recycling, energy recovery,
treatment of toxic substances to remove or reduce toxicity, and
disposal were also acceptable methods of reducing releases. 


--------------------
\3 1992 Toxic Release Inventory, Public Data Release, U.S. 
Environmental Protection Agency, Office of Pollution Prevention and
Toxics (Washington, D.C.:  Apr.  1994). 

\4 Source reduction includes measures such as substituting a nontoxic
chemical for a toxic chemical. 

\5 Pollution Prevention or Public Relations?, Citizens Fund
(Washington, D.C.:  May 1994).  Citizens Fund is the research and
education affiliate of Citizen Action. 


   PARTICIPATION IN EPA'S EARLY
   REDUCTIONS PROGRAM HAS BEEN
   LIMITED
------------------------------------------------------------ Letter :5

While giving EPA 10 years to complete development of the MACT
standards for all source categories, the Congress provided for the
Early Reductions Program to stimulate reductions in toxic air
emissions before the MACT standards are proposed.  To qualify for the
6-year extension for complying with requirements under the program, a
facility must first establish base-year emission levels and then
demonstrate a 90- to 95-percent reduction from those levels. 

Participation in the Early Reductions Program has been limited.  As
of September 1994, EPA had only 40 active applications from
facilities and had approved 12 for the 6-year extension, provided the
applicants are able to demonstrate achievement of the required
reduction.  EPA officials told us that the number of facilities that
are eligible to participate in the program is unknown.  As of June
1994, EPA had identified between 8,000 and 13,000 major sources of
pollution that are subject to either a 1992 or a 1994 MACT standard,
but officials recognize that the benefits of the program do not apply
for all of the identified major sources.  Thus, taking into account
that the Early Reductions Program may have no practical application
for some major sources, EPA officials estimate that fewer than 10
percent of the eligible facilities are participating in the program. 

Of the 40 active applications, 20 came from the synthetic organic
chemical manufacturers that will have to comply with the Hazardous
Organic NESHAP (National Emission Standards for Hazardous Air
Pollutants), the first major MACT standard issued by EPA.  This
standard is intended to limit the emissions of 149 hazardous air
pollutants used in this manufacturing industry's production process. 
EPA estimates that there are about 370 facilities subject to the
Hazardous Organic NESHAP.  Although 53 applications were submitted,
33 were subsequently withdrawn.  Thus, the 20 active applications
represent about 5 percent of the facilities subject to this standard. 
As of September 1994, EPA had approved the base-year emissions data
of six of the applicants subject to the standard.  These applicants
will receive a 6-year extension on compliance requirements if they
can demonstrate the required reduction from their base-year emission
levels. 

Officials from industry, the states, and EPA told us that the
requirement for developing historical emissions data has been a major
reason for the limited participation.  The compilation of base-year
data is a difficult process, requiring a significant investment of
time and personnel.  Several facilities indicated that their decision
to withdraw their application to participate in the program was due
at least in part to the difficulty of finding the resources and
personnel needed to provide the required historical emissions data. 
One facility, which has used a computer system to track emissions
since before 1987, stated that over 900 staff hours would be needed
to present base-year data in the form EPA requires. 

EPA and state officials acknowledge that developing accurate
base-year emissions data may present an even greater problem for
facilities that lack adequate records.  EPA cited some alternatives
to requiring facilities to provide these data, such as requiring them
to (1) demonstrate a specified percentage reduction from current
levels rather than base-year levels, which would be easier for
companies to do, or (2) have a specified technology in place. 
According to EPA officials, the agency has used one of these
alternatives in proposing the MACT standard for chromium
electroplating, which specified the use of a technology, thereby
eliminating the need for historical data. 

Uncertainty about how the states' standards will relate to the
federal MACT standards has also been cited as an impediment to
participation in the Early Reductions Program.  According to a
representative from the State and Territorial Air Pollution Program
Administrators and the Association of Local Air Pollution Control
Officials (STAPPA/ALAPCO), some states may require controls that go
beyond the requirements in the federal MACT standard.  If a state's
limits exceed those of the MACT standard, industry will be forced to
meet the tougher standard.  According to some industry
representatives, there is little incentive to apply for the program
as long as a state's regulations could potentially require controls
in addition to those already required. 

According to state officials, delays in the promulgation of the MACT
standards have also contributed to the reluctance of facilities to
participate in the Early Reductions Program.  EPA's failure to
propose the MACT standards by the statutory deadlines added to the
uncertainty about what benefits facilities would derive from making a
90- or 95-percent reduction before the MACT standards are proposed,
according to state officials.  EPA officials acknowledge that a delay
in proposing a MACT standard lengthens the time facilities have
before they must comply with the standard.  For some facilities, a
6-year extension in exchange for making early reductions offers
little benefit if a delay in the promulgation of the MACT standard
provides the facility with adequate time to comply. 

Industry officials we contacted also cited the cost of pollution
control equipment, given the uncertainty of control requirements, as
another factor limiting participation in the Early Reductions
Program.  Representatives of the chemical industry indicated that
until the state and federal control requirements are definitive,
facilities will be reluctant to invest significant sums in equipment
only to discover that a different technology is needed and more
capital investment is required. 


   CONCLUSIONS
------------------------------------------------------------ Letter :6

Substantial reductions in releases of toxic substances have been
reported in EPA's Toxic Release Inventory.  However, there is little
or no review by EPA or the states of the validity of year-to-year
changes in the reported releases.  Furthermore, EPA's not adjusting
for reductions in toxic releases that result from changes in the
instructions and guidance, method of estimating releases, and
production levels limits the usefulness of data in the TRI and tends
to result in an overstatement of the program's accomplishments.  EPA
recognizes the shortcomings in the data in the TRI and plans to ask
the states to validate large increases and decreases in their
reported releases. 

The reported reductions in releases of the chemicals targeted by the
33/50 Program have led EPA to conclude that the program has exceeded
its interim goal of a 33-percent reduction and will meet or exceed
its goal of a 50-percent reduction.  However, a significant
proportion of these reductions occurred before the program was
established or were made by companies that are not participating in
the program.  Therefore, reductions in releases of the 17 chemicals
cannot be attributed solely to the program.  Also, because the 33/50
Program's progress is being measured by data in the TRI, the volume
of the overall reductions resulting from source reduction techniques
is not known.  In another report to be issued this month,\6 we are
recommending that to evaluate progress in preventing or reducing
pollution at its source, EPA obtain and analyze data on the
quantities of waste that were prevented or reduced through source
reduction activities. 

The Early Reductions Program thus far has had limited success in
attracting participants.  As a result, the environmental benefits of
reducing toxic emissions earlier than required by regulation are not
being realized.  While EPA may consider alternatives to the
requirement that facilities provide historical base-year emissions
data, it is too early to determine whether such alternatives would
promote more interest in the program, given the current uncertainty
about whether federal and state regulations will differ, delays in
the promulgation of the MACT standards, and the size of the capital
investments required. 


--------------------
\6 Toxics Substances:  EPA Needs More Reliable Source Reduction Data
and Progress Measures (GAO/RCED-94-93). 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :7

We conducted our review from February 1993 through May 1994 in
accordance with generally accepted government auditing standards. 

To determine whether the emission reductions reported were valid, we
selected a judgmental sample of facilities that reported the largest
reductions of specific chemicals to Texas, Louisiana, and Virginia
and asked state officials to document the way these reductions were
achieved.  We also interviewed officials in EPA's Office of Pollution
Prevention and Toxics and state officials to determine what policies
and procedures were implemented to ensure the quality of the data. 
In addition, we reviewed studies initiated by EPA to determine the
validity of the data submitted to the TRI in 1987, 1988, 1989, and
1990 and examined EPA's annual reports on the TRI. 

To determine the progress of the 33/50 Program in meeting its goals
for reducing releases and transfers, we interviewed officials
responsible for the program in EPA's Office of Pollution Prevention
and Toxics.  We also examined and analyzed status reports prepared by
EPA on the 33/50 Program. 

To determine the status of the Early Reductions Program, we
interviewed officials responsible for the program in the Office of
Air Quality Planning and Standards.  We analyzed documents maintained
by EPA on participation.  We also interviewed officials representing
the Chemical Manufacturers Association, the Synthetic Organic
Chemical Manufacturers Association, and the State and Territorial Air
Pollution Program Administrators and Association of Local Air
Pollution Control Officials (STAPPA/ALAPCO) to determine reasons that
facilities do not participate.  In addition, we interviewed EPA,
regional, and state officials for their opinions on the reasons for
nonparticipation.  We also reviewed the formal withdrawal letters
submitted by former applicants to determine their reasons for
withdrawing.  We contacted some of these companies for additional
information. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :8

We discussed the information in this report with the responsible EPA
officials, including the Director of the Environmental Assistance
Division, Office of Pollution Prevention and Toxics, and the Director
of the Emission Standards Division, Office of Air Quality Planning
and Standards; we incorporated their comments where appropriate. 
These agency officials generally agreed with the information in this
report but believed that the agency deserved more credit for
achieving reductions under its voluntary 33/50 Program.  As
requested, we did not obtain written agency comments on a draft of
this report. 


---------------------------------------------------------- Letter :8.1

As arranged with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 30 days after the date of this letter.  At that time, we will
send copies to the Administrator of EPA.  We will also make copies
available to others on request. 

This work was performed under the direction of William McGee,
Assistant Director, Air Quality Issues, who can be reached at (919)
829-3500 if you or your staff have any questions.  Major contributors
to this report are listed in appendix I. 

Sincerely yours,

Peter F.  Guerrero
Director, Environmental
 Protection Issues


MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix I


   RESOURCES, COMMUNITY, AND
   ECONOMIC DEVELOPMENT DIVISION,
   WASHINGTON, D.C. 
--------------------------------------------------------- Appendix I:1

Bernice Steinhardt, Associate Director
William F.  McGee, Assistant Director


   NORFOLK REGIONAL OFFICE
--------------------------------------------------------- Appendix I:2

Edwin J.  Soniat, Evaluator-in-Charge
DeAndrea M.  Leach, Evaluator

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