INTERSTATE  AIR  POLLUTION

                                            STUDY
 BI-STATE DEVELOPMENT
        AGENCY

ST.  LOUIS DEPARTMEKT OF
 HEALTH AND HOSPITALS


ST.  LOUIS -  DIVISION OF
 AIR POLLUTION CONTROL


 EAST ST. LOUIS  -  AIR
   POLLUTION CONTROL
      COMMISSI ON
     PHASE II PROJECT REPORT
    ST.  LOUIS COUNTY
   HEALTH  DEPARTMENT

    EAST SIDE HEALTH
       DISTRICT


    MISSOURI DIVISION
       OF HEALTH


   ILLINOIS DEPARTMENT
    OF  PUBLIC HEALTH

 CHAMBER OF COMMERCE OF
 METROPOLITAN ST.  LOUIS
   VIII. A PROPOSAL FOR AN AIR
RESOURCE MANAGEMENT PROGRAM
 ILLINOIS AIR POLLUTION
    CONTROL BOARD


         DHEW
  PUBLIC  HEALTH SERVICE

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         INTERSTATE AIR POLLUTION STUDY
              PHASE II PROJECT REPORT
            VIII.  A PROPOSAL FOR AN AIR

         RESOURCE MANAGEMENT PROGRAM
                     Prepared by

                    J. D. Williams

                      G. Ozolins

                     J. W. Sadler

                    J. R. Farmer
U. S. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE

                  Public Health Service
   Bureau of Disease Prevention and Environmental Control
         National Center for Air Pollution Control
                    Cincinnati, Ohio

                      May 1967
            U.S.  Environmental  Protection Agenoy,
            Region 5, Library  (5PL-16)
            230 S. Dearborn St-eet, Room 1670
            Chicago, IL   60604

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      Copies of this report are available from the cooperating agencies listed on
the cover of this report and from the National Center for Air Pollution Control,
1055 Laidlaw Avenue, Cincinnati, Ohio  45237.
                                        11

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                            ACKNOWLEDGMENTS
    Volume VIII of the Interstate Air Pollution Study Phase II Project Report,
although prepared by J. D. Williams, G. Ozolins, J. W. Sadler, and J. R. Farmer,
is the product of contributions from all participating project agencies and many
individuals. Several of the original ideas and approaches submitted were incor-
porated into the report. The Division of Air Pollution, Technical Assistance
Branch staff helped develop and clarify numerous ideas and concepts, and re-
viewed the report in several stages.  The individuals who have contributed are too
numerous to mention by name, but their contributions were in all cases significant.
All  should gain a  sense of satisfaction from the role this report plays in helping
the  people of the St. Louis Metropolitan Area reach their clean-air goals.
                                      111

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                                 FOREWORD
    The Interstate Air Pollution Study was divided into two phases.  Phase I, a
general study of the overall air pollution problems in the St. Louis - East St. Louis
Metropolitan area, was conducted to determine specific  activities that would require
further study in Phase II of the project.  The effort was  divided into two phases to
provide a logical stopping point in the event that interest and resources for proceed-
ing further might not materialize.  The necessary impetus did continue,  however,
and the Phase II operation was also completed.

    The Phase  I operation resulted in a detailed report, designed primarily for use
of the Executive Committee members and their agenices in making decisions con-
cerning the Phase II project operation.  A Phase I summary report was also pre-
pared; it received wide distribution.

    Numerous  papers, brochures,  and reports were  prepared during Phase II opera-
tions, as were some 18 Memorandums of Information and Instruction concerning
the project.  All of these documents were drawn upon in the preparation of the
Phase II project report.  It consists of eight separate volumes under the following
titles:

              I. Introduction
             II. Air  Pollutant Emission Inventory
            HI.  Air  Quality Measurements
            IV.  Odors - Results of Surveys
             V. Meteorology and Topography
            VI.  Effects of Air Pollution
            VII.  Opinion Surveys and Air Quality Statistical Relationships
           VIII.  Proposal for an Air Resource Management Program

    The Project Executive Committee has prepared  and approved a technical plan
for an air resource management program.  It represents a majority view of the
agency representatives composing the Executive Committee, but does not necessarily
indicate acceptance of all items by all representatives or agencies cooperating on
the project.

    It is realized that some of the  air pollutant sources will be unable to comply with
the recommended standards because of economics and lack of technical development;
therefore, provision for variance should be provided to avoid unnecessary burden on
such sources.

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    Clean air is an economic good that, once attained, is enjoyed by everyone in an
air pollution basin. It seems reasonable that the cost of obtaining clean air should
be shared by everyone enjoying the benefit. Unfortunately this ideal is not feasible
because control equipment cannot and should not be publicly owned, nor can the
knowledge for limiting pollutant emissions be a monopoly of government.  To assist
in establishing a degree of equity it is therefore suggested that tax benefits be given
those sources that must purchase pollutant controls,  in proportion to these expendi-
tures. These  benefits should be given at any or all appropriate levels of govern-
ment  - local, state, or Federal.
                                       VI

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                                  CONTENTS



RECOMMENDATIONS	    1

INTRODUCTION	    3

AIR-USE PLANS	    6
        Introduction	    6
        Air-Use  Plan - Particulates	    8
                 Air-Quality Goals	    9
                 Existing Air Quality	    9
                 Existing Emissions	   10
                 Relationship Between Air Quality and Emission Density ...   14
                 Land Use and Allowable Emission Densities	   18
                 Emission Reduction  Plan	   18
                 Impact of Proposed Regulation on Existing and New
                      Emissions	   30
                 Special Applications of the Emission Reduction Plan	   32

        Air-Use  Plan - Sulfur Dioxide	   32
                 Air-Quality Goals	   33
                 Design Period	   33
                 Relationship of Air-Quality Goals to Design Period
                      Concentrations	   34
                 Existing Concentrations	   35
                 Existing Emissions	   38
                 Relationship of Emission Density and Air Quality	   43
                 Allowable Emission  Density	   45
                 Emission Reduction  Plan	   46

        Air-Use  Plan - Hydrocarbons	   54
                 Air-Quality Goals	   54
                 Existing Concentrations	   55
                 Existing and Projected Emissions	   55
                 Emission Reduction  Plan  	   63

        Air-Use  Plan - Carbon Monoxide	   65
                 Air-Quality Goals	   65
                 Existing Concentrations	   66
                 Existing and Projected Emissions	   66
                 Emission Reduction  Plan	   66

        Air-Use  Plan - Nitrogen Oxides	   68
                 Existing Concentrations	   68
                 Existing Emissions	   68
                                     vn

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        Air-Use Plan - Odors	   72
                Existing Conditions	   72
                Air-Quality Goals - Odors	   74
                Evaluation of Existing Conditions	   74
                Odor Reduction Plan	   75

        Benefits of Rapid Transit System	   76

SUGGESTED ORGANIZATION OF INTERSTATE AIR POLLUTION STUDY AREA
     AIR RESOURCE MANAGEMENT PROGRAM	   78

        Illinois Program in St. Clair and Madison Counties	   79
        Missouri State Air Pollution Program	   80
        Illinois Local Agencies	   80
        Missouri Local Agencies	   81
        Interstate Agreement	   81
        Interstate Coordinating Organization	   81

GUIDELINES FOR  FUTURE AIR RESOURCE MANAGEMENT PROGRAM
     ELEMENTS AND FINANCING	   82

        Continuing Air-Quality and  Effects-Monitoring Program	   82
        Current and Continuing Emission Inventory	   83
        Air-Quality Goals, Standards and Criteria	   85
        Use of Conditions Influencing Transport of Air Pollutants	   85
        Air Pollution Control Decisions Based upon Air-Quality Information
              and  Goals	   86
        Program Financing	   86

REFERENCES  	   86

APPENDICES	   88

        A - Particulate Levels Due  to Venice Power Plant	   88

        B - Suggested Ordinance Provisions	   89
                                     Vlll

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                        VIII. A PROPOSAL FOR AN AIR
                   RESOURCES MANAGEMENT PROGRAM
                            RE COMME NDATIONS
    The following summary of major recommendations for an air resource man-
agement program is based on the Interstate Air Pollution Study findings reported
in Volumes I through VII of this report.  The recommendations, developed and ex-
plained in detail in this section, Volume VIII, are outlined below.

ORGANIZATION
1.  Establish a means for joint air pollution activities, involving local and state
agencies, by agreement or compact between the States of Missouri and Illinois.

2.  Develop a regional organization covering the Illinois  portion of the air pollution
basin and delineating appropriate roles for both State and local agencies.

3.  Strengthen, improve, and increase air pollution program activities in St. Louis
and St. Louis County.

4.  Establish a functional linkage between regulatory and urban planning activities
directed toward preventing air pollution problems arising from land-use and
air-use conflicts, to optimize the air use.

5.  Plan for  governmental air pollution program expenditures at a level of 50 cents
per capita per year by 1970.

ACTIVITIES

1.  Implement the following major program elements of an air resource management
program in a balanced and coordinated manner but with emphasis on control of
pollutants in the immediate future through utilizing the information and data pro-
vided by the Study:

    a.  A continuing air-quality monitoring program.

    b.  A current and continuing emission inventory.

    c.  Air-quality goals and standards based on air-quality criteria.

    d.  A thorough knowledge and use of the conditions influencing the transport of
       air pollutants.

    e.  Urban planning  decisions based on air quality as  well as other environmen-
       tal factors.

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     f.  Air pollution control decisions and resulting ordinances based on air-qual-
        ity information and relationships between air quality and effects.

     g.  Air-use plans.

2. Implement the particulate air-use plan by enacting regulations or ordinance
provisions to accomplish the following objectives, which are designed to reach the
air-quality goal of 75 micrograms per cubic meter as a yearly average at any
place where people live or where  an undesirable effect might result:

     a.  Elimination of hand firing of fuels on a gradual basis.

     b.  Elimination of open burning.

     c.  Limitation of pollutants from incinerators.

     d.  Limitation of pollutants from the burning of coal.

     e.  Limitation of allowable visible pollutants.

3. Implement a vigorous  odor control program to eliminate objectionable odors
in any residential area.

4. Implement the sulfur dioxide air-use plan by enacting regulations or ordi-
nance provisions to accomplish the following objectives, which are designed to
meet an air quality goal of 0.1 ppm for a 24-hour average not to be exceeded over
1 percent of the time in any 100 consecutive  days at any place where people  live  or
where an undesirable effect might result:

     a.  Limitation of the  sulfur content of fuels to 2.3 pounds sulfur dioxide  per
        million Btus of heat input for equipment smaller than 2,000 million Btus  of
        heat input.

     b.  Development of a plan within 2 years, for equipment larger than 2,000
        million Btu  to meet the limitation of (4a) by some scheduled future  date.

     c.  Limitation of sulfur emissions from  industrial processes.

5. Implement the hydrocarbon,  carbon monoxide, and nitrogen oxides air-use
plans primarily by designing into  the proposed mass transit study items that will
help prevent undesirable  levels of the following:

     a.  Hydrocarbons.

     b.  Nitrogen oxides.

     c.  Carbon monoxide.

     d.  Oxidants.

     e.  Aldehydes.

     f.  Odorous  materials (e.g. diesel exhaust).

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    g.  Particulate matter.

6.  Limit emissions of acidic and alkaline pollutants.

7.  Limit hydrocarbon emissions by:

    a.  Requiring submerged fill pipes on certain new tanks.

    b.  Requiring vapor-recovery systems to be installed on certain new tanks.

    c.  Requiring refuse disposal methods that will not contribute hydrocarbons to
        the air.

                               INTRODUCTION
     Benefits are gained by good management practices whether these practices
 are applied to the home and family, business, or government.  The principles are
 basically the same in each case: a thorough knowledge of resources must be  ob-
 tained, and plans must be formulated to apply those resources toward achieving
 specific  goals.  For example, good business management calls for a knowledge of
 what is wasted so that wastes can be converted into by-products, materials can be
 conserved, and new products can be developed.  On a somewhat broader scale,
 knowledge of all wasted solid, liquid, and gaseous materials, lost to the atmos-
 phere as pollutants, could provide the means for optimizing material use and con-
 serving  many basic materials. Materials conserved or reclaimed would be used for
 other purposes and economic gain.

     The air, being a basic material for any manufacturing process, combustion
 process, or for  the use  of humans in supporting life, can hardly escape the atten-
 tion due  it by present day society.  In the past,  air was considered God given and
 free. This attitude is revealed in many expressions of our society, such as "free
 as the air". Air is not unlimited however, at least in certain geographical areas.
 This fact is revealed, and has been for many years,  by numerous land-use and air-
 use conflicts. For example, an industry located in a residential area might want to
 use the air for disposal of wastes, whereas the residents would want the air to be
 safe for  breathing and clean enough to protect their property.

     The air is a matter of public business, calling for good management practices.
 The public must have knowledge of air quality,  effects of air pollutants, and the
 types and quantities of pollutants put into the air.  Armed with this knowledge, the
 public depends on its governmental organizations to establish air quality goals and
 standards, and to develop the program goals, air-use plans, and action programs
 needed to reach the desired air quality.  Simply stated,  the public embarks on an
 air resource management program to assure sound community growth in which the
 air resources of the air pollution basin*  are put to optimum use. The major  pro-
 gram elements of an air resource management program are:
* The term "air pollution basin" as used in this report refers to an area in which
air pollutants originate and collect, and in which the principal effects of those pol-
lutants occur.

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     1.  A continuing air-quality monitoring program.

     2.  A current and continuing emission inventory.

     3.  Air-quality goals and standards based on air-quality criteria.

     4.  A thorough knowledge and use of the conditions influencing the transport of
air pollutants.
     5.  Urban planning decisions based on air quality as well as other environmen-
tal factors.

     6.  Air pollution control decisions and resulting ordinances based on air-qual-
ity information and relationships between air-quality and effects.


     The interrelationships between the six program elements are shown in
Figure  1, a flow diagram that explains air resource management.  Note the central
importance of air quality goals and how they relate each program  element to the
other parts.  The goals are  based on the  effects that air pollutants at particular
levels may cause. Effects in turn are related to numerical air-quality levels by
criteria - word meanings equated with numbers. These program  elements consid-
ered within a suitable decision-making process  lead to the establishment of goals,
which in turn lead to air  quality standards, ordinances, rules and  regulations, plan-
ning decisions, and community purposes  and policies.  The  results are  changed
levels of air pollution, changes in emissions, and changes in the effects that pollu-
tants cause.


     The Interstate Air Pollution Study has presented the information and data
needed for initiating an air resource management program in seven major sections
of the Study Phase II Project Report.  These seven  sections were used to prepare
this  section, which presents recommendations concerning air quality goals, emis-
sion limitations needed to reach those goals, and the program organization suitable
to assure a viable and continuing program.


     For the Interstate Air Pollution Study Area air resource management program
to meet its goals, the following points must be agreed to:
     1. The air pollution basin must be covered adequately and all listed air re-
 source management activities (program elements) must be carried on to assure
 complete success.

     2. Air-quality goals must be established that will be uniform or that will be
 uniformly applicable on a meteorological and land-use basis.

     3. The air-quality levels as defined by goals will be  reached by control of air
 pollutant sources adequate to prevent air pollutants that cross political or land-use
 boundaries from causing the goals to be exceeded.

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                              AIR-USE PLANS
INTRODUCTION

    The basic objective of an air resource management program is to obtain and
maintain optimum air quality defined by air-quality goals. These goals for the
Interstate Air Pollution Study were selected on the basis of effects.  The goals and
justification for their selection are reported in Volume VI of this report.


    This report section, Volume VIII, is devoted to the development of air-use
plans for each of the major air pollutants found in the St.  Louis urbanized area.  An
air-use plan may be thought of as a link between the pollutant emissions of a com-
munity and the air-quality goals. The overall function of  these plans is to optimize
the use  of the air by considering the amounts, configurations, and locations of the
sources and the dilution capability of the air basin.  The air-use plans may be used
as the basic framework for achieving the desired air quality by such means as
limiting the emissions from individual sources, limiting the emissions from sources
in certain areas,  or even  disallowing new pollutant sources in overburdened areas.
The air-use plans thus provide the bases for enacting control regulations and serve
as a guide for future planning activities.
    The type and configuration of pollution sources, the extent by which the air-
quality goals are exceeded, and the meteorology and the topography are peculiar to
each urban area. For these reasons, it is unrealistic to expect that common air-use
plans and the same control regulations may be applied indiscriminately in any area.
Control regulations must be based strictly on the reductions in pollutant emissions
needed in each air pollution basin.

    The design of an air-use plan consists of two parts.  The  first part is the cal-
culation of  the quantity of pollutants that may be safely emitted and the reductions
needed to reach  the allowable emission  rates. The second part consists of guide-
lines for achieving these reductions by determining the reductions in emissions
needed from specific source categories in certain areas or even from individual
sources.

    The design of an air-use plan at the present stage of design-system develop-
ment is complicated by the number and  diversity of pollutant sources present in ur-
ban areas,  the incompleteness of data concerning emission rates and release heights,
and the uncertainty of knowledge concerning the diffusion characteristics of the at-
mosphere.   In the effort to  determine the dilution capacity of the atmosphere in the
Study area,  it was necessary to employ  several simplifying assumptions,  some of
which have not been fully tested.  Until more accurate  emission and meteorological
data become available and the use of computerized diffusion models capable of con-
sidering all the important variables are perfected, the presented techniques and the
air-use plans for the St.  Louis area will provide an adequate framework for making
decisions.

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    The pollutants considered in this section include particulates, sulfur dioxide,
hydrocarbons, carbon monoxide, oxides of nitrogen, and odors; however, compre-
hensive emission reduction plans have been developed for only particulates and sul-
fur dioxide.  Hydrocarbons, carbon monoxide, oxides of nitrogen, and odors have
been considered to a lesser degree. Hydrocarbons and carbon monoxide are emitted
primarily by motor vehicles and are expected to be controlled primarily on a nation-
wide scale and secondarily by changes in the mass transit systems in St.  Louis.

    Oxides of nitrogen are becoming an increasing problem; however, the limited
air-quality data and lack of air-quality goals as the Study was being conducted would
not permit a  more complete treatment.   Because odors are generally associated with
individual sources, a comprehensive reduction plan is not workable; therefore, the
treatment of  odors is discussed only in general terms.

    Since the development of a rapid transit system will have a notable effect on the
air concentrations of certain pollutants  in the St. Louis area, and especially in the
downtown areas, its importance as a means to  reducing air pollution must not be
overlooked.  For this purpose a special report section on the impact of a rapid
transit system is also included.

    In the design of air-use plans, the pollution sources have been classified accord-
ing to the following land-use  categories: residential, commercial, industrial, and
open space (including roads).  With the land-use designated, the variability in emis-
sion sources may be considered and different area emission limitations dependent
on land-use may be prescribed. This leads to  a more equitable basis for reducing
the emissions and permits cleaner air in the places where people  live.

    Although the Interstate Study covered an area of over 3,500 square miles and
included the City of St. Louis and the six surrounding counties, the design of the
air-use plans was based on only the centrally located, highly urbanized area of
some 394 square miles (Figure 2*). This was done for two reasons.  First, this
area contains the vast majority of the pollutant sources, and second, the sources
located in this area add to the pollution  of this  area at all times, whereas those
located in the surrounding areas do so only under certain meteorological conditions.
It would, therefore, be unsuitable in an engineering design sense to consider these
sources in the same context.  Since, however, the meteorology and topography are
similar within this 3,500-square-mile area, the design relationships developed
should be applicable to all parts of this  area provided emission and air-quality data
are collected for those sub areas.  In other words,  a decision to have ordinances
uniform in all parts of the counties in the air pollution basin based on central ur-
banized area calculations  would not be primarily an engineering design decision,
but would be  a program design decision.

    As noted previously, utilization of air-use  plans is not limited to setting emis-
sion control regulations, but  is also applicable  in urban planning activities. Future
activities should be evaluated with respect to the information presented here since
some of the best and least expensive ways of combating air pollution may come
 * Area maps used in this report are divided into 10,000-foot-square grids.  Refer-
 ence to grid cells by coordinate numbers indicates the grid cell to the north and
 east of the designated point.

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                                                           / EG END
                                                      BOUNDARIES
                                                        STATE
                                                        COUNTY
                                                      HIGHWAY MARKERS
                                                        FEDERAL
                                                        STATE
     590  400™ 410  420  430  440  450  460  470  480  490  500™ 510  520  530  540   550  560  570

Figure 2.   Location map - central urbanized area of prime interest in Interstate
           Air Pollution Study.

under the responsibilities of planning and not control agencies.  Similarly, infor-
mation needed to fill the gaps in the presented air-use plans should be collected so
that refinement is continuous.  For example, information relating to the variation
in emission rates with time as well as  emission release elevations is needed.
Furthermore, accurate and up-to-date  land-use data are a necessity  for further re-
finement of the air-use plans.

AIR-USE  PLAN - PARTICULATES

     Particulate matter is the most common air pollutant in urban areas.  The prin-
cipal sources of this pollutant are the burning of heavy fuels, industrial processes,
and refuse disposal by burning.  In terms of the quantity of particulate matter emit-
ted to the air, a few large pollutant sources contribute,  or have the potential for
contributing, more than 50 percent of the area total. Since these emissions are re-
leased from much higher elevations than most others, the additional dilution dis-
perses the pollutants over a large area.  Smaller sources distributed throughout the
area cause many localized problems. In the design of the particulate air-use plan,
both types of sources were considered.  The plan is developed by using the follow-
ing items:

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     1.  Air-quality goals.

     2.  Existing air quality.

     3.  Existing emissions.

     4.  Relationship between air quality and emission density.

     5.  Land-use and allowable  emission densities.

     6.  Emission reduction plan.



Air-Quality Goals

     The three measures of particulates  - suspended particulates, dustfall, and
soiling  index - are closely interrelated;  therefore, usually if one is reduced, the
others are also reduced.  Suspended particulate values measured by high-volume
filter samplers are the most representative; therefore, these values have been the
accepted as the measure of choice for particulate concentrations.  Trial calculations
have shown that reductions in particulate emissions necessary to meet the suspended
particulate goal will probably also result in the achievement of the goals set for the
other measures of particulates.   The desired goals for suspended particulates as
measured by high-volume samplers have been  set at:

     1.  An annual geometric mean concentration of 75 micrograms per  cubic meter.

     2.  Two-hundred micrograms per cubic meter, not to be exceeded for more than
1 percent of days in any 1 year.

These goals are applicable to all areas where people  live or an adverse effect may
occur.  The use of these air-quality goals and subsequent design of the air-use plan
for particulates are based on the weight  of particulate matter.  The particle size
distribution and the chemical composition are probably just as important as the
weight,  but lack of data at this stage of air quality measurement capability does not
allow their consideration.


Existing Air Quality

     As recorded at the 17 high-volume sampling stations during 1963-1964, the an-
nual geometric mean concentrations of suspended particulates varied from approx-
imately 60 micrograms per cubic meter  at one suburban station to more than 220 at
a sampling site close to a major source  of pollution.  From an isopleth  map based
on these data, the weighted geometric mean for the area  was found to be approximately
92 micrograms per cubic  meter. Approximate land areas and the mean annual con-
centration they are subjected to, according to these measurements, are presented
in Table 1.  The annual geometric mean  concentrations of suspended particulates
are in excess of 75 micrograms per cubic meter over more than 50 percent of the
area, or 200  square miles, and the 99 percentile goal of 200 micrograms per cubic
meter is exceeded over almost the entire area. (Figures 3  and 4.)

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           Table 1.  MEAN ANNUAL SUSPENDED PARTICULATE
           CONCENTRATION BY LAND AREAS IN ST. LOUIS -
              EAST ST. LOUIS CENTRAL URBANIZED AREA
Land area,
mi2
21
124
31
41
91
86
Central urbanized area 394
Percent
of total
5
32
8
10
23
22
100
Mean
concentration,
jug/m3
175
125
92
82
68
60
92
Existing Emissions

    Approximately 106,000 tons of participates, or an average of 269 tons per square
mile, is emitted annually to the air of the central urbanized area.  The emission
densities of particulates  range from a few tons per square mile per year in the
sparsely populated residential areas to over 5,000 tons per square mile in highly
industrialized areas.  The primary sources of particulates are the combustion of
coal, certain industrial processes, and the open burning of refuse material.  A sum-
mary of the annual emissions by political subdivisions and source categories is pre-
sented in Table 2.  Volume II of this report presents emission information in detail.
 10

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         Table 2.  ANNUAL (1963-1964) PARTICULATE EMISSIONS IN ST.
         LOUIS - EAST ST. LOUIS CENTRAL URBANIZED AREA
                                  (tons/year)
Land-use category/
Emission sources
Industrial
Fuel-use
Coal
Fuel oil
Gas
Process emissions
Refuse disposal
Incineration
Open-burning
Residential
Fuel-use
Coal
Fuel oil
Gas
Refuse disposal
Incineration
Open-burning
Commercial
Fuel-use
Coal
Fuel oil
Gas
Refuse disposal
Incineration
Open-burning
Open space
Transportation
Road vehicles
Other
Totals
City of
St. Louis
14,450
10,619
10,522
36
61
2,664
1,167
1,167
nab
9,689
7,569
7,273
168
128
2,120
50
2,070
3,693
3,533
3,500
19
14
160
160
na
2,754
2,754
2,150
604
30,586
St. Louis
Countya
8,487
4,607
4,412
138
57
3,865
15
15
na
4,747
3,559
3,161
243
155
1,188
28
1,160
982
960
940
9
11
22
22
na
1,822
1,822
1,510
312
16,038
Madison
Countya
23,887
12,665
12,315
200
150
10,600
622
12
610
4,957
3,177
3,062
87
28
1,780
nc
1,780
503
503
500
2
1
na
na
na
648
648
385
263
29,995
St. Clair
Countya
21,199
11,333
11,248
30
55
5,544
4,322
n
4,322
6,143
4,213
4,089
95
29
1,930
n
1,930
636
615
610
4
1
21
21
na
1,242
1,242
415
827
29,218
Entire
central
urbanized
areaa
68,023
39,224
38,497
404
323
22,673
6,126
1,194
4,932
25,536
18,518
17,585
593
340
7,018
78
6,940
5,812
5,609
5,550
32
27
203
203
na
6,466
6,466
4,460
2,006
105,837
aData are from only the portion of the study area included within the 394-square-
mile central urbanized area of principal interest in the Study.

bna = information not available or reported.

cn = negligible.
                                                                           11

-------
                                 15   I/  8J,  IOC
     LOUIS  CO
  EFFERSON *CO
                                       LEGEND
                                 BOUNDARIES
                                   STATE          	
                                   COUNTY         	
                                 HIGHWAY MARKERS
                                   FEDERAL         —D~
                                   STATE          —O—
ISOPLETHS OF ANNUAL GEOMETRIC MEAN
VALUES
       LINES OF ACTUAL EQUAL VALUE
       LINES OF PROBABLE EQUAL VALUE
HIGH VOLUME SAMPLING FROM JULY 1.1963
TO JULY 1,1964. IT STATIONS
   390  400"' 410   420   430  440   450   460   470  480  490   5001"' 510  520  530   540  550  560  570
Figure 3.   Annual geometric mean values for suspended particulates measured by
             high-volume  sampler (micrograms per cubic meter).
12

-------
                                      LEGEND
                                BOUNDARIES
                                  STATE
                                  COUNTY         	
                                HIGHWAY MARKERS
                                  FEDERAL         —Q
                                  STATE          —O
          ISOPLETHS OF 99 PERCENTILE VALUES
          — LINES OF ACTUAL EQUAL VALUES
              LINES OF PROBABLE EQUAL VALUES
          BASED ON ANNUAL GEOMETRIC MEANS
          AND STANDARD DEVIATIONS FOR IT
          STATIONS DURING JULY 1.1963 TO
          JULY 1.1964.
 390  400"" 410   420  430  440   450   460   470
490   500"°' 510  520   530   540  550  560   570
Figure 4.   Annual 99th percentile values for suspended particulates measured by
             high-volume sampler (micrograms per cubic  meter).
                                                                                          13

-------
    Emission densities in industrial areas range from an average 1,060 tons per
square mile for St. Louis County to an average of approximately 2,843 tons per
square mile for Madison County, with an overall average for the industrial area of
1,890 tons per square mile per year.  The emission densities corresponding to other
land uses are small by comparison: 255 tons per square mile for commercial land-
use areas,  170 tons per square mile for residential, and approximately 35 tons per
square mile for other land uses. Although industrial  land  use constitutes most of
the particulate pollutants, it occupies  only 9 percent of the land in the central urban-
ized area.  The emission densities corresponding to the different land uses and
political subdivisions are given in Table 3.  With the exception of the  City of
St.  Louis, the land-use areas listed are only approximations and should be inter-
preted as such.  Open-burning dumps, included in the  industrial category because of
their  location in industrial land-use areas, are also used for the disposal of domes-
tic and commercial refuse material.
   Table 3.  DENSITY OF PARTICULATE EMISSIONS BY TYPE OF LAND USE IN
          ST. LOUIS - EAST ST. LOUIS CENTRAL URBANIZED AREA
                                 (tons/mi^/yr)
Jurisdictional
subdivision
City of St. Louis
St. Louis Countya
Madison Countya
St. Clair Countya
Central urbanized
area
Land— use category
Industrial
1,460
1,060
2,843
2,185
1,890
Residential
450
52
260
290
170
Commerical
950
83
150
170
255
Open Space
108
17
28
47
35
Total
500
74
555
482
269
aData are from only the portion of the Study area included within the 394-square-
mile central urbanized area of principal interest in the Study.


    The heights of emissions vary from 300 feet for the Cahokia Power Plant to
practically ground level for backyard burning installations.  Nearly all of the resi-
dential emissions and most of commercial and industrial are discharged from ele-
vations of less than 120 feet above ground.


Relationship Between Air Quality and  Emission Density


    As pointed out earlier, the ambient air concentrations of suspended particulates
are dependent not only upon the total quantity of particulates emitted to the air pol-
lution basin, but also on the geographical distribution of the emissions, the types of
 14

-------
sources, the diffusion capacity of the air pollution basin, and the seasonal and diur-
nal variations in pollutant emissions.  To attain the desired air quality goal, even in
the presently most polluted areas, the emission limitations should be considered
according to particulate emissions from specific locations  in the Study area.  Since
emission density (tons per square mile) relates to  the quantity of particulates emit-
ted to the area, this  parameter is used as a basis in setting emission limitations.
    It therefore becomes necessary to determine the limiting emission density
that would result in the desired air-quality in all parts of the area. By considering
several contiguous areas of considerable size and relating their average emission
densities to the corresponding ambient concentrations, a relationship between these
parameters is  obtained.  Figure 5 presents the relationship between the annual
geometric mean concentration and the corresponding average emission density.
This relationship is valid only for areas of considerable size (probably about 20
square miles) where the net effect of pollutant transfer between adjacent areas is
relatively minor.  The location of the preselected areas and the values used in
deriving Figure 5 are presented in Figure 6 and Table 4, respectively.
            200
             50
             00
                         250         500         750        1,000

                        PARTICULATE EMISSION DENSITY,  tons/mi2/yr
1,250
  Figure 5.  Relationship between emission density and mean annual concentration
            for any considerable area in St. Louis urbanized area.
                                                                             15

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                                           I	L _L
                                                AREA E
L E6END
BOUNDARIES
STATE 	
COUNTY 	
HIGHWAY MARKERS
FEDERAL — CJ—
STATE — O —

ISOPLETHS OF ANNUAL GEOMETRIC MEAN
VALUES
__ LINES OF ACTUAL EQUAL VALUE
__« LINES OF PROBABLE EQUAL VALUE
HIGH VOLUME SAMPLING FROM JULY 1,1963
TO JULY 1.1964. 17 STATIONS

   Figure 6.  Location maps of areas used in determining relationships between
             emission density and air quality.
16

-------
              Table 4. MEAN ANNUAL PARTICULATE LOADINGS
              AND CORRESPONDING PARTICULATE EMISSION
              DENSITY IN ST. LOUIS - EAST ST. LOUIS CENTRAL
                              URBANIZED AREA

Area
No.a
A
B
C
D
E
Land
area,
mi^
394
176
75
42
218
Mean annual
concentration,
AJg/m3
92
115
125
150
60
Emission
density,
tons/mi^
269
510
637
993
74
            aLocations of areas are shown in Figure 6.
    According to Figure 5, the limiting emission density corresponding to the
desired annual geometric mean concentration of 75 micrograms per cubic meter is
approximately 175 tons per square mile per year.  To achieve the desired 75 micro-
grams per cubic meter, the average emission density of any contiguous area of
considerable size (probably about 20 square miles or more) should  be limited to
175 tons per square mile per year. The variation in emission density within these
areas will undoubtedly result in a considerable variation in the ambient concentra-
tions of suspended particulates within these areas.
     The 175 tons per square mile is an average over an entire year; the rate at
which the pollutant is emitted and meteorological parameters determine the ambient
air concentration. For example, if the 175 tons per square mile were emitted
during a 3-month period, the concentrations would be far different than if the emis-
sions were spread over the entire year.  Similarly,  a constant emission over a
24-hour period would result in a much different concentration than if the same
amount were emitted during an 8-hour period. In light of this, the following quali-
fying condition must be made for interpreting and applying the desired emission
density of 175 tons per square mile per year.  This  emission density can be related
to air-quality only if the hour-to-hour, day-to-day, and season-to-season emission
variations remain approximately the same as they were during the sampling period
on which the relationship curve is based.  Any major changes in the  distributional
patterns of emissions during the year will undoubtedly displace the curve presented
in Figure 5.  Since, however, the distributional patterns of emissions are not expected
to change drastically, the relationship expressed in  Figure 5 can be  used effectively.
                                                                           17

-------
Land Use and Allowable Emission Densities

     The emissions of particulate matter are categorized according to the type of
land use from which they originate.  Such categorizing relates the emissions to the
actual land areas from  which they arise and allows the development and use of
different allowable emission densities for each type of land use.  The use of the
same allowable emission density for all types of land use would be highly imprac-
tical and in the cases of industrial areas unattainable. Furthermore, the control of
industrial emissions to the same degree as emissions in a residential area is not
needed.  The industrial areas are generally removed from populated  areas even if
only by several hundred yards, and the majority of emissions are discharged from
elevated stacks.  In contrast, the emissions from residential areas are discharged
from much lower elevations  and in most instances may be within a few feet of
the point where effects  may occur.   Furthermore, the requirements for general air-
quality in industrial areas are not as strict as in the areas where people live.

     Four different land-use  categories are considered: industrial, commercial,
residential, and open space.  The industrial land-use category includes the emis-
sions generally arising from this type of land use and also open-burning dumps
and  municipal incinerators.  The commercial land-use category, as used herein,
besides including all the business districts, also includes the emissions from
institutional facilities such as schools and hospitals. Residential  land-use areas are
considered as all of the present built-up residential areas and include the emissions
:fremJ;hese areas.  All land areas not included in the industrial, residential, or
commercial categories were considered as open space and include roads, parks,
cemeteries, and presently undeveloped or vacant land.  The emissions from this
category are emitted by transportation sources.

     According to the previously established relationship between air quality and
emission density, an allowable emission density of 175 tons per square mile per
year will result in an air quality of approximately 75 micrograms per cubic meter.
To be consistent with the average emission density of 175 tons per square  mile per
year, the allowable emission densities selected for each type of land  use should
yield this value overall, if considered in terms of land areas in each  category.  The
selected allowable emission densities are presented in Table 5.  The selection of
these densities was based on the distributional patterns of the different land-uses
and  are expected to provide an average of  175 tons per square mile per year, not
only for the entire area, but also for each political subdivision and most areas of
more than 20  square miles.


Emission Reduction Plan

     The existing and allowable emissions have been established previously.  It is
the purpose, through the development and use of an emission reduction plan, to de-
termine what  control regulations are needed to reduce the  existing emissions to
within allowable limits  and yet allow for future growth. At the same  time, it has
been necessary to test the proposed regulations in terms of their feasibility and to
suggest dates for compliance.

     In a few instances  the proposed regulations may not achieve the needed reduc-
tions in pollutant emissions. This  may happen,  for example, if a number of large
pollution sources are located in a relatively small area. To insure that such
 18

-------




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19

-------
problems are solved, a proposal for individual consideration of the sources in these
areas is included.

     The discussion of the emission reduction plan is divided into four sections
according to land-use  categories.   Since the proposed regulations  in some cases
apply to sources in more than one land-use category, a certain amount of duplication
has been unavoidable.

     Although the objective is to treat the central urbanized area as a whole, without
regard  to political subdivision boundaries, and to develop uniform control regulations
for all areas, the applicability of the proposed regulations had to be tested on a
smaller area basis.  The four political subdivisions  were selected as the basic
areas for this purpose.  The effects of the various control regulations in reducing
the emission were tested by considering what the resultant emissions would be in
each political subdivision.   For a control regulation  to be acceptable, the resultant
emissions were required to be less than the allowable emission in each area.


Industrial Land Use -  During 1963, an estimated 68,023 tons of particulates were
released from the various  sources located in this land-use category and resulted in an
average density of approximately 1,890 tons per square mile per year.  The primary
sources of these emissions were the combustion of coal (57%),  industrial processes
(33%), and refuse disposal  (9%).  The existing emission densities ranged from ap-
proximately 1,060 tons per  square  mile per year in St.  Louis County to over 2,800
tons per square mile in the urbanized portion of Madison  County.  All the existing
emission densities are far above the estimated allowable  emission density of 600
tons per square mile,  and therefore particulate emissions must be reduced in all
parts of the urbanized area.

     To achieve the desired emission density of 600 tons per square mile per year
as an average for the industrial land-use use portion of each of the political sub-
divisions, emissions from  each of the primary sources must be reduced consider-
ably. Programs for limiting emissions from the burning  of coal, industrial pro-
cesses, and refuse disposal must be implemented. The control regulations proposed
herein are expected  to reduce the  emissions  to the allowable limits.


     Combustion of fuels - An estimated 38,500 tons of particulate matter from the
combustion  of coal was emitted in industrial  areas during 1963. A reduction in
coal combustion emissions to approximately  9,147 tons  per year is needed.  The
9,147 tons per year represents approximately 42 percent of the total allowable
emission for the industrial land-use category.  The remaining 58 percent would  be
emissions from industrial processes and refuse disposal.

     Various control plans and approaches to reduce  the emissions to within the
allowable limits were investigated. The control plan presented in  Figure 7 was
chosen as the most applicable to achieve the  desired emission reductions overall
and in each  of the political subdivisions.  The control of particulate emissions
according to curve No. 1 of Figure  7 is expected to reduce the emissions from the
combustion  of fuels from 39,224 tons per year to 9,871 tons per year, for an
overall  reduction of 75 percent.  Calculated emissions after control on a plant-
by-plant and boiler-by-boiler basis were based on estimated rated capacities
of boilers to determine the allowable emission rates and on annual fuel consumption
20

-------
to determine the yearly emissions.  The total annual emissions after reduction
could thus be determined on the total area as well as on political subdivisions. The
control equipment needed to achieve the emission limitations of  curve  No. 1 of
Figure 7 varies from simple mechanical collectors (cyclones and multicyclones)
with collection efficiencies of approximately 70 percent to electrostatic precipi-
tators with efficiencies of 96 percent. According to the equipment sizes in use
in the  Study area, most pulverized-coal units and spreader stokers would re-
quire electrostatic precipitators, whereas most of the other stokers could be
equipped with mechanical collectors.

     An exception was made for spreader stokers. A separate emission limitation
(curve No. 2 of Figure  7) permits the use of high-efficiency mechanical collectors
on spreader stokers up to 500  million Btu per hour rated capacity.  The main con-
sideration in adopting this special limitation was the reported high  cost of controll-
ing a relatively small percentage of total combustion emissions.  Because only
about 20 of these units  are in use at the present time, the net effect of  this exception
on the planned emissions  will increase the planned emission by some  600 tons per
year in the industrial land-use category and by much less in the commercial land-
use category.

     If spreader stokers continue to be  installed in built-up urban areas, methods to
control their emissions will have to be found so that limitations  comparable to those
placed on other types of equipment can also be achieved with spreader stokers.
Appointment of an officially constituted technical  committee is recommended to
study controlling the emissions from spreader stokers by using  curve  No. 1 as a
guide.  Two years should be sufficient time for this study.
   o.i
                                  100            1,000

                              TOTAL HEAT INPUT, 106 Btu/hr
10,000
100,000
Figure 7.  Maximum permissible emission of particulate matter from indirect-
          heating, fuel-burning installations in Interstate Air Pollution Study Area.
                                                                             21

-------
    Industrial processes - Since particulate emissions from industrial processes
contribute a considerable portion of total industrial emissions, reductions in pro-
cess emissions are also necessary. During 1963., an estimated 22,673 tons of
particulate matter was emitted to the air from the various industrial processes.  To
attain the desired emission densities for industrial land-use, a plan to  reduce the ex-
isting process emissions to approximately 5,000 or 6,000 tons per year for the
entire urbanized area is required.  Emissions from  industrial processes will then
constitute approximately 25 percent of total industrial  emissions.

    Various means and approaches were investigated for providing reduction of
process emissions.  The emission limitation table based on process weight that was
adopted in the San Francisco  Bay Area (Table 6) was found to be a practical and
adequate means of reaching the desired emission densities.  The applicability of
these emission limitations  was tested to the extent possible by considering each
plant and process individually.  For each major manufacturing process for which
production data were obtained by questionnaire, a process weight rate  in tons of
material per hour was computed and then translated  into allowable emission  rates
by the use of Table 6.  This procedure provided an estimate of the total process
loss emissions in the community after control.

    The adoption and full implementation of these emission limitations are expected
to result in the reduction of process emissions from 22,673 tons annually to approx-
imately 4,200, for an overall  reduction of 81 percent.  This is comparable to the 75
percent reduction needed for  emissions from fuel-burning installations.


    Essentially, these limitations require a reduction  of emissions of about 80
percent for small operations  and 95 percent or more for large operations. In a
few isolated cases the controls needed according  to the process weight table  may
be unduly strict if considered in terms of the total quantity of particulate matter
emitted from the plant.  In such instances,  a variance may be granted if it can be
shown that increases in emissions will not create nuisances or appreciably affect
the emission reduction plan.  Whenever variances are  granted, other emissions
must be more stringently controlled and limitations  placed on future expansion
in the area.

    An alternative method for determining the allowable emissions from individual
processes would be on the basis of potential or uncontrolled emissions. This
method would require that each manufacturer provide data on the quantity of  ma-
terial that would be emitted if no controls were employed. Such a method would
eliminate the two primary objections to the use of the process-weight table.  The
use of the process-weight table is  predicated on the  assumption that the quantity
of material used and not the type of material or process  determines the quantity
of material emitted. This, however, is not entirely true.  For a given  process-
weight rate, the uncontrolled  emissions may vary considerably.  The other objec-
tion to  the use of the process-weight table in  determining an allowable  emission rate
is the necessity for industries to divulge process data  that are considered proprie-
tary.  Both of these shortcomings would be overcome if a potential emission  in-
stead of process-weight scale were used.

    Industries should  therefore  be encouraged to develop capability in assessing
the types and quantities of pollutants emitted; and when data on potential emissions
become available,  emission limitations could be prescribed on a potential emission
22

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            Table 6. ALLOWABLE RATE OF EMISSION BASED ON
                          PROCESS WEIGHT RATEa
Process weight
rate,
Ib/hr
100
200
400
600
800
1,000
1,500
2,000
2,500
3,000
3,500
4,000
5,000
6,000
7,000
8,000
9,000
10,000
12,000
tons/hr
0.05
0.10
0.20
0.30
0.40
0.50
0.75
1.00
1.25
1.50
1.75
2.00
2.50
3.00
3.50
4.00
4.50
5.00
6.00
Rate of
emission,
Ib/hr
0.551
0.877
1.40
1.83
2.22
2.58
3.38
4.10
4.76
5.38
5.96
6.52
7.58
8.56
9.49
10.4
11.2
12.0
13.6
Process weight
rate
Ib/hr
16,000
18,000
20,000
30,000
40,000
50,000
60,000
70,000
80,000
90,000
100,000
120,000
140,000
160,000
200,000
1,000,000
2,000,000
6,000,000

tons/hr
8
9
10
15
20
25
30
35
40
45
50
60
70
80
100
500
1,000
3,000

Rate of
emission,
Ib/hr
16.5
17.9
19.2
25.2
30.5
35.4
40.0
41.3
42.5
43.6
44.6
46.3
47.8
49.0
51.2
69.0
77.6
92.7

     Interpolation of the data in this table for process weight rates up to
     60,000 Ib/hr shall be accomplished by use of the equation E = 4.10 pO-67?
     and interpolation and extrapolation of the data for process weight rates
     in excess of 60,000 Ib/hr shall be accomplished by use of the equation

        E =  55.0 pO-11 _ 40, where E  = rate  of emission in Ib/hr and

                   P = process weight rate in tons/hr.

scale.  Until such time, however, the use of the process-weight scale is the most
practical method of regulating the emissions from the many different processes
employed in the area. Whenever potential emission data become available, a  better
understanding of the hour-to-hour and day-to-day variations in emission rates will
ensue. It is, therefore, reasonable to expect that frequency distributions of emis-
sions similar to the ones used for air-quality will be formulated and emission limi-
tations based on maximum as well as  average emissions will be prescribed.  In
this  manner a closer control on the actual emissions, and thus the daily or even
hourly concentrations, can be achieved. Relating such emissions to the actual
land area a source occupies, and  setting emission limitations on the basis of  areas
and land-use mix rather than process-weight or volume of stack gases seems to be the
best method for insuring desired air-quality in all areas as well as the most  equi-
table means for apportioning the total allowable emissions to individual sources.
                                                                            23

-------
     Refuse disposal - An estimated 6,200 tons of particulates is emitted annually
 from the burning of refuse material in industrial areas.  Included in this total are
 the estimated emissions from all of the open-burning dumps and the municipal
 incinerators. Although only a portion of the waste burned in these dumps and
 incinerators originates with the area's industries, the general location of these
 dumps in the industrial land-use areas necessitates their inclusion in the indus-
 trial land-use category.

     Besides emitting some 5,000 tons of particulates per year, open-burning dumps
 precipitate complaints about smoke, reduced visibility, odors, and general  unsani-
 tary practices.  Regulations prohibiting open-burning in dumps have been enacted
 in all of the political jurisdictions included in the urbanized portion of the Study
 area.  To eliminate this source of air pollution, regulations prohibiting open-
 burning  must be strictly enforced.

     The municipal incinerators presently emit approximately 1,000 tons of partic-
 ulates per year.  If these emissions were controlled  to the recommended rate of
 0.2 grain per standard cubic foot, the annual particualte emissions would be reduced
 to approximately 670 tons per year.  If all refuse material presently being  burned
 openly in all land-use categories were  to be burned in municipal incinerators, total
 particulate emissions from refuse burning would decrease from approximately
 15,000 to 3,000 tons annually.


     Relatively small quantities  of refuse material are being disposed of by indus-
 trial incineration.  Particulate emissions from this operation during 1963 were
 estimated to be only 200 tons.  The recommendations  made relating to domestic
 incinerators should be extended to include all incinerators. Such regulations should
 require that all incinerators be  of the multiple-chamber design and that the emis-
 sions be limited to 0.2 or 0.3  grain per standard  cubic foot, depending on size.

    Implementation of the  recommended regulations  concerning the refuse  disposal
 is expected to reduce the refuse-disposal emissions in the  industrial areas from
 the presently estimated 6,200 to approximately 2,700 tons per year.

     Summary - Implementation of the recommended  emission limitations on the
 sources  of pollution included in  the industrial land-use category is expected to
 reduce the emissions of particulates from the present total of 68,023 tons per year
 to approximately 16,760 tons per year.   The resulting emission of 16,760 tons per
 year is within the  allowable emission for the entire area  and only slightly exceeded
 in one of the political subdivisions (Table 7).  A breakdown of industrial emissions
 by source category, showing both the existing and reduced emissions, is presented
 in Table 8.

Residential Land Use - Annually, 25,540 tons of particulates is emitted in the resi-
dential portions of the Study area. The primary sources are the combustion of
coal for  space heating and the open-burning of refuse  material. In areas where
these practices are common, the proposed allowable  emission density of  130  tons
per square mile per year is exceeded by as much as a factor of 5.  The average
emission density from the residential areas is approximately 170 tons per  square
mile, but is as high as 450 tons per square mile in the City of St. Louis.  Of the
450 tons  per square mile, 75 percent, or an equivalent of 388  tons per square mile,
is caused by the burning of coal and 21  percent by the open-burning of refuse.
24
                                                                    GPO 805-084-2

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          Table 7.  EXISTING, ALLOWABLE, AND PLANNED EMISSIONS OF
          PARTICULATES IN ST. LOUIS - EAST ST. LOUIS CENTRAL
                                 URBANIZED AREA
Subdivision

City of
St. Louis



St. Louis
County^



Madison
County d



St. Clair
Countyd



Central
urbanized
area

Land-use
category
Industrial
Residential
Commercial
Open space
Total
Industrial
Residential
Commercial
Open space
Total
Industrial
Residential
Commercial
Open space
Total
Industrial
Residential
Commercial
Open space
Total
Industrial
Residential
Commercial
Open space
Total
Land
area,
mi^
9.9
21.6
3.9
25.6
61.0
8.0
91.0
11.8
107.6
218.4
8.4
19.0
3.3
23.3
54.0
9.7
21.0
3.7
26.2
60.6
36.0
152.6
22.7
182.7
394.0
Particulate emissions, tons/yr
Existing
14,450
9,690
3,690
2,750
30,580
8,490
4,750
980
1,820
16,040
23,887
4,960
500
650
29,995
21,199
6,140
640
1,240
29,218
68,023
25,540
5,810
6,460
105,837
Allowable
5,940
2,810
680
2,560
11,990
4,800
11,830
2,065
10,760
29,455
5,040
2,470
578
2,330
10,418
5,820
2,730
650
2,620
11,820
21,600
19,840
3,973
18,270
63,683
Planned21
4,220
l,970b
700C
2,750
9,640
1,660
600b
2,050C
1,820
6,130
5,805e
540b
580C
650
7,575
3,575
l,570b
640C
1,240
8,405
16,760f
4,680b
3,970C
6,460
31,870
aEmissions from existing installations after reduction.
 Estimated 1975 emissions based on complete elimination of open burning and natural
decline in use of coal as heating fuel.
cArbitrary estimate.

 Data are from only the portion of the study area included with the 394-square-
mile central urbanized area of principal interest in the Study.

elncludes 5,200 tons per year from The Venice Power Plant.

^Includes a projected emission of 1,500 tons as a result of increased incineration
of waste (not  included in subtotals).
                                                                           25

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              Table 8. INDUSTRIAL PARTICULATE EMISSIONS
              IN ST. LOUIS - EAST ST. LOUIS CENTRAL
                            URBANIZED AREA

Fuel use
Coal
Fuel oil
Gas
Process emissions
Coffee processing
Sulfuric acid
Asphaltic concrete
Steel foundries
Gray iron foundries
Non ferrous foundries
Steel mills
Superphosphate mfg.
Coke plants
Cement plants
Grain industry
Other reported sources
Refuse disposal
Municipal incineration
Industrial incineration
Open burning dumps
Totals
Existing
emissions,
tons/yr
39,224
38,500
406
318
22,673
38
192
198
517
437
38
9,159
223
73
3,630
6,695
1,473
6,126
1,004
193
4,929
68,023
After
reduction
emissions,
tons/yr
9,871
9,147
406
318
4,196
34
192
128
295
140
38
2,056
60
73
360
67 Oa
150a
2,700
2,700
2,700
0
16,767
            aAssumed additional 90 percent efficiency.
26

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These data indicate that to achieve the desired emission density, emissions from
these two source categories must be reduced.

    Combustion of coal  - Emissions from a domestic space-heating unit burning
coal are equivalent to emissions from over 100 comparable units using gas or 30
units  burning fuel oil. In effect, one coal-burning unit requires as much air space
as 100 units heating with gas.

    The use of coal for  domestic needs has declined rapidly during the past 20
years (Figure 8), and emissions have been reduced accordingly.  If the present
trend continues, by 1975 the emissions from the burning of coal will reach an aver-
age density of approximately 100 tons per square mile in the City of St. Louis and
less overall.  This would be within acceptable limits.
         250,000
         200,000
     c/l
     <
     §   150,000
     o
         100,000
Q

U_
o

LJ

i
          50,000
                                                                  I II I  \
                              ST.  LOUIS CITY
                       ST. LOUIS COUNTY
                       ST. CLAIR COUNTY
                       MADISON COUNTY
              0 h i I I I I  I I I I I I I  I I I I I I  I I I I I I I  I I I I I I  I I I
                          1940
1950         1960

      YEAR
                                                        1970
1980
         Figure 8.  Domestic-heating use of coal in Interstate Study Area.
                                                                              27

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    Some of the 50,000 coal-heated dwelling units in the urbanized area are equipped
with hand-fired units.  In addition to contributing inordinate amounts of particulates
to the atmosphere, these units cause excessive smoke and odors.  Operating hand-
fired units without creating excessive smoke emissions is practically impossible.
Elimination of these units would eliminate the smoke and odor nuisances and acceler-
ate  the natural decline in the use of coal.  The incurred costs of converting to the use
of gas- or oil-fired central heating would be approximately $550 for gas and $650 for
fuel oil.  To convert from coal hand-fired room heaters to gas units would be about
$100.  Heating with gas instead of coal would be $23 per year cheaper. Heating with
fuel oil would cost only about $10 per year per dwelling more.  Heating with gas or
oil is  more convenient and cleaner, and provides much better temperature control
than heating with coal.  Elimination of hand-fired units is recommended and should
be carried out on a progressive and equitable  basis over a period  of approximately
3 years.  Each air pollution control agency  should devise a schedule so that one-
third  of all units are converted each year.   This could be done by  delineating zones
to the severity of the problem.

    Open burning of refuse -  The open burning of refuse is prevalent in all parts
of the urbanized area.  Besides  emitting almost 7,000 tons of particulates  annually,
open  burning releases excessive smoke, hydrocarbons, odors,  and undoubtedly
creates a fire hazard.  The burning of leaves, not included in the above estimate,
adds a considerable quantity of particulates to this total.

    The cities of St. Louis and  East St. Louis presently have regulations prohibit-
ing open burning of refuse.  Such regulations should be adopted throughout the
entire metropolitan area. To assure compliance with these regulations, a strict
enforcement program is required.  The collection of refuse from  the outlying
sparsely populated areas would create enforcement and collection problems  greater
than anticipated air pollution problems and  would be expensive; therefore outlying
areas of less than 100 dwelling units per square mile should be exempted from
open-burning restrictions.  To provide a workable basis for enforcement of this
type program, each air pollution control agency should designate the boundaries
by streets and roads of areas in which open-burning is prohibited.

    Incineration of refuse - The severity of smoke, odor, and particulate  matter
emitted during the incineration of refuse varies considerably and  depends  pri-
marily on the design and operation of the incinerator.  Stack tests have shown that
the emissions of particulate matter associated with incinerators of multiple-
chamber design are 4 to 10  times less than those from the single-chamber type.
To  reduce the particulate emissions in the community and minimize excessive
smoke and odors, it is recommended that only incinerators of multiple-chamber
design or of an equally effective design be allowed.  This provision will  require
that the single-chamber incinerators in use at present be eliminated or  converted
to multiple-chamber type. Five years should provide ample time for a complete
changeover.

    To insure that the incinerators are properly designed, built, and operated, an
additional requirement limiting the emissions of particulate matter to 0.3  grain per
standard cubic foot for installations burning less than 200 pounds  per hour and
0.2 grain per standard cubic foot for others should be included. A properly designed
and operated multiple-chamber incinerator in this size range can meet these
limitations without additional  air pollution control devices.
 28

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    Burning of Leaves - Although quantitative data are not available, the burning
of leaves during the fall months releases large quantities of particulates to the air,
causes excessive smoke that results in a drastic reduction in visibility, and is a
potential fire hazard. Until facilities for collecting and handling this refuse are
available, burning of leaves should be permitted only between 10 a.m. and 4 p.m.
when the atmospheric dilution capacity  is the greatest.


    A period of 5 years seems to be reasonable for developing a collection and
disposal capability that will accommodate all forms of domestic refuse. The above
recommended restrictions on domestic refuse disposal, while reducing the emis-
sions of particulates by more than 7,000 tons per year, will create a demand for
extending the collection coverage and for additional municipal refuse disposal
facilities.
     Summary - An estimated 25,500 tons of particulates is discharged annually
from residential land-use areas.  The elimination of all hand-fired units will reduce
this total; however, because of the lack of data concerning the number of these units
in use, a quantitative estimate cannot be made.  The natural decline in the domestic
use of coal is expected to reduce particulate emissions. Assuming that half of the
coal-burning units are converted to gas and  the other half to distillate fuel  oil, the
net reduction would be 10,800 tons per year by 1970 and 13,800 tons per year by
1975.
     The elimination of all open-burning of refuse is expected to decrease the par-
ticulate emissions by some 6,940 tons per year.  Since this quantity of refuse is
expected to be disposed of in municipal incinerators, the 6,940 tons per year may
be taken as the net reduction in the residential areas.


     The overall reduction in particulate emissions of 17,700 tons per year by the
year 1970 can be pxpected if the '  we recommendations are implemented and if
the present trend  ,  ay from the  ,u of coal for heating residences continues.  In
the City of St. Loui3, where the residential emission density is presently the high-
est at 450 tons per square mile per year, these actions would result in an estimated
emission density rf 145 tons per year by 1970 and slightly less than 100 tons per
square mile per year by 1975.   These estimates were based on the premise that the
existing residential land-use areas are already fully developed and occupied.
Increases in the population of the urbanized area can,  therefore, occur only in the
areas presently labeled as open space, and estimates of additional pollution sources
in the existing residential land-use areas need not be made.
Commercial Land-Use - During 1963 the emissions of particulate matter from
commercial land-use areas amounted to 5,800 tons, 95 percent of which was from
the combustion of coal. Because the emissions were from relatively small land
areas, the resultant emission densities exceed the allowable by a considerable
amount.  To achieve the desired emission limits, a reduction in emissions from the
combustion of coal is also needed in this  category.
                                                                             29

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    Elimination of all hand-fired furnaces is also recommended for commercial
establishments.  Although only a small number are in use, their elimination will
tend to reduce the numerous nuisance complaints arising from excessive smoke.
Because of the similarities among commercial, institutional, and industrial firing
equipment used, the same emission limitations (Figure 8) can be applied to these
installations. The lack of data concerning the types and sizes of the units in use
does not allow an estimate of the  quantities of particulates that would be emitted
after compliance with the regulations.  It is expected, however, that the reductions
in emissions will be sufficient to  reach the desired emission densities. Recommen-
dations  concerning the control of  emissions from refuse disposal made previously
for domestic and industrial units  should also cover all commercial on-site inciner-
ation and open-burning.

Open Space - As previously noted, open space includes  roads, parks, cemeteries,
vacant land, lakes, and rivers. The only emissions arising from these areas are
from automobiles, trucks, buses,  locomotives, and ships.  During 1963 an estimated
6,460 tons of particulates was emitted from these pollutant sources.  Assuming  that
24 percent of the St. Louis urbanized land area is taken up by roads, railway rights-
of-way,  and surface waters, the existing emission density would be approximately
70 tons  per square mile per year, which is within the preselected allowable density
of 100 tons per  square mile per year.
Impact of Proposed Regulations on Existing and New Emissions
    The existing, allowable, and planned particulate emissions summarized in
Table 7 show that the emission reduction plan provides for sufficient reductions
for the urbanized area as a whole as well as for each political subdivision.  Further-
more, sufficient reductions are also achieved for each of the land-use categories
except for the industrial land-use category in Madison County, which is a special
case to  be discussed in the next section. The difference between the allowable and
planned emissions in Table 7 is the quantity of particulate matter that can be added
to the air without exceeding the desired emission density.  An allowance of approx-
imately 20 percent of the planned emissions is provided for the City of St. Louis
and Counties of St. Clair and Madison.  The large difference observed for the St.
Louis County portion of the urbanized area allows for a considerable expansion,
provided that a proper distribution of sources is achieved.

    Increases in pollutant emissions in the industrial category, for instance, may
result from expansion of existing plants or addition of new  plants on the industrial
land-use areas.  An allowance for this expansion is included by providing the planned
emissions of lower magnitude than the allowable.

    The development of new lands in  the open-space category for industrial, com-
mercial, or residential purposes would increase the allowable emissions for these
categories and provide for less allowable emissions in the  open-space category.
This is  the primary reason for including an allowance of 100 tons per square mile
per year for the open-space category.  Since little pollution will emanate from open-
space, the allowable  emission density for certain areas is in reality higher than
100 tons per square mile.
30

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    The effect that the proposed reductions in emissions would have on air-quality
in certain presently heavily polluted areas  can be surmized from Figure 9. The
frequency distributions of concentrations recorded at one  sampling station in each
of the three political subdivisions, City of St. Louis,  Madison County, and St. Clair
County, were plotted and then reduced by the percent reduction in emissions ex-
pected to result from complete compliance  with the proposed regulations.  Accord-
ing to Figure 9 the City of St. Louis requires a reduction of 54 percent; Madison
county, 77 percent; and St. Clair County,  67 percent.  In all three cases a close
agreement between the air-quality goal and "resulting planned concentrations" has
been projected.  The technique employed  in formulating Figure 9 has been used in
other areas to calculate the reductions in emissions needed to meet the air-quality
goal.  The reductions indicated in Figure 9  are in general agreement with reduc-
tions determined by the methods used in developing the particulate air-use plan
for the St. Louis Study area. According to  results determined by methods used in
developing the air-use plan, the City of St.  Louis requires a reduction of 68 percent;
Madison County, 75  percent; and St. Clair County, 71 percent.
     O
     LU
     O
     z
     UJ
     D-
         1,000
          500
          200
          100
50
                                                    I   I   I    I  I
                                                         I  I
           10
            0.01
                                                   (EXISTING, JULY 1963-JULY 1964
                                                   AFTER REDUCTION
              1  2     10         50          90  95  98199  99.
                   % OF  SAMPLES Z STATED CONCENTRATION
     Figure 9.  Existing and projected 24-hour suspended particulate frequency
                distribution.
                                                                             31

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 Special Applications of Emission Reduction Plan

     As indicated previously, implementation of the reduction plan is expected to
 reduce emissions to the allowable levels for land-use categories and political
 subdivisions. Because of the presence of an extremely large source of pollution or
 a complex of sources in a small area, the resulting emissions may not be within
 the acceptable limits in the immediate area. In such situations, more stringent
 regulations than those previously proposed  may be needed to achieve the desired
 air-quality.  To assure that such problem areas are given the needed consideration,
 such areas should be considered individually.
     As a guide to locating such areas, the following recommendations are made.
 Any 2-mile-diameter area from which the emissions  of particulates, after the imple-
 mentation of the suggested controls, are greater than 2,000 tons per year should
 be considered as a potential problem area.  The emissions from all major sources
 in these areas should then be investigated and the  expected air-quality determined
 by the use of diffusion equations, with suitable allowance for factors such as
 expected life of  sources and cost of additional controls. If the investigation reveals
 that the air-quality goals will not be met, additional control should be prescribed.
 Such an evaluation should also be made for any proposed pollution source in these
 particular areas.

     A typical example is the area including the Venice Power Plant.  The emissions
 of particulates from the Venice  Power Plant, even after controlled to the limits
 specified in Figure 7, would be approximately 5,000 tons per year.  Preliminary
 diffusion calculations show that the emissions from this source could add as much
 as 100 micrograms per cubic meter in the downwind direction to the particulate
 loading from the other sources in the area (see calculations in Appendix A.).  In
 light of the air-quality goal  of 200 micrograms per cubic meter as the 99 percentile
 value, the emissions from this source could be using  about half of the dilution
 capacity of the air space within 2 or 3 miles and  therefore  should be further re-
 duced.  The controls specified by Figure 7 necessitate control equipment of approx-
 imately 96 percent efficiency; but an additional 2,500  tons of particulate could be
 removed by equipment with  an efficiency of  98 percent. Before additional controls
 are prescribed for the plant, a cost evaluation should be made and the expected life
 of this source should be determined.
     The control of emissions above those previously  specified from this and any
other source or  sources falling into this category  should be investigated jointly by
 the source operators and the respective air  pollution  control agency in an effort to
determine the manner in which the requirements of the air-use plan and clean air
may best be achieved.

 AIR-USE PLAN -  SULFUR DIOXIDE

     Sulfur dioxide is emitted primarily during the burning of sulfur-bearing fuels
and the manufacture of sulfuric acid.  The two basic approaches to reducing the
emissions of sulfur dioxide  from the burning of fuels are the removal of sulfur com-
pounds from the exit gases and the use of fuels with lower sulfur contents.  The
emissions from  sulfuric acid production may be reduced either by the removal of
sulfur dioxide from the  exit  gases or through the improvement of the conversion
efficiency of sulfur dioxide to useful products.  Methods for cleaning discharge
gases have recently been developed, and equipment is nearing the final stages of
development.  The use of lower sulfur fuels  can, however, be implemented sooner.
32

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Air-Quality Goals


     The recommended air-quality goals for sulfur oxides (measured as sulfur
dioxide) in the Study area are based on effects.  These goals specify that the annual
arithmetic mean concentration should not exceed 0.02 ppm and that the concentra-
tion of 0.1 ppm should not be exceeded on more than  1 percent of the  days in any
consecutive 100-day period. These  goals, based on the West-Gaeke method (or
other method giving comparable results) of analysis and a 24-hour sampling period,
should apply to any place where people live or where undesirable effects could occur
if the specified concentrations are exceeded.  For a complete discussion of air-
quality goals  and related criteria, see Volume VI of this report.


Design Period
     Since the air-quality goal at the 99 percentile is defined in terms of 100 con-
 secutive days, the reduction plan should be based on the season when sulfur dioxide
 concentrations are highest.  The application of the  emission reduction plan through-
 out the year would then result in approximating the desired air-quality during the
 worst season and provide lower pollutant concentrations during the other seasons.
 An alternative to this scheme would be to develop different emission limitations
 for each of the seasons. The approach used here is to design an emission reduction
 plan for the worst conditions and to approximate the degree to which these emission
 limitations could be relaxed during the other seasons.


    Although sulfur dioxide concentrations were recorded only during the 3 winter
months, certain inferences as to seasonal variation in sulfur dioxide concentrations
may be made by considering the seasonal variation of the sulfation rates,  the
amount of emissions, and the atmospheric dilution capacity.  During the winter
season, the emissions of sulfur oxides are the maximum (140% of the annual aver-
age), and the measured sulfation rate is highest (150% of the annual average).  The
meteorological conditions during the fall and winter seasons are generally more
conducive  to higher concentrations than during other times of the year.  The emis-
sions during the heating season (winter) are increased primarily from the residen-
tial and commercial sources, which because of their relatively low heights of
release have a more pronounced effect on ambient air concentrations. The winter
season was, therefore, selected as  the design period.

    The degree by which the proposed emission limitations could be relaxed during
other seasons can be  inferred from the  seasonal variation in emissions and sulfa-
tion rates. Assuming that the seasonal variation in emissions results in comparable
variation of sulfur dioxide concentrations in the  ambient air, the degree by which the
emission limitations may be relaxed during the other seasons may then be calcu-
lated.  Considering that the diffusion capacity is generally greater during the other
seasons, with the possible exception of fall, and  that the emissions during the non-
heating season are primarily from  industrial sources that discharge at much higher
elevations, these calculations would be on the conservative side.  Furthermore,  the
validity of this assumption, at least qualitatively, is supported by the observed sea-
sonal relationship between the sulfation rate and emissions.  The mean sulfation
                                                                            33

-------
rate for the winter season is 150 percent of the annual and for the summer months
is 74 percent of the annual.  The corresponding percent distribution of emissions
are 140 percent for the winter season and 75 percent for the summer.

    Using the seasonal variation in emission rates alone as the basis, the emission
limitations designed for the winter months could be reduced by factors of  1.6 for
spring and fall, and 2.0 for summer.  For a more workable plan, the time period
tor "winter" emission limitations may be extended to also include October, Novem-
ber, and March.  During the remaining 6 months the emissions could be doubled.

Relationship of Air-Quality Goals to Design Period Concentrations

     To allow the use of average concentrations and emission rates in subsequent
calculations relative to the design period, it  is necessary to express the 99 per-
centile air-quality goal in terms of a mean concentration.  On the basis of the ob-
served frequency distribution of 24-hour sulfur dioxide concentrations (for the
period December 1964 through February 1965) at 21 centrally located sampling
sites, a log-normal frequency distribution curve corresponding to 0.1 ppm at the
99 percentile and parallel to the average observed distributions was constructed
(Figure 10).  By this means a seasonal geometric mean concentration of 0.023 ppm
    Q-
    Q-
    C3
    <
    o:
    a:
    =>
    Q
    X
    o
    i—i
    O
    a:
1.00
0.80

0.60

0.40



0.20 —
 0.10
0.080

0.060

0.040
        0.020
        0.010
                                      ST. LOUIS,
                                  21  SELECTED STATIONS
                                                        AIR QUALITY GOAL   —
            0.01  0.1
                        10  20  30l40'506070 80   90  95  9899  99.8 .9 99.99

                     % OF SAMPLES 2 STATED CONCENTRATION
     Figure 10.  Geometric mean values of 24-hour sulfur dioxide frequency
                distribution - Dec. 1964 - Feb. 1965.
 34

-------
was obtained.  This concentration is in keeping with the presently observed ratios
of concentration at the 50 and 99 percentile points of the distribution.
    As indicated earlier, the annual mean goal recommended for the Study area has
been set at 0.02 ppm and relates to effects based on normal distribution of data. It
is well to differentiate between this goal and the seasonal value of 0.023 ppm,
geometric mean concentration, as related to a log-normal distribution.  On the basis
of a standard geometric deviation of 2.0, calculated from the observed distribution
of data, the seasonal geometric mean concentration would be equivalent to an arith-
metic seasonal mean concentration of 0.028  ppm. On the basis of the  highest season.
therefore, the goal for the annual arithmetic mean concentration is exceeded.  The
seasonal geometric mean of 0.023 ppm, however, relates to the 99 percentile goal
of 0.1 ppm in a statistical sense only and does not directly relate to the  emission
reduction program design. It is therefore a secondary rather  than a primary goal.
    Although the emission limitations are to be relaxed during the nonheating season,
other factors such as elevated release points, improved meteorological conditions,
and lack of low-level emissions from space-heating operations should result in
lower atmospheric concentrations of sulfur dioxide during this period as compared
with the heating season.  These lower concentrations during the nonheating season
should in turn aid in the attainment of both the 99 percentile goal of 0.1 ppm and the
annual arithmetic mean goal of 0.02 ppm in most portions of the Study area.  Al-
though both air-quality goals are  expected to be achieved by implementing the emis-
sion reduction plan,  24-hour sulfur dioxide concentrations for other than the winter
months should be measured both before  and after the various portions of the emis-
sion reduction plan are implemented. This will permit an evaluation of the seasonal
variations of ambient sulfur dioxide concentrations as well as the effect of the emis-
sion reductions on these concentrations.
Existing Concentrations
    Sulfur dioxide was measured at 20 locations during the period December 1963,
and January and February 1964 and at 40 locations during December 1964, and
January and February 1965.  The data collected during the winter of 1964-1965 were
selected as the basis for the reduction plan. The more complete coverage of the
area and the higher concentrations recorded  during this time period influenced
the selection.  The differences observed during the two sampling periods are
discussed in Volume III of this report.

    The geometric mean concentrations recorded at the 40 sampling sites during
the winter of 1964-1965 ranged from 0.015 ppm to 0.097 ppm.  The geometric mean
concentration for the area shown in Figure 2 weighted according to land areas was
approximately 0.034 ppm. Figures 11 and 12 show the isopleths of the geometric
mean and the 99 percentile concentrations,  respectively. As evidenced from the
isopleths in Figure 12, the air-quality goal of 0.1 ppm was exceeded at all of the
sampling sites.
                                                                            35

-------
                                     LEGEND
                                BOUNDARIES
                                  STATE
                                  COUNTY        	
                                HIGHWAY MARKERS
                                  FEDERAL       —Q
                                  STATE
    390  40
-------
                                                                                       — 820
                                                              ISOPLETHS OF 99 PERCENTILE VALUES
                                                              	LINES OF ACTUAL EQUAL VALUE
                                                              •	LINES OF PROBABLE EQUAL VALUE
      / EG END
BOUNDARIES
  STATE
  COUNTY          	
HIGHWAY MARKERS
  FEDERAL         —Q—
  STATE           —O—
                                                              40-STMIQN NETWORK-DECEMBER!,
                                                              1964 TO FEBRUARY 28,1965
390   400"°'  410  420   430  440   450  460   470   480   490   500W 510   520   530  540  550  560
 Figure 12.   Sulfur dioxide 99 percentile values for 24-hour  samples 1964-1965
               winter season (ppm).
                                                                                             37

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Existing Emissions

    Approximately 455,500 tons of sulfur oxides is released annually from the
various pollutant sources in the Study area.  A breakdown of these emissions by
source category is given in Table 9.  The primary source of sulfur oxides pollution
is the combustion of  sulfur-bear ing fuels.  More than 92 percent of the total emis-
sions may be attributed to this source category.  The combustion of coal, the pri-
mary producer of sulfur oxides, accounts for 403,000 tons of the emissions.  The
burning of distillate and residual fuel oil contributes 18,000 tons annually.  The
combustion of gas is insignificant as a source of sulfur oxides pollution.  The annual
quantities and the sulfur contents of the fuels burned in the Study area are summar-
ized in Table 10. The listed values represent the average for  each type and grade
of fuel.

    The 455,500 tons of sulfur oxides emissions comes from sources located in an
area of some 3,500 square miles.  If the emissions were  distributed evenly through-
out this area,  the resulting concentrations would undoubtedly be within acceptable
limits.  This,  however, is not the case.  Some 250,000 tons of emissions is released
in approximately 400 square miles of the highly urbanized portion of the Study area.
The emissions from  sources located in this urbanized portion  (see Figure 2) are
summarized in Table 11. Of the remaining sulfur oxides emissions, an estimated
137,000 tons is discharged from the Meramec Power Plant, which is some 10 miles
away from the outlying areas of the urbanized portion, and approximately  60,000
tons is released in the Alton - Wood  River area.  The emissions from these sources
affect the air-quality of the City of St. Louis and its immediately  surrounding area
only at times of specified meteorological conditions and thus cannot be considered

                 Table 9.  EMISSIONS OF SULFUR OXIDES IN
          INTERSTATE AIR POLLUTION STUDY AREA, 1963 - 1964
             Source category
Emissions,
  tons/yr
Percent of total
     Transportation:

         Road vehicles
         Other

     Combustion of fuels:

         Industry
         Steam-electric utilities
         Residential
         Commercial and institutional

     Refuse disposal

     Industrial process emissions

     Total
    4,400

    3,600
      800

  421,000

  113,000
  244,000
   50,000
   14,000

      500

   29,600

  455,500
       1.0
      92.3
       0.1

       6.6

     100.0
38

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                      Table 10.  COMBUSTION OF FUELS IN
             INTERSTATE AIR POLLUTION STUDY AREA, 1963-1964
                  Fuel
         Coal  (tons/yr)

             Belleville District
             Southern Illinois
             Miscellaneous

         Residual fuel oil
             (gal/yr in 1,000's)

         Distillate fuel oil
             (gal/yr in 1,000's)

         Gas (million cubic feet)
 Annual
quantity
burned
5,411,600
1,724,000
  250,000

  106,865
  135,233
  131,454
Percent sulfur
 by weighta
    3.3
    1.5
    3.0

    1.6
    0.4
    0.0008
         a As received.
 in the same manner as the emissions from the sources located in the area.  For
 the purposes of the following calculations, therefore, only the emissions within the
 area shown in Figure 2 and tabulated in Table 11 are considered.
Seasonal Distribution of Emissions - Since the emission reduction plan for sulfur
dioxide is based on the winter season, only the quantities of pollutants emitted
during this time period are considered.  The seasonal fluctuation in the  emissions
from the stationary combustion sources is considerable. The increased space-
heating requirements during the winter season increase the use of fuels and hence
the emission rates of pollutants.  The emission data by political subdivisions for
December, January, and February are presented in Table 12.  Approximately 36
percent of the industrial emissions of sulfur oxides occur during the winter season,
and almost 46 percent of the residential and commercial emissions can  be  attri-
buted to that period. The  data presented in Table 12 were based on the information
supplied in the questionnaires for the industrial category and estimated  on  degree-
day data for the domestic  and commercial categories.
Geographical Distribution of Emissions - The geographical distribution of pollutant
emissions is a determining factor in the resulting ambient concentrations of pol-
lutants. The estimated emissions per grid area presented in Figure 13 indicate
that the emissions are highest near the center of the urbanized area. It can also
be clearly seen that the emissions arising from a few of the grids are extremely
high.
                                                                            39

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                                               1  2060^113
                                         454215200,1,964,1385
 •'ST LOUIS  CO
                                                    TONS PER GRID AREA
                                                   APPROXIMATE LQCAIIW QF THE
                                                    TENJ.ARGEST EMITTERS OF
                                                    SULFUR OXIDES
                                             AREA OF GRID = 3.58 SQUARE MILES
                                        "ALLOWABLE EMISSION PER GRID" = 1,100 TONS
                                                      PER 3 MONTHS
   390   40(T 410   420  430  440  450  460   470   480  490  500°"  510  520   530  540  550  560  570

    Figure 13.  Sulfur oxides emissions per grid area during 3 winter months.


    A relatively small number of plants emit large quantities of sulfur oxides.  For
example, the ten largest emitters of sulfur oxides account for almost 50 percent of
the total emissions.  The approximate locations of these are also presented in
Figure 13.  The emission densities by type of land-use and political subdivision
are presented in Table 13.
42

-------
  Table 13.  DENSITY OF SULFUR OXIDE EMISSION BY TYPE OF LAND USE IN
  ST. LOUIS - EAST ST.  LOUIS CENTRAL URBANIZED AREA - WINTER 1963-1964
                                    (tons/mi2/3mo)
Land-use category
Residential
Commercial
Industrial
Open space
All areas
City of
St. Louis
390
1,050
1,450
20
450
St. Louis
County3-
50
100
1,150
5
70
St. Clair
County3-
240
190
1,400
5
340
Madison
County a
70
170
2,420
5
410
Entire
urbanized
area a
120
280
1,620
5
210
 a Data are from only the portion of the Study area included within the central
   unchanged area of principal interest in the Study.

Relationship of Emission Density and Air Quality
     Comparison of Figures 11 and 13, the air quality versus emission density,
shows that areas of high emission strengths coincide, for the most part, with those
of highest concentrations.  Determining a relationship between emission density and
the resulting mean ambient air concentrations should, therefore, be possible.  One
way is to relate the emission density with the mean concentration for considerable
areas - areas of at least 20 square miles.  For such areas, the net effect of pollu-
tant transfer in or out of the area is minimized and the relative concentrations are
primarily dependent upon the emissions originating in the particular area.  Another
method is to establish a relationship by relating the average concentration for a
relatively small area (3 to 4 square miles) with the emission density of that area
plus a portion of the emissions of a much larger surrounding area.  After an eval-
uation of both of these methods, the latter was selected for use in developing this
air-use plan.

     The relationship established between "the effective emission density" and
average air quality is presented in Figure 14.  This relationship was based on the
following simplifying assumptions:

     1. With the exception of a few pollutant sources, which will be mentioned later,
the average effective stack heights of pollution sources for any grid are relatively
uniform throughout the area.

     2. The average concentration of sulfur dioxide observed in any  one grid is
dependent primarily upon the emissions from this and the eight immediately sur-
rounding grids (total area of 32.2 square miles).
                                                                            43

-------
   0.08
 Q.
 0.
§  0.06
i—
z
LLl
(_>
•z.
O

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°  0.04
ce
=D
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   0.02
                  I I I I I I I I I  I I I I I I I I I  I I I I I I ! I I  I I I  I  I I I  I I I I I I I I I  I  I M   1
                                                                GRID 490-720^
            I I i I I I I I I I I I I I I ll I	I I I I I I I I I I ll I I I I I I I I ll I I I I I I I I III I I I I I I r
500       1,000      1,500      2,000      2,500

       EFFECTIVE EMISSION DENSITY, tons/mi2/3 mo
                                                                 3,000
                                                                           3,500
    Figure 14.  Relationship between sulfur dioxide concentrations and emission
               density in Dec. 1964 and Jan. and Feb. 1965.

    3. The average concentration in any grid is more strongly influenced by the
emissions within that particular grid than from the surrounding grids.

    4. The emissions in any one grid are uniformly distributed throughout the grid.

    5. The hourly and daily distributions of emissions are somewhat similar from
grid to grid.

    6. The meteorology and topography of the area are relatively uniform.


The mechanics of obtaining this relationship are briefly summarized below.


A 10,000-foot-square grid  cell (area = 3.58  square miles), as shown in Figure 2,
was selected as the basic unit area.  An average 24- hour sulfur dioxide concentra-
tion for each of the grids was obtained from the isopleth map shown in Figure 11.
An  average emission density was calculated for each grid cell.  For purposes of
relating the average sulfur dioxide concentration with the emission density, an
"effective emission density" based on the emissions from that particular grid
(central grid) and from the surrounding eight grids was calculated. The assump-
tion made is that the emissions originating more than 3 miles away will not usually
have a significant effect on the air-quality of the central grid. Furthermore, since
the emissions of the central grid have a more pronounced effect on the concentra-
tions  of that grid than from the surrounding eight grids, a weighting factor based on
relative distances was included.  The "effective emission density" was therefore
calculated as follows:
44

-------
     Effective emission density = 0.6 (emission density of central grid) + 0.4 (the
     average emission density of the eight surrounding grids).

As shown in Figure 14, a good correlation between concentration and "the effective
emission density" was found for  12 of the 16 grids considered.  As can be seen
from the location of the points, the remaining four show a higher emission density
for a given average concentration than that obtained by curve 1.  All of these four
grids contain large emission sources with considerably higher stacks than those in
other grids. That the relative stack heights are responsible for this deviation is
further  supported by the fact that the relative displacement of these four points
from the curve for "other grids" is in ascending order of the average stack heights,
i.e., the grid containing the Venice Power Plant with an effective stack height of
approximately 400 feet being the most displaced point. By reducing the emissions
(from the sources with higher stack heights) by a factor of Q/H^, the relationship
between the average  concentration and the effective emission density conforms to
that shown by the curve for the "other grids."

     This relationship is expressed in terms of an average 24-hour concentration
of sulfur dioxide and the total emissions during the 3 winter months.  This does not
seem compatible. It can  be used, however, if one considers that the total emissions
were distributed in some certain manner during the sampling period and that this
distribution of total emissions resulted in the observed concentrations.  Since the
distribution of emissions with time is not expected to change appreciably, the de-
sired emission density should result in approximately the desired air-quality.
 Allowable Emission Density


    From Figure 14, it is now possible to obtain an "effective emission density,"
which corresponds to the desired mean concentration of 0.023 ppm.  According to
Figure 14, the allowable emission density is approximately 300 tons per square
mile for the 3 winter months. Although the 300 tons per square mile is the allow-
able "effective emission density," as defined previously, it may be used as the
actual allowable density for each grid, because each grid in the area has at one
time been considered as the "central grid."  This value will be used for all grid
areas except those containing emission sources of considerably higher stacks than
the average of approximately  100 feet or less.  For these grids (the displaced
points), an allowable emission density may be theoretically obtained by extending
a line from the origin through these points and selecting an allowable emission den-
sity corresponding to an average sulfur dioxide concentration of 0.023 ppm.  Since
the line through the points calculated for grids 480-700 and 490-710 are relatively
close to the line for other grids, they will be considered in the same manner. The
allowable emission densities for the two grids are as follows:

              490-720                   1,650 tons per square mile
              490-700                     850 tons per square mile

The qualifying condition for particulates should also apply  in this case.  This con-
dition states that the allowable emission density of 300 tons total emission per
square mile will be emitted during the 3 winter months according to the same
                                                                             45

-------
hour-to-hour and day-to-day variation as that during the period when the sulfur
dioxide concentrations were measured, except in smaller magnitudes. The emis-
sion density of 300 tons per square mile represents the limiting density  for all
areas and land-uses.  On the basis of the same arguments as for particulates,
different emission densities are assigned to each land-use category.  These are
given in Table  14.


         Table 14.  ALLOWABLE SULFUR DIOXIDE EMISSION DENSITIES
           BY  LAND-USE CATEGORY IN ST. LOUIS - EAST ST. LOUIS
           CENTRAL URBANIZED AREA DURING 3 WINTER  MONTHS
            Land-use category
            Residential
            Commercial
            Industrial
            Open space
           All areas
Allowable emission density,
                                              tons/mi  /3 mo
            100
            250
            550
            235
            300
Emission Reduction Plan
    The allowable and existing emissions are summarized in Table 15.  Compari-
son of these two shows that a major reduction in sulfur oxides emissions must be
made if the desired ambient air concentrations are to be attained.  As in the report
section for particulates, the reductions needed for each land-use category are
considered individually.


Industrial Land  Use - The industrial sources of sulfur oxides emissions include
the combustion of coal, oil, and gas; certain processes (sulfuric acid manufacture);
and refuse disposal. Since the sulfur oxides emissions from refuse disposal and
the combustion of gas are negligible, the allowable industrial  emissions given in
Table  15 should be allocated among the combustion sources using coal and fuel
oil, and the plants emitting sulfur oxides from their processes.  The industrial
emissions of sulfur oxides for the 3 winter  months have been  estimated at 58,400
tons.  Although the entire industrial area consists of some 36 square miles, most
of these industrial emissions originate in two relatively small areas.  Approximately
16,000 tons is emitted from one source occupying a  small area,  and a total of
13,600 tons is released from a group of sources included in an area of less  than 4
square miles. The  remaining 28,800 tons of sulfur oxides is emitted from sources
distributed throughout the Study area.
46

-------
        Table 15. EXISTING, ALLOWABLE, AND PLANNED EMISSIONS OF
        SULFUR OXIDES IN ST. LOUIS - EAST ST. LOUIS CENTRAL
                  URBANIZED AREA FOR 3 WINTER MONTHS
Subdivision

City of
St. Louis



St. Louis
Countyd



St. Clair
Countyd



Madison
Countyd



Central
urbanized
area

Land- use
category
Industrial
Residential
Commercial
Open space
Total
Industrial
Residential
Commercial
Open space
Total
Industrial
Residential
Commercial
Open space
Total
Industrial
Residential
Commercial
Open space
Total
Industrial
Residential
Commercial
Open space
Total
Land
area, mi^
9.9
21.6
3.9
25.6
61.0
8.0
91.0
11.8
107.6
218.4
9.7
21.0
3.7
26.2
60.6
8.4
19.0
3.3
23.3
54.0
36.0
152.6
22.7
182.7
394.0
Sulfur oxide emissions, tons/mi^/3 mo
Existing
14,260
8,450
4,075
450
27,235
9,200
4,280
1,100
300
14,880
14,615
4,940
710
150
20,415
20,300
1,245
565
100
22,210
58,400
18,900
6,450
1,000
84,750
Allowable
7,695
2,160
975
6,016
16,846
4,400
9,100
2,950
25,286
41,736
7,135
2,100
925
6,157
16,317
5,610
1,900
825
5,475
13,810
24,840
15,260
5,675
42,934
88,709
Planneda
4,460
2,580b
975C
450
8,465
5,500
l,070b
1,100C
300
7,970
5,070
2,080b
710C
150
8,010
7,570
450b
565C
100
8,685
22,600
6,180b
3,350C
1,000
33,130
aE missions from existing installations after reduction.

bEstimated 1975 emissions based on complete elimination of open burning and
natural decline in use of coal as heating fuel.

cArbitrary estimate.
      are from only the portion of the Study area included within the central
urbanized area of principal interest in the Study.
                                                                           47

-------
    For purposes of calculating emission limitations, the two grid cells of high
emissions are considered individually and separately from the rest of the area.
Both cells were assumed to be entirely  industrial for the following reasons.  The
emission rates  of sulfur oxides from these areas are extremely large, the eleva-
tions at which emissions are discharged are much higher than the average, and
land-use data for small areas were not  available.  The estimated average stack
heights are  rough approximations, and only their order of magnitude is  of signifi-
cance.  The "planned emissions" refer to the emissions resulting from  the control
of combustion sources according to the  allowable emission rate  given in terms of
pounds of sulfur oxides per million Btu  heat input, and for industrial process
sources according to the proposed emission limitations.  The  allowable emissions
were calculated on the following emission densities; 1,650 tons per square mile
for grid 490-720, 850 tons per square mile for grid 490-700, and 550  tons per
square mile for the other industrial areas considered collectively.  As shown in
Table 16, the planned emissions for the  industrial areas considered collectively
are less than the allowable. This difference is the amount allowable for future
increase in  emissions.
    As noted previously, the planned emissions from sulfuric acid manufacturing
processes were calculated on the basis of 30 pounds of sulfur oxides per ton of
acid produced. This corresponds to a conversion efficiency from sulfur dioxide to
sulfur trioxide of approximately 97.5 percent, which is attainable with the processes
in use. The  existing emission rates of sulfur oxides were calculated on the basis
of 45 pounds per ton of acid produced.
    The planned emissions from the combustion of coal and fuel oil were deter-
mined from the existing quantities of fuels burned.  Allowable emission rates
selected were 2.3 pounds of sulfur oxides per million Btu heat input for the indus-
trial areas considered collectively and approximately 1.4 pounds and 0.7 pound
respectively, for the individually considered grids.  The  emission rate corres-
ponding to 2.3 pounds per million Btu heat input is equivalent to burning coal con-
taining 1.4 percent sulfur and fuel oil containing 2.0 percent sulfur. In the absence
of sulfur dioxide removal systems, these are the recommended limitations on the
types of fuels to be allowed in the area. The 1.4 percent sulfur content for coal
was calculated on an as-received basis using the average heating value of 11,300
Btu per pound.  Assuming that the average moisture content of coal is approximately
10 percent by weight, the allowable sulfur content in coal if analyzed on a dry basis
would be approximately 1.6 percent.
    The above limitations refer only to the sources included in the general category
and not to the major sources in the two previously mentioned grids.  For the major
sources located in these two areas, specific calculations relating to emission limi-
tations are needed.  Factors such as stack heights, diffusion characteristics, ex-
pected life of sources, and costs  should be considered in these calculations.  Cal-
culations for one area have been  made and used in program development activities.
48

-------
s
-4-i
O ^ T-H
CW
0}
i-H
nissions,
no
le Planned
£co|
o; w £
o "^
Sulfur
Existing
•O ... -M-
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.§ S3 5
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CO c
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1— 1 CO ,—c CO r-t CO
O 


-------
           250
           200
       CD

       C

       3
           150
           100
      O

      OO
            50
                             COAL  (3.3% SULFUR)
                                                                 FUEL  :
                                                                 OIL  ;
                                                           (0.4% SULFUR)'
                                                                   GAS -
                       2,000       4,000       6,000       8,000

                             DWELLING UNITS PER SQUARE MILE
10,000
   Figure 15.  Sulfur oxide emissions from burning of coal, fuel oil, and gas in
               residential heating units.

Residential Land Use - An allowable emission density of 100 tons per square mile
for the 3 winter months has been previously selected. As shown in Figure 15, this
would correspond to the emissions expected from 1-square-mile areas occupied by
500 dwelling units using coal, 6,700 using 0.4 percent sulfur distillate fuel oil, or
an unlimited number using gas. According to the existing population densities, only
the most populated areas would exceed the density requirements if all dwelling
units used oil.

     The existing emission densities for residential areas range from an average of
50 tons per square mile in St. Louis County to an average of 390 tons per square
mile  in St. Louis City. The residential emissions are highest in areas where coal
is used. If this decline in the use of coal continues, the expected emissions from
residential sources in 1975 would be as shown in Table  15.  A comparable reduction
in emissions can be achieved sooner if the sulfur content of the fuels is lowered to
the limits specified for industrial installations.  A sizeable reduction in residential
emissions is expected to have a more pronounced effect on the reduction of the
ambient air concentrations of sulfur dioxide than comparable reductions in other
50

-------
 source categories.  This is primarily due to the proximity of the source to the
 receptor, the wide geographical distribution of sources, and the  generally low
 elevations of emission discharge points.  Because of the significant influence of
 residential emissions on sulfur dioxide ambient  air concentrations, especially in
 areas where people live, fuel limitations proposed for industrial sources are rec-
 ommended for the fuels burned in households. This change would improve air-
 quality sooner than could be expected from the natural decline in the use of coal.

 Commercial Land Use - An allowable  emission  density of 250 tons per  square  mile
 was selected for the commercial land-use areas. Presently, an estimated 6,450
 tons of sulfur oxides is released from  the commercial areas, and on this basis an
 average reduction of slightly less than 20 percent is needed.  An average reduction
 basis, however, is misleading because most of these emissions come from areas
 in the City of St. Louis, where an average reduction of 76  percent is needed.

     Because very little information on the sizes of combustion equipment in the
 commercial sources is available, estimating the control measures needed to  reduce
 the emissions is difficult. It is suggested that the limitations prescribed for  in-
 dustrial and residential sources be extended to include the commercial  establish-
 ments so that the needed reductions can be achieved.

Open Space - An allowable emission density of 235 tons per square mile  has been
proposed for unused land and road space collectively.  The existing emissions from
this land-use category include only the  pollution arising from transportation sources,
which do not emit  much sulfur dioxide.

    As pointed out earlier, a rather high allowable emission density was assigned
to this land-use category to provide a safety factor for future expansion. An allow-
able emission density of approximately 300 tons per square mile  has  been provided
in the event that half of the open space is eventually developed.

Summary - Presently an estimated 84,750 tons of sulfur oxides is emitted to the air
during the 3 winter months. According to the  emission reduction plan, these emis-
sions will be reduced to approximately  33,130 tons for an overall reduction of
approximately 61 percent.  The plan calls for  reductions in all of the  major source
categories and in all of the land-uses.   The added dilution provided emissions  from
high elevated sources was considered by allowing such sources to emit considerably
larger quantities.

    If the industrial sources were controlled according to  the emission limitations
specified, a reduction to 48,950 tons of  sulfur oxide emissions during the winter
season would result.  This reflects only the decrease in existing emissions without
adding emissions for new sources in the area.  Of this reduction,  the  major decrease
in emissions would need to take place in the stationary combustion sources using
coal.  Although a quantitative estimate of the impact of the  emission reduction plan
upon emissions from commercial areas cannot be made, the measures prescribed
would presumably  be sufficient to reduce the emissions within the allowable limits.
In the residential category the emission reduction resulting from both the decline
in the use of coal and the burning of coal of lower sulfur content is expected to re-
duce the emissions by approximately 12,720 tons  during the winter season.  As
shown in Table 15, the proposed controls are expected to result within the allowable
emission limits.
                                                                            51

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    Another method that has been used elsewhere for determining the reductions
in emissions needed to attain the desired air-quality is predicated on the assump-
tion that the emissions should be reduced by the percentage that the air-quality
goal is exceeded by present concentrations in the worst area. Using this method
of calculating the percent reduction needed in sulfur oxides emissions results in
an overall emission reduction of 76 percent. As would be expected, this is somewhat
higher than the 61 percent obtained through the methodology used here.

Recommendations For Control Regulations  - In the preceeding subsections reduc-
tions in sulfur oxides emissions are determined to meet the allowable emission
densities in each of the four  major land-use categories and each political subdivi-
sion.   The ways in which these reductions should or  can be  achieved depend pri-
marily on the available technology and are dictated,  at least in part, by various
socioeconomic factors. Wherever possible, however, these have been considered
in the drafting of the recommendations relating to the control of sulfur oxides
emissions.

    In the interests of attaining the air-quality goals for sulfur dioxide as soon as
possible, the following recommendations concerning the use of sulfur-bearing fuels
and regulation of emissions of sulfur oxides are made. Since, however, the estab-
lished fuel-use patterns cannot be changed immediately, the achievement of the
desired emission  levels is expected to occur through a series of steps that may
require 5 to 10 years for full implementation.

    Washing of Coal - An indirect means of reducing the sulfur oxides in stack
exit gases is to reduce the sulfur content of the fuels burned. A certain portion of
the sulfur present in coals may be removed by washing the coal. The City of
St. Louis presently requires washing of all coal of 2 percent sulfur  or more or 12
percent ash or more.  The effectiveness of removing sulfur by washing depends on
the quantity of pyritic sulfur in the coal and on the washing techniques used. The
coals used  in the St. Louis area for  the  most part contain 2 percent or more of
organic sulfur, which  cannot be removed by any washing techniques. Although
washing the coal will not  reduce the sulfur dioxide emissions from the organic
portion of the sulfur in coal, it will reduce the emissions from pyritic sulfur and
 should therefore be continued.

    Emissions of Sulfur Oxides from Industrial Processes - Wherever improved
efficiency of existing plant operations will reduce sulfur oxides emissions, such
improvement should be made, especially if the emissions add  appreciably to the
existing ambient air concentrations where people live.

    Emissions of Sulfur Oxides from Fuel-Burning Installations of Rated Plant
Capacities of Less Than 2,000 Million Btu Per Hour -  As noted previously, achiev-
ing the allowable emission rate of 2.3 pounds of sulfur  oxides  per million Btu heat
input places a limitation on the sulfur content of the fuels used.  For coal, this has
been calculated as 1.4 percent (as-received basis) and  for fuel oil as 1.6 percent.
As a first step in sulfur oxides reduction, these fuel  limitations are  proposed only
for the heating season.

    The schedule for implementing the  sulfur oxides allowable emission rates de-
pends upon the time necessary to develop the capabilities to supply the required
quantity of 1.4 percent sulfur coal, which may require opening new mines.  In a
52

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provision for a suggested-ordinance the burning of low-sulfur coal is urged within
2 years after the enactment of the ordinance.  If a gradual transition to the use of
low-sulfur coal is advantageous, the complete transition could be effected over a
3-year period.  In this event,  the burning of low-sulfur coal should be started ini-
tially during the months of December and January when the sulfur dioxide levels
are the  highest and then subsequently extended to include the other 4 space-heating
months.

    An  estimated 1,400,000 tons of low-sulfur coal per year is needed.  This is the
quantity of high-sulfur coal presently burned in the urbanized area (Figure 2) during
the 6-month heating season by the industries, households, and commercial estab-
lishments.  This  amount is only 20 percent of the annual consumption of coal in the
Study area.

    According to the U.S. Bureau of Mines 1  and the Illinois State Geological
Survey, 2  coals of low enough sulfur content required to  meet the sulfur content
requirements could probably be supplied from the Illinois coal fields. On the basis
of average costs  supplied by the U. S.  Bureau of Mines, an increase of 25 percent
in the cost for  coal with a sulfur  content of less than 1.5 percent can be  expected.
Since an estimated 1,400,000 tons of low-sulfur coal is needed annually, the total
cost to  the community is estimated at $1.9 million per year.  If sulfur content is
limited to 2 percent and the availability of coal increases, the additional cost would
be an estimated $1.3 million per year.  Whereas the use of coals containing 1.5
percent sulfur  is expected to  result in reaching the 0.1 ppm air-quality goal, the
use of coal containing 2 percent sulfur is projected to result in a 99 percentile con-
centration of 0.12 ppm over a considerable part of the central urbanized area.  This
concentration is  above the air-quality goals; therefore, in making a decision on
fuel requirements, the effect on air-quality should be  considered as should the pos-
sibility of reaching the goals in more than one step. The above calculations relat-
ing to air-quality levels were made on the assumption that the emissions from
steam-electric power plants are controlled to the required limits. If low-sulfur
coal is  not available in Illinois, and must be obtained elsewhere, additional shipping
costs would increase the cost of coal.  Whether this coal is to be supplied from the
Illinois coal fields or elsewhere is primarily a question of availability and econom-
ics, which can best be resolved through channels other than those available to the
Interstate Air Pollution Study Project Executive Committee.

     Although this suggested regulation requires only a partial change to lower
sulfur coals, the needed alterations can,  however,  have long-range implications
requiring concentrated and combined efforts to reach the most feasible  way to
supply the needed quantities of low-sulfur coals.  To assure that the air-quality
goals for sulfur dioxide are reached as soon as possible, an annual reevaluation of
the factors involved by means of hearings is recommended. Such hearings would
initially serve to inform the public of the progress made in developing the resources
of low-sulfur coals and to evaluate the effectiveness of the reductions in emissions
achieved through the use of the various control measures.


     Emissions of Sulfur Oxides from  Fuel-Burning Installations of Rated Plant
Capacities of 2,000 Million Btu Per Hour or More  - More than half of the sulfur
oxides,  235,000 tons per year, and 22,400 tons per year of particulates origin-
ate from steam-electric utility plants. Atmospheric diffusion of these pollutants is
                                                                               53

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influenced considerably by high stacks as well as topography and probably heat-is-
land effects. The numerous alternatives for handling these emissions involve fac-
tors beyond the authority and technical scope of the Project Executive Committee.
This report, therefore, in an ordinance provision, suggests inclusion of a time dead
line for limiting emissions  from steam-electric  utilities.  To assure action, the
formation of an officially constituted committee to  prepare an emission reduction
plan for this type of air pollutant source is recommended.  The plan should consider
at least particulates, sulfur oxides,  and nitrogen oxides.  It should consider any
steam-electric utility plant that may contribute pollutants to the Study area.   The
committee would be composed of individuals representing the following: steam-
electric utilities, universities, industrial science, weather bureau, and the public,
with an elected public official as a member ex-officio.  The group would select its
own chairman, obtain reports and consultant help as needed, and present within a
2-year period  after appointment, a plan indicating alternatives, costs, and time
schedules to reach air-quality goals.
AIR-USE PLAN - HYDROCARBONS


    Hydrocarbons are discharged to the air from a variety of sources, but the
most important sources are gasoline-powered vehicles and burning of refuse ma-
terial. In 1963, an estimated 373,900 tons of total hydrocarbons was discharged to
the air of the St. Louis Metropolitan Area. Of this total, 63 percent was attributed
to the automobile and 22 percent to the burning of refuse material. Evaporation of
solvents  contributes 10 percent, industrial process losses, 3 percent and the com-
bustion of fuels, 1.7 percent.

    The  reactive type of hydrocarbon, is one  of the precursors of oxidants and con-
sequently photochemical smog.  This property of hydrocarbons is of primary con-
cern and requires that means for reducing hydrocarbon emissions be developed
and implemented.  The automobile and refuse disposal are closely linked to the
needs of  inhabitants and are therefore expected to increase as population growth
continues.  Vehicle gasoline consumption in the Study area is expected to double by
1980.   Refuse material generated is expected  to increase at a rate comparable to the
population increase, with an expected increase of almost 40 percent by 1980.  In-
creases in the  emissions from  the other source categories will undoubtedly follow
the population increase.
Air-Quality Goals
     Air-quality goals, as such,  are not prescribed for hydrocarbons.  As noted pre-
viously, it is primarily total oxidant in the atmosphere that causes harmful effects
and is of primary concern.  The air-quality goal for total oxidant of 0.15 ppm
(potassium iodide colorimetric  method of measurement) has been suggested as the
maximum permissible 1-hour average concentration.  The effects of oxidant levels
above 0.15 ppm on visibility, eye irritation, and vegetation damage are discussed
in detail in Volume VI of this report.
54

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Existing Concentrations


     Total oxidant in the air was measured at nine Study sites from May through
October 1964.  The method of measurement was the phenolphthalein method, which
gives results approximately twice as high as those with the potassium iodide
colorimetric method.  In addition, since March 1964 total oxidant has been monitor-
ed continuously at the Continuous Air Monitoring Program (CAMP) station. Data
obtained at the nine sites indicated that the smog odor level of 0.15 ppm was ex-
ceeded 4 percent of the time,  and the eye irritation level of 0.25 ppm  was exceeded
1  percent of the time. The highest concentration observed during this sampling
period was 0.30 ppm  at site 449-719, about 2 miles west of the city limits of St.
Louis.  The maximum monthly average during this sampling period was 0.06 ppm
in July 1964.
    At the CAMP station,  the  monthly mean concentrations varied from 0.013 ppm
in December 1964 to 0.04 ppm in May 1964.  A maximum 24-hour average concen-
tration of 0.07 ppm was measured several times in April, June, and July.  The max-
imum 1-hour concentration observed was 0.26 ppm in July.

     Comparison of the observed concentrations of total oxidant in the air with the
air-quality goal of 0.15 ppm as the maximum permissible 1-hour concentration
shows that the  air-quality goal is exceeded 4 percent of the time during the sum-
mer months.  Similarly, the maximum 1-hour average concentration for each
month, except May 1965, was higher than 0.15 ppm.  Using the nine-station network
measurements  as representative of the  existing oxidant levels, a reduction in
oxidant levels by approximately a factor of 2 may be needed to reach the air-quality
goal.
Existing and Projected^ Emissions


Emissions of Hydrocarbons From Transportation Sources - In 1963, an estimated
236,000 tons of total hydrocarbons was released by all transportation sources in
the area.  The hydrocarbon emissions from gasoline-powered vehicles in 1963 were
estimated at 239,800 tons.   The importance of aircraft, vessels, and diesel-powered
vehicles as a source of hydrocarbons is relatively minor (2  percent) and for the
purpose jf this discussion will be assumed to be insignificant.

    Gasoline Consumption - Existing and Projected - In 1963, approximately 759
million gallons of gasoline was burned in the Study area. Gasoline consumption in
the Study Area is expected to increase  to 1.4 billion gallons  per year by 1980. In
accordance with the national trend,the 1980 figure will be doubled again by 2000.
The rate of increase in gasoline consumption far outweighs the growth in popula-
tion, which has been projected as approximately 43 percent between 1960 and 1980.
The ever-increasing number of vehicles per family and the increasing distances of
travel in urban areas are  expected to produce the anticipated increase in gasoline
consumption.  Projections of gasoline consumption for the Study area are shown in
Figure 16.   A considerable reduction in the projected consumption rate would un-
doubtedly result if an extensive mass transit system is implemented or a radical
change in the mode of travel comes into effect.
                                                                             55

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            u
            1,400
            1,200
        Ol
        c
        o
       o
       I—
       Q.
            1 ,000
             800
       o
       GO
       <
       o
             600
             400
                  M I  I I I I
                           I  i i i i I M i i I i i i i I i i i i I M i i I i i i n
                    1955
1965
1975
1985
                                      YEAR
    Figure 16.  Projected gasoline consumption in Interstate Study Area.

     Emissions of Hydrocarbons - The emissions of total hydrocarbons, if uncon-
 trolled, would increase proportionately with gasoline consumption and would reach
 an annual emission of 472,000 tons in 1980.  This is an increase of 100 percent
 over the estimated 1963 emissions.  The impact this increase  on deterioration of
 the air-quality in the central part of the urbanized area will be even more signifi-
 cant since most of the emissions from motor vehicles occur in this limited area.
    The effect that the various reduction devices, presently proposed for installa-
tion on new vehicles, would have on the emissions of total hydrocarbons in the Study
56
                                                                     GPO B05-OS4-3

-------
            250 p
       o
       E
            200
            150
       o
       t—t
       GO
       £    100
             50
                 CONTROL DEVICES  ON
                 NEW AUTOMOBILES
A -
B -
C -
D -
E -
                    BLOWBY DEVICE
                    EXHAUST CONTROL (275 ppm)
                    EXHAUST CONTROL (180 ppm)
                    FUEL TANK EVAPORATION CONTROL
                    CARBURETOR EVAPORATION CONTROL
             1950
        1960
1970
1980
1990
2000
                                         YEAR
 Figure 17.  Projected hydrocarbon emissions from gasoline-powered motor
             vehicles - without control and with various combinations of control.

area are shown in Figure 17, 18, and 19 and are discussed below.  Included are all
reduction measures and devices ranging from those in use at the present to those
expected to be developed in the years to come. For the latter it has been necessary
to estimate the reduction efficiencies expected to result from the various control
devices.

    The  existing and anticipated control devices, their efficiencies in removing
total hydrocarbons, and the year they are expected to be in use  are summarized in
Table 17.  The emission rates presented in Table 17 represent  the emissions under
average urban driving conditions.

    As shown in Table  17, five individual control measures have been assumed,
with the year of implementation ranging from 1963 to 1971.  Starting with the 1963
models, all gasoline-powered vehicles are equipped with a crankcase blowby con-
trol device. This device reduces crankcase emissions 85 percent by venting the
piston blowby gases from the crankcase back into the intake manifold of the com-
bustion chambers.  The blowby device costs $5.00 to $10.00 factory installed and
                                                                             57

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   400,000
   300,000
c
o
o
co
a:

3
0£
O
   200,000
o

to
   100,000
                                                                 TRANSPORTATION
                                                                 SOLVENT  EVAPORATION  -
                                                                INDUSTRIAL  PROCESS    I

                                                                     COMBUSTION SOURCESJ

                                                        l7 |  | |" |  REFUSE .DISPOSAL | |  | | r
0

1950         1960         1970         1980          1990         2000

                                YEAR
            Figure 18.  Projected total hydrocarbon emissions - plan I.
58

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400,000
J | I I  | I I I I  I I I I  I I I I  I I | I I  I I I I  I I I |  I I I I  I I I I I  | I I I  I I I I  I l| I I  I I I I  I I I |  I '{-
      1950
                                                             TOTAL
                                                             TRANSPORTATION

                                                             SOLVENT  EVAPORATION
                                                            INDUSTRIAL PROCESS  LOSSES-
                                                       STATIONARY COMBUSTION  SOURCES -
                                                        +-I-M REFUSE,DISPOSAL | | i i  I i r
          1960
1970
1980
                                               1990
                                                                  2000
                                    YEAR
          Figure 19.   Projected total hydrocarbon emissions - plan II.
                                                                                   59

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            Table 17.  EMISSION RATE OF HYDROCARBONS
                          (Ib/automobile/day)
Source of emission
Exhaust
Crankcase
Evaporation
Fuel tank
Carburetor
Total
% of 1962
Year
1962a
0.363
0.216
0.068
0.091
0.738
100.0
1963b
0.363
0.032
0.068
0.091
0.554
75.1
1968C
0.073
0
0.068
0.091
0.232
31.4
1971d>e
0.048
0
0.014
0.018
0.080
10.8
 a Values for 1962 are based on experimental data measured at 25 mph for
   a typical cycle, taken from: Rose, A. Summary Report of Vehicular
   Emissions and Their Control.  Presented at ASME Meeting, Chicago, 111.

 " In 1963, blowby devices installed on all new cars, assumed to be 85% effective.

 c A control device limiting exhaust emissions to 275 ppm to be installed on
   all 1968 cars. Starting with 1968 models, the blowby device assumed 100
   percent effective.

 ^ A control device limiting exhaust emissions to 180 ppm installed on all
   1971 models.

 e Reduce fuel tank and carburetor emissions by 80% on 1971  model cars.

$12 to $25 when  added to a used vehicle.  The overall reduction of hydrocarbon
emissions from a motor vehicle equipped with this device is approximately 25 per-
cent.

    The passage of Federal Law S-306 in 1965 authorized the Secretary of Health,
Education,  and Welfare to  set limitations on  air pollutant emissions from motor
vehicles. The specified regulations require  the complete elimination of crankcase
emissions and limit the hydrocarbon emissions  in the exhaust  to 275  ppm (measured
as hexane).  These limitations will go in effect starting with the 1968 models.

    The uncontrolled concentration of hydrocarbons in the exhaust gases are of the
order of 1,365 ppm under the average urban driving conditions. There are several
means available to achieve the desired emission rate.  The control costs vary
accordingly,  but an average cost of approximately $50 per unit is  probably a reason-
able estimate. The overall reduction in emissions from motor vehicles equipped
60

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with exhaust as well as 100 percent effective blowby control devices is expected to
be approximately 69 percent.

    Assuming that a requirement for additional reduction in hydrocarbon emissions
in the exhaust gases to 180 ppm, as required in the State of  California, is adopted
nationwide and implemented starting with the 1971 models, a reduction of 72 percent
of the uncontrolled hydrocarbon emissions would result.

    Further reductions in hydrocarbon emissions  from the  evaporation from the
fuel tank and carburetor  have been assumed to be implemented starting with the
1971 models.  This reduction is assumed to result from controlling the evaporation
losses from the fuel tank and carburetor by approximately 80 percent.  The assumed
effectiveness of these reductions  was  based on work  and requirements of the
State of California. The  implementation of these control measures would result in
an overall reduction of emissions per equipped vehicle of approximately 89 percent.

    The percent reductions achievable by the various control measures and the
data given in Table 17 refer to  the emission rates  of hydrocarbons from vehicles
equipped with these control devices. These data coupled with projected gasoline
consumption (Figure 16)  and information on retirement schedule of automobiles,3
were used to project the emission- of hydrocarbons in the St. Louis Metropolitan
Area.  These projections were  based on two additional assumptions, (1) only new cars
are equipped with the control devices and (2) the efficiency of control devices re-
mains  unchanged through the life of the vehicle.  It is  expected, however, that rou-
tine inspections will be needed  to maintain the efficiencies of these devices within
the specified limits.

     Figure 17 shows the percent reduction achievable by the various control means.
The emissions are expressed as percent of  the 1963 hydrocarbon emissions.  The
curves reflecting the effect of the various control means are, as plotted in Figure
17, based on the assumption that all the intermediate  measures have been imple-
mented at the time specified in Table 17.  It is evident that controls other than  the
blowby device are needed to reduce the hydrocarbon emissions below the 1963
emissions.

     The reduction in emissions achieved by the use of the blowby device (in use
since 1963) and the exhaust  control to 275 ppm (starting with 1968) can be consid-
ered as relatively accurate  estimates.  The other  reductions are only in the spec-
ulative stage and should  be interpreted as rough approximations.

Emissions of Hydrocarbons From Refuse Disposal - An estimated 1,328,600 tons
of combustible refuse material was generated in the Study area during 1963.  A
breakdown by the modes of disposal used and the quantities  of hydrocarbons re-
leased are presented in Table 18.  In 1963, approximately 45 percent of the com-
bustible  refuse generated was burned at dumps and on-site.  These modes of dis-
posal accounted for 84,300 tons of hydrocarbons, or 99.5 percent of the  total, re-
leased by refuse disposal.


    Generation and disposal of  combustible  refuse  - Assuming that the present
average of 3.4 pounds of  combustible refuse material  per capita per day remains
unchanged, the quantity of refuse material generated in 1980 would be approximately
1,835,000 tons. At present onlv about 20 percent of the combustible refuse is being
                                                                           61

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 Table 18.  EMISSIONS OF HYDROCARBONS FROM REFUSE DISPOSAL IN 1963
                 INTERSTATE AIR POLLUTION STUDY AREA
Mode of
disposal
Incineration
Municipal
On- site
Landfill
Open burning
Dumps
On- site
Total
Refuse,
tons/yr

223,000
62,600
441,000

284,000
318,000
1,328,600
Total hydrocarbons
released;
tons/yr

33
363
--

44,500
39,800
84,696
incinerated within municipal or on-site units.  Open burning for disposal of wastes
will undoubtedly decrease because the recommended reduction plan for particulates
calls  for (1) elimination of open burning and (2)  multiple-chamber design for all
incinerators.  These recommendations, when acted on, will result in a considerable
reduction in the emissions of hydrocarbons.

    Emissions of hydrocarbons - On the basis of the above and the presently
available  emission factors, the emissions of hydrocarbons  for future years were
calculated.  The following assumptions were made for these calculations: (1)
441,000 tons per year of refuse is and will continue to be disposed of by sanitary
landfill, (2) all existing incinerators will be converted to multiple-chamber types,
(3) the quantity of refuse presently disposed of by open burning will be incinerated,
and (4) the additional quantity of refuse generated because  of population growth will
be incinerated.  January 1, 1969, has been assumed as the  completion date for act-
ions required by these four items.
    Emission factors indicate that during the  incineration  of a ton of refuse, a
municipal incinerator releases 0.3 pound of hydrocarbon and an industrial or
commercial multiple-chamber incinerator releases 0.25 pound of hydrocarbon.
Since these emission factors are relatively close, an average of 0.30 pound of
hydrocarbons has been  assumed for both types of incinerators.

    The estimated hydrocarbon emissions for 1963 and the projected emissions
for future years are  shown in Table 19. The elimination of all open burning and
the conversion to multiple-chamber types is expected to reduce the hydrocarbon
emissions by approximately 99.8 percent.   The validity of the emission factor of
280 pounds per ton for open burning used in this calculation is open to some
question.  Regardless of future findings, the expected reduction will be large  and,
therefore, will reduce the hydrocarbon emissions from this source category to a
relatively insignificant amount.
62

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           Table 19.  PROJECTIONS OF HYDROCARBON EMISSIONS
  FROM REFUSE DISPOSAL IN INTERSTATE AIR POLLUTION STUDY AREA
                                  (tons/yr)
Mode of
disposal
Municipal incineration ^
On- site incineration •)
Landfill
Open burning
Total
% cr "°63 total
Year
1963
33
363
--
84,696
85,092

1969
159
--
--
159
0.2
1980
219
--
--
219
0.3
Emissions of Hydrocarbons From Other Sources - "Air Pollution Emission Inven-
tory," Volume II of this report, lists other sources of hydrocarbons as solvent
evaporation (including gasoline from stationary sources), industrial process losses,
and fuel combustion.  Collectively, these source categories contribute slightly more
than 14 percent of the area total,  or an estimated 53,900 tons of hydrocarbons
annually.  They include approximately 24,000 tons from the solvents used in in-
dustries and dry cleaning plus other non-industrial uses. An additional 12,000 tons
per year is added from the evaporation of gasoline from storage tanks  and the fil-
ling of automobile fuel tanks.  Industrial processes annually emit an estimated
11,700 tons, which is probably low, since information relating to some  industries
was not available. The combustion of fuels (primarily coal) contributes another
6,200 tons annually.

    For the purposes of  predicting future emissions of hydrocarbons, the emissions
from  sources considered in this subsection were increased for future years pro-
portionately to the expected increase in population.  They appear in Table 20.

Emission  Reduction Plan

    The mathematical relationship between hydrocarbons and oxidant concentrations
could not be found.  (See  Volume III of this report.)  For this reason, it is not pos-
sible  to predict reductions in oxidant levels based on hydrocarbon reductions.  It
is known,  however, that oxidant levels should be reduced to meet the  goal and that
hydrocarbon reduction is one way to do it.

    Two separate  projections of hydrocarbon emissions are presented in Figures
18 and 19.  The Plan I projections shown in Figure 18 considered only the reduc-
tions  in motor vehicle hydrocarbon emissions that are in effect now or  are  pro-
                                                                            63

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            Table 20.  EXISTING AND PROJECTED EMISSIONS OF
                      HYDROCARBONS FROM OTHER SOURCESa IN
                      INTERSTATE AIR POLLUTION STUDY AREA
                                       (tons/yr)
Source category
Solvent evaporation
Industrial processes
Stationary combustion sources
Total
Year
1963
36,000
11,700
6,200
53,900
1970
41,000
14,500
7,500
63,000
1980
49,800
16,000
9,000
74,800
     a Projections were made on the basis of controls presently in use.

 vided by existing regulations (curve labeled "A and B" on Figure 17) and do not
 include the expected decreases that are still in the speculative stage. The Plan II
 projections shown in Figure 19 were made on the basis that all of the controls stated
 would, in fact, be implemented (curve labeled "A,  C, D, and E" on Figure 17).

     Figure 18 shows that a considerable reduction in hydrocarbon emission may  be
 attained in the next few years as a result of the recommended changes in refuse
 disposal practices and to a lesser extent the increasing number of automobiles
 equipped with the blowby control devices. The reduction in emissions after 1969
 would occur as a result of controls on motor vehicle exhaust emissions.

     The reductions shown in Figure 19 are more spectacular than those in Figure
 18.  The additional control devices on automobiles through 1971 result in a consid-
 erably higher reduction rate in hydrocarbon emissions in the Study area.

     On the basis of the results of the emission inventory and projections of
 hydrocarbon emissions, the following conclusions may be drawn.

     1.  The principal sources of hydrocarbons are gasoline-powered motor vehicles
 and refuse disposal by  open burning.

     2.  A decrease in hydrocarbon emissions from motor vehicles will occur
 starting in 1968 as a result of exhaust controls on all new cars, as required by
 Federal regulations. A  decrease of approximately 31 percent of the 1966 emissions
 by the year 1980 is expected.

     3.  If additional reduction in hydrocarbon emissions from motor vehicles is
 achieved by limiting the evaporation losses and further reducing the exhaust
 emissions, a decrease  of almost 56  percent can be expected by 1980.

     4.  A considerable  reduction in total hydrocarbons released to the atmosphere
 can be achieved by regulating the means of refuse disposal.  A reduction of more
 than 99  percent of hydrocarbons from refuse burning will result if all open burning
64

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 is prohibited and strictly enforced and all incineration is performed in multiple-
 chamber incinerators.

     5.  Restrictions on the evaporation of gasoline from storage tanks and those on
 certain industrial processes will not add greatly to the overall area reduction in
 hydrocarbons,  but may be necessary to minimize the hydrocarbon emissions in
 localized areas.

     6.  A reduction in hydrocarbon emissions in the St. Louis area is expected
 as a result of limiting emissions from automobiles and the implementation of
 regulations relating to refuse disposal.  An overall decrease of approximately 23
 percent  by 1970 and 37 percent by  1980 can be expected.

     7.  The emissions of hydrocarbons are greatest in areas of high traffic densities,
 principally in the central business district.  The actual concentration of hydrocar-
 bons in this area has not been  determined; however, available information indi-
 cates the advisability of starting to limit hydrocarbon emission in this area now.
 An important reduction would occur as a result of decreased traffic density if a
 rapid transit system that will be used by large segments of the population is
 developed.

     8.  Since not all of the hydrocarbons enter into photochemical reactions to
 produce smog, a precise estimate of the impact of these reductions on concentra-
 tions of  total oxidant in the area is not possible  at present.

     9.  The formulation of relationships between traffic densities, hydrocarbon
 and nitrogen oxide  emissions,  and observed concentrations of total oxidant is
 necessary to provide a useful guide for future transportation studies.  To under-
 take the development of such relationships, information relating to existing and
 projected traffic volumes, traffic speeds, and diurnal variation in traffic are needed.

 AIR-USE PLAN - CARBON MONOXIDE


     Carbon monoxide is emitted primarily from motor vehicles.  Consequently, the
 emission patterns and ambient air  concentrations are  closely related to the traffic
 patterns with respect to both time and location.  If major reductions in ambient
 air concentrations of carbon monoxide are to be achieved,  automotive emissions
 must be  reduced.  The air quality can be improved by  limiting the emissions from
 automobiles through the  installation of central equipment and by reducing the number
 of vehicles on the road by the development of a rapid transit system.  Both of these
 approaches are needed to lessen the emissions of pollutants in the Study area.


 Air-Quality Goals


     A maximum 8-hour average concentration of 30 ppm and a 1-hour average con-
centration of 120 ppm have been proposed as the air-quality goals for the Study
area. Although these goals are based on effects, there is some question whether
the selected goal of 30 ppm is sufficiently low to meet  the needs of certain popula-
tion  groups living in the central urban area.  The effects of carbon monoxide are
discussed in detail in Volume VI  of this  report.
                                                                            65

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Existing Concentrations

    Continuous monitoring of carbon monoxide concentrations has been performed
at the CAMP station in St. Louis since March  1964.  During the period from March
1964 to September 1965,  the average monthly concentrations varied from 5 to 10
ppm, with an overall average of approximately 6 ppm.  The  maximum 24-hour,
1-hour, and 5-minute average concentrations observed during this period were  17
ppm, 27 ppm, and 53 ppm, respectively, which, allowing for time-concentration re-
lationships, are within the air-quality goals. Since these measurements represent
the concentrations at only one location, this comparison of existing concentrations
and air quality goals cannot be  extended to include the entire city or even the en-
tire central business district.  For example, the concentrations  of carbon monoxide
observed at the CAMP site represent the conditions  some 30 or  40 feet away from
the street.  Recent investigations have shown that the concentrations in vehicles
are about two times the CAMP  values and those in traffic  are as much as four times
as high as those recorded at the CAMP site. It is  probable  that  the concentrations
of carbon monoxide in the more heavily traveled parts  of the central business
district are higher than those observed at the  CAMP station. Furthermore, one
can expect much lower concentrations  in areas outside of  the central business
district and away from major traffic arteries.


Existing and Projected Emissions


    During  1963, an estimated  1,115,000 tons of carbon monoxide was emitted to
the air of the St. Louis Metropolitan Area.   Gasoline-powered motor vehicles ac-
counted for  approximately 98 percent of this amount.

    Projections indicate that by 1980 the rate  of gasoline  consumption in the area
\vill be double that of 1963.  If automobile exhausts continue uncontrolled, the emis-
sions of carbon monoxide would increase in proportion to  more than 2 million tons
annually in the year 1980.

    The uncontrolled emissions of carbon monoxide  in the exhaust gases are
approximately 3.1 percent by volume under  average urban operating conditions. 4
Depending on the average route speed, the rate of emission varies from approximately 6
percent by volume at 5 miles per hour to 2 percent at 60 miles per hour.  The
3.1 percent  by volume corresponds to an average route speed of 25 miles per hour.
On the basis of the average speed in urban areas and the average daily mileage
traveled, an average of 4.2 pounds of carbon monoxide  is emitted daily per auto-
mobile.
Emission Reduction Plan
    Federal Law S-306 authorizes the Secretary of Health, Education,  and Welfare
to set limitations on air pollutant emissions from automobiles. The limitations on
carbon monoxide emissions have been specified as 1.5 percent by volume  for all
vehicles with an engine displacement  in excess of 140 cubic inches. (For  smaller
engines a slightly higher emission rate is allowed.)  These limitations will go in
effect starting with the 1968 models.  The overall reduction in emissions achieved
 66

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by these controls, although decreasing the emissions per equipped vehicle by 50
percent, is almost negated by the expected increase in automobile travel.  The net
effect, as shown in Figure 20, is the maintenance of the existing emissions quantities
for the next 20 years.
     Assuming that emissions of carbon monoxide from motor vehicles will be con-
trolled to 1 percent by volume,  starting with the 1971 models, a reduction as shown
in Figure 20 can be expected. (The State of California requires that carbon monox-
ide be controlled to 1 percent by volume starting with the 1970 models.)  The  im-
plementation of this emission limitation would reduce overall emissions in 1980 to
20 percent below the  1963 amounts.

     The curves in Figure 20 as well as the  above discussion are based on the
existing and projected emissions of carbon monoxide for the entire Study area.
It is, however, the central business district where the traffic density and hence
pollutant emissions are high and of primary concern. Before the impact of these
           250
           200
           150
      Ol
      CL
           100
      ro
      10
      en
            50
                MM 7 M I | I M M M M |MMMMT|MMMII MlXT M M I  L
                                                             A AND
                                   CONTROL DEVICES ON NEW AUTOMOBILES

                                   A  - EXHAUST CONTROL (1.5% BY VOLUME)
                                   B  - EXHAUST CONTROL (1.0% BY VOLUME)
            0 H I I I I  I I I I I I I  I I I I I I I  I I I I I I I  I l l I II  I l I I I l |  I | | |
            1950         1960        1970         1980        1990
                                        YEAR
200C
 Figure 20.  Projected carbon monoxide emissions from gasoline-powered motor
             vehicles with and without control devices.
                                                                             67

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reductions on that area can be evaluated, more detailed information on the expected
increase in traffic density is needed.


AIR-USE  PLAN - NITROGEN OXIDES
    An air-use plan for nitrogen oxides, as such, is not included in this report. The
primary reason for this omission has been the lack of air-quality measurement
data and criteria, which in turn make the setting of air-quality goals for this class
of pollutants impractical.   Whenever the air-quality goals are prescribed, the
emissions of nitrogen oxides and the resulting ambient concentrations of these
pollutants will need to be evaluated in terms of these goals and,  if necessary, re-
ductions in these emissions will have to be prescribed and measures will  have  to
be taken to achieve the reductions.  As a first step in the design of an air-use plan,
this report chapter relates nitrogen oxides emissions to the various types of
sources, and gives estimates of future emissions.

    By far the most important source of nitrogen oxides is the combustion of fuels.
The ever-increasing population and the continuous urbanization of the Study area
will undoubtedly result in  higher energy requirements.  These requirements, at
least  in part, will be fulfilled by increased consumption of fossil fuels, which will,
unless controlled,  increase the emissions of nitrogen oxides.  The magnitude of
increase is  dependent not  only on the future energy requirements, but more im-
portantly on the types of fuels used to meet the requirements.
Existing Concentrations

    Nitric oxide and nitrogen dioxide have been monitored at the St. Louis CAMP
site since March 1964.  The monthly mean concentrations of nitrogen  dioxide during
the period from March 1964 to September 1965 varied from 0.02 to 0.05 ppm.  The
maximum 24-hour average concentration observed during this time was 0.12 ppm,
whereas the highest 1-hour average concentration during the  same time period was
0.22 ppm. The frequency distribution of measurement data observed from March
1964 to February 1965 showed a geometric mean  value of 0.028 ppm and a 99
percentile value of 0.091 ppm.

    Comparison of the observed concentrations with the State of California air-
quality standard, which is 0.25 ppm for  a maximum 1-hour average concentration,
shows that this air-quality goal was not exceeded at the CAMP site.  The  CAMP
measurements cannot be used, however, as the maximum value for the St. Louis area.


Existing Emissions

    During 1963, an estimated 138,300 tons of nitrogen oxides was released to the
air of the Study area.  In terms of their contribution to the total area emissions,
the various source categories accounted for the following percentages:  electric
power  generation,  38 percent; transportation sources, 35 percent; industrial fuel use,
16 percent; residential-commercial fuel use, 6 percent; industrial processes, 3
percent; and other sources, 2 percent. The burning of refuse material accounts for
less than 1 percent of the community total.
68

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Stationary Combustion Sources  - During 1963, an estimated 85,500 tons of nitrogen
oxides was emitted from the combustion of fuels in stationary sources. The com-
bustion of coal accounted for 83 percent, natural gas for 12 percent, and fuel oil for 5
percent.  During the same time period, coal supplied 57.7  percent; gas, 31.1 percent;
and fuel oil, 4.2 percent of the energy requirements. These figures are based on a
total heat input of 312 X 1012  Btu.  Emission rates of nitrogen oxides according to
Btu output from coal, fuel oil  and gas are  given in Table 21.

              Table 21.  EMISSION RATES OF NITROGEN OXIDES IN
                   INTERSTATE AIR POLLUTION STUDY AREA
                            (Btu heat generated)
Fuel
Coal
Fuel Oil
Gas
Industrial
boilers
1.1
0.9
0.3
Domestic- commercial
units
0.4
0.9
0.2
Fuel Consumption - Fuel consumption for the Study area has been projected by
Ridker5 for the years 1970 to 1980 and is listed by user category in Table 22.  The
projections for 1980 indicate an increase above the 1963 consumption levels of
            Table 22.  PROJECTIONS OF FUEL CONSUMPTION IN
                INTERSTATE AIR POLLUTION STUDY AREA
Fuel
Coal, tons/yr




Fuel oil
gal/yr



GaS * Q
10° ftVyr



User category
Steam-electric utilities
Industry
Residential
Commercial
Total
Steam-electric utilities
Industry
Residential
Commercial
Total
Steam-electric utilities
Industry
Residential
Commercial
Total
1963
4,874,000
1,628,000
738,000
222,000
7,462,000
642,000
114,507,000
120,543,000
6,414,000
242,106,000
9,200
42,550
42,685
2,876
97,311
1970
7,100,000
1,560,000
428,000
111,000
9,199,000
642,000
133,000,000
98,800,000
8,900,000
241,342,000
9,200
54,500
55,700
3,900
123,300
1980
6,200,000
1,530,000
340,000
95,000
8,165,000
642,000
145,000,000
80,800,000
12,300,000
238,742,000
9,200
65,000
63,800
5,500
143,500
                                                                          69

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almost 47 percent in the use of gas and 9 percent in the use of coal, and a 1 percent
decline in the use of fuel oil.  The overall increase in the energy to be supplied by
these fuels was estimated to be approximately 20 percent.


     A change in fuel-use patterns is expected to accompany the increase in total
energy requirements.  In the case of the residential use of fuels, use of gas and
electricity are projected to increase whereas coal and fuel oil consumption are ex-
pected to decline. In the industrial category,  gas and fuel oil  consumption are pro-
jected to increase, with the consumption of coal remaining at  the present levels.
Consumption of coal by the steam-electric utitities is projected to  increase by 64
percent by 1970 and then decline to about 31 percent above the 1960 consumption in 1980.
The decline in the use  of coal between 1970  and  1980 is expected to be offset by the
use of hydro and  nuclear power for electrical generation.


Emissions of Nitrogen Oxides - According to  the above projections, approximately
101,000 tons of nitrogen oxides will be emitted in 1980 from the combustion of
fuels in stationary sources.  This  is 15,500 tons or  18 percent  more than the 1963
emissions.  The emissions from steam-electric utilities and industrial fuel use are
expected to increase by 27 and 10 percent, respectively.  The emissions of nitrogen
oxides from residential and commercial fuel uses are, however, expected to de-
cline by approximately 10 percent. Projected annual emission rates  are summarized
in Table 23 by type of fuel and user category.

Mobile Combustion Sources  - During 1963,  an estimated 759 million gallons of
gasoline burned in the  Study  area resulted in an emission of 43,400 tons of nitrogen
oxides. An additional 4,700 tons was emitted by aircraft, vessels,  and railroads.
Unless controlled, the  emissions of nitrogen oxides  from motor vehicles would be
approximately 80,000 tons per year by 1980.
Summary - Nitrogen oxides constitute one of the five or six groups of major pollu-
tants that orginate community-wide and are of general importance.  Population
growth and its related activities in urban areas have caused the emissions of these
pollutants to increase, and, unless controlled, the emissions will continue to in-
crease.

     The  emission of nitrogen oxides from all sources is expected to increase
slightly more than 2 percent per year until 1980, when approximately 195,000
tons per year will be released in the Study area.  Because of the changing fuel-use
patterns, comparable increases cannot be expected in all parts of the Study area.
Because of the rapid rate of increase in gasoline consumption, the emission rate
of nitrogen oxides in the downtown area probably will increase considerably more
than elsewhere.  In contrast,  emissions from residential areas are expected to
decrease.

    A reversal of the continually increasing  nitrogen oxides emissions may be
necessary, if not at the present then surely in the future.  To assess the existing
concentrations, sampling of the nitrogen oxides throughout the community should
be initiated.  Similarly, investigation of control measures for reducing emissions
from mobile as well  as stationary sources should be encouraged.
70

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         Table 23.  PROJECTIONS OF NITROGEN OXIDE EMISSIONS IN
                 INTERSTATE AIR POLLUTION STUDY AREA
Source
category
Combustion of fuels -
stationary sources
Steam-electric utilities
Coal
Fuel oil
Gas
Industry
Coal
Fuel oil
Gas
Commerical
Coal
Fuel oil
Gas
Residential
Coal
Fuel oil
Gas
Combustion of fuels -
mobile sources
Motor vehicles
Other
Industrial process
emissions
Totals
Emissions of nitrogen oxides, tons/yr
1963

53,100
51,300
a
1,800
23,800
16,300
2,100
5,400
900
600
100
200
7,900
3,000
2,000
2,900
48,100
43,400
4,700
4,700
138,500
1970

76,800
75,000
a
1,800
24,900
15,600
2,400
6,900
720
300
150
270
7,200
1,700
1,700
3,800
64,300
58,600
5,700
5,700
179,620
1980

67,300
65,500
a
1,800
26,000
15,300
2,600
8,100
800
200
200
400
7,100
1,300
1,400
4,400
87,000
80,300
6,700
6,700
194,900
a Negligible.
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 AIR-USE PLAN - ODORS
 Existing Conditions
     Surveys conducted during portions of the Study Phase I and Phase II operations
 (for detailed information see Volume IV of this report) indicated that odors are a
 serious problem in certain portions of the Study area. The odor frequency sum-
 mary for the Phase II report is presented in Figure 21.  This summary shows
 that odors occur most frequently in the City of St. Louis and  Illinois (principally
 in the East St.  Louis  area), and with a somewhat lower frequency in St.  Louis
 County. The two most frequently detected categories of odors were combustion
 (auto exhausts, coal smoke, etc.) and chemical (refinery, medicinal, sulfurous,
 vanilla, etc.).
            TOTAL POSITIVE
            UNPLEASANT
            PLEASANT
            NO REACTION*

            TOTAL POSITIVE
            UNPLEASANT
            PLEASANT
            NO REACTION*

            TOTAL POSITIVE
            UNPLEASANT
            PLEASANT
            NO REACTION*

            TOTAL POSITIVE
            UNPLEASANT
            PLEASANT
            NO REACTION*
            ST. LOUIS CITY
             ST. LOUIS CO.
                 ILLINOIS
METROPOLITAN AREA

                                     10
        20
                                                       30
40
                             PERCENT OF OBSERVATIONS IN WHICH
                                    ODORS WERE DETECTED
                   Figure 21.  Odor frequency summary.
72

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    Chemical odors are of particular concern in the City of St. Louis, where they
represented 28  percent of all the odors observed.  These odors occur primarily
in association with winds from the east-southeast to south-southeasterly directions
(see Figure 22).  Because of its  proximity to the large chemical complexes  on the east
side of the Mississippi River, the downtown area of St.  Louis,  in particular, ex-
periences a high frequency of chemical odors, many of  which are very objectionable.
     Length of arrow indicates the maximum number of
     chemical odors observed at a given station, with
     the wind blowing toward the direction the arrow is
     Tip of arrow corresponds to the location of the
     observation station.
        Figure 22.   Chemical odor observations related to wind direction.
                                                                                 73

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    In contrast to chemical odors, combustion and combustible waste odors
 were not associated with winds from a particular direction because the sources of
 these odors are located throughout the community.

    The results of the odor surveys indicate that unpleasant odors often cover a
 significant portion of  the metropolitan area.
Air-Quality Goals - Odors
    Air-quality goals for odors pertain to "objectionable" odors. An odor is
considered "objectionable" when 15 percent or more of the people exposed to it
believe it to be objectionable in usual places of occupancy.  The sample size needed
to determine the "objectionable" quality should be at least 20 people or 75 percent
of the exposed if fewer than 20 people are exposed.  The goals are:

    1. No odors would be permitted to occur on or immediately adjacent to
properties used for residential, recreational, educational, institutional, hotel,
retail sales, or other similar purposes.

    2. On or immediately adjacent to industrial properties where the  need for
odor-free air is not so imperative, the release of pollutants would be prohibited
if persons with a normal sense of smell could detect the odors after they were
diluted in the ratio of one volume of odorous air to not more than 20 volumes of
odor-free air.

    3. In areas not included under items 1 and 2  above, the release of pollutants
would be prohibited if persons with a normal sense of smell could detect the
odors after they were diluted in the ratio of one volume of odorous ambient air
to not more than four volumes of odor-free air.
Evaluation of Existing Conditions
    The surveillance of odors throughout the entire Interstate Air Pollution
Study area should be made an integral part of the developing air resource manage-
ment program. This  surveillance can be accomplished by surveys of the type de-
scribed in Volume IV of this  report and through odor observations made by both
source and program personnel.

    Because of their  generally complex nature, the odorous pollutants released
to the atmosphere  can not be easily estimated quantitatively,  and up to the present
time the most reliable and sensitive instrument available for detecting and judging
odors is the human nose.  Because of this,  odors  must be measured and evaluated
by the quite simple  and satisfactory dilution technique.  By using variations of this
technique, measurements may be made on odorous materials obtained either from
the source or from the ambient air.
74

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    For sampling at the source, a  volumetric sample of the material from the
stack or other appropriate portion of the process is obtained and diluted with a
known volume of odor-free air.  Sampling can be accomplished quite simply by
means of a hypodermic syringe or other commercially available device.  After the
sample  is obtained and diluted, a panel consisting of three or more persons sniffs
the sample to determine the presence of an odor.  If an odor is detected,  successive
dilutions are made to determine the volume ratio of odor-free air to contaminated
air required to render the contaminated air mixture odor free, as determined by
the panel.

    The volume ratio thus determined can then be utilized in conjunction with
atmospheric diffusion equations to indicate ground-level concentrations at varying
distances from the source.

    The use of this technique by source owners or operators to determine their
individual contribution to the overall odor problem should be encouraged.  The
multitude of sources in the Study area would make such monitoring by governmental
program personnel entirely too burdensome.  In addition, by requiring the source
owners  to monitor their own activities, each of them will develop a greater appre-
ciation and understanding of the existing problem, which should serve as  encourage-
ment  for the effort necessary to achieve the desired level of air-quality.

    Because, among other things,  the syringe technique is not adequately sensi-
tive and is time consuming, it is not suitable for making ambient air measurements
in the field.  Odors in many cases are very transient and require a device that can
make dilutions rapidly and reasonably accurately.  Such a device,6 called the
"Scentometer," has been developed.  This instrument consists of two plenum
chambers for air that is to be purified, two activated-carbon filters for purifying
a portion of the air, a mixing chamber, and several critical orifices through which
the odorous air passes into the mixing chamber. By closing off all of the critical
orifices, the operator can draw ambient air through the activated-carbon filters.
After eliminating olfactory fatigue by breathing the purified air for about a minute,
he can open orifices until the volume ratio obtained produces a detectable odor.
This procedure is used to determine whether the ambient air-quality goals are
being exceeded. Also, by using the device  in conjunction with wind direction in-
formation and a map,  odor sources can be  located by triangulation.

    Valuable information regarding existing conditions can also be obtained from
citizen complaint records. A citizen's complaint form adapted to electronic data
processing has recently been developed for use in the  Study area. Since the data
forms for the odor surveys are also adapted to this method of data handling, a
rapid and up-to-date analysis of the information produced by these two sources
will be possible.


Odor Reduction Plan
 Priorities  - On the basis of data provided by the Phase I and II odor surveys and
 that generated by present and future surveillance activities and complaint records,
 priorities for action should be established to attain an acceptable level of air-
 quality for the entire air pollution basin.  These priorities should relate to the
 numbers of people, to the geographical area affected, and to the degree of
                                                                             75

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objectionableness of the odor.  The geographical area should be considered from
a land-use standpoint.  For example, an odor that affects a primarily residential
area should receive a higher priority for reduction or elimination than one that
affects an area used mostly for industrial purposes.

    In some parts of the Study area land use is mixed, and in others residential
areas border on heavy-industry areas.  These  areas  should be treated on an
individual basis,  with suitable long-range plans implemented to install source
controls or provide suitable separation of source and receptor. Steps leading to
the achievement of the desired air-quality goals should be based initially on
community understanding of the nature  of the problem and subsequently on com-
munity-wide understanding of the efforts and improvements made  by both govern-
ment and industry.

Controls - Following the  establishment of priorities, owners of the sources re-
sponsible for the emissions should be encouraged to institute and control actions.
If possible, and before ordinances are enacted, cooperative  agreements between
the priority sources and program  agencies should be entered into.  By proceeding
in this manner, the source operators will have an opportunity to demonstrate their
good intentions, and improvements in existing conditions will occur at an earlier
time than would otherwise be possible.

Planning and Zoning - Liaison with planning and zoning authorities should be
developed to increase the  understanding and appreciation of the odor problem, and
to encourage their cooperation in obtaining suitable separation of sources and
receptors.

Research - Research activities on the  part of both government and industry should
be encouraged, for there is much to be  learned about the kinds of compounds that
produce odors and their related physiological and  psychological effects.
Researchers should be  encouraged to develop methods for measuring odorous
pollutants that do not rely on the human sense of smell.
BENEFITS OF RAPID TRANSIT SYSTEM
    Rapid transit has been considered as a cure for congested streets, overcrowded
parking facilities, and long commuting times.  It can also be a cure for certain
types of air pollution.  Rapid transit facilities can reduce the volume of traffic,
especially in the central business district during the "rush hours," and con-
sequently reduce the emissions of pollutants from motor vehicles.  These
pollutants are carbon monoxide, hydrocarbons, oxides of nitrogen, odors and
oxidants (indirectly).  The development of the  air-pollutant-free type of rapid
transit system in the St. Louis area would materially reduce the amounts of these
pollutants.   Construction of a rapid transit system should, therefore, be supported
on the basis of its importance in reducing air  pollution.  Local air pollution con-
trol agencies should aid in the development of a rapid transit system by further
evaluation of the air pollution aspects and participating in any discussion and
decisions involved.
76

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    Large amounts of hydrocarbons, carbon monoxide, and nitrogen oxides are
emitted daily from the operation of motor vehicles in the area. As noted in pre-
ceding sections, motor vehicles emit an estimated 63 percent of hydrocarbons, 98
percent of carbon monoxide, and 35 percent of nitrogen oxides of the total amounts
of these pollutants emitted from all types of sources in the Study area.  A large
proportion of these pollutants are emitted in the central business district or along
the main thoroughfares leading into the center of the city. The high traffic density
in the central business district and the low average speeds of vehicles result in
high emission rates.  In addition to the high emission rate of pollutants, the con-
finement of these pollutants by the tall buildings and narrow streets results in
much higher sidewalk concentrations of pollutants than elsewhere.

    Emissions of carbon monoxide and hydrocarbons are expected to be reduced
as a result of Federal regulations limiting the emissions of these pollutants from
motor vehicles. Preliminary estimates based on CAMP data and projected traffic
increases show, however, that these reductions will probably not be sufficient to
maintain the desired  ambient air levels of these pollutants in the downtown area.

    Since reductions in emissions of nitrogen oxides from automobiles have not
yet been required, the ambient air concentrations of this pollutant will undoubtedly
continue to increase.  A rapid transit  system can assist in reducing nitrogen
oxides in the downtown area by reducing the number of automobiles in the congested
area.

    Before any quantitative estimates of the impact of the proposed rapid transit
system on the ambient air levels of pollutants can be made, it will  be necessary to
determine the existing emissions on a smaller area basis than has previously been
done.  For this purpose, information on traffic count, average speeds, and density
variations is needed. With this information, the expected reductions  in pollutant
levels or the traffic density that will result in desirable air-quality may be deter-
minable.  The air-quality data collected in the St. Louis  CAMP station, which is
located in the central business district, can provide a good starting point for this
investigation.

    Investigations concerning various effects of motor vehicles emissions such  as
vegetation damage, eye irritation, and odors should also be carried out to estimate
the effects of the proposed rapid transit system. With this information it may
then be possible to design an air-use plan for the central business  district and
provide a quantitative estimate of the effect that a rapid transit system may have
on the air-quality.
                                                                             77

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        SUGGESTED ORGANIZATION OF INTERSTATE AIR POLLUTION
            STUDY AREA AIR RESOURCE MANAGEMENT PROGRAM

     Previous portions of this report have presented a general air resource man-
agement program outline, specific air-quality goals, and plans designed to reach
those goals.  The purpose of this chapter  is to outline the administrative organiza-
tion needed to assure functioning of the activities envisioned by the air  resource
management program.  In general, the organization is composed of existing govern-
mental agencies with new or expanded functions.  Major emphasis is placed on
coordination of functions and assurance of decisions and action over the entire air
pollution basin.

     In brief,  a three-level (state, regional, local) coordinated organization is pro-
posed (Figure. 23).  The first level stems from the general authority of the States
of Illinois and Missouri.  The second, consisting of a regional organization formed
by interstate agreement, is  currently being implemented by continuation of ac-
tivities of the Study Project Executive Committee, with this Committee attached to
the East-West Gateway Coordinating Committee.  The third level pertains to the
local level involving St.  Louis County, which is currently covered completely by
          Figure 23.  Air resource management program organization.
78

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a single agency - the St. Louis County Health Department; St. Louis City, currently
covered completely by the Division of Air Pollution Control of the City of St.  Louis;
and St. Clair and Madison Counties in Illinois.  These two counties contain 54
separate incorporated areas plus county jurisdictions all overlain by the jurisdic-
tion of the Illinois Air Pollution  Control Board.  In terms of organization to meet
the air pollution problem, this area is currently out of balance with the two major
areas in Missouri.
ILLINOIS PROGR4M IN ST. CLAIR AND MADISON COUNTIES


    To implement air pollution control in St. Clair and Madison Counties, it is
proposed that the Illinois Air Pollution Control Board organize a regional office
in that area and assign to it an adequate and competent  staff.  It is further proposed
that the Board meet in that area to consider the problems of that area. The
Board should be guided by an advisory committee representing county and municipal
governments of that area.

    The specific activities of the regional office should include:

    1.  General responsibility for air quality and regulatory action.

    2.  Control of major air pollutant sources, including negotiation of control plans
with major sources.

    3.  Technical supervision of personnel hired by local government.

    4.  Monitoring of air quality levels.

    5.  Emission inventory.

    6.  Establishment of air-quality goals and standards.

    7.  Establishment of rules and regulations,  including emission regulations.

    8.  Participation in urban planning and zoning functions to assure adequate con-
sideration of air-quality in the planning process.

    9.  Program organization and administration.


    The regional office of the Illinois Air Pollution Control Board, while carrying
out program responsibilities in the  area, should be continually alert to the interest
of local groups working toward a local control effort - an effort that might eventually
result in a local assumption of responsibility for air pollution control in the entire
area pursuant to a certificate of exemption issued by the Illinois Board.  As a step
toward qualifying for exemption, the local control effort might take the form of a
locally financed district operation, administered by the Board (similar in organiza-
tion to those in the State of Massachusetts). The eastern parts of both counties
should probably be excluded from such a district operation because of their physical
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 seperation from the main air pollution basin.  The line of separation is the bluff
 line bordering the American Bottoms.  It is suggested, however,  that the Board
 consider appropriate recommendations for State legislation to permit local govern-
 ments to join legally for the control of air pollution.

    Initially, activities of a local agency might include:

    1.  Solid waste collection and disposal problems including backyard burning on
private premises, but excluding those involving large incinerators or disposal of
wastes from entire communities.

    2.  Space-heating problems involving units with input of less than 1  million
Btu per hour.

    3.  Weed control.

    4.  Wind-borne dust control from construction and other sites within the
jurisdiction of the local agency.

    5.  Other problem areas or items that may be agreed to in writing between the
State  Air Pollution Control Board and the local agency.


MISSOURI STATE AIR POLLUTION PROGRAM
    The Missouri Air Conservation Commission would participate in any interstate
agreement preparation and in any governing board provided by such an agreement.
The State agency would review air-quality goals, rules, and regulations of the St.
Louis area and take action to approve or disapprove them in accordance with State
requirements.  The State's approval authority would apply to intrastate  standards
and rules and regulations, and would through them apply to the State  of Missouri's
responsibility to the State of Illinois under the terms of the agreement.  The
Missouri State agency would also have the responsibility  for controlling air pollu-
tion sources outside the jurisdiction of the agreement area that might have a
deleterious influence on the air-quality in the Missouri portion of the air pollution
basin.  These would include St. Charles and Jefferson Counties in which an
organizational arrangement between State and local agencies would be needed.

ILLINOIS LOCAL AGENCIES


    As  a general policy, there should be few air pollution control agencies at a
local level.  Where local ordinances are enacted, they should follow the suggested
ordinance provisions in Appendix B and should be reviewed and approved by the
Illinois  Air Pollution Control Board.  In its considerations,  the Board should seek
and be guided by any interstate agency created for the purpose of coordinating the
efforts of all control groups.  Agreement among the control groups regarding
which agency is responsible for specific activities is necessary to assure that no
geographical areas are missed or functional items overlooked.  The  general policy
should be to have activities assigned to the agency that can best handle them
technically.
 80

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     The air resource management plan and the air-quality goals should serve as
 the primary basis for decisions regarding activities to be conducted by local
 agencies.  The local agency must have authority to enforce action and the technical
 capability for handling the activity.  Types of air pollutant source categories will
 usually be the basis for establishing the division of responsibility.


 MISSOURI LOCAL AGENCIES


     With the modifications and growth envisioned in its development plan the Division
 of Air Pollution Control of the city of St. Louis is organizationally satisfactory, except that
 the agency needs a means for coordination of its activities with those of other air
 pollution control agencies in the area and with those of planning agencies within
 their areas of jurisdiction.

     St. Louis County is covered by a single air pollution control agency, which is
 part of the St. Louis County Health Department.  This agency's immediate develop-
 ment plan is satisfactory. A report? of November 30,  1965, describes this plan.  Like
 those of the rest of the Study area, this agency's plan for the future needs to include
 a means for coordination of its activities with other agencies.
INTERSTATE AGREEMENT


    The Study participants recognize a need for an interstate agreement between the
States of Illinois and Missouri to provide for an interstate organization to control
air pollution originating in one state and affecting the other. This organization would
initiate its own enforcement action only after it had provided opportunity through
leadership and coordinating activities for the appropriate state and local agencies
to manage the air resources  and resolve the pollution problems.  The interstate
organization should consist of representatives of state  and local control agencies and
other appropriate groups from each state, and should have authority to adopt standards
and regulations. It is suggested that the interstate control organization provided for
in the agreement between the states be supported by  equal appropriations from the
two states.
      As of May 1966 the States of Missouri and Illinois had not fully considered the
 nature of any compact or agreement between the two states.  The concensus is,
 however, that an agreement or compact is needed, that it should provide for a
 continuing day-to-day  operation in the St. Louis area, and that it should, from the
 state levels, contain elements that assure adequate  action at any point needed
 along the boundary of the two states.

 INTERSTATE COORDINATING ORGANIZATION

     It is recommended that the activities of all control agencies throughout the
 area be coordinated through a central organization comprised of representatives
 of each agency.  Such an interstate coordinating organization should have as its
 primary objective  the provision of an orderly and scientifically correct approach
 toward the control of air pollution through an air resource management program
 and,  as its secondary objective, the development of other aspects of metropolitan
                                                                               81

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 area governments. Such an organization might well be the successor agency to the
 Exective Committee of the Interstate Air Pollution Study.

     The duties of an interstate coordinating organization she aid include considera-
 tion of emission standards or other regulations, which could ne uniformly applied
 to meet air-quality goals.  The recommendations of the org? ization would be
 made available to the control agencies.  The organization mi^ht provide meteorolo-
 gical service for the area, including prediction of air pollution levels.  It might
 provide a data-handling service for the several control agencies.  The organization
 must have its own technical staff and provisions for adequate continuing financing.


           GUIDELINES FOR FUTURE AIR RESOURCE MANAGEMENT
                    PROGRAM ELEMENTS AND FINANCING

     Previous sections of this report have considered the basic elements of air
 resource management programs and have developed suggested goals and air-use
 plans to reach those goals.  An organizational plan has been suggested to provide
 for the development and implementation of the air resource management program.
 The objective of the following section is to provide orientation f^"  he developing
 air resource management program by discussing each of t    rogram elements
 and its major requirements separately.  This discussion,  supplemented by other
 volumes of this report, will be useful in implementing as well as developing ordin-
 ances, control practices, and plans for reduction of air j ollutants.


 CONTINUING AIR-QUALITY AND EFFECTS-MONITORING PROGRAM
     Volumes III and IV of this report provide adequate air-quality data for imple-
menting the air resource management program.  A report of operations and pro-
posed air-quality monitoring program plans may be found in a report of the Inter-
state Air Pollution Study Air-Quality Monitoring Subcommittee.  Additional air-
quality data are being provided by the Continuous Air-Monitoring Program of the
Public Health Service and activities  of the several agencies.

     The'immediate program need is to  institute the data-handling system for
assembling, interpreting,  and using these new data. The air-quality monitoring
program should be directed toward two  major objectives. The first is the determin-
ation of long-term trends  of the following:

     1.  Particulates. Special emphasis should be placed on determining particle
size distribution and composition.

     2.  Sulfur oxides.  Investigation  should not be limited to sulfur dioxidejbut
should also include sulfur trioxide, sulfuric acid, and sulfate.  Attention should be
given to determining the chemical changes undergone by sulfur compounds in the
air. The latter should be  handled as  a research activity by  a research institution.

     3.  Oxidants.  Special attention should be given to hydrocarbons, ozone, nitrogen
oxides,  and other components that relate to oxidant formation.  The nitrogen oxides
and end products of oxidant buildup,  including such  items as eye-irritating and
vegetation-damaging compounds,  should be given adequate research attention.
82

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     4.  Aeroallergens. Collection and identification of pollens and other
aeroallergens should proceed at a level in keeping with the practical application
of the data. Basic research should be encouraged.

     5.  Odors. An odor survey should be made every 9 months.  Personnel at all
fire stations as well as other  cooperators  and the methodology developed in the
Phase II Odor Survey should be employed.

     6.  Effects.   The initial approach toward monitoring long-term effects is the
complaint-recording and follow-up system placed in operation by the agencies in
the air  pollution basin in 1966.  Detailed effects studies based on needs discovered
by the system should adequately define long-term trends and  at the same time assist
with the solution  of localized problems on a priority basis.

     The second major objective of the air-quality monitoring program should be
the defining of local or special problems, primarily for the purpose of improving
air-quality in selected areas of the air pollution basin. The following are examples
of the pollutants involved.

     1.  Fluorides.

     2.  Acid mist.

     3.  Cement dust.

     4.  Diesel exhaust.

     5.  Odors of  a chemical nature.

     6.  Grain dusts.

     The monitoring  equipment used for this type of program  should be mobile.
Equipment for measuring long-term trends should be located  in the same place
during each sampling period.

     In general the problem areas would be found by the long-term-trend program
and treated on a priority basis by the activities  directed toward defining local and
special  problems. As  much as possible, source owners and operators should par-
ticipate in these activities  to assure understanding and corrective action. It is
anticipated that many problem solutions will depend on research by universities
and others.  These research activities should be encouraged,  but should not be
used as a means of unduly  delaying corrective action.

     In all cases the  data should be handled by computer methods, and yearly re-
ports made. Until data handling can be taken over by a central group, it should be
handled by cooperative arrangement between the several agencies involved.

CURRENT AND CONTINUING EMISSION INVENTORY

     Volume II of  this report provides an adequate backlog  of information for initiat-
ing an air resource management program in the air pollution  basin;  however, the
program for maintaining a current emission inventory has not been developed.
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     The emission inventory should be linked with registration and permit systems
 as well as with urban planning agency activities.  The first two are regulatory in
 nature.  The third is not, although it has a regulatory expression in zoning.  With
 the development of both regulatory and planning agencies under way, it is not  pos-
 sible to indicate what the ideal relationship between the two should be.  That there
 should be coordination is clear, and that potential advantages in addition to economics
 of a joint effort exist is apparent.  As a start, the regulatory agency could be
 responsible for large sources and the planning agencies for the small numerous
 sources.  The regulatory agencies would also be responsible for preparing guide-
 lines and evaluating the emission inventory data.

     As a result of the involvement of planning agency personnel in the Study,  land-
 use information from Madison and St. Clair Counties is being collected on the same
 map grid coordinate  system used by the Interstate Air Pollution Study.  Attention
 should be given to encouraging all planning agencies in the air pollution basin to
 utilize this same grid coordinate  system; the Illinois grid coordinate system.  In
 those  areas where its use is not feasible, agencies  should collect data on grid sys-
 tems that can be readily converted to the Illinois system.  A basic system for
 collecting land-use data in a manner allowing ready compr^ion of emission in-
 formation will facilitate development and use of the air pollution prediction model.
 This will be true for both the daily predictions and  for use of the model as a plan-
 ning tool.

     Planning agencies should use land-use classifications that are suitable for
 application of air pollutant emission factors.  In other words, the land-use classi-
 fications should have air-use characteristics.  For example, dwelling density
 should be treated on  a dwelling volume basis to facilitate calculation of emissions
 resulting from space-heating.  The area of land involved should also be recorded
 since  this will be important in developing performance zoning standards. Land
 used for industrial purposes should likewise have structure volumes indicated to
 facilitate space-heating pollutant  emission calculations.  Floor space,  by use  type
 as well as land area, should be recorded to facilitate development of performance
 standards for zoning and development of pollutant emission factors based on floor
 space for  certain types of industry.  Traffic volumes in terms of vehicle miles
 should also be calculable on the basis of grid squares to facilitate emission
 calculations as well as to  serve traffic study needs. Garbage and rubbish emission
 inventories based on quantities generated by the several types of land-use should
 be prepared using the planning activities. In addition to its use for emission  in-
 ventory purposes, this information would be invaluable for the planning,  develop-
 ment,  and sound operation of garbage and rubbish storage, collection,  and disposal
 systems.

     Furthermore, planning agencies should La encouraged to develop data cards,
 which would allow for correlating information recorded on the basis of parcel
 numbers,  addresses, and grid coordinates.

     Although the planning agency through its normal work could be expected to ob-
tain a large amount of necessary emission inventory data for numerous small
sources, the regulatory  agency would need to develop a system for maintaining an
emission inventory by categories of large and relatively specialized  sources.  This
information should be submitted by the source owners or operators themselves and
be verified by the agencies by field evaluation.  This arrangement would encourage
consideration of wastes  in  the source operation itself. The information collected
84

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 in this way by the regulatory agency would pertain to recognized major sources
 such as power plants, incinerators, dumps, other major open burning, and process
 emissions - starting with those that are recognized major problems in the air
 pollution basin and advancing as resources and program needs of the regulatory
 agency change.
 AIR-QUALITY GOALS, STANDARDS, AND CRITERIA
     Criteria will presumably be developed by other agencies or will be available
 as a result of research work by others. The air-quality goals will in general apply
 to the long-range goals of the air resource management program, and standards
 will be  legally defined and will appear  in ordinances and rules and regulations.

     Responsibility as well as capability for setting and updating air-quality goals
 and standards must be assured.  Goals and standards are related to effects; there-
 fore, the professional talent needed to  set them should include people concerned
 with: (1) human health, (2) animal health, (3) agriculture, (4) deterioration of
 materials, (5) natural resources, (6) economics, and other areas of interest.  Since
 decisions on air pollution matters are of a similar nature to those made on other
 community affairs,  air pollution control boards should have experts available as
 advisors when decisions are to be mar1"1,  ^he decisions and the responsibility
 should rest with the boards and shoulu be made in the name of the governmental
 entity that the boards represent.  Coordination should be provided through inter-
 state agreement and the organization provided for by that agreement.

     Volume VI of this report provides suggested air-quality goals and information
 supporting those goals.  It will assist those groups and individuals who have the
 responsibility for setting legal standar,


 USE OF CONDITIONS INFLUENCING TRANSPORT OF ^IR POLLUTANTS

    Volume V of this report provides an adequate basis on which to start an air
reo ' ,>rce management program.  Additional information, all of which is specific
for the St. Louis  area, is being developed as the result of research work on the
diffusion of luorescent  particles and mathematical models based on sulfur dioxide
bLidier  m?de during two winter seasons (1963 - 1965).  In addition, starting in 1965,
the df exopment of an air pollution potential prediction sy   >r is under wi     A.11
 if 1hc ,e activities .ncourage ->*   ?ive considerable Lnpet'L  to a program for the
v ec,;> :i3n of air-quality to bt -_ iO ai  a tool *ui air pollution control a-4'"Hi--^.
T.:  prpdiciion system should be  plac d in operation as  soon as :)ossibl^ ;  • p^  vide
news media with  daily predictions ano supporting news releases.  Predictions will
bring about voluntary suppression of pollutant emissions by source operators,
either through process modification or  delay of activities until more suitable times
of Ju  day,  or until more suitable meteorological conditions occur. In the  future,
in case  the air resource management program does not move swiftly enough, an
air pollution warning system will need to be developed to restrict activities under
certain  adverse meteorological conditions.  Additional use of the daily prediction
system would be  made by the regulatory agencies to alert inspectors and others
for control action, studies, and solution of specific problems.
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    The long-range use of the air-quality prediction system would be as a planning
tool.  Its development stems from research activities completed during the Study
on fluorescent particle diffusion and sulfur dioxide diffusion predictions.  Use of
the system should be through a joint activity of the urban planning and air pollution
control agencies.  It should start with an air pollutant emission inventory.  Once the
system is tested and computerized, data could be easily  and quickly  interpreted on
the basis of actual or proposed land-use.  In this way the impact on a given area of a
proposed development of a new industrial or residential  area could be determined.
On this basis, logical planning decisions could be made.

    As another starting measure, the regulatory agencies  should calculate and re-
port to the planning agencies on the probable impact of certain large pollutant
sources on air-quality in the area. The Portage de Sioux Power Plant Analysis,
which is on file  with the area's regulatory  agencies, is an example of the type of
calculations that should be made.


AIR POLLUTION CONTROL DECISIONS BASED UPON AIR-QUALITY INFORMA-
TION AND GOALS


    Appendix B suggests ordinance provisions that will reduce emissions  sufficiently
to meet the air-quality goals.  Justifications for these ordinance provisions  have
been developed throughout  the several volumes of this report.

    The preparation of emission reduction plans by many source owners is antici-
pated. After approval by the air pollution control agency, these reduction plans will
undoubtedly form part of the program implementation.  On major community matters
such as transportation and garbage and rubbish collection and disposal, air
pollution control plans will be incorporated in general plans by other branches of
government, probably from guidelines prepared by the air pollution control agency.


PROGRAM FINANCING


    The air resource management program should develop as a coordinated and
balanced activity working toward both long-term and short-term goals.  The total
cost of financing such an effort cannot be predicted with certainty; however, based
on the program described,  the availability of resources,  and the legislation required,
an expenditure level goal of 50 cents per capita per year is suggested for 1970.
                                REFERENCES

    1. Private communication.  Perry, H., Director of Coal Research, U.S. Depart-
ment of Interior, Bureau of Mines. Washington, D. C. April 27, 1966.

    2. Private communication.  Simon, J.A., geologist and Head, Coal Section,
Illinois State Geologic Survey. Urbana, Illinois, February 24, 1966.
86

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    3. Landsberg,  H.H., L.L. Fischman and J.L. Fisher. Resources in America's
future.  The Johns Hopkins Press. Baltimore, Maryland. 1963.


    4. Rose, A.H. Jr. Summary report of vehicular emissions and their control.
Presented at the Annual Winter Meeting of the ASME.  November 7-11, 1965.
Chicago, Illinois.

    5. Ridker, R.G. Economic costs of air pollution, studies in measurement.  In
preparation.

    6. Gruber, C.W., G.A. Jutze, N.A. Huey.  Odor determination techniques for
air pollution control.  JAPCA.  10:329.  August 1960.

    7. The air pollution control program in St. Louis County, Missouri. St. Louis
County Health Department. Clayton, Missouri. November 30, 1965.
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                                 APPENDICES


 APPENDIX A -PARTICULATE LEVELS DUE TO VENICE POWER PLANT

     The Venice Power Plant emits about 5,000 toms of particulates per year from
 stacks 225 feet tall. To estimate the effects of these emissions on the area, cer-
 tain values and conditions must be assumed:

     1.  Effective stack height (top of  plume) averages  400 feet.

     2.  Effective average meteorological stability is class 4.

     3.  Average wind speed is 9.3 mph (4.15 m/sec).

     The first assumption is an approximation,  based on experience.  The second
 is based on a limited tabulation of stability frequencies, which indicates that class
 4 stability occurs 54 percent of the time. The third is the average wind speed at
 Lambert Airport over a 10-year period.
     Figure A-l indicates the maximum ground-level concentration to be expected
from any elevated source and stability combination, and the distance at which the
maximum will occur. To facilitate its use it has been prepared for  a unit source
strength and unit wind speed.  In this case, the distance is slightly over 2 miles
and the indicated maximum concentration is about 5.6 x 10-6 with a dimension of
per square meter resulting from the formulation of the diagram.  To convert to
actual values, this number must be multiplied by the source strength, 144 grams
per second, and divided by the wind speed, 4.15 meters per second. The resulting
maximum concentration is then 5.6 x 10~6 x 144/4.15 = 194 x 10~" g/m3 or 194 (ig/m3.
     One assumption made in preparing the diagram, which was intended primarily
for gaseous pollutants is that total reflection of the particles takes place at the
ground surface. Since particulates are more likely to remain on the ground once
they contact the surface, the concentration obtained above should be reduced,
possibly to as low as 97
    This value, 97 |ag/m^, would be added to particulates from other sources, on
the average, when the wind is in the proper direction and the receptor about 2
miles from the source.  Since the maximum concentration depends upon wind speed,
plume height,  stability, and source strength, the value suggested here may be
greatly  exceeded  under certain conditions, with a resulting very dirty atmosphere.
For a year-round average, however, the  frequencies  of various wind directions
must be considered.  The maximum frequency of winds from a single sector
(16-point divisions) is 10.8 percent of the time, from the south.  When this factor
is applied to the average maximum as calculated above, the average annual in-
crease of particulates at any one point attributable to the Venice Power Plant is
not over 10.5 ug/m^, and probably about  4.5 \ig/m% since the wind sector is con-
siderably wider than the plume width.
88
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                                                                            10'
                                                                           10'
 Figure A-l.  Distance from source and relative value of maximum concentration
              for various source heights and stability classes.

APPENDIX B - SUGGESTED ORDINANCE PROVISIONS

    The Interstate Air Pollution Study Phase II Project Agreement activity item
number 6  provided for a subcommittee on ordinances, rules, and regulations and
charged it with the task of preparing suggested ordinance provisions.  The following
provisions and policies designed to implement the air-use plans found in the body
of this report stem from that subcommittee's work, supplemented by the active
participation of all project executive committee members.

    The ordinance provisions are recommended for use as  guides by the several
political jurisdictions in the Interstate Air Pollution Study area.  Some jurisdictions
have laws, ordinances, or regulations that accomplish some of the recommended
provisions.  Administrative procedures vary among the several jurisdictions;
therefore, they are not included.  For these reasons the provisions cannot  be
adopted without consideration of how they relate to existing  legislation.
    There should be as few air pollution control agencies at a local level as is
consistent with efficient and effective functioning.  This calls for an expansion of
air  pollution functions  on the basis of the levels of government best suited  to per-
form the air pollution activities.

    The intent of the recommended ordinance provisions and policies is to:

    1. Provide the means whereby air pollutant sources that are committed to
a clean-air policy may by their own decisions determine the means of reaching the
needed pollutant emission limitations.
                                                                            89

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    2.  Provide the means for convincing those sources not committed to a clean-
air policy that such a policy is in the public interest.

    3.  Provide the means whereby the public, through its public agencies, can
manage the air resources of the Interstate Air Pollution Study area.

    4.  Provide the means whereby the air-quality goals can be established as
public policy.

    The purposes of the recommended ordinance provisions are to (1) protect the
public health, (2) provide for the protection and advancement of  the public welfare,
protection and enjoyment of property,  and protection of business, (3) optimize the
use of the air resource in the St.  Louis Metropolitan Area air pollution basin, (4)
provide the implementing ordinances needed to establish the air resource manage-
ment  program required to meet the air-quality goals listed in Table B-l, and
(5) establish  the emission regulations  indicated as required by the air-use plan
to meet the air-quality goals.  The air-use plan design basis is  in Table B-2.

    The engineering air-use plan design is based on an urbanized area of approxi-
mately 400 square miles.  The program designed to implement the engineering
plan extends  the area covered to include St. Louis City, St. Louis County, and the
western parts of St. Clair and Madison Counties.  This is the area proposed to
come under the ordinance provisions in this Appendix. The other parts of the
Study area come under control programs of the respective states.  In Illinois, rules
and regulations of the  Illinois Air Pollution Control Board are being promulgated
under a policy requiring a high degree of emission control.  The Missouri Air
Pollution Commission is expected to take similar action. The Study area is,
therefore, completely  provided for in the air resource management program plan.
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               Table B-l.  SUGGESTED AIR-QUALITY GOALS
             FOR INTERSTATE AIR POLLUTION STUDY AREAa
Sulfur oxides
   Sulfation, measured by lead peroxide candle method
     Maximum annual average 0.25 mg 803 per 100 cm^ per day
     Maximum month 0.5 mg 803 per 100 cm^ per day

Sulfur dioxide, measured by West-Gaeke or conductometric methods
     Maximum annual average 0.02 ppm
     24-hr average 0.1 ppm not to be exceeded over 1 percent of the days in any
        100-day period
     1-hr period not to exceed 0.20 ppm more than once in any 4 consecutive days
     5-min period not to  exceed 0.50 ppm more than once in any 8-hr period

   Suspended sulfate, measured by high-volume sampler
     Maximum annual average not to exceed 4 jig per m^
     Not to exceed 12 ug  per m3 over 1 percent of time

   Sulfuric acid
     Maximum annual average not to exceed 4 jag per m^
     Not to exceed 12 ug  per m^ over 1 percent of time
     Not to exceed 30 ug  per m^ hourly average over 1 percent of time

Hydrogen sulfide, measured by AISI spot sampler using lead acetate impregnated
paper
   0.05 ppm 1/2-hr average not to be exceeded over 2 times per yr
   0.03 ppm 1/2-hr average not to be exceeded over 2 times in any 5-consecutive-
     day period

Oxidant (total), measured  by potassium iodide colorimetric method
   0.15 ppm for 1 hr (not to be exceeded)

Carbon monoxide, measured by nondispersive infrared method of measurement
   30 ppm for 8 hr
   120 ppm for 1 hr

Dustfall, measured by settled particulate accumulated in dry jars for 1 mo
   10 tons per mi^ per mo, 3-mo average above background in all areas except
     those zoned heavy industrial
   (Use 5 tons per mi2 per mo background)
   25 tons per mi2 per mo, 3-mo average above background in zoned heavy
     industrial areas
   (Use 5 tons per mi2 per mo background)

Suspended particulate, measured by high-volume sampler
   75 ug per m^ annual geometric mean
   200 ug per m^, annual 99th percentile
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                               Table B-l.  (Cont.)
 Soiling index, measured by AISI spot sampler
   0.4 Coh per 1,000 lineal ft, annual geometric mean
 a Abbreviations defined
          mg = milligram
          cm - centimeters
         ppm = parts per million
           hr = hour
          mo = month
 ug = microgram
 m = meter
 mi = mile
  ft = feet
Coh - function of optical density - see
         reference 1
 Note:  All goals, unless otherwise stated, apply to any place where people live or
       an undersirable effect could result from levels  above the goal.
                TABLE B-2.  AIR-USE PLAN DESIGN PARAMETERS
Land-use
category
Industrial
Commerical
Residential
Open spacea
Air -pollution-
basin average
Particulates,
tons/mi^ /yr
600
175
130
100
175
Sulfur oxides,
tons/mi2/3 mo
550
250
100
235
300
  aRoads, parks, playgrounds, cemeteries, vacant.
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Regulation I.  DEFINITIONS
A.  As used in the air pollution regulations of (jurisdiction), except as otherwise
specifically provided in such regulations and except where the context indicates
otherwise, the following words shall have the meaning ascribed to them in this
regulation:

1.  Air contaminant:  Any smoke,  soot, fly ash,  dust, cinders, dirt, fumes, gases,
vapors, liquids, particulate matter, or odorous  matter.

2.  Air pollution:  (The definition of air pollution should be consistent with the
respective state law.)

Illinois:  "Air Pollution" is presence in the outdoor atmosphere of one or more air
contaminants in sufficient quantities and  of such characteristics and duration as to
be injurious to human, plant or animal life or to property, or which unreasonably
interfere with the enjoyment of life and property.

Missouri:  "Air Pollution", the presence in the ambient air of one or more  air
contaminants in quantities of characteristics and of a duration which directly and
proximately cause or contribute to injury to human, plant, or animal life or health
or to property or which unreasonably  interfere  with the enjoyment of life or use of
property.

3.  Approved source:  A source of fuel that has had its fuel tested according to
procedures specified by the (head of the air pollution control agency) and whose
name appears on the approved source list.

4.  Existing:  Things, such as equipment, machines, devices, articles, contrivances,
or installations which are in being at a stated time except that any such existing
equipment, machine, device, article, contrivance, or installation which is altered,
repaired or rebuilt at a cost of 30 percent or more of its replacement cost shall
be reclassified as "new", as defined in this regulation.

5.  New: Things, such as equipment, machines, devices,  articles,  contrivances or
installations built or installed on or after a  stated time.

6.  Multiple chamber incinerator:  Any article,  machine, equipment, contrivance,
structure or part of a structure,  used to dispose of combustible refuse by burning,
consisting of three or more refractory lined combustion furnaces  in series, physically
separated by refractory walls, interconnected by gas passage ports or ducts and
employing adequate  design parameters necessary for maximum combustion of the
material to be burned.  The refractories  shall have a Pyrometric  Cone Equivalent
of 31, tested according to the method described in the American Society for Testing
Materials, Method C-24-56.
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 7.  Open burning:  The burning of any matter in such manner that the products of
 combustion resulting from the burning are emitted directly into the open atmosphere
 without passing through a stack, duct, or chimney.

 8.  Particulate matter: Any material, except uncombined water, which exists in a
 finely divided form as a liquid or  solid at "standard conditions."

 9.  Person: Any individual, firm, public or private  corporation, association, business
 trust, company, partnership, contractor, supplier, installer, user, operator or own-
 er, or any political subdivision or employee thereof.

 10.  Process weight:  The total weight of all materials introduced into a"source
 operation," including solid  fuels, but excluding liquids and gases used solely as
 fuels, and excluding air introduced for purposes of combustion.

 11.  Refuse: Any combustible waste material containing carbon in a free or combined
 state, other than liquids or gases.

 12.  Salvage operation:  Any business, trade, industry or other activity  conducted
 in whole or in part for the purpose of salvaging or reclaiming any product or
 material such as metals or chemicals.

 13.  Smoke:  Small gas-borne particles resulting from combustion, consisting of
 carbon, ash, and other material.

 14.  Source operation:  The last operation preceding the emission of an air con-
 taminant which operation (a)  results in the separation of the air contaminant from
 the process materials or in the conversion of the process materials into air con-
 taminants, as  in the case of combustion fuel; and (b) is  not an air pollution  abate-
 ment operation.

 15.  Standard conditions:  A gas temperature of 60 degrees Fahrenheit and a gas
 pressure of 14.7 pounds per square inch absolute.

 16. Trade waste:  Solid, liquid or gaseous material resulting from construction; the
prosecution of any business, trade or industry; or any demolition operation includ-
ing, but not limited to, plastics, cartons, grease, oil, chemicals and cinders.


 Regulation II.  MAXIMUM ALLOWABLE EMISSION OF  PARTICULATE MATTER
              FROM  FUEL-BURNING EQUIPMENT USED FOR INDIRECT
              HEATING
A.  General Provisions
1. This regulation applies to installations in which fuel is burned for the primary
purpose of producing steam; hot water; hot air or other liquids, gases or solids and,
in the course of doing so, the products of combustion do not come into direct contact
with process materials.  Fuels include those such as coal, coke, lignite, coke breeze,
 94

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fuel oil, and wood but do not include refuse. When any products or by-products of
a manufacturing process are burned for the same purpose or in conjunction with
any fuel, the same maximum emission limitations  shall apply.

2. For  purposes of this regulation, the heat input shall be the aggregate heat con-
tent of all fuels whose products of combustion pass through a stack or chimney.
The heat input value used shall be the equipment manufacturer's or designer's
guaranteed maximum input, whichever is greater.  If two or more fuel-burning
units are connected to a single stack or chimney, the total heat input of  all fuel
burning units connected to the stack or chimney shall be the heat input value used
for the purpose of computing the maximum allowable amount of particulate matter
which may be emitted. If a single fuel-burning unit is  connected to two  or more
stacks or chimneys, the heat input of the fuel-burning unit shall be used for the
purpose of computing the  maximum allowable  amount of particulate matter which
may be  emitted.
B.  Provisions Applicable to Existing Fuel-Burning Equipment

1.  No person shall cause or permit the emission of particulate matter, caused by
combustion of fuel in existing fuel-burning equipment, from any stack or chimney
in excess of the quantity set forth in the following table, except as provided in
Section  C of this regulation:

                                  Maximum allowable emission of particulate
Heat input millions of              matter in pounds per hour per million
British thermal units per hour     British thermal units of heat input   	

            10 or less                              0.60
            50                                     0.46
           100                                     0.41
           500                                     0.32
         1,000                                     0.29
         2,500                                     0.25
         5,000                                     0.225
         7,500                                     0.210
        10,000 or more                             0.20

2.  For  heat inputs between any two consecutive heat inputs in the tables in this
regulation, the maximum allowable particulate  matter emission shall be determined
by graphical  interpolation on logarithmic graph paper.

3.  The  amount of particulate matter emitted shall be measured according to the
American Society of Mechanical Engineers "Power Test Codes - PTC-27," dated
1957, and entitled, "Determining Dust Concentration in a Gas Stream."  This publi-
cation is hereby made a part of this regulation  by reference or other  method as
approved by the (Title of head of the air pollution agency).

4.  The  heat  content of coal shall be determined according to American Society for
Testing Materials D-271-64, Standard Methods of  Laboratory Sampling and Analysis
of Coal  and Coke, D-2015-62T, Tentative Method of Test for  Gross Calorific Value
of Solid Fuel by the Adiabatic  Bomb Calorimeter,  or equivalent methods in future
revisions of these standards.
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C.  Provisions Applicable Only to Spreader-Stoker-Fired Coal-Burning Equipment

1. The provisions of section B of this regulation shall not apply to spreader-stoker-
fired coal-burning plants except as provided in this section.  No person shall cause
or permit the emission of particulate matter caused by combustion of coal in exist-
ing or  new spreader-stoker-fired installations from any stack or chimney in excess
of the quantity set forth in the following table:

                                  Maximum allowable emission of particulate
Heat input in millions of           matter in pounds per hour per million
British thermal units per hour     British thermal units of heat input	

          10 or less                                  1.0
          50                                         0.76
         100                                         0.67
         200                                         0.59
         300                                         0.55
         400                                         0.53
         500                                         0.50
       larger than 500                    Same as other equipment as
                                          set forth in section B of this
                                          regulation

Regulation III. USE OF FUEL IN HAND-FIRED EQUIPMENT PROHIBITED

A.  General

1. This regulation shall apply to any fuel-burning equipment in which fuel is
manually  introduced directly into the combustion chamber, including, but not
limited to, heating and cooking stoves and hot water heaters. It shall not apply to
wood-burning fireplaces, wood-burning heating stoves in dwellings, fires used for
recreational purposes,  nor to fires used solely for the preparation of food by bar-
becuing.

B.  Prohibition

1.  On and after the dates specified in the following schedule, it shall be unlawful to
operate any hand-fired fuel-burning equipment.

Approximate geographical boundary        Date on and after which said hand-fired
enclosed by a circular area, centered      fuel-burning equipment shall not be
at the  centerline of Eads Bridge	     used	

             3-mile radius                      3 years      After
             7-mile radius                      3 years    passage of
All other  parts of the city of St. Louis          4 years  the ordinance
and St. Louis County and areas of St.  Clair
and Madison Counties west of a line 1-mile
north and east of State Route  159 and follow-
ing the eastern boundaries of townships
covering the bluff line to the south boundary
of St. Clair County.
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2. The (Title of head of the air pollution control agency) shall select and publish
specific boundaries of areas provided for in subsection B (1), in general consonance
therewith.

3. The (Head of the air pollution control agency) may order that any hand-fired
fuel-burning equipment not be used at any time earlier  than the schedule  in section
B (1) whenever such equipment has been found in violation of any air contaminant
emission regulation on three or more occasions in any  6 months.

4. The (Head of the air pollution control agency) may order that hand-fired fuel-
burning equipment be sealed (or removed from any building) when it is found that
such equipment is being used subsequent to the dates given in the schedule in sub-
section B (1).

5. The prohibitions of the use of hand-fired fuel-burning equipment provided for in
this regulation shall not apply to any installation when it can be shown beyond
reasonable doubt that the  building in which such installation is located will be
demolished prior to 6 years after this regulation is put into effect.
Regulation IV.  RESTRICTION OF EMISSION OF PARTICULATE MATTER FROM
               INDUSTRIAL PROCESSES
 A.  General Provisions
 1.  This regulation applies to any operation,  process, or activity from which parti-
 culate is emitted except (a) the burning of fuel for indirect heating in which the
 products of combustion do not come into direct contact with process materials, (b)
 the burning of refuse,  and (c) the processing of salvable material by burning.


 2.  For purposes of this regulation, particulate matter is any material, except
 uncombined water, that exists in a finely divided form as a liquid or solid at 60
 degrees Fahrenheit and a gas pressure of 14.7 pounds per square inch absolute.


 3.  Process weight per hour is the total weight of all materials introduced into any
 specific process that may cause any discharge of particulate matter. Solid fuels
 charged will be  considered as part of the  process weight, but liquid and gaseous
 fuels and combustion air will not.  For a cyclical or batch operation, the process
 weight per hour will be derived by dividing the total process weight by the number
 of hours in one complete operation from the beginning of any given process to the
 completion thereof, excluding any time during which the equipment is idle.  For a
 continuous operation, the process weight per hour will be derived by dividing the
 process weight for a typical period of  time.

4. Emission tests relating to this regulation shall be made following the standards
in The American Society of  Mechanical Engineers "Power Test Codes 11  - PTC-27,"
dated 1957, and entitled, "Determining Dust Concentration in a Gas Stream."
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B.  Emission Limitations


1. Except as provided for in section B (2), no person shall cause, suffer, allow,  or
permit the emission of particulate matter in any 1 hour from any source in excess
of the amount shown in Table B-3 for the process weight  allocated to such source.

2. The limitations established by section B (1) shall not require the reduction of
particulate matter concentration, based on the source gas volume, below the con-
centration specified in Table B-4 for such volume; provided that, for the purposes
of this section,  the person responsible  for the emission may elect to substitute a
volume determined according to the provisions of section B (3); and provided that
the  burden of showing the source gas volume  or other volume substituted therefor,
including all the factors that determine such volume and the methods of determining
and computing such volume, shall be on the person seeking to comply with the pro-
visions of this section B (2).


      Table B-3.  ALLOWABLE RATE OF EMISSION BASED ON PROCESS
                              WEIGHT RATE
Process weight
rate,
Ib/hr
100
200
400
600
800
1,000
1,500
2,000
2,500
3,000
3,500
4,000
5,000
6,000
7,000
8,000
9,000
10,000
12,000
tons/hr
0.05
0.10
0.20
0.30
0.40
0.50
0.75
1.00
1.25
1.50
1.75
2.00
2.50
3.00
3.50
4.00
4.50
5.00
6.00
Rate of
emission,
Ib/hr
0.551
0.877
1.40
1.83
2.22
2.58
3.38
4.10
4.76
5.38
5.96
6.52
7.58
8.56
9.49
10.4
11.2
12.0
13.6
Process weight
rate,
Ib/hr
16,000
18,000
20,000
30,000
40,000
50,000
60,000
70,000
80,000
90,000
100,000
120,000
140,000
160,000
200,000
1,000,000
2,000,000
6,000,000

tons/hr
8.00
9.00
10.
15.
20.
25.
30.
35.
40.
45.
50.
60.
70.
80.
100.
500.
1,000.
3,000.

Rate of
emission,
Ib/hr
16.5
17.9
19.2
25.2
30.5
35.4
40.0
41.3
42.5
43.6
44.6
46.3
47.8
49.0
51.2
69.0
77.6
92.7

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          Table B-4.  MINIMUM CONCENTRATIONS TO BE REQUIRED
Source gas
volume, scfm
7,000
or less
8,000
9,000
10,000
20,000
30,000
40,000
50,000
60,000
80,000
100,000
120,000
Concentration,
grains/scf
0.100
0.096
0.092
0.089
0.071
0.062
0.057
0.053
0.050
0.045
0.042
0.040
Source gas
volume, scfm
140,000
160,000
180,000
200,000
300,000
400,000
500,000
600,000
800,000
1,000,000
or more
Concentration,
grains/scf
0.038
0.036
0.035
0.034
0.030
0.027
0.025
0.024
0.021
0.020
3.  Any volume of gases passing through and leaving an air pollution abatement
operation may be substituted for the source gas volume of the source operation
served by such air pollution abatement operation, for the purposes of section B
(2), provided such air pollution abatement operation emits no more than 40 percent
of the weight of particulate matter entering thereto; and provided that such substi-
tuted volume shall be corrected to standard conditions and to a moisture content
no greater than that of any gas  stream entering such air pollution abatement
operation.

Regulation V. REFUSE NOT TO BE BURNED IN FUEL-BURNING PLANTS

No person shall burn or cause or permit the burning of refuse in any installation
designed for the primary ournosp nf hnmine- fupl.
Regulation VI.  OPEN-BURNING RESTRICTIONS

A.  Refuse Burning Restrictions

1.  No person shall dispose of refuse by open burning, or cause, suffer,  allow,  or
permit open burning of refuse.

2.  In areas where no public or commercial refuse collection service is available by
the effective date of this regulation, the open burning of  refuse on residential
premises or of refuse originating in dwelling units on the  same premises shall not
be in violation of this regulation until  such refuse collection service becomes
available or until 3 years from the effective date of this regulation, whichever  is
sooner.
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3. Regardless of provisions of subsections A (1) and A (2) of this regulation, open
burning of refuse on residential premises of refuse originating in dwelling units on
the same premises shall not be  a violation of this regulation in areas of low popu-
lation density.  The (Head of the air pollution control agency), after consultation
with public agencies concerned with refuse collection and disposal,  shall select and
publish the specific boundaries of areas in which such open burning of refuse will
not be in voilation of this regulation. In selecting such areas, he shall use a density
of 100 dwelling units or less per square mile as an approximate definition of areas
of low population density and he shall give due consideration to the desirability of
having restrictive air pollution control regulations within the conterminous area
comprising the St. Louis metropolitan area air pollution basin. The (Head of the
air pollution control agency) shall select and publish revised boundaries, as de-
scribed above, from time to time as population density changes.
 4.  Any open burning of refuse permitted by subsection A (2) or A (3) of this regula-
 tion shall be permitted only between the hours of 10:00 a.m. and 4:00 p.m.


 B.  Prohibition of Salvage Operations by Open Burning
No person shall conduct or cause or permit the conduct of a salvage operation by
open burning.

C.  Restrictions on Open-Burning of Trade Wastes


1.  No person shall cause or permit the disposal of trade wastes by open-burning,
except as provided in subsection C  (2) of this regulation.

2.  The open-burning of trade wastes may be permitted when it can be shown by a
person that such open-burning is absolutely necessary and in the public interest.
Any person intending to engage in open-burning of trade wastes  shall file a request
to  do so with the (Head of the air pollution control agency).  The application shall
state the following:

    a.  The name, address, and telephone number of the person submitted the
       application.

    b.  The type of business or  activity involved.

    c.  A description of the proposed equipment and operating practices; the type,
       quantity, and composition of trade wastes to be burned; and the expected
       composition and amount of air contaminants to be released to the atmosphere.

    d.  The schedule of burning operations.

    e.  The exact location where open-burning will be used to dispose of trade
       waste.

    f.  Reasons why no method  other than open-burning can be used for disposal of
       trade waste.
 100
                                                                        GPO 805—O84—5

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    g. Evidence that the proposed open-burning has been approved by any fire
       department which may have jurisdiction. Upon approval of the application
       by the (Head of the air pollution control agency), the person may proceed with
       the operation without being in voilation of subsection C (1).

D. Restrictions on Open-Burning of Agricultural Wastes

1. The burning of plant life is prohibited.  Provided that the open-burning of plant
life grown on the premises in the course of any agricultural operation may be per-
mitted when it can be shown that such open-burning is necessary and that no fire
hazard will occur.  Any person intending to dispose of plant life by open-burning
shall file a request to do so with the (Head of the air  pollution control agency) on
forms provided by him.  Such form may require the provision of such information
as the (Head of the air pollution control agency) may reasonably need to determine
the air pollution aspects of the  situation and whether the request should be granted.
The applicant shall furnish the  (Head of the air pollution control agency) evidence
that the proposed open-burning has been approved by any fire department which may
have jurisdiction.  Upon approval of the application by the (Head of the air pollution
control agency) the person may proceed with the operation without being in violation
of this subsection D (1).

2. Any open-burning permitted under provisions of subsection D (1) of this regula-
tion shall be permitted only between the hours of 10:00 a.m. and 4:00 p.m. and
only at times when the actual or forecast surface wind speed, as given by the local
U.S. Weather Bureau, is 5 miles per hour or greater.

 E. Restriction on Open-Burning of  Tree Leaves


 1.  The open-burning of tree leaves in such manner  as to cause nuisance,  detriment,
 or annoyance to any person or the public is prohibited.

 2.  The open-burning of leaves  is prohibited except between the hours of 10:00 a.m.
 and 4:00 p.m.

 3. All open-burning of leaves  shall be  prohibited (5 years after this ordinance
 provision is put into effect) except in areas of low population density.  Such areas
 of low population density shall  be specified by the (Head of the air pollution agency)
 in the same manner as described in subsection A (3) of this regulation.


 NOTES CONCERNING SECTION A AND E  OF ORDINANCE  PROVISION VI
1. The City of St. Louis will not need subsections A (2), A (3), and A (4).

2. In St. Louis County, all of sections A and E should be adopted; however, pro-
vision should be made to ensure that  political subdivisions smaller than the
county are still permitted to adopt and enforce ordinances and regulations restrict-
ing open-burning of leaves and refuse, which are consistent with the county regula-
tion.  These smaller political subdivisions should be  encouraged to do so.  However,
                                                                            101

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the county should adopt the regulations to provide for action in unincorporated areas
and in areas where smaller political subdivisions fail to act.

3. In Illinois, the same principles apply to State regulations applicable in Madison
and St. Clair Counties, as stated above for  St. Louis County.  In  some respects,  this
is at variance with an existing State regulation.  The matter will have to be con-
sidered by the Illinois Air Pollution Control Board.
 Regulation VII.  INCINERATORS


 A.  General Provisions


1. This regulation shall apply to any incinerator used to dispose of refuse or other
wastes by burning and the processing of salvable material by burning.  Notwith-
standing definitions in other regulations, as used in this regulation the word refuse
includes garbage,  rubbish, trade wastes, leaves, salvable material, agricultural
wastes, and other  wastes.  The word incinerator, as used in this regulation, in-
cludes incinerators and other devices, structures,  or contrivances used to burn
refuse (as defined herein) or to process refuse by burning.

2. The burning capacity of an incinerator shall be  the manufacturer's or designer's
guaranteed maximum rate or such other rate as may be determined by the (Head
of the air pollution control agency)  in accordance with good engineering practices.
In case of conflict, the determination made by the Director of the air pollution
control agency shall govern.

3. The amount of  particulate matter emitted from  any incinerator  shall be deter-
mined according to the American Society of Mechanical  Engineers  "Power Test
Codes -PCT 27," dated 1957  and entitled "Determining Dust Concentration in  a
Gas Stream." This publication is hereby made a part of this regulation by refer-
ence.  In calculating the amount of particulate matter in stack gas, the loading
shall be adjusted to 12 percent carbon dioxide in the stack gas.  The carbon dioxide
produced by burning of any liquid or gaseous fuel in the  incinerator shall be excluded
from the calculation to 12 percent dioxide.  Emissions shall be  measured when the
incinerator is operating at its maximum capacity or at any other burning rate
during which emission of particulate matter is greater,  when expressed as grains
per standard dry cubic foot of stack gas.
B.  Provisions Applicable to Existing Incinerators
1.  No person shall cause or permit the emission of particulate matter from the
stack or chimney of any existing incinerator in excess of the following:

    a.  Incinerators with  a maximum refuse burning capacity of 200 or more pounds
        per hour, 0.2 grain of  particulate matter per standard dry cubic foot of ex-
        haust gas.
 102

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    b. All other incinerators, 0.3 grain of particulate matter per standard dry cubic
       foot of exhaust gas.

2.  No existing incinerator shall be used for the burning of refuse unless such
incinerator  is a multiple-chamber incinerator. Existing incinerators which are
not multiple chamber incinerators may be altered, modified,  or rebuilt as may be
necessary to meet this requirement.  The (Head of the air pollution control agency)
may approve any other alteration or modification to an existing incinerator if such
be found by  him to be equally effective for the purpose of air  pollution  control as a
modification or alteration which would result in a multiple-chamber incinerator.

3. The provisions of subsections B (1) and B (2) of this regulation shall not apply
to any incinerator on residential premises used to burn refuse arising from domes-
tic activities on the  same premises in areas of low population density. The (Head
of the air pollution control agency) shall  select and publish the specific boundaries
of areas in  which subsections B (1) and B (2) of this regulation do not apply.  In sel-
ecting such areas, he shall use a density of 100 dwelling units or less per square
mile as  an  approximate  definition of areas of low population density and he shall
also give due consideration to the desirability of having restrictive air pollution
control regulations within the coterminous area comprising the St.  Louis
metropolitan area air pollution basin. The (Head of the air pollution control agency)
shall select and publish  revised boundaries, in the manner described in the fore-
going, from time to time as  population density changes.

C.  Provisions Applicable to New Incinerators


1. All new  incinerators shall be multiple chamber incinerators, provided that the
(Head of the air pollution control agency) may approve any other kind of incinerator
if he finds in advance of construction or installation that such other kind of incin-
erator is equally effective for purposes of air pollution control as an approved
multiple-chamber incinerator.

2. No person shall cause or permit the  emission of particulate matter from the
stack or chimney of any new incinerator  in excess of the limitations prescribed
in subsection B (1) of this regulation.


D.  Permitted Hours of Operation

No person shall operate or cause or permit the operation of any incinerator  at anj
time other  than between the  hours of 10:00 a.m. and 4:00 p.m. This restriction
shall not apply to incinerators having a refuse burning capacity of five tons per
hour or  more.
Note:  A time schedule for compliance will need be incorporated in section B (2).
It is suggested that large incinerators be controlled first and smaller ones later,
perhaps  on  the following schedule:

            2000 pounds  per  hour and larger  12 months
            1000 - 1999 pounds per hour      18 months
             500 -  999 pounds per hour      24 months
            All                              30 months
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 Regulation VIII.  RESTRICTION OF EMISSION OF VISIBLE AIR CONTAMINANTS


 A. Restrictions Applicable to Existing Installations


 1.  No person shall discharge into the atmosphere from any single source of
 emission whatsoever any air contaminant of a shade or density equal to or darker
 than that designated as No. 2 on the Ringelmann Chart, or

 2.  Of such opacity as to obscure an observer's view to a degree equal to or greater
 than does smoke  described in subsection A (1) of this regulation, exclusive of
 water vapor.

 3.  This section shall not apply to existing incinerators.


 B. Restrictions Applicable to New Installations and All Incinerators


 1.  No person shall discharge into the atmosphere from any single source of emis-
 sion whatsoever any air  contaminant of a  shade or density equal to or darker than
 that designated as No. 1  on the  Ringelmann Chart, or

 2.  Of such opacity as to obscure an observer's view to a degree equal to or greater
 than does smoke  described in subsection B (1) of this regulation.


 C. Exceptions


 1.  A person may discharge into the atmosphere from any single source of emission
 for a period or periods aggregating not more than six minutes in any sixty minutes
 air contaminants  of a shade or  density not darker than No.  2 on the Ringelmann
 Chart.

 2.  Of such opacity as to  obscure an observer's view to a degree not greater than
 does  smoke described in subsection C  (1)  of this regulation.
 3.  Where the presence of uncombined water is the only reason for failure of an
 emission to meet the requirements of section "A" or "B" of this regulation, such
 sections shall not apply.

 4.  The provisions of section A  of this regulation shall not apply to the following,
however the most modern and effective concepts and practices shall be applied
to the control of pollutants.

    a. Transfer of molten metals

    b. Emissions from transfer ladles

    c. Coke ovens when  pushing coke from oven

    d. Water quenching of coke on discharge from ovens
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 D. Method of Measurement
 1.  The Ringelmann Chart published and described in the U.S. Bureau of Mines In-
 formation Circular 7718 or the U.S. Public Health Service Smoke Inspection Guide
 as described in the Federal Register, Title 42,  Chapter 1, Subchapter F,  Part 75
 shall be used in grading the shade or opacity of visible air contaminant emissions.
 The (Head of the air pollution control agency) may specify other means of measure-
 ment which give comparable results  or results  of greater accuracy.  The two pub-
 lications described in this subsection are hereby made a part of this regulation by
 reference.
 Regulation IX.  PREVENTING PARTICULATE MATTER FROM BECOMING
                AIR-BORNE.
 A.  No person shall cause or permit the handling or transporting or storage of any
 material in a manner which allows or may allow unnecessary amounts of particulate
 matter to become air-borne.

 B.  No person shall cause or permit a building or its appurtenances or  a road, or a
 driveway, or an open area to be constructed, used, repaired or demolished without
 applying all such reasonable measures as may be required to prevent particulate
 matter from becoming air-borne.  The (Head of the air pollution control agency)
 may require such reasonable measures as may be necessary to prevent particulate
 matter from becoming air-borne including but not limited to paving or frequent
 cleaning of roads, driveways and parking lots;  application of dust-free surfaces;
 application of water; and the planting and maintenance of vegetative ground cover.


 Regulation X.  RESTRICTION OF EMISSIONS OF SULFUR DIOXIDE
              FROM USE OF FUEL
 A.  General Provisions
1. This regulation shall apply to any installation in which fuel is burned and in which
the sulfur dioxide emission is largely due to the content of the fuel burned, and in
which the fuel is burned primarily to produce heat.

2. For purposes of this regulation, a fuel-burning installation is any single fuel-
burning furnace or boiler or other unit, device, or contrivance in which fuel is
burned or any grouping of two or more such furnaces or boilers or other units, de-
vices, or contrivances on the same premises or otherwise located in close proximity
to each other and under control of the same person.  The capacity of such installa-
tions shall be the manufacturer's or designer's guaranteed maximum heat input rate.

3. The method for determining the percent of sulfur in coal shall be that described
in ASTM D-271-64, Standard Methods of Laboratory Sampling and Analysis of Coal
and Coke or equivalent method approved by the (Head of the air pollution control
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agency). The method for determining the heat content of coal shall be described in
ASTM D-271-64, Standard Methods of Laboratory Sampling and Analysis of Coal
and Coke or D-2015-62T, Tentative Method of Test for Gross Calorific Value of
Solid Fuel by the Adiabatic Bomb Calorimeter.  All coal analyses and heat contents
are to be made on a dry basis.

     Moisture content of coal is to be determined in all cases and results reduced to
facilitate calculations of actual pollutants. The  method for determining the sulfur
content of fuel oil shall be that described in ASTM D-129-64 Standard Method of Test
for Sulfur in Petroleum Products by the Bomb Method.

     The method for determining the heat content of fuel oil shall be that described
m ASTM D-240-64 Standard Method of Test for  Heat of Combustion of Liquids by
Bomb Calorimeter or other method giving comparable results.

     The testing methods specified  in this subsection A (3) are hereby made a part
of this regulation, by reference.  A certified copy of each is on file in the office of
the (Head of the air pollution control agency).

4. The (Head of the air pollution control agency) is authorized to take samples of
any fuel by any appropriate means for the sampling of the quantity which he finds,
at any reasonable time or place, for purposes of determining compliance with this
regulation.  Where applicable, the following methods will be used.

     For coal:  ASTM: D-492-48(1958),  Standard Method of Sampling Coals Classified
               According to Ash Content

               ASTM: D-2013-65T, Tentative Method of Preparing Coal  Samples for
               Analysis

               ASTM: D-2234-65T, Tentative Method for Mechanical Sampling of
               Coal

     For oil:   ASTM: D-270-65,  Standard Method of Sampling Petroleum and
               Petroleum Products
B.  Restrictions Applicable to Fuel-Burning Installations With a Capacity of 2,000
Million or More British Thermal Units Per Hour
1. After acceptable technology has been developed, no person shall cause or permit
the emission of sulfur dioxide to the atmosphere from any fuel-burning installation
with a capacity of 2,000 million or more British thermal units per hour in an
amount greater than 2.3 pounds of sulfur dioxide per million British thermal units
of heat input to the installation.

2. After acceptable technology has been developed, no person shall burn or permit
the burning in any fuel-burning installation with a  capacity of 2,000 million or more
British thermal units per hour of any coal containing more than 1.4 percent sulfur
(analyzed on a dry basis but calculated to include normal moisture) or of any oil
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containing more than 2.0 percent sulfur unless it is shown by a person desiring to
burn a fuel containing a higher percentage of sulfur that the installation in which
the fuel is to be burned is  equipped in such manner that the  requirements of sub-
section B (1.) will be met.

3.  On and after the effective date of this regulation and until the requirements of
subsection B (1.) of this regulation are met, no fuel-burning installation with a
capacity of 2,000 million or more British thermal units per hour shall burn a fuel
or fuels having a higher average sulfur content than the fuel or fuels used in such
installation during the 12 months prior to the effective date  of this regulation based
on a comparable British thermal unit content.  For purposes of determining com-
pliance with this subsection B (3.) the average sulfur  content of all fuel or fuels
used for the 12-month period prior to the effective date of this regulation shall be
determined by averaging the sulfur content of all fuel used during such period, on
the basis of pounds of sulfur per million British thermal units heating value of the
fuel or  fuels.   This computed average sulfur content shall not be  exceeded during
any 12-month period after the effective date of this regulation, when determined on
the same averaging basis.

    Persons responsible for  installations subject to section B of this regulation
shall furnish the (Head of the air pollution control agency) such data as he may
reasonably require to determine whether an installation is being  operated in com-
pliance with this subsection B (3.) of this regulation.
 C.  Restrictions Applicable to Fuel-Burning Installations With a Capacity of Less
 than 2,000 Million British Thermal Units Per Hour
1.  During the months of December	and January	(years to be inserted by
legislative body) no person shall burn or permit the burning of any  coal containing
more than 1.4* percent sulfur or of any fuel oil containing more than 2.0 percent
sulfur, in any fuel-burning installation having a capacity of less than 2,000 million
British thermal units per hour.

2.  During the months of November and December     and January and February
(years to be inserted by legislative body to be 1 year after C (1)) no person shall
burn or permit the burning of any coal containing more than 1.4* percent sulfur or
of any fuel oil containing more than 2.0 percent sulfur  in any fuel-burning installa-
tion having a capacity of less than 2,000 million British thermal units per hour.

3.  During the months of October, November and December of	and January,
February and March of	(years to be inserted by legislative body, to be 1
year after  C (2)) no person shall burn or permit the burning of any  coal containing
more than  1.4* percent sulfur or of any fuel oil containing 2.0 percent sulfur in  a
fuel-burning installation having a capacity of less than 2,000 million British thermal
units per hour.
*Analyzed on a dry basis, but calculated to include normal moisture.
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D.  Unlawful Conduct
    It shall be unlawful for any person to import,  sell, offer for sale,  expose for
sale,  exchange, deliver or  transport for use and consumption in the (jurisdiction)
or to  use or consume in (jurisdiction) any fuel which does not meet the requirements
of this regulation.
                    NOTES PERTAINING TO REGULATION X
     A steam-electric utility air-use plan committee should be officially appointed
to determine means of meeting provision B (1) of regulation X.  Such a committee,
primarily technical in nature but with an elected public offical as a member ex-
officio, would prepare, in not over a 1-year period, a steam-electric utility air-
use plan which would indicate the alternate methods available to meet the air-use
limitations for this class of sources, and would present costs, methods, and time
schedules (not to exceed 5 years) for reaching the air-quality goals.

     The values of 2.3 pounds sulfur dioxide per million Btu's, 1.4 percent sulfur
coal, and 2.0 percent sulfur oil are based on sulfur limitations needed to reach an
air-quality goal of 0.1 ppm, 24-hour average not to be exceeded over 1 percent of
the time during any 3-month period.  As such they are themselves goals which
could be reached by other means than straight reduction of sulfur content of fuels.
For example, the source  configuration could be changed to fit the diffusion  capacity
of the air, or different fuels could be substituted in part to fit the diffusion
characteristics of the air. Since the air-use plan and percent reduction are based
on fuels currently in use  in the urbanized area, with fuel oil having a sulfur content
of 1.6 percent, the percent should not be increased until the sulfur ascribed to other
fuel has decreased proportionately.

     A 5- to  10-year period is suggested for meeting provision C fully with major
accomplishments by the  end of 5 years,  and yearly review and step-at-a-time action
by the governmental subdivisions involved. The phased approach to implementing
fuel changes is based on the air pollution characteristics of the area.  If economic,
market, labor, or other considerations indicate, it would, of course, be desirable
to have uniform requirements for the entire year.  In that way the regulatory pro-
gram would be materially simplified.


Regulation XL. INFORMATION ON SALES OF FUELS TO BE PROVIDED AND
               MAINTAINED


A.  Tickets to be Furnished and Retained


     Every delivery of coal or residual fuel oil when first delivered to  a consumer
or wholesaler  in the jurisdiction must be accompanied by a ticket prepared in
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triplicate and containing at least the name and address of the seller and the buyer;
the grade of fuel; and the source of  the fuel, which must be an approved source.
Tickets on delivery of coal shall also  show the ash content  of the coal. One copy
of each ticket shall be kept by the person delivering the fuel and be retained for 1
year; one copy is to be given to the  recipient of the fuel to be retained for 1 year;
and, upon request, within 30 days after delivery of the fuel, the delivering party
shall mail one copy to the (air pollution control agency).


B.  Lists May Be Published
     The (Head of the Air Pollution Control Agency) is authorized to publish lists
of approved sources or descriptive lists of fuels available in the area which meet
the requirements of regulations.

                    NOTE PERTAINING TO REGULATION XI

     Regulation XI is designed to supplement the type of fuel-control system now in
operation in the City of St. Louis.  It is not complete in itself.

Regulation XII.  CERTAIN COALS TO BE WASHED

A.  Certain Coals to be Washed
     It shall be unlawful for any person to import, sell, offer for sale, expose for
 sale, exchange, deliver or transport for use and consumption in the (jurisdiction)
 or to use or  consume in the (jurisdiction) any coal containing in excess of 2 per-
 cent sulfur or  12 percent ash on a dry basis as mined, before importation, sale,
 transportation, or use in the (jurisdiction) shall have been cleaned by a process
 known as washing so that it shall contain no more than 12 percent ash on a dry
 basis.  The term "washing" is meant to include purifying, cleaning, or removing
 impurities from coal by mechanical process, regardless of  cleaning medium used.

 B.  Testing Methods

     The method for determining ash and sulfur content of coal shall be as described
 in American  Society for Testing Materials D-271-64,  Standard Methods of Labora-
 tory Sampling and Analysis of Coal and Coke, or equivalent method approved by the
 (Head of the air pollution control agency) which publication is hereby made a part
 of this regulation by reference.
C.  Samples May Be Taken
    The (Head of the air pollution control agency) is authorized to take samples of
any coal at any reasonable time or place for purposes of determining compliance
with this regulation.
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D.  Exception
    This regulation shall not apply if a person proposing to use unwashed coal can
show that the emission of sulfur dioxide from the plant in which the coal is to be
burned will emit no more than 2.3  pounds of sulfur dioxide per million Btu's of
heat input to the installation and that emission of particulate matter will be no
more  than that allowed in regulation  II section A (3).
Regulation XIII.  EMISSION OF CERTAIN SETTLEABLE ACIDS AND ALKALINE
                SUBSTANCES RESTRICTED
A.  General Provisions
    This regulation shall apply to all emissions from any source or any premises.


B.  Method of Measurement
1. The fallout sampling devices used in determining compliance with this regulation
shall consist of circular glass dishes 15 centimeters in diameter.  The dishes shall
be supported on a nearly horizontal surface not larger than the dish.  The dish bot-
tom shall be at least 3 feet above  the earth or other surface on which its support
is resting.  The dish shall be coated with a solution of thymol blue, ammonia water
solution and gelatin dried to a yellow color in a vacuum oven at room temperature.
Prepared dishes shall be stored in a desiccator at 40 percent relative humidity, or
in plastic bags.

2. Fallout sampling devices shall be put in place at one or more locations up-
wind and down-wind of a premises at locations beyond the premises on which  a
source or sources are located. The devices shall be left exposed to substances
settling out of the ambient air for a period of 1 hour.  The presence of  red-colored
spots visible to the naked eye on the samplers used to measure fallout  of acidic
substances shall be construed to mean that acidic substances have settled out of the
air.  The presence of blue-colored spots visible to the naked eye on the samplers
used to measure fallout of alkaline substances shall be construed  to mean that
alkaline substances have settled out of the air.  The number of spots visible on
samplers exposed up-wind of a premises is to be subtracted from the number of
spots visible on samplers exposed down-wind of the same premises. The difference
in the number of spots, if any, shall be construed to be attributable to emissions
occurring on the premises under investigation.

3. In lieu of the test methods specified in B (1) and B (2) any other method approved
by the  (Head of the air pollution control agency) may be used.
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 C.  Emissions Restricted


 1.  No person shall cause or permit the emission from any source or premises of
 substances having acidic or alkaline properties in such manner and amounts that
 the fallout rate of acidic or alkaline substances, at any place where an adverse
 effect could occur down-wind of such source or premises greater than 1.2 times
 the fallout rate of acidic or alkaline substances up-wind of the same source or pre-
 mises, as measured in the manner described in Section B of this regulation.

 2.  No person shall cause or permit the emission from any source or premises
 of substances having alkaline properties in such manner and amounts that the fall-
 out rate of alkaline substances at any place where an adverse effect could occur
 down-wind of such source or premises is greater than 1.2 times the difference in
 the fallout rate of alkaline substances up-wind and down-wind of the same source
 or premises, as measured in the manner described in Section B of this regulation.
 Regulation XIV.  EMISSION OF CERTAIN SULFUR COMPOUNDS RESTRICTED


 A.  General Provisions


 1.  Section B of this regulation shall apply to all emissions except those in which
 both

    a.  Fuel is burned primarily to produce heat,  and

    b.  Sulfur compound emission is due primarily to the sulfur in the fuel burned.

 2.  Sections C and D shall apply to all emissions from any source or sources
 whatsoever.

 3.  The method of measuring sulfur trioxide, sulfuric acid, or any combination there-
 of in stack gases shall be:

    a.  Particulates (H2SO4 -  acid mists)

    Ref. "Atmospheric Emissions from Sulfuric Acid Manufacturing Processes."

    Public Health Service Publ. 999-AP-13. Appendix B, 61-6.

    (Modified Monsanto Company Method)*
*Secondary reference for industrial emission sampling and analysis for particulates
(sulfuric acid - acid mists), W. F. Patton, J. A. Brink "New Equipment and Tech-
niques for Sampling Chemical Process Gases." J. Air Poll. Control Assoc. 13,
162-66 (April 1963).
                                                                          Ill

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 b.  Gaseous (803 - 802)

 Ref. "Atmospheric Emissions from Sulfuric Acid Manufacturing Processes."

 Public Health Service Publ. 999-AP-13.  Appendix B, 85-7.

 (Shell Development Co. Method)*'
     The method of measuring sulfur dioxide in stack gases shall be:

     Gaseous (803 - 802)

     Ref. "Atmospheric Emissions From Sulfuric Acid Manufacturing Processes."

     Public Health Service Publ. 999-AP-13. Appendix B, page 85-7.

     (Shell Development Co. method)

     The method of measuring sulfur trioxide and sulfuric acid or any combination
 thereof suspended in the ambient atmosphere shall be:

     Particulate (H2SC>4)

     Ref. B. T.  Commins.  "Determination of Particulate Acid in Town Air."

     Analyst. 88: 364-67. (May 1963)

     The method of measuring sulfur dioxide in the ambient atmosphere shall be:

     Gaseous (802) colorimetric

     Ref. "Selected Methods for the Measurement of  Air Pollutants"

     Public Health Service Publ. No. 999-AP-ll

     "Determination of Sulfur Dioxide: West and Gaeke Method - p. Al-5 (May 1965).

     Gaseous (SO%) Conductimetric

     "ASTM Standards on Methods of Atmospheric Sampling and Analysis," 2nd
     edition, Method D 1355-60, Method A, American Society for Testing
     Materials,  1916 Race St., Philadelphia, Pa.
4.  Other test methods approved by the  (Head of the air pollution control agency)
may be used.  The publications describing methods of measurement specified in
this Section A are hereby made a part of this regulation by reference.
   *Secondary reference for industrial emission sampling and analysis for gases
  (sulfur trioxide and sulfur dioxide) "Determination of Sulfur Dioxide and Sulfur
  Trioxide in Stack Gases," Emeryville Method Ser. 4S16/59a. Anal. Dept Shell
  Development Co., Emeryville, Calif. (1959).
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 B.  Concentration of Sulfur Compounds in Emissions Restricted^

    1.  No person shall cause or permit the emission into the atmosphere from any
 existing source specified in subsection A (1) of this regulation, gases containing
 more than 2,000 parts per million by volume of sulfur dioxide or 300 parts per
 million by volume of sulfur dioxide from  any new source.

    2.  No person shall cause or permit the emission into the atmosphere from any
 source  specified in  subsection A (1) of this regulation, gases containing more than
 70 milligrams per cubic meter of sulfuric acid, sulfur trioxide, or any combination
 thereof or 35 milligrams per cubic meter of sulfuric acid, sulfur trioxide or any
 combination thereof from any new source (expressed as sulfuric acid).


 C.  Emission of Sulfur Compounds in Certain Amounts and Manner Restricted


    1.  No person shall cause or permit the emission of sulfur dioxide from any
 premises in such manner and amounts that the concentrations and frequencies
 attributable to such emission exceed those shown in the following table in the
 ambient air at any occupied place beyond the premises on which the source  is
 located.

 Concentration                 Averaging                        Maximum
  (by volume)                     time                      allowable frequency

 0.25 ppm  or more             5 minutes                     Once in any 8 hours

 0.10 ppm  or more             1 hour                        Once in any 4 days

 0.05 ppm  or more             24 hours                       Once in any 90 days

    2.  No person shall cause or permit the emission of sulfuric acid, sulfur trioxide,
 or any combination  thereof from  any premises in such manner and amounts that the
 concentrations  and frequencies attributable to  such emission exceed those shown in
 the following table in the ambient air at any place where people live, work or con-
 gregate beyond the premises  on which the source is located.
       Concentration*
of sulfuric acid or sulfur
trioxide or any combination     Averaging                    Maximum
thereof	      time                         allowable frequency

0.03 nig/m^ or more            30 minutes or more           Once in any 48 hours

0.01 mg/m^ or more            24 hours                      Once in any 90 days


    3. No person shall cause or permit the emission of hydrogen sulfide from any
premises  in such manner and amounts that the concentrations attributable to such

*Milligrams per cubic meter at standard conditions, measured and calculated as
sulfuric acid.
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emissions in the ambient air at any occupied place beyond the premises on which the
source is located exceed 0.03 part per million by volume for any averaging period
of 30 or more minutes on more than two occasions in any 5 days.
 D.  More Restrictive Limitation to Apply

     In any situation in which more than one requirement of this regulation is appli-
 cable, the most restrictive provision shall govern.
Regulation XV.  ADDITIONAL AIR-QUALITY CONTROL MEASURES MAY BE RE-
                QUIRED WHEN SOURCES ARE CLUSTERED IN A SMALL LAND
                AREA
 A.  Areas to Which This Regulation Applies


     1.  This regulation shall apply to areas in which there are one or more existing
 major sources and/or proposed new major sources of particulate matter in any
 circular area with a diameter of 2 miles from which the sum of particulate emis-
 sions allowed from major sources by regulations of general application are or
 would be greater than 2,000 tons per year or 500 pounds per hour.  For purposes
 of this regulation, "major sources" include coal-burning units with a heat input
 capacity of  100 million or more Btu's per hour, refuse-burning plants with a refuse-
 burning capacity of 5 tons or more per hour, and industrial processes having a pro-
 cess weight rate of 10 tons or more per hour.


    2. This regulation shall apply in areas in which there are one or more existing
major sources and/or proposed new major sources of sulfur dioxide in any cir-
cular area with a diameter of 2 miles from which the sum of sulfur dioxide emis-
sions from major sources allowed by regulations of general application  are or
would be greater than 1,000 tons for any consecutive 3 months or 1,000 pounds per hour.
For purposes of this regulation, "Major sources" include coal- or oil-burning
units with a heat input of 100 million or more Btu's per  hour and industrial pro-
cesses which emit 1 ton or more of sulfur dioxide per day.
B.  (Agency) May Prescribe More Restrictive Air-Quality Control Measures
    1. In areas where this regulation applies, as specified in Section A herein,
the (air pollution control agency) may prescribe air-quality  control requirements
that are more restrictive and more extensive than provided in regulations of
general application.  Such measures shall provide for air-resource and land-use
management within these areas for the purpose of obtaining the  best feasible air-
quality in the particular area and for the (jurisdiction) as a whole,  consistent with
air-quality standards prescribed by regulations or otherwise.
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     The air-quality control measures prescribed by the (Head of the air pollution
control agency) may include, without limiting the same, additional reduction of
emissions, modifications of fuel or process material, specified operating time
schedules, use of tall stacks,  relocation of sources, and other measures.  In the
event that a proposed new installation will cause the sum of allowable emissions
to exceed those given in Section A herein and thus make this regulation apply,
only the proposed new plant shall be  subject to more restrictive or extensive re-
quirements.  (These requirements will be issued as a special use permit  issued
by the appropriate legislative procedure in the jurisdiction taking into account
items in C (a)).

     2.  In considering the need for the nature of any air-quality  control measures
to be imposed which are more restrictive or more extensive than those provided
in regulations of general application  the (Head of the air pollution control agency)
shall consider, among others,  such matters as: (a) dispersion of emissions; (b)
ability of the atmosphere to disperse pollutants; (c) existing and anticipated land-
use; (d) stack heights; (e) existing and anticipated air-quality;  (f) existing and
anticipated emissions; (g) expected service life of sources; (h) cost of additional
control measures; and (i) feasibility  and impact of various possible ways  to pre-
serve or improve air-quality.  To the extent feasible, the (Head  of the air pollution
control agency) shall confer and work with all persons who would be affected by
any special air-quality control measures.

                    NOTE PERTAINING TO REGULATION XV

     The air pollution regulations of (jurisdiction) are designed to achieve certain
air-quality in the general atmosphere.  In most cases, the generally applicable
emission control and other regulations are adequate for these purposes.  However,
in a few cases where one or more pollution sources are, or will be,  located in a
relatively small area, compliance with regulations of general application  may not
result in satisfactory air-quality.  Since it is not feasible to write  regulations
which will be suitable in each such special case, this regulation  is to provide a
formalized procedure for arriving at any necessary more restrictive air-quality
control measures  needed to ensure satisfactory air-quality in the most equitable
manner possible.
Regulation XVI. VARIANCES
A.  Any person subject to the air pollution regulations of the (air pollution control
agency) may apply to the (Head of the air pollution control agency) for a variance
from such regulations or any order of the (Head of the air pollution control agency).
The application shall be filed on forms provided by the (Head of the air pollution
control agency) who may require submission of such information as he may reason-
ably require to bring out all  pertinent facts in the case.  The  (Head of the air pol-
lution control  agency)  shall examine the application and all pertinent facts relating
thereto and promptly transmit the application along with his findings, recommenda-
tions, and records of the matter to the (Body authorized to  grant variances).  The
(Body authorized to grant variances), within 20 days, shall  conduct a hearing on
the matter.
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    The (Head of the air pollution control agency) may also request and he shall be
granted a hearing before the (Body authorized to grant variances) on any matter
involving a variance.

B.  The (Body authorized to grant variances) shall serve notice of the time and
place of a hearing on a variance upon the applicant, if any, and upon the  (Head of
the air pollution control agency), not less than 10 days prior to such hearing.

C.  The (Body authorized to grant variances) may grant a variance from any re-
gulation or order of the (Head of the air pollution control agency) if it finds that
compliance with the  regulation or order from which a variance is sought would
produce serious hardship without a corresponding benefit or advantage to the
people.  The (Body authorized to grant variances) shall exercise  a wide discretion
in weighing the equities involved in each case.

D.  The (Body authorized to grant variances) may  prescribe other and different
requirements not more onerous, applicable to any situation for which a variance is
sought.  However, no variance may permit or authorize the maintenance of a
nuisance, or a danger to public health or safety.

E.  Variances shall be granted by the (air pollution agency) for such periods of
time and upon such conditions as permitted by applicable laws. Such variance may
be renewed provided a request for renewal is submitted by the applicant to the
(Head of the air pollution control agency). If the (Head of the air  pollution control
agency) approves of  the renewal, no hearing need be held.   If he disapproves, the
(Body authorized to grant variances) shall conduct a new hearing. At such hearing,
the (Body authorized to grant variances) shall decide whether the variance should
be renewed, revoked, or modified.

F.  The (Body authorized to grant variances) may, after a hearing, revoke or modify
any variance it has issued, at  any time.
 Regulation XVII.  CONTROL OF ODORS IN THE AMBIENT AIR


 A. No person shall emit odorous matter such as to cause an "objectionable" odor:

     1. On or adjacent to residential, recreational,  institutional, retail, sales,
 hotel or educational premises.

     2. On or adjacent to industrial premises when  air containing such odorous
 matter is  diluted with 20 or more volumes of odor-free air.

     3. On or adjacent to premises other than in 1 and 2 when air containing such
 odorous matter is diluted with four or more volumes of odor-free air.

 B. The  above requirement shall apply only to "objectionable"  odors.  An odor
 will be deemed  objectionable when 15 percent or more of the people exposed to it
 believe it  to be  objectionable in usual places of occupancy. Sample size to be at
 least 20 people  or 75 percent of those exposed if fewer than 20 people are exposed.
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Regulation XVIII.  CONTROL OF ODORS FROM PROCESSING OF ANIMAL MATTER


A.  General

     1.  For purposes of this regulation the word "reduction" is defined as any
heated process, including rendering,  cooking, drying, dehydrating, digesting,
evaporating, and protein concentrating.

     2.  The provisions of this regulation shall not apply to any device, machine,
equipment, or other contrivance used exclusively for the processing of food for
human consumption.

B.  Odor Control Equipment Required on Reduction Processes

     1.  No person shall operate or use  any device, machine, equipment or other
contrivance for the reduction of animal matter unless all gases, vapors, and gas-
entrained effluents from such facility are incinerated at a temperature of not less
than 1,200 degrees Fahrenheit for a period of not less than 0.3 second, or  pro-
cessed  in such manner as determined by the (Head of the air pollution control
agency) to be equally or more effective for the purpose of air pollution control.

     A person incinerating or processing gases, vapors or gas-entrained effluents
pursuant to this rule shall provide, properly install and maintain, in good working
order and in operation, devices as  specified  by the (Head of the air pollution control
agency) for indicating temperature, pressure, or  other operating conditions.

C.  Other Odor Control Measures Required


     1.  Effective devices and/or measures shall be installed and operated such that
no vent, exhaust pipe, blowoff pipe or opening of any kind shall discharge into the
outdoor air any odorous matter, vapors, gases, dusts or any combination thereof
which create odors or other nuisances in the neighborhood of the plant.

     2. Odor-producing materials shall be confined and handled in a manner such
that odors produced within or outside the plant from such materials are  controlled.
Accumulation of odor-producing materials resulting from spillage or other escape
shall not be permitted.

     3. Odor-bearing gases, vapors, fumes, or dusts arising from materials in pro-
cess shall be confined at the point of  origin so as to prevent liberation of odorous
matter into the work room,  and the confined  gases, vapors, fumes, or dusts shall
be treated before discharge to the atmosphere, as required in subsection C (1).


D.  Enclosure of Building May be Required


    When dust, fumes, gases, mist, odorous  matter, vapors,  or any  combination
thereof escape  from a building used for processing of animal matter in such
manner  and amount as to cause a nuisance or to violate the odor control  regulation
of the (jurisdiction), the (Head of the air pollution control agency)  may order that
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 the building or buildings in which processing, handling and storage are done be
 tightly closed and ventilated in such a way that all air and gases and air - or gas-
 borne material leaving the building are treated by incineration  or other effective
 means for removal or destruction of odorous matter or other air contaminants be-
 fore discharge to the open air.


 Regulation XIX.  CONTROL OF HYDROGEN SULFIDE EMISSIONS


     No person shall emit hydrogen sulfide in quantities which will  cause the
 following concentrations to be exceeded at any place outside the premises where
 emitted:

     1.  0.05 ppm 1/2-hour average not to be exceeded over  two times per  year.

     2.  0.03 ppm 1/2-hour average not to be exceeded over two times in any
 5-consecutive-day period.

 Regulation XX.  EMISSION OF VISIBLE AIR CONTAMINANTS FROM INTERNAL
                COMBUSTION ENGINES

     No person shall cause or permit the emission of visible air contaminants for
 the internal combustion engine of:

     1.  Portable or stationary equipment for longer than 10  consecutive seconds;
 or

     2.  A motor vehicle while the vehicle is stationary for longer than 10 seconds;
 or

     3.  A motor vehicle after the vehicle has moved more than  100 yards from a
 place where the vehicle was stationary.
 Regulation XXI. APPROVAL OF PLANNED INSTALLATIONS, LAND-USE PLANS,
                AND ZONING REGULATIONS REQUIRED
 A.  Review of Plans and Approval


     1.  The (building department or other office responsible) shall not issue a per-
 mit for the erection, construction, reconstruction, alteration or occupancy of any
 building or structure when the plans and specifications for such structure or
 occupancy include any fuel-burning or refuse-burning device, or any chimney or
 smoke stack, or the occupancy of any building for industrial purposes, until such
 plans and specifications have been submitted to the (Head of the air pollution con-
 trol agency) and approved by him within 30 days as making adequate provisions  for
 meeting the requirements of this ordinance. If the (Head of the air pollution con-
 trol agency) does not submit his recommendations to the (building department or
 other office responsible) within 30 days, the plans or specifications shall be deemed
 approved.
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 B.  Planning Agency Land-Use Plans - Preparation and Approval


     1.  Planning agencies will, in preparing land-use plans, obtain and use infor-
 mation supplied by the (air pollution agency) concerning:

     a.  air-quality

     b.  air pollutant emissions

     c.  air pollutant meteorology

     d.  air-quality goals

     e.  air pollution effects

     2.  The (air pollution agency)  will review all land-use plans prior to formal
 adoption and prepare recommendations that must be adequately considered in the
 plan adoption process.


 C.  Zoning Agency Regulations - Preparation and Approval

     1.  Zoning control agencies will, in preparing regulations, obtain and use infor-
 mation supplied by the (air pollution agency) concerning:

     a.  air-quality

     b.  air pollutant emissions

     c.  air pollution meteorology

     d. air-quality goals.

     e. air pollution effects

     2. The  (air pollution agency)  will review all zoning regulations prior to formal
 adoption and prepare recommendations  that must be adequately considered in the
 regulation adoption process.


 Regulation XXII. AIR POLLUTION NUISANCES PROHIBITED


A.  No person shall cause or permit the discharge from any source whatsoever such
quantities of air contaminants or other material which cause injury,  detriment,
nuisance, or annoyance to any considerable number  of persons or to  the public'
or which endanger the comfort, repose, health,  or safety of any such persons or
the public or which cause or have a tendency to cause injury or damage to business
or property.

B.  Nothing in any other regulation concerning emission of  air contaminants or any
other regulation relating to air pollution shall in any manner be construed as
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authorizing or legalizing the creation or maintenance of a nuisance as described
in section A of this regulation.
Regulation XXIII. MEASUREMENT OF EMISSIONS OF AIR CONTAMINANTS
A.  Responsible Persons to Have Tests Made

    The (Head of the air pollution control agency) may require any person respon-
sible for emission of air contaminants to make or have made tests to determine the
emission of air contaminants from any source, whenever the (Head of the air
pollution control agency) has reason to believe that an emission in excess of that
allowed by an air pollution regulation of the (air pollution control agency) is occur-
ing. The (Head of the air pollution control agency) may specify testing methods to
be used, in accordance with good professional practice.  The (Head of the air pol-
lution control agency) may observe the testing.  All tests shall be  conducted by
reputable, qualified personnel.  The  (Head of the air pollution control agency) shall
be given a copy of the test results in writing and signed by the person responsible
for the tests.
 B.  (Head of the Air Pollution Control Agency) May Make Tests


     The (Head of the air pollution control agency) may conduct tests of emissions
 of air contaminants from any source.  Upon request of the (Head of the air pollution
 control agency), the person responsible for the source to be tested shall provide
 necessary holes in stacks or ducts and such other safe and proper sampling and
 testing facilities, exclusive of instruments and sensing devices as may be necessary
 for proper determination of the emission of air contaminants.


 Regulation XXIV.  SUBMISSION OF EMISSION INFORMATION - AUTHORITY


     The (Head of the air pollution agency) may require the submission of air
pollutant information from  any or all potential sources for purposes of maintain-
ing an air pollutant emission inventory.


 Regulation XXV.  REQUIREMENTS FOR CONSTRUCTION OF NEW GASOLINE
                 STORAGE FACILITIES


 A.  General


     1.   For purposes of this regulation,  the term "gasoline"  is defined as petroleum
distillate having a Reid vapor pressure of 4 pounds or greater.

     2.   For purposes of this regulation, the term "submerged fill pipe" is defined
 as any fill pipe the discharge opening of which is  entirely submerged when the
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liquid level is 6 inches above the bottom of the tank.  "Submerged fill pipe" when
applied to a tank which is loaded from the side is defined as any fill pipe the dis-
charge opening of which  is entirely submerged when the liquid level is 18 inches
above the bottom of the tank.
B.  Petroleum Storage Tanks


    1. After the effective date of this regulation, no person shall build or install or
permit the building or installation of any stationary tank, reservior or other con-
tainer of more than 40,000 gallons capacity which will or might be used for  storage
of any petroleum distillate having a  vapor pressure of 1.5 pounds per square inch
absolute  or greater under actual storage conditions, unless such tank,  reservoir or
other container is to be a pressure tank capable of maintaining working pressures
sufficient at all times to prevent hydrocarbon vapor or gas loss to the  atmosphere
or is  designed, and will be built and equipped with one of the following  vapor loss
control devices:

    a. A floating roof,  consisting of a pontoon-type or double-deck-type roof, which
       will rest on the surface of the liquid contents and be equipped with a
       closure seal,  or seals, to close the space between the roof edge and tank
       wall.  The control equipment to be provided for in this subsection B (1) shall
       not be permitted if the gasoline or petroleum distillate to be stored  will
       have a vapor pressure of 12 pounds per square inch absolute or greater
       under actual storage conditions.

    b. All tank gauging and sampling devices  shall be built so as to be gas-tight
       except when gauging or sampling is to  take place.

    c. Other equipment or means of equal efficiency for purposes of air pollution
       control as may be approved  by the (Head of the air pollution control
       agency).
C.  Submerged Fill Pipes Required

1.  After the effective date of this regulation, no person shall build or install or per-
mit the building or installation of a stationary gasoline storage tank with a capacity
:>f 250 gallons or more unless such tank is equipped with a permanent submerged
fill pipe or is a pressure tank as described in subsection B (1) of this regulation,
or is fitted with a vapor  recovery system as described in subsection B (1) (a) of
this regulation.

Regulation XXVI.  ENTRY ONTO PREMISES - AUTHORITY

     In the general performance of its duties the (air pollution agency and its
authorized personnel) are hereby authorized to  enter at all reasonable hours upon
and into any buildings, establishments, premises, and enclosures in or from which
they have reason to believe the provisions of this (ordinance) are being violated, to
inspect or examine such buildings, establishments, premises or enclosures, and to
collect and preserve  evidence of all facts as to  violations of this (ordinance).
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 Regulation XXVII.  CIRCUMVENTION
   No person shall cause or permit the installation or use of any device or any
 means which without resulting in reduction in the total amount of air contaminant
 emitted, conceals or dilutes an emission of air contaminant which would otherwise
 violate an air pollution control regulation.  This regulation shall not apply when the
 only violation involved is violation of a regulation based on concentration  or presence
 of one or more air contaminants at locations beyond the premises on which a source
 or sources are located.

 Note:  Operating Permit Systems and Registration Systems

     The legislative body enacting ordinances  should consider the merits of permit
 and registration systems for program administration and select the system that
 meets the jurisdiction's program needs and objectives.
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 USE OF SUGGESTED ORDINANCE PROVISIONS IN APPENDIX B AFTER RELEASE
            OF DRAFT REPORT ON MAY 30, 1966, UNTIL JULY 1967
     Since the release of the draft of Volume VIII of the Interstate Air Pollution
 Study, the suggested ordinance provisions have been put to important use.  They
 have undergone some modifications in this process to relate specifically to the
 realities of the jurisdictions applying them.  When thought of in terms of reaching
 the air quality goals, some of these modifications have  strengthened the ordinance
 provisions and some have not. The actions taken have all been carried on indepen-
 dently by the responsible agencies and political jurisdictions and therefore are
 indicative of both the positions and capabilities of local governments in fashioning
 their own ordinances.


     For the purpose of brevity, only major changes to the suggested ordinance
 provisions given in Appendix B are reported.  Minor additions, deletions,  and
 alterations  are not covered.
 EAST-WEST GATEWAY COORDINATING COUNCIL ACTION
     The East-West Gateway Coordinating Council was formed in the St. Louis area
 during the time that the Interstate Air Pollution Study project was in operation. Its
 membership is  composed of six elected officials from the Illinois part and six from
 the Missouri part of the St. Louis Standard Metropolitan Statistical Area.  A 13th
 member represents the Bi-State Development Agency.  The Council's purpose is to
 deal with regional problems such as transportation.  The Council has an executive
 secretary with an office in East St. Louis, Illinois.

    The Interstate Air Pollution Study project agreement states that the project
Executive Committee members and their agencies "recognize the need for coordina-
tion and continuity of air pollution activities and indicate their intention of meeting
thic need..until such time as a successor body might be formed." As a result of
this project agreement statement, agencies and individuals in the St. Louis area
knew that  the project Executive Committee was looking for a permanent "home" for
its regional activities.   For this reason, it was quite logical for the East-West
Gateway Coordinating Council members to informally indicate an interest in pro-
viding  such a "home" and for a letter to be sent from the study  Executive Committee
to the Council formally  asking its interest and intent. After considerable deliberation
the Council formally offered to  provide a temporary  base for the project Executive
Committee. In addition, in July 1966,  the  Council decided to hold public hearing on
the suggested ordinance provisions (Appendix B). These hearings were scheduled
for September and October.  All 13 of the  Council's members formed the hearing
board which was chaired by the Council's  executive secretary.  The hearings
lasted  a full 3 days and took place in St. Louis, Missouri; Edwardsville, Illinois;
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and Clayton, Missouri.  The hearings publicized the study report and the recommen-
dations and findings widely. Although they concentrated on controversial aspects
and the discussion was limited largely to the suggested ordinance provisions, they
uncovered a considerable area of truth that the technically oriented project
Executive Committee could not bring forth. Following these three hearings and
some additional meetings, the Technical Representatives of the Governmental
Agencies of the Interstate Air Pollution Study revised the suggested ordinance
provisions, and the Industrial Waste Control  Council,  an industry sponsored  group,
wrote a set of ordinance provisions. With these two sets of ordinance  provisions
at their disposal, the  East-West Gateway  Coordinating Council approved a model
ordinance.  Later the City of St. Louis,  St. Louis County, enacted ordinances and
the states of Illinois  and Missouri adopted rules and regulations to  control air
pollution in the portions of the area under their jurisdiction.

     The two sets of  ordinance provisions, the model ordinance, the two ordinances
and two sets of rules and regulations are discussed in the following sections in re-
spect to their differences from the ordinance provisions in the first part of the
Appendix=

REVISED PROPOSAL BY TECHNICAL  REPRESENTATIVES OF GOVERNMENTAL
AGENCIES OF INTERSTATE AIR POLLUTION STUDY
     The revised proposal was prepared on November 22, 1966, and included the
following changes:
Regulation II - Maximum Allowable Emission of Particulate Matter from Fuel Burn-
ing Equipment Used for Indirect Heating
    This regulation is based on the American Society of Mechanical Engineers pub-
lication "Recommended Guide  for the Control of Dust Emissions - Combustion for
Indirect Heat Exchangers" (ASME  Standard No. APS-1;  1966); however, the following
modifications were included:

    1. The stack height as determined by the ASME method is reduced by the differ-
ence in elevation, if any, between the elevation of the ground at the base of the stack
or stacks and any other point having a higher elevation and lying within 1 mile of the
stack. A stack height of 50 feet is used to determine the maximum allowable
emission rate for installations having stacks less then 50 feet high.

    2. A maximum allowable emission of 0.6 pound of particulate matter  per million
Btu of heat input is used in place of the ASME proposal of 0.8 pound of particulate
matter per million Btu of heat input.

    3.  All installations having a total heat input rate of 5 million Btu or more per
hour  must be equipped with particulate matter emission control equipment that will
remove at least 85 percent of  the particulate matter in the gases arising from the
installation.
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 Regulation X - Restrictions of Emissions of Sulfur  Dioxide from Use of Fuel

      Under Section C, No. 1, the time periods December 1967 and January  1968
 were added.  The sulfur limit for coal was changed from 1.4 to 2.25 percent.

      Under Section C, No. 2, the time periods November and December 1968 and
 January and February 1969 were  added. The sulfur limit for coal was changed
 from 1.4 to 2.25 percent.

      Under Section C, No. 3, the time periods October -  December 1969 and
 January - March 1970 were added.  The sulfur limit for coal was changed  from
 1.4 to 2.25 percent.
 Regulation XIV - Emission of Certain Sulfur Compounds Restricted

      Under Section B, No. 1, the sulfur dioxide emission limitation for new sources
 was changed from 300 to 500 ppm.

 Regulation XIX - Emission of Visible Air Contaminants from Motor Vehicles

     This regulation was changed so as to prohibit the emission of visible air con-
 taminants from  motor vehicles of  a shade or density equal to or darker than that
 designated as No. 1 on the Ringelmann chart, or of such opacity  as to obsure an
 observer's view to an equivalent degree.  Emissions of visible air contaminants
 having a shade or density not darker than that designated as No. 2 on the Ringelmann
 Chart or  of such opacity as to obsure an observer's view to an equivalent degree is
 permitted for a  period not to exceed 5 seconds.
 INDUSTRIAL WASTE CONTROL COUNCIL PROPOSAL FOR A CLEAN AIR PROGRAM
    The Industrial Waste Control Council presented its proposed program on No-
vember 15, 1966. The proposal was divided into two parts. The first part contained
administrative provisions for both Missouri and Illinois, and the second part con-
tained the regulations. Regulations I, XVI, XXI, XXII, XXIII, and XXV of Appendix B, which
are administrative in  nature, were included in the Administrative Section.  The major
areas of difference in the proposed regulations and those of Appendix B are as follows:
Regulation II - Maximum Allowable Emission of Particulate Matter from Fuel-Burn-
ing Equipment Used for Indirect Heating


    The ASME Standard APS-1 "Recommended Guide for the Control of Dust Emis-
sions -- Combustion for Indirect Heat Exchangers" was adopted for this regulation
with no recommended modifications. Figure  2 of that publication establishes the
maximum allowable emission levels.
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Regulation IV - Restriction of Emission of Particulate Matter from Industrial
Processes"


    The same process weight limitation as given in Appendix B is used; however,
certain processes are excluded.  A maximum emission of particulate matter from
any source of 0.40 grain per standard cubic foot is permitted instead of the 0.30
grain per standard cubic foot given in Appendix B.

    The processes excluded from the process weight limitation are as follows:

    1.  Catalytic crackers: Existing installations having collection equipment
with an overall collection efficiency of 99  percent or better.

    2.  Cement plants:  All installations are  allowed a maximum emission of
0.10 grain of particulate matter per standard cubic foot.

    3.  Existing foundry cupolas and foundry open-hearth furnaces:  All existing
foundry cupolas  and foundry open-hearth furnaces must be equipped with gas-cleaning
devices that will meet the following emission limitations:
          Process Weight,                         Maximum allowable
               Ib/hr	                          discharage, Ib/hr

               1,000                                     3.05
               2,000                                     4.70
               3,000                                     6.35
               4,000                                     8.00
               5,000                                     9.65
               6,000                                    11.30
               7,000                                    12.90
               8,000                                    14.30
               9,000                                    15.50
             10,000                                    16.65
             12,000                                    18.70
             16,000                                    21.60
             18,000                                    22.80
             20,000                                    24.00
             30,000                                    30.00
             40,000                                    36.00
             50,000                                    42.00
             60,000                                    48.00
             70,000                                    49.00
             80,000                                    50.50
             90,000                                    51.60
            100,000                                    52.60

     4.  Blast furnaces:  A maximum allowable emission for gases after burning is
0.10 grain of particulate matter per standard cubic foot.  A maximum allowable
emission for excess gas is 0.25 grain of particulate matter per standard cubic  foot,
and burning of  the gases is required before being discharged.
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     5.  By-product coke plants:  Smoke emitted during charging of the ovens or
 pushing coke from the ovens is allowed to exceed No. 2 of the Ringelmann chart
 for a period or periods aggregating not more than 20 minutes in any 60-minute
 period.  Smoke from the doors and frames of the ovens must not exceed No. 2 of
 the Ringelmann chart.

     6.  Continuous ferrous cupolas:  Those installations constructed subsequent to
 the enactment of the  rules and regulations are limited to a maximum emission rate
 of 0.20 grain per standard cubic  foot.

     7.  Sintering plants, open-hearth furnaces, electric furnaces, and basic oxygen
 furnaces:  The particulate matter in the discharge gases must not exceed 0.10
 grain per standard cubic foot.
 Regulation VII - Incinerators

     A maximum emission rate of 0.30 grain of particulate matter per standard dry
 cubic foot of exhaust gases for all sizes of incinerators is permitted.
 Regulation VIII - Restriction of Emission of Visible Air Contaminants

     No fuel-burning installation is allowed to discharge black smoke of a shade or
 density equal to or darker than that designated as No. 2 on the Ringelmann  chart.
 Black smoke darker than No. 2 is allowed for a period or periods aggregating not
 more than 6 minutes in any 60-minute period.

     An equivalent opacity limitation is not included.
Regulation X - Restriction of Emissions of Sulfur Dioxide from Use of Fuel

    All existing and new combustion installations must burn or be designed to burn
the lowest sulfur content fuel that is reasonably available.  No  specific limitations
are given, and factors such as price, firmness of supply, extent of existing pollution,
and assurance of supply under adverse weather and natural disaster conditions
determine whether the fuel is reasonably available.
Regulation XIII - Emission of Certain Settleable Acids and Alkaline Substances
Restricted

    This regulation is not included.
Regulation XVIII - Control of Odors from Processing of Animal Matter

    The Industrial Waste Control Council omitted this regulation because it is
covered under the general odor regulation, "Control of Odors in the Ambient Air."
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 Regulation XIX - Emission of Visible Air Contaminants from Motor Vehicles

     This regulation is not included.
 Regulation XX - Approval of Planned Installations, Land-Use Plans, and Zoning
 Regulations Required

     This regulation is not included.
 EAST-WEST GATEWAY COORDINATING COUNCIL MODEL ORDINANCE

     The East-West Gateway Coordinating Council adopted a model ordinance on
 January 11, 1967.  This model was patterned around the suggested ordinance pro-
 visions of Appendix B; however, several changes were made on the basis of the
 revised proposal by the technical representatives of the governmental agencies of
 the Interstate Air Pollution Study and the Industrial Waste Control Council proposal.
 Regulation II - Maximum Allowable Emission of Particulate Matter from Fuel
 Burning

     The model ordinance includes the same changes as were given above under the
 revised proposal by the technical representatives of the governmental agencies of
 the Interstate Air Pollution Study.
 Regulation IV - Restriction of Emission of Particulate Matter from Industrial
 Processes

     The model ordinance includes the same changes as were given above under the
 Industrial Waste Control Council proposal, except that continuous ferrous cupolas
 are not excluded from the process weight limitation.
 Regulation VIII - Restriction of Emission of Visible Air Contaminants

     The Ringelmann limitations for black smoke are the same as those in Appendix
 B; however, they shall not apply to metallurgical fume emissions or measurement
 of the opacity of noncombustion process emissions. Equivalent opacity units based
 on the Ringelmann chart can only be used as a method of inspection by the control
 agency.

 Regulation X - Restriction of Emissions of Sulfur Dioxide from Use of Fuel


    All fuel  burning installations are required to burn coal having a maximum sul-
fur content of 3.3 percent and fuel oil having a maximum sulfur content of 2.5 percent.
The sulfur content of fuel oil is to be reduced by 0.1 percent each year beginning on
January 1, 1968, until January 1, 1972,  when it will remain at 2.0 percent sulfur.
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Regulation XIV - Emission of Certain Sulfur Compounds Restricted

     Existing sources are limited to a maximum emission of sulfur dioxide of 2,000
ppm by volume. The 500 ppm of sulfur dioxide by volume restriction for new plants
may be adopted after the technology develops and this limit is demonstrated in the
United States.  The sulfuric acid or sulfur trioxide (expressed as sulfuric acid)
emissions are limited to 70 milligrams per cubic  meter for the burning of sulfur
and 200 milligrams per cubic meter from any other process source.

Regulation XIX - Emission of Visible Air Contaminants from Internal Combustion
Engines

     This regulation was changed to read the same as the revised proposal of the
technical representatives of the governmental agencies of the Interstate Air Pol-
lution Studies.
MISSOURI AIR CONSERVATION COMMISSION RULES AND REGULATIONS FOR
ST. LOUIS METROPOLITAN AREA~

    On February 22,  1967 the Commission adopted rules and regulations that con-
tained essentially the same provisions as the revised proposal of the technical
representatives of the governmental agencies of the Interstate Air Pollution Study
described earlier.  The air-quality goals given in Appendix B were adopted as air
quality standards.  Minor modifications were as follows:


Regulation II - Maximum Allowable Emission of Particulate Matter from Fuel
Burning Equipment Used for Indirect Heating.

    The stack height  is defined as the  upward vertical distance from an elevation
600 feet above mean sea level to the location at which gases passing through the
stack enter the atmosphere.

    In addition to the modified ASME Standard and the minimum collection  effi-
ciency of 85 percent,  the Commission also adopted  a curve similar to the one pro-
posed in Appendix B,  which does not give credit for stack height. The  Commission's
curve stops  at 0.18 pound for each million Btu input for equipment having a capacity
rating of 10,000 million Btu or more instead of 0.20 pound as proposed in Appendix
B.  When two or more of the Missouri  provisions are applicable in a particular
case,  the one resulting in the lowest emission rate  shall apply.
Regulation IV - Restrictions of Emissions of Particulate Matter From Industrial
Processes

    A paragraph included on grey iron jobbing cupolas requires them to be equipped
with control equipment and so operated as to remove 85 percent by weight of all the
Particulate matter in the cupola discharge gases or to release not more than 0.40
grain of particulate matter per standard  cubic foot of discharge gas, whichever is
more stringent.  Incineration of all cupola discharge gases at 1200°F for at least
0.3 second is also  required.
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 Regulation X - Restriction of Emissions of Sulfur Dioxide from Use of Fuel


    The sulfur content of coal is limited to 2.0 percent for installations having a
capacity of less than 2,000 million Btu heat input.  Installations having a capacity of
2,000 million or more Btu per hour must burn fuel containing no more than 2.3
pounds of sulfur dioxide per million Btu heat input 3 years after the effective date
of the regulations.  Installations having a capacity of less than 2,000 million Btu
per hour must burn 2.0 percent sulfur fuel during the following periods:

              1. December 1968 and January 1969.
              2. November 1960 and February 1970.
              3. October 1970 and March 1971 and every year thereafter.


STATE  OF ILLINOIS AIR POLLUTION CONTROL BOARD RULES AND REGULA-
TIONS GOVERNING CONTROL OF AIR POLLUTION

    Rules and regulations were  adopted on March 26, 1965 and amended on March
30, 1967, to control smoke and particulate matter in the State.  No provisions were
included for the control of gases.

    Since the Illinois  Board did  not follow the format or content of the suggested
ordinance provisions, a brief description of that agencies rules and regulations
is  given below.
Chapter I - Definitions

    This chapter gives 52 definitions of terms used in the rules and regulations.


Chapter II - Rules for Controlling Existing Pollution

    This chapter requires all manufacturers in the State to submit a letter of intent
to the State Air Pollution Control Board.  The letter must supply complete informa-
tion on process equipment, fuel combustion, and emissions to the atmosphere.  An
air-contaminant emission-reduction program must also be filed with the Board.
The intent of this requirement is to schedule over a reasonable period of time either
an installation of gas-cleaning devices and/or the replacement and/or  alteration of
specified facilities so that emissions of air contaminants are reduced to the levels
required by the Regulations.  The Technical Secretary will review the  programs
and judge whether they are adequate and reasonable.

    Most existing equipment located inside the Standard Metropolitan Statistical
Areas (SMSA) must comply with the emission standards for new equipment within
60 days after the effective date of the Regulations or else submit an acceptable
emission reduction program.

    Most existing equipment located outside the SMSA must comply with the emis-
sion standards for new equipment 12 months after the effective date  of the Regula-
tions or else submit an acceptable emission reduction program within  6 months of
the effective date of the Regulations.
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    The processes excluded from these requirements are as follows:

    1.  Catalytic cracking units: The emission standards for new equipment will
not apply if gas cleaning devices have an overall efficiency of 99.7 percent.

    2.  Blast furnaces:   This limitation is the same as that proposed by the
Industrial Waste Control Council and the East-West Gateway Coordinating Council.

    3.  Combustion for indirect heating outside SMSA:  These installations must
meet  the ASME Standard No. APS-1, "Recommended Guide for the Control of Dust
Emission - Combustion for Indirect Heat Exchangers."  A maximum allowable
emission of 0.8 pound of particulate per million Btu input regardless of stack
height is allowed.

    4.  Foundries:  Small foundries (less than 20,000 pounds per hour) are required
to meet the following emission limitations:
         Process weight rate,                     Allowable emissions,
         	Ib/hr	                      	Ib/hr	

              1,000                                     3.05
              2,000                                     4.70
              3,000                                     6.35
              4,000                                     8.00
              5,000                                     9.58
              6,000                                    11.30
              7,000                                    12.90
              8,000                                    14.30
              9,000                                    15.50
             10,000                                    16.65
             12,000                                    18.70
             16,000                                    21.60
             18,000                                    23.40
             20,000                                    25.10
Chapter III - Rules for Control of Emissions from New Equipment

    Emissions from the combustion of fuel in new equipment are limited by the
ASME Standard No.  APS-1, with a maximum allowable emission of 0.6 pound of
particulates per million Btu input regardless of stack height.

    The Ringelmann chart is used only to evaluate smoke, and is not to be used
for determining metallurgical fume emissions or measuring the opacity of noncom-
bustion process emissions.  Smoke having an appearance which is No.  2 or darker
of the Ringelmann chart is prohibited except during maintenance or a breakdown.

    The particulate emissions from most new process equipment is limited accord-
ing to the process weight as recommended in the suggested ordinance provisions
of Appendix B.  The installations excluded are as follows:

    1.  Blast furnaces:  All gases discharged to the atmosphere after burning must
contain no more than 0.05 grain of particulate matter per standard cubic foot. The
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excess gas must be burned before being discharged and contain no more than 0.10
grain of particulate matter per standard cubic foot.

    2. By-product coke plants: When charging or pushing coke from a battery of
coke ovens, smoke darker than No. 2 of the Ringelmann Chart is permitted for not
more than 20-minutes in any 60-minute period.

    3. Sintering plants, open-hearth furnaces, electric furnaces, and basic oxygen
furnaces: The gas discharged to the atmosphere must contain no more than 0.10
grain of particulate matter per standard cubic foot.

    4. Cement kilns:  All plants must have gas-cleaning devices that are at least
99.7 percent efficient; however, no discharge gas may contain more than 0.1 grain
of particulate matter per standard cubic foot.

    5. Incinerators: Incinerators rated at 1,000 or more pounds per hour must not
emit gas containing more than 0.2 grain of particulate matter per standard cubic
foot adjusted to 50 percent excess air. All other incinerators are limited to 0.35
grain of particulate matter per standard cubic foot.

    6. Nonferrous electric furnaces:  The process weight limitation does not
apply during charging and pouring operations.

    7. Food and agriculture and fertilizer product processes:  Corn wet-milling
process dusts are  not limited to process weight if there is proof that it is technically
and economically unreasonable to do so.  A limit of 0.75 grain per standard cubic
foot applies to all new equipment processing material with a specific gravity less
than 2.0 and the exit gas has a dew point higher than the ambient air.


CITY OF ST. LOUIS - ST. LOUIS AIR POLLUTION CONTROL ORDINANCE OF
1967

    The  City of St. Louis adopted its air pollution control ordinance on March 27,
1967. The provisions were almost identical to the revised proposal of the technical
representatives, of the governmental agencies of the Interstate Air Pollution Study
with the following minor exceptions.

    A section added to cover existing foundry cupolas requires control equipment
with at least an 85 percent collection efficiency or a maxin um exit  gas concentra-
tion of 0.40 grain of particulate matter per standard cub c foot.

    The limitation of sulfur content of coal is the same as that adopted by the
Missouri Air Conservation Commission.
ST. LOUIS COUNTY - AIR POLLUTION CONTROL CODE

    St. Louis County adopted an ordinance on June 15, 1967, which became effective
July 5, 1967. It includes by reference, the Rules and Regulations for the St. Louis
Metropolitan Area adopted by the Missouri Air Conservation Commission.
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                                                                       GPO 805—084—6

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