EPA/450/2-81/017g
U.S. Environmental Protection Agency
Air Pollution Training Institute
COURSE 81:422
3rd Edition
AIR POLLUTION CONTROL
ORIENTATION COURSE
*************************************#**»***********************
Unit 7
Standards and Regulations
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United States Air Pollution Training Institute EPA 450/2-81 -017g
Environmental Protection MD 20 June 1961
Agency Environmental Research Center
Research Triangle Park NC 27711
Air
APTI
Course S 1:422 3rd Edition
Air Pollution Control
Orientation Course
Unit?
Standards and Regulations
Prepared By: Under Contract No.
Northrop Services, Inc. 68-02-2374
P. 0. Box 12313 EPA Project Officer
Research Triangle Park, NC 27709 R. E. Townsend
United States Environmental Protection Agency
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
This is one of nine self-instructional units in the
Air Pollution Control Orientation Course SI:422.
This unit consists of a cassette tape and this flip -
book, which you will use simultaneously.
Turn the page and read the tips on effective use
of this material.
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Tips for Effective Use of This Material
1. Listen to the recorded script while you gu through this flipbook. The recorded
portion is coordinated with the flipbook. Wait for the tape to finish the details
of one point before studying the next point on the page.
2. When you hear a "beep" on the tape, direct your attention to the next page in
the flipbook.
3. Pay attention to both words and pictures — they both convey important informa-
tion. The flipbook will usually summarize main points or give examples.
4. Stop the tape at any point if you wish to spend more time reading a page in the
flipbook. Rewind the tape if you wish to review a portion of the script.
5. Review the lesson objectives before answering the questions at the end of each
lesson. Ask yourself whether you have mastered the information indicated in the
objectives.
6. Answer the questions. They will help you assess your progress in mastering the
course materials.
7. Check your answers. The correct responses can be found on the page(s) fol-
lowing the questions.
8. If you answer a question incorrectly, review the flipbook material covering the
subject matter. Now Turn On the Tape Recorder and Begin Lesson I.
ii
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Lesson I: Introduction to Control Strategies
Objectives
1. List 2 major objectives a State control strategy must address.
2. Identify statements which are true of PSD and NAAQS.
3. List two steps involved in the development of control strategies.
4. Recall the proportional rollback model formula and explain what it represents.
5. Match statements about AQM and BACT to the relevant philosophical
approach.
6. Identify two ways in which air quality simulation models differ.
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State Strategies
Our discussion will center on State strategies,
but remember: municipalities, counties, and
other subdivisions of a state may also:
• Develop control strategies for their area
• Enforce any regulations they adopt.
Such strategies must be consistent with or more
stringent than State regulations.
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State Control Strategy Objectives
Meet National Ambient Air Quality Standards
(NAAQS)
Ensure Prevention of Significant Deterioration
(PSD)
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NAAQS
(National Ambient Air Quality Standards)
Definition
National Ambient Air Quality Standards (NAAQS) specify the maximum pollutant
levels which may not be exceeded in the ambient air to protect the public from
adverse effects. These national standards are only set for "Criteria" pollutants.
Criteria pollutants are those for which EPA has published an ambient air quality
criteria document. An air quality criteria document describes the kinds of effects
on health and welfare to be expected from various pollutant exposures and presents
other information.
Kinds
There are two kinds of standards for criteria pollutants:
Primary—intended to protect public health
Secondary—intended to protect public welfare
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Prevention of Significant
Deterioration (PSD)
• where air is purer than national air quality standards require
• where the data on air quality is insufficient
Baseline concentrations: pollutant levels as of August 7, 1977 measured
or estimated from current data with corrections for emissions sources
which began construction after
January 6. 1975.
INDUSTRIAL PARK
CLASS III
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Philosophical Approaches to Control Strategies
Air Quality Management (AQM)
write emission control standards that will control emissions to the extent that
National Ambient Air Quality Standards are attained and maintained.
Best Available Control Technology (BACT)
write emission control standards that reflect the degree of control known to be
achievable through application of best available control technology.
AQM BACT
Air quality control Does not encourage further
technology-forcing development of control
technology by the private
sector
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Development of State Control Strategy
Step 1—Determine whether to operate under National Ambient Air Quality
Standards or to adopt State air quality standards
Most States adopt Federal standards because:
• Expensive research required to justify more stringent standards.
• More Federal support available for attaining and maintaining national
standards.
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Development of State Control Strategy
Step 2 — Compare the existing ambient concentrations of air pollutants with
ambient air quality standards and estimate amount of reduction needed
for each pollutant.
Simplest method to determine required reduction: proportional (or rollback)
model: R = Total percentage reduction needed.
A x Existing pollutant concentration.
C = Air quality standard.
B = Background concentration of pollutant.
(100)
A-B
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Disadvantages of the Proportional
Rollback Model
• Poor assumption for pollutants that react rapidly in the
atmosphere
• Does not consider how emissions and resulting air quality
levels are spatially distributed across an area
• Does not consider how pollutants behave in the atmosphere
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Disadvantages of the Rollback Model led to the
development of more sophisticated models which
are mathematical descriptions of the
• Transport
• Dispersion and
• Chemical transformation processes that
occur in the atmosphere.
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Simulation Models Differ With
Respect To:
Pollutant types for which they may be used,
Emissions data input requirements.
Meteorological data input requirements.
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Specification of required emissions reductions is
most difficult for some pollutants that undergo
extremely complex photochemical reactions in
the atmosphere.
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Review of Lesson I
State Control Strategy
Definition
Objectives for: NAAQS and PSD
Standards to be considered:
NAAQS including primary and secondary standards.
State Ambient Air Quality Standards: disadvantages
Philosophical approaches: AQM, BACT
Steps involved in developing:
1 . Choosing NAAQS or State ambient air quality standards
2. Estimation of needed reduction using
Simple proportional rollback model
More sophisticated models
Characteristics of these models; differences
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Lesson I
Questions
1. List 2 major objectives a state control strategy must address.
2. For each statement, determine whether it pertains to PSD and/or NAAQS.
a. two major concerns which must be addressed in a state control strategy
b. concerns the maintenance of air quality where the air is already purer than
required by standards for SO2 or paniculate matter
c. set for all the criteria pollutants
d. relevant areas designated as Class I, Class II and Class III
3. List two steps involved in the development of control strategies.
4. Write the formula for the porportional rollback model and explain what it
represents.
5. State two weaknesses of the proportional rollback model.
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6. Simulation models may differ with respect to (indicate the appropriate
parameters):
a. types of pollutants.
b. emission data input requirements.
c. AQM.
d. State control strategies.
e. meteorological data input requirements.
7. For each phrase or term, identify whether it relates to AQM or BACT in terms of
philosophy for writing emission control standards.
a. technology forcing
b. controls criteria pollutants
c. achievable through the application of best technology available
d. controls specific new sources
Answers are on the next 3 pages.
15
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Lesson I
Answers
1. Meet NAAQS, ensure PSD
2. a. PSD and NAAQS
b. PSD
c. NAAQS
d. PSD
3. (1) Choose ambient air quality standards for the designated criteria
pollutants.
(2) Compare the existing ambient concentrations of air pollutants with the
ambient air quality standards and estimate the amount of reduction
needed for each pollutant.
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4. The proportional rollback model formula is:
A-C
R=-(100)
R=tot. percentage reduction required
A = existing pollutant concentration
C = air quality standard
B = background concentration of the pollutant
5. Any two of the following:
• not appropriate for pollutants which react rapidly in the
atmosphere
• does not consider how emissions and resulting air quality levels are
spatially distributed across an area
• does not consider how pollutants behave in the
atmosphere
17
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6. a. types of pollutants
b. emission data input requirements
e. meteorological data input requirements
7. a. AQM
b. AQM
c. BACT
d. BACT
After checking your responses, please turn on the tape recorder.
18
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Lesson II: Legal Aspects of
Emission Control Regulation
Objectives
1. List, in order, five basic steps in the development of
enforceable emission control regulations.
2. List the agency responsible for each step in the control regulations develop-
ment process.
3. Describe enforcement powers that must be available to a state air pollution
control agency in order to receive federal approval of a state
implementation plan.
4. State the location, in the Code of Federal Regulations, of information
about enforcement power.
5. List and briefly describe four legal concepts that should be considered
when developing emission control regulations.
6. Identify which one of the four legal concepts applies to specific cases or
examples of emission control regulations.
19
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Developing Enforceable Emission Control Regulations
Emission control regulation: a rule which restricts in some way the amount of
pollutants coming out of a stack.
1
Enact
Basic
Law
Determine
Ambient Air
Quality
Standards
by State
legislature
3
Design
Program
by State legislature
or State air pollution
agency
by air pollution
control officials
4
Adopt
Regulations
5
Enforce
Regulations
by air pollution
control officials
20
by State air pollution
control agency
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Enforcement Powers that must be available to the State
Agency are spelled out in:
Title 40, Section 51.11 of the Code of Federal Regulations
(CFR)
Most important authorities required:
• Authority to prevent construction, modification or operation of any sta-
tionary source where emissions will prevent attaining or maintaining a
national standard or violate any emission regulation.
• Authority to obtain information necessary to determine whether air pollution
sources are in compliance with applicable laws, regulations, and standards.
21
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Legal Aspects to be Considered
in Developing Emission Control Regulations
*,;.-* \,£
-*
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FAIRNESS
UNDERSTAND
ABILITY
CLOSED
^™
ENFORCEABILITY
ATTAINABILITY
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Fairness
unequal treatment = problems
PERMISSIBLE
PROHIBITED
23
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Enforceability
• Enforcement personnel with
authoniy to cite a violator and se-
cure the evidence required to con-
vict him
• The practicality of detecting a vio-
lation with effective defensible,
test methods
• Careful wording or regulations to
avoid loopholes that allow circum-
vention
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Understandability
Personnel immediately in-
volved in the affected pro-
cesses must be able to
understand the provisions
of the regulations and
know what is expected of
them.
25
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Limit the use of solid
fuels to those of no more
than 0.5% sulfur by
weight!
Attainability
That's not attainable.
I can't get low sulfur
coal in my region. .
The court agrees.
If he can't get the
low sulfur coal,
the regulation is
unreasonable.
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ALSO ATTAINABILITY
Limit the use of solid
fuels to those of no more ,:'
than 0.5% sulfur by .
weight!
That's not attainable.
I can't get low sulfur
coal in my region.
It is attainable!
Use oil or gas to
meet the standard!
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Lesson II
Questions
Answer the following questions on a separate sheet of paper.
1. State in order, five steps in the development of enforceable emission con-
trol regulations.
2. After each step listed in answer one, write the name of the agency respon-
sible for that step.
3. List four legal points that should be considered when developing emission
control regulations.
4. After each legal point listed in answer three, write a brief definition.
5. For each of the following examples, identify one legal concept (from
those listed in answers three and four) that applies to the case.
a. a state regulation requiring a small plastics plant to curtail emissions
by 95% while a larger plastics manufacturer must curtail emissions by i
only 88%.
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b. emission regulations for apartment incinerators use technical terms to describe
the chemical composition of waste that may be burned.
c. a large state industry exceeds state emission limits but the state lacks an effec-
tive detection system to prove that the violation occurred.
d. an industry legally satisfies emission regulations by diluting the gas stream with
air rather than reducing the amount of pollutant emitted.
e. a state limits the use of solid fuels to those of no more than 5% sulfur by
weight but such fuels must be ordered from another state where fuel orders are
backlogged six months or more.
f. an industry repeatedly violates state emission regulations but state air pollution
officials lack the authority to cite the violator and secure evidence against him.
29
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6. Give one example of an enforcement power that must be available to a state air
pollution control agency to receive federal approval of a state implementation
plan.
7. In what part of the Code of Federal Regulations can you find information about
enforcement powers that are to be available to state agencies in order to comply
with the Federal Clean Air Act?
Title?
Section?
Answers are on the next 3 pages.
30
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Lesson II
Answers
a. enact basic law
b. determine ambient air quality standards
c. design program
d. adopt regulations
e. enforce regulations
a. State legislature
b. State legislature or State air pollution agency
c. air pollution control officials
d. air pollution control officials
e. State air pollution control agency
a. fairness
b. understandability
c. attainability
d. enforceability
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4. (Definitions should approximate those listed below)
a. standards and regulations must be fair to all parties.
b. personnel immediately involved in affected processes must be able to
understand provisions of regulations
c. regulations must not impose undue economic hardships or technically impos-
sible restrictions
d. enforcement personnel must have authority to cite a violator and secure
evidence against him, detection of violations must be practical and regulations
must be carefully worded to avoid loopholes.
5.a. fairness
b. understandability
c. enforceability
d. attainability
e. attainability
f. enforceability
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6. (either answer below)
Authority to prevent construction, modification, or operation of any stationary
source at any location where emissions from such sources will prevent attaining or
maintaining a national standard or violate an emission regulation.
OR
Authority to obtain information necessary to determine whether air pollution
sources are in compliance with applicable laws, regulations, standards.
7. Title 40, section 51.11
After checking your responses, please turn on the tape recorder.
33
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Emission
Regulations
Require direct measurement
of the pollutant output from the
source to test for compliance
4 Types
• Air Dispersion Regulations
• Concentration Regulations
• Process Weight vs. Emission
Rate Regulations
• Heat Energy Input Regulations
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Types of Emission
Regulations
Air Dispersion Regulations
are based on the principle of dispersion
of pollutants in the atmosphere and
limit a plant's emissions in accordance
with the distance between the stack, the
nearest property line, and stack height.
Regulations of this type generally at-
tempt to limit the ground-level concen-
tration at the nearest property line to
an acceptable level under the worst
weather conditions.
Note: Many of these regulations have been abandoned because
they have generally proved ineffective and are
generally inconsistent with the Federal Clean Air Act.
(Best applied to large, isolated sources such as a rural power
plant —less applicable in an urban setting)
37
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Lesson III: Control Regulations
Objectives
1. List four types of control regulation.
2. Briefly describe each of the four types of control regulation.
3. List four types of emission regulations.
4. Briefly explain the way in which levels of emission standards are determined
(quantitatively) for all four types of emission regulations.
5. Label examples of control regulations with the appropriate regulation type.
6. Match legal concepts learned in lesson II with problems associated with types of
control regulations learned in lesson III.
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Types of Control Regulations
1. Emission regulations
• Dispersion regulations
• Concentration regulations
• Process weight vs. emission rate regulations
• Heat energy input regulations
2. Regulations of use of types of equipment, practices or fuels
3. Plume opacity regulations
4. Odor regulations
35
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Pollution Concentration in Gas Stream
Constructed in terms of ratios including:
Weight unit of pollutant per
weight unit of total stack gas
Volume unit of pollutant
per volume unit of stack gas
Weight unit of
pollutant per
volume unit
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Regulations Based on Concentration
of Pollutant in the Gas Stream
City of Archville, Air Pollution Control Ordinance
Section 14:
The emission or escape into the open air of fly ash or other solid paniculate
matter resulting from the combustion of fuel. . . from any furnace or other
combustion device for the burning of fuel, or from any chimney connected
thereto, in quantities exceeding 0.85 pounds per 1000 pounds of gases is pro-
hibited and is hereby declared to be a nuisance.
Weight Unit/Weight Unit
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Regulations Expressed as Weight Units
Per Volume of Stack Gas
Portincula County
Rule 5, Particulate Matter —Concentration
A person shall not discharge into the atmosphere from any source particulate
matter in excess of the concentration shown in the following table:
Where the volume discharged falls between figures listed in the table (28) the
exact concentration permitted to be discharged shall be determined by linear
interpolation.
The provisions of this rule shall not apply to emissions resulting from the
combustion of liquid or gaseous fuels in steam generators or gas turbines.
For the purposes of this rule "particulate matter' includes any material which
would become particulate matter if cooled to standard conditions.
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Table for Rule 5
Volume discharged
cubic feet per minute
calculated as dry gas
at standard conditions
1000
1200
1400
1600
1800
2000
2500
3000
3500
4000
5000
6000
7000
8000
10000
15000
Maximum concentra-
tion of particulate
matter allowed in dis-
charged gas grains per
cubic foot of dry gas
at standard conditions
0.200
.187
.176
.167
.160
.153
.141
.131
.124
.118
.108
.101
.0949
.0902
.0828
.0709
Volume discharged —
cubic feet per minute
calculated as dry gas
at standard conditions
20000
30000
40000
50000
60000
70000
80000
10000
20000
40000
60000
80000
100000
150000
200000
250000
Maximum concentra-
tion of particulate
matter allowed in dis-
charged gas —grains per
cubic foot of dry gas
at standard conditions
0.0635
.0544
.0487
.0447
.0417
.0393
.0374
.0343
.0263
.0202
.0173
.0155
.0142
.0122
.0109
.0100
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Concentration Regulations Expressed as
Volume Unit to Volume Unit
No person shall cause or permit the
emission of an air contaminant
from equipment used in a manu-
facturing process if the air con-
taminant emitted as measured in
flue gas contains sulfur com-
pounds, calculated as sulfur di-
oxide, of more than 2,000 parts per
million.
A person shall not discharge into
the atmosphere sulfur compounds,
which would exist as a liquid or
OR gas at standard conditions, ex-
ceeding in concentration at the
point of discharge, 0.2 percent by
volume calculated as sulfur dioxide
(S02),
Volume Unit/Volume Unit
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It is possible to circumvent concen-
tration regulations:
• By altering temperature
• By altering pressure
• By diluting concentration by addition
of more air
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To Prevent Circumvention of Concentration
Regulations Agencies Must:
• Define standard conditions of temperature, pressure and include a correction for
dilution where possible.
Example of a general provision to prevent circumvention:
A person shall not install or use any device or equipment, the use of which,
without reducing the total release of pollutants to the atmosphere, reduces or con-
ceals emissions which would otherwise be in violation of State law or these
regulations.
• Concentration regulations applicable to fuel burning sources specify the amount
of combustion air to be considered present in calculating emissions (% excess air
or %CO2 or % oxygen).
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Concentration Regulations With Standards
Specified and a Means of Preventing
Circumvention by Dilution Are:
• Fair
• Enforceable
But in an industrial source in which combustion
is just one of the processes, it may not be proper
to apply the correction for dilution from the
process to the whole operation.
45
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Process Weight vs. Emission Rate Regulation
Controls emissions from industrial processing plants such as:
• Steel plants
• Cement plants
• Gray iron foundries
• Asphalt batching plants
Allowable emissions are measured as weight units per unit of
time—usually pounds per hour related to the weight of process
materials input to the production system.
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Problems That Cause Some People to Prefer
Concentration Regulation Over Process
Weight Rate vs. Emission Rate Regulation
• Considered by some to be unfair to larger sources
• Can be partially circumvented by dividing an operation into
several smaller ones, each allowed to produce emissions just
below the standard
• Enforcement complicated by the need for source testing to
include determination of process weight figures
47
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Heat Input vs. Emission Rate
Regulation
A fourth type of emission regulation similar to
process weight regulations is one that regulates
emissions based on
Heat energy input to a combustion system.
50
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Heat Input Rate vs. Emission Rate Regulation
used to determine the allowable particulate emission rate from
existing fossil fuel combustion sources
If, for example, a coal-fired power plant uses coal with a gross
heating value of twenty million Btu per ton and it has a maxi-
mum, one-hour average input rate of 5 tons per hour, then the
heat input —the product of these two values—is one hundred
million Btu per hour. The regulation will specify an allowable
emission rate commensurate with this heat input rate.
51
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It
is
c g
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« u
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JU
3
H
o
10.0
1.0
0.1
0.0
Allowable Emissions From Solid
Fuel Combustion Sources Outside Bovopolis
10
100
1,000
10,000
100.000
10 100 1,000
Actual heat input, million Btu per hour
52
10,000
100,000
Types of Control
Regulations
1. Emission regulations
• Dispersion regulations
• Concentration regulations
• Process weight vs. emission rate regulations
• Heat energy input regulations
2. Regulations of use of types of equipment, practices or fuels
3. Plume opacity regulations
4. Odor regulations
53
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Regulations
Pertaining to the
Use of Fuels and to
Fairness
Need to assure that fuel of the
required quality is or can be
made available.
Should allow for alternative
means of compliance (e.g.,
emission control equipment) if
fuel of required quality is not
used.
54
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Regulations Pertaining to the Use of Types of
Equipment, Fuels or Practices
Rule 62 of the Metro Air Pollution Control District
A person shall not burn any gaseous fuel containing sulfur compounds in excess
of 50 grains per 100 cubic feet of gaseous fuel, calculated as hydrogen sulfide
at standard conditions, or any liquid fuel or solid fuel having sulfur content in
excess of 0.5 percent by weight.
55
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The provisions of this rule shall not apply to:
a. The burning of sulfur, hydrogen sulfide, acid sludge or other sulfur com-
pounds in the manufacturing of sulfur or sulfur compounds.
b. The incinerating of waste gases provided that the gross heating value of
such gases is less than 300 British thermal units per cubic foot at standard
conditions and the fuel used to incinerate such waste gases does not contain
sulfur or sulfur compounds in excess of the amount specified in this rule.
c. The use of solid fuels in any metallurgical process.
d. The use of fuels where the gaseous products of combustion are used as raw
materials for other purposes.
e. The use of liquid or solid fuel to propel or test any vehicle, aircraft, missile,
locomotive, boat or ship.
f. The use of liquid fuel whenever the supply of gaseous fuel, the burning of
which is permitted by this rule, is not physically available to the user due to
accident, act of God, act of war, act of the public enemy, or failure of the
supplier.
Turn on the tape recorder and stay on this page.
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Regulations Prohibiting or Requiring Use of
Types of Equipment
Examples:
• Prohibiting the use of single-chamber apartment house
incinerators in many large cities.
• Specifying that floating roofs be used on large gasoline storage
tanks.
57
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Regulations
Pertaining to the
Use of Certain
Practices
Examples:
• Open burning is prohibited in
many areas.
• Wetting down unpaved haul
roads is required on construction
sites to control fugitive dust.
58
Types of Control Regulations
1. Emission regulations
• Dispersion regulations
• Concentration regulations
• Process weight vs. emission rate regulations
• Heat energy input regulations
2. Regulations of use of types of equipment, practices or fuels
3. Dense smoke and plume opacity regulations
4. Odor regulations
59
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The
Ringelmann
Scale
Maximillian Ringelmann
developed charts used to
train smoke inspectors to
differentiate the density of
smoke plumes with the
naked eye.
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Ringelmann No. 1
(20% black —equivalent to 20% opacity)
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Ringelmann No. 2
(40% black—equivalent to 40% opacity)
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Ringelmann No. 3
(60% black —equivalent to 60% opacity)
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Ringelmann No. 4
(80% black —equivalent to 80% opacity)
Turn on the tape recorder and stay on this page.
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Opacity Used As An
Indication of Accept-
ability of Emissions
Density is detected from reflected light.
Because darker colored plumes reflect less light,
they appear blacker.
Opacity is based on the amount of light
passing through a plume. The more opaque
the plume, the less light passing through.
For practical purposes, density and opacity are
equivalent. Standards for paniculate matter in the
Code of Federal Regulations, Title 40, Part 60, are
written in terms of opacity only, with no reference to
Ringelmann numbers.
65
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Ringelmann/Opacity Regulations
and
Fairness and Enforcement
66
Types of Control Regulations
1. Emission regulations
• Dispersion regulations
• Concentration regulations
• Process weight vs. emission rate regulations
• Heat energy input regulations
2. Regulations of use of types of equipment, practices or fuels
3. Plume opacity regulations
4. Odor regulations
67
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Odorous
Emissions
are generally controlled under
nuisance-type laws rather than by
specific, quantitative emission
regulations.
Proof of nuisance depends on
evidence given by representatives of
the affected population and on
proof that a particular source is the
cause of the nuisance.
i--.
I
The intensity of a perceived
odor is very nearly a linear
function of the logarithm of
concentration of a chemical.
Thus, to have significant
impact on the intensity of
the perceived odor of some
odorous compounds, the
emission must be reduced to
1/1 Oth of its original rate or
less.
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Emission regulations for odors based on standards for equipment used to
burn odorous gases before emission to atmosphere are:
• Fair
• Attainable
• Enforceable
Rather than collecting samples of odorous emissions, monitoring
compliance with these regulations consists of evaluating such combustion
factors as:
• Temperature
• Gas flow rate
70
Types of Control Regulations
1. Emission regulations
• Dispersion regulations
• Concentration regulations
• Process weight vs. emission rate regulations
• Heat energy input regulations
2. Regulations of use of types of equipment, practices or fuels
3. Plume opacity regulations
4. Odor regulations
71
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Lesson III
Questions
1. List four general types of control regulations.
2. Briefly explain the meaning of each of the types of regulations listed in answer 1.
3. List four types of emission regulations.
4. For each type of emission regulation listed above, briefly explain the way in
which levels of emissions are determined (quantitatively).
5. For each of the following examples, name the control regulation that best
describes the situation indicated. For emission standards-specify which type
applies.
a. restricts percentage of sulfur dioxide in the smoke stack.
b. restricts paniculate matter emission according to million Btu per hour heat
input to boilers of coal-fired plants.
c. requires continual wettng-down of demolition sites to control asbestos
particles.
d. restricts allowable emission of pollutants from gray iron foundaries as a func-
tion of pounds of iron produced per hour.
e. usually based on nuisance laws rather than specific quantitative emission
regulations.
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6. For each of the following examples, choose the one legal concept that best
describes problems associated with types of control regulations. Use the legal
concepts listed below.
w. understandability
x. enforceability
y. attainability
z. fairness
a. industry circumvents concentration regulations by altering temperature or
pressure.
b. process weight vs. emission weight regulation requires large cement plants to
exercise more pollution control than small cement plants.
c. a locally occurring high-sulfur fuel is prohibited and alternatives are costly
and difficult to obtain.
d. residents near a petroleum processing plant complain about intolerable
odors, but plant managers insist that the odors are caused by other nearby
plants.
Answers are on the next 3 pages.
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Lesson III
Answers
1. (in any order)
• emission regulations
• regulations pertaining to use of types of equipment, practices, or fuels
• plume opacity regulations
• odor regulations
2. (descriptions should approximate those given below)
• An emission regulation is a rule which restricts in some way the amount of
pollution coming out of a stack.
• Regulations pertaining to use of types of equipment, practices, or fuel restrict
choice of materials and procedures which could contribute to air pollution.
• Plume opacity regulations restrict density of smoke emissions.
• Odor regulations restrict odorous emissions on the basis of public nuisance
(inteference with use or enjoyment of property for a significant number of
people).
3. (in any order)
• air dispersion regulations
• concentration regulations _
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3. (continued)
• process weight vs. emission regulations
• heat energy input regulations
4. Answers should approximate those listed below.
• Air dispersion regulations: measure distance between stack and nearest pro-
perty line and stack height (limit ground level concentration at nearest pro-
perty line to acceptable level under worst weather conditions).
• Concentration regulations: measure ratios such as mass unit pollutant per
mass unit of total stack gas, volume unit pollutant per volume unit of stack
gas, percentage of pollutant in stack gas, or mass unit pollutant per unit
volume of stack gas.
• Process weight vs. emission rate regulations: measure weight of process
materials moving through production system (weight per unit time, for
example pounds per hour) and weight of pollutant in stack gas per unit time.
• Heat energy input regulations: measure heating value (in Btu's) of
the fuel and the rate of input of the fuel.
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5. a. concentration regulations
b. heat-energy input regulations
c. regulations pertaining to use of types of equipment, practices, or fuels
d. process weight vs. emission rate regulations
e. odor regulations
6. a. enforceability (x)
b. fairness (z)
c. attainability (y)
d. enforceability (x)
After checking your responses, review any material that you are not sure of, and
then take the unit test which begins on page 77.
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Unit Test
1. State whether the following sentence defines an ambient air quality standard or
an emissions control regulation: "Maximum levels of pollutants which may be
maintained in the air without adverse effects on public health or welfare."
2. In your own words, describe the two philosophical approaches to air pollution
abatement discussed in this module.
3. List four legal elements that should be considered when developing control stan-
dards and regulations.
4. Match the types of control regulations listed on this page with examples
provided on the following pages.
a. air diffusion regulations
b. concentration regulations
c. process weight rate regulations
d. regulations based on the heat energy input to combustion
e. regulations limiting use of specific fuels
f. smoke or plume opacity regulations
g. odor regulations
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(1) No person shall cause or permit the use of, if intended for the use in
New York City, the purchase, sale, offer of sale, storage or transportation
of: fuel oil Grade No. 2, as classified by the American Society for Testing
and Materials, which contains more than 1.0% of sulfur by weight.
(2) No person shall cause, let, permit, suffer, or allow the emission from any
combustion operation of paniculate matter in a concentration in excess
of 0.10 grain per standard dry cubic foot of exhaust gas volume.
(3) No owner or operator of a gaseous fossil fuel-fired steam generating unit
of more than 250 million Btu per hour heat input shall discharge or
cause the discharge into the atmosphere of nitrogen oxides in excess of
0.20 Ib per million Btu heat input (0.36 g per million cal.), maximum
2-hour average, expressed as NO2.
(4) No owner or operator of a Portland cement plant shall discharge or
cause the discharge into the atmosphere of paniculate matter from the
kiln which is greater than 10 percent opacity, except that where the
presence of uncombined water is the only reason for failure to meet the
requirements for this subparagraph, such failure shall not be a violation
of this section.
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(5) No person shall cause or permit the emission of paniculate matter from
equipment used in a manufacturing process if the paniculate matter
emitted as measured in the flue exceeds 0.5 pounds for each 100 pounds
or less of process weight per hour...
(6) The basic allowable emissions for coarse solid particulates shall be com-
puted as follows:
Step 1: Establish stack height
Step 2: Determine distance from the stack to the nearest property line
Step 3: Divide result of Step 2 by result of Step 1; this is the distance
from stack to nearest property line in stack heights
Using the chart provided by the agency, determine basic emissions in
pounds per hour. Then multiply the basic emission by the effect factor
assigned by the agency to find the allowable emission for coarse solid
particles.
(7) No owner, occupant or person in charge, by himself, his agent or
employee, shall cause, suffer or allow the emission of poisonous,
obnoxious, pungent or ill smelling gases, fumes, or other air pollution
from any stack or from any other source in the city so as to cause a
public nuisance.
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Answers
1. ambient air quality standard
2. a. The "air quality management" approach is to establish ambient air
quality standards which, when attained, will protect the public health
and welfare. Emission control regulations are then imposed at a degree
of control needed to bring about attainment and maintenance of the
ambient air quality standards.
b. The "best available control technology" approach is to write emission
control regulations which require sources to apply the best control
technology available. Ambient air quality is not a governing factor in
the BACT approach.
3. Fairness, understandability, enforceability, attainability.
4- (1) e (5) c
(2) b (6) a
(3) d (7) g
(4) f
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