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U.S. DEPARTMENT OF HEALTH, EDUCATION AND WELFARE
Public Health Service
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10OR62001
Air Pollution Control
FIELD OPERATIONS MANUAL
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AIR POLLUTION CONTROL
FIELD OPERATIONS
MANUAL
A Guide for Inspection and Enforcement
COMPILED AND EDITED
BY
MELVIN I, WEISBURD
S. SMITH GRISWOLD
AIR POLLUTION CONTROL OFFICER
COUNTY OF LOS ANGELES
1962
U.S. DEPARTMENT OF HEALTH, EDUCATION AND WELFARE
Public Health Service
Division of Air Pollution
Washington 25, B.C.
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TECHNICAL ASSISTANCE
Lloyd H. McEwen
Lowell G. Wayne
Maurice E. Fykes
John S. Clawson
Nathan Zlasney
Arthur J. Hocker
Harold Nicholls
Public Health Service Publication No. 937
1962
For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington 25, D.C. Price $1.25
IV
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FOREWORD
Those who have been concerned with the solution of community air pollution problems
realize the multi-faceted approach required in any effective control program. This volume is
concerned with a single facet of such a program, the field inspection and enforcement activity.
Much of the information included here necessarily is based on the fourteen years experi-
ence accrued by the Los Angeles County Air Pollution Control District. This organization for
many years has been the largest community air pollution control agency in the United States.
The size of the agency has permitted the organizational specialization of functions necessary to
the solution of the Los Angeles air pollution problem. Although such special organizational
activities might not be completely applicable to the programs administered by many govern-
mental agencies, knowledge of the techniques and procedures successful in Los Angeles might
nevertheless assist others in the battle against air contamination.
It is with this thought in mind that this manual is being made available for general distri-
bution through the auspices of the United States Public Health Service, which also contributed
to its preparation. This manual was originally prepared as a training manual for field personnel
of the Los Angeles District.
Many officers and employees of the Air Pollution Control District have contributed to its
preparation. We hope it has effectively tapped the combined experience and views of these
people. The major writing and editing load was carried by Melvin Weisburd, who, for several
years served the District as a Senior Engineering Inspector in the Enforcement Division.
The District, of course, bears full responsibility for the information contained in the manual.
It is our hope that it may contribute to the growing national understanding on the control of
community air contamination.
S. Smith Griswold
Air Pollution Control Officer
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ACKNOWLEDGMENT
Under the provisions of the law creating the Los Angeles County
Air Pollution Control District, the Board of Supervisors is empowered
to act as the Air Pollution Control Board. The pioneering efforts of
the Board over the past 14 years, the immediate adoption of advanced
control techniques, the continued support of research and develop-
ment projects and the prompt enactment of rules and regulations
have resulted in the development of a considerable body of field
enforcement and inspection practices. Without such support, the
comprehensive field control operations program, as described in this
manual, would not have been possible.
THE BOARD OF SUPERVISORS
OF LOS ANGELES COUNTY
ERNEST E. DEBS
Third District
Chairman
FRANK G. BONELLI BURTON W. CHACE
First District Fourth District
KENNETH HAHN WARREN M. DORN
Second District Fifth District
VII
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CONTENTS
Foreword v
Acknowledgment vii
1 THE NATURE AND EXTENT OF AIR POLLUTION 1
Air pollution saturation potential 1
Metropolitan pollution zone - 15
Pollution potentials - 26
2 THE TECHNOLOGY OF SOURCE CONTROL 39
Control techniques and devices 39
Control programs - 50
3 THE LAW OF AIR POLLUTION CONTROL 57
Authority and precedent for legislative enactments - - 57
Enacting air pollution control law . - 59
Air pollution control law in California — 62
ELEMENTS OF THE AIR POLLUTION CONTROL PROGRAM 71
Identification and analysis of specific air pollution problems 72
Promulgation of control standards 74
Registering the sources of air pollution 77
Field control operations — inspection and enforcement 80
ORGANIZATION OF THE AIR POLLUTION CONTROL AGENCY 83
Principles of organization 83
The Los Angeles County Air Pollution Control District 88
6 AIR POLLUTION CONTROL FIELD OPERATIONS 91
Preliminary considerations 91
Detection of the sources of air pollution 93
Inspection of the sources of air pollution 103
Reporting results of inspections 104
Review and disposition of reports 105
Prosecuting violators and handling hearing board cases 108
Maintaining record systems 114
7 THE AIR POLLUTION INSPECTOR ....121
The inspector's role 122
Conduct of the inspection 128
ix
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CONTENTS (Continued)
8 HANDLING THE CITIZEN COMPLAINT
Public relations
._-
Handling the general smog complaint [[[
Handling the specific source complaint ................................................ .................. ..................................
9 IDENTIFYING EFFLUENT PLUMES
141
The macroscopic point of view
Effluent formation and composition
Types of effluent plumes
10 READING VISIBLE EMISSIONS 155
Techniques of visual determination
11 DETECTING AND MEASURING INVISIBLE CONTAMINANTS 167
Stationary source testing 167
Toxicity and physiological response 176
On-the-spot testing 183
Sampling fuels and effluents 184
12 TRACKING SOURCES OF PUBLIC NUISANCES: ODORS, STAINS AND DEPOSITS 195
The public nuisance problem 195
Odors 197
Nuisance deposits — stains 206
Solid deposits 213
13 COLLECTING AND REPORTING EVIDENCE OF VIOLATION 215
Establishing the prima-facie case 215
Required evidence for the violations 218
Completing and serving notice forms 235
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CHAPTER ONE
THE NATURE AND EXTENT OF AIR POLLUTION
Ever since man has attempted to satisfy his basic
needs by seeking ways to manipulate his environment
more efficiently, one form or another of air pollution
has been present to plague him. The various periods of
human history — the ages of fire, copper, bronze, iron
and atomic —• testify to the fact that man has always
engaged in air polluting activities. Initially, these
were isolated in small settlements and towns and were
treated as individual cases of smokes and fumes affect-
ing only those persons living close to the sources of air
pollution. But with the impact of the industrial revolu-
tion in the 18th and 19th centuries, cities grew and air
pollution nuisances increased in frequency and com-
plexity, giving rise to total pollution of entire metro-
politan air spaces. The belching of black smoke from
chimneys and stacks over residential and industrial
areas, the blackening of the countryside with smoke
and soot symbolized not only the Victorian faith in in-
dustrial progress, but also the gloom and squalor of the
cities.
It was not until the twentieth century that the re-
sources of science and technology began to be applied
to the control of municipal air pollution with any
degree of concentration. Engineers, meteorologists,
chemists, and physicists began to investigate air pollu-
tion either as a concomitant to their basic interests, or
as a direct attack on specific problems. Consequently,
considerable knowledge of the nature and control of air
pollution emerged. The problem of air pollution was
subject to many professional disciplines, including en-
gineering, law, public administration, economics, med-
icine, and most of the major fields of pure and applied
science. While research findings cannot be said to be
complete from the scientific point of view, the control
of this historic problem is now within reach of society.
This manual is intended to complement the scien-
tific literature on the subject of air pollution by deal-
ing with the organization and administration of an air
pollution program within the legal and economic
framework of the community, and the operations con-
ducted in controlling air pollution in the field. Air
pollution control field operations are those activities
conducted by a control agency which are intended to
secure certain and continuous control of the sources of
air pollution. While this manual is necessarily more
concerned with legal and enforcement problems than
with scientific analysis of air pollution problems, sci-
ence and law are highly inter-dependent in air pollu-
tion. Field control objectives are predicated on scien-
tific analyses of specific air pollution problems, while
science, in turn, is dependent on the empirical evi-
dence generated by control activities for a proper eval-
uation of pollution and control trends.
In implementing a practical field control opera-
tions program for any given community, three basic
considerations must be taken into account. These are:
(1) the air pollution saturation potential of the air
space — the inherent capacity of the metropolitan air
space to retain air contaminants, (2) the pollution
zone — the characteristics of that land area in which
the causes and effects of air pollution are concentrated
in terms of the metropolitan economy, and (3) the
pollution potentials — the capacity of the metropolitan
economy to pollute the air in terms of contaminant
species, rates of emission, and atmospheric reactions.
This chapter is concerned with defining these variable
groupings and with reconstructing their interrelation-
ships with the view of establishing the objectives and
limitations of a realistic field operations program.
I THE AIR POLLUTION SATURATION POTEN-
TIAL OF THE AIR SPACE
A. Definition of Air Pollution
Air pollution is usually the unintentional result
of the conduct of some activity which emits undesir-
able substances into the air in either one or combina-
tion of the following physical states: (1) liquid or
solid particles capable of remaining air-borne either
permanently or for significantly long periods of time,
or (2) gaseous contaminants which expand and mix
with the gases of the atmosphere. The contaminants
may be subsequently changed from their initial state
to liquid, solid or gas forms as a result of temperature,
humidity and pressure, or they may undergo further
chemical or photochemical change as a result of atmos-
pheric forces and the presence of other reactive con-
taminants. The distribution of contaminants in the air
from a multitude of contaminant plumes causes the
formation of hazes or clouds, sometimes referred to as
"smog" or "smaze" The properties of these smogs and
the type of air pollution problems they produce depend
upon the chemical and physical nature of the contam-
inants, and the concentrations they reach in the atmos-
phere.
1. Aerosols and Particulates
The diameter of contaminant particles emitted
from man-made sources varies greatly in size, from
about 1,000 microns* (near the size of raindrops), to
particles substantially less than one micron. Particu-
lates are considered to be particles generally larger
than 50 microns, at which size they settle out of the
atmosphere. Aerosols are usually particles which
range in size from 50 microns to something less than
.01 microns. Most aerosols are considered to be less
than 1 micron in diameter.
*A micron is a microscopic unit of measure equivalent to 1/1,000
of a millimeter, or 1 /25,000 of an inch.
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Air Pollution Control Field Operations
Particulates are responsible for two basic types of
air pollution problems: (1) soiling, corrosion, injury to
clothing, property and crops as a result of deposition,
and (2) adhesion of particulates to repiratory tissues,
with possible physiological impairment or damage.
Particulates may, therefore, include toxic substances,
possible carcinogens and radioactive materials.
Aerosols tend to remain suspended permanently
in the air and are usually emitted either in aerosol
form, or evolve from the fracturing and decomposition
of larger particulates, or they may form in the air from
the condensation and nucleation of gaseous contamin-
ants. The smaller the aerosols, the more they behave
like a gas. Aerosols, therefore, are not as readily de-
posited as the particulates, and may be inhaled and
exhaled with air. Aerosols are also important for their
ability to reduce visibility through the process of light
scattering. They may grow through accretion of
matter, absorb water vapor present in atmospheres
of high relative humidity (hygroscopic particles) and
then settle out as particulates. Some thermal precipi-
tation of aerosols on cooler surfaces occurs, but this
effect is not significant. Much yet remains to be known
about the properties of aerosols and their effect on the
environment.
2. Gases
The gases significant in air pollution represent a
wide range of organic and inorganic compounds, as
shown in Tables 1-1 and 1-7.
Contaminant gases diffuse and mix with air, and
to a small degree may alter the natural composition of
the atmosphere. Gases are important for their reac-
tive, toxic, irritant and malodorous properties in con-
centrations found in many urban atmospheres. The re-
active gases, such as organic vapors, oxides of nitrogen
and ozone, may participate in the formation of a num-
ber of other contaminants, both gases and aerosols.
(See Part IV B, this chapter.) The toxic and irritant
gases include those emitted directly from the sources
of air pollution, such as carbon monoxide, sulfur diox-
ide, and those deriving from atmospheric reactions,
such as ozone and nitric oxide. The contaminant gases,
most of which are invisible, appear to present the
greatest possibility of affecting the health of the pop-
ulation.
"Ambient air quality"(3) may be defined as that
composition of the natural and foreign constituents of
the metropolitan air which may affect health, illness,
death, damage to vegetation, and interference with
visibility. In virtually all air pollution problems in-
vestigated, significant alteration of the natural compo-
sition of the air either by addition of a foreign constit-
uent, or by an excess or depletion of vital oxygen, has
not occurred. In relation to the total volume of air, the
effects of gaseous contaminants, as well as those of the
particulates, are manifested at extremely low concen-
trations. The total volume of air contaminants found
in urban atmospheres is generally far less than one-
tenth of 1 per cent of the total air volume.
3. The Sources of Air Pollution
To the extent that there is constant and varied
activity taking place on the surface of the earth, the
general concept of air pollution includes a large vari-
ety of specific air pollution problems. These can be
divided into two broad classes: natural and man-made.
Natural pollution results from physical and bio-
logical processes in the earth's environment, and in-
cludes dusts or minerals ventilated from the soil, ash
from volcanic eruptions, salt water crystals blown from
the surfaces of large bodies of water and air-borne
bacteria and pollen spores from an infinite variety of
plant life. The atmosphere also absorbs quantities of
solar and cosmic radiation from outer space. Short
wave-lengths, in particular, influence the production of
ozone at high altitudes.
Man-made air pollution, as it is known today, is
a by-product of a civilization which has become de-
pendent on its technology and industry for its survival.
Modern civilization has progressed by the replace-
ment, substitution or extension of manual or natural
activities, such as those found in primitive economies,
with mechanical devices and synthetic or fabricated
materials. These involve industrial techniques, vehicu-
lar, marine and aerial forms of transportation, mass
communication, rapid distribution of raw materials
and manufactured products, centralization of energy
and heat sources, together with all services necessary
to the construction and maintenance of the metropol-
itan community. These activities can be reduced to
three forms of air-contaminating processes: (1) com-
bustion, (2) vaporization and (3) mechanical attrition.
The combustion of fossil fuels and waste materials
for heat, steam and electrical energy is applied uni-
versally throughout the metropolitan economy to pro-
vide warmth, metal melting, motive power, food pro-
cessing, incineration of waste materials, baking, temp-
ering, curing, and many other processes. The products
of combustion — smoke and gases — comprise contam-
inant plumes typical of all cities.
Vaporization or volatilization is a by-product of a
large variety of chemical and manufacturing processes
which induce physical changes in substances through
the application of heat and pressure, thereby causing
some component materials to vaporize in the atmos-
phere. Vaporization includes the evaporation of vola-
tile materials at normal atmospheric temperatures and
pressures; fuming as a result of induced temperatures;
and decomposition of organic materials as a result of
natural processes. Some materials with high vapor
pressures will evaporate within the range of normal
atmospheric temperature and pressure conditions.
These include petroleum derivatives such as gasoline
and fuel oil which are consumed by the entire econo-
my, from motor vehicles and fuel-oil burning to organ-
ic solvent usage.
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TABLE I -1
CALIFORNIA STANDARDS FOR AMBIENT AIR QUALITY
POLLUTANT
Oxidant
Ozone
Nitrogen Dioxide
Hydrocarbons
Photochemical
Aerosols
Carcinogens
Sulfur Dioxide
"ADVERSE" LEVEL
Level at which there
will be sensory irritation.
damage to vegetation, re-
duction in visibility or
similar effects.
"Oxidant Index"
0.15 ppm for one
hour by the potas-
sium iodide method
(eye irritation.
plant damage and
visibility reduction )
Not applicable
1 com for 1 hour or 0.3
j| ppm for 8 hours (plant
Sulfuric Acid
Carbon .Monoxide
Lead
Ethylene
Particulates
damage)
Footnote 6
Not applicable
Not applicable
Footnote 10
Sufficient to reduce visi-
bility to less than 3 miles
when relative humidity is
less than 70 percent
"SERIOUS" LEVEL
Level at which there will
be alteration of bodily
function or which is
likely to lead to chronic
disease.
Not applicable
Footnote 1
Footnote 3
Footnote 4
Not applicable
Footnote 5
5 ppm for 1 hour (bron-
choconstriction in hu-
man subjects)
Footnote 6
30 ppm for 8 hours or
120 ppm for 1 hour (in-
terference with oxygen
transport by blood)
Footnote 9
Not applicable
Not applicable
"EMERGENCY"
LEVEL
Level at which it is
likely that acute sickness
or death in sensitive
groups of persons will
occur.
Not applicable
Footnote 2
Footnote 3
Footnote 4
Not applicable
Not applicable
10 ppm for 1 hour (se-
vere distress in human
subjects)
Footnote 7
Footnote 8
Footnote 9
Not applicable
Not applicable
1. Ozone, at 1 ppm for eight hours daily for about a year, has produced bronchiolitis and fibroaitia in rodents
(Stokinger, H. E. , Wagner, W.D., and Dobrogorski, O. J. A. M. A. Archivea of Industrial Health, 16:514,
(1957). Extrapolation of these data to man ia difficult. Functional impairment data have been reported by
Clamann and Bancroft (Clamann, H. G. , and Bancroft, R.W. Advances in Chemistry. No. 21, pp. 352-359,
1959); at 1. 25 ppm some effect is observed on residual volume and diffusing capacity. The variability of the
tests was not reported. Additional data would be needed before a standard is set.
2. A value of 2. 0 ppm of ozone for one hour may produce serious interference with function in healthy persons,
and the assumption is made that this might cause acute illness in sensitive persons. (Clamann, H. G. op. cit. )
*3. Five ppm of nitrogen dioxide for eight hours will produce decreased pulmonary function in animals. Slightly
more may produce pulmonary fibrosis (Stokinger, personal communication); nitrogen dioxide from air pollution
exposures is usually combined with nitric oxide and ozone. More data on human exposures will be needed prior
to setting a standard.
4. Hydrocarbons are a group of substances most of which, normally, are toxic only at concentrations in the order
of several hundred parts per million. However, a number of hydrocarbons can react photochemically at very
low concentrations to produce irritating and toxic substances. Because of the large number of hydrocarbons
involved, the complexity of the photochemical reactions, and the reactivity of other compounds such as nitrogen
dioxide and ozone, it is not yet possible to establish "serious" and "emergency" levels for hydrocarbons.
From the public health standpoint, the concentration of those hydrocarbons which react photochemically ahould
be maintained at or below the level associated with the oxidant index defined in the "adverse" standard.
5. Carcinogens include a few organic compounds such as some polycyclic hydrocarbons, and some metals such
as arsenic and chromium. Studies on effects of such substances are currently under way, but there are not
sufficient data, at present, to set standards. In the meantime, it is recommended that concentrations of
carcinogens in air should be kept as low as possible.
6. A sulfuric acid mist level of 1 mg/M3 with an average particle size of one micron will produce a respiratory
response in man. (Amdur, M. O. , Silverman, L. , and Drinker, P. Archives of Industrial Hygiene and
Occupational Medicine, 6;305, 1952. ) It is not possible to generalize from this for all air pollution conditions,
because under natural conditions, particle size will vary. Only with large droplets would sensory irritation
be produced without other physiological effects.
7. A level of 5 mg/M3 of sulfuric acid mist for a few minutes produces coughing and irritation in normal individuals
(Amdur, M. O. , Silverman, L. , and Drinker, P. op. cit.). Presumably, it could cause acute illness in sensitive
groups of persons in a period of one hour.
8. Given certain assumptions concerning ventilatory rates, acute sickness might result from a carbon monoxide
level of 240 ppm for one hour in sensitive groups because of inactivation of ten per cent of the body's hemoglobin.
In any event it is clear that when a population exposure limit has been set for carbon monoxide, because of
exposures from other sources, community air pollution standards should be based on some fraction of this
limit.
9. It is clear that lead levels should be set on the basis of average values for long periods. While data are
abundant concerning human response to eight-hours-a-day, five-days-a-week exposures, data are insufficient
for the effects of the continuous exposure i " " "
be pursued with vigor, it becomes very irr
Since lead exposures are from multiple so
of the total limit for population exposure.
10. Ethylene causes severe damage to vegetation. Ornamental plants are severely injured by exposures from 0. 2
to 0. 5 ppm. Tomatoes and fruit are adversely affected at similar levels. Current work is expected to permit
a standard to be set within a year.
However, this change has not yet been approved by the State Board of Public Health.
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Air Pollution Control Field Operations
Fuming includes both the phenomena of volati-
zation and condensation of contaminants and takes
place in acid manufacturing and handling and in
metal melting operations where molten metal liquids
are first volatilized to the gas state and then condensed
to dusts by rapid cooling.
Decomposition of materials is associated with the
handling of highly organic compounds or animal tissue
with nitrogenous or sulfurous contents.
Mechanical attrition processes consist of crush-
ing, grinding, drilling, demolishing, mixing, batching,
blending, sweeping, sanding, cutting, pulverizing,
spraying, atomizing of materials, etc., which either
directly or indirectly disperse particulates such as dusts
and mists into the atmosphere. These activities are in-
volved in practically all aspects of metropolitan life
and industry.
B. The Saturation Potential
The air pollution saturation potential is the capac-
ity of that air space which envelopes a community to
absorb, build-up and retain the air contaminants which
are emitted from the sources of air pollution at such
levels and for such durations as to be intolerable or
annoying to the community as a whole. The satura-
tion potential begins to be realized when the rate at
which pollutants enter the air space of the living zone
exceeds the rate at which they are dispersed. Because
this potential is determined by many independent vari-
ables, it cannot be construed as a single physical con-
struct in the way that air can be measured for satura-
tion of water vapor, but must be rendered largely in
descriptive terms. These include the range of air pol-
lution effects manifested, and the meteorological con-
ditions which accompany the air pollution problem.
1. Syndrome of Air Pollution Effects
As the concentrations of contaminants in the at-
mosphere increase, certain typical air pollution effects
become apparent. The atmospheric concentration of
contaminants at which an effect of air pollution is just
noticed is known as the threshold pollution level. A
community whose saturation potential has been real-
ized will exhibit a "syndrome" of effects in which the
thresholds of individual contaminants are reached or
exceeded. By borrowing the medical term "syndrome",
we may indicate the totality of effects resulting from
air pollution which disturb a whole or major portion
of an urban population, and which cause cognizance to
be taken of the air pollution problem.
Initially, the syndrome is one of social unease,
rather than an actual health or physiological problem
known to exist (unless a disaster is involved), charac-
terized by essentially subjective reactions, expressions
of annoyance, and speculations as to the true nature
of the causes and effects of air pollution. Upon inves-
tigation of the community problem, however, a syn-
drome will ,be revealed to consist of such effects of air
pollution as reduction of visibility, physiological re-
action and toxicity, soiling and property damage ana
public reaction.
a. Reduction in Visibility
Visibility reduction is due to the concentration of
aerosols in the atmosphere and indicates an air pollu-
tion condition in the same manner that the clouding or
darkening of a liquid may be said to be polluted by
impurities. Two types of air pollution occur which
affect visibility: (1) sky darkening, and (2) haziness
or light scattering. In the former the sky darkens and
visibility is reduced by the physical obstruction of sky
illumination as a result of clouds of contaminants and
plumes of smoke and fumes emitted from concentrated
sources of pollution. In the latter, a haze evolves from
atmospheric reactions which alters sky illumination by
forward light scattering from the random disturbance
of light photons by the invisible aerosols. The blue
color of the sky, it should be noted, is the result of the
mass uniform scattering of light from the molecules of
atmospheric gases. Similarly, the color of the sky is
altered by pollution hazes, depending on the size of the
aerosols relative to the wave length of light. Between
.4 and .9 microns, aerosols are most effective in light
scattering. Early analysis of the Los Angeles atmos-
phere disclosed that 95 per cent of the particles sam-
pled in smog were below 1 micron in diameter and
that, as visibility decreased, the particles in the .5 to
.8 micron range increased more rapidly than in the
other size ranges, (n)
The nuisance value of visibility reduction appears
to be relative to the climate, geography, population
density and heights of structures, and the point of view
of the average observer. This nuisance can be roughly
expressed as the percentage of the maximum visibility
normally available to the average observer reduced by
air pollution. An observer accustomed to the restric-
tion of his visibility due to high buildings, fog, over-
cast hills, etc., may not be able to see far enough to
detect the formation of a pollution cloud unless he
rises to a vantage point which increases his range of
possible visibility. On the other hand, where visibility
is normally unobstructed, the observer may view the
formation of a pollution haze at a much greater dis-
tance since the cross-section of his view is obscured by
the accumulation of aerosols in the depth of field of his
vision.
The nuisance value of Los Angeles smog is real-
ized by the role visibility plays as an aesthetic quality
of the environment. Because the Los Angeles metro-
politan area consists of large flat basin areas and low
widely separated buildings, the appearance of a Jow-
lying haze in all directions creates an inescapable nui-
sance. This may be indicated by the fact that the
maximum visibility possible, from the sea to the
mountains, is sometimes of the magnitude of 35 miles.
During a smog attack, this visibility is reduced to less
than 5 miles.
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The Nature and Extent of Air Pollution
Figure I - 1. The above photograph illustrates visibility reduction as a result of smog formation in Los Angeles.
60
50
40
fe
o 30
g
10
1932 34 36 38 1940 42 44 46 48 1950 52 54 56 58 1960
YEAR
Figure I - 2. The above graph illustrates visibilit3' reduction trends, measured as >/4 mile or less from the Los Angeles civic center at noon.
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Air Pollution Control Field Operations
Visibility reduction is an indication of pollution
accumulation, and its measurement is one of the
means by which pollution intensity is determined.
An objective measurement of visibility reduction due
to air pollution alone is made by observing the greatest
distances in miles or fractions of miles prominent
objects can be seen over half of the horizon circle.
These measurements, usually made by U. S. Weather
Bureau Stations, are considered to reflect true pollution
hazes when the relative humidity is less than 50 per
cent, and wind speeds are within critical smog-
producing ranges. High relative humidities reflect
hazes produced from water droplets, and visibility
reductions noted during periods of high wind speeds
often reflect wind-blown dusts.
Visibility records can be used to show daily,
weekly, monthly and yearly variations, and reflect the
changes which take place in weather, the industrial
economy, and the effects of control practices.
In the case of Los Angeles (Figure 1-2), pollution
during World War II increased sharply as a result of
wartime activity, and then began to decline to a low
in 1951, three years after the Los Angeles County Air
Pollution District began operation. However, with the
continued growth of population and industrial activity,
days of minimum visibility began to increase once
more, until it dropped off again after single-chamber
incinerators were banned in 1957. Visibility studies
of Los Angeles also show that more days of minimum
visibility occur during the months of July through
September, than during the rest of the year, and visi-
bility is more severely reduced during the week, than
on week-ends(i5).
b. Damage to Vegetation
Injury and disease to sensitive forms of life such
as crops and plants resulting from air pollution have
been clearly established. Certain air contaminants are
capable of causing bleaching, discoloration, stippling,
stunting of growth, lesions, cell damage, spotting and
pitting, drooping, defoliation, etc. Some forms of
vegetation respond uniquely to concentrations of cer-
tain contaminants, a fact which has the following
implications for the study of air pollution: (1) damage
to any form of life serves to warn man of the presence
of toxicants which may also adversely affect human
health, cause crops grown for human consumption to
become unmarketable or inedible, as well as poison
foraging cattle; (2) damage of plants may indicate the
chemical reactivity of the air; and (3) the extent of
economic damage sustained by commercial growers of
plants and crops in polluted areas may point to the
need for research and control to remove the suspected
contaminants from the air, or the undesirability of
growing sensitive crops.
In Los Angeles County, smog causes damage to
various leafy crops such as spinach, oats, endive, ro-
maine, beets and sugar beets. According to Bobrov (2)
plant damage has been found beyond the Los Angeles
smog belt, and has been traced 100 miles along the
coast from as far north as Oxnard, to as far south as
Oceanside, California. The types of damage observed
in Los Angeles are as follows:(19)
1. Silvering and bronzing of the undersides of
many broad-leaved plants, particularly annu-
als, as a result of the presence of unsaturated
hydrocarbons.
2. Retardation of growth of many plants as a
result of the presence of plant toxicants in
Los Angeles smog. Reductions of 60 per cent
in endive and about 75 percent in bella-donna
have been observed in Los Angeles under con-
trolled conditions.
3. Dry sepal in orchids and sleepiness in carna-
tions have resulted from the presence of eth-
ylene in the atmosphere (18).
4. Stippling on grapes and tobacco and bleaching
on the upper surfaces of older leaves of some
plants as a result of ozone, a product of the
hydrocarbon-N02 reaction, discussed later in
this chapter.
5. Bleached areas between veins of some plants
as a result of sulfur dioxide, which is capable
of damaging plants at relatively low concen-
trations(25).
6. Other forms of damage to plants include
cumulative poisoning from fluorine and lead
compounds, damage to leafy vegetables and
flowers from sulfuric acid aerosols, crop dam-
age from insecticide sprays, etc.
c. Physiological Reaction and Toxicity
It is known from the air pollution disasters that
have occurred in Donora, Pennsylvania, London, Eng-
land, Poza Rica, Mexico, the Meuse Valley, Belgium,
and from the toxic potentials of contaminants now
found in the atmosphere in many cities, that concen-
trations of air pollution can be reached in the atmos-
phere which may cause irritation of the eyes and the
respiratory tract, headache, nausea, odor, allergy, ill-
ness and even death and that continuous daily expos-
ure to polluted air may cause life-shortening diseases,
as well as possible permanent impairments of some
normal bodily functions (3).
Knowledge of the effects of various contaminants,
both by direct attack, or by reaction with other
materials which will attack (synergism), is derived
from experience with various occupational diseases as
reported in industrial toxicology. These findings, how-
ever, are concerned with the immediate symptoms re-
sulting from the exposure of toxic concentrations.
Much remains to be known about the long-range
effects of low concentrations, particularly their influ-
ence on such respiratory diseases as emphysema,
asthma, and lung cancer. Although data is insufficient
to prove such relationships, most informed authorities
-------
The Nature and Extent of Air Pollution
7
on the subject believe that they exist in some degree.
In an effort to determine the potential adversity of
contaminants on whole populations from the best
information available, so that source control and auto-
mobile exhaust standards can be fixed, the State of
California has established air quality standards, as
shown in Table I - 1.
In Los Angeles County, eye-irritation is a leading
known effect of air pollution and is a basic criterion
in estimating the presence and severity of any smog
attack. Studies show that eye-irritation generally ac-
companies the other end effects of smog, such as re-
duced visibility and crop damage(io). Its presence
and severity, however, show no exclusive correlation
with any single contaminant or group of contaminants.
d. Soiling and Property Damage
One of the first material effects of air pollution
is the soiling of clothing, buildings and property. A
familiar annoyance is the soiling of clothing and tex-
tile materials exposed to air containing smoke, soot
and dust. Air pollution has a direct influence on the
cost of cleaning and laundering, on the marketability
of merchandise, and the cleaning of buildings. This
cost to society is probably in the billions. Gibson esti-
mates that the damage from smoke alone is about $1.5
billions annually(9).
Air pollution may also damage property. The
damage is usually of a cumulative nature, tends to
shorten the durability of materials exposed to the at-
mosphere, and is generally caused by the interaction
of the contaminant with the surface or the protective
coatings of materials in the form of corrosion (chem-
ical or electrochemical reaction between metal, pro-
tective coating and the surrounding atmosphere con-
taining contaminants, usually of an acidic nature),
erosion (mechanical abrasion of surfaces by wind-
borne materials), oxidation (such as rubber cracking
from ozone and other oxidants present in the atmos-
phere) and spotting (contamination of surfaces by
paints and oil droplets, carbon spheres and fly ash).
See Chapter 12 for a fuller treatment of this subject.
e. Impact on Public Attitude
Not too much can be said about the psychological
aspects of air pollution as comparatively little research
in this area has been conducted. Several obvious
psychological characteristics are manifest, however,
particularly by a severe smog problem. First, of
course, is the fact that, with the possible exception of
"pleasant" odors, both animal and man attempt to
avoid air pollution. Secondly, unlike crime which
affects a small proportion of the population at any one
time, smog affects everyone in the community at the
same time, regardless of economic or geographical dis-
tinction. In fact, no other metropolitan problem oper-
ates with such thoroughness and simultaneity. Third,
air pollution may devaluate real estate and contribute
to the blighting of neighborhoods. There is no ques-
tion, especially where the effects of air pollution on
health are concerned, that chronic pollution may cause
anxiety, frustration and anger, with whatever conse-
quences these may have for individuals. For some,
air pollution may merely embarrass civic pride, for
others very definite psychological hazards exist, especi-
ally when air pollution becomes a subject of rumor.
To the extent that smog reduces visibility, irritates the
eyes, and soils the general appearance of the environ-
ment, it depresses general welfare and efficiency. One
can easily imagine the psychological damage that can
be created in a community which not only suffers,
helplessly, from its smog problem, but from misin-
formed opinion, distortion, superstition and confusion.
2. The Evacuation and Build-Up of Contaminants
in the Air Space
Since the rate at which a community pollutes the
air can be assumed to be constant, only the variations
in weather determine the intensity of pollution. For
each community a set of meteorological conditions
sufficient to create a characteristic pollution syndrome
prevails.
The air space over the community consists of a
volume of gaseous fluids subject to movement in three
dimensions. Imbalances within large air masses
cause individual air parcels to flow within the air
space until equilibrium is achieved with the surround-
ing air. This essential instability of the air continu-
ously favors the evacuation of pollutants.
Generally, the more unstable the air mass, the
more vigorous the air movement, and hence, the less
the pollution loading. Conversely, the more stable the
air mass, the greater the pollution loading. We may
speak, then, of the conditions which inhibit or favor
evacuation, i.e., the ventilation versus the retention
potentials. These distinctions are not qualitative op-
posites, but a matter of degree.
a. Evacuation of Air Contaminants
The mechanism of evacuation is expressed in
terms of dilution, dispersion and precipitation.
Dilution is the diffusion of liquid, solid and gas-
eous contaminants in a parcel of air, and the mixing
of that parcel with uncontaminated air until the con-
centrations of contaminants are so reduced as to be
negligible or undetectable. The mechanism of dilution
tends to cause a contaminant plume to mix uniformly
throughout the entire earth's atmosphere. While dif-
fusion, itself, is a slow process in still air, dilution is
rapidly facilitated by atmospheric agitation, or turbu-
lence, which is an irregular and random flow of air.
Dispersion is the movement of an entire polluted
parcel of air either vertically or horizontally away
-------
Air Pollution Control Field Operations
from the living zone of the metropolitan area. Polluted
parcels of air are dispersed by (1) the horizontal and
lateral flow and mixing of air as it moves parallel to
the ground in a stream or breeze out of the metro-
politan air space, either at the surface of the earth
(surface winds) or at heights above the living zone
(winds aloft) and (2) the upwards movement of light
warm air and its mixture with the fresh air above the
living zone. The processes of dilution and dispersion
are involved simultaneously, and quite often the term
dispersion is used to include both mixing and trans-
port.
The multi-directional flow of air masses is in-
duced by three forces: (1) the drag of the earth's at-
mosphere over the surface of the earth due to gravita-
tional rotation, (2) the movement of large masses of
air from areas of high pressure to areas of low pres-
sure, and (3) local climatological and topographical
conditions (sea-land-valley-mountain effects) of a local
area on the seasonal wind patterns.
The flow of any parcel of air is determined by its
temperature and pressure in relation to the surround-
ing air. The differences in temperatures between ad-
joining air masses cause cool air to drain below warm
air. Since the temperatures of the air are influenced
by the temperatures at the surface of the earth, air
cooled at one surface will flow towards air heated by
an adjacent surface. Thus, a "sea breeze" is a condi-
tion in which the air cooled over a body of water flows
inland towards the warm land. Quite frequently
where a temperature gradient exists between two con-
trasting surface masses, such as the sea and the land,
an alternating diurnal wind pattern prevails.
The vertical transport of air parcels is made pos-
sible by the decrease in air temperature with height.
The air warmed near the surface rises quickly to the
upper air where it is mixed with the fresh air aloft.
This condition of decrease in temperature with height
is known as the adiabatic lapse rate. A dry adiabiatic
lapse rate is 5.4 degrees Fahrenheit per 1000 feet of
altitude. A superadiabatic lapse rate is a more rapid
decrease in temperature with height, a condition which
is ideal for the rapid evacuation of contaminants.
Air is also cleaned by the natural precipitation of
contaminant particles due to the (1) influence of grav-
ity on particles of air pollution heavier than air, and
(2) entrainment or nucleation of particles by water
droplets in rain or fog. Contaminants which are
water soluble will deposit to earth with rain and dew.
Aerosols in the atmosphere may also "grow" by at-
tracting other aerosols until they are heavy enough
to settle out. Particles which are slightly heavier than
air, however, may remain indefinitely suspended as
a result of continuous atmospheric agitation. Some
particles have aerodynamic properties which make
continued suspension possible, whereas others may be
deflected out of the atmosphere by centrifugal action
in turbulent and gusty atmospheres.
b. Retention of Air Contaminants
Given the significant pollution potentials of most
metropolitan areas, severe restrictions of all three es-
cape mechanisms over a protracted period of time
cause pollution to build-up. Restriction occurs when
the dispersion of air contaminants is inhibited in all
three dimensions — horizontally, laterally and ver-
tically.
(1.) Wind Speeds and Patterns
The first important restriction to dispersion is the
weak horizontal and lateral flow of air, and the pat-
tern of flow. The pollution loading, under given stabil-
ity conditions, varies inversely with the wind velocity,
i.e., the slower the wind, the slower contaminant
plumes dilute and disperse, and the longer the air
remains significantly polluted. A critical wind speed
may be considered for all metropolitan areas, given a
constancy of other factors. As the rate of pollution
of a metropolitan area increases over the years, the
critical wind speed tends to decrease. For Los Angeles,
with an average yearly wind speed of 6 miles per hour,
a speed of 5 miles per hour or less is critical. During
periods of severe smog, wind speeds are generally 3
miles per hour or less (13). The fact that smog occurs
with such frequency and intensity in Los Angeles
County is due to the fact that wind speeds are regu-
larly lower for this area more days during the year
than for any other major metropolitan community in
the United States. The Los Angeles average of 6 miles
may be contrasted to those of St. Louis (10 miles) and
New York and Chicago (8 miles).
Wind speed is also important with respect to the
distance a polluted parcel of air travels before it leaves
the metropolitan area. The larger the land area of
the metropolis, the longer a polluted parcel of air
remains in the community. Air moving uniformly at
a rate of 3 miles per hour across a 30-mile area (this
is not uncommon in Los Angeles) may remain in the
pollution zone for 10 hours during which time it
continues to absorb other contaminants.
An adverse restriction of the dispersion factor is
slow wind speeds in combination with a curcuitous
wind pattern. A parcel of air which takes the fastest
and most direct route out of the metropolitan area, of
course, is being dispersed efficiently. But a slow-moving
parcel which flows for a time in one direction, then
retreats, cuts laterally over another dimension of the
metropolitan area, or flows in a circular pattern, tends
to absorb a maximum amount of pollution.
Many metropolitan areas exhibit a pattern of air
movement favorable to maintaining a relatively fresh
air supply, whereas others exhibit patterns favorable
to the build-up and retention of pollutants. The Los
Angeles area has a unique sea-land-desert effect which
at times operates to entrap pollutants, and at others
aids their escape. The alternating temperature dif-
ferentials between the land and the sea may reverse
-------
The Nature and Extent of Air Pollution
the wind pattern and delay the departure of the con-
taminated air or an air parcel may be transported to
a locality at a fairly brisk rate and then stagnate over
a congested area due to changes in atmospheric con-
ditions which take place as the day progresses. At
other times, clashes between land and sea breezes may
occur causing one of the opposing breezes to dominate.
In still another situation, a "zone of discontinuity,"
i.e., an air barrier may form between two wind sys-
tems, causing the blockage of air (16).
An example of a build-up in Los Angeles is as
follows: An air mass crosses the western coast line
late in the afternoon and remains in the area to receive
pollution for a period of less than 24 hours (Figures
1 - 3 and I - 4). This air mass may slow down due to
the friction of the land mass or the opposition of a land
breeze, causing it to stagnate in the vicinity of down-
town Los Angeles the next morning around 8:00-9:00
A.M. The air remains in the general vicinity and
absorbs pollution from automobile traffic congestion.
The effects of air pollution — eye-irritation and reduc-
tion in visibility — then intensify until generally
around noon when the air mass is released due to
vertical mixing made possible by the lifting of the
inversion layer (see below) or by the revival of the
afternoon sea breeze. During relatively favorable
conditions, the sea breeze disperses the air mass in a
general northeasterly direction causing the polluted
air to leave the basin in the afternoon. However, an
adverse condition can occur when the atmosphere re-
mains stable throughout the day and a slow land
breeze forces the air mass to retreat in the direction
from which it came (13, 20, 21, 22).
The Los Angeles wind system is thus a two-
edged sword. It possesses temperature differentials
between the surfaces of the sea, the land, and the in-
terior desert regions which provide the escape of ac-
cumulated pollution each day. On the other hand,
wind speeds occur which are slow enough to cause
stagnation of the pollution in the metropolitan area.
In some communities located in valleys, such as in
the Meuse Valley or Donora, Pennsylvania, most of
the polluted air may be trapped in the air space for
longer periods of time. Unfortunately, the wind sit-
uation alone in Los Angeles would not be so bad if it
were not for the fact that the vertical flow of air is
also restricted.
(2.) Temperature Inversions
The dispersion of contaminants vertically is made
possible by the fact that temperature normally de-
creases with height, causing warm air to rise and
cool air to descend. The rate at which air masses
rise depends on the rapidity with which the tempera-
ture drops with altitude. Normal adiabatic lapse rates
are usually sufficient to permit pollution to escape
from the living zone of the community. The continu-
ous reduction of the lapse rate to conditions approach-
ing little or no difference in change in temperature
(isothermal) tends to cause contaminant plumes to
rise sluggishly, or to remain suspended for long periods
of time. However, when the temperature begins to
increase with height (negative lapse rate) the upward
movement of polluted air becomes impossible. This
condition is referred to as temperature inversion.
An inversion layer is that layer of air through
which temperature inversion takes place. The altitude
of the inversion layer varies with height above the
ground. The air below the inversion layer is that of
the limited air space of the city, the temperature of
which decreases normally with height up to the base
of the inversion. The air above the layer cools indefi-
nitely with height, unless there is another inversion
layer at a higher altitude.
Since all of the polluted air below the warm layer
is heavier, parcels of air warmed by the ground will
rise and cool and will either reach a point of equilib-
rium below the inversion layer, or sink back to the
surface of the earth again.
A "strong" inversion is one in which the tempera-
ture of the air forming the base of the inversion layer
is significantly lower than the temperature at the top
of the layer. Figure 1-5 illustrates an example of this
system. As shown, the temperature of the air at the
ground is 80 degrees Fahrenheit, and thereafter de-
creases with height at the rate of 6 degrees Fahren-
heit per 1,000 feet. The temperature at the base of the
inversion is 74 degrees Fahrenheit and thereafter
increases for the next 1,000 feet of altitude until it
drops again at the top of the layer.
The inversion layer breaks when the meteoro-
logical factors causing the formation of the inversion
are nullified, and normal temperature distribution is
restored. The inversion layer may lift to such an
altitude that it no longer has any material effect on
the retention of air pollution, or it may lower to fur-
ther intensify the pollution effects. In Los Angeles
County, inversions form with particular strength and
persistence, and are broken by rises in temperature of
the surface air sufficient to raise the temperature of
the inversion base above that of the inversion top.
This temperature is called the breaking temperature.
In the example in Figure 1-5, the heating of the sur-
face air to 103 degrees Fahrenheit is sufficient to in-
crease the temperature of the air at the inversion
top to 91 degrees Fahrenheit, one degree more than
the temperature at theltopof the inversion previously.
The maximum vertical dimension of the air avail-
able for mixing of polluted air in any one day as a
result of inversion breaking or lifting is known as the
maximum mixing height. The maximum mixing
height is an indication of the maximum vertical dis-
persion factor for any one day.
Temperature inversions .may occur under a vari-
ety of conditions, and with varying frequencies and
-------
10
Air Pollution Control Field Operations
Figure 1-3. Streamlines for late afternoon over Los Angeles County.
Figure I - 4. Streamlines for early morning over Los Angeles County.
-------
The Nature and Extent of Air Pollution
11
persistence. Some types of inversion are: inversions
formed by a calm before an advancing warm front;
advection inversions, resulting from the drainage of
cold air off the ocean under the warm air on the land;
radiational inversions, resulting from the cooling of the
surface air, usually during the evening or morning
hours; and subsidence inversions forming from the
heating of air under compression from a high pres-
sure mass.
DESCENDING AIR
MASS FROM HIGH
PRESSURE AREA
2000
INVERSION LAYER
NORMAL '.
ADIABATIC:
LAPSE •
1000 — -
INVERSION CONDITIONS
(103°
INVERSION BROKEN
Figure 1-5. The above profile of the Los Angeles air space
shows typical vertical distributions of temperature during forma-
tion and dispersion of smog, respectively.
The two most important inversions are the radi-
ational and subsidence types. Radiation inversions
tend to form more in winter when, as a result of
shorter days, the land is cooled more than it is heated,
and during the evening and morning hours. In Los
Angeles, radiational inversions are quite common
between 2:00 and 4:00 A.M.
In Los Angeles County, the subsidence inversion
is of greater importance due to its duration and fre-
quency, particularly during the late summer and fall.
The subsidence inversion is a feature of the west
coasts of continents, and extends on the west coast
of the United States from Baja California to north of
San Francisco, some 340 days each year. This inver-
sion evolves from the descent of a high pressure cell,
centering north of the Hawaiian Islands, which swirls
gigantic air masses down and around in a vast clock-
like motion towards the Pacific Coast. As the air is
compressed, it heats at about 5'/2 degrees during each
1,000 feet in its descent. Strong inversions are present
within 1,500 feet of the earth's surface on about 120
days of each year. While there are variations, Pacific
Coast inversions average about 2,000 feet in depth,
and possess a temperature differential between base
and top of about 7 degrees Fahrenheit.
(3.) Topographical and Geographical Effects
Other impediments to contaminant dispersal arise
from the barriers to airflow present in the natural and
man-made environment.
The character of the surface of the earth has an
important bearing on air turbulence, wind speed and
direction. Smooth, level land offers less of an impedi-
ment to airflow, than does land which is rough or
rocky, hilly, mountainous or congested with tall struc-
tures. Irregular surfaces, while contributing to greater
air turbulence tend to retard the flow of a whole air
mass. Hills, tall buildings and rises in land may create
down-washes causing polluted air to flow at ground
levels. Of even more importance to pollution retention
however, is the general physical geography of the
metropolitan environment. Cities appear to have
grown on sites favorable to pollution retention, i.e.,
sheltered low-land regions or river valleys which
either adjoin large bodies of water, or through which
rivers flow. Although variations in geography resist
generalization, four different types of land formations
are relevant to the retention of air pollution. These
are: 1) valleys, 2) coastal basins, 3) peninsulas, and
4) inland plains.
(a) Valleys
Valleys present the topographical conditions most
favorable to the build-up of contaminants. Valleys
are low levels of land enclosed by mountains. Depend-
ing on the heights of the mountains and the narrow-
ness of the valleys, the circulation of the air is usually
confined within the valley, although some air flows
up and down the sides of the mountains and through
the passes between either end of the valley. (A moun-
tain breeze flows down the mountain slopes at night,
and a valley breeze flows up the slopes during the
day). Low-lying temperature inversions are critical
in valley situations, frequently causing contaminant
plumes to intersect rises in land. Most of the air pol-
lution disasters have occurred in valleys.
(b) Coastal Basins
Like the valley, the basin is an area enclosed by
higher land. The basin, however, is not necessarily
enclosed on all sides and usually adjoins a large body
of water. The Los Angeles Coastal Basin (Figure 1-7)
consists of an area of more than 1,200 square miles
ringed on the north and east by the Sierra Madre
mountain range and rising to an average height of more
than 5,000 feet and to a maximum height of 10,000
feet at Mt. Baldy. From the mountain ranges, the
-------
Air Pollution Control Field Operations
Figure I - 6. Appearance of smog during formation of low subsidence inversion over Los Angeles.
Figure I 7. Topographical map of the Los Angeles County coastal basin.
-------
The Nature and Extent of Air Pollution
coastal basin itself, including San Fernando and San
Gabriel Valleys, gradually slopes towards the harbors
and beaches fronting the Pacific Ocean.
The movement of sea and land breezes described
for the Los Angeles Basin is somewhat typical for
metropolitan basins in general, particularly on the
west coasts of continents. The occurrence of both sub-
sidence and radiational inversions below the moun-
tains, particularly at the eastern portion of the ranges
of the basin, are sufficient to effectively entrap pollu-
tants, and may at times contribute to severe conditions
in the foothill communities.
(c) Peninsulas and Inland Plains
Both peninsulas and inland plains present condi-
tions which favor the dispersion of polluted air. In the
case of the peninsula the surrounding bodies of water
provide reservoirs of uncontaminated air for dilution.
Stagnation of the air and temperature inversions, how-
ever, may still be effective in pollution retention when
large air masses enveloping the peninsula become
stabilized. Tall buildings, as in New York, may pro-
vide impediments to the horizontal motion of polluted
air, and cause pollution to accumulate at street levels.
Moreover, the absence of such natural barriers may
contribute to the formation of a larger polluted air
space, including many metropolitan communities. The
waterways between New York and New Jersey, and
between Detroit and Windsor at the United States and
Canadian borders, contribute to the exchange of pollu-
tion from industry, metropolitan areas, ships and
harbor installations, thereby complicating pollution
problems.
3. The Parameters of Air Pollution
The parameters of the air pollution saturation
potential are the meteorological dimensions of the vol-
ume of air available for dilution of contaminants each
day, i.e. wind speed, the height of inversion base, and
the maximum mixing height. At critical points in
a smog episode, that volume may be expressed as the
height to the inversion base times the area of the
metropolitan area (see next section), and the number
of air changes in the area.
On a monthly basis, the first basic parameter to be
considered is the seasonal variations in local climate.
Some climates, particularly in frigid continental areas,
present a great variety of diurnal weather conditions,
whereas others present conditions which are repeti-
tive. The northern hemisphere, with its four seasons
and rapid temperature and wind changes, exhibits
sporadic incidents of air pollution attacks, rather than
continuous pollution sieges. The subtropical climate of
Southern California, on the other hand, presents two
seasons — a summer or dry season — from June to
November, and a winter or wet season — from De-
cember through May. The summer, particularly from
October through November, constitutes the "smog"
season. At that time the weather consists of light
winds and calms with sustained subsidence inversion.
The inversion layer frequently falls below 1,500 feet
and the wind speeds are less than 3 miles per hour
on the average.
Given the seasonal pattern of weather conditions,
the intensity of the air pollution attack can be fore-
casted from synoptic data of the diurnal cycle of
weather events. (These are usually supplied from the
U. S. Weather Bureau). In Southern California, all of
the pollution built up in the air space over a 24-hour
period is usually dispersed from the air space during
the same period. However, on occasion, air pollution
may accumulate over a period of days, particularly
during the wintertime.
Due to the great number of variables involved,
the parameters can only be approached empirically,
and are computed, like all weather forecasts, with a
degree of probability, involving on occasion substantial
statistical error. The science of micrometeorology, on
which such forecasts must be based, is a relatively re-
cent development. Each region must be studied in
great detail, before accurate air pollution forecasts are
possible.
Keeping in mind that air pollution effects may
occur independently, forecasts should tend to be made
of specific effects, rather than of a general condition.
The Los Angeles County Air Pollution Control District
forecasts four conditions involving several parameters.
These are: (1) smog warning, (2) permission or pro-
hibition of open burning, according to criteria estab-
lished by Rule 57 of the APCD Rules and Regulations,
(3) possible alerts resulting from high concentrations
of key contaminants (ozone, oxides of nitrogen, sulfur
dioxide, and carbon monoxide) set by Regulation VII
of the Rules and Regulations, and (4) plant damage.
a. Smog Warning
For the purposes of the smog forecast (see Figure
1-8), smog is defined in terms of visibility reduction
and eye-irritation. A smog warning is issued to the
public whenever a visibility of less than 3 miles (with
humidity less than 50% in interior regions, and less
than 60% in coastal regions) and/or moderate and
heavy eye-irritation are forecasted for any area of the
basin. These forecasts are based on past correlations of
eye-irritation with weather data.
b. Open Burning, Rule 57
In Los Angeles County, open burning is prohib-
ited by law whenever any of the following occurs:
a. The inversion base at 4:00 A.M. PST is 1,500
feet or less.
b. The maximum mixing height is less than 3,500
feet.
c. The average wind speed is less than 5 miles
per hour.
-------
AIR POLLUTION CONTROL DISTRICT - COUNTY OF LOS ANGELES
U3U South San Pedro Street, Los Angeles 13, California
Forecast Issued: 10 a.m. 6/lh/60
Time
Date
.Forecaster:
EK
^Forecast For:
DAILY WEATHER AND "SMOG" FORECAST
6/15/60
Wed
Day
Date
DOWNTOWN ins ANGFI FS
Inversion Base
(Rule $7A)
1200 Ft.
VISIBILITY
(MILES)
SURFACE
WIND
(MPH)
V
8:00
3A
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li
ISIB
9:00
3/1
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l»
Inversion Breaking
(Rule £7B)
NO * Yes
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Clock
10:00 11:00
3A ii
P S
h 5
Max. Mixing
(Rule 57B
2500
SURFACE WIND
Tine
12:00 1:00 2:00 3:00
2 2j 3 It
S SW W W
$679
4:00
5
W
7
Ht.
)
Ft.
5:00
$
W
7
Ave. Wind u6-i:
(Rule 57C)
Iu2 r
SKY
8:00
CLEAR
PARTLY
CLOUDY
CLOUDY
RAIN
X
2P
nph.
Inversion Breaking
Temperature
100 OF_
Maximum Surfa
Temperature
88 c,
CONDITION— PRECIPITATION
Clock Time
9:00 10:0011:0012:00 1:00 2:00 3:00
X
X
X
X
X
X
X
4:00
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F.
5:00
X
X
wn POSSIRIF- punpAPLF YF«
AIR POLLUTION EFFECTS BY AREAS
AREA
c (CENTRAL)
w (WEST)
s (SOUTH)
SE (SOUTHEAST)
NE (NORTHEAST)
SF (SAN FERNANDO)
SG (SAN GABRIEL)
FOR ENFORCEMEN
DIVISION:
OPEN FIRES
PERMITTED:
VISIBILITY
LESS THAN 3 MILES
WITH LOW RELATIVE HUMIDITY
NO YES
X
X
T
X
X
X
X
X
PLANT
DAMAGE
NO YES
X
X
X
X
X
X
X
NO
X
X
YES
X
X
X
X
X
8:00
EYE IRRITATION
(L = LIGHT, M = MODERATE, H = HEAVY)
Clock Time
9:00 10:0011:0012:00 1:00 2:00 3:00
L
L
M
L
M
M
L
L
L
L
M
M
M
L
L
L
H
H
M
FOR PUBL C RELEASE: There will be moderate to heavy eye
irritation in the Basin Wednesday
FOR DISTRICT USE ONLY:
M
M
H
L
L
M
4:00
L
5:00
SAMPLING
CONDITIONS
GOOD FAIR POOR
X
X
X
X
X
X
X
FOR PUBL C INFORMATION DIV SI ON:
SMOG WARNING: AREA(s)
NO YES C SE NE SF SG
ALERT FORECAST FOR L.A. BASIN:
Nn POSSIBLE YES
§
•*]
I
t6-75D25
Figure I - 8. Official A.P.C.D. smog forecast for administrative, enforcement and research purposes, and for the notification of the general public.
-------
The Nature and Extent of Air Pollution
15
These criteria come closest to the parameters of
Los Angeles smog. They were designed to define those
adverse smog conditions in which the additional load-
ing of pollutants from open burning could not be tol-
erated. Although based on the best information avail-
able, they are not necessarily representative of all
threshold pollution effects. Forecasts based on these
parameters are good some 50% of the time, the error
resulting from incomplete information with respect to
such variables as the differences in wind averages be-
tween polluted and unpolluted masses of air, varia-
tions in height of the inversion layer during the day,
and the total streamline pattern.
c. Possible Alerts
The Los Angeles County APCD calls alerts and
takes appropriate action as defined by law whenever
any of the concentrations of the key contaminants
reaches alert proportions. The alert forecast is made
in terms of (1) no alert forecast, (2) possible alert fore-
cast, and (3) alert forecast (see Figure 1-8). Predic-
tions of alert forecasts are predicated on adverse airflow
patterns, severe lowering of the inversion base and
maximum mixing height, low average wind speeds
and a wide difference between the inversion breaking
and maximum surface temperatures, and other factors.
A progressively worsening condition is marked by
values which increase in the following order: (1) plant
damage, (2) visibility reduction, (3) eye-irritation,
and (4) ozone concentration.
d. Plant Damage
The forecast of plant damage is based on the
season in which sensitive crops begin to grow. The
APCD always predicts plant damage when a smog
warning is called, as conditions which obtain are
sufficient to injure plants. It is not unusual for the
APCD to predict plant damage in the spring on the
basis of a forecast of light eye-irritation, even though
smog is not forecast and approved open burning is
permitted.
II THE METROPOLITAN POLLUTION ZONE
While the saturation potential of the air space is
a fixed feature of the natural environment, the kinds
and quantities of air contaminants emitted are a func-
tion of man-made factors. The saturation potential has
meaning only with respect to the quantities and
rates at which pollutants are emitted into the air
space. A community with a greater saturation poten-
tial will tolerate less quantities of contaminants than a
community with a lower saturation potential. It can
be assumed, however, that every metropolitan air
space has a saturation potential which can be realized
by an increasing rate of emission. In this section, we
shall be concerned with the capacity of the metropoli-
tan economy of the pollution zone to pollute the air.
A. Definition of the Metropolitan Pollution Zone
A pollution zone is the geographical boundary of
a continuous land area coterminous with areas affected
by the flow of polluted air and in which both the
sources and the effects of air pollution are concen-
trated. The pollution zone subsumes a relationship
between cause and effect due to the movement of
polluted air. The maximum boundary of the pollution
zone is comprised of all areas from which the polluted
air may originate and over which it may be effectively
distributed. The pollution zone is, therefore, integrated
from two basic types of land areas, either singly or in
combination, 1) source areas, the areas containing the
sources of air pollution, and 2) effect areas, those
areas fumigated or otherwise affected by the flow of
pollution.
Various possible juxtapositions of source and
effect areas occur within the pollution zone. The
source and effect areas may be individually homo-
geneous, but geographically opposed, or the source and
effect areas may be mixed over the same land area.
The relationship between the source area and the
effect areas may be direct in that plumes from a source
may fumigate areas immediately downwind, or in-
direct in that contaminants emitted from a source are
diluted and stabilized in a whole smog mass before
being distributed to effect areas.
The capacity of the metropolitan pollution zone
to realize its saturation potential depends on the nature
of the metropolitan economy and the source and popu-
lation density. The nature of the economy determines
the kinds and rates of contaminants emitted into the
air, whereas the density of the sources of air pollution
influences the concentrations these contaminants will
reach in the air. A compact pollution zone with a high
population density, of course, is one which is likely to
present a severe air pollution problem, in addition to
a profusion of public nuisances. Moreover, as the
source density increases, the concentrations of non-
reactive contaminants, such as carbon monoxide, in-
crease proportionately, while the reactive contaminants
are likely to create secondary contaminants whose con-
centrations tend to increase geometrically (see IV-B
this Chapter).
The definition of the metropolitan pollution zone
is of importance to the conduct of an air pollution con-
trol program for several reasons. First, the boundaries
of the pollution zone must take into account the fact
that a unified political and judicial system should pos-
sess the authority to regulate and control all sources
of air pollution to alleviate all of the effect areas in-
volved. Secondly, the pollution zone is postulated on
preventing future problems as well as remedying
existing problems, since the sources of air pollution,
as well as the population affected, may grow in num-
ber and over a larger land area. Also, whenever cer-
tain effects of air pollution are known to exist, it is
-------
Air Pollution Control Field Operations
necessary to assume that other effects as yet unknown
may also occur. Finally, the pollution zone must be
viewed as a field of control operations to be physically
approached by field personnel.
B. The Metropolitan Economy
The traditional city first developed either to (1)
exploit a rich and abundant natural resource, such as
coal, metals, petroleum or other mineral deposits or
agricultural products located nearby, or (2) to capital-
ize on a commercial advantage due to proximity to
trade routes — rivers, lakes, natural harbors and
oceans. Cities which specialize in a single economic
activity are known as single economies. Cities tend to
develop multiple or diversified economies due to the
tendency of a population to satisfy all of its needs in
one place, and the growing technological and economic
ramifications any single economy may present. All
cities, of course, must develop the so-called ubiquitous
industries — construction, printing and publishing,
food processing, transportation, etc.(i) Cities may also
develop to include a full range of industrial potentials.
The industrial revolution created the type of
metropolitan community we live in today consisting of
large, interdependent, industrial, commercial and
transportation complexes, each of which possesses a
permanent and growing air pollution potential. Two
world wars and an interbellum period of economic
rivalry accelerated the urbanization and industrializa-
tion of old and new cities, particularly with the advent
of mass production techniques. The twentieth century
subsequently witnessed a technological revolution in
which not only unlimited production became possible,
but industrial research and engineering development
greatly expanded and diversified mechanical and
chemical processing techniques. The air-contiminating
activities ramified the chemical pollution possible and
spread the sources of pollution throughout a broader
economic base.
It is with the development of a chemical tech-
nology that the character of urban pollution changes
from one of smoke from the combustion of coal to the
subtle and aggressive effects resulting from the wide-
spread emissions of a variety of sometimes invisible
and highly reactive pollutants whose identities change
in the atmosphere. These are chemical hazes or
"smogs" which paradoxically, are associated with gen-
eral prosperity, improved living and working condi-
tions, advanced technology, and a consumer power
which makes possible the increased use of automobiles,
and other new sources of air pollution.
There is a tendency in modern times for cities to
grow for reasons which cannot be attributed entirely
to the presence of natural resources and historic trade
routes due to the growing independence of technology
from the traditional sources of power, and the need for
more land to accommodate the population explosion.
The growth of many cities in the southwest, for
example, is based on the fact that industry has fol-
lowed the movement of population to desirable areas.
Thus, industrial and economic activity will locate
where new markets and labor supplies present them-
selves. It can be anticipated that, on a world-wide
basis, large cities may develop in subtropical and
desert regions. Moreover, water transportation and
hydroelectric sources of power, so long the necessity
for community growth, may no longer be absolutely
required as a result of the development of new forms
of steam generating facilities and transportation
systems.
The recent development of cities has also changed
with respect to the relationship between local manu-
facturing and consumer economies. Early industrial
economies maximized land areas for industrial and
commercial uses, and where land became dear, cities
centralized, built vertically, causing high concentra-
tions of population and structures. Suburban or con-
sumer oriented communities, on the other hand, first
utilized land space to meet the demand for private
dwellings, and all of the materials and appliances nec-
essary to their construction, use, maintenance and
repair, thereby creating large local markets for in-
dustry. The growth of suburbanized cities, while
including industrialization, tends towards decentrali-
zation and lower population densities.
The centralization of industrial, commercial,
transportation and residential activities tends to cause
higher concentrations of air pollution. The decentral-
ized community, on the other hand, may possess less
concentrated source areas, but considering an equal
population, may require a larger land area over which
the sources become distributed. The decentralized
community thus creates a larger pollution zone.
The decentralized community would present the
ideal situation for air pollution prevention were it not
for the fact that the tremendous use of automobiles
which become necessary present high concentrations
of exhaust contaminants throughout the pollution
zone.* The incineration of rubbish and fuels used for
domestic heating in private households, follows a sim-
ilar pattern.
The type of air pollution problem which develops
in a community reflects the nature of the economy and
its level of technology. For the purpose of defining the
metropolitan air pollution problem, the economy may
be considered in three parts: (1) the fuel economy,
(2) the industrial or manufacturing economy, and (3)
the service or commercial economy.
1. The Fuel Economy
Since fuel is required to meet all the demands
for space heating, power, electric generation, thermal
processes, metal melting, transportation (automobiles,
*In a large, highly decentralized community such as Los Angeles,
mass rapid transportation systems pose a critical problem since
the population densities are too low to support their financing
and operation.
-------
The Nature and Extent of Air Pollution
17
TABLE I - 2
COMPARATIVE POPULATION DENSITIES OF MAJOR U. S. CITIES
(Population per square mile(i))
CITY
New York
Chicago
Philadelphia
Detroit
Washington, D.C
Los Aneeles City
Los Angeles County Basin
YEAR
1950-58(2)
1950
1950
1950
1950
1959(3)
1959(4)
POPULATION
8,010,000
3,620 962
2,071,605
1,849568
802,178
2,406,000
5,756,000
AREA
SQ. MILES
315.5
2075
127.2
1396
61.4
450.9
1200.0
POPULATION
DENSITY
25,000
17,540
16,285
13,200
13,064
5,344
4,800
(1) All statistics, except as noted, are from Bureau of the Census, Statistical Abstracts of the United States, U. S. Department of Com-
merce, 1958.
(2) As reported in the World Almanac, 1959, New York World Telegram and the Sun, New York, New York.
(3) January 1, 1959 estimate by the City Administrative Office, Los Angeles, California.
(4) April 1, 1959 estimate of the Regional Planning Commission, Los Angeles County. The Los Angeles County figure was actually re-
ported as 6,059,161. An estimated 95% of this population lives in the Los Angeles County Basin. The area of Los Angeles County is
4,083 square miles. ^______
ships, trains, buses, etc.), it is a primary source of all
metropolitan air pollution problems.
Fuel economies fall into three basic categories:
(1) solid fuels represented by coal, coke, wood and
charcoal; (2) liquid fuels, represented by a wide range
of petroleum derivatives including residual, kerosene
and distillate fuels used for power plants and boilers,
and motor fuels, such as gasoline and diesel oil in
automotive transportation; and (3) gaseous fuels such
as natural gas and liquefied petroleum gas. While the
use of gasoline and diesel fuels is universal, the fuel
used for industrial and power generating purposes is
dependent upon the availability and cost of the fuels
to the area.
Cities adjacent to coal deposits, typically found in
the northern latitudes of the United States, are fre-
quently referred to as coal economies, since coal is
used for practically all combustion purposes, except
transportation. The combustion of coal is most re-
sponsible for a type of air pollution consisting of car-
bon particles, smoke, sulfur dioxide and sootfall. Smoke
emissions from coal, of course, have been controlled or
prevented by several means. Highly volative bitumi-
nous or "soft" coal is replaced by the relatively smoke-
less anthracite and coke. Power plants and heating
units are designed to provide enough time and tem-
perature for complete combustion, in addition to the
utilization of electrical precipitators and settling cham-
bers. In the case of Pittsburgh, home owners are re-
quired to either use a smokeless grade of fuel or to
install stokers or other heating units as will allow the
smokeless combustion of fuels.
Petroleum economies are those which make use
of liquid fuels for industrial power and domestic heat-
ing due to proximity to oil refineries. An area like
Los Angeles, a major oil-producing and refining cen-
ter, as well as one of the largest urbanized petroleum
markets, is, strictly a petroleum economy Even though
a smoke problem from the combustion of fuel oil is not
as pronounced in Los Angeles as it is in the coal-
consuming economies, the widespread use of petroleum
products is a major contributor to Los Angeles smog,
particularly as a result of the combustion of more than
6,000,000 gallons of gasoline per day in internal com-
bustion engines, and 60,000 barrels of fuel oil at steam
generating and industrial facilities. The principal con-
taminants emitted from fuel oil are sulfur dioxide and
oxides of nitrogen, whereas those produced from the
combustion of gasoline are unsaturated hydrocarbons
and oxides of nitrogen, both of which have a secondary
pollution or smog-forming potential.
Although fuel economies based exclusively on the
use of natural gas are rare, the use of natural gas is
increasing, and both liquid and gaseous fuels tend to
supplement each other and to supplant the use of solid
fuels. Natural gas originates from the Utah, Colorado,
New Mexico and Texas fields, and is piped to cities at
great distances away. Of all of the fuels, natural gas,
which consists of about 85% methane, 12% ethane and
some inert materials, emits less contaminants, burns
smokelessly, and variations in gas-air mixtures, and
other mechanical factors involved in its combustion,
are not as critical as with liquid and solid fuels. In
Los Angeles County, the increasing availability of
natural gas from the Texas fields has made it possible
to require its use instead of fuel oil.
2. The Industrial Economy
The industrial economy of any metropolitan pol-
lution zone consists of the types and number of manu-
facturing operations or processes employed in produc-
ing basic or by-product commodities from raw or sal-
vaged materials, and the services necessary to main-
tain these industries. Industries tend to fall into stand-
ard categories,(26) whether all related processes are
-------
18
Air Pollution Control Field Operations
captive to one enterprise, or whether they are conduct-
ed individually on a contracting basis. From these in-
dustrial categories, it is possible to compare the kinds
and extent of industrial activity of the various cities
and to compute the air pollution potentials from each.
Each industry presents a certain type of air pol-
lution problem in terms of the emission of smoke,
fumes, mists, dusts, vapors or gases. The .effluents de-
rive directly from the materials employed in the man-
ufacturing, the process methods used and their efficien-
cy, the control measures taken, as well as the fuels
used to provide mechanical or thermal energy.
Table 1-3 lists the standard industrial categories,
types of activities conducted and types of air pollution
problems encountered. Metropolitan economies pos-
sessing a heavy concentration of any one industry tend
to exhibit the types of air pollution problems associated
with that industry, unless effectively controlled. A
city with a diversified economy tends to possess a
more varied type of air pollution problem. The ex-
tent of diversity and concentration may be given com-
paratively on the basis of employment figures. Al-
though industries with relatively automated processes
employ less persons, such as oil refineries, the presence
of that industry may be sufficient to indicate its im-
portance to air pollution. In such cases, figures can be
given in throughput and output quantities of materials
processed, as in Table 1-5, page 25.
3. Service Industries
The service industries represent a vast variety of
commercial, professional, governmental, military and
educational activities, primarily of a non-manufactur-
ing nature. These include:
Transportation and freight, including
ships, automobiles, trucks, buses and trains.
Telecommunications.
Retail and wholesale trade.
Finance, insurance and real estate.
Hotels, motels and lodging places.
Medical services, clinics and hospitals.
Schools, colleges and universities.
Public administration and government facilities.
Repair services.
Laundry and cleaning.
Entertainment and motion pictures.
Salvaging and dumping.
Private households.
The services themselves do not, as a rule, consti-
tute the air pollution potential. However, the shelters
for such activities require space heating, disposal or
incineration of combustible rubbish, and their occu-
pants and supplies require transportation. Statistically,
these comprise a mass of sources of air pollution
spread throughout the pollution zone. In some in-
stances these may constitute the principal sources of
air pollution through the preponderance of their popu-
lation. Air pollution thus can arise from a commercial
and suburban economy, as well as from an industrial.
When this happens, the entire pollution zone may be
considered as both source and effect area.
Some service operations are similar to manufac-
turing type activities and may directly emit air con-
taminants. The extensive use of a variety of organic
solvents, for example, in the application of protective
coatings, dry cleaning and printing, as well as in a
number of industrial operations such as degreasing and
tire manufacturing, may result in the widespread
emission of reactive air contaminants. Certain govern-
mental operations, such as electric power generation,
municipal incineration, sewage treatment and disposal,
may constitute large single sources of air pollution.
Salvage operations, particularly in the dismantling or
separation of manufactured components, as in remov-
ing rubber coatings from wire and automobiles by
torch or fire, may involve smoke and local nuisances.
C. Industrial and Commercial Expansion and
Diversification
Because of phenomenal population increases ev-
erywhere, pollution zones change in size, population
density, and technology. These changes lead to both
gradual and spontaneous growths of the pollution
potentials, factors which must be continuously sur-
veyed by the control activity. There are several ways
in which these potentials may increase.
a. Since population growth stimulates new mar-
kets in the economy, industrial growth follows.
Industries relocating from other regions of the
country will tend to bring with them their
existing markets, thus greatly expanding the
local economy. This factor of industrial growth
may represent a sudden increase in the pollu-
tion potential of that industry.
b. As the market for any industry expands,
existing plants expand their facilities with ad-
ditional process equipment to meet new condi-
tions of competition.
c. Dependent and subcontracting industries asso-
ciated with the industry expand to help main-
tain that industry as well as to help distribute
its products.
d. Plant expansion tends to offset gains made by
existing control techniques and in time pollu-
tion potentials may be brought back to pre-
control levels. This growth factor will thus
increase the level of pollution despite control
efforts. In order to decrease it, the average
control efficiency must be raised.
e. Changes in industrial operations, materials,
and fuels or the introduction of novel processes
may cause new air pollution problems. The
manufacture of products employing radiational
derivatives may emit radioactive contaminants
whose presence in the air may not be tolerated.
-------
TABLE 1-3
STANDARD MANUFACTURING INDUSTRIES OF THE METROPOLITAN ECONOMY
(Based on Reference 26)
MANUFACTURING
INDUSTRY
NATURE OF ACTIVITY
TYPES OF AIR POLLUTION
PROBLEM
NUMBER EMPLOYED IN
LOS ANGELES COUNTY*
PRIMARY METALS
(Ferrous and non-
ferrous)
FABRICATED
METAL PRODUCTS
MACHINERY
ELECTRICAL
MACHINERY
Primary smelting** of ore to obtain metallic ele-
ments. Steel Mills—manufacture of steel alloy prod-
ucts by removal of graphitic carbon from iron and
addition of alloy elements. Ferrous and nonferrous
foundries—cast products from sand or permanent
molds.
Secondary smelting — separates ingots of each ele-
ment from scrap. Secondary ingot production - pre-
pares alloyed ingots from scrap.
Manufacture of a large variety of products: Heating
and plumbing equipment, tools and hardware, struc-
tural metal products, cutlery, metal stamping and
coating, lighting fixtures, tin cans and others. Usually
involves metal melting from ingot; machine shops,
metal finishing and surface coating.
Machining and finishing of component machinery
parts and/or their assembly in the production of a
wide variety of mechanical equipment (but not in-
cluding electrical machinery). Farm implements,
machine tools, printing, office and store equipment,
oil field production and refinery equipment, textile,
shoes and clothing equipment, construction equip-
ment, household equipment, etc.
Manufacturing and assembly of machinery; appa-
ratus and supplies for the generation, storage, trans-
mission, and utilization of electrical energy, prin-
cipally electrical motors and generators.
Primarily fuming of metallic oxides,
and emission of CO, smoke, dust and
ash from melting operation, depending
on the volatility and impurities of the
metals, scrap or ore concentration.
Smelting is most notorious, emitting
sulfur dioxide, lead and arsenical cop-
per fume, depending on metal smelted.
Metals melted are usually refined, and
melting operations are easily con-
trolled. Principal air contaminants are
metallic fumes and dusts from found-
ries and solvent mists and vapors from
application of protective coatings in fin-
ishing departments.
Primarily dusts and mists from finish-
ing departments, some smoke and
fumes from quenching in tempering
and heat treating. Metal melting is not
usually involved.
Air contaminants similar to those de-
scribed under machinery.
23,100
55,700
it
B
3
a,
t*i
H
61,300
o
3
74,400
* As reported by the California State Department of Employment, January 1959.
** No primary smelting activity is conducted in Los Angeles County. Smelters have caused adverse air pollution conditions and damage to vegetation, crops or animals in Ducktown,
Tennesse; Anaconda, Montana; Salt Lake City, Utah and Trail, British Columbia. These operations are now controlled.
-------
TABLE I - 3 (continued)
MANUFACTURING
INDUSTRY
NATURE OF ACTIVITY
TYPES OF AIR POLLUTION
PROBLEM
NUMBER EMPLOYED IN
LOS ANGELES COUNTY*
MINING'
FURNITURE,
LUMBER AND WOOD
PRODUCTS
TRANSPORTATION
EQUIPMENT
Quarrying and milling of solid products and min-
erals — coal, iron and metallic ore.
Petroleum and petroleum refining. Drilling and ex-
traction of crude petroleum from oil fields, recovery
of oil from oil sands and oil shale, and production of
natural gasoline and cycle condensate. Oil refining
consists of a number of complex flow processes based
on heat and pressure which crack, build up, alter or
segregate hydrocarbons from crude oil in the pro-
duction of a large variety of commercial products
from high octane gasolines to heavy oils and
greases.
Natural gas originates from the oil fields in the
southwest.
Logging and milling, including veneering, planing,
and plywood manufacturing; boxing and container
manufacturing; sawdust and other by-product man-
ufacturing. Furniture mfg., household, office and
store fixtures. Involves production wood working,
(planing, milling, cutting, sanding, shaping, etc.),
finishing (staining, priming, painting, etc.) and oc-
casionally elimination of large volume production
wastes by burning.
Manufacture and/or assembly of component parts
for ships, automobiles, rolling stock, aircraft and
other transportation equipment involving fabrication
of structural assemblies and components, and, in the
case of ships and rolling stock, riveting, welding and
sheet metal work. A high degree of specialization, es-
pecially in automobiles and aircraft, necessitates ex-
tensive subcontracting activities, or concentration of
many captive industries into coordinated production
systems.
Waste explosive gases, CO, etc., dusts
and fumes.
Due to the large number of production
steps, all forms of air pollution arise
from refineries. These include vapors
from evaporation of petroleum prod-
ucts in handling and storage; sulfur
dioxide and smoke plumes from scav-
enging and burning of refinery fuels
in heating equipment; odors, mists and
dusts from cracking operations.
Fines and dusts from milling opera-
tions. Paint and solvent emissions from
surface coating. Smoke from burning
waste lumber, mill ends, fines and saw-
dust.
Aside from assembly lines which are
not in themselves significant sources of
air pollution, captive subsidiary opera-
tions may involve foundries, heat treat-
ing, wood-working, plating, anodizing,
chem-milling and surface coating op-
erations which contribute all types of
air contaminants including organic va-
por emissions from the application,
drying and baking of protective coat-
ings.
19,900
28,300
"B
o
o
3
3
Si
5'
P^w
ft.
.
o
3
225,700***'
*** American mining locations are not as a rule distributed among urban areas. In Los Angeles County, only petroleum refining is significant as a mining activity.
**** 27,400 motor vehicles and equipment; 188,400 aircraft and parts, 9,900 ships and boats.
-------
TABLE I - 3 (continued)
MANUFACTURING
INDUSTRY
CHEMICALS AND
ALLIED PRODUCTS
MINERALS
(Stone, Clay and
Glass Products)
TEXTILE
NATURE OF ACTIVITY
Manufacture of almost an unlimited variety of prod-
ucts: petro-chemicals, heavy or industrial chemicals
such as sulfuric acid, soda ash, caustic soda, chlor-
ine and ammonia; pharmaceuticals, pesticides, prod-
ucts of nuclear fission, plastics, cosmetics, soaps, syn-
thetic fibers, such as nylon, pigments, etc. Manufac-
turing techniques encompass virtually the entire
chemical technology.
Manufacture from earth materials (stone, clay and
sand), glass, cement, clay products, pottery, con-
crete and gypsum products, cut stone products, abra-
sive and asbestos products, roofing materials, bricks,
etc., involving mechanical processes such as crush-
ing, mixing, classifying and grading; batching, dry-
ing and baking in kilns to vitrify dishware, and
melting and forming to produce glass products.
Includes milling and manufacturing of yarns,
threads, braids, twines, fabrics, rugs, apparel, lace,
and a vast variety of products involving processes of
spinning, spooling, winding, weaving, braiding, knit-
ting, sewing, bleaching, dyeing, printing, impreg-
nating, batting, padding, etc.
TYPES OF AIR POLLUTION
PROBLEM
Chemical technology makes possible all
forms of pollution, involving the emis-
sions of the chemicals (both chemical
and end-product) and the derivative or
reaction products of the chemicals in
process or in the atmosphere.
Dusts from mechanical processes,
smoke and fumes from melting or kiln
operations.
Lint and fines are emitted from pro-
duction wastes; organic vapor emis-
sions or other mists from dyeing,
bleaching, impregnating, cleaning;
smoke from combustion equipment re-
quired to power weaves, looms, and
other processing and conveyor equip-
ment.
NUMBER EMPLOYED IN
LOS ANGELES COUNTY*
22,100
19,000
r
a
r**.
c
3
a
3
3
r-<
,o
48,900
o
3
RUBBER
PRODUCTS
Manufacture from natural, synthetic, or reclaimed
rubber (gutta percha, balata, or gutta siak), rubber
products such as tires, rubber footwear, mechanical
rubber goods, heels and soles, flooring, and other-
rubber products. Processes involve mastication, mix-
ing or blending of crude rubber, reclaim or chemical
rubbers, calendering, tubing, binding and cementing,
curing, etc.
Local dusts and carbon black emissions
from mixing and rolling operations, but
usually under careful control. Organic
vapor emissions from solvents used in
bonding and cementing, coating and
drying of products.
15,400
-------
TABLE 1-3 (continued)
to
MANUFACTURING
INDUSTRY
NATURE OF ACTIVITY
TYPES OF AIR POLLUTION
PROBLEM
NUMBER EMPLOYED IN
LOS ANGELES COUNTY*
PAPER AND ALLIED
PRODUCTS
PRINTING AND
PUBLISHING
INSTRUMENTS
FOOD
AND KINDRED
PRODUCTS
OTHER
MANFUACTURING
INDUSTRIES
Manufacture of paper and paper products from
wood pulp, cellulose fibers, and rags involving cut-
ting, crushing, mixing, cooking, and paper mills.
Printing and publishing by means of letterpress,
lithography, gravure, or screen, bookbinding, type-
setting, engraving, photoengraving, and electrotyp-
ing. Involves lead melting pots for typesetting ma-
chines, and significant quantities of inks containing
organic solvents.
Manufacture and assembly of mechanical, electrical
and chemical instruments for dental, laboratory, re-
search and photographic uses, including watches and
clocks. Involves casting and machining of a variety
of hard metal alloys, including brass and steel; as-
sembly, plating and finishing.
Includes the slaughtering of animals and the curing
and smoking of meat products as well as the prepara-
tion of all other foods such as dairy products, canning
and preserving of fruits, vegetables and seafoods;
grain and feed milling, baking, preparation of bev-
erages, including coffee, beer and other alcohols; ani-
mal rendering, manufacture of fats, oil, grease,
tallow, etc.
Tobacco, ordnance and armaments, leather and
leather products, building construction, jewelry and
silverware, etc.
Some possible sawdust emissions, but
otherwise practically no emissions, ex-
cept from combustion equipment to
provide steam heat and power for me-
chanical equipment. Construction ma-
terials such as roofing paper involve
saturating paper with asphalt and im-
pregnating with minerals, causing mist
and dust problems.
Lead oxide emissions are possible from
lead pots, but these are easily con-
trolled. Organic solvent emissions arise
from the large volume of inks, particu-
larly in rotogravure processes.
Emissions from these plants are usually
controlled, but can involve smokes,
dusts, and fumes similar to those of
fabricating and machinery manufac-
turing industries. Hard-chrome electro-
lytic plating is usually involved with
high quality instrumentation, causing
emission of acid mists.
Most notably odors, particularly from
rendering operations and from poor
housekeeping where products are per-
mitted to decompose. Odors may also
occur from the handling of by-prod-
ucts, and from coffee roasting. Dust
from grain and feed mill operations.
All types of air pollution arising from
basic processes described in the fore-
going.
12,100
34,600
14,600
o
3
§
t-*.
3
'
3
O)
46,900
pollution arising from 38,800
-------
The Nature and Extent of Air Pollution
New petroleum refining techniques may cre-
ate products with higher vapor pressures and
greater quantities of unstable compounds. Sim-
ilarly, slight alterations of basic fuels can re-
sult in a sudden increase of air contaminants.
By fractionally increasing the sulfur content in
gasoline or other fuels in mass use, for ex-
ample, the visibility reduction resulting from
increasing quantities of aerosols in the atmos-
phere may be increased several hundredfold.
f. With the expansion of both industry and the
population, power requirements increase quite
sharply. The increased use of fuels is not only
influenced by the growth factor but also by a
higher standard of living, creating a demand
for more appliances utilizing greater amounts
of electrical energy.
D. The Los Angeles Metropolitan Pollution Zone
Los Angeles County covers 4,083 square miles and
includes 71 separately incorporated cities as well as
large unincorporated areas (Figure 1-9). The area is
topographically divided by the Sierra Madre mountain
range into two sections. The southern section, the Los
Angeles County coastal basin proper, comprises some
1200 square miles and virtually the entire metropoli-
tan area of Los Angeles County. The second, or north-
ern section, includes the mountain ranges, and the
sparsely populated desert regions of the Antelope Val-
ley.
The boundaries of the pollution zone tend to co-
incide with the Los Angeles Basin.* The north-south
dimension of the zone from the mountain ranges to
the coast lines provides a clear definition of the zone's
breadth. The pollution zone also extends along the
coastal strips north of Santa Monica and the mountain
passes and out-bound routes just north and west of the
San Fernando Valley.
The pollution zone is less defined at the Los
Angeles-Orange-San Bernardino County lines where
both wind flow and metropolitan areas overlap causing
some exchange of pollution among the bordering coun-
ties. The actual boundary of the Southern California
Pollution Zone should probably be extended to include
the expanding and merging metropolitan complexes to
a point south of San Diego, if not to the Mexican bor-
der. It may also extend in the foreseeable future
through the mountain passes and coastal strips north
to Santa Barbara and Bakersfield**.
The metropolitan area has grown by increments
in land area in all directions, rather than through
concentrations of tall buildings. The effect of such
development has resulted in the encroachment of in-
dustrial and residential communities onto each other's
areas. Agricultural areas, for example, have been re-
placed by industrial establishments or housing devel-
opments. Refineries and industries previously located
in relatively uninhabited areas are being surrounded
by residential communities, thus increasing the num-
ber of incidents of public nuisance. The metropoli-
tan complex itself continues across county boundaries.
With the complete saturation of the land area, taller
buildings are expected to be constructed.
1. The Los Angeles Economy
Prior to 1940, the Los Angeles economy consisted
of a number of industries which depended on the
climate of the area and the availability of relatively
cheap land. These were the nucleus of an aircraft
industry (favorable year-round flying conditions),
citrus products (the county was one of the richest ag-
ricultural areas in the United States), motion picture
industry (all-year sunshine for camera illumination),
retail trade (encouraged by tourism and retired citi-
zens), and a resort area (access to beaches and moun-
tains). In addition, the area contained abundant pet-
roleum resources for oil-field development and refin-
ing, and excellent harbor facilities in the Long Beach-
Wilmington-San Pedro areas.
During World War II all industries developed
phenomenally, particularly in aircraft and ship build-
ing, while Los Angeles became an important military
center. Thousands of civilians and military personnel
residing in or passing through the area eventually de-
cided to live in Southern California after the war.
The population movement to Southern California
since World War II never ceased, and Los Angeles has
grown from 2% million in 1940 to more than 6 million
in 1960. Aircraft, missiles and subsidiary industries
also continued to grow during the post-war period.
Established industries expanded their facilities, and
new industries were created to meet market demands,
while industries in other parts of the country either
developed subsidiary or west coast divisions, or moved
their home offices entirely. Due to the local demand
for automobiles, automobile and other assembly plants
were established in the area. A diversified and self-
sustaining economy developed which grew from 6,000
TABLE 1-4
GROWTH OF LOS ANGELES COUNTY
* The iurisdiction of the Los Angeles County Air Pollution Con-
trol District, however, includes the entire County of Los
Angeles.
* * On the east coast there is a growing awareness of pollution
of a national air space extending from metropolitan New York
and New Jersey south through Washington, D.C.
Year
1940
1950
1960
1970
1980
Population
2,785,643
4,151,687
6,120,000
8,050,000
9,980,000
Registered
Vehicles
1,220,361
2,007,552
3,450,000
4,900,000
6,350,000
Gasoline
Consumption
Gal /Day
1,920,000
3,850,000
6,400,000
9,100,000
11,780,000
Industries
5,900
11,500
17,000
21,000
25,000
Source: Reference 6.
-------
to
t)
o
o
3
s
<5°
<—.
R,
f
B
T^4.
5'
3
Figure I - 9. The boundaries of the Los Angeles Basin, as legally defined by the Rules and Regulations of the A.P.C.D.
-------
The Nature and Extent of Air Pollution
industrial establishments in 1939 to more than 17,000
in 1960. Los Angeles County, consequently, developed
as the largest heavily industrialized semi-tropical area
in the world, as well as the third largest metropolitan
area in the United States.
The petroleum industry, which grew to satisfy a
market which developed virtually on its own door-
steps, now accounts for about 10% of the national
refining capacity and is concentrated in some 19 re-
TABLE I - 5
CURRENT STATISTICS
FOR LOS ANGELES COUNTY
ITEM
QUANTITY
Population
Total employees in manufacturing
Gasoline powered vehicles
registration
Diesel powered vehicle registration
Gasoline consumed by vehicles
Diesel fuel consumed by vehicles
Fuel oil consumed by industrial
combustion sources
Natural gas consumed by indus-
trial combustion sources
Refinery gas consumed by indus-
trial combustion sources
Fuel oil consumed by domestic and
commercial combustion sources
Natural gas consumed by domestic
and commercial combustion
sources
Solvents used for all purposes
Refinery crude oil throughput
3,830,000
740,000
2,920,000
9,000
5,820,000 gal/day
100,000 gal/day
1,900,000 gal/day (a)
3,200,000 gal/day(a), (b)
1,600,000 gal/day (b)
200,000 gal/day (b)
3,300,000 gal/day(a), (b)
1,000,000 Ibs /day
650,000 bbls/day
(a) Prior to Rule 62.
(b) Equivalent gas/day on a Btu basis.
Source: Reference 7.
fineries with a crude oil processing capacity of approx-
imately 750,000 barrels, and a finished gasoline pro-
duct of about 16 million gallons per day. The extent
of the other industrial activities conducted in Los
Angeles, as shown from the employment figures in
Table 1-3, indicates the degree of industrial diversity
in Los Angeles County.
The industrial and steam-generating fuel require-
ments in Los Angeles County are met entirely by fuel
oil and natural gas. The increasing demand for fuel
has severely taxed available fuel supplies, particularly
natural gas, and is one of the major factors to be con-
sidered in the Los Angeles problem.. Prior to 1940, a
majority of the power was supplied by Hoover Dam,
but since that time excess demand has been met by
the construction of some 11 steam-electric power gen-
erating stations located throughout the Basin (see
Figure 1-9).
Due to the severe meteorological conditions in
Los Angeles County, the extensive use of fuel oil is
being replaced by natural gas which is conveyed by
pipline from Texas. Gas supplies are available in
sufficient quantities to meet current needs during the
seven months of the smog season, as required by Dis-
trict Rule. Population increases, however, continue to
increase this demand.
The spread of a large population over such an
extensive land area has caused an unprecedented in-
crease in traffic population, some 3,000,000 registered
motor vehicles consuming almost 6,000,000 gallons per
day of gasoline — the largest metropolitan concentra-
tion of automobiles in the world.
TABLE 1 - 6
EFFECTS OF POPULATION AND INDUSTRIAL GROWTH IN LOS ANGELES COUNTY ON STEAM-
ELECTRIC POWER PRODUCTION AND FUEL REQUIREMENTS AND COMPARISON OF
CONTAMINANT EMISSIONS FROM THE BURNING OF FUEL OIL AND NATURAL
GAS EQUIVALENT OF FUEL OIL (a)
YEAR
1950
1958
1970
POPULATION
(MILLIONS)
4.2
5.6
8
TOTAL POWER
REQUIREMENT
(BILLION
KILOWATT-HOURS
PER YEAR)
8
24
66
STEAM-ELECTRIC
POWER PRODUCTION
(BILLION
KILOWATT-HOURS
PER YEAR)'
4.5
15
43
FUEL REQUIRED FOR
POWER PRODUCTION
(THOUSAND EQUIVALENT
BARRELS PER DAY)
20
60
190
SULFUR
DIOXIDE
EMISSIONS FROM
FUEL OIL
(TONS PER DAY)
105
320
1020
YEAR
1950
1958
1970
SULFUR DIOXIDE
EMISSIONS FROM
NATURAL GAS
(TONS PER DAY)
0.02
0.1
0.2
NITROGEN OXIDE
EMISSIONS FROM
FUEL OIL
(TONS PER DAY)
60
185
570
NITROGEN OXIDE
EMISSIONS FROM
NATURAL GAS
(TONS PER DAY)
40
120
380
AEROSOL
EMISSIONS FROM
FUEL OIL
(TONS PER DAY)
10
30
95
AEROSOL
EMISSIONS FROM
NATURAL GAS
(TONS PER DAY)
1
3
10
(a) Los Angeles County Air Pollution Control District Fuel Survey; Tulin, R. S., Fuel Requirement and Supply — Liquid Petroleum and
Natural Gas, District V — Los Angeles Basin; Twenty-Eighth Annual Report — Utilities — Los Angeles Area, 1957-1958 Los Angeles
Chamber of Commerce.
Source: Reference 6.
-------
26
Air Pollution Control Field Operations
Prior to October 1956, 11,000 tons of domestic,
commercial and industrial wastes were disposed in
some one-and-a-half million inefficient single-chamber
incinerators and open fires, thus causing an important
smoke problem. Since that time, rubbish burning has
been eliminated by rule, except in a relatively few
instances where approved multiple-chamber inciner-
ators are permitted. Open fires, with a few exceptions,
are also illegal in the Los Angeles Basin.
At the present time, most combustible refuse is bur-
ied in land-fill dumps, and the remainder is burned in
municipal incinerators or approved multiple-chamber
incinerators capable of smokeless combustion. Like
fuel burning, rubbish disposal is a more or less per-
manently constituted problem, involving either the
availability of dump sites, which becomes reduced by
population growth, or the construction of municipal
incinerators which, while more efficient than single-
chamber incinerators collectively, still contribute to
air pollution.
IV POLLUTION POTENTIALS OF THE
METROPOLITAN ECONOMY
Due to the diversity and complexity of the sour-
ces of air'pollution, the atmospheres of large cities con-
tain most of the chemical substances and their deriva-
tives or oxidation products known to chemical tech-
nology, including, perhaps, many that are unknown.
To determine what is in the air, it is necessary to in-
vestigate the types and quantities of pollutants emitted,
the activities responsible for their emission, and the
relative contributions to the major classification of air
contaminants. These involve both the sampling of the
ah- to identify and measure the contaminants present
and an analysis of the air pollution potential of the
metropolitan economy. The air pollution potential,
which we shall now consider, is divided in three parts:
the primary potential of metropolitan activities to emit
contaminants; the secondary potential of the contami-
nants to produce other contaminants in the atmosphere
through chemical reaction; and the nuisance potentials
of individual sources of pollution.
A. The Primary Potentials
The primary pollution potentials may be said to
represent the kinds of contaminants and the rates at
which they are emitted from the sources of air pollu-
tion prior to any interaction or to modifications as a
result of natural forces in the atmosphere. Computa-
tion of the primary potentials involves (1) classifica-
tion of the important air contaminants emitted from
the activities of the metropolitan economy, (2) deter-
mination of the average rates at which they are emit-
ted from the respective activities, i.e., the emission
factors, (3) a survey of the quantities of materials
handled, processed or burned by the economy, and (4)
computation of the pollution potentials in weight-units
per day.
1. Classification of Primary Air Contaminants
Because some contaminants predominate in the
atmospheres of some cities, and not in others, the clas-
sifications are oriented towards the significant effect-
producing contaminants. Generally, such classifica-
tions first distinguish between the two physical states
of contaminants — aerosols and gases (organic and in-
organic), then the major chemical families or classes,
and finally the subgroupings of each family, if not the
actual names of the specific chemical compounds. The
more important the contaminant, the more specifically
is it identified. Table 1-7 illustrates, for example, the
classification of air contaminants found in the Los An-
geles atmosphere.
2. Emission Factors
The emission factor is a statistical average of the
rate at which contaminants are emitted from the pro-
cessing, handling or burning of given quantities of
material. It is determined by measuring the quanti-
ty and composition of the effluent by representative
source testing and evaluating the material and fuel
specifications reported by the sources of air pollution
and the technical literature. For example, assuming
no control process is employed, the emission factors
for oxides of sulfur (estimated as SO2) from tests and
past experience are as follows(5):
Fuel oil combustion — 30 pounds per 1,000 pounds of oil.
Coal burning — 40 pounds per ton of coal.
Automobile engines — 17 pounds per 1,000 gallons of gasoline.
Diesel engines— 15 pounds per 1,000 gallons of fuel.
TABLE 1 7
CLASSES OF CONTAMINANTS FOUND IN THE
LOS ANGELES ATMOSPHERE
MAJOR CLASSES
OF AIR
CONTAMINANTS
Organic Gases
Inorganic Gases
Aerosols
SUBCLASSES OF
AIR
CONTAMINANTS
Hydrocarbons
Aldehydes and
Ketones
Other Organics
Oxides of Nitrogen
Oxides of Sulfur
Carbon Monoxide
Other Inorganics
Solid Particulate
Matter
Liquid Particulate
TYPICAL
MEMBERS
OF SUBCLASSES
Hexane, Benzene
Ethylene, Methane
Butane, Butadiene
Formaldehyde,
Acetone
Chlorinated Hydro-
carbons, Alcohols
Nitrogen Dioxide,
Nitric Oxide
Sulfur Dioxide
Sulfur Trioxide
Carbon Monoxide
Hydrogen Sulfide,
Ammonia, Chlorine
Dusts, Smoke,
Fumes
Oil Mists, Entrained
Liquid Droplets
Source: Reference 7.
-------
The Nature and Extent of Air Pollution
Tables I - 8 through 1-12 show the emission fac-
tors for the major contributors to those classes of con-
taminants which are significant in Los Angeles. Al-
though these emission factors represent the best avail-
able data, they are subject to continuously changing
27
conditions. Emission factors, moreover, cannot be sat-
isfactorily generalized for the nation as a whole, but
must be computed for each specific pollution zone.
Such factors as materials used, processing techniques
and efficiency, etc. as practiced locally affect the final
estimates.
TABLE 1-8
EMISSION FACTORS FOR AIR CONTAMINANTS DISCHARGED
FROM THE COMBUSTION OF FUELS IN STATIONARY SOURCES
LOCATION OF
STATIONARY COMBUSTION
SOURCE
Power Plants
Gaseous Fuels
Liquid Fuels
Refineries
Gaseous Fuels (b)
Liquid Fuels
Other Industries
Gaseous Fuels
Liquid Fuels
Domestic and Commercial
Gaseous Fuels
Liquid Fuels
EMISSION FACTORS, POUNDS PER THOUSAND EQUIVALENT BARRELS
OF FUEL OIL BURNED(a)
Hydro-
carbons
n
33.9
156
146
n
31.6
n
27.9
Aldehydes
and
Ketones
6
24.9
18
26.8
12
25
n
22.1
Other
Organic
Gases
18
114.2
84
473
30
70.6
n
62.2
Oxides of
Nitrogen
2340
5000
1009
3200
1283
3360
696
3060
Sulfur
Dioxide
2.5
11,000
2.5 (c)
12,200
2.5
10,710
2.5
4,725
Carbon
Monoxide
n
1.79
25
n
2.4
6.25
2.4
n
Other
Inorganic
Gases
n
n
n
n
n
n
n
n
Aerosols
90
893
126
821
105
839
112
593
n —• Negligible, traces only.
(a) 6000 cubic feet of gas is equivalent to one barrel of fuel oil.
(b) Applicable to emissions from the burning of natural gas and refinery make gas.
(c) Applicable only to natural gas. Sulfur dioxide emissions from the combustion of refinery make gas are dependent upon the amount
of hydrogen sulfide removal accomplished prior to burning.
Source: Originally appeared in reference 7; estimates revised, 1-30-61.
-------
28
Air Pollution Control Field Operations
TABLE I -9
EMISSION FACTORS FOR AEROSOLS FROM
METALLURGIC AND MINERAL PROCESSING
OPERATIONS IN LOS ANGELES COUNTY
SOURCE
Hot Asphaltic Concrete Plants
Perlite and Vermiculite Furnaces
Glass Furnaces (recuperative)
Frit Manufacturing Furnaces
Open Hearth Steel Furnaces (58-
ton capacity) (a)
Grey Iron Melting Cupolas (avg.)
Less than 48" I D
4,0 en" T r\
TQ-UU i.LJ.
Greater than 60" I D
Electric Steel Melting Fur-
naces (avg.)
