Three suburban Washington Volkswagen dealers were among 12 accused nationwide yesterday by the Environmental Protection Agency of tampering with pollution control equipment on 1975 and 1976 model Rabbits and Sciroccos.

The three dealers named here were Ray Burnette Volkswagen of Alexandria Storlman Volkswagen Subaru at Tysons Corner and Montgomery Cars in Rockville.

EPA charged the dealers with "an incredible injustice to consumers" for allegedly removing catalytic converters, which reduce pollution, and failing to make engine modifications on Volkswagen so they would meet pollution control standards.

Volkswagen of America, the German automaker's U.S. distributor, agreed with EPA in 1976 to pay its dealers to fix pollution controls on up to 195,000 cars by removing catalytic converters and making engine modifications, according to Marvin B. Durning, EPA's assistant administrator for enforcement. Customer complaints, Durning said, led EPA to discover that catalytic converters in 12 instances were removed but the engine modifications were not made.

"The consumer paid nearly $150 for emission control when he purchased the car, and part of that was profit to the dealer," Durning said. Volkswagen "then paid the dealer to fix the cars. The result now is that neither the consumer nor Volkswagen got what they paid for.

"The dealer, however, has been paid twice for pollution control that does not exist, and the public still gets dirty air," Durning said.

Volkswagen, in a statement issued from its main office in Englewood Cliffs, N.J., called EPA charges "ill-founded" and said the allegations "unnecessarily impugn dealer integrity."

Volkswagen said it was "surprised" at the EPA charges because the company said they are based on what it called "incomplete test results from a limited sample." The company also said it offered to conduct a test program on cars which had been modified, but that EPA did not respond to the offer.

EPA has asked the Justice Department to take civil action against the dealers and Volkswagen in connection with the violations of the Clean Air Act. A dealer can be fined up to $10,000 for each car with pollution controls that have been "removed or rendered inoperative."

An EPA spokesman said yesterday the agency has inspected 31 cars serviced by the 12 dealers, including 20 cars in the Washington area, and that none of them passed emission inspections. "This is the most pervasive (emission control tampering) problem we have uncovered to date," Durning said.

Reached by telephone, Ray Burnette, owner of Ray Burnette Volkswagen, said, "We know nothing about it (the EPA action). We don't know what they are talking about." He said that he did not know of any money his company received from Volkswagen to fix faulty catalytic converters, but that he would have to check his books to be certain. He said that he has not heard of any complaints about VW's catalytic converters, complaints EPA said are widespread.

At Montgomery County Cars, manager Dan Martin said EPA called him Friday and told him his company would be cited for a year-old violation on one car. The problem, Martin said, was that "we goofed" by putting a 1976 pollution-control conversion kit on a 1975 Rabbit. Martin said the mistake involved two parts of an 11-part conversion kit. "We have done hundreds and hundreds of them and we goofed on this one," he said.

Officials of Stohlman Volkswagen-Subaru could not be reached for comment.

The EPA also accused a Volkswagen of America representative of improperly modifying one of the cars. EPA did not identify the person involved. Durning said the failure of an official Volkswagen representative to uphold pollution control standards "indicates a disregard for the problem of air pollution and lack of responsibility."

The repairs that were required on 1975 and 1976 Rabbits and Sciroccos, which EPA said had a high rate of catalytic converter failure when then were new, involved removal of the converter and modification of the carburetor, crankcase ventilation system, exhaust gas recirculation system and vehicle labels.

Durning said partial modification of these engine parts "increases the pollution emitted by the cars."