EPA-
June 1976
450376026H
NATIONAL ASSESSMENT
OF THE URBAN
PARTICIPATE PROBLEM
Volume \9 -
SedJ&TleArea
* I . * ' '* '\ ^"f »
**. 5, '
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
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EPA-450/3-76-026h
NATIONAL ASSESSMENT OF THE URBAN
PARTICULATE PROBLEM
Volume X
Seattle, Washington
FINAL REPORT
by
Gordon L. Deane
Frank Record, Project Director
GCA/Technology Division
Burlington Road
Bedford, Massachusetts 01730
Contract No. 68-02-1376, Task Order No. 18
EPA Project Officer: Thompson G. Pace
Prepared for
ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
June 1976
:.;
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This final report was furnished to the Environmental Protection Agency by
the GCA/Technology Division in fulfillment of the requirements under Contract
No. 68-02-1376, Task Order No. 18. The contents of this report are repro-
duced herein as received from the contractor. The opinions, findings and
conclusions are those of the authors and not necessarily those of the
Environmental Protection Agency.
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FOREWORD
This document is part of a 16-volurae report assessing the urban particulate
problem, which was conducted by GCA/Teclmology Division for EPA.
This particular document is one of the 14 single city volumes that provide
working summaries of data gathered in the 14 urban areas during 1974 to
support an assessment of the general nature and extent of the TSP problem
nationwide. No attempt was made to perform detailed or extensive analyses
in each urban area. Rather, the city reports are intended as a collection
of pertinent data which collectively form a profile of each urban area. This,
in turn contributes to a comparative analysis of data among the 14 areas
in an attempt to identify general patterns and factors relating to attainment
of the TSP problem nationwide. Such an analysis has been made in Volume I
of the study-National Assessment of the Urban Particulate Problem-National
Assessment. The reader is referred to this volume as the summary document
where the data is collectively analyzed.
This and the other 13 city reports are viewed primarily as working documents;
thus, no effort was made to incorporate all the reviewer's comnents into the
text of the report. The comments were, however, considered during the prepara-
tion of Volume I and are included herein in order to alert the reader to
different points of view. The 16 volumes comprising the overall study are
as follows:
Volume
Volume
Volume
Volume
Volume
Volume
Volume
Volume
Volume
Volume
Volume
Volume-
Volume
Vo] time
Vol urue
I
11
III
IV
V
VI
VII
IX
X
XI
XII
XI IT
XIV
XV
XVI
National Assessment of the Urban Particulate Problem
Particle Characterization
Denver
Birmingham
Baltimore
Philadelphia
Chattanooga
Oklahoma Citv
Seattle
Cincinnati
Cleveland
- Mi aril
- St. Louis
-- Providence
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CONTENTS
Page
Foreword ill
List of Figures v
List of Tables vii
Acknowledgments ix
Executive Summary x
Reviewers' Comments xv
Sections
I Statement of the Problem 1
II Analyses 17
III Conclusions 51
Appendixes
A Meteorological Data 55
B Particle Characterization 62
IV
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LIST OF FIGURES
No. Page
1 Puget Sound Intrastate Air Quality Control Region 2
2 Manufacturing Employment in the Puget Sound AQCR 3
3 Location of Monitoring Sites in the Puget Sound AQCR 7
4 Trends in Total Suspended Particulates at the Public
Safety Building, Seattle . 10
5 Trend in Total Suspended Particulates at the USCG
Station in Seattle 11
6 Trends in Total Suspended Particulates at Tolt River
Watershed, King County 12
7 TSP Annual Geometric Means at Monitors and Isopleths
in the Puget Sound AQCR, 1974 13
8 Location of Point Sources in King County 20
9 Location of Point Sources in Duwamish Valley 21
10 Duwamish Air Basin Gravel Road Location 25
11 Particulate Emission and TSP Air Quality Trends in
King County 27
12 Comparison of Stringency of the Particulate Emission Regu-
lation of PSAPCA With Other Controls Nationwide - General
Processes 32
13 Comparison of Stringency of the Particulate Emission Regu-
lation of PSAPCA With Other Controls Nationwide - Fuel
Burning 33
14 Wind Roses at Three Sites Around Seattle 41
v
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LIST OF FIGURES (continued)
No. Page
15 Monthly Inverse Precipitation - 1974, Seattle 44
16 Normal/Yearly Precipitation and TSP Concentration in
Seattle, 1957 to 1974 46
17 Comparison of TSP Levels at Two Sites Near E. Marginal
Way, Seattle 48
A-l Yearly Rainfall in Seattle 56
A-2 Monthly Rainfall in Seattle 57
A-3 Monthly Number of Days of Rain in Seattle 58
A-4 Yearly Heating Degree Days in Seattle 59
A-5 Monthly Heating Degree Days in Seattle 60
A-6 Monthly Wind Speed in Seattle 61
VI
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LIST OF TABLES
No.
L Ventilation Characteristics for Seattle
2 Puget Sound Air Pollution Control Agency Atmospheric
Sampling Network 1974 8
3 History of TSP Monitoring Sites in the Puget Sound AQCR -
1974 15
4 NEDS Particulate Emissions for the Puget Sound AQCR and
King County (in tons per year) 18
5 Ratio of Emissions From Fuel Combustion by Fuel Type to
Total Emissions Due to Fuel Combustion, Puget Sound AQCR
and King County 22
6 Fugitive Dust Emissions in the Puget Sound AQCR (in tons
per year) 22
7 Pollution Inventory for Dusty Paved Roads and Unpaved
Roads in the Duwamish Valley 24
8 Characteristics of Seattle Monitor Sites Reviewed 38
9 Percentage of Frequency of Low-Level Inversion (Seattle-
Tacoma International Airport) 43
B-l Meteorological Data on Selected Sampling Days (Seattle-
Tacoma Airport) 64
B-2 Annual Average Concentration of Sulfate and Nitrate Ions
at the Seattle, Washington NASN Site No. 491840001 64
B-3a Results of Filter Analyses for Selected Sites in Seattle
and Vicinity (Public Safety Bldg. No. 1 and 6770 E.
Marginal Way - No. K-99) 65
vn
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LIST OF TABLES (continued)
No. Page
B-3b Results of Filter Analyses for Selected Sites in Seattle
and Vicinity (Harbor Island - No. K-60) 66
B-3c Results of Filter Analyses for Selected Sites in Seattle
and Vicinity (Duwamish Valley Ny. K-59) 67
B-3d Results of Filter Analyses for Selected Sites in Seattle
and Vicinity (Food Circus No. K-10 and USCG Station
No. K-4) 68
B-4 Composite Summary of Filter Analyses for Selected Sites
in Seattle and Vicinity 69
B-5 Results of Replicate Analyses of Seattle Filters 70
B-6 Citywide Composite Summary of Filter Analyses in Seattle 71
vxn
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ACKNOWLEDGMENTS
GCA/Technology Division wishes to sincerel> thanl; those persons and organi-
zations who made significant contributions to this effort. On-going project
supervision was provided by Thompson G. Pace of EPA's Control Programs
Development Division. The case study in Seattle was greatly assisted by
the cooperation and helpfulness of the staf'' ot ciit Puget Sound Air Pollu-
tion Control Agency, particularly Milton Svobocta, Kay Saito, Ron Bisby, and
Harry Walters. In addition, much guidance and information was obtained
from Michael Schultz and George Hofer of EPA Region X,
ix
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EXECUTIVE SUMMARY
The report summarized herein presents the analyses of the particulate
situation in the Seattle area conducted as part of the study for the
national assessment of the problem of attainment or nonattainment of the
National Ambient Air Quality Standards for particulates. Seattle repre-
sents a moderately industrialized area, with above average heating re-
quirements and a definite rainy season, that has had some success in re-
ducing emissions and particulate concentrations though not enough to at-
tain the standards. Fugitive dust generated in the industrial valley
during the dry season has been implicated as a major contributing source
to the ambient levels of particulates in Seattle.
In addition to a discussion of this fugitive dust problem, analyses of
the air quality levels, emissions, regulations, monitoring network, and
meteorology, are included in this report. The major findings in each of
these areas are summarized below in the order in which they appear in the
text.
AIR QUALITY
The trends in TSP levels at several monitors have been primarily down
during the past 8 years though an upturn has been rioted in the past 2
years. Of those stations reporting a full year of data, the national
2
primary annual air quality standard for particulates (75 ^.g/m ) was ex-
ceeded at two stations in the industrial area of Seattle and the secondary
3
annual standard (60 ^g/m ) was exceeded at another two sites one in the
industrial valley and one in the city. The highest annual geometric mean
x
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3
was 105 |j,g/m at a site in the industrial valley which is being considered
for relocation back away from the road. Violations of the 24-hour stan-
dards occurred five times for the primary and 41 times for the secondary
standard out of a total of almost 700 observations in 1974.
The spatial distribution of the TSP concentrations is related to the topo-
graphical characteristics of the region. The highest concentrations (60
3
to 105 ^g/m ) are centered in the industrial valley with the levels lower
3
in the city (45 to 63 (jg/m ) and lowest in the residential areas out of
3
the valley (35 |_ig/m ).
EMISSIONS
The spatial distribution of emissions in the area varies widely from
almost no major sources in the eastern part of the county to the densely
industrialized Duwamish Valley. Local estimates of the impact of fugitive
dust in the valley amount to almost a third of the major point sources in
the area. Consistent data on yearly emission levels is not available to
establish any correlation between TSP concentration and emissions. How-
ever, utilizing best available data, an estimate of 40 percent for the
degree of reduction since 1969 was made. This estimated reduction was
in agreement with that expected by EPA over a comparable period of time
yet it was not paralleled by a similar improvement in air quality.