Less than 5-ton capacity
5-20 ton capacity
50-75 ton capacity
Melting of Red Brass:
CViiriVOn nr Pnt PiifnarAC
Rotary Furnaces
Reverberatory Furnaces
Electric Furnaces
Melting of Yellow Brass:
Crucible Furnaces
Rotary Furnaces
Reverberatory Furnaces
Electric Induction Tvpe Furnaces
Melting of Bronze:
Crucible Furnaces
Rotary Furnaces
Melting of Aluminum:
Crucible Furnaces
Reverberatory Furnaces
Aerosol Emission Factor,
Pounds per ton of Raw
Material Processed
U NCONTROLLED
5
21-88
3.4
9.4
17.8
17.1
19 Q
i jii.y
1 Q £
1:7.3
18 Q
i o.y
8.6
10.6
5.7
9.6
3.3
21.3
16.8
3
14
0.7
3.8
30.6
1.9
5.2
CONTROLLED
0.45
0.19
0.36
0.26
0.17
10.1 (b)
5.1 (b)
22.8 (b)
5.7(c)
4.7
2.1
(a) Principally scrap remelt.
(b) Using slag cover as the only control method.
(c) With baghouse control.
Source: Reference 7.
TABLE I 10
HYDROCARBON EMISSION FACTORS FOR
PETROLEUM REFINING SOURCES
SOURCES OF EMISSION
Crude Oil Storage
Petroleum Distillate Storage
Fluid Catalytic Cracking
Thermofor Catalytic Cracking
Separators
Valves and Flanges
Pump Seals
Relief Valves
Loading Racks
Vacuum Jets
Slowdowns, Turnarounds, Vessel
and Tank Maintenance
Treating
Cooling Towers
Compressor Exhausts
Miscellaneous
Hydrocarbon Emission Fac-
tors — Pounds per 1000
Barrels Crude
UNCONTROLLED CONTROLLED
500
670
200
50
270
28
125(c)
80
150(e)
150
25
8
6(g)
50
75(a)
100(a)
12(b)
8
20(d)
5
2(e)
0(f)
5
12
(a) Floating roof controls. For vapor recovery, factor would
theoretically be zero.
(b) Controlled by carbon monoxide waste heat boiler.
(c) Mostly packed gland seals.
(d) Mechanical seals for light hydrocarbon service.
Pounds per 1000 barrels loaded.
(e)
(f)
Controlled by condensation and incineration of non-
condensables.
(g) Pounds per 1,000,000 gallons of cooling water.
(h) Pounds per 1000 c.f. of gas burned.
Source: Reference 7.
TABLE I 11
AVERAGE EMISSION FACTORS FOR AIR
CONTAMINANTS DISCHARGED FROM AUTO-
MOBILES IN LOS ANGELES COUNTY
PER 1,000 GALLONS (a) (b)
Contaminant
Carbon Monoxide
Organic Vapors
Oxides of Nitrogen
Aldehydes
Sulfur Compounds
Organic Acids
Ammonia
Solids
(Zinc, lead, other metallic
oxides and carbon)
Emission Factor
3000
200-400
50-150
5
5-10
2
2
0.3
.(a) Although these emission factors are subject to a number of
engine, fuel and operating variables, they may be consider-
ed to be reasonable average conditions.
(b) Chambers, Leslie A., Automotive Vehicles as Air Pollution
Sources, National Conference on Air Pollution, Washington,
D.C., November, 1958. Estimates revised January 1961- sub-
ject to change pending further investigation. '
-------
The Nature and Extent of Air Pollution
29
TABLE I 12
AVERAGE EMISSION FACTORS FOR AIR CONTAMINANTS
FROM BURNING COMBUSTIBLE REFUSE IN OPEN
FIRES (a) AND SINGLE-CHAMBER INCINERATORS
PRIOR (b) TO BAN, IN POUNDS PER TON BURNED (c)
CONTAMINANT
Hydrocarbons
Aldehydes and Ketones
Other Organic Gases
Oxides of Nitrogen
Sulfur Dioxide
Carbon Monoxide
Other Inorganic Gases
Aerosols
EMISSION FACTOR
6
10
8
4
3
40
n
22
n Negligible, traces only.
(a) Rule 57 of the Rules and Regulations of the Los Angeles
County Air Pollution Control District prohibits the burning
of combustible refuse in the Los Angeles Basin after Septem-
ber 30, 1957 except for certain acts of fire hazard prevention.
fire fighting training and agricultural operations.
(b) Rule 58 of the Rules and Regulations of the Los Angeles
County Air Pollution Control District prohibits the burning
of combustible refuse in any incinerator within the Los
Angeles Basin except in an approved multiple-chamber in-
cinerator or its equivalent.
(c) Emission factors used in total emissions computed in refer-
ence 7..
3. Surveys of Materials Processed and
Fuels Burned
Realistic estimates of the quantities and composi-
tion of materials handled or processed in metropolitan
activities are siimmarized from data supplied by sur-
veys, questionnaires, registration and inspection of the
sources of air pollution, chambers of commerce, gov-
ernmental agencies, research organizations, scientific
publications, etc. and from a statistical analysis of the
activity and growth of the metropolitan economy.
4. Computing the Primary Potentials
In determining the total polhition potential of
each activity, the amount of material processed per
day is multiplied by the emission factor. Table 1-13
summarizes the primary pollution potentials of the
Los Angeles economy for 1960. From these estima-
tions, the total daily primary potentials include 1775
tons of hydrocarbons, 70 tons of aldehydes and ke-
-tones, 146 tons of other organic gases. 125 tons of aero-
sols, 695 tons of oxides of nitrogen. 585 tons of sulfur
dioxide and 9.950 tons of carbon monoxide. It is
valid to asstmie a uniform day-to-day gross potential.
although adjustments might be considered for week-
ends, holidays, seasonal variations of activity, and
yearly changes in the economy due to growth and con-
trol activity.
a. Maximum and Minimum Primary Potentials
The primary pollution potentials express relative
source contributions to the major classifications of air
contaminants and are computed at the current level of
control technology. From these estimates the mini-
mum and maximum emissions possible under ideal or
adverse circumstances can be determined. A maxi-
mum primary potential may be defined, therefore, as
that potential which results from the total engagement
of the economy in its normal activities, without, or
prior to, the assumption of control measures. A mini-
mum primary potential is that potential resulting from
the maximum control of the sources of air pollution
through the application of the most advanced control
techniques and devices available.
The maximum potential is an indication of the
"absolute" potential of the economy to pollute the air.
Since it is based on the conditions prevalent at the
time a control agency begins operation, the maximum
potential constitutes the sum of the actual, surveyed
potential and the quantities prevented from entering
the atmosphere as a result of an active control pro-
gram. For Los Angeles, the maximum potential for
1960 exceeds 17.000 tons per-day of all kinds of con-
taminants, and includes some 4.000 tons a day which
have been controlled since 1948. This potential will
continue to increase with the growth of population
and economic activity.
The attainment of a minimum primary potential
at any one time may not mean that air pollution is
eliminated, but that emission rates are cut to irreduci-
ble minima. Further reductions must often await en-
gineering solutions to uncontrolled problems. More-
over, some primary contaminants may be controlled
to minimum levels, whereas others may continue at
maximum levels until reduced. With the outstand-
ing exception of hydrocarbons, carbon monoxide, and
oxides of nitrogen, which are emitted primarily from
uncontrolled automobiles, the rates of emission in Los
Angeles County, as shown in Table 1-13. approach
the minimum pollution potentials. However, the min-
imum primary potential continues to grow with con-
tinued metropolitan growth.
b. Evaluation of the Primary Potentials
Although it is useful to rank the emissions of
contaminants to the atmosphere in terms of weight-
units, the primary potentials so computed have a lim-
ited meaning. Several considerations must be taken
into account in' evaluating the importance of these
emissions. First, the dilution capacity of the atmos-
phere and the location and concentration of the sources
of air pollution affect the concentrations the contami-
nants reacli in the air. Secondly, each contaminant
possesses unique chemical and physical properties
which influence their capacity to enter into smog-
forming reactions, their contribution to eye-irritation.
their toxic potential, and their general reactivity in
the atmosphere. The carbon monoxide potential of all
sources (9950 tons per day*) while significant, is of
less consequence when the actual concentrations found
in the air are below threshold levels, than the 695 tons
-------
30 Air Pollution Control Field Operations
TABLE 1-13
SUMMARY OF AIR CONTAMINANT EMISSIONS IN LOS ANGELES COUNTY IN TONS PER DAY, 1960
(Prepared by the A.P.C.D. Engineering Division, January 1961)
FMTSSTON OF ATR CONTAMINANTS TO THE ATMOSPHERE, BY SOURCE, IN TONS PER DAY
SOURCE
Transportation — Automobiles (b) Exhaust
- Blowby
- Evaporatior
(a)— Trucks & Buses J g^jjj11^
- Blowby
- Evaporatior
— Trucks & Buses (Diesel)
— Ships and Railroads
— Aircraft - Jet
Piston
Petroleum — Refining
— Marketing
— Production
Organic
Solvent Uses — Surface Coating
— Degreasing
• — Dry Cleaning
— Plastics & Rubber
— Other
Combustion
of Fuels (c) — Liquid
— Gaseous
(d) — Liquid
— Gaseous
Chemical — Sulfur Plants
— Sulfuric Acid Plants
—Other
Metals —
Incineration — Municipal
— Industrial
—Other
Minerals —
Miscellaneous —
TOTALS (Rounded) (d)
ORGANIC GASES
Hydro-
carbons)
680
140
145
130
40
45
8
n
n
15
90
100
60
190
20
20
17
50
0
5
2
4
0
0
16
0
n
n
0
2
u
1775
Aldehydes
& Ketones
10
U
0
3
u
0
n
n
n
n
2
0
n
25
n
n
4
14
0
1
1
1
0
0
8
0
n
0
0
0
0
70
Other
Organics
12
U
0
4
u
0
n
n
n
n
n
0
0
35
40
8
3
13
0
3
6
2
0
0
16
0
3
1
n
0
u
145
AERO-
SOLS
25
u
0
8
u
0
2
n
1
n
5
0
0
7
0
n
n
n
n
11
38
14
0
n
8
6
3
n
1
4
2
125
INORGANIC GASES
Dxides of
Nitrogen
250
U
0
80
u
0
8
n
1
5
1
0
u
0
0
0
0
0
3
184
187
150
n
n
n
3
3
1
n
6
0
695
Oxides of
Sulfur
19
n
0
6
n
0
2
n
0
n
40
0
n
0
0
0
0
0
2
8
454
13
30
20
1
n
1
n
n
0
u
585
Carbon
Monoxide
6850
n
0
2100
n
0
2
•n
1
110
700
0
u
0
0
0
0
0
0
1
n
1
0
0
0
180
3
1
n
0
0
9950
Other
Inorganics
n
n
0
n
n
0
n
n
0
n
4
0
0
0
0
0
0
0
0
0
0
0
0
1
0
n
n
0
0
u
5
(a) These emissions are subject to confirmation by the current joint survey by L. A. County APCD, U. S. P. H. S., Calif.
Health Dept., Auto. Mfrs. Assn., and Auto. Club of So. California.
(b) Includes trucks under 4000 pounds unladen weight
(c) Average emissions during effective period of Rule 62
(d) Average emissions during period Rule 62 not in effect
0 — 20.05 ton per day
n —• negligible, (0.05 - 0.5 ton per day)
u —• unknown
of oxides of nitrogen and the 1775 tons of hydrocar-
bons whose smog-forming tendencies are greater at
relatively lower concentrations. The main value of
the pollution survey arises from the comparison
which can be made of the relative source contributions
of a given contaminant, once the significance of the
contaminants is established.
B. Secondary Pollution Potential
The secondary pollution potential may be defined
as that capacity of the primary contaminants to inter-
act in the atmosphere to produce new species and
quantities of air contaminants. In assessing the sec-
ondary potential, two general categories of primary
contaminants are considered, reactants and non-
-------
The Nature and Extent of Air Pollution
reactants. Reactants are contaminants which are either
so unstable as to be susceptible to chemical interaction
with other contaminants present in the atmosphere, or
which act as catalysts in promoting interaction among
other contaminants. A non-reactant is a relatively
stable contaminant which will not react or reacts too
slowly to be of any consequence, and which retains
its chemical identity. We shall include as non-
reactants substances which merely alter their physical
state due to changes in temperature, pressure and
humidity, or the simple oxidation products of these
contaminants. It is important to note that the re-
activity of the contaminants i s significant only if
they contribute to the manifestations of the air pollu-
tion problem.
Current knowledge of the secondary reaction sys-
tems which take place in urban air is primarily an
outgrowth of investigations into the causes and effects
of Los Angeles smog. Prior to the Los Angeles prob-
lem, most air contaminants were viewed as non-
reactants related directly to source effluents. The pres-
ence in the atmosphere of sulfur dioxide, sulfuric acid
mists, carbon monoxide, carbon dioxide, carbon parti-
cles and fly ash — all relatively nonreactant as far as
is known — were accounted for from the sulfur and
carbon content of fuels. Early in the Los Angeles
problem, however, certain gases and vapors — alde-
hydes, organic acids, organic peroxides, and ozone —
were found in the atmosphere in concentrations that
could not be accounted for from the known sources of
air pollution. Although large quantities of hydro-
carbons were known to be emitted into the atmosphere,
their consequence was dismissed since it was believed
that hydrocarbons broke down into carbon dioxide and
water, relatively harmless substances. The contami-
nants in the air responsible for eye-irritation, plant
damage and reduction in visibility, moreover, were not
related to any contaminants known to be in the air.
Although sulfur dioxide was suspected, since low con-
centrations were known to cause plant damage and
eye-irritation; the concentrations measured in the air
were insufficient to indict this contaminant. Moreover,
eye-irritating substances like acrolein and formalde-
hyde also were not found in sufficient quantities to
account for all of the eye-irritation. It became increas-
ingly apparent that atmospheric reactions were taking
place which could not be explained in terms of the
traditional air pollution problem.
Dr. A. J. Haagen-Smit, Professor of Chemistry
at the California Institute of Technology, and a con-
sultant to the Los Angeles County Air Pollution Con-
trol District, first identified in 1953 the rather singular
mechanism by which smog is produced in Los Angeles
County. He discovered that the irradiation of mixtures
of nitrogen dioxide and organic gases, primarily ole-
finic hydrocarbons, with the ultra-violet portion of the
spectrum produced both ozone and the type of plant
damage found in the area. Thus, two of the effects of
smog, ozone and plant damage, were related to a
photochemical mechanism presumed to embrace a
variety of chemical reactions and end effects peculiar
to Los Angeles smog(io). "Photochemical smog," as
Los Angeles pollution came to be known, opened up
an entirely new field for investigation.
Subsequent tests by Haagen-Smit and others not
only confirmed this relationship, but synthetic smogs
were created in the laboratory from the reactions of
oxides of nitrogen and hydrocarbons in the presence of
sunlight which reproduced all of the known effects of
Los Angeles smog, including visibility reduction and
eye-irritation(n). These reactions required only the
presence of the two primary reactants, oxides of nitro-
gens and hydrocarbons, and ultra-violet light under
normal atmospheric conditions. The inter-relationship
was further established by the fact that the absence
of any one of these variables was sufficient to prevent
the reaction.
Although this theory identified the basic reactants
in Los Angeles smog, the contaminants causing eye-
irritation and plant damage and the precise chemical
reactions which take place, are still unexplained. Cer-
tain relationships between reactants and end effects,
however, are sufficiently known to permit intelligent
research into a further understanding of the reactions.
In general, a series of chemical reactions take place
involving (1) primary reactions between organic ma-
terials (hydrocarbons) and atoms of oxygen released
from the photochemical dissociation of nitrogen diox-
ide, (2) newly formed compounds such as ozone and
organic materials, and dissociated components of mo-
lecular compounds such as free radicals and free atoms
— substances which are not only available for further
reaction, but which probably produce the typical smog
effects, and (3) secondary reactions which produce
end-products such as alkyl-nitrates, carbon dioxide,
formaldehyde, formic acid and materials which prob-
ably contribute to the oxidizing capacity of the at-
mosphere (8).
1. Primary Reactants in Los Angeles Smog
In Los Angeles County, the two principal con-
taminant reactants participating in the photochemical
smog reaction are certain classes of hydrocarbons
(1180 tons from vehicle exhaust, 300 tons from or-
ganic solvent uses, and 250 from petroleum refining
and production) and 695 tons of oxides of nitrogen.
Both contaminants are emitted in the form of a gas or
vapor.
a. Hydrocarbons
Hydrocarbons are a class of organic materials
comprising thousands of compounds made up of
hydrogen and carbon classified by carbon-hydrogen
ratio, and by structure as paraffins, naphthenes, aro-
matics and olefins. The speed at which the photo-
chemical reaction occurs, the products formed and the
effects produced are closely related to the composition
-------
32
Air Pollution Control Field Operations
and the structure of the hydrocarbon classification.
Some hydrocarbons are highly stable, and may be
classed as non-reactants, whereas others possess rela-
tively unstable structures which react under appropri-
ate influences.
The structures of hydrocarbons, with respect to
their reactivity, are divided between saturated and un-
saturated hydrocarbons. Saturated hydrocarbons, such
as the paraffiins and naphthenes, are made up of sat-
isfied valency bonds, i.e., the hydrogen and carbon
atoms are appropriately matched. Unsaturated hydro-
carbons, such as the olefins, diolefins, and acetylenes,
which are straight or branched-chain hydrocarbons
containing one or more double bonds, possess a defi-
ciency in hydrogen which is readily satisfied by re-
action with other compounds.
The smog-forming potential is also dependent on
the properties of the specific hydrocarbons, particu-
larly on their ability to be oxidized. Generally speak-
ing, hydrocarbons possessing more than four, but less
than nine carbon atoms, enter into the smog reaction.
Of these, the olefins are considered to be the most im-
portant. Other hydrocarbons, such as some branched-
chain paraffins and many forms of aromatics, as well
as certain hydrocarbon derivatives resulting from in-
termediate reactions are reactive in varying degrees,
and may all be proportionately involved in the smog
reaction, especially during prolonged smog sieges(s).
By far the largest source of olefins is the unburned
gasoline emitted from exhaust pipes and carburetors
of motor vehicles. Some seven per cent of all gasoline
used in the automobile is estimated to be exhausted to
the atmosphere in an unburned state. The hydro-
carbons and oxides of nitrogen are mixed in the ex-
haust, and when this mixture is exposed to sunlight,
the rapid smog reaction takes place.
Hydrocarbons are also emitted in substantial
quantities into the atmosphere from the evaporation
of petroleum products and organic solvents. The rate
at which such products evaporate, or vaporize, is
directly related to their vapor pressure. Products with
high vapor pressure generally consist of cracked petro-
leum stocks and distillates such as gasoline, aviation
gasoline, propane or butane, liquid petroleum gas,
some jet fuels, and some solvents and naphthas.
b. Oxides of Nitrogen
Oxides of nitrogen — principally nitric oxide and
nitrogen dioxide — are inorganic gases formed by the
fixation of elemental oxygen and nitrogen at high
temperatures, such as occur during combustion. Nitric
oxide, which is first formed in the exhaust, oxidizes to
nitrogen dioxide. Nitrogen dioxide, in turn, dissoci-
ates from the absorption of sunlight causing oxygen
to be released. Some of the oxygen atoms react with
oxygen molecules (0,) to form ozone (0:)), while oth-
ers react with organic materials and water vapor to
produce a series of complex reactions which generate
free radicals and other intermediate reaction prod-
ucts (14). The oxides of nitrogen thus can be said to
provide the oxygen atoms necessary for the photo-
chemical oxidation of organic materials.
2. Total Oxidant and Ozone
Aside from ozone, which is clearly the cause of
rubber cracking, each of the effects of air pollution —
eye-irritation, visibility reduction and plant damage—
is presumed to be caused by a different, and as yet
unidentified, reaction product. It is thus not yet pos-
sible to quantify and classify the secondary pollution
potential — the secondary and intermediate reaction
products — in the manner of the primary pollution
potential. However, a readily measurable indication of
the over-all reactivity of smog is the oxidizing capacity
of the contaminated atmosphere. This index of smog
reactivity is known as total oxidant.
Total oxidant may be defined as all those sub-
stances in the air — ozone, some peroxidic compounds,
immeasurably small quantities of oxygen atoms and
other substances — which make available oxygen or
oxygenated compounds for chemical reaction. Practi-
cally all of the oxidants are attributed to intermediate
and secondary reactions rather than to primary source
' origin.
In actual chemical measurement, total oxidant
is the measure of an amount of iodine released by the
exposure of a stream of contaminated air to a buffered
neutral potassium iodide reagent. This is a specific
chemical method amenable to automatic sampling, and
is not necessarily an absolute measure of all of the
oxidants. Consistent use of this method, however, pro-
vides a reliable tool for comparing the reactivity of an
atmosphere from time to time, and is used by control
agencies as a check on the measurement of other
contaminants in the air. An atmosphere with a high
oxidant potential is a fairly good over-all indication of
a high secondary potential, although no precise cor-
relation can be made with any of the other contami-
nants found in the atmosphere.
In addition to its contribution to the smog re-
action, ozone (the major oxidant) is an important
contaminant which will not only crack rubber, but
will affect human health at concentrations as low as
1.5 parts per million. Concentrations of ozone can be
specifically measured by a rubber-cracking method,
and by the ozone photometer.
C. Contaminant Levels
The concentrations contaminants reach in the at-
mosphere is a function of the rate at which they are
emitted from the pollution zone and the period of timg
the polluted air remains in the zone. In Los Angeles,
contaminants build up and are retained long enough
to permit them to undergo photochemical reaction,
usually during a period which lasts from four to six
hours each day. During that time the air contains
-------
The Nature and Extent of Air Pollution
33
continuous quantities of "fresh" primary contami-
nants, intermediate reactants and end products or
"aged" pollution. We may refer to the measured vol-
umetric concentrations (in parts per million of air)
of the principal contaminants in a representative par-
cel of air at any point of the smog attack as the con-
taminant level. During this period, the level of the im-
portant contaminants and reactants will increase, but
not at the same rate. Some will reach and then main-
tain a steady level, whereas others will increase rap-
idly and then drop off sharply as atmospheric condi-
tions change.
TABLE 1-14
TYPICAL RANGES OF AIR CONTAMINANT LEVELS
ON SMOGGY AND NON-SMOGGY DAYS
CONTAMINANT
Aldehydes
Carbon Monoxide
Hydrocarbons
Oxides of Nitrogen
Oxidant
Ozone
Sulfur Dioxide
Kin(c)
RANGE PARTS PER MILLION
TYPICAL CONTAMINANT
(v/v)
SMOGGY
DAY (a)
0.05-0.60
8 -60
0.20-2.00
0.25-2.00
0.20-0.65
0.20-0.65
0.15-0.70
5.0-15.0
NON-SMOGGY
DAY(b)
0.05-0.60
5 -50
0.10-2.00
0.05-1.30
0.10-0.35
0.05-0.30
0.15-0.70
4.0-14.0
RECORD MAXIMUM
VALUE PARTS PER
MILLION (V/v)
1.87
72.0
4.66
2.65
0.75
0.90
2.49
24.8
(a) Defined as a day with severe eye-irritation in Central Los
Angeles.
(b) Defined as a day with no eye-irritation in Central Los
Angeles.
(c) Arbitrary units providing a measure of dark-colored air-
borne particles.
Source: Reference 28.
The control agency is concerned with the levels of
pollution for several reasons. First, it must monitor
the concentrations of the principal contaminants in
order to detect an approaching health menace or dis-
aster. Second, it must determine contaminant trends
to either detect gradually worsening conditions, or to
verify the effect of the reduction of primary potentials
by control measures. Third, it must know how con-
taminant levels correlate so as to learn more about re-
actant relationships, and to provide bases for accurate
smog forecasts. And finally, it will need to develop
substantial and accurate data from which standards
of air quality can be formulated for the purpose of
safeguarding the long term health of the population.
1. Monitoring the Key Contaminants
Air monitoring can be considered in two phases:
(1) continuous monitoring of the pollution levels with
sampling equipment located at strategic positions in
the pollution zone, and (2) monitoring of the effects of
contaminants such as plant damage and eye-irritation.
KEY CONTAMINANTS MONITORED KEY EFFECTS MONITORED
IN LOS ANGELES COUNTY (12) IN LOS ANGELES COUNTY
Carbon Monoxide Eye-Irritant
Oxides of Nitrogen Plant Toxicant
Ozone
Oxides of Sulfur
Parti culates (Km)
Total Oxidant
It is impractical, of course, to conduct continuous
automatic monitoring of all contaminants which may
be found in the air due to the limitations and expense
encountered in current instrumentation techniques.
The control agency must therefore adapt its monitor-
ing program towards the key contaminants.
,,,,AIR SAMPLING STATION REPORTING NETWORK,,,,*^ ""<.. *
'' " '""
AIR POLLUTION CONTROL DISTRICT
jf- '/l\"'tsj ' * V.'' — ^
S:-*. ''^"''^••'''m^**^ •*'',„,w**
4JPA5ADENA fy.
Figure I - 10. Typical distribution of air-sampling stations in
Los Angeles County.
In Los Angeles County, the monitoring of ozone,
sulfur dioxide, oxides of nitrogen and oxides of sulfur
on a 24-hour basis at six stations is required by Regu-
lation VII of the District Rules and Regulations.
The specific purpose of monitoring stations is to
determine when these contaminants approach and ex-
ceed the concentrations set forth in the various alert
stages as defined in Rule 156.
TABLE 1-15
ALERT STAGES FOR TOXIC AIR CONTAMINANTS (PPM)
REGULATION VII
ALERT STAGES
NUMBER OF ALERTS
CALLED IN LOS ANGELES
tJUIN 1 AlViliN A1N 1 S
Carbon Monoxide
Nitrogen Oxides
Sulfur Oxides
Ozone
First Second Third
Alert Alert Alert
100 200 300
3 5 10
3 5 10
0.5 1.0 1.5
COUNTY
Year First Second Third
Alert Alert Alert
1955 15 0 0
1956 10 0 0
1957 1 0 0
1958 800
1959 400
1960 200
-------
34
Air Pollution Control Field Operations
CONTACT
COLUMN
Proper mixing of
contaminated air
and reagent. Only
specific contamin-
ant is absorbed.
-\
ReactantX
Product /
COLORIMETER
The color of the sub-
stance is measured
by the relative amt.
of light transmitted
to a photoelectric
cell from a constant
light source. The
difference between
this cell and a refer-
ence cell is transmit-
ted electrically.
ElectricX
Signal /
•y
AMPLIFIER
Produces an elec-
tric signal of suf-
ficient magnitude
to operate chart
recorder mechan-
ism.
}
RECORDER
Recorder special-
ly calibrated to
record concentra-
tion values in
ppm.
Contaminated Air,
Reagent specific to\
one contaminant /
•y
Figure I-11. SIMPLIFIED DIAGRAM OF A TYPICAL AUTOMATIC AIR SAMJPLING DEVICE. ^ Under^Regulation VII, ^
Los Angele ' ' • • *- . *-»--
ments at t
ment and „
nificant variations, these instruments are generally designed to accomplish the following processes:
air are drawn through the instrument to a Contact Column which then mixes the contaminated air with an appropriate absorbing agent.
The reaction gives off a color which is measured photometrically in a Colorimeter according to the differences in light absorption from
a common light source, between a sample cell and a reference cell. An electrical signal is then transmitted from the Colorimeter to an
Amplifier and thence to a specifically calibrated Chart Recorder.
TABLE I 16
PRINCIPLES OF AUTOMATIC SAMPLING DEVICES EMPLOYED IN LOS ANGELES COUNTY
CONTAMINANTS
Ozone
Sulfur
Dioxide
Carbon
Monoxide
Oxides of
Nitrogen
Total
Oxidant
Km
ALERT LEVELS
(ppm)
1st .5
2nd 1.0
3rd 1.5
1st 3
2nd 5
3rd 10
1st 100
2nd 200
3rd 300
1st 3
2nd 5
3rd 10
To check ozone
and sampling
data
To measure the
general dirti-
ness of air
SAMPLING DEVICE
(Manual Rubber Cracking)
* * * *
Ozone Photometer
Thomas Autometer
Mine Safety Appliance
Lira-Gas Analyzer
Borman Engr. Inc.
Beckman Oxidant
Recorder
Chaney Auto Sampler
BASIC CHEMICAL PRINCIPLES
(Concentration of ozone is computed at rate at which rubber
cracks) * * * * *
Absorption of ultra-violet light of a certain wave length by
ozone. Ozone-free reference cell, reduced by Mn02 catalyst,
compared with the ozone in the contaminated air in sample cell.
Absorption of SOa by distilled water solution in hydrogen per-
oxide and in sulfuric acid with simultaneous oxidation to sul-
furic acid. Measurement is made of the electrolytic conductiv-
ity of the solution rather than color-change.
Employs principle of non-dispersion, infra-red spectroscopy.
Measures the relative differences in the expansion of a known
concentration of CO alternately from the unabsorbed infra-red
radiation passing through a pure nitrogen cell and a cell con-
taining the air to be sampled.
Both NO and NO* are measured consecutively. NOj is meas-
ured by change of color resulting from the reaction between
NO3 and the absorption solution (Saltzman Reagent). The
sample is then passed through a potassium permanganate solu-
tion to oxidize the NO to NO«, and then treated again with
Saltzman. The product of the reaction in each instance passes
through a photoelectric cell — one for NO and the other for
N02.
Reaction of oxidants in an air stream with a buffered neutral 20
per cent potassium iodide reagent. Measurement is made of the
iodine release by a recording double beam colorimeter.
Blackness of filler spot is measured by means of light reflectance
or transmittance.
While the first alert is primarily a warning alert,
the second and definitely the third alert may call for
emergency action as outlined in the Regulation (see
Chapter 3). The alert stages also provide a reference
for comparing the relative intensities of the pollution
levels. In addition to meeting Regulation VII require-
ments, the Air Pollution Control District also monitors
or samples nitric oxide, total oxidants, ether-soluble
aerosols and particulate matter to provide more com-
plete data on contaminant levels.
2. Monitoring Key Effects
Plant toxicants (phytotoxicants) are measured by
estimation of total leaf damage resulting from daily
exposure of smog to fresh, carefully grown plants in
test boxes. For such measurements, poa annua and
petunia are used. Eye-irritation is measured in terms
of a questionnaire graded on an hourly basis and is
compared to monitored concentrations and weather
conditions.
-------
The Nature and Extent of Air Pollution
35
Figure 1-12. Automatic sampling device for atmospheric par-
ticulates.
Figure 1-13. Automatic sampling device for nitric oxide and
nitrogen dioxide.
Figure I 14. Luft Principle gas analyzer for carbon monoxide
with automatic recorder.
Figure 1-15. Automatic sampling device for both oxidant and
oxidant precursor.
-------
Air Pollution Control Field Operations
Figure I -16. Thomas autemetef used for measuring sulfur di-
oxide in the atmosphere,-
Figure 1-17. Spectroradiometer receiver unit for long path ozone
recorder. The light source may be seen in the background to the
right of the receiver.
In Los Angeles County, an attempt is being made
to refine and correlate this data so as to identify any
possible correspondence between concentration trends,
weather conditions and eye-irritation and plant dam-
age. Unfortunately, the Los Angeles monitoring net-
work, the first of its kind, began operation in the last
three years and not all of the data is complete enough
to permit consummate analysis,
D. Other Pollution Potentials
We have considered both primary and secondary
pollution potentials as they prevail over the entire pol-
lution zone. To complete an accounting of pollution
potentials, it is necessary to include all of the poten-
tials of individual sources of air pollution as they con-
tribute to unique problems or nuisances. The import-
ance of these problems is not assessed in terms of
their quantitative contribution to the entire pollution
potential, but by the effect they have on the inhabit-
ants' of a community neighboring the source in terms
of smoke, odors, soot, dust and corrosive deposits. Both
primary contaminants and reactants may be involved,
particularly where odors and corrosive contaminants
are concerned. The degree of reactivity of such con-
taminants is often quite out of proportion to the quan-
tities emitted.
Pollution potentials of this type are related to the
legal problem of public nuisances resulting from high
Figure I - 18. Poa Annua (annual blue-grass) and Petunia are
placed in fumigation and filtered air chambers to assess the dam-
age to these plants from exposures to smog.
-------
The Nature and Extent of Air Pollution
37
population densities and the crowding of commercial,
residential and industrial areas. Industries which emit
nuisance contaminants like odors (such as the animal
rendering industries and other "obnoxious" trades),
toxic materials or corrosive acids (such as refineries
and chemical plants), dusts (such as cement manufac-
turers and mineral processors) and fumes and smoke
(such as foundries and steel mills) must be given spe-
cial attention even though they may not contribute
significantly to the total air pollution potential.
E. Pollution Potentials Determine Control and
Enforcement Objectives
As we have seen, the causes of air pollution are
divided between those which are natural in origin.
such as climate, topography and weather, and those
which are man-made, such as the growth of the metro-
politan economy and its pollution potentials. Since the
weather cannot be controlled, the control of air pollu
tion must be accomplished by reducing the primary
and secondary pollution potentials, either by applying
control techniques and devices to reduce emission
rates, by abolishing sources of air pollution, or by dis-
tributing the sources of air pollution through zoning
ordinances to dilute contaminant plumes. The mini-
mum and maximum primary potentials significant to
the saturation of the local air space thus establish real-
istic objectives for control. Control activities then fall
into two complementary phases: research and control
operations.
1. Research
The research activity is concerned with ascertain-
ing pollution potentials and levels and their effects on
the environment, as well as the devices and techniques
which will accomplish control. Research findings in
form legislative bodies of the standards required for
control regulation. The control agency then attempts
to realize minimum primary potentials.
2. Control Operations
The control operations are primarily concerned
with the enforcement of legal standards to achieve the
maximum practicable reduction of the pollution polen
tials. At the same time, the control agency must moni-
tor the atmosphere and forecast pollution condition s in
order that action can be taken to avoid disasters.
Field operations is essentially a law-enforcing
function involving the inspection and registration of
the sources of air pollution, continuous surveillance of
the pollution zone, investigation of specific, air pollu-
tion problems, promotion of zone-wide compliance, and
prosecution of air pollution violators, continuously and
simultaneously in all parts of the pollution zone.
The attainment of the minimum pollution poten-
tial is thus a basic operational function of the enforce-
ment program.
REFERENCES
1. Alexandersson, Gunnar, The Industrial Structure of American
Cities, University of Nebraska Press, Lincoln, Nebraska, p. 13,
1956.
2. Bobrov, Ruth Ann, The Effect of Smog on the Anatomy of Oat
Leaves, Phytopathology, Volume 42, No. 10, pp. 558-563, Oc-
tober, 1952.
3. California State Department of Health, Standards for Ambient
Air Quality and Motor Vehicle Exhaust, December 4, 1959.
4. Chambers, Leslie A., Automotive Vehicles as Air Pollution
Sources, Nat. Conf. on Air Pollution, Washington, D.C., No-
vember, 1958.
5. Chambers, Leslie A., Where Does Pollution Come From?, Pub-
lic Health Service, Proc. National Conference on Air Pollution,
U. S. Govt. Printing Office, pp. 34-38, 1958.
6. Chass, Robert L., George, Ralph E., Contaminant Emissions from
the Combustion of Fuels, 52nd Annual Meeting of the Air
Pollution Control Association, June 1959.
1'. Chass, Robert L., Lunche, Robert C, Shaffer, Norman R., Tow,
Philip S., Total Air Pollution Emissions in Los Angeles County,
52nd Annual Meeting of the Air Pollution Control Association,
Los Angeles, Calif., June 1959.
8. Dickinson, Janet E., Organic Emissions in Smog Formation, 52nd
Annual Meeting, Air Pollution Control Association, Los Angeles,
June 1959.
9. Gibson, W. B., The Economics of Air Pollution, Proc. 1st Nat.
Air Pollution Symposium, p. 109, Pasadena, California, 1949.
10. Haagen-Smit, A. J., Chemistry and Physiology of Los Angeles
Smog, Industrial and Engineering Chemistry, Volume 44, p.
1342, 1952.
11. Haagen-Smit, A. J., Bradley, C. E., and Fox, M. M., Ozone
Formation in Photochemical Oxidation of Organic Substances,
Ind. Eng. Chemistry 45, pp. 2086-9, 1953.
12. Hamming, W. J., MacPhee, R. D., Taylor J. R., Contaminant
Concentration in the Atmosphere of Los Angeles County, 52nd
Ann. Meet, of the Air Poll. Control Assoc., Los Angeles, "'
pp., June 1959.
13. Holmes, R. G., Kauper, E. K., Street, A. B., Taylor, J. R., Air
flow Studies of Heavy Smog in Los Angeles, 49th Annual
Meeting of the Air Pollution Control Association, Buffalo, New
York, May 1956.
14. Johnston, H. S., Photochemical Oxidation of Hydrocarbon', Ind.
Eng. Chem. 48, pp. 1488-91, 1956.
15. Kauper, Erwin K., Holmes, Raymond G. and Street, Arthur B.,
Visibility Studies, Report No. 12, Los Angeles County Air Pol-
lution Control District.
16. Kauper, Erwin K., The Zone of Discontinuity Between the Land
and Sea Breeze and Its Importance to Southern California Pol-
lution Studies, The American Meteorological Society, San Diego,
California, June 16, 1959.
17. Los Angeles County Air Pollution Control District, Second
Technical and Administrative Report on Air Pollution Control,
p. 27, 1950-51.
18. Middleton, J. T., Paulus, A. O., The Identification and Distri-
bution of Air Pollutants Through Plant Response, A.M.A. Ar-
chives of Industrial Health, 14: 526-532, 1956.
19. Noble, W. M., Smog Damage to Plants, Los Angeles County
Air Pollution Control District, Research Division Report, April,
1959.
20. Neiburger, M., Meteorological Aspects of Oxidation Type Air
Pollution, The Rossby Memorial Volume, The Rockefeller In-
stitute Press, New York, pp. 158-169, 1959.
21. Neiburger, M., Tracer Tests of Trajectories Computed from
Observed Wnids, Air Pollution Foundation Report No. 7., Los
Angeles, California, 1955.
22. Neiburger, M., Renzetti, N. A., and Tice, R., Wind Trajectory
Studies of the Movement of Polluted Air in the Los Angeles
Basin, Air Pollution Foundation Report No. 13, 1956.
23. Sutton, O. G., Atmospheric Turbulence, John Wiley and Sons,
New York, 1955.
24. Sutton, O. G., Micrometcorology, McGraw-Hill Book Company,
New York, 1953.
25. Thomas, M. D., Gas Damage to Plains, Annual Review of
Plant Physiology 2: 293-332, 1951.
26. U. S. Bureau of the Budget, Standard Industrial Classification
Manual, U. S. Government Printing Office, Washington 25, D.
C., 1957 with 1958 supplement.
27. Whyte, Jr. and other editors of Fortune Magazine, The Explod-
ing Metropolis, Doubleday and Company, Inc., Garden City,
New York, 1958.
28. Dickinson, J. E., "Air Quality of Los Angeles County,' Tech-
nical Progress Report, Volume II, Los Angeles County Air Pol-
lution Control District, p. 2, pp. 224-257, February 1961.
-------
CHAPTER TWO
THE TECHNOLOGY OF SOURCE CONTROL
I CONTROL TECHNIQUES
Just as the metropolitan area possesses a potential
to pollute the air, so does it possess a definite potential
to prevent that air pollution. The control of air pollu-
tion is preventive in nature since the atmosphere can't
be cleaned artificially once it has become polluted.
Cleaning the atmosphere by such methods as "inver-
sion breaking," "air blowers," "air filtering," or "rain-
making" is tantamount to revolutionary weather mod-
ification, not feasible at the present time.
The capacity of a community to prevent air pol-
lution is limited to reducing pollution potentials
through one of more of the following methods:
A. Eliminating the sources of air pollution.
B. Controlling source area pollution through
zoning.
C. Controlling or changing the sources of air
pollution.
A. Eliminating the Sources of Air Pollution
The elimination of the sources of air pollution is
motivated by the assumption that nothing short of ab-
solute control can be tolerated. Advocates of this ap-
proach claim that reduction of air pollution at the
source is only a relative matter; real control is not
achieved unless the actual source is entirely prohibited
or eliminated. This concept would, in the extreme,
assign to the state powers which could be used to con-
fiscate the sources of pollution or to prohibit their xise.
Although this approach represents an extreme,
especially when applied to all of the sources of nir pol-
lution simultaneously, there are instances in which it
is reasonably applied. These depend on the need for
absolute control of a given source of air pollution, and
constitutional powers and limitations. Sources of air
pollution which are completely unessential to the econ-
omy, such as single-chamber incinerators, open fires,
and dump burning, may be completely banned when
substitute practices become available. Certain types of
fuels — such as soft coal or fuel containing excessive
quantities of sulfur and impurities, may be banned
altogether when cleaner fuels become available. In-
dustries which are anomalous to the character of the
community can be outlawed through zoning ordinance
restrictions or by direct prohibition. The elimination
of a widespread existing practice, however, depends on
the availability of materials or processes which can be
reasonably and economically substituted.
B. Controlling Area Source Pollution Through Zoning
Control of air pollution is based on treating the
entire pollution zone, or area subdivisions vvithin that
zone, as sources of air pollution which can be regulated
to maximize the prevailing dilution capacity of the
areas. Essentially, this consists of regulating source
density, the space intervals between sources and poten-
tial effect areas, the time periods contaminants are
released, and raw materials and processes employed.
The prime objective of such zoning is to place source
and effect areas in such relationship to one another,
and of such density, as to allow for sufficient dilution
of contaminated air. This may be accomplished by
confining industries with high pollution potentials in
"wind corridors" where, as a result of terrain, stream-
line patterns, and turbulence, etc., contaminants are
readily dispersed. By placing industry in the down-
wind peripheries of the pollution zone, areas of high
population density and chronic atmospheric stagnation
can be avoided.
Another zoning technique is to establish "smoke-
less zones" either through creation of agricultural or
"buffer" zones between industrial and residential a-
reas, or by applying stringent regulation of equipment
and fuels in areas of high source concentration.
"Smokeless zones" were first applied in England in
such industrial towns as Coventry, Manchester, and
Bolton, where they range in area from 30 to more
than 100 acres. In these zones the emissions of the
visible and particulate products of combustion are pro-
hibited, heating equipment is revamped, and bitumin-
ous coal is replaced by electricity, gas, or coke.C7)
The zoning of source areas to minimize the effects
of air pollution, especially in large diversified econo-
mies, is complicated by growth patterns, economic and
legal factors, and by the need for detailed mfoi'mation
necessary to forecast future growth patterns and to
determine the dilution capacities of the respective
source areas. Research is required in the following
areas: (6)
1. The pattern of natural dilution capacity.
2. The determination of community air stand-
ards.
3. Forecasts of locations of future source emis-
sions.
4. The classification of industries by their pollu-
tion potentials.
5. Air monitoring network coverage.
Zoning through legal sanctions is within the con-
cept of the police power of the state, when sufficient
evidence established through objective zoning studies
can be presented. Air pollution zoning can be legally
applied to prohibit new industries, limit expansion of
existing industries, liquidate non-conforming indus-
tries after amortizing their existing investments, or
eliminating existing harmful industries. (6)
Air pollution zoning, however, is somewhat cir-
cumscribed by the number of variables and costs in-
volved. Radical modification of the existing growth
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40
Air Pollution Control Field Operations
pattern through forced relocation of industries is prob-
ably impossible, if not undesirable. Air pollution zon-
ing plans, therefore, must be applied through coordin-
ation of existing metropolitan zoning functions, urban
redevelopment programs, or to normal growth patterns
through continuous surveillance of land use and past
and future emission factors. To some degree, local
zoning ordinances take into account air pollution fac-
tors along with noise, glare, vibration, fire hazards,
water pollution, traffic, aesthetics, and psychological
effects. (14) These ordinances are enforced to segregate
commercial, industrial, and residential activities, al-
though not always in a manner that would prevent air
pollution problems. Planning agencies should thus be
supplied with sufficient information on specific air pol-
lution problems as will provide a sound basis for ren-
dering expert zoning decisions. As new industries are
established, and older industries change ownership or
seek to relocate themselves voluntarily, they become
subject to new zoning laws. Similarly, residential com-
munities can be prevented from entering industrial
areas.
C. Controlling the Sources of Air Pollution
Most air pollution control activity to date has
been directed at effecting changes in equipment or op-
erations to prevent the emission of air contaminants.
These are control techniques and devices applied at
any appropriate point in the process or operation cy-
cle of equipment — from the charge of the feed (fuel,
material, and air) to the equipment, the flow of such
materials through the equipment, to the discharge of
contaminated air and other waste products accumulat-
ing at the completion of the operation cycle. Control
may be effected through any one or combination of the
following methods:
(1) instituting operational and maintenance tech-
niques to rigidly control the handling of fuels,
materials, and equipment so as to minimize con-
taminant losses;
(2) incorporating design features in equipment to
efficiently utilize all materials and fuels to prevent
contaminant losses;
(3) replacing or altering the composition of fuels or
materials, so as to reduce or eliminate those vol-
atile or impure elements which cannot be utilized
or collected by the equipment; or
(4) installing control or collection devices which will
either eliminate the contaminant through com-
bustion, chemical reaction, or collect the contami-
nant by entrapment.
A well developed control technology now exists
which makes available a variety of techniques and
devices to virtually the whole range of industrial
practices in the metropolitan economy. A considerable
economic choice in the selection of suitable control
methods is available to plant operators. In each in-
stance, the operator can select that control technique
which will attain the required collection or control
efficiencies, and minimize cost from the standpoint of
the initial investment and long term maintenance and
operation.
While most air pollution problems can be con-
trolled through available techniques, many air pollu-
tion problems require engineering development for
their solution. These include problems arising from
the collection or control of dilute concentrations of
contaminant gases, such as the organic vapors, particles
which are much smaller than 1 micron, certain con-
taminant gases such as oxides of nitrogen, oxides of
sulfur, carbon monoxide, and various unique opera-
tional problems encountered at power plants, steel
manufacturing, animal rendering industries, and sol-
vent handling. Furthermore, as populations continue
to grow, refinements of existing control techniques are
required.
1. Operational and Maintenance Techniques
Control through operation and maintenance con-
cerns the skill and care taken to operate equipment and
maintain equipment in good working order, and in the
handling of fuels and materials fed to the equipment.
These practices are frequently mandatory not only to
efficiently fulfill the function of the operation, but to
prevent air pollution. For most air contaminating
equipment, optimum operational efficiency means
maximum control of air pollution, whereas air pollu-
tion usually results whenever production practices ex-
ceed design standards of equipment. Combustion
equipment, for example, can only be efficiently oper-
ated within design-specified air-fuel ratios, fuels, igni-
tion and combustion temperatures, and at rated capaci-
ties. Similarly, in metal melting, good operational
technique means controlling temperatures to prevent
excessive volatilization and fuming. Operational tech-
niques employed to purify metals (degassing and slag-
ging, use of ingot rather than scrap, etc.) also contrib-
ute to product excellence, as well as to the reduction
of air pollution.
This manual, of course, cannot attempt to even
sample the operating practices applied at all of the
sources of air pollution. These are as numerous and
diverse as the technology itself, and will engage the
complete technical skill of the control operation. We
shall deal with these as they become involved in spe-
cific air pollution problems later in this manual. It is
sufficient here to point out various functional difficult-
ies which contribute to poor operating efficiency, as-
suming that equipment possesses an inherent capabil-
ity for control. These are:
a. Sacrifice of Operational Efficiency for Volume
Production. Disproportionate increases in con-
taminant emissions frequently result from over-
loading equipment to meet production demands
beyond the capability of equipment.
-------
The Technology of Source Control
41
b. Use of Unusual Fuels or Process Materials. Fuels
and materials with unusually high amounts of
impurities or volatile elements not specified for
use in the equipment, or feeds which are inade-
quately prepared or conditioned before introduc-
tion to the process, may emit contaminants in
excess of those correctly used.
c. Inexpert or Insufficient Supervision of Equipment.
Poor operational technique may result from a lack
of knowledgge, skill, or training. Batch processes
(starting and stopping), in particular, are usually
more difficult to control. Most contaminants in
batch processes are emitted at the beginning and
the completion of the cycle where peak operation
efficiency either is not yet attained or drops off.
Continuous processes, while less variable, must be
checked for proper functioning.
Ignorance or negligence on the part of operators
often results when management itself is disinter-
ested in the pollution potentials of the plant, par-
ticularly where the loss of air contaminants is not
critical to the economics of the plant. Insufficient
supervision, also, as a result of personnel short-
ages, affects the operational efficiency of the plant.
d. Inadequate Maintenance. Lack of care in main-
taining equipment in peak operating condition
may cause equipment malfunctioning and failure,
thereby creating air pollution. Equipment should
be checked, repaired, and maintained so as to
permit operation within design standards. Par-
ticular attention should be paid to hood and duct
fittings, leaks or corrosion in ductwork, impaired
passages in combustion equipment, faulty regula-
tion of automatic feeding equipment, damaged or
encrusted burner tips, grates, etc.
e. Time and Temperature. When time and temper-
ature variables are subject to manual control,
they are frequently very critical in the gen-
eration of air contaminants. This is particularly
true of such equipment as boilers, furnaces, and
metal melting where smoke and fumes readily
result from irregularities in temperature and time
interval of the heat or melting cycle.
The operation of equipment is frequently aided
by instruments which monitor air pollution along with
operational efficiency and product quality. Draft and
flow pressure gauges, photoelectric smoke detection
equipment, stack analysis, recorders, mirrors in stacks,
explosimeters, pyrometers, and thermometers, etc., are
invaluable aids to trained operators.
Suitable operational and maintenance practices
are of importance regardless of whether or not the
equipment incorporates control design characteristics
or control devices are used, since neglect of these fac-
tors directly affects the pollution potential of the
source. If control equipment breaks down or collection
efficiency reduces as a result of poor maintenance, the
source may emit pollutants at or near its maximum
potential.
Operational and maintenance practices are of ut-
most importance when they are employed as the sole
control technique. In many instances, basic equipment
is designed with a capability of complete control which
can be realized only by the skill of a trained operator.
In other cases, the poor control features of old, ineffi-
cient equipment can be successfully compensated for
by alert operational and maintenance practices.
Because of the variability of the human factor,
general control efficiency is not attained by reliance on
operation and maintenance only. Far greater reliance
must be placed on design standards and equipment of
high collection or control efficiency which possess a
capacity to operate in an automatic, trouble-free man-
ner and with minimum maintenance. It is thus desir-
able to reduce, though it can never be fully eliminated,
the variability of the operational and maintenance
factor.
2. Control Through Design of Basic Equipment
By far the most important technique of control-
ling air pollution is in the design of basic production
equipment to efficiently utilize or completely consume
materials. Generally speaking, the greater the design
efficiency, the less air pollution. Because economy,
good design, and minimum material losses go together,
a greater control effort is made in ever improving the
design of production equipment.
Considerable progress has been made, particular-
ly in such categories of combustion equipment as
boilers, furnaces, heaters, ovens, and incinerators.
Design improvements have not only made possible
the smokeless combustion of fuels, but increases in
the output of thermal energy and the conservation of
fuels. Essentially, this equipment is designed to
provide sufficient temperature to permit complete com-
bustion throughout ignition, burning, and burn-down,
sufficient mixing or turbulence of air with combustion
materials and fuels, and sufficient time interval to
allow complete combustion, hence complete disposal
of all of the components of the fuel or materials,
including dilute volatilized gases and fly ash. Strict
attention is paid to the dimensions and design of com-
bustion chambers, burners, grates, and control of air
supply (Figure II 1). Burner designs for oil burning
boilers and power plants are designed to preheat liquid
fuels to reduce viscosity of the fuel, and to atomize the
fuel with air or steam so as to efficiently provide proper
air-fuel mixtures. Cross-fed, chain-grate stokers have
been developed for burning volatile solid fuels such as
bituminous coal. "Smoke eliminator" doors, and other
accessories have been designed to provide sufficient
secondary air to eliminate smoke during the ignition of
coal. Multiple-chamber incinerators, consisting of two
or more combustion chambers, have been developed
for the smokeless combustion of a wide range of indus-
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42
Air Pollution Control Field Operations
THE EFFICIENT MULTIPLE CHAMBER INCINERATOR ..
L'j*d principally by builneu and industry and deiigned
to control imote and fly aih . When engineered and
operated wirhin the ttondardi *et by the Rule* and
Regulation) of tfio Air Pollution Control Diitrict, the
multiple cKamben of the incinerator provide iuFftc-
isnl rime, remperotur« and turbulence for complete
can-.bullion of smoke, parKculDte matter and volntil-
Figure II - 1. Combustion sequence through an in-line multiple
chamber incinerator.
trial, commercial, and domestic types of rubbish. Fur-
thermore, automatic and continuous feeding equip-
ment is designed so as to accommodate proper air-
fuel ratios for variable load conditions, thus reducing
the effects of human error resulting from manual oper-
ation and maintenance.
In the metallurgical field, furnaces have been
designed to operate without control equipment under
many operating conditions. When ingot or pig iron is
melted in the electric steel furnace, or refined metal is
melted in most crucible or other metallurgical furnac-
es, a relatively fume-free operation results. A rever-
beratory type of furnace has been designed for non-
ferrous metals which attains a luminous heat from the
reflection of light from the arches in the roof and side-
walls of the furnace. Since melting temperatures are
reached quickly in this type of furnace, it can be used
to melt various alloys with relatively less fuming than
most conventional furnaces.
Design improvement may not only be applied to
individual pieces of equipment, but to the entire pro-
cess flow of an industrial plant to minimize pollution
potentials from equipment, material handling, and
plant housekeeping activities. The flow of materials
may involve mechanical and thermal processes, such
as batching, blending, grading, roasting, drying (con-
nected by sealed conveyor systems), or chemical
processes, particularly in chemical and petrochemical
plants and petroleum refineries, where product mole-
Figure II - 2. Electric-steel furnace.
Figure II - 3. Reverberatory gray-iron furnace.
cules are separated, converted, or otherwise altered by
means of chemical, catalytic, or thermal processes. An
entire process, or even a plant, may be considered for
design purposes in the control of air pollution by pro-
viding for recovery and scavenging systems, sealed
pumps, glands and valves, hoods, ducts, and pumps
and other equipment which conserve products, mini-
mize the human factor, and reduce air pollution po-
tentials.
The effective design of basic production equip-
ment and processes, it should be cautioned, may not
succeed in controlling all types of air contaminants
generated. Smokeless combustion equipment, for ex-
ample, while reducing smoke, may still emit such con-
taminants as organic vapors, oxides of nitrogen, sulfur
dioxide, and carbon monoxide. The accumulated emis-
sions from a metal plant operating many efficient fur-
-------
The Technology of Source Control
naces, or from the entire industry itself, may contrib-
ute significant amounts of air pollution. Continued im-
provements in the design to equipment, however,
should increasingly result in compliance with com-
munity air standards.
3. Replacing or Altering Composition of Fuels or
Materials
From the discussion in Chapter One, we have seen
how the nature of the fuel economy of the metropol-
itan area becomes, perhaps, one of the most important
causative factors in air pollution. Since the fuel econ-
omy is dependent on the fuels available, the choice of
the relative smokeless fuels is limited in each fuel re-
gion. In the manufacturing belt of the United States,
the choice of fuels is made among coals ranging from
peat, lignite, and high volatile bituminous coals,
through the lower volatile anthracite coal, or among
the various processed coal fuels such as coke (volatiles
removed), or pulverized coal (which can be atomized
in burners like fuel oil). In the petroleum economy.
fuels may range from heavy residual fuel oils with
high sulfur content, to fuel oils and distillates with low
sulfur content, or natural or liquified petroleum gases
which are practically pollution free.
To meet control standards, combustion equipment
employed is designed to compensate for the type of
fuel used. Fuels with high amounts of impurities, in-
cluding moisture, sulfur, and volatile matter, require
equipment of more elaborate design in addition to
careful operation and maintenance. Relatively smoke-
less fuels, such as coke, low sulfur fuel oil, and natural
gas, on the other hand, only require combustion equip-
ment relatively simple in design, and less operational
and maintenance control.
The handling of the many types of process ma-
terials in industry follows a similar pattern. Materials
with high vapor pressures, impurities, and wide ranges
in boiling points, variations in particle size, toxic or
corrosive components, etc., may be either rjepla|c|e|d
by other materials which do not have such properties.
when they are available and practical for use, or they
may be controlled by any of the other control tech-
niques described here.
4. Control Devices
Whenever both design and operational efficiency
are inadequate to control air pollution, specially de-
signed control equipment becomes necessary. Control
devices are equipment whose prime function is to con-
trol or collect contaminants, and which generally con-
tribute nothing toward the economic objectives of pro-
duction equipment. Thus operations in which air pol-
lution is inevitable, such as melting of metal alloys
with wide differences in volatility, the melting of im-
pure or low grade metals, the melting of ores, and
scrap materials, the handling of milling dusts, evapora-
tion from large quantities of volatile materials, etc.,
require specially designed control devices.
Control devices are designed to prevent air pollut-
ants produced from basic equipment from entering the
air either by separating the contaminant from the air
stream in which it is being conveyed and collecting it
for disposal, or by destroying the contaminant by com-
bustion at elevated temperatures and maximum com-
bustion efficiency. These are usually installed in the
stack or ductwork of equipment. In some cases the
effluent is transmitted from production equipment to
the control device by blower exhaust systems.Another
cases, particularly gases, the effluent is motivated by
draft pressures and diffusion. Control devices general-
ly follow the basic equipment, and a single device can
be applied to several or even a large number of equip-
ment units | by means of hoods and ductwork.
The classes of control equipment are divided be-
tween those which collect particulates and aerosols
(solid and liquid forms) and those which collect or
control gases.* Equipment used for the collection of
aerosols and particulates is based on one or more of
the following entrapment principles:
1. Inertial entrapment by altering the direction
and velocity of the effluent.
2. Increasing the size of the particles through
conglomeration or liquid mist entrainment so
as to subject the particles to inertial and gravi-
tational forces within the operational range of
the control device.
3. Impingement of particles on impact surfaces,
baffles, or filters.
4. Precipitation of contaminants in electric fields
or by thermal convection.
The design of the device depends on the prin-
ciple utilized and the following:
1. Size, weight, and shape of the particulate.
2. The inertial, settling, and filtration proper-
ties of the particles.
3. The grain loading and velocity of the effluent
affecting the stream capacity of the device.
4. The temperature of the gas stream.
5. The physical form of the particulate (solid or
liquid).
Generally speaking, the larger and more uniform
the particle sizes, the cooler the exhaust gas, and the
higher the grain loading or contaminant density, the
simpler the control device. Effluent velocity is an addi-
tional factor, but optimum velocities vary according
to the design and purpose of the device. The cut-off
point between simple devices and more elaborate
equipment, all other factors being equal, appears to be
around 10 microns for particle size.
* Control devices, as well as other control techniques discussed
in this chapter, represent engineering practices beyond the
scope of this manual. For further information, consult refer-
ences 4, 5, and 11.
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44
Air Pollution Control Field Operations
COLLECTOH —
DTJSTjoUT
Figure II - 4. Flow of dust
through cyclone.
Figure II - 5. Diagram of
cyclone separator.
With the exception of the combustion of volatil-
ized gases, the collection of gases and vapors must
usually be accomplished through a method which is
specific to the physical and chemical properties of
the individual gases. Gases may be absorbed into
reactive solutions, collected by adsorption to an active
surface area of a solid (such as activated carbon),
condensed through temperature and pressure changes,
reduced to carbon dioxide and water through high
temperature controlled combustion, catalyzed to harm-
less substances, converted by chemical reaction to
by-products, or conserved and re-used by means of
vapor collection equipment.
a. Collectors and Separators
By utilizing the inertial properties of moving
particles, a variety of collectors and air separators have
been developed to remove dust particles from effluents
and to collect them for disposal by other means. Col-
lectors and separators are used widely to control dusts
and fines from such mechanical operations as crush-
ing, mixing, pulverizing, grading, blending, sanding,
woodworking, milling, and in the handling of grain,
feed, flour, sand and minerals.
The simplest of these devices is a settling chamber
which sets lengthwise in the exhaust ductwork. As the
dust-laden air enters the box, its velocity is suddenly
reduced due to a drop in pressure, thereby causing
contaminants to precipitate inertially. Although the
collection capacity of settling chambers can be large,
they are limited to the collection of dusts not smaller
than 40 microns in diameter, and moving gas streams
generally slower than ten feet per second. Some special
settling chambers, utilizing shelves, have been built
capable of collecting particles as small as 10 microns.
Centrifugal or inertial separators, frequently
called cyclones because of the whirling, spiraling mo-
tion the air takes through the device, are quite suitable
in collecting particles not smaller than 5 or 10 microns,
although some efficient collectors have been developed
which handle dusts as small as 2 microns in diameter.
These devices are quite versatile and are easily con-
structed for a large variety of industrial situations.
The cyclone (Figures II-4 and II-5) is a closed
device consisting of a cylinder on top of an inverted
cone. Dust-laden air enters the top of the cylinder
through a tangential duct. The velocity of the air, as
governed by a blower motor in the ductwork, is suffi-
cient to accomplish -a spiraling downward movement,
causing the particles to be separated from the air
stream by centrifugal deflection. The particles slide
down the walls of the cyclone into a hopper, while the
cleaned gases escape through a tube at the top of the
cylinder. Cyclones can handle large capacities of par-
ticles varying in size from 5 to 200 microns, at high
velocities (generally from 30 to 25,000 cubic feet per
minute). In fact, the greater the velocity of the dust-
laden gas, the greater the centrifugal force applied to
the particles, and the more efficient the collector.. The
smaller the diameter of the cyclone, the more efficient-
ly particles are collected, although the steam capacity
is reduced. Combinations of cyclones or multi-clones
(see Figure II-6) can be used by first removing the
Figure II - 6. High-efficiency cyclone collecting system used to
control dusts from flour mills. The large high-capacity cyclone is
followed by eight low-capacity but highly efficient cyclone col-
lectors.
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The Technology of Source Control
TUBES(BAGS)
SHAKER DEVICE
OUTLET PIPE-
OUTLET
EXPANSION"
CHAMBER
INLET PIPE
BAFFLE
INLET
EXPANSION
CHAMBER
HOPPER
<• s-HOPPER VALVE
Figure II - 7. Simplified diagram of a baghouse.
bulk of the larger particles in the large cyclones, and
then collecting the smaller fines with the smaller cy-
clones. Cyclones, and even settling chambers can be
used as primary collectors to be followed by more
efficient devices, where particles in the effluent are
extremely small.
Separation of liquid or solid particles from effluent
air is also facilitated by building up particle size by
means of a sonic collector to increase the effectiveness
of inertial, centrifugal and gravitational collection
devices(i3). In the sonic collector, high frequency
sound waves emitted from an acoustical horn create
pressure oscillations on the dust-laden stream. The
particles vigorously vibrate and hence collide arid
agglomerate. The heavier particles which result can
then be collected through other means. Some col-
lectors are effective for particles smaller than ten
microns.
b. Filters
Filters (fibrous, cloth or viscous) are porous sur-
faces which entrap contaminants while permitting air
to pass through them. The filter media may consist
of cloth, orlon, dacron, silicon-treated glass fiber or any
other suitable media. The filter media selected de-
pend on the temperature of the exhaust gas, the dura-
bility desired, grain loading and capacity, and particle
size. The critical factor is temperature, since high tem-
perature gases are usually involved, particularly in
metallurgical fume and smoke collection. Filter media
Figure II - 8. Baghouse, non-ferrous foundry.
made of cotton or wool cannot withstand temperatures
greater than 28CTF., whereas those made of silicon -
treated-glass fibers can withstand temperatures in the
neighborhood of 500°F. Hot gases, however, also must
be cooled to the maximum operating temperatures of
the filter media by quench tanks or cooling towers.
Filters with industrial applications generally take
two forms: the baghouse, which is effectively used in
many heavy metallurgical operations; and the screen
collector. A typical baghouse is a box-like structure
(Figure II-7) consisting of rows of tubular bags from
5 to 18 inches in diameter and from 2 to 30 feet in
length, secured by their open ends to an inlet manifold
or expansion chamber located either at the bottom or
the top of the housing. The contaminant-laden air is
conveyed by hoods and blower exhaust systems from
the source of pollution, first to a cooling system, and
then to a baffle plate in the expansion chamber, which
deflects and precipitates most of the larger particles.
The air is then forced through the bags and the parti-
cles are deposited on the inner surfaces. The accumu-
lation of the collected contaminants forms a matrix
which continues to increase the filtering efficiency of
the device until the air can no longer pass through the
pores of the material. The bags are periodically
shaken or "flexed" either automatically or manually
to dislodge the contaminants. The particles then drop
through the inlet manifold into a receiving hopper.
Baghouses of this type are extremely effective for most
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46
Air Pollution Control Field Operations
ELECTRODES
CATALYST
COLLECTION
PLATES
RECLAIMED CATALYST
(SHAKEN FROM PLATES)
Figure II - 9. Diagram of plate-type electrostatic precipitator
used to collect catalyst dust.
heavy metallurgical operations, since they are capable
of collecting fine metallurgical fume below 10 microns
in diameter and at efficiencies exceeding 95%. In
large volume steel operations involving open hearth
furnaces, Bessemer processes, etc., however, difficulties
are frequently encountered due to the high tempera-
tures and gas volumes encountered.
Cloth-screen collectors are generally used to con-
trol dusts in smaller, intermediate industrial opera-
tions, such as tumbling, grinding, or abrasive cleaning.
The collector generally comprises a series of cloth-
covered frames set into a steel chamber. The device
forces dust-laden air through the screens, which are
replaced after use. Other filter media consist of packed
fibres, filter beds, granules and oil-baths.
c. Electrical Precipitators
Although they are quite costly, electrical pre-
cipitators (Figure II-9) are perhaps one of the more
effective control devices. They possess high collection
efficiencies over a wide particle size range, low power
requirements for moving large volumes of gases be-
cause of low resistance to flow, and they can be applied
in industries with high air pollution potentials such
as the metallurgical, refining and heavy chemical in-
dustries to collect metallic oxide fumes, catalyst dusts
and asphalt and acid mists.
The electrical precipitator employs the principle
of attraction of opposite charges. The particles in the
Figure II - 10. Heavy duty, single-stage electrical precipitator
used to collect fumes from high capacity electric-steel furnaces.
contaminated exhaust stream are charged in a high
voltage electric field and are then attracted to a plate
of the opposite charge where they are collected. When
the plate is shaken or rapped the pollutants drop into
a hopper.
Electrical precipitators are capable of handling
gases which are hot or cold, wet or dry and at gas tem-
peratures as high as 1100° F., although temperatures
usually range around 600° F. and lower. They oper-
ate best for the collection of particles less than .5
micron and for this reason precleaners such as cy-
clones and settling chambers are used to remove the
larger particles and reduce dust loading.
Electrical precipitators are either of the single or
dual-stage types. In the single stage, discharge elec-
trodes are usually wires of negative polarity, and the
collecting electrodes are either plates or pipes in which
the discharge electrodes are hung. In the single stage
types the collection is accomplished in a single electric
field. These are used extensively for large industrial
operations. In the dual-stage types, the contaminant
particles are subjected first to an ionizing field, and
then to a separate collecting field. These are used pri-
marily in the air conditioning field.
Both types of precipitator run on rectified AC
current, the single stage units at voltages of 25,000
and over (sometimes as high as 100,000 volts) and
the two-stage units at about 12,000 volts in the ion-
izing section and 6,000 in the collection section.
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CLEAN AIR OUTLET
The Technology of Source Control
47
Figure 11-11. Centrifugal-wash collector.
CLEAN
GAS —
.LIQUID IN
DIRTY
G>AS
X^E
/ GAS
i-f
CYCLONE
SEPARATOR
LIQUID
Figure 11-12. Venturi scrubber.
STACK TO ATMOSPHERE
STEEL PLATE
INSULATING FIBEBBICK
REFRACTORY TYPE BAFFLE
BAFFLE SUPPORTS
GAS BURNER
PREMIXED GAS AND
AIR MIXTURE
Figure 11-13. Typical direct-fired afterburner.
Figure II - 14. Tangentially-fired afterburner showning burner
arrangement used in controlling air contaminants from varnish
cookers.
SEALING RING.
COUNTERWEIGHT
SEALING DEVICE
BOTTOM OF TANK
Figure 11-15. Diagram of a floating-roof mechanism.
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48
Air Pollution Control Field Operations
d. Wet Collectors
These are various forms of washers, collectors,
wet filters, centrifugal and venturi scrubbers (Figures
11-11, 11-12) which both clean and cool particle-laden
gas streams by use of a high pressure liquid spray.
This is accomplished in the various devices by atomiz-
ing the particle-laden gas stream at high velocities
with droplets of water, thereby precipitating the con-
taminants. Most frequently water is used as the wet-
ting agent; occasionally caustics are added for acid
mist collection. Wet collectors are generally used to
control particles forming as dusts, mists and fogs.
According to the device, the collection range and
efficiency are generally much greater than the cyclone,
but considerably less than cloth filters or electrical
precipitators. Efficiency will sometimes reach 99%,
while the particle sizes collected may range, according
to the device, from 40 microns to slightly less than 1
micron.
e. Afterburners
The afterburner (Figure 11-13) has been applied
in a wide variety of industrial situations to eliminate
air contaminants and, consequently, varies consider-
ably in design. Afterburners are capable of burning
effluent gases creating malodors, and containing car-
bonaceous materials, fumes, organic vapors, particulate
matter, smoke, hydrogen sulfide, carbon monoxide, or
other contaminants. Their most significant use in Los
Angeles County is in the abatement of malodors from
refineries, rendering, paint and varnish, sulfur recov-
ery, coffee roasting and fish processing plants. After-
burners are also employed to complete the combustion
of smoke and particulate matter from incinerators in
apartment houses and smokehouses in meat packing
plants.
Afterburners operate at temperatures sufficient to
ignite the contaminants. Temperatures may range
from 900°F. to 1600°F, according to the material being
burned, but usually at approximately 1200° F. The
contaminated gases are mixed vigorously with a lumi-
nous swirling flame and are completely burned. Baf-
fles in afterburners are used to produce turbulence and
to slow the gases in the chamber to permit enough
time for completion of combustion.
Some catalytic types of afterburners are also in
use, especially on coater or lithographic ovens. In
these afterburners, the contaminated gases are drawn
by a blower through a preheat burner into a catalyst
chamber containing a platinum coated ceramic tear-
drop. Here the temperature is catalytically raised and
the gases are burned. Some of the cleaned gases are
vented to the oven for heating, while the remainder
of the gases is vented to the atmosphere.
f. Vapor Conservation Equipment
Conservation equipment is designed to capture
vapors escaping from the storage and handling of gaso-
line or other volatile products. Vapors are created in
the storage tanks of refineries and other processes due
to increases in atmospheric temperature or from im-
balances in refinery processes. Conservation is ac-
complished either by sealed floating roofs on storage
tanks and oil-water separators, or by vapor recovery
equipment. The floating roof rests on the surface of
the liquid product and rises and lowers with the
fluid level in the tank (Figure 11-15). Floating roofs
thus prevent tank breathing losses and the product is
conserved directly in the tank. The floating roof is also
applied to oil-water separator compartments to prevent
breathing losses resulting from volatile materials in
refinery waste streams.
In the vapor recovery system, the vapors are
drawn from the fixed roof tanks to a vaporsphere (Fig-
ure 11-18). A flexible diaphragm inside of the vapor-
sphere expands when the vapor pressure in the tank
increases, and contracts when it decreases, very much
like a lung. When the diaphragm expands to a pre-
determined height, a starter mechanism is actuated,
and a compressor begins operation. The condensable
vapors are then cpmpressed into a liquid and the non-
condensable gases are conveyed to fuel gas systems
where they are used to fire boilers or they are incin-
erated in a flare. When the storage tanks are cooled
by the atmosphere or the vapors generated from the
process units decrease, the diaphragm drops to a point
where the compressor automatically shuts off. Below
this point, a vapor balance is maintained between the
sphere and the tanks.
g. Gas and Vapor Collection Techniques
In addition to those gases and vapors which may
be incinerated, or those which have a recovery value,
gases and vapors may be collected through condensa-
tion, absorption and adsorption techniques. With
the exception of absorption, these are essentially
physical processes intended in one way or another to
condense the gas from the vapor phase to a liquid
which can then be handled for convenient disposal. In
condensation, gas streams are compressed, cooled and
adiabatically expanded. This technique by itself, how-
ever, is frequently impractical due to the energy re-
quired to bring the vapor to the dew point, especially
when the vapors are in dilute concentrations as en-
countered in organic solvent emissions.(8) Although
condensation through cooling and compression plays a
part in gas collection equipment, the main emphasis is
placed on absorption and adsorption principles of
collection.
Absorption consists of the use of some substance
which will selectively remove a gaseous or liquid ma-
terial from another gas or liquid. Control is accom-
plished through gas-liquid contact devices either in
cylindrical towers packed with an absorbing medium
or spray towers which scrub the gas stream. For ex-
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The Technology of Source Control
49
Figure II- 16. Floating roofs on petroleum storage tanks.
Figure 11-19. Vapor recovery system serving petroleum stor-
age tanks.
HK- - t
?r y
Figure 11-17. Covered oil-water separator.
•GAUGE & STARTER CONTROL
AIR VENT—- Hlj
FLEXIBLE f AIR
DIAPHRAGM
-,'/ TO COMPRESSOR
VAPOR COLLECTION HEADER
TO FUEL GAS
Figure 11-18. Simplified diagram of a vapor recovery system.
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50
Air Pollution Control Field Operations
ample the following absorbing media are used for the
gaseous contaminants specified:
Sulfur Dioxide—Water solutions of sodium sul-
fite, ammonium sulfite, ammonium sulfate
and dimethylamine.
Oxides of Nitrogen—Water.
Hydrogen Sulfide—Diethanolamine, phenolate
solutions, tripotassium phosphate.
Hydrogen Fluoride—Water and alkaline water
solution.
Organic solvents—Mineral Oil, but not efficient
due to need for control of low vapor concen-
trations.
Adsorption is a physical process in which the
molecules of either a gas or a liquid are condensed on
the surface of a solid material. Usually the capturing
solid is a porous material with a specific affinity for
the gas being adsorbed. Adsorbents include activated
carbon, chars, gels, aluminas, and silicates. The
adsorbent has a large surface area due to either the
porosity of the material or capillary construction. Con-
taminant gases are brought in contact with the ad-
sorbent and are collected in the pores or the capillaries.
The adsorbent is regenerated by steam which drives
off the adsorbed material in the form of a vapor which
may then be condensed along with the steam and
conveniently disposed of by otherLmeans.
II. AIR POLLUTION CONTROL PROGRAMS
Source control has long been practiced on an in-
dividual basis, either incidentally by improving plant
efficiency, conserving fuels and materials, or directly
in the practice of industrial hygiene and the promotion
of community relations. Particularly is this true when
industrial managers are not only aware, but keep
themselves informed of air pollution control develop-
ments.
The control of all of the sources contributing to a
community air pollution problem, however, cannot be
left solely to the initiative and conscience of individ-
uals, for a number of important reasons. First, the
severity of the problem may dictate the need for com-
prehensive control of most, if not all, of the equipment
in the important source categories. Second, it is econ-
omically as well as morally unjustified to permit one
industry to operate without controls while a similar in-
dustry practices source control. Third, the degree of
control practiced may be far below that required to
achieve the necessary reductions in pollution poten-
tials. Fourth, industries emitting contaminants which
may appear harmless, but which have a subtle sec-
ondary pollution effect, may find no obvious need for
control. Fifth, pollution problems result from the col-
lective contribution of an industrial economy, even
though individual source contributions may appear to
be small. And sixth, individuals do not possess the
resources to establish meaningful control standards.
To achieve control of the sources of air pollution
in a whole pollution zone, it is necessary to bring the
social and technical resources of the community to bear
on the problem, either in the form of a volunteer
association, or a governmental agency, or both. The
initial purpose of such organizations is to establish
objective equipment control standards scientifically
predicated on the air quality desired and to investigate
solutions to pollution problems.
Although private industrial, or trade associations
or committees can promote effective clean-air cam-
paigns, as well as serve as a clearing house for control
developments, little can be done to control a severe and
complex pollution problem without governmental par-
ticipation. Only government can legislate and enforce
control standards which will have a material effect on
the entire pollution zone. Furthermore, only govern-
ment, through elections, can reflect in its control activ-
ity the degrees of pollution reduction necessary to
guarantee the health and well-being of citizens. There-
fore, air pollution control is clearly a governmental,
as well as an individual, responsibility. It becomes the
responsibility of government to develop purposeful
control standards which are certain, enforceable, ap-
ply to all, are based on demonstrable needs, and, at
the same time, are not unreasonable, or capricious.
The control agency, therefore, develops a control pro-
gram suited to the needs and resources of the com-
munity. The typical elements of such a control pro-
gram are as follows:
1. Identification and evaluation of both the com-
munity-wide air pollution or smog problem,
and specific or local air pollution problems.
2. Establishing community air quality standards
in terms of maximum allowable atmospheric
concentrations, and promulgation of specific
control standards which can be applied to con-
trol all of the equipment and activities respon-
sible for air pollution.
3. Registration of the sources of air pollution in
order to assess pollution potentials and to de-
termine (1) the need for remedial or preven-
tive measures, (2) trends in pollution poten-
tials, (3) relationships between pollution
potentials and atmospheric concentrations, and
(4) objective criteria for anti-pollution legis-
lation.
4. Enforcement of control standards simultane-
ously and continuously at all of the sources of
air pollution in order to obtain minimum pol-
lution potentials, as well as solutions to speci-
fic air pollution problems.
A. Air Pollution Control Operations
Air pollution control operations are the ap-
proaches taken to any air pollution problem by which
all problems antecedent to actual institution of ap-
proved control methods are systematically attacked.
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The Technology of Source Control
Control operations are intended to reach and inspect
all of the sources of air pollution in the pollution zone
in order to effect and assure their control. This re-
quires not only the detection, apprehension and pros-
ecution of those who flagrantly violate the control
laws, but any other measures that will influence com-
pliance and control, either through inter-agency and
inter-industry cooperation, or through public informa-
tion and education.
The approaches to the different air pollution
problems are dictated by factors which cannot be
academically anticipated. An attempt to systematize
control operations by an artificial classification of pol-
lution problems based simply on contaminant, equip-
ment source or industrial activity, will be defeated by
unexpected factors. The approaches taken to accom-
plish control of the various categories of sources will
thus be determined by the leading obstacles encoun-
tered. In this sense, air pollution control attacks prob-
lems, not industries. In Los Angeles County, some six
types of control operations have been required, most
of which are representative, in some degree, of prac-
tices conducted by other agencies. These are given
here, with practical examples, as follows:
Agency Control Operations
1. Control of public sources — public information
and education and inter-governmental cooper-
ation (incinerators).
2. Control of an industry-wide problem (oil
refineries).
3. Control of a key contaminant (Sulfur Di-
oxide).
4. Control of the industrial sources of air pollu-
tion (general source control program).
5. Control through trade associations.
6. Development programs for uncontrolled
sources.
1. Control of Public Sources of Air Pollution
Frequently the full force of public opinion is
directed at the obvious sources of air pollution, such as
smoke and inefficient combustion equipment. The
improvement of coal quality and the installation of
smokeless combustion equipment by industrial, com-
mercial and domestic users in St. Louis and Pittsburgh
are classic cases in point. However, when the sources
of air pollution are not so obvious, as in the case of Los
Angeles, the control emphasis may not be so clearly
indicated. In complex problems, the control authority
must not only vigorously investigate the problem, but
must inform the public adequately. It has been par-
ticularly fortunate in the Los Angeles experience that
public pressure, in so aggravating a problem, could be
channeled into intelligent and creative control pro-
grams.
The Los Angeles problem was complicated in-
itially by the reluctance on the part of the community
to accept its share of the responsibility for air pollu-
tion. The popular assumption that "smog" arose from
oil refineries and chemical plants obscured the fact
that all sources of air pollution contributed to the prob-
lem. The control program of the A.P.C.D. sought con-
trol, therefore, of not only industry and refineries, but
of the public sources — some million and a half single-
chamber incinerators and, inevitably, the automobile,
now the major uncontrolled source of air pollution.
The burning of domestic, commercial and indus-
trial rubbish in Los Angeles County became a problem
not only because of the large number of incinerators,
which emitted about 500 tons a day of smoke and
combustion contaminants, but also because incinera-
tors created a heavy complaint load, requiring the full-
est attention of the A.P.C.D. Public support was nec-
essary before backyard burning could be abolished.
The elimination of the backyard incinerator and all
other inefficient industrial and commercial single-
chamber incinerators was the only means of certain
control. Various communities within Los Angeles
County, furthermore, demonstrated the feasibility of
collecting and disposing of rubbish through other,
means. Action to abolish incinerator pollution was un-
dertaken in the following manner:
1. A public information program was designed
to inform the public of the role of the refuse
burning in the smog problem, and of the fea-
sibility of abolishing the use of the single-
chamber incinerator.
2. A program of inter-governmental liaison and
cooperation to secure cut-and-cover dumps and
adequate rubbish collection services in the
more than 50 cities and other unincorporated
areas of the County was instituted.
3. Efficient multiple-chamber incinerators to dis-
pose of production wastes or dwelling refuse
with a minimum of smoke pollution were de-
veloped to meet stringent burning regulations.
The preponderance of the initial control effort
was spent in the public information program. It was
necessary for the public to be conscious of the effect
of the mass use of incinerators on the atmosphere.
When the public was fully apprised of the facts
through the media, its elected representatives were
prepared to take the necessary 'steps. Incinerators
were then banned by regulation everywhere in Los
Angeles County.
2. Control of Industry-Wide Problems —
Oil Refineries
Occasionally, an industry-wide problem will
occur requiring a planned and concentrated control
effort. The oil refining, metallurgical, and animal
rendering industries are typical of such problems.
Where the industry presents a wide range of complex
sources of air pollution, the problems within each in-
dustry are classified and attacked systematically. The
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Air Pollution Control Field Operations
petroleum refining industry, particularly in Los An-
geles, is the most complex of such industries.
The oil refining process consists of rearranging
hydrocarbon molecules obtained from crude oil to pro-
duce a variety of petroleum products, including avia-
tion and automobile gasolines, Diesel and industrial
fuel oils, domestic heating oils, lubrication oils and
Figure II - 20. Residential rubbish pick-up truck with compact-
ing unit.
greases, kerosene, asphalt and coke, hydrocarbon gases,
solvents, and a variety of specialty products. The re-
arrangement and modification of hydrocarbons is ac-
complished by any one or combination of the following
processes:
1. Distillation — separation of hydrocarbon mol-
ecules according to boiling range and type in
stills and fractional distillation columns.
2. Cracking — breaking down of large compli-
cated molecules into different compounds in
thermofor or fluid catalytic cracking units.
3. Polymerization — joining together smaller
hydrocarbon molecules to form larger mole-
cules in polymerization units.
4. Hydrogenation and dehydrogenation — alter-
ing the hydrocarbon structure by adding or
removing hydrogen in hydrogenization and
dehydrogenation units.
5. Alky la ti on — substituting or adding an alkyl
group such as methyl or ethyl.
6. Isomerization — rearranging molecular struc-
ture of hydrocarbon molecules without chang-
ing chemical formula to develop new proper-
ties in compounds.
7. Reforming — cracking of hydrocarbon to in-
crease octane rating or to produce aroma tics
and paraffins from olefins in reforming, Hy-
droforming or Platforming units.
Virtually all of these processes are conducted cat-
alytically at high temperatures and pressures in suit-
ably designed equipment, or by thermal processes as
in distillation and some cracking processes. Petroleum
stocks are also extensively handled, treated, blended,
stored and marketed. Virtually every phase of petrol-
eum production, recovery of waste products, refining
and marketing possesses pollution potentials including
emissions of saturated and unsaturated organic vapors,
sulfur dioxide, hydrogen sulfide, oxides of nitrogen,
carbon monoxide, catalyst dust, and visible smoke
plumes. These may occur anywhere from the feeding
and processing of stocks to the storage and handling of
final products and the disposal of waste water streams.
In Los Angeles County legal requirements and volun-
tary action by the petroleum industry have resulted
in comprehensive control of emissions to an extent not
known elsewhere. The local refinery problem has also
been studied intensively to determine the full nature
and extent of the refinery contribution, and to indicate
further control needs through a joint project of the
Los Angeles Air Pollution Control District, the U. S.
Public Health Service, the State of California Depart-
ment of Public Health and the Western Oil and Gas
Association. (8)
The air pollution problems and the solutions ap-
plied are described below.
1. PROBLEM: Carbon monoxide, oxides of ni-
trogen, oxides of sulfur, hydrocarbon vapors,
catalyst dust plume and visible plume from
coke and other deposits from catalyst regener-
ators and cracking units.
CONTROL: Electrical precipitators and cen-
trifugal collectors for catalyst dust collection
and waste-heat boilers for combustion of car-
bon monoxide and other contaminants.
2. PROBLEM: Black smoke from emergency
flares used to burn excess gas surges created
by upset or abnormal refinery operations.
CONTROL: Redesign of flares using either
Venturi burners to obtain suitable fuel-air
ratio, or introduction of steam injection into
the combustion zone.
3. PROBLEM: Vapor losses from storage tanks.
CONTROL: Vapor collection system or float-
ing roofs on storage tanks to prevent evapora-
tion of volatile products.
4. PROBLEM: Malodor and hydrocarbon emis-
sions from oil-effluent water separators (sep-
arate oil from waste waters).
CONTROL: Completely enclosed separator
boxes with suction lines and compressor to re-
move vapors to absorption tower, or floating
roof covers with automatic skimming devices,
or covers over inlet compartments in oil
sumps.
5. PROBLEM: Hydrocarbon vapor losses from
large volume loading of gasoline into tank
trucks.
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The Technology of Source Control
53
Figure 11-21. Smokeless flare with control equipment not in
operation.
Figure II - 22. Smokeless flare system for emergency gas re-
leases with control equipment in operation. Controls regulate
quantity of steam to the flares for varying gas flows.
CONTROL: Vapor tight fittings and seals for
loading arm adaptors and vapor collection
equipment.
6. PROBLEM: Smoke from boilers and heaters
in refinery processes.
CONTROL: These are controlled primarily
through effective operational and maintenance
practices, and proper design of fireboxes,
burners, and controls.
7. PROBLEM: Hydrocarbon vapors from vac-
uum jets associated with vacuum distillation
facilities.
CONTROL: Effluent from final stage of pro-
cesses is controlled by condensation and col-
lected in a closed settler for separating the
water and hydrocarbons. The non-condensable
vapors are burned in an afterburner, fur-
nace or boiler, or are added to refinery fuel gas
systems.
8. PROBLEM: Light hydrocarbon vapor losses
from centrifugal pumps with packed gland
seals.
CONTROL: Conversion to mechanical seal
pumps, and enforcement of inspection and
maintenance procedures.
9. PROBLEM: Hydrocarbon losses from accu-
mulator vents and relief valves and other
processes.
CONTROL: Vented to vapor collection equip-
ment or waste heat boilers.
10. PROBLEM: Malodors from processing of sul-
fur compounds, acid treating, doctor treating,
mercaptan removal processes, caustic regen-
eration, cresylic and naphthenic acid manufac-
turing and air blowing of asphalt.
CONTROL: Burning malodorous vapors in a
combustion chamber or boiler firebox at
1200°F.
Figure II - 23. An open overhead controlled loading rack show-
ing Greenwood vapor closures on the pneumatically operated
loading arms.
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54
Air Pollution Control Field Operations
3. Control of a Key Contaminant — Sulfur Dioxide
Sometimes a control program may be directed
toward a specific contaminant, and all of the sources
which may produce it, regardless of the industry.
When the Air Pollution Control District formed in
1948, it followed the procedure of other control agen-
cies in emphasizing the control of sulfur dioxide. The
control of sulfur dioxide in Los Angeles County has
involved a number of control actions taken appropri-
ately at a variety of sources.
1. PROBLEM: Sulfur dioxide emissions from
the burning of sulfur compounds such as hy-
drogen sulfide produced from the processing of
fuel oil and residuals at refineries.
CONTROL: This problem was solved over a
period of time by the development of the sul-
fur recovery plant and expansion of hydro-
gen sulfide facilities in the refineries.
2. PROBLEM: Sulfur dioxide emissions from
fuel oil burning in heating and processing
boilers, and from large steam-electric generat-
ing facilities.
CONTROL: This problem has been partially
solved by rule prohibiting the burning of fuel
oil during certain months of the year; in ef-
fect, requiring the use of natural gas. Studies
continue, however, to seek means of eliminat-
ing air contaminants from power plant flue
gases by electrical precipitation and other
means.
4. Control of Industrial Sources of Air Pollution
Once air pollution problems from any source or
industry are solved by proven control techniques, and
all other obstacles to control have been eliminated,
then a special control program for that equipment
source or industry is no longer required. The sources
of pollution are inspected to assure that control prac-
tices are properly conducted. New industries or equip-
ment sources entering the pollution zone are then re-
quired to select an approved control practice before
they are permitted to operate. In these instances, field
operations are intended to insure continued control of
the sources. In Los Angeles County all such routine
control processes are systematized and are known as
the Industrial Source Control Program.
An example of such routine practices may be
found in the metallurgical and mineral processing in-
dustries. In the metallurgical industry, control is di-
rectly applied, as required, in the form of cyclones,
baghouses, scrubbers, electrical precipitators, or by
change-over to improved furnaces and equipment.
Each problem, however, is studied for such factors as
temperature, equipment layout, and variations in the
quantity and sizes of particle emissions before success-
ful control is accomplished. (1)
The same may be said of mineral processing in-
dustries (asphaltic concrete batching plants, concrete
batching plants, glass container manufacturing plants,
perlite, vermiculite and other insulation plants, and
specialized mineral processes). In these industries
standard collection equipment is modified to collect
the specific particulate matter involved. Baghouses or
scrubbers are used on glass furnaces. Other mineral
processes, such as rock and gravel crushing and class-
ification, mica grinding and classification, sand drying,
roofing granule plants, silica abrasive classification,
cement handling, diatomaceous earth processes, man-
ufacturing of building brick, and many others are con-
trolled by means of cyclones, scrubbers and baghouses.
5. Trade Associations
Where trade associations are established, a control
program may be instituted through cooperative action.
Early in the control program of the Air Pollution Con-
trol District, equipment manufacturers and designers
from the metallurgical industries, in cooperation with
A.P.C.D. engineers, established a control equipment
development program. From such a program, the de-
velopment and use of the first effective high tempera-
ture gas filtration equipment for the collection of
emissions from gray iron cupolas was developed. This
same equipment has not only since been refined, but
has found wide application in many industries.
6. Air Pollution Control Development Programs —
Automotive Exhaust and Organic Solvents
When the means for controlling a source of a
major air pollutant are not available, then the control
agency must attempt to promote their development.
This is accomplished by means of a control development
program with the following features:
(1) adequate research on the pollution problem in
question, so that the importance of the air
contaminant can be ascertained;
(2) development and substantiation of the data
characterizing the nature of the problem, so
that development of control techniques can
begin from valid assumptions;
(3) promotion of engineering control develop-
ment projects; and
(4) testing of control devices or techniques as
they are developed for efficiency to determine
control standards.
When control devices and techniques are devel-
oped and approved, legislation may then be promul-
gated, and control action instituted.
In Los Angeles County two such developmental
control programs are currently conducted. These con-
cern the emission of unburned gasoline products from
automobiles and the emission of organic solvents from
a variety of industries.
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The Technology of Source Control
55
SECONDARY Alfi INLET IGNITION PLUG
EXIT EXHAUST
HEAT EXCHANGE AREA
Figure II - 24. Ignition type exhaust afterburner. Unburned
hydrocarbons are consumed as they pass through this exhaust
muffler where they are mixed with fresh air and ignited by a
spark or flame.
a. Automobile Exhaust
Since auto exhaust control methods were not
available at the time that the importance of the auto-
mobile exhaust problem was first established, it was
necessary to explore all possible avenues of control.
Control concepts explored were based on (1) elimi-
nating all unburned gasoline products, whether satu-
rated or unsaturated, through all operating cycles of
the automobile engine; (2) eliminating all unburned
gasoline products during those operating cycles only in
which the majority of the unburned gasoline is ex-
hausted; and (3) eliminating only key reactants, such
as the olefins and/or the oxides of nitrogen. Some of
the following devices and control methods have been
developed or are currently under consideration.
1. Direct-flame afterburners with or without an
ignition device for burning unburned con-
taminants in the exhaust.
2. Catalytic mufflers which oxidize the unburned
contaminants in the exhaust.
3. Fuel cutoffs which function to prevent fuel
flow to the engine during the deceleration
cycle.
4. Vacuum-limiting devices which allow suffi-
cient air to enter the intake manifold to effect
more efficient combustion during the deceler-
ation cycle.
5. An oxides of nitrogen reducer utilizing a re-
ducing agent such as vanadium pentoxide to
convert oxides of nitrogen into oxygen, nitro-
gen and carbon monoxide.
6. Reduction of nitrogen dioxide by recirculating
a small amount of cooled exhaust to the engine.
7. Recirculation of "blowby" emissions from
crankcase to the intake system.
8. Modification of gasoline composition to reduce
smog-forming effects of unsaturated hydro-
carbons principally by reducing olefinic con-
tent of gasoline.
9. Reduction of automobile traffic by implement-
ing rapid transit systems.
10. Modification of power plant, so as to elimi-
nate or minimize the emission of contami-
nants.
The development of many of these techniques
and devices has progressed to a point where practical
INLET EXHAUST
Figure II - 25. Catalytic type muffler exhaust afterburner. Un-
burned hydrocarbons mixed with fresh air pass through a catalyst
bed where the smog-forming hydrocarbons are destroyed.
control is now imminent, not only in Los Angeles
County but, eventually, throughout the country. Auto-
mobile manufacturers, private research and develop-
ment groups, as well as individuals, for the last five
years have been intensively developing and refining
a number of promising devices. The automobile ex-
haust laboratory of the Los Angeles County Air Pollu-
tion Control District, the first of its kind, has been
testing these devices, as well as researching the prob-
lem to determine control standards.
The specific objective in controlling automobile
exhaust is to certainly control the olefins, oxides of
nitrogen and carbon monoxide at such efficiencies, as to
avoid a backsliding of pollution to pre-control levels
due to increasing automobile population. The control
of auto exhaust, therefore, cannot be partial. To insure
complete control, several approaches are being taken.
The first of these is the control of olefin content of
gasoline, and the second, the direct control of auto
exhaust emissions.
In Los Angeles County gasoline composition is
regulated by Rule 63 of the A.P.C.D. which prohibits
the sale of gasoline for motor fuel having a Bromine
number of more than 30 (13%) after June 30, 1960,
and a Bromine number of 20 (12i/2%) after December
31, 1961. After the latter subdivision of the rule be-
comes effective, a 75% reduction in smog-forming
olefins is expected.
The direct control of automobile exhaust emis-
sions is now possible by virtue of the devices men-
tioned. The primary consideration at the present time
is the cost and efficiency of such devices. Air quality
standards, as set by the California Department of
Health, require that they accomplish an overall 80%
reduction of hydrocarbon emissions, and a 60% reduc-
tion of carbon monoxide.
On April 15, 1960, the California State Legisla-
ture passed Assembly Bill No. 17, requiring the in-
stallation of control devices on all cars throughout the
entire state, with the exception of those counties of the
state which demonstrate through public hearings that
no pollution problems exist. The law further requires
that, upon the certification of at least two proven
devices by a Motor Vehicle Pollution Control Board,
all new vehicles, when first registered, and all
used vehicles which change ownership, must be
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Air Pollution Control Field Operations
equipped with a control device within one year, all
used commercial vehicles within two years, and all
motor vehicles within three years. The entire control
of automobile exhausts, therefore, is now subject to
the certification of control devices, and control devel-
opment and testing continue to hasten this end.
b. Organic Solvents
The air pollution problem presented by the emis-
sion of many solvents used in industrial, commercial
and domestic activities carried on in Los Angeles
County has posed a problem similar to that of the
automobile exhaust. The existence of this problem
was theoretically assumed on the basis of experience
with automobiles and refineries, and substantiated by
surveys and other statistical findings. It was deter-
mined that some organic solvent vapors, including al-
cohols, ethers, paint thinners and lacquer thinners, re-
act in the Los Angeles atmosphere to produce smog in
the same manner as gasoline vapors. Recent estimates
indicate that about 500 tons per day of these solvents
are discharged into the atmosphere (See Chapter 1).
The problem of controlling organic solvents in-
volves questions similar to those posed by the automo-
bile. Is it sufficient to eliminate only the most reactive
unsaturates or must all of the contaminants produced
by the complex of activities using organic solvents in
one form or another be controlled? The final decision
in this regard is dependent upon research which must
determine the relative importance of all contaminants
and the means available to control them upon develop-
ment of controls at a cost which can be met by small
users, the establishment of reasonable standards and
the development of suitable methods for measuring
vented contaminants.
Since solvents vary and are used under a wide
variety of conditions from paint thinner to metal de-
greasing •—• each particular type of industrial user
encounters a different problem. To comprehend the
differences, control development concerns these prob-
lems.9)
1. PROBLEM: Gases with high concentrations of
hydrocarbon solvents.
POSSIBLE CONTROL: Catalytic afterburners
and direct-fired afterburners. Catalytic after-
burners have been applied to lithograph ovens,
and direct-fired afterburners have been installed
on paint baking ovens, varnish thinning tanks
and other equipment where high solvent concen-
trations may be expected.
2. PROBLEM: Solvent emissions (chlorinated hy-
drocarbons) from dry cleaning plants.
POSSIBLE CONTROL: A packaged activated
carbon adsorption unit adaptable to certain small
operations. This unit is economically attractive
to the user.
3. PROBLEM: Losses of solvents with low concen-
trations of hydrocarbons which result primarily
from spraying or surface coating.
POSSIBLE CONTROL: In development stage.
4. PROBLEM: Dilute solvent vapors such as are
emitted from rotogravure presses.
POSSIBLE CONTROL: A large regenerative ab-
sorption unit has been installed as a voluntary air
pollution control measure on a rotogravure press.
This unit has a design capacity for the removal of
1800 pounds per day of ketones, ethers and alco-
hols. Removal efficiency is about 99 per cent.
5. PROBLEM: Chlorinated hydrocarbons emitted
from metal degreasing units.
POSSIBLE CONTROL: In development stage.
An adaptation of activated carbon adsorption
techniques is being investigated.
These represent a few of the many problems in-
volving organic solvents. There are also many instal-
lations in Los Angeles County emitting more than
10,000 pounds per day of solvents which could be con-
trolled through adsorption recovery. When all solvent
losses can be feasibly controlled, regulations will be
adopted.
REFERENCES
1. Chass, R. L., Engineering Control of Air Pollution in Los An-
geles County, Journ. of the Sanitary Engrg. Div., Proc. of the
Amer. Soc. of Civil Engineers, Los Angeles, Calif., 19 pp., Feb-
ruary 1959.
2. Chass, R. L., Lunche, R. G., Kanter, C. V., Control of Hydro-
carbon Emissions at Petroleum Refineries in Los Angeles County,
136th Nat. Meet, of the Amer. Chem. Soc., Div. of Pet. Chem.,
27 pp., September 1959.
3. Chass, R. L., Lunche, R. G., Shaffer, N. R., Tow, P. S., Total
Air Pollution Emissions in Los Angeles County, Air Pollution
Control Assoc., Los Angeles, Calif., 38 pp., 1959.
4. Faith, W. L., Air Pollution Control, John Wiley and Sons,
Inc., New York, pp. 50-178, 1959.
5. Friedlander, S. K., Silverman, L., Drinker, P., First, M. W.,
Handbook on Air Cleaning, Paniculate Removal, United States
Atomic Energy Commission, Washington, D. C., pp. 1-89, Sep-
tember 1952.
6. Holland, W. D., Hasegawa, A., Taylor, J. R., Kauper, E. K.,
Industrial Zoning as i Means of Controlling Area Source Air
Pollution, 52nd Annual Meet., Air Pollution Control Assoc.,
Los Angeles, Calif., 22 pp., June 1959.
7. Journal Amer. Med. Assoc., Smokeless Zones, V. 154, 852,
March 1958.
8. Kanter, C. V., Elliott, J. H., Spencer, E. F., Jr., Kayne, N.,
LeDuc, M. F., Control of Organic Emissions from Surface Coat-
ing Operations, 52nd Annual Meet., Air Pollution Control
Assoc., Los Angeles, Calif., 27 pp., June 1959.
9. Krenz, W. B., Adrian, R. C., Ingels, R. M., Control of Solvent
Losses in Los Angeles County, 50th Annual Meet., Air Pollution
Control Assoc., St. Louis, Mo., 7 pp., June 1957.
10. MacKnight, R. J., Williamson, J. E., Sableski, J. J., Dealy, J.
O., Controlling the Flue Fed Incinerator, 52nd Annual Meet.,
Air Pollution Control Assoc., Los Angeles, Calif, llpp., June,
1959.
11. Magill, P. L., Holden, F. R., Ackley, C., Air Pollution Hand-
book, McGraw-Hill Book Co., Inc., 13, 1-106, 195(5.
12. Mills, J. L., Hammond, W. F., Adrian, R. C., Design of
Afterburners for Varnish Cookers, 52nd Annual Meet., Air
Pollution Control Assoc., Los Angeles, Calif., 25 pp., June
1959.
13. Newmann, E. P., Soderberg, C. R., Jr., and Fowle, A. A,
"Design, Application, Performance, and Limitations of Sonic
Type Flocculators and Collectors," Air Pollution, Proc. of the
U. S. Tech. Conf. on Air Pollution, Louis McCabe, Chairman,
McGraw-Hill Book Co., Inc., pp. 388-393, 1952.
14. O'Harrow, D., "Performance Standards in Industrial Zoning,"
Planning, 1951, Chicago: Amer. Soc. of Planning Officials,
pp. 42-55, 1952.
15. Los Angeles County Air Pollution Control District, "Control of
Stationary Sources," Technical Progress Report, Volume I, Los
Angeles, Calif., April I960.
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CHAPTER THREE
THE LAW OF AIR POLLUTION CONTROL
The right of a society to prohibit and to regulate
the sources of air pollution is firmly established in
legislative and judicial precedent and in the police
power delegated to the states by the Federal Constitu-
tion. Political organizations, from the municipality to
the state, possess the full power to legislate and enforce
air pollution control laws as long as the control of air
pollution is technically feasible and reasonable. Severe
measures can be lawfully adopted as they become nec-
essary, provided that they are not arbitrary and cap-
ricious. Moreover, the statutory control of air pollu-
tion is not limited to correction of existing conditions,
but can be applied in a flexible and farsighted manner
to prevent pollution hazards, disasters, or worsening
pollution trends. The legal control of air pollution is
no different in these respects from any other form of
statutory and administrative law designed to protect
the health and welfare of the public.
Air pollution control law, however, is unique in
terms of the abstract nature of air pollution. Because
law regulates the conduct of individuals, and air pollu-
tion results from collective acts which are otherwise
individually lawful, air pollution law does not appear
to be morally or criminally self-evident. Air pollution
control law is essentially the adaptation of legal con-
cepts to scientific evidence and standards designed to
achieve gross reductions of air pollution potentials.
Although violations of air pollution law may re-
sult in criminal action, the basic intent of the law is
to achieve standards of compliance on the part of the
sources of air pollution, not to punish for its own sake.
Air pollution law takes into account the technical na-
ture of air pollution and the fact that actual control is
achieved, in the last analysis, by cooperation on the
part of the community, industry and individuals. Law
is thus one of the many tools used in the control of air
pollution.
I AUTHORITY AND PRECEDENT FOR
LEGISLATIVE ENACTMENTS
Although the law concerning air pollution is com-
plex, a few basic legal principles underlying the capa-
bility of a community to enact valid laws to prevent air
pollution can be stated. These will be discussed in
terms of (1) common law nuisances, (2) constitution-
al powers and limitations, and (3) recent case law.
A. Common Law Nuisances
Both the nuisance value and the criminal aspects
of air pollution have been derived from the exposition
of the concept of the "common nuisance" and, particu-
larly, the "public nuisance" at common law. In Eng-
land early common nuisances involved encroachments
and infringements on the royal domain of the crown
and by the time of Edward III, many acts resulting in
air pollution were included.a) The concept was later
extended to include any form of annoyance or incon-
venience which interfered with common public rights.
The public nuisance has been numerously and vari-
ously defined, but most definitions and statutes con-
cerning public nuisances were later worded in terms
of any act or omission which offended the health, com-
fort, welfare, morals, safety, etc. of the public. A pub-
lic nuisance, for example, is an act or omission "which
obstructs or causes inconvenience or damage to the
public in the exercise of rights common to all Her Maj-
esty's subjects." "' Public nuisances resulting from such
specific forms of air pollution as smoke, fumes and
odors were contained in a class with other minor crim-
inal offenses in the common law and were classed as
misdemeanors.
Each nuisance case, therefore, was tried on its
own merits. Historically, the problem of air pollution
was not immediately considered as a nuisance per se,
that is, a nuisance in and of itself. Cases of public nui-
sance arose as a result of complaints made by citizens
in a community against a source or sources of air pol-
lution.
In modern times, the increasing use of the term
"air pollution" rather than smoke, odors, fumes, etc.,
reflects acceptance of the judgment that anything
which contaminates the air in a crowded community
is detrimental to the public welfare, just as the con-
tamination of drinking water, or the industrial pollu-
tion of streams, is so considered. "Air pollution" came
to be regarded as an "absolute" nuisance. Thus, under
the police powers of the state, specific air pollution
problems are declared by statute, within constitutional
limitations, to be nuisances.c)
Because of their uncertainty, however, public nui-
sance statutes were inadequate to form the sole basis
for air pollution control law in modern communities.
Therefore, laws were written limiting the emission of
specific contaminants, either by setting maximum per-
missible pollution standards or by regulating the use
and operation of equipment and fuels. The first such
ordinance giving specific authority to local government
to regulate smoke discharge in the United States ap-
pears to have been adopted in Chicago in April, 1881.
Cincinnati and St. Louis soon followed, and by 1913,
23 out of 28 cities with more than 200,000 population
had smoke abatement programs involving ordinances
a) Prosser, W. L. See reference 12, p. 390. Chapter 14. traces
the history and case law of the various forms of nuisance and
is fundamental to the subject.
b) Ibid, p. 401, from Stephen, General View of the Criminal
Law in England, 1890, 105.
c) Ibid, page 400.
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58
Air Pollution Control Field Operations
against specific contaminants.d) Thus, under authority
of the state legislature, definite control standards were
established for specific types of air pollution problems,
such as smoke, and the problem of air pollution was
systematically attacked without the necessity of prov-
ing in each case a statutory or common law nuisance.6)
The control laws enacted in the United States are
of two principal types: (1) punitive ordinances which
impose fines for discharging contaminants into the air;
and (2) regulatory ordinances which seek to abate air
pollution by preventing the discharge of contaminants
into the atmosphere. The validity of these laws de-
pends entirely upon whether or not they come within
constitutional limitations and, in the case of a city,
its charter or constitutional provisions to pass such
laws.f)
B. Constitutional Powers and Limitations
In essence, the Constitution of the United States
contains no provision which prevents the enactment of
air pollution control acts in the states. The police pow-
er of the state, that is,the power to protect the health,
morals, safety and welfare of the citizens, is derived
from the Tenth Amendment of the Constitution,which
states:
The powers not delegated to the United States by the
Constitution, nor prohibited by it to the States, are re-
served to the States respectively, or to the people.
The power to control air pollution, to all intents
and purposes, lies exclusively with the states. The
limitation in the amendment is imposed on the federal
government in that the federal government has no
general power to enact police regulations within the
territorial limits of the states.K'
The only other constitutional limitation to this
police power is contained in the Fourteenth Amend-
ment of the Constitution^ follows:
.... nor shall any State deprive any person of life, liberty,
or property, without due process of law; nor deny to any
person within its jurisdiction the protection of law.
This particular amendment determines the extent to
which air pollution control law can go.
C. Recent Case Law
Case law refers to the interpretations of the law
which have entered into the decisions handed down by
the courts in settling disputes. Case law thus validates
or limits air pollution control enactments, and consti-
tutes a third component of the authority of air pollu-
d) A Review and Appraisal of Air Pollution Legislation in the
United States, by Samuel M. Rogers, June 4, 1957, for the
golden jubilee meeting of the A.P.C.D., St. Louis, Mo. (per
Reference No. 3).
e) Board of Health of Weehawken Township v. New York Cen-
tral Railroad, 10 N. J. at 306, 90 Atl. (2d) at 735.
f) Kennedy, Harold W. in reference 7, "Validity Not Based on
Nuisance", cases cited, p. 381.
g) However, the Congress of the United States has very definite,
though indirect, powers to regulate pollution of the national
air space, if warranted, in the same way that it regulates
pollution of navigable streams under the commerce clause of
the Constitution.
tion control law. Case law in the United States results
primarily from decisions handed down in a federal
court, or appellate or higher court in any state. Since
Municipal and Superior court decisions are not gen-
erally reported to the bound case records, their
precedence is generally limited to the jurisdictions
in which they apply. Case decisions are extremely
important to the control effort since they may settle
questions of law for the first time. Cases which are
appealed to the higher courts have a tendency to either
strengthen, confirm, or weaken specific air pollution
control provisions.
Generally speaking, most of the air pollution cases
which are appealed to the higher courts test the con-
stitutionality of the control act by means of the due
process clause of the Fourteenth Amendment, a few
by the equal protection clause. These tests of law deter-
mine how far air pollution control laws may go with-
out violating due process of law. The results of most
of the recent air pollution cases handled in the courts
demonstrate that control law can be as strict as is
reasonably necessary. Case law has, consequently,
provided a strong and adequate authority to control by
legal means modern air pollution problems.
1. Precedent-Making Decisions
A few of the important precedent-making deci-
sions which contribute to the power of the people to
enact air pollution control laws may be summarized
from Kennedy7) as follows:
1. The power to prohibit the emission of dense smoke
in cities or populous neighborhoods is inherent in the
police power of the state. Smoke can be declared a
nuisance and be subject to restraint . . . the harshness
of such legislation, or its effect upon business interests,
short of merely arbitrary enactment, is not a valid con-
stitutional objection.*1)
2. The validity of statutes prohibiting visible or in-
visible pollutants under state authority need not be
based on the concept of nuisance.')
3. Ordinances based on a definite scientific standard
for the density of smoke, such as the Ringelmann Scale
(see Chapter 10), are approved if such standards or
equivalent standards are specified in the law.8) The
point at which emissions of air contaminants are pro-
hibited or are permissible is a matter of legislative dis-
cretion, which the courts will validate.8)
4. Statutes or ordinances are not invalid and unreas-
onable merely because there is no known control de-
vice or technique to permit compliance.') Such laws,
however, cannot require compliance that is impossible
to attain. They may not prohibit entirely air pollution
h) Northwestern Laundry v. Des Moines, 239 U. S. 486, 36
Sup. Ct. 206, 60 L.Ed. 396 (1916).
i) Board of Health of Weehawken Township v. New York Cen-
tral Railroad, 10 N. J., at 306, 90 Atl. (2d) at 735.
j) Moses v. U. S., 16 App. D. C. 428.
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The Law of Air Pollution Control
or any class of air pollution, but must establish stand-
ards of reduction consistent with scientific possibili-
ty^
5. A law or ordinance prohibiting one type of con-
taminant in a community is not invalid because there
is not a law or ordinance regulating another type of
contaminant.^)
6. Laws are not valid in regard to any injury to the
public which is trivial, fastidious, or offensive merely
to the esthetic senses.™) On the other hand, it is not
necessary to show impairment to health in order to
establish the emission of smoke and fumes as a nui-
sance and to permit its abatement by law. Discomfort,
inconvenience, and annoyance to the public are suffi-
cient.')")
7. Several sources of air pollution may be found
liable in contributing jointly to a nuisance.0)
Other case laws arising from the Los Angeles
problem will be discussed in relation to the enactment
of the California Air Pollution Control Act.
II ENACTING AIR POLLUTION CONTROL LAW
An air pollution control act is a body of law con-
sisting of civil procedures, specific laws, legislative de-
terminations and findings, prohibitions, and rules and
regulations intended to implement and provide for the
administration of air pollution control programs in
recognized pollution zones. Air pollution law, funda-
mentally, is the responsibility of the state legislature
either through legislation which directly affects the
entire state, or through legislation which delegates
powers to local governing bodies such as boards of su-
pervisors and city councils.
A. Public versus Private Interests
The creation of air pollution legislation results
from the resolution of conflicts between public and
private interests. On one side citizens demand clean
air; on the other, private interests wish to protect their
rights and interests without public interference. The
demand for clean air usually begins with the expres-
sion of public opinion through communication media,
taxpayer groups, associations, citizens' committees,
government agencies and officials. The demand for
clean air may develop into a political issue, and legis-
lative committees or other political bodies may form
for the purpose of drafting proposals for debate and
final enactment.
k) Department of Health of the City of New York v. Phillip
and William Ebling Brewing Co., 38 Misc. 537, 78 N. Y. S.
13. (Mun. Ct. City of N. Y., 1902).
1) Ballentine v. N ester, 350 Mo. at 69, 164 S. W. (2d) at 381.
m) Tuebner v. California Street R. R. 66 Cal. 171, 4P, 1162,
1164 (1884).
n) Judson v. Los Angeles Suburban Gas Co., 157 Cal. 168, 106
Pac. 581, 26 L. R. A. (N.S.) 183 (1910).
o) Ingram v. City of Gridley, 100 Cal. App. (2d) 815, 823-824,
224 Pac. (2d) 798,803 (1950).
On the negative side are those groups which either
oppose control in its entirety, or raise objections to spe-
cific provisions in the control bill. These may not only
include industrial and trade groups, but citizens' com-
mittees, and taxpayer groups. Some of the opposition
may express a sincere interest in the effects of control
on the economy, while others may reflect the desire to
protect private interests, or positions which rationalize
a political belief. Some of the sincere opposition may
arise, also, from civic-minded groups who believe that
control can be achieved best through voluntary action
without resorting to government control. Because ef-
fective legislation must take into account the objections
made, some of them are included here:
1. Some believe that smog is merely a product of high-
er civilization and must be accepted and coped
with accordingly; that there is nothing essentially
harmful about air pollution which can be demon-
strated; and that a smoking stack, a symbol of
prosperity, is of benefit to the community.
2. Some believe that the control of air pollution costs
great sums of money, both immediately and on a
continuing basis, and object that the costs of con-
trol are likely to be passed on to the consumer in
the form of higher prices.
3. Some believe control has disproportionate effects
on competition in that the area with air pollution
control is unable to compete with an area without
air pollution control.
4. Some believe that governmental interference
should be avoided on its own merits.
5. Some fear that changes in traditional modes of
operation, necessitated by control measures, threat-
en the existence of certain industries.
6. Others feel that industry should pay for and solve
its own air pollution problems. This is a taxpayer's
position, as well as industry's, and is frequently
expressed as voluntary self-control.
7. Still others complain of specific legislation intended
to control specific types of air contaminants, since
the relative effects of various contaminants in the
local atmosphere may not as yet be ascertained.
This faction believes that control should await
research findings. Others oppose specific provisions
in the proposed laws such as the permit system.
8. In the case of Southern California, many of the in-
dividual cities initially objected to county-wide
control on the basis of how such a control agency
might be financed, and the possible application of
the control authority to municipally owned equip-
ment.
These conflicts, of course, can only be resolved by
the orderly process of law. If the law-making body
determines that the atmosphere is polluted to an ex-
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60
Air Pollution Control Field Operations
tent that the peace, health, safety and welfare of the
people of the state are disturbed, then the right to con-
trol air pollution by means of legislation assumes pre-
cedence over interests which seek to prevent such con-
trol.
The outcome of the struggle between proponents
of strong measures and proponents of token or volun-
tary measures is highly important inasmuch as the en-
tire capability of controlling air pollution is being de-
termined. The final control bill may compromise in-
terests, or, where compromise is rejected, conflicts may
be resolved by wise revision of control proposals. The
object of control legislation is to provide powers which
make the control of air pollution clear and certain
while protecting the equities and constitutional rights
of individuals. Where an air pollution problem is se-
vere, involving unknowns, legislation must make ulti-
mate solutions possible. Also, while the law must be
clear and certain in its regulatory provisions, it must
also be broad and flexible enough to permit the control
agency to cope routinely with problems which daily
arise. The scope and stringency of the law, also,
should not be in excess of that required to accomplish
efficient control, nor should it be so weak as to render
control ineffective.
B. Construction of the Air Pollution Law
The approaches to establishing air pollution con-
trol law and the creation of control authorities vary
from state to state. Regulatory ordinances may be in-
dividually incorporated into existing Health, Safety,
or Engineering Codes, or separate chapters or sections
may be adopted respecting the establishment of an
air pollution control authority together with a related
body of administrative laws.
The primary control jurisdiction always rests
with the state. But the state may delegate wholly, or
in part, its police powers to communities (counties and
cities). Usually the state determines and defines the
authority for local control before it delegates the rule-
making power. In each community, then, two distinct
bodies of law may be involved: (1) the state law, and
(2) the rules and regulations, or the ordinances of the
local control authority. Regardless of how such laws
are constituted, the control law will require the fol-
lowing declarations, powers, and provisions:
1. Findings as to the Existence of Air Pollution
The findings as to the existence of air pollution
problems in a community or portions of a state are
based on public hearings and expert testimony. The
law declares its findings, usually in the form of a pre-
amble, stating that air pollution is detrimental to the
health, welfare, comfort, and well-being of the state,
thereby establishing the fact that air pollution is in and
of itself an absolute nuisance. The right of people to
obtain relief from polluted air under the police power
of the state is affirmed. Specific regulations and prohi-
bitions intended to control contaminant emissions are
then justified.
2. Creation of the Control Authority
At the same time, the law states, either specifically
or generally, the existence of pollution zones and estab-
lishes the specific authority or the nature of that au-
thority which will encompass and regulate recognized
pollution zones. The law may provide for the creation,
organization, staffing, budgeting, and administration
of an air pollution control authority, agency, district,
board or commission. State practices, in this regard,
differ substantially in the placement of the control
authority.
Of the 9,500 communities in the United States ex-
periencing local air pollution problems, 2,050 have
adopted some kind of legislation aimed at controlling
air pollution.1*) A large part of such legislation is
designed to attack specific air pollution problems on the
city level, and undoubtedly much of such legislation is
based primarily on common law or statutory nui-
sances. The enforcement of such laws is usually con-
ducted by the police, health, fire, engineering and safe-
ty departments or other subdivisions of municipal bur-
eaus. Only a small minority of such communities have
enacted comprehensive independent control authori-
ties.
With the advent of air pollution over large muni-
cipalities or extended metropolitan areas, a single and
unified authority armed with air pollution control laws
became necessary. The level of authority (city, coun-
ty, state, etc.) necessary to control air pollution is de-
termined primarily by the character of the pollution
zone. If the boundaries of a city contain the pollution
zone, then a municipal agency, or a bureau or division
of a municipal agency may suffice, if that agency and
the laws it promulgates and enforces lare authorized by
the police power of the state. If the pollution zone is
larger than the municipal area, or constitutes several
political organizations, then the control effort must be
conducted at a higher political level — at the county
or state level, for example. There are presently in the
United States five principal types of air pollution con-
trol authorities, aside from those which are vested in
the branches or divisions of agencies not devoted ex-
clusively to air pollution control.
a. Municipal Departments or Bureaus of Air Pollu-
tion Control. A good example is the City of New
York which, in 1952, instituted a Department of
Air Pollution Control. In this city a board of air
pollution control was established with the power
to promulgate, adopt and enforce rules aimed at
controlling air pollution within the boundaries of
New York City.
b. State Air Pollution Authority. This authority is
frequently established by smaller states. Dela-
p) 8 Baylor Law Review, 249, 1956, citing report of Arthur
C. Stern.
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The Law of Air Pollution Control
61
ware and Oregon have created organizations re-
sponsible for promulgating and enforcing rules
and regulations on a state-wide basis. The Oregon
Air Pollution Control Authority encourages cities
to maintain local control programs, and provides
them with technical assistance.
c. State Air Pollution Enabling Authority. Califor-
nia, in 1947, adopted the first state-wide air pollu-
tion control statute, but in doing so left the actual
enforcement to local air pollution control districts
on the county level. This type of act is called an
enabling act. Following its adoption in 1947, Los
Angeles County immediately set up a control dis-
trict and was later followed by San Bernardino,
Riverside, Orange and San Diego Counties. Un-
der a special provision of the Air Pollution Con-
trol Act (The Health and Safety Code) a nine-
county air pollution control district was formed
in the San Francisco Bay area. This consists of
Alameda, Contra Costa, Marin, Napa, San Fran-
cisco, San Mateo, Santa Clara, Solano, and Son-
oma counties.
d. Interstate Compacts. Establishment of interstate
compacts can arise when it becomes necessary to
control a pollution zone comprising several con-
tiguous metropolitan areas in neighboring states.
An air pollution problem exists in a well populat-
ed region which includes Staten Island, Manhat-
tan, and New Jersey. To control this regional
problem an interstate commission was authorized
by the legislatures of New Jersey and New York
to agree upon an adequate control program for
the areas, enforced by agencies within the respect-
ive states. The power to enter in such compact is
limited by consent of Congress which can, how-
ever, be given after such compact has been estab-
lished.1^ Federal approval came in 1956 when
Congress authorized this commission to carry out
the study.
e. International Compacts or Treaty. International
air pollution problems are encountered in the
Detroit-Windsor and in the Port Huron-Sarnia
areas along the borders of the State of Michigan
and Canada. Most of this air pollution results
from heavy marine traffic, but some originates
from stacks of industrial plants on both sides of
the border. This international problem is under
study by the International Joint Commission to
determine whether it can be controlled by regu-
lations resulting from a treaty between the Uni-
ted States and Canada.1'
q) Kennedy, H. W., reference 8, p. 389, which quotes Article I,
Section 10, clause 3, as follows: "No state shall, without the
consent of Congress . . . enter into any agreement or compact
with another state . . ." The courts have held that this consent
may be given by Congress after, as well as before, the agree-
ment between the States is made. State v. Joslin, 116 Kan.
615, 227 p. 543.
r) Cooper, W. S., reference 3, p. 424.
3. Source Regulations and Prohibition
If the primary authority is the state law, the
state may reserve the right to create and pass on all
control standards and regulatory statutes, or it may
delegate that power to local governments or control
authorities. When it is necessary to establish uniform
standards throughout the state, the law includes such
standards. But where controls are required for local
pollution problems only, the state delegates the rule-
making authority to the local control authority.
The statutes, ordinances, or rules and regulations
which are finally adopted for the purpose of control-
ling the sources of air pollution, fall into the following
categories:
a. Public Nuisance
A version of the common law nuisance is included in the
law which directly makes illegal any quantity of air contamin-
ants which has a detrimental effect on the health, comfort and
property of any considerable number of persons. Because the
nuisance does not incorporate specific standards, it must be es-
tablished on its own merits in each case.
b. Maximum Permissible Emission Standards
These are a class of regulations which prohibit quantities of
contaminants from a specific source in excess of standards speci-
fied. The standard may be stated in terms of (1) maximum opa-
city, shade, or optical density of the effluent (Ringelmann Stand-
ard), together with a time limit, (2) a maximum dust or particu-
late, or contaminant gas loading for effluent emissions either in
terms of grains per unit volume of stack gas, gas volume, or
weight of contaminant lost per weight of materials processed in
equipment.
c. Regulation of Use or Design of Equipment
This type of rule regulates the equipment or process con-
stituting the source of pollution by such means as will certainly
accomplish the desired reductions in the emission of air contam-
inants. This may be done by (1) banning the use of a certain
type or category of equipment or activity, (2) establishing de-
sign standards for usable equipment, (3) establishing operational
standards, and (4) requiring the use of specific types of control
equipment or control techniques.
It is assumed that the adoption of these equipment regula-
tions will result in reducing pollution emissions so that such
equipment or activity does not violate any of the other prohibi-
tions contained in the legal authority, such as the public nui-
sance or the maximum permissible emissions, as well as reduc-
ing emissions to desirable levels.
d. Regulation of Fuels or Fuel Composition
These regulate the use or composition of fuels themselves
and may require, for example, the washing, coking, briquetting
of coal, etc., specification of smokeless grades of fuels, the reduc-
tion of the sulfur content of fuel oils, reduction of the olefinic
hydrocarbons in gasoline, regulation of liquid vapor pressures,
etc. In such cases the regulation usually affects the producer,
rather than the consumer, of these fuels.
A comprehensive air pollution law generally in-
corporates all of these laws according to the need of
the control program being conducted. The actual cri-
teria on which these standards are based are considered
in Chapter 4 and elsewhere in this manual.
4. Registration of Pollution Sources (Permit and
Licensing Systems)
Most air pollution control authorities provide for
a system of source registration which may or may not
include a permit or licensing system. Permit or licens-
ing systems are one of the most effective types of
source control regulation in that all sources of air pol-
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62
Air Pollution Control Field Operations
lution are systematically and thoroughly reviewed for
compliance and air pollution potentials. The object of
these systems is to obtain permanent and continuous
compliance and to check the growth of the sources of
air pollution. Equipment capable of violating any of
the provisions of the control law, including the public
nuisance, is not permitted to operate in the pollution
zone. Some control authorities, however, may omit
this strict feature, but provide for a system of registra-
tion from which air pollution potentials only are de-
termined. (See Chapter 4.)
5. Enforcement Powers
In order to enforce the law, the air pollution
control officer and his deputies, i.e., air pollution in-
spectors and other enforcement personnel, must pos-
sess peace officer powers for the purpose of entering
industrial and commercial establishments and halting
vehicles on the public highway. The air pollution con-
trol law also classifies the types of violations involved,
such as misdemeanors, felonies, etc., and enables the
agency to take civil or criminal action against viola-
tors. Air pollution violations, however, are almost
always misdemeanors. Furthermore, the law may pro-
vide for offenses resulting from interference with the
accomplishment of inspectors' duties, non-cooperation,
circumvention, false documentation, refusal to submit
information, and operation of equipment without
permits.
6. Hearing or Appeals Procedures
Most laws of a control or regulatory nature con-
form to the principle of the separation of powers, i.e.,
distinguish between legislative, judicial, executive or,
in this case, enforcement, functions to provide checks
and balances and to avoid arbitrary conduct. Even
though an air pollution control authority may be pro-
vided for in the law, the three functions are created
independently: the law-making body in a board or
commission, the enforcement component in the control
agency itself, and the judicial in a specially constituted
appeal or hearing board, and the courts themselves.
Where a permit system is used, a hearing board is
mandatory, but procedure for appeal must also be pro-
vided for in those cases where immediate compliance
may result in hardship or cessation of a lawful busi-
ness. In such cases the air pollution control law pro-
vides for a variance procedure. Such a board is gen-
erally independent of the control agency proper, al-
though it is sometimes constituted in the rule-making
body.
7. Emergency Provisions
A comprehensive air pollution law provides the
control authority with emergency powers in the case
where an air pollution disaster is possible or immi-
nent. Such powers enable the control agency to shut
down all air polluting activity, conduct air monitor-
ing to detect worsening conditions, and notify the
sources of air pollution and the community of alert
levels.
Ill ENACTMENT OF AIR POLLUTION
CONTROL LAW IN CALIFORNIA
Although the exact year when smog was first
recognized as a problem in Los Angeles is not known,
the public appears to have first demanded relief from
air pollution immediately after World War II. News-
papers, in particular, began to expose the problem in
the public interest. During the summer of 1943, pub-
lic opinion was vehemently expressed through a vig-
orous editorial campaign conducted by the Los An-
geles Times. As a consequence, air pollution control
groups were set up under health department jurisdic-
tions — first by the city of Los Angeles, and then by
the county of Los Angeles in the unincorporated areas.
Additional smoke control ordinances were also passed
by many of the 45 cities then in the county. However,
these control efforts failed due to the multiplicity and
inadequacy of the control jurisdictions. It was soon
apparent that adequate control action could only be
taken by a single control authority with jurisdiction
over the entire pollution zone — the incorporated and
unincorporated areas of Los Angeles County.
Public protest led to action on various levels,
principally citizens' committees, associations and
leagues, and government. The first Citizens' Smog
Committee, headed by William Jeffers, a retired rail-
road president and wartime rubber "czar," was
formed. A Legal Advisory Committee, consisting of
noted lawyers and judges, followed. The League of
California Cities, the Board of Supervisors, and the
County Counsel's office of Los Angeles County all co-
operated in promoting and developing air pollution
control measures. As community action broadened,
scientists and experts studied the various aspects of the
Los Angeles problem in order that control legislation
could be advanced from valid technical assumptions.
A. The California Control Act
After presentation of Assembly Bill No. 1, which
crystallized the final control proposals, the 1947 session
of the California Legislature voted to add Chapter 2,
"Air Pollution Control District", to Division 20 of the
Health and Safety Code, relating to the control and
suppression of air pollution. Thus, the first state-wide
air pollution control statute was enacted.
The California Act is an enabling type of legisla-
tion which provides the legal basis for the establish-
ment of air pollution control districts on a local option
basis by the counties of California. The law is organ-
ized into seven articles of the State Health and Safety
Code. These are:
ARTICLE 1 — Creation and Functioning of Districts
In essence this article states the conditions and
procedures by which air pollution control districts can
be established by the counties of California.
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The Law of Air Pollution Control
In the preamble of this article, the legislature de-
termines that air pollution problems exist in certain
portions of the state by declaring that . . . (Sec.
24198)
. . the people of the State of California have a
primary interest in atmospheric purity and free-
dom of the air from any air contaminants and
that there is pollution of the atmosphere in many
portions of the State which is detrimental to the
public health, safety and welfare of the people of
the State.
The legislature defines some of these air contami-
nants to include "smoke, charred paper, dust, soot,
grime, carbon, noxious acids, fumes, gases, odors, par-
ticulate matter, and other air contaminants," (Sec.
24208), and goes on to say that it is necessary to pro-
vide for air pollution control districts in those portions
of the state where regulations are necessary and
feasible to reduce air contaminants to safeguard life,
health and property and the public welfare and to
make possible the comfortable enjoyments of life and
property (Sec. 24199). The legislature then delegates
to the board of supervisors of each county the power
to determine that the air within such county is so
polluted with air contaminants as to be injurious to
health or an obstruction to the free use of property of
a considerable number of persons, or which interferes
with the comfortable enjoyment of life or property
(24203, 24204). Once the board of supervisors of any
county has determined that such a condition exists, an
air pollution control district coterminous with that
county is created with all of the authority of the State
Act (24205).
ARTICLE 2 — Officers
This article states that the supervisors of each
county are the members of the air pollution control
board of the air pollution control district of that
county, and that the air pollution control board shall
appoint an air pollution control officer, and a hearing
board consisting of three members. Two members of
the board shall; haveibeeni admitted to the practice of
law in the State of California, and one member shall
be either a mechanical or chemical engineer. In addi-
tion, this law provides that the air pollution control
officer, his assistants, deputies, etc., are entitled to civil
service provisions and benefits.
ARTICLE 3 — Prohibitions
This article deals primarily with standards pro-
hibiting the emissions of contaminants, provided that
a control district has been activated. These prohibi-
tions are vital to the enforcement operation of the dis-
tricts and are utilized in a great many enforcement
actions. These are principally Section 24242, excessive
emissions of visible contaminants, and Section 24243,
public nuisances. In addition, the law also establishes,
in Section 24246, the right of entry into any industrial
or commercial establishment during reasonable hours,
and the right to halt all vehicles which do not run
on rails.
Section 24242 reads as follows:
A person shall not discharge into the atmosphere
from any single source of emission whatsoever
any air contaminant for a period or periods aggre-
gating more than three minutes in any one hour
which is: (a) as dark or darker in shade as that
designated as No. 2 on the Ringelmann Chart, as
published by the United States Bureau of Mines,
or (b) of such opacity as to obscure an observer's
view to a degree equal to or greater than does
smoke described in subsection (a) of this section.
There are certain exceptions to the provisions of
Section 24242 set forth in Section 24245 and 24251 of
the Health and Safety Code. In general, these excep-
tions apply to agricultural operations, the abatement
of a fire hazard, and the instruction of public em-
ployees in fire fighting methods.
Section 24243 states the public nuisance as
follows:
A person shall not discharge from any source
whatsoever such quantities of air contaminants or
other material which cause injury, detriment,
nuisance or annoyance to any considerable num-
ber of persons or to the public or which endanger
the comfort, repose, health or safety of any such
persons or the public or which cause or have a
natural tendency to cause injury or damage to
business or property.
The provisions of Section 24243 do not apply to
odors emanating from agricultural operations and the
growing of crops or the raising of fowls and animals.
The law provides that any person who violates
these sections is guilty of a misdemeanor, and enables
an air pollution control district to enjoin in a civil
action any violators of these provisions.
Section 24246 relates to refusal of entry, or failure
to halt vehicles as follows:
The Air Pollution Control Officer, during reason-
able hours, for'the purpose of'enforcing or admin-
istering this chapter, or any provisions of the
Vehicle Code relating to the emission or control
of air contaminants, or of any order, regulation or
rule prescribed pursuant thereto, may enter every
building, premises, or other place, except a build-
ing designed for and used exclusively as a private
residence and may stop, detain, and inspect any
vehicle, designed for and used on a public high-
way but which does not run on rails. Every per-
son is guilty of a misdemeanor who in any way
denies, obstructs, or hampers such entrance, or
such stopping, detaining, or inspection of such
vehicle, or who refuses to stop such a vehicle
upon the lawful order of the Air Pollution Con-
trol Officer.
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64
Air Pollution Control Field Operations
ARTICLE 4 — Rules and Regulations
Perhaps the most important feature of the Cali-
fornia State Health and Safety Code is Article 4 which
provides the air pollution control district with the
power and procedures for enacting rules and regula-
tions as may be required to control any air pollution
control problem and to accomplish the purposes of this
law. The California Health and Safety Code thus en-
ables the control districts to be flexible in handling
problems of a local nature and provides a potential
whereby future or unanticipated air pollution prob-
lems can be legally regulated. The specific rules and
regulations enacted by the air pollution control board
of the district (the board of supervisors) provide the
specific battery of administrative law required to con-
trol local air pollution problems in California.
New rules and regulations necessary for the
proper administration of Chapter 2, Division 20, of the
Health and Safety Code and those necessary to reduce
the amount of air contaminants released within the
control district can only be enacted after first holding
a public hearing. Ten days notice is required before
the hearing is held.
The article also provides that the air pollution
board may require permits for the building, erection,
alteration, or operation of any equipment capable of
emitting air contaminants and provides that if an air
pollution control district adopts a permit system, any
person who constructs, alters, or uses such equip-
ment without a permit, is guilty of a misdemeanor.
Detailed exceptions, however, are made in Section
24265. In this section, equipment of a minor nature,
or any for which the permit process is inapplicable,
or impractical to enforce, is exempted.
To make the permit system more workable, the
law provides that the air pollution control officer may
require from either the applicant for a permit, or
the holder of a permit, information, analysis, plans,
and specifications which disclose the nature, extent or
quantity of air contaminants released by the equip-
ment; and provides that if a person fails to supply such
information he is guilty of a misdemeanor. The air
pollution control officer may also suspend his permit.
ARTICLE 5 — Variances
In essence, this article provides for the granting
of variances from the requirements of either the state
law or the rules and regulations of the air pollution
control district. Such variances can only be granted
after a public hearing before the hearing board. The
hearing board is granted wide discretion in the weigh-
ing of equities which may arise in each case, although
limited by conditions set forth in Section 24296 of the
Health and Safety Code. The hearing board, for ex-
ample, cannot grant a variance for longer than one
year. A variance may be continued from year to year,
however, without a further hearing, provided the air
pollution control officer agrees to the extension of the
variance.
ARTICLE 6 — Procedure
This article provides a procedure whereby any
person deeming himself aggrieved by a decision of the
hearing board may file a proceeding in the Superior
Court to determine the reasonableness and legality of
the action of the hearing board, and entitles the person
to a trial de novo and an independent determination
by the court on all the issues.
ARTICLE 7 — Unified Air Pollution Control Districts
This article provides a procedure by which two or
more counties having activated air pollution control
districts may merge the several districts into one.
B. Enactment of Rules and Regulations
in Los Angeles County
Under authority of the Health and Safety Code,
the Board of Supervisors of Los Angeles County held
hearings in the fall of 1947 and found that the need
existed for the establishment of an Air Pollution Con-
trol District. The Los Angeles County Air Pollution
Control District was activated on October 14, 1947, and
on December 30. 1947, the first Rules and Regulations
guiding the conduct of the Los Angeles County Air
Pollution Control District were enacted. Additional
rules and regulations were subsequently added as the
need arose.
The Rules of the Los Angeles County Air Pollu-
tion Control District are divided into seven regula-
tions, as follows: I "General Provisions," II "Permits,"
III "Fees," IV "Prohibitions," V "Procedure Before
the Hearing Board," VI "Orchard Heaters," VII
"Emergencies."
The Rules and Regulations are quite extensive
and should be consulted for detailed information. This
chapter will attempt to summarize these Rules to in-
dicate the scope of the authority of the Los Angeles
County Air Pollution Control District, and a few sali-
ent characteristics of these Rules which have either
been contested and validated in the courts, or form
the basis of an active control program.
REGULATION I — General Provisions
These define important terms employed in the
Rules such as "Los Angeles Basin," the various con-
taminants and equipment, as well as describing stand-
ard conditions in making calculations for analyses and
source tests.
REGULATION II — Permits
The permit system of the Los Angeles County Air
Pollution Control District is one of the most important
features of the air pollution control program. In gen-
eral, it requires owners, operators, or lessees to apply
for permits to construct and operate any equipment
capable of emitting air contaminants. If the applicant's
plans, specifications, and actual field tests show that the
equipment can operate within the limits allowed by
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The Law of Air Pollution Control
law, a permit is granted. If the equipment is capable
of emitting contaminants which create a public nui-
sance, or violate any of the sections of the State Health
and Safety Code or the Rules and Regulations of the
Air Pollution Control District, then permission to con-
struct such equipment or permit to operate equipment
already constructed is denied.
The effectiveness of the permit system as far as
the control program is concerned consists, in essence,
of eliminating from use equipment which emits ex-
cessive air contaminants or of requiring the reduction
of emissions from equipment to within allowable limits
by modifying design or process, or constructing ade-
quate control equipment. The construction and opera-
tion of control equipment also must be authorized by
permit. Thus, the permit system is a positive means
of controlling air pollution.
REGULATION III — Fees
Authorizes and states conditions under which fees
may be paid by applicants for permits to construct and
operate equipment, according to a specified fee
schedule.
REGULATION IV — Prohibitions
The rules contained in this regulation are in-
tended to prohibit and regulate the emission of certain
air contaminants, or certain types of equipment, and
are of primary concern to field control operations. As
these rules are applied to engineering problems, and
touch upon many sciences, extraordinary care is re-
quired to frame them so that they fulfill their function.
Although these rules have been tested frequently in
the courts, no substantive rule of the Los Angeles
County Air Pollution Control District yet has been
held to be unconstitutional. Over a period of years
these prohibitions have been found to be practical and
intelligible to those who must observe them, as well
as to those who must enforce them. 13) The prohibition
rules are estimated to have resulted in controls which
have prohibited the emission of 3640 tons of pollution
into the air each dayi3), as shown in Table III-l.
The basic operational rules in this series are Rule
50, Ringelmann Chart, which is an exact reiteration of
Section 24242, quoted previously, and Rule 51, Public
Nuisance, which is an exact reiteration of Section
24243. Violations of these rules can be ascertained
through field investigation. However, the rules on
combustion contaminants, dust and fumes, etc., require
an analysis of the emission in order to determine com-
pliance. A summary of these rules can be noted in
Table III-2.
a. Rule 50 -— The Ringelmann Chart
The Rule which is basic to the enforcement opera-
tion is Rule 50, which provides standards for the read-
ing of densities and opacities of visible emissions in
determining violation of, or compliance with, the law
in the field.
The importance of this rule, of course, lies in the
fact that it presents an effective and practical standard
by which excessive emissions can rapidly be deter-
mined. Without this Rule, the enforcement operation
would be severely handicapped. This Rule, however,
has been subject to several searching court tests con-
cerning (1) the validity of using the Ringelmann
Chart as a standard; and (2) the validity of reading
smoke without physical reference to the Ringelmann
Chart in the field, and other technical matters relating
to the reading of smoke which are discussed in detail
in Chapter 10. (See also Figure X-l.)
In the validation of Section 24242 (and hence,
Rule 50), the Appellate Division of the California Su-
preme Court in the case of People v. International
Steel Corporation s) determined that it was permis-
sible for a statute to refer to and adopt in the descrip-
tion of a prohibited act an official publication of a
United States board or bureau established by law, such
as the United States Bureau of Mines, publisher of the
Ringelmann Chart. The court, in reviewing the Ringel-
mann Chart itself, came to the conclusion that the stat-
ute adopted was not lacking in certainty, and that the
line in the standard between permission and prohibi-
tion is a valid matter of legislative discretion.
In a series of cases which were consolidated on
appeal, People v. Plywood Manufacturing Company,
People v. Shell Oil Company, People v. Union Oil
Company, and People v. Southern California Edison
Company, *' the Appellate Division of the Superior
Court, in a lengthy and detailed opinion, stated that
(1) both subsections of Section 24242 were constitu-
tional and enforceable; and (2) a witness can testify
to the opacity or density of visible emissions without
using a Ringelmann Chart at the scene, provided that
he has been properly trained. "We see no reason to
depart from this conclusion that a witness may testify
although he did not have a Ringelmann Chart actually
in the field with him at the time that he made his
observation. One does not have to have a color chart
in his hands to recognize a red flower, a blue sky, or a
black bird. The question is one of credibility not com-
petency. Nor, do we assume that we see any difficulty
arising from the fact that a plume of smoke, for ex-
ample, may appear less dark than #2 Ringelmann
from one position, but darker than #2 Ringelmann
from another point. If the contaminant has the sub-
stance that fairly viewed from any position and gives
a shade of dark or darker than #2 Ringelmann, it is
condemned no matter how light the color may look to
someone situated at another vantage point." In gen-
eral, other rulings on Section 24242 in these and other
s) 102 Cal. App. (2d) (Supp.) 935, 938-939, 226 Pac. (2d)
587, 590 (1951)
t) People v. Plywood Mfr's. of Calif., Shell Oil Co., Union Oil
Co., and Southern California Edison Co., Cal. Juris. 291 P2d
578 137 CA2 SUP. 859.
-------
66 Air Pollution Control Field Operations
TABLE III - 1
EFFECT OF LOS ANGELES COUNTY A.P.C.D. RULES ON EMISSIONS FROM STATIONARY SOURCES
MAY 1961
EMISSION SOURCE
lAPCO
CATEGORY IRULE-^-
INCINERATION & REFUSE BURNING
Municipal incinerators
Industrial ' '
Commercial ' '
Residential ' '
Open fires
FUEL OIL BURNING
Power plants, refineries & others
PETROLEUM REFINING
Catalytic cracking
Storage
Separators & sewers
Flares
Slowdown & relief valve systems
Refinery gas burning
Others
PETROLEUM MARKETING
Bulk Storage (Ref. storage
not included)
Bulk loading
Service station storage
Service station loading
PETROLEUM PRODUCTION
Storage
Other (gas blowoff, etc.)
METALS
Furnaces for magnesium
" " aluminum
' ' " brass
" " bronze
" lead
Grey iron melting cupolas
Electric steel melting furnaces
Open hearth " " "
Galvanizing kettles
Other
CHEMICAL
Sulfur and sulfuric acid
Phosphates and phosphoric acid
Fertilizer
Other
MINERAL
Asphalt batching
Asphalt roofing saturators
Insulation
Glass & frit furnaces
Concrete batching
Other
ORGANIC SOLVENT USE
Surface Coating
De greasing
Dry cleaning
Rotogravuring
Paint bake ovens
Varnish cooking
Other
MISCELLANEOUS
Rendering Inedible )
Coffee roasting
Meat smokehouses
Feed & grain
Wood processing
Other
TOTALS OF CONTAMINANTS REDUCEL
BY A.P.C.D. RULE
CONTAMINANTS PREVENTED FROM ENTERING L.A. ATMOSPHERE UN TONS PER DAY
Hydrocarbons & Other
Organic Gases
56
350
5
1
56
57.58
56.
125
25
Jft
10
x
05
61
50
x
50
62
7
7
OTHER
18
x
125
90
x
X
225
20
4
R.5~o;
x
1
19
X
502
Olefins,
Lhsaturates
63
(9a)
x
(la)
«
>
>
>
y
"X
X
s
X
31
>
x
x
x
620 *
Snoke
:baaue Plume
57,56
0 58.1
It X
c
c
c
62
x
X
X
X
Paniculate
Matter
51
x
X
X
X
x
X
X
X
X
x
52
X
X
Combustion
Contaminants
5Jk
X
X
X
X
X
57,56
58.1
75
75
62
40
0
Ists
umes
1 5»
5
75
7
7
6
x
X
20
25
2
2
1
1
IOC
'>
2
11
?6S
Odors
i at
X X
X
X
x
X
,
57,58
58.1 59
X
X
X
X XX
Tnl-alg Qf
Contaminants
Categories
S16»
4JO
770
1S50
x
* 55
225
95
65
135
20
15
x 3640
This figure is not included as a reduction in total emissions but a change of type of hydrocarbons emitted to the
atmosphere (about 159 tons/day of olefins are converted to other hydrocarbon compounds in the automobile engine).
Contaminant reduction not capable of being measured quantitatively.
Source: Reference 13
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The Law of Air Pollution Control
67
TABLE III-2
TYPES OF PROHIBITIONS
RULES AND STATE CODE SECTIONS PRINCIPALLY INVOLVED IN ENFORCEMENT OPERATIONS
EXCESSIVE EMISSIONS
Visible
Sec. 24243.
Public Nuisance.
Sec. 24242
Contaminants ex-
cess of #2 Ring-
elmann or 40%
opacity for more
than three min-
utes in any one
hour.
Sec. 27153.
Vehicle Code. Any
unduly excessive
emissions for ve-
hicles.
Invisible
Sec. 24243.
Public Nuisance.
Rule 52. Particu-
late matter excess
of .4 gr. cu. ft.
Rule 53a. Sulfur
Compounds, .2%
by volume as SO2.
Rule 53b. Com-
bustion Contami-
nants, .3 gr. cu. ft.
gas, calculated to
12% CO,.
Rule 54. Dusts ex-
ceeding amis, for
each process
weight on gradu-
ated scale.
UNAUTHORIZED
CONSTRUCTION OR
OPERATION OP
A/P EQUIPMENT
Sec. 24278. Opera-
tion or erection
under suspended
or revoked per-
mit.
Sec. 24279. Opera-
tion or erection
without permit or
authority to con-
struct.
Sec. 24280. Opera
tion or erection
contrary to provi-
sions of permit.
EQUIPMENT
REGULATION
Rule 56 requires
vapor loss control
devices for storage
tanks under speci-
fied conditions.
Rule 59 requires
vapor loss control
devices for oil-
water separators
under specified
conditions
Rule 61 requires
vapor loss control
devices for gaso-
line loading facili-
ties under speci-
fied conditions.
Rule 64 requires
incineration of
malodors from an-
imal rendering in-
dustries.
EMERGENCIES
Rule 157 burning
of rubbish in open
fire or s/c inciner-
ator during first
alert.
Rules 158 and 159.
Acting contrary to
the instructions of
the air pollution
control officer.
BANS
Rule 57 open fires.
Rule 58 s/c incin-
erators.
Rule 62 bans the
use of high sulfur
fuels seven
months each cal-
endar year.
Rule 63 bans the
use of gasoline
with high olefinic
content.
NON-COOPERATION
AND CIRCUMVEN-
TION
Rule 60. Circum-
vention, reducing,
concealing or di-
luting emissions
which would oth-
erwise violate.
Sec. 24246. Refus-
al of entry or re-
fusal to halt ve-
hicles.
decisions have upheld the practical use of the Ringel-
mann Chart in the field.
b. Rule 51—Nuisance
The wording of this rule is identical to that of
Section 24243, quoted previously. According to this
rule, whatever tends to endanger life or property or
whatever affects the health of the community is gen-
erally a public nuisance. The nuisance, however,
must affect the community at large and not merely
one or a few persons. It is sufficient to establish a
crime from a nuisance if it contributes seriously to the
discomfort of an area.
An important feature of the nuisance is that it is
not a crime which requires a specific intent. The
intent of a person to maintain a nuisance which is
dangerous or offensive to the public is entirely im-
material.
Moreover, nuisances cannot be justified by the
fact that the public is benefited as well as injured by
the act alleged to be a nuisance, as, for example, that
the business is useful or necessary or that it contributes
to the wealth and prosperity of the community.
Neither does mere lapse of time give a right to main-
tain a nuisance nor the fact that it was first established
away from the population, and that the population had
later approached.
The public health, the welfare and safety of the
community, are matters of paramount importance, to
which all pursuits, occupations, and employments of
individuals inconsistent with their preservation must
yield.")
There is a conflict of authority, however, on this
point and it would appear that the law does balance
equities with respect to the particular surroundings,
the character of the business and its particular loca-
tion. In one case, it was said, "People who live in great
cities that are sustained by manufacturing enterprises
must necessarily be subject to many annoyances and
positive discomforts by reason of noise, dirt, smoke and
odors more or less disagreeably produced by and re-
sulting from the business that supports the city. They
can only be relieved from them by going into the open
country."v^
The enforcement procedure for the public nui-
sance statute cannot be standardized and must, there-
fore, be conducted according to the merits of each case,
due to the uncertainty of this law. A proceeding under
the nuisance section of the Health and Safety Code of
California must establish the elements of the crime
and such additional testimony as is necessary to prove
that it caused injury, detriment, nuisance or annoy-
ance to any considerable number of persons or to the
public. Also, proof that it endangered the comfort,
repose, health and safety of any such persons or the
public. The conduct of handling a Public Nuisance in-
spection is described in detail in Chapters 12 and 13.
c. Rule 52 — Particulate Matter
This rule establishes the maximum allowable
limits for the discharge of particulate matter. It limits
the discharge of this contaminant from any source to
a maximum concentration of .4 grains/cu. ft. of gas.
u) Com. v. Upton, 6 Gray (Mass.) 473.
People v. Detroit White Lead Works, 82 Mich. 471.
v) Com. v. Miller, 139 pa. 77, 214 A. 138, 23 Am. St. Rep.
170.
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68
Air Pollution Control Field Operations
This rule, however, does not apply when the particu-
late matter is a combustion contaminant.™)
d. Rule 53 — Specific Contaminants
This rule establishes the maximum allowable
limits for the discharge of sulfur compounds and com-
bustion contaminants. These limits are:
Rule 53a. Sulfur compounds calculated as sulfur
dioxide (S02): 0.2 per cent, by volume.
Rule 53b. 0.3 grain per cubic foot of gas calcu-
lated to 12 per cent of carbon dioxide
at standard conditions.
The present limit of .3 grains was adopted on Jan-
uary 16, 1958; prior to this time the limit was .4
grains. This rule is one of the standards which must
be met by the performance of any multiple chamber
incinerator constructed for operation in Los Angeles
County.
e. Rule 53.1 — Scavenger Plants
The rule sets forth the conditions under which a
scavenger or recovery plant may operate under per-
mit. Such plants are built in Los Angeles County to
recover sulfur products, which might otherwise be
emitted to the air.
f. Rule 54 — Dust and Fumes
This rule establishes the maximum allowable
limits for the discharge of dusts and fumes according
to the process weights of materials entering the pro-
cess. The maximum allowable limit in pounds per
hour are graduated according to the weights of mater-
ia|ls processed per hour. The maximum emission
allowed under Rule 54 is 40 pounds per hour where
60,000 or more pounds are processed in the equipment
in any given hour.
g. Rule 56 — Storage of Petroleum Products
This rule sets forth the type of control equipment
that can be used for the control of hydrocarbons from
the storage of gasoline and certain petroleum distil-
lates. This rule provides that any tank of more than
40,000 gallons capacity used for storing gasoline or
any petroleum distillate having a vapor pressure of 1 Vz
pounds per square inch absolute or greater, must be
equipped with a vapor loss control device. This rule
also provides for the installation of floating roofs, vapor
recovery systems, or other collection equipment of
equal efficiency.
h. Rule 59 — Oil-Effluent Water Separators
This rule regulates the type of control equipment
that can be used for the control of hydrocarbons from
oil-water separators. It provides that such equipment
w) Participate matter may be defined as any material, except
uncombined water, which exists in a finely divided form as
a liquid or solid at standard conditions. Combustion con-
taminants are defined by the Rules and Regulations as par-
ticulate matter discharged into the atmosphere from the
burning of any kind of material containing carbon in a
free or combined state.
must either be covered, provided with a floating roof,
equipped with a vapor recovery system, or equipped
with other equipment of equal efficiency provided that
the effluent water handled by the separator contains
a minimum of 200 gallons per day of petroleum
products.
i. Rule 61 — Gasoline Loading into Tank Trucks
and Trailers
This rule sets forth the type of control equipment
that can be used for the control of hydrocarbons from
the loading of gasoline into tank trucks. It provides
for the installation of vapor collection and disposal
systems on bulk gasoline loading facilities where more
than 20,000 gallons of gasoline are loaded per day and
requires the loading facilities to be equipped with a
vapor collection and disposal system. The disposal
system employed must have a minimum recovery
efficiency of 90 per cent or a variable vapor space tank
compressor and fuel gas system of such capacity as to
handle all vapors and gases displaced from the trucks
being loaded.
j. Rule 62 — Sulfur Content of Fuels
This rule bans the use of high sulfur fuel oils
seven months each calendar year. The rule bans
gaseous fuels 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 a sulfur content in
excess of 0.5 per cent by weight. This rule is in effect
beginning with April 15, and ending with November
15, a period in which natural gas is in supply.
k. Rule 63 — Gasoline Specifications
This rule prohibits the sale and use of fuel for
motor vehicles having a degree of unsaturation exceed-
ing a bromine number of 30 after June 30, 1960, and
a degree of unsaturation exceeding a bromine number
of 20 after December 31, 1961.
1. Rule 64 — Reduction of Animal Matter
This rule requires that malodors from all equip-
ment used in animal rendering be either incinerated
or processed in an odor-free manner under conditions
stated in the rule.
m. Rules 57 and 58 — Open Fires and Incinerators
These rules ban the burning of combustible ref-
use in the Los Angeles Basin in open fires and single-
chamber incinerators.
REGULATION V — Procedure Before the Hearing Board
The California State Health and Safety Code
specifically authorizes and outlines the functioning
and purposes of the Air Pollution Control Hearing
Board. Regulation V of the Rules and Regulations fur-
ther outlines the procedures to be used by the Air Pol-
lution Control District before the Hearing Board.
-------
The Law o/ Air Pollution Control
The Air Pollution Control Hearing Board is an
administrative tribunal with power limited to the
adjudication of the actions of the control district. The
Hearing Board is not organizationally connected to
the Air Pollution Control District, but assumes prece-
dence over the District in issuing decisions in specific
cases. The Hearing Board is appointed by the Air Pol-
lution Control Board (the Board of Supervisors) and
consists of three members. Two members are admitted
to the Hearing Board who practice law in the state,
and a third member is a chemical or mechanical
engineer.
The purpose of the Hearing Board in general is to
weigh equities involved in the rights of individuals
in conflict with the provisions of Chapter 2, Division
20, of the State Health and Safety Code and the Rules
and Regulations of the Air Pollution Control District.
The Hearing Board is thus given the power in indi-
vidual instances to permit variances of the law, to hear
appeals made when denials for permit applications
have been issued by the District, and to weigh cases in
which the District seeks revocation of permits. The
decisions of the Hearing Board do not involve fines or
imprisonment, but are intended to direct both the
District and the petitioner in a course of action which
will abate air pollution within the limitations of both
public and private property rights.
The decisions of the Hearing Board are not abso-
lute and may be tested further in the courts. Either
the individual or the Air Pollution Control District
itself may file a special proceeding in the Superior
Court to determine the reasonableness and legality of
any action of the Hearing Board. The persons taking
such action are then entitled to a completely new
trial in obtaining an independent determination of the
reasonableness and legality of the Hearing Board
action. The decisions of the Superior Courts, of course,
can be further appealed.
REGULATION VI — Orchard or Citrus Grove Heaters
This Regulation deals with the discharge of un-
consumed solid carbonaceous matter from orchard
heaters. This regulation was enacted in the fall of
1949 following the cold period in the winter of 1948-
1949, when householders in the citrus area of the Los
Angeles Basin requested that action be taken to solve
this problem through the Air Pollution Control
District.
It should be pointed out that in the citrus areas of
California and Florida, orchard heating equipment is
utilized on nights when the temperature falls below
freezing to prevent frost damage to crops and trees.
When Los Angeles County was predominantly
agricultural, a black pall of smoke from these sources
was apparent on mornings following the frost, even in
downtown Los Angeles area. This regulation lim-
its emissions from orchard heaters to 1 gram per
minute and specifies procedures and conditions for
obtaining permits, and prohibits or qualifies the use
of certain makes of heaters.
REGULATION VII — Emergencies
This regulation was advanced and adopted in
1954 as a result of widespread concern among the gen-
eral public, lay groups and medical groups that Los
Angeles might be approaching a London-type disaster.
Although later evidence has failed to substantiate this
view, the concern was great enough that the 1954
Grand Jury urged the establishment of an official and
orderly disaster-prevention program by the County
Air Pollution Control District. This regulation is prob-
ably the first air pollution legislation of this type.
The regulation is designed to prevent the excess-
ive buildup of air pollutants and to avoid any possibil-
ity of a catastrophe caused by toxic concentrations of
air contaminants. It describes procedures required for
the sampling and measurement of toxic air pollutants;
declaration of alert stages; notification of law enforce-
ment agencies and other local public officials; curtail-
ment of rubbish burning, vehicular traffic, and shut-
down of industry; and other activity contingent upon
a state of emergency.
The responsibility for the disaster-prevention pro
gram rests with the Air Pollution Control Officer and
the District. This responsibility in the rules contained
in this regulation specifies various requirements.
These are:
a. That an air sampling network be established and
maintained, consisting of at least six permanently
located stations which monitor the atmosphere con-
tinuously for four specific contaminants — ozone,
sulfur oxides, nitrogen oxides and carbon monox-
ide. The alert stages for the toxic levels of these
contaminants are shown in Table 1-15, page 33.
b. That the Control Officer develop detailed plans call-
ing for the shutdown of significant air pollution
sources in the event "alert stages" are reached for
any of the four contaminants enumerated in the
rule. According to which alert level is reached, the
District initiates the appropriate action:
(1) During the first alert level the regulation pro-
hibits all refuse burning within the limits of the
Los Angeles Basin and requires the Control Of-
ficer to secure the voluntary cooperation of the
public in limiting use of all privately-owned
vehicles.
(2) During the second alert level the Control Officer
requests industrial establishments to implement
"voluntary" shutdown plans and in the event
the implementation of these plans fail to halt
rising concentrations of contaminants, the Con-
trol Officer is authorized, with the advice of a
special "emergency action committee" and with
the approval of the Air Pollution Control Board,
-------
70
Air Pollution Control Field Operations
to implement compulsory curtailment activities
as may be necessary.
(3) During the third alert level the Air Pollution
Control Board requests the Governor to declare
a state of emergency and is authorized to take
vigorous police action as set forth in the Cali-
fornia Disaster Act.
c. The Control Officer was given the further respon-
sibility for communicating alert levels to the pub-
lic and to principal law enforcement agencies by
means of the Sheriff's teletype and radio systems,
air polluting industrial plants and processes which
require "alert" data in order to effect prearranged
plans designed to reduce the output of air contam-
inants, and to Air Pollution Control District per-
sonnel. Under Rule 155.2 of this Regulation vari-
ous industrial categories are listed which are re-
quired to maintain radio communication systems
capable of receiving messages of the Air Pollution
Control District's base station.
d. The final responsibility assigned to the Control
Officer involves the continuing revision, adjust-
ment, and improvement of the disaster-prevention
program. To assist the Control Officer in this re-
spect, a fifteen-member scientific committee was
activated under the regulation, consisting of medi-
cal and air pollution experts. This committee was
entrusted with the responsibility for studying and
recommending to the Control Officer the most
"suitable methods for measurement of air pollut-
ants" and for recommending any changes in the
alert standards.
In order that the Air Pollution Control District
fulfill its responsibility in enforcing the Rules of this
Regulation, enforcement personnel are equipped with
emergency vehicles and two-way radios. It is the task
of the Enforcement Division of the Air Pollution Con-
trol District to enforce the provisions of the Regula-
tion. Rule 161, for example, states:
When an alert has been called the Air Pollution Control
Officer, the Sheriff, their deputies, and all other peace
officers within the Basin shall enforce the appropriate pro-
visions of this regulation and all orders of the Air Pollu-
tion Control Board or the Air Pollution Control Officer
made pursuant to this regulation against any person who,
having knowledge of the declaration of an alert, refuses to
comply with the rules set forth in this regulation or any
order of the Air Pollution Control Board or the Air Pol-
lution Control Officer made pursuant to this regulation.
The principal provisions enforced under Regula-
tion VII are Rule 157, first alert, Rule 158, second
alert, and Rule 159, third alert; and any "order of the
Air Pollution Control Board or the Air Pollution Con-
trol Officer made pursuant to this regulation." The
enforcement procedure and the data gathering activi-
ties in enforcing these rules are dependent upon the
conditions which obtain during the state of emergency
and the exact nature of the orders given by the Air
Pollution Control Officer.
REFERENCES
1. California State Health and Safety Code, Chapter 2, Division 20.
2. Chass, R. L., Pratch, M., Atkisson, A. A., Air Pollution Disas-
ter-Prevention Program of Los Angeles County, 50th Ann. Meet.
of the Air Pollution Control Association, St. Louis, Missouri,
22 pp., June 6, 1957.
3. Cooper, W. S., "Solving Interstate Air Pollution Problems,"
Proceedings: National Conference on Air Pollution, United
States Public Health Service, pp. 416-426, November 18-20,
1958.
4. Hocker, A. J., draft material on Air Pollution Control District
Rules and Regulations.
5. Interstate Sanitation Commission, New York, New Jersey, Con-
necticut, Smoke and Air Pollution, 16 pp. February 1958.
6. Kennedy, H. W., The History, Legal and Administrative As-
pects of Air Pollution Control in the County of Los Angeles,
Report submitted to the Board of Supervisors of Los Angeles
County, 83 pp., May 9, 1954.
7. Kennedy, H. W., The Legal Aspects of Air Pollution Control
with Particular Reference to the County of Los Angeles, Sou-
thern California Law Review, V. 27, No. 4, pp. 373-398 inc.,
July, 1954.
8. Kennedy, H. W., Levels of Responsibility for the Administra-
tion of Air Pollution Control Programs.
9. Kennedy, H. W., "Levels of Responsibility for the Administra-
tion of Air Pollution Control Programs", Proceedings: National
Conference on Air Pollution, United States Public Health Serv-
ice, pp. 389-400 incl., November 18-20, 1958.
10. The Los Angeles Air Pollution Control District Rules and Regu-
lations.
11. Mestad, John B., Legal Aspects of Air Pollution Control, Air
Pollution Control District, material in preparation.
12. Prosser, William L., Handbook of the Law of Torts, West Pub-
lishing Co., 2nd Ed., Chapter 14, p. 390, 1955.
13. Kennedy, H. W., Griswold, S. S., The Purpose of Los Angeles
County A.P.C.D. Rules and Regulations and Their Effect on
Emissions from Stationary Sources, report to the Air Pollution
Control Board, Los Angeles County Air Pollution Control Dis-
trict, June 1961.
-------
CHAPTER FOUR
ELEMENTS OF THE AIR POLLUTION CONTROL PROGRAM
Once a control authority has been established, it
will devise a plan of action; i.e., a comprehensive air
pollution control program. The control program will
be based partially on the past history of control efforts
in other communities, and partially on the need for
special solutions to problems unique to the community.
Regardless of such considerations, however, the basic
elements of an officially sponsored control program re-
main the same from community to community. These
are:
1. RESEARCH AND INVESTIGATION. Identification and
evaluation of causes and effects of, and solutions to,
both the community-wide air pollution or smog
problem, and specific or localized air pollution
problems.
2. CONTROL STANDARDS. Promulgation of control
standards based on confirmed research findings and
air quality standards.
3. SOURCE REGISTRATION. Registration of the sources
of air pollution in order to determine pollution po-
tentials for (1) locating the need for remedial or
preventive measures, (2) estimating trends in pol-
lution potentials and atmospheric concentrations,
(4) establishing evidence for anti-pollution legisla-
tion, and (5) planning field control operations.
4. FIELD CONTROL OPERATIONS. Inspection of the
sources of air pollution and enforcement of the air
pollution law to obtain minimum pollution poten-
tials and solutions to specific air pollution prob-
lems.
Although the elements of the control program are
more or less fixed, control policies vary in strictness,
scope, and depth from community to community, and,
from time to time within the same control agency.
The differences in policy may be seen in terms of two
situations. On the one hand, standards resulting from
a control program may be few in number, easy to
comply with, flexible and applicable only to some
sources of air pollution, while on the other hand, legal
standards may be certain, inflexible, strict, and apply
to all.
Where there are relatively few sources of air
pollution, as in a medium or small sized community,
air pollution problems may be handled with a mini-
mum of government-sponsored control. These com-
munities may provide only a few legal sanctions such
as the public nuisance or visible smoke regulations, in
addition to an inspired clean air campaign. Control of
this nature may be effective to the extent that control
techniques may be applied with little cost to the com-
munity, limited perhaps to operational and mainten-
ance control.
In complex metropolitan problems, like those in
Los Angeles, New York, and St. Louis, however, air
pollution control programs cannot be so loosely admin-
istered. As the air pollution problems in these com-
munities become severe, the demands made on the
control program increase. In the Los Angeles prob-
lem, for example, a stringent and thoroughgoing pro-
gram evolved due to the increasing impact of smog-
producing factors. The state and local law which
evolved permitted the Los Angeles County air pollu-
tion control program to be more restrictive than has
been possible in many other areas of the nation. As a
matter of fact, few control regulations have been
enacted in which economic considerations dominated.
By denial of operating permits and injunctive action,
specific pollution sources have been completely elim-
inated. In the case of certain metallurgical operations
the cost of the required control equipment has exceed-
ed the cost of the equipment which it was designed to
control. (9)
I THE IDENTIFICATION AND ANALYSIS OF
SPECIFIC AIR POLLUTION PROBLEMS
The first approach taken to any air pollution
problem must identify the air pollution problems
which exist, determine cause and effect, and investi-
gate means for control. This is fundamentally the re-
search phase of the control program. By research is
meant both a systematic investigation into the causes
and effects of air pollution, arid the analysis and inter-
pretation of such data for the purpose of developing
legislation, controlling sources of air pollution, and
guiding control operations. The term "research" here
may be used quite broadly — it may mean only the
conduct of an impartial and objective study or survey
of an air pollution problem which may be relatively
simple in nature, or a major scientific task requiring
the utilization of skills and disciplines from various
technical fields. The research phase may involve short
term projects which terminate upon the assembling of
the required data, or long-range or permanent pro-
grams geared to such functions as continuous monitor-
ing of the atmosphere, and sampling of contaminants
from ducts and stacks of stationary sources.
The number of variables in the pollution problem
determine the research requirements. When the num-
ber of sources of air pollution are pinpointed and are
manageable in number, an objective presentation of the
available data by means of such a device as a survey
may be all that is required to set about establishing ef-
fective control standards. When, however, the sources
of pollution are "infinite" in number and indefinitely
diversified in character, the relationship of the polluted
atmosphere to all of the ground sources may not
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Air Pollution Control Field Operations
be ascertained by such superficial means of analysis.
Well organized and detailed research projects are re-
quired. Regardless of the extent of the need for a re-
search project, however, it will be necessary to conduct
some type of scientific or objective investigation. Even
where the sources of pollution are few in number, it
may be necessary to make a detailed analysis of the
polluted atmosphere as a means of providing evidence
that the atmosphere is polluted, and by certain definite
contaminants, before legislators or boards will promul-
gate and adopt specific measures.
Occasionally, a community may find that it is
experiencing a complex problem for which there is no
precedent. The control agency may be required to en-
gage in original research sponsored by either local or
state government or by contract with private research
agencies. Whichever is the case, local government
may only afford to conduct such research as will prove
the causes and effects of its air pollution problem.
The extent to which an original research program
may go into specific areas may be considerable, how-
ever. The agency may find it necessary to develop
special techniques in such fields as instrumentation
and calibration, laboratory methods, special testing
and measuring techniques, and other basic scientific or
technical work in order ultimately to achieve its broad
objectives. Analytical methods applied to the field of
air pollution from other fields such as industrial hy-
giene and toxicology may require rigorous evaluation
and modification.
In this chapter the research program will be view-
ed in terms of a typical research project. In general.
this is conducted in the following steps or stages:
(1) determining purposes and objectives, (2) gather-
ing data, (3) analytical laboratory analysis, (4) reduc-
tion, analysis, and interpretation of data, and (5) pre-
sentation of findings.
A. Determining Purposes and Objectives of Research
The research program may be viewed as a sys-
tematic means of answering certain questions. The
first questions, of course, which may have to be an-
swered are natural and predictable, such as: "What
pollutants are in the air and in what quantities?"
"What meteorological factors serve to accumulate or
disperse the pollutants in the air?" "What climate and
weather conditions unique to the area serve to intensi-
fy or relieve the problem?" "Where do the contamin-
ants come from?" "How can the sources of pollution
be controlled?" All initial surveys or studies of any
air pollution problem will be devoted to seeking an-
swers to these questions. To answer them, the control
program may be required to accomplish the following:
1. Identify air contaminants and measure their con-
centration in the atmosphere for purposes of deter-
mining pollution thresholds and air quality stand-
ards.
2. Survey the sources of pollution in the pollution
zone in order to determine pollution levels, poten-
tials, and relative contribution.
3. Compare pollution levels in various portions of the
pollution zone at various times and with other cit-
ies to determine critical areas.
4. Monitor levels of various key contaminants by
means of both manual and automatic sampling
equipment in order to determine when alert or
toxic levels of contaminants are reached to protect
the public in case of disaster, and to determine pat-
terns of peak and average concentrations.
5. Determine improvements resulting from control
techniques and the field operations control pro-
gram.
6. Gather data as are essential in providing a basis for
forecasting air pollution or smog conditions on a
daily basis.
7. Determine factors necessary for correlation such as
wind trajectories, pollution concentrations, eye ir-
ritation, etc., for control development purposes,
such as zoning of source areas.
B. Gathering Data
In the research phase of the control program,
most of the basic data compiled concern three primary
facets of the air pollution problem: air contaminants,
atmospheric conditions, and equipment operation.
Other factors, of course, are studied to provide checks
on the data gathered, or to verify assumptions made
from data acquired from the basic data gathering tech-
niques. It is interesting to note that in research, gen-
erally similar and identical principles tend to be em
ployed in the sampling of contaminants in the atmos-
phere, the sampling of stack gases, and in the mechan-
ics of the various control devices. Thus, there is a core
of scientific principles, peculiar to air pollution control,
such as sedimentation and settling, inertial and centri-
fugal collection, filtration, electrostatic precipitation.
The following types of data gathering activities
are germane to the research program:
1. Atmospheric Sampling and Air Analysis
This involves the sampling of the atmosphere for
air contaminants, or the continuous monitoring of cer-
tain key contaminants at permanent locations in the
pollution zone, and the laboratory analysis of samples
collected. Sampling may be made of a homogenous
smog blanket, a local condition, pollution from a spe-
cific plant or industrial area, or background pollution
when all of the air pollution activities are at a mini-
mum.
«<
The trend in air analysis is toward the develop-
ment of automatic sampling devices, which not only
offer continuous around-the-clock readings of certain
contaminants, thus providing invaluable data for eval-
uation purposes, but also eliminate the labor and time
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Elements of the Air Pollution Control Program
73
consumed in conventional analyses of manually col-
lected samples. These highly sophisticated, but some-
times temperamental, instruments require, however.
continuous and careful calibration, adjustment, and
maintenance on the part of skilled technicians.
2. Source or Stack Gas Sampling
Source sampling concerns the sampling of efflu-
ents from stacks and ducts at the sources of air pollu-
tion to determine (1) compliance with standards, and
(2) emission factors and pollution potentials of equip-
ment. Source sampling requires special techniques for
the collection of a representative sample of contamin-
ants from each source being tested. This procedure is
used in making both qualitative and quantitative de-
terminations.
Figure IV - 1. APCD testing cre\
chemical plant.
performs a stack test at a
3. Weather Measurements
Weather observing stations are employed to ob-
tain data of relevance to the direction and distribution
of contaminants in the atmosphere. Ordinarily such
data comprise inversion conditions, temperature, solar
radiation, humidity, wind and atmospheric stability.
etc. These data are used in making "smog forecasts"'
as well as plotting trajectories of polluted parcels of air
for land use studies, high concentrations, etc.
4. Photographic Analysis
Various photographic techniques can be used to
study the visual character of air pollution in a com-
munity. Time-elapsed photography can be used to
compare the hourly differences in visibility at a cer-
tain location to illustrate the manner in which a haze
or smog builds up as a result of the diffusion of con-
taminant plumes from various industrial sources, or
it can be used to study plume formation and plume
characteristics, as well as to locate primary sources of
air pollution in a community. The inferences which
can be drawn from photographic techniques, however,
are limited to the effect of visibility reduction. Photog
raphy also can be used to map topography and smog
flows and in revealing violations of the law in enforce-
ment operations. Photography is a useful adjunct to
other analytical and investigative techniques, but is of
limited value in itself.
5. Survey of the Industrial Economy
Surveys involve the analysis of selected data of
the entire industrial, commercial, and domestic sectors
of the economy to determine total and relative pollu-
tion potentials. It is acquired either by a question-
naire, by means of a canvas or inventory inspection, or
by analyses of data acquired from other agencies.
Surveys catalog and quantify the air contaminants as
a basis for computing the air pollution potentials of
specific industries or operations.
6. Analysis of Damage to Life, Property and
the Environment
Invaluable analytical and experimental tools in
research are the studies made of the damage or effects
of air pollution on life (crops, plants, animals, and
humans), property, and the environment. A study of
these effects not only supplies clues as to the nature of
the important and possibly unknown contaminants,
but can be used to measure concentrations and areas
of widespread contamination.
7. Public Surveys
Various types of surveys and polls can be taken
of the public in general, or from such specialized pub-
lics as managers and operators of businesses or indus-
tries, for the purpose of obtaining data required by
the control program. Opinion may be sampled to re-
late subjective experiences to measurable phenomenon.
For example, eye-irritation can be rated and correlated
with known contaminant concentrations. Surveys can
also be used to sample a specific neighborhood in eval-
uating a local source problem. A community or neigh-
borhood may be systematically canvassed to determine
frequency, direction, and severity of an odor or con-
taminant in assessing nuisance value. (See Chapters 8
and 12.)
C. Laboratory Analysis
The control agency will require laboratory ana-
lytical services either on a contract basis or will con-
duct such activity itself. Where the scope of the re-
search activity is extensive and involves original an-
alysis, it may be best that such research be contained
within the administration of the control agency, since
many techniques will require special development and
integration with other phases of the control program.
In the laboratory analysis of samples of contamin-
ants collected under experimental or field conditions,
various methods are used. Some are conventional
qualitative and quantitative methods established in the
field of analytical chemistry. Others are particular
modifications or original developments adapted spe-
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74
Air Pollution Control Field Operations
cifically to the field of air pollution or related fields, as
described in such publications as the American Society
for Testing Materials' (ASTM) STANDARD METHODS OF
ANALYSIS, University of Michigan's ENCYCLOPEDIA OF
INSTRUMENTATION FOR INDUSTRIAL HYGIENE, and in
publications produced by private agencies such as
SHELL METHODS SERIES, FLUOR LABORATORY METH-
ODS, and the Los Angeles County Air Pollution Control
District's LABORATORY METHODS. These methods are
used to determine the identity and quantity of an ele-
ment or radical of a substance by methods involving
the following principles:
1. Assay to identify metals by means of heat treat-
ment and use of various reagents.
2. Organic methods used to determine solubility, or
resistance to solubility of a substance.
3. Reactions to acids, bases, certain salts, or other
chemicals.
4. Measurement of certain characteristics such as
color change (colorimetry), texture, odor, hard-
ness, density, etc.
5. Tests of other physical properties such as melting,
boiling, sublimation, decomposition, etc.
The basic problem in conventional laboratory an-
alysis, however, is the errors which result from concen-
trating the contaminants collected in the sampling
process. To a certain degree, such errors may be
statistically compensated, but there remains an uncer-
tainty as to the accuracy of the results. Considerable
progress has been made toward devising analytical
techniques which do not alter the contaminants or the
atmospheric conditions under which the air sample is
being analyzed, and which are capable of identifying
and measuring samples containing concentrations in
the order of parts per million. This requirement has,
in part, influenced the development of a special field
of analytical chemistry known as microchemistry
and ultra-microchemistry. In these fields, special in-
struments based on absorption and infra-red spectro-
photometry and gas chromatography have been de-
veloped.
A special long-path infra-red spectrophotometer
which can identify compounds in concentrations as
dilute as one part in two million is employed by the
Los Angeles County Air Pollution Control District lab-
oratory. This device operates on the principle that
compounds absorb specific light waves from the beam
passed through them. A precise measurement of the
wave-lengths absorbed identifies the compounds. With
this device, the progress of reactions in dilute concen-
trations comparable to those actually found in the
atmosphere is studied.
D. Reduction, Analysis, and Interpretation of Data
The research program will be required to provide
some means whereby it can digest all of the informa-
tion obtained from the data gathering activities, and
evaluate the meaning and significance of the raw re-
sults. These findings answer such questions as "In
which portions of the day or year do contaminants
reach their peaks?" "Which contaminants or classes
of contaminants?" "Are the concentrations in the at-
mosphere of one or more contaminants rising?" "How
do contaminant concentrations correlate with eye-irri-
tation, plant damage, weather factors, etc.?" "How do
the parcels of air move over the pollution zone, etc.?"
Because of these questions, and the multifaceted char-
acter of the air pollution problems, the research pro-
gram will be devoted to conducting various categories
of quantitative measurements to be correlated, and
which lend themselves to statistical and comparative
analysis.
In Los Angeles, the raw data obtained from the
data gathering activities — contaminant concentra-
tions, pollution potentials, meteorolgical factors, eye
irritation severity, and plant damage — are fed to an
electronic computer which is capable of reducing, sum-
marizing, and correlating tremendous quantities of
data to statistical norms (maximum values, peaks,
averages, means, medians, modes, etc.)
In general, the methods of analysis applied to data
depend upon the objectives and purposes for which the
data were collected. Considering such purposes, the
problem of statistical analysis is to determine the val-
idity, reliability, and reproducibility of the results.
Occasionally, the results may be found to be invalid,
inconclusive, subject to qualification, and may suggest
further types of tests or refinement of test methods to
attain a higher degree of validity. When the results are
rigorously established, however, they may then be
used as a basis for control action.
E. Presentation of Data
With the evaluation and interpretation of data,
the research phase is only half complete. The informa-
tion, to be of any value, must be translated into both
legal and lay language for those who are responsible
for control planning. The importance of preparing the
information so that it can be comprehended and accur-
ately understood, especially by other elements of the
control program, cannot be overemphasized. The ad-
ministration of a technical organization like an air
pollution control agency serves as the agent of such
research results in assuring that the proper control
action is being taken.
II PROMULGATION OF CONTROL STANDARDS
The next step in the control program is the utili-
zation of the rule-making authority to promulgate con-
trol standards into law (ordinances, rules and regula-
tions, codes, etc.). Legal standards are the direct result
of well established research findings pertaining to the
range of pollution levels, the sources of air pollution,
the causal factors of air pollution phenomena, and the
various means possible for control. These are translat-
ed directly into simple and clear expressions of prohi-
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Elements of the Air Pollution Control Program
75
bition, giving dates of adoption, the dates laws become
effective, and whatever conditions or exceptions as
make the intent of the law clear. The law, further-
more, must clearly include all persons upon whom
it is binding, and exclude those who need not com-
ply. These laws are usually drafted by the control
agency, or the agency with the research facility, and
are either used as models for adoption by local author-
ities or are forwarded from the control agency to the
rule-making authority for approval and adoption.
In developing control standards, the following fac-
tors are specifically taken into account:
1. The category or identity of contaminants to be pro-
hibited.
2. The maximum allowable emission rate.
3. The most effective control techniques available.
4. Legality, feasibility, and enforceability of the legal
standard.
A. The Category or Identity of Contaminants to be
Prohibited
The analysis of the pollution potentials of the pol-
lution zone and smog-forming phenomena indicates
the specific classes of contaminants which must be con-
trolled. In complex pollution problems, control stand-
ard are approached from two points of view: (1) stand-
ards which are applied to air contaminants collective-
ly, and intended to accomplish gross reductions of air
pollution; and (2) specific standards applied to special
contaminants or equipment. Control standards, there-
fore, may encompass the following classification of
contaminants:
1. All air contaminants as defined by the control law.
2. All visible air contaminant emissions.
3. Any quantity of air contaminants which creates a
public nuisance.
4. All solid and liquid particulates.
5. Certain gaseous contaminants.
6. Specific contaminants.
Although it is the ultimate purpose of the control
authority to control or reduce all air contaminants, it
is impractical to prohibit "all air contaminants" by a
single inclusive rule or law. Contaminants must be
meaningfully qualified by law. That is, we must speak
of visible contaminants; the physical form of the con-
taminants, such as fumes, dusts, mists, smoke, gases,
and vapors; we may speak of any quantity of contam-
inants which may create a nuisance to a considerable
number of persons or damage health, property, vege-
tation, etc.; or we may be concerned with a specific
contaminant or an entire class of contaminant com-
pounds.
The contaminants are either clearly identified or
directly implied in the standards, so that all involved
in assuring compliance understand what must be con-
trolled. The contaminant is always identified, of
course, where standards of maximum permissible emis-
sions are involved. Where equipment or fuel regula-
tion is involved, however, the contaminant may not be
specifically mentioned.
B. The Maximum Permissible Emission Rate
All laws which relate to the control of air con-
taminants at the sources of air pollution must embody
directly, or be based on, a maximum permissible emis-
sion rate. The permissible emission rate may either
be derived from (1) the maximum allowable concen-
trations of atmospheric contaminants which are either
toxic or which contribute to the formation of toxic con-
taminants, or (2) an assessment of what emissions are
excessive in terms of the nature and operation of the
individual sources of pollution.
Varying degrees of mathematical precision are
employed in objectively computing the quantitative
standard in the rules. These may be expressed in
terms of (1) emission rates vs. atmospheric concentra-
tions of the same or related contaminants, (2) effluent
concentration and stack height vs. ground concentra-
tion in the vicinity of the source, and (3) opacity
standards vs. atmospheric visibility. Where it is not
possible to wholly base legal standards on strictly
mathematical considerations, the rule-making author-
ity may use its discretion in terms of what is reason-
able and prudent. Particularly is this true when stand-
ards are based on considerations of "excessive" emis-
sions. The object may be to obtain the greatest degree
of emission reduction at the individual sources of air
pollution consistent with what can be technically or
scientifically accomplished.
1. Emission Rates vs. Atmospheric Concentrations
The attempt is made here to reduce concentra-
tions of primary and secondary contaminants to a de-
sired level by adopting standards which proportion-
ately allocate maximum permissible emission rates
among the individual sources. For example, suppose
that a satisfactory improvement in pollution conditions
can be achieved by reducing the total pollution poten-
tial to Y tons which is possible if a given control device
is employed on all of the sources, which are N in
number. An emission rate of Y/N, expressed in
terms of pounds per hour, grains per cubic foot of
stack gas, or per cent of volume, and adjusted to allow
for growth and other factors (since N represents a
changing quantity), may then be used as the control
standard. The standard may be directly written into
rule, the responsibility for maintaining this standard
of performance being left to the operator, or the rule
may require the operation of such controls or control
techniques as will automatically accomplish this re-
duction. To certainly realize desired reductions in
pollution levels, the trend in control regulation has
been toward equipment or fuel regulation.
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Air Pollution Control Field Operations
2. Effluent and Stack Height vs. Ground Concentrations
Early in the field of air pollution control Sutton
and Bozanquet(i2) established mathematical formulas
which could be applied at each source to determine, on
the basis of stack height and stack concentrations, the
distance a plume of smoke or fumes reaches the
ground, the distance at which the maximum concen-
trations are reached (usually eight to ten times the
stack height in still air), as well as variations in con-
centration with distance. These formulae were based
on assumptions of atmospheric stability, flat terrain,
etc. Other variables, of course, are accounted for in
increasing the validity of the criteria. This type of
standard, therefore, represents a mathematical basis
for determining excessive emissions.
These formulas have found some application in
Europe, particularly in Holland(5), where congested
communities are directly affected by the plumes of
smoke emitted from the stacks of large coal burning
plants. In these instances, air pollution is reduced by
building taller stacks, or the maximum permissible
emission allowed is based on the height of the existing
stack. The shorter the stack, the less emissions al-
lowed. For example:
Maximum emissions allowed = height of stack2
50
Where height is expressed in meters and emis-
sions in grams per cubic meters. Furthermore, the
emission of particles larger than 50 microns (in Hol-
land) must be:
Maximum emission r= height of stack2 X 0.025
~~50
Although these principles may be considered in
setting standards, they are not directly written into
law in the United States due to the difficulty involved
in enforcing such legislation, and the fact that air
pollution does not originate from stacks and chimneys
only, but from many types of outlets at ground levels.
A single opacity standard applied directly at the outlet
of the stack is considerably more effective in the ad-
vent of recent types of air pollution problems.
3. Opacity Standards vs. Atmospheric Visibility
Although the Ringelmann standard, developed
by Professor Ringelmann in the late nineteenth cen-
tury, and officially published by the United States
Bureau of Mines, was originally devised as a means of
determining power plant efficiency, its adoption and
popularity appear to be based on the assumption that
contaminant plumes can be attacked from the point of
view of improving visibility. The Ringelmann stand-
ard was thus available to provide a standard based on
the obscuration of vision of contaminant plumes
directly at the sources of air pollution. (See Chapter
10 for a complete explanation of the Ringelmann
system.)
The Ringelmann scale, designated by panels in-
creasing in darkness of shade in six equal steps (from
"0" through "5" inclusive), provides a standard which
can be used in drawing the line between permissibility
and prohibition in terms of one of the six panels and
a time limit. For example, the Los Angeles ordinance
(Rule 50) prohibits smoke in excess of #2 Ringelmann
for more than three minutes in any one hour. The
problem here is, how are such standards determined?
Is any specific Ringelmann panel arbitrary, or is there
a definite mathematical relationship between observed
phenomena and the Ringelmann panels?
Actually, such standards are neither entirely pre-
determined, nor are they completely arbitrary. The
choice in the panels can be logically narrowed. Ringel-
mann designations "0" and "1", which are close to
complete transparency and the minimum of pollution,
and designations #4 and #5, which are perfect or near
perfect opacities, may be eliminated as extremes. The
standard of prohibition, therefore, is chosen from
panels #2 and #3. A control program with strict re-
quirements will favor the #2 Ringelmann standard,
and a relatively shorter time allowance. The Ameri-
can Society of Mechanical Engineers in 1949, after
eight years of study, published "Example Sections
from a Smoke Regulation Ordinance" as an aid to
communities considering smoke regulation ordinances.
In Section 8 of this bulletin "smoke the appearance of
which is equal to or darker than #2 of the Ringelmann
Chart" is prohibited except for limited periods under
certain conditions. This bulletin has been used as a
basis for smoke ordinances in more than 100 cities.
The Ringelmann standard is strictly a device for
defining excessive emissions of visible contaminants.
Since it can be assumed that invisible contaminants
are reduced in effluent plumes as the opacity decreases,
the Ringelmann standard is an effective overall rule
that can be applied in controlling a wide variety of
emissions. It is especially effective when applied to
smoke, dust, fume, and mist emissions.
C. Control Techniques Available
The type of control regulations adopted, i. e.,
maximum permissible emission, public nuisance, and
equipment and fuel regulations, depend on the devel-
opment and availability of the control devices to the
sources of air pollution. Here the design parameters
and other engineering factors involved in the control
of air pollution directly determine the wording and
character of the legislation. The control standard may
make the control of factors causing the emission of air
contaminants mandatory by regulating an appropriate
phase of the process or operation cycle of equipment
— from the charge of the feed, fuel, material, and air
to the equipment, the flow of these materials through
the equipment, to the final discharge of contaminated
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Elements of the Air Pollution Control Program
77
air and other waste products accumulating at the com-
pletion of the cycle. The legal standard may require
the operator to accomplish a specific change on the
source, such as change of fuel, replace equipment,
attach a control device, etc., in which case the con-
taminant reduction is presumed. Or the operator of
the equipment may be required to accomplish any
change at his own volition — including elimination of
the equipment if correction is not possible — as may
be necessary to bring about a reduction of contami-
nants to meet a maximum permissible emission stand-
ard. The former type of regulations apply to more
specific situations, to classes of equipment or fuels, and
the latter applies to all sources of air pollution simul-
taneously. To comprehensively control all air pollu-
tion through control regulation, it is necessary to in-
clude both types of regulations.
The control standard, to be reasonable, must
consider the availability and practicality of such de-
vices. The implementation of the standard must some-
times await the development of such devices to the
point where they are capable of being standardized in
industrial practice, or the development of a variety of
approaches to the same problem so as to allow plant
operators an economic choice. In more urgent prob-
lems, the control regulation may adopt performance
standards upon the immediate development of a con-
trol device and state a deadline for compliance. In this
way, steps toward control are immediately undertaken,
and manufacturers of devices are encouraged to refine
a variety of control methods for competition in the
open market.
D. Legality, Feasibility, and Enforceability of the
Legal Standard
While the foregoing represents objective criteria
by which control standards may be developed, the
standard may be modified by factors involving any
other social, economic, political, or legal consequences
resulting from the administration of the regulation,
such as:
1. Constitutional and legal limitations.
2. Cost of control to the community, consumer.
industry, and producers.
3. Efficiency of available control devices.
4. Uncertainty as to the presumed consistency
of effects of pollutants on toxicity or nuisance.
5. Enforceability, i. e., the facility encountered
in obtaining evidence as to violation and com-
pliance.
With the exception of constitutional and legal
limitations, such as due process of law, the standards
are modified to favor either these considerations or
the degree of control which has been objectively deter-
mined to be necessary. A strict control policy leads
to the adoption of standards which are not only in-
tended to obtain immediate and uniform results, but
prevents the resurgence of air pollution problems, pro-
tects the health of a minority of persons who may be
sensitive to low concentrations, and which positively
weighs the need for, against the cost of, control. As we
have seen from Chapter 1, control standards may be
based on maximum and minimum pollution potentials
by estimating the most adverse pollution possible un-
der prevailing conditions. As more becomes known
about the causes and control of air pollution, stand-
ards reflect more exact relationships between actual
and desired conditions.
Regardless of the strictness of the control policy,
all control standards, to be; effective, must be enforce-
able. The regulations should contain few and clear
restrictions, and these should be capable of being ascer-
tained in the field. For this reason, fuel and equip-
ment regulations are definitely superior to maximum
permissible emission standards, since it is only neces-
sary to determine whether the specified equipment or
fuel is being properly employed. The Ringelmann
standard, also, is highly enforceable, although legal
questions are periodically raised in the courts concern-
ing the validity of its use. Compliance with standards
based on grain loading or gas volume are more difficult
to ascertain in the field and require elaborate source
testing. For this reason, these standards are applied
more in granting and denying operating permits than
in on-the-spot field determinations of compliance. Field
measurement techniques, however, continue to be
devised to make field detection and measurement pos-
sible. (See Chapters 11 and 12.)
In the promulgation of control standards, all of
these considerations are taken into account and are
assembled as facts and evaluations to be presented in
testimony before the rule-making body. The oppon-
ents to the proposed control measure likewise assemble
facts to demonstrate that the standard is unfair or has
an adverse effect on the economy or industry. There-
fore, the control program must continuously evaluate
the effects on the community, both in anticipation and
as an evaluation of the effects after the control stand-
ard has been in effect for a time. If a regulation has
been found to have assumed an incorrect approach, or
fails to do the job it was intended, or creates adverse
effects on the community, it can be rescinded.
HI REGISTERING THE SOURCES OF
AIR POLLUTION
The success of the control program depends on the
accuracy and completeness of data concerning the air
pollution potentials of each of the sources of air pollu-
tion. Without such information, the control program
lacks direction and purpose, and the results of control
activity are uncertainly verified.
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78
Air Pollution Control Field Operations
The registration process is intended to secure a
detailed breakdown of the air pollution potentials.
This information is used to:
1. Indicate specific sources, or classes of sources,
of air pollution which require remedial action,
or which indicate the need for action, or are
potential or actual violators of air pollution
law.
2. Determine the growth of the sources of air
pollution, so that it may be checked, and to
prevent potential air pollution problems.
3. Provide a sound basis for promulgating anti-
pollution legislation.
4. Correlate pollution potentials with atmos-
pheric concentrations of contaminants mea-
sured by the air monitoring program, and pro-
vide a statistical basis for measuring improve-
ments in pollution levels as a result of control
activity.
5. Provide a system for assuring uniformity and
fairness of enforcement of air pollution laws,
and completeness of source coverage.
In order that the registration of the sources ac-
complishes the above purposes, it will be required to
compile for each single source of air pollution the fol-
lowing data:
1. Corporate or individual ownership or respon-
sibility.
2. Location of the equipment source.
3. Complete identification and description of the
equipment, including all important constitu-
ents, appurtenances, and other conditions
which affect the emission of contaminants.
4. All data relevant in demonstrating and ex-
pressing the air pollution potentials of the
equipment. These data may include the na-
ture of process, rates of emission based on size
of outlet and flow rate of effluents, composition
and description of effluent, etc.
5. Some record of status to indicate the degree
of compliance with the air pollution laws.
There is little disagreement among those inter-
ested or affected by air pollution control regarding the
necessity for source registration, but there is consider-
able disagreement as to the methods by which the
sources of air pollution should be registered. The con-
flict relates to the powers of the control agency to
gather such data, and the rights of plant operators to
secrecy. Depending on its control policy, a community
may provide for any one or combination of the fol-
lowing methods of registration:
1. Plant operator supplies information on a vol-
untary basis as conditions change in the plant.
2. Plant operator supplies information as author-
ized and required by law, but only upon for-
mal request.
3. Plant operator supplies information under
order of the control agency, and as required
by law.
4. All data acquired by field inspection person-
nel, with the necessary authority.
Basically, it is a question of whether or not the
plant operator supplies the required information, or
the information is acquired through legal force by
agents of the control agency. There are three basic
registration methods: (1) survey, (2) inventory, and
(3) permits or licensing systems.
A. The Survey
Surveys are applied to determine the size of an
air pollution problem, and the sources where control
should be emphasized. They are designed and imple-
mented generally for specific purposes and specific
industries, and since they may only be required to
scale a problem from the information supplied by
random samples or key industrial plants, they do not
necessarily accomplish complete source coverage.
A survey generally is conducted by means of a
carefully designed questionnaire which is sent to all
of the sources of air pollution being considered and
known from other references to exist at the time. The
questionnaire requests specific information on equip-
ment, its operation, raw materials used, time of opera-
tion, etc. Suitable calculations are then performed on
the data so as to determine emission factors, pollution
potentials, and other information desired.
The questionnaire technique, of course, is subject
to several errors, and large discrepancies may be found
which will require correction. Notably, there is uncer-
tainty regarding completeness of the sources, accuracy,
and in the response to questionnaires, particularly by
mail. Approximately 60 per cent of these queried will
respond to a first mailing of a questionnaire. A sec-
ond request, using a little more blunt language, usu-
ally provides an additional 35 per cent. It then be-
comes necessary for field personnel to visit the sources
to determine if the companies are still in business and
if the sources are in operation, etc. Of course, the
questionnaire need not be mailed, but can be filled
out by field personnel and plant operators, unless the
information requested is of such a nature as to require
an allowance of time for purposes of investigation or
analysis. (2)
The survey technique, despite its inaccuracies and
incompleteness, is a rapid means of gathering informa-
tion for a specific operation and key segments of the
data can be verified by spot-checking inspections. But
it is doubtful whether surveys can be used alone as a
means of obtaining complete and accurate source data.
Nor can it form a solid legal basis for the enforcement
of the laws of specific sources of air pollution. Surveys
can lead to control, but do not constitute a control force
in themselves.
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Elements of the Air Pollution Control Program
J9
B. Inventories
The inventory inspection is intended to specifi-
cally provide some accurate data on all equipment
sources of air pollution in all industrial-commercial es-
tablishments in the pollution zone by means of direct
contact with the sources of pollution by field per-
sonnel. The inventory inspection is conducted on a
systematic plant-by-plant, equipment-by-equipment
basis. The equipment is inspected and listed on
inventories or equipment lists. Such lists supply the
information required for each source as previously
described. In addition to such data, the inventory in-
spection provides an excellent opportunity to make a
thorough analysis of the status of compliance or non-
compliance at each of the equipment sources so that
potential or actual violators of the laws are detected
(see Chapter 14).
In general, the inventory list is headed according
to a plant activity and the equipment units are each
listed and identified, so that the inventory inspection
is essentially limited to what can be more or less ascer-
tained by means of the direct senses at the time of
inspection. The inventory, then, is used primarily to
determine the identity, number, and nature of the
sources of air pollution, and such additional informa-
tion as may prove consistently useful in noting status
of compliance with the air pollution control laws.
Air pollution potentials can be roughly estimated
on the basis of inventory inspections, but not very
accurately. Moreover, inventory inspections do not, in
specific instances, provide enough data to determine
compliance with those regulations based on dust load-
ing, grain loading, or gas volume, as can only be deter-
mined by a thorough analysis of plans, specifications,
and other engineering data on each equipment source
and by actual source testing. However, such violations
can be reasonably suspected by indirect evidence to
one who is experienced in making inventory in-
spections.
The inventory inspection thus works toward com-
pleteness and currency of information, since the
sources of air pollution are periodically and systemati-
cally visited, but may be limited in providing all of
the data required for registration.
C. Permits or Licenses
The question of a permit or licensing system, as
traditional as such systems are with respect to other
fields of enforcement, is whether or not the sources of
air pollution are to be properly and certainly regis-
tered. The permit system is the most effective means
of registering sources of air pollution in that there is
no question that the sources of pollution are being
registered, no haziness or doubt about the information
being submitted, no question concerning which equip-
ment should be registered and when, no problem con-
cerning the responsibility for veracity and good faith,
and no time lag between the time such information
may be required and the time it is received.
In the permit system, the applicant registers a
source of pollution by submitting performance and
operational data suitable to an accurate determination
of both the pollution potential and compliance with
control standards. If the equipment cannot comply
with the control standards, the permit or license is
refused, and the equipment cannot be legally operated
within that control jurisdiction. To obtain a permit or
license, the operator must either bring the equipment
up to standard or replace it by more effective equip-
ment. The permit system, thus, has control over the
entire piece of equipment. It is an effective control
weapon in that, while it registers the sources of pollu-
tion, it systematically eliminates from use equipment
with high pollution or nuisance potentials, or equip-
ment which may chronically violate air pollution laws.
The permit system, therefore, is a means of remedying
existing pollution problems and preventing future
problems from occurring. The value of the permit
system is indicated by its direct effect on checking the
growth of sources of air pollution, particularly when
there is a significant growth factor to be considered in
the pollution zone. In Los Angeles County, an average
of ten per cent of all permit applications received are
denied, indicating the eradication of numerous pollu-
tion problems.
In general, a complete permit system will require
that specifications and plans be submitted prior to
actual construction of the equipment source for per-
mission to construct. If a thorough review of the plans
and specifications shows, in comparison with past
experience with other sources of the same nature, that
it may operate without violating any of the prohibi-
tions, including a public nuisance, such authority is
granted. Upon completion of the equipment source,
and prior to actual use, a field inspection is conducted
to verify construction and operational details and to
observe the equipment in operation. If the equipment
complies, an operating permit is issued.
There are variations to this procedure (the one
outlined here is basically used in Los Angeles). Some
permit systems do not require submissions of plans
and specifications in advance, and issue only a cer-
tificate or operating permit. Some provide for author-
ization or suspension or revocation of a permit, but
most do not. Some agencies may require fees, others
do not. Basically, the intent of all such permit sys-
tems, however, is to provide for preventive means of
controlling air pollution and to register the sources of
air pollution.
Inasmuch as the permit system tends to give the
control agency control over the entire piece of equip-
ment, and since it may require the submission of plans
and specifications, it has raised some significant objec-
tions*:
See also reference 4, p. 238 and following, and reference 7.
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80
Air Pollution Control Field Operations
THE PERMIT SYSTEM: H™ !t operatefs w.he.n
stall equipment which may pollute
SUIMISSION OF CONSTRUCTION PLANS
AUTHORITY TO CONSTRUCT ISSUED
PERMIT TO OPltATE DENIED
INSPECTION of EQUIPMENT
A Continuing PrtKeis
REVOCATION Of PERMIT
Or action in cr||ninol or civil
court, if inspection disclose*
defects or impr^ier operation.
» in- Engineering
air. Enforcement
AUTHORITY TO CONSTRUCT DENIED
APPEAL Of DENIAL
To hearing! board, or
new plan§submifted.
APPEAL Of DENIAL
To hlarinj-board
PETITION F0$ VARIANCE
Submitted le| hearing hoard to permit
operation foilimited time while control
equipment ill developed or installed.
Figure IV - 2. The Los Angeles County Air Pollution Control District permit system.
1.
2.
3.
4.
5.
6.
Applicants fear that the information which
may be required may be of a confidential
nature.
Applicants may fear that information may be
used for purposes other than intended.
Many feel that the "red tape" involved in the
permit system interferes with the freedom to
seek the best control for a problem.
Many object to the assumption contained in
the permit system that the burden of proving
compliance may rest with the operator, which
is contrary to the accepted notion of assumed
innocence.
Others may feel that the permit system is
dangerous in that it can be used as a power"
device by arbitrarily withholding permits.
Many feel that the permit system creates an
unnecessary and expensive bureaucracy by
requiring a large technical staff to review the
plans and specifications in processing the
permits.
The possible inconvenience resulting from the
imposition of the permit system can be conceded. Cer-
tainly any unnecessary harshness in a law, as well as
excessive administrative machinery, should be avoided.
But two important considerations have, by now, been
clearly settled: (1) that an air pollution law can go
to such lengths as is necessary to control a given prob-
lem; and (2) constitutional safeguards are always
present, in addition to those which may be built into
the law itself. The stricter the law, the more the safe-
guards are usually clarified in order to prevent abuses,
or aberrations in the administration of the control
program. It is quite clear that neither blanket condem-
nation nor complete acceptance of the permit system
means anything, unless they are made with respect to
the pollution zone in question. A permit system, or
its equivalent, will be required for an extensive pollu-
tion zone in which the sources of air pollution are
highly diversified, "infinite" in number, and the in-
dustrialization and population of the community in-
creases at a rapid rate. In other communities these
factors may not be crucial, and the permit system may
be considerably compromised, or avoided altogether,
especially when other control techniques can bring
about the desired results.
Objections to the permit system on the grounds
of its harshness, arbitrariness, and its possible political
uses are often met in the framing of the air pollution
control law by providing definite safeguards, and by
recourse to a hearing board, administrative tribunal,
or the courts themselves. The California act, as we
have seen, provides for a hearing board which operates
independently of the air pollution control district. The
rules also spell out the permit requirements and pro-
cedures, so that there is no uncertainty in the law.
Objections as to expense are not valid if it is
understood that the specializations employed in re-
viewing applications provide a thorough and certain
analysis of each air pollution potential, without which
specific air pollution problems may not readily be
solved.
In fact, experience has shown that the price paid
for the enforcement of the permit system has been
worth it in terms of the definite reductions in pollution
levels and potentials it has accomplished. In fact, the
permit system may be the leading and most effective
control technique that can be used in a community
with a serious air pollution problem.
IV FIELD CONTROL OPERATIONS —
INSPECTION AND ENFORCEMENT
In order to certainly achieve the objectives of the
control program, it becomes necessary to reach all of
the sources of air pollution in the field to effect and
to assure their control. This can only be accomplished
by a field inspection and enforcement program. It is
the purpose of this particular phase of the control pro-
gram to obtain for the pollution zone the minimum
pollution potential.
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Elements of the Air Pollution Control Program
81
There may be some question as to the spirit and
purpose of the law enforcement program based on the
conflict between technical and police action considera-
tions. What constitutes law enforcement may be con-
troversial to the extent that, on the one hand, it may
appear to the critic or to the public to lack strictness
because of its absorption in technical considerations,
especially when a chronic air pollution problem per-
sists, and, on the other, as an excessive abuse or ex-
tension of police powers. In the former, it is felt that
the air pollution problem will never be solved unless
there are stringent laws and strict enforcement, and
on the other, it is believed that air pollution problems
are solved primarily through initiative in technical
fields leading to voluntary control. Needless to say,
both these positions beg the question by oversimplify-
ing the purpose of enforcement.
We may define "law enforcement" as the detec-
tion, investigation, and prosecution of violators of the
law — probably the strictest definition that can be
given this term. The definition is qualified, of course,
by constitutional and legal limitations, by application
of common sense, a hearing board, and a variance
procedure.
Essentially, this definition applies to air pollution
control just as it does to police activity, so that the air
pollution control agency is a law enforcement agency
and an instrument of the police power of the state.
However, the spirit of air pollution control enforce-
ment, the attitudes involved in the enforcement of
laws, may differ considerably from those involved in
the commission of anti-social crimes such as murder,
burglary, theft, etc. Violators of air pollution control
laws are not considered to be criminals; acts resulting
in air pollution, instead, require correction, so that
emphasis on law enforcement here is on compliance,
rather than punishment. Air pollution control en-
forcement is intended to safeguard the public health
along with health, fire prevention, and industrial hy-
giene programs. At the same time, however, the en-
forcement operation must not only be tactical in the
best police sense in approaching a well populated in-
dustrialized area, but must also have developed sound
techniques based on a technical understanding of the
air pollution problems which may occur at each of the
sources of air pollution.
There are other important considerations which
distinguish air pollution control field operations, a
few of which are enumerated below:
1. Field control operations are intended to deter-
mine air pollution potentials and solve air
pollution problems. Actual law enforcement
is only one activity engaged in by those re-
sponsible for conducting field operations.
2. Field control operations assure interrelation
between goal and action; between the people,
the control agency, and those responsible for
the sources of air pollution.
3. Field control operations also concern problems
for which no legal solutions may exist and
which require original legal or technical treat-
ment. It may require various special analyti-
cal testing and research activities in many
cases in order to prove a violation of a pro-
hibition, or a public nuisance, or it may re-
quire the development of special inspection
techniques.
4. Field control operations gather information
and data for use by the entire control pro-
gram, assure that the sources of air pollution
are registered and inventoried, and answer
citizens' complaints.
5. Field control operations provide certain know-
ledge of pollution activity through field patrol
and inspection by assuring consummate, fair,
and uniform enforcement of the law. Control
operations assure that the laws are being con-
tinuously and simultaneously complied with-
in the entire pollution zone.
6. Field control operations inform the managers
and operators of the sources of air pollution of
the laws, basic control techniques, as well as
the facts of the air pollution problem.
A. Functions of Field Control Operations
Field control operations are called "inspection" or
"inspection and enforcement" or just "enforcement,"
when applied to the appropriate unit of the control
agency. Actually, four distinct types of operation,
each of which may accomplish the intended enforce-
ment objectives.
1. Field Patrol
This is the patrol of all areas, highways, and har-
bors of the pollution zone to detect all visible violations
from stationary and mobile sources and to enter and
to serve notices of violation where violations are ob-
served, to maintain surveillance of all sources of air
pollution, and to answer all specific source complaints
made by citizens.
2. Source Inspection
This is the continual inspection of all manufac-
turing industrial plants and commercial establishments
to determine air pollution potentials, to inventory and
register the sources of air pollution, and to determine
compliance or non-compliance with specific rules and
regulations.
3. Investigation of Violations
This is the investigation of all alleged violations
of air pollution law to determine the elements of the
crime, and to gather evidence and to identify witnesses
for preparation of complaint and conduct of cases to
be held before the courts and the hearing board.
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82
Air Pollution Control Field Operations
4. Prosecution of Violators
This involves the preparation of charges against
violators, the filing of complaints in the courts, and
the prosecution of violators. Petitions are also filed
with the hearing board or commission or other appro-
priate administrative tribunal to seek revocation or
suspension of permits or licenses, or other administra-
tive action; or injunctive action is filed to restrain a
person or industry from activity resulting in air pol-
lution.
In practice, the field control operations break
down into two distinct types of activity. The first is
the patrol and inspection operation which is concerned
directly with contacting the sources of air pollution.
The result of most patrol activities and inspections
are adequate in achieving compliance and cooperation.
Control operations may be predominantly concerned
with preventive control through persuasion by means
of imparting information, appeal to civic pride, and by
otherwise motivating voluntary compliance. These are
most often sufficient in achieving enforcement objec-
tives without resorting to the courts. But, it should
be mentioned, the effectiveness of these techniques is
often dependent upon the existence of strict laws and
policies.
The second phase constitutes the investigation and
prosecution of violators, and is often referred to as
"legal action," or the enforcement action proper. In
contrast to other techniques used in obtaining compli-
ance, legal action is usually taken against a minority
of those responsible for the sources of pollution, al-
though, in Los Angeles County, both the number of
prosecutions and the conviction ratio have been high
for this type of law enforcement. In most instances,
legal action is taken as a last resort, after all other
means have failed.
One may say, then, that "law enforcement" in
the air pollution control program pertains mostly to
the influence of the control law in the community, and
the authority it provides for the conduct of meaningful
and purposeful source inspections. To establish and
maintain this authority, however, legal action must be
carefully and thoughtfully conducted in all cases, and
especially those cases which may test new laws or
facets of the control program, and which tend to cre-
ate important precedents. Despite the relatively small
number of cases handled, in comparison to other
actions not requiring legal force, the outcome of such
cases may affect the potentiality of the control pro-
gram. Loss of a key case may mean the necessity of
abandoning an important element of the control pro-
gram. The success or failure of these cases, and all
other enforcement actions, depend, then, on the accu-
racy and completeness of the technical data reported
by all echelons of personnel involved in inspecting the
sources of air pollution.
Following chapters of this manual will treat in
detail the various phases of field control operations
and the techniques employed in obtaining the maxi-
mum amount of useful evidence necessary to enforce
the laws of air pollution. These concern the ability to
apply the exact sections of the law, a practical know-
ledge of legal procedures employed in the prosecution
of violators, the ability to identify and read visible
emissions of air contaminants, determine violations,
and establish public nuisance cases, and to write ac-
curate and complete field reports.
REFERENCES
1. California Department of Public Health, Clean Air jor Cali-
fornia, Initial Report of the Air Pollution Study Project, San
Francisco, 57 pp., March 1955.
2. Chass, R. L., Procedures and Techniques Used in Inventorying
Air Pollution Sources in Los Angeles County, United States
Public Health Service, Seminar on Air Pollution Problems, Rob-
ert A. Taft Sanitary Engineering Center, 8 pp., October 29,
1957.
3. Cherniak, I., Ortman, G. C, Hocker, A. J., Bryan, R. J.,
Instruction Manual jor Field Data. Reporting from Automatic
Air Sampling Instruments, Los Angeles County Air Pollution
Control District, 10 pp. (no date given.)
4. Faith, W. L., Air Pollution Control, John Wiley and Sons, Inc.,
New York, pp. 225-248, 1959.
5. Linden, A. J. ter, "Air Pollution in Holland," Problems and
Control of Air Pollution, Frederick S. Mallette, Editor, Rein-
hold Publishing Corp., pp. 236-244, 1955.
6. Magill, P. L., Holden, F. R., Ackley, C., Air Pollution Hand-
book, McGraw-Hill, pp. 14-1 to 14-20, pp. 11-1 to 11-30, 1956.
7. Manufacturing Chemist's Association, A Rational Approach to
Air Pollution Legislation, 2d Ed., 19 pp., 1958.
8. Phair, J. J., Carey, G., Shephard, R. J., Thompson, M. L., Some
Factors in the Design Organization and Implementation of Air
Hygiene Survey, Int. Journ. of Air Pollution, Vol. 1, No. '/Z>
October 1958.
9. Pratch, M., Regulatory and Legal Aspects of Air Pollution,
United States Public Health Service, Seminar on Air Pollution
Problems, Robert A. Taft Sanitary Engineering Center, 5 pp.,
October 30, 1957.
10. Romanovsky, C. J., Taylor, J. R., McPhee, R. D. Dickinson,
J. E., Air Monitoring of the Los Angeles Atmosphere with
Automatic Instruments, Ann. Meet, of the Air Pollution Con-
trol Association, Buffalo, New York, 12 pp., May 21, 1956.
11. Rossano, A. T., Jr., Schell, N. E., Procedures jor Making an
Inventory of Air Pollution Emissions, Golden Jubilee Meet, of
the Air Pollution Control Association, St. Louis, Missouri, 13
pp., June 3, 1957.
12. Sutton, O. G., Theoretical Distribution of Airborne Pollution
from Factory Chimneys, Quart. J. R. Met. Soc. London, 73, ?•
257, 1947.
13. Taylor, J. R., Holland, W. D., MacPhee, R. D., Schoenemann,
K. H., Laboratory Methods, Los Angeles County Air Pollution
Control District, 1958.
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CHAPTER FIVE
ORGANIZATION OF THE AIR POLLUTION CONTROL AGENCY
I PRINCIPLES OF ORGANIZATION
The air pollution control program outlined in the
previous chapter indicates the activities which must be
implemented either by a single agency or by a number
of interested agencies. These may be conducted not
only by the federal, state, and local governments, but
also by universities and private foundations and in-
stitutions. The responsibility for the enforcement of
air pollution laws, for example, can be assumed by one
of several governmental units, such as health, fire, or
police departments, not to mention separately created
air pollution control agencies. Permit or licensing
systems, although usually a part of, or connected with,
enforcement functions, may be the responsibility of
health or civil engineering departments. The rule-
making authority, aside from that originating in estab-
lished legislative bodies, may also be the responsibility
of a specially created commission or board. Thus the
control program can be instituted in any number of
ways in order to best adjust to the needs and resources
of any particular community.
An air pollution control "movement," working at
different levels, has, in fact, been gaining momentum
in the United States due to the rising demand for re-
search, control, and enforcement. This movement has
resulted in the concentration of many resources and
agencies into a coordinated effort to control air pollu-
tion in recognized pollution zones. The agencies par-
ticipating in this movement vary in number, size, type.
purpose, and sponsorship. Of these, there are basically
two types: (1) the research, information, and advisory
agency, and (2) the control or enforcement agency.
The current trend in the field of air pollution is
the establishment of research and advisory types of
agencies on federal and state levels, and control or en-
forcement agencies on the local level. By placing the
research responsibility with state and federal authori-
ties, the cost of research is not only reduced substan-
tially per capita, but a larger number of communities
are directly benefited by the results.
A. Research and Information Agencies
1. Federal Level
At the federal level, various bureaus and depart-
ments of the United States government have made con-
tributions toward the field of air pollution. Most nota-
bly these have been (1) the United States Public
Health Service; (2) the Atomic Energy Commission,
which is interested in the biological effects of radio-
activity on man and life resulting from nuclear ex-
plosions; (3) the Department of Agriculture, which is
concerned with the influence of air pollution on the
growth of livestock and crops which might render
them toxic or distasteful; and (4) the Department of
Commerce, including the National Bureau of Stand-
ards, U. S. Weather Bureau, Civil Aeronautics Ad-
ministration, and others. (8)
More direct action in the field of air pollution and
control is taken by the United States Public Health
Service under authority of Public Law 159, passed by
Congress in 1955, and authorizing the federal govern-
ment to:
Support and aid technical research to devise and
develop methods of abating (air pollution), and
to provide federal technical services and financial
aid to state and local government, air pollution
control agencies, and other public and private in-
stitutions in the formulation and execution of the
air pollution abatement research program.
The federal government, thus, has been playing
an increasingly important role, primarily through the
agency of the Public Health Service (Department of
Health, Education, and Welfare), by providing the
following services:
1. Research into the causes, effects (notably health
and economic) and control of air pollution.
2. A national air sampling network.
3. Basic and advanced training of professional person-
nel for state and local governments, industry, and
other institutions in the problems and techniques of
air pollution control at the Robert A. Taft Sani-
tary Engineering Center at Cincinnati, and the
preparation of manuals used in training other per-
sonnel. This agency has conducted some detailed
and comprehensive surveys of community prob-
lems in such states as Connecticut, Washington,
and Tennessee.
Table V 1
LEVELS OF JURISDICTION AND TYPES OF AGENCIES
Jurisdiction
Sample Location Type of Agency
International Treaty Canada - U. S.
Detroit - Windsor
Port Huron - Sarnia
Federal
Interstate Compact
State
Washington, D.C.
Cincinnati, Ohio
New York-New Jer-
sey Interstate Sani-
tation Commission
Delaware, Oregon
New Jersey
Advisory Commission
Public Law 159, Pub-
lic Health Service —
technical assistance,
research, advisory,
professional training
Advisory
Technical assistance,
research, some en-
forcement
County, District,
or Regional
Intercity
City
San Francisco Bay
Area, Los Angeles
County
Cincinnati and en-
virons
New York City De-
partment of Air
Pollution Control
Research, enforce-
ment, engineering
Research, enforce-
ment, engineering
Research, enforce-
ment, engineering
on contract basis
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84
Air Pollution Control Field Operations
The federal government does not, of course, di-
rectly engage in enforcement and rule-making, al-
though it may indirectly do so through its power to
regulate interstate commerce, just as it protects the
public from the pollution of streams. The federal gov-
ernment could, therefore, regulate on the federal level
those sources which the states could not themselves
regulate.
2. State Level
In essential respects, the state function in air pol-
lution control is similar to the federal, and some efforts
may, in fact, be duplicated (duplication in air pollu-
tion control research is frequently useful as a means
of verifying and checking the results of other agen-
cies to provide confidence in recent findings). The
state, however, tends to conduct such research pro-
grams as are specific to the area and may explore
more fully the problems encountered in the individ-
ual cities. It may participate occasionally in joint ac-
tion with the federal government, and in providing
technical services to local communities. In addition to
such services, the state, with its police powers, may
provide the following: (3)
1. State-wide community air standards.
2. Emergency disaster powers, should an air pollution
disaster occur.
3. Enabling legislation providing the authority for lo-
cal communities to organize agencies and to en-
force prohibitions, etc.
4. Participation in control development projects of
pertinence to the communities in the state.
5. A state-wide sampling network.
6. Surveys estimating potential problems based on
such data as population density and growth, indus-
trial growth, fuel-use patterns and trends, topo-
graphical data, refuse disposal, etc.
7. Investigation of complaints, and public hearings.
The degree to which the state will actually par-
ticipate in the administration of the control program
is dependent to some degree on the size of the state, on
the extent of the pollution zones, and the nature and
extent of the air pollution problems. Smaller and geo-
graphically unified states such as Delaware' and Mas-
sachusetts may require only a state-wide pollution au-
thority. Large states like California, on the other hand,
may be divided up into diverse geographical units and
various metropolitan complexes, each requiring indi-
vidual treatment.
Another feature of state participation is that it is
more directly concerned with the health aspects of air
pollution, since it is the responsibility of the state to
protect the health and welfare of its citizens. There-
fore, in many states, as in California, air pollution is
the responsibility of the public health department,
whereas this identification is not usually made on the
local level.
B. Control and Enforcement Agencies
on the Local Level
Most control or enforcement agencies are con-
ducted at the local level — the city, a group of cities,
a county, a district or region. The control of air pol-
lution is essentially the function of the pollution zone
itself. Whether that zone is defined by a bay, a valley,
a basin, or a general area, control is best conducted by
that governmental level which immediately encom-
passes the zone. The reasons for this are obvious.
Better service is provided if the control agency is
closer to the community it must serve. The commun-
ity affected by the air pollution problem should de-
cide for itself the degree to which its air pollution
problem should be controlled. Local control responsi-
bility is more adapted to applying solutions to prob-
lems which may arise, in balancing equities and in
dealing with nuisances.
Generally speaking, there are two basic types of
comprehensive local jurisdictions: (1) a metropolitan
area composed of one city only, and (2) a metropoli-
tan area composed of more than one and often many
neighboring cities. The New York Department of Air
Pollution, for example, has jurisdiction over the entire
city. On the other hand, Cincinnati has employed a
unique long range plan which is capable of being ex-
tended, by contract, to neighboring communities. This
plan envisions cooperative activity inevitably extend-
ing to communities across the Ohio River into Kentuc-
ky. (2) In California, a district system is used because
of the size of most counties in the state. These are
generally inclusive of entire pollution zones, especially
those counties which are becoming saturated as metro-
politan areas.
Los Angeles County, for example, comprises some
71 separately incorporated cities (many of them, like
Long Beach, Pasadena, Los Angeles, and Pomona, are
very large in themselves), in addition to large unin-
corporated sections of the area. In San Francisco, the
entire bay and surrounding environs constitutes one
pollution zone, necessitating a six-county air pollution
control district.
The control agency is thus shaped according to
needs and resources. Although some aspects of agency
organization may be traditional to certain communi-
ties, the control agency is organized to best cope with
the nature and magnitude of the air pollution produc-
ing factors themselves: the number and kinds of sour-
ces,of lair pollution, the area and topography of the pol-
lution zone (that is, the amounts and kinds of work
which must be distributed to accomplish control objec-
tives), and the cost of the program. A single import-
ant factor may be influential enough to determine an
entirely unique operation. For example, the area of
the pollution zone determines the amount of area cov-
erage the field control operation must provide.
This chapter is primarily concerned with the lo-
cal control or enforcement type of agency responsible
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Organization of the Air Pollution Control Agency
85
UNINCORPORATED AREA
LOS ANGELES CITY
OTHER CITIES (WITHIN BASIN)
LOS ANGELES BASIN BOUNDARY
/S JURISDICTIONAL AREAS MARCH, I960
f
AIR POLLUTION CONTROL DISTRICT
LOS ANGELES BASIN
LOS ANGELES COUNTY, CALIFORNIA
Figure V - 1. Jurisdictional areas of the Los Angeles Basin, March 1960.
for all elements of the control program. Even though
this type of agency is not presently typical in the Uni-
ted States, a single agency is merely an organized con-
centration of the components of the control program.
centralizing control in the hands of the community.
What constitutes the control agency will vary
considerably from community to community. In some
instances, only one or a few persons, in addition to
other duties, may be responsible for a control program.
He may investigate the causes of air pollution, conduct
source sampling, recommend rules, and enforce these
rules as they are passed by his governing authority.
In other cases, these functions will require separation
and specialization, involving many personnel. Regard-
less of the size or type of organization, the local agency
should behave as if it were guided by a coherent pol-
icy.
C. The Chief Governing Authority — Local Agency
In most instances, when we refer to the control
authority we include in our frame of reference at least
three units of government. These are: (1) a chief
rule-making and administrative branch, such as an
air pollution control commission or board, empowered
or authorized by the state legislature; (2) the actual
control and enforcement agency or staff — that is, the
operational unit or municipal department implement-
ing the control program; and (3) the appeal, hearing
board, or administrative tribunal set up to settle dis-
putes, and the courts themselves. This authority thus
parallels the traditional separation of the legislative,
executive, and judicial functions of government.
The chief governing authority is a commission, a
board, a municipal department or bureau, or a com-
bination of both. The commission is generally ap-
pointed by an elected official and is frequently com-
posed of a cross section of leaders from business, in-
dustry, government, science, medicine, law, etc. Mem-
bers of the commission may serve with or without
compensation. The board is generally composed of
elected representatives acting as an air pollution con-
trol board in an ex-officio capacity. In Los Angeles
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86
Air Pollution Control Field Operations
TABLE V-2
ADMINISTRATIVE AIR POLLUTION AGENCY*
IN 110 CITIES HAVING AN AIR POLLUTION ORDINANCE
Population
Group
Under 50,000
50,000 - 99,000
100,000 - 199,000
200,000 - 499,000
500,000 - 999,000
1, 000,000 & Over
% of Total
Health
2
2
2
1
2'/2
1
10
Dept. of
Public
Safety
6
2
4
6
2
18
Building
Dept.
4
3
-
3
1
1
11
Dept. of
Public
Works
4
3
3
2
%
-
11
Dept. of
A. P.
Control
2
3
4
-
2
1
11
A. P.
Control
District
2
1
1
3
6
Other
6
4
4
2
1
1
16
None
8
7
2
-
-
16
Total
32
26
19
16
10
7
1 From A Review and Appraisal of Air Pollution Legislation, by Samuel M. Rogers, presentation at the Golden Jubilee Meeting of
the Air Pollution Control Association, St. Louis, Missouri, June 4, 1957.
County, the Air Pollution Control Board of the Air
Pollution Control District consists of the members of
the Board of Supervisors of the County of Los An-
geles elected to office from their respective supervisorial
districts, The San Francisco Bay Area employs an in-
teresting combination of systems. In that area, the
chief governing authority consists of a Board of Di-
rectors made up from a six-county unified district com-
posed of one county supervisor and one mayor or city
councilman from each of the six counties of the Dis-
trict.
In general, the chief governing authority — the
commission or board — organizes and administers the
air pollution control agency itself. Most of such
authorities pass on rule-making, operating budgets,
and select the director or directors of the control
agency itself. It may even constitute a permanent
advisory function if, as a commission, it is composed of
qualified members from technical or scientific fields.
If the authority is an air pollution control board con-
sisting of elected officials, it may appoint a scientific
and technical committee to advise both the board itself
and the agency, as has been done in the Los Angeles
County district. (See Figure V-2.)
D. Types of Air Pollution Control Agencies
There are two basic types of air pollution control
agencies: captive and autonomous. The captive agency
is generally an operational unit administered by an
established municipal department or bureau whose
main concern is with sanitation, engineering, environ-
mental engineering, health, or building and safety.
The actual air pollution control unit is sometimes
called a division or section of air sanitation, smoke
inspection, air pollution control, etc. The autonomous
agency is a fully independent agency created for the
sole purpose of air pollution control and responsible
only to the chief governing authority — a board or
commission.
The delegation of air pollution control responsi-
TABLE V-3
PROVISIONS FOR BOARDS
IN AIR POLLUTION ORDINANCES OF 110 CITIES*
Population
Group
Under 50,000
50,000 - 99,000
100,000 - 199,000
200,000 - 499,000
500,000 - 999,000
1,000,000 & Over
TOTALS
APC - Boards
a
1
1/3
1-1/3
b
1
2-1/2
1-1/2
1/2
5-1/2
c
1/2
1/3
1/2
2-1/3
3-2/3
ab
2-1/2
1
3-1/2
Special Boards
a
2
1
1
2
4/5
6-4/5
b
3
6
5-1/3
3
2
4/5
20-1/10
c
2
1/2
1
1/2
4
ab
1
2
1
2
6
abc
3
1
1
1
1
7
Other
1
1
2
1
5
None
22
11
4
7
2
1
47
%of
Group
31
58
79
56
80
86
Approximately 53% of the communities provide one or more boards in accordance with ordinance requirements.
Note: a — Advisory
b — Appeal
c — Rules & Regulations
* From A Review and Appraisal of Air Pollution Legislation, by Samuel M. Rogers, presentation at the Golden Jubilee
Meeting of the Air Pollution Control Association, St Louis, Missouri, June 4, 1957.
-------
Organization of the Air Pollution Control Agency
87
bility to a municipal department or bureau depends
on such factors as the capacity of existing departments
and bureaus to handle an air pollution control program
in addition to established duties, the extent of the de-
partment's authorized powers and area of jurisdiction,
etc. If only a modicum of enforcement is required,
then the control function might well be placed within
the jurisdiction of an existing department. If a com-
prehensive control program is required, which would
overtax existing departments, then an autonomous
agency is called for.
In some instances, the distinction between captive
and autonomous is merely technical. A captive agency
can have the force of a completely autonomous agency,
or at least an agency that is parallel and equal to other
agencies administered by the same authority. For ex-
ample, a bureau of smoke control implies an equiva-
lence to other bureaus, all of which may be adminis-
tered by a department of public health or safety. In
some instances, municipal government may prefer to
integrate all services relating to concepts of health and
welfare, rather than create a complex of independent
single-purpose agencies. For example, air pollution
control may be considered as a facet of public safety,
public health, or environmental engineering. Even
when the air pollution control program is captive, it
may enforce laws and be otherwise guided by a speci-
ally created air pollution control commission, as in the
case of New Jersey. In that state, an appointed com-
mission possesses the primary rule-making authority,
but air pollution control laws are enforced by the Air
Sanitation Division of the Department of Health. (4)
E. Organizational Structure
Assuming that a single, comprehensive agency is
required, the control agency is organized so as to (1)
separate the technical functions to be performed ac-
cording to the kinds and amounts of work to be accom-
plished and the professional resources available, (2)
coordinate and integrate the functions of the control
agency so as to make control functions meaningful and
purposeful, and (3) permit flexibility in creating, mod-
ifying, or abolishing operational components as may be
required from time to time.
Each element of the control program can be
effected by a proper grouping of personnel into distinct
operational units and subunits. The typical units of a
fully developed control agency are: (1) field control
operations, (2) engineering, and (3) research. The
air pollution control agency, to provide for coordina-
tion of functions, will require a director and his staff.
and such other administrational staffs as business man-
agement and public information and education as may
be necessary. A typical organization chart based on
a staff responsible to a single director is indicated
below:
Commission, Board
or Municipal Department
Air Pollution Control Officer
Public Information
Business Management
Field Control Operations Engineering
Figure V-2. Organizational pattern for a control agency responsi-
ble for administering a comprehensive air pollution control
program.
1. Field Control Operations
All agencies require an organizational component
devoted to the inspection of the sources of air pollution
and the enforcement of air pollution control laws;
i. e., field control operations. Field control operations
are charged either partially or wholly with all duties
connected with the pollution zone, such as the inven-
torying of the sources of air pollution, answering com-
plaints, surveillance, emergencies.
2. Engineering
Because the control program requires registration
of the sources of air pollution, source testing, and eval-
uation of all technical source data, engineering per-
sonnel will be required. If the sources of air pollution
in the pollution zone are large in number, and a per-
mit or licensing system is incorporated into the local
control program, then a distinct engineering unit will
be required to review plans and specifications to deter-
mine compliance with that system. Where the indus-
trial complex of a given community is not so ramified
or extensive, engineers may comprise the field inspec-
tion and enforcement operation, or be assigned to it
in an advisory capacity. Where the industrial field is
large and diversified, a number of approaches may be
employed.
3. Research
The research unit in the organization continu-
ously gathers data, takes air samples, forecasts pollu-
tion conditions, conducts source testing and laboratory
analyses, and reduces and evaluates all data gathered
by others in the organization. In a comprehensive
agency, the research unit constitutes a grouping of
scientific personnel devoted to the technical aspects of
air pollution and its control.
The organization of a fully developed control
agency is partially based on permanent control func-
tions, partially on a project basis — since the agency
may tend to mobilize around a concerted effort to solve
one or more major problems at a time. Because of this
fact, a control agency may grow to accommodate a
need in, say, its research function and when projects
are completed and translated into law, that function
may cease.
-------
88
Air Pollution Control Field Operations
4. Character of the Organization
There are, of course, significant differences in
organizational structure. The variations in organiza-
tional structure from the pattern shown above are
based primarily on emphasis, on need, and on the his-
tory of the development of that control agency. These
particular variations constitute the character of the or-
ganization. This character is important insofar as it
may describe the ability of the organization to handle
problems which arise.
When describing the character of the organiza-
tion, we may speak about the emphasis taken in the
administration, which may either be the philosophy of
a professional element dominating the organization, or
an emphasis which is tactical in coping with problems.
There is no question that certain control philosophies
tend to be unique to certain professions. A research
scientist may exert a mood of overcaution on the entire
program by virtue of his need for exhaustive informa-
tion on any subject. A professional enforcement officer
may feel the necessity for strong and uncompromising
enforcement. On the other hand, technical personnel
may feel that solutions may be obtained through mass
technological change, unmindful, perhaps, of the real
and practical problems which are current in the field
and which can be solved by immediate enforcement
action. Public relations personnel may feel that real
control is accomplished by dealing directly with public
opinion to motivate compliance. There is no one "true"
character a control agency should assume. Organiza-
tions vary from community to community according
to local requirements. What is important is that the
agency be capable of responding to problems which
arise.
Sometimes, where a large number of tasks and
disciplines are required to accomplish objectives, it is
advantageous for the control agency to be admin-
istered by those skilled in public administration in
order to provide for a balanced and coordinated pro-
gram. Professional administration obviates those ad-
ministrative tasks which interfere with the technical
concerns of various functions. The individual divisions
of the organization, however, will be administered in
terms of the most qualified personnel in the fields
directly involved, each representing a corps of experts
as shown in Figure V-2. At the same time, leadership
provided by the administrative unit expands, contracts,
or shifts the resources of the agency to fit the needs of
the problem.
II ORGANIZATION OF THE LOS ANGELES
COUNTY AIR POLLUTION CONTROL DISTRICT
The activities of the Los Angeles County Air Pol-
lution Control District are basically organized to pro-
vide for separation, specialization, and coordination of
functions. The basic operational divisions, as shown in
Figure V-3, are Enforcement, Engineering, and Re-
search, supported by such administrative staffs as
Business Management and Public Information and
Education.
The important characteristic of the Air Pollution
Control District in Los Angeles County is that each
division is vested with a large degree of independence,
Air Pollution Control Board (County Supervisors)
Scientific Committee
Emergency Action Committee
Technical Consultants!
Air Pollution Control
Hearing Board
Air Pollution Control Officer
Public Information
Staff
Business Management
Staff
RESEARCH DIVISION
1. Conducts an organized research pro-
gram.
2. Provides analytical air monitoring
services, develops and analyzes air
monitoring methods, tabulates and
analyzes collected data.
3. Performs statistical analyses for zon-
ing studies, smog forecasting and
other studies.
4. Provides laboratory services for an-
alyses of samples from source tests.
5. Maintains an automotive testing lab-
oratory to evaluate methods and de-
vices for controlling automobile ex-
haust.
ENFORCEMENT DIVISION
1. Conducts recurrent inspections of all
manufacturing, industrial and com-
mercial establishments, and enforces
air pollution statutes and rules.
2. Provides a 24-hour patrol and surveil-
lance of mobile and stationary sources
of air pollution throughout the county.
3. Administers and enforces that phase
of the air pollution emergency pre-
vention program relating to the shut-
down of significant sources of air pol-
lution during alerts.
4. Answers and investigates all com-
plaints.
5. Cites and investigates all violations
and prepares court and hearing hoard
cases.
ENGINEERING DIVISION
1. Administers the permit system through
(1) permit processing and (2) field
engineering inspection.
2. Conducts detailed source testing of air
pollution sources.
3. Conducts industrial surveys and de-
velops recommendations for specific
measures.
Figure V-3. Functional organization chart of the Los Angeles County Air,Pollution Control District.
-------
Organization of the Air Pollution Control Agency
89
and is administered by a director selected for his skill,
knowledge, and experience in the field. Each division,
except for the supporting staff functions, represents a
fully developed organization capable of existing in its
own right. The directors of the various divisions, as
well as the heads of the staffs, form the executive staff
of the Air Pollution Control Officer.
Since the District was organized in 1948, it has
undergone successive internal reorganizations, periodi-
cally shifting activity emphases to achieve what might
be called a "balanced" control; i. e., coordination of the
operating divisions so that the entire organization
could operate in concert and with the emphasis as may
be required at any given time.
In considering the organizational structure of the
Air Pollution Control District, it is important to note
that the District is not only charged with the responsi-
bility of implementing the industrial source control.
enforcement, and research programs as discussed in
Chapter 4. but also with the responsibility of handling
virtually any type of emergency which might arise.
These additional responsibilities include:
1. Emergencies resulting from unusual rises in
concentrations of chemical contaminants as
defined in Regulation VII (see Chapter 3).
2. Emergencies arising from hazardous increases
in radioactive contaminants.
These responsibilities are integrated into the
control organization. Under Los Angeles County
Ordinance 5582. the District has been declared the
Radiological Defense and Disaster Service of the Civil
Defense Authority. As such, both activities involve
planning, forecasting, and monitoring. Emergencies
resulting from smog-forming contaminants are the re-
sponsibility of established components throughout the
District (Regulation VII). The Radiological Disaster
Service, while involving air monitoring, is primarily
concerned with coordinating local responsibilities and
personnel training, in order to prepare for disaster
arising from nuclear war.
A. Engineering Division
The functional diagram of the Air Pollution Con-
trol District as shown in Figure V-3 is self-explanatory.
As will be noted, enforcement and engineering func-
tions are separated. The separation, rather than the
consolidation of the divisions, has long been established
in Los Angeles Count}', though they are in many spe-
cific instances coordinated to accomplish a given ob-
jective. In Los Angeles, the Rules and Regulations
require competent review of plans, applications, and
specifications in addition to engineering field inspection
before permits can be issued, necessitating review by
personnel expert in the various engineering fields such
as combustion, metallurgy, chemical processing, pet-
roleum, etc., as well as source testing and control
development. Since the Los Angeles area is fully rep-
resented by almost all types of industry, the engineer-
ing talent necessary to process permit applications for
this industrial economy must be equally extensive and
diverse.
B. Enforcement Division
Because of the more than 1200 square miles
which must be patrolled by the enforcement operation,
and the amount of attention required by the numerous
sources of air pollution, it is impractical for enforce-
ment personnel to spend office time in engineering re-
view of permit applications. Furthermore, the degree
of compliance in the field and the engineering stand-
ards which must be met by equipment are so high that
specialization on the part of inspectors and engineers,
respectively, is mandatory. Therefore, in the Los An-
geles County Air Pollution Control District, the en-
forcement and engineering divisions are permanently
maintained, with personnel strength based on field-
load requirements.
C. Research Division
The Research Division, on the other hand, is not
entirely within the concept of local government,
organizationally speaking. Research can be contracted
for, or performed on a state or federal level. In the
absence of concerted research at any level, however,
it was first necessary in Los Angeles to determine what
contaminants must be controlled, and how. The re-
search function is more variable than any of the other
control functions, and falls into two categories: (1)
self-terminating projects, and (2) permanent activi-
ties, such as source sampling and air monitoring.
In the Air Pollution Control District, the advance
on the unknowns of the air pollution problems has had
the effect of shifting the research emphasis from the
causes and effects of air pollution to the resolution of
immediate ground source problems, such as auto ex-
haust and organic solvents. The phenomenal effects
of the various types and quantities of air contaminants,
together with their meteorological variables, have be-
come sufficiently understood for control development
purposes. Once particular projects are completed
toward realizing goals, they are terminated. Some of
these may result in permanent control functions on
other operational levels, others may not.
To conclude, the uniqueness of the Los Angeles
County Air Pollution Control District resides in the
fact that it is a balanced, coordinated agency, fully
encompassing all elements of the control program. As
such, it represents a primary jurisdiction in the 4000
square mile area of Los Angeles County. Thus, the
Los Angeles County Air Pollution Control District,
with its hearing board, consultants, scientific and
emergency action committees, and the completeness of
its control and enforcement organization, represents
an amalgamation of many resources into one district-
wide task force.
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90
Air Pollution Control Field Operations
REFERENCES
1. Air Pollution Control Association, 19)8 Directory of Governmen-
tal Air Pollution Agencies.
2 Council of State Governments, Air Pollution. Summary Report to
the Governor's Conference, 49 pp., May 1958.
3. Keagy, Donald M., et al, Methodology for Evaluating the Air
Pollution Problems of a State, LI. S. Public Health Service, pre-
sented at the Air Pollution Session of the annual meeting of the
American Industrial Hygiene Association. St. Louis. Missouri, 17
17 pp., April 25, 1957.
4. New Jersey State Department of Health, Air Pollution Control in
New Jersey, progress report of the New Jersey Air Pollution
Control Commission, including a report of the Department of
Health Air Sanitation Program, July-October 1957.
5. Rogers, Samuel M., A Review and Appraisal of Air Pollution
Legislation in the United States, U. S. Public Health Service,
presented at the Golden Jubilee Meeting of the Air Pollution
Control Association, St. Louis, Missouri, 21 pp., June 4, 1957.
6. Stern, A. C., Air Pollution Control—Administrative Needs and
Patterns, U. S. Public Health Service, Robert A. Taft Sanitary
Engineering Center, Cincinnati, Ohio, presented at the First Inter-
national Congress on Air Pollution, New York City, 9 pn
March 1, 1955.
7. Stern, A. C., Tailoring the Air Pollution Ordinance to the Needs
of. the Community, U. S. Public Health Service, presented at the
Dust and Fume Product Group Session, Foundry Equipment
Manufacturers Association, Washington, D.C., 8 pp., April 1955,
8. U. S. Public Health Service, The Federal Role in the Community
Air Pollution Problem (antedates passage of Public Law 159,
84th Congress), 20 pp.
-------
CHAPTER SIX
AIR POLLUTION CONTROL FIELD OPERATIONS
I PRELIMINARY CONSIDERATIONS
Air Pollution Control Field Operations are those
activities conducted by a control agency to secure
continuous control of the sources of air pollution in
the pollution zone. The nature of this activity varies
with the specific laws and policies of control agencies.
In some agencies, field control operations are of an
advisory and data-gathering nature; in others, they
are confined to law enforcement activities. In this
chapter we shall be concerned with a severe air pollu-
tion problem in which both the laws enforced and the
enforcement policy are intended to obtain a mass
reduction of all pollution potentials, the highest rate
of mass-compliance possible and an alert emergency-
response capability. To achieve these goals, field con-
trol operations must provide for two distinct activities
— source inspection and law enforcement.
Source inspection includes all of the activities
conducted by the control agency to attain minimum
pollution potentials and to gather information. These
include:
1. Continuous and simultaneous surveillance of
all source areas of the pollution zone.
2. Detection and location of the sources of air
pollution.
3. Inspection and inventory of stationary source
production and control equipment to secure
compliance and to assess air pollution po-
tentials.
4. Rapid response to air pollution hazards and
emergencies whenever and wherever they
arise.
5. Resolution of unique pollution problems
through application of special legal, technical
and engineering skills.
Law enforcement is the detection, investigation
and prosecution of the violators of the air pollution
control laws. The primary concern of enforcement is
to attain the highest degree of compliance possible.
Air pollution law enforcement, therefore, concentrates
on those provisions and prohibitions of the legal
authority which are intended to regulate the sources
of air pollution. For example, of the numerous pro-
visions in the California State Health and Safety Code,
the Rules and Regulations of the Los Angeles County
Air Pollution Control District, and Section 27153 of
the California Motor Vehicle Code, the Enforcement
Division of the A.P.C.D. enforces primarily those pro-
hibitions shown in Table III-2. All other legal pro-
visions are handled administratively by the Air Pollu-
tion Control District as a whole.
Although the two types of activities are embodied
in the same function — i. e., field control operations —
only a relatively small minority of the sources of air
pollution inspected in an established program result
in direct legal action. The inspection phase of the
field control activity, therefore, will assume major
emphasis, not only because of its influence in achiev-
ing voluntary control, but in the information it sup-
plies the control agency.
Another important requirement of the field op-
erations program is that it be capable of handling
emergencies or special problems in the field for which
there may or may not be legal solutions. Control
operations must be alert to contaminant problems
occurring at any place or any time in the pollution
zone, without prior notice, and which may upset the
balance in actual pollution levels, or whose contami-
nant levels, while remaining in legal compliance, may
be intensified by adverse atmospheric conditions. Such
problems are: accidental equipment failures; refinery
breakdowns; accidental emission of poisonous gases
or fumes; accumulation of air contaminants in a
community from a concentration of industries, even
though all are in compliance; the emergency dumping
of ammonia from commercial refrigeration systems;
and the diffusion of an obnoxious odor from animal
rendering sources.
A. The Enforcement Division of the Los Angeles
County Air Pollution Control District
In the A.P.C.D. practically all of the responsibil-
ity for conducting field operations and law enforce-
ment is vested in the Enforcement Division. The or-
ganization of the Enforcement Division (Figure VI-1)
takes into account assigned functions in law enforce-
ment and technical duties associated with source in-
spection. Since the former reflects a firm policy of the
control program, the organization of the Enforcement
Division in some respects resembles the chain-of-
command system employed by typical police depart-
ments. The discipline exerted, however, is not in-
tended to regiment for the sake of military efficiency,
but to maintain an alertness to field conditions and to
obtain a maximum degree of valid evidence for each
legal action which may be undertaken.
The activities of the Enforcement Division are
administered by a Director of Enforcement and super-
vision is accomplished by a Chief Engineering Inspec-
tor with the assistance of three Head Engineering
Inspectors. Field operating personnel consist of Air
Pollution Inspectors, Air Pollution Engineering In-
spectors and Senior Air Pollution Engineering Inspec-
tors (field supervisors).
In order to facilitate field operations and to con-
solidate activities on a functional basis, personnel are
assigned to three major field operations groups, two
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92
Air Pollution Control Field Operations
DIRECTOR OF ENFORCEMENT
CHIEF INSPECTOR
AIR MONITORING
DETAIL
Sampling for contaminants,
specified in Regulation VII,
during night and morning
hours to determine concen-
trations of these contami-
nants in the air.
RECORDS SECTION
Maintains and controls rec-
ords of:
a. Inspectors' reports.
b. Court and Hearing
Board actions.
Prepares statistical reports
on enforcement activities.
INDUSTRIAL INSPEC-
TION SECTION
Continuously inspects as-
signed manufacturing
plants.
Prepares source inven-
tories.
Checks compliance with
permit system and condi-
tions of variances in as-
signed industries.
Investigates breakdowns.
Investigates complaints
made against assigned in-
dustries.
REFINERY AND
CHEMICAL IN-
SPECTION SECTION
Continuously inspects oil
refineries, petrochemical,
chemical plants and all
allied activities.
Continuous surveillance
of these industries.
Prepares source inventor-
ies for these industries.
Checks compliance with
permit system, vapor loss
regulations, and condi-
tions of variances.
Investigates complaints
and public nuisances in-
volving the above indus-
[tries.
PATROL SECTION
Patrols assigned zones in-
cluding highways and
harbors for all visible vi-
olations from stationary
and mobile sources.
Enters and cites all plants
where visible violations
are observed.
Keeps under surveillance
plants on referral from
other sections.
Answers
plaints.
public com-
COMMUNICATIONS
SECTION
Maintains and operates
radio transmitter and re-
ceiver 24 hours a day for:
a. Complaints, instruc-
tions and data to mo-
bile units.
b. Declaration of alerts
to specified industries
and all mobile units.
c. Receipt and recording
of data from air mon-
itoring stations during
night and morning
hours.
INVESTIGATION
DETAIL
Investigates and pre-
pares cases to be heard
before the Courts.
Court Liaison.
Figure VI - i. Functional organization chart of the Enforcement Division of the Los Angeles County A.P.C.D.
service groups and two special details. The field
operations groups are known as the Uniformed Patrol
Section, the Industrial Inspection Section and the
Refinery-Chemical Section. The service groups are
the Communications Section and the Records Sections.
The Air Monitoring Detail, recruited from the field
force on a rotation basis, operates eight air monitoring
stations during night and early morning hours, in
addition to maintaining overall surveillance of indus-
trial activities during these hours. The Investigation
Detail, which is assigned to court case preparation and
presentation, is assigned to a member of the Records
Section, or to any other enforcement personnel with
investigative experience.
1. Field Operations Groups
Because of the diversity of the many industrial,
domestic and commercial sources of air pollution, the
geographical distribution of these sources and the vari-
ous air pollution and enforcement problems which
arise, two general approaches to the deployment of
field personnel are necessitated by the A.P.C.D. These
may be summarized as: (1) geographical deployment
of inspectors by sectors, and (2) assignment of field
personnel to various categories of complex industries,
or unique air pollution problems. The grouping of
personnel in the Enforcement Division takes into
account both needs simultaneously. All enforcement
sections in the Division are delimited by geographical
areas, yet all assume some specialized assignments.
2. The Service Groups
In an enforcement agency, the service groups are
primarily concerned with the transmission of informa-
tion to and from field inspectors and headquarters
personnel, the recordation and filing of information,
the rendering of dispositions to reports and the initia-
tion of some field assignments. In the Enforcement
Division, the service groups consist of two head-
quarters-based sections: (1) the Communications Sec-
tion which, by means of radio and telephone communi-
cations, serves to continuously and instantaneously
dispatch, locate and coordinate all mobile field units;
and (2) the Records Section, whose responsibility it is
to compile case histories and enforcement statistics,
provide a basis for controlling work-loads and assign-
ments, maintain continuity of enforcement actions,
provide selective analyses to data for evaluation of
specific field operations programs, and other important
functions.
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Air Pollution Control Field Operations
93
3. Administration of Work Assignments
Because of the number of variables which must
be subject to administrative control in any field opera-
tions program conducted in a metropolitan economy as
large and diverse as Los Angeles County, planning
of an effective enforcement program must provide for
optimum use of all available personnel. The object
of planning is to deploy personnel in such a manner
that inspectors' reports, violation notices and citations
issued represent as much as possible true conditions of
compliance or non-compliance. At the same time, it
is important that industries having specific air pollu-
tion problems receive necessary attention, that equal
amounts of work-loads be divided among any given
category of inspector, that the correct number of per-
sonnel be employed to provide both saturation and
selective coverage, and that all activities and the
sources of air pollution be easily located and assigned.
II DETECTION OF THE SOURCES OF AIR
POLLUTION
The first task of field control operations is to
locate and identify the sources of air pollution and
the problems which require solution. The sources of
air pollution are detected throtigh patrol surveillance,
systematic equipment inspection and registration, and
investigation of citizens' complaints. Each source of
air pollution must be observed by a responsible mem-
ber of the control agency, and the stack emissions and
the equipment and operational procedures employed
must be noted.
To accomplish the observation and inspection of
each source of air pollution in the pollution zone, field
control operations must provide adequate coverage of
the pollution zone in the shortest possible time with-
out compromising quality or justice. This, of course,
must be accomplished within budgetary restrictions
and with a limited number of inspection personnel.
Initially, the control agency must choose between
either one or a combination of saturation or selective
coverage techniques.
Saturation coverage is intended to obtain a mini-
mum pollution potential (see Chapter 1 for definition)
through securing the greatest degree of mass-
compliance with the statutory authority possible. Sat-
uration coverage, therefore, provides for (1) uniform
and complete inspection of all potential sources of air
pollution, (2) continuous status determination of com-
pliance as well as non-compliance, and (3) a degree of
surveillance and inspection capable of detecting the
critical number of violations which may occur at any
time.
Selective coverage, on the other hand, is con-
cerned only with the investigation and solution of cer-
tain key and isolated problems.
Obviously, the more field personnel employed by
the control agency, the greater the coverage that can
be provided. Since all control operations are limited
by budgetary considerations, optimum, rather than
maximum, coverage is sought. Field deployment,
therefore, must be based on two considerations:
1. Surveillance Factor. The period of time and
the frequency each source of pollution is to be
observed.
2. Inspection Factor. The frequency with which
each piece of equipment is inventoried for
source registration and inspected thoroughly
to determine compliance with the air pollution
control law.
Surveillance consists of observing both specific
industrial plants and whole source areas at a time
within the radius of vision of a patrol inspector. Given
a surveillance factor, the chance of observing recur-
rent visible violations increases with the fraction of the
time during which the plant is under observation, pro-
vided that the observation period is randomized with
time. For example, supposing that the surveillance
factor for each industrial plant in a sector is one hour
during each eight-hour day, the probability of observ-
ing instantaneous violations in a sector during an
eight-hour period is one in eight; but the chance that
any instantaneous violation will escape detection in 20
violations is one in sixteen. Therefore, with appropri-
ate deployment of patrol inspectors, all recurring vio-
lations can be detected within a reasonable period of
time. A sector whose area enables a patrol inspector
to detect all recurring violations within about 30 work-
ing days may be considered as providing saturation
coverage. This time period should be long enough to
allow for the detection of random visible violations and
other duties which may be performed by the patrol
inspector. The smaller the patrol sector, the sooner
this can be accomplished.
To maximize the surveillance factor, the patrol
inspector should be trained to patrol in a manner
that will bring the greatest area of his sector under
view while taking the shortest route. Each location
should be patrolled at different times each day, max-
imum use should be made of vantage points, and
streets should be patrolled which are central to the
area under view. As the patrol inspector becomes
familiar with his sector, his patrol activity tends
to concentrate in the areas of highest source density.
The inspection factor is predicated on the changes
which may take place in industrial equipment and op-
erations. Since equipment and operation do not change
rapidly, a common practice is to provide for at least
one inspection of each source of air pollution annually.
This is based on an equipment and business turnover
that tends to be realized at the end of each fiscal cycle
or year. (See Chapter 14.)
Sources of air pollution are not only detected
through patrol and source inspection, but also by
citizen complaints and aerial inspection. The fact that
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94
Air Pollution Control Field Operations
fil
'
MARCH,I960
LOS COUNTY
AIR POLLUTION CONTROL DISTRICT
LOS COUNTY, CALIFORNIA
Figure VI - 2. Comparative size of the Los Angeles County Air Pollution Control District and other major Air Pollution Control agencies.
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Air Pollution Control Field Operations
citizens complain of outstanding visible emissions,
malodors and contaminant deposits extends the total
surveillance factor considerably.
A field control operation just beginning will have
more work than it can complete in terms of handling
all visible violations observed. Nevertheless, field in-
spectors must be deployed systematically in the field
so that all sources of equal importance are equally ob-
served. Initial planning criteria include (1) the size
of the control area and the possible inspection sectors
based on the above consideration; (2) the number,
types and importance of the sources of air pollution;
(3) the location and distribution of industrial and
commercial establishments and residential areas; and
(4) other factors such as major freeways and highway
routes, number of incorporated cities in the area, areas
of heavy vehicular traffic, important geographical
barriers.
A. Deployment of Field Inspectors in Los Angeles
County
The Los Angeles County Air Pollution Control
District maintains control jurisdiction over the entire
land area of Los Angeles County comprising 4,083
square miles and 71 separately incorporated cities.
This area is geographically divided by the mountain
chain into two sections. The southern section, the
coastal plain, is the Los Angeles County Basin, which
includes virtually the entire metropolitan area of Los
Angeles County — some 5,000,000 people spread over
a 1200 square mile area. The second section is the
sparsely populated desert areas north of the mountain-
ous regions.
Since both the smog problem and the sources of
air pollution are concentrated within the metropolitan
area, the major enforcement effort is conducted in the
Los Angeles Basin. All laws and regulations, with the
exception of Regulation VII (Emergencies) and bans
on rubbish burning (Rules 57 and 58), however, apply
to all stationary and moving sources in all 4,083 square
miles of the county area.
Both sections of the control jurisdiction represent
an unusually large area to be covered by an enforce-
ment agency. The field of operations, in fact, is larger
for the A.P.C.D. than it is for any other local law
enforcement agency under a single command in Los
Angeles County, and it is one of the largest in the
nation patrolled by a single air pollution control
agency.
Although industrial decentralization is the gen-
eral pattern of development in Los Angeles County,
various types of source areas are differentiated by
special air pollution problems. These are:
1. Central Manufacturing Industrial area —in-
cluding eastern portions of downtown Los An-
geles, Vernon, Bell, Maywood, Huntington
Park, and South Gate. These consist of varied
industrial manufacturing plants.
2. Southern sections of the basin — these include
virtually the entire southern strip — El Seg-
undo, Torrance, Dominguez, North Long
Beach, Long Beach, containing some 10,000
oil wells and 5,000 crude oil tanks, major re-
fineries, tank farms, petrochemical and chem-
ical plants and nearly all aircraft and second-
ary air frames industries.
3. The harbor and coastal areas — these include
all ports, shipping offices, harbors, naval sta-
tions, fish canneries and steam generating
plants.
4. The west-central metropolitan area — in-
cludes most congested areas of vehicular traf-
fic, apartment house dwellings which, prior to
incinerator bans, constituted a significant
source of smoke, and a correspondingly high
complaint load area.
5. The downtown Los Angeles area — includes
office buildings, government buildings, de-
partment stores and textile lofts providing the
greatest concentration area-wise of boilers.
6. The cities — include relatively large incorpor-
ated cities such as Pasadena, Glendale, Long
Beach, and Burbank, and community develop-
ments such as the San Fernando Valley, each
having an industrial community.
7. Exterior outbound and inbound traffic areas —
these include arterial highways, the major
trucking routes for diesel tractors and trailers.
8. Agricultural areas — include peripheral por-
tions of the county in which agricultural
burning may be conducted, or agricultural
areas burned and cleared for tract develop-
ments; also dumps, hog ranches, asphalt
batching plants, concrete batching plants and
other dusty or malodorous industries.
The sources of air pollution to be inspected consist
of a total of approximately 16,000 industrial and com-
mercial establishments and all local, state and federal
governmental facilities containing sources of air pollu-
tion* This potential includes, in the southern part of
the county, 19 major and independent oil refining in-
dustries with a total throughput capacity of crude oil
of about 730,000 barrels per day, and a finished gaso-
line product of about 16 million gallons per day. The
area is also served by 11 oil-fuel burning power plants
with a capacity of 14,000,000,000 kilowatt hours.
Mass sources also include about 3,000,000 motor ve-
hicles, including trucks and buses which must be ob-
' L.A. Co. A.P.C.D., Activity Location Maps, March, 1959.
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96
Air Pollution Control Field Operations
served for smoke pollution. A breakdown of the major
air pollution potentials, as of March 1959, follows:
Asphalt Paving "Hot Plants" 34
Asphalt Saturators - 11
Brass Foundries 97
Cast Steel Foundries 25
Galvanizing and Tinning Plants 23
Grey Iron Foundries 45
Meat and Fish Smoking Plants 44
Paint Manufacturing Facilities 25
Petrochemical Plants 13
Public and Privately Owned Power
Plants 11
Refineries 19
Rendering Facilities 26
Secondary Metal Melting Plants 49
Tire Manufacturing Plants 5
These represent major potentials whose compli-
ance is assured through field control operations. Other
air pollution potentials resulting from such sources as
auto exhaust and organic solvents may be subject to
control pending completion of research projects and
passage of control legislation.
In addition to the major sources of air pollution,
other industries requiring less attention as a whole
must still be inspected. These include such industries
as aircraft and automobile assembly plants, metal fab-
ricating plants, woodworking plants, aluminum foun-
dries and other non-ferrous industries other than
aluminum or brass, bulk loading and marine refueling
stations, grain and feed mills, totalling together with
the major sources, but exclusive of commercial estab-
lishments, some 5,000 plants. Although such plants
may not present large contributions to the total air
pollution problem, they may cause local nuisances.
In order to overcome problems presented by this
diversity and complexity of the sources and the mag-
nitude of the land area, it is necessary to make inspec-
tion assignments according to the following:
Sector patrol and inspection
Scheduled inspection
Specialized enforcement
Citizens' reports
Aerial inspection
1. Sector Patrol and Inspection
The decision to employ a geographical sector
system is determined by the fact that individual
inspectors must operate over a limited land area in
order to locate, observe thoroughly and inspect a
certain number of plants. The sector system is useful
in dividing up equal amounts of work loads among any
given category of field inspector, assures that plants of
equal importance receive equal attention, and provides
a system whereby all of the field responsibilities,
activities and the sources of air pollution may be easily
located and assigned.
The size of a sector is based on the number of
man-hours the sector required to perform the essential
routine inspections in the sector. A sector with a lower
source density will be larger in area than one which is
highly concentrated.
The first determination of the size of the sector is
usually made experimentally since the time it takes to
inspect the actual number of equipment units is unde-
termined. The first sector boundaries may be estab-
lished from rough estimates of source densities and
locations compiled from Chamber of Commerce sta-
tistics, telephone directories, preliminary surveys, etc.
After inspectors have been assigned to the sectors, the
amount of time required to perform the various field
inspections is ascertained. Time factor units may then
be averaged for each significant source of air pollution
in the sector and situated on a map of the pollution
zone. The sector boundaries may then be adjusted to
provide areas of equal work loads in terms of man-
hours while compensating for such factors as travel
time, accessibility of sources. The sector division,
of course, can never be perfectly accurate, but it can
be used to correct outstanding discrepancies resulting
from previous procedures.
In Los Angeles County, sectors are weighted by
the time necessary to conduct an inventory inspection
of each piece of equipment in the sector. One-half of
approximately 2,000 man-hours per year available for
each sector are allocated to inventory inspections, and
the remainder to other duties.
The inspection sector which results then repre-
sents that amount of work an inspector can complete
in a year.
a. Patrol and Engineering Inspectors
In Los Angeles County, a Patrol Inspector and an
Engineering Inspector are assigned to each sector,
under separate supervision. The Patrol Inspector is
concerned with the activity of the sector as a whole,
the Engineering Inspector with each industrial plant
in the sector.
The Patrol Inspector thoroughly and systemati-
cally patrols the sector for all visible violations which
may issue from stationary and vehicular sources of
air pollution. He answers all complaints dispatched to
him and provides whatever other field assistance may
be requested by other inspection personnel in his
sector. The important characteristic of the Patrol In-
spector is his mobility, unencumbered by the paper
work that must accompany more technical inspections,
thus promoting a higher degree of ground coverage.
The patrol coverage enables a reasonable percentage of
the control jurisdiction to be kept under continuous
observation each day. Another benefit is also conferred
by the activity of the Patrol Inspector. Since he is
uniformed and patrols in a clearly marked black and
white emergency vehicle he poses a definite visible
deterrent to negligent operation of equipment by
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98
Air Pollution Control Field Operations
would-be violators. The Patrol Inspector thus serves
as a first-line of defense against any mass emission of
visible air contaminants.
The Engineering Inspector systematically inspects
all of the pertinent equipment units in each plant in
the sector for the purpose of conducting an inventory
inspection and determining compliance with the Rules
and Regulations. He especially checks for possible vio-
lations resulting from the emission of invisible con-
taminants, and requests source tests when violations
are suspected. The most important overall aspect of
his work, however, is ferreting out all equipment units
which require permits and which are inadequate by
current standards. The Engineering Inspector also
handles complaints directed against any industrial
establishment, as well as serving notices for any viola-
tion he observes.
2. Scheduled Inspections
During most of the time that the Air Pollution
Control District has been in operation, the responsibil-
ity for scheduling inventory inspections and, in a
sense, managing each inspection sector, was delegated
to the inspector under the assumption that with proper
experience, qualification and training, the inspector
would adopt effective inspection methods suitable to
each sector. Considering the inadequate number of
personnel employed in the early years of the District's
operation (variously between 12 and 20 inspectors for
the entire 4,000 square mile area) reliance was placed
on the judgment of trained field inspectors. It could be
said of this system that, while not all of the sources of
air pollution were contacted, or were not contacted
frequently enough, most of the significant sources of
air pollution in the county, such as the foundries and
steel mills, were brought under control. At that time
the emphasis was not on saturation, but selective cov-
erage. This initiative system worked most effectively
in terms of the manpower then available.
However, as the major offenders were brought
under control, and as Los Angeles County grew, even
greater reduction in pollution potentials was required
from all of the sources of air pollution. This system
thus fell short of the aggressive inspection program
outlined previously in at least two respects. First, it
was not able to assure certain inspection of all sig-
nificant sources of air pollution, failing to provide ac-
curate knowledge of the degree of compliance and non-
compliance at all of the sources of air pollution. Infer-
ences cannot be as accurately drawn from infrequent
observations and inspections as they can from more
frequent surveillance. It became apparent that there
was one frequency of inspection which encouraged an
operator to take calculated risks, and another which
discouraged him. Secondly, not all inspectors applied
the same methods and techniques, and not all would
evaluate the same sources of air pollution in exactly
the same way.
It therefore became necessary to devise a system
of scheduled inspections in order to assure adminis-
tratively that the major sources of air pollution were
inspected as frequently as necessary everywhere in
the pollution zone and that minor or insignificant
sources were inspected less frequently.
The scheduling of inspection assignments is based
on the data and experience gained from previous in-
spections. It requires that all files and record-keeping
be classified and maintained on a continuous basis so
that the number of plants ready for inspection may be
compiled each month for each sector. Such a system
can be based on a Master Punch Card and Key Sorting
System used for selective analysis of master record
cards, described in Part VII "Maintaining Record
Systems" of this chapter. In the Enforcement Division
a list of such plants is forwarded from the Records Sec-
tion to the Head Inspectors for scheduling.
The frequency of inspection is based on some
measure of the complexity of the plant as indicated by
the number of equipment units, the type of equipment
and processes employed, and the time required to con-
duct reinspections. A larger and more complex plant
will, in general, have a higher degree of probability
for change and, hence, will be susceptible to permit
infractions. Such plants require more time to inspect,
and must be inspected more frequently. The fre-
quency of reinspections assigned to industrial plants
ranges from less than once per year (Frequency "0")
to three times per year.
3. Specialized and Selective Enforcement
In fashioning an enforcement program to the
needs of a complex industrial economy, it soon be-
comes apparent that assignments made solely on the
basis of sectors restricts the field operation to the
handling of only the most common types of enforce-
ment problems. The adequacy and thoroughness of
the inspections of technologically complicated indus-
tries are left to chance and to the initiative and interest
of the sector inspector. It is obvious that to adequately
inspect these industries it is necessary to assign in-
spectors with special training or qualifications. This
approach is known as specialized enforcement. It is
intended to bring to each significant air pollution prob-
lem the special skills that may be required.
Specialization has already been noted in the func-
tions of the Engineering Inspector and the Patrol In-
spector. Engineering Inspectors are assigned to one of
two specialized sections, the Industrial Engineering
Inspection Section, and the Refinery and Chemical In-
spection Section (see Figure VI-1). Within each of
these sections are two further divisions of personnel,
the sector inspectors, and special inspectors or "selec-
tive" enforcement teams. In the Patrol Section,
inspectors may further specialize into a Vehicle Unit
(trucks and buses), ship inspection at marine termi-
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Air Pollution Control Field Operations
99
nals, agricultural and open burning situations, and
surveillance of plants in special enforcement problems.
Specialized enforcement is intended to provide:
(1) the special skills required to conduct routine in-
ventory and other inspections in complicated or highly
technical industries, and (2) a procedure which brings
to the attention of field personnel those chronic or
marginal air pollution problems which may exist or
develop in any industry and which require unusual
treatment. This second phase is referred to as "se-
lective" enforcement. These programs are necessi-
tated by the lack of effective control techniques within
certain industries, or by sensitive air pollution prob-
lems requiring strict supervision of operating and
maintenance practices inside the plant. To illustrate
a few of these situations: some industries may be the
object of continuous complaints and may repeatedly
create a public nuisance in a general locality, even
though the industry may otherwise operate in com-
pliance. Others may operate equipment which con-
tinuously emits opacities of pollutants just below
violation thresholds. Others may employ equipment
which is obsolete and inadequate by current control
standards, but are permitted under the grandfather
clause (Rule 13).*
Assignments are made by industry, or by related
production or process units. For example, the Refinery
and Chemical Section of the Enforcement Division is
generally assigned all industries which are either
related in process, in principle, or in complexity to oil
refining, production and manufacture of petroleum
products, chemical manufacturing, chemical deriva-
tives and related industries. Detailed assignments are
made to the following:
1. Oil Production and Transportation Facilities.
2. Petroleum Refineries.
3. Tank Farms.
4. Petroleum Marketing Stations, Bulk Plants.
Service Stations, Marine Terminals.
5. Gasoline Absorption Plants.
6. Sulfur Recovery Plants.
7. Petrochemical Plants.
8. Chemical Plants.
9. Asphalt Roofing Plants.
10. Asphalt Manufacturing Plants.
11. Paint and Varnish Manufacturing.
12. Soap and Detergent Manufacturing.
13. Public and Private Power Plants.
14. Oil Reclaiming Plants.
* This APCD Rule automatically grants permits to equipment
constructed prior to February 1, 1948. See Chapter 14, REG-
ISTERING THE SOURCES OF AIR POLLUTION.
The oil refining industry, itself, representing an
unusually high degree of industrial complexity, is fur-
ther unitized for special assignment as follows:
Separation Processes
1. Fractional Distillation Unit.
2. Gas Absorption Unit.
3. Solvent Extraction Unit.
Conversion Processes
1. Cracking, TCC and FCC Units.
2. Polymerization Unit.
3. Alkylation Unit.
4. Hydrogenation Unit.
5. Dehydrogenation Unit.
6. Isomerization Unit.
7. Reforming Unit.
8. Hydroforming and Platforming Units.
Manufacturing of Products
1. Gasoline.
2. Grease, etc.
a. "Selective" Enforcement
While specialized enforcement refers to the total
enforcement treatment of an entire class of industry
(such as oil refineries and chemical plants), "select-
ive" enforcement brings to complicated air pollution
problems the skills of inspectors with appropriate tech-
nical training and knowledge. Selective enforcement is
primarily interested in obtaining final solutions to
chronic pollution problems which are not adequately
defined, or for which no adequate inspection or control
techniques exist, and to provide intelligence for possi-
ble administrative or even extra-legal solutions to these
problems.
Since the inspectors of the Refinery-Chemical
Section of the APCD possess a level of expertise which
enables them to conduct thorough inspections in refin-
ery and chemical plants, and to also handle other
industrial problems within their geographical area),
selective enforcement functions in that section are con-
ducted on a routine basis. In the Industrial Inspection
Section, however, special selective enforcement assign-
ments, distinct from routine sector assignments, are
necessitated due to the large variety of industries and
air pollution problems handled by that section. In
particular, engineering inspectors are assigned to the
following:
Rendering plants and Smokehouses
Chemical Plants
Paint and Plastics Industries
Ferrous Metals
Non-Ferrous Metals
Dusty Industries
Paint Spray Installations
Special Investigations
-------
100
Air Pollution Control Field Operations
The engineering inspectors involved perform a
number of functions concerning the technical aspects
of the air pollution problems of these industries. These
include:
1. Keeping abreast of the technological advances
and changes which may affect air pollution
potentials or compliance.
2. Making determinations and appraisals of air
pollution and nuisance potentials in these in-
dustries.
3. Informal suppression of air contaminants not
adequately covered by existing rules. Con-
certed effort at control may result in the com-
plete control of housekeeping problems which
may be individually of a minor nature, but
collectively significant.
4. Gathering of data in relation to the above and
to the exploitation of "loop-holes" in the laws.
These data may be used in the promulgation
of new rules or amendments.
5. Determination of the possibility of emission
of "invisible" contaminants by careful scru-
tiny of industrial process, or by recommending
source testing.
6. Achievement of certain control of marginal
and chronic violators.
7. Conducting general liaison and public rela-
tions with industrial plants to induce favorable
conditions for cooperation and voluntary
action.
8. Handling of problems referred from other in-
spection sections and personnel, as well as
inspections and follow-ups involving denials,
variances, engineering final reports, violation
notices involved with these industries, and
special memoranda and instructions issued by
the Director of Enforcement and his staff.
9. Conducting surveys involving special situa-
tions such as Rule 62, filter controls, etc.
10. Providing technical assistance and training for
other enforcement personnel.
The selective enforcement process consists of re-
view and enforcement functions. The review function
consists of (1) preparation and maintenance of status
charts for all industries which may have unique,
chronic, or difficult types of air pollution problems,
from data supplied from inspection and enforcement
records, and (2) evaluation of these data to determine
either the nature of the specific problems occurring in
these industries, or the absence of information required
to make a thorough evaluation of compliance.
The sources of air pollution which require atten-
tion are then inspected to obtain a complete compli-
ance determination, or to initiate remedial measures or
enforcement action. The inspection may be conducted.
jointly with the sector inspector involved, with a
senior engineering inspector, or individually by the
selective enforcement inspector. Selective Enforce-
ment personnel also perform relief inspections in the
absence of the regular sector inspectors.
4. Aerial Inspection
A ready check on all of the activities in the pollu-
tion zone can be made daily from an airplane. With
reasonable visibility an aerial observer can instantly
detect any plume anywhere in the pollution zone. A
trained observer, by means of maps, can identify the
location of the plume and, in some instances the in-
dustry involved or even the company name. Observers
are thus experienced with the layout of the pollution
zone as well as the sources. The effectiveness of aerial
inspection, however, depends on whether or not a
radio-communications system is employed by the
agency since that is the only satisfactory means by
which field units can be directed to the source of
pollution being observed.
Aerial inspection is especially useful as a check
on actual ground field coverage, but it cannot substi-
tute for that coverage. A.P.C.D. experience has shown
that most sources observed from the air are independ-
ently observed by ground units. In other instances,
ground units are not able to get through traffic or
travel the long distances involved to reach the source
reported by the aircraft in time to observe a violation.
Aerial inspection is further limited to days of good
visibility and daylight hours.
5. Citizens' Reports and Complaints
The public itself is also in a position to observe
and to report special pollution problems or nuisances
since individuals tend to be sensitive to any visible
plumes or clouds of pollution in the community. In
this case, the surveillance factor is virtually universal
and continuous.
In the Los Angeles Basin, for example, not only
is the public aroused to the general smog problem, but
the basin is so inhabited as to expose most of the
sources of air pollution to ordinary observers. The
basin is primarily a flat land area from which plumes
of air contaminants may be observed at long distances,
and especially from the many homes located in the
hills surrounding the basin and valley areas. More-
over, due to the rapid growth of the Los Angeles area,
zoning of property has not progressed on an orderly
basis, at least from the point of view of air pollution
control. Consequently, many residential areas have
been surrounded by large industrial sources of air
pollution.
The complaints resulting from this condition are
of great assistance in locating and determining fre-
quency of violations and in directing inspectors to the
violations when they occur, and to the major sources
of air pollution. By means of a radio-communication
system, and the deployment of zone inspectors, it is
thus possible to dispatch field inspectors to the sources
of air pollution complained of during the time of the
-------
Air Pollution Control Field Operations
101
Figure VI - 4. Aerial observation of a source of
air pollution: weed burning, North Long Beach.
LJ
Figure VI - 6. A.P.C.D. Communications Center.
©<
D®
©
©
©
©
©
©
©
Figure VI - 5. Layout of A.P.C.D. Communications Center. A—
operator positions, B—watch commander's position, C—micro-
phones (on booms), D—time stamping machines, E—telephones,
F—radio consoles. G—automatic coding transmitters, H—bulle-
tin board for memos and instructions, J—metal file drawer for
filing of radio logs as required by the F.C.C., K—large sector
reference ma;p of Los Angeles County.
-------
102
Air Pollution Control Field Operations
violation. This is an important factor since no legal
action can be taken unless the inspector witnesses the
violation and all of the attendant facts.
6. Radio Communications
An important aid to the detection of the sources
of air pollution is the use of radio-communications
system for the instruction, integration, and location of
all field units. In Los Angeles, a radio-communications
system became necessary for the following reasons:
1. Preparedness in enforcing the emergency pre-
vention regulations made the use of a radio-
communications system mandatory.
2. Necessity to reach complainants and violators
quickly to obtain the necessary evidence.
3. Field units require certain types of informa-
tion necessary to completing inspections. Such
information pertained to status of variances
and reported breakdowns which are available
at Headquarters.
4. Headquarters may require the immediate dis-
position of any complaint handled, or any air
pollution problem of special interest.
5. Where activities are specialized into distinct
field units such as Refinery and Chemical,
Patrol and Industrial, field coordination may
be conducted satisfactorily only by means of
radio communications.
6. In order for aerial inspection to be of any
practical use, a radio-communications system
is necessary to transmit information from
aerial to ground units.
7. It is also desirable that Supervisors be able to
dispatch special instructions to field units as
may be required.
The District's communications system consists of
two console radio transmitters operated by radio-
telephone operators. The consoles are connected by
direct wire to a main power transmitter located at a
Sheriff's Station (Biscailuz Center) in East Los An-
geles. The transmitter has an effective radiated power
of 250 watts operating on a modulated frequency band
of 39.98 megacycles. The base station is known as
KMF 964, whereas the field units, some 100 of them,
are each known as KA 4306. The communications sys-
tem also contains a special radio transmitter with
selective calling facilities for the purpose of broadcast-
ing the declarations of alerts and information and in-
structions to the categories of industries specified in
the emergency regulation.
7. Emergency-Response Capability
In addition to the use of a central radio communi-
cations system, the black-and-white emergency vehicle
equipped with sirens and lights, as authorized by Sec-
tion 120 of the California Motor Vehicle Code, and
used in patrol duty, has greatly facilitated the emer-
gency-response capability of the District.
The very nature of air pollution control opera-
tions in Los Angeles County has required an alert and
swift field response capability. Particularly with
respect to air pollution emergencies, inspectors must be
prepared to reach any point in the 1200 square mile
area of the Los Angeles Basin in sufficient time to ob-
serve emissions of toxic contaminants, determine their
identity and concentration, ascertain the existence or
non-existence of a hazard, warn inhabitants, locate the
source of the contaminants and the cause of the emis-
sion, notify responsible parties to obtain immediate cor-
rective action, and secure the proper evidence in order
that violations of the law may be prosecuted to deter
re-occurrence of such episodes. Unlike most other
types of law enforcement activities for which evidence
can be secured after a crime has been committed, in
air pollution enforcement work, legal evidence can
only be obtained on the scene and at the time of the
violation or emergency by a qualified member of the
A.P.C.D. Obviously, considering traffic congestion, and
the size of Los Angeles County, this response capability
depends entirely on radio-communications and on the
geographical deployment of emergency vehicles.
The emergency vehicle is required in Los Angeles
County to enforce and implement various provisions of
the Health and Safety Code, the Rules and Regulations,
particularly Regulation VII (Emergencies), and Sec-
tion 27153 (excessive emissions from motor vehicles)
of the Vehicle Code. It enables personnel of the Dis-
trict to:
1. Respond to localized air pollution dangers and
disasters.
2. Implement any orders given by the Air Pollu-
tion Control Officer during a Regulation VII
alert.
3. Maintain emergency access 'to the roadways,
streets, highways and freeways of Los Angeles
County during Regulation VII alerts.
4. Provide supplementary on-the-spot sampling
of atmospheric contaminants in areas of un-
usually severe contamination during a Regu-
lation VII alert.
5. Provide access to air monitoring stations dur-
ing such alerts.
6. Verify industrial shutdowns called during an
alert.
7. Assist in the curtailment of vehicular traffic
during an alert.
8. Coordinate activities of other enforcement
agencies during an alert.
9. Halt, inspect and cite moving motor vehicles
in violation of air pollution control laws on the
roadways.
10. Monitor radio-active contaminants resulting
from accidental discharge or from nuclear
war.
-------
Air Pollution Control Field Operations
103
III INSPECTION OF THE SOURCES OF
AIR POLLUTION
The next step in field control operations is the
inspection of equipment in the industrial and commer-
cial plants located in the inspection sectors. The
smallest and most important unit of inspection is the
equipment unit — that unit of equipment which
would legally constitute a single source of emission.
Most often the equipment unit is a single piece of
equipment: a boiler, a furnace, an incinerator, con-
stituting the equipment unit or the single source of
emission. *
Two types of inspections are made of equipment
units: (1) violation inspections, and (2) inventory in-
spections. We may also consider, in relation to these
inspections, follow-up and periodic reinspections, and
complaint and miscellaneous inspections.
A. Violation Inspection
The violation inspection is usually conducted on
the occasion of observing a violation of a legal standard
committed by, or involved with, a single equipment
unit. The violation may be observed by an inspector
patrolling an area, or by an inspector inside of the
plant. There are three phases of the violation inspec-
tion: (1) observation, (2) investigation, and (3) re-
port and notification.
The first phase of the violation inspection consists
of the observation of the violation by determining the
excessive emissions of air contaminants, by substanti-
ating the existence of a public nuisance, or by deter-
mining illegal construction or operation of equipment.
These three broad categories of violations in turn
involve more than 20 different laws and rules which
the inspector enforces (see Chapter 3).
The second phase of the violation inspection con-
cerns the investigation which is made to determine the
facts and to obtain evidence as to the causes of the
violation, such as responsibility, operation and design
factors contributing to the violation.
The third phase of the violation inspection consists
of the writing and serving of a written Notice of Vio-
lation, if the equipment involved is stationary, or a
Citation, or Vehicle Notice, if the equipment is a motor
vehicle. The Notice or Citation is written to include
an accurate description of the violator, ownership re-
sponsibility, or negligence involved in the commission
of the violation, and the cause of the violation in order
to establish a prima facie case in the event that legal
action is taken.
B. Inventory Inspection
The inventory inspection is conducted for the
purpose of identifying and listing all equipment units
capable of emitting air pollution located in all individ-
ual commercial, industrial and governmental establish-
ments. Unlike the violation inspection, the inven-
tory inspection groups equipment units into activities
* For definition of equipment unit, see Chapter 14.
or source locations. The inventory inspection thus
assures the registration of all important sources of air
pollution in the pollution sector. In particular it pro-
vides:
1. A record and identification of all equipment
capable of emitting air contaminants at each
activity location.
2. Determination of the exact permit status of
each piece of equipment and all permit in-
fractions.
3. A reference file which will assist inspections
and investigations of public nuisances or vi-
olations.
4. Systematic coverage of sectors and statistical
tabulation to determine work-load require-
ments.
5. Data for the construction of Plant Status
Charts for use in special enforcement activities.
Status charts for use in special enforcement
activities.
The inventory inspection is the most complete
type of inspection made of source activities since it
requires a detailed inspection of each piece of equip-
ment involved. The inspector conducting the inven-
tory inspection ascertains compliance with all of the
Rules and Regulations and the State Laws affecting
air pollution.
The inventory inspection may lead to a number
of subsequent actions. An APCD Permit Request may
be issued for equipment which requires a permit or
a Notice of Violation may be written for excessive
emissions, or alteration or illegal construction of
equipment.
C. Follow-up and Reinspection
Both violation and inventory inspections may
involve follow-up inspections. For one reason or an-
other, the inspector may not be able to complete all
three phases of the violation inspection on his initial
inspection stop and he may be required to return at
some other time to gather all of the evidence. The
inventory inspection may also involve several follow-
up inspection stops. If a permit request is issued, a
follow-up may be required to assure the submission of
applications, or if equipment is being constructed with-
out authorization, a follow-up will be required to
determine that unauthorized construction is not con-
tinuing. Each stage in the process of obtaining a per-
mit may, in fact, require a follow-up reinspection.
D. Complaints and Miscellaneous Inspections
Other types of inspection involve investigation of
public nuisances, breakdown of equipment, answering
complaints, follow-ups on denial of applications, vari-
ances, engineering final field reports, and any other
assignments which may be necessitated.
The collection of data for each of these categories
of inspections is discussed in greater detail in following
Chapters of this manual.
-------
104
Air Pollution Control Field Operations
IV REPORTING RESULTS OF INSPECTIONS
The field report is a record of an event occurring
at a specific time in relation to an actual or potential
air pollution problem. Although it is not evidence
itself, it constitutes the relevant facts upon which an
event can be reconstructed into evidence in a court of
law. The inspector's report also provides data from
which enforcement operations and inspection tech-
nique can be improved.
The inspector prepares a report covering his in-
spection made of equipment units at each location.
As a means of definitely fixing responsibility for the
ownership and operation of equipment units, all re-
ports are titled and filed according to the name of the
company or individual, and the address of the location
inspected.
Field reports fall into three general types: (1)
investigative, (2) descriptive and statistical, and (3)
administrative or work reports.
A. Investigative Reports
In an investigative report the inspector relates the
facts developed from a physical inspection of equip-
ment units involved in a specific or potential air pol-
lution problem. The object of the report is to determine
whether the equipment violates a standard, is capable
of violating the standard or complies with the standard.
The investigation report consists basically of five
parts: (1) corporate and/or individual responsibility,
(2) identification and location of the equipment
unit(s) being investigated, (3) the Findings, consist-
ing of a report of the objective facts, (4) statements of
all persons made under interview, and (5) conclusions
and recommendations made by the investigating
inspector. (See Chapter 7.)
The investigative report is designed and written
so as to enable a reviewer to readily reconstruct the
incident. If the situation covers a violation, all of the
elements of a corpus delicti are logically incorporated
into the report. (See Chapter 13.)
Investigative reports are acted upon in two dis-
tinct ways. In one instance the report is negative —
no legal action is required; in the other, it is positive,
the report must be processed towards prosecution of
the violator. A negative report is made on an In-
spector's Report (Figure VII-7), an Activity Status
Report (Figure XIV-9) or other functional or special-
ized types described below. The positive report is
usually made on a Notice of Violation (Figure XIII-1)
or Citation (Figure XIII-4) as described below.
1. The Inspector's Report
The Inspector's Report is a general report made of
the results of an inspection. It does not immediately
initiate court action. In the main, this report develops
ownership data, location and identification of the
source of air pollution, responsible parties contacted,
the inspector's findings, recommended action and re-
ferral notations. When filed, these reports evolve into
case histories for use in future enforcement work.
In the A.P.C.D., various forms of the Inspector's
Report are used. The Inspector's Report (see Figure
VII-7) is used to cover investigations made of com-
plaints, reported breakdowns of equipment, permit-
denial and permit follow-up inspections, and other
situations in which the findings may be briefly re-
ported. Another form of the general Inspector's
Report is the Activity Status Report (see Figure
XIV-9) which is limited primarily to (1) reporting
results of specialized or technical inspections such as
those concerning complicated flow of processes or
products and (2) reporting changes in permit status,
inventory or compliance on inventory reinspections
when a new Equipment List (see below) is not
required.
Other forms of Inspector's Reports may be de-
signed to cover the inspection of just one type of equip-
ment (such as a gasoline storage tank) or a situation or
circumstance involving a specific rule (such as Rule
10, Permits Required, etc.). These reports tend to be
mostly of the standardized-blank completion variety,
since the same information is required in each case.
An example of this type may be found in Figure
XIII-7, Inspector's Questionnaire for Steamships which
concerns boilers only. In this form all of the data
required is categorized and presented so that it can be
supplied merely by filling in the required information.
A circumstantial report, on the other hand, may
be typified by the Request to Apply for APCD Permit
(see Figure XIV-17). This report is made when a
piece of equipment requires a permit. The Findings
on the form are broken down into categories which
document the reasons the application for permit is
mandatory. Such data as "date construction started",
"degree of construction", "reason permit is required",
"date permit became necessary", etc., are completed
in the proper spaces on the form.
In the sense that the operator is notified that a
permit is required, and must submit the applications
or face the legal consequences under permit require-
ments (Rule 10), the Request is positive. However,
since no legal action is intended by the request itself,
it is here considered as a negative report requiring a
follow-up inspection (permit follow-up inspection).
2. Notice of Violation
This is a positive report form since its very use
indicates that legal action is required. The Notice
contains the essentials of the Inspector's Report de-
scribed above but, in addition, presents a more rigorous
description of the Findings in order to establish a
prima facie case. It also prominently displays a
specific charge made in the second person to the vio-
lator, declaring that a violation of a state code section
or District Rule has been committed (see Figure
XIII-1). A duplicate copy of the charge portion of the
-------
Air Pollution Control Field Operations
105
Notice is served to the violator. The original copy
reports the findings of the investigation on the reverse
and is forwarded to the inspector's supervisor for re-
view and preparation of the court case. In the
A.P.C.D., the Notice of Violation takes two forms, the
"F-type" for stationary sources of air pollution, and
the "V-type" for vehicular sources when Section 24242
is being applied only (see Figure XIII-5).
3. The Citation
The Citation is another form of a positive report
but is limited to citing violators of Section 27153 of the
California State Vehicle Code, which prohibits ex-
cessive emissions from vehicles. The citation differs
from the Notice in that it constitutes the court com-
plaint itself. The Notice, on the other hand, requires
preparation of a separate court complaint, and has no
legal force in itself.
The citation is made in quadruplicate. The first
copy is the court complaint, the second is reviewed
and filed for record, the third is the driver's copy, and
the fourth is retained in the citation book to refresh
the inspector's memory should he be required to ap-
pear in court (see Figure XIII-4).
B. Descriptive Reports
The second type of report is the descriptive report.
This type is used to cover all situations in which the
investigation sequence is not employed, and the pri-
mary purpose of the inspection is to list or to identify
equipment, or to describe or draw flow processes, or
to present data for subsequent statistical tabulation.
The most important descriptive report used by the
A.P.C.D. is the Equipment List (see Figure XIV-3).
This is a record made of the inventory inspection
itself. It is used to inventory all sources of air pollu-
tion which may be found at industrial or commercial
locations. It consists of the following report sections:
(1) all pertinent ownership and plant responsibility
data, (2) descriptive identification of each piece of
equipment in the plant, (3) determination of the per-
mit status of each piece of equipment, and (4) the
reinspection record. The Equipment List also classifies
other information to assist in scheduling work assign-
ments in the inspection sectors. (See Chapter 14 for
detailed explanation of the Equipment List and other
descriptive reports.)
C. Work Reports
The work report or, as it is known in the
A.P.C.D., the Daily Report, is a daily record made by
the inspector of all inspection stops and reports made,
in chronological order of performance as well as any
other field or office work not involving inspection (see
Figure VI-7).
The Daily Report is used for review purposes, to
check completion of assignments, work efficiency and
to tabulate the number of inspections or man-hours
spent in the field in the various categories of field
duties. The Daily Report also shows sector coverage
in terms of areas patrolled, plants observed and miles
driven.
V. REVIEW AND DISPOSITION OF REPORTS
The review process, in essence, is intended to
maximize and validate the data and evidence collected
by the inspector since important legal use may be
made of this information at any time.
All of the reports, together with the Daily Report,
are assembled each day by the inspector's immediate
supervisor, the Senior Engineering Inspector, for re-
view, correction and disposition. The Senior Inspector
performs the following when reviewing the reports:
1. Checks all reports for accuracy, completeness
of data or evidence of violation.
2. Corrects or returns for correction reports
which are incomplete or in error and instructs
or trains the inspector accordingly.
3. Checks the completion of all assigned inspec-
tions.
4. Checks work for general efficiency, ability,
conscientiousness, etc.
5. Disposes of reports or takes appropriate action.
By his review function, the Senior Engineering
Inspector coordinates field and headquarters operations
towards the completion of all inspection and enforce-
ment activity.
In determining accuracy, reports must be system-
atically and carefully checked. Especially important
are the specific elements of the crime, the corpus
delicti, the names and addresses of responsible parties
involved, opacity and Ringelmann values and time
intervals of violations, as well as a record of all per-
sons involved (see Chapter 13). In permit cases, an
accurate and specific description of status and such
facts as degree of alteration or modification, date of
change of ownership, relocation of equipment, exemp-
tions, must be accurately ascertained and described
(see Chapter 14).
The disposition of most reports is predetermined
since routine processing is set up for each report.
Actually, the action to be taken is initiated by the
inspector himself. The review process, in essence, is
concerned with confirming, challenging, or correcting,
if necessary, the inspector's judgment. If the inspector
observes a violation and is able to collect the necessary
evidence, then he must write a Notice or Citation,
whichever is the case. If the Notice is valid, it must
then be processed towards prosecution. If the inspector
does not observe a violation, or he is unable to acquire
the necessary evidence, then he must use the proper
form of the inspector's report. The function of the
report thus determines the disposition and routing
procedure, as follows:
1. If the report is a Citation, Notice of Violation,
or an Inspector's Report recommending legal
-------
INSPECTOR'S DAILY REPORT
DOE, JOHN B.
INSPECTOR'S NAME
DATE JUNE 27th
DETAIL
PATROL
TIME
STARTED
7*50
8:00
8:15
9:15
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Ll:20
L2:30
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5:30
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ENDED
AM
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2:00
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PM
ZONE
18
llli
(PR 1 NT) BADGE NO.
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WATCH CALL NO.
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1 HOURS
REASON : C -1859
AUTHOR. BY: ROBERTS
LOCATION OF ACTIVITY
STREET
NUMBER
123
r
1252
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S.
PASADENA AVENUB
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MAIN STREET
S.
N.
SAN PEDRO STREET
ATLANTIC BLVD.
50th ST. & SOTO ST.
W.
AVENUE 26
S.
VERMONT AVENUE
CITY OR
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L.A.
L.A.
NAME
TOTAL TIME WORKED
FIELD TIME 8
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TIME 1
COURT TIME -
TOTAL 9
OF ORGANIZATION
OR PERSON CONTACTED
HOME
PATROL
JONES POUTJTRT
MR. HARRY JONES
PASADENA MFG. CO.
MRS. J. SMITH (COMP.)
MR. ROBT. JORDAN (SOURC1
LUNCH
A.P.C.D. HG.
ARROWHEAD PRODUCTS
CONSOLIDATED TRUCK CO.
JAMES BURNER CO.
PATROL
HOME
AIR POLLUTION CONTROL DISTRICT-LOS ANGELES COUN
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Figure VI - 7. The Inspectors Daily Report is used to report chronological inspection and enforcement activities, and to tabulate the results of such activities.
-------
Air Pollution Control Field Operations
107
INSPECTOR
Writes Notice in the field and
brings original copy to Head--
quarters
THE SENIOR ENGINEERING
INSPECTOR
Reviews Notice for completeness
and accuracy, and forwards it to
the
THE SENIOR CLERK
Logs the Notice in the Master
Control Log and pulls the back-
file of the defendant, and for-
wards it with the notice to the
THE INVESTIGATOR
Processes the Notice as follows:
1) Investigates ownership of
company through corpor-
ate files, business licenses,
Department of Motor Ve-
hicles, and other agencies,
as may be necessary.
2) Dictates court case on the
"Request for Complaint"
forms.
3) Enforcement Director signs
the Request.
4) Files "Request for Com-
plaint" with the prosecut-
ing attorney.
5) Files both "Request for
Complaint" and the "Mis-
demeanor Complaint" in
the court of proper juris-
diction.
r\ serves copy
~L/to VIOLATOR
SENIOR
CLERK
-fS INVESTIGATOR
Inspector's
Notice
Filed
THE COURT
Holds arraignment,
Defendant is sentenced if "guilty plea'' is
entered; date of trial is set if "not guilty"
plea is entered.
Court or jury trial.
Sentencing, if guilty.
Figure VI-8. Processing of written notices of violation.
action, it is forwarded to the Investigation
Detail for court processing (see Figure VI-8).
2. If the report is a Request to Apply for APCD
Permit, or other inspector's report covering
permit matters, a copy is kept in suspense for
follow-up inspection to assure submission of
applications, and another copy is forwarded to
alert the Engineering Division to the forth-
coming applications and to provide data essen-
tial to permit processing.
3. If the inspector's report calls for further
investigation or surveillance before the matter
can be resolved, it is referred to the appropri-
ate sector or special inspector.
4. If the inspector's report resulted from an
assignment, it is referred to the assignor.
5. If the inspector's report involves a policy
decision, it is referred to the appropriate staff
member.
6. If the inspector's report requires no further
action due to resolution of the problem or lack
of evidence, it is filed for reference.
Any given report may be viewed as terminal or
inconclusive. A terminal report is a report in which
the field action is reported to be completed, and is filed.
An inconclusive report is a report in which the field
action is reported as being incomplete or inconclusive.
thus requiring further investigation. Inconclusive re-
ports cover situations in which not all of the necessary
evidence is collected, or inspection results are negative,
but a violation is suspected, or processes are so com-
plicated or extensive that data must be gathered by
means of joint or coordinated inspections, or an air
pollution problem is involved for which there is no
established legal solution.
MASTER CONTROL
MISDEMEANOR VIOLATIONS
NUMBER
598^8
V-5036
V-3650
59840
C-757U
59841
F-789
5984*
F-l(058
DEFENDANTS
Janes Roe (dr.)
Consolidated Trie.
Los Angeles
Hemy Driver (dr)
Apex Trucking Co.
Seattle, Wash.
Harry Jones
1323 Simon Road
Whittier
Jones Poultry
1252 N. Figueroa
Highland Park
A .B.C. Laundry
7320 N. Broadvray
long Beach
U- O
°i=
£5
< O
o —
>
6-21
6-2^
6-21
6-21
t^s
< ~*
Q ^_
DATE 1
COMPLETED [
CHARGE
2U2U2
2U2U2
27153TC
Rule 58
OtOiZ
COURT
L.A.37
NO. OF ]
COUNTS [
1
1
1
2
1
DISPOSITION
a
i
0
i
GUILTY
OTHER
FINES ft PENALTIES
SEN-
TENCE
^
\
\
\
\
\
\
IM-
POSED
^
\
\
\
\
\
\
sus.
PENDED
^\
\
\
\
\
\
\
EQUIPMENT
INCINERATORS
s,
E
O
ID
O
X
£
i
o
ii
O.N
Ok
[VEHICLES
X
A
REMARKS
Figure VI - 9. The Master Control Log provides an accurate accounting of the disposition of each written notice issued by A.P. Inspectors.
-------
108
Air Pollution Control Field Operations
The inconclusive report may require careful eval-
uation in order to determine the type of follow-up
action that may be necessary. In these situations, the
Senior Engineering Inspector reviews the findings
carefully to determine from the facts and the inspect-
or's recommendation, the inspection techniques and
the reinspection schedule which should be employed.
The report may then be returned to the inspector for
reinspection, with special instructions, or it may be
referred to special or selective enforcement teams, or to
a patrol inspector for surveillance. In this way, all
problems which arise are handled with the fullest
competence in completing any given field action.
VI PROSECUTING VIOLATORS AND HANDLING
HEARING BOARD CASES
Although court action may appear to be the con-
cluding phase in the handling of an air pollution
violation, it should be actually viewed as a link in a
kind of circular process in which the decisions handed
down by the courts tend to influence and regulate the
field control operations program. This is done in two
ways:
1. Each step in the field control operations pro-
gram is conducted so as to be capable of fur-
nishing the court or the APCD Hearing Board
with the facts needed for a prima facie case,
and any other facts from past records which
are pertinent to a final disposition. Control
operations are conducted as if legal action
might be taken in each case, even though only
a relatively small percentage of the sources
inspected are violations.
2. The principles involved in court decisions,
particularly at the appellate level, directly
affect administrative practices, policies and
inspection techniques.
The Court and Hearing Board's influence on the
agency may be found not only in the actual disposition
of a case, but both in the anticipation of a decision
prior to the actual filing of the case, and the interpre-
tation of the final decision. Since the agency is a part
of government, it is ethically bound to all legal prin-
ciples which the courts find valid, and it must avoid
all malpractice or circumvention of principle. This
imposes several obligations on the enforcement op-
eration.
First, it is necessary to realize that courts are con-
cerned with justice, not in justifying the actions of the
control agency. The control agency is not infallible.
It is the court's purpose to determine whether or not
a defendant is guilty or innocent of allegations made.
Therefore, the handling of court cases, as well as all
legal matters, cannot be irresponsible or incompetent.
To be so is to cause the loss of cases and, hence, control
powers, by default.
Second, to operate satisfactorily in this regard,
the agency will require competent and experienced
counsel by a civil attorney.
Third, the control agency will require a special
Investigation Detail within the enforcement function
especially oriented to all of the judicial systems and
counsels affected in the pollution zone. This Detail
processes all violations towards prosecution, handles
Hearing Board cases, and acts as a liaison between the
courts, the Hearing Board, the District Attorney, the
city attorneys and the civil attorney. In the liaison
and in the processing of notices, the Investigation De-
tail must translate technical data into legal language,
and translate the decisions handed down by the courts
into administrative and operational terms. This may
actually result in the training or retraining of field
personnel, or the modification or elimination of certain
inspection techniques.
In the Los Angeles County Air Pollution Control
District the civil attorney employed is the County
Counsel of Los Angeles and his legal staff. The
County Counsel hands down opinions to the District
on any matter or subject requested. The County Coun-
sel also functions to initiate civil action in injunction
proceedings and handles cases before the Air Pollu-
tion Control Hearing Board.
The Investigation Detail of the Enforcement
Division processes all notices of violation received from
the field operations groups towards prosecution, pro-
vided that the evidence is valid.
Most air pollution cases are misdemeanor actions,
and are tried in Municipal or Justice Courts in the
locality in which the violation occurred. Injunction
proceedings, which occur rarely, are processed in the
Superior Courts. Still other cases which may be ap-
pealed from Municipal or Justice Court decisions may
be further heard in the appropriate appellate court.
In addition to the courts, the Investigation Detail
prepares cases handled before the Air Pollution Con-
trol Hearing Board. These are initiated by correspond-
ence with the County Counsel who prepares the
petition to be filed with the Hearing Board.
Because we shall not treat it elsewhere again, the
various steps in the enforcement action will be dis-
cussed with respect to (1) court cases and (2) hearing
board cases. To recall the legal authority exercised by
the Los Angeles County Air Pollution Control District,
the reader may desire to refer again to Chapter 3, The
Law of Air Pollution Control.
A. Court Cases
The steps taken to process violations are: (1)
assembly and review of evidence from Notices of Vio-
lations and reports, (2) preparing the Request for
Complaint, and the Misdemeanor Complaint, and (3)
the court trial (see Processing of Written Notices,
Figure VI-8).
-------
Air Pollution Control Field Operations
109
1. Assembling Evidence from Notices of Violation
After the investigator receives the inspector's
notice, he reviews it for sufficiency of a prima facie
case. "Prima facie" means that there is sufficient evi-
dence under the law to bring the case to a court test.
In establishing a prima facie case, the investi-
gator abstracts the elements which comprise a corpus
delicti from the inspector's Notice of Violation. These
will include, in most violations: (1) Rule or State
Code Section violated, (2) date and location of the
violation, (3) the time of the violation, (4) the opacity
or densities of the air contaminants, or other basic
findings, (5) the identity of the air contaminants, i. e.,
"smoke", "dust", "mist", "fume", gas'", "vapor", (6)
the names of the inspectors observing the violation,
and (7) the owners and operators of the equipment
responsible.
The above evidence is required for prosecutions
involving excessive air contaminants. The elements
required in permit, nuisance, open fires and other
cases differ and are described in greater detail in
Chapter 13. It will be sufficient here to show the type
of evidence generally required to successfully pros-
ecute cases involving operation of equipment without
a permit as an example of how cases are handled in
court. It should be noted that in these cases not all of
the evidence required need be supplied by the in-
spector. Some evidence is supplied by the investigator
and, in other cases, expert opinion is obtained from
specialists on the District's staff.
Evidence in Court used to Prosecute Permit Cases.
1. A certified copy of the resolution of the Air
Pollution Control District regarding the adop-
tion of the Rules and Regulations, and a certi-
fied copy of the Rules and Regulations.
2. Stipulation or testimony given as to the own-
ership and location of the plant in violation.
3. Testimony by inspector and defendant as to
the construction, use and operation of the
equipment in question.
a. Date of construction, if known, or deter-
mined in the course of the inspector's in-
vestigation. Occasionally evidence may be
supplied from the seller, manufacturer or
installer of the equipment involved.
b. Testimony is given regarding the operation
or status of construction at the time of the
inspector's observation.
c. Expert testimony as to the capability of the
device to emit air contaminants.
d. Testimony as to the inspector's determina-
tion that the equipment emitted air con-
taminants at the time of his inspection.
4. Testimony by investigator of the non-existence
of permit or authority to construct, determined
from a search of the A.P.C.D. records.
Should an important element of the evidence be
lacking, despite the inspector's efforts, the investigator
conducts his own investigation. Generally such inves-
tigations establish ownership and responsibility, em-
ployer and employee relationships, etc. In other cases
the investigator may inspect the equipment in question
himself to obtain any data needed to positively identify
the air contaminants and to determine design charac-
teristics and operational practices in establishing the
cause of violation. In obtaining proof of continuity of
ownership, the investigator may check with the cor-
porate files, the Business License Rureau, the Depart-
ment of Motor Vehicles, etc. Governmental agencies
generally provide any information that is pertinent to
establishing a prima facie case. The investigator may
also check with installers and sellers to determine dates
of construction or other information needed. Proof of
employer-employee relationships, however, must usu-
ally be obtained from direct testimony of the defend-
ants, or through the inspector's testimony of the own-
er's admission.
The procedures for processing Citations and other
reports differ in some respects. The Citation need only
be reviewed and filed with the proper court since it
acts as the complaint itself.
Legal action can be taken by the Investigation
Detail on the basis of any Inspector's Field Report that
is not a Notice or Citation, provided that the evidence
contained on the report is sufficient in establishing a
prima facie case. For example, action can be taken on
reports which disclose:
1. A public nuisance involving signed District
Attorney Forms.
2. Non-compliance warranting revocation of
permits.
3. Excessive smoke from private residences.
4. Violations observed in connection with exemp-
tions, breakdowns, accidents or variances. For
example, the claim that a given open burning
operation is "agricultural" may be disproved
upon subsequent evidence. Accidental fires
and equipment breakdowns may later be
shown to have been deliberate. When terms
of variances are violated, reports are rendered
on Inspector's Field Reports and are forwarded
to the Investigation Detail.
2. Preparing the Request for Complaint and the
Misdemeanor Complaint
When the evidence is assembled, it is then trans-
cribed in its proper form on the "Request for Com-
plaint" (Figure VI-10). The written Notice of Viola-
tion is then filed. The "Request for Complaint" con-
tains the items of description similar to those contained
on the Notice, i. e., the "visible emissions observed",
the names and addresses of the defendants, the place
of violation, the Section of the State Health and Safety
Code or the Rules and Regulations violated, the source,
-------
IN THE MUNICIPAL COURT OF LOS ANGELES JUDICIAL DISTRICT
COUNTY OF LOS ANGELES. STATE OF CALIFORNIA
THE PEOPLE OF THE STATE OF CALIFORNIA,
Plaintiff,
A. B. C. LAUNDRI COMPANY, a Corp.,
and MORGAN SMOKLET
Defendant
Case No
COMPLAINT — MISDEMEANOR
Personally appeared before me the undersigned who, first being duly sworn, upon information
and belief, complains and says:
That on or about
June 27, I960
, at and in the
above entitled Judicial District, in the County of Los Angeles, State of California, a misdemeanor,
to wit, violation of Section 24242 of the Health and Safety Code of the State of
Callforn ia
was committed by A. E. C. LAUNDEJ COMPANY, a Corp., 7320 North Broadway, Long
Beach, California, and MORGAN SMOKLEY, 1560 East 55th Street,
Long Beach, California
(whose true name to affiant is unknown), who at the time and place last aforesaid did willfully
and unlawfully, at and n»Ar 7320 North Broadway. Long Beach. California
, discharge into the atmosphere from a single source of
emission, to wit: a boiler
an air contaminant for periods aggregating more than three minutes in any one
hour, which contaminant was then and there: (a) as dark and darker in shade
as that designated as No. 2 on the Ringelmann Chart as published by the United
States Bureau of Mines; and (b) of such opacity as to obscure an observer's
view to a degree equal to and greater than does smoke described in (a) above.
Said complainant therefore prays that a warrant may be issued for the arrest of said defend-
ant who may then be dealt with according to law.
Subscribed and sworn to before me
on
Clerk of the ftbove entitled Court
By....
Arresting officer employed by. A!J?..jrotLulJ_™..coNTRpj.^sTRicT
WITNESSES
INSPECTOR. JOHN SMEBLEI, Jjjlt South San Pedro Street, Los Angeles 13, California
Figure VI-10. The Request for Complaint initiates court action at the A.P.C.D.
Air Pollution Control District — County ot Los Angeles
434 SOUTH SAN PEDRO STREET, LOS ANGELES 13, CALIFORNIA
REQUEST FOR COMPLAINT
DATE OF VIOLATION.
APCD NUMBER
NOTICE NUMBER
A- B- °-
COMPANY, a Corp.
ADDRESSI..)
and MORGAN SMOKLEI
7320 Horth Broadway, Long Beach, Calif.
1560 East ggth Street, Long Beach
PLACE OF vim ATI on
732° North
Beach. California
CHARGE: VIOLATION OF sFCIsl 2U2U2 of the Health and Safety Code of the State of California
^nnur-c » boiler POINT OF OBSERVATION approx. 20" east of source
WEATHER °lear W|ND south PHYSICAL EVIDENCE ILISTI
PHOTOGRAPHS three (3>
DR 1 VER ' S
DESCRIPTION- 1
VISIBLE EMISSIONS OBSERVED INSPECTOR'S REPORT
START
iflS
1:17
1:19
TOTAL
R.NO.
STOP MIN. % OP. COLOR
1:17 2 #U R black
1=19 2 #3|R black
1:20 1 #3 R black
5 MIN.
WITNESSES:
ISSPECTCE JCHH SMEDLET
U3U South San Pedro Street
Los Angeles 13, California
APPROVED.
On June 27, I960, Inspector John Smedley reported the
excessive smoke was being emitted from an oil fired
boiler located on the above premises owned and operated
by the above corporation. Mr. Morgan Smokley advised
the inspector that he was employed by the corporation
as Engineer and Fireman, and that he comes on duty at
12s 30 pm, and that he regularly had to readjust the
boiler controls to maintain a proper fuel air ratio,
and that the equipment was old and had to be watched
constantly.
Upon completion of his observation, the Inspector
issued a notice charging a violation of Section 2U2U2
of the Health and Safety Code of the State of California
to the corporation through Mr. L. E. Read, General
Manager, who confirmed that Mr. Smokley was employed
by the corporation and stated that he did not know how
the boiler could have smoked.
LLUX1J H. HL MU1H, UUUSUTUK (Jt ENt'OKUKKKNT HOWARD L. CLARE, CHIEF
_, ENGBIEERING INSPECTCE
JBH:un
6-28-60 16-40D70
Figure VI-11. The Misdemeanor Complaint is filed with the jurisdictional court.
?
o
3
O
o
3
•*j
*«-i.
w
-
3
<•>
-------
Air Pollution Control Field Operations
111
the point of observation, weather, wind, etc. The
request will also contain a list of the physical evidence
and photographs.
The section of the "Request" which is used to
abstract the Inspector's report is written in firm and
concise language, relating only to the facts of the
prima facie case. The names of the witnesses, usually
the inspectors involved, are included.
The Request for Complaint is then forwarded by
the Investigator to the Director of Enforcement for
signature. The Request for Complaint is delivered to
the prosecuting attorney, who prepares a Misdemeanor
Complaint (Figure VI-11) for filing in the appropriate
court. The original copy of the Request for Complaint
is delivered to the court where the Request is filed.
The court then places the case on a calendar for ar-
raignment. If, at the arraignment, a not guilty plea
is entered, the trial date is set.
3. Conduct of the Court Trial
Should any action taken by the inspector in the
field result in legal action and a plea of "not guilty" is
entered during the arraignment, then the inspector
will receive a subpoena or will be instructed to appear
as one of the witnesses in the court trial.
When the inspector is called upon to testify, the
prosecuting attorney, if he desires to do so, will
attempt to establish his competence as a witness to
testify on the matter before the court. The defense
attorney, if not satisfied, may examine the witness
himself on Voir Dire. Voir Dire is accomplished by
inquiring into the background and qualification of the
witnesses answering the questions.
All air pollution inspectors are qualified to testify
on nearly all of the facts of the violations they observe
by virtue of their in-service and smoke school training.
However, the greater the technical training related to
air pollution problems the inspector has received either
from previous employment or formal education, the
more his testimony will be accepted as evidence. In
complex air pollution problems, expert testimony may
be required to substantiate the identity and the chem-
ical constituents of any air contaminants and the
physical and chemical causes of pollution. If the in-
spector's qualifications are limited, he may not be per-
mitted to testify on such crucial matters. In these cases
expert testimony is given by District staff members
who have specialized in technical fields related to the
type of air pollution problem under question.
In the examination on Voir Dire, the inspector
is usually required to answer the following:
1. His name, title and place and length of
employment.
2. His duties as an air pollution inspector. The
following is a condensed version of a hypo-
thetical answer:
Question: What are the duties of an Air Pol-
lution Control Inspector?
Answer: To patrol an assigned area and to
observe, investigate and report on violations
of the Health and Safety Code of the State
of California and the Rules and Regulations
of the Air Pollution Control District.
To interview complainants and to investi-
gate the sources complained of.
To inspect equipment relative to compliance
with existing law.
To consult with representatives of business
and industry in an effort to assist in con-
structive operational methods of controlling
air pollution.
To assist in certain source tests and to per-
form such other duties as are assigned by a
supervisor.
3. Previous employment and educational experi-
ence. Degrees awarded, nature of courses.
4. Length and nature of in-service training.
5. Smoke School training.
a. Number of times attended.
b. Smoke School proficiency (does the in-
spector read within a 10% opacity or Vz
Ringelmann Density accuracy?) (See
Chapter 10.)
c. Methods of smoke readings. Generally
speaking, both the defense and prosecuting
attorney will attempt to establish the in-
spector's ability to determine a violation of
the law. In most cases the validity of the
inspector's testimony will depend on his
knowledge of the laws and, particularly,
of the principles of reading air contami-
nants in terms of the Ringelmann Chart or
smoke opacity. (See Chapter 10.)
6. Training with qualified inspectors and Senior
Inspectors in the field.
7. Number of smoke readings in the field since
graduation from smoke school.
Next, the inspector is examined for any other
facts pertinent to the case. The inspector is generally
prepared to testify as accurately as possible from mem-
ory. If he cannot, he requests permission from the
court to refresh his memory from his reports. If he
testifies on the basis of his reports, he can be cross-
examined on any portion of them. In general, the line
of questioning taken will be similar to the following:
1: * On date and location, were you on duty as
inspector?
2. What directed your attention to this location?
3. Where were you when you first saw it?
4. Could you determine the source of emission?
5. Describe the premises.
* These questions are for smoke from incinerators and open fires,
usually the simplest types of air pollution cases.
-------
112
Air Pollution Control Field Operations
6. Did you make any readings? What time com-
menced? What time concluded? How far
from source? Ringelmann number or opacity?
a. What was the length of the plume after
recorded observation?
b. Weather and lighting conditions.
7. Did you see what was in the source of the
smoke?
8. Any conversation? with defendant? with em-
ployee? (With tenants in apartment house or
similar premises?)
9. Introduce Ringelmann Chart into evidence.
(By reference.)
10. Testimony or stipulations re ownership and/or
agency.
B. Hearing Board Cases*
The nature and function of the Air Pollution
Control Hearing Board was previously described in
Chapter 3.
The Hearing Board is concerned only with per-
mit and variance cases. It is approached by means of
a formal petition either from citizens appealing a
decision of the Air Pollution Control District, or by
the Air Pollution Control District itself when it seeks
a revocation of a permit or a revocation or modification
of a variance. The petitition is prepared to provide the
Hearing Board with all of the facts necessary to render
a decision in terms of the standards prescribed by the
State Health and Safety Code. When requests for
hearings are granted, witnesses are subpoenaed before
the Board in the same manner as in a civil action. The
procedures for qualifying witnesses and delivering
testimony are similar to those in a court of law. There
are some exceptions, however, particularly with refer-
ence to the admissibility of hearsay evidence. For this
reason, Rule 86 below is quoted in full.
Rule 86. EVIDENCE
a. Oral evidence shall be taken on oath or affirmation.
b. Each party shall have these rights: to call and examine
witnesses; to introduce exhibits, to cross-examine oppos-
ing witnesses on any matter relevant to the issues even
though that matter was not covered in the direct ex-
amination; to impeach any witness regardless of which
party first called him to testify; and to rebut the evi-
dence against him. If respondent does not testify in his
own behalf he may be called and examined as if under
cross-examination.
c. The hearing will not be conducted according to tech-
nical rules relating to evidence and witness. Any
relevant evidence shall be admitted if it is the sort of
evidence on which responsible persons are accustomed
to rely in the conduct of serious affairs, regardless of
the existence of any common law or statutory rule
which might make improper the admission of such
evidence over objection in civil actions. Hearsay evi-
dence ma}' be used for the purpose of supplementing or
explaining any direct evidence but shall not be sufficient
in itself to support a finding unless it would be admis-
sible over objections in civil actions. The rules of priv-
ilege shall be effective to the same extent that they are
now or hereafter may be recognized in civil actions,
and irrelevant and unduly repetitious evidence shall be
excluded.
* Although this activity is now supervised by the A.P.C.D.
Engineering Division, it is included here as an enforcement
concept.
1. Variances
In some cases where individuals or companies
cannot conduct their businesses without undue hard-
ship, or where business activity might be completely
suspended as a result of compliance with any of the
prohibitions of the State Health and Safety Code, the
Hearing Board may hear such cases and deny or grant
variances of the rule or code section involved under
prescribed conditions. The variances are granted or
denied strictly in terms of the conditions set forth in
Section 24296 of the Health and Safety Code as
follows:
SECTION 24296. If the Hearing Board finds that because of
conditions beyond control compliance with Article 3 of this
chapter or with any rule, regulation, or order of the Air
Pollution Control Board will result in an arbitrary and
unreasonable taking of property or in the practical closing
and elimination of any lawful business, occupation or activ-
ity, in either case without a sufficient corresponding benefit
or advantage to the people in the reduction of air contami-
nation, it shall prescribe other and different requirements
not more onerous applicable to plants and equipment oper-
ated either by named classes of industries or persons, or to
the operation of separate persons; provided, however, that
no variance may permit or authorize the maintenance of a
nuisance.
Variances granted by the Hearing Board are usu-
ally expressed in terms of limitations and conditions.
For example, the Hearing Board may determine that
in order for a person to operate his equipment within
the law, he will require a certain period of time to
correct his air pollution problem. In the time period
allowed, he may be permitted to operate the equip-
ment, and the standard of the Rule in question is mod-
ified in his case to permit those quantities of air
pollutants which cannot be avoided in the most careful
operation of the equipment. The standard of per-
missibility may be raised — contaminants may be per-
mitted to be emitted at a rate, for example, of 60%
opacity for periods totaling not more than 6 minutes in
any one hour, instead of 39% for periods not totaling
more than 3 minutes in any one hour. The Hearing
Board may also stipulate certain operating conditions
which must be complied with.
When the written decision is handed down by the
Hearing Board, abstracts of the variance conditions
and limitations are made on the form shown in Figure
VI-12 and are distributed to all District personnel con-
cerned. One copy of the abstract of the variance is also
sent to the APCD Communications Center, in order
that all claims regarding the possession of variances
made by persons in the field can be instantly verified
by radio. The Sector Engineering Inspector also re-
ceives a copy and immediately inspects the plant to
determine if the operator is in compliance with the
conditions of the variance. If non-compliance of con-
ditions is observed, the inspector can initiate legal
action in the same manner as any other violation.
The facts of the case, however, are noted on an In-
spector's Field Report rather than on a written Notice
of Violation.
-------
Air Pollution Control Field Operations
HEARING BOARD ACTION
FIRM NAME.
Super Strong Steel Co., inc.
CASE NO.
U759
ADDRESS.
711 West " B" Ave.
CITY-
Beverly Hills
EQUIPMENT AND/OR
(PREMISES WHERE EQUIPMENT is LOCATED) - (OR COMMUNITY)
ton electric steel furnace and bag house.
5/31/60
6/21/60
PETITION FILED •'/-'*/ CASE
ACTION:
g] VARIANCE Q APPEAL FROM DENIAL Q REVOCATION
GRANTED ON O/^-L/O" yp "/-U3/OU— SUSTAINED EFFECTIVE GRANTED EFFECTIVE.
DENIED ON EFFECTIVE REVERSED ON DENIED ON
RECEIVED-
6/2U/60
D OTHER
WITHDRAWN
DiSMISSED
BASIC FINDINGS OF BOARD:.
Petitioner is replacing its old baghouse with new unit
DECISION AND
emission
etine is
,I
maximum of 60.
a variance from Section 2k2h2 to allow an
'etitioner is to inspect baghouse daily to replace
defective bags prior to start of new heat. There will be a further hearing without
not-ine at 2;00 P.M. 9/L3/60/.
DISTRIBUTION
DATE.
AIR POLLUTION CONTROL DISTRICT - COUNTY OF LOS ANGELES
Figure VI - 12. Memo of abstract of Hearing Board variance distributed to all concerned A.P.C.D. personnel.
SOD254
2. Appeal from Denial of Operating Permit and
Authority to Construct
Under the permit system, application must be
made to the District for an authority to construct and
a permit to operate equipment capable of emitting air
contaminants. If the application submitted by the
applicant is approved by the Engineering Division of
the APCD, a permit is issued. If the application is
denied, then a letter of denial is sent to the applicant.
The applicant may then, if he desires, petition the
Hearing Board to review the denial. The petition must
be filed by the applicant within 10 days after receipt
of the denial. When the public hearing is held, the
Hearing Board examines all of the data concerned and
will either sustain the District's denial, grant an oper-
ating permit, or state conditions which must be com-
plied with before a permit will be granted.
When the denial is issued, the inspector receives
a denial check slip to inspect the equipment involved
and determine the status of compliance or non-compli-
ance with the denial. Non-compliance with the denial
is a violation of Section 24279.
3. Revocation and Suspension of Permits
Whenever equipment which has been granted a
permit either by reason of compliance with the pro-
2.
3.
visions of Rule 10, Permits Required, or by reason of
Rule 13, Blanket permits, develops a chronic history
of non-compliance with other rules or code sections, the
Air Pollution Control Officer may petition the Hearing
Board for a revocation of the permit. According to
Section 24276 of the State Health and Safety Code, an
existing permit is revoked if the Hearing Board finds:
1. The permittee has failed to correct any conditions re-
quired by the Air Pollution Control Officer, or
A refusal of a permit would be justified, or,
Fraud or deceit was employed in the obtaining of a
permit, or
4. Any violation of this chapter or of any Rule or Regula-
tion of the Air Pollution Control Board.
Permits may also be suspended by the Air Pollu-
tion Control District if the permittee fails to furnish
the APCD with information, analyses, plans or speci-
fications. If the permit is suspended, the permittee
may petition the Hearing Board for a public hearing
to determine whether or not the permit was properly
siispended. The Hearing Board, accordingly, may re-
instate the permit, sustain the suspension, or set forth
conditions which must be met before reinstatement is
granted. The Air Pollution Control Officer may rein-
state a suspended permit on his own discretion.
SECTION 24276. After a public hearing, the Hearing
Board may:
a. Continue the suspension of a permit suspended by the
Air Pollution Control Officer, or
-------
114
Air Pollution Control Field Operations
b. Remove the suspension of an existing permit invoked
by the Air Pollution Control Officer pending the fur-
nishing by the permittee of the information, analysis,
plans and specifications required, or
c. Find that no violation exists and reinstate an existing
permit.
When an inspector in the field observes operation
of equipment under a suspended or revoked permit, he
can take such action under Section 24278 as is outlined
in Chapter 13.
VII MAINTAINING RECORD SYSTEMS
In order that maximum use can be made of all
reports generated from field activity, a functional
record-keeping system is required. Record-keeping in
enforcement is intended to provide information which
is actively and continuously employed in the conduct
of the field control operations program. There are
three basic uses required of such record systems.
1. Case Histories — The record system provides
case histories of prior compliance or violation
and other factual information which could be
submitted as evidence in a court of law, such
as:
frequency of violation
causes of pollution problems
pollution potentials
process flows
equipment maintenance and operational
practices
permit status
products manufactured.
2. Monitor Operations — The record system
should provide a record of field and admin-
istrative practices in order that all phases
of the inspection and enforcement program
may be monitored. Record-keeping discloses
the judgments and decisions made in each
operational step and at each level of responsi-
bility in completing an enforcement action.
3. Statistical Analyses — The record system
should provide valid statistical summariza-
tions and analyses of the results of the pro-
gram for evaluating progress made, pollution
potentials, and in preparing budgets and de-
termining personnel needs.
To fulfill these requirements, it is necessary to
develop filing systems which make available any infor-
mation which may be required. In the APCD, two
general filing systems are employed, the (1) Basic
Operational Files consisting of the original field reports
made by inspectors, and the decisions and dispositions
handed down from the courts and the Hearing Board.
and (2) the Administrative or Secondary Operational
Files consisting of data summarized or abstracted from
the basic reports for analyses, classification, or quick-
finding reference. Other filing systems are used for
expedience in highly functional or specialized situa-
tions. These are "dispatch" or "suspense" files set up
to make possible rapid communications of certain
information to field units, such as variances granted,
permit status, name and addresses of locations, or
chronological systems used to alert personnel to pend-
ing reports or applications.
A, Basic Operational Reports
In the APCD, the Basic Operational Files consist
of the inspection reports and the court and hearing
board dispositions and decisions (enforcement ac-
tions) . Separate file drawers are maintained for each
type of report form used by the APCD in the field,
with the exception of the general Inspector's Report
(Figure VII-7) and the Notice of Violation (Figure
XIII-1) which are filed together in the Inspector's
Field Report File.
Filing systems are either of the alphabetical or
numerical types. The alphabetical arrangement makes
for direct accessibility and is employed in the filing of
all basic operational reports, with the exception of the
Equipment Inventory Dossier Files and the Permit
Applications and Permit Files which employ a numer-
ical system (see below).
Numerical systems used by the APCD, in turn,
are of two types (1) coded classification, and (2) nu-
merical sequence. The first system is employed when
the type of data contained in the report is of a statis-
tical or descriptive nature (see descriptive reports)
and readily breaks down into a logical classification
system. The grouping of the records themselves into
the categories and classifications directly yields up-to-
date statistical information. A coded classification
system of this nature can be applied with great advan-
tage to inventory records (Equipment Lists) to break
inventories down into industrial activities (refinery
and petrochemical, metal melting, power plants, etc.).
The APCD files Equipment Lists according to a Pri-
mary and Secondary Industrial Activity Classification
System (see Table XIV-1).
The Numerical Sequence System is employed
when a strict accounting is required of all legal docu-
ments issued or processed such as those involved in
permit applications and permits to operate. The nu-
merical system not only serves to register the sources
of air pollution in the order of the receipt of applica-
tion, but provides running totals of such applications
received and permits granted.
With both systems, however, an alphabetical
cross-index card or visible file system will be required
for reference finding.
Secondary operational files comprise the records
and reports used to evaluate the progress of any gen-
eral or detailed phase of the inspection and enforce-
ment program, and are obtained from such analytical
operations performed on the basic files as classifying!
abstracting, condensing, summarizing or recombining
data in new forms. For example, the APCD may
require from time to time the following kinds of in-
-------
Air Pollution Control Field Operations
115
formation: the number and identity of all oil-fired
brass furnaces in a certain sector, the number of elec-
trical precipitators in the entire pollution zone, the
number of court cases involved in a dust-nuisance
problem, and other similar types of information.
Figure VI-13. Punch card and key sorting files for selectively
recording and locating enforcement data.
B. Administrative or Secondary Operational Files
There are four types of secondary filing systems
employed by the A.P.C.D. These are as follows:
1. The Master Control Record System — Selective
Analysis
The Master Control Record System is a means of
posting on a single card all of the key findings and
dispositions obtained from the basic operational reports
for a single plant location. The data is supplied to the
card in two ways: first, by code punching the rim or
periphery of the card, permitting subsequent analysis
by key sorting, and, second, by posting of information
in writing in the classified columns on the interior of
the card. The coded punch data represents the classi-
fication of data most desired for analyses, while the
written information provides more detailed, explana-
tory material.
Ideally, it may be desired to combine all data on
one Master Card. In actual practice, however, more
than one Master Record System may be required. In
the District, two such Master Record Systems are used,
the (1) Violation Record (Figure VI-14) and the (2)
Equipment Inventory Master Record (Figure VI-15).
a. The Equipment Inventory Master Record
This card is used for the posting of data selected
from the Equipment Lists and Activity Status Reports
and is used to determine the number and identity of
plants existing in any of the following categories.
Type of basic contaminant emitted (smoke, dust.
fumes, etc.)
Type of control used (cyclone, precipitator, scrub-
ber, etc.)
Month reinspection due
Primary and secondary activity classifications
Frequency of inspection.
Additional information is recorded in writing in
the appropriate blank spaces. This includes data of last
complete reinspection, nature of ownership (corpora-
tion, partnership, individual, etc.), time factor unit
(time taken to complete previous inspections) and gen-
eral Hearing Board disposition (Figure VI-12).
These cards are then filed in special drawers by
inspection sector, and then alphabetically by company.
b. Violation Record
The Violation Record is intended primarily to
provide statistical information with respect to the types
of violations and the disposition of court and hearing
board cases. The system is also intended to provide
ready cross-reference between company names and
individual defendants and co-defendants. The card
records the following punched coded information:
Map grid, coordinates of source
Time of Violation (year, month, day and
time)
Inspection sector
Rule or State Coae Section violated
Type of Equipment source
Disposition of court and Hearing Roard cases.
The names of co-defendants, affiliates and other
detailed administrative data are written in the appro-
priate blank spaces on the card.(See Figure VI-14).
One violation card is made out for each specific viola-
tion or Hearing Board case, and all violations are listed
on the Master Inventor)^ Card in order of occurrence.
2. Quick-Reference Visible Files
As may be noted, the administrative files just dis-
cussed are maintained in a numerical system. Thus.
the Master Record of an individual company cannot
be located by its name. An alphabetical reference
finding file is therefore required. This finding file
should contain just the essential finding information
and should be easily consulted and revised.
To meet this need, alphabetical visible finding
files are employed by the Enforcement Division. These
are used primarily as a reference to locate either the
Equipment Lists, or the Sectors by which the Master
Record cards can be located. Two of such files com-
plement the Equipment Inventory Master Record and
the Violation Record Cards, respectively (see Fig-
ure VI-16).
The Finding Reference File for Equipment In-
ventory records the following information.
Name and address of company
Primary and secondary activity classification
Date of last inspection
Inspection Sector
-------
•
-"
1
,.
NAME OF PRINCIPAL
JOHN DOE CORPORATION
3^5 West Hill Street '
CIT1f LOB Angeles |GRIDNO
•
6-10- „ 58 |
a
<
0
z
<
i
NAME
John Doe Corp.
Bill Brown
IDENTITY
owner
empl.
MR..
N
HE
CASE
UMBER
1
vIR
HATES
NO. 05-3
AR1NG BOARD CASES - RE PRINCIPAL Jj
DATE OF
FILING
DECISION
DISPOSITION
O.C
-
NC.
Figure VI- 14. VIOLATION RECORD CARD #1. The data on the
above card reports that the John Doe Corporation, a brass foundry (the
industrial activity can be decoded from Table XIV - 1), at the address
shown on the card, and an employee, Bill Brown, were charged with a
violation of Sec. 24242 of the Health and Safety Code from a baghouse
on a metallurgical furnace (note "source" and "control" punching) on
June 20, 1958 between 12 Noon and 2:00 p.m. A guilty plea was en-
tered and the court case was completed. The backside shows the data
relating to the processing of the case in court. The corporation was
found guilty and fined $50. The charge against Brown, the operator,
was dismissed.
(Front)
• l!»U»]i''
« • • *u
(Back)
:u
JOHN DOE CORPORATION
NOTICES ISSUED
F-100
5-20- 5£
TIME
l:35l»
VIOLATION
2b2k2
CONTROL NO
1^281
ACTION
COURT
L.A.
DATE FILED
7-1-58
CASE NO.
10000
MR*s 05-3
DISPOSITION
X
D
$5
dl
5 P
ml
CT
• •
se
J T
c
arp
Br
^vn
M
cr
c:
o
3
O
3
O
•
3
-------
NAME OF PRINCIPAL
JUKN DOK COKPUtaTICN
John Doe Corp.
John Smith
owner
driven
CORPORATION NUMBER
FICTITIOUS NAME NUMBER.
AIR POLLUTION CONTROL DISTRICT LOS ANGELES COUNTY ENFORCEMENT DIVISION
Figure VI - 14.1 VIOLATION RECORD CARD #2. The John Doe
Corporation and its driver, John Smith, are charged with a Section
24242 (smoke opacity) violation from a company truck on August 20,
1959, between 2:00 and 4:00 p.m. (7). The case was submitted on re-
port (1 and 2) and both defendant and codefendant were found guilty
and were sentenced $25. Smith's sentence was suspended, however.
(Front)
(Back) B
•
•
•
•
•
•
~D
~D
•
/:::::::l/::::::t':::::i/:::::::V::::V
JOHN DOE CORPORATION
NOTICES ISSUED
V-100
8-20-5!
> 2:30p
1 2U21+2
17336
ACTION
L. A.
9-1-59
100001
MRNO. 05-3
DISPOSITION
X
$2
$2
5 P
5 s
i.
SLBp
- C
. -
orp
Sir
.
jlth
M
•
•
•
•
•
•
•
•
-------
s
Oi
O (.
Ot *
•o c
at ^
NM71H - 11/JI
JOHN DOE
CORPORATION
ABOBESS
3^5 West Hill St.
M"Es-8
CITY Los Angeles
DATE OF LAST COMPLETE REINSPECTION
3-5-58
7-10-58
11-15-58
3-20-59
7-2lt-59
DATE
cw" |
CASE
NUMBER
15036
00
6-25-507-10-583
Figure VI-15. This Master Control Record Card classifies the John
Doe Corporation as a brass foundry. The basic contaminants emitted
from its activities are smoke and combustion products, solid particulates
(dust and aerosols), gases and vapors. The principal types of controls
employed are dry filters, e.g., baghouses. The corporation is scheduled
for inspection three times a year, and has already been inspected five
times. The company applied for a variance at the Hearing Board on
7-10-58, presumably to install improved equipment or to make modifi-
cations or repairs in order to achieve compliance. Note also that both
the stationary and moving violations are recorded on the reverse of the
Master Control Equipment Card.
(Front)
(Backl
•
u u...y...u»»
NAME OF PRINCIPAL
JOHN DOE CORPORATION
NOTICES ISSUED
NUMBER
F-100
V-100
DATE
6-20- %
8-20-5!
TIME
) 1:35P
) 2:3QP
VIOLATION
n 21*2^2
u 2b2kZ
CONTROL NO
11*281
17336
ACTION
COURT
L. A.
L. A.
DATE FILED
7-1-58
9-1-59
CASE NO.
10000
100001
MR^ °5-3
DISPOSITION
G
X
X
D
$5
di
$a
$2
AQ.
3 p
ami
5 P
5 s
CT
i.
ase
1.
lap
J.T
- C
i -
• C
5 R.
Drp
Br
orp
Sm
o.c.
iwn
Lth
M
•
£
•
c:
§
s
f-«y
1*1
S'
£
-------
Air Pollution Control Field Operations
119
ENFORCEMENT DIVISION.
-SECTION
INSPECTOR
Smith
Hardv
Jones
Perkins
Doe
Henderson
Black
Masters
Wavne
Powell
Williams
Brown
Johnson
Holmes
Benson
Morcan
Reed
McGrath
Boberts
Mann
Grimes
Sterlins
Abbott
TOTALS
CONSOLIDATED MONTHLY ACCOMPLISHMENT REPORT MONTH June i860
IN5P
IhS
126
99
139
132
10B
156
171
138
108
132
157
105
155
7
70
146
66
156
129
126
248
211
3237
(ONE UNIT is i HR. )
RPTS
FILES
OMP
vt
13
(,
6
7
11
17
34
29
101
46
38
23
67
28
35
495
TEST
12
12
TEST
RPTS
SUB
TOTAL
194
139
105
139
138
108
163
182
155
10R
166
157
105
196
108
70
192
66
194
152
193
276
246
3744
OTHER UNITS
AIR
MON.
PATROL
422
452
367
409
518
540
445
370
289
540
450
427
411
380
518
574
420
578
454
388
419
276
414
10333
TOTAL
UNITS
616
5%
47?
548
656
648
604
552
444
648
616
584
516
572
628
644
612
644
648
540
612
548
660
14072
D
IR
18
7
2
??
9
24
9
9
75
17
8
30
35
8
19
5
19
20
23
22
26
37?
DCUMENTS
N
15
7
?n
6
3
3
17
6
7,
16
2
3
11
4
8
?.
20
9
19
5
26
!2
R
23
">*i
9
fi
6
5
28
16
18
3
g
7
4
15
4
70
6
14
17
10
33
14
304
ENG
FIN
NOTICES
F
1
1
?,
1
1
6
1
4
1?
7
4
5
1
34
c
p
4
1
4
3
9
7
5
3
9
1
4
6
4
5
1
6
4
92
T
18
2
4
4
1
?
7
?
3
5
1
1
51
TOTAL
62
60
35
66
64
55
61
43
36
55
51
65
50
75
36
36
47
34
60
48
58
64
67
1278
TIME WORKED
154
149
118
137
164
162
151
138
111
162
154
146
129
143
157
161
153
161
162
135
153
137
165
3518
NON-
6
9
18
32
5
6
7
6
49
6
14
23
7
25
10
7
7
7
7
7
11
26
4
314
1
1
7
7
16
•OTAL
160
158
136
169
169
168
159
144
160
168
168
169
136
169
174
168
160
168
169
14?,
164
170
169
3848
OVER
1
9
1
1
1
6
1
4
2
3
29
MILES
2224
1813
1107
1326
1705
1212
1641
1329
819
1174
1274
1524
1174
1397
1780
1357
1233
1233
1210
1347
1051
1706
2254
33671
AIR POLLUTION CONTROL DISTRICT COUNTY OF LOS ANfiFI FS HFAD INWTOR J. Wilson r,ATF 6-5 ,„ 60
400174 R-60-5
Figure VI - 17. Inspector's Consolidated Monthly Report of Enforcement Activities.
AIR POLLUTION CONTROL DISTRICT COUNTY OF LOS ANGELES
ENFORCEMENT DIVISION
INSPECTION SECTION MONTHLY SUMMARY OF ACTIVITIES
MONTH OF_ __I!
INSPECTIONS SECTIONS
PATROL (UNIFORM)
INDUSTRIAL
REFINERY AND CHEMICAL
TOTALS
AIR MONITORING ACTIVITIES
ENGINEERING FINAL INSPNS.
RADIO COMMUNICATIONS
AIRCRAFT RECONNAISSANCE
INSPN.
UNITS*
11630
6900
5755
14285
IRS
338
215
1130
1683
LISTS
N
4
65
20
89
R
420
61
481
570
NOTICES ISSUED
CP CT
159 66
159 ' 66
STATIONS MANNED 8 PERSONNEL INVOLVED 4?
V
28
28
F
14
2
2
18
271
TIME WORKED
F IELD
3405
3096
2740
9241
NON-
f 1 ELD
478
265
363
1106
COURT
21
21
7
49
HOURS EXPENDED 2400 PERSONNEL TRAINED 0
PENDING— 0__ ORIGINATED AND RECD. FROM E
APCD
COMPLAINT
TRAFFIC
148
APCD
NON-COMPLAINT AMBULANCE
TRAFFIC TRAFFIC
15507 1115
FLIGHTS—?— HOURS'
COMPLETED _! PEN
POUND
TRAFFIC
3154
TOTAL
T IME
3904
3382
3110
10396
OVER
T IME
10
29
67
106
HRS. IN TRAINING 0
->|NR 0
MARSHAL S
OFFICE TOTAL
TRAFFIC TRAFFIC
3233 23157
VISIBLE EMISSIONS OVER 40% REP
nRTFD
* AN INSPECTION UNIT IS j HOUR.
CHIEF ENGINEERING INSPECTOR
16-40M296
REV. 8-59
Figure VI - 18. Inspection Section Monthly Summary of Activities.
-------
120
Air Pollution Control Field Operations
And the Violation Finding File records the fol-
lowing information:
Name and address of violator.
Citation and written notice number.
Driver's license and vehicle number.
Date of violation.
Figure VI- 16. Visible finding files.
3. Statistical Files
The basic and secondary operational files dis-
cussed so far are thus readily available for any number
of uses which may be demanded of them. The uses
take two forms, (1) summarization or reduction to
manageable and meaningful entities, and (2) statisti-
cal analysis of any particular phase of the field control
operations program.
Summarization involves periodically compiling
such data as the number of inspections, number of
written reports, the number and type of written
notices issued, and the number of new and revised
Equipment Lists. These results are compiled for each
inspector on a Monthly Accomplishment Report. The
totals of the inspection activities conducted by all of
the inspectors are then computed 011 a Monthly Sum-
mary of Activities (See Figures VI-17 and VI-18).
This data informs the command unit of the degree to
which saturation coverage is being maintained, trends
in compliance, the relative performance of the
individual inspectors, inspection and enforcement in-
tensity and scope.
Statistical analyses can be made for any number
of specific purposes. Generally, it will involve either
comparison or correlation of those categories of data
contained on the rims of the Master Cards, or any
other data which may be readily accessible.
4. Dispatch and Suspense Files
These are special files which may be located at
strategic dispatching points in the Enforcement Di-
vision and are usually of the "visible" reference, log or
journal entry, or card-filing types. Their purpose is
to provide certain types of information which may be
immediately required by field personnel. The informa-
tion is generally dispatched on request of the field
inspectors by radio or telephone.
The Dispatch Files include a constantly main-
tained visible file of current variances and reported
breakdowns of equipment. Also included are: (1) a
complaint log in which complaints are maintained in
order of receipt, (2) a radio-telephone message log,
which records chronologically the receipt and trans-
mission of all messages in the APCD communications
center, and (3) a radio-telephone message file, con-
sisting of messages filed in order of receipt.
The various Inspection Sections maintain records
and files required for their daily operations. These
include source-testing files, permit logs, plant status
cards, permit suspense files, and Engineering Field
Report Assignment Logs.
REFERENCES
1. McEwen, Lloyd H., Enjorcemei/l Division Annual Report, Los
Angeles County Air Pollution Control District, 41 pp., 1959-1960.
-------
CHAPTER SEVEN
THE AIR POLLUTION INSPECTOR
An inspector, according to most dictionary defini-
tions, is one who views or examines closely and crit-
ically as an official act or as part of a legal proceeding.
He is often fictionally portrayed as being highly capa-
ble in detecting clues and perceiving motives. A more
sophisticated conception characterizes him as a crim-
inal psychologist. To some extent, this conception is
true since there are many occasions in which the de-
termining factor in taking enforcement action is the
inspector's findings with respect to motive. However
colorful some of these attributes are, inspectors from
all branches of law enforcement must be analytical,
critical and objective.
But, aside from these characteristics, inspectors
differ substantially according to the services they per-
form. While all are concerned with the enforcement
of the law, the means for obtaining compliance may
differ considerably. The criminal investigator, for
example, is only interested in a case when a crime is
alleged to have been committed. The public health or
safety inspector is concerned more with public prac-
tices with regard to health and safety standards. In
public health programs, criminal prosecution plays an
important, but not the primary role. Rather, inspectors
are concerned with (1) imparting information and
educating the public in achieving standards of compli-
ance and preventing problems resulting from neglect
or ignorance, rather than criminal intent; (2) reporting
facts and data acquired from field inspections to assist
in the intelligent direction of an over-all health pro-
gram. The public health inspector is interested in the
whole problem — his work is preventive as well as
prohibitive. He attempts to inform citizens and oper-
ators of the legal authority he enforces and the ways
and means of controlling health or nuisance problems,
and motivates, rather than compels, compliance.
The air pollution inspector belongs to the family
of the public health inspector since air pollution con-
trol is one of the many specialized public health pro-
grams. Inspection and enforcement techniques and
practices have, in fact, derived from industrial hygiene
and public health agencies. In Los Angeles County,
this is reflected by the fact that the basic legal author-
ity is contained in the California State Health and
Safety Code.
In several other interesting respects, the air pollu-
tion inspector differs from other inspectors. In the first
place, the air pollution inspector deals with abstract or
indirect, as opposed to direct, justice. Ordinary
crimes are confined to the persons directly involved.
the thief and the victim. But in serious community-
wide air pollution problems everyone is involved.
Even though an emission from a single source may
in itself be inconsequential, that emission contributes
along with all other similar emissions to create
an air pollution problem. Control and enforce-
ment is thus not concerned with the individual, but
with the statistical effects of individuals. The paradox
here is that the relationship of the contributor to col-
lective acts and to the production and intensification
of smog effects is remote. The contributor is not often
aware that he is violating the rights of others. The air
pollution inspector has a more difficult job, since quite
often, he cannot make an appeal to the violator di-
rectly on moral grounds, but may have to attempt to
inform the violator of the consequences of his acts.
This more abstract notion of enforcement requires that
the inspector possess a working knowledge of the air
pollution problem and the control programs.
Secondly, the air pollution inspector, working
alone, first views the field as chaos, a condition in
which he will have to find a path as gracefully and as
tactfully as he can to the evidence or the facts he is
trying to find. To the inspector, the field is something
more than a zoned territory made up of many sources
of air pollution. It is made up of people, the public,
confrontations, amenities, human reactions, attitudes
and opinions as well as a host of problems which are
antecedent to actual air pollution control. The in-
spector is not able to obtain the facts he needs unless he
is capable of managing the social relationships which
arise.
Each source of air pollution, also, is inherently
unique even though it may be conveniently classified
on paper. The equipment, location of the equipment,
management policies, the products and processes, the
volume of production, plant layout, etc. differ from
plant to plant. Some problems are highly complex in
terms of equipment and processes. Others, involving
a few simple pieces of equipment, may be complex in
terms of the human factor alone.
The inspector, because he is for the most part
alone in the field, works in an unstructured frame of
reference. It is his purpose to apply a structure in the
form of the law and the policies he enforces. His dis-
cipline then must be based on constant use of analysis
and judgment in distinguishing between subjective
conditions, e.g., states of mind, and objective facts;
between procedures and policy making; between ini-
tiative and standardized practices; between literal in-
terpretation of the law and the use of common sense;
between inertia from continuous application of proven
methods, and adaptation to changes in policies, laws
and political situations.
In order to strike an effective balance between
these extremes, the inspector must view the facts im-
personally and by concrete rules, standards and cri-
teria. He must possess the prerequisite abilities, the
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122
Air Pollution Control Field Operations
training, clearly established duties, ethics, policies,
powers and the proper equipment with which to work.
But, more important, he must be thoroughly grounded
in inspection technique. Inspection technique is of
fundamental importance to the inspection and enforce-
ment program. It is an art insofar as the inspector must
elicit information, deal with the public and organize
and handle his inspections smoothly. Basically, the
artful handling of material involves the creation and
organization of material out of chaos, performed with
efficiency and grace. It is also a science insofar as the
inspector must accurately determine and evaluate all
of the facts disclosed from each inspection in order that
the most effective action can be taken.
Inspection technique can be continuously devel-
oped and promoted by the agency in training programs
and by constructive supervision. If it is neglected, the
control agency may find it necessary to establish
cumbersome administrative machinery to compensate
for the deficiencies in inspection technique. Within
the limits of essential routines, the greater the effi-
ciency of inspection, the less the complexity of admin-
istrative actions necessary to control the inspector in
the field.
I THE INSPECTOR'S ROLE
The Air Pollution Inspector is involved with more
phases of the control program than any other
category of personnel. This degree of involvement is
shown in Figure VII-1. E
w
Sj Ident. &
3 Analysis of
rh AP Problems.
1
&<
O Control
pS Standards.
to Registering
° Sources of ^
£ Air Pollution
Controlling
Sources of ^
Air Pollution.
Detecting
sources of
air pollution.
^
Inspecting
sources of
,/air pollution.
Reporting
inspection
findings.
D
O
oooooReview and dis- E§
position of
reports.
Maintaining
record
systems.
0 Prosecuting
violators.
CO
I
Direct involvement
—» Occasional involvement
oooooooooooooo Action resulting from inspection activities
Figure VII-1. Degree of involvement of air pollution inspectors
in the control programs.
The control agency thus begins with the Air Pol-
lution Inspector and builds accordingly. Those prob-
lems which cannot be handled by him alone are then
assigned to specialists and technicians who are avail-
able to assist the inspector in handling problems
requiring special research and analysis. The inspector^
therefore, is not truly in isolation since the facilities
and resources of the agency are behind him. As a
matter of fact, part of his effectiveness in the field Will
depend on his ability to use these resources properly
when he needs them.
The Air Pollution Inspector is a general air pollu-
tion technician, and should possess the ability to grasp
the overall aspects of the program.
In the following, the various professional quali-
ties or practices which enter into the qualification of
the Air Pollution Inspector are examined.
A. Prerequisites
The educational background and previous experi-
ence required for candidacy for the base positions of
Engineering Inspectors and Inspectors respectively in
the Los Angeles County Air Pollution Control District
are as follows:
Engineering Inspectors: Candidates for the position of
Engineering Inspector are required to possess a degree from
an accredited college with specialization in engineering,
chemistry, physics, or metallurgy. One year's experience
in engineering, chemistry, physics, metallurgy or air pollu-
tion technical or enforcement work is permitted to be sub-
stituted for each year of college.
Patrol Inspector: No academic requirements are stipulated.
Candidates are required to achieve a relatively high score
on a general intelligence test and are then screened through
oral interview for such qualities as are needed for the
position.
In addition to the formal requirements for em-
ployment eligibility, candidates are screened and se-
lected for employment as follows:
1. Potentiality as Law Enforcement Officer
The inspector must be able to comprehend the
law he enforces and relate the proper code sections or
rules to the corresponding practical situations encoun-
tered in the field. Perhaps the most important single
attribute that the inspector should possess is the ability
to make logical and reasonable judgments. Judgment
in this case means the ability to discriminate from the
facts between flagrant, chronic, borderline or acciden-
tal violations, to recognize sincerity, intention, hon-
esty, on the part of plant managers.
Emotional stability is also an important quality.
The inspector must remain consistent and reliable
without being readily influenced. The inspector must
also be free of prejudices and biases which influence
his judgment. He must be capable of analyzing situa-
tions for the objective facts and be able to enforce the
law equally and firmly.
The ability of the inspector to express himself
completely and accurately, orally and in writing, is
also important since his findings are always being re-
ported for proper action. Particularly is this important
when an inspector testifies in court or explains a law
or policy to a plant operator.
Approach and appearance are also important
since the kind of appearance the inspector makes be-
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The Air Pollution Inspector
123
Figure VII - 2. An A.P.C.D. Patrol Inspector explains the air
pollution control law to management as it applies to the zinc
furnaces in the above plant.
fore the public influences compliance directly by his
ability to obtain respect for and confidence in his
function as a law enforcement officer for the Air Pol-
lution Control District.
2. Background and Potentiality for Technical
Expertness
The greater the technical background of the in-
spector, the more the field operations program will be
able to probe field problems.
The technical background required of inspectors
will vary according to the ultimate positions they will
hold when assigned to one of the three Inspection Sec-
tions. There are, however, certain desirable technical
qualifications which apply to all inspectors and which
are either a part of the inspector's formal education or
experience, or are provided the inspector during his
initial and subsequent in-service training.
Since the specialized engineering functions of the
Los Angeles County Air Pollution Control District are
almost wholly contained within the Engineering Di-
vision, it is not necessary for all of the inspectors to be
professional engineers. However, the minimum en-
gineering abilities that must be possessed are: (1) a
basic knowledge of combustion processes and equip-
ment operation, (2) techniques for determining and
reporting the causes of violation, and (3) the ability to
identify and classify for source registration, equipment
capable of air pollution.
Of these, determining the causes of violation in
the preparation of reports is perhaps the most crucial.
In determining the causes in all industrial violations,
a considerable amount of practical air pollution experi-
ence is required. In complex cases, not only must air
contaminants be identified and distinguished from
water vapor or natural constituents of the atmosphere,
but the inspector must possess a working knowledge of
equipment, process, maintenance and operation.
Furthermore, in investigating a violation, the in-
spector must be prepared to analyze various phases of
operating cycles of industrial equipment. He may have
to correlate such data as excessive pouring tempera-
tures, alloys, fluxes used, and relative volatilities of
metals with the opacities or densities of emissions he
observes. In each case, the inspector must be prepared
to take any engineering analytical approach necessary
to tie each violation to its cause.
Inspectors specializing in complex industries will
generally require a greater technical background in
chemistry or chemical engineering to enforce the law.
In the refinery and petrochemical industry, for ex-
ample, inspectors are required to understand all phases
of the complex technology of the industry.
3. Ability to Deal with the Public
The inspector's ability to perform his assigned
duties effectively, given a technical proficiency, will
stand or fall on the manner in which he conducts him-
self with the public.
Since the inspector is in the field most of the time,
he is constantly dealing with people—employers, em-
ployees, technicians, engineers, complainants, public
officials, vehicle operators, etc. He must be able to
approach each person according to the attitudes they
manifest. Some individuals will favor the control
agency's policies, others will be vehemently opposed;
some will be cooperative, others may be belligerent
and will seek to circumvent or obstruct the inspection.
Figure VII 3. An A.P.C.D. training class for ne\v field in-
spectors.
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124
Air Pollution Control Field Operations
In this regard, the inspector must be polite and cour-
teous, yet firm.
B. Training
Because of the recency of air pollution enforce-
ment, the control agency must train its personnel.
This training may continuously require extension and
modification in order to accommodate the broadening
scope of the control program. These include the fol-
lowing major elements:
1. Initial basic training, given to all inspectors.
2. Smoke reading training — given to all new field
personnel entering the division and bimonthly
thereafter. (See CHAPTER 10, IDENTIFICATION
AND EVALUATION OF SOURCE PROBLEMS.)
3. Specialized training to meet specific requirements.
The objectives of this program are to:
1. Develop proficiency in determining violations
within prescribed standards.
TABLE VII 1
FIELD INSPECTORS' TRAINING PROGRAM
Los ANGELES COUNTY AIR POLLUTION CONTROL DISTRICT
Hours of
Subject Instruction
INITIAL TRAINING.
1. Program Orientation 7
Introduction to L.A.Smog
problem, objectives and or-
ganization of the District;
personnel matters and note-
taking.
2. Legal Authority. 14
The laws and rules en-
forced as well as peace of-
ficer's powers, rules of evi-
dence, and Hearing Board
and Court procedures and
demeanor.
3. Report and Notice Writing. 8
Recording facts and elements
of corpus delicti on reports
and notices.
4. Equipment Description and
operation. 4
Academic instruction on
principal equipment and
industries capable of air
pollution.
5. Care and Use of Inspec-
tion Equipment. 5
Care and use of emergency
vehicles, stop watches,
cameras, storage kits and
communications.
6. Inspector's Duties and Re-
sponsibilities. 4
Duties, conduct and ethics
of inspectors.
7. Enforcement Division Poli-
cies. 2
Conduct with headquarters,
administrative policies of
the divisions.
8. Activities of Inspection
Sections. 4
Operation of Patrol, In-
dustrial and Refinery
Inspection Sections.
Total 52
Frequency Recipients
On Entry All inspectors
2. Develop understanding of basic equipment oper-
ations and potentials for causing specific pollution
problems.
3. Develop understanding of equipment inspection
techniques capable of revealing those problems.
4. Determine the specific air pollution problems
in any given area and the tracking of the problem
to a specified source.
A course outline is shown in Table VII 1.
C. Duties
The duties of the air pollution inspector immedi-
ately comprise the detection, inspection and reporting
activities described in the previous chapter. These are,
briefly, to patrol and conduct physical inspections and
inventories of equipment, to interview responsible par-
ties, witnesses and complainants, and to report inspec-
tion findings to supervisors and to the courts. The in-
spector also performs other duties made possible by his
field deployment, such as air monitoring, on-.the-spot-
source testing, etc. The duties of the inspectors in the
Patrol, Industrial and Refinery Sections are differenti-
ated as follows:
1. Patrol Inspectors
The duties of the Patrol Inspector are as follows:
a. Patrol assigned sectors thoroughly and systemat-
ically in order to seek out all stationary and mov-
ing visible violations.
Hours of
Subject Instruction
INITIAL FIELD TRAINING
1. Smoke School 24
Actual instruction in
smoke reading.
2. Field Orientation 8
Bus tour of representative
Industrial facilities.
3. Supervised Field Training
Individual supervised in-
struction in the field.
Total
SPECIALIZED TRAINING
1. Industrial Engineering Insp.
(no organized training pro-
gram). Individual instruc-
tion given as needed for
selected equipment inspec-
tions, source testing, etc.
2. Refinery and Petrochemical
Covers all technical phases
of refinery operations.
3. Radiological Monitoring 42
Theory and field practices
of radiological monitoring
4. Driver's Training 8
Frequency Recipients
Entry All inspectors
80
112
Given individual-
ly as needed
Industrial
Inspectors
20-100 As needed Refinery
40 hrs. initial
2 hrs. once
ayr.
Once
5. On-the-Spot Source
Testing
6. Air monitoring
REFRESHER
1. Smoke School
Given individual- As
ly as needed needed
20 lecture and
lab - 20 field
Initial
All
Inspectors
Selected Re-
finery In-
pectors
Source: Reference 3.
4 6 times All
per year Inspectors
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The Air Pollution Inspector
125
Figure VII - 4. A.P.C.D. Patrol Inspectors and emergency vehicles.
b. Answer and investigate all complaints issued by
radio, landline, memoranda, or instructions from
supervisors.
c. Enter locations where visible violations are ob-
served or complaints are involved in order to in-
vestigate excessive emissions.
The Patrol Inspector, however, does not enter a
refinery or petrochemical plant, a plant operating
under government control requiring a security
clearance. Investigation of complaints and viola-
tions are made by making preliminary observa-
tions of the exteriors of these locations, and by
calling upon the assistance of an Engineering
Sector Inspector or a Senior Inspector, or by for-
warding a report to the appropriate Section of the
Enforcement Division.
d. Patrol Inspectors may also conduct some sched-
uled inventory inspections limited to non-indus-
trial establishments such as hotels, hospitals,
warehouses, auto sales and services, agricultural
operations, etc., and government agencies includ-
ing schools and colleges. These sources will in-
volve either one or a combination of (1) inciner-
ators (multiple-chamber or illegal single-cham-
ber), (2) boilers, (3) paint spray booths, and (4)
open burning in land clearing, agricultural or
dumping operations.
e. Handle any other special assignments such as sur-
veillance, continuous observation of smoke plumes
for engineering tests and other related duties.
2. Industrial Engineering Inspectors
The Industrial Engineering Inspector:
a. Conducts inventory inspections and scheduled re-
inspections of all industrial plants where manu-
facturing or processing is involved, such as air-
craft, automotive and trailer manufacturing, man-
ufacture of construction materials, food process-
ing, foundries, etc., and prepares equipment lists
for each plant location.
b. Conducts physical inspection of equipment to de-
termine operational and maintenance practices
and general compliance with the Rules and Reg-
ulations and State Health and Safety Code or with
variance conditions imposed by the Hearing
Roard.
c. Assures that equipment operates under valid oper-
ating permits, and takes action against all unper-
mitted equipment or infractions of permit con-
ditions.
d. Checks for possibility of invisible emissions and
requests source testing, if warranted.
e. Investigates reported breakdowns of air pollution
equipment.
f. Investigates emergency air pollution problems
developing in any industrial plant.
g. Conducts technical inspections which may be in-
volved in selective enforcement activity, and as-
sists patrol inspectors in acquiring evidence for
observed visible violations.
h. Elicits the cooperation and confidence of plant
management in order to encourage voluntary
compliance. Advises management of proper op-
eration of equipment, but does not offer engin-
eering advice.
i. Handles complaints made against industrial es-
tablishments.
j. Handles special assignments and details. Makes
opacity readings and observations for the En-
gineering Division on engineering final inspec-
tions and for the Research Division on laboratory
tests. Engineering Inspectors are also required to
participate in air sampling when an alert is pre-
dicted and during alert periods, and in air monit-
oring details during late and evening hours.
3. Refinery and Petrochemical Inspectors
The duties of the Industrial Engineering Inspect-
tors assigned to the Refinery and Chemical Inspection
Section are essentially the same as those described
above for the Industrial Inspection Section, with the
exception that effort is concentrated on refinery, petro-
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126
Air Pollution Control Field Operations
chemical, chemical and allied plants. The degree of
specialization, also, is generally higher than in the
other sections. Inspectors selected for this section
usually possess petrochemical and chemical back-
grounds, and are specially trained. The Refinery
Inspector also performs the following:
a. Conducts special and continuous inventories and
surveys to locate, classify and quantify materials
and equipment.
b. Develops test procedures and conducts on-the-spot
tests for visible or lethal contaminants, rack tests
to determine API gravity, Reid Vapor pressures,
and quantities of H2S, CO, etc., emitted to the at-
mosphere.
c. Refinery Inspectors systematically patrol sectors
to provide refinery surveillance.
4. Night and Morning Watches
Night and morning watches are conducted for the
purpose of maintaining continuous around-the-clock
surveillance of the pollution zone. Enforcement per-
sonnel must thus be available for any emergency
situation which might arise, to monitor the air and to
answer complaints. A minimum crew is maintained,
and the inspectors are deployed as required, rather
than by sectors.
D. Powers
In Los Angeles County, the Air Pollution In-
spector is a peace officer with powers restricted to
those defined in the California Health and Safety
Code. The essentials of this power are contained in
Section 24246 which gives the Air Pollution Control
Officer the power to:
1) Enforce any provision of the California Health
and Safety Code, or any provision of the Vehicle
Code relating to the emission of air contaminants
or any order, regulation or rule established un-
der the authority of the California Health and
Safety Code.
2) Enter every building, premises, or other place,
except a building designed for and used ex-
clusively as a private residence.
3) Stop, detain, and inspect any vehicle, designed
for and used on a public highway but which
does not run on rails.
This power is delegated to the Inspector, who is
a deputy of the Air Pollution Control Officer. This
delegation is established by Section 24100 of the Cal-
ifornia State Government Code which states:
"Whenever the official name of any principal offi-
cer is used in any law conferring powers or imposing
duties or liabilities, it includes his deputies."
Section 24223 of the State Health and Safety Code
makes this delegation explicit:
"The Air Pollution Control Board may provide
for assistants, deputies, clerks, attaches, and other per-
sons to be employed by the Air Pollution Control
Officer, . . ."
The Air Pollution Inspector, as a peace officer for
the purpose of enforcing the air pollution control law
only, possesses the power of arrest. This power is de-
rived from the California State Penal Code. The in-
spector may make arrests for misdemeanors in air
pollution law committed in his presence. However,
such arrests are never made, except possibly in ex-
treme cases of provocation, or assault by the violator.
Even in such cases, arrests are made only with the
assistance of a police officer. All infractions of air pol-
lution laws, including those of Section 24246, can be
handled by means of legal action, i.e., through the
courts themselves.
E. Policies
A policy is a course of action usually agreed upon
in advance; it is a rule or guide to conduct, a criterion
for disposing of problems which continuously arise in
the operations of an organization. In the case of the
air pollution control agency, we may consider policy
as anything which guides the conduct of field person-
nel, but which is not law itself.
Although the inspector is not directly one of the
policy-making members of the Enforcement Division,
he must be able to recognize situations in which policy
decisions are called for. These are usually situations
not covered by existing practices and procedures. All
such questions are forwarded to the appropriate com-
mand level, to the Chief Inspector, Enforcement
Director, or Air Pollution Control Officer and his staff.
In such cases, it is of the greatest importance that the
decision be made at that command level which is cog-
nizant of all of the operations affected. Any given
policy decision must be capable of being applied to all
similar situations and must be consistent with other
policies.
The inspector thus enforces and applies existing
policy, and, also, raises questions which may cause the
revision or institution of new policies. Because all
situations will not be covered by strict rules or guides,
the inspector must frequently be prepared to infer the
proper course of action from general policy pronounce-
ments. For example, the course to be taken in many
diverse cases may be derived from the following state-
ments:
1. The diversity of the enforcement program em-
phasizes one of the fundamental concepts of
air pollution control: all sources of air pollu-
tion, regardless of size or economic impor-
tance, must be controlled or eliminated.
2. The Enforcement Division prescribes results,
rather than methods of obtaining results. In-
spectors do not engineer air pollution projects
in the field or advise management on the con-
struction of equipment. (Certain advice may
be given as to operation, however.)
3. All violators who are either cited or served a
written notice are prosecuted in the courts if
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The Air Pollution Inspector
127
the evidence under investigation is sufficient.
4. Court cases are processed with dispatch and
promptness in order that there be no delay in
justice on the part of the District.
Policies evolve with respect to meeting the public,
performance, personal conduct, and relations with
Headquarters. All such policies should descend from
clear and consistent principles of enforcement.
F. Ethics
Ethics deals with principles of honesty, of right
action. An emphasis on ethical conduct and practices
on the part of inspectors may often preclude restrictive
internal policies designed to prevent unethical conduct.
For the air pollution inspector, existing engineer-
ing codes of ethics are adequate for all situations which
may arise. However, there are several items which
must be given more attention, particularly in a gov-
ernmental agency, in order to avoid any possibility of
misunderstanding on the part of the public:
1. Inspectors do not take any action or make any
statement which interferes with any official
act or decision of the District.
2. Information acquired in any plant should
never be disclosed to a competitor.
3. The law must be applied uniformly to all.
Uniformity of treatment is the basis of suc-
cessful governmental control.
4. No special consideration can be given.
5. No firms can be recommended for air pollu-
tion control projects; no engineering recom-
mendations will be made by inspectors.
6. Reports must not in any way be falsified.
7. No gratuities should be accepted.
G. Inspector's Equipment
In order to accomplish his duties, the inspector
requires the use of the following equipment:
1. Vehicles
Two types of vehicles are employed in Los An-
geles County—,the emergency vehicle operated by
Patrol Inspectors, and the neutrally colored county
vehicles operated by Engineering Inspectors. Both are
equipped with two-way radios. The purpose of the
emergency vehicle is to enable inspectors of the Dis-
trict to remain on the road during any period of alert
in which vehicular traffic is restricted, to speed to any
local emergency of an air pollution nature, and to
halt motor vehicles emitting excessive emissions. The
Air Pollution Inspector cannot, however, use siren and
lights unless he receives a Code 3 authorization from
Headquarters. (Figure VII-4.)
Each Patrol Inspector is assigned a black and
white emergency vehicle equipped with sirens, lights
and two-way radios. In operating the vehicle, the
Patrol Inspector must take extra care to obey the rules
of the road at all times.
The operation of the emergency vehicle is exempt
from the rules of the road under Section 22105 of the
Vehicle Code under the following conditions:
a. In responding to an emergency call.
b. In the immediate pursuit of an actual violator
of the law.
c. In the immediate pursuit of a suspected vio-
lator of the law.
d. In responding to, but not returning from, a
fire alarm.
And when the following conditions are met:
a. A siren is being sounded in a manner which
gives reasonable warning of the approach of
the vehicle.
b. One lighted red lamp which is visible in nor-
mal atmospheric conditions for a distance of
500 feet is displayed on the front of the ve-
hicle. (Sees. 21055, 22107, 22108).
Three things must always exist simultaneously before
these exemptions provided by Section 454 of the Ve-
hicle Code are effective:
a. The vehicle must be an authorized emergency
vehicle.
b. One or more of the four circumstances listed
above must exist.
c. Both a siren must be sounded and a red light
displayed, simultaneously.
No privilege to operate a vehicle in disregard of the
"rules of the road" can be established unless all of
these facts can be proved. And having complied with
all these conditions, the benefits of the privilege are
still denied if the driver of the vehicle fails to show
due regard to the safety of all persons using the high-
way, or arbitrarily exercises his privilege.
Even with the siren and light the peace officer
must give adequate warning, and drive in a manner
which shows regard, under the circumstances, for the
safety of persons and property on the roadway. The
siren must be sounded a sufficient time before reaching
intersections to allow persons coming from intersecting
roadways to adjust mentally, react physically, and
bring their car to a stop before the emergency vehicle
reaches the intersection. This warning can be more
clearly given if the siren is sounded well enough in
advance and in a manner which will cause a fluctua-
tion in tone and volume. In congested areas, also, the
emergency vehicle should be operated in second gear.
2. Test Equipment
A few emergency vehicles employed by the Re-
finery and Petrochemical Section are fully equipped
with on-the-spot testing equipment used for testing
local atmospheres. Such equipment includes test paper,
M.S.A. gas testers, Tutweiler apparatus, M.S.A. mid-
get impinger and gas absorption cell, Halide leak de-
tector, Explosimeters or combustion meters, etc. In
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128
Air Pollution Control Field Operations
Figure VII - 5. Polaroid Land Camera used for obtaining pho-
tographic evidence by inspectors in the field.
addition to such test equipment, all inspectors carry
Geiger counters or ion chambers for radiological mon-
itoring. (See Chapter 11.)
3. Cameras
Inspectors are issued Polaroid land cameras for
assistance in gathering evidence in the field. These
are capable of photographing and developing prints
at the site of investigation. Cameras are used primarily
to photograph excessive emissions from stacks and
vehicles, equipment and operators for identification
purposes. (Figure VII-5.)
4. Stop Watches
Inspectors are issued accumulative stop watches
for use in recording total time period of excessive
emissions.
5. Inspector's Kit
This kit is issued to each inspector for the holding
and storing of all essential equipment including forms,
cameras, flashlights, maps, etc., as a means of keeping
all of such material organized in space allocated within
the vehicle.
II CONDUCT OF THE INSPECTION
In air pollution field operations one single prin-
ciple appears to apply more than any other: air
pollution cases exhibit greater diversification than
similarity. The classification of work and sources of
air pollution break down so extensively that it is
difficult to generalize on methods and principles, or to
briefly illustrate typical instances. Yet, it would be
well to consider in one place the steps taken in the
conduct of an air pollution field inspection. An origi-
nal inventory inspection is chosen here since it is
usually the most thorough inspection conducted. The
violation inspection, or other types of inspection differ
according to the type of air pollution problems encoun-
tered. These will be discussed in greater detail in
following chapters of this manual.
The inspection breaks down into five parts: (1)
observation of the plant exterior, (2) interviewing
plant management, (3) the physical inspection of
equipment, (4) concluding the inspection, and (5)
preparation of the report.
A. Observation of the Exterior
The outside of the plant is the first thing that the
inspector observes. The general layout, relative size
and location of stacks, vents, and incinerators are par-
ticularly noted. The inspector estimates the possible
contaminants that could be emitted into the atmos-
phere by such a plant. He tours the periphery of the
plant, unless it is so small that all sides can be observed
without the tour, and takes notes to make certain that
all observations of visible air contaminant emissions
are recorded. Particular attention is paid to points of
observation, location of emission, time, color, opacity of
contaminant and accuracy of source description.
B. Interviewing Plant Management
The inspector enters the plant, identifies himself
and attempts to contact the top authority before con-
ducting any business with any other person within the
plant. The inspector makes an effort to see the head
of each plant personally; and in the event that this
person is out, the next in authority and so on. This
rule applies every time a plant is entered, unless the
head of a plant designates a certain person to be con-
tacted on future visits. This is a procedure which the
INSPECTOR'S MANUAL
PERMIT APPLICATION BLANKS
MISCELLANEOUS
DAILY REPORT PADS
EQUIPMENT LIST PADS
AND ENVELOPES
CAMERA
EXTRA STOP
FILM WATCH
RULES & REGS.
NOTE BOOK
I.R. BLANKS
NOTICE PADS
WORK
CALENDAR
Figure VII-6. Inspector's kit.
-------
The Air Pollution Inspector
129
dignity of the situation as well as common courtesy
demands.
Before the plant is inspected, the inspector in-
forms management of his planned inspection of the
premises. Usually permission to enter is granted with-
out question, but at times it is necessary to explain
that the Health and Safety Code gives the inspector the
right of entry. The inspector either reads or shows the
plant head Section 24246 of the Code if necessary. If
permission is then refused, the inspector does not enter
forcibly but asks for a direct verbal refusal of entry
and then informs the party concerned that such re-
fusal is a misdemeanor. The inspector then reports at
once by telephone to headquarters. Refusal of entry is
rare, however, as most plants are prepared to co-
operate.
The inspector then interviews the representative
of plant management contacted. The interview ac-
complishes three objectives: (1) it informs the man-
agement of the purpose of the inspection, as well as
imparts all information the plant manager may re-
quire regarding the air pollution control program; (2)
it elicits information that the inspector requires to
determine permit status and compliance; and (3)
organizes the inspection.
The inspector approaches any individual in the
plant at his own level of speech and understanding.
It does harm to the inspector's prestige to use ex-
tremely colloquial English with an executive, but, on
the other hand, it ruins cooperation if the inspector
assumes a superior attitude and uses complicated
words with a person whose vocabulary is limited. The
inspector uses as clear expressions as will adequately
describe whatever idea he is trying to implant. An
interested and sincere, but not unfriendly attitude,
creates the most desirable atmosphere for accomplish-
ing the inspector's purpose.
After the plant manager is informed of the visit,
the inspector then gathers preliminary data regarding
the ownership of the plant, and the basic processes
conducted by the plant. Pertinent laws regarding the
permit system can be explained at this point in the
inspection.
If the plant is exceptionally large or the processes
employed are complex, the inspector plans the inspec-
tion with the manager or whoever is subsequently
detailed to accompany him. The company escort thus
assists the inspector in making a complete inspection.
In planning the inspection, the basic manufactur-
ing processes are usually discussed. This provides an
opportunity for the inspector to ask questions about
unfamiliar processes beforehand. This is often quite
helpful, since the working area of the plant may be
too noisy for normal conversation. The inspector, after
learning of the steps taken in the process, can formu-
late a department-by-department inspection plan. He
generally follows the flow of materials, the actual steps
through which the manufacturing process is con-
ducted. As this is discussed the inspector collects oper-
ating data which he can verify when he inspects the
equipment. A friendly discussion of this nature at the
beginning of the inspection saves much time.
C. The Physical Inspection
The plant to be inspected will comprise one of two
distinct types of situations — (1) a plant consisting of
individual pieces of equipment units, such as a foun-
dry, even though individual operations may be con-
vey orized, or (2) plants constructed on the basis of
process units, i.e., equipment units inter-connected by
sealed or ducted flow systems.
In a plant that is relatively simple, it is only
necessary to list equipment units. In a more compli-
cated plant a generalized box-type flow diagram on the
reverse of the Equipment List may be required. Re-
gardless of the type of plant, the inspector should
always provide the information or diagrams necessary
to describe the plant to one who has not seen it. (For
process flow diagrams, see CHAPTER 14.)
The inspector then inspects each equipment unit
individually and acquires information from his obser-
vations and inquiry. In collecting inventory data, it is
essential to write down the data at the time it is given
to avoid errors. Some inspectors find it necessary to
draft information first on notes, others record the in-
formation properly in final form on the proper report
form. The inspector then performs the following:
1. Identifies the equipment unit by function,
commercial name and plant location.
2. Analyzes the physical operation of the equip-
ment, from influent to effluent, determines de-
gree of operation and use; notes capacity, gen-
eral operational efficiency and compliance
with conditions stated on operating permits.
3. Checks and evaluates all pertinent mainte-
nance and operational practices.
4. Determines permit status, date of construc-
tion, alteration or structural modification since
last visit for each piece of equipment.
5. Acquires evidence through observation and
inquiry for any violation observed.
Much of the data can be observed directly at first
hand, especially if the equipment unit is in full opera-
tion. Other data can only be elicited by asking devel-
opmental questions. If the latter approach is required,
it is often best for the inspector to be genuinely
interested in the process, to be curious about the
operation, rather than to frame questions in terms of
alleged guilt. In dealing with statements, the inspector
may repeat them to assure their accuracy. This can
always be done by stressing the fact that an accurate
record of plant information protects management
against the use of incorrect information.
The operational and maintenance practices are
important as evidence, since negligence or ignorance
may result in violations. The inspector is interested in
-------
Air Pollution Control Field Operations
the physical operation of the equipment in relation to
the air contaminants emitted from the stacks or ex-
hausts of the equipment. He checks those parts of the
equipment, or phases of the operating cycle which
directly affect the emission of air contaminants.
It should be noted that the inspector does not
directly order or instruct the operator in proper opera-
tional and maintenance procedures. The inspector pre-
scribes results rather than methods of obtaining results.
He can discuss effective control practices as he knows
them, but he is always careful to explain that the
methods employed are up to management.
A quick analysis of the plant situation and the
statements made by management enables the inspector
to ascertain whether any violation observed is flagrant.
chronic, borderline, or accidental in nature. The inter-1
view likewise enables the inspector to distinguish
between sincerity, dishonesty, conscientiousness or
negligence on the part of management.
These discriminations may be subjective, but if
the inspector has used his judgment, he will be able
to substantiate his findings and decisions, verbally or
in writing. An analysis of a corpus delicti, discussed
in Chapter 13, defines how these discriminations may
comprise the facts in the commission of a crime. The
guiding criterion in the field, as in the courts, is rea-
sonableness, that is, is the plant operating within "due
or just limits", and is the evidence compiled clear as
to the intent and commission of a crime?
As the inspector checks the individual items of
equipment and records them on his inventory list, he
also determines the date each piece of equipment was
installed so that he can evaluate the permit status of
the equipment. In Los Angeles County the date of
installation is important in determining whether or
not equipment requires permits. Equipment capable
of air pollution requires a permit to operate if in-
stalled after February 1, 1948. (See (1) "When Per-
mits Are Required," Chapter 14.) The inspector ex-
plains the air pollution control law in each case.
In completing all items required on the Equip-
ment List, the inspector attempts to determine whether
or not any alteration of the equipment has taken place
since the last inventory inspection. He checks for the
posting of permits near the equipment, as required
by Rule 10 and determines whether or not the equip-
ment is being operated according to the conditions
stated on permits (Section 24280).
D. Concluding the Inspection
In concluding the inspection, the inspector com-
pliments the plant operator on a well operated and
clean plant. However, the operator is not told that he
"does not violate" the air pollution control laws when
what is meant is that he is not violating at the par-
ticular moment under consideration.
At this point, the inspector may desire to review
the results of the inspection with the plant operator.
If the plant manager needs operating permits for
some of his equipment, the inspector explains the pro-
cedure for submitting the applications and the dates
the applications are due. The inspector supplies appli-
cation forms together with any written requests when
permits are mandatory. He also supplies the plant
operator with additional forms when he learns through
inquiry that plant expansion is contemplated. If the
operator has also shown interest in the air pollution
problem, the inspector may leave appropriate informa-
tional publications.
The inspector then takes his leave without unnec-
essary delay. The plant operator has taken time from
his usual duties to be with the inspector, and his time
represents money. The leave is taken on a friendly
note.
E. Writing the Report
After the inspector completes the inspection, he
writes his report. Since reports are usually short
and can be confined to the report forms, they are
written just as soon as the inspector reaches his ve-
hicle. Occasionally, when inspections are highly tech-
nical or are involved, and data at headquarters are
required, the inspector may complete his report at
headquarters. This is especially true when the in-
spector needs to check plans and specifications in
permit application folders.
Since inspector's reports are short, the inspector
must be able to select essential and relevant details
and to describe them accurately and coherently. This
is important since the inspector, by taking an interest
in the plant, may have gathered a great deal of infor-
mation. Only a portion of this information relates to
the air pollution problems which may be encountered.
The inspector attempts, however, to be complete and
accurate. He cannot be so if he has not fulfilled the
objectives of his inspection. An effective report, there-
fore, correlates directly with the quality of the in-
spection.
The inspector completes from his notes and his
recorded data the following sections of the report:
(See Figure VII-7 and also Figure XIV-10, Activity
Status Report.)
1. The Heading
The heading consists of the accurate identification
and location of the source of air pollution: the name
of the company and the address, the date, time and
interval of time of the inspection, the name and title
of the person contacted.
2. The Findings
**
The findings first show the reason the plant was
inspected. Then only the facts of the observation are
reported, such as the densities or opacities of emissions
observed, time intervals and time of emissions, a def-
initive description of equipment involved, operating
-------
Ok'd. to File; By
Title
Date
19
M.R. File
INSPECTOR'S REPORT
AIR POLLUTION CONTROL DISTRICT
LOS ANGELES COUNTY
NAME LCM4 IJKDA APARTMENTS
1959
ADDRESS 7211 Fountain ivenue""1 " ""'
PREMISES USED FOR:Apartment8°f """"
CITY West Covina
Reason for Report: Denial No.
Re. Hear. Bd. CH Complaint No.
PermltD Dust S3 Odor EH Fumes CHI Smoke CD Breakdown D Requested By
Inspector's Findings: Investigation disclosed a U-story, 32-unit apartment house equipped
with an Anderson flue-fed incinerator modified with a Grant gas-fired afterburner. The
incinerator and afterburner were in operation at this time. Ash pit was 15% filled with
ashes, and ash pit door was open. An accumulation of fly ash in S.E. corner of firewall
on roof area, and on the front porch, lawn, and window sills of complainant's properly
were noticed. An emission of 20? white smoke, but no fly ash was being emitted at this
time. Spark arrester was in good condition.
Inspector's Recommendation: Equipment covered by AFCD Pemit No. 9772. Will observe
operation early mornings.
16-40D179
Figure VII - 1. Front and back sides of an Inspector's Report of a typi-
cal incinerator complaint. In the APCD, the Inspector's Report is used
for all situations in which the inspection findings are negative and are
not covered by any of the other report forms. For example, the report
is used to cover situations which are borderline, doubtful, suspected (m
the case of visible contaminants), or are otherwise uncitable. This form
is also used to report follow-up inspections (permit, denial, memoranda,
compliance checks, complaints and variances), plant surveillance and
complaints. An inventory inspection, on the other hand, such as is
described in this chapter, is reported on special inventory forms (see
Chapter 14), while a violation is reported on a Written Notice or Cita-
tion of violation (see Chapter 13).
(Front)
(Back)
PERSON CONTACTED
AT PREMISES INSPECTED HenTyJackson
TITLE
PE'R'S"QNECONT|A'CTED I light *he incinerator every morning at 6:30 A.M. On
Manager
occasions I
forget to light the auxiliary gas burners. The owner says the gas bills are too high
if I keep them going every time I burn. No, I didn't know we had a fly
ash problem,
I'll check the stack the next time I burn.
-
NAME OF COMPLAINANT Krs. Nancy Graham
ADDRESS OF COMPLAINT 7207 Fountain Avenue
TITLE
CITY
STATEMENTOF (street inumberJ
COMPLAINANT "Every time they burn in the morning my house, my yard, and
soiled by the burnt paper dust'.'
Housewife
West Covina
Icity or communityl
my wash are
Elapsed Time on Insp. & Report 8:30-p^;To 9:20 m!
Signature of Reporting Inspector: Donald Jordon
n . . . T DIRECTOR OF CHIEF HEAD
Keter d lo:- ENFORCEMENT INSP. INVESTIG.
vtfk~»4Sjfa6*
Time Left Source
A.P
RADIO
COMMUNIC.
Premises 9:20 ££
.C.D. Zone 7
PATROL
«- TITLE DATE 19
r 16-40D179
o
3
5"
PH.
^
-------
132
Air Pollution Control Field Operations
conditions such as fuels and materials used, operational
and maintenance practices and any other pertinent
information which relates to the cause, control and
effects of air pollution. These represent a complete
account of the air pollution "configuration" described
in Chapter 9, or, in violation cases, the corpus delicti
described in Chapter 13.
The findings record results only of direct observa-
tions. No assumptions, opinions, statements, specula-
tions or notes on past performance should appear in
this section. Facts reported should be logically related
in a causative sequence and should refer either posi-
tively or negatively to all of the elements of the evi-
dence which may be required to prove a violation. In
this sense, facts involving successful compliance with
the rules and regulations are as important as those
which prove non-compliance.
Where complicated processes are involved, the
findings constitute a complete description of the unit
process written in a logical flow sequence. All physical
and chemical operating conditions which bear on the
actual or potential air pollution problem are shown.
Enough of the associated equipment involved is de-
scribed so that the reviewer may draw conclusions
from the report.
3. Statements
This section of the report records the statements
made by the responsible party under interview and
includes any remarks made or answers to specific
questions which explain, qualify, or supplement the
facts observed by the inspector. These will include
verification of responsibility for equipment, general
maintenance and operational policies, admissions as to
compliance and non-compliance and knowledge of air
pollution laws.
The statements that the inspector records are
germane to the intent or negligence involved in com-
pliance and non-compliance with air pollution laws.
This section also provides space for any state-
ments made by complainants under interview.
4. Conclusions
This space is used to summarize the findings and
the statements made and to make recommendations
regarding the filing of the report, scheduling of a re-
inspection, or recommending some specific type of
headquarters action. It is also used to record pertinent
comments or warnings the inspector made to the re-
sponsible party. The inspector's assumptions, opinions,
statements, recommendations, speculations, or notes on
past performance may also appear here.
The report concludes with the signature of the
inspector and the sector number.
F. The Reinspection
The frequency and type of reinspection depend
entirely on the factors involved in each plant situation.
A chronic problem of air pollution in any given plant
may require numerous reinspections. Some plants
may require inspections or observations of the exterior
once each day, others are inspected only for the pur-
pose of the inventory inspection once or twice each
year.
The criterion for conducting reinspections should
be made on logical grounds. A logical schedule of re-
inspection is deduced directly from the data gathered
on preliminary inspections and is based on such factors
as the time equipment operates, shuts down, starts up,
the dates unusual materials are processed, the season
of greatest productivity, curtailment of natural gas,
and complaints.
1. Inventory Reinspection
It is the purpose of the inventory reinspection to
determine what changes and improvements have been
made since the inspector's last visit. If equipment
which requires an air pollution control permit has
been installed in the interim without proper authoriza-
tion, the inspector issues either a written Notice or a
Request for Application for A.P.C.D. Permit depending
upon whether he finds that the construction of the
equipment constitutes a flagrant or willful violation,
or whether extenuating circumstances are involved.
2. Permit Follow-up Reinspection
If the applications for permit are not received, a
permit follow-up inspection is conducted usually ten
days (the "due date") after issuance of the Request.
If the operator continues to operate this equipment
without making application, he can be cited for a vio-
lation of Section 24279 of the Health and Safety Code.
When the inspector discovers the equipment
which is capable of air pollution to be under construc-
tion at the time of his visit, he takes steps towards
legal action by immediately writing and serving a
written notice. He also issues a Notice each day he
returns and finds the construction progressing. The
distinction between unauthorized new construction
and unauthorized existing construction is made ad-
ministratively since in those cases in which a violation
of the law is involved, the District has an option and
can discriminate between situations involving neglect
and ignorance and those involving flagrant violations.
(See Chapter 11, COLLECTING AND REPORTING EVI-
DENCE OF VIOLATION.)
3. Denial Follow-up
Another type of permit reinspection or follow-up
concerns that which is made to determine whether or
not equipment has been removed from premises or is
otherwise secured against future use, after the applica-
tions for operating permits for such equipment have
been denied. In these cases, no administrative dis-
tinctions are made unless the applicant has taken steps
within a ten-day period to petition for a variance or
-------
The Air Pollution Inspector
review of denial to the Air Pollution Control Hearing
Board. If this has not been done, then continued
operation of equipment is a flagrant violation of the
law. When the inspector returns and finds such un-
permitted equipment in operation, he issues a Notice
of Violation.
Reinspections conducted to investigate public nui-
sances may be more complex and are described in
greater detail in Chapter 12.
REFERENCES
1. McEwen, L. H., Hocker, A. J., Inspector's Guide, Inspection Di-
vision, A.P.C.D., April 1. 1953.
2. Weisburd. M. I., Roberts, P., Inspector's Manual, Los Angeles
County A.P.C.D., Enforcement Division, May 1957.
3. Griswold, S. S., Parmelee, W. H., McEwen, L. H., Training oj
Air Pollution Inspectors, presented before 51st Annual Meeting,
Air Pollution Control Association, Philadelphia, Pennsylvania,
May 28, 1958.
-------
CHAPTER EIGHT
HANDLING THE CITIZEN COMPLAINT
I THE ROLE OF PUBLIC RELATIONS IN
THE CONTROL PROGRAM
Since air pollution is exposed to public view, the
citizen complaint is likely to become an important part
of field operations. Complaints made to the control
agency fall into two general categories: (1) protest
against general air pollution conditions, and (2) com-
plaints against specific sources of air pollution. The
more severe and frequent the air pollution problem,
the greater the number of complaints. It is therefore
necessary to consider the role public relations plays in
the control agency, since the information available to
the public has an important influence on the way field
inspectors handle complaints, and on the usefulness
and pertinency of citizen complaints to the field con-
trol operations program.
The propriety of conducting a public relations
program by a government agency frequently is raised.
Actually, it is difficult to generalize on ethical prac-
tices in this matter, except to state that public relations
in government is limited to the advancement and ex-
position of public policy and to the dissemination of
facts and information necessary to the proper function-
ing of a democracy, and should not be used for politic-
al purposes.
Still, within such limits, the question is raised
whether public relations should be active, aggressive
and professional, or whether it should be passive and
limited only to answering individual complaints.
Should public relations attempt to anticipate com-
plaints? Should it attempt to elicit support for neces-
sary legislation?
The answers to these questions determine the na-
ture of the services to be provided. The functions and
problems of police, health or fire departments are
clearly visualized by the public. Therefore, an agency
like a police department may seek by means of a pub-
lic relations program to maintain a good feeling and
understanding between the department and the com-
munity. Such departments may also engage in pro-
grams intended to prevent crime, disease and fire
disaster by means of public information and education,
as well as various types of community relations pro-
grams. Such practices generally go unquestioned.
A new agency created to control a problem like
air pollution has entirely different needs in public re-
lations. In this case, an air pollution control program
must be advanced to the public for acceptance. Before
acceptance is possible, the facts must be presented, as
well as those difficult areas of the problem requiring
research. The public, then, must be constantly in-
formed of the facts, developments, successes, failures
and problems faced by the agency. If the public lacks
such information, the control program will not rally
the support essential to its success.
Because smog tends to induce widespread annoy-
ance whenever it occurs, a public information and
education program is especially required in air pollu-
tion control. Regardless of the steps taken towards
control, public complaints will continue as long as there
is smog. If the causes of smog are not obvious, then it
becomes easy for individuals to invent or to imagine
causes, and to direct blame unfairly on the basis of
personal bias. For example, when an air pollution
problem appears in a community, "big business" is
likely to be blamed, and quite often a specific industry
will be named. Here it is important to realize that
while many "big" businesses contribute to a complex
problem, others may not, and that many small sources
may contribute far greater amounts of pollution than
one large source. In such situations, the size of a busi-
ness or its commercial prestige may have little to do
with the amount of pollution it produces.
The control agency and local government in gen-
eral may also be condemned. The less informed the
attacks are, the wilder the generalizations made by the
public. Uninformed protest usually arises as a result
of a lack of understanding of the causes and effects of
smog, and the progress and problems of the control
program. As generalizations based on misinformation
can lead to distortion, confusion, hysteria and, ulti-
mately, civic paralysis it is of the utmost importance
that the public be exposed generously to the facts about
air pollution control.
II HANDLING THE GENERAL SMOG
COMPLAINT
The general type of smog complaint consists of
expressions of annoyance, discomfort, or displeasure
with prevailing smog conditions. It is generally ex-
pressed in terms of eye or respiratory irritation, reduc-
tion in visibility, or general dissatisfaction with control
progress.
Quite often complainants imply that 1) a single
or a group of industries is responsible for the air pol-
lution in the community, and 2) r overnment is in-
capable or unwilling to solve the problem.
Since the control agency is already engaged in
abatement activities there is no special action that can
be taken on the general smog complaint, except to im-
part to the complainant as much information as possi-
ble. This is done through normal public relations ac-
tivities conducted by a Public Information and Educa-
tion staff. It is the duty of this staff to answer all such
complaints and to release information concerning the
activities of the control program to all communication
media. Most of the other personnel in the agency are
-------
Air Pollution Control Field Operations
also called upon to answer telephone complaints made
by the public. Enforcement personnel, in particular,
perform a public relations function since they are in
constant contact with the public in the field.
The answer given to each complainant, of course,
depends on the nature of the complaint. The employee
who responds to the complaint is not being challenged
to debate. He serves a valuable function in letting the
complainant "get it off his chest." On the other hand,
he imparts information regarding both the progress
made and the problems or obstacles to control being
encountered. This can be done by telephone or by
sending the complainant literature on the subject.
In answering the general type of complaint, it is
often necessary to point out the multiplicity of sources,
mass emissions, the collective nature of the respon-
sibility, and the legal, social and economic framework
within which the control agency must function. It
also may be pointed out that air pollution problems
involve significant unknowns which require research,
especially where proven control methods in certain
crucial areas of the problem are not available. The
answers to all such smog complaints are generally re-
ducible to the "control-of-the source" concept described
in Chapters 2 and 3 of this manual.
It is extremely important in all of these cases for
the employee not to become so involved in the com-
plaint that he becomes emotional. On the other hand,
neither should he apologize, or assume a purely de-
fensive position.
The facts cited in answering complaints should
be honest, accurate and complete, and should be recited
in a calm and friendly manner. If the agency has an
unsolved problem, that problem, or any recognized
deficiency should be admitted and the steps being
taken to correct it explained.
It is important that the employee never regard
such complaints as being directed against him person-
ally. Rudeness and insults should not arouse anger or
place the employee on the defensive. There are, of
course, situations of unwarranted abuse after the in-
spector has accommodated the complainant to the best
of his ability. If the complainant does not accept the
honesty or accuracy of the facts, after it has been ex-
plained that such data is a matter of public record,
such abuse need not be any longer accepted by the
employee, and the conversation should be turned over
to a higher employee, if circumstances permit, or it
should be terminated.
In the area of general public relations, the field
inspector accomplishes more by creating an effective
agency image through his deportment, than by mere
persuasion. The inspector's appearance, manner,
speech and general competence creates confidence in
the activities of the agency. In responding to com-
plaints, the inspector makes that response which is ap-
propriate to the dignity of a governmental agency.
The inspector never expresses anger. An inspector is
courteous, helpful and firm if necessary. If relation-
ships break down, they should be terminated.
Ill HANDLING SPECIFIC SOURCE
COMPLAINTS
A. Receiving the Complaint
In the Los Angeles County Air Pollution Control
District, the switchboard operator determines whether
the complaint is concerned with a specific source, or
with general smog conditions. If it is the former, the
call is forwarded to a Senior Engineering Inspector in
the Enforcement Division.
B. Dispatching an Inspector
The Senior Inspector then immediately notes the
names and addresses of the source and the complainant
respectively on a Radiophone Message Log (Figure
VIII 1). He attempts to determine the validity of the
complaint, the nature of the problem, and exactly what
a field inspector could accomplish. In some instances it
is unnecessary to dispatch an inspector since the loca-
tion may already be under investigation. In other cas-
es the source may already have been reported by the
inspector in the field.
TIME RECEIVED
1960JUL 7 PM 4 21
REC'D. FROM: Jh/£
930 HMi
DO HOT CONTACT
961 -SMOKE
962-OPEN FIRE
963-ODORS
96H-DUS
967-BRE KDOWH
968-RE OUT TO COURT
9G9-RE ORT TO H.flO.
980-CA SERVICE
TEN 19- OWE TO HDQRS.
TEH 21- ELE. HDQRS.
TEN 88-TELE. HUMBERT
TEN 91 -ROLL CALL CHG.
CODE:
V
Air Pollution Control District—County of Loa Angeles T
C t Division L&()JUL . pM
ASSIGNED TO: P-27 OPfi-^
HE DISPATCHED
4 26
/.26t
SOURCE: 4L.WE& RENDERING Co. v
ADDRESS: 7/7 No. ALW66 ST. VeUNOH
COMPLAINANT: HEHR
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Handling the Citizen Complaint
gates, writes and serves a notice, if warranted. Then he
visits the complainant. However, if no violation is
immediately apparent, the inspector contacts the com-
plainant first. This is most often the procedure fol-
lowed.
The inspector makes every effort possible to avoid
obvious identification of the complainant. He is par-
ticularly careful not to park his official vehicle too close
to the complainant's residence should the complainant
and the source be near each other. The inspector con-
siders the identities of all complainants to be confiden-
tial and never, under any circumstances, discloses
them to anyone who is not an employee of the District.
The inspector then attempts to contact the com-
plainant. If he is not at home, he leaves his calling
card, and tries to contact him again at some other
time. If he is at home, the inspector identifies himself
by name and agency in a friendly manner.
D. Listening to the Complainant
The ability to listen carefully is one of the skills
the inspector develops to gather facts.
The inspector is friendly, but dispassionate. He
generally employs a "non-directive" interview tech-
nique in that he allows the complainant to get the mat-
ter off his chest so that the facts of the situation can be
calmly discussed. The inspector also appreciates the
fact that a person who is angry may honestly be mo-
tivated by a serious or chronic air pollution condition.
The complainant may, in fact, be living in a daily
nightmare if he is particularly sensitive to or fearful
of exposure to air contaminants. A local pollution
problem may be as aggravating to persons affected as
the smog problem is to the general community.
In permitting the complainant to speak his mind,
it is well for the inspector not to interrupt. It is par-
ticularly effective, however, that when facts appear,
that the inspector repeat them aloud for verification,
and then jot them down.
E. Conducting the Inquiry
After the complainant has expressed himself, the
inspector then proceeds on a line of questioning which
will 1) determine the cause of the complaint, and 2)
the nature and source of the air pollution problem
cited in the complaint. The line of questioning in this
case is intended to complete and verify the data sup-
plied by the complainant.
The cause of the complaint, it should be noted,
may not always involve air pollution. Although most
complaints are justified, some will concern problems
over which the control agency has little or no control
and in which air pollution may play a minor role.
These concern backyard feuds, natural contaminants,
resentment towards a nearby company,! or small con-
centrations of contaminants which may affect illness
or allergy in an individual. Although the inspector
may have no legal powers in such cases, he thoroughly
investigates and attempts to correct all air pollution
problems. If such complaints are unsubstantiated, the
inspector establishes the cause of the complaint, and
documents the fact that no violation has occurred by
recording the operational data of the equipment at the
alleged source.
In verifying the validity of the complaint, the in-
spector attempts to recognize contradictory, exaggerat-
ed and biased statements. He may politely challenge
terms used by the complainant to denote fequency or
inclusiveness such as "generally", "sometimes", "nev-
er", "all of the time", "rarely", in order to distinguish
first-hand knowledge or experience from speculation
and inference. Precise indications of frequency may
be crucial in tracking a nuisance to a specific piece of
equipment.
In order to obtain the necessary data, the inspect-
or inquires to obtain the following:
1. Name and location of source complained of.
2. Frequency of annoyance or occurence of plume.
3. Time of day nuisance was first noticed.
4. Duration of nuisance at each occurrence.
5. Names and addresses of persons affected.
6. Location and extent of property damage, if any.
7. Description and frequency of any illness alleged
to have resulted from the air contaminants.
8. Description of odors, if any involved.
9. Any other information the complainant may have
that will relate the nuisance to a specific piece of
equipment.
In an air pollution problem which appears to
have an immediate effect on health, the inspector re-
cords all observed or reported symptoms such as:
nausea eye tearing
vomiting soreness of throat
headache nasal discharge
eye-irritation turning blue
fever cough
constriction of chest difficulty of breathing, etc.
If the symptoms are serious, a doctor and the
health authorities should be contacted. The control
agency should also be immediately notified in order
that an emergency vehicle may be dispatched to the
scene to measure the concentrations of any possible
toxic contaminant. (See Chapter 11.)
It should be noted that only a doctor can make a
diagnosis. The inspector records reported symptoms
under the complainant's remarks on the Inspector's
Report. The inspector can note under "findings" the
name of the doctor conducting the diagnosis and treat-
ment. This information is important if public nui-
sance action should be initiated.
In his questioning, the inspector attempts to anti-
cipate the laws that may be violated. Although, the
inspector cannot come to any definite conclusion at
this point, since he must inspect the source of air pol-
lution first, he is always visualizing the problem in his
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138
Air Pollution Control Field Operations
mind so that he can consider all possible facets and
solutions. This may be temporarily necessary in order
that the complainant may be given some realistic esti-
mate of the situation.
While interviewing complainants, the inspector
does not promise legal action nor does he commit him-
self or the control agency to any course of action. He
should, however, explain to the complainant the laws
involved and the evidence required to instigate legal
proceedings. But he will also explain that he will
first attempt to seek such cooperation on the part of
those responsible.
F. Physical Inspection of Complainant's Property
Next, during the course of the interview, the in-
spector examines the complainant's property for any
deposits or effects of air contaminants such as paint or
acid stains, dusts, odors, fly ash, etc. The pattern of
fall-out of contaminants may indicate the direction
from which they came. If a malodor is detected at the
complainant's property, the wind direction can be de-
termined for the purposes of tracing the odor to its
source.
G. Canvassing
As a rule, air pollution inspectors do not solicit
opinion in a neighborhood regarding the behavior of
any plant, but confine themselves to those persons
volunteering complaints. It is usually citizens who do
the canvassing and who forward the information to
the air pollution inspector. The inspector may then
interview all complainants involved. The canvassing
of complainants by the inspector is usually discour-
aged because the inspector is not sampling, and does
not act on, opinion, but on properly motivated com-
plaints. The canvassing by the inspector of the neigh-
borhood can be construed in a court of law as being
prejudicial to the plant.
In some complaint situations, however, where the
inspector cannot assess the validity of the complaints
from his own direct observation and judgment he may
wish to canvass the community. In such cases the in-
spector is interested in determining the degree to
which an air pollution problem exists. That is, if
there is a problem which is:
existent, but not objectionable
tolerable
offensive
utterly intolerable
In canvassing, the inspector, on the basis of his
knowledge of air pollution, evaluates the consistency,
correspondence, and intensity of remarks made by all
of the witnesses. He attempts to find some degree of
unanimity regarding the objectionability of the prob-
lem among those who might be equally affected. Di-
verse opinions and inconsistencies are first signs that
a public nuisance may not be easily developed.
As with the initial complainant, the inspector's
prime purpose is to obtain facts. He never urges,
forces, or persuades persons to agree to become wit-
nesses. Nor does he ask questions in such a way as to
indicate that support for a legal action is being solicit-
ed. The inspector wants to know, first, the degree to
which the witness is affected. He attempts to deter-
mine if the person is so affected by the air contamin-
ants that he desires to appear in court as a witness.
Some witnesses may be adversely affected, but are not
willing to testify in court. The unwillingness does not
mean that the problem does not require correction,
however.
H. Inspection of the Source
From the facts gathered so far, the inspector may
already have a notion of what it is he should inspect,
especially if he has identified contaminants and has ob-
served definite evidence of damage, or detected odors
on the complainant's property. In other cases, he may
know the identity of the contaminants, but not the
source of origin, and will have to first locate a possible
source to inspect. And in still other cases, the contam-
inant may be completely unknown. The tracking and
identification of contaminants are discussed in Chap-
ter 12.
The inspector's immediate problem in a public
nuisance case is to find enough evidence to prove that
a source of emission in a certain plant is responsible
for the nuisance. In some cases, the equipment in-
volved may be obvious; in others, especially in a plant
containing many pieces of equipment, the source may
be difficult to locate. In the latter instance, the inspect-
or may be required to inspect each piece of equipment
in detail, and to eliminate from consideration those
which do not contribute to the air pollution problem.
Quite often the job is completed if the complaint
or nuisance also involves a violation of the Rules and
Regulations through the emission of contaminants in
excess of that allowed, or through the operation of un-
permitted equipment, or through operation of equip-
ment contrary to permit conditions. In these instances,
the action to be taken is indicated.
If, however, the nuisance is a result of quantities
of air pollution which are allowed by quantitative
standards in the Rules and Regulations, a public nui-
sance will have to be proven.
When the inspector contacts the plant operator,
he explains that he is investigating a complaint, un-
less, in the individual instance it should be strategic
not to do so. The inspector may also explain that he is
trying to determine whether or not the complaint is
justified. This gives management the opportunity to
state its case, since it knows that the inspector is not
yet committed to any action. As with the complainant,
the inspector is also attentive and takes notes. Then,
on the basis of the information he acquires from the
complainants, he asks developmental questions, and
completes the story. He then inspects the equipment
and compares actual operating conditions, cycles and
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Handling the Citizen Complaint
139
times of operation, with the times and frequencies of
complaints.
7. Mediation
Because the inspector is an indifferent observer
between two parties in conflict, he has a natural tend-
ency to act as mediator and will attempt to find that
solution to a problem which will satisfy both the com-
plainant and the operator. For example, if the com-
plaint is made of an operation conducted in the even-
ing when the complainant is at home, the operator
may agree to shift the operation to a daytime sched-
ule. The company may also agree to relocate equip-
ment, put a spark arrestor on an incinerator stack,
raise a stack, and even eliminate a process unessential
to the business activity as a means of becoming a "good
neighbor". It is important, however, that such agree-
ments do not compromise the law. The inspector does
not agree to a maintenance of a violation. But, on the
other hand, when there is no legal solution to a prob-
lem, the plant operator can do whatever he wishes to
improve the situation.
The inspector attempts to promote such solutions.
He can make a direct appeal to management by relat-
ing previous histories of similar nuisances, recalling
the three inducements for control: 1) conservation, 2)
public relations, and 3) employee relations. When
complaints are made as a result of a grievance it is
always wise to attempt to develop the "good faith",
upon which continued neighborhood harmony de-
pends, of all parties concerned. A plant operator im-
proves his standing in the community if he solves his
problem voluntarily. The inspector is always willing
to explain this fact. As a matter of fact, plants with
progressive public relations programs will often moni-
tor their own operations by canvassing the neighbor-
hood, and by adopting an effective air pollution control
policy.
If the company is demonstrating good faith
through purchase of new equipment, or modification
of old equipment under permit approval to correct its
problem by clearly established deadlines, then the in-
spector informs the complainants involved of the prob-
able deadline or correction date and the progress being
made by the company.
/. Public Nuisance
The most difficult type of air pollution case is the
public nuisance. A public nuisance frequently occurs
when a number of persons are annoyed by a quantity
of contaminants which is otherwise allowed. The prob-
lem in cases of alleged public nuisance is to determine
whether a private dispute or a valid public dispute is
involved. If a private dispute is involved, then the
citizen must initiate his own legal action. A public
nuisance, however, involving a "considerable number
of persons" or a reasonable cross-section of the imme-
diate community affected is handled as an enforcement
action by the District. (See Chapter 12.)
Once the inspector determines that a public nui-
sance is involved, he must assume an attitude of ob-
jective indifference since the rights of the company to
maintain the alleged nuisance, and the rights of the
citizens to be rid of it, constitute a conflict of equities
which can only be resolved in court. The burden of
proving the public nuisance ultimately rests on the
testimony of the complainants themselves. The in-
spector is also a witness in that he can, in his opinion,
verify the existence of the nuisance. But if, after thor-
ough review, the control agency does not feel a valid
nuisance is involved, it will not initiate legal action.
The inspector explains the facts to all parties con-
cerned. In some cases, he may motivate the company
to remedy the problem since many firms attempt to
maintain good public relations in the community. The
inspector will also explain all of the facts, rights and
laws involved, as he has determined them, to the citi-
zens and what actions can and cannot be taken.
He then distributes special District Attorney
forms to be completed and signed by the complainants
in their own handwriting. These documents, together
with the inspector's findings of the problem, are filed
as a Section 24243 violation in the courts to test whe-
ther or not a public nuisance exists. (See Chapter 13.)
It is necessary, also, that in interviewing com-
plainants that the inspector be candid and discreet.
There may be situations in which the District cannot
act to solve a public nuisance due to a lack of the "con-
siderable number of persons" required, contradictory
testimonies or the unwillingness of complainants to
testify in court. The inspector should clearly explain
to the complainants once he determines that a public
nuisance is involved that the only substantial evidence
is the testimony those who are affected by the contam-
inant are prepared to give.
At the same time, the inspector must not aggra-
vate the situation by leaving an angry community in
his wake. The names of complainants must be held
in the strictest confidence, and the inspector should
avoid making derogatory statements about any of the
parties concerned.
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CHAPTER NINE
IDENTIFYING EFFLUENT PLUMES
I THE MACROSCOPIC POINT OF VIEW
There are three basic points of view assumed by
the science of air pollution control in identifying and
evaluating emissions of contaminants. These are the
microscopic, the macroscopic and the megascopic. In
the field of air pollution control these points of view
are assumed by the chemist, the inspector or control
engineer and the meteorologist, respectively.
The microscopic point of view is fundamental to a
scientific understanding of all air pollution phenom-
ena. The scientist here is primarily interested in the
properties and behavior of the smallest units of air
pollution measurable by instruments and techniques of
scientific analyses. He identifies, classifies and mea-
sures concentrations of the individual units. With the
knowledge thus compiled, the researcher not only pro-
vides information adequate to the definition of prob-
lems and descriptions of air pollution phenomena, but
he will be able to measure, analyze and evaluate air
pollution trends.
The macroscopic viewpoint is that which can be
accurately inferred by means of direct, first-hand ob-
servation through utilization of the senses of sight,
smell, hearing, and touch. Such direct first-hand ob-
servers are represented mostly by the field inspector
and the control engineer. They are both interested in
such operational techniques, equipment, designs, and
control devices as may be effectively employed — not
only for collecting and reducing the total emissions of
contaminants but also for controlling contaminants
which cannot be observed with the naked eye. The
macroscopic viewpoint also includes assumptions of
microscopic phenomena made from clues perceived by
the direct senses, together with expert knowledge of
air pollution problems. The application of such under-
standing to a current problem — in this case, air pollu-
tion — is known as apperception.
On the face of it, it would appear that all the in-
spector need do in observing specific air pollution prob-
lems is to be able to demonstrate that what he observes
is an air contaminant, that is, a plume or effluent
which is not water vapor or a natural constituent of
the atmosphere, and that the emission constitutes a vio-
lation of some standard. Many regulations or prohi-
bitions do not require the enforcement officer to identi-
fy specific contaminants.
However, the only certainty that an air con-
taminant is involved is through identification and
measurement. The specific identity of the air contam-
inant is also important to those responsible for source
control. The inspector cannot report or testify on his
observations unless he understands what he sees.
While the specific contaminants in such effluents
as smoke can be assumed, in more complex instances
the contaminants in a plume can only be inferred from
an analysis of fuels, processes, operation and equipment
design. The inferences made from these operational
and maintenance practices comprise the engineering
analytical approach that must be taken by both the
field inspector and the control engineer.
The megascopic view is the expanded, magnified,
or extrapolated view of air pollution depicting the
chemical and physical behavior of the entire air pol-
lution cloud in the pollution zone. It is the statistical
effects of both microscopic and macroscopic phenom-
ena, the total complex of air pollution emissions and
the atmospheric reactions which take place in the air.
The foremost megascopic discipline applied to air pol-
lution in this regard is the science of meteorology.
The field inspector is not directly concerned with
the megascopic view although he must understand it.
The inspector is primarily interested in individual air
pollution problems. He is concerned with the mega-
scopic in a practical way, however, whenever the air
pollution "configuration" described below is so pro-
tracted as to envelope a general community.
The three points of view described above are not
mutually exclusive. The chemist or researcher may
also be interested in the meteorology in determining
concentrations of contaminants which may be reached.
The inspector or engineer, as we have stated, is taking
an analytical approach to specific air pollution prob-
lems, looks for visible clues, evidence or indications,
from which reasonable assumptions of microscopic be-
havior can be drawn. The criterion here, however, is
one of perception. By and large, the inspector con-
ducts field observations directly by means of his direct
senses and his knowledge of air pollution.
In the macroscopic point of view, there are two
essentials to the identification and, subsequently, the
evaluation of field observations made of source emis-
sions. These are (1) the particular "configuration" or
"gestalt" of any specific air pollution situation, all ele-
ments of which are necessary to a complete, coherent
understanding of what is happening. It is, in essence,
the story of any air pollution problem ("who, what,
where, when, how, why"); and (2) the identification
of the effluent formation and, possibly, its composition.
This procedure should be adequate for the identification
of the observed emission and the proof that it is an air
contaminant.
A. The Air Pollution Configuration
The air pollution configuration is represented by
the entire cycle of cause and effect and is composed of
identifiable stages. The configuration described here,
it should be noted, approximates the elements of a
corpus delicti or a crime discussed in Chapter 13.
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142
i
The possible, prob-
able or direct cause
of the air pollution
emission in terms
of equipment, oper-
ation, design, main-
tenance, fuels, or
material fed.
The effects of the contam-
inants in the atmosphere-
clouds, hazes, reduction of
visibility, photochemical
effects, etc.
The air pollution
plume or effluent
as emitted, and
rate or quantity.
Air Pollution Control
3
The possible con-
taminants in the
emission.
The effects of contaminants
on life and property such as
odor, corrosion, toxicity, de-
posits and eye-irritation.
Insofar as stages 3 to 5 may not always be readily
deductible by direct sense perceptions, the inspector
may make assumptions from his knowledge which can
be borne out later by actual source testing or by an
expert in the given field. For example, he is aware of
the principal types of atmospheric contaminants and
their effects as shown below:
Aerosols
Dusts, Fumes, Mist
Sulfur Dioxide j_
1
7fT~
1 -v
Sulfuric Acid
-4
Soiling and
Nuisance Deposits
Vapors
Hydrocarbon Vapors I
Reduced Visibility
Nitrogen Dioxide
Specific Gases
Sulfur Dioxide, Fluorine
and Fluorides, Hydrogen
Sulfide, Mercaptans, Am-
monia, Formaldehyde,
Acrolein, Acids
1 n 1 ^
! Uzonej s
v_y
Rubber Cracking
Corrosion,
Strong Odors
Source: Reference 4.
Figure IX-1. Relationship of contaminants to contaminant
effects.
The inspector in the field, of course, may not
always be able to connect cause with effect. In many
situations he may have to rely on source testing and
on general research activities. However, he should be
prepared to make some approximate description of
each stage or element in the entire air pollution situa-
tion. Particularly must he be able to identify the form
of the effluent emission, i.e., smoke, fumes, dusts, mists.
gases and vapors.
II EFFLUENT FORMATION AND COMPOSITION
An effluent of air contaminants is a colloidal sys-
tem, i.e., a suspension of particles in the air or other
gaseous medium, or a gaseous mixture released as a
plume from a specific source outlet. Contaminant
Field Operations
plumes may be either visible or invisible to the naked
eye. Visible effluents are those which consist of any
one or combination of the following contaminants:
1) A sufficient concentration of a colored contaminant gas,
such as nitrogen dioxide (brown to yellow), bromine
(reddish-brown), iodine (purplish) and chlorine (green-
ish-yellow). With the exception of these gases, however
virtually all contaminant gases significant in air pollu-
tion are colorless.
2) Aerosols seen by light-scattering greater than .4 micron.
In the case of aerosols, the visual threshold is de-
pendent upon the intensity and the direction of the
light source with respect to the observer, and the posi-
tion and concentration of the effluent. The maximum
visibility reduction occurs when the light source is di-
rectly opposite the observer and behind the effluent.
As the observer changes his angle of position, the vis-
ual effect of the light scattering diminishes until, at a
change of 180° of position, the visual effect is nil.
Effluents are invisible when the aerosols cannot
be seen with the naked eye, or they consist of colorless
gases, or the concentrations of visible materials are too
low to be detected by the naked eye.
For purposes of definition here there are three
basic types of emissions which may be observed by the
inspector.
A. . The Plume or Effluent
The plume or effluent (Figure IX-2) is the flow
itself of the contaminant-laden gas stream from a
specific outlet such as a stack or vent. The plume,
particularly when it is distinctly visible, is character-
ized by (1) a point of release and formation just at the
outlet of a stack or opening of a closed system, or a few
feet above the outlet in the case of a "detached" plume,
(2) the body or stream, comprising most of the con-
taminants carried by the momentum of the escaping
gases, and (3) the point at which the plume or effluent
dissipates.
The breakdown of the plume structure is impor-
tant. The point of discharge of the emission, or the
point of maximum opacity, is the point at which the
opacities of visible emissions are read or sampled. The
stream or body of pollution provides some relative
notion of quantity and velocity of the escaping con-
taminants, as well as other characteristics such as color
and particle size which help identify the plume. The
point of dissipation is also important in determining
whether or not the plume is a contaminant, water
vapor or steam, or some combination of both. Depend-
ing on wind velocity, humidity and temperature, water
vapor or steam tends to dissipate more rapidly than
any contaminants contained in the effluent. The
greater the humidity, generally speaking, the longer
will be the steam plume. Where most of the effluent
appears to consist of water vapor, the opacities or dens-
ities of the contaminants are read at the point of dis-
sipation or evaporation of the steam.
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Identifying Effluent Plumes
143
STRUCTURE OF A PLUME
BODY OR
STREAM OF PLUME
ifef POINT OF
L ;£V DISSIPATION
POINT OF
RELEASE
STACK
CLEAR AREA
STACK
DETACHED
PLUME
Figure IX - 2. General structure of continuous and detached plumes, respectively. Emissions are read at points of maximum opacities.
General atmospheric conditions may also be indi-
cated by the behavior of the plume, and may be of
significance in assessing a nuisance potential. A plume
which rises straight up, for example, indicates rapid
vertical mixing of contaminants favorable to the dis-
persion of the contaminants. Horizontal plumes, how-
ever, may cause fumigation of an area down-wind
from the source of emission. The direction and extent
of diffusion may then be indicated by the type of
plume. A plume which disperses both vertically and
laterally is known as a coning plume, in that the shape
of dispersion is in the form of a cone. A coning plume
generally results when wind speeds are in excess of
20 miles per hour. A looping plume occurs in turbu-
lent or gusty atmospheres, and in general, results in
good dispersion and only sporadic fumigation. A fan-
ning plume generally results from a steady, and some-
times, slow wind stream, and tends to maximize the
area of effective fumigation possible at relatively high
contaminant concentrations.
In most cases, a trained observer can distinguish
between smokes and fumes by color, behavior and dis-
sipation point. Since a fume consists of relatively
heavier molten liquid droplets which condense rather
rapidly to a solid or mist, the point of dissipation is
often closer to the stack outlet than in the case of
smoke particles. Also, fume plumes often tend to form
hazes sooner than do smoke plumes.
An experienced observer can also distinguish be-
tween emissions of smoke resulting from rubbish burn-
ing, fuel-oil burning, and even natural gas, when gas-
fired boilers are severely out of adjustment, by color
and escape velocity of the body of the plume.
Of course, these generalizations must be supported
by a thorough inspection of equipment and processes.
and by any source testing which may be required in
delineating the air pollution configuration.
Invisible plumes, i.e., escaping gas streams, can
frequently be inferentially detected by sound of gases
escaping from high pressure systems and light refrac-
tion (shadows cast by evaporating vapors) from low
pressure systems. Some gases, like butane or propane
under high pressure, can be detected by frosting at the
point where the pressure drop occurs at the valve and
still others by physiological responses on the part of
those near the source. Gases may be detected by odor
or by irritation or pressure on mucosa.
B. The Cloud
A cloud of air pollution is an emission of air con-
taminants which has become completely divorced from
its source or sources and is gradually being dissipated
by the processes of dilution, sedimentation and diffu-
sion, but still retains a distinctly visible shape. The
cloud is shaped by the direction of air flow, and by
dilution which occurs at right angles to this flow. The
cloud is the extension, or the fanning effect of the
plume and generally occurs under conditions of rela-
tive atmospheric stability. Clouds are often produced
from large source emissions and from building, brush
and forest fires. Generally speaking, the larger the
quantity of air pollutants, the longer the cloud re-
mains.
Noting the appearance of clouds in reports, especi-
ally as to height, length, breadth and thickness can be
of importance in determining the severity of a general
or local problem.
C. The Haze
The air pollution haze is sometimes similar in
appearance and behavior to a light fog in that it is a
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144
Air Pollution Control Field Operations
widespread condition. Hazes are frequently formed by
condensation of vapors on atmospheric particles, or by
aerosol production in smog formation, and by dusts
and pollen. Smog is itself a chemical haze. A haze
may also be considered as a more attenuated form of
cloud residing at ground level, representing a condi-
tion of atmospheric stagnancy. Notation of the exis-
tence of the haze is important to the inspector par-
ticularly when it is peculiar to a community, rather
than to the entire pollution zone, since a severe local
problem may be present.
Ill TYPES OF EFFLUENT PLUMES
Since the plume is the precursor of the cloud or
haze, or other polluted air stream, it represents the
form of the air contaminant of primary interest to the
inspector. In fact, it is the "discharge" or "emission"
regulated or prohibited in most statutes or rules.
Section 24208 of the California State Health and
Safety Code defines an air contaminant as "smoke,
charred paper, dust, soot, grime, carbon, noxious acids,
fumes, gas, odor, or particulate matter or any combi-
nation thereof" This particular definition, however,
does not classify air contaminants in practical and de-
finable categories, but identifies familiar contaminants.
Since these contaminants are not necessarily mutually
exclusive, they tend either to be synonyms of one an-
other or to represent a common class of pollutants.
Thus, particulate matter may be inclusive of soot and
acids; and carbon, a chemical element, is also included
in the term smoke. The legal definition, though incon-
sistent in terms of a definitive classification system,
however, is practically inclusive of all known air
contaminants, if an air contaminant is considered to be
any substance which is foreign to the natural compo-
sition of the atmosphere. As a matter of fact, gases and
particulate matter in the definition alone can be used
as a basis for classifying all known contaminants.
Since all substances become liquid, solids and
gases at certain temperatures, any effluent or plume
will consist of a variety of contaminants in various
states of matter. Smoke, for instance, may consist
chiefly of aerosols — carbon particles and solid or
liquid particles (acids and aldehydes) of partially
burned fuels — but may also consist of such gases as
sulfur dioxide, oxides of nitrogen, or unburned vapors
generated in the gaseous state.
Here, again, the identity ascribed to the effluent
is generally made in terms of its outstanding visual
characteristic. For example, even though sulfur diox-
ide may be the most significant of the pollutants
emitted from a stack, the effluent in which it is con-
tained is frequently described as smoke due to the
visible soot, carbon particles and fly ash also contained
in the plume.
The mere observation of a plume, however, does
not result in its conclusive identification. The in-
spector will require knowledge of the specific condi-
tions which caused the contaminants. The technical
distinction between smoke and fumes cannot be made
unless the process by which they are generated is
described. With this in mind we may define each of
the six categories of effluents: Smoke, fumes, dust,
mists, gases and vapors.
A. Smoke
Smoke is the visible effluent resulting from incom-
plete combustion and consisting mostly of soot, fly ash
and other solid or liquid particles less than one micron
in diameter. Depending upon the composition of the
fuel or materials being burned and the efficiency of
combustion, various volatilized gases and organics
such as aldehydes, various acids, sulfur oxides, nitro-
gen oxides and ammonia may also be emitted. Due to
the low vapor pressures and slow settling properties of
the particles, the smoke may be carried considerable
distances from the source and many sub-micron par-
ticles will be permanently dispersed in the air medium.
When complete combustion occurs, only carbon
dioxide, water vapor and small amounts of ash are
emitted. Thus the generation of smoke depends on the
efficiency of combustion equipment in relation to the
fuel or material being burned. Whether such com-
bustion devices are incinerators, boilers, afterburners,
etc., their design and operation must accommodate the
entire burning cycle — (ignition, burning and burn-
down) by means of providing for the following:
1. Temperature high enough to ignite and burn
all of the material.
2. Sufficient time to allow complete burning of
all of the fuel or material.
3. Sufficient turbulence to permit thorough mix-
ing of fuel particles with combustion air.
4. Sufficient oxygen for a proper air-fuel ratio.
An excess of air, it should be noted, can cause
smoking due to cooling.
Smoke will vary in color, but will be generally
observed as grey, blue, black, brown and white, and
sometimes yellow, depending upon the conditions un-
der which certain types of fuels or materials are
burned. The color of smoke is generally a fairly good
indication of the type of combustion problem en-
countered.
Smoke which is grey or black in color may indi-
cate that the material is being burned with insufficient
air or inadequate mixing of fuel and air.
White smoke usually results when the fire is
cooled by excessive drafts of air, and may also be
generated when the materials being burned contain
excessive amounts of moisture.
Brown or yellow smoke may result from the burn-
ing of semi-solid tarry substances such as asphalt or
tar paper, resulting from inadequate temperature and
mixing.
-------
Identifying Effluent Plumes
145
BOILER TYPES
Steam Nozzle
£'
— Z- ^ ^_
±rw<_ •' < : — _ ^2
: — , — r=r-=-^ ~ _ :— — =— -=— — p_zr-^=- — ^
ing Door Corrugated
Fire Tube CL
1 1 i | 1
s
;anou
T.
r
i:
r
t
U> — •",; "-I. .-,-,;... '.•,.;.-..• .,--.,.-.-.. .; .,•- _,/,- .-,,-y- t,v, »^
Figure IX - 4. Scotch Marine boiler.
Figure IX - 3. Cast-iron sectional boiler.
I Stack
. ,
Nozzle tor
„ , ,, <>
Nozzle for Steam
Firing
Door I
Smoke
Connector
Water Column
Feedwater
Inlet
Firebox
Grates
Figure IX - 5. Horizontal return-tubular boiler.
Figure IX - 6. Vertical tubular boiler.
WATER-TUBE: Water conveyed by tubes is surrounded and heated by hot gases.
FIRE-TUBE: The tubes, surrounded by water, convey hot gases and serve as heating elements.
HORIZONTAL RETURN-TUBULAR: Commonly used in small power plants. The gases from the furnace, after passing below the boiler along
the outside of the shell to the rear, return through tubes to the stack connection at the front of the shell.
VERTICAL TUBULAR: This type of boiler requires small floor space per boiler horsepower, and furnishes superheated steam. Small boilers
range from 3 to 100 h.p., and large boilers range from 50 to 500 boiler horsepower.
SCOTCH MARINE: Combustion chambers are internally fired, are entirely surrounded by water, and are located at the rear end of the
furnace. This is a variation of the fire-tube type boiler.
CAST IRON SECTIONAL: A radiator type boiler consisting of a series of water jackets which are heated by the furnace.
GAS-FIRED BOILERS: Boilers fired by gas alone, and not employing supplementary solid or liquid fuels, do not normally create air pollu-
tion problems since complete combustion is achieved. During the adjustment period of a new gas-fired boiler, however, there may be
occasional emissions of smoke.
A blue color or light blue color is often associated
with the burning of domestic trash consisting mostly
of paper or wood products. The light blue color seems
to stem from the fine particles of pyroligneous acid
from sulfide treated paper and wood tar in the mate-
rial. The blue plume contains little or no carbon or
soot particles.
We may consider briefly here the principles of
combustion as they apply to (1) the combustion of
liquid fuels in process and heating equipment such as
boilers; and (2) the combustion of rubbish and other
waste materials in incinerators.
1. Fuel-Oil Burning
Because of the tremendous quantities of oil
burned, contaminants such as oxides of sulfur, oxides
of nitrogen, and soot particles can become significant
as emissions from large oil-burning installations even
though a maximum degree of control is practiced. For
this reason, operation and maintenance factors are
-------
146
Air Pollution Control Field Operations
critical in such combustion equipment as boilers. Ob-
servance and understanding of the following five
factors are important in avoiding smoke: (See Table
IX-1).
Air-fuel ratio Ignition temperature
Atomization Time interval
Mixing and turbulence
The oil burner prepares fuel for complete and
rapid combustion. The oil is not burned in a liquid
state but is vaporized or "atomized" into finely divided
liquid droplets of oil by mechanical means or by
inter-mixture with steam or air.
The various types of burners are as follows: (Fig-
ures IX-7 and IX-8).
BURNER TYPES
OIL
STEAM
OIL
STEAM
A.
B.
Figure IX - 7. Simple steam-jet oil burners: (A) inside-mixing burner, (B) outside-mixing burner, (C) Hauck
low pressure inside-mixing type oil atomizing nozzle.
TABLE IX — 1
COMMON CAUSES OF POOR COMBUSTION IN BOILERS
1. Insufficient air or too much oil
(Improper air-fuel ratio).
2. Poor draft.
3. Excess air (causing white smoke).
4. Dirty or carbonized Burner Tip
(caused by improper location in-
sufficient cleaning at regular in
tervals).
5. Carbonized or damaged atomizing
cup (rotary cup).
6. Worn or damaged Orifice Hole
7. Improper burner adjustment (dif-
fuser plate protruding improper
dist) .
8. Oil pressure to burner too high or
low.
9. Oil viscosity too high.
10. Oil viscosity too low.
(too high fuel oil temperature)
11. Burner is being forced (especially
after initial light-off or when
combustion space is relatively
cold).
12. Insufficient atomizing steam.
13. Water in fuel oil.
14. Dirty fuel oil.
15. Fluctuating oil pressure.
16. Incorrect furnace construction
causing flame and oil impinge-
ment.
1 7. Carbon clinker on furnace floor or
walls.
18. Incorrect atomizer tip size.
19. Condensate in atomizing steam.
20. Atomizing steam pressure too
high.
21. Furnace cone angle too wide.
22. Furnace cone angle too narrow
(making it necessary to have at-
omizer in maximum position).
23. Atomizer not immediately re-
moved from burner after being
secured.
SMOKING
FIRE
X
X
X
X
X
X
X
X
X
X
X
X
X
Inter-
mittent
X
X
X
X
X
X
X
CARBON
FORMA-
TION
X
Some-
times
X
X
X
X
X
X
Some-
times
X
X
X
X
X
X
X
X
X
X
FIRE
PUL-
SATES
X
X
Some-
times
X
X
X
X
X
X
X
X
X
X
Atomizing Burners. Used primarily in marine,
locomotive, stationary power and heating installations.
Steam atomization may be effected by outside mixing
in which steam and oil are externally mixed at the
burner tip, producing a flat flame. When used in sta-
tionary boilers, the outside mixing burner is limited in
application to boilers requiring moderate burning rates
with relatively little variation in loading. The inside
mixing burner atomizes the oil internally. Some de-
signs of this burner produce a flat flame and others a
conical flame controlled by air registers. The air for
this latter type of burner is induced both by the fur-
nace suction and the aspiration of the expanding steam
jet in the burner nozzle.
The oil temperature required at the entrance to
the burner to give a suitable viscosity for atomization
is usually between 150 and 200°F. (unless the oil is
of a low viscosity and does not require preheating) and
the steam supplied to the jets ranges from 25 to 80
pounds per square inch gauge.
- ATCMIZING CUP
ANGULAR VANE NOZZLE
• BOILER HINGE PLATE
ROTATING HOLLOW
MAIN SHAFT
STATIONARY FUEL TUBE
WORM GEAR
Source; Reference 8.
Figure IX - 8. Cross-section of a Ray rotary cup oil
burner.
-------
Identifying Effluent Plumes
147
Mechanical Atomizing Burners are either of the
rotary cup or spray nozzle types, for which no atom-
izing fluid is used. The spray nozzle type is usually
used with power plant steam generating units. The oil
in this type of burner is sprayed from a small nozzle
under its own pressure, (30 to 300 pounds per square
inch gauge, 10°F. to 350°F.). The spray passages are
so designed as to give a whirling motion to the spray
as it emits from a small orifice which is concentric to
its axis of rotation. The flame issues as a hollow cone.
In the rotary burner the oil is fed through a hol-
low rotating shaft on the end of which is usually a
hollow cup which throws the oil from its edges in the
form of small particles. Rotary or "centrifugal" burn-
ers are used only in small low pressure installations.
Should the operator neglect or fail to control any
one of the five factors, boiler efficiency and economy
will be lowered, and excessive smoke may result.
When "lighting-off" (firing) a cold boiler, the
operator should take these measures: (8)
1. Open stack damper and air registers (allow
sufficient time for any accumulated gases to
be dissipated).
2. Recirculate fuel oil until proper temperature is
reached at the burners.
3. Insure sufficient oil pressure on the burner
header line.
4. Thoroughly blow out all condensate in the
atomizing steam line (make sure atomizing
steam to burner is dry).
5. Be sure that burner to be used in "lighting-
off" is clean.
6. Use small orifice tips (pressure burner).
7. Only one burner (on boilers fitted with multi-
ple burners) should be used until refractory is
relatively hot.
8. Use most centrally located burner during the
initial period.
9. Allow sufficient time to bring cold boiler up
very gradually to operating temperature and
pressure. (2 to 3 hours for water tube boilers
and 8 to 10 hours for fire-tube boilers. This
time may be less for smaller boilers.)
2. Incineration
Incineration is a practice which disposes of waste
materials through combustion. An incinerator is essen-
tially a heat-resistant enclosure providing for the intro-
duction of combustion air either through the bottom
of a grate supporting the charge (underfire), or
through port openings across the surface of the fuel
bed (overfire). In its simplest form, the incinerator
consists of a combustion chamber, an ash chamber and
a smoke stack. With respect to efficient and smokeless
combustion, incinerators are classified as single and
multiple chambers. Both types of incinerators may
involve auxiliary aids to combustion such as gas or oil
burners, forced draft blowers, continuous feed systems,
movable grates, ports, doors and dampers for control of
secondary air, and spark arresters.
A single-chamber incinerator is a device in which
one chamber serves ignition, combustion and ash re-
moval, partitioned only by a fixed or movable grate.
Since this type of incinerator fails to provide the con-
ditions necessary for complete combustion — it is quite
often nothing more than an enclosed open fire — the
control of smoke, volatilized gases (fumes) and fly ash
in its operation is uncertain. Single-chamber incin-
erators are variously designed for domestic, commer-
cial and industrial waste disposal, and fall into the
following categories:
1. Small residential concrete-slab incinerators.
(Figure IX-9).
2. Intermediate box-type or Dutch-oven types for
commercial and medium sized industrial es-
tablishments (Figure IX-10).
3. Flue-fed incinerators for apartment houses. In
these the smoke flue also serves as a depository
for rubbish (and sometimes garbage) at the
respective floors of the apartment house (Fig-
ure IX-13).
4. Large silo, cyclone-fed incinerators designed
for continuous burning of industrial wastes,
most notably from the wood-working indust-
tries (Figure IX-11).
5. Large municipal oven-type incinerators de-
signed to accommodate large quantities of mis-
cellaneous rubbish (Figure IX-12).
Needless to say, most single-chamber incinerators
are not designed to control smoke, but to dispose of
rubbish. As a consequence, the widespread use of these
incinerators in a large metropolitan area causes signifi-
cant amounts of smoke pollution. The control of in-
cinerators is essentially the finding of a suitable means
for rubbish disposal or more efficient types of combus-
tion equipment. The problem of rubbish burning in
Los Angeles County was controlled through the elim-
ination of open burning dumps in 1950, the elimina-
tion of all types of open fire refuse burning in 1955,
elimination of all industrial waste disposal in single-
chamber incinerators in 1957, and finally, a ban on all
single-chamber incinerators. The rubbish problem
was largely resolved by disposal in cut-and-cover
dumps.
Multiple-chamber incinerators are designed for
the purpose of providing efficient and maximum com-
bustion of the materials being burned, and hence less
emissions of smoke, fly ash and volatilized gases over
a wide (though limited) range of operating conditions.
The multiple-chamber incinerator is constructed in a
series of three chambers interconnected by flame ports:
(1) a charging or "ignition" chamber for the initial
light-off and burning of the material, (2) a "mixing"
chamber providing the turbulence and temperature
necessary to consume incompletely burned or organic
-------
J-IS
Air Pollution Control Field Operations
Figure IX - 9. Backyard concrete-slab, single chamber incmera
tor.
Figure IX 11. Cyclone-fed, silo-type wood-burning incinera-
tors.
II A.H Tl) 4 I'.tl
KOTHM (IVEn 3"IIU
III) 'UIING
11(1 Ulilit AHTS.OF
TINES I1UUFIKC ECI
W EXI'lnSIVES
UK IIII.ST
Figure IX - 12. Municipal incinerator.
Figure IX 10. Commercial box-type inc.
merator.
-------
Identifying Effluent Plumes
149
BASEMENT
FLOOR
CLEANOUT DOOR
UNDERFIRE AIR PORT
COMBUSTION CH,
CLEANOUT
DOOR
Figure IX-13, Uncontrolled flue-fed incinerator.
Figure IX- 14, Flue-fed incinerator controlled by a roof after-
burner, settling chamber and barometric damper.
CHARGING DOOR
IGNITION CHAMBER
MIXING CHAMBER
SECONDARY AIR PORTS
FLAME PORT
STOKING DOOR—,
GRATES
Figure IX - 15. Diagram of a large multi-chamber "in-line" in-
cinerator.
STACK
BAS BUHNER
ASH PIT CLEANOUT DOOR
GRATES
CHARGING DOOR
FLAUEPOItT
GAS BURNER
IOMTION CHAMBER
PRIHART AIR PORT
MIXING CHAMBER
SECONDARY COMBUSTION CHI
SECONDARY CLEANOUT DOOR
Figure IX-16. Diagram of a small multiple-chamber "retort"
incinerator.
-------
1. Clean out grate and ash-pit.
2. Close charging door © and ash-pit door ©•
3. Open overfire air port (L), secondary air port (3) and undergrate
air port @.
4. Ignite mixing chamber burner @ through lighter port ® and
close port (8).
5. Open charging door, charge material to fill chamber one-half to
three-quarters full.
6. Ignite material on grate at top rear of pile and close charging
door ©.
7. Turn on ignition chamber burner (5) only if very moist or wet
material is charged.
8. Before adding more material to the burning pile in the incinerator
a. Wait until burning pile fills less than one-half the chamber.
b. Push burning pile to rear of grates. (Do this gently, without
causing bits of burning rubbish to fly off the pile).
c. Charge new material on front portion of grates. Do not put
new material on top of the burning pile.
9. Operation during burndown. Close all air ports (T) @ (3). Ignite
ignition chamber burner ©, leave it on until only ash is left
on grate. Leave mixing chamber burner (4) on until all smoking of
materia.] on grate is stopped, then shut it off.
@Mixing
Chamber
condary Air
Port(rear wall)
©Lighter
Port
©Ignition
Chamber
Burner
(side wall)
©Charging
Door
lyerf ire
Air Port
©Ash Pit Door
©Undergrate
Air Port
!)Combustion Chamber
Cleanout Door
WHAT TO DO IF:
Mixing chamber burner (4) flame goes up instead of down when it is first lit. White smoke comes out of the stack. (Follow steps until it stops).
1. Shut off burner.
2. Put piece of burning paper into incinerator through combustion chamber
cleanout door @, close door, light mixing chamber burner again.
Smoke comes out around the charging door or ash pit door or both. (This
Ts normally the result of overcharging).(Follow steps until its^ops).
1. Shut off ignition chamber burner ©.
2. Make sure flameport (opening at top rear inside ignition chamber), is
not blocked by charged material.
3. Make sure combustion chamber cleanout door (9) is closed (and if it has
a spinner or damper, be sure it is closed).
4. Do not overcharge incinerator again.
1. Check mixing chamber burner @, be sure it is burning.
2. Close secondary air port (3).
3. Close overfire air port (I).
4. Close undergrate air port @.
5. Open gas valve of mixing chamber burner (4) fully.
Black smoke comes out of the stack. (Follow steps until it stops).
1. Check mixing chamber burner @, be sure it is burning.
1. Open secondary air port (3).
3. Open overfire air port Q.
4. Shut off ignition chamber burner ©.
5. Open charge door © about one-fourth.
Figure IX -17. Multiple-chamber incinerator operating instructions.
-------
Identifying Effluent Plumes
151
materials, and (3) a combustion chamber for organic
gases and the settling of fly ash. The multiple-chamber
incinerator is constructed according to basic design
principles in relation to the type of material and the
rate at which it is being burned for the use intended.
In particular, the relationship of grate loading to com-
bustion rate and arch height to the grate area in the
ignition chamber is considered to be critical (10) (12).
Underfire air, which is normally used to obtain high
fuel-bed temperatures in other types of combustion
equipment, is minimized to prevent volatilization of
inorganic materials. Overfire air, on the other hand, is
used to promote surface combustion and to prevent ash
entrainment. In addition, "secondary air" and addi-
tional flame coverage may be supplied to the mixing
chamber when required.
There are two general types of multiple-chamber
incinerators: the "in-line" type (Figure IX-15), usu-
ally used in the larger installations, and the "retort"
type (Figure IX-16) usually used in the smaller in-
stallations. The portable type incinerator is of the
"retort" type. This multiple-chamber incinerator was
designed primarily to burn rubbish and wastes for
contractors. Orange trees removed for the purpose of
clearing land sites are often burned in these inciner-
ators as well as construction materials such as wood
waste, tar, tar paper, cardboard and other combustibles
at the rate of 700 to 1000 pounds per hour.
Small units are considered to be those with design
capacities in the range of 35 pounds to 1000 pounds
per hour. The portable retort type is generally rated at
about 450 pounds per hour of mixed rubbish.
Since the control of air supply and burner opera-
tion are not critical, multiple-chamber incinerators
have an excellent, though not perfect, capability for
smokeless combustion, and can be designed to operate
in compliance with minimum permissible emission
regulations, in particular Rules 50, 52, 53 and 54.
However, to avoid occasional violations, certain pre-
cautions are necessary, particularly in the charging of
the refuse to the incinerator.
The ignition chamber should be filled to a depth ap-
proximately one-third to three-quarters of the distance
between the grates and the arch prior to lightoff. After
approximately half of the refuse has been burned, the
remaining refuse should be carefully stoked and pushed as
far as possible to the rear of the ignition chamber. New
refuse should be charged over the front section of the grates
which was emptied by the moving of the burning refuse.
To prevent smothering of the fire, no new material should
be charged on top of the burning refuse at the rear of the
chamber. Through use of this charging method, flames will
cover the rear half of the chamber, fill the flame port, and
provide nearly complete flame coverage in the mixing
chamber. The fire will propagate over the surface of the
newly charged material, spreading evenly and minimizing
the possibility of smoke emission. If the refuse pile is not
disturbed unduly, little or no fly ash will be generated (12).
Multiple-chamber incinerators can smoke excess-
ively through careless operation, by exceeding rated
capacities, by burning unauthorized materials, or
through neglect of any of the conditions necessary for
complete combustion outlined previously. When ca-
pacities are exceeded or flame ports are physically
blocked, excessive smoke may occur from the stack or
the charging doors. Some large multiple-chamber in-
cinerators are designed to burn rubber insulated mate-
rials in large quantities and may be equipped with an
additional ignition chamber for paper and wood
wastes. Where two of such chambers are used, it may
be necessary for both to operate close to rated capaci-
ties at the same time in order to eliminate smoke. If
gas burners are involved, their operation may be re-
quired to assist combustion.
3. Other Sources of Smoke
We have briefly described the principles behind
complete or incomplete combustion with respect to two
types of common sources of air pollution. The prin-
ciples enunciated here are sufficiently typical of other
sources of smoke such as trucks, buses, automobiles,
waste gas disposal systems, or wherever the effluent is
a direct result of combustion.
B. Fumes
In air pollution control, fumes are referred to
specifically as "condensed fumes". "These are minute
solid particles generated by the condensation of vapors
from solid matter after volatilization from the molten
state, or may be generated by sublimation, distillation,
calcination, or chemical reaction when those processes
create air-borne particles."* Fume particles are gen-
erally less than one micron in diameter and will be-
have like smoke. Fumes will more commonly consist
of metals and metallic oxides and chlorides. Also con-
tained in the fumes are common solid particulates such
as fly ash, carbon, mechanically-produced dust and
gases such as sulfur dioxide. The fumes principally
emitted, however, are actually dusts condensed from
the more volatile elements in the metals melted such
as zinc, sulfur, lead and others. The inspector, there-
fore, will probably be more concerned with metallur-
gical fumes, and frequently with emissions from gal-
vanizing operations.
The metallurgical fume will consist primarily of
the metallic oxide which is driven from the melting
surface when metal is heated to the molten state.
Metals such as copper and bronze with relatively high
boiling temperatures, as compared to their melting
and pouring temperatures, do not readily volatilize and
do not constitute an air pollution problem. Copper and
tin, for example, have boiling temperatures above
4000°F., but are poured at temperatures of about
2200 °F. Some metals may contain alloys with extreme
differences in volatility. Copper-based alloys such as
* Los Angeles County Air Pollution Control District Rules and
Regulations, Rule 2L.
-------
152
Air Pollution Control Field Operations
TABLE IX-2
RELATIVE VOLATILITIES AND MELTING
TEMPERATURES FOR NON-FERROUS METALS
Figure IX 18. The relatively high volatility of zinc results in
fuming when excessive melting temperatures are reached. (Zinc
distillation furnaces).
yellow brass, manganese bronze, brazing spelter and
various plumbing metals contain from 15 to 40 per
cent zinc, the boiling temperature of which is around
2200°F. Since the metal must be heated to melt the
copper which has the highest pouring temperature, a
portion of the zinc will be brought to its boiling point
and wiTl volatilize. Copper alloys with high zinc con-
tents may lose from 2 to 15 per cent of their zinc
through fuming.
METALS
Zinc Alloys
Lead Alloys
Magnesium
Alloys
Aluminum
Alloys
Copper Alloys
(Manganese
bronze)
APPROXIMATE
MELTING TEMPS.
650°— 700"F
600°— 650°F
800°— 900 °F
1250°— 1280°F
Around 1800°F
1650°— 2000°F
RELATIVE
VOLATILITY
1
2
3
4
5
FLUXES
USED
Ammonium
chloride
Sodium Nitrate
Sal amoniac
Lump sulphur
Dow#l and #2
Flowers of
sulphur
Chlorine gas
Aluminum
chloride
Zinc chloride
Aluminum
fluoride
Silica sand
blown with air
Soda ash
Borax
Figure IX 19. Removal of tanks from fuming galvanizing
kettle
In brass and bronze melting operations (copper alloys),
zinc is the first base-metal to fume because of its low melting
temperatures in relation to copper. Copper alloys containing
more than 5% zinc are likely to fume without proper con-
trols. In particular, the following metals must be carefully
controlled: Yellow Brass, 20% or more zinc; Manganese
Bronze, up to 45% zinc; Brazing Spelter, 40% zinc; Plumb-
ing Metals, 12% zinc. Copper alloys of less than 5% zinc
content, such as Red Brass, are not likely to fume and may
not require controls.
When vented to the atmosphere fumes have the
appearance of smoke. However, all of the sources of
fumes may not be practically vented in a large scale
foundry operation so that fumes in the vicinity of a
plant may appear as a haze or a cloud emitted from
factory monitors and windows.
All foundry operations attempt to control fumes
in some manner by the use of a flux or degasser which
removes impurities from the molten metal. The im-
purities form a slag cover and prevent the volatilized
material from escaping to the atmosphere. Furnaces
may also be vented to baghouses, electrostatic precipi-
tators, or afterburners.
Other processes which will produce fumes include
calcination, sublimation and distillation.
Calcination consists of heating, roasting or smelt-
ing to decompose minerals. Calcination is commer-
cially applied in the manufacture of glass and mineral
catalysts through the heating of materials such as sand
and limestone. It is variously employed to remove
moisture or a volatile constituent by such methods as
heating limestone to form carbon dioxide gas and cal-
cium oxide, or to reduce minerals by oxidation.
Sublimation is the process in which a solid sub-
stance is converted to a gas without a change in com-
position and without first going through the liquid
state. Iodine, carbon dioxide (dry ice) and many
metallic and nonmetallic crystals are examples of sub-
limed materials. Sublimation of these materials may
-------
Identifying Effluent Plumes
be accomplished by lowering the pressure, raising the
temperature, or by changing both temperature and
pressure.
Distillation is a cycle of vaporization and con-
densation in which a liquid is converted to a vapor and
condensed to a liquid. Distillation is generally em-
ployed to purify a liquid or to segregate components
according to relative volatility.
C. Dusts
Dusts are "minute solid particles released in the
air by natural forces or by mechanical processes such
as crushing, grinding, melting, drilling, demolishing,
shoveling, sweeping, sanding, etc."* Dust particles are
larger and less concentrated than those in collodial
systems such as smoke and fumes and will settle fairly
quickly on surfaces.** A dust effluent, however, may
also contain many submicroscopic particles.
Dusts are produced from virtually every human
activity as well as from the natural environment. Some
dusty industries include mineral earth processors such
as ceramic and cement manufacturing, calcining, and
wood-working and feed and flour industries.
Dust particles generally exceed one micron in
diameter and are readily controlled by centrifugal
separators, cloth filters and electrostatic precipitators.
D. Mists
Mists are liquid particulates or droplets, about the
size of raindrops, such as fog, and are formed by con-
densation of a vapor, or atomization of a liquid by
mechanical spraying. Mist droplets contain contami-
nant material in solution or suspension. The impreg-
nation and coating of building materials with asphalt,
or the manufacture or heating of asphalt at batch
plants may produce hazes or fogs containing droplets
of liquid asphalt. Paint spraying operations emit liquid
particulates containing organic solvents, pigments and
other materials. Mists may also be emitted from con-
trol devices such as cyclones and scrubbers,using a
liquid air cleaning medium. Acid particulates, such as
chromic and sulfuric acid produced from chrome plat-
ing operations, may also form mists when exhausted
to the atmosphere.
It is important to distinguish here between a cloud
of liquid aerosols and a mist of liquid droplets especi-
ally in relation to liquid contaminants involving sulfur
compounds. For example, sulfur trioxide (S03J exists
at normal temperatures as a liquid. But when exposed
to stack temperatures encountered in large oil-burning
installations, sulfur trioxide becomes a gas, and, after
contact with sufficient moisture in the air, forms as a
white-to-blue plume several feet above the stack (de-
tached plume). After further contact with moisture in
Figure IX - 20. Hot asphalt saturator in roofing plant. Mists
may be controlled by wet collectors, mist extractors or electro-
static precipitators.
* Los Angeles County Air Pollution Control District, Rules and
Regulations, Rule 2k.
** However, some heavier particles may be so shaped aerody-
namically as to "sail" or travel surprising distances from a
source,such as metallic substances in metallized paints.
the air, the sulfur trioxide is transformed to a weak
sulfuric acid mist. But when the moisture in the mist
evaporates, a sulfuric acid aerosol is formed, and if the
concentration is sufficient, a visible cloud. The acid
mist is more dangerous to health than the aerosol
cloud, since the latter can be inhaled and exhaled with-
out .effect, whereas the former adheres to respiratory
tissue.
E. Gases
A gas is a state of aggregated matter or a fluid of
freely-moving molecules tending to expand infinitely
and to diffuse and mix readily with other gases. As
pollutants, gases include a large variety of inorganic
and organic gases which may have noxious, malodor-
ous, toxic, or corrosive effects, or which may have an
effective smog-producing potential. These include car-
bon monoxide (CO), ozone (03), oxides of nitrogen
(NOV), sulfur dioxide (S02), hydrogen sulfide (H=S),
hydrocarbons and their oxidation products, halogens
(chlorine, bromine, fluorine, iodine) and their deriva-
tives such as hydrogen fluoride (HF), and the various
chlorinated solvents such as those used in industrial
degreasing and dry cleaning. Other important toxi-
cants not significant quantitatively in Los Angeles air
pollution potentials include ammonia (NH:1), arsine
(AsH;,) fluorine (F2), hydrogen chloride (HC1), phos-
gene (COCL ) and hydrogen cyanide (HCN).
Two gases which commonly occur in air pollution
problems as a result of direct emission to the atmos-
phere are described below: (For other gases see Chap-
ter 11, Detecting and Measuring Invisible Emissions.)
I. Sulfur Dioxide
Sulfur dioxide is a common stack gas produced
from the combustion of such fuels as coal, fuel oil and
hydrogen sulfide, the burning off of residue on cat-
alyst in oil refining operations, the burning of tail
gases from the recovery of sulfur from refinery waste
gases, and various other chemical and metallurgical
-------
154
Air Pollution Control Field Operations
processes. In Los Angeles County the primary source
of sulfur dioxide is the burning of fuel oil by refineries
and power plants. Crude oil with sulfur content con-
tains from less than 1% sulfur to 5% in some of the
heavier fuels. Sulfur dioxide is readily absorbed by
vegetation and soil. At 2-3 ppm, S02 has a noticeable
odor and will damage certain species of vegetation at
1/4 ppm. In the presence of sunlight, sulfur dioxide
oxidizes to sulfur trioxide which condenses out in the
presence of moisture to form sulfuric acid mist. Al-
though sulfur dioxide is an invisible gas, it oxidizes to
sulfur trioxide and emits the detached plume de-
scribed previously under "mists" This type of plume
is commonly observed emitting from the stacks of large
oil burning power generating stations. On humid or
rainy days the plume will "seed" the atmosphere with
sulfuric acid mist and will be abnormally prolonged.
Sulfur dioxide gases and sulfuric acid mists are capable
of accelerating the corrosion of wires, metals and other
materials.
2. Hydrogen Sulfide and Organic Sulfides
(Mercaptans)
Both thermal and catalytic cracking processes in
oil refining operations tend to convert the sulfur con-
tained in the crude oil into hydrogen sulfide in the
heavier materials and mercaptans in the gasoline frac-
tions. When hydrogen sulfide is released to the atmos-
phere as a gas, it manifests a characteristic rotten egg
odor. Mercaptans also exhibit varying types of strong
unpleasant odors such as garlic, decayed garbage,
skunk or onions from relatively small gas concentra-
tions. Hydrogen sulfide is detectable at .12 ppm and
mercaptans from .001 to .041 ppm. H2S will also dis-
color some painted surfaces with lead pigments under
humid conditions.
F. Vapors
A vapor is the gaseous phase of a substance which
at normal temperature and pressure is a liquid or solid.
The most important vapor in the Los Angeles
County air pollution problem is that which results
from the evaporation of petroleum products, such as
the unburned gasoline vapors in automobile exhaust.
Gasoline vapors also originate from processes in which
volatile products are maintained in storage tanks and
from the operation of pumps, compressors and blowers
required for moving liquid gas streams.
Another principal source of vapors in Los Angeles
County originates from the consumption, marketing
and manufacture of paints and other coating products
containing organic solvents which are used to dilute
or extend surface coatings. These are released to the
atmosphere upon application.
REFERENCES
1. Allen, G. L., Viets, F. H., McCabe, L. C, Control of Metal-
lurgical and Mineral Dusts and Fumes in Los Angeles County,
U.S. Department of the Interior, Bureau of Mines Information
Circular #762, April 1952.
3. Green, H. L., Lane, W. R., Paniculate Clouds: Dusts, Smokes
and Mists, D. Van Nostrand Co., Inc., 1957.
4. Larson, G. P., Smokes and fumes, Encyclopedia of Chemical
Technology, Vol. 12, The Interscience Encyclopedia, Inc., 1954.
5. Magill, P. L., Holden, F. R., Ackley, C., Air Pollution Hand-
book, McGraw-Hill Book Company, Inc., 1956.
6. Manufacturing Chemist's Association, Inc., Air foliation Abate-
ment Manual, Chapter 2, Terminology and Selected Data.
7. Los Angeles County Air Pollution Control District, Rules and
Regulations, Rule 2, Definitions.
8. Parmelee, W. H. and Elliott, J. H., Operation of Oil Burners
on Steam Boilers, APCD, #18.
9. Los Angeles County Air Pollution Control District, Evaluation
and Planning Staff, Report on Incineration of Combustible Rub-
bish, August, 1956.
10. Rose, A. H., and Crabaugh, H. R., Incinerator Design Stand-
ards: Research Findings, Los Angeles County Air Pollution
Control District, March 1955.
11. Williamson, J. E. and Twiss, H. M., Multiple Chamber Incin-
erator Design Standards for Los Angeles County, Los Angeles
County Air Pollution Control District, August 1957.
12. Los Angeles County Air Pollution Control District, Technical
Progress Report, Vol. I: Control of Stationary Sources, April
I960.
-------
CHAPTER TEN
READING VISIBLE EMISSIONS
Once a plume or effluent is identified as an air
contaminant, it must be measured by some standard
to determine whether or not a violation of the la\v has
occurred, or it must be evaluated to determine the si/.e
or severity of a given air pollution problem. Here the
inspector may bo required to make evaluations based
primarily on direct observation.
First-hand observation, despite its inherent sub-
jectivity, is not so inexact a means of evaluation if it is
recalled that air pollution is primarily a nuisance
affecting the sense perceptions. Most laws in the his-
tory of air pollution control are based on standards
which expivss annoyance to the senses by the use of
such qualifying terms as "noxious", "excessive", "re-
pugnant", "innirious" Relative air pollution intensi-
ties thus may be rated according to the sense of sight.
smell, and. in some cases, touch.
While the sense of smell is extremely unreliable
— and of no value at all with odorless contaminants —
and the sense of touch, or, rather, physiological re-
sponse, is only valid in detecting certain types of toxic
substances, sight can be employed with a practical
degree of accuracy to distinguish between shades or
opacities of visible emissions. For this reason, maxi-
mum permissible emission standards based on the
visual determination of the effluent are widely used
aroxuid the world.
Compliance with maximum permissible emission
standards is determined by visual evaluation of visible
emissions, and source testing of emissions which are
invisible or near the threshold of vision. This chapter
is concerned with the evaluation of visual emissions by
the use of the Ringehnann Standard, and. specifically.
Section :2-fc24:2 of the California State Health and Safety
Code.
I TECHNIQUES OF VISUAL DETERMINATION
The only practical maximum permissible emis-
sion standard which developed for large-scale use in
the history of air pollution was one which related to
shade or opacity, that is. the darkness or optical density
of the plume. Standards which limited emissions ac-
cording to grain or dust loading alone were obviously
impractical due to the difficulty of conducting source
tests at all of the sources of air pollution.
The benefits of basing smoke statutes on opacity
or density are quite evident, even though equipment
and fuel regulations have increasingly assumed prece-
dence in control legislation. Since the visual standard
is specific with reference to a cut-off point and time
interval, it is simply and directly enforced. All an
inspector need do is observe an emission of an opacity
or density beyond that allowed for a specific period of
time in order to cite a violator for excessive smoke.
Also, although the visual standard is limited to esti-
mations of particles of pollution which obscure vision,
its application simultaneously tends to reduce grain
loading and gaseous contaminants. (As the grain load-
ing in the plume increases, the light transmission de-
creases exponentially.) In order to comply with the
opacity standard, more efficient combustion or equip-
ment operation is necessary. The Ringehnann stand-
ard, therefore, is most versatile in accomplishing gross
reductions of atmospheric pollutants in a community,
and can be applied not only to smoke, but fumes, dusts
and mists arising from a variety of problems as well.
It is perhaps one of the most comprehensive types of
rules adopted.
It should be cautioned, however, that while such
benefits can be assumed, they cannot always be pre-
cisely predicted or evaluated. No useful correlation
exists between the shade or opacity of an effluent with
any quantitative measurement of a plume. Some corre-
lation can be made in the study of a specific operation,
particularly when grain loadings, operating conditions,
and opacities were previously correlated with great
care. Determination of opacity and shade of any emis-
sion alone, however, gives no specific measurement of
the quantities of contaminants being emitted.
A. Description and Use of the RiHgelmana Chart
The history, description and general use of the
Ringehnann Chart is discussed in the Bureau of Mines
Information Circular "7718 (August, 1955). Since
this document has formed the basis of smoke regula-
tion in many cities, and is used as evidence in many
court actions, it is quoted in full here.
Summary
The Ringehnann Smoke Chart fulfills an im-
portant need in smoke abatement work and cer-
tain problems in the combustion of fuel. A know-
ledge of its history and method of preparation is,
therefore, of interest to many. Since instructions
on its use are not shown on the recent edition of
the chart, those included in this revision of the
previous information circular, by Rudolf Kudlich,
now are a necessary complement to the chart.
More detail regarding the use of the chart is in-
cluded than was given in the earlier manuscript.
Introduction
The Ringehnann Smoke Chart, giving shades
of gray by which the density of columns of smoke
rising from stacks may be compared, was devel-
oped by a Professor Ringehnann of Paris. Maxi-
milian Ringelmann, Kirn in 1861, was professor
of agricultural engineering at Vlnstitute National
Agronomiqne and Director de la Station. d'Essais
de Machines in Paris in 1888. and held those posi-
tions for many years thereafter.
The chart apparently was introduced into
the I'nited States by William Kent in an article
published in "Engineering News" of November
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156
Air Pollution Control Field Operations
11, 1897, with a comment that he had learned of
it in a private communication from a Bryan Don-
kin of London. It was said to have come into
somewhat extensive use in Europe by that time.
Kent proposed in 1899 that it be accepted as the
standard measure of smoke density in the stand-
ard code for power plant testing that was being
formulated by the American Society of Mechani-
cal Engineers.
The Ringelmann Chart was used by the en-
gineers of the Technologic Branch of the Federal
Geological Survey (which later formed the nu-
cleus of the present Bureau of Mines) in their
studies of smokeless combustion beginning at St.
Louis in 1904, and by 1910 had been recognized
officially in the smoke ordinance for Boston passed
by the Massachusetts Legislature.
The chart is now used as a device for deter-
mining whether emissions of smoke are within
limits or standards of permissibility (statutes and
ordinances) established and expressed with refer-
ence to the chart. It is widely used by law-
enforcement or compliance officers in jurisdictions
that have adopted standards based upon the chart.
In 1908 copies of the chart were prepared by
the Technologic Branch of the Federal Geological
Survey for use by its fuel engineers and for public
distributions. Upon its organization in 1910, the
Bureau of Mines assumed this service together
with the other fuel-testing activities of the Tech-
nologic Branch.
Additional copies of the chart may be ob-
tained free by applying to the Publications Dis-
tribution Section, Bureau of Mines, 4800 Forbes
Street, Pittsburgh 13, Pa.
Description and Method of Preparing the Chart
The Ringelmann system is virtually a
scheme whereby graduated shades of gray, vary-
ing by five equal steps between white and black,
may be accurately reproduced by means of a rec-
tangular grill of black lines of definite width and
spacing on a white background. The rule given
by Professor Ringelmann by which the charts
may be reproduced is as follows:
Card 0 — All white.
Card 1 —Black lines 1 mm. thick, 10 mm.
apart, leaving white spaces 9 mm.
square.
Card 2— Lines 2.3 mm. thick, spaces 7.7
mm. square.
Card 3 — Lines 3.7 mm. thick, spaces 6.3
mm. square.
Card 4 — Lines 5.5 mm. thick, spaces 4.5
mm. square.
Card 5 — All black.
The chart, as distributed by the Bureau of
Mines, provides the shades of Cards 1, 2, 3, and 4
on a single sheet, which are known as Ringelmann
No. 1, 2, 3, and 4, respectively.
Use of Chart
To learn to use the chart, it is supported on a
level with the eye, at such a distance from the ob-
server that the lines on the chart merge into
shades of gray, and as nearly as possible in line
with the stack. The observer glances from the
smoke, as it issues from the stack, to the chart and
notes the number of the chart most nearly corres-
ponding with the shade of the smoke, then records
this number with the time of observation. A clear
stack is recorded as No. 0, and 100 per cent black
smoke as No. 5.
To determine average smoke emission over a
relatively long period of time, such as an hour,
observations are usually repeated at one-fourth or
one-half minute intervals. The readings are then
reduced to the total equivalent of No. 1 smoke as
a standard. No. 1 smoke being considered as 20
per cent dense, the percentage "density" of the
smoke for the entire period of observation is ob-
tained by the formula:
Equivalent units of No. 1 smoke X 0.20 percentage
= smoke
Number of observations density
Figure X-l shows a convenient form for recording
and computing the percentage of smoke density.
This procedure is often used on acceptance tests
of fuel-burning equipment.
The timing and extent of observations made
for the purpose of determining compliance with
a local smoke abatement ordinance depend upon
the wording and smoke limitations of the ordi-
nance.
There are two general methods of using the
chart. One is for the observer to make actual ref-
erence to it, as previously described, while judging
the smoke shade. The other method is based on
the fact that, with proper experience, it is unnec-
essary for an observer to continue to refer to the
chart. By repeated reference to the chart, during
a suitable training period, the shades of the Ring-
elmann scale become fixed in the observer's mem-
ory. Hence, the chart is used by most cities only
for training and examination of smoke inspectors,
before certification that they are proficient in
judging smoke shade on the Ringelmann scale
without referring to the chart. Since smoke-shade
observations by inspectors, thus trained and certi-
fied, are easily made and are accepted as evidence
in courts, this latter method of using the chart is
preferred by most authorities.
B. Smoke Measuring Methods
Although virtually all of the control agencies have
employed the Ringelmann Chart as a means of defin-
ing smoke standards, the methods by which smoke
densities and opacities are determined by enforcement
officers in the field vary. Some agencies use special
measuring devices, whereas other agencies train their
personnel to sight-read the effluent emissions within a
prescribed degree of accuracy without making direct
reference to the Ringelmann Chart. Some of the de-
vices used are described as follows:
1. Smoke Tintometer: This instrument,
developed prior to 1912, used tinted glasses
graduated to the Ringelmann scale for visual
comparison with the smoke. It contains two
apertures, one for observing the smoke and one
for viewing the clear sky through the opening
or through one of the tinted glasses. This in-
strument is probably not significantly more
effective than a trained sight-reader.
-------
Reading Visible Emissions
157
Locati
Hour .2;Q
9
0
1
2
3
k
5
6
7
8
9
10
11
12
13
l4
1?
16
X7
18
19
20
21
22
23
24
25
26
27
28
29
0
-
-
-
1
1
2
2
3
2
1
-
-
-
-
-
-
-
-
-
2
2
2
3
3
k
5
5
3
2
1
1/4
-
-
-
1
1
2
3
3
2
1
-
-
-
-
-
-
-
-
-
2
2
2
3
k
5
5
J+
3
2
1
1/2
-
-
-
1
1
2
3
3
1
-
-
-
-
-
-
-
-
-
-
2
2
2
3
4
5
5
3
3
1
1
3/4
-
_
-
i
i
2
3
3
1
-
-
_
-
-
-
-
-
.
-
2
2
2
3
if
5
5
3
3
I
1
Observer
Chec
30
31
32
33
34
35
3°
37
38
39
4o
4l
42
43
44
45
46
4?
48
49
50
51
52
53
54
55
56
?7
58
59
3TlQ;QQ.4iUi.. D
0
i
i
_
-
-
i
i
i
i
_
-
_
_
_
i
2
3
3
2
2
2
1
1
-
-
-
-
-
-
-
i/4
i
i
_
-
-
i
i
i
i
_
-
_
_
_
i
2
3
3
2
2
1
1
I
-
-
-
-
-
-
-
1/2
1
1
_
-
-
1
1
1
-
-
-
_
_
-
2
3
3
4
2
2
1
1
1
-
-
-
-
-
-
-
3A
1
1
-
-
-
1
1
1
_
-
-
-
-
-
2
3
3
3
2
2
1
1
-
-
-
-
-
-
-
-
ked
by
Point of observation
Equiv. No. 1 Units
..7. Units No. 5 35
..T. Units No. 4 ....?§
.?!. Units No. 3 Q
.3^. Units No. 2 §§
.5?. Units No. 1 ....5?
113. Units No. 0 Q
?40. units ...264
264 ,w _
240 X ^
?<$ Smoke density
Int. - Bu. of Mines, Pgh., Pa. 6866
Figure X - 1. Ringelmann Chart reading scheme suggested by the Bureau of Mines.
-------
158
Air Pollution Control Field Operations
i E
i!
55 I
Bj
-t
bo
a
•rH
H3
i
I!
I
X
I
-------
Reading Visible Emissions
159
2. Umbrascope: This is a tube using tinted glass
segments which can be adjusted to cover one-
half of the field of view. The smoke can then
be compared visually with the darkness of the
glass. Its main disadvantage is its small range.
3. Smokescope: This instrument uses a film disc
of two shades graduated to #2 and #3 on the
Ringelmann Scale. One aperture is used for
viewing the smoke and one for viewing the
film reference disc against the background. Its
disadvantage is that the quantity of light fall-
ing on the reference disc may be influenced by
objects nearly in line with the smoke. Judg-
ment and skill are required in its use.
4. Photoelectric Cells: Photoelectric smoke me-
tering equipment measures variations in the
intensity of a beam of light passing through
the effluent in the stack, thus directly measur-
ing opacity or optical density. Because the
equipment is permanently built into the stacks
at the sources of air pollution, these devices
are not portable for transporting by field in-
spectors to the stacks. However, they may be
required either by permit condition or law to
be constructed, and are of particular impor-
tance in training air pollution inspectors to
sight-read effluents.
In these devices, a constant light source is
used to illuminate a standard photoelectric
cell, both of which are diametrically opposed
across the stack. The light source must pass
through any smoke which will rise in the
stack before falling on the cell. Thus the cell
will produce a current of electricity which is
directly proportional to the amount of light
falling upon the cell, i.e., the lumens of light
falling upon the cell are directly related to the
microamperes of current transmitted by the
cell to the smoke measuring meter.
The metering devices vary in construction —
some use a potentiometer, a closed circuit re-
lay, or a direct reading microammeter. Re-
gardless of the type of smoke meter used, or
the method of calibration, the amount of cur-
rent generated by the cell will be either di-
rectly or inversely proportional to the amount
of light falling on the cell, and will exhibit a
straight curve function which may be con-
sidered to be linear.
5. Smoke Comparison Charts: Several smoke
comparison charts were reported in the
A.S.M.E. (1936) Power Code. One of these
was a circular chart with radial lines of vari-
ous widths. The operator spins the chart on
an object inverted through a hole in the center
of the chart. The apparent shades of gray on
the spinning chart are then compared with the
smoke. Shades of gray have also been pro-
duced on photographic film for smoke com-
parison charts. Another device consists of
black lines photographed on celluloid film
which is seen partly by transmitted light and
partly by reflected light.
6. Sight Reading: In Los Angeles County, the
direct sight reading method of determining
violations of visible emissions without the use
of the Ringelmann Chart at the scene of the
violation was required for several reasons.
First, Section 24242 limits emissions of air
contaminants according to opacity, as well as
Ringelmann Smoke Density. It was found
that the general principles of visual determi-
nations apply to both opacity of colored
plumes as well as smoke density. Smoke read-
ing devices are limited to gray smoke. Sec-
ondly, it was found that devices were cumber-
some and were generally not significantly
more accurate in establishing opacity viola-
tions. Inspectors can be trained to read within
'/2 Ringelmann or 10% opacity. Thirdly, the
methods by which the inspector is trained and
the methods by which he reads visible emis-
sions have been validated by the courts.
The accuracy and validity of the sight
reading method, without immediate reference
to the Ringelmann Chart, are determined by
intensive initial training, periodic refresher
courses and proficiency testing. The initial
and continuous refresher training an inspector
receives is of prime importance in establishing
his expertness.
The training conducted consists of two
important phases: (1) Training in the prin-
ciples of smoke and opacity readings, and (2)
proficiency training in the reading of smoke.
C. Principles of Smoke and Opacity Reading*
The Bureau of Mines pamphlet, quoted previ-
ously, describes the various cards of the chart. The
terms "density" and "opacity", however, as used in
the literature are only inferentially defined. The
semantics of these has been the subject of much
controversy and have been confused by defense at-
torneys attempting to invalidate the entire smoke
reading procedure.
The definitions of these terms are, however, rather
simple, as they are limited by the law and the nature
of the Ringelmann Chart.
\. "Smoke Density": "Density" means the "quan-
tity of anything per unit of volume or area", as
defined by Webster's Dictionary. An examination
of the Ringelmann Chart discloses the obvious
fact that the shades of gray smoke are reproduced
* Based in part on reference 3.
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160
Air Pollution Control Field Operations
according to the ratio of the area occupied by the
black grid lines to the total area of each card, and
are expressed as the per cent of each card black-
ened. Since the black grid lines represent opaque
areas, and the white spaces the area through
which light is transmitted, it is implicit in the
design of the Ringelmann Chart that "smoke
density" can only be defined as a measure of de-
gree of opacity. This definition does not imply
any relationship with the definition which might
be made in terms of "weight per unit volume".
To determine the per cent densities of each
Ringelmann Card we need simply subtract the
square of the distance across a white space from
the distance between the black lines as measured
from the center of each line. Since the first card
of the chart contains black lines 1 mm. thick, 10
mm. apart, leaving white spaces 9 mm. square,
the per cent of the area which is black is calcu-
lated as follows:
(102) — (92) =
100 — 81 = 19.0% of total area covered by
the black (opaque) grid lines
By similar calculation, Cards 2, 3, and 4 are
found to be 40.71%, 60.31% and 79.75% black.
Since the accuracy demanded of the chart for all
purposes in which it is to be used will not be 1 %
or less, these panels may be considered as perfect
20% increments. That is, the density of Card 0
is 0 per cent; Card 1, 20 per cent gray; Card 2,
40 per cent gray; Card 3, 60 per cent gray; Card
4, 80 per cent gray; Card 5, 100 per cent black.
Thus the Ringelmann Smoke Densities on the
chart may, by the optical phenomenon of the
blending of black lines to form varying shades of
gray when the chart is placed at a distance from
the observer, be measured by equivalent percent-
ages of opacity. This is true because the black
grid lines are seen only as the obscured area, and
the white spaces are seen as the background or the
area through which the light is transmitted.
Smoke density is therefore nothing more than de-
gree of opacity.
2. "Opacity": The term "opacity" means the degree
to which transmitted light is obscured. The de-
gree of opacity is usually rated directly in per-
centage of perfect opacity, 0 per cent opacity be-
ing equivalent to perfect transparency, and 100%
opacity being perfectly opaque. In air pollution
work opacity is actually judged by the degree to
which an observer's view is obscured. That is, the
expert reader makes his judgment of opacity on
the basis of the amount of background, sky or
light that he cannot actually see through the
emission. This manner of observing and record-
ing the opacities of visible emissions is clearly
implicit in the law. For instance, Section 24242
of the State Health and Safety Code prohibits
smoke of periods totaling more than three minutes
in any one hour . . .
(a) . .as dark or darker in shade as that des-
ignated as No. 2 on the Ringelmann
Chart . . .
(b) Of such opacity as to obscure an observer's
view (emphasis supplied—ed.) to a degree
equal to or greater than does smoke ... (de-
scribed in "a", above)
It is obvious that the Ringelmann Chart and
the Opacity method are measured in direct equiv-
alents in that they both measure the same thing.
The determination of density is actually the de-
termination of opacity. The difference is that the
Ringelmann Chart is a recognized standard ap-
plied only to shades of gray smoke. The opacity
system is applied only to the shades of all other
colored emissions.
3. Other Principles: In reading smoke it is not nec-
essary for a trained observer to actually use the
Ringelmann Chart in his smoke measurement.
The thought process is the same without the chart
for all color emissions. The U. S. Bureau of Mines
pamphlet states that "observers with proper ex-
perience find it unnecessary to continue to refer
to the chart". The Superior Court of Los Angeles
County, in a recent appeal, ruled that "in proving
a violation, a witness may testify although he did
not have a Ringelmann Chart actually in the field
with him at the time he made his observations.
One does not have to have a color chart in his
hands to recognize a red flower, a blue sky, or a
black bird".* Thus, through training and repeated
examination, enforcement personnel are made
proficient in applying standard Ringelmann ref-
erence readings to field determination of both the
shade and density or opacity of any visible emis-
sion, without regard to its basic color — whether
black, white, yellow, or any other color.
The A.S.M.E. Power Test Code(i) states that
smoke may be read with Ringelmann Charts from
several blocks away with a clear atmosphere and
clear sky. Thus the distance from the smoke is
limited primarily by conditions of visibility and
positive identification of the source. The 1955 re-
vision of the Bureau of Mines Circular does not
specify any required distance from the smoke.
The A.S.M.E. recommends placing the chart
so that the same light falls on the chart as on the
smoke. The observer should not be looking toward
* People vs. Plywood Mfr's of California (CRA 3284-5), Shell Oil
Company (Cfl/4-3286), Union Oil Company (CRA 3303-06),
Southern California Edison Company (CRA 3327), November
21, 1955. Memorandum Opinion of Superior Court, County of
Los Angeles.
-------
Reading Visible Emissions
161
the sun while the face of the chart is shaded.
About the same amount of light should be re-
flected from the white portion of the chart as
comes from the background of the smoke. Opaque
smoke charts are seen wholly by reflected light
while light colored smoke is seen mainly by trans-
mitted light. Thus, with a properly placed chart,
60% of the light reflected from a No. 2 Ringel-
mann Chart is equal to 60% of the light trans-
mitted through a No. 2 black smoke plume.
1. Smoke Reading School*
With these principles clearly and legally estab-
lished, it is now possible to train inspectors to become
expert smoke readers. An expert smoke reader can be
defined as one who can distinguish smoke densities
within a margin of error of V-i Ringelmann or ten per
cent opacity in a significant number of readings dur-
ing both the hours of light and darkness and from any
given view of the emission.
Figure X - 3. A.P.C.D. Smoke School. Inspectors are trained
to make visual determinations of Ringelmann Smoke Density by
use of a black smoke generator equipped with a photoelectric cell.
The stack on the left serves a white smoke generator used to train
inspectors in reading smoke opacities. To qualify as an expert,
the inspector must not deviate more than plus or minus 10%
from the smoke measuring meter for any 50 readings.
During the early period of smoke reading instruc-
tion at the A.P.C.D., technical problems were encoun-
tered in reading and sustaining a desired smoke
density or opacity with the training equipment then
* Based on reference 2.
available. As a result, a specially-designed black smoke
generating system was placed in operation in 1953, and
a comparable white smoke generating system one year
later. (See Figures X-4 and X-5.) A specially designed
metering system was installed to replace the conven-
tional density recorder since in the latter device the
several stages of amplification were subject to malfunc-
tions which influenced the accuracy of meter readings.
a. Smoke Generating Equipment
In the design of smoke generating equipment, at-
tention was given to a means of regulating air fuel
ratios, to preventing horizontal distortion of the smoke
plume through the action of wind, and to accurate
determination of the actual smoke density or opacity
being observed by trainees.
The systems now utilized consist of two smoke
generating units, each with a vertical stack and a
density or opacity detection system.
(1) Black Smoke System: In this unit, the combustion
chamber consists of a 40-cubic foot rectangular
steel box, lined with six inches of refractory fire
clay.
The oil burner is a modified mechanical pressure
atomizing type, with the combustion air fan set
to operate continuously at full capacity. Various
degrees of incomplete combustion of the fuel are
obtained by altering air fuel ratios through adjust-
ment of the fuel flow rate. This adjustment is se-
cured through manual operation of a needle valve
located in the fuel supply line, between the pres-
sure pump and the spray nozzles. Combustion
products pass from the chamber through a hori-
zontal duct and cooling chamber into a vertical
stack where they pass through the opacity detec-
tion system and are vented into the atmosphere.
A force draft fan, discharging approximately 300
cubic feet of dilution air per minute into the base
of the stack, deters wind-caused horizontal distor-
tion of the smoke plume. The cooling chamber
prevents secondary combustion from occurring at
the base of the stack as the combustion products
are diluted with air.
(2) White Smoke System: In this system, the specific
opacity desired is obtained by controlling the rate
at which a distillate type of oil is sprayed into a
vaporizing chamber where it is diluted with air.
Upon leaving this chamber, the generated smoke
enters a vertical stack where it passes through the
opacity detection system before venting to the at-
mosphere. At times, it is necessary for the operator
to adjust both the oil pressure on the spray nozzle
and the heating chamber temperatures in order to
sustain a specific opacity.
(3) Opacity and Density Detection Systems: The
opacity and density detection systems comprise a
-------
162
Air Pollution Control Field Operations
OIL BURNER
COMBUSTION CHAMBER
43" x 43" v 61" OD
n
SYSTEM — »• YI
®
STACK — »•
12" Diameter x 16' High
J 1
COOLING
CHAMBER
• 1
•^^^•MB
^^^^•MBH
^
^"Nfc.
* REFRACTORY LINING ^ \ J {
DILUTION FAN
300 Watt
Proj. Lamp
Weston
• Phototronic
Cell
AIR SUPPLY TUBE
Figure X - 4. Design of gray smoke generator used by the A.P.C.D.
OPACITY DETECTION SYSTEM
OIL PRESSURE GAUGE
MANUAL OIL CONTROL VALVE
nnrnAL.iuni
STACK
12" Diameter x 16' High
AIR DILUTION FAN
1200 CFM
COMBUSTION GAS VENT
DISTILLATE OIL BURNER
I
Figure X - 5. Design of white smoke generator used by the A.P.C.D.
-------
Reading Visible Emissions
161
light source, a photoelectric cell and a milliam-
xneter.
A photoelectric cell and a light source are posi-
tioned at opposite ends of a light tube protruding
horizontally from each side of the smoke stack.
Upon receiving light energy passed through the
tube, the photoelectric cell generates an electrical
current which deflects the pointer of a milliam-
meter. The face of the meter has been modified
so as to indicate, not the amperage reaching the
meter, but rather the per cent of opacity or dens-
ity of the measured plume. Normally, a milliam-
meter reading 100 would be registering free
passage of light from the source of the cell. It
therefore was necessary to reverse the scale of the
meter so that 100 would indicate that no light
energy was reaching the cell and that 0 would
indicate free passage of light. When the operator
adjusts the foot-candle output of the light source
to cause a full scale deflection in the milliammeter,
an opacity of zero is read. Conversely, if the light
is turned out, no light energy reaches the cell and
the milliammeter, therefore, reads one hundred,
or 100% opacity.
The detection system has been calibrated to per-
mit accurate reading of smoke opacity and density
in terms of the Ringelmann standard. This has
been accomplished by inserting photographic
plates of known opacities and densities between
the light source and the photoelectric cell.
Through this method milliammeter deflections of
20, 40, 60 and 80 are produced.
b. Training Methods
The training objective of the "smoke-reading
school" is a level of individual inspector proficiency
which permits field determination of smoke opacity or
density within a margin of error of Vz Ringelmann, or
10 per cent opacity. The past experience of the Dis-
trict indicates an optimum average deviation of 7 to
8 per cent with an acceptable and attainable group
deviation of not more than 10 per cent. Since any
emission equal to or greater than No. 2 Ringelmann
constitutes a violation in Los Angeles County, it can
be proven that a violation has occurred when an in-
spector trained in the District smoke school determines
that an emission equals or exceeds No. 2V& Ringel-
mann.
During the instructional sessions, trainees are po-
sitioned approximately fifty feet from the smoke gen-
erator stacks.
As the training run begins, inspectors observe the
emission and, in the case of a black or gray emission,
compare it with a Ringelmann Chart posted on the
generator stack. Whenever the generator operator
sounds a bell, the trainees individually record their
reading of opacity or density, and then are advised by
the Instructor as to the actual opacity or density, as
determined by the detection system.
Training runs are conducted under a variety
of conditions simulating actual field situations under
varying conditions of light and darkness, and from
many different possible views of the plume in respect
to the inspector's position and the light source. Back-
ground color and varying lighting conditions may be
critical to accurate opacity determination of white or
other colored emissions, and these varying factors,
therefore, are introduced during the training runs.
During the initial smoke-reading training given a
new inspector, approximately one hour is devoted to
the training run, and, during refresher sessions, ap-
proximately thirty minutes. In total, each inspector
receives twenty-four hours of smoke-reading instruc-
tion during his initial entry-training, and annually,
thereafter, receives six refresher training sessions, each
of four hours' duration.
c. Proficiency Testing
Testing of individual inspector proficiency is con-
ducted both as a diagnostic device to determine the
need for additional training and as a means of assur-
ing a level of expertise that will fully meet the re-
quirements of the District's field operation program
and the possible test of a court action.
Since all new inspectors must serve a six-month
probationary period, failure to qualify fully during
the training program may lead to termination of em-
ployment during the probationary period.
During the test, inspectors are required to record
fifty readings of effluent density or opacity from the
smoke generators. The determinations are recorded
on a "Proficiency Record" (See Figure X - 7) when-
ever the generator-operator sounds a bell.
Since air pollution emissions of 40 per cent opaci-
ty or density are illegal in Los Angeles County, testing
of inspectors is concentrated on determination of the
inspector's ability to discriminate between emissions in
the range of 30 to 50 per cent opacity or density, with
testing also of the highs and the lows.
Scoring of the inspector's "Proficiency Record" is
accomplished by recording opposite the inspector's
reading, the actual opacity or density as determined
by the detection system. The trainee's deviation from
the meter reading is then indicated in an adjacent col-
umn, and for each set of twenty-five readings indicat-
ed on the record the following computation is made:
1. The total number of correct readings.
2. The total number of plus and minus readings.
3. The average plus and minus deviations for each
set of twenty-five readings as well as for the en-
tire fifty.
4. The percentage of readings deviating less than %
Ringelmann from the actual opacity or density.
-------
164
Air Pollution Control Field Operations
AIR POLLUTION CONTROL DISTRICT -- COUNTY OF LOS ANGELES
434 SOUTH SAN PEDRO STREET, LOS ANGELES 13, CALIFORNIA. MADISON 9-4711
NO.
NAM
1. E
1
2. E
3. E
4.
e
am VIVE
F A. S. MENIO
DATE
6-2-60
f * 4 M i N F R ffWAFn PHTTTPS
Inter readings incolumns 1, 2, 4 and 5 in Ringelmann numbers or fractions only. Do not enter
hem decimally. Enter fractions no less than 1/4.
Inter readings in columns 7, 8, 10 and II in percent opacity from 0 to 100 by 5's or 10's.
nter deviations in columns 346 in percent only, i.e., one R deviation = 20%, 4 R deviation =
j%, etc. In co umns 9 and 12 simply enter % difference between columns 7 and 8 or 10 and II.
f your reading is less than the meter reading enter the deviation as minus. If it is greater
nter deviation as plus.
BLACK
READING
1
2
3
4
5
6
7
8
9
10
11
12
13
14
1
READING
INSP.
2
24
3
L 3/h
^
A
i
2
3
H
U
>* 3A
4
2
READ 1 NG
METER
3
34
U
2
1
4
i*
24
3
•ft
k
5
i
2
3
DEVIATION
+20
+20
+20
+ 5
+10
+ 5
+10
+10
_
+ ?
.
+ 5
+10
+ 5
READING
15
16
17
18
19
20
21
22
23
24
25
4
READING
INSP.
24
5
24
li
?T
3
2
3|
3/li
^
5
5
u
Z
-------
Reading Visible Emissions
165
\l
Figure X - 7. Light source should emanate from the rear of observer during daylight hours (reflected light).
Figure X - 8. During darkness, the light source should emanate from behind the plume, opposite the observer (transmitted light).
Figure X - 9. Readings should be made at right angles to wind direction and from any distance necessary to obtain a clear
view of stack and background.
-------
166
Air Pollution Control Field Operations
5. The total number of readings deviating more
than l/2 Ringelmann from the actual opacity or
density.
6. The total number of readings deviating more than
1 Ringelmann from the actual opacity or density.
The inspector successfully completes his training
and qualifies as an expert in smoke reading if his pro-
ficiency record meets two requirements:
1. He must not deviate more than 10 per cent from
the actual opacity or density determination of the
detection system for an average of fifty readings,
and
2. He must demonstrate a consistency and reliability
in his determinations.
Even though a trainee achieves an average within
the allowable 10 per cent deviation, he does not qualify
if any reading deviates 20 per cent or more from the
actual, or his readings are inconsistent with one an-
other.
An analysis of the Proficiency Record indicates
whether or not the inspector was guessing, whether his
determinations are consistent, and whether he reads
high or low.
Weakness on any of these factors dictates the need
for further training.
2. Reading Smoke in the Field
On the basis of the training given in the smoke
school, and the accepted methods by which visual de-
terminations are made, the following general rules
apply to sight-reading in the field.
a. Reading Air Contaminants
1. Black smoke is read in densities and recorded in
Ringelmann numbers.
2. All other colored emissions are read in opacities
and recorded in percentages.
3. All opacity readings are related to corresponding
densities on the Ringelmann Chart in the follow-
ing manner:
RINGELMANN OPACITY
#1 20%
#2 40%
#2fc 50%
#3 60%
#31/2 70%
#4 80%
#4V6 90%
#5 100%
4. Light source should be from rear of observer dur-
ing daylight hours.
5. Light source should be behind plume during hours
of darkness (transmitted light).
6. Readings should be made at right angles to wind
direction, and from any distance necessary to
obtain a clear view of stack and background.
b. Recording Air Contaminants
1. Readings are recorded in the appropriate space on
the report or notice form as taken.
2. Observation times may be noted in terms of min-
utes and quarter-minutes, but not in terms of
seconds except in extraordinary circumstances.
3. Record all emissions during observation, showing
consecutive changes in readings.
4. Total only the time in which emissions of 40%
or greater and for No. 2 Ringelmann or greater are
observed.
5. Color of visible emissions should be recorded as
seen and as it changes.
6. It is advisable to record all or a significant portion
of the periods of excessive smoke observed during
the inspection.
7. A Violation Notice cannot be issued unless the
source emitted excessive smoke for more than
three minutes in any one hour and preferably for
more than 4 minutes. Continuing emission should
be recorded for at least six minutes of violation.
8. Any one hour means any period of sixty consecu-
tive minutes.
9. Photograph should be taken before or after but
not during visual determinations.
c. Smoke from Moving Sources
1. Smoke from tailpipes and exhausts of vehicles is
generally read in the same way that it is read
from stationary sources. The observer following
or pursuing a vehicle, however, should avoid
reading directly into the plume, if possible. Line
of observation should intersect the smoke trail at
as wide an angle as possible. Error of reading
smoke in this fashion should be compensated for.
2. Smoke should be read at its point of maximum
density.
3. Stop watch should be used to record accumulated
violation time.
REFERENCES
1. American Society of Mechanical Engineers, Power Test Codes,
Determinations, 1936.
2. Griswold, S. S., Parmelee, W. H., McEwen, L. H., Training of
Air Pollution Inspectors, presented before 51st Annual Meetiflg,
Air Pollution Control Association, Philadelphia, Pennsylvania,
May 28, 1958.
3. Hocker, Arthur J., Opacity Reading Principles, report to the
Director of Enforcement, 6-28-56.
4. Kudlich, Rudolf, Ringelmann Smoke Chart, United States De-
partment of the Interior, Bureau of Mines Information Circular
#7718, revised by L. R. Burdick, August 1955.
-------
CHAPTER ELEVEN
DETECTING AND MEASURING INVISIBLE CONTAMINANTS
"Invisible" contaminants are any contaminants
the field inspector cannot identify or measure by
means of direct and unaided observation, but whose
presence is indirectly or .inferentially determined
either by flow analysis or by physiological reaction.
These include contaminants which are transparent
gases, particulates below the threshold of vision in both
size and quantity, any visible plume containing such
contaminants, or any plume, usually below No. 2
Ringelmann or 40% opacity, which may require quan-
titative measurement.
Essentially, the problem of the inspector is to de-
termine the identity (the chemical element or com-
pounds involved, such as sulfur dioxide, carbon
monoxide, etc.) and the concentration (actual numeri-
cal values in units of measurement: p.p.m., per cent
volume, grains, pounds, tons, micrograms, etc.). Obvi-
ously such determinations normally fall within the
science of testing and measurement, involving a high
degree of specialization and skill, and are not truly
within the scope of the field inspector's duties. Never-
theless, there are various situations in which the field
inspector must depend upon these sciences and upon
such knowledge of air pollution chemistry as will pro-
vide the necessary clues and evidence he will require
for enforcement and other field purposes. These are as
follows:
1. STATIONARY SOURCE TESTING. Although not a
skilled member of a test team, the inspector will
require an understanding of stationary source
testing in order to make intelligent requests for
testing of stacks suspected of violating various
contaminant rules. He must also be prepared to
recommend testing methods and to suggest the
conditions under which testing should be per-
formed.
2. TOXICITY AND PHYSIOLOGICAL REACTION. The in-
spector should be prepared to make an intelligent
estimate of the concentrations of certain contami-
nants on the basis of physiological response, par-
ticularly where toxic contaminants and potential
hazards may be involved.
3. SAMPLING OF EFFLUENTS AND FUELS; FUEL AND
EQUIPMENT REGULATION. In the enforcement of
fuel and equipment rules the inspector may be
required to sample for laboratory analysis, gase-
ous, liquid or solid fuels or materials, including
gasoline.
4. ON-THE-SPOT TESTING. The inspector may con-
duct some limited field testing himself with
portable equipment in order to establish the exis-
tence of a nuisance or to determine hazardous
concentrations of contaminants. This type of
testing is usually made of the outdoor atmosphere,
but may also be applied to some stack effluents.
5. INTERPRETATION OF TEST RESULTS. The inspector
should be able to interpret the results of test data
in order to properly determine the course of en-
forcement action, and to prepare documentary
evidence.
6. READING AIR MONITORING DEVICES. As a general
air pollution technician, the inspector may be
required to take readings from air monitoring
equipment located at air sampling stations.
I STATIONARY SOURCE TESTING
Source testing is crucial to any program which at-
tempts to control a major and diversified air pollution
problem. It is not only a means whereby evidence
may be gathered to determine compliance with maxi-
mum permissible emission regulations based on grain
and dust loadings, or volumetric concentrations, but it
is used as a basis for granting or denying permits and
establishing emission factors for computing air pollu-
tion potentials.
Stationary source testing refers to the techniques
employed to sample, identify and measure contami-
nant concentrations in a stack effluent. The samples
collected may be analyzed in the laboratory for such
properties as particle size, weight, soiling characteris-
tics, reactivity, etc. Because of a host of variables en-
countered in testing and sampling, source testing must
be carefully planned.
It is necessary to schedule the categories of data
required in advance and to select the proper equip-
ment. Of great importance is the number of samples
and the various sampling methods required to produce
statistically significant results. The object here is to
take as many samples as will approximate actual stack
conditions.
Sampling methods are divided sharply between
those which test for gases and those which test for par-
ticulates and dusts.
The methods applied to gases may be grouped
according to the particular characteristics of the gases
and vapors, such as solubility and vapor pressure. For
instance, water soluble gases can be collected with
water, those which are not water soluble may be ab-
sorbed by highly reactive reagents or special solvents,
whereas those which react slowly may require special
treatment for collection.
Sampling methods applied to dusts and particu-
lates may also be affected by the solubility of the
material, or by their organic or inorganic nature. Per-
haps the most important factors in the sampling of
particulates are the size, volume and the velocity at
which they are emitted.
-------
168
Air Pollution Control Field Operations
Figure XI - 1. Members of an A.P.C.D. testing crew insert Pitot
tube in stack breeching to measure exhaust velocity on a differen-
tial gauge. This source test was conducted to sample oxides of
nitrogen from a steel smelting operation.
A, Determining Velocity and Temperature
of Effluent
Where a quantitative determination is to be made
(gravimetric or volumetric), it is necessary that mea-
surements be made with maximum precision of the
flow rate, and the volume and temperature of the gas
stream carrying the particulates.
The volume of gas in a stack or duct system is the
product of the average flow rate of that gas and the
area of the cross section of the stack or duct. The flow
rate is determined by means of a Pitot tube and differ-
ential pressure gauge. An anemometer can be used
when the flow rates are less than 10 feet per second.
Venturi meters and orifice disc meters may be used
to measure high velocities or pressures in ducts with
small diameters.
To assure accuracy, the measurement of velocity
is taken at a number of representative points in the
stack or duct cross-section. This area is divided into
a number of equal areas, the centers of which comprise
the sampling points. Where the flow rate is determined
to be uniform, sampling at one point is sufficient.
Where flow rates fluctuate greatly at any of the points,
many samples are taken, and when the flow varies
uniformly at the representative points, a few samples
are sufficient at each point.
The actual temperature and pressure of the stack
gas are corrected to standard conditions of 60°F. and
14.7 pounds per square inch absolute, as required by
Rule 3.
B. Probe, Sample Line and Sample Train
The sampling apparatus for stack gases as shown
in Figures XI- 1 and XI-4 consists of three main sec-
tions: (1) the sample probe, (2) the trap or traps in-
tended for the collection of specific contaminants, and
(3) the vacuum pump with flow meter and flow regu-
lation devices.
In order to obtain representative concentrations of
particulates, samples must be collected under condi-
tions of isokinetic flow(i). This means that the sample
probe must be adapted to the specific stack by utilizing
the appropriate nozzle size, and so situated and ad-
justed as to assure that the rate and direction of the
gas flow is the same in the sampler as in the stack. The
required rate of flow through the meter for a given
nozzle diameter is obtained from the following re-
lation (2):
M =
d2
4X144
X V x 60 X
Tm Tm
- = 0.33 - V d2
Ts Ts
where
M — Meter rate, cubic feet per minte
Tm= Temperature in meter, degrees F. absolute
Ts = Temperature in stack, degrees F. absolute
V = Velocity of stack gases, feet per second
d = Diameter of sampling nozzle, inches
The sample probe, usually !4" to Vz" in diameter,
is connected to the collection equipment and is inserted
at sample points in the stack either at the stack outlet
or the breeching close to the flame end point in com-
bustion equipment, depending on the purpose and
requirements of the test. (See Figures XI-2 and
XIII-5.) The probe is long enough to traverse the
diameters of most ducts and stacks. Sample probes are
usually made of stainless steel, glass or quartz to with-
stand reaction with sampling materials, high tempera-
tures, and corrosion.
Many air pollution inspectors in specialized en-
forcement components are equipped with probes and
Figure XI - 2. Sample bottle and evacuated flask.
-------
Detecting and Measuring Invisible Contaminants
169
simple collection bottles and other equipment which
enable them to collect and to take samples to the lab-
oratory for analysis. The use of such equipment, how-
ever, is greatly limited to sampling of stationary
facilities at permanent industrial locations such as
refineries and power plants and other locations where
construction of sampling facilities is mandatory.
Where only identification of effluent constituents are
required at these locations, accurate quantitative mea-
surements are unnecessary.
The inspector looks for a sampling point which is
not too close to any bend in the ductwork or stack so
as to avoid eddies and turbulence of gas flows. Since
sampling may be conducted under a slight negative
pressure, 1 to W water, the sample line is flushed by
steam injection or compressed air, employing facilities
at the source of air pollution. When the line is flushed,
the sample is drawn through the sample feed line by
means of an impinger and aspirator, or syringe, dis-
placement or other suction producing methods, into a
sample bottle with shutoff valves (Figure XI-2).
For determining compliance with maximum per-
missible regulations a sampling train arranged for col-
lection of specific contaminants follows the probe (see
Figure XI - 4). In most enforcement tests all that is
really required is a quantitative measurement of grain
or dust loading and gas volume for Rules 52, 53 and
54. The standards stipulated by the rules are primar-
ily gravimetric, or volumetric in the case of Rule 53a,
"Specific Contaminants". These tests generally in-
volve specialized skills and elaborate equipment and
are conducted by a special component of the Engin-
eering Division, rather than the Enforcement Division.
When tests become necessary in any enforcement ac-
tion they are requested by the inspector.
We shall deal here with the particular types of
traps or sampling devices used first in the collection
of particulates, then gases. Following this discussion,
a survey of the methods employed by the A.P.C.D. in
sampling for specific contaminants shall be presented.
C. Paniculate Sampling Devices*
The methods used in sampling particulates are in
themselves similar in principle to the various types of
dust control equipment employed by industry. The
principles involved are based on sedimentation or set-
tling, inertial or centrifugal action, filtration, imping-
ing and impacting, electrostatic and thermal precipita-
tion. The sampling devices, however, must possess a
very high collection efficiency for all particle sizes
collected.
1. Sedimentation and Settling Devices. These are
generally settling chambers, fallout jars, Petri
dishes, trays and gum paper stands used for col-
lecting particulates which may settle out of the
atmosphere. The settling chamber can be used
for obtaining grab samples of representative vol-
*Based in part on reference 3.
umes of air, from which a rough quantitative
analysis can be performed. Because the collection
of particulates by these methods for quantitative
analysis is subject to many inaccuracies, they are
generally limited to estimating dustfall trends in
an area. Gum paper stands, or stands coated with
petroleum jelly are particularly useful to inspect-
ors in tracking down unidentified sources of par-
ticulates involved in public nuisances.
2. Inertial or Centrifugal Collection Equipment.
These are midget cyclone collectors used for grav-
imetric determinations of large particles such as
fly ash, usually above 1 micron in diameter. For
particles over 10 microns cyclone collectors are
almost 100% efficient. Inertial collection equip-
ment is simple in design, temperature resistant,
and has low pressure drop. The samples collected
may be readily removed. (See Figures XI-7 and
XI-8.)
3. Filtration. Equipment used in this method con-
sists of a suction type blower system which draws
the air through a specially selected filter medium.
The filter medium may be soluble or insoluble.
Soluble filters, in particular — such as the mille-
pore filter — may be dissolved to recover the par-
ticles. The filtration method is particularly use-
ful in collecting almost unlimited quantities of'
particulates which can be analyzed for weight,
particle size and composition. In overcoming the
difficulty of separating the particulate from the
filter medium, a soluble filter medium can be
used. Samplers may be of the high volume, tape
or molecular types. Filtration is suitable for
measurements of mass quantity, soiling proper-
ties, chemical analysis, counting and sizing, and
determining radioactivity.
4. Impingement. Impingers provide for the separa-
tion of the particulates by means of sudden
changes in direction of the gas stream. The wet
impinger is useful in collecting fine particles. In
the dry type impinger, the particulates impinge
and adhere to special surfaces. The latter is limit-
ed to relatively larger particles. The impinger is
suitable for counting and sizing and for detailed
chemical analysis. A well known impinger is the
Greenburg-Smith or "midget impinger", which is
small, efficient and relatively inexpensive.
5. Cascade Impactors. This consists of a number of
impingement stages through which the velocities
of the gas stream systematically vary, thus col-
lecting and sorting particles in several size ranges.
The collection surfaces are small collodion screens
on microscopic slides for study under the micro-
scope. The cascade impactor is almost 100% effi-
cient and will collect particulates ranging from .7
micron to 50 microns.
-------
170
Air Pollution Control Field Operations
Electrostatic dust and fume sampler.
"Staplex" sampler and filter.
Midget impinger apparatus.
Cascade impactor.
Figure XI - 3. Portable contaminant sampling devices.
-------
Detecting and Measuring Invisible Contaminants
171
6. Electrostatic Sampling Devices. Electrostatic
sampling devices are highly efficient and can be
used for studying the physical characteristics of
airborne particulates ranging below 1 micron in
size. These function on the principle of ionization
of particles by means of a platinum electrode. The
particles are collected on a removable electrode of
opposite charge.
7. Thermal Precipitators. These devices are based
on the principle that particulates carried in a slow
moving gas stream between hot and cold surfaces
will settle out on the cooler surface, due to the
heat transfer or convection between the surfaces.
Thermal precipitators are designed to collect the
particles on a coated grid for examination under
the electron microscope. Although these devices
will collect sub-micron particles, they do not sat-
isfactorily collect particles over a wide-size range.
D. Gas Sampling Devices
Since the properties of gases and vapors radically
differ from those of particulate matter, different test
methods apply. Gases do not conglomerate or settle
out, so they cannot be adequately collected by means
of filtration, precipitation or impaction. Gases, how-
ever, may be absorbed into reactive solutions, dissolved
in solvents, collected by adsorption to an active surface
area of a solid, condensed out by freezeout methods
(ice bath) or may be captured bodily by means of dry
evacuated flasks.
The sampling of gases consists primarily of sep-
arating the gas being sampled from other gaseous
media, such as air. In sampling, it may be necessary
to utilize a filter to capture the particulates which may
adsorb some of the gases and interfere with accurate
gas sampling.
The volumes of individual gases at the same pres-
sure in any mixture are additive. Each gas in a mix-
ture has its own pressure. The total pressure of the
gas mixture will thus consist of the sum of the individ-
ual pressures. The term "part per million" (ppm) is
a measurement based on the proportion of gas volumes.
The determination of part per million is equivalent to
per cent of volume, and can be calculated by simple
arithmetical proportion. Ten thousand parts per mil-
lion is equivalent to 1 % of gas volume. Sulfur dioxide
at 0.2 per cent volume is equivalent to 2000 parts per
million of air.
In sampling for gaseous contaminants, tempera-
ture and pressure conditions are of the utmost impor-
tance, and must be accurately recorded. A weight or
a Standard Temperature Pressure volume analysis
should always be converted back to the temperature
and pressure conditions existing when the sample
volume was first measured.
Gas sampling techniques are adapted either to the
sampling of specific gaseous compounds, or to deter-
minations of gross gaseous contaminant concentrations.
The specific methods are generally used for testing
inorganic gases or reactive organic gases, and in almost
every case involve an absorption method by bubbling
the gas through a reactive liquid agent or by exposing
the contaminated air to impregnated papers and gran-
ules for colorimetric reactions.
For sampling mixtures of contaminated gases, the
freezeout, adsorption and grab sample techniques may
be used. For concentrations of specific gases greater
than 1 ppm, squeeze-bulb methods may be used (see
"On-the-Spot Testing").
E. Sampling for Specific Contaminants
An example of source testing for combustion con-
taminants, including particulates and gases, follows.
This source testing procedure is conducted to deter-
mine compliance with Rule 53a and b, sulfur com-
pounds and combustion contaminants. Sampling
methods for ammonia, organic acids, hydrocarbons,
aldehydes, and oxides of nitrogen are also described*.
1. The Sampling Train
The sampling train consists of a sampling nozzle,
three impingers (4' 5- 6) in series in an ice bath, a
weighed paper thimble, dry gas meter, and pump, all
connected as shown in Figure XI-4. A glass tube bent
to point into the gas flow may serve as the sampling
nozzle and is used when the stack temperature does not
exceed 900°F. The sampling rate for this train may
range from one-half to one cubic foot per minute.
The first two impingers in the train each contain
100 ml. of distilled water and the third impinger is dry
with a thermometer attached to the stem.
During the sampling, the Pitot tube and thermo-
couple are inserted into the stack at the reference
point. The following readings are taken at least once
every five minutes for the duration of the test:
1. Meter reading. (Also taken at start and end
of run.)
2. Meter vacuum.
3. Gas temperature at meter.
4. Temperature in third impinger.
5. Pitot tube draft gauge.
6. Stack temperature.
The impingers serve to cool the stack gas sample,
to collect particulate matter, and to condense moisture
from the gases before they pass through the paper
thimble. The thimble collects any particulate matter
which may pass through the impingers.
The duration of the sampling is normally one
hour, but in some cases the operating conditions en-
countered may require a longer or shorter time for
sampling.
* Quoted directly, in part, from Ranter, Lunche and Fudurich,
reference 2.
-------
172
Air Pollution Control Field Operations
Figure XI - 4. Prescribed sampling train for combustion con-
taminants. The first two impingers following the glass sampling
tube contain water, but the third one is dry. A paper thimble,
meter and pump complete the sampling train.
2. Sampling for Carbon Dioxide
Under the provisions of Rule 53b, the concentra-
tion of combustion contaminants must be calculated to
12 per cent carbon dioxide. This gives a standard basis
for all types of combustion operations, and insures
against circumvention of the Rule by dilution. Thus
on all tests for combustion contaminants, it is neces-
sary to determine the average carbon dioxide concen-
tration for the period of sampling.
An integrated gas sample for Orsat analysis is col-
lected by withdrawing gases continuously from the
stack at a constant rate by a liquid displacement meth-
od. As shown in Figure XI-5, a five-liter bottle filled
with a saturated sodium sulfate solution, acidified with
sulfuric acid, is used as the collecting gas holder. As
the solution siphons out, the gas sample is drawn into
the bottle. The rate of siphoning is adjusted so that a
gas sample of about four liters is obtained during the
course of the test. The sample is drawn from the stack
at the same cross section used for collecting the com-
bustion contaminants.
3. Measuring the Combustion Contaminant
Sample
At the end of the sampling period the sampling
train is disconnected, and all the collection apparatus
is stoppered and returned to the laboratory for an-
alysis.
The paper thimble is dried in a constant tempera-
ture oven for 30 minutes at 105°C. and allowed to con-
dition in the balance room before being weighed. A
weighed control thimble is treated similarly, so that a
correction may be applied to the sampling thimble for
any change of weight which may occur because of
humidity changes in the balance room temperature.
The solution in the impingers is volumetrically
measured. An increase in volume occurs because of
condensation of moisture from the stack gases. This
must be taken into account when calculating the
sample volume.
The contents of the impingers and connecting
tubing are carefully washed into a beaker and slowly
evaporated to a volume of 20 to 30 ml. This is trans-
ferred quantitatively to a weighed 50 ml. beaker, and
evaporated to dryness at 105°F. in an oven. The beaker
is cooled in a desiccator and weighed.
The total weight of combustion contaminants is
the sum of the weights of material collected in the
impingers and the thimble.
The volume of flue gases sampled is the difference
in initial and final meter readings plus the volume
calculated from the water condensed in the impingers.
This moisture volume is obtained as follows:
C 379 Tm
_ v - ___ V — _ V _
453.6 18 ' 520 (Pa-Pm)
29.92 Tm
= 0.00267 C
Pa-Pm
where
W =
C =
Tm =
Pa =
Pm =
Vapor volume of condensed moisture at meter condi-
tions, cubic feet
Volume of condensed water, ml.
Temperature in meter, degrees F. absolute
Atmospheric pressure, inches of mercury
Meter vacuum, inches of mercury
The combustion contaminants are reported as
grains per standard cubic foot, calculated to 12 per
cent carbon dioxide.
Figure XI-5. Bottle for collecting sample for CO2 determina-
tion. Contains acidified sodium sulfate solution. Gas is drawn in
during siphoning out of solution. After gas sample is collected.
solution in funnel is allowed to flow down to maintain a pressure
in the bottle slightly above atmospheric.
-------
Detecting and Measuring Invisible Contaminants
Figure XI - 6. Alundum thimble and holder. From left, samp-
ling nozzle cap, with heat resistant gasket, alundum thimble with
glass wood plug, spring and holder, thimble housing.
4. Alternate Sampling Trains for
Particulate Matter
In many cases, tests are run to obtain information
about the participate matter being emitted from the
combustion process when the question of compliance
with existing rules is not involved. In addition to grain
loadings, it may be desirable to make particle size de-
terminations, microscopic studies, or chemical anal-
yses. In these cases, other sampling trains more
suitable to the desired purposes may be used.
In one train, an alundum thimble is placed before
the impingers so that the particulate matter is collected
in a dry state (Figures XI-6 and XI-7). Very fine
particulate matter will usually pass through the alun-
dum thimble and be collected in the impingers. The
weights of the material collected are obtained in a
manner similar to that described for the prescribed
sample train.
A miniature glass cyclone has been used in front
of the thimble (Figure XI-8) on a number of tests to
separate out the particulate matter above five microns.
5. Sulfur Dioxide and Sulfur Trioxide
The sampling train for sulfur dioxide and sulfur
trioxide consists of a paper thimble maintained just
above the dew point of the stack gases followed by
three series-connected impingers immersed in an ice
bath, a dry gas meter and a pump. The thimble acts
as a collector for the sulfuric acid aerosol formed from
the sulfur trioxide. The first two impingers contain
100 ml. each of approximately five per cent sodium
hydroxide solution. The third impinger is dry. The
sulfur dioxide gas passes through the thimble and is
collected in the impingers.
The thimble is extracted with hot water and the
solution is titrated with standard sodium hydroxide
solution to determine the sulfur trioxide. The sulfur
dioxide collected in the impingers is determined by
oxidation with bromine, acidification, and precipita-
tion as barium sulfate.
6. Ammonia
The sampling train for ammonia consists of three
series-connected impingers immersed in an ice bath
followed by a dry gas meter and a pump. The first two
Figure XI 7 Sampling train using miniature glass cyclone,
alundum thimble, and impingers. Meter and pump complete the
train.
impingers contain 100 ml. each of approximately five
per cent hydrochloric acid solution. The third im-
pinger is dry.
The ammonia is determined by a modified Kjel-
dahl distillation method. An excess quantity of sodium
hydroxide is added to the impinger solution and the
ammonia is distilled into a measured volume of stand-
ard acid. The excess acid is titrated with a standard
base to obtain the ammonia content.
Ammonia is not normally found in the flue gases
from combustion sources. Tests for ammonia are made
only in special cases where its presence might be sus-
pected. For example, it has been found that flue gases
from catalytic cracking regenerators contain ammonia.
7. Organic Acids
The sampling train for organic acids consists of
three series-connected impingers followed by a dry gas
meter and a pump. The first two impingers contain
Figure XI - 8. Miniature glass cyclone, with ground glass joints.
Constructed to specified design within close tolerances.
-------
174
Air Pollution Control Field Operations
100 ml. each of a five per cent sodium hydroxide solu-
tion and the third impinger is dry.
The impinger solution is acidified to a pH of two
and is extracted with ether in a liquid-liquid extraction
apparatus. Water is added to the extract and the mix-
ture is titrated with standard sodium hydroxide solu-
tion to the phenolphthalein end point.
8. Hydrocarbons, Aldehydes, Oxides of
Nitrogen
Samples for the determination of hydrocarbons,
aldehydes, and oxides of nitrogen are collected in
evacuated bulbs. At least four samples for each of the
gases are taken during a one-hour test period. The
bulbs for hydrocarbon samples are used dry; for alde-
hyde samples they contain sodium bisulfite absorbing
solution; and for oxides of nitrogen they contain a
mixture of hydrogen peroxide and 0.1 N sulfuric acid.
The hydrocarbons are determined by an infrared
spectrophotometer and the results are expressed as
hexane.(7)
The aldehydes are determined by a modified
Ripper's method(8) and are expressed as formaldehyde.
The oxides of nitrogen are determined by the
phenol disulfonic acid method (9, 10, 11) and reported
as nitrogen dioxide. Both the nitric oxide and nitrogen
dioxide which may be present are measured by this
method.
F. Requesting Source Testing
The field inspector, as a practical matter, is inter-
ested in sampling or testing "invisible" contaminants
in two basic types of situation:
1. To determine compliance with maximum per-
missible emission regulations rules: 52, 53,
and 54.
2. To identify and measure, if possible, any sus-
picious contaminant emitted from a source
and which may be involved in an air pollution
problem.
We shall deal with these as they relate to source
sampling and testing.
1. "Invisible" Contaminant Rules
The invisible contaminant rules are as follows:
Rule 52—This Rule limits the concentration of all
particulates to 0.4 grains per cubic foot of gas
at standard conditions. (A grain is 1/7000 of
an avoirdupois pound.)
Rule 53a—Specific Contaminants. This Rule lim-
its sulfur compounds to 0.2 per cent by vol-
ume, calculated as sulfur dioxide.
Rule 53b—This Rule limits combustion contami-
nants to 0.3 grains per cubic foot of gas cal-
culated to 12 per cent of carbon dioxide
(C02) at standard conditions.
Rule 54—Dusts and Fumes. This Rule limits the
total quantities of dusts and fumes emitted
per hour according to a graduated schedule of
the weight of materials handled in the spe-
cific process per hour. The maximum allow-
able loss permitted by Rule 54 is 40 pounds
of dusts and fumes lost for 60,000 or more
pounds of material processed. (See Process
Weight Table, TABLE XI-1).
TABLE XI-1
RULE 54 PROCESS WEIGHT TABLE
'PROCESS
WT/HR
(LBS)
50
100
150
200
250
300
350
400
450
500
550
600
650
700
750
800
850
900
950
1000
1100
1200
1300
1400
1500
1600
1700
1800
1900
2000
2100
2200
2300
2400
2500
2600
2700
2800
2900
3000
3100
3200
3300
MAXIMUM
WEIGHT
DISCH/HR
(LBS)
.24
.46
.66
.852
1.03
1.20
1.35
1.50
1.63
1.77
1.89
2.01
2.12
2.24
2.34
2.43
2.53
2.62
2.72
2.80
2.97
3.12
3.26
3.40
3.54
3.66
3.79
3.91
4.03
4.14
4.24
4.34
4.44
4.55
4.64
4.74
4.84
4.92
5.02
5.10
5.18
5.27
5.36
'PROCESS
WT/HR
(LBS)
3400
3500
3600
3700
3800
3900
4000
4100
4200
4300
4400
4500
4600
4700
4800
4900
5000
5500
6000
6500
7000
7500
8000
8500
9000
9500
10000
11000
12000
13000
14000
15000
16000
17000
18000
19000
20000
30000
40000
50000
60000
or
more
MAXIMUM
WEIGHT
DISCH/HR
(LBS)
5.44
5.52
5.61
5.69
5.77
5.85
5.93
6.01
6.08
6.15
6.22
6.30
6.37
6.45
6.52
6.60
6.67
7.03
7.37
7.71
8.05
8.39
8.71
9.03
9.36
9.67
10.0
10.63
11.28
11.89
12.50
13.13
13.74
14.36
14.97
15.58
16.19
22.22
28.3
34.3
40.0
Determination of compliance with these contami-
nant rules is not ventured by the inspector, but by a
special test team. Conditions and criteria for reason-
able suspicion of violations, however, exist. For ex-
ample, where solid and liquid particulates, such as
dusts and mists are distinctly visible as a plume emit-
ted from a specific stack, duct or source, a violation of
Rules 52, 53b, or 54 may be reasonably suspected. An
* Rule 2j. Process Weight per Hour. "Process Weight" is the
total weight of all materials introduced into any specific process
which process may cause any discharge into the atmosphere.
Solid fuels charged will be considered as part of the process
weight, but liquid and gaseous fuels and combustion air will
not. "The Process Weight per Hour" will be derived by divid-
ing the total process weight by the number of hours in one
complete operation from the beginning of any given process to
the completion thereof, excluding any time during which the
equipment is idle.
-------
Detecting and Measuring Invisible Contaminants
175
opacity of 20% or more, excluding water vapor or
steam which may be included in the plume, is suffi-
cient to suspect a violation. This suspicion may be
reinforced if such other factors as poor operating
procedures, low-grade fuels, inefficient processing, or
public nuisances are involved. In the case of Rule 54,
an excessive visible discharge in relation to a relatively
small rate of material processing may strongly indicate
the possibility of a violation. An experienced inspector
will be able to learn from an examination of the entire
air pollution configuration whether or not the opera-
tion or design of equipment is extraordinary. Sus-
picious operation of equipment can be checked against
conditions stated on operating permits. Should a test
be necessary, the operating conditions of equipment at
the time of the opacity or suspicion of violation should
be noted.
In most instances in the burning of liquid, gase-
ous or solid sulfur-bearing fuels, enforcement of Rule
53a is obviated by Rule 62, Sulfur Content of Fuels,
which fixes the sulfur content of fuel below that which
would yield the excessive gaseous concentration pro-
hibited in Rule 53a. A fuel regulation thus tackles the
problem more directly at the source than does a maxi-
mum permissible emission. Rule 53a, however, is still
useful in enforcement, especially at sources which
involve the processing of sulfur-bear ing materials
rather than the combustion of fuels. This includes
acid plants which make sulfur and certain refinery or
petrochemical operations such as the burning of tail
gases of hydrogen sulfide to produce sodium and cal-
cium polysulfides. Also, Rule 53a must still be cur-
rently applied during the periods of the year when
Rule 62 is not in force.
The best estimation that can be made in terms of
the probability of violation of Rule 53a is by observa-
tion of the plume. There are several simple rules
which can be remembered in the formation of plumes
resulting from the combustion of materials containing
sulfur.
1. The complete combustion of sulfur or hydrogen
sulfide yields twice its weight in sulfur dioxide
gas.
2. Approximately 3-5% of the total gas volume of
sulfur dioxide consists of sulfur trioxide (SO3).
3. Sulfur trioxide generally becomes visible at ap-
proximately 20 parts per million. The plume
opacity is "trace" or about 5%. This means that
a 5% plume will contain about .04% of sulfur
dioxide, far below a violation, but enough to war-
rant sampling and testing. Of course, as the opac-
ity of the plume increases, so will the probability
of violation.
Since sulfur dioxide and hydrogen sulfide are
gases, the inspector is not handicapped by the necessity
to perform isokinetic sampling. All that he need do is
take a representative sample by squeeze bulb, Tut-
weiler or iodometric methods, as described in the "On-
the-spot" section of this chapter. These "portable"
methods are generally accurate within a 10% degree
of error. Where concentrations are significantly more
than ten per cent above that prohibited as disclosed by
the use of such test equipment a definite violation can
be proven in court.
These field determinations, however, are not al-
ways practical due to the inconvenience or the lack of
sampling facilities at all sources of air pollution. They
are mostly conducted at oil refineries, chemical plants,
and large power generating stations, where the condi-
tions of operations are well known by the inspector
and where variables in operation are readily ascer-
tained. Stationary sampling facilities, permanent
sample lines, air compressors, steam lines, and testing
equipment are usually available at refineries and
power plants. Since tests may not be practical at
smaller installations, in extreme cases stationary tests
may be requested from the Engineering Division. It
should be noted that violations of Rule 53a in other
than large installations or refineries are rare. The in-
spector, therefore, may still more effectively apply
Section 24242, Ringelmann smoke density, or Section
24243, Public Nuisance, if one exists, in preference to
Rule 53a.
2. Suspicious Contaminants — Grab Samples
Occasionally, an inspector may desire to merely
sample a contaminant, whether gaseous or particulate,
for identification in the investigation of a special prob-
lem or a public nuisance. A gas sample may merely
be taken by means of a sample probe and impinger
with an aspirator, or by an evacuated flask, syringe,
etc., according to methods previously described. The
samples can then be brought to the laboratory for
analysis.
3. Requesting Source Testing
All requests for tests are made on the form "Re-
quest For Test And/Or Analysis" shown in Figure
XI-9. This form may be used to initiate tests by the
Inspector, Senior Inspector, or any member in the
chain of command, should such a test be warranted.
The Senior Engineering Inspector carefully reviews
the reasons for testing as well as the conditions under
which the tests should be conducted. Judgment must
be used in determining whether or not there is suffi-
cient cause for testing, since testing is expensive. Most
air pollution problems not involving permit processing
are resolved without source testing even when invisible
contaminants are involved. As a matter of practical
expedience the inspector can adequately determine air
pollution problems through design and operational
and maintenance practices and bring them to the
attention of management. When a chronic or serious
air pollution problem is presented by the emission of
invisible particulates which may cause public nuis-
ances or complaints, however, and no other means is
-------
176
Air Pollution Control Field Operations
LENTRHL FILES Coi
TEST NO. 1638
SOURCE LOCATION DATA
Ajax Asphalt Company
4321 W. Industrial St.
Mr. R. T. Smith
r.TY Onvx
„„., .„ Central 6540
REQUEST INITIATION DATA
. R. Handv
T,,,, Prod. MET.
L. B. Tones
Rnfnrrement
OP...
CJs...
d
o
SOURCE AND SAMPLE DATA
U-Fired Rotary Drier
1. Sample labeled "Fuel Oil from P..P.I TanV rn Hnr rHl Haal-CT" - T p
Inspector. 10 a. nv - ft-17-fin
2. Sample labeled "Fuel nil from Pnpl Piimp rn B»t-ary rM^i-" -JR. H°ir1y.
toroectnr- Q-17-66;
Per cent sulfur by weight (Rule 62)
Samples accompany request.
.ACTION BY SOURCE TESTING UNIT_
Figure XI - 9. Request for source test or sample analysis.
available for controlling the source through the usual
enforcement methods, source testing is indicated.
All requests for tests are reviewed again by the
Engineering Evaluation and Planning Division before
action is taken. The review is made to obtain the
maximum useful information per test. For example,
the Enforcement Division might request a test on a
multiple-chamber incinerator for combustion contam-
inants to determine compliance with Rule 53b. The
Evaluation and Planning Staff might make additions
to the request to obtain information on aldehydes or
oxides of nitrogen for total air pollution studies.
The operating conditions of the equipment are
specified on the test request form by the person origi-
nating the request. On an incinerator, these conditions
might include, for example, the type of material to be
burned, the burning rate, and the cycle of operation,
such as start-up or burndown.
II TOXICITY AND PHYSIOLOGICAL RESPONSE
Concentrations of air contaminants may be mea-
sured not only by the use of specially designed instru-
ments, but by their effects on life and property. In
fact, minute traces of some contaminants may often
be immeasurable, or difficult to measure, and are only
detected by their environmental effects. Odors, for
example, may be produced by minute quantities of air-
borne materials, such as mercaptans, which otherwise
do not reduce visibility or cause any significant dam-
age to property. Some contaminants, such as hydrogen
sulfide attack lead-based paints. Other contaminants
may have toxic effects on humans and various species
of vegetation. The extent to which these effects are
created, or the type of nuisance or hazard effect evi-
denced such as corrosion, irritation, odor, systemic poi-
soning, or other biological effects on living organisms
are in themselves a means of identifying and measur-
ing the concentrations of many types of contaminants
in the air dispersed from a nearby source. We shall
treat here the physiological reactions to toxic sub-
stances.
Although the most common effect expected of
toxic materials is irritation, there are many others, i.e.
the sensation of pressure experienced on the mucosa in
some persons due to the presence of ozone; headaches
associated with carbon monoxide; increased breathing
rate due to carbon dioxide; the loss of sensual percep-
tion due to fatigue or anaesthesia as in the case of
higher concentrations of hydrogren sulfide or gasoline
fumes. Other toxicants are even more insiduous, ex-
hibiting no immediate effect, but marked suffering
after several hours or days.
Identification and concentration of air contami-
nants in terms of biological influences are made in
terms of the concept of the threshold. A threshold is
that concentration of a contaminant which is just
barely detectable in the effect that concentration has
on an organism. Thus an odor threshold is the lowest
concentration of a contaminant at which its odor is
first detected. The odor threshold quite often is used
as a reference point in roughly estimating the concen-
tration of air contaminants. Similarly, a threshold will
exist for other physiological responses such as those
symptoms and sensations described in the preceding
paragraph.
There are two general types of thresholds of use
in the fields of industrial hygiene and air pollution
control. These are odor thresholds and toxic or eight-
hour working thresholds established as safety stand-
ards for certain occupations. The latter is referred
to as the Maximum Allowable Concentration (the
MAC). Such thresholds are investigated and
established to guide governmental agencies and others
concerned by the Committee on Threshold Limits,
American Conference of Governmental Hygienists.23)
More recently, a greater interest is being shown on the
effects of low concentrations of air contaminants in
metropolitan areas for the purpose of establishing air
quality standards. The information supplied from this
general field is very useful to the inspector. Odor
thresholds are of particular value in that some gases
give odor warning before a toxic level is reached, such
as hydrogen sulfide and sulfur dioxide, whereas such
gases as carbon monoxide and arsine give no warning.
Threshold data, therefore, has two fundamental
uses for the field inspector.
-------
Detecting and Measuring Invisible Contaminants
177
1. Identification and estimation of contaminant con-
centration involved in enforcement problems such
as public nuisances.
2. Estimation of hazardous concentrations of con-
taminants in an area for the inspector's pro-
tection. In all dangerous situations, the safest
thing to do is to remove oneself from the contami-
nated area or to put on protective equipment if the
presence of dangerous material can be perceived.
Thresholds and other important data regarding
some gases encountered by A.P.C.D. personnel, along
with data regarding testing techniques were compiled
by Clawsoni2) as follows:
ALDEHYDES
ACROLEIN, CH0 ;= CHCHO
(PROPENOL)
A colorless liquid; boiling
point 126.5°F. Solubility: 1
part acrolein in 3 parts H2O.
A colorless gas with density of
FORMALDEHYDE, HCHO
(METHANOL)
PROPERTIES:
A colorless gas with density
of 0.815; soluble in H20d5);
very reactive, explosive lim-
its: 7%-73%.
ODOR:
Suffocating, pungent, irritating, (15) choking <26) (These
aldehydes, at threshold levels, are probably perceived by rea-
son of their irritating quality rather than by the sense of
smell.)
SOURCES:
Occurs in a great diversity
of industries as raw materi-
al, product and/or by-prod-
uctdS).
Results from thermal decom-
position of fats, oil or glycer-
ol d5). Used as war gas in
World War I.
ATTACK:
The toxic effect of these compounds (especially formaldehyde)
is the denaturing of tissue (especially mucous membrane) pro-
teins. Formaldehyde is more soluble and exerts the greatest
effect on upper respiratory tract*14) (can lead to death by
edema or spasm of larynx)*13). Acrolein can cause death by
pulmonary edema, respiratory paralysis*13). Both are powerful
irritants of eyes, respiratory tract and skin*13) (14).
SYMPTOMS:
Sneezing, coughing, salivation, eye irritation with lachryma-
tiou (especially acrolein)*25). Bronchial catarrh, conjunctivitis.
Some individuals become highly sensitized to formaldehyde,
leading to asthma or skin disorders on later exposures*13).
REMARKS:
GOOD WARNING CHARACTERISTICS, due to strong irrita-
tion. Concentrations not immediately dangerous to life can
become intolerable in a very short time.
TOXICITY:
CONC.: PPM RESPONSE
0.25 Eye irritation(22).
5 Max. allowable cone.,
8 hr.(23).
200 For 31/2 hr.: quick re-
covery (animal) (25).
650 For 4 hrs. lung, eye
irritation, recovery
650 8 hr. edema & hemor-
rhage, death
1600 4hr. edema & hemor-
rhage,death
4900 3 hr. edema & hemor-
rhage, fatal.
(Responses to concentrations
above 200 ppm are from an-
imal studies: cat)
PLANT DAMAGE: 30 ppm for 24 hrs. killed
plants*22).
TEST:
Goldman & Yagoda Bisulfite Method(13) Ind. & Chem. Anal.,
ed. 15-377, 1943.
CONG.: PPM RESPONSE
0.5 Max. allowable cone., 8
hr(23).
0.5-1.5 Eye irritations thresh-
old
1.8 "Odor" threshold!23)
1.0 Eye & nose irritation in
3 min.
5.5 Eye & nose irritation in
20 sec., intolerable in 1
min.
10 Lethal to most animals
in a few min.*13).
153 Fatal to man in 10
min. (25).
AMMONIA,NH3
CHARACTERISTICS:
Colorless gas, density 0.597 X air*13). Extremely soluble in
water (to 29%) *13>."Easily liquefied by pressure. L.E.L. 16%
NH3 by vol. (15). Corrosive to copper, brass, aluminum and
zinc.
ODOR:
Pungent and irritating'13) characteristic.
SOURCES:
Many uses, especially in refrigeration(18). Also used in tex-
tile, dye-making, explosive, lacquer, fertilizer, etc., indus-
tries d3).
ATTACKS:
Upper respiratory tract, moist eye tissues d3). High cone.
(above 2%) will produce chem. burns on wet skind9).
SYMPTOMS:
Violent respiratory reflexes, as coughing and arrest of breath-
ing
(13)
Secretion of saliva; eye irritationd3>.
REMARKS:
Good warning properties, since odor threshold is below injuri-
ous concentration!13).
TOXICITY:
CONCENTRATION
(P.P.M.)
53
100
300
408
698
•1720
5000 to 10,000
2% to 3%
TESTS:
Expose red litmus
mosphere(15):
CONCENTRATION
(P.P.M.)
1
10
100
1000
PHYSIOLOGICAL RESPONSE
Odor threshold!13)
Maximum allowable cone., for eight
hrs. (23).
Maximum allowable cone., one hour (I3).
Least cone, causing throat irritation (13)
(14).
Least cone, causing immed. eye irritation
(13).
Least cone, causing coughingd3).
Rapidly fatal for short exposure (14).
Can cause chemical burns on wet
Also:
Also:
paper moistened with water in suspect at-
LITMUS TURNS BLUE IN:
70 sec.
6.5 sec.
1 sec.
Immediately
Sense of smell is good gauge of conc.d5).
Draw suspect air through 0.01N sulfuric acid (with
methyld3) red indicator), at a known rate, until in-
dicator changes. Cone, of NH3 can be calculated, know-
ing air volume of sample.
ARSINE, AsH3
PROPERTIES:
A colorless gas with a density of 2.7 X aird7), solubility is 20
vol. AsH,
in 100 vol. H2O at 20°
C. Arsine is inflammable.
ODOR:
Slight garlic-like odord7).
SOURCES:
Results whenever nascent hydrogen is formed in a solution
containing arsenic'25). Thus, it can occur in any soldering,
pickling, etching or plating process involving metals or acids
containing arsenic(15). Possible in manufacturing of zinc
chloride, HCL, H2SO4 and smelting of arsenic containing
ores d3>.
ATTACK:
Arsine has an affinity for hemoglobin of the red blood cells.
After it is absorbed by these cells it is oxidized to arsenic oxide
which causes hemolysis (breakdown) of the red cells. If severe,
this hemolysis results in great diminution of red cell count,
kidney damage due to clogging by cellular debris, and jaun-
dice (14) as it is absorbed through the lungs.
SYMPTOMS:
Acute: Starts with feeling of illness and weakness, followed by
nausea, vomiting and epigastric pains. Vomiting becomes
continuous and productive of blood(14). Urine can be dark,
bloody and/or completely retained. After a day or two, severe
jaundice and cyanosis and death may occur. Symptoms usually
start 4 hrs. or more after exposure*!4); sometimes 1 or 2
days'13'. Chronic: Yellowness of skin, hemoglobin in ur-
ine, malaised") d3).
-------
178
Air Pollution Control Field Operations
REMARKS:
Poor warning characteristics, despite low odor threshold, be-
cause of extreme toxicity of low concentrations'2**).
TOXICITY:
CONCENTRATION
(P.P.M.)
0.05
0.5
3.1
1 to 10
100 to 200
250
500
PHYSIOLOGICAL RESPONSE
Maximum allowable cone., 8 hrs.'22)
Odor threshold (22)
Maximum allowable cone, for several hrs.
without serious effects 113'
Probably dangerous'17)
Immediately hazardous to life'17'
Fatal after l/2 to 1 hr.(14>
Lethal in a few minutes'13)
TESTS:
Mercuric chloride test papers'16'
Silver nitrate test papers'16)
Detection tubes containing silica gel impregnated with AgNO3:
for squeeze bulb aspirators, are in prospect.
CARBON DIOXIDE, CO2
CHARACTERISTICS:
A colorless gas, density 1.529 X air'13>, (15).
ODOR:
Odorless'13*, (15); (however, at concentrations above 5% it
is perceptible by its physiological actions) .
SOURCES:
Utilized widely in the solid state (dry ice) as a refriger-
ant'15). Occurs universally in gases from combustion of car-
bonaceous material'13'. Respiratory CO2 can be a hazard to
workers in confined places'13). Also present in onion ship-
ments in ships' holds. CO2 is used in, or produced by many
industries.
ATTACK:
C02 is always present in the blood as a normal metabolic
product. It is the primary respiratory stimulus. High concen-
trations cause increased and labored breathing, unconsciousness
and, ultimately, death'13).
REMARKS:
CO2 is toxic only in abnormally high concentrations which
result in overstimulation and ultimate paralysis of the respira-
tory center <13). However, as a constituent of "black damp",
with nitrogen, it can act as a simple asphyxiant by excluding
oxygen'13), (15).
SYMPTOMS:
Respiration rate increases with C02 concentration to the point
of respiratory exhaustion and paralysis'13'.
TOXICITY:
CONCENTRATION
(P.P.M.)
5,000
20,000
30,000
50,000
100,000 (10%)
120,000-150,000
PHYSIOLOGICAL RESPONSE
Maximum allowable concentration'23)
5% increase in lung ventilation'13)
100% increase in lung ventilation'13)
300% increase in lung ventilation' I3'
Can be endured for only a few minutes'13'
Unconsciousness US)
250,000 (25%) After several hrs. death may occur (13)
TEST:
Fyrite C02 tester volumetric: absorption of COj in base, then
measurement of residual gases.
CARBON MONOXIDE — CO
CHARACTERISTICS :
A colorless gas with density 0.967 times that of air<13). Ex-
plosive limits: 12.5 to 24% CO'13).
ODOR:
None'13); practically odorlessdS); slight garlic-like odor,
seldom noticed<2).
SOURCES:
The most universally distributed toxic gas'13). Likely to be
present wherever carbon or organic compounds and fuels are
burned (due to incomplete combustion) <13>. The greatest single
nonindus trial hazard, it causes casualties in residences, gar-
ages and vehicles, as well as in industries'13). High concen-
tration in steel and aluminum furnaces'13). In one study
the average cone, in automobile exhaust gases was 7% COU3).
Enclosed warehouses and freezers using internal combustion
fork trucks.
ATTACK:
Nonirritating and nontoxic to tissues, CO produces its damage
by combining preferentially with hemoglobin of the blood, thus
excluding oxygen from the tissues and leading to asphyxiation
of the cells, especially nerve cells'13). Affinity of CO for
hemoglobin is 300 times that of oxygendO).
REMARKS:
Insidious because of poor warning characteristics (due to ab-
sence of odor, and mildness of symptoms preceding very dan,-
gterousi blood 'levels, especially at high concentrations'13). Fac-
tors causing rapid breathing lead to increased absorption of CO
in the blood'13). Cannister (activated carbon) "gas masks"
cannot be relied on for protection against CO'16).
SYMPTOMS:
Dizziness, headache, discomfort, weakness, heart palpitation,
staggering, confusion of mind, nausea, vomiting, unconscious-
ness, convulsion, weak pulse and slow respiration'13).
TOXICITY:
CONCENTRATION PHYSIOLOGICAL RESPONSE
(P.P.M.)
100 Allowable for eight hrs.(23>.
200 Headache, dizziness, palpitation after 2 hrs.
(active individual)'16'.
400 Headache and discomfort in 2-3 hrs.'13).
500 Headache and discomfort in one hr. (active
individual).
600-700 Slight effect after one hr.
1000-12000 Confusion, nausea in 2 hrs.d*).
Palpitation in 30 min. with light exercised3).
Long exposure could be fatal'16'.
1500-2000 Dangerous for 1 hr. exposure!*3).
2000-2500 Unconsciousness in 30 min.'13>.
4000+ Fatal in 1 hr.dS).
10,000 Symptoms in 3-5 min., rapidly worsening'16).
Very high cone. No warning before collapse.
The above indications of toxicity can be quite variable be-
cause factors other than time and concentration affect blood levels
of carbon monoxy-hemoglobin (including respiration rate and
sometimes acclimatization to low CO concentration) d4'.
The following rule of thumb is brief and useful:
Time (in hrs.) x concentration (p.p.m.) = 300—no appre-
ciable effect <2).
Time X concentration ;= 600 — barely appreciable effect
Time X concentration — 900 — headache and nausea
Time X concentration =1500 — dangerous
TESTS:
M.S.A. Squeeze bulb aspirator with CO detecting tubes (10
P.P.M.)
J W combustible gas indicator 1000 to 70,000 p.p.m. (0.1%
to 7%)
CHLORINE, C12
PROPERTIES:
A greenish-yellow gasd5), density 2.44 X air'3). Not ex-
plosive or inflammable<21), solubility at 20°C. is 2.15 volumes
C12, in 1 vol. of water (is). Corrosive to most metals in moisture
only'21'. It is easily liquefied by pressure!13).
ODOR:
Characteristic choking, pungent odor, irritating to nose and
throat d).
SOURCES:
In manufacture by electrolysis dS), used as a bleach for cot-
ton, flour, etc.'14). Also a hazard where Used as a water
purifier and in production of bleach and organic chemi-
cals'13), para-dichlorobenzene, phenol.
ATTACK:
C12 attacks the entire respiratory tract as well as mucous mem-
branes of the eyes<13>, '14>. It produces irritation, then in-
flammation of the affected tissue, and after severe exposure,
edema of the lung'13), which can result in death. Liquid
C12 can cause skin burns'21).
SYMPTOMS:
Coughing, eye-irritation, labored breathing, general excite-
ment, restlessness, throat irritation, sneezing, copious saliva-
tion, retching, vomiting, extremely difficult breathing'21'.
REMARKS:
Although its odor threshold is above the maximum allowable
concentration (8 hrs.) <14', C12 is considered to have adequate
-------
Detecting and Measuring Invisible Contaminants
179
warning properties of dangerous concentrations*^). Effects
are not cumulative and complete recovery from mild exposures
can be expected <21). It is 20 times as toxic as HCL gas and
probably does most tissue damage by oxidation*14).
TOXICITY:
CONCENTRATION (P.P.M.) PHYSIOLOGICAL RESPONSE
1.0 Maximum allowable cone., 8 hr.'23>.
3.5 Odor threshold (22)
4.0 Max. allowable cone, for short exposure
15
30
40-60
1000
- r..
Least cone, causing throat irritation'14).
Least cone, causing coughing *2i).
Dangerous in y3-\ hr.(2i).
Short exposure <2), (a few deep breaths) can
be fatal.
PLANT DAMAGE:
0.46 Minimum cone, causing damage to buckwheat.
TESTS:
Bubble suspect atmosphere through a midget impinger con-
taining o-tolidine sol. Intensity of yellow color is then matched
with standards <13>. This test can be disturbed by Fe, man-
ganic Mn, NO:*13). There are in prospect o-tolidine indicator
tubes for squeeze bulb aspirator. NH4OH can be used for
tracing and locating CL; leaks.
HYDROGEN CYANIDE, HCN
(Hydrocyanic Acid, Prussic Acid)
PROPERTIES:
A water-white I19', exceedingly volatile liquid with a boiling
point of 26°C*13) infinitely soluble in water*17'; a colorless
gas(13> with a vapor density, relative to air, of 0.93*17'.
ODOR:
Penetrating!13), bitter almonds!17), sweetish bitter almonds*19*.
SOURCES:
Used extensively in fumigation*1*). Can be evolved from metal
plating operations*13), found in other industries, incl. blast
furnaces, dye stuffs works, mining, etc. (13), used as a reagent
in organic chem. mfg. and chemical laboratories (13'.
ATTACK:
A "Protoplasmic poison"*14), HCN is a chemical asphyxi-
ant'15', which interferes with the oxidation processes of tissue
cells*14). As with other types of asphyxiation, nerve cells are
most susceptible and HCN deaths result from, paralysis of the
respiratory center of the brain*16'. It is absorbed, either as
liquid or gas, by any living body tissue, including the intact
skin, but is most dangerous on inhalation*16). Acute HCN
asphyxia is one of the most rapid causes of death*19).
REMARKS:
HCN has relatively poor warning properties because it is not
an irritant*13', and the odor is easily missed*16'. It is exceed-
ingly hazardous for acute exposure*17', but recovery from mild
poisoning is rapid and complete*19). In acute cases, venous
blood assumes the bright color of arterial blood*19'. HCN is a
powerful respiratory stimulus'14'.
SYMPTOMS:
High concentration: rapidly developing giddiness, severe head-
ache, unconsciousness, convulsions*13', *16', *19'. Lower con-
centrations: irritation and dryness and constriction of throat,
indistinct vision, sweating, palpitation,headache*19'.
TOXICITY:
CONCENTRATION
(P.P.M.)
1
10
20
50-60
100
300
200-480
2000
3000
PHYSIOLOGICAL RESPONSE
Odor threshold (of trained personnel) '5'.
Maximum allowable cone, for 8 hrs. *23>.
Slight symptoms after several hours*13).
Safe for one hr.*17).
Very dangerous in one hr.
Death possible from few minutes exposure
Fatal after 30 minutes'14). <19>.
Fatal'13).
Rapidly fatal*17'.
TESTS:
M.S.A. Hydrocyanic gas detector (simplest but not entirely
specific for HCN); phenolphthalin field method (not specif-
ic) US'. Bicarbonate iodine method*13', (requires titration).
HYDROGEN FLUORIDE, HF
(HYDROFLUORIC ACID)
PROPERTIES:
Below 67°F.: A colorless, noninflammable, fuming liquid'19',
very soluble in water. Above 67 °F.: A colorless, noninflam-
mable gas*19', of density 0.71*15', which fumes in moist air
and is reactive and corrosive to many substances.
ODORS:
Pungent, irritating; sharp and penetrating'9>.
SOURCES:
Used as a catalyst in some petroleum refining processes (iso-
merization); also in etching glass, silicate extraction, phos-
phorus extraction, gold refining. A by-product in electrolytic
production of aluminum and processing of phosphate rock for
fertilizer.
ATTACK:
Tissue damage is caused primarily by strong acid properties,
but the fluoride ion is a protoplasmic poison as well*14'. This
acid has a strong irritant and corrosive action on all body tis-
sues'13). Inhalation can lead to respiratory tract inflammation,
lung edema and death'19'. Skin and (especially) eye contact
with vapors or liquid can lead to slow-healing, painful ulcers
or even total destruction of involved tissue'19'. Ingestion yields
G. I. tract damage'19).
SYMPTOMS:
Inhalation: Constricted breathing, coughing, throat irritation,
ulceration of mucous membranes, pulmonary edema(D. Con-
tact: high concentrations cause immediate severe pain and re-
sult in deep ulcers. Low concentrations can result in the slow-
healing ulcers but without the pain accompanying exposure.
Chronic exposure to low concentrations can lead to fluoride
poisoning'17'.
REMARKS:
GOOD WARNING PROPERTIES at immediately dangerous
levels, due to irritating odor. A temporarily trapped victim
might save life by breathing through dry cloth or clothing.
High danger of burns.
TOXICITY:
CONCENTRATION
(P.P.M.)
3 Maximum allowable cone., 8 hr.US', (23),
10 " " " l/2-lhr.'20).
30 Sour taste, smarting of eyes for several min.(25).
60 " " apparent, irritation of eyes and nose (25).
120 Same, including irritation of skin(25),
respiratory tract.
50-250 Dangerous for short exposure.
1800 Fatal to animals within 5 min. (25'.
PLANT DAMAGE:
0.1 ppm for 3-4 hrs. yields minimal effects.
TEST:
M.S.A. Hydrogen fluoride detector.
HYDROGEN SULFIDE, H2S
PROPERTIES:
A colorless gas with a density, 1.19U5) x air, explosive limits
are 4.3%-46% by vol.<19>. It is corrosive to many metals*19'.
Solubility is 3 volumes H2S to one vol. H2O at room tempera-
ture*19).
ODOR:
Characteristic foul odor of rotten eggs*19'. Not reliable as
warning of dangerous concentrations*19'.
SOURCES:
Refinery gases, crude oil*13). Sulfur recovery plants. Some
metallurgical processes*15'. Various chemical industries using
sulfur-containing compounds'15'. Certain "mineral" wat
Decomposition of organic material (as sewage wastes) *14'.
ATTACK:
Irritating to eyes and respiratory tract'19'. H2S blocks oxida-
tive processes of tissue cells (probably by enzyme poison-
ing) U8)? thus affecting early the susceptible nerve cells and
leading ultimately to death through paralysis of the respiratory
center of the brain*19'.
waters.
-------
ISO
Air Pollution Control Field Operations
SYMPTOMS:
Acute: Slow heart respiratory increase, respiratory paralysis,
convulsions, deathd8). Subacute: Headache, sleeplessness, diz-
ziness, pain in eyes, conjunctivitis.
BEMARKS:
Though the odor of H2S is readily recognizable in low concen-
trations, detection of dangerous concentrations by smell is
unreliable and unsafe because of olfactory fatigue, which
occurs quickly at high concentrations; and also occurs, though
slowly, at lower concentrations*!6).
TOXICITY:
CONCENTRATION PHYSIOLOGICAL RESPONSE
(P.P.M.)
0.13-1.0 Odor threshold(22), (17).
20 Maximum allowable cone., 8 hrs.<23>.
100 Olfactory fatigue in 2-15 min.d7).
Irritation of eyes and resp. tract after 1 hr. d6).
Death in 8-48 hrs. (18).
170-300 Maximum allowable for 1 hr.d9>.
Eye irritation in 6-8 minutesdS).
400-700 Dangerous after 30 minutes - 1 hr.d9).
600+ Fatal in 30 minutes < 19 >.
700-900 Rapid unconsciousness, respiratory arrest and
death (18).
1000+ Immediate unconsciousness and rapid death*16).
TESTS:
M.S.A. squeeze bulb aspirator with H2s detection tubes.
Lead acetate ampules (for warning purposes).
Lead acetate paper (warning or can be quantitative).
NITROGEN OXIDES (Nitrous Fumes)
REMARKS (H):
There are many oxides of nitrogen. Of the total, only two need
be considered as common toxicants in air pollution and in-
dustry. These are nitrogen dioxide NO2 (or nitrogen tetroxide,
or peroxide N20j, its isomeric form) and nitric oxide NO.
Nitric oxide is oxidized further to nitrogen dioxide (2NO +
OS-»2NOS)-
PROPERTIES («):
The equilibrium 2 NOs
N204 favors nitrogen dioxide as
the temperature increases. At 40°C., the mixture is a yellow
to brown gas, depending on concentration. The density is
1.59 X air. It is soluble in water, forming nitric acid. The gas
is corrosive to many metals. Does not form explosive mixtures
with
ODOR (17):
Pungent, sweetish.
SOURCES:
A product of high temperature combustion. Also found as
product or by-product in the following industries: Metal clean-
ing, fertilizer, explosive'15', nitric acidd6*, mfg. H2SO4 (by
chamber process) d3), photographic film, carbon arc combus-
tion d3). It is also formed by the action of nitric acid on oxidi-
zable materials (14).
ATTACK:
An irritant gas (15), NO- produces its injury by reacting with
the alkalies of lung tissues (14). In sufficient amounts this leads
to edema of the lungs which can result in deathd7). The
edema may arise a number of hours after exposure.
SYMPTOMS:
NO2 is among the most INSIDIOUS of gasest"). Since it
fails to set up respiratory reflexes (13), a victim may breathe a
fatal amount without significant discomfortd4). Hours after
an acute exposure, the victim develops a dry cough, shortness
of breath and restlessness which can progress to frothy sputum
tinged with blood, massive edema and death by "drowning" in
body fluids (I*). High concentrations may produce moderate
irritation and coughing at time of exposure'17).
TOXICITY:
CONCENTRATION
PHYSIOLOGICAL RESPONSE
(P.P.M.)
5 Odor threshold (22).
5 Maximum allowable concentration, 8 hrs.(23).
62 Least cone, causing immediate throat irrita-
tion!").
75-100 Visual threshold d7).
100 Least cone, causing coughingd4)
100-150 i/2-l hr. dangerousd4), (15).
200-700 Rapidly fatal for short exposured4)
700 Fatal in 30 minutes or less d3).
Because of POOR WARNING PROPERTIES, it is prudent to
leave an area where NO2 can be smelled or its presence sus-
pected.
TEST:
Suspect air is drawn into an evacuated bottle (to equilibrium)
which contains a small amount of Saltzman's reagent. The
resulting color change is read on a colorimeter.
OXYGEN, 02
REMARKS:
Oxygen is not a toxic gas<13>, but is included here because its
diminution and absence can result in functional impairment
and ultimately death by anoxia.
PROPERTIES:
Colorless, active gas.
ODOR:
Odorless.
SOURCES:
O2 comprises 21% of the atmosphere d4); however, very
dangerously low partial pressure of O2 can occur, from various
causes, in enclosed spaces and at extremely high altitudes^4).
Other causes of anoxia within the body include mechanical
obstructions to breathing*14), drugs which paralyze the respira-
tory center, and poisons such as carbon monoxide and hydrogen
cyanide which prevent tissue utilization of O2 d4).
ATTACK:
Complete lack of oxygen at the cell level stops the energy
yielding processes that are essential to life.
SYMPTOMS:
Progressive impairment of behavior, judgment and self control
to unconsciousness, failure of respiration and arrest of heart
beat. Lack of Oz alone is not easily sensed by the victim, thus
anoxia acts INSIDIOUSLY d4). Severe nonfatal anoxia may
lead to permanent brain tissue damage.
RESPONSE TO REDUCED 02 TENSION (20):
CONCENTRATION PHYSIOLOGICAL RESPONSE
(P.P.M.)
21% (normal Normal
atm. cone.)
12%-16% Breathing volume increase, pulse rate increased,
thinking ability diminished, muscular coordina-
tion upset.
9%-14% Judgment faulty, emotions aroused, irregular
respiration.
6%-10% Nausea, vomiting, bewilderment, loss of con-
sciousness.
6% Gasping, convulsive movements, cessation of res-
piration, death.
TESTS:
Pyrite oxygen tester.
(Below 16% O2 a flame is extinguished) d3).
OZONE, O3
PROPERTIES:
A colorless gas<17>, of low solubility, but of intensely irritating
action (14). Density 1.655 X air.
ODOR:
Characteristic pungent odor*17).
SOURCES:
Prepared (technical scale) by exposure of O2 to brush dis-
charges(l3). Used for bleaching (flour, oils, waxes, etc.), for
sterilizing drinking water d3>. Produced in smog by atmos-
pheric photochemical reactions d7>.
ATTACK:
Because of low solubility, O3 acts primarily on the lungs'20' as
a strong irritant (14), and can lead to delayed pulmonary edema
and death!").
SYMPTOMS:
Low concentrations (1 + P.P.M.) produce dryness of eyes and
respiratory tract, and headache d7). Higher concentrations can
lead to typical symptoms of delayed lung edema d7), (difficulty
in breathing, frothy sputum with blood, arrest of breathing,
death).
-------
Detecting and Measuring Invisible Contaminants
181
REMARKS:
Although the characteristic odor is easily detectable at very
low concentrations, this gas must be considered insidious,
since physiological reactions are out of proportion to danger
accompanying exposure.
PHYSIOLOGICAL RESPONSE
TOXICITY:
CONCENTRATION
(P.P.M.)
0.02-0.05 Odor threshold! 17).
0.1 Maximum allowable cone., 8 hrs.!17', (23).
1+ Dryness of eyes and respiratory tract!17), head-
ache.
2 Probably safe for a few minutes!17).
50 Might be fatal for 30 min. exposure.
TESTS:
Rubber cracking.
PHOSGENE, COC12 (Carbonyl Chloride)
CHARACTERISTICS:
A liquid boiling at 8°C(13'; at standard conditions a colorless
gas of density 3.45 X air!13'.
ODOR:
Described as "musty hay"!13); sometimes as "new mown hay".
SOURCES:
Thermal decomposition of chlorinated hydrocarbons!13), (from
de-greasers, cleaning plants and CCla used as fire extinguish-
ers) ; used in manufacturing of dyestuffs, Pharmaceuticals,
organic chemicals*13).
ATTACKS:
Damages primarily alveolar epithelium, leading to pulmonary
edema, often delayed*16).
SYMPTOMS:
Immediate symptoms produced by even a fatal exposure may
be mild!13'. Elicits no marked respiratory reflexes<13). How-
ever, inhalation of higher concentrations produces choking,
coughing, slight lachrymation, and tightness of chest!13'.
REMARKS:
Possibly fatal concentration can be below odor threshold!16).
Thus, poor warning properties.
TOXICITY:
CONCENTRATION PHYSIOLOGICAL RESPONSE
(P.P.M.)
1 Maximum permissible for 8 hr. exp. <23>.
3.1 Least cone, that affects throat!14).
4 Least cone, that causes eye irritation!14).
4.8 Least cone, that causes coughing!14).
5 Prob. fatal for 30 min. exposure!16).
5.6 Odor threshold!").
165 50% mortality on 2 min. exposure*16).
TEST:
Filter paper impregnated with diphenylaniine and p-dimethyl-
amino benzaldehyde*13). (Color chart)*16).
Nitroso reagents and other methods*13'.
PHOSPHINE, PH3 (Hydrogen Phosphide)
PROPERTIES:
A colorless gas with density, 1.46 X air<24), Solubility is 26
gm. in 100 gm. of water at 17°C.
ODOR:
Foul odor, slightly resembling decayed fish.*25).
SOURCES:
Action of water oh metal phosphides (as with Ca phosphide
contaminating Ca carbide in manufacturing acetylene) (13>,
extraction of phosphorus!25), etc.
ATTACK:
Action on the body is not fully worked out*26). It appears to
cause central nervous system depression and irritation of the
lungs*26). Necropsy findings sometimes include heart dilation
and pulmonary edema *26>.
SYMPTOMS:
Acute exposure: Restlessness, tremors, drowsiness, nausea,
vomiting!25), gastric pain, diarrhea, thirst!26), substernal cold-
ness and pain<25>, bronchitis, lung edema, convulsions and
death!25). Chronic: Similar to phosphorus poisoning*25).
Anemia, nervous disorders, gastrointestinal disturbances (26).
PHYSIOLOGICAL RESPONSE
REMARKS:
Very toxic gas for both acute and chronic exposures!26), warn-
ing properties relatively poor for low concentrations.
TOXICITY:
CONCENTRATION
(P.P.M.)
0.05 Maximum allowable cone. 8 hrs.<13), <22>, (23>.
1.5-3 Minimum perceptible cone.!25)
7 Maximum cone, not causing symptoms in several
hrs.<25>.
100-200 Maximum allowable concentration, Y2-l hr.*25)
290-430 Dangerous to life after one hr.(25>.
400-600 Death can follow exposure of yz-\ hr.*2S).
2000 Rapidly fatal.
TESTS:
Meter a known volume of suspect air through a tube packed
with silica gel impregnated with silver nitrate, then measure
length of black coloration in tube*.
* Analytical Chemistry, Vol. 29, pp. 1665-1666, November 1957.
SULFUR DIOXIDE, SO2 (Sulfurous Acid Anhydride)
PROPERTIES:
A colorless liquid below -10°C., SO2 is a colorless gas with
density 2.26 X air *26', solubility: 79.8. vol. S02 to 1.0 vol.
H20 at 0°C.; 18.8 vol. SO2 is noninflammable and is corrosive
to many metals (in moisture).
ODOR:
Characteristic pungent, suffocating odor*26). Odor of "burning
sulfur" *25>.
SOURCES:
Formed wherever sulfur, sulfur-containing petroleum products,
sulfur-bearing coal, etc., are burned in air*25). Mfg. of paper
by sulfite process*13'. Used as refrigerant,fumigant, etc.(26).
Commonly an air contaminant over large cities*1").
ATTACK:
SO, is an irritant of the mucous membranes of the respiratory
tract and the eyes *15'. High concentrations can produce
edema of the lungs or glottis and can cause respiratory paral-
ysis. Information on SO2 metabolism is inadequate!1*). Burns
from liquid S02 result from freezing effect <18).
SYMPTOMS:
Acute: Lower concentrations, sore throat, cough, high con-
centration, hoarseness, oppression and pain in chest, difficulty
in swallowing; very high concentration, acute bronchitis, pul-
monary edema, cyanosis and death*1*). Chronic: Pallor, anor-
exia!18', increased nasopharyngitis, upset of taste and smell*25).
REMARKS:
Good warning characteristics, since it readily elicits respiratory
reflexes*13'. High concentrations become intolerable before
reaching immediately dangerous levels. No apparent irre-
versible damage from chronic or nonfatal exposures.
TOXICITY:
CONCENTRATION PHYSIOLOGICAL RESPONSE
(P.P.M.)
.03-1.0 Threshold (probably taste) <2«>.
3 Easily noticeable odor.
f> Maximum allowable cone., 8 hr.*23).
6-12 Immediate irritation of nose & throat*26), cough-
ing*1).
20 Least amount causing eye irritation*26).
50-100 Maximum allowable cone., 1 hr. *26).
400-500 Immediately dangerous to life*26), immediate
feeling of suffocation*19'.
!,350 Median lethal concentration for mice (10-minute
exposure).
10,000 (Not breathable) irritating to skin in a few min-
utes I26'.
PLANT DAMAGE:
0.04 P.P.M. for 7 hours, injures most susceptible species.
TESTS:
M.S.A. Aspirator tester with S02 detecting tubes, starch iodate
papers <16>.
-------
182
Air Pollution Control Field Operations
—1
E.
D.
F.
Figure XI - 10. Photographs of portable field-testing equipment: A—Tutweiler apparatus, B—explosimeter, C—halide leak detector,
D—squeeze bulbs and ampules for H»S testing, E—squeeze bulbs and ampules, from left to right: carbon monoxide, sulfur dioxide (also
used for aromatic hydrocarbons and hydrogen cyanide), and hydrogen fluoride testers, F—test papers, G—Parsons Engineering particu-
late sampling device suitable for use in tracer studies, H—Fyrite CO2 and O2 analyzer, I—Ion chamber.
-------
Detecting and Measuring Invisible Contaminants
III ON-THE-SPOT TESTING
183
H.
A knowledge of the physiological response to con-
taminants is thus of use in making quick and some-
times crucial estimates of air pollution problems in any
environment. While the inspector cannot make accur-
ate determinations of concentration on the basis of
sen.se perceptions only, he at least may be able to
identify pollutants, allow for hazardous concentrations,
and trace them to a logical source. In order to elimin-
ate guesswork and to establish identity and concentra-
tion within a reasonable degree of accuracy some field
sampling equipment is required. Such equipment, to
be of use in enforcement, must be portable, require a
minimum amount of equipment and field preparation,
be of a direct-reading type, yet substantially accurate.
In the Enforcement Division of the APCD an on-
the-spot-testing program is conducted by the Refinery
Section which mans three especially equipped emer-
gency test vehicles on a rotation basis. The use of
these radio-equipped test vehicles extends considerably
the District's ability to quickly identify and track down
sources of air pollution which may be otherwise diffi-
cult to locate. A noxious or malodorous gas may orig-
inate from almost any point and spread over an entire
community. A test car can be dispatched to the scene
in a short time. The inspector manning the car is
skilled in the use of the testing equipment and is pre-
pared to test for the contaminant and trace it quickly
to its source.
Noxious gases, odors, vapors and phenomena for
which tests can be made in the field and which require
no collection of samples for laboratory analysis are al-
dehydes, ammonia, aromatic hydrocarbons (benzene,
toluene, styrene, xylene) atomic radiation, bee spots,
carbon dioxide, carbon monoxide, chlorine, combusti-
ble gases and vapors, organic halides, humidity, hydro-
gen cyanide, hydrogen sulfide, mercaptans, oxygen
(deficiency) and sulfur dioxide.
Operation of such equipment is beyond the scope
of this manual. Instructional manuals are issued with
the equipment on purchase. Here we shall point out
the major types of such field equipment.
Testing equipment is added to test vehicles when
proven to be reliable. The reagents and equipment
used for testing as well as concentration ranges and
thresholds are shown in Table XI-2. This equipment
includes the following:
A. Test Papers
Certain types of simple sensitized papers will
change color in the presence of physiologically signifi-
cant concentrations of noxious gases, fumes or dusts.
These can be used to test for or to verify the existence
of certain suspected contaminants such as ammonia,
hydrogen sulfide and phosgene. For example, am-
monia reacts with litmus to produce a red to blue color
change. Concentrations of ammonia from 0 to 1,000
ppm. can be detected by this method. Similarly, hy-
-------
184
Air Pollution Control Field Operations
drogen sulfide may also be detected with lead acetate,
phosgene with diphenylamine, etc.
B. Squeeze Bulbs and Ampules
These generally consist of two arid three ounce
squeeze bulb aspirators and glass tube ampules packed
with impregnated granules. These granules stain, color
or bleach in specific gas/solid reactions. The reagent
in the granule surfaces gives colorimetric reactions
when contaminated air is drawn through them. These
are commercially available as the Mine Safety Appli-
ance gas testers constructed for specific contaminants
as shown in appropriate places in Table XI - 2.
C. Tutweiler Apparatus
This apparatus is used to determine concentra-
tions above 150 p.p.m. of hydrogen sulfide, sulfur di-
oxide, ammonia and carbon dioxide in stack analyses,
etc., by gas/liquid titrations. The apparatus consists
of a 110 ml. burette serving as a gas/liquid reaction
chamber with a leveling bottle; and a 10 ml. graduate
mounted on top of the burette through a two-way
cock. The third outlet of the cock, the gas inlet tube,
is open to the atmosphere to be tested or connected by
a tygon tube to the gas sample.
D, Reich's Test
This test is performed specifically to make volu-
metric determinations of SO2 by gas/liquid titration.
A metered amount of contaminated air is bubbled
through a solution of water, iodine and starch in a
graduated cylinder until a color change is observed.
An amount of iodine equivalent to .2% of S02 in 1000
ml. of air is used in the solution, providing a calibra-
tion point.
E. Midget Impingers and Gas Absorption Cells
These are used for collecting particulate matter,
aerosols and mists and are aspirated with a small 6" x
10"x5" hand-operated pump, as in the case of the
M.S.A. midget impinger. These employ the impinge-
ment principles described earlier in this chapter. The
samples collected are analyzed in the field.
P. Halide Leak Detector
This equipment, based on Beilstein's reaction, is
used for the determination of the concentration of halo-
genated hydrocarbon vapors such as freon, carbon tet-
rachloride, trichlorethylene and perchlorethylene. It
consists of a small LPG fuel tank fitted with a micro-
burner that has a copper ring reaction plate above the
flame tip. A rubber tube sampling line feeds the con-
taminated air to the burner by natural draft. The
flame color for a specific contaminant at an unknown
concentration is compared with a color chart to esti-
mate the concentration.
G. Measurement of Volume Change
These include principally the Fyrite C02 and 02
analyzer shown in Table XI-2. Carbon dioxide is
measured by the volume change resulting from absorp-
tion in caustic and oxygen by absorption in pyrogallic
acid.
H. Explosimeters or Combustion Meters
These are used for testing combustible gases, i.e.,
carbon monoxide, natural gas, hydrocarbon vapors,
similar to the explosimeters used by the gas companies.
A three-foot metal tube probe is connected to the port-
able meter by a length of rubber tubing. The meter is
operated on self-contained batteries and uses a two-
ounce squeeze bulb to aspirate samples through the
reaction chamber.
/. Geiger Counters and Ion Chambers
These are for use in radiological monitoring in the
field in the event of disaster. A.P.C.D. personnel are
given a sixteen-hour training course in the use of these
instruments. All District vehicles are equipped with
ion chambers since the A.P.C.D. has been designated
by the Board of Supervisors as responsible for this
phase of civil defense.
IV SAMPLING FUELS AND EFFLUENTS —
FUEL AND EQUIPMENT REGULATION
Some categories of equipment, particularly those
in refineries, produce predictable quantities of known
"invisible" pollutants. For example, for each 1000 gal-
lons of petroleum stocks stored in the open or in un-
controlled vessels some 100 pounds of organic vapors
are lost to the atmosphere each day. When these pet-
roleum products are stored or handled in large quanti-
ties, the loss may be considerable. Because the emis-
sion rate is relatively constant with product and temp-
erature, the problem of "invisible" pollutants is read-
ily solved by prescribing the use of control equipment
which will reduce this loss to acceptable limits. In this
instance, the storage of petroleum products is brought
to acceptable limits either by the use of a floating roof
or a vapor recovery system (Rule 56 below).
Regulations which prescribe equipment or fuel as
a direct means of control symbolize a high degree of
technological progress in the field of air pollution con-
trol, in that they are certain and directly enforceable,
and are relatively unaffected by the human factor.
The APCD Rules of this type are as follows:
Rule 56 — Storage of petroleum products.
Rule 59 —• Oil-effluent water separators.
Rule 61 — Gasoline loading.
Rule 62 — Sulfur content of fuel oil.
Rule 63 — Olefin content of gasoline.
Rule 64 — Rendering odors.
-------
TABLE XI-2.
CONTAMINANTS WHICH CAN BE TESTED IN THE FIELD WITH PORTABLE DEVICES*
CONTAMINANT
Aldehydes
Ammonia
Aromatic Hydrocarbons
1. Benzene
2. Toluene
3. Xylene
4. Styrene
Arsine
Carbon Dioxide
Carbon Monoxide
Chlorine
Combustible Gases
Hydrocyanic Acid Gas
Hydrogen Fluoride
Hydrogen Sulfide
Nitrogen Dioxide
Ozone
Oxygen Deficiency
Phosgene
Phosphine
Sulfur Dioxide
REASON FOR TESTING REAGENT OR
OR SOURCE TEST EQUIPMENT USED
Eye Irritation
Complaints
Odor Complaints
Odor Complaints
" "
ii u
" "
Odor Complaints
Plating Operations
Exhaust Complaints
Exhaust Complaints
Cylinder Loading &
Bleach Mfg.
Venting Storage Tanks
Odor Complaints
Rule 56 and Rule 59
Plating Processes
Phosphate Rock
Odor Complaints
Refineries and
Chemical Processes
Atmospheric
Safety Level from
Air Purifiers
Closed Vessels or
Room
Thermal Decomposition
of Organic Halides
Mfg. of Acetylene
Complaints
Rule 53a
Rule 62
a. Preparation in minutes
b. 'Test or Sampling
Absorption in Sodium
Bisulfite
M.S.A. Midget Impinger
Red Litmus & Stop Watch
M.S.A. Aromatic Hy-
drocarbon Detector
" "
It U
" "
M.S.A.Arsine
Detector
Fyrite CO, Analyzer
M.S.A. CO Detector
O-Tolidine in the
M.S.A. Midget Impinger
M.S.A. Model 40
Combustible Gas
Indicator
M.S.A. Hydrocyanic
Acid Gas Detector
M.S.A. Hydrocyanic
Fluoride-in-air
Detector
M.S.A. H,S Detector
Saltzman Reagent
Rubber Cracking
Fyrite Oxygen
Analyzer
Treated Filter Papers
Treated Granules
M.S.A. SO, Detector
Treated Granules
Reich's Test
Tutweiler
c
d
TREATMENT OR TIME REQUIRED CONCENTRATION EIGHT-HOUR23 SUFFICIENT WARNING
REACTION OBSERVED a b c RANGE OF TEST THRESHOLD LIMIT WITHOUT TESTING
lodometric
Titration
Color Change to Blue
Colors. Treated Gran-
ules. Stain Length
Measured
" "
tt u
" "
Treated Filter Papers
Change Color
Absorption in Caustic
& Measure Vol. Change
Colors. Treated Gran-
ules — Color Change
Color Intensity Com-
pared to Standards
Direct Reading
Instrument
Treated Granules
Orange Color
Treated Filter Papers
Change Color
Treated Granules
Change Color
Color Change Measured
Time Interval of
Cracking Measured
Absorption
Measure Volume Change
Color Change
Compared to Standards
Color Stain Length
Measured
Length of Bleaching
Action Measured
Gas Titration
Gas Titration
10
1
10
10
10
10
10
1
1
10
1
10
5
1
1
10
5
5
5
10
10
10
5
1
2
2
2
2
2
3
2
5
2
2
5
2
1
20
5
5
5
2
10
10
10
0
0
0
0
0
1
0
2
2
2
0
0
0
d
2
0
1
2
0
5
5
0-
10-
0-
0-
0-
1000 ppm
100 ppm
100 ppm
400 ppm
400 ppm
Qualitative
0-
0-
0-
0-
0-
0-
.5-
0-
0-
0-
0-
1 -
1 -
1-
100 ppm
20%
1000 ppm
70 ppm
20 x LEL
50 ppm
5 ppm
50 ppm
10 ppm
100 ppm
21%
100 ppm
10 ppm
150 ppm
.20%
.5 to 5.0 ppm
100 ppm
25 ppm
200 ppm
200 ppm
100 ppm
0.05 ppm
5000 ppm
100 ppm
1 ppm
10 ppm
3 ppm
20 ppm
5 ppm
lOpphm
18-21%
1 ppm
5 pphm
5 ppm
Yes — Eye Irritation
Yes — Odor
Yes — Odor
Yes — Odor
Yes — Odor
Yes — Odor
No
No
No
Yes — Odor for Immedi-
ately Dangerous Levels.
No — for Low Cone.
Some Yes — Odor
Yes — Odor — by
Trained Personnel
Yes — Odor for Immedi-
ately Dangerous Levels.
No — for Low Cone.
No — Odor Is
not Reliable
Not Reliable
No
No
No
No
Yes — Odor
c?
1
V)
*••* .
0<5
ft.
i*
8
K
3'
£>
3
PS.
§
3
3'
3
PS.
"
50 Grains /ft3
. Calculation and Interpretation
. Laboratory Analysis
* Prepared by
Maurice Fykes
Senior Engineering Inspector
"•*.
00
-------
186
Air Pollution Control Field Operations
In most instances, the enforcement of these rules
will involve sampling of fuels or materials before
emission to the atmosphere, and checking maintenance
and operation of equipment.
A. Rule 56 —Storage of Petroleum Products,
Rule 56 requires that any tank or reservoir of
more than 40,000 gallons capacity storing petroleum
products of a vapor pressure of 1.5 pounds per square
inch absolute or greater under actual storage condi-
tions must use either a floating roof type of vapor con-
trol adequately secured against leaks, provided that the
vapor pressure does not exceed 11.0 pounds per square
inch absolute or greater under actual storage condi-
tions; or a vapor recovery and vapor disposal system
which prevents the emissions of hydrocarbon vapors
and gases to the atmosphere, or other equipment of
equal efficiency.
Figure XI - 11. Reid vapor pressure bomb and gauge.
The important check points in determining com-
pliance are the vapor pressure, the efficiency of the
control device and the quality of operating and main-
tenance practices. A vapor loss can be detected by the
hissing sound of gas under high pressure, by refraction
of light (which casts shadows), or by condensation of
the moisture from the air with subsequent formation
of frost on the leaking valve which has been cooled by
the sudden expansion of the escaping gas.
The vapor pressure of a liquid is that pressure
exerted by the molecules of the liquid to change from
the liquid to the vapor state. If the vapor pressure is
below that of the pressure of the atmosphere, the
molecules will remain in the liquid state. However,
by increasing the temperature of the liquid, the vapor
pressure begins to increase rapidly. When the vapor
pressure exceeds the atmospheric pressure, the sub-
stance vaporizes. The boiling points of substances indi-
cate, as a matter of fact, the points at which they
vaporize. Substances of high vapor pressure thus vol-
atilize at lower temperatures than substances of low
vapor pressure.
Vapor pressure is measured in pounds per square
inch absolute at actual storage conditions. Reid vapor
pressure is a measurement taken in the petroleum in-
dustry by means of an A.S.T.M. Reid Vapor Pressure
Bomb and Gauge (Figure XI-11). The Reid measure-
ment is made by carefully sampling the liquid in a
bomb and by immersing it in a water bath,temperature
at 100°F. The vapor pressure is thus rated at this ele-
vated temperature. The Reid vapor pressure is usually
about 5 to 9 per cent lower than the absolute pressure,
although this relationship will vary widely (see Figure
XI-12). A grab-sample of the product can be taken by
the inspector in a 1 qt. or 2 qt. tin which is sealed tight
and refrigerated as soon as possible when brought to
the laboratory.
Petroleum products with vapor pressures greater
than 1.5 Ibs. per square inch absolute consist generally
of cracked petroleum stocks and distillates such as gas-
oline, aviation gasoline, propane or butane (L.P.G.),
some jet fuels, and some solvents and naphthas. In
questionable cases a Reid vapor pressure test may be
taken at the refinery with refinery facilities, or a
sample taken to the APCD Laboratory. If one is taken,
the storage temperature should be recorded.
The inspector also checks the equipment for leaks,
maintenance of gas-tight seals on floating roof tanks,
or degree of malfunctioning of vapor recovery systems.
B. Rule 59 — Oil-Effluent Water Separator
Rule 59 in essence states that no compartment of
a single or multiple compartment oil-effluent water
separator which receives effluent water containing 200
gallons a day or more of any petroleum product from
any equipment processing, refining, treating, storing
or handling kerosine* or other petroleum product of
equal or greater volatility, can be used unless such
compartment is equipped with one of the following
vapor loss control devices:
a. A cover totally enclosing the liquid contents
or
b. A floating roof pontoon or double-deck type or
c. A vapor recovery system or
d. Other equipment of equal efficiency approved
by the APCD.
* Rule 59 defines "kerosine" as "any petroleum product which,
when distilled by ASTM standard test Method D86-56, will
give a temperature of 401°F. or less at the 10 per cent point
recovered".
-------
Detecting and Measuring Invisible Contaminants
187
VAPOR PRESSURE OF GASOLINES
180 -3
J
170 -^
160-
150-
140-
130-
120-
1 10-
100-
90-
80
70-
60-
50-
40-
30-
20-
10-
o-
.e:
.9-
1.0 :
-
•
* SLOPE OF DISTILLATION + LOSS |.5~
CURVE (A.S.T.M.). •F®l5%-"Fff5%
10 ]
IN THE ABSENCE OF DISTILLATION «ftj
DATA THE FOLLOWING AVERAGE
SLOPES MAY BE USED: i
•F/% Q J
LIGHT NAPHTHAS (F.B.R-300'F) 2.5 SLOPE
NAPHTHAS tF.B.P-400'F) 4 01234
AVIATION GASOLINES 2 ^ ill 30-
7 MOTOR GASOLINES 3 ~ L-l+lfZ ' '
OT 2*J I // j
v> LI HI :
ri" sJ-J/jj-s ^ 4-0-
i 4—4- • 1 O :
71 rTjJT to
C" 4HllJr4 tf> so-
0 C_l I "^
" ?" ^ eW5 ' i
cc lu ("* J 5E j
- ? § 8iH-rIr7 w 70^
ff w "p^ sg oj ;
IU Ul j^Jjjjf9 J fto"
- 5 * I2rw'° «r ' "
•*• ft» ^ Tvj V O9 0~
/*N ** if*1 12 CL
| IBJhfflfw ^ 10^
o ^iW'e o ":
C /Nfl8 f 12-
20 13-
EXAMPLE: DETERMINE THE TRUE 14!
VAPOR PRESSURES AT 320F, IOO°F J
AND ISO^F OF THE FOLLOWING 15 "
GASOLINE: Ig -
REID VAPOR PRESS. - 9.0 LB&/SO. IN. ._ ;
DISTILLATION t LOSS, 5% 9 120 «F ' -
I5%@I60«F I8t
19-
SLOPE= jeoiiio .4.o«F/% 20-
K>
TRUE VAPOR PRESSURES CORRE-
SPONDING TO A R.V.R OF 9.0 LBS./
SO. IN. AND A SLOPE OF 4.0°F/%
ARE READ FROM THE CHART AS
FOLLOWS:
TEMPERATURE TRUE VAPOR PRESS.
•F LBS,/ SO. IN.
32 2.6 30-
100 9.9
ISO 21.4
-40
-50
-60
-70
-80
-90
- 100
- 150
-200 ^
u.
O
2
i
-300 ^
IT
2)
U)
(/)
LU
-400 £
-------
188
Air Pollution Control Field Operations
DIAGRAM OF A VAPOR RECOVERY SYSTEM
REPRESSING GAS HEADER,
COMPRESSOR SUCTION HEADER\
A WET GAS RE6ULATOR--
A REPRESSURING GAS REGULATOR
I WET GAS SCRUBBER
2 ABSORBER
3 STRIPPER
4 CONOENSATE ACCUMULATOR
5 GAS COMPRESSOR
6 LEAN OIL COOLER
7 FAT OIL HEATER
8 HEAT EXCHANGER
9 FAT OIL PUMP
10 STRIPPER REBOILER
II STRIPPER CONDENSER
DRAIN WATER
Figure XI -13. Diagram of a vapor recovery system.
MODERN OIL-WATER SEPARATOR
To Vapor Reco'
Waste Water Draw
To Water Disposal
Oil-Water In
Transverse Openings
Figure XI - 14. Diagram of an oil-water separator.
Legs
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Detecting and Measuring Invisible Contaminants
189
This does not apply to any separator used exclu-
sively in conjunction with the production of crude oil.
Petroleum products generally affected by this rule
are kerosine and other products of equal or greater
volatility such as jet fuels, paint thinner, cleaner and
naphtha (Stoddard solvent), the various grades of gas-
oline and possibly some Liquefied Petroleum Gas
(L.P.G.). Processes affected by this rule are generally
related to absorption, thermal and catalytic cracking,
crude distillation, laboratory areas, barrel cleaning
(light oil), alkylatioii, polymerization, kerosine and
lighter oil treating, light oil redistillation, gasoline sta-
bilization, and tanks and shipping points connected
with the above.
Figure XI - 15. Vapor collecting adaptor forms vapor-tight seal
between adaptor and hatch.
To aid in determining volatility, the inspector
may trace effluent water flow from individual pieces
of equipment, identify waste products from each, and
note any intermediate treatment prior to disposal of
the effluent water in the separator. If the inspector
suspects that the volatility of any of the products in the
separator i s equal to or greater than kerosine, he
takes a sample to the APCD Laboratory for analysis.
C. Rule 61 — Gasoline Loading into Tank Trucks
and Trailers
Rule 61, in essence, states that any loading facility
on any premises where more than 20,000 gallons of
gasoline are loaded in one day into any tank truck or
trailer must be equipped with a vapor collection and
disposal system.
If loading is effected through the hatches of a
tank truck or trailer, the loading arm must be
equipped with a vapor collecting adaptor so as to force
a vapor-tight seal between the adaptor and the hatch.
If loading is effected through other means, all
loading and vapor lines should be equipped with fit-
tings which make vapor-tight connections and which
close automatically when disconnected.
For the purpose of Rule 61, any petroleum distil-
late having a Reid vapor pressure of four pounds or
greater is included by the term "gasoline".
To ascertain compliance with Rule 61, the in-
spector must identify the product loaded. All racks on
premises loading gasoline or petroleum distillates hav-
ing a Reid vapor pressure of four pounds or greater,
such as Liquefied Petroleum Gas (L.P.G.), some naph-
thas, some jet fuels and some solvents, are affected by
this Rule. In doubtful cases, samples should be brought
to the laboratory for analysis.
The quantity of gasoline or petroleum distillates
loaded each day should be determined. The company
files can be checked for the total quantity in gallons of
petroleum distillates loaded from each rack for any one
day. If there is more than one rack on the premises,
the gallons loaded from all racks is taken as a daily
total. If a premises load more than 20,000 gallons in
any one day, it is affected by this rule.
The inspector inspects the presence and operation
of the controls in the following manner:
1. Check all fittings for vapor-tight connections. Note
whether they close automatically when discon-
nected.
2. Check for vapor-tight seals between adaptors and
hatches.
3. Check whether drainage from the loading device
is prevented when it is removed from the hatch of
the tank or trailer.
4. Check efficiency of control of vapor collection and
disposal system.
D. Rule 62 — Sulfur Content of Fuels
Rule 62 is quoted here in full.
RULE 62. SULFUR CONTENT OF FUELS. A per-
son shall not burn within the Los Angeles Basin at any
time between May 1 and September 30, both dates in-
clusive, during the calendar year 1959, and each year there-
after between April 15 and November 15, both inclusive, of
the same calendar year, any gaseous fuel containing sulfur
compounds in excess of 50 grains per 100 cubic feet of gas-
eous fuel, calculated as hydrogen sulfide at standard condi-
tions, or any liquid fuel or solid fuel having a sulfur content
in excess of 0.5 per cent by weight*
The provisions of this rule shall not apply to:
a. The burning of sulfur, hydrogen sulfide, acid sludge
or other sulfur compounds in the manufacturing of sulfur
or sulfur compounds.
t. 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
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190
Air Pollution Control Field Operations
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 com-
bustion are used as raw materials for other processes.
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 gas-
eous 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 public enemy, or failure of the
supplier.
1. Gaseous Fuel
To determine compliance with Rule 62 of gaseous
fuels two separate tests are required: (1) determina-
tion of heat value (Btu) and (2) determination of
sulfur loading.
These tests need not be performed on fuel lines
containing commercially available natural gas only,
since natural gas meets the specifications of Rule 62.
Two types of refinery gas fuels will, however, re-
quire the inspector's attention. These are: (1) refinery
"make" gas derived from light ends from processes and
sweetened or diluted in mixing drums, and (2) re-
finery waste gases generally arising from tail gases
from H2S absorption and waste water stripping sys-
tems, or any gas which is not diluted and sweetened.
"Make" gas in refinery fuel distribution systems
generally has a heat value in excess of 300 Btu as speci-
fied in the Rule and need only be tested for an excess
of 50 grains as described below. "Make" gas usually
complies with Rule 62 due to dilution with natural gas.
However, sulfur loading tests are conducted routinely,
and especially upon observance of a visible plume.
The waste gas, on the other hand, should be tested
for heat value and sulfur loading. The pressure gauge
is removed from the waste gas line and a probe con-
nected to a combustible gas indicator is inserted for
testing of heat value. The combustible gas indicator
acts as a thermocouple that has been previously cali-
brated for on-scale readings by use of a proper size
dilution orifice (see Figure XI-16).
If the gross heating value exceeds 300 Btu/ft3,
then the sulfur loading must be determined. The test-
ing is accomplished in the field by applying an MSA
H2S tester which gives colorimetric reactions. The
H2S tester (Figure XI-10D) is applied at the pressure
gauge of the waste gas line by means of a nipple,
adaptor and a T-joint whenever the waste gas fuel line
is under greater than atmospheric pressure (see Figure
XI-7). The sulfur loading of this gas is determined by
measuring the length of the stain on the impregnated
granules. If the reading is in excess of 25 grains with
5 squeezes of the bulb, an excess of 50 grains is indi-
cated. A sample should be taken to the laboratory to
determine actual grain loading so that the necessary
enforcement action can be taken.
* Emphasis supplied — ed.
Waste gases under less than atmospheric pressure,
usually those originating from sour water stripping
operations and introduced into combustion zones by jet
or steam injection, must be sampled in an evacuated
gas sample bottle adequately equipped with stop cocks
applied to the line by means of a straight adaptor. The
sample is then brought to the laboratory for analysis
(see Figure XI-8).
2. Liquid or Solid Fuels.
To determine compliance with Rule 62 of solid
or liquid fuels an adequate sample must be collected
from the fuel line and taken to the laboratory for anal-
ysis to determine sulfur loading of the fuel.
Assuming that equipment is in good order and is
being operated correctly, a visible emission is a good
indication that this rule is being violated. A sample of
the fuel should then be taken.
Excessive sulfur content in liquid or solid fuels
may be suspected, also, by the known specifications of
the fuel being used. Fuel specifications are given in
terms of:
Grade
Description
Bunker No.
API Gravity
Specific Gravity "Be1
Btu/lb.
Dens. Ib/Gal.
Specific Gravity
Whenever a value given for any of these fuel
specifications correlates closely with .5 per cent sulfur
by weight, a sample should be taken. It should be cau-
tioned, however, that sulfur content varies consider-
ably within any specification category, depending on
the geographical source of the crude. The specific sul-
fur content should be ascertained from purchase
receipts or through inquiry.
If the inspector cannot through interview of the
operator or examination of fuel oil receipts determine
the API gravity, he ascertains some other fuel specifi-
cation which he correlates with sulfur content. If he is
in doubt and cannot acquire any specifications, he
should take a sample.
Fuel oil samples should be collected in 1 or 2
quart tins.
E. Rule 63 — Gasoline Specifications
RULE 63. GASOLINE SPECIFICATIONS:
a. A person shall not, after June 30, 1960, sell or sup-
ply for use within the District as a fuel for motor vehicles
as defined by the Vehicle Code of the State of California,
gasoline having a degree of unsaturation greater than that
indicated by a Bromine Number of 30 as determined by
ASTM method D1159-57T modified by omission of the
mercuric chloride catalyst.
b. A person shall not, after June 30, 1962, sell or
supply for use within the District as a fuel for motor ve-
hicles as defined by the Vehicle Code of the State of Cali-
fornia, gasoline having a degree of unsaturation greater
than that indicated by a Bromine Number of 20 as deter-
mined by ASTM method D1159-57T modified by omission
of the mercuric chloride catalyst.
c. For the purpose of this rule, the term "gasoline"
means any petroleum distillate having a Reid vapor pres-
sure of more than four pounds.
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Detecting and Measuring Invisible Contaminants
f
191
I
Figure XI -16. Measuring gross heating value on a refinery
waste-gas line with a combustible gas indicator.
Figure XI - 17. Application of JLS Tester to the waste-gas line.
Figure XI - 18. Application of an evacuated gas sample bottle
to the waste-gas line under negative pressure.
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192
Air Pollution Control Field Operations
Compliance with Rule 63 must be determined by
laboratory analysis of sample taken at retail pumps.
The bromine number is the number of grams of bro-
mine consumed by 100 g. of the sample when reacted
under given conditions. The sample is dissolved in a
specific solvent and titrated with bromide-bromate so-
lution at 0 to 5°C. The end point is indicated by a dead
stop electrometric apparatus.
The bromine number is approximately 60% of
the olefin content. A bromine number of 20 is ap-
proximately equivalent to an olefin content of 12!/2%,
that of 30 to 18%, etc. (ASTM, ASTM Standards, 1957
Supplement, Part 5, 1968, p. 81).
Figure XI - 19. Equipment used in determining excessive brom-
ine values of gasolines in the field.
To avoid costly and time consuming laboratory
analyses of all field samples collected, a modification
of the ASTM method has been devised by Fykes,
Clawson and Kuramoto for direct field testing(28).
This modification does not give the bromine number of
each sample, but quickly indicates whether the sample
is above or below a bromine number of 30. By chang-
ing reagent quantities this test can also be made to
indicate bromine number values above or below 20 etc.
Only those samples which then indicate an excessive
bromine value are brought to the laboratory for de-
tailed testing. The procedure employed is quoted from
Fykes et al below.
This simple test consists of adding a measured sample of the
gasoline to be tested to a measured volume of reagent (see pro-
cedure below), followed by the addition of a solvent and agitating
the mixture for 30 seconds. If the resulting mixture shows a
yellow color, from a faint tinge to strong yellow, the gasoline is
below 30 bromine number. (The yellow color is due to unreacted
bromine). If the reaction mixture is water "white" the gasoline
is above a bromine number of 30. Gasolines which "fail" this
test can be sent to the laboratory for more precise ana^sis. Dyes
used in some gasolines need not confuse the operator. All color
is bleached out by the free bromine liberated during the test
reaction.
The equipment needed for each testing "kit" is as follows:
EQUIPMENT QUANTITY
Flask, Ehrlenmeyer, 125 ml. 1
Polyethylene washing bottle, 500 ml. 1
beaker, 100 ml. 1
pipette, 1 ml. 1
Graduated pipette, 10 ml. 1
Stock bottle for reagent, 3 ounce 1
Stock bottle for solvent, 1 quart 1
CHEMICALS
Reagent: Dissolve Sl.Og KBr and
water and fill to 1 liter
13.92g KBrOa in distilled
Solvent: 714ml. glacial acetic acid
134 ml. carbon tetrachloride
134 ml. methyl alcohol
18 ml. sulfuric acid (one to five)
GASOLINE SAMPLING PROCEDURE
Sampling container: 4 oz. can with screw cap
1. Fill container with fresh gasoline.
2. Cap immediately and use for field test.
3. Return sample to station operator if it passes or deliver
to the laboratory at headquarters as soon as possible if
it fails field test.
TEST PROCEDURE
1. Pipette 5.5 ml. of reagent into the Ehrlenmeyer flask,
with the 10 ml. pipette.
2. Pour 50 ml. of solvent into the beaker (fill to mark).
3. Pipette exactly 1.0 ml. of the gasoline to be tested into
the reagent in the Ehrlenmeyer flask, with the 1.0 ml.
pipette.
4. Quickly add the solvent from the beaker to the mixture
in the flask. (The acid in the solvent liberates bromine
from the reagent.) Agitate (swirl) mixture in flask for
30 seconds.
5. Read result.
(CAUTIONS: (1) Blow out the last drops of reagent
and gasoline sample remaining in the pipette tip after
free flow has ceased. (2) In pipetting take care to avoid
drawing materials into the mouth.)
CLEANUP
Rinse the Ehrlenmeyer flask with tap water and drain;
then rinse it twice more with a small quantity of distilled water
after each test. Blow through 1 ml. pipette after each test.
The beaker and 10 ml. pipette need not be cleaned between
tests at any one location. After finishing tests at any one location
rinse beaker and 10 ml. pipette in same manner as flask.
DISCUSSION
Field and Laboratory Appraisal.
The results from more than 150 tests using the field method
in the laboratory and in the field agree with results obtained by
ASTM D1159-59T (electrometric titration).
This method uses an arbitrary visual end point. No temperature
control is used.
1. Catalyst. To establish the effect of a catalyst in this test, a
series of samples were tested with and without the use of the
catalyst HgCL. The results from the two were identical.
2. Temperature. All tests were made at ambient temperatures.
The increase in temperature upon the addition of the
bromide-bromate solution was found to be approximately 1 °C.
3. Visual End Point. The retention of some degree of yellow
color, due to the presence of unreacted free bromine, for
thirty seconds is the arbitrary limit set for samples passing
the test. Samples turning water clear in less than thirty
seconds fail this test. All dyes encountered so far are imme-
diately decolorized by the free bromine. The following varia-
tions in color and clearing time were noted from synthetic
samples of hexene—2 and N—heptane but no attempt will
be made to calibrate these phenomena:
-------
Detecting and Measuring Invisible Contaminants
BROMINE NUMBER
2-20
24-26
26-29
30
31.3
34-35
40-50
50-64
PHENOMENA
dark yellow-orange
medium yellow
light yellow
colorless after 30 sees.
colorless after 5 sees.
colorless after 3 sees.
colorless after 2 sees.
colorless instantly
After Color. Some reaction mixtures on standing for several
minutes (1-3 with catalyst; 3-5 without catalyst) develop a
pink or orchid color. This color bears no relation to the test
results.
4. Critical Point. This test is critical for samples with a bro-
mine number of thirty. By not blowing out the last drop of
bromide-bromate solution from the pipette the sample under
test retains its color only fifteen seconds, thereby failing the
test. The proper blowing out of the last drop causes the
yellow color to be retained in excess of thirty seconds. By
not blowing out the last drop of the gasoline sample, border-
line (30-31) bromine numbers pass this test.
5. Reagent Stability. Work to this time, including the routine
gasoline analyses indicates that the bromide-bromate reagent
is quite stable, and possibly much more so than the standard
olefin composed of hexene-2 and heptane. If the higher
temperatures of summer field work tend to make the reagent
less stable they would also tend to change the composition of
the standard olefin, which must be exposed to air at each
use. An example of the stability of the Br-, BrOs- solution
under laboratory storage conditions is:
One solution varied only 0.0002 normality after
storage for one month (standardized at' 0.5027N,
and a month later, at 0.5029N). Errors of much
greater magnitude (0.02±) are inherent in the nec-
essary assumption of 0.73 for the density of the gas-
oline samples. The reagent is described as stable in
Scott's Standard Methods of Chemical Analysis.
6. Low Actinic Glassware. Low actinic glassware is used for
storage of bromide-bromate solution and the titration solvent.
7. Fpur-oz. Sample Cans. A four-fluid-ounce sample is a suffi-
cient quantity for this test. The problems of cost of the
gasoline (less than Ic in most cases) and confiscation (32
samples are needed to make a full gallon) are avoided. The
cans cost approximately lOc each.
REFERENCES
1. Wilcox, J. D., Isokinetic Flow and Sampling, Journal of the Air
Pollution Control Association, 5, 226 (1956).
2. Kanter, C. V., Lunche, R. G., Fudurich, A. B., Techniques of
Testing for Air Contaminants from Combustion Sources, Journal
of the Air Pollution Control Association 6, No. 4, 191-199
(1957).
3. U. S. Public Health Service, "Source Sampling and Analysis,"
Air Pollution Training Manual, Cincinnati, Ohio.
4. Greenburg, L., and Smith, G. W., A New Instrument for Sam-
pling Aerial Dust, U. S. Bureau of Mines, R. I. 2392 (1922).
5. Bloomfield, J. J., and Dallavalle, J. M., The Determination and
Control of Industrial Dust, Public Health Bulletin No. 217,
(1935).
6. Dallavalle, J. M., Note on Comparative Tests Made with the
Hatch and Greenburg-Smith Impingers, Public Health Reports
(U. S. Public Health Service), 52, 1114, (1937).
7. Mader, P. P., Hedden M. W., Lofberg, R. T., and Koehler,
R. H., Determination of Small Amounts of Hydrocarbon! in the
Atmosphere, Anal. Chem. 24, 1899 (1952).
8. Goldman, F. H., and Yagoda, H., Collection and Estimation of
Traces of Formaldehyde in Air. Ind. and Eng. Chem. Anal.
Edition 15, 377 (1943).
9. Glater, J., The Determination of Oxides of Nitrogen by the
Phenoldisuljonic Acid Procedure, Chemical Methods Notebook
APCD (1953) (Unpublished).
10. Beatty, R. L., Berger, L. B., and Schrenk, H. H., Determination
of the Oxides of Nitrogen by the Phenoldisuljonic Acid Method,
U. S. Bureau of Mines R. I. 3687 (1943).
11. Jacobs, M. B., Analytical Chemistry of Industrial Poisons, Haz-
ards and Solvents, Interscience Publishers, Inc., N. Y., p. 354
(1949).
12. Physiological response data compiled by J. S. Clawson, Enforce-
ment Division, L. A. Co. Air Pollution Control District.
13. Jacobs, M. B., Analytical Chemistry of Industrial Poisons, Inter-
science Publishers, New York, 778 p. (1949).
14. Henderson, Y., Haggard, H. Noxious Gases, Reinhold Publishing
Corp., 294 p., (1943).
15. Baily, J. F., Jennings, B. H., Toxic Gases and Vapors in In-
dustry, Technologic Institute, Northwestern University, 142 p.
(1944).
16. Great Britain, Department of Scientific and Industrial Research,
Methods for the Detection of Toxic Gases in Industry, H.M.S.O.
(leaflets) (1945).
17. American Industrial Hygiene Association, Hygienic Guide Series
(series issued periodically) 1957.
18' American Petroleum Institute, American Petroleum Institute
Toxicological Review, 1959.
19. Manufacturing Chemist's Association, Chemical Data Safety
Sheets, April, 1960.
20. Shilen, J., Noxious Gases, Pennsylvania Department of Health,
June 1952.
21. The Chlorine Institute, Inc., Chlorine Manual, 2d ed., New
York, 32 p., 1954.
22. Manufacturing Chemists's Association, Air Pollution Abatement
Manual.
23. American Conference of Governmental Industrial Hygienists,
Threshold Limit Values for 1959, A.M.A. Archives of Industrial
Health.
24. Lange, N. A., Hand Book of Chemistry, Handbook Publishers,
Sandusky, Ohio, 1934.
25. Patty, K. A., Industrial Hygiene and Toxicology, 2nd ed., Inter-
science Publishers.
26. Sax, N., Dangerous Properties of Industrial Materials, Reinhold,'
N. Y., 1467 p.
27. Coordinating Research Council, Handbook, pp. 244-254 (1946).
28. Fykes, Jr., Clawson, J. S., Kuramoto, M., Field Test for Olefins
in Gasoline, L. A. Co. A.P.C.D., Enforcement Division, April,
1960.
-------
CHAPTER TWELVE
TRACKING SOURCES OF PUBLIC NUISANCES:
ODORS, STAINS AND DEPOSITS
I THE PUBLIC NUISANCE PROBLEM
Up until now control standards have been treated
in terms of proscribing exact concentrations, effluent
loadings, or opacities of air contaminants, thus provid-
ing an unequivocal basis for legal action. A type of
air pollution problem shall now be dealt with, which is
characterized by an adverse effect of a certain but
unpredictable quantity of a contaminant on the health,
welfare or comfort of a significant community of per-
sons. The effect may be an odor sensation caused by
the emanation of malodorous gases and vapors; stains
on surfaces of property resulting from impaction or
deposition of liquid particles, usually of an acidic na-
ture; nuisance deposits generally arising from dusts
or fly ash; or toxicity or plant damage arising from
the presence of toxic contaminants.
The public nuisance is typically an urban problem.
Incidents of nuisance thus increase with population and
chaotic growth patterns, especially when industrial
plants encroach upon residential areas and vice versa.
The more compact mixed industrial-residential com-
munities, the smaller the concentrations and quantities
of contaminants necessary to create a public nuisance.
The public nuisance is always first manifest by a
reaction on the part of a segment of the public. The
air pollution configuration here must be worked back-
wards from effect to cause, i.e., the contaminant or
contaminants causing the nuisance must be tracked
from the complainant to the source by the field in-
spector. Sometimes the source of the nuisance may be
obviously known to the community, or, as in many
cases, it may be completely unknown. In some cases
multiple sources may exist, or an entire industrial
community may contribute to a nuisance. In still
other cases, sources may be situated at remote distances
from complainants.
As an enforcement tool, the public nuisance stat-
ute is awkward to apply, if not frequently ineffective
altogether, for three important reasons(7):
1. Lack of Definite Emission Standards. Public
nuisance rulings do not involve emission stand-
ards which are as definite as maximum permissi-
ble emission standards. Because small quantities
of pollutants create odors or nuisance deposits in
some situations and not in others, no prohibitory
emission level can be logically established. The
principle difficulty here involves incomplete
knowledge concerning the range of human atti-
tudes towards nuisances. It is conceivable that
further knowledge regarding susceptibility and
air quality will increase and that standards will
inevitably be applied which will eliminate most,
if not all nuisances. For the present, we can only
restrict and control specific practices which are
known to emit nuisance contaminants.
2. Difficulty of Relating Source, Contaminant and
Nuisance. Proof must be shown of the nuisance
value of a contaminant or class of contaminants,
as distinguished from other possible contaminants,
and that the contaminant originates from a speci-
fic piece of equipment at an address-location, even
though many plants may be found in the vicinity
capable of emitting the same type of contaminant.
Thus, rigorous tracking techniques and proof
may be required. The evidence necessary may be
difficult, if not impossible to obtain in some sitj
uations.
3. Unreliability of Testimony from a Considerable
Number of Persons. This is the greatest weakness
of the public nuisance case. Even though all com-
plainants may agree that a nuisance exists, con-
siderable disagreement as to quality, severity, time
of occurrence of the nuisance, etc., usually arises.
Testimony must withstand rigorous cross-exami-
nation by a defense attorney and sustain a judicial
finding that annoyance, discomfort or injury oc-
curred, all nebulous terms in the eyes of jurists.
For these reasons, the enforcement agency may
employ means to solve a nuisance without enforcing
the nuisance statute. It may (1) apply some other rule
or law which will accomplish the same result, (2)
motivate voluntary correction on the part of manage-
ment, or (3) promulgate corrective legislation to estab-
lish new per se standards for specific contaminants,
equipment or fuel regulation.
With regard to (1) above, various other regula-
tions can be enforced in public nuisance cases, such as
those employed by the A.P.C.D. below:
Section 24279. PERMITS. This law, in effect, requires
plants to secure permits prior to installing or operating
equipment. If, after scrutiny, equipment causing nuisances
do not have valid operating permits, they can be eliminated
through the permit system.
Section 24280. PERMIT CONDITIONS. All equipment
is required to meet exacting standards before an operating
permit or authority to construct is issued. Permits can be
strictly conditioned in regard to operational and mainte-
nance procedures. Operation of equipment contrary to the
conditions of the permit is, therefore, a violation.
REVOCATION PROCEEDINGS. Old unconditioned per-
mits granted by virtue of Rule 13 can be revoked through
hearing board procedures if violations or nuisances are
observed. New permits issued under improved operating
conditions can be applied for by management. These then
may be severely conditioned. This procedure, however, is
not as effective as taking nuisance cases to court.
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196
Air Pollution Control Field Operations
Rule 19. SAMPLING FACILITIES. This rule requires
that plant operators erect and maintain appropriate sam-
pling facilities. This rule enables inspectors and testing
personnel to sample discharges from stacks to determine
more exact compliance with maximum permissible emission
standards, or to more thoroughly evaluate nuisance con-
taminants.
OTHER LAWS. Any other laws involving visible or in-
visible air contaminants are automatically enforced.
The promulgation of new specific legislation (i.e.,
maximum permissible emission, fuel or equipment reg-
ulation) generally follows engineering or technical
solutions to air pollution problems. Contaminants
which were previously public nuisances only in fact
become nuisances per se by the passage of rules with
definite contaminant standards. For example, such
District Rules as 52, 53, 54 and particularly 57, 58, 62
and 64 automatically eliminate a multitude of inci-
dents which previously created public nuisances. In
an active control program new rules incorporating
specific standards tend to obviate the use of the public
nuisance statute.
Problems which cannot be solved by specific con-
taminant, equipment or fuel regulations must still be
treated as public nuisances, however. Especially is this
true in the case of the odor nuisance. Various means
of measuring odor quality and intensity have been
developed by means of odor surveys (organoleptic
methods) and vapor dilution but these are still inad-
equate for development of odor standards for legisla-
tion comparable to the smoke standard. In the absence
of such standards, odor cases must still be generally
handled as public nuisances.
A public nuisance, then, in any active control
program, is a problem for which there is no standard
solution. Solutions are encouraged through enforce-
ment action. Once a legal nuisance is established, the
plant operator will either be required to abandon the
specific nuisance-causing operation, or develop reme-
dial or alternative methods of operation.
A. Tracking the Nuisance
In a routine inspection of an industrial plant, the
inspector traces the normal air pollution configuration,
as described in Chapter 9, from cause to effect —
from the feed input of equipment to the effects of the
contaminant generated from the equipment on re-
ceptors and the environment. The tracing of an air
pollution problem reported as a public nuisance is just
the reverse of this procedure. The investigation begins
with the complainant and his environment and works
back to the equipment responsible in the following
steps:
1. Interview of complainants to obtain as much factual infor-
mation as to the intensity, evidence and source of the con-
taminant. (See Chapter 8).
2. Identification of the contaminant causing the nuisance.
3. Tracking the contaminant to its source or sources.
4. Inspection of the equipment at the source to determine
plant's capacity to emit the contaminant.
5. Collecting signed district attorney forms from complainants
who desire to testify in court.
6. Serving notices of violation to the source, or motivating plant
management to remedy the situation.
Most of these techniques are described in appro-
priate sections of this manual. This chapter is primar-
ily concerned with the problem of tracking and identi-
fying sources of public nuisances, assuming that the
source is not immediately determined.
In a public nuisance, the field inspector must
establish the existence of two areas: the effect area,
that is, the geographical boundaries containing the
complainants, in addition to the area over which the
nuisance effect is widespread; and the source area —
that area which can be assumed by logical tracking
techniques to contain the specific source or sources of
the nuisance contaminant. The determination of a
source area is often a first step in isolating the exact
source and cause of the nuisance, especially in those
cases where the specific source is difficult to establish
initially.
1. Determining Air Flow from Source
The basic problem in a public nuisance is to posi-
tively establish the flow of air masses from a source of
air pollution to establish responsibility, or to determine
relative contributions to a nuisance problem from two
or more sources. This procedure is otherwise known
as source tracking, and is especially applied when the
source of the nuisance is originally unknown. This
basically involves determination of wind direction and
velocity for the purpose of triangulating the source.
In source triangulation, only two vectors are re-
quired, i.e., wind directions taken on separate occasions
and locations at times of nuisance occurrence. Wind
direction is always ascertained from the direction in
which it is blowing. (A south wind blows from the
south.) Wind direction can be determined from flags,
steam or smoke plumes, finger-wetting, or, in the case
of acid stains or nuisance deposits, by the pattern of
increasing deposition on surfaces. A more accurate
determination of air flow can be made with balloons
(See "Tracking Odors," this Chapter).
The interview with the complainant should also
attempt to establish, particularly in the case of odors,
the wind direction at the time of contamination. In
fact, the inspector should instruct complainants in
recurring problems to maintain a record of time, in-
tensity and wind direction. If this is not possible, the
inspector should attempt to estimate the time the con-
tamination is likely to occur, so that he can logically
schedule reinspections.
In complex cases involving heavily industrialized
communities with many possible sources, or where
contamination or nuisance does not appear to be local-
ized according to wind direction, the inspector may
plot a wind rose, based on his estimates of wind direc-
tion and intensity. (See Figure XII-1.) A check with
the Air Analysis Section of the A.P.C.D. may disclose
prevailing wind patterns and other pertinent micro-
meteorological data for the area in question.
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Tracking Sources of Public Nuisances: Odors, Stains and Deposits
197
A.- 8-10:00 A.M. -3-5 MPH
B. - 10-12:00 N - 1-2 MPH
C - 3-4:30 P.M. - 3-4 MPH
D - 2-3:00 P.M. - 5-6 MPH
E - 12-2:00 P.M. - 3-4 MPH
Figure XII - 1. Plotting of a wind rose for chronological
changes in direction and velocity of the wind.
A conclusive determination of air flow movement
may be made by tracer studies utilizing tracer materi-
als and aerosol filter sampling devices'5-10'12'261.
Tracer material may consist of fluorescent dusts,
spores, lycopodium powder, radio-active materials,
neutron activation powders, zinc cadmium sulfide or
zinc silicate, or other material which can be recognized
and counted under a microscope and which range in
size from 1.5 to 2 microns in diameter. Tracer materi-
als can be either introduced into an effluent system at
the source of air pollution or blown by portable blower
equipment into the atmosphere near the suspected
source. Inspectors may be simultaneously deployed
according to wind flow for sampling in or near the
reception and suspected source areas. The greater the
distance to the suspected source area, the greater the
number of detection stations required. The sampling
is also performed either under atmospheric conditions
which occur during the nuisance or during periods of
atmospheric stability.
In complex cases, the following tracking results
are recorded on a map: (See Figure XII-3.)
1. Location of complainants and distances from possible sources.
2. Plant source layout showing principal types of equipment
which may be involved.
3. The number of complaints, and frequency of complaints as
well as the time of day.
4. Observations by inspectors at various points to fill in any
gaps in data.
5. The tracked contaminant routes and vectors of triangulation.
6. Wind roses or other indications of wind direction.
Of course, the requirements of each problem will
dictate the type of map or notation system which will
be required. Such maps are not only of assistance in
systematically tracking down a nuisance, but are use-
ful in hearings or in court cases as demonstration
evidence. For such maps, the Beaufort system for des-
ignating wind direction and intensity is useful. (See
Figure XII-2.)
II ODORS,
The interesting fact about odors is the enormous
ability of humans to respond to thousands of distinct
odor stimuli, and to detect contaminants which may
originate from sources at relatively great distances.
Odors can be detected in concentrations of gaseous
materials as low as 1 part per billion parts of air. For
this reason the nose has often been characterized as
one of the best known devices for gas analysis. At the
same time, the average person appears to lack the nec-
essary vocabulary to describe odors.
A major difficulty in measuring odors is that an
odor is not an air contaminant but an effect of an air
contaminant on humans*. To be more precise, it is a
sense-perception conveyed to the brain by nerve end-
ings and sensory cells in the nose. Like all sense per-
ceptions, intensity of sensation depends not only on the
intensity of the stimulus but on the sensitivity of the
percipient. For this reason, the capacity in humans to
* However, Section 24208 of the California State Health and
Safety Code defines an odor as an air contaminant.
MILES PER HOUR
0 0 - Calm
\ _D ] - 3
0 4 - 7
0 8 - 12
\\
\\v
\\V
_0 13-18
JO 19-24
J) 25-31
RIGHT HALF
3 Night
0 Day
(J Dawn
0 Twilight
LEFT HALF
Q Clear
(0) Cloudy
g) Snow
(J) Rain
® F°8
Reporting Station
Complainant
Figure XII - 2. Meteorological code used as designations in fieldnuisance surveys by Johnson and Kempe (Reference 11).
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198
Air Pollution Control Field Operations
11:50 P.M.
3M.P.H..1:30P.M.
M-R *
233 1C.
LEGEND
— Direction from which wind is blowing:
• Complainant's Report
O Inspector's Report
R Rendering Odor
L Light
M Moderate
H Heavy
Horse Stable Odors
Aluminum Dross Odors
"B"STREET
3M.P.H. «.
91:45 P.M.^4
M-R
M-R 2M.P.H.
®1:50 P.M.
M-R •
«— O
6M.P.H.
6:30 P.M.
NIL
5 M.P.H.
e6:00 P.M.
"A"STREET
2 M.P.H.
H-R 2 P.M.
3 M.P.H. 91:30 P.M. 23! WEST
M-R • ^
233 W.\ \
ARROW HIGHWAY
CITY OF ONYX
Figure XII - 3. ODOR SURVEY. Although possibly malodorous industries are centered-between Onyx St. and End Road and along the
Onyx Basin River, reports and observations indicate that the Blameless Rendering Company is the primary source of the odors. This find-
ing is verified by the fact that complaints are reported in two time periods — from 11:00 A.M. to 5:00 P.M., from residents north of Ar-
row Highway and west of Onyx Street, when the wind was from the southeast, and from 5:00 to 7:00 P.M., from residents in the area a-
rpund Oakwood Street, south of Arrow Highway, when the wind was from the west. Inspection reports, operating data and point observa-
tions verify the existence of a public nuisance at the Blameless Rendering Company.
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Tracking Sources of Public Nuisances: Odors, Stains and Deposits
199
perceive odors varies considerably, and in the same
person from time to time. Some individuals are very
insensitive to odors (anosmiacs) while others are
acutely sensitive to odors unnoticed by most people.
This fact complicates any estimate of the prevalence
of an odor nuisance.
Sagarin(20) has defined odor as the "property of a
substance (or substances) that is perceived, in the
human higher verberbrates, by inhalation in the nasal
or oral cavity; that makes an impression upon the
olfactory area of the body, and that, during and as a
result of such inhalation, is distinct from seeing, hear-
ing, tasting, and feeling and does not cause or result
in choking, irritation, cooling, warmth, drying, wet-
ting and other functions foreign to the olfactory area."
This definition is of practical use to the field
inspector because it distinguishes between many sensa-
tions which may be confused with odor. In the investi-
gation of odors, the field inspector is concerned only
with establishing whether or not a nuisance is odor-
caused.
Any discussion of odor is likely to be extensive by
virtue of the elaborate attempts that have been made
to objectify this subjective experience. Psychological
and even cultural factors contribute to the favorable
or unfavorable perception of odors. The air pollution
inspector, however, is primarily interested in a legal
definition of an odor problem, i.e., a problem which is
a nuisance to a considerable number of persons over a
continuing or significant period of time. Both elements
in the odor problem are necessary, since little can be
done with an odor which occurs just once.
In such problems, the inspector is concerned with
(1) identifying and rating the intensity of an odor,
(2) identifying the contaminant (odorant) causing the
odor, (3) locating the "odor route", (4) locating the
source of the odorant, and (5) influencing some opera-
tional or engineering control over the odorant.
A. Characteristics
There are a few characteristics about odor percep-
tion which the inspector should be familiar with in
estimating whether an odor problem exists; these are
as follows: <6>-<15>
1. The olfactory sense becomes fatigued after continuous per-
ception of an odor.
2. The sensation of odor is usually detected whenever there has
been a significant change in odor quality or intensity. A
pleasant odor can become objectionable to one who has be-
come used to it under continuous exposure, ljut increased
odor intensity.
3. Odors do not, in themselves, cause physical disease. The
odor of many toxic materials may serve as a warning agent,
however.
4. The ability to perceive odors varies from day to day with
the same person.
5. Compounds of different constitution may yield similar odors,
whereas compounds of very similar constitution may yield
different odors.
6. An unfamiliar odor is more likely to cause complaint than a
familiar one.
7. The perception level of odors decreases with increasing hu-
midity. High humidity tends, however, to concentrate odors
within certain localities.
8. Odor quality may change upon dilution.
9. Some persons are capable of sensing certain odor qualities
but not others.
B. The Odorants and Their Sources
It is not necessary for enforcement purposes to
consider all of the odorants. Nearly all substances
known, excepting those to which one is accustomed
such as oxygen, have an odor. According to Mon-
crieff(i5).> potent odorants generally possess a signifi-
cant degree of volatility and chemical reactivity such
as are exhibited by the aldehydes and various classes of
hydrocarbons. Also, materials of high vapor pressure
tend to yield odors more readily than those of low
vapor pressure.
The average person would find all familiar en-
vironmental odors objectionable were they strong
enough. There is no problem about identifying these
through mental association. Such familiar odors as
coffee, gasoline, moth balls, roses, tobacco, wood smoke,
jasmine, paint, skunk, do not need further definition to
most people and can be termed characteristic odors.
However, there are many odors whose qualities
are familiar though the odorants themselves are not.
These are the so-called chemical odors, as complain-
ants might call them, associated with chemical and
petrochemical processes. The odors of skunk, garlic,
onions and cabbage, for example, may arise from vari-
ous sulfur compounds, ethyl, methyl, propyl and butyl
mercaptans, respectively, generated from oil-refining
processes. These are good examples of the fact that
compounds of different constitution have similar or
analagous odors. Important typical contaminants and
odorants as might be found in the Los Angeles problem
are listed under toxicity and physiological responses in
Chapter 11.
We may further distinguish between strong, pun-
gent "chemical" odors, which offend primarily because
of intensity, and those which are obnoxious or mal-
odorous because of their quality. It is the latter type
which causes most complaints. These tend to be odors
originating from the handling and processing of or-
ganic compounds containing nitrogen and sulfur. The
odors arising from nitrogenous compounds may be
associated with animal odors, decomposition and putre-
faction of animal tissue. The odors arising from sulfur
are characterized by "rotten egg", "skunk", and "de-
cayed cabbage", as well as the acrid, bitter sulfide odors
found in metallurgical operations. (Elementary sul-
f u and nitrogen do not exhibit odors.)
Tke introduction of nitrogen compounds tends to
imbue substances with objectionable animal odors.
Amines, in particular, can have ammoniacal, '^Uy_i_'_
or decayed flesh odors. In the decomposition products of
protein, such as occur in the animal rendering indus-
try, both nitrogenous and sulfurous compounds may
be involved(5). These also contain hydrogen sulfide,
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200
Air Pollution Control Field Operations
putrescine, cadaverine, skatole, and butyric acid. Other
odorous compounds not involving nitrogen include
phenols and cresols employed principally in the man-
ufacture of resins, plastics, disinfectants, inhibitors and
agricultural chemicals(5, 1, 14).
Fortunately, there is fair agreement as to which
activities produce obnoxious odors. Table 1, compiled
by the Air Pollution Control Association, shows the
types of odors most frequently reported by city bu-
reaus. The list here is fairly typical for most industrial
economies, though the order of importance may change
from community to community. Animal odors such as
those issuing from rendering processing are apparently
the most unpleasant and are similarly unpopular in
Los Angeles. The problem they present necessitates
a full-scale enforcement effort.
TABLEXII-K12)
LIST OF ODORS MOST FREQUENTLY REPORTED
BY CITY BUREAUS
SOURCE OP ODOR NO. OP THOSE
REPORTED
I—ANIMAL ODORS
1. Meat packing and rendering plants 12
2. Fish-oil odors from manufacturing plants 5
3. Poultry ranches and processing 4
II—ODORS FROM COMBUSTION PROCESSES
1. Gasoline and diesel engine exhaust 10
2. Coke-oven and coal-gas odors (steel mills) 8
3. Maladjusted heating systems 3
III—ODORS FROM FOOD PROCESSES
1. Coffee roasting 8
2. Restaurant odors 4
3. Bakeries 3
IV—PAINT AND RELATED INDUSTRIES
1. Mfg. of paint, lacquer, and varnish 8
2. Paint spraying 4
3. Commercial solvents 3
V—GENERAL CHEMICAL ODORS
1. Hydrogen Sulfide 7
2. Sulfur Dioxide 4
3. Ammonia 3
VI—GENERAL INDUSTRIAL ODORS
1. Burning rubber from smelting & debonding 5
2. Odors from dry-cleaning shops 5
3. Fertilizer plants 4
4. Asphalt odors—roofing and street paving 4
5. Asphalt odors—manufacturing 3
6. Plastic manufacturing 3
VII—FOUNDRY ODORS
1. Core-oven odors 4
2. Heat treating, oil quenching, and pickling 3
3. Smelting 2
VIII—ODORS FROM COMBUSTIBLE WASTE
1. Home incinerators and backyard trash fires 4
2. City incinerators burning garbage 3
3. Open-dump fires 2
IX—REFINERY ODORS
1. Mercaptans 3
2. Crude oil and gasoline odors 3
3. Sulphur 1
X—ODORS FROM DECOMPOSITION
OF WASTE
1. Putrefaction and oxidation—organic adds 3
2. Organic nitrneen r°*npcmnas—decomposition of protein 2
Above odors are probably related to meat
processing plants.
3. Decomposition of lignite (plant cells) 1
XI—SEWAGE ODORS
1. City sewers carrying industrial waste 3
2. Sewage treatment plants 2
1. Rendering Operations
Because of its universal contribution to odor nui-
sances, the animal rendering problem deserves special
treatment here 1,14).
Animal rendering consists of reducing to solids,
fats and water, animal tissue from inedible meat and
bone scrap derived either from slaughterhouse rem-
nants, or offal from poultry, dogs, cats or other animal
carcasses picked up from the streets. When the render-
ing operation is conducted in a slaughterhouse or meat
packing plant it is termed "captive" or "live render-
ing". Independent Tenderers, on the other hand, com-
prise the animal by-product industry and are concerned
mostly with rendering the carcasses of animals sal-
vaged from the streets. The products generally pro-
duced are tallow, grease, fertilizer, and animal feed.
The processing of whole blood in a liquid form in
slaughter houses or captive rendering operations yields
solid blood meal which also is valuable as fertilizer and
in the manufacture of glue.
Fish wastes in the cannery industry are similarly
rendered to yield such by-products as fish meal, fish
oil and high vitamin content residue. The odors in the
case of fish reduction in canneries differ somewhat
from the rendering plants described above, and are
readily identified by complainants.
Rendering plant odors arise from two sources: (1)
general housekeeping —• the decomposition of animal
tissue and offal in transit or storage prior to processing,
and (2) vapor emissions from improperly controlled
rendering equipment. Odors from the former are gen-
erally sharper than those from vapor emissions, which
are dryer and mustier in quality.
a. "Housekeeping" Odors
A primary source of housekeeping odors results
from the natural and bacterial decomposition begin-
ning at the death of animal tissue.which produces pow-
erful odorants whose potency increases with time and
temperature. These factors are greatly responsible for
obnoxious odors arising from offal whose rendering has
been delayed by transportation and handling. The
arrival and then storage of offal may be sufficient to
create an odor nuisance before processing. Moreover,
some organs such as stomachs and intestines are more
odorous in themselves(27). Captive Tenderers, on the
other hand, are not subject to this problem to the same
extent as the independents since the material to be
rendered is freshly acquired from the slaughter-house.
Housekeeping odors also result from spillage, im-
proper cleaning of plant floors, and storage in the open
while awaiting rendering. The handling of materials
in 5 5-gallon drums which are not properly cleaned
after use alone can create strong odors. This also ap-
plies to captive rendering plants when processing is
delayed by week-end or holiday shut-downs. Monday
mornings, for instance, are considered the most odor-
ous periods in the vicinity of animal reduction plants,
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Tracking Sources of Public Nuisances: Odors, Stains and Deposits
201
due to decomposed cooker feed-stock left from the pre-
vious week(i).
The problem of housekeeping maintenance at
these plants is complicated by the fact that operators
may either be anosmiacs or suffer from chronic odor
fatigue. To control such odors greater cleanliness and
sanitation in the plants are required.
b. Vapor Emissions
The second source of odors arises from vapor
emissions to the atmosphere from improperly con-
trolled process equipment. Equipment involved con-
sists mostly of boilers, dryers, blood spray dryers,
crackling bins, rendering kettles, mixers, holding
tanks, storage tanks, incinerators and "catch basins."
The most important part of the rendering operation
is the cooking or dehydrating of the animal materials
in steam-jacketed cooking vessels at temperatures gen-
erally exceeding 200°F. The cooker effluent contains
mostly steam driven from the animal tissue -— about
99% water. The material cooked generally varies be-
tween 35% to 50% moisture. Fat bone scrap is lower
in moisture content than meat, and results in less
vapor. The remaining one percent in the effluent
consists of the odorous proteins and fats, hydrocarbons,
and hydrocarbon derivatives — hydrogen sulfide, ska-
tole, putrescine, and cadaverine(i4). These materials
may not only be highly odorous as discharged but may
break down on contact with air or sunlight to form
even more potent odorants.
Odors from rendering vapors may travel consider-
able distances and are responsible for most of the com-
plaints from communities neighboring rendering
plants. Under some atmospheric conditions such odors
may travel for many miles.
2. Other Odors
Other odors commonly experienced in Los An-
geles County are hydrogen sulfide emissions (rotten
eggs), mercaptans (garlic and skunk odors) and "sour
gases" from petroleum operations; acid mists from
plating operations (dead cat odors); aluminum oxides
from slag or dross piles; decayed organic matter from
dumps; coffee roasting; paint, lacquer and varnish
odors.
C. Description and Measurement
Whenever inspectors investigate odor complaints
and attempt to establish the existence of a nuisance,
they must identify the odor and odorant, describe its
characteristics in terms of delineating the objectiona-
bility of the odor, and provide some notion as to its
severity. Nader(i6), in describing perceptual measure-
ment of odors in the laboratory, defines the following
set of subjective values which are pertinent to such an
evaluation.
1. Quality
2. Intensity
3. Acceptability
4. Pervasiveness
Although developed primarily for experimental
use, the values are excellent for evaluating odors in the
field. Of these, quality and intensity are of direct con-
cern to field operations. Psychologically speaking, it is
perhaps best to conceive of these terms as "dimensions"
or "components" of odors to place the observer in a
more analytical frame of mind. To the untrained
person, the odor makes primarily one impression. To
the trained observer, it makes several which can be
distinguished. The skill in evaluating odors is not to
confuse the components of an odor sensation.
1. Pervasiveness
Pervasiveness, according to Nader, is sometimes
referred to as odor potential or threshold dilution
ratios.
These essentially are a measure of the ability of an odor to
pervade a large volume of dilution air and continue to pos-
sess a detectable intensity. The odor unit, defined as the
amount of odor in a cubic foot of air at threshold intensity,
is a unit of measure of odor potential. A practical measure
giving information on odor potential is the threshold di-
lution ratio, which is the ratio of odorant concentration to
its threshold concentration. A ratio of 100:1, for example,
would indicate an odor potential of 100 units. This in effect
means that the odorant present in a cubic foot of air is
capable of odorizing 100 cu. ft. of clean air to the threshold
A pervasive odor such as might result from mer-
captans and decomposed proteins, will tend to spread
in all directions over a community. An inspector notes
and records when tracking or establishing odor routes
the general pervasiveness of odors. Such notations in-
dicate the continuity and range of the odorant.
2. Quality
Quality describes the characteristics of odors
either in terms of association with a familiar odorant,
such as coffee, onions, etc. (characteristic odors) or by
associating a familiar odor with an unfamiliar odorant,
by analogy. Aside from such direct descriptive terms,
the observer, in an attempt to be complete and accur-
ate, may add modifiers to his description to indicate
nuance or overtones to the body of an odor. These may
actually include subjective reactions such as "fra-
grant," "foul" and "nauseating ;" or characteristics of
odor which may be associated with the sense of taste
such as "bitter," "sweet," "sour," "burnt," or even,
partially with the sense of touch as far as contaminants
which are irritating are concerned, such as "pungent,"
"acrid," "acidic," and "stinging". As a matter of fact,
a contaminant may sometimes affect more than one
sense. An irritant can affect the sense of smell, cause
eye-irritation, and be tasted.
Odor terminology is meaningless without actual
exposure through odor training. Therefore, the in-
spector should be exposed to samples of typical odor-
ants found in the industrial economy, so that he can be
prepared to make quick and accurate identifications.
There is no substitute for this kind of training. Verbal
descriptions of odors do not implant as vivid an imag-
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202
Air Pollution Control Field Operations
ery in the mind as do descriptions of visual or auditory-
phenomena.
A few of the well-known odor classification sys-
tems are indicated here. They are useful in training
inspectors in making associations and analyzing the
various component sensations which odors may pro-
duce. For field purposes, one system is as good as
another. The advantage of all systems is that they
yield a usable odor vocabulary.
12
11
10
Figure XII-4. ODOR CHART. This chart attempts to present
a complete range of odor terms which can be used to construct
phrases of odor description. Each of these terms, moreover, can
be numerically fixed from a "clock" chart for map notations,
tabulations, or general reporting. Reported by Gruber, and
attributed to Dean Foster, Head of the Psychophysical Laboratory
at the Joseph E. Seagram Co., Louisville, Kentucky.
Henning's Odor Classification^3-13'1
BASED ON SIX TYPES OP ODOR CLASSIFICATION
1. Spicy: Conspicuous in cloves, cinnamon, nut-
meg, etc.
2. Flowery: Conspicuous in heliotrope, jasmine, etc.
3. Fruity: Conspicuous in apple, orange oil, vine-
gar, etc.
4. Resinous: Conspicuous in coniferous oils and tur-
pentine.
5. Foul: Conspicuous in hydrogen sulfide and prod-
ucts of decay.
6. Burnt: Conspicuous in tarry and scorched sub-
stances.
Crocker-Henderson Classification^3-13'1
A CONDENSATION OF THE HENNINO ARRANGEMENT
1. Fragrant or sweet.
2. Acid or sour.
3. Burnt or empyreumatic.
4. Caprylic, goaty, or oenanthic.
3. Intensity
Intensity is some numerical or verbal indication
of the strength of an odor. Intensity may remain con-
stant, vary or fluctuate depending on air/odorant dilu-
tion rates. A gradual increase in intensity is readily
detected, although persons may have become fatigued
by the odor. A sudden increase in odor intensity, how-
ever, such as might be encountered by suddenly open-
ing a flask containing ammonia or chlorine in a room
has an intensity which may be characterized by an
impact. Thu!s, an intensity has shock value, particu-
larly in relation to pungent or putrid odors.
Some general mathematical relationship exists be-
tween quantity of odorant (the stimulus) and odor
intensity in any given situation. Equal degrees of sub-
jective odor intensity are stimulated by quantities of
odorant which have increased geometrically rather
than arithmetically. This phenomenon is described by
the well-known Weber-Fechner Psychophysical Law
which states that the intensity of the sensation is pro-
portional to the logarithm of the strength of the
stimulus, for middling strengths of stimuli'13-19'. Odor-
ometers and other inanimate odor detection equipment
appear to verify this principle both under field and
laboratory conditions. According to Gruber(9), the
Scentometer, devised by the Cincinnati Bureau of Air
Pollution, provides 5 odorous inlets which permit
dilution of 2, 4, 8, 16 and 32 parts total air to one part
odorous air on the assumption that a trained observer
can detect five levels of odor intensity.
Experimental findings on the discernment of odor
intensity are still incomplete. It can be said, however,
that the average observer or complainant can be ex-
pected to distinguish between three intensities, weak,
medium and strong, whereas the expert should be able
to distinguish between those five degrees of intensity
shown below and at least 16 categories of odor qual-
ity (18-19> in the following typical rating scheme:
The intensity of the odor may be noted as follows:
0 A concentration of an odorant which produces no sensa-
tion.
1 Concentration which is just detectable (the threshold
dilution).
2 A distinct and definite odor whose unpleasant character-
istics are revealed or foreshadowed (the recognition
threshold).
3 An odor strong enough to cause a person to attempt to
avoid it completely.
4 An odor so strong as to be overpowering and intolerable
for any length of time.
This rating system is adapted especially for field
work since it is made in terms of the behavior or re-
sponse of a percipient that can be observed by an in-
spector. The response here is clearly one of avoidance.
The fact that a person desperately attempts to avoid
a strong and unpleasant odor clearly indicates the in-
tensity of that odor.
Furthermore, we may speak here of a point at
which the odor may clearly possess a nuisance value
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Tracking Sources of Public Nuisances: Odors, Stains and Deposits
203
in the legal sense. Here again, depending on the num-
ber of complainants, the desires of the complainants to
be witnesses, and the consistency and persistence of the
complaints, odor intensities from #2 on may be capable
of establishing a legal nuisance.
D. Tracking Odors
During the inventory inspection conducted at all
of the industrial plants, inspectors attempt to initiate
correction on all odor potential processes in order to
prevent nuisances. It should be kept in mind, however,
that if a plant is otherwise in compliance, but produces
odors, no nuisance is involved if no one is affected.
The plant, therefore, is not obligated to prevent the
odors. Nevertheless, in such cases, the inspector de-
scribes the odor potential on his reports in the event
that complaints are received regarding that type of
odor so that the source may be readily located.
In most odor problems tracking is unnecessary.
An experienced inspector is often able to identify the
source of an odor by its quality and intensity and may
be able to relate the odor to a specific activity. Since
inspectors are familiar with the industrial establish-
ments in their inspection sectors, they are often able
to connect the odor with a specific piece of equipment.
The field inspector verifies his findings by follow-
ing a definite odor route in order that he may prove
that the odor emanates from a specific piece of equip-
ment. In such tracking situations it is not necessary
to rate odors numerically, but to describe the odors as
they are perceived. In these cases the inspector either
follows the odor from the suspected source as it moves
downwind to effect areas, or he proceeds from an
effect area (i.e., from the complainants themselves)
upwind to the source. The first method is for verifica-
tion, the second for tracking an unknown source.
1. Point Observations
The purpose of tracking odors or making odor sur-
veys is (1) to locate an unidentified source of an odor,
and (2) to prove to the satisfaction of the courts that
a given odor results from a contaminant emanating
from a specific source or sources. The proof can only
be made by an expert witness, the inspector, familiar
with odors and the equipment and operations located
in a suspected area.
An odor may be tied to the source by two basic
processes: (1) Association of odor with odorant, and
thence with a source. A given putrescent odor, for ex-
ample, is associated with protein decomposition, and
that in turn, depending upon the quality, with either
cooking or rendering processes. Such an odor may be
legitimately called "rendering odor", that is, by the
name of the odorant or the process producing it, and
(2) by a process of eliminating plants incapable of
emitting the odorant. Inventory records can be per-
used, or a key sorting selective analyses operation at
Headquarters employed to locate all suspected equip-
ment in the plants in a given source area.
The consensus of odor quality in the complaint
area must be identical to the odor quality emanating
from the source* That is, with the exception of "in-
tensity" all significant point observations should agree.
The "intensity" should vary in a geographical pattern.
A point observation here is a stationary location at
which an evaluation was made of the following:
1. Odor quality and intensity.
2. Wind direction and strength at time of odor.
3. Duration of odor.
4. Time of day and date.
Each nuisance complaint represents a point of
observation. Either the inspector verifies the complain-
ant's information, or if there are so many complain-
ants that he cannot do so, he requests the complainant
to keep a record of this information. The pattern of
complaints may thus, in itself, delineate a vector which
will point upwind to the source. Especially is this true
when complainant locations form a circle or a crescent
on a map, when odors are reported under relatively
stable weather conditions. The projected center of any
circular locus of point observations can be assumed to
be the source area.
Where an insufficient number of point observa-
tions are disclosed, inspectors make scheduled point
observations in order to triangulate the source. At such
point observations, the inspector may, when odors are
detected, take several samples of the air with evacuated
flasks. One flask can be used for comparison purposes
in an odor-free room at Headquarters and another for
lab analysis of the odorants. For even more effective
analysis, odorants can be sampled from the atmosphere
at point observations by activated carbon sorption or
by freeze-out trapping; analysis can then be made by
infrared or mass spectrometry.
2. Micrometeorological Problems
Several complications with respect to odors due to
the micrometeorology of given areas may arise. These
are the distances and elevations at which odored
streams of air travel. The distance at which an odor
travels may be very considerable. Sour gas odors from
oil fields have traveled as much as 100 miles from a
source, though this instance is rare(i3). Where meteor-
ological conditions are favorable to odor dissemination,
the radius will not generally exceed 5 to 10 miles. In
Los Angeles County most odors seem to be confined in
an area % to 2 miles in radius due to stagnant air con-
ditions. Odor dissipation may depend on temperature,
humidity, wind velocity and steadiness of prevailing
wind.
Some estimate of wind velocity may be useful in
determining relative distances at which a source might
be located from the complaint area. A weak breeze,
for example, suggests that a source may be nearby,
* This is sometimes complicated by changes in odor quality in
some substances resulting from variations in dilution ratios.
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204
Air Pollution Control Field Operations
since a slow moving odor stream may dissipate by
diffusion before it is carried very far. If the breeze is
strong, on the other hand, and no suspected sources
are nearby, the odor may have traveled a long dis-
tance, especially if it is a particularly pervasive odor.
The tracking of an odor from a complaint area to
a source is a matter of approaching an increasing inten-
sity of a given quality of odor. This can be accomplished
by making representative point observations along the
odor route. To avoid odor fatigue, inspectors may travel
with their vehicle windows closed to maintain as rela-
tively odor-free vehicle as possible, then open them
upon arrival at a new point observation for purpose of
comparisons).
Actual "skips" in the odor route may be observed
due to local turbulence, eddies, etc. Odorants may also
travel in air streams at varying elevations above the
ground, then strike a neighborhood or community sit-
uated on a rise of land.
To positively establish an "odor route", Gruber(9)
suggests the use of balloons to plot low-level wind
directions along the path of the wind itself. He
suggests partially inflating such balloons with helium
gas so that they will rise slowly and indicate a low-
level wind direction which can be plotted with a com-
pass and recorded on a map.
3. Approaching the Plant
The inspector in tracking problems travels
towards the plant on its downwind side and notes the
intensity of the odor. In more complicated cases, sev-
eral radio-equipped cars are deployed to transmit in-
tensities which are then recorded and interpreted at
the communication center. Several cars may be neces-
sary when the odor fluctuates, the wind direction
changes, or a complex of possible sources in an area
makes positive identification of a source difficult.
If the odor is traced to an industrial community
and to a group of industrial plants all performing sim-
ilar industrial operations, it will be necessary to deter-
mine whether all of the plants, a few, or just one plant
is responsible. Because the responsibility must be
clearly determined, a studied surveillance of the inside
and outside of each suspected plant may be required.
Action can be taken against multiple sources, as well as
single sources, as long as the odor concentration arising
from each, and together, can account for the intensities
noted.
If the odor is not chronic, and was reported for the
first time, it may be due to deviation in operational
practice, to a breakdown of equipment or to the intro-
duction of a new process. Because of these probabili-
ties, a one-time odor is likely to originate from one
industrial source. An inspection of the plant may
disclose the specific operation which has caused the
nuisance. When the inspector has traced the odor to
the equipment, he must fully document the conditions
under which the malodorous contaminants were
emitted.
Although the odors which are detected in the field
arise from the diffusion of gases and vapors, the source
of the odors may be in solid or liquid form. Samples
of petroleum products, chemical fluxes, solvents, de-
composed organic matter, materials from open dumps,
etc., can be taken as evidence, or the material can be
photographed. The fact that substances may have
vapor pressures sufficient to yield an odor or have low
odor thresholds can be substantiated by expert testi-
mony, as long as other operational and conditioning
factors which caused the odor are reported.
4. Sampling and Measurement of Intensity
To confirm field estimates of odor intensity in
nuisance problems, or to determine odor removal effici-
ency of odor control equipment, the inspector may col-
lect samples of odorous gases low in moisture content
by means of a Pyrex glass probe connected by a ball
and socket joint with clamp to a 250 ml. MSA gas col-
lection tube as shown in Figure XII-5. The odorous
gas is drawn into the tube by means of a rubber
squeeze bulb evacuator. For gases highly laden with
moisture, such as may be found in steam plumes, a
special means of collection'2^ is required to prevent
condensation of water vapor and possible absorption of
odor by the water. In this method, a capillary glass
tube, and a hypodermic needle and medical syringe
are used to draw 10 ml. of the sample into a collection
tube containing odor-free air.
tall and socket Joint (with clamp)
I Pyrex glass probe
MSA sample tube (250 ml.)
Rubber squeeze bulb evacuator
Capillary glass tube (2 mm. O.D.)
Hypodermic needle (18 gauge)
Cork stopper Ball Joini
MSA sample tube (250 ml.) Serum stopper Medical flyrlngc
(10ml.)'
Figure XII-5. Schematic diagrams of odor sampling apparatus.
Method "A" is used to collect samples low in moisture content;
Method "B,'1 samples high in moisture content. The latter meth-
od permits primary dilution of odor sample in the field, and
minimizes condensation of vapors on the inner surface of the
sample tube.
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Tracking Sources of Public Nuisances: Odors, Stains and Deposits
205
At the laboratory, the original sample of gas is
diluted with pure air until a dilution is achieved at
which only 50% or less of the members of an expert
test panel can detect any odor. The procedure em-
ployed by the A.P.C.D. is a slightly modified version
of the ASTM Standard Method D 1391-57, "Standard
Method for Measurement of Odor in Atmospheres
(Dilution Method)"(29>- The amount of dilution nec-
essary to dilute gas to the odor threshold measures the
relative amount of the odor in the gas. The relation-
ship of the field estimate of the odor intensity of the
original sample or nuisance to the odor threshold can
be compared for use as evidence in court.
5. Reporting
In concluding odor investigations, the maps (Fig-
ure XII-3) and reports collated from the various in-
spections can be perused to establish the elements of a
public nuisance. Reports are used to record data com-
piled at each point observation. In simpler cases, odor
surveys or maps are not required. A written account
either in tabular or narrative form reporting the ap-
proach to an increasing intensity, as well as notations
regarding the elimination of industrial plants which
might have been logically suspected as contributors,
may be all that is required. Here, again, the process of
elimination is just as important as that of positive
identification.
E. Odor Control
The elimination of odors is the most important
part of any odor problem. Air contaminants responsi-
ble for an odor should be controlled so that threshold
concentrations are never reached in the outdoor atmos-
phere. This is accomplished by adopting any one or a
combination of control devices or techniques such as
waste gas incinerators, catalytic oxidation, adsorption
in activated carbon, masking, counter-action, etc., to
the odor source (24'23) Such common-sense control
methods as general sanitation, refrigeration of animal
tissue, improved maintenance and operational tech-
niques should also be applied where odors arise from
plant housekeeping.
The abatement of odors is accomplished either by
complete destruction of odorants and prevention of
odorant emissions, or neutralizing the malodorous ef-
fects of contaminants. Odor prevention or odor de-
struction is generally preferable since air pollution
control in critical pollution areas seeks control of
contaminants themselves, not the effects of contami-
nants. For this reason, the ideal odor control method
is perfect combustion. This is accomplished by an
afterburner or waste gas incinerator. To be effective,
such devices must maintain complete combustion at
proper temperatures and exposure times, reducing all
contaminants to odorless water and carbon dioxide.
Partial or incomplete combustion may result in a series
of reactive secondary products which may not only be
malodorous, but eye-irritating and corrosive as well.
1. Waste-Odor Incineration
In Los Angeles County, afterburners have been
successfully employed in a large variety of situations
to abate odors from refineries, rendering, paint and
varnish, sulfur recovery, coffee roasters and fish pro-
cessing plants and enameling ovens and dryers, paint
and enameling baking ovens, chute type incinerators
and smoke houses in meat packing plants.
Their use is made compulsory in connection with
rendering processes by Rule 64, quoted in full below:
RULE 64. REDUCTION OF ANIMAL MATTER. A per-
son shall not operate or use any article, machine, equip-
ment or other contrivance for the reduction of animal mat-
ter unless all gases, vapors and gas-entrained effluents from
such an article, machine, equipment or other contrivance
are:
a. Incinerated at temperatures of not less than 1200
degrees Fahrenheit for a period of not less than 0.3 sec-
ond, or
b. Processed in a manner determined by the Air Pol-
ution Control Officer to be equally, or more, effective for
the purpose of air pollution control than (a) above.
A person incinerating or processing gases, vapors or
gas-entrained effluents pursuant to this rule shall provide,
properly install and maintain in calibration, in good work-
ing order and in operation devices, as specified in the Au-
thority to Construct or Permit to Operate or as specified by
the Air Pollution Control Officer, for indicating tempera-
ture, pressure or other operating conditions.
For the purpose of this rule, ''reduction1' is defined as
any heated process, including rendering, cooking, drying,
dehydrating, digesting, evaporating and protein concen-
trating.
The provisions of this rule shall not apply to any
article, machine, equipment or other contrivance used ex-
clusively for the processing of food for human consumption.
This rule shall be effective on the date of its adoption
as to any article, machine, equipment or other contrivance
used for the reduction of animal matter not completed and
put into service. As to all other such articles, machines,
equipment or other contrivances this rule shall be effective
October 1, 1959.
In enforcing Rule 64 at rendering plants it is first
important to ascertain the adequacy of vapor collection
arid disposal facilities. The emissions from the kettles
are conveyed by ductwork to a condenser where most
of the moisture is removed. The noncondensables, in-
cluding the odorants not removed by the condensers,
are burned in an afterburner or in the firebox of a
boiler which meets the requirements of Rule 64. The
inspector thoroughly checks all equipment for leaks
or breaks in ductworks, or for negligent operation of
kettles, or any other conditions which may result in
vapor emissions.
When applications for rendering or rendering
control equipment are processed for permits, the con-
trol engineer determines whether or not sufficient gas
is available to provide the minimum required tempera-
ture for combustion of odorants, and calculates to de-
termine proper retention time. This is necessary to
meet the law and to incinerate the materials properly.
The inspector determines compliance with the temper-
ature restriction and checks for obvious changes which
might reduce the retention time, such as alteration of
combustion zone dimensions.
The inspector must check the operation of the af-
terburner, and the calibration of the pyrometers. A
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206
Air Pollution Control Field Operations
company which desires to evade the rules need only
corrupt the electrical system of the recording equip-
ment, merely, for example, by altering the leads to the
thermocouple. The inspector may do his own electrical
verification by using a pyrometer furnished him.
Waste gas streams can also be incinerated in the
fireboxes of waste heat boilers provided that the same
conditions for combustion obtain as above.
Other methods of preventing the escape of odors
to the atmosphere include chemical scrubbing and
charcoal filtering. These methods of control have been
described in Chapter 2.
2. Neutralization
The neutralization of odors is not concerned with
the reduction of odorants but with nullifying both the
quality and intensity of the odor by means of mixing
anti-odorant materials with the odorants, usually by
atomization. The result is primarily psychological.
These anti-odorants are: (1) masking agents, (2)
counteractants, and (3) chemical reactants.
a. Masking Agents
A masking agent is an odorant with pleasant
qualities strong enough to subordinate the stimulus of
the unpleasant odorant. It is usually prepared from
synthetic aromatic chemicals, their by-products, vari-
ous essential oils, and i s used in odor control in
industries manufacturing solvents, fuels, rubbers, plas-
tics and textiles.
b. Counteractants
Counteractants involve the pairing of odors which
counteract each other, i.e., by being present in effective
proportions, make the perception of odor completely
unnoticeable. Rubber and paraffin, cedarwood and
rubber are two familiar examples of counteractants.
Counteractants are also prepared from synthetic aro-
matic compounds, various essential oils, with the addi-
tion of quaternary ammonium compounds and disin-
fectants.
c. Chemical Reactants
These "deodorize" by chemical alteration of the
odorant itself. Reactants include such chemicals as
ozone, chlorine, chlorine dioxide, permanganate, or-
ganic peroxides, formaldehydes, or catalytic materials,
etc.
Ill NUISANCE DEPOSITS — STAINS
Stains refer to the damaging or soiling of property
resulting from the interaction between air contami-
nants and the surfaces or surface coatings of materials.
In nuisance problems, typical stains include pitting,
incrustation, etching, spotting, buckling, abrasion, cor-
rosion and other forms of deterioration.
Stains usually result from the deposition of mist
droplets or liquid particulates usually of an acidic or
caustic nature. Some solid particulates and aerosols
may also exhibit staining or damaging properties. Dust
particles will contribute to deterioration of materials
by abrasion and erosion, or by chemical or electro-
chemical reaction. For example, ammonium sulfate
silica, produced on carbon particles which have ab-
sorbed sulfur dioxide, tends to increase the general
corrodibility of the atmosphere.
Since solid deposits are treated separately in Sec-
tion IV of this chapter, a stain shall be considered here
as any significant deposition or damage resulting from
the chemical reaction between a mist droplet and the
surface of a material.
The type of nuisance found in a community as a
result of mists depends on the nature of the industrial
economy and the climate, particularly with respect to
sunlight and humidity. Humidity increases the rate
of corrosion, as well as influencing mist production.
Sunlight induces photochemical reactions and catalytic
reactions leading to the formation of oxidants. A typi-
cal corrosive atmosphere found in urban communities
today is one which contains a high degree of sulfur
dioxide. Sulfur dioxide in the atmosphere, as will be
recalled, readily converts to other aggressive sub-
stances. Hydrogen sulfide and sulfuric acid will attack
lead-based paints, leaving a brown to black discol-
oration. Sulfuric acid, also, will attack a variety of
substances, including building materials such as
carbonate-bearing stone, zinc gutters, canvas, copper
wire and surface coatings. The properties of this type
of contamination have been previously discussed in
this manual.
Local nuisances resulting from liquid particulates
tend to fall into two categories: (1) acid and caustic
stains causing some form of permanent damage to
property, and (2) spotting by paints, oil, greases or
other materials which adhere to surfaces without nec-
essarily damaging them and which can be removed.
A. Damage by Acids and Caustics
A frequent type of public nuisance encountered in
Los Angeles concerns the discoloration and damage of
lead-based paints, particularly automobile finishes, by
acids. Acid stains usually appear as brown-going-to-
black irregular pin pricks to spots which range in size
to approximately 'A" in diameter, shaped in the cross-
section of the depositing mist droplet. Cars so dam-
aged exhibit a spotty appearance, particularly on the
upper surfaces of the vehicle — the hood, decks and
roof, or on the side of the car facing into the wind.
Cars found in employee parking lots in industrial com-
munities are most frequently affected by this form of
contamination and occasionally cases develop in which
the cars affected are owned by the employees of the
company creating the nuisance, thus involving an
employee-employer management problem which must
be resolved by cooperative action. In other cases where
acid deposits are found, the source is usually located
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Tracking Sources of Public Nuisances: Odors, Stains and Deposits
207
close by, although this may not always be true.
House-sidings, usually discolored from yellow-to-black,
steel fencing and uncoated aluminum sidings on houses
and trailers may also be affected by acid contaminants.
Virtually all acids in appropriate concentrations
by their nature contain properties of a potentially nui-
sance character. They will attack and discolor materi-
als, dissolve or corrode metals, oxides and carbonates,
burn or ulcerate skin, irritate the eyes and cause a
sour taste. The acidity of aqueous solutions can be
measured quantitatively by the pH factor. The pH
factor, a measure of the reactivity of a solution, is
based on the fact that an acid contains hydrogen which
may be replaced by a metal to form a salt. Thus, re-
activity is measured in terms of the hydrogen-ion
concentration of a solution by means of electrometric
apparatus or colorimetric indicators (pH or Hydrion
papers, see Figure XI-10F).
The types of acids found in nuisances depend, of
course, on the particular industrial plants and pro-
cesses employed, and hence, on the general nature of
the industrial economy. Some acids like phosphoric
acid, used in the production of fertilizers, ceramic and
glass products, phosphoric acid anodizing, petroleum
refining, catalysts, and cleaning of metals are capable
of attacking canvas and aluminum sidings and will
cause incrustations on automobile finishes which, how-
ever, can be wiped off. Nitric and nitrous acids, which
may be emitted as a brown cloud in by-product man-
ufacturing or fertilizer processing, may also give off
irritating corrosive mists. Hydrochloric acid, which is
emitted as a by-product in the manufacture of chlorine
products, used in the manufacture of scale solvent, in
making swimming pool acidic adjustments, in pickling
processes, etc., will attack metal fencing and similar
materials.
The three most important acid mists entering into
public nuisances in Los Angeles County are chromic,
sulfuric and hydrofluoric acids. We shall consider
these acids as being emitted directly into the atmos-
phere and condensing out as dew, mist or rain, rather
than the type of acid which subsequently results from
atmospheric processes. These acids are not usually
emitted as a regular consequence of production cycles,
but usually as a result of accident or equipment fail-
ure. Most plant operators, for reasons of health and
safety, attempt to maintain careful control over acid
handling. When air pollution control equipment fails,
acid particles build up with moisture on control sur-
faces (entrainment) and are dumped or exhausted into
the atmosphere under draft pressure.
1. Chromic Acid
In addition to attacking paint, chromic acid mists
are also capable of causing eye-irritation and offensive
("dead cat") odors. The primary source of chromic
acid mist is inadequately controlled electrolytic chrom-
ium plating tanks. Chromic acid mist results from the
fact that hydrogen and oxygen bubbles, released elec-
trolytically, pick up particles of the acidified solution
formed in the film on the surface of the tank. Gener-
ally speaking, such nuisances arise from hard chrome
rather than soft (decorative) chrome plating opera-
tions, since in the former greater current densities and
higher balh temperatures are applied, thus creating
more side reactions and increasing the rate of emission
of liquid particulates. Typical solution compositions
for both soft and hard chrome plating are .53 ounces
of chromic acid per gallon solution. Typical current
density and bath temperature for soft chrome are 115
amps, per sq. ft. and 105°F; for hard chrome, 216-288
amps, per sq. ft. at 122°F. Such operations can be con-
trolled by a commercial mist inhibitor or surface-active
agent, which breaks up surface tension and keeps the
particles which would ordinarily form a surface film
in solution, or by the use of wet collection or dry-type
filters described in Chapter 2.
Figure XII - 6. Hard chrome plating tank used for coating diesel
engine crankshafts.
2. Sulfuric Acid
Because sulfuric acid is one of the most econ-
omical of the inorganic acids, it is widely used in
industrial operations to remove sulfur and unsaturated
compounds, in battery manufacturing, for purification
and in many refinery and plating processes. Sulfuric
acid mist droplets are capable of producing brown to
black discolorations and pitting on lead-based surface
coatings. Another familiar nuisance effect is the depo-
sition of sulfuric acid either directly or indirectly in
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208
Air Pollution Control Field Operations
the troughs formed in the slack of canvas awnings.
Sulfuric acid will destroy materials wherever it is
permitted to accumulate.
3. Hydrofluoric Acid
Hydrofluoric acid readily fumes and is capable of
severely attacking skin, poisoning leafy vegetables and
flowers, and pitting glass and metal. It is used in the
commercial production of fluorides, in metallic alumi-
num and metal fluorides, insecticides and laundry
products. It is prominently used in the etching, frost-
ing and polishing of glass and as a catalyst in the
conversion of olefins and isoparrafins in alkylation
plants in refineries, as well as in the pickling of steel
alloys. It will distinguish itself from the other acids
by causing comprehensive damage. When it attacks
an automobile, for example, it will contaminate the
paint, chrome and glass. Because of the high degree of
acitivity of this contaminant, and its danger to health,
equipment and vegetation, it is handled and controlled
carefully by maintenance in a dry state or in such
dilute quantities as to avoid causing damage in the
vicinity of its use. Because of the interest in its control,
hydrofluoric acid is more likely to create a one-time
nuisance as a result of equipment break-down, particu-
larly from an alkylation plant, rather than a continu-
ing chronic public nuisance. It may also occur as a
by-product in the manufacture of rocks and phosphates
when sand used in its control is spent. (Hydrofluoric
acid reacts with silica, or sand, to form hydrofluosilic
acid.)
4. Caustics
Caustics fall into the chemical category of alkalies,
that is, they are capable of neutralizing acids as well as
providing a detergent, and in some caustics, an etching
action. Principal caustics are sodium carbonate and
sodium hydroxide, the latter being more commonly
used. Sodium carbonate is used in large scale chemical
manufacturing, the manufacture of glass, soap pow-
ders and detergents. Of the caustics, sodium hydroxide
is perhaps the most significant since it attacks the skin,
is strongly alkaline, and very soluble. It is employed
in the petroleum industry, in the viscose process for
rayon manufacturing, and the manufacturing of chem-
icals and soaps. In sufficient concentrations it will
attack paint, glass, and aluminum and cause pitting,
etching and buckling. The etching properties of this
chemical are put to use in the aircraft industry in a
chemical milling process which reduces the thickness
of preformed, stress-relieved aircraft parts made of
aluminum, magnesium, stainless steel and titanium.
This chemical process performs milling jobs such as
shaping and tapering and can mill surfaces at the Tate
of one-thousandth of an inch per minute. The chem-
mill bath consists of a caustic etching solution of 7%
sodium hydroxide by weight, water and a trace of sodi-
um aluminate, and is heated to about 195°F. The sodi-
um hydroxide mists are usually vented by means of
slot hoods to a water scrubber. If uncontrolled, chem-
milling may cause a public nuisance.
B. Spotting by Paints and Other Materials
Here we consider the type of nuisance which
results from the deposition of paint, oil, grease droplets
or other materials which adhere to surfaces or surface
coatings without necessarily damaging them. Quite
often such deposits are readily removed with water,
thinners, or detergents. In some cases, surfaces may
require rebuffing and repainting. The droplets of this
type are generally significantly larger or heavier than
those described previously and enter the atmosphere
directly from spray or atomizing devices, and occasion-
ally by entrainment and ejection from wet collection
equipment or blower exhaust systems. They frequently
contribute to the contamination of automobiles, house
sidings, clothing, etc. in the community in which the
spraying is performed.
1. Paint Spots
Paint spots are mist droplets of paint pigments
and binders which deposit in a liquid state and adhere
to surfaces. Paint mists are frequently emitted from
paint spraying operations usually conducted under
high-volume production conditions. With average wind
movement and humidity, all paints tend to fall out
within the first 150 to 500 feet from the source with
the exception of certain metallic pigmented paints,
such as aluminum, which may on occasion travel up-
wards to one-half of a mile.
The important nuisance properties of paint drop-
lets are the drying rate, the distance traveled, and the
degree of surface adhesion. The speed at which paints
dry depends primarily on the rate of evaporation of the
volatile portion (solvents) contained in the paint.
Paints containing slow-drying solvents may travel in
the air as mist droplets which then dry after deposition
on surfaces. Paints which require heating or baking
for drying are generally of this type. Baking enamel,
for this reason, is a basic source of public nuisances.
Primers, sealers and water-based paints, although
emitted as a liquid are deposited as solids and have the
appearance of colored dust, depending on the relative
distance between the source and the surface. Zinc
chromate primer, for example, is yellow-green, while
lead primer is red.
Paints also give off characteristic odors usually
due to the evaporation of the organic solvents (var-
nishes or oils) contained in the vehicle of the paint.
The principal vehicles used are oleoresinous varnishes,
alkyds, dispersion resins, malamine and phenolics(22).
An odor problem from paint is generally not signifi-
cant unless complainants are very close to the source.
The uses and relative nuisance properties of com-
monly used paints are described below in Table XII-2.
Drying rates, it should be noted, vary considerably
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Tracking Sources of Public Nuisances: Odors, Stains and Deposits
209
within any category of coating, depending on the in-
itial drying or "flash-off" of the specific solvents. Those
shown below are for typical industrial situations.
TABLE XII-2(4)
RELATIVE NUISANCE PROPERTIES
OF COMMONLY USED PAINTS
COATING
Clear
lacquer
Pigmented
lacquer
Lacquer
enamel
Synthetic
enamel
Primer
Clear
sealer
Water-
based
paint
Metallic
pigmented
enamel
USE
Used for wood and
metal finishing and
as sealer.
For painting automo-
biles, or metal sur-
faces, for rapid dry-
ing ( Alkyd resin) .
Same as above, but
bake dried.
Automobiles, refrig-
erators, stoves, light-
ing fixtures, etc.
Undercoating may
use all types of res-
ins and pigments
such as red lead and
zinc chromate.
Non-pigmented
primer.
Emulsified with
water; manm'kins,
papier mache,
houses, etc.
Painting large stor-
age tanks, an econ-
o m i c a 1 protective
coating.
DRYING RATE
Fast, air
drying.
Fast, air
drying.
Bake dry,
slow air
drying.
Fast-slow
air drying.
Very fast
drying.
Fast to
slow.
Very fast
drying.
Usually
medium-
slow, light,
may travel
long dis-
tances.
REMOVAL
Very light and
volatile. May be
removed with lac-
quer thinner.*
With lacquer
thinner.*
With lacquer
thinner.*
With lacquer
thinner.*
Usually dries to
dust. May be eas-
ily rubbed off.
Same as above.
may be removed.
Same as above.
Aluminum-metal-
lic paint adheres,
may be removed
with mineral
spirits or thinner.
* Since lacquer thinner is a strong solvent, caution must be
taken with its use in removal of paint stains, as it may also
damage the protective coating.
Paints are capable of causing nuisances when they
are sprayed or atomized, usually with standard pres-
sure spray guns. Paint spraying may be conducted in
the open or in one of several types of specially con-
structed paint spray booths. "Open spraying" is con-
ducted outdoors on structures so large that it is
impractical or uneconomical to utilize a paint spray
booth; for example, the spraying of houses, structural
steel beams, etc. However, most spraying, for reasons
of economy and safety, and fire and health department
restrictions, are conducted within a suitably designed
paint spray booth. The article to be coated is placed or
mounted in the booth either on a pedestal or conveyor-
ized assembly unit, and is sprayed by an operator and
occasionally by automatic spray equipment.
The types of paint spraying operations employed
depend on the nature of the material to be coated —
wood, plastic, metal; the quality of the surface, i.e.,
smooth, rough, porous, etc., and the quality of the
surface coating desired, i.e., hardness, permanence.
luster, etc.(22) Woodworking, metal fabrication plants.
and automobile and aircraft manufacturing and repair
plants are most generally encountered in air pollution
problems, although paint spraying operations tend to
be common to the entire industrial economy. Wood-
working techniques include conditioning of the article
by means of sanding, application of sealer, stain (eith-
er oil or water-based) and application of final coat of
lacquer. In plants manufacturing metal products, arti-
cles to be coated may be conditioned by degreasing
with vapor solvents and buffing, and primers may be
applied as undercoating. Lacquer-enamels, synthetic-
enamels or metallic pigmented enamels are applied as
a finishing coating. To improve the properties of ad-
hesion, hardness and resistance to chemical deteriora-
tion, painted articles, such as automobiles and other
metal products are baked or force-dried in ovens at
temperatures ranging from 150° to 400°F. In small
plant operations, one booth may be used for applica-
tions of preparatory and final coatings, whereas in
large conveyorized assembly-line plants, a paint spray
booth may be utilized for each type of spray operation
conducted.
The design of the booth, the equipment used, and
the type and volume of paints sprayed affect directly
the amount of air contaminants emitted. Booth design
generally falls into two categories: dry and wet types.
The simplest dry-type booth is merely an enclosed
structure equipped with a blower motor fan and stack.
The size of the booth depends on the size of the objects
to be sprayed, and the blower motor and fan diameter
are rated to handle the volumes of paint sprayed and
the dilution necessary to keep the air in the booth
clear. The amount of paint mist entering the exhaust
flow after spraying depends on the size and nature of
the article being sprayed. A large flat article will
retain most of the spray whereas smaller objects, or
those which are gridded or perforated, result in a
greater overspray.
Although the walls and ceiling of the simple dry
type booth retain some of the overspray, most of the
mists and vapors are drawn out through the blower
system to the outer atmosphere. To reduce emissions
of these contaminants, flat metal panels, or baffles, are
constructed as impact surfaces at approximately right
angles to the air flow entering the outlet of the booth.
Depending upon the percentage of the cross-section of
the exhaust outlet obstructed by the baffles, a propor-
tion of the overspray is deposited and retained on the
baffles.
A more advanced type of booth employs filters
packed with a dry filter medium, such as glass fiber,
fine wire, metallic screening, or crimped paper. These
are constructed in banks breaching the exhaust pass-
ages of the booth. The efficiency of such filtering media
is relatively high for all paint particles.
-------
210
Air Pollution Control Field Operations
ri
Figure XII - 7. Placing dry filter tray into spray booth.
An even more efficient design of booth is of the
wet-type. This type of booth is a special form of water
scrubber constructed in the form of a recirculating
waterfall curtain which entrains the paint mist before
it is exhausted to the outer atmosphere. The paint
particles then are scrubbed out of the flow by a deter-
gent, are collected in a settling tank, and recirculated.
The more advanced of these booths are capable of
collecting practically all types of liquid particulates.
Some odors, however, will be emitted, and the emis-
sion of volatile solvents is, at the present time, un-
controllable.
The effectiveness of the control features of all
booths depends upon proper operation and mainten-
ance. Skilled operators attempt to reduce unnecessary
overspray, not only to prevent air pollution but to
conserve paint. Pressure guns are operated only when
necessary and with such skill as to accomplish an
efficient and uniform coating of the article. Automatic
electronic spray devices have been recently developed
in which the paint particles are given an electric
charge and are attracted to the article to be coated on
a grounded conveyor belt, in an electrostatic field
created by rows of fine wires on each side of the con-
veyor. (28)
Booths utilizing dry-type filter media will
require that filter media be changed or replaced when-
ever there is a significant drop in draft pressure. Ag-
glomerated contaminants in neglected and overloaded
Figure XII-8. Recirculating water-fall paint spray booth.
filter media will be forced into the atmosphere by draft
pressure. Wet booths require constant recirculation of
water and the use of a suitable chemical detergent to
keep the curtain flow clean. Periodic cleaning of the
booth is necessary to prevent stoppages in drainage and
pumping systems which otherwise might result in ex-
haus.ting portions of the contaminated solution into the
atmosphere.
The design standards which must be met by paint
spray booths are determined both by engineering cal-
culation and empirically in the field. The amount of
contaminants emitted into the air is readily deter-
mined from the estimate of overspray, production
quantities of paints and thinners used, the scrubbing
or filtering ratio, indraft and cross-draft velocities as
well as the volume of air (CFM) moving through the
control sections of the booth. The data are routinely
calculated in processing applications for permits in
determining whether the proper type booth is em-
ployed for any specific operation.
2. Other Materials
Other spotting, sometimes similar to acid or paint
stains, can occur from a variety of industrial and non-
industrial sources. A familiar problem encountered in
Los Angeles involves spots on houses and cars result-
ing from bee droppings. These have a characteristic
light to dark yellow, orange or brown appearance,
round or oval on horizontal surfaces (.15" to .20" in
diameter) or as streaks on vertical surfaces (.05 to .1"
long), with a waxy consistency when fresh. On aging,
bee spots become dark grey-green or dark-brown in
color, are brittle and easily removed from a surface
by scraping with the finger nail. They can be washed
off with water, though not water soluble. Because
property will frequently appear peppered with spots,
bee spots are often mistaken for stains resulting from
industrial equipment. Quite often such spotting is
severely localized in residential communities far from
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Tracking Sources of Public Nuisances: Odors, Stains and Deposits
211
industrial sources, usually near bee hives, open fields,
or commercial apiaries, and in the line of flight be-
tween feeding or foraging areas and the hive. Bee spots
contain some pollen grains and some beeswax, enough
to give the characteristic sweet odor of beeswax when
heated over a small match flame on a spoon or pen
knife. They may be collected simply by removal with
a small spatula or pen knife and sent to the laboratory
for analysis and verification.
Oil droplets on property can occur from several
sources — from malfunctioning oil wells or pumping
and drilling equipment in oil production fields, a re-
finery itself, high volume oil-quenching operations,
and jet and other aircraft, particularly in the vicinity
of a heavily trafficked airport. Asphalt droplets may
also occur from paving, roofing equipment, or asphalt
saturators. Mist droplets form from some types of
quench operations where a large volume of material to
be tempered has also a high degree of surface area in
relation to its bulk. Large quantities of nuts and bolts,
for example, will cause vaporization of vapor bath
when suddenly immersed in an oil bath at high tem-
peratures. The amount of mist vapor driven off in this
type of operation usually requires control equipment.
Another source of liquid particulates arises from
the malfunctioning of collection, equipment, particu-
larly water scrubbers and wet filters, when particles
entrained in the liquid medium on wet walls, impact
surfaces, or baffles are ejected into the atmosphere.
This may occur accidentally from spray towers, Roto-
Clones, and even electrostatic precipitators. Asphalt
mists have been emitted from scrubbers and control
equipment serving asphalt saturators. Occasionally,
mud-like particles are emitted from wet collectors serv-
ing sand conditioning equipment in foundries.
C. Tracking Liquid Particulates
Because air-borne liquid particulates do not travel
nearly as far as do odors, they will generally settle out
in the neighborhood close to the source of the mist.
This particular property of liquid particulates, taken
together with the fact that they can be sampled, is of
great assistance in tracking down sources since simple
sampling equipment or test panels can be used.
In proving a public nuisance, it is not usually nec-
essary to determine the concentration of the particulate
in the atmosphere. But where the source and the par-
ticulate are unknown, it may be necessary to collect
samples for identification by laboratory analysis. The
general methods of tracking unknown sources are de-
scribed below. Once a suspected source is determined,
an analysis of the suspected stack or vent can be re-
quested.
Where the source is unknown, an estimation of
wind direction may be required. This may be accom-
plished by a study of paths of deposition. If one side
of an automobile or house is habitually contaminated,
the wind direction may be inferred. The interview
with the complainant should attempt to establish, if
possible, the wind direction at the time of contamina-
tion. If this is impossible, the inspector should
attempt to establish the time the contamination took
place, so that he can inspect the premises to determine
wind patterns for himself. In complex cases involving
heavily industrialized communities with many possible
sources, or where contamination does not appear to be
localized according to wind direction, the inspector
should plot a wind rose showing the direction from
which the winds came, the time intervals, and the
relative intensity. This information then can be used
to plan reinspections and to determine the possible
location of test panels should they be required.
Most sources of liquid particulates can be located
by downwind tracing of trail of fallout, or areas of
contamination. If the contaminant has been identified,
a given source may be shown to exist if the contami-
nated area is within the probable range of travel or
fallout of the air contaminant, if the air contaminant
is observed or detected emitting from the source in
such quantities as to make contamination in the af-
fected area probable, and if no other sources can be
accounted for.
Once a plant is suspected, roof areas adjacent to
stacks and vents should be observed for stains, coatings,
and other deposits which have accumulated. The ex-
tent of the damage, and the degree of deterioration,
decay, erosion, or general filth on the deposited mate-
rial should be compared with the total time the equip-
ment or process has been in use, and that compared, if
possible, with the extent of recent damage. The over-
riding path of such deposition should also indicate the
general direction contaminants have traveled in the
atmosphere, and can be lined up with the "target" or
complaint area in the community. A photograph of
such deposition on roofs or other structures should be
taken whenever possible.
If the source is unknown or a number of possible
sources exist, or if the air contaminant is not readily
identifiable, then any of the following procedures may
be used:
1. Identification of the Air Contaminant
Is Needed Only
There are two general methods for collecting
aerosols for identification. One of these is the use of
fall-out jars, with a known area of opening. The jar
is filled half full with distilled water and is stationed
at a location selected after analysis of the wind rose.
After a specified period of time, the jar is picked up
and brought to the laboratory. An aliqxiot of the sam-
ple, i.e., a known fraction of the solution, is evaporated
to isolate the soluble and insoluble portions. These are
then tested either for a suspected material (such as
phosphates, sulfates, iron oxides, silica, any of the
acids, etc.) or a qualitative analysis is run. The quan-
tity of the material determined is then multiplied by
-------
212
Air Pollution Control Field Operations
the number of fractions, or aliquots contained on the
basis of the initial fraction selected, and is averaged
over the area of the opening. Thus, not only the parti-
cle identity, but an indication of the amount of fallout
of the suspected contaminant in the immediate area is
given.
Figure XII - 9. Dust-fall jar.
The second method is the use of a panel consisting
of either a porcelain or other smooth non-reactive
metal about one foot square coated slightly with petrol-
eum jelly or an absorbent type panel paper. The
former is generally preferable for the collection of solid
particles or particles resulting as a solid residue. The
absorbent paper is generally preferable for acid mists,
paint spots, or any substance which will be absorbed
by the paper. Tests made of materials in petroleum
jelly, however, are uncertain due to chemical inter-
ference and the possible reactivity of the jelly. In the
case of the absorbent paper, the possible chemical con-
stituents which might interfere or be mistaken in the
analysis should be determined independently.
Whenever the contaminant can be sampled di-
rectly from the atmosphere, and a substantial sample
is needed for positive identification, any of several
types of portable aerosol sampling equipment can be
used. These are generally of the filter, impinger, in-
ertial separator, or electrostatic types (see Figures
XI-3 and XI-10G) and are either powered by aspirat-
ors or pressure pumps. A known volume of air is
passed through each such device, and the sample col-
lected is extracted for qualitative or quantitative anal-
ysis for identification.23)
When such field tests are made, the inspector ac-
curately determines the time, date, interval of testing,
wind direction, distance from source, and any other
pertinent information. The samples of contaminants
collected are then brought to the laboratory for an-
alysis.
2. Proof Is Needed of Contribution from a
Suspected Source
Assuming that the contaminant is known, and a
source is suspected with some certainty, a method may
be required for providing demonstrative proof. Test
panels (either of the paper or metal type) may be
placed in a path downwind from the source ranging
from the contaminated area to the equipment sus-
pected. The panels should all be of the same size. If
the frequency of contamination of panels increases as
the distance to the suspected source decreases, then the
evidence may indicate that the source in question is
the actual offender. Inclusive dates and times of ex-
posure, distance of individual panels from the source
and any other conditions of testing should be shown
on the report.
3. The Identity of an Unknown Source or Sources
Needs to be Determined
If no specific source is suspected, or more than one
source is possible, a major investigation may be re-
quired. This is accomplished by coordinating the acti-
vities of several inspectors, particularly if the damage
from contaminants is serious and widespread. An
effort will be required to determine the boundaries of
the damage in order to establish the range of travel.
Once that is established, inspections of industrial facili-
ties can be concentrated in the suspected area. At the
same time, a thorough analysis of the contaminated
area should be conducted. The following should be
determined from observation, testing and interview:
a. Frequency and time of day contamination takes place.
b. Length of period of contamination.
c. When contamination was first noticed.
d. Prevailing wind patterns for the area.
In complex cases a sketch or map should be drawn
including the above information and indicating:
a. All possible plants, equipment and their distances from con-
taminated area.
b. All areas affected, with notation as to which areas are most
frequently affected, and their distances and directions from
suspected sources.
c. Pertinent addresses, such as point observations and com-
plainants.
d. Location of test-panel or fallout jar stations.
When fallout jars or test panels are necessary,
they may be posted or stationed in the following
manner:
a. On or near contaminated objects, such as automobile or
house-sidings.
b. If necessary, in 360° circle around contaminated area to de-
termine the path or trajectory of the contaminant unless an
inspection of the contaminated area already discloses the
general pattern of deposition.
c. Posting of one or more panels horizontally or stationing fall-
out jars as an indication of general fallout since some con-
taminants may travel long distances.
d. Posting panels or stationing jars in possible lines of travel of
contaminants from suspected source.
e. Panels or jars should be systematically numbered and should
show dates of exposure. Exposure may be expressed in terms
of hours, minutes, or days.
-------
Tracking Sources of Public Nuisances: Odors, Stains and Deposits
f. Panels and fallout jars should be stationed and removed in
a manner which will show time of day contamination takes
place. The pattern for change may be based on a study of
the wind movement for the area.
In evaluating data compiled by employing the
above procedures, the inspector may feel assured that
he has reasonably substantiated his case, provided the
following are true:
a. A series of panels downwind from the plant shows increase
in deposition per unit area over a decreasing distance to
source.
b. If other panels testing other sources in the vicinity show
little or no spotting.
c. If the contaminants on the complainant's property, test pan-
els in series, and adjacent to source are chemically identical.
d. If the suspected equipment emits the contaminant in ques-
tion during exposure period of test panels.
When the above evidence is gathered, the source
should be contacted and the findings explained. In
many cases in which management is convinced it is
responsible, voluntary remedies may be instituted.
With respect to stains resulting from liquid par-
ticulates, a check should be made of possible violations
of maximum permissible emission Rules 52, 53, or 54.
Where management refuses to correct the prob-
lem, a Section 24243 Public Nuisance Notice may be
issued and District Attorney forms completed and
signed by complainants. Complainants must be willing
to testify in court. All District Attorney forms should
be made out by the complainants in their own hand-
writing.
Where the source was originally unknown, the
complainants should be prepared to testify that a nui-
sance exists after the inspector has explained that he
has accurately identified the source.
Where multiple sources exist, legal action can be
taken simultaneously.
IV SOLID DEPOSITS
By deposits we refer specifically to particles of
solid materials which settle out of the atmosphere or
impact on surfaces. These are fine materials which
are substantially in excess of one micron in diameter
and have a relatively fast settling rate, such as dusts,
ash, minerals, grains, powders, flour, etc., and are
large enough to be seen with the naked eye. Small
invisible particulates do not generally enter into com-
plaints, unless they react chemically with surfaces to
form visible stains, abrasions or pittings. Complaints
made against deposits concern the littering, soiling
qualities of deposits, and the time and expense required
to keep property free of them. Deposits may also con-
taminate materials such as clothing and silk stockings,
or enter into commercial or industrial processes as
impurities. For this reason one industrial plant might
complain of another about the contamination of its
product by dusts or solid particles. Occasionally com-
plaints are received concerning the chronic contamina-
tion of swimming pools from fly ash or soot from
incinerators or boilers located nearby. Such deposits
frequently collect in rain gutters, window sills, side-
walks, porches, curtains and clothes.
The sources of solid deposits are extremely nu-
merous. Dust is created by almost every commercial,
domestic and industrial activity. Dusts are produced
wherever materials are ground, pulverized, crushed,
destroyed, scraped, milled, conveyed, etc. Deposits en-
tering into significant complaints and public nuisances,
however, most likely originate from the "dusty" indus-
tries, i.e., wherever dusts, grains, minerals, and other
solid particles are either manufactured or handled in
large volumes, or evolve as production waste. The
"dusty" industries include grain and feed mills, min-
eral processors, fertilizer plants, pottery and ceramic
manufacturing, hot asphalt and concrete batch plants,
cement manufacturers, the roofing industry (mica,
talc and crushed rock), woodworking industries (saw-
dust) and others. Handling and production equipment
found in these industries include hammermills, pulver-
izers, crushers, bagging machines, shaking, classifying
and grading devices, batching equipment, bucket ele-
vators, air conveyor systems, aggregate dryers, loading
hoppers and scales, sanding equipment, shot blast
booths, etc.
Dusts or solid particles are controlled according
to the size and volume of the particles involved, the
efficiency of control being dictated both by production
requirements and A.P.C.D. law, specifically Rule 54,
Dusts and Fumes. The finer the material, the greater
the collection efficiency required. For example,
dusts from rock crushing, ore handling, woodworking,
sand conditioning, etc., in the range of 5 to 200 mi-
crons can be handled satisfactorily by a centrifugal
collector. Water scrubbers are capable of handling
fines in the nuisance range, but their efficiency is gen-
erally dependent upon high grain loadings and soluble
contaminants. The most efficient and perhaps versatile
of control devices is the baghouse, which is capable of
achieving collection efficiencies close to 100%. In the
case of asphalt mixes, which range in Los Angeles
County from a low of 2 per cent minus 200 mesh mate-
rial, to a high of 12 per cent minus 200 mesh material,
collection efficiency of control devices must range from
95 per cent to more than 99 per cent. This can be met
by a cyclone separator followed by an efficient type of
water scrubber such as a multi-pass type or a wet-wall
multiple cyclone.
Regardless of the efficiency of control devices, dust
emissions should be checked particularly at the dissi-
pation point of steam plumes (see Chapter 10). Leaks
in hoods and conveyor systems should also be checked
for emissions. Dust emissions may not only violate
Rule 54 (dust loading), but also Rule 50, should
opacities exceed 40%. When a nuisance complaint is
registered against a dusty industry, the inspector gen-
erally inventories all of the equipment on an Equip-
ment List (see Chapter 14) and makes a flow chart to
check out all possible points of dust emission.
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214
Air Pollution Control Field Operations
The methods employed for tracking solid particu-
lates from unknown sources are the same as those
applied to liquid particulates, discussed previously.
Solid particles, however, are more readily traceable
due to the trails, drifts or piles they tend to leave on
the ground.
Where no immediate source is apparent in the
community, the inspector may be required to look for
large sources located at considerable distances from
complainants, such as steam-generating plants, ships,
industrial incinerators, etc., especially when such dusts
can be carried by strong prevailing winds, usually in-
coming shore breezes near the coast. A study of the
micrometeorology of the area, as with odors and stains,
will help locate a probable source area. Test panels
with a slight coating of petroleum jelly may be used
for tracking purposes.
The sample of the dust collected on complainant's
property may be used both as the sample for analysis.
if necessary, and as evidence. Its trail may be traced
to a source on the ground or through observation of
plume.
REFERENCES
1. Chass, R. JL, Testimony for Rule 64 before the Board of Super-
visors, June 25, 1959.
2. Clark, H. L. and Edelen, E. W., Odor Control in Los Angeles
County, L. A. Co. APCD Publication No. 27.
3. Crocker, E. C, Henderson, C. F., Analysis and Classification of
Odors, Am. Perfumer and Essent. Oil Rev. 22:325, 1927.
4. Dixon, A. B., L. A. Co. APCD, Enforcement Division, 1957.
5. Faith, W. L., Air Pollution Control, John Wiley and Sons, Inc.,
New York, odors, pp. 179-187, surveys pp. 225-327, 1959.
6. Franklin Institute Laboratories for Research and Development,
Odor, Measurement and Control, see especially "Deficient Mea-
surements Encourage Capricious Odor Control", by Richard D.
Hoak, pp. 2-9, April, 1959.
7. Fuller, L. J., Testimony for Rule 64 before the Board of Super-
visors, June 25, 1959.
8. Gruber, C. W., Odor Pollution from the Official's Viewpoint,
Presented at the Fifty-Seventh Annual Meeting, American Soci-
ety for Testing Materials, Chicago, Illinois, p. 16, pp. 56-68,
June 15, 1954.
9. Gruber, C. W., Jutze, G. A., Huey, N. A., Odor Determination
Techniques, Fifty-Second Annual Meeting of the Air Pollution
Control Association, June 21-26, 1959.
10. Haires, G. F., Jr., Hemeon, W. C., Method for Treating the
Ground-level Distribution of Stack Gas Emissions, Air Pollution
Control Assoc., Vol. 7, No. 4, pp. 226-265, February 1958.
11. Johnson, W. C., Kempe, L. L., Experiences in Controlling At-
mospheric Pollution Encountered in Pharmaceutical Manufactur-
ing Processes, Journal of the Air Pollution Control Association.
Suggested use of the Beaufort System. Vol. 9, No. 1.
12. Kerka, W. F., Kaiser, E. R., An Evaluation of Environmental
Odors, "Journal, the Air Pollution Control Association", Vol 7
No. 4, February 1958.
13. McCord, C. P., Witheridge, William N., Odors, Physiology
and Control, McGraw-Hill Book Company, Inc., p. 45, 1949.
14. Mills, J., Testimony for Rule 64 before the Board of Super-
visors, June 25, 1959.
15. Moncrieff, R. W., The Chemical Senses, John Wiley and Sons
Inc., pp. 166-235, 1944.
16. Nader, J. S., Current Techniques of Odor Measurement, Chem-
ical-Toxicological Conference, A.M.A. Archives of Industrial
Health, Vol. 17, No. 5, May 1958.
17. Neiburger, M., Tracer Tests of the Accuracy of Trajectories
Computed from the Observed Winds in the Los Angeles Area,
Report No. 7, Air Pollution Foundation, 1955.
18. Pfaffmann, C., Engen, T., Psychology: Absolute Judgments of
Odor, reported in abstract reported in "Symposium on Odors,"
A.M.A. Archives of Industrial Health, Vol. 17, No. 5, May
1958.
19. Prince, R. G. H., Ince, J. H., The Measurement of Intensity of
Odor, J. Appl. Chem., 8, May, 1958.
20. Sagarin, E., Odor: A Proposal for Some Basic Definitions, Pre-
sented at the Fifty-seventh Annual Meeting, American Society
for Testing Materials, Chicago, 111., p. 5, June 15, 1954.
21. Schueneman, J. J., What Cities Are Doing About Their Odor
Problems, Presented at the Metropolitan Cincinnati Conference
on Air Pollution Control: Odor Control, Cincinnati, Ohio,
October 25, 1956.
22. Sward, G. G., Surface Coatings,^ Scientific Section, National
Paint, Varnish and Lacquer Association, Inc. Roger's Industrial
Chemistry, 1942.
23. Tremaine, B. K., All About Odors, Air Engineering, p. 28,
October 1959.
24. Turk, Amos, (Odor) Control, Chemical-Toxicological Confer-
ence, A.M.A. Archives of Industrial Health, Vol. 17, No. 5,
May 1958.
25. Turk, Amos, Odor Control Methods: A Critical Review, pre-
sented at the Fifty-seventh Annual Meeting, American Society
for Testing Materials, Chicago, 111., June 15, 1954.
26. U. S. Weather Bureau, Meteorology and Atomic Energy, Wash-
ington; U. S. Government Printing Office, p. 140, 1955.
27. Wilkes, T. M., Dixon, J. A., Martin D. T., Rendering Plant
Operations and Operations and Control, A.P.C.D. Enforcement
Division report 1958.
28. Los Angeles County Air Pollution Control District, "Control of
Stationary Sources", Technical Progress Report, Volume 1, pp.
130-132, April I960.
29. DeVorkin, H., Manual of Source Test Methods, Los Angeles
County Air Pollution Control District, Manuscript in prepara-
tion, June 1961.
-------
CHAPTER THIRTEEN
COLLECTING AND REPORTING EVIDENCE OF VIOLATION
Virtually all of the inspection techniques de-
scribed in this manual are employed primarily towards
one end —• the collection oi data and evidence. In fact,
all data collected by inspectors are of ari evidentiary
nature. Evidence of compliance is as important as evi-
dence of violation. Data collected on surveys and
inventories are evidence which can be used in deter-
mining future enforcement policy. Whatever form the
data take, they will always consist of facts and findings
acquired, primarily, through the inspector's direct
senses, and reported and stated in such a manner as to
be clear of prejudices and other subjective factors.
The data collected by the inspector is written
down on a report form. The written report, however,
is not in itself the evidence that is normally used in
a court of law to prove a case. The evidence compiled
by inspectors consists primarily of testimonial evi-
dence, when the inspector testifies to the facts obtained
from his observations and inspections, and expert opin-
ion, when he testifies to the observations of excessive
emissions he observes. Physical or demonstration evi-
dence, such as photographs, samples of fuels, etc., are
also used in air pollution control cases. The written
report may not actually appear in court proceedings,
though it may be used to refresh the inspector's
memory.
I ESTABLISHING THE PRIMA FACIE CASE
To provide a sufficient basis for court prosecution,
the field inspector must gather the evidence essential
to establish a prima facie case — that is, a case, which
unless rebutted, adds up to the commission of a viola-
tion of an A.P.C.D. Rule or Regulation by the de-
fendant. Each and all of the individual elements of
the crime, (in legal terminology, the corpus delicti)
must be proved. Thus, if the prohibition is that "a
person shall not discharge into the atmosphere from
any single source . . . any air contaminant" of any
particular quality for more than the maximum per-
missible time specified, it must be proved that: (1) a
person (2) discharged (3) into the atmosphere (4)
from a single source (5) a contaminant (6) of the
quality proscribed (opacity or density) (7) for more
than the time specified.
If any of the required elements is absent, for ex-
ample it was not a single source, the corpus delicti is
not established and there is no case.
In some instances, in order for there to be a vio-
lation, there must have been knowledge or intent on
the part of the defendant. This is known in legal
terminology as "scienter".
Most prohibitory air pollution regulations do not
require scienter, but impose "strict liability" upon the
defendant. This means that "I didn't know the stack
was smoking" is not a defense any more than "I didn't
realize I was going that fast" is a defense for speeding.
In order to establish a prima facie case and to
meet the requirements for reporting the air pollution
"configuration" described in Chapter 9, the following
information must be reported by the field inspector for
each violation* observed.
1. The nature and extent of the violation.
2. The time and location of the violation.
3. The person (s) responsible for the violation.
4. The equipment involved with the violation.
5. The operational, design or maintenance factors
which caused the violation.
Each of these elements, in turn, requires a suffi-
cient degree of documentation before the violation can
be established. The courts require adequate proof of
all five of the above before conviction can be obtained.
It should be noted that even when a specific act
affecting the emission of air contaminants or air pollu-
tion rules is attended by all of the elements of a crime
discussed in this section, an actual violation does not
exist if the act is specifically exempted from the pro-
visions of the Rules and Regulations or is covered by
a variance. The legal authority usually makes certain
detailed exceptions of equipment or acts which need
not comply. For example, in Los Angeles County,
Section 24245 of the State Health and Safety Code
prevents the District from taking any criminal action
against publicly owned facilities. Section 24245 and
24251, agricultural operations, specifies conditions un-
der which violation of Section 24242, smoke and opac-
ity, are permissible. Detailed exemptions are also
made with reference to the permit requirements, such
as Section 24265 and District Rules 11 and 13.
A. The Nature and Extent of the Violation
This element of the violation requires that the
inspector determine the exact Rule which has been
violated by any specific type of air pollution problem.
The inspector, therefore, must be thoroughly familiar
with all of the Rules he may enforce in the field. These
fall into six categories: (1) excessive emissions (all
maximum permissible emission standards, including
public nuisance), (2) unauthorized construction or
operation of equipment, (2) uncontrolled equipment,
(4) bans, (5) noncompliance with alert instructions,
and (6) noncooperation and circumvention.
The severity or extent of the violation must be
determined before a violation can be demonstrated.
The "extent" of violation refers to the degree of air
pollution measured in terms of the specific standard in
the rule, or the extent of non-compliance with the
* Under Sections 24253 and 24281, any violation of the Health
and Safety Code or the Rules and Regulations is a misdemeanor
and each day the violation occurs constitutes a separate offense.
-------
216
Air Pollution Control Field Operations
phrasing of the prohibition in the rule. Most Rules
stipulate a single standard of compliance. The "extent"
in a Section 24242 smoke or opacity violation, for ex-
ample, is measured in terms of the Ringelmann stand-
ard. In a 24279 violation, unauthorized construction
of equipment, the extent is determined according to
the date construction took place and the degree of com-
pletion.
The fact that a violation is observed, must be ac-
companied, in the report, by the methods used to
measure the extent of the violation. The procedures
used in making visual determinations must be accu-
rately recorded. For example, each Notice of Violation
issued for a Section 24242, smoke or opacity violation,
requires the following data to confirm accurate use of
the approved smoke reading method (see also Figure
XIII-1):
1. Point of observation from source.
2. Weather conditions during observation.
3. Wind direction.
4. Visible emissions observed showing continuous
time intervals for each opacity and density, color
change, and total violation time in minutes.
5. Status of plume at end of recorded observation.
A Notice of Violation issued for invisible contami-
nants should be accompanied by the test results and
procedures used by the source testing team.
B. The Time and Location of the Violation
The exact date and time the violation occurred is
also a necessary element. The time of violation is gen-
erally noted in terms of (1) the time the inspector
arrived and the time he departed from the scene to
investigate the violation, and (2) the specific time
period or time intervals of the violation.
The time of violation usually is noted within the
"Arrival" and "Departure" times, although, in in-
stances where reinspections are necessary, the last in-
spection stop made may be a date and time occurring
after the violation was observed. The written Notice
contains a specific blank for inserting the "Arrival"
and "Departure" times. The Inspector's Field Report
(see Figure VII-7) provides blanks for showing the
total elapsed time of the inspection and the total time
spent at the source, to differentiate between the time
spent in conducting the physical inspection of the
premises and the time spent in writing the report, in-
terviewing complainants, and other related investiga-
tive work.
The location is the actual address at which the
violation was observed, the "RE PREMISES AT:"
blank on the Notice of Violation. The address must be
given in terms of number and street. If the number is
not known or available, the block number may be used
with the street name. The street name must be given
in full (including "Ave.", "Rd.", "Dr.", "PI.",
"Blvd.", etc.).
The city or community name must be that of the
post office delivering mail to the location. Should the
location of the violation be in unincorporated territory,
the post office or other legal designation must be used.
The location of the violation for moving sources
should be described as follows:
a. Ships — the berth and the harbor.
b. Locomotives — the street on which the inspector
observed and followed the train and the intersec-
tions and cities where observation began and
ended, as well as the direction traveled.
c. Vehicles — the actual location of the violation is
important, since the court jurisdiction is based on
that location where the inspector completes his
observation of the excessive emissions. The loca-
tion includes the street on which the vehicle was
followed and the intersecting streets at which the
observation began and ended. The initial and
terminal communities involved should be included
as well as the proper court jurisdiction.
C. The Persons Responsible for the Violation
Rule 2b includes under the term "Person" any
person, firm, association, organization, partnership,
business, trust, corporation, company, contractor, sup-
plier, installer, user or owner, or any state or local
governmental agency or public district or any officer or
employee thereof.
The "Persons" include all individuals responsible
for the equipment by reason of legal operations and all
individuals who may be responsible for the specific
act which resulted in the violation. The persons gen-
erally associated with the violation will consist of the
owners of the company, and the employees immedi-
ately responsible. Court action in most cases is filed
against the owners of the company, and sometimes
against both the owners and the employees immedi-
ately responsible for the operation of the equipment,
depending on the circumstances. In all investigations
of violations, the inspector must report the name of the
company, its form of ownership (company, partner-
ship, individual, corporation, etc.), the highest author-
ity contacted, and the name and description of the
employee or person operating the equipment at the
time of the violation. The association of all persons
involved, such as employee-employer relationship, etc.,
may be determined by direct interview.
The steps by which the persons responsible are
established, follow. The data should be written in the
appropriate blanks of the Notice. (See the Written
Notice of Violation, Figure XIII-1.)
a. Obtain the name and title of the person in highest
authority contacted.
b. Obtain the name of the firm or the person (in-
clude full name and middle initial) owning or
leasing the equipment. If the equipment is leased,
the lessee is responsible. The name of the com-
-------
Collecting and Reporting Evidence of Violation
217
pany should be designated as one of the following,
whichever is appropriate:
(1) Corporate Name—"Smith Products, Inc."
(2) Registered Fictitious
Owner—John Doe and Richard Roe, dba
"Rough and Ready Co."
(3) Individual Owner—"Joseph P. Doaks
(Apts.)"
(4) Proper Name Used Only —
"JudsonR. Smith (Apts.)"
"John Doe (Contractor)"
"Sam Rrown (Private Residence)"
(5) Division of Corporation—"Midwest Steel
Corp. (Pacific Coast Division)"
(6) Subsidiary — Subsidiary corporate name
alone may be used.
(7) Sole owner or partner — Show first and last
names of owners doing business as a cer-
tain company, such as "William Blake, dba
Tiger Upholstery Company." The names
of other partners should be listed under the
"Findings" portion of the Notice.
(8) Management Companies — Both the names
and the addresses of the management com-
pany and the legal owner should be sup-
plied. The report should be titled accord-
ing to the name of the activity at the
source.
(9) Driver's Identification (Vehicle) •— Driver's
full name, residential and business ad-
dresses, operator's or chauffeur's no., the
license number and state issued, and other
identifying data acquired from the driver's
license.
(10) Vehicle Identification — Registered owner
and address, license no., make, body type,
cab no. of tractor, state licensed.
(11) Locomotives—Railroad line and engine no.
(12) Ships — Name painted on either side of bow.
Nationality, determined by flag at stern.
Name of home port, usually across the
stern. Legal owner and official number lo-
cated on ship's document on board Ameri-
can coastal ships or at the United States
Customs Office, Federal Building, San
Pedro, in the case of foreign ships from
foreign ports of origin.
c. Obtain the address where the business affairs of
the company are conducted, i.e., the mailing ad-
dress. This address will sometimes differ from the
address at which the violation occurred. In cases
where the owner (corporation or individual) uses
an address other than the business address shown,
that address should also be shown.
d. Enter phone number of the owner or business.
e. Obtain the title, name and address of the person
actually carrying out the operation involved in
the violation. If possible, his automobile license
number should be obtained for positive identifica-
tion. The individual's connection with the firm
and his relation to the operation involved should
be determined by questioning that person to de-
termine whether or not the operation being car-
ried out was a part of his normal duties. The
interview should also disclose the name and title
of the person from whom the employee takes his
orders.
f. Statements are next recorded on the "HIS RE-
MARKS" section. These are the remarks made
by management and employees w h ic h are
pertinent to the elements of the crime. These will
include verification of ownership status, employer-
employee, manager-owner or tenant-owner rela-
tionships; permit status of equipment, practices of
management in regard to air pollution prevention,
the cause of the violation, knowledge of the law,
etc., and any other information related to the
violation.
D. The Equipment
The cause of the violation is ascertained from the
physical inspection of the source of emission or the
equipment involved in the violation. The first impor-
tant step in determining the cause of a violation is the
location of the specific piece of equipment responsible.
Equipment may be traced from the stack or ductwork,
observed directly as the source, or deduced through a
process of elimination as the only possible piece of
equipment capable of producing the plume observed.
In other cases, the responsible piece of equipment may
occur as one among several possible pieces of similar
or identical equipment. In these cases the inspector
observes plant conditions closely for those operating
cycles which result in excessive emissions. Excessive
emissions observed inside of the plant from equipment,
it should be noted, can be reported as violations, al-
though, as a matter of administrative policy, this is not
done.*
The identification of the equipment consists of
constructing a verbal description which positively
identifies the source as a specific class of equipment
capable of air pollution. The identification must do
two things: (1) It must distinguish the exact piece of
equipment from among all other equipment in the
plant, and (2) it must describe all of the important
constituents of the equipment which affect the genera-
tion of pollutants, or which possibly qualify the permit
status of the equipment. Below are listed some guide
points which can be used in identifying equipment.
* Rule 2n. " 'Atmosphere' means the air that envelops or sur-
rounds the earth. Where air pollutants are emitted into a
building not designed specifically as a piece of air pollution
control equipment, such emission into the building shall be
considered an emission into the atmosphere."
-------
218
Air Pollution Control Field Operations
1. The number of equipment units taken as the
single source.
2. The function or application of the equipment.
3. The class or design category of the equipment, or
the process in which it is used, or the materials
fed, if these are pertinent to a positive identifi-
cation.
4. Size, charge or feed capacity of equipment, if
these are pertinent.
5. The commercial name of the equipment and the
manufacturer's serial number, if any.
6. Plant's equipment location number or relative or
approximate location of equipment within the
plant.
7. Important equipment appurtenances which would
qualify its permit status, such as type of heating
element, blower motors, etc., together with man-
ufacturer's name and serial number.
8. Other equipment serving or served by the equip-
ment identified as the source.
9. Description, manufacturer's name and serial
number of all control equipment involved.
Examples of four types of source descriptions are
listed below. The numbers in parentheses refer to the
numbered guide points above.
a. One (1), Horizontal Return Type (3), Smith Iron
Works, Serial No. 2345 (5), eastmost of two (6),
Boilers (2), served by 2 Ray Rotary Cup oil burn-
ers, Serial Nos. 2000-1, 2000-2 (7). Both boilers
are breeched to a common 4-foot diameter x 30-
foot high stack (8). Westmost boiler not in oper-
ation at this time.
b. One (1), open fire (2), 5 feet diameter x 3 feet
high (4), consisting of eucalyptus tree cuttings,
tar paper, creosoted number, rubber tires, oil rig
timbers and paint cans (3).
c. Three (1), 350-pound (4), yellow brass, hydrau-
lic tilt (3), melting furnaces (2), venting directly
through one roof monitor, 20 feet long x 3 feet
wide (8). Melt contains 14% zinc, poured at
2200°F. All furnaces in full operation at this time.
d. One (1), Local Blower Exhaust System (2), XYZ
Pipe (5), ductwork, 24 inches diameter, 15 H.P.
blower capacity (4), served by one 3-foot diam-
eter cyclone (9), and serving four belt sanders,
one sticker, one tenoner, two planers, and one
cross-cut saw (8). Only the belt sanders were in
operation at this time.
Although the descriptions of the hundreds of dif-
ferent types of equipment vary considerably, the above
four examples are sufficiently typical to illustrate the
elements necessary in the proper description of the
source of emission, or the equipment involved in the
violation. As will be noted, the identification may also
include those design, process or operational character-
istics which affect the air pollution problem. The nota-
tions of the brass furnaces include, for example, the
amount of zinc melted and the pouring temperature.
Also, in this example, the entire roof monitor is taken
as the source and the important notation that all three
furnaces are in operation at the time of observation is
included. The findings may also include observations
of emissions within the plant. In example "d," the list
of equipment served by the blower system is important
in determining cause, since the notation that only the
sanders were operating may indicate that the cyclone
is not efficient in collecting sanding dust alone. Sim-
ilarly, in sample "a," the source is tied to one of two
boilers, the eastmost, both breeched to one stack, since
the westmost boiler, presumably used for standby pur-
poses, was not in operation at the time of the in-
spection.
E. Operational and Maintenance Factors
The identification of the equipment logically leads
to the next step in determining the actual cause of the
violation. In some cases, the identification will be suf-
ficient since, for example, an open fire per se is a viola-
tion of Rule 57, and if excessive smoke is also observed,
a violation of Section 24242. In the case of excessive
smoke (example "b"), the fact that the fire consisted
of such materials which cannot possibly be burned in
an open fