Engineering the Environment: Regulatory Engineering at the U.S. Environmental Protection Agency, 1970-1980 Jongmin Lee Dissertation submitted to the faculty of the Virginia Polytechnic Institute and State University in partial fulfillment of the requirements for the degree of Doctor of Philosophy In Science and Technology Studies Matthew H. Wisnioski, Chair Mark V. Barrow, Jr. Gary L. Downey Saul Halfon Ann Johnson August 2, 2013 Blacksburg, VA Keywords: air pollution, control technology, environmental regulation, regulatory engineering, catalytic converter, scrubber, U.S. Environmental Protection Agency Copyright Jongmin Lee Engineering the Environment: Regulatory Engineering at the U.S. Environmental Protection Agency, 1970-1980 Jongmin Lee ABSTRACT My dissertation addresses how engineers, scientists, and bureaucrats generated knowledge about pollution, crafted an institution for environmental protection, and constructed a collective identity for themselves. I show an important shift in regulators’ priorities, from stringent health-based standards to flexible technology-based ones through the development of end-of-pipeline pollution control devices, which contributed to the emergence of economic incentives and voluntary management programs. Drawing on findings from archival documents, published sources, and oral history interviews, I examine the first decade of the EPA amid constant organizational changes that shaped the technological and managerial character of environmental policy in the United States. Exploring the EPA’s internal research and development processes and their relationship with scientific and engineering communities sheds light on how the new fields of environmental engineering and policy were co-produced in the 1970s. I argue that two competing approaches for environmental management, a community health approach and a control technology approach, developed from EPA’s responses to bureaucratic, geographical, and epistemic challenges. I focus on researchers and managers from the Office of Research and Development at Research Triangle Park, North Carolina, as they were engaged in (1) controversy about integrated aerometry and epidemiology research intended to correlate air pollution and health, (2) intra-agency debate about the government’s responsibility for introducing catalytic converters for tailpipe emissions reduction and responding to the potential environmental and social consequences, and (3) inter-agency activities for the demonstration of scrubbers for smokestack emissions and further application of the control technology approach in energy-related environmental problems. My principal conceptual contribution is “regulatory engineering.” I define regulatory engineering as an approach to sociotechnical problems in which engineering practices are incorporated into regulatory and organizational changes, which in turn influences technical knowledge and identity formation. As EPA activities became closely associated with energy and economic issues toward the end of the 1970s, I argue that engineers took the initiative in demonstrating and evaluating control technologies for pollution abatement and energy development, scientists carefully studied environmental and health effects of these technologies, and regulators set up pollution standards and attainment deadlines accordingly. Studying the co- production of knowledge, institution, and identity through the lens of regulatory engineering helps us to understand technoscientific and managerial aspects of environmental governance beyond the 1970s EPA where technical feasibility considerations, economic incentives, and cooperative management expanded into legislation and regulation. iii Acknowledgements As an advisor, mentor, and friend, Matt Wisnioski has shown me his tireless energy and careful guidance for the entire period from the day I met him at his first course at Virginia Tech to our goodbye lunch at Gillie’s. I also appreciate Gary Downey, Saul Halfon, and Mark Barrow for their continuing advice and support. Ann Johnson from the University of South Carolina watched me and my project grow since we first met at Lisbon. Skip Fuhrman generously helped me in finding academic, financial, and life support, and the departmental staff Karen Snider, Crystal Harrell, Doris Shelor, and Carol Sue Slusser have been great in everything from coordinating last-minute submissions to the graduate school to opening Lane 132 multiple times during my last week. Chris Hays was a perfect editor and I hope I can become one for others. There has been much institutional support outside of my department and every bit of it helped me mature. I benefitted from assistantships from the departments of Engineering Education and of Religion and Culture. The National Science Foundation Dissertation Improvement Grant (SES 1059029) funded my numerous trips to the National Archives, EPA libraries, and interview sites. I was fortunate to get long-term fellowships from the Chemical Heritage Foundation and Linda Hall Library that allowed me to focus on my research and share my results with a broad audience. Michael Gorman provided timely advice for revision of my NSF proposal; Jody Roberts, Ron Brashear, and Carin Berkowitz brightened my days at CHF; and Donna Swischer and Bruce Bradley equally brightened my LHL days. My dissertation would have taken longer to write if I had not met my interviewees early in my research. I would like to thank them for all their time and willingness to share their histories. Chuck Elkins of the EPA Alumni Association helped me find essential contacts and background information. I also appreciate the regulators and engineers who I met in less formal iv settings. I would like to thank the following archivists, historians, and librarians who offered invaluable help for my project: Andrew Youngkin, Kezia Procita, Richard Steele, Susan Forbes, and Lisbeth Wells-Pratt (EPA); Ashley Augustyniak (CHF); Nancy Officer, Bill Ashworth, Nancy Green, and Christine Taft (LHL); and Bruce Pencek (Virginia Tech). Furthermore, I really appreciate the generosity of the following institutions and individuals for their permission of oral history interviews and photos: David Caruso at the CHF, Mark Greenwood, and E- Muscle. Eunsil endured first our long-distance relationship and later seven-day work weeks with and for me. I could not finish a page without her utmost support and understanding. Our son, Aiden, increased our sense of accomplishment the last two years. I am so glad that there are more journeys ahead for the three of us. I developed my love of books and people from my father and mother and hope I can find more time to share with them what I’ve learned in the near future. The trust and support I received from extended family are greatly appreciated. Occasional conversations with friends, mentors, and colleagues gave me enough energy to survive the next week or month. Writing two pages has not been easy as my daily goal. When I was stressed, I found relief and reinvigoration from my favorite Korean novelist’s assurance that the daily two-page might be easier than I think and no one can write this for me. After hundreds of days and nights, I thought I became familiar with this quota. But it may not be the case. I have my last two pages in front of me. It was still difficult to write and revise. I have an additional concern that it might not be possible to mention all the help that I received for this dissertation and made me who I am. If you think we haven’t talked recently, please contact me so I can give you a call or send an email full of joy and energy soon! v Table of contents Chapter 1. Introduction................................................................................................................ 1 1.1 Background .......................................................................................................................... 6 1.1.1 Environmental Protection as a Technopolitical Systems Challenge ............................ 6 1.1.2 Engineers as Moderate Environmentalists ................................................................... 8 1.1.3 Regulators as Technology Policymakers ................................................................... 12 1.2 Approaches of the Dissertation .......................................................................................... 14 1.2.1 Regulatory Engineering .............................................................................................. 14 1.2.2 Research Methods ...................................................................................................... 18 1.2.3 Organization of the Dissertation ................................................................................ 22 Chapter 2 Establishing and Managing the Federal Environment, 1969-1973 ...................... 25 2.1 The Road to a New Regulatory Agency ............................................................................ 28 2.2 Incorporating Diverse Traditions and New Ideals into One Agency ................................. 33 2.2.1 Inheriting Existing Agendas ....................................................................................... 33 2.2.2 Inventing New Functions ........................................................................................... 42 2.3 Organizing Research Laboratories for Environmental Protection ..................................... 44 2.4 Competing Approaches to Managing the Federal Environment ........................................ 53 2.5 Conclusion: