II INVESTIGATION INTO NONAEROSOL USES OF CHLOROFLUOROCARBONS

A. Industrial Use Profiles

As part of Phase II of the chlorofluorocarbon (CFC) program,
EPA is investigating ways to further reduce CFC emissions in the
United States. EPA is examining all uses of CFCs not covered
under the Phase I rule to determine where feasible controls may
be possible.

EPA and FDA held two public meetings, the first in October
1977 and the second in February 1978, to obtain information from
industry and other interested parties about nonaerosol uses of
CFCs. The following is a summary of preliminary findings from
these meetings and from reports by the Rand Corporation (Rand),
E.I. duPont deNemours & Co., Inc. (DuPont), SRI International
(SRII), and others.

The following lists the major uses of CFCs in the United

States in terms of both quantity of CFCs used and quantity of
CFCs emitted:

1. Solvents used for cleaning and drying.

2. Blowing agents for manufacturing urethane and
nonurethane foam for various products including
packaging materials, insulation, and furniture.

3. Heat transfer medium (refrigerant).

a) Mobile air conditioners.

b) Refrigerators and freezers.

c) Centrifugal and reciprocating chillers or
air conditioners.

-16-


environmental damage into a firm's production costs as discussed
above, by instituting a fee for using or emitting a unit of the
substance that causes the environmental damage. If a payment of
$4 was required in order to emit the pollution resulting from the
production of each unit of good in the example above, then the
perceived cost of production would be equal to the true total
cost of $14. The firm could reduce production costs by reducing
emissions. If the firm were to reduce emissions by 50 percent at
a cost of $1, the resulting production costs would be $10 for
inputs, a $2 fee for emitting 50 percent of the original level of
pollution, and $1 emission control costs, for a total production
cost of $13. Since this is a net reduction in production cost,
an individual profit maximizing firm would have incentive to
adopt the emission controls under the use fee system.

In the case of CFCs, all the CFCs used in a process are
eventually emitted. Therefore, rather than impose a fee on CFC
emissions, which could be difficult to monitor, a fee could be
imposed on CFC use. Since the health and environmental damage
from CFC emissions does not depend on the source, a single per
pound fee for CFC use would be appropriate. This implicitly
assumes a zero discount rate for the effects of future emissions
from the existing CFC bank.

One major problem with instituting a use fee is its
computation. The optimal use of a chemical is defined by the
point at which the marginal social value of chemical use
associated with emissions equals the marginal cost of production
plus the marginal environmental costs or externalities. The
correct tax would be the value of the marginal environmental
damage caused by the chemical emissions. Since it is very
difficult to estimate the value of environmental quality, direct
computation of the fee would be impossible. If a required level
of emission reduction could be identified, the use fee necessary
to achieve that reduction could be estimated from an analysis of
all the elasticities of demand for CFCs. Since this analysis may
be prohivitive, an iterative approach to setting the fee could be

-36-


e) Whipped Topping Stabilizer

CFC-115 is used as a stabilizer for whipped toppings in
spray cans. Approximately 100,000 pounds are used for this
purpose annually. Market growth historically has been 2 to 4
percent annually; however, a market decline attributable to
concern over possible regulation has been observed.

Research continues on substitutes. At this time, no
chemicals appear as effective as CFC-115 in stabilizing whipped
toppings.

£) Other Miscellaneous Uses

There are other miscellaneous products, such as those listed
below. This list is not meant to be exhaustive, since there may
be uses of CFCs of which we are not aware.

-aerosol chiller for isolating defective electronic parts.
-drying system in numismatic blanks, coins, and medals.
-dielectric fluid in transformers.

-cleaner and preserver for printed material, films and
Phonographic recordings at the Library of Congress.

-coolant in the uranium enrichment process of nuclear
power plants.

B. Regulatory Options

The two parts of regulatory pollution control are
determining the level of emission reduction sufficient to protect
human health and the environment, and defining and implementing
the least cost method of achieving emission reduction. To define
the best method for reducing emissions, EPA is examining three

-32-


Several reports are essential to the completion of the risk
assessment. The Rand Corporation report provides information on
the nonaerosol CFC industries and their emission rate profiles.

A draft final report is expected from the Rand Corporation in the
Fall of this year this summer. SRI International, using Rand's
emission rates, is analyzing available control options from a
cost/benefit point of view. A general cost/benefit analysis also
is the focus of the University of Maryland report. The two
latter reports will be submitted to EPA's Office of Research and
Development in the early Fall.

As required in Section 153 of the CAA, the National Academy
of Sciences has the responsibility of reviewing the state-of-
knowledge of atmospheric physics and chemistry, the health
effects, environmental effects, and alternative control measures
associated with stratospheric ozone depletion. The NAS report on
atmospheric physics and chemistry should be available in
September; the other studies will follow shortly thereafter.

Data from these studies will provide additional input to the risk
assessment. The EPA estimates of CFC emission reductions
resulting from various control scenarios should be available by
the end of the year.

-41-


These regulations primarily affected four commercially used
compounds, namely, CFC-1l (F-11), CFC~12 (F-12), CFC-114 (F-114),
and CFC-115 (F-115).”

Comments received during the review of the proposed rule in
the Spring of 1977 included requests from many companies for
exemptions for their products from the proposed CFC rule. The
interagency work group developed the criteria used to evaluate
these requests. The criteria guidelines included 1) the
availability of substitutes; 2) the economic significance of the
product, including the economic effects of removing the product
from the market place; 3) the environmental and health impacts of
the product and its substitutes; and 4) the effects on the
quality of life resulting from no longer having the product or a
reasonable substitute available.!2 Each product for which an
essential use exemption was requested was judged by these
criteria. EPA and FDA then determined that certain aerosol
products would be exempted in both the EPA and FDA regulations.
The EPA regulation exempted

1. mercaptan stench warning devices (an odor-
warning device used to alert coal miners of a
pending danger),

2. release agent for molds used in the production of
plastic and elastomeric materials,

3. flying insect pesticides used in nonresidential food

handling areas and for space spraying of aircraft,

4. diamond grit spray,

*The letters F (referring to Freon, a duPont trade name), R, and
CFC all refer to chlorofluorocarbons. In the refigeration indus-
try, the letter R refers to refrigerant.

-10-


31.

32.

33.

34.

35.

36.

37.

38.

39.

40.

The Rand Corporation; "The Use and Emissions of
Chlorofluorocarbons in Centrifugal and Reciprocating
Chillers"; prepared for The RAND Corporation by The
International Research and Technology Corporation;
Preliminary Draft; April 1979.

The Rand Corporation; "The Use and Emissions of
Chlorofluorocarbons Sterilization Applications"; Preliminary
Draft, RAND/WN-10275-EPA; Sept. 1978.

The Rand Corporation; "The Use and Emissions of
Chlorofluorocarbons in Fire Extinquishing Applications";
Preliminary Draft, RAND/WN-10276-EPA, Sept. 1978.

The Rand Corporation; "Miscellaneous Products"; Preliminary
Draft, RAND/WN-10278-EPA; March 1979.

Halter, Paul W.; Letter from the Environmental Coordinator,
Freon Products Division, E.I. DuPont de Nemours & Co. to
Ferial Bishop, Office of Toxic Substances, Environmental
Protection Agency; August 7, 1978.

Keller, Douglas V. Jr.; Testimony on behalf of Otisca
Industries, Ltd. before the Public Meeting on Nonaerosol
Uses of Fully Halogenated Chlorofluoroalkanes (Chloro-
fluorocarbons); February 23, 1978.

SRI International; "Policy Assessment of Alternatives for
Ozone Layer Protection"; Unedited Discussion Draft; SRI
Project 6806; May 4, 1979.

Department of State Incoming Telegram from the U.S. Mission,
Geneva, Switzerland; "WMO Statement on Modification of
Atmospheric Ozone Layer"; November 1978.

Blum, Barbara, Deputy Administrator, EPA; Speech before the
International Conference on Chlorofluoromethanes; Munich
Germany; December 6-8, 1978.

Department of State Incoming Telegram from the American
Embassy, Stockholm, Sweden; "Swedish Regulation of Aerosol
Sprays"; February 1978.

-51-


10.

ll.

12.

13.

14.

15.

16.

17.

18.

19.

20.

Environmental Protection Agency; "Final Action Support
Document to Final Regulation on Fully Halogenated
Chlorofluoroalkanes"; March 17, 1978.

Federal Register Notice; 43 F.R. 11301; March 17, 1978;
"Certain Fluorocarbons (Chlorofluorocarbons) in Food, Food
Additive, Drug, Animal Food, Animal Drug, Cosmetic and

Medical Device Products as Propellants in Self-Pressurized
Containers".

Environmental Protection Agency; "Essential Use
Determinations--Revised Support Document to Final Regulation
on Fully Halogenated Chlorofluoroalkanes"; March 17, 1978.

Environmental Protection Agency, Office of Air Quality
Planning and Standards; "Preliminary Economic Impact
Assessment of Possible Regulatory Action to Control

Atmospheric Emissions of Selected Halocarbons"; prepared by
Arthur D. Little, Inc.; September 1975.

Environmental Protection Agency, Office of Planning and
Evaluation; "The Economic Impact of Potential Regulation of
Chlorofluorocarbon-Propelled Aerosols, Final Report";
Contract No. 68-01-1918; prepared by International Research
and Technology Corporation (IR&T); April 1977.

Brunner, Perry, EPA; Personal Communication; 1978.
Sterling, Sherry, EPA; Personal Communication; 1978.

Federal Register Notice; 43 F.R. 24818; June 7, 1978;
"Notification of Export of Polychlorinated Biphenyls and
Fully Halogenated Chlorofluoroalkanes Under Section 12(b)".

Federal Register Notice; 43 F.R. 29001; July 5, 1978; "Fully
Halogenated Chlorofluoroalkanes - Final Rules; Correction".

Federal Register Notice; 43 F.R. 55241; November 27, 1978;
"Pully Halogenated Chlorofluorocarbons - Clarification of
Final Rule".

Federal Register Notice; 43 F.R. 59500; December 21, 1978;

“Fully Halogenated Chlorofluoroalkanes; Final Rule amending
pesticide essential use exemption".

-49-


balance of methyl chloroform and carbon tetrachloride is
currently being developed. Once sources of the chemical are
identified by the general materials balance, emissions data can
be collected on an annual basis. Annual materials balances are
planned by OTS in the near future for other potential
stratospheric ozone depleters.

OTS has developed an interagency agreement with the National
Oceanic and Atmospheric Administration (NOAA). Under this
agreement, NOAA will organize a workshop in late September that
will focus on methodologies for screening chemicals for
stratospheric ozone depletion potential. OTS expects the
methodology to be integrated into risk assessment procedures for
the premanufacturing review of new chemicals required by Section
5 of TSCA. Moreover, OTS will recommend to the Interagency
Testing Committee that their ranking of existing chemicals
include consideration of potential to adversely modify the
stratosphere. OTS is also developing a methodology for
identifying chemical substances that may have potential for
affecting the radiative transfer balance of the atmosphere.

The Stratospheric Impact Research and Assessment (SIRA)
Program of the EPA Office of Research and Development has the
responsibility under Section 153 of the CAA to study human causes
of stratospheric ozone depletion, its effects on public health
and welfare, and alternative methods for regulation. This study
includes the effects on human health and terrestrial and aquatic
ecosystems of ultraviolet radiation associated with ozone
depletion, and climatic effects research associated with changes
in penetrating ultraviolet radiation. Monitoring UV radiation,
developing instrumentation to measure UV radiation, and analyzing
socioeconomic effects of UV radiation on health and the
environment are also important program considerations. The
progress of EPA's research program will be reported to Congress
on or before January 1, 1980, as required under Section 153(g) of
the CAA.

-47-


The following is a summary of emission reduction strategies
identified by the EPA:

1. Modify current technology.
a) Improve design to reduce CFC emmissions.
b) Substitute another substance for CFCs.
c) Improve operating procedures.

2. Recover and recycle used CFCs during normal use and
at disposal.

3. Destroy CFCs at disposal.
4. Ban the use of CFCs.

These strategies are being reviewed in Phase II to determine
their application to the various CFC uses. Below is a summary of
progress to date.

1. Solvents

CFC solvents are used by some 2000 plants as industrial
cleaning and drying agents. The primary user is the electronics
industry. Approximately 65 million pounds of CFC-113 solvent
(which account for over 90 percent of all CFC solvent sales),
were used and promptly emitted in 1977.26 The use of CFC-113 as
a solvent may triple to nearly 200 million pounds by 1990.2°

DuPont estimates that emissions can be reduced 35 to 50
percent through equipment redesign and recycling of waste. These
modifications are estimated to be cost effective at current
prices. However, in preliminary reports The Rand Corporation
warns that by improving equipment efficiency, the cost of using
CFC-113 as a solvent may decrease relative to other solvents
thereby increasing the use and emissions of cFC-113.25 EPA is
evaluating substitutes as well as strategies for reducing overall

emissions from solvent uses.

-19-


used; depending on the resulting emission reduction, the fee
could be adjusted up or down. However, some business leaders
claim that rapidly changing use fees would complicate investment

and other business decisions because of added uncertainity of the
market .37

Currently EPA does not impose use fees. There are many
legal questions that must be addressed before use fees could be
employed as a means of controlling emissions. This strategy
needs to be studied further.

b) Marketable Permits

A use fee system would not set a limit on chemical use.
Instead, a fee would only be an economic incentive to reduce
emissions. Firms would be free to use as much CFCs as they like
so long as the fees were paid. A marketable permit system would
take the opposite approach. EPA would set a rigid quota, and
firms would bid for the rights or permits to a portion of that
quota. The permits would have a positive economic value so long
as the quota was set below whatever demand would have been in the
absence of regulation.

Unlike the use fee system that would set a single price for
CFC usage, the price of a marketable permit would be determined
on the open market. The final equilibrium price of the permit
would primarily depend on 1) the stringency of the quota in the
short run; 2) the ability of firms to reduce CFC usage at a per
unit cost below the unit cost of the permit; and 3) final demand
for products that require CFCs.

The advantage of using a marketable permit approach to
allocate a quota is that it allows the market to determine which
uses of CFCs are most highly valued or "essential". As the
permits are traded, the producers of those products for which
there are no substitutes will be willing to pay more for the
permits in order to get their needed CFCs. As the price of the
permits increases, industry will stop manufacturing nonessential

-37-


SUMMARY

As mandated by Section 155 of the Clean Air Act Amendments
of 1977, PL 95-95 (CAA), the Environmental Protection Agency
(EPA) submits to Congress this report on the progress of
regulation to protect the stratospheric ozone. By doing this,
EPA fulfills the requirement that a final report be prepared
within two years of legislative enactment of the CAA. As
directed, subsequent follow-up reports on actions to protect
stratospheric ozone will be prepared annually.

This report summarizes the final action taken against the
use of chlorofluorocarbons (CFCs) as propellants in aerosol
products. Because regulatory development had begun under the
Toxic Substances Control Act (TSCA) before the CAA was passed,
EPA promulgated the CFC aerosol ban regulation under Section 6 of
TSCA.

This report also outlines the current investigation of
nonaerosol uses of CFCs, the status of international cooperation
to control CFCs, and the evaluation of other possible ozone
depleting substances. If EPA finds that there is a need to
require control of CFC emissions from nonaerosol uses, EPA will
use the authority of Section 155 of the Clean Air Act. '

Together with the Food and Drug Administration (FDA), EPA
issued final rules prohibiting the manufacturing and processing
of CFCs for nonessential aerosol propellant uses in March 1978.
EPA and FDA based this action on the theory, supported by labora-
tory determined reaction rates and ambient measurements of CFC
and other reaction species, that CFCs may deplete the ozone layer
that shields the earth's surface from harmful ultraviolet radia-
tion emanating from the sun. Scientific evidence shows that
increased exposure to short wavelength ultraviolet radiation can
harm human health and the environment.


Included in this category are those aerosol products not
covered by the ban on the manufacture and processing of CFCs as
propellants for aerosol products. EPA's rule defines an aerosol
propellant as a substance that expels a substance different from
itself from a container. Aerosol products such as the
pressurized blower that contain only CFCs are exempt from the CFC
rule, but are currently under investigation. The information
below is based on the Rand's preliminary analysis of

34

miscellaneous uses. Investigation is continuing on this

category of products to develop more detailed information.
a) Warning devices

Warning devices are those products which use CFCs to sound
an alarm. This category includes devices which can be divided
into prompt emitting products and nonprompt emitting products.
The single-station heat detector is a nonprompt emitting product
since it may sit idle many years before discharging. Intruder
alarms, boat horns and bicycle horns are considered prompt
emitters. In all types of warning devices a chlorofluorocarbon,
generally CFC-12, is released by a detector mechanism through a
horn.

The warning device industry uses an estimated 1.5 million
pounds of CFCs per year. Roughly 5000 pounds of CFCs were
emitted in 1975 for heat detectors alone. Projected emissions
for heat detectors in 1990 may be as high as 90,000 pounds.

b) Pressurized Blowers and Drain Cleaners

Products from this category emit approximately 1 million
pounds of CFCs per year. Emissions are projected to double by
1990.

Pressurized blowers are used to blow dust from photographic
work, electronic equipment, lenses, graphics work, and art
work. CFC-11 is commonly used as the propellant. Carbon
dioxide, nitrogen and compressed air have been mentioned as

~-30-


4. Direct contact freezing agent in liquid fast
freezing applications.

5. Diluent gas in sterilizing applications.

6. Active agent in fire extinguishing applications
(bromofluorocarbons*).

7. Miscellaneous uses.

These uses of CFCs can be divided into two groups, prompt
emitters and nonprompt emitters. Prompt emitters are defined as
products which emit all CFCs within one year, either during
manufacturing or immediately upon use. Prompt emitters include
solvents used for cleaning and drying; blowing agents for
flexible urethane foams and nonurethane packaging foams; direct
contact freezing agent in liquid fast freezing; and diluent gas
in sterilizing applications.

Nonprompt emitters retain CFCs over a long period of time.
Although some emissions occur during the manufacturing process
itself, manufacturing emissions for most nonprompt emitters
represent a small portion of total CFCs used. The remaining
CFCs, not emitted during manufacturing, become part of what is
referred to as the CFC bank. The CFC bank represents CFCs that
are stored in products such as air conditioners and insulating
foams and are emitted slowly during the normal use or disposal of
the product.

For example, a nonprompt emitter such as an insulating foam
May contain a total of one pound of CFCs, but it may take many
years of normal product use for these CFCs to be emitted to the
atmosphere. Disposal emissions occur when a product reaches the

* Although not included in Phase I, bromine compounds such as
Halon 1301 are included in Phase II because they have been
identified as potential ozone depleters in Section 153 (a) of the
Clean Air Act.

-17-


CFC-11, CFC-113, CFC-114, and CFC-115 are also used in small
quantities. Rand predicts that without controls, annual CFC
consumption for this industry will climb to approximately 65
million pounds by 1990.27

CFC recovery is a potential, yet untested technological

27 since the

method of reducing emissions from packaging foams.
exact nature of emissions from these foams is not known, it is
impossible to predict the emissions reduction attainable through
recovery. Although available data suggest a maximum possible
recovery of 60 percent, evaluation of applicable control

technology is needed in this area.

A substantial portion of packaging foam, especially extruded
polystyrene sheet, is pentane blown. However, pentane does pose
a serious fire hazard. Paper, on the other hand, may be the
safest and cheapest substitute for CFC blown packaging foam.

c) Rigid Urethane Insulating Foams

Insulating foams such as rigid urethane foams and extruded
polystyrene board required 58 million pounds of CFCs for
manufacturing in 1977, primarily CFC-1l1. Because of the rapidly
growing demand for insulation, CFC consumption in this category
is expected to quadruple to approximately 236 million pounds by

1990. This insulation is widely used in both the residential and
commercial construction industries.

Unlike the flexible and packaging foams discussed above,
rigid foams retain the CFCs used in production for many years.
Since CFCs function as a better insulating medium than air, the
more CFCs that are retained, the better the insulating qualities
of the foam. Only about 15 percent of the CFCs used is emitted
during the manufacturing process. Emissions in 1977 are
estimated to have been approximately 20 million pounds. Rand
predicts annual emissions to increase to approximately 85 million
pounds annually by 1990, taking into account the gradual release

of CFCs from foams in use and a 50 percent release of the CFCs
remaining at the time of disposal of the foams.

-22-


-egt-

SUMMARY OF ESTIMATES OF USE,

Table 1

EMISSION,

FOR NONAEROSOL APPLICATIONS*
(million of pounds)

AND BANKING OF CFCS

1976 1990

1976/1977 1990
CFC Application Used __Emitted Used  Emitted Banking
Solvents 65 65 200 200 0 0
(CFC-113)
Urethane Flexible 35 35 59-98 59-98 0 0
Foams (CFC-11)
Nonurethane Packaging 24 24 65 65 0 0
Foams (CFC-11, 12, 113,
114, 115)
Insulating Foams 58 20 236 85 230 1400
(CFC-11)
Mobile Air Conditioners 96 83 131 128 220 380
(CFC-12)
Chillers (CFC-11, 12, ? 14 ? 20 60 90
114, 502)
Fire Extinguishers 2 <1 ? <2 6 35
(Halon 1301)
Liquid Fast Freezing 6 6 18 18 0 0
Sterilization 12 12 ? ? 0 0
(CFC-12)
Totals (298) 278 (709-748) (601-640) 666 2100

*all estimates are from preliminary reports by the Rand Corporation.


possible substitutes; however, more study is needed to determine
the effectiveness of these substitutes.

Drain cleaners primarily use CFC-12. CFC-114 is also used
in drain cleaners, but to a lesser extent. Hydrocarbons can be
substituted for the CFCs; however, the higher flammability of
hydrocarbons may make them a less desirable alternative for
CFCs. Although lye is used as a drain cleaner, the consumer
faces considerable danger during normal use.

¢) Coal Cleaning

Interest in the research and development of using CFCs to
clean coal is growing. Newly developed coal cleaning processes
use CFC-11 and may be more efficient and less costly than
currently employed coal cleaning techniques. Coal cleaning
processes which use CFCs reduce the sulfur and ash emissions from
coal incineration. The energy value (BTUs) per pound of CFC-
treated coal is greater than untreated coal or hydro-treated
coal. 36

Because the CFC coal cleaning processes are totally
enclosed, emissions are limited to leaks from mechanical seals,
air streams and residues on the products. As a pollution control
measure in the incineration of coal, coal cleaning could become a
major source of CFC emissions by 1990. One company estimates
that annual emissions could be as high as 3.5 million pounds by
1989,

d) Presurgical Skin Cleaner and Skin Chilling

In 1976, presurgical skin cleaners used 100,000 pounds of
CFC-113. Small amounts of CFC-113 are also used as a coolant to
relieve myofascial pain and muscle spasm, to freeze skin for
surgery, and to topically anesthetize patients. Applied to the
surface of the skin, CFCs evaporate immediately; thus, these
products are considered prompt emitters.

-31-


Even though EPA and FDA continue to receive requests for
exemptions to the regulations, to the best of our knowledge, the
impact of this regulation on American businesses does not appear
to be greater than anticipated. Currently, EPA is in the process
of reviewing contractor proposals to undertake a retrospective
economic study of the actual economic impacts associated with the
aerosol ban rule. We anticipate that this contract will be
negotiated by November 1979.

C. Export Notification

On June 7, 1978, EPA published interim procedures covering
notification for export of polychlorinated biphenyls and fully
halogenated chlorofluoroalkanes.27 As required by Section 12(b)
of TSCA, individuals must notify EPA if they export or intend to
export chemicals subject to proposed or final actions under
Section 6 of TSCA. Exporters of these chemicals will notify EPA
of the dates of each shipment, the country to which the chemicals
are being exported, and related information. EPA in turn will
notify the importing countries of the fact of export. Currently,
EPA is developing permanent procedures applicable to all
chemicals subject to actions under TSCA. EPA intends to propose
these procedures later this year.

D. Amendments to the Rule

Since the publication of the rule, EPA continues to receive
and review requests for exemptions and clarifications of the
rule. One minor notice corrected the format of the rule to
conform with requirements of the Code of Federal Regulations.
EPA published an important clarification statement on November
27, 1978.19 the notice states that the definition of "aerosol
propellant" covers not only CFCs which directly expel active

18

ingredients but also CFCs which modify the expelling force to
achieve the propelling effect in the desired manner. Vapor

pressure depressant, flame retardant, and solvent uses may be
“aerosol propellant" uses.

-14-


nonmelanoma skin cancer may be caused by exposure of the human
skin to UV-B radiation. In addition, increased incidence of
sunburn (erythema) can also be expected from UV-B exposure.

Previous studies reported that a two percent increase in
nonmelanoma skin cancer occurs from a two percent increase in
UV-B resulting from a one percent depletion of ozone, assuming
all other factors (e.g., lifestyle, ethnic makeup) remain con-
stant. More recent analyses project increases in nonmelanoma
skin cancers to be four percent for a two percent increase in
uv-B.° Thus, current estimates of an 18 percent ozone depletion,
at equilibrium, would indicate a 72 percent increase in
nonmelanoma skin cancers. White-skinned people who spend more
time outdoors have a much greater incidence of skin cancer, most
frequently occurring on those body parts habitually exposed to
sunlight.

It is also believed that increased UV-B leads to an
increased incidence of melanoma skin cancer. This cancer
accounts for about 2 percent of skin cancer cases and about one-
half of these are fatal. The quantitative uncertainties of skin
cancer predictions are expected to be reduced in the next several
years by conducting more detailed epidemiological studies and
more accurate measurements of UV-B on exposed areas of the skin
of various population cohorts.

Enhanced UV-B radiation flux has been shown to adversely
affect growth and production of certain plants and animals.®
Terrestial plants show damage when exposed to more UV-B in the
laboratory. However, the presence of visible radiation in
natural sunlight may induce photorepair or some other adaptive
mechanism to mitigate UV-B damage. Some aquatic animal and plant
species living near the water surface appear to be very sensitive
to UV-B for at least part of their life cycle. Climatic effects
due to ozone depletion and increased CFC burden in the atmosphere

are anticipated, but are not quantifiable nor measurable at
present.


used and emitted to the atmosphere. The market is likely to
expand rapidly through 1985 when CFC-12 use may reach as high as
18 million pounds annually.

However, the rising cost of CFC-12 has already stimulated
the development of conservation measures. Since this liquid fast
freezing technology is fairly new, it is possible that further
technological developments such as improved condensers can
maintain emissions at a constant level of about 6.5 million
pounds while the frozen food output expands. There are close,
although less desirable, substitute processes for LFF.

5. Diluent Gas In Gas Sterilizing Applications

CFC-12 is mixed with ethylene oxide (E0) to form sterilizing
gas used in hospital and industrial gas sterilizing
applications. Pure EO can be used as sterilizing gas, but it is
highly toxic, flammable, and explosive. 32 In 1976 between 11 and
14 million pounds of CFC-12 were used to dilute E0 to a mixture
known as 88/12, consisting of 88 percent CFC-12 and 12 percent
EQ. These CFCs are generally emitted directly to the atmosphere
from the sterilizing units following use. Approximately 200
large industrial sterilization units account for 75 to 80 percent
of the CFC used as diluent gas. The remainder is used in smaller
hospital units. Both the large and small units supply hospitals
with sterilized equipment.

Rand predicts growth in the use of CFC-12 for this
purpose. Carbon dioxide (CO2) may be substituted for CFC-12, but
switchover costs would be very high because equipment designed
for the CFC/EO mixture cannot handle a C05/E0 mixture. Because
of increased CFC costs, manufacturers of industrial sterilizers
have shown considerable interest in recycling used 88/12.
Further investigation is required to determine the level of
emissions reduction attainable through recovery and recycle.

~28-


Rand has identified three major emission reduction
strategies. First, redesigning mobile air conditioners to
eliminate leaking would reduce emissions by at least 25
percent. 2° Second, a change in servicing and recharging
procedures could result in emission reductions of over 25
percent. Currently CFCs are released into the atmosphere during

servicing. However, techniques to recover and recycle used CFCs
during servicing are being developed. 2?

The third strategy is to recover used CFCs at time of
disposal. This recovery could yield a significant reduction in
lifecycle emissions. By 1990, disposal emissions may be a
significant part of total mobile air conditioner CFC emissions.
However, it is uncertain how much of the CFC charge remains in
the air conditioner at the time of disposal. Technology must be
developed to economically recover, refine, and recycle the used
CFCs. A system of incentives such as rebates, deposits, or
bounties may be needed to make CFC recovery from automobiles
attractive.

EPA is currently investigating a mobile air conditioner that
uses air as its primary refrigerant and may use a non-
chlorofluorocarbon as its secondary refrigerant. If this system
is found to be technically feasible and economically competitive,
it would substantially reduce future annual CFC emissions.

b) Refrigerators and Freezers
1. Retail Food Store Refrigeration Systems

Currently, some 183,000 retail food stores have food
refrigeration systems. CFC emissions from these systems were
about 13 million pounds of CFC-12 in 1976, and are anticipated to
grow to 15 million pounds by 1990. Annual emissions are expected
to increase only slightly, since manufacturers are switching to

-25-


EPA is awaiting the release of several key reports: the
National Academy of Sciences' updated report on the chemistry and
physics relating to stratospheric ozone depletion by CFCs,
resulting effects to life on earth of decreased stratospheric
ozone, and alternative control technology; the Rand Corporation's
final report on the economic feasibility of controlling
nonaerosol uses; SRI International's risk/benefit analysis; the
University of Maryland's cost/benefit analysis; and our own
assessment of the risk to health and the environment from
continued use of CFCs. These reports will be used by EPA to
support its decision of whether or not to regulate. In the
meantime, EPA is investigating several regulatory strategies to
reduce CFC emissions. Currently under consideration are 1)
direct regulation; 2) economic incentive approaches to pollution
abatement; and 3) a conservation program relying on industry
cooperation. These three options are not mutually exclusive and
could be used in combination to maximize net social benefit.

In addition to the Phase II investigation, the Office of Air
Quality Planning and Standards is currently developing
regulations which will lead to a reduction in the emissions of
volatile organic compounds, including CFC-113, from organic
solvent cleaning operations which include vapor phase degreasing
and cold cleaning. The potential for depletion of stratospheric
ozone is the basis for designating CFC-113 as one of the solvents
covered by this rulemaking.

Because CFC emissions in any country are distributed
globally throughout the atmosphere, the regulation of CFCs is an
international problem. Representatives from the United States,
13 foreign countries, and three international organizations met
in Munich in December 1978 to discuss the latest scientific and
regulatory approaches to protect the ozone layer. Following the
U.S. lead, a few nations indicated that they are issuing rules to
prohibit nonessential uses of CFCs as aerosol propellants.
However, there were many more nations who questioned scientific
predictions of ozone depletion and the need for restrictive

-3-


The EPA rule (referred to as Phase I) covers all aerosol
propellant uses except uses in food, drugs, medical devices, and
cosmetics which are covered under the FDA regulation. The Con-
sumer Product Safety Commission (CPSC) played a major role in
supporting the EPA and FDA regulations. However, CPSC chose not
to issue a separate regulation, since most uses under its
jurisdiction were covered under the EPA and/or FDA regulations.

The Phase II investigation of nonaerosol and miscellaneous
uses is currently underway. This is primarily directed toward
nonaerosol categories of CFCs, including refrigerants for
refrigeration and air conditioning units, foam blowing agents in
the manufacture of foams, cleaning agents in the electronic and
metal industries, freezing agents for foods, and solvents.
Annual emissions from the manufacture and use of U.S. nonaerosol
products containing CFCs are estimated to be about 300 million
pounds for 1976/77, and the total is expected to about double by
1990, although the rate of increase may vary for different
categories of use.

A phenomenon called "banking", connected with certain
products using CFCs appears to be growing. The CFC bank
represents CFCs that remain or are stored in products such as
insulating foams and air conditioners and will be released slowly
to the atmosphere during normal use or disposal of the product.
Emissions from banked products can vary widely depending upon the
product. Preliminary estimates indicate that the quantity of
banked CFCs, about 675 million pounds in 1976/77, is expected to
increase annually at a rate of about 160 million pounds per year,
to over 2 billion pounds by 1990.

Phase II studies also include evaluation of a host of
miscellaneous aerosol products which use CFCs as active
ingredients instead of as propelling agents. These products,
excluded from the aerosol ban regulation by definition, emit

small quantities of CFCs ranging from several thousand to over a
million pounds per year.


The pesticide essential use exemption was modified to permit
application by metered value and total release devices. 20
Special exemptions are proposed for manufacturers of pyrethrin
pesticide formulations! and inkless fingerprinting systems.
Another exemption proposes to exclude spinnerette release agents
from inclusion in the original mold release agent category.23

Other requests are under review.

-15-


I CHLOROFLUOROCARBON AEROSOL BAN REGULATION
A. The Problem

Chlorofluorocarbon molecules consist of one or more carbon
atoms with chlorine and fluorine atoms attached. When released
through normal use they remain stable in the troposphere and over
many decades slowly rise from the troposphere into the
stratosphere. Here CFCs photochemically decompose, liberating
chlorine atoms. Ozone molecules react with the chlorine and are
reduced to molecular oxygen. The decreased ozone concentration
permits more ultraviolet radiation with wavelengths between 290
and 320 nanometers (UV-B) to penetrate to the earth, resulting in
adverse health and environmental consequences.

In September 1976 the National Academy of Sciences (NAS)
estimated a 7 percent (with a possible range from 2 to 20
percent) reduction in stratospheric ozone, at equilibrium, due to
crcs.! Ina September 1977 report of a workshop sponsored by the
National Aeronautics and Space Administration (NASA), expert
scientists predicted a 10 to 16 percent reduction as the most
probable value.* A later NAS report, prepared in response to
Section 153(d) of the CAA, supported the NASA finding that the
expected ozone reduction at equilibrium by CFC emissions is
roughly double that predicted in September 1976.3

The latest, and to date the largest, estimated stratospheric
ozone depletion due to CFCs, predicted by the Model Predictions
Group at a recent NASA workshop, is about 18 percent (with a
possible range between 5 percent and 30 percent).4 This
equilibrium depletion would be achieved by about the year 2050.
All of these ozone depletion values are based on the assumption
that CFC emissions remain constant at 1975 worldwide release
rates of 750 metric tons per year.

Most scientists agree that there is a correlation between
shin cancer incidence and UV-L exposure. Both the fatal but rare
malignant melanoma and the more frequent but usually non-lethal

-5-


In the area of vapor phase degreasing and cold cleaning,
regulatory efforts are currently underway by the Office of Air
Quality Planning and Standards which will result in a reduction
of approximately 64% in the emissions of solvents used in these
applications. The emission standards, developed under Section
111 of the CAA, will apply equipment, design, work practice, and
operational standards to limit emissions of volatile organic
chemicals (VOC) including CFC-113 and other non-CFC solvents from
cleaning operations which use cold cleaners, open top vapor
degreasers, and conveyorized degreasers.

2. Blowing Agents

CFCs are used as blowing agents in three types of foam
products: urethane flexible foams, nonurethane (packaging) foams,
and urethane rigid (insulating) foams. Blowing agents give the
foams certain performance characteristics. The flexible urethane
foams and nonurethane packaging foams require CFCs for soft
resiliency. The rigid urethane insulating foams contain CFCs as
the insulating medium.

CFCs are released at different stages in the manufacture and
use of each of the three types of foam. During the manufacture
of flexible, open-cell urethane foam, CFCs are released into the
atmosphere almost immediately. The CFCs pass through the product
because the cells are open. On the other hand, CFCs slowly
diffuse out of rigid insulating foams during their normal use,
and must be considered as part of the CFC bank. Approximately 40
percent of the CFCs used in manufacturing nonurethane packaging
foams are retained in the foams but are generally released within
a year upon disposal of the product. For the purpose of
estimating total emissions, packaging foams will be considered
prompt emitters.

a) Flexible Foams

Flexible urethane foam is used in furniture, automobiles,

-20-


SEPA Report on the Progress of
Regulations to Protect
Stratospheric Ozone

Report to Congress
August 1979



Based on global research and monitoring, the WMO noted that
there is evidence to support the theory that continued CFC
release into the atmosphere would cause ozone depletion. 38
Continued CFC releases at 1975 levels (750 metric tons) would
eventually lead to an estimated steady state ozone reduction of
15 percent and about a 30 percent increase in ultraviolet
radiation in the 280-320 nanometers wavelength range.

CCOL concluded that it was possible to correlate latitude to
skin cancer incidence, even though correlation of the incidence
of skin cancer malignancy with solar UV levels had not yet been
made with great accuracy .® White-skinned populations are
susceptible to skin cancers believed to be caused by solar UV-B
6 in addition, UV-B radiation is potentially
detrimental to certain plant species. Aquatic species living
near the surface waters are also very suspectible to uv-B.© Even
though impacts on changes in climate in the ozone layer are
considered to be small, stratospheric temperature changes may
eventually be as large as 5 to 10 degrees centigrade. ® Such

radiation.

changes could lead to structural modification in the atmospheric
planetary-scale waves, with consequent effects on storm tracks
and regional climates .°®

EPA headed the United States delegation to the international
regulatory meeting in Munich which included representatives from
FDA, CPSC, and the State Department. With the background of U.S.
research data, UNEP and WMO statements, and other information,
the U.S. delegation attempted to convince the representatives of
the CFC producing and consuming countries that a substantial
reduction of CFCs in aerosol products is low cost insurance
against the risk of stratospheric ozone depletion. The Deputy
Administrator of EPA in her speech to the conference pointed out
that if there are no additional restrictions on global releases
of CFCs, worldwide emissions could reach 1975 levels within 10
years, thereby offsetting U.S. action regulating CFCs as aerosol
propellants. The Deputy Administrator believed that, "there was
only one course of action open: a unified global approach to

-43-


that release of CFCs presented an unreasonable risk or that there
was time to delay the proposed rule. Specifically, the public
argued that

1. because of a voluntary reduction of CFCs in aerosol
propellants, there no longer was a need to regulate,

2. uncertainties about the ozone depletion estimates

were unresolved,

3. more time was needed for research on alternative
propellants,

4. modeling studies to determine if ozone depletion has
occurred had not been validated,

5. a delay in regulating would not result in adverse
health and environmental consequences from continued
use of CFCs as propellants, and

6. only after scientists address the inadequacies of
present theories (NAS predicted two years would be
adequate time) should selective regulation proceed.

After evaluating these and other comments, including
scientific and economic reports, EPA and FDA concluded that
despite the uncertainties in the magnitude of ozone depletion,
there existed an unreasonable risk to health and the environment,
if emissions from the use of aerosol products containing CFCs as
aerosol propellants were allowed to continue. Data from the
scientific community indicated that a decrease in the ozone
concentration in the stratosphere and a resultant increase in
ultraviolet radiation at the earth's surface could 1) increase
the incidence of melanoma and nonmelanoma skin cancer, 2) damage
ecological systems, and 3) produce climatic perturbations.


As with skin cancers, research on UV-B effects on biological
and climatic systems is currently being conducted to
quantitatively assess adverse impacts and to reduce remaining
uncertainties. Although aware of the quantitative uncertainties
in these various findings, EPA and other Federal agencies have
initiated regulatory action to protect the ozone layer from
adverse substances, especially nonessential uses of CFCs.

B. The Regulation

The first report to Congress dated, March 14, 1978 and
required under Section 155 of the CAA, described actions taken by
EPA and other Federal agencies to regulate sources of halocarbons
or more specifically, chlorofluoroalkanes (CFCs).7 The 1978
report discussed key research documents that supported the
proposed rule published in May 1977. This chapter will report on
the final rule published in 1978.

During the initial stages of regulatory development, EPA
with assistance from other key Federal agencies, formed an
interagency work group.* An EPA-approved development plan
outlined the ground rules for the work group, and among other
things, provided for regulating CFCs in a two-phased effort .8
Phase I concentrated on the regulation of aerosol products using
CFCs as an aerosol propellant and the promulgation of the current

aerosol ban regulation.

Most of the comments received by EPA on the proposed aerosol
ban rule indicated that either there was no basis to determine

*The interagency work group was formed during the Fall of 1976
when it became clear that EPA, FDA, and CPSC had begun regulatory
activities on regulating CFCs. Along with members from the three
agencies, representatives from the National Aeronautics and Space
Administration (NASA), Department of Transportation (DOT),
Department of Commerce (DOC), National Science Foundation (NSF),
and the Council on Environmental Quality (CEQ) were invited to
participate. Because of the recent passage of the TSCA with its
broad authority, EPA was chosen as the lead agency. This work
group had primary responsibility for developing the regulation.


emissions from the CFC bank. For example, if the maximum
acceptable annual emissions were 100 pounds, and previous use
information indicated that CFC inventory emissions would be 20
pounds, then the emissions quota for that year would have to be

at most 80 pounds. How best to address these and other issues is
currently under investigation.

3. Conservation Program

Depending upon its assessment of all the pertinent
scientific, economic, and technological factors from all sources,
including the industry, EPA could decide to defer further
regulation until additional research and other studies were
completed. In that case, EPA most likely would adopt a con-
servation program for reducing CFC emissions and promoting
research in the area of ozone depletion. Relying on voluntary
cooperation and compliance from industry, this program would
concentrate on limiting the market growth of new applications of
CFC uses, particularly where new uses may not be essential.

It has been noted that both the academic community and
industry are devoting considerable resources to research the uses
and environmental impacts of CFCs. EPA could serve as a
clearinghouse to collect and disseminate the information on
methods for reducing CFC emissions from various uses. EPA could
participate with industry and academia in defining research needs
and funding essential projects. EPA could negotiate voluntary
emission reduction goals (e.g., 20 percent by 1985) and monitor
uses, emissions, and the development of emission control
technologies to help meet the emission reduction goals. By
instituting a conservation program along the lines described, EPA
would

1. advance its knowledge of uses and emissions of CFCs,

2. begin to reduce CFC emissions by promoting new
emission reduction technologies, and

-39-


c) Centrifugal and Reciprocating Chillers (air conditioners)

In 1976 an estimated 43,000 large centrifugal chillers, air
conditioners which are used primarily in large buildings, emitted
a total of 12.2 million pounds of CFCs. In the same year
approximately 125,000 smaller reciprocating chillers, air
conditioners which are used primarily in homes, emitted only 2.4
million pounds of CFCs.

An estimated 90 percent of newly installed reciprocating
chillers use CFC-22. Thus, CFC emissions from reciprocating
chillers should be negligible by 1990. However, CFC emissions
from centrifugal chillers are expected to increase to 20 million
pounds annually by 1990.31 the amount of CFCs banked in
centrifugal and reciprocating chillers is expected to grow from
60 million pounds in 1976 to 90 million pounds by 1990.

In 1976, 80 percent of chiller emissions were caused by
leaking and servicing; this is expected to fall to 68 percent by
1990. Because of the rising cost of refrigerant, the centrifugal
‘chiller manufacturers are trying to reduce emissions caused by
leaking. The red dye leak identifier mentioned above may be used
in future systems to pinpoint leaks that currently go undetected.

Recovery and recycle of CFCs at product disposal is not
economical for chillers alone. However, Rand suggests that
recovery in conjunction with mobile air conditioners may be
possible.25

4. Direct Contact Freezing Agent

CFC-12 is used as a freezing agent in approximately 30
liquid fast freezing (LFF) systems. Products such as fruits,
vegetables, seafood, and meats come in direct contact with CFCs
in the LFF process. In 1977, 6.5 million pounds of CFC-12 were

-27-


dealing with the health and environmental risks associated with
CFC production and use. Multilateral and unilateral support for
worldwide reduction of aerosol emissions must come from the
European communities and international organizations, as well as
from those of us who have already taken some form of action on
this problem."39 Other U.S. speakers pointed out that
investigations into the nonaerosol uses of chlorofluorocarbons
have shown that it will probably cost the American economy more
to take action against the U.S. nonaerosol products than it will
cost the economies of other nations to take action against
worldwide nonessential aerosol products.

Although quantitative commitments were not agreed upon, all
countries did agree to make significant reductions in aerosol use
from 1975 levels. The participants agreed further that if new
evidence to substantiate the ozone depletion theory were
forthcoming, they would undertake further reductions. In
addition, the conference members acknowledged the need to
continue research in atmospheric chemistry and physics and
related scientific areas, in order to broaden the scientific
knowledge of the hazards to the ozone layer by continued use of
CFCs. They noted that additional study is also required to
better estimate the effects of increased ultraviolet radiation on
world population, vegetation, and ecosystems. The members also
recommended continued research on potential substitutes for CFCs,
on control techniques to reduce CFC emissions, and on the
economics of regulatory and non-regulatory actions.

The discussions that occurred during this two-day conference
produced two bodies of opinion on the preferred way to achieve
CFC reduction. Some countries favored voluntary agreements with
industry, as opposed to the usual regulatory approach. Some
countries reported taking action; others reported no action, with
a few unsure about what to do, if anything.

The United States, United Kingdom, France, Germany, Italy
and Japan account for more than 90 percent of the world

-44-


CFC-502 which is 48.8 percent CFC-22 * and 51.2 percent CFC-
115. By 1990, at the current rate of conversion, CFC-502 will
grow from 33 to 67 percent of the total refrigerant stock in
retail food store refrigeration systems. However, even assuming
this rate of conversion, the amount of CFCs banked in these
products is expected to grow from 55.5 million pounds in 1976 to
approximately 81 million pounds in 1990.

Approximately 70 percent of retail food store refrigeration
and freezer emissions result from maintenance and leakage. Since
CFC-502 costs nearly three times as much as CFC-12, there is a
strong economic incentive to reduce these refrigerant losses.
Investigation along these lines is only now beginning. One
promising method of leak detection involves the use of a red
dye. This dye, when mixed with the refrigerant, will make
currently undetectable leaks easily identifiable.

2. Home Freezers and Refrigerators

Home freezers and refrigerators accounted for a small
fraction of the annual CFC refrigerant emissions. Estimated
annual CFC-12 emissions are 4.9 million pounds in 1976 and 7.3
million pounds in 1990. The amount of CFCs remaining in these
products, however, is expected to grow from 96 million pounds in
1976 to 117 million pounds in 1990 as the number of home freezers
and refrigerators increases.

The major source of emissions from home units is equipment
disposal. Rand reports that control of emissions at disposal
would require that small quantities of refrigerant be collected
at several million separate locations. The cost of collection,
reprocessing, and redistribution would greatly exceed the value
of the recovered crc.3° The only other emission reduction option
currently under consideration is a switch to CFC-22 which is
currently used in window air conditioning units.

* CFC-22 is not fully halogenated chlorofluoroalkane and there-
fore is not subject to either Phase I or Phase II regulation.

The potential of CFC-22 as an ozone depleter is now being
investigated.

-26-


action. Although they made no quantitative commitments to reduce
CFC use or emissions, the participants did agree to make
significant reductions in aerosol use from 1975 base levels.
Further reductions will be made if supported by new evidence.

EPA will continue to encourage other nations to reduce, and
eventually eliminate, CFC emissions from nonessential aerosol
uses.

Investigations into other substances or chemicals that may
deplete the ozone are moving ahead. The Office of Toxic
Substances (OTS) has developed preliminary plans to screen
chemicals for their ozone depleting potential, as part of the
ongoing risk assessment of toxic chemicals. Screening criteria
will also be applied to new chemicals reported under Section 5 of
TSCA, and to existing chemicals recommended for EPA review
through established channels (e.g., the Interagency Testing
Committee) to identify those substances which may affect the
chemical and radiative balance in the stratosphere. Moreover,
plans for monitoring activities are underway in OTS to
systematically collect global data and prepare materials balances
of chemicals suspected of depleting the ozone layer.

In implementing the CAA, and in deciding to what extent
further regulation is necessary, EPA is continuing its studies
and requests for studies by other Federal departments and
agencies of current developments in ozone processes, of adverse
health and environmental consequences of ozone depletion, of
technological capability to reduce emissions from major sources,
and of the costs of achieving control. A decision to propose
additional regulation would be based on an evaluation of all
these factors, as well as on the advantages and disadvantages of
controlling nonaerosol emissions in the United States in the
absence of meaningful actions to restrict either aerosol or
nonaerosol emissions in other countries. Based on the findings
of this investigation of nonaerosol uses of CFCs, EPA anticipates
deciding in early 1980 whether or not to proceed with initiation
of regulation.


end of its useful life, and is disposed of before emitting all of
its CFCs. All or part of the remaining CFCs may be emitted at
that time.

Emissions from the CFC bank play an important role in
estimates of future emissions. Rand estimates that without
controls the CFC bank will grow from approximately 670 million
pounds in 1976 to 2100 million pounds in 1990. Nonprompt
emitters contributing to the CFC bank include blowing agents for
rigid urethane insulating foams; refrigerants in mobile air
conditioners, refrigeraters, freezers, and chillers; and active
agents in fire extinguishing applications (bromofluorocarbons).

During the course of this investigation, EPA, CPSC, FDA and
the interagency work group have been collecting information on
current and predicted demand for CFCs, the amount of CFCs emitted
from each use, the value of each use, and the cost of reducing
emissions from each use. (See Table 1 for a summary of CFC
emission estimates.) This information will be analyzed in
conjunction with a theoretical damage function based on predicted
levels of ozone depletion caused by estimated levels of CFC
emissions. The cost of reducing emissions will be balanced
against the benefits of decreased damage.

Since virtually all CFCs used today are eventually emitted
to the atmosphere, EPA has been seeking ways that producers and
users of CFCs can reduce emissions. An overall reduction in
emissions through substitution or recovery and recycle will
reduce demand for CFCs. Reduced demand for CFCs may adversely
affect the markets for some related chemicals such as those used
in the production of CFCs or produced as by-products of the CFC
production process. 24 Any of these effects will be included in
the cost of regulation.


20 percent in a specified amount of time, they would have the
freedom to use what they considered to be the best control
technologies. Industry initiated control strategies may be
desirable when EPA has less information about control
technologies than does industry. However, emission standards
could be more difficult to enforce than technology requirements,
because surveillance of emissions is often more complicated than
surveillance of technologies or equipment.

The final form of direct regulation is product limitation,
use restrictions, or ban. As noted in the previous chapter, the
ban approach was used to limit aerosol uses of CFCs. Aerosol
uses of CFCs were banned because the hazards posed by continued
use greatly outweighed the costs of eliminating the emissions.
Substitutes were available that did not pose risks to human
health or the environment, and the costs were minor. This is a
good example of direct regulation being applied to only a portion
of the uses of a particular substance.

Unlike most stationary source pollution problems, the
Majority of CFC emissions occur during the normal use and
disposal stages of a product's life rather than during its more
centralized production stage. For example, CFC emissions from
rigid insulating foams in buildings are so small and occur
incrementally over long periods of time that it would be very
difficult to regulate the hundreds of thousands of buildings that
contain such insulation. Similarly, CFC emissions from mobile
air conditioners could be reduced by as much as 23 million pounds
in 1990 if improved servicing procedures were used. However,
mobile air conditioners are serviced at approximately 140,000
locations nationwide, thus making specific service and
maintenance standards virtually impossible to enforce. Although
other options are being investigated, EPA will continue to study
combinations of the various types of direct regulation if CFC
emissions must be reduced.

-34-


2.

Economic Incentive Approaches

An alternative to direct regulation is an economic incentive

approach to pollution control.

Economic theory defines a

pollution problem as existing when the cost of producing a good

does not include the social cost
by its production. For example,
produce one unit of a good. The
production may cause $4 worth of

Without controls, the total cost

of environmental damage caused
it may require $10 of inputs to
pollution emitted during

damage to the environment.

of producing the good would be

perceived by the firm as being $10 instead of the actual $10 +
$4= $14. The extra $4 of environmental costs, referred to as
"externalities", would be borne by the general public in terms of
reduced environmental quality or increased health hazard.

If these environmental costs, or externalities, could be
internalized into the firm's production costs, then the firm
would seek to reduce emissions as part of its overall goal of
cost minimization. The cost of the remaining environmental
damage would then be borne by those who enjoy the benefits of the
good through a higher product price. In addition, this economic
approach could reduce EPA's cost of administration and
enforcement. Once environmental damage costs are internalized
into production costs, individual profit maximizing firms will
reduce emissions as long as marginal emission reduction costs are
less than marginal environmental damage costs. Therefore, this
economic incentive of internalized environmental costs would

necessarily lead to emission reduction.

EPA is currently investigating two economic approaches, use
fees and marketable permits. Each is discussed in more detail
below.

a) Use Fees

Use fee systems have been discussed extensively in the

economics literature. EPA could incorporate the cost of

-35-


21.

22.

23.

24.

25.

26.

27.

28.

29.

30.

Federal Register Notice; 43 F.R. 27702; May 11, 1979; "Fully
Halogenated Chlorofluoroalkanes Toxic Substances Control
Act".

Federal Register Notice; 44 F.R. 31238; May 31, 1979; “Fully
Halogenated Chlorofluoroalkanes: Toxic Substances Control
Act".

Federal Register Notice; 44 F.R. 34167; June 14, 1979;
"Toxic Substances Control Act; Fully Halogenated
Chlorofluorocarbons".

The Rand Corporation; "The Chlorofluorocarbon and Precursor
Chemical Industry"; Preliminary Draft, RAND/WN-10278-EPA;
Nov. 1978.

The Rand Corporation; "Identification of Regulatory Options
for Detailed Analysis"; Preliminary Draft, RAND/WN-10371-
EPA; Dec. 1978.

The Rand Corporation; "Emissions Projections for Flexible
Foams"; Preliminary Draft, RAND/WN-10274-EPA; Sept. 1978.

The Rand Corporation; "The Use and Emissions of
Chlorofluorocarbons in Nonurethane Closed-Cell Foams",
prepared by The RAND Corporation; Preliminary Draft,
RAND/WN-10401-EPA; Dec. 1978.

The Rand Corporation; "Domestic Use and Emissions of
Chlorofluorocarbons in Mobile Air-Conditioners", prepared
for The RAND Corporation by The International Research and
Technology Corporation; Preliminary Draft; April 1, 1979.

E.I. DuPont de Nemours & Co., Freon Products Division,
Petrochemicals Department; "Nonaerosol Propellant Uses of
Fully Halogenated Halocarbons"; Submission No. 2 to The
Environmental Protection Agency; June 7, 1979.

The Rand Corporation; "Domestic Use and Emissions of
Chlorofluorocarbons in Home Appliances"; prepared for The
RAND Corporation by The International Research and
Technology Corporation; Preliminary Draft; Feb. 1979.

-50-


All the CFCs that have been used in the production of
insulating foam, but have not been emitted, are part of the CFC
bank. The amount of banked CFCs from insulating foams alone is
expected to grow to approximately 1.4 billion pounds by 1990.25
With this amount of CFCs stored away in the insulation of
buildings, refrigerators, and freezers, annual emissions would

eventually double even if insulation production ceased to expand
in 1990.25

We have not yet identified an emissions control strategy for
insulating foams. Little is known about the rate of CFC
emissions and the amount of CFCs remaining in the foam at the
time of disposal. Therefore, it is difficult to estimate the
amount of CFCs recoverable at the time of product disposal.

3. Heat Transfer Medium (Refrigerants)

CFCs are used extensively as refrigerants in mobile or
automobile air conditioners, refrigerators, freezers, and
chillers (stationary air conditioners). It is estimated that
approximately 115 million pounds of chlorofluorocarbon
refrigerants were emitted in 1976. Over 80 percent of these
emissions were from mobile air conditioners. Rand predicts CFC
refrigerant emissions to increase to over 170 million pounds
annually by 1990.

All the refrigerant uses are similar in that a significant
portion of refrigerant inside each unit is held within the
product for many years and becomes part of the CFC bank. Air
conditioners, refrigerators, and freezers are estimated to have
accounted for 430 million pounds of the CFC bank in 1976 and may
account for as much as 670 million pounds by 1990. Mobile air
conditioners account for over 50 percent of these banked CFCs.

a) Mobile Air Conditioners

Mobile air conditioners emitted an estimated 83 million
pounds of CFC-12 in 1976. Seventy-four percent of all

-23-


TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)

1, REPORT NO. 2. |3- RECIPIENT’S ACCESSION NO,
EPA-560/12-79-003
4. TITLE AND SUBTITLE 5. REPORT DATE

Report on the Progress of Regulations to |_ August 1979

Protect Stratospheric Ozone 6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S) . PERFORMING ORGANIZATION REPORT NO.

Ferial S. Bishop

9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.

Office of Toxic Substances 02LS811

U.S. Environmental Protection Agency 11. CONTRACT/GRANT NO.

401 M St., S.W.

Washington, D.C. 20460 N/A

12. SPONSORING AGENCY NAME AND ADDRESS 13, TYPE OF REPORT AND PERIOD COVERED
Office of Toxic Substances Annual _ 1978-79

U.S. Environmental Protection Agency 14. SPONSORING AGENCY CODE

401 M St., S.W.
Washington, D.C. 20460

15, SUPPLEMENTARY NOTES

This Report to Congress is required annually by the Ozone Protection
Sections of the Clean Air Act Amendments of 1977.

16. ABSTRACT
This report reviews the progress made by EPA from March 1978 to August
1979 in regulating ozone depleting substances. In March 1978 EPA along
with Food and Drug Administration (FDA) issued final rules prohibiting
the manufacturing and processing of chlorofluorocarbons (CFCs) for non-
essential aerosol propellant uses. EPA continues its investigation of
nonaerosol and miscellaneous CFC uses, including use as refrigerants,
foam blowing agents, cleaning agents in the electronic and metal
industries and as solvents. The EPA study includes several regulatory
strategies to reduce CFC emissions, namely, 1) direct regulation,

2) economic incentives and 3) a conservation program. Because CFC
emissions in any country may have adverse effects globally, the reduc-
tion of CFC emissions is an international concern. EPA is developing
programs to investigate other substances or chemicals that may deplete
the stratospheric ozone. In implementing the Clean Air Act and decidin
whether and to what extent further regulation is necessary, EPA is con-
tinuing its studies of current developments in ozone processes, of
adverse health and environmental consequences of ozone depletion, of
technological capability to reduce emissions from major sources, and of
the cost of achieving control.

7. KEY WORDS AND DOCUMENT ANALYSIS

js DESCRIPTORS Ib. IDENTIFIERS/OPEN ENDED TERMS |c. COSATI Ficld/Group
Stratospheric Ozone Regulatory Options 04a
Chlorofluorocarbons (CFCs) Emission Rates 11G
Ozone Depletion Risk 11K
Aerosol Propellants O6F

Nonaerosol Use of CFCs
Marketable Permits

NS. DISTRIBUTION STATEMENT 19. SECURITY CLASS (This Report} 21. NO. OF PAGES:

ss ified
Release Unlimited 20. SECURITY CLASS (This page) 22. PRICE

Unclassified

EPA Form 2220-1 (9-73)


TABLE OF CONTENTS

SUMMARY... . cece cece eee cece cc cecceceeee L
I. CHLOROFLUOROCARBON AEROSOL BAN REGULATION
A. THE PROBLEM. ....--eeeeeeeeeeeeee 5
B. THE REGULATION......-.e.eeeeeeee 7
C. EXPORT NOTIFICATION............. 14
D. AMENDMENTS TO THE RULE.......... 14

II. INVESTIGATION OF NONAEROSOL USE OF
CHLOROFLUOROCARBONS

A. INDUSTRIAL USE PROFILES......... 16
B. REGULATORY OPTIONS.............. 32
C. RISK ASSESSMENT............22-++- 40
III. INTERNATIONAL COOPERATION.........2.22-+. 42

Iv. INVESTIGATION OF OTHER STRATOSPHERIC
OZONE DEPLETING SUBSTANCES............ 46

REFERENCES... 2c ccc ee eee e ccc c cece ccecccee 48


III INTERNATIONAL COOPERATION

The first international regulatory meeting on
chlorofluoromethanes or CFCs, held from April 26-28, 1977, in
Washington, DC, sponsored by the Department of State, EPA, FDA,
and CPSC was discussed in the first report to Congress. A second
meeting was held on December 6-8, 1978 in Munich, Germany. This
international conference on CFCs was attended by representatives
from Australia, Belgium, Canada, Denmark, France, Federal
Republic of Germany, Italy, Netherlands, Norway, Sweden,
Switzerland, United Kingdom, United States, Yugoslavia, the
European Community Commission (ECC), the OECD Environment
Committee, and the United Nations Environment Program (UNEP). As
before, these countries met to share information on the state of
knowledge about CFCs and their effect on health and the
environment. One of the major conference objectives was to
determine what future actions could be taken by these countries
to mitigate harmful effects.

UNEP's Coordinating Committee on the Ozone Layer (CCOL) met
in Bonn, Germany from November 28-30, 1978 to assess
stratospheric ozone depletion and its resulting effects on life
on earth, and to provide a scientific basis for the international
regulatory meeting in Munich. Experts from Australia, Canada,
France, Federal Republic of Germany, Netherlands, Norway, United
Kingdom, United States, UNEP, World Health Organization (WHO),
World Meteorological Organization (WMO), International Council of
Scientific Unions, Chemical Manufacturers Association, and the
European Economic Community (EEC) attended the meeting.

The CCOL reviewed the latest reports on stratospheric ozone
depletion, including the October 1978 World Meteorological
Organization (WMO) statement on the modification of the ozone
layer caused by human activity. CCOL essentially agreed with WMO
and noted that while there are still large uncertainties in both
the predicted ozone depletion and the consequences of ozone
depletion a relatively consistent picture of the effects of human
activity on stratospheric ozone is emerging.

~-42-


3. promote state-of-the-art advances in analyzing the
effect of CFC emissions on the ozone layer.

To date some segments of industry have been very receptive to
these types of initiatives. Continued industrial cooperation
plus detailed planning would be needed before this program could
be implemented effectively.

C. Risk Assessment

One of the key evaluations necessary in the regulatory
decision making process is an assessment of the environmental and
health risks associated with continued use of CFCs. This risk
assessment must take into account the potential magnitude of CFC
release, the effects on stratospheric ozone, and the resulting
effects on health and the environment.

Based on historical emission rates as well as projections
through 1990,2> EPA has developed emission rate profiles through
1990 for each CFC in commercial use, and for the various
regulatory options under consideration. These options include
unrestrained growth, a conservation program, technological
controls and a total ban on CFCs. Emission rate profiles are
vital input into model predictions of ozone depletion.

Once ozone depletion rates are developed, estimates of
increases in biologically harmful ultraviolet radiation reaching
the earth's surface can be made. The results of laboratory and
epidemiological studies should provide a reasonable basis to
conclude that exposure to this radiation increases the risk of
skin cancer in humans. EPA will also qualitatively assess the
potential effects of alterations in the levels of ozone on
climate and biota.

-40-


nonconsumer articles used as cleaner solvents,
lubricants, or coatings for electrical or electronic
equipment,

articles necessary for safe maintenance and
operation of aircraft, and

uses essential to the military preparedness of the

United States as determined by the Administrator of

EPA and the Secretary of Defense.?

The FDA regulation exempted

1.

metered-dose steroid human drugs for nasal
inhalation,

metered-dose steroid human drugs for oral
inhalation,

metered-dose adrenergic bronchodilator human drugs
for oral inhalation,

contraceptive vaginal foams for human use, and

metered-dose ergotamine tartrate drug products

administered by oral inhalation for use in humans.11

In 1975, U.S. aerosols (511 million pounds) accounted for about
one half of U.S. production (1060 million pounds) and less than
one quarter of total world production (about 2300 million pounds)
of crcs.13 the u.S. used (and presumably emitted) slightly less
CFCs both for aerosols and nonaerosols than the rest of the
world.
to eliminate more than one-half of total U.S. emissions and a
little more than one-quarter of world emissions (very roughly
1700 million pounds, about equally divided between the U.S. and

The U.S. regulation of aerosols was therefore estimated

-ll-


41.

42.

43.

44,

45.

Brydon, Dr. J.E.; Environment Canada, Ottawa, Canada; "News
Release: Len Marchand Calls for Ban on Chlorofluorocarbons
in Spray Cans to Protect the Ozone Layer"; March 29, 1979.

Department of State Incoming Telegram from the American
Embassy, The Hague, Netherlands; "Dutch Labeling Requirement
for Aerosols"; July 1978.

Olson, Edward, U.S. State Department; Personal Communication
concerning International Conference on Chlorofluoromethanes;
December 1978.

Commission of European Communities; "Proposal for a Council
Decision Concerning Chlorofluorocarbons in the Environment";
COM(79)242; May 14, 1979.

The Environmental Protection Agency, Office of Toxic
Substances; "A Preliminary Analysis of Nitrous Oxide (N20)
Including A Materials Balance"; January 1979.

~52-


could handle the conversion to alternative products without any
costly effects. Conversion to mechanical delivery systems would
possibly benefit the small firms that produce these systems.

The adverse impact on small businesses using CFCs was
estimated to fall most heavily on the filler segment of the
industry. One-half of the total number of fillers in the United
States manufacture less than 10 million units a year, and in
aggregate account for 6 percent of total aerosol filling. These
fillers must convert production equipment in order to use
hydrocarbon propellants, the most likely replacement for CFCs.
This is largely because of the precautions necessary to handle
the more flammable hydrocarbons. Since small firms have limited
capital resources necessary for conversion and research and
development, the impact on small filler businesses was likely to
be more severe than on larger firms.

Because EPA was concerned about the impact of this rule on
small businesses, EPA chose an 18 month phase-out schedule
instead of an immediate ban, to minimize the economic impact on
all sectors of the industry .?/10 EPA noted that even before the
rule was published, many businesses had already switched to other
propellants or products. According to an industry source, by the
spring of 1978 over 80 percent of products previously using
chlorofluorocarbons as a propellant had switched to non-
fluorocarbon propellants or finger activated pumps.}5 Figures
from the Can Manufacturers Institute showed that although aerosol
can shipments were 7 percent behind 1977 during the first quarter
of 1978, by the end of September 1978 aerosol shipments were
running about 5 percent ahead of the 1977 figures.16 EPA
concludes that this continued demand for aerosol cans during the
third quarter of 1978 indicates that marketers had successfully
converted to substitute propellants.

-13-


pe

a
(sz) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
na WASHINGTON, D.C. 20460

THE ADMINISTRATOR

The Environmental Protection Agency transmits

its report on regulatory actions to protect the
stratospheric ozone in accordance with Section 155

of the Clean Air Act Amendments of 1977 (Public

|

Law 95-95).

Oo as M. Costle


regulatory options: 1) direct regulation; 2) economic incentive
approaches; and 3) a conservation program. These options are not
mutually exclusive and could be used in combination to maximize
net social benefit. The choice of a regulatory strategy will be
based on, but not limited to, the following criteria: the
certainty of achieving emission goals; the cost of control; the
ease of implementation; equity; the amount of information
required to promulgate and enforce the regulation; and
administrative costs. The following is a description of the
various strategies.

1. Direct Regulation

Until now, EPA has used three basic forms of direct
regulation: 1) technology requirements, where EPA requires the
use of specific equipment or processes; 2) emission standards,
where EPA limits the concentration or amount of certain
pollutants released into the environment; and 3) banning a
substance for a certain use.

As an example of a technology requirement, EPA must approve
the process used to incinerate polychlorinated biphenyls
(PCBs). One characteristic of technology requirements, and
direct regulation in general, is that different requirements can
be developed for different industries that use the same
substance. For example, industries with very low emission
control costs could be required to adopt a process or technology
that eliminates a large percentage of their emissions. At the
same time, industries with high emission control costs could be
required to reduce emissions only a small amount. Although this
strategy may reduce emissions to a specified level at minimum
control cost, it may not be perceived as equitable.

Emission standards are a less restrictive form of regulation
than technology requirements for industry production processes.
Emission standards allow firms to adopt their own least cost
methods of achieving the required level of emission reduction.
For exauple, if industries were required to reduce emissions by

-33-


and carpeting. CFC-11 is used as a blowing agent in
approximately one-third of all flexible foams, with the remaining
foam being blown with carbon dioxide, water, or methylene
chloride. In 1977 35 million pounds of CFC-11 were used for this
purpose, and Rand predicts that without controls use will grow to
between 59 and 98 million pounds annually by 1990.26 since
flexible foams are prompt emitters, the amount of CFC-11l

predicted to be used in a year is also predicted to be emitted in
that same year.

Two methods for reducing emissions are substitution, and
recovery and recycle. Less expensive methylene chloride can be
substituted for 75 percent of overall CFC-1l use. In the past
the use of methylene chloride as a blowing agent was limited
because it could cause the foam to collapse. 26 Recent
technological advancements are believed to alleviate this
problem. 26 If methylene chloride is found to be environmentally
acceptable, it could be used as a substitute for CFC-11 in most
flexible foams. However, methylene chloride is currently on
EPA's list of toxic pollutants under Section 307(a) of the Clean
Water Act of 1977, and is being investigated for toxicity,
degradability, persistence in water, and other criteria listed
under Section 307.

Recovery and recycle may be feasible for applications for
which methylene chloride cannot be used as a substitute. Carbon
adsorption beds may be used to recover the CFCs for future
recycling. However, this technology requires further study.

b) Nonurethane Packaging Foams

Approximately 24 million pounds of CFCs were used as a
blowing agent in the production of packaging foams in 1977.
These products, made of extruded polystyrene sheet, polyolefin,
expanded polystyrene, and polyurethane, include stock trays, egg
cartons and single service food containers for the fast food
industry. ‘The principal CFC blowing agent is CFC-12, although

-21-


REPORT ON THE PROGRESS
OF
REGULATIONS TO PROTECT

STRATOSPHERIC OZONE

REPORT TO CONGRESS

AUGUST 1979

U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF TOXIC SUBSTANCES
401 M Street, S.W.
Washington, D.C. 20460


production of CFCs. As of July 1979 the United States and Sweden
have taken regulatory action banning CFCs as aerosol

propellants. 9-10,40 Canada will follow suit in December

1979.41 The Netherlands has published a law requiring that all
aerosol products containing CFCs be so labelled.42 In addition,
the Netherlands has concluded that a banning regulation may be
necessary, but is waiting to see what action is taken by the
European Economic Community and other countries. Norway

anticipates that by 1981 regulations are likely to reduce
emissions by 50 percent.43

The nine members of the EEC are expected to act jointly in
accordance with the council decision proposed in May 1979 which
would require the member countries to

1. not increase CFC capacity,

2. reduce CFCs in aerosols by 30 percent by January
1982 based on 1976 levels,

3. report on the effectiveness of controls early in
1982, and

4. consider the Commission's proposals for further
measures later in 1982.44

Several countries have reported voluntary reduction
agreements with their industry. Under an agreement with the
aerosol industry associations in Germany and Switzerland, each
country will reduce CFC use in aerosols by 30 percent by 1979; in
Denmark CFC had already been reduced by 24 percent in 1978.43

There appear to be more countries who are undecided about
taking any action than countries who have taken some action.
Nevertheless, EPA and other regulatory agencies will continue to
work with the international community to stress that emissions of
substances harmful to the ozone layer is a global problem and
that a multilateral approach to protecting the stratosphere is
essential to our mutual wellbeing.

-45-


6. Active Agent In Fire Extinguishing Applications

FC-13B1 (Halon 1301), a bromine compound, is used in "total
flooding" fire extinguishing systems. Rand estimates that in
1977, 1.5 to 3.0 million pounds of Halon 1301 were used in fire
extinguishing applications with emissions occurring during
testing, servicing, and use. In 1977 Halon 1301 emissions are
estimated to have been under 1.0 million pounds. 33 By 1990
emissions are not likely to be greater than 2.0 million pounds
annually.33 Despite the small quantity of emissions, Halon 1301
may also contribute to the depletion of the ozone layer.33
Research is underway to evaluate the atmospheric chemistry of
bromine compounds and their potential effect on the ozone layer.

There are approximately 10,000 "total flooding" systems
today, with approximately 80 percent of those installed in spaces
containing electronic equipment such as computers and other
microcircuit equipment. It is difficult to estimate the amount
of Halon 1301 banked because little is known about the average
charge per system. Rand predicts that the amount of Halon 1301
banked in total flooding fire extinguishing systems will grow
from 6 million pounds in 1976 to approximately 30 million pounds
in 1990. DuPont states that Halon 1301 is the only compound
which can be used safely at the concentrations required to

extinguish a fire in a confined space.2?

Rand reports that because of the high cost of Halon 1301,
Manufacturers are attempting to limit emissions.2® Further
investigation is required to determine possible emission
reduction strategies that do not compromise adequate fire
protection.

7. Miscellaneous Uses

EPA is currently evaluating numerous miscellaneous products
that use small amounts of CFCs. The estimates for the total
annual use of CFCs in such products range from several thousand

to over a million pounds per year.

-29-


products, adopt substitutes for other products, and employ
emission controls and recovery measures where possible in order
to minimize use of CFCs. In the long run the permits will be
distributed among those firms that place highest value on their

use.

There are several basic questions which must be resolved
before a marketable permit strategy could be implemented. EPA
must decide how to allocate the permits. They could be
distributed either by direct sale to the highest bidder in a
central market or auction, or by allocation to current CFC users
as a function of past usage. The choice between these strategies
would not affect the ultimate equilibrium price of the permits.
The two initial distribution methods will, however, have
different effects on the redistribution of wealth that may result
from a marketable permit system. If the permits were auctioned
off, wealth would be transferred to the government from
industry. The large firms may be able to outbid the small firms,
thus preventing small businesses from using CFCs. If the permits
were allocated based on past use, wealth would be transferred
among firms as the permits were traded. One problem with
allocation based on past use is that it prevents new and
potentially highly valued uses of CFCs from being allocated
permits. New CFC users would have to buy permits from existing
users who receive them automatically. The two permit
distribution methods could also be used in combination. For
example, 80 percent of the permits could be sold at auction to
the highest bidders, while 20 percent of the permits could be
allocated or sold at a predetermined price to small businesses.

In addition to the question of initial permit allocation,
there is the problem of tracking "prompt" versus “nonprompt"
emissions. Since marketable permits apply to CFC use, and not
CFC emission, a method must be devised to keep track of how much
of a year's quota is placed in nonprompt emitting products (the
CFC bank). In order to keep future annual emissions under a
certain level, the estimate of total emissions must include

-38-


automobiles manufactured in the United States in 1976 came
equipped with air conditioners, up from 7 percent in 1960.29
Each air conditioned car is charged with between 2 and 5 pounds
of CFCs. Air conditioners installed as original equipment in
U.S. cars average approximately 3.8 pounds per unit. Rand
predicts continued growth in the mobile air conditioner market
and estimates 1990 emissions to be as high as 128 million pounds

of CFC refrigerant.

CFC emissions from mobile air conditioners are divided into
six separate categories: 1) manufacture; 2) leakage;
3) recharge; 4) service; 5) accidents; and 6) disposal. Leakage
and service (other than recharge) account for over 50 percent of
emissions. Disposal emissions are expected to increase from 10
percent in 1976 to 19 percent of total emissions by 1990.25 this
increase is due to the expected growth in disposal of cars
equipped with mobile air conditioners. Manufacturing emissions
are expected to decline because of improved work practices;
recharge emissions may grow slightly. Accident emissions will
probably remain a small category. Table 2 summarizes these
emission estimates.

Table 2

Estimate of Most Likely Emissions From Mobile Air Conditioners?8

(thousands of pounds per year of CFC)

1976 1990
Manufacturing 14,600 11,300
Leakage (normal use) 22,800 36,300
Service 28,000 43,200
Recharge 3,300 4,700
Accident 5,400 8,400
Disposal 8,500 24,900
Total 82,600 128,800
CFC Cumulative Bank 222,000 383,500

from 1960.

-24-


The final EPA and FDA chlorofluorocarbon aerosol regulations
were published on March 17, 1978.9710 at that time CPSC
announced that its own banning action was unnecessary, given the
EPA and FDA regulations, and given that TSCA and the Federal
Food, Drug, and Cosmetic Act (FFDCA) together had sufficient
authority to control those products under CPSC's jurisdiction.
Under the TSCA, the final EPA rule prohibited

1.

The manufacture of fully halogenated
chlorofluoroalkanes for nonessential aerosol
propellant uses after October 15, 1978,

The processing and distribution in commerce of fully
halogenated chlorofluoroalkanes for nonessential
aerosol propellant uses after December 15, 1978,

The processing for export of fully halogenated
chlorofluoroalkanes for nonessential aerosol
propellant uses after December 15, 1978, and

The importation of fully halogenated
chlorofluoroalkanes as a chemical substance or as
part of an article for any nonessential aerosol
propellant use after December 15, 1978.

Under the FFDCA the final FDA regulation? prohibited

1.

The manufacture or packaging of food, drug, medical
device, or cosmetic products containing fully
halogenated chlorofluoroalkanes as an aerosol
propellant after December 15, 1978, and

The initial introduction into interstate commerce of
finished food, drug, device, or cosmetic products
after April 15, 1979.


IV INVESTIGATION OF OTHER STRATOSPHERIC
OZONE DEPLETING SUBSTANCES

CFCs are not the only possible ozone depleting materials
under scientific investigation. EPA is investigating other
chemical substances such as methyl chloroform, nitrous oxide, and
carbon tetrachloride for ozone depletion potential. Monitoring
programs also have been established to quantify the ozone
depleting potential of several suspected substances.

OTS and the Office of Research and Development (ORD) are
assessing the risk associated with methyl chloroform. At the
request of the Office of Air Quality Planning and Standards
(OAQPS), the risk assessment will study the long-term effects of
methyl chloroform as an ozone depleting compound. This risk
assessment will provide a scientific basis for implementing or
not implementing a standard proposed by OAQPS which would remove
methyl chloroform from the list of chemicals exempt from air
quality standards.

A preliminary analysis of nitrous oxide has been prepared
which includes a materials balance. The nitrous oxide report
concludes that the problem could be serious in 20 to 50 years,
but it is not an immediate crisis. The report recommends more
accurate analyses on estimated global emission change in nitrous
oxide from soil, fertilizer, and crop systems and on the amounts
of nitrous oxide concentration changing in the atmosphere.

Except for CFC-1l and CFC-12, global data for stratospheric
ozone depleting materials have not been collected in any
centralized or systematic way. Strengthening the data base is a
Major goal of the current OTS monitoring program for other ozone
depleting emissions. Methylene chloride, CFC-22, and nitrous
oxide are currently the subjects of such monitoring studies.

Materials balances and studies to trace the fate of
chemicals through the atmospheric system will provide initial
steps in the ozone depletion analysis. For example, a materials

-46-


REFERENCES

Committee on Impacts of Stratospheric Change, National
Academy of Sciences, "Halocarbons: Environmental Effects of
Chlorofluoromethane Release", National Academy of Sciences,
National Research Council, Assembly of Mathematical and
Physical Sciences; Washington, D.C.; 1976.

NASA, “Chlorofluoromethanes and the Stratosphere", NASA
Reference Publication 1010; Greenbelt, Maryland; August
1977.

Committee on the Impacts of Stratospheric Change, National
Academy of Sciences; “Response to the Ozone Protection
Sections of the Clean Air Act Amendments of 1977: an
Interim Report"; National Academy of Sciences; December 15,
1977.

Proceedings from the NASA Stratospheric Ozone Workshop at
Harper's Ferry, West Virginia; June 4-8, 1979; in
preparation.

National Cancer Institute, National Institutes of Health,
Department of Health & Education and Welfare Communication
to be included in their Report to Congress as required under
Section 154 of the Clean Air Act.

UNEP, Coordinating Committee on the Ozone Layer; Final
Report of the Second Session; Bonn Germany; November 28 ~
December 1, 1978.

Blum, Barbara; Letter from the Acting Administrator,
Environmental Protection Agency to the President of the
Senate and the Speaker of the House of Representatives; U.S.
Congress; March 14, 1978.

Breidenbach, Andrew W.; "Request for Approval of a
Development Plan to Initiate the Regulatory Process to Phase
Out the Nonessential Use of F-11 and F-12
Chlorofluorocarbons--Decision Memorandum" and
"Chlorofluorocarbons Development Plan"; Environmental
Protection Agency; Washington, D.C.; October 29, 1976.

Federal Register Notice; 43 F.R. 11318; March 17, 1978;
"Fully Halogenated Chlorofluoroalkanes".

-48-


the rest of the world).* Remaining U.S. CFC production was
expected to be marketed almost entirely for nonaerosol uses, with
the exempted aerosol uses estimated to account for two to three
percent of the total U.S. CFC aerosol use.

The EPA rule was estimated to have an economic impact
ranging from 169 million to 267 million dollars annually for the

14 Approximately

four years following publication of the rule.
2,000 jobs were estimated to be lost in the filling, valve, and
container segments of the aerosol industry. Because other types
of propellants were less expensive, consumers were estimated to
save 58 million to 240 million dollars annually by buying
substitute products during the same four-year period. With the
exception of the filling segment of the aerosol industry, the
impact on small businesses was expected to be minimal, since
there were likely to be some positive effects on small businesses
that produced and marketed alternatives to chlorofluorocarbon
products.

At the time of the publication of the EPA rule, there were
six manufacturers of CFCs in the United States. Five companies
(DuPont, Allied, Kaiser, Pennwalt, and Union Carbide) are large,
diverse firms capable of adapting to the rule with very little
effect on their profits. The smallest firm, Raycon, manufactured
only CFCs, but stated at that time that it produced none for
propellant uses. Thus, EPA concluded that the regulation of
aerosols would not have a major effect on these firms. Since
that time Union Carbide has ceased its production of CFCs.

The economic report indicated that most marketers, container
manufacturers, and valve suppliers could adapt to this rule,
since they were large outfits with significant aerosol volumes in
other than the affected product areas. Container manufacturers
and valve suppliers were both found to produce products that

* This estimate assumes that all aerosol production was promptly
emitted. The study revealed that much of the nonaerosol produc-
tion is retained in the product for many years.

-12-