REGULATIONS AND SURVEILLANCE
The sources in the Seattle area are controlled by regulations from both
the state's Department of Ecology (DOE) and the Puget Sound Air Pollution
Control Agency (PSAPCA). The PSAPCA regulations are generally as stringent
or more stringent than the DOE's regulations; however, the DOE has promul-
gated regulations for several types of industry. Surveillance of the
sources is performed through the use of the permit system, visible emis-
sions, and complaints. The majority of sources are determined to be in
XI
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compliance through theoretical calculations though some stack testing is
done to determine compliance, especially with new construction.
NETWORK DESIGN
The network reviewed was found to be generally well-designed in terms of
neighborhood selection and monitor siting. Monitors are spaced at inter-
vals of about 1 mile from the mouth of the Duwamish Valley, where indus-
trial emissions are concentrated, to the agricultural and residential areas
to the south. This network is backed up by modeling and monitoring for
wind speed and direction at numerous sites to better understand the wind
flow in the complex topography.
The primary difficulty noted was that the monitors in the center city
area (Public Safety Building, Food Circus) were located two to three times
higher than the other monitors which were uniformly located at the more
standard 15 to 25 feet above ground level. This increase in height is ex-
pected to result in lower readings and may therefore downplay the impor-
tance of planning in this area. In addition, there have been some reloca-
tions of monitors in the Duwamish Valley that have recorded high levels
of TSP. While the movements of these monitors are probably appropriate,
it was felt that some guidelines for documentation of these moves would
be helpful.
METEOROLOGY AND CLIMATOLOGY
Numerous meteorological parameters were investigated for Seattle including
the yearly and monthly variations in precipitation and space heating de-
mands , the average wind speed and number of days of precipitation each
month, and other ventilation characteristics of the region such as mixing
height, inversions, and the movement of air masses through the region.
While the seasonal pattern in space heating and various ventilation param-
eters (mixing height, inversion frequency) would tend to indicate higher
XII
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levels of particulates in the winter, the significant pattern of precipi-
tation, with a definite rainy winter season and dry summer-fall, has an
overwhelming influence on the seasonal pattern of TSP levels. On an
areawide basis, the TSP concentration is 50 percent higher during the
dry months than during the rainy season.
Precipitation has apparently also had an impact on the yearly levels of
particulates. From 1969 to 1973 the improvement in air quality has been
paralleled by increasing levels of precipitation. In 1973 and 1974, how-
ever, when the yearly precipitation decreased 25 percent, the TSP concen-
tration increased. This trend was noticeable throughout Region X at rural,
3
background sites. At these sites, the TSP levels rioted a 5 (j.g/m increase
to 35 [_ig/m .
URBAN ACTIVITY
Insufficient data was available for an analysis of the possible impact on
TSP levels due to the paving and conditioning of roads in the Duwamish
Valley. Data from a DOE study underway to compare the effect of the lo-
cation of a monitor with respect to a heavily traveled road was reviewed.
Forty sets of paired measurements taken over the period from October 1974
to June 1975 indicated that the monitor located approximately 15 feet
back from the road had values averaging over 60 percent higher than the
concentration at the monitor located approximately 100 yards back from
the road. Further analyses of this data have not indicated other expected
relationships so it is undergoing additional study.
CONCLUSIONS
The results of this study indicated that significant reductions in the
emissions from industry may be possible under a more stringent process
weight rate regulation. However, the impact that such a regulation would
have is not known at this stage due to insufficient information on the
impact of the fugitive dust sources. In addition, the complexity of
Xlll
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the topography and meteorology of the area may call for other, less tra-
ditional control measures. The seasonal pattern of TSP may mean that
controls for fugitive dust and/or seasonal controls on industry (fuel
switching in the summer) would be most cost effective.
xiv
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for existing and 0.05 gr/scr for new sources. Therefore, although the
process weight regulation is less stringent than the others, the impact
on emissions may not be much less. In addition, the effect of the pro-
cess emissions relative to area source emissions and combustion sources
is the important comparison to make to determine tne impact of process
on emissions air quality.
MONITORING
1. Third paragraph, page 37, reference fire station on 4th Avenue.
In the Agency's opinion, inordinately high traffic from the Spokane Street
viaduct running east-west and only 1000 feet south of the sensor and the
six-lane road in front of the fire station (4th Avenue) combined with other
traffic conditions were sufficient to bias the sensor by more than
25 percent with reentrained particulate during dry road conditions and
S.W. winds. The viaduct is about 30 feet high.
2. Data from the monitor located at the Public Safety Building (dis-
cussed on pages xii and 37) can be used for showing trends in air quality
even though it is located higher than the ideal height to represent peo-
ple's respiration zone. The original objective of this monitor was to
obtain data to assess air quality trends.
3. Attainment date for primary standard for suspended particulate
matter is December 1973, not July 1975 as stated on page 51.
GENERAL
The inset map on page 2 (Figure 1) incorrectly shows the location of
the AQCR in question. The region does not include areas west of Puget
Sound.
xvi i
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SECTION I
STATEMENT OF THE PROBLEM
CHARACTERISTICS OF THE REGION
The Puget Sound Intrastate Air Quality Control Region (AQCR) encompasses
the Counties of King, Kitsap, Pierce and Snohomish (Figure 1). It covers
an area of about 6,300 square miles, extending roughly 60 miles east and
west by 100 miles north and south and straddling the central part of
Puget Sound, a large irregular mass of salt water containing numerous
islands. On the east side of the AQCR is the 3000 to 6000 foot high
Cascade Range, which effectively blocks the ventilation of the Puget
Sound Lowlands in that direction. On the west side, the Olympic Moun-
tains intercept a large part of the westerly rain-bearing winds. How-
ever, the winds can sweep freely north and south through the valley.
More than half of the population of the State of Washington resides in
the AQCR yet the heavily forested eastern section of Snohomish, King,
and Pierce Counties is largely uninhabited. All of the region's cities
and most of the population are located along a narrow 20-mile wide low-
land corridor, mainly on the east side of the Sound. This leads to the
high urbanization of the area: 92 percent, 82 percent, 72 percent and
44 percent urbanized for King, Pierce, Snohomish, and Kitsap Counties,
respectively. The region has two Standard Metropolitan Statistical Areas
(SMSA's). The largest, ranking 22nd in the nation, is the Seattle-Everett
SMSA with a population of 1.4 million; the Tacoma SMSA is much smaller
with only 405,000 inhabitants. Both of these areas have had declining
populations in the past several years.
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The industry of the area is also located along this lowland area. The
Puget Sound Region's economic structure is heavily oriented toward manu-
facturing and service activities in aerospace, shipbuilding, trade,
transportation, and forest-related industries. While the Region's pol-
lution problems are similar to those of many heavily-urbanized areas,
sources especially noteworthy in the Seattle area include steel manufac-
turing, iron foundry, lumber mills, kraft pulp mills, two sulphite pulp
mills, and various lumber, single and plywood mills. Figure 2 provides
a graphical representation of the employment mix in the AQCR by 2-digit
Standard Industrial Classification (SIC) code; this figure demonstrates
the overwhelming influence of the transportation equipment industry on
the employment in the area.
20 Food
22 Textiles
23 Apparel
24 Lumber
25 Furniture
26 Paper
27 Printing
23 Chc-nicals
29 Petrol CU.TI and Coal
30 Rubber and Plastics
31 Leather
32
33
Stone, Clay, Glass
Pru-.iry Metal
34 Fabricated Metal
35 Machinery
36 Electrical Equip.
37 Transportation Equip.
SEATTLE
10 20 30 40 50 60 70
employees (thousands)
Figure 2. Manufacturing employment in the
Puget Sound AQCR
The climate in the AQCR is predominately a mid-latitude, west coast,
marine-type, with dry season and pleasant temperatures during the summer
and rather mild but rainy winters. Precipitation averages less than 40
inches in the lowlands bordering Puget Sound, while 60 to 100 inches is
common in the Cascade Mountains in the Region's eastern sector.
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Some of the factors which influence the climate are: its location in
the belt of the prevailing westerly winds, the distance and direction
of the Pacific Ocean, the terrain, and the position and intensity of
the semipermanent high and low pressure centers located over the north
Pacific Ocean. The Cascade Mountains serve as an effective barrier in
preventing the cold continental air in the winter and the warm air in
the summer from reaching the Puget Sound lowlands. Most air masses
reaching Puget Sound have their source regions over the Pacific Ocean;
the maritime air has a moderating influence in both winter and summer.
The prevailing wind is from the southwest in fall and winter, gradually
shifting to northwest in late spring and summer.
Seattle has a relatively high number of expected episode days in a 5-
year period with mixing heights less than 1000 meters and wind speeds
less than 4 m/sec. Over this period, 18 different episodes lasting at
least 2 days each may be expected to occur with the greatest number of
episode-days in the autumn. Table 1 presents mean ventilation charac-
teristics for Seattle.
Table 1. VENTILATION CHARACTERISTICS FOR SEATTLE
Mean mixing height
0)
Mean wind speed
through mixing
layer (m/sec)
Median X/Q for a
10-km city
(sec/m)
Annual
AM
705
5.2
10
PM
1175
5.4
10
Winter
AM
824
6.2
10
PM
718
5.4
10
Spring
AM
838
5.5
10
PM
1577
6.2
10
Summer
AM
576
4.2
11
PM
1419
4.9
10
Autumn
AM
585
5.0
11
PM
987
5.0
10
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AIR QUALITY PLANNING
The program of air pollution control in the State of Washington is a
cooperative effort between the State agency, which is the Department of
Ecology (DOE) and the various local agencies. The Washington Clean Air
Act of 1967, as amended, places the primary responsibility for control
of air pollution into the hands of local agencies. The first of the
local agencies formed under this act was the Puget Sound Air Pollution
Control Agency (PSAPCA). Prior to this, the City of Tacoma and the City
of Seattle had separate programs. In July of 1967, King, Pierce, and
Snohomish Counties formed a three-county agency with Kitsap County join-
ing in January 1970.
The Puget Sound AQCR was designated a Priority I region for all pollutants
except SO,., for which it was considered IA (the designation for N0« has
been changed to Priority III). The implementation plan to meet the
National Ambient Air Quality Standards (NAAQS) was completed by the
Puget Sound Agency, in cooperation with the Department of Ecology, and
submitted to EPA in January 1972. The state implementation plan (SIP)
predicted that, under the then existing state regulations and Regulation I
of the Puget Sound Air Pollution Control Agency, the particulate standards
would be attained by July 1975. The analyses was based on projected emis-
sion levels given plant capacities, new plants, and growth in the region
and using these emissions in the Martin-Tikvart atmospheric diffusion
model. The SIP is currently approved for all pollutants except oxidants
in the Puget Sound AQCR. However, the standards for particulates are not
expected to be attained and the Puget Sound area is designated as a main-
tenance area solely for particulates.
AIR QUALITY SUMMARY
There were 34 monitoring stations operating in the four-county region
during all or part of 1974; five of these are being run by the Washington
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State Department of Ecology. These stations are distributed around the
region with one station in a rural region east of Seattle and the rest
reasonably distributed among the industrial, commercial, and residential
sectors. As shown in Figure 3, the greatest density of stations is in
the Seattle metropolitan area. The location of the stations and the types
of monitors operated at each are given in Table 2. Of the 30 stations
with hi-volume air samplers operating in 1974, 23 of them operated every
month.
Two Seattle area stations have been monitoring particulate matter since
February 1965, thereby accumulating 10 years of data. These samplers
have operated on an intermittent schedule sampling continuously for 24
hours every third day from February 1965 through December 1968, every
fourth day from January 1969 through December 1972, and every sixth day
since January 1973. A total of 20 stations have acquired at least 4
years of data through the end of 1974.
An analysis technique which allows a reasonable determination of trends
is the moving mean or average. As applied to suspended particulates, a
12-month moving geometric mean relates directly to the annual standard.
This moving mean is calculated by computing the 12-inonth geometric mean
for consecutive 12-month intervals and identifying each resultant value
with the ending month for the particular 12-month interval. These values
may be easily plotted on a graph to depict observed concentrations which
relate directly to the annual standard. A variation of this technique of
portraying a trend which requires more years of data is the calculation
of the moving geometric mean in multiples of 12 months. For example,
24- and 36-month moving geometric means smooth out some of the year to
year variations in meteorology and short-term changes in source emissions
to more clearly depict the trend.
Data has been acquired continuously at the Public Safety Building (K001)
in downtown Seattle since February 1965, and the 12-, 24- and 36-month
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£.
SIO 0 SIS 0
Figure 3. Location of monitoring sites in the Puget Sound AQCR/
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moving geometric means are plotted in Figure 4. The 12-month moving geo-
metric mean plot shows short-term fluctuations, but also depicts a long-
term downward trend which appears to level out at about the value of the
annual standard. This long-term trend is even more evident in the 24-
and 36-month moving geometric mean graphs.
The other Seattle area station with about 10 years of data is located at
2700 West Commodore Way in a commercial area. The 12-month moving geo-
metric mean plot (Figure 5) indicates a long-term downward trend with val-
ues generally below the annual standard except for an upturn during 1973.
In February 1974, a reversal of the short-term uptrend occurred and is
sustained for the remainder of the year. The 24- and 36-month moving
geometric mean graphs more clearly depict the long-term downward trend
which appears to level off during the past 2 years.
Parallel to depicting levels of suspended particulates in the urban areas,
it is important to document these concentrations in the nonurban regions.
The Agency has operated a single station near the Tolt Water Reservoir in
the foothills of the Cascade Mountains since November, 1966. The 12-,
24-, and 36-month moving geometric mean graphs (Figure 6) all depict a
reasonably constant value of about 14 micrograms per cubic meter which is
neither increasing nor decreasing. Evidently this station is not sig-
nificantly affected by the urbanized areas in the Puget Sound region,
and this value is considered to be an average background value for the
air of the Puget Sound region.
In 1974, the majority of the AQCR was meeting both the primary and sec-
ondary annual standards. Of those stations reporting a full year of data,
3
the national primary annual air quality standard for particulates (75 u,g/m )
was exceeded at two stations in the industrial area of Seattle and the
3
secondary annual standard (60 ug/m ) was also being exceeded at two other
stations in Seattle and one in Tacoma. Figure 7 provides an isopleth
map of the 1974 annual geometric means in the AQCR indicating the hori-
zontal distribution of suspended particulates throughout the region. The
-------
(a) ,
na»TM IW1HC CtOtTHtC 1IWS
(b)
196" '9E
(c)
1966 15i 196"
Figure 4. Trends in total suspended particulates at
the Public Safety Building, Seattle^
10
-------
(a)
/v
Figure 5. Trend in total suspended particulates at
the USCG Station in Seattle2
11
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120"
no
100
(a)
1Z MKTM rVwilC CC9CTRIC >
s i
1966 1961 1968 191
| | t i
1970 " 1911 1912 1973
EIOIMC MWTH
120
110
100
(b)
{4 NtMTH rrrvi* GEMTRIC rERNS
to
10
i :
1966 1967
(c)
: : :
1969 " 1970
EW1NG rOflH
36 rmTti WING CE9CTAIC r
1971 1972
.
I9M 1967 1968 1969 1910 1971 197?
EIOIW nONIH
Figure 6. Trends in total suspended particulates at
Tolt River Watershed, King County2
12
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S*0 P 585 0 590 0 595 0 MHO BOS 0
DIM (KILOMfTtR'C, LRS1)
Figure 7. TSP annual geometric means at monitors and isopleths
in the Puget Sound AQCR, 1974
13
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development of these annual average isopleth maps by the PSAPCS required
the input of (1) measured air quality data, (2) meteorological conditions,
(3) topographic influences, (4) demography of the area, and (5) the par-
ticulate emissions of all sources. This map indicates the problem of
attainment of the annual standards is a matter of local influences as
opposed to a regionwide problem.
Of the 1580 individual 24-hour samples taken in 1974, 67 (4.2 percent)
3
of the samples violated the secondary 24-hour standard (150 )ag/m ). One
station operated by the PSAPCA violated the primary 24-hour standard
3
(260 |jg/m ) once in 1974 and another station operated by the DOE in the
same industrial area the Duwamish valley in Seattle is reported to
have violated the primary standard four times in 1974. This DOE site,
which also had the highest annual mean, is under study regarding its
siting and will be discussed further under monitor siting in Section II
of this report. Another DOE station in Tacoma is known to have violated
the primary 24-hour standard at least once.
Table 3 summarizes the 1974 monitoring history of the monitoring stations
in the AQCR, arranged by county and type of neighborhood in which the
monitor is located. More detailed data on the stations visited in the
course of the study are given in Section II.
14
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Table 3. HISTORY OF TSP MONITORING SITES IN THE PUGET SOUND AQCR - 1974
Location
Tolt River Watershed
Tulalip Test Facility
b*
Everett & Pine, Everett
Medical-Dental Bldg. , Everett
U.S.C.G. Station, Seattle
Food Circus Bldg,, Seattle Center
Public Safety Bldg. , Seattle
Harbor Island, Seattle
4500 Blk. E. Marg. Way S., Seattle
*
6700 E. Mars. Way S., Seattle
South Park, Seattle0
10000 W. Marg. Way S., Seattle
Duwamish Valley, King Co.
Puget Pouer Bldg., Bellevuc
S.E. Dist. Health Center, Reiiton
Municipal Bldg., Ren ton
Southccnter, Tukwila
KcMicken Hts., King Co.
1234 N. Central Ave. , Kent
Main St. & Auburn Avc . , Auburn
Meeker Jr. U.S., Taccma
Area
class
RUR
RUR
RES
COM
COM
COM
COM
INI)
IND
IND
RES
IND
RES
COM
SUB
COM
COM
RES
COM
COM
RES
Mann-Russell Klec., Tacoma ' INI)
Fife Sr. U.S. , fife
*
Cascadja College, Tacoma
Willard Elem. School, Tacoma
Hess Bldg. , Tacoma
112th St. S.W. & Loch Lea, LakcwoodE
N. 26th & Pearl , Tacoina
City Hall, Bremerton
Dewey Jr. U.S., Bremerton
All-station totals
COM
RES
RES
COM
RES
COM
COM
RES
Ceo.
mean
13
18
43
40
50
45
63
77
. 68
105
50
Std.
geo.
dcv .
2.50
2.11
2.05
1.63
1.61
1.51
1.66
1.76
1.76
1.97
1.87
60 2.12
48 1.82
Max .
46
143
123
110
159
Date
Jul 22
Oct. 8
Jan 5
Oct 8
Jan 11
97 Oct 26
229 Oct 8
Number of observations
Exceed i in',
secomi.i rv
s tanda rd
2
3
257 ; Sop 20 i 8
Exceed i nj.;
pr iLkir \
s t andard
264 Jan 8 6 ! 1
t
320 Jan 5 18 ! 4
152 Oct 16
235 Oct 8 - !
147 ': Jan 8
32 1.57 70 Jan 11
i
33 1.82 | 92 Sop 20
1,3 1 . 64 119
36
35
53
Scp 20
1.56 80 ' Dec 31
i
1.71
2.05
51 1.63
38 1.74
69
Total
57
15
19
61
61
59
62
65
65
58
56
31
61
61
60
61
1 11
122 Aut, 9 55
234 Sep 14 2 . 33
136 Jan 5 61
119 i Jar 8
61
1.75 23'. '.\i.,- 9 3 ! 61
4, ; 2.05 147 Jan 8 61
56
49
42
38
41
33
24
2.60 316 Ian 11 1 j h
1
?.14
1.92
2.0-',
2.15
1.52
1.68
17 1
164
1?2
131
bo
60
Oct 8
Oct 8
Oc t 8
Jan 11
Oct 17
Oct 14
4
9
67
£rt
54
61
60
37
60
53
60
1 ,580
Washington State Department of Ecology Stations.
"Site established 10/08/74
Site discontinued 4/23/74
CSite established 2/16/74
dSltc established 7/13/74
Site established 11/07/74
fSlte established 6/22/74
gSitc established 5/29/74
Data not available
15
-------
REFERENCES
1. Holzworth, George C. Mixing Heights, Wind Speeds, and Potential
for Urban Air Pollution Throughout the Contiguous United States.
U.S. Environmental Protection Agency. January, 1972. AP-101.
2. 1974 Air Quality Data Summary. Puget Sound Air Pollution Control
Agency, Seattle, Washington. June 1975.
16
-------
SECTION II
ANALYSES
This section presents the individual analyses that were performed on the
data gathered for the study of the particulate problem in Seattle. It
attempts to correlate various factors which are known to influence air
quality with the measured ambient TSP concentrations. These factors
include those that most often come under the jurisdiction of the air pol-
lution control agency emissions, regulations, and monitor siting and
other factors that are not usually or cannot be controlled urban activ-
ity, meteorology, etc.
EMISSIONS
The Puget Sound Intrastate AQCR is a moderately industrialized area with
most of the sources compacted into several localities. Data in the cur-
rent National Emissions Data System (NEDS) for the area indicates that
industrial processes contribute the largest share (44 percent) of the
total inventoried particulate emissions and 67 percent of the total point
source emissions. Inventoried area source emissions are approximately
half the magnitude of particulate emissions from point sources.
In King County, the primary area for study under this effort, the indus-
trial processes account for 77 percent of the point source emissions and
29 percent of the total inventoried particulate emissions. However, in-
ventoried area sources contribute almost 70 percent more than point sources
to the total particulate emissions in King County. Emissions from trans-
portation sources represent 63 percent of these area source particulate
emissions (see Table 4).
17
-------
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18
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The spatial distribution of emissions in the AQCR is quite varied. Almost
all sources lie in the valley along the Sound, the various inlets, and
rivers in the area. Figure 8 locates the point sources in King County
and provides an idea of the relative size of each source. As may be seen
from this figure, the greatest density of point sources is along a river
south of Seattle, an area known as the Duwamish Valley. Figure 9 identi-
fies, by the dashed line, that area defined as the Duwamish Valley by
PSAPCA and also provides a closer look at the location of sources in the
Duwamish Valley area.
The wide variation in the degree of industrialization of the AQCR makes
analysis of the emission levels difficult for levels reported at the AQCR
or county level. A particular example of this is reflected in the emis-
sions from fuel combustion. Table 5 provides a breakdown of the emissions
from combustion based on fuel usage for the AQCR and King County as re-
ported in NEDS. This table indicates that almost 55 percent of the emis-
sions from fuel combustion in the AQCR are from the burning of wood and
in King County this contribution is over 30 percent. However, these
emissions are almost totally due to combustion occurring in the rural
areas of the AQCR and county and are not of significance when consid-
ering the violation of the standards in the metropolitan areas. In the
Seattle-Everett SMSA in 1970, based on the U.S. Census of Housing, 44
percent of dwelling units used distillate oil and the other units were
evenly divided between gas and electricity usage with only 0.2 percent
using coal.
The above NEDS data does not include any estimate of the emissions from
possible fugitive dust sources. A calculation of the preliminary data
supplied from the MRI study of dirt roads, dirt air strips, construction,
and agricultural tilling indicates that the fugitive dust emissions from
these sources would be more than 22 times the total tonnage as the in-
ventoried emissions, and, in King County by itself, the fugitive dust is
over 30 times the total inventoried emissions (see Table 6). Almost
19
-------
PT. SOURCE EMISSIONS
K.I.NG CO.
J- "---
PIERCE CO.
KM
10 15
20 25
5205-
510
i
520
\
530
I
540
550
I
560
515 525 535 545 555 565
UTM COORDINATES
o ; 10 is
MILES
' I I I « I I I
570 I 580 I 590 I 600 I
575 585 595 605
Figure 8. Location of point sources in King County
20
-------
D
0
5272 -
5267 -
6259 -
PT SOURCE EMISSIONS
TPJT
LI <25
R 25-100
M 100-500
K 5OO-IOOO
H >iooo
I I
546 547
iil
UTM COOHDINATtS
Figure 9. Location of point sources in the Duwamish Valley
21
-------
Table 5. RATIO OF EMISSIONS FROM FUEL COMBUSTION BY FUEL TYPE TO
TOTAL EMISSIONS DUE TO FUEL COMBUSTION, PUGET SOUND
AQCR AND KING COUNTYa
Area
AQCR
King
County
Source
type
Point
Area
Point
Area
Fuel type
Bituminous
coal
0.133
0.004
0
0.007
Residual
oil
0.059
0.101
0.047
0.215
Distillate
oil
0.010
0.118
0.009
0.334
Natural
gas
0.008
0.018
0.013
0.046
Wood
0.509
0.039
0.282
0.046
Total
0.719
0.280
0.351
0.648
From NEDS data
Table 6. FUGITIVE DUST EMISSIONS IN THE PUGET SOUND AQCR
(in tons per year)a
County
King (0980)
Kitsap (1020)
Pierce (1560)
Snohomish (2000)
Total
Percent of total
Unpaved
roads
196,765
110,625
160,480
171,100
638,970
64
Dirt
air
strips
44
40
16
35
135
< 1
Construction
204,680
13,072
70,348
66,048
354,148
36
Land
tilling
39
20
59
106
224
< 1
Total
401,528
123,757
230,903
237,289
993,477
100
Percent
of AQCR
40
12
23
24
100
a 1
From an MRI Study
22
-------
all of these emissions are contributed from unpaved roads (64 percent)
and construction activity (36 percent).
The problem of fugitive dust in Seattle has been recognized and analyzed
in several studies by J. W. Roberts. In a thesis prepared by Roberts in
2
1973 , he developed an emission inventory for fugitive dust generated as
a result of vehicular activity in the Duwamish Valley. In this study,
Roberts attempted to identify not only those total emissions that may be
expected to result from traffic on dusty paved roads and gravel roads but
also the amount that would remain suspended for any period of time. Par-
ticulates less than 10 microns in diameter were defined as the suspended
portion and, on average, this amounted to approximately 25 percent of the
total emissions.
Table 7 details the emission inventory calculated by Roberts for the
Duwamish Valley air basin with the grid numbers referring to the map in
Figure 10 as given in his thesis. This table indicates that there is an
estimated emission level of 2540 tons of particulates per year within
this area due to traffic on paved gravel roads and that 655 tons of this
would remain suspended. While the determination of this level may have
some problems due to sampling directly behind a moving vehicle and it can
be expected to vary greatly depending upon climatic and individual road
conditions, the amount of "suspended" particulates generated is signifi-
cant. It amounts to almost one-third of the emissions from the major
point sources in the area and is emitted directly into the breathing
zone without much dilution as occurs with emissions from stacks.
Due in part to this research and the recognition that these sources are
contributing to the ambient air levels (and water pollution) in the area,
some stabilization of roads (about 15 miles in 1974) and paving of parking
lots has occurred in the Duwamish Valley. Unfortunately, this is a rela-
tively recent and ongoing activity so that sufficient data is not available
to establish an estimate of the impact on air quality that these programs
are having.
23
-------
00
Q
I
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-------
Air Basin Boundary
Gravel Read
r Monitoring Station
Figure 10. Duwamish Air Basin gravel road location
25
-------
While no consistent set of data was available to establish any long-term
trends in emissions from different source categories, annual emission in-
ventories for King County for the years 1969 to 1972 had been compiled by
the PSAPCA. (However, differences in emission factors and approaches to
compiling the inventories have varied over this time and no attempt has
been made to update previous inventories.) In addition, the EPA Region X
office had compiled a 1973 inventory for a study of the King County area"
and the NEDS data is supposedly representative of 1974 emissions. There-
fore, utilizing these data bases, it is possible to develop an approxi-
mation of the trends in emissions over time.
Figure 11 provides a graph of the changes in these emission inventories
for the major source categories and the total emissions (divided by two
to fit on the graph). Emissions of approximately 1000 tons/year from dirt
roads, included in the 1973 inventory, were excluded in the 1973 total to
try to maintain consistency between the inventories. Despite the dif-
ferences in the emission inventories, the magnitude of reduction of emis-
sions is almost equivalent to the 40 percent reduction expected in the
3
Region X report. The major problem in establishing a trend is for the
transportation category, however all other sources show a noticeable con-
tinuing downtrend. An average of annual TSP concentrations at three
stations (USCG, Public Safety Building, Food Circus) is also plotted on
this figure. This air quality plot indicates that, while improvements in
air quality were noted in the early years, 1973 and 1974 have shown in-
creasing levels at a time when emissions have continued to decrease.
Possible factors relating to this discrepancy are investigated under the
discussion of meteorology and climatology.
LEGAL AUTHORITY, REGULATIONS, AND SURVEILLANCE
The program of air pollution in control in the State of Washington is a
cooperative effort between the state agency, which is the Department of
Ecology (DOE) and the various local agencies. The Washington Clean Air
26
-------
Q.
I-
CO
CO
uu
I-
I-
cr
12,000
11,000
10,000
9,000
e.ooo
7,000
6,000
5,000
4,000
3.000
2,000
1.000
KEY'
-X-TOTAL EMISSIONS/2
I-INDUSTRIAL PROCESS
T- TRANSPORTATION
-F-FUEL CONSUMPTION
S-SOLID WASTE DISPOSAL
A-AIR QUALITY (AVERAGE
3 STATIONS)
F _
I
60
55
50
40
35
30
25
20
15
10
H
<
IT
LJ
O
z.
o
o
d
CO
1969
1970
1971
YEAR
1972
1973
1974
Figure 11. Particulate emission and TSP air quality trends
in King County
27
-------
Act of 1967 as amended in 1969 and 1970 and 1971 places the primary re-
sponsibility for control of air pollution into the hands of local agencies.
The first of the local agencies formed under this act was the Puget Sound
Air Pollution Control Agency (PSAPCA). Prior to this, the City of Tacoma
and the City of Seattle had separate programs. In July of 1967, King,
Pierce, and Snohomish Counties formed a three-county agency with Kitsap
County joining in January 1970.
Regulations
The Department of Ecology is organized to provide technical advice and
consultation for the local agencies and to assist them in their programs
and planning. The state agency has also been granted the authority to set
standards and assume jurisdiction for certain source categories if it is
determined that these should be controlled on a uniform statewide basis.
The State of Washington's air pollution regulations are applicable state-
wide unless the local regulation is more stringent, in which case the local
regulation would be applied. Some areas under the direct jurisdiction of
the state agency can be designated sensitive areas by the director, de-
pending on present and predicted ambient air quality, population density,
topographic and meteorological conditions and other factors. These areas
would be subject to more stringent regulations.
The state's regulations include sections on compliance schedules, source
registration, odors, fugitive dust, sulfur dioxide, hazardous substances,
combustion and general process sources, as well as separate sections on
the following sources: wigwam burners, asphalt batching, hog fuel boilers,
orchard heaters, grain elevators and catalytic cracking units. There are
separate regulations for primary aluminum plants, open burning, field
burning, sulfite pulping, Kraft pulping, thermal power plants, chemical
wood pulp mills, and suspended particulates.
28
-------
The regulations which DOE has adopted for the ambient air quality standard
is identical to the secondary National Ambient Air Quality Standards (NAAQS)
for particulates with one exception of interest. Included in the standard
is the possibility of variance from the standard in areas east of the
Cascade Mountain Crest "in recognition of natural dust loading:"
(1) If concentrations, measured at approved background loca-
tions, exceed 30 micrograms per cubit meter of air on
individual sample days, the concentration of suspended
particulate matter measured at any primary air mass sta-
tion shall not exceed 120 micrograms per cubic meter of
air plus background as a maximum 24-hour concentration
not to be exceeded more than once per year.
(2) If concentrations, measured at approved background loca-
tions, exceed 20 micrograms per cubic meter of air as an
annual geometric mean, the concentration of suspended par-
ticulate matter at any primary air mass station shall not
exceed 40 micrograms per cubic meter of air, plus back-
ground, as an annual geometric mean.
The ambient air quality standards for particulates that were promulgated
by the PSAPCA under Regulation I are identical to those of the DOE; and,
since the region is west of the Cascade Mountains, it has no exempted areas.
However, an additional standard for particulate has been adopted which
regulates the level of fallout based upon the area which is being measured:
(1) Ten grams per square meter per month (10 g/m /mo) in an
industrial area; or
(2) Five grams per square meter per month (5 g/m /mo) in an
industrial area if visual observations show a presence of
wood waste and the volatile fraction of the sample exceeds
70 percent.
r\
(3) Five grams per square meter per month (5 g/m /mo) in resi-
dential and commercial area; or
(4) Three and one-haIf grams per square meter per month
(3.5 g/m /mo) in residential and commercial areas if
visual observations show the presence of wood waste and
the volatile fraction of the sample exceeds 70 percent.
Regulation I includes general policy and implementation sections as well as
rules governing ambient air quality and required control measures. It
29
-------
regulates the sulfur content of fuel, odors, and emissions of sulfur oxides,
particulates, and oxides. The general regulation adopted by the agency
contains provisions requiring the registration of sources and a notifica-
tion of construction to be filed for any new construction. The agency has
the authority to deny construction upon finding that the new facility will
result in a violation of the standards adopted by the agency.
As the controls adopted by the PSAPCA are generally equivalent to or more
stringent than those of the DOE, they are the ones summarized below.
Open Burning Open burning is restricted, depending on loca-
tion, purpose, air pollution potential and the
material to be burned. Small fires on residen-
tial property are generally allowed, provided
that the material to be burned is not prohibited
material and depending on the proximity of other
structures.
Visible After July 1, 1975, visible emissions cannot be
Emissions darker than No. 1 on the Ringelmann chart (20
percent opacity) for periods greater than 3
minutes in any 60 minutes.
Refuse After June 30, 1975, emissions from incinerators
Burning are limited to 0.10 grains per standard cubic
foot of exhaust gas, adjusted to 12 percent car-
bon dioxide. Incinerators must be of the multi-
chambered design.
Fuel Burning Emissions from equipment existing before the ef-
fective date of the regulations are limited to
0.10 grains per standard cubic foot of exhaust
gas adjusted to 12 percent carbon dioxide. For
equipment installed after 10 October 1973 emis-
sions are limited to 0.05 grains per standard
cubic foot. The emissions from existing fuel
burning equipment using wood residue cannot ex-
ceed 0.20 grains per standard cubic foot; the
emission standard for new facilities is 0.10
grains per standard cubic foot.
30
-------
Manufacturing The allowable particulate emissions for manu-
Processes facturing processes are presented graphically
in Figure 12 on a process weight rate basis.
The further restriction that emissions not ex-
ceed 0.10 grains per standard cubic foot for
existing installations and 0,05 grains per
standard cubic foot for new facilities is also
applied,
Fugitive Dust Reasonable precaution must be taken to prevem.
particulate matter from becoming airborne.
The plot of the PSAPCA general process regulation in Figure 12 is super-
imposed on a graph which represents the maximum ard minimum controls cur-
4
rentlv being applied in the U.S. The dashed lines in this figure repre-
sent the most (least) stringent of the regulations in each size category
and, as such, do not reflect the controls in any one jurisdiction. The
shaded area in this figure reflects the arithmetic mean, plus and minus
one standard deviation, of the 14 cities reviewed under this stud}. This
figure indicates that the process weight rate regulation for the Puget
Sound AQCR is much less stringent than may be reasonably expected. In fact,
die PSAPCA regulation for particulate emissions for industrial processes
was the least stringent of the process weight rate regulations in the 14
cities studied for a process weight: rate greater than 4000 pounds per hour.
Similar reviews were conducted for regulations governing fuel burning,
incinerators, and fugitive dust. The PSAPCA regulation was converted to
a pounds per 10 Btu rate and plotted in Figure 13 on which a relative
stringency measure had been graphed. The emission standards for fuel
burning equipment are more stringent than the average for facilities with
less than 400 million Btu per hour heat input and somewhat less stringent,
relatively, for the larger size ranges.
The regulations for visible emissions and incinerators were found to be
comparable with most other areas with incinerator controls being perhaps a
bit more stringent than average for the smaller sizes (< 100 tons per day).
31
-------
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33
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Surveillance Procedures
The surveillance of sources and enforcement of regulations in the Puget
Sound AQCR are maintained by use of several techniques including inspec-
tion, registration of sources, notices of construction, and field surveys,
The general program for enforcement by the PSAPCA is given below.
Inspection
Field inspectors perform inspections on processes subject to
regulation under Air Pollution Control regulations and stan-
dards. The types of inspections are:
1. Violation inspection
2. Follow-up and reinspection
3. Inventory inspection
4. Investigation of complaints
5. Miscellaneous inspections such as equipment break-
down, follow-up on variance conditions, compliance
schedules, engineering final field reports, etc.
Complaints and inspection orders are relayed to field in-
spectors via two-way radio contact. The frequency of in-
spection depends upon the type. Complaints and visible emis-
sions are investigated as soon as possible. Follow-up and
reinspection on violations and variance conditions, status
of compliance schedules, and inventory inspections are done
on a scheduled basis. Each inspector conducts systematic
coverage of his control area for optimum use of time.
Appropriate records of all types of inspections are made on
appropriate forms and routed to source files. A file is
initiated on the first contact with a source and maintained
thereafter until retired for cause.
Violations
When evidence of a violation is established, a Notice of Vio-
lation is served in person by a field inspector or sent by
certified mail, depending upon circumstances. The notice asks
that the Agency be advised in writing within 10 days of the
corrective action taken or to be taken to prevent continued or
recurrent violations. If the source management fails to re-
spond within the time specified, a second request for reply is
34
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sent over the signature of the Supervising Inspector before re-
sorting to one or more of the legal enforcement alternatives
that are available. The most frequent legal action taken is
issuance of a civil penalty.
Registration
Registration of active sources is accomplished on submission of
one or more forms containing specific information regarding pro-
cess equipment data, physical data, air pollution control equip-
ment, combustion control devices, fuel used, fuel consumption
and unit operation. Sources who do not respond when advised of
the registration requirement are followed up in the field by air
pollution inspectors.
Information obtained on the registration forms is entered onto
load sheets for key-punching into computer cards, thereby creat-
ing a data bank from which emissions inventory, summaries, and
other computer printouts can be generated at will.
Notices of Construction
Detailed plans and specifications submitted with Notices of Con-
struction are reviewed by the Agency's engineers. Based upon
plan evaluation the Agency will issue either an order or approval
of an order to prevent construction. Failure to submit a Notice
of Construction is a violation of Regulation I. In addition to
the assurance that new sources will meet emission standards, a
Notice of Construction system provides continuing help for the
updating of source registration and emission inventory. Detailed
information for this purpose is required to fulfill the Notice of
Construction requirement.
Compliance Schedules
Compliance schedules are initiated by supervising inspectors on
the recommendation of field inspectors. The air pollution source
is supplied with a compliance schedule form and requested to sub-
mit the form by a fixed date. If the form is not submitted to
the Agency on time and sufficient reason has not been presented,
the supervising inspector recommends enforcement action.
On return of the compliance schedule form to the Agency, the
supervising inspector forwards it to the Chief of Enforcement
with recommendations. The Chief of Enforcement in turn for-
wards a copy of the schedule for Engineering review. On deter-
mining the proposed control methods are adequate for compliance
and the completion dates are reasonable, the source is notified
by letter that the compliance schedule is accepted, and that the
Agency will not initiate legal action against the violator as
long as the terms of the compliance schedule are met.
35
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Variances
Applications for variances are made on forms supplied by the
Agency and are accompanied by supporting data as required by
the Hoard. Public notice of all hearings are placed in a news-
paper officially designated by the Hoard and in a daily news-
paper in the county from which the application is made. The
Engineering Division studies the merits ot the application and
prepares a draft of staff recommendations to the Board. After
hearing the applicant, the stall' recommendations, and any other
pertinent testimony, the Hoard directs its legal counsel to
prepare a resolution containing the findings and decisions of
the Hoard, for signature by the Chairman. This written notice
oi disposition is mailed to the applicant and made part of the
record.
A review of the 1'SAPCA enforcement program indicated that it was quite an
active program which apparently maintains complete and up-to-date files
on most sources in the area. There are four inspectors in King County
who visit each plant at least once per year to update the emission in-
ventory. Twenty to thirty source tests are conducted each year to check
compliance, often after construction of a new source. Within tht last
couple ot years most major sources have come into coni|'1 iance.
NETWORK DESIGN
Because of the widespread nature of the AQCR and the multitude oi neighbor-
hoods that would be involved, no analysis of the monitoring network (Fig-
ure i) for the whole AQCR was attempted. Instead, attention was directed
at the monitoring network operated by the PSAPCA in and around Seattle.
The network reviewed was found to be fairly well designed in terms of
neighborhood selection and monitor siting with the exceptions noted below.
From the standpoint of emissions, topography, and associated local meteo-
rology, the area of maximum concern is the Duwamish valley. This lias been
confirmed both by monitoring and by modeling and the monitoring effort has
accordingly been concentrated along the valley. Monitors are spaced at
intervals of about 1 mile from the mouth of the valley where industrial
36
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emissions are concentrated to the agricultural and residential areas to
the south. It is felt that this area has an appropriate density of
monitors .
The monitoring sites reviewed in the course of this study are grouped in
Table 8 according to the predominant characteristic of the neighborhood
of each. This table also provides the height of each monitor, its slant
distance from the nearest major road, the geometric mean for each station,
and summarizes the siting comments for each monitor.
The primary difficulty noted was that the monitors in the center city
area (Public Safety Bldg. , Food Circus) were located much higher above
ground that the other monitors visited. This increased height has been
shown to produce lower readings than would be measured if the monitors
were located at the more standard 15 to 25 feet above ground level. While
the stations were not inappropriately high according to guidelines, lower
sites would have been more in line with the other monitors in the network.
In addition to the sites listed in Table 8, the location of a previous
monitor that had been discontinued was reviewed. This site was also in
the Duwamish valley at a fire station in the 3200 block of 4th Avenue
and was recording the highest concentrations of any monitor in the period
1968 to 1970. In the preparation of the SIP, this site was deemed in-
appropriate because its values did not fit with the modeling results. The
site visit did not indicate any major sources that may have been impacting
on the monitor to cause the higher readings.
A similar situation is currently being studied at the DOE site on E. Mar-
3
ginal Way. This site recorded the highest TSP value (102 (ag/m ) in the
Puget Sound AQCR and is being considered for relocation because of its high
values which appear to result from its proximity to the heavily traveled
road. The DOE is operating another monitor 100 yards back from the road
for comparison purposes; to date, its values have averaged almost 40 per-
cent lower than the site closer to the road.
37
-------
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Such movements of monitors which measure high levels of particulates
raise some questions about the siting of monitors and the interpretation
of the resulting citywide trends. While for most purposes monitors should
not be located in areas heavily influenced by a single source, the reloca-
tion of those monitors recording high values may provide a picture of the
TSP situation much less serious than actually exists. Though the moves
may be totally appropriate, guidelines for a documentation of these siting
decisions should be available.
METEOROLOGY AND CLIMATOLOGY
The general meteorology of the area appears to be one of the factors
prominent in determining the TSP levels in Seattle. Numerous meteorologi-
cal parameters were investigated for Seattle including the yearly and
monthly variations in precipitation and space heating demands (degree days),
the average wind speed and number of days of precipitation each month, and
other ventilation characteristics of the region such as mixing height,
inversions, and the movement of air masses through the region. Those
factors which are known to be most influential for air quality levels
ventilation and precipitation were found to be the same ones with the
greatest seasonal variation. However, the analyses conducted indicated
that the influence that precipitation has on the yearly and monthly TSP
patterns in Seattle far outweighed any of the other meteorological factors.
Therefore, the discussion below focuses primarily on precipitation and
its impact after a short review of some of the other factors. Supporting
data on the meteorological parameters are presented graphically in the
appendix.
Ventilation Characteristics
The topography of the region significantly affects the climatology and
meteorology, having its major effect on the ventilation. The middle-
latitude west coast climate of the Seattle-Tacoma area is modified by
the imposing barrier of the Cascade Range on the east and to a lesser
39
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extent by the comparatively short Olympic Range to the west and northwest.
The Cascades are very effective in excluding continental influences from
the Seattle-Tacoma area, particularly in keeping cold air from draining
westward during the winter. Occasionally the pressure distribution will
result in a southward flow of cold air from Canada west of the Cascades
and it is only under these conditions that extremely cold weather strikes
the southern Puget Sound area. Since the southern end of the Puget Sound
trough is open to the southwest winds generated by storms moving in off
the ocean, the prevalent wind for the storm season of the winter and spring
months is southwest. The trough of the Puget Sound is also open to the
north allowing for strong winds from the northerly quarter during oc-
casionally severe winter storms. During the summer months, the relatively
light winds are influenced by the land- and sea-breeze effects as well as
the channeling of the topography.
The wide variations in wind speed and direction that occur at different
sites in the area can best be seen by looking at some of the wind roses
at several sites operated by the PSAPCA. Wind roses at three sites around
Seattle are given in Figure 14. In these roses, representing 1974 winds,
each spoke points in the direction from which the wind blows. The length
of each segment of a spoke indicates the relative frequency of winds of
different speeds. Using the scale located to the lower right of the fig-
ure, these lengths may be converted to percentages of the total observa-
tions. The percentage frequency of winds from any given direction (with-
out regard to speed) is expressed numerically beneath that direction on
the perimeter of the roses. The percentage frequency of light and variable
winds (winds less than 1.5 knots) is shown in the center of the rose.
These roses indicate that, within 20 kilometers, one may expect to find
significantly different wind patterns. Of particular interest is the high
percentage of light and variable wind conditions. Such conditions are
often associated with poor mixing and resulting high levels of particulates
For example, on many summer days light north winds pass over Elliot Bay
40
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(a) NWS Urban Site, Station No. K100
\\\\wm *
(b) Duwamish Valley, 4500 Blk.
E.Marg. Way, Station No. 55
(c) McMicken Heights,
Station No. Tl
Figure 14. Wind roses at three sites around Seattle
41
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into the Duwaraish Valley and the air cooled by the water causes warmer
air to rise. In such a manner a thermal lid is placed on the dispersion
of air pollution. This condition compounds the effect of normal nighttime
radiation inversions that occur during the same period of the year. The
winds at the mouth of the Valley near Harbor Island are influenced by air
currents from the Sound and this fact makes the Valley difficult to model.
For any given wind speed, the greater the mixing height, the greater the
volume of air available to dilute the pollutants and therefore to lower
their concentrations. The maximum vertical depth of the atmosphere avail-
able in any day for the mixing of polluted air usually occurs in the after-
noon following the period of maximum surface heating and is known as the
maximum mixing height. The minimum mixing height is associated with mini-
mum surface temperatures and usually occurs at or around sunrise. From
the data that was given in Table 1, it is apparent that this pattern of
higher afternoon mixing heights is not followed in Seattle during the
winter months. Instead, the afternoon mixing height is almost 13 percent
lower than that calculated for the morning. In addition, the percentage
of frequency of low-level inversions is higher in the winter and fall than
during other seasons and the persistence of these inversions is also much
greater (see Table 9).
While both of these conditions (inversions and mixing heights) would tend
toward increased concentrations of particulates in the winter, such a
trend is not seen due to the fact that the majority of precipitation also
occurs during this time.
42
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Table 9. PERCENTAGE OF FREQUENCY OF LOW-LEVEL INVERSION
(SEATTLE-TACOMA INTERNATIONAL AIRPORT)
Season
Fall
Winter
Spring
Summer
4 p.m.
9
24
0
1
7 p.m.
19
13
6
3
4 a .m.
69
63
54
57
7 a .m.
32
31
30
19
Hosier, Charles R. , 1961: Low-level inver-
sion frequency in the Contiguous United
States. Monthly Weather Review, vol. 89,
Sept. , 1961, 319-339
Precipitation
Precipitation is normally considered to be the meteorological parameter
which has the maximum impact on air quality levels, aside from ventilation
rate. It helps to clean the air of particulates through washout and rain-
out and can suppress the rise of pollution levels by wetting down particu-
lates that would be resuspended if dry or even washing particulates off
the streets into sewer systems if the rain is heavy enough. The expected
relationship is one of inverse correlation with the pollutant concentra-
tion. Seattle has a well defined seasonal pattern of precipitation with
as much as eight times the precipitation in the winter months than in the
summer months on a normal basis. In 1974, this trend was even more pro-
nounced with only 0.01 inch of precipitation recorded in August and 7.78
inches in January.
Because of the expected inverse relationship between TSP concentration and
precipitation, Figure 15 provides an inverse graph of the precipitation
during 1974 by dividing the average monthly (annual/12) by the actual
monthly precipitation in 1974. Overlayed on this graph is a plot of the
average monthly geometric mean for all the monitors in King County that
operated for the full year. This countywide average is utilized to dis-
count major influences that certain activities may have on individual sites.
43
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PRECIPITATION
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80
70
60
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50
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Figure 15. Monthly inverse precipitation 1974, Seattle
44
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The degree to which the inverse precipitation graph and the TSP concentra-
tion rise and fall together provides an indication of the correlation of
the two parameters. The most pronounced characteristic of the precipita-
tion plot is closely paralleled by the seasonal pattern in TSP.
This correlation must be considered even more significant since all other
meteorological parameters (except for average monthly windspeed) would
tend to indicate a pattern with higher TSP levels in the winter than in
the summer. The fact that the pattern is not as closely paralleled during
the rainier season may be partially explained by other meteorological
factors such as ventilation characteristics. In addition, the daily
pattern of precipitation may be used to better understand the impact
that rainfall has on TSP levels. While Figure 15 would indicate that
the rainfall in October was a sufficient amount to have a lower average
TSP concentration for that month, almost all of the precipitation in
October 1974 occurred within the last 4 days of the month and the other
significant rainfall that month came in a downpour lasting about 5 hours
on 1 day.
Just as precipitation has an impact on the short-term seasonal pattern of
TSP concentrations, it can also affect the longer-term annual trends if
the total level of precipitation varies significantly from year to year.
In recent years in Seattle, the precipitation has fluctuated more than
20 percent on either side of the normal amount. This has led to differ-
ences of as much as 50 percent between 2 consecutive years. Again to
provide an easier comparison of the correlation between the two param-
eters, a graph of the inverse (normal/yearly) precipitation and TSP
levels measured at the NASN station on the Public Safety Building in
Seattle between 1957 and 1974 is plotted in Figure 16. While there are
obvious discrepancies in the correlation, this figure indicates that the
precipitation has been having a measurable impact on the TSP concentra-
tion on a yearly basis. Of particular interest is the correlation in
the most recent years which may be one explanation for the rise in TSP
levels at a time when more sources were coming into compliance with the
PSAPCA regulations.
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URBAN ACTIVITY
Beyond industrial activity, fuel combustion, and other traditional pol-
lution sources, it is increasingly apparent that in many locations other
urban activities , such as routine traffic and construction and demolition
activities, are a more major part of urban pollution problems than had
been previously recognized. The primary area of interest in Seattle,
because of published reports on the subject, was the problem of fugitive
dust in the Duwamish Valley. It had been expected that data would be
available on changes in concentration due to paving and road stabilization
measures. However, this activity had not been completed and was too re-
cent to have established any trends in TSP levels.
The other source of data that was identified for analysis of urban activity
was the comparative study of the impact of the proximity of monitors to a
heavily traveled street being conducted by the DOE. One of the hi-vols
was located on top of an instrument shelter (height 15 feet) immediately
adjacent to E. Marginal Way, while the second hi-vol was located at the
same height on top of a flat-roofed, one-story building set back approxi-
mately 100 meters from the street. The closer instrument shelter has a
hedge-row of trees between the street and the monitor that provides some
screening of street-generated particulates. Apart from this row of trees,
there are no significant obstructions or local sources between the street
and the second hi-vol.
Forty sets of paired measurements taken over the period from October 1974
to June 1975 are available for analysis. On 37 of the observation days,
concentrations adjacent to the. street exceeded those measured 100 meters
from the street, with geometric mean concentrations at the two locations
being 89 and 55 |jg/m respectively. These paired observations are plotted
in Figure 17 to demonstrate the degree to which the monitor closest to
the street is measuring higher levels.
-------
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240
220
200
180
160
140
120
100
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20 40 60 80 100 120 140 160 180 200
CONCENTRATION 100 METERS FROM ROADWAY (/jg/m3 )
Figure 17. Comparison of TSP levels at two sites near
E. Marginal Way, Seattle
48
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While this data alone tends to indicate that the road is acting as a
significant source, other analyses, including correlation with precipita-
tion, wind speed, and wind direction, failed to indicate any of the ef-
fects expected if the road were actually a source. The lack of such ef-
fects is not conclusive evidence that the road is not the major cause of
the increased values noted but rather that further data and consideration
is needed. This is being pursued for the final report for this project.
49
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REFERENCES
1. Cowherd, C. C., et al. Emissions Inventory of Agricultural Tilling
Unpaved Roads and Airstrips , and Construction Sites. Prepared for
the U.S. Environmental Protection Agency, Office of Air and Waste
Management, Office of Air Quality Planning and Standards.
November, 1974.
2. Roberts, John W. The Measurement, Cost and Control of Air Pollu-
tion from Unpaved Roads and Parking Lots in Seattle's Duwamish
Valley. A thesis submitted in partial fulfillment of the re-
quirements for the degree of Master of Science in Engineering,
University of Washington. 1973.
3. Air Quality Profile for King County Primary Abatement Area. Air
Surveillance Section, EPA, Region X, Seattle, Washington. April,
1975.
4. Martin, W. and A. C. Stern. The World's Air Quality Management
Standards. Volume II: The Air Quality Management Standards of
the United States. U.S. EPA, October 1974. EPA-650/9-75-001-b.
5. A Plan for the Implementation, Maintenance and Enforcement of
National Ambient Air Quality Standards in the State of Washington,
prepared for the Environmental Protection Agency by the Washington
State Department of Ecology. January 1972.
50
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SECTION III
CONCLUSIONS
Both the primary and secondary standards for total suspended particulate
are exceeded in the Duwamish-Harbor Island area of Seattle, and did not
meet the 1975 attainment date as required by the State Implementation
Plan. The portion exceeding the primary standards extends from the south
end of Boeing Field to the northern portion of Harbor Island. The area
exceeding the secondary standards extends farther south than Boeing Field,
and on the north includes the Seattle Central Business District. This is
a relatively localized problem in terms of King County as a whole, re-
sulting from the high density of large sources in an adverse topographical
setting.
According to the analyses in the EPA King County study which assumed a
3
25 ug/m influence from particulate from outside the area, the following
estimated emission reductions would be necessary for standard attainment
in the vicinity of the following stations.
Primary Secondary
Duwamish 35 percent 54 percent
Harbor Island 4 percent 33 percent
Municipal Building 8 percent
Also according to this study, the Compliance Data System (CDS) projects
that by 1977 these necessary reductions will not be achieved. By that
date, an additional point source emission reduction of only 24 percent
is anticipated in the Duwamish area. The analysis of the regulations
51
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given in Section II of this report tends to indicate that there is still
potential for reducing emissions through more stringent regulations,
especially process weight rate, without becoming unreasonable. Tighten-
ing of the process weight regulation to the studywicle average stringency
would result in as much as 40 percent less emissions from major sources.
Meteorology has been a complicating element in any planning for attainment
strategies. The season pattern in precipitation is such that the controls
are primarily needed to keep down the elevated levels in the dry summer-
fall season as opposed to the winter when additional emissions from space
heating would be expected to raise the TSP levels. Because of this sea-
sonal variation, the most appropriate, cost-effective strategies may not
be those relating to traditional control of industrial point sources.
Rather, it may be more reasonable to put emphasis on the control of fugi-
tive dust emissions during the several months of the year that the problem
is prominent. Further study in this area is obviously warranted.
Precipitation may also have been a confusing factor in the review of
progress to date. Between 1969 and 1972, precipitation would have im-
pacted on the TSP levels to the extent that a downward trend was estab-
lished. Since 1972, however, the precipitation has decreased and TSP
levels have risen an unexpected occurrence given decreasing emissions.
(The TSP trend plot given in this report is considered more pertinent
than the one in the PSAPCA Air Quality Data Summary because a consistent
set of monitors was used for establishing an average.)
With respect to these problems in the study of the area, the PSAPCA ap-
pears to have recognized them and is currently attempting to determine
the relative contributions of fugitive dust and industrial emissions
to the high particulate levels observed along the Duwamish Valley.
The agency has devoted more than the normal amount of effort and resources
in the monitoring and modeling of the area. In addition, the enforcement
division has an active, well-structured program. As in most areas of the
52
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county, further work is needed in tracking emissions from different
facilities on a year-by-year and even a seasonal basis. The work underway
at the PSAPCA directed at the computerization of the emission inventory
for cross-referencing between years should be most helpful in this regard.
The apparent lack of data on the spatial distribution of area sources
needs to be resolved. Studies undertaken by Roberts, Boeing, and others
have helped to provide much of the understanding of the problem area.
53
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en
to
en
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10
9
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o>
u
.5 7
Ul
o 4
(E
UJ ,
> 3
2
I
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NORMAL,-/'^
JFMAMJJAS ONO
MONTH
Figure A-2. Monthly rainfall in Seattle
57
-------
26
24
22
0 18
u.
O
cr 16
ui
CD
i 14
12
10
8
6
4
2
0
^NORMAL
_j i i
j i
i i
J F M A M
J J A S
YEAR
0 N D
Figure A-3. Monthly number of days of rain in Seattle
58
-------
20
18
o.
o- l4
UJ
UJ
o
I 10
Ul
o 8
oc
tu
4
2
0
M
M J J
MONTH
N
Figure A-6. Monthly wind speed in Seattle
61
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APPENDIX B
PARTICLE CHARACTERIZATION
For most of the study cities members of the GCA study team acquired
hi-vol filters from the 1974 filter banks of the cognizant local agen-
cies. In addition, several filter samples for 1974 and selected earlier
years were obtained from state and federal filter banks. Although some
filters underwent chemical and/or detailed physical analysis, the prin-
cipal purpose of obtaining filters was to utilize optical microscopy to
identify each of the constituents that comprised more than five percent
of the particulate mass. The selected filters, which were representative
of several different site types and TSP levels within each study area,
were returned to a clean room at GCA/Technology Division and carefully
inspected for artifacts and evidence of sampler or filter malfunctions.
Each filter was then assigned a randomly generated five digit number
which served as the only identifier for the filter sample so that each
analyst had no information concerning the city, site, TSP loading or
probable local sources associated with the sample. Furthermore, the use
of two laboratories for the microscopy, coupled with the randomly gen-
erated identifying numbers, permitted a fairly comprehensive quality
control program in the form of blind replicate analyses. Since both
laboratories utilized more than one analyst, these procedures resulted
in as many as four microscopists observing samples from the same filter
and, in some cases, the same analyst examining replicate samples from
the same filter as many as three times.
62
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The resuls of this quality control effort, which are presented in Vol-
umes I and II, warn against relying very heavily on the results of any
one filter analysis. However, the random match-up between analyst and
filter sample should minimize systematic bias in composited results,
Twenty-three filters from six sites were selected for analysis in Seattle
and the meteorological data from the Seattle-Tacoma Airport for the
selected sampling days are summarized in Table B-l. To gain some insight
into the contribution of secondary particulates, much of which is too
small to be observed by the microscopists, the annual average sulfate
and nitrate concentrations for the NASN site are shown in Table B-2.
The results for each of the filters submitted for routine analysis are
presented in Table B-30 The results for the filters at each site have
been averaged to give a composite of the particulate composition as
shown in Table B-4. Six filters underwent replicate analyses, and the
results are presented in Table B-5o
The composite particulate characterization for all filters from Seattle
that underwent routine analysis, presented in Table B-6, shows that
minerals predominat but not to as great a degree as observed in many
study cities. Only three cities had lower average percent minerals than
Seattle. Quartz was the major mineral constituent observed (over half
of the mineral content) followed by lesser but nearly equal amounts of
feldspars and calcite0 The DOE site, which recorded the highest TSP
levels in 1974, showed somewhat larger than average amounts of minerals
presumably because of its proximity to the highway.
The site with the lowest average percent minerals was the Public Safety
Building (K-l) which seems to be consistent with the high sampler
location (80 feet above ground). Oddly, this site also recorded the
highest levels of rubber, an observation apparently inconsistent with
the sampler location.
63
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Table B-l. METEOROLOGICAL DATA ON SELECTED SAMPLING DAYS
(SEATTLE-TACOMA AIRPORT)
Pre
Day
Date ob
6/10/74 C
6/28/74 C
cipitation,
in. Wind speed, mph
of Preced-
s. ing day Average
; 0 8.1
t 5.6
7/22/74 00 8.9
9/14/74 C
9/26/74 t
!
0 3.5
i
0 8.5
10/08/74 0 0 4.6
Resultant
6.6
3.2
8.2
2.3
2.9
4.6
Wind direction, deg
3-hour
20,
360,
120,
210,
200,
220,
C,
270,
180,
160,
20,
290,
10,
310,
160,
240,
160,
230,
C,
290,
130,
320,
10,
290,
obs.
350,
350,
200,
C,
190,
230,
300,
C,
170,
340,
330,
30,
250
20
250
330
220
240
260
30
220
100
10
C
Resul-
tant
360
220
210
300
170
350
Note: C = Calm
t = Trace
Table B-2. ANNUAL AVERAGE CONCENTRATION OF SULFATE AND
NITRATE IONS AT THE SEATTLE, WASHINGTON
NASN SITE NO. 491840001 (yg/m3)
Year
1972
1973
1974
Sulfate
Arithmetic
mean
6.27
6.69
8.40d
Geometric
mean
6.02
6.53
8.19a
Nitrate
Arithmetic
mean
1.56
2.36
2.153
Geometric
mean
1.22
2.09
1.943
Indicates insufficient data for statistically valid year.
64
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Table B-6. CITYWIDE COMPOSITE SUMMARY OF
FILTER ANALYSES IN SEATTLE
No. of filters
Components
Minerals
Quartz
Calcite
Feldspars
Hematite
Mica
Other
Combustion
Products
Soot:
Oil
Coal
Misc. soot
Glassy
. fly ash
Incinerator
fly ash
Burned wood
Burned paper
Magnetite
Carbon black
Other
Biological
Material
Pollen
Spores
Paper
Starch
Misc. plant
tissue
Leaf
trichomer
Miscellaneous
Iron or steel
Rubber
Other
23
Quantity,
percent
Average
(60)
35
9
10
5
<1
1
(27)
10
6
1
<1
9
<1
<1
1
( 3)
1
<1
1
<1
<1
1
(10)
<1
10
<1
Range
30-96
7-65
1-20
0-28
1-15
0-4
1-62
0-25
0-22
0-16
0-45
0-6
tr-24
0-20
0-2
0-3
0-2
0-2
0-18
<1-40
0-2
0-40
0-15
71
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EPA 450/3-76-026h
n 1 L< ,.M,} Sl'L- , I ' I.
I! KLCir.lNI ', ACCLGSIUN-iVO
National Assessment of the drbar, ''articulate Problem; I June .976
Volume X - Seattle
Gordon L. Deane, Frank Record, Project Director
GCA Technology Division
Burl ing ton Road
Bedford, MA 01730
1? SPONLOHIMC, Ai ' Tj C i' '. / \ '_ M N I ) A ' u-' ."
U. S. Environmental Pro+ertion Agency
Office of Air Qual'ty Planning and Standards
Research Triangle Park, fiorth Carolina
! GCA-TR-76-25-G(10)
liO I'I it il 11'AM I I I Ml ri I Nil
i I ! COMYllAC I -GUAM f f\f)
68-02-1375
15 supi'UMiNTAFWNo..:, Volii!i,c I, "iatioMal Assessment - EPA 450/3-76-024; Volume 11,
Particle Characterizecion - EPA 450/3-76-025; Volumes III-XVI, Urban Area Reports
EPA 450/3-76-0266 1 hru 026n.
16 ABSTRACT
This document is one volu.iie of a s ixtcon-vo'i un.o report presenting an overall
assessment of the particulate problem, which was conducted by GCA/Technoloyy
Division for L'PA.
This particular document is one of fourteen single-area volumes that provide
working summaries jf data a r: tiered in the foui'teen urban areas studied. These
city reports primarily provide documentation and background information for
Volume I of the study - [,'ation-il Assessment of the Participate Problem - Filial
Report. Volume I should be considered the primary output of the report.
17
Particulate Matter
Total Suspended Particulate
Emission Sources
Control Metnods
Air Quality Measurements
13 o i s r P i rf OT i o \
U.VI..-M Re]ease Unlimited.
Available for a fee, Thru the National
Technical Information Service, 52f;5 Port
Royal Road. Springfield, VA 22151
I Optical Kicroscopy
j Secondary Particulates
j Fuel Coribustion
j Process Emissions
| Fugi tive Emissions
I Fugitive Dust
j Moni tor Si t ing
I Mnteoro.ogy
' 19 L.L CURI I y CLA /;
Unclassified
?0 bt CURIT V CLA',r,
Unclassified
OI I' A i i I S
89 __
CL ~
EPA Form 2220-1 (9-7:,
72
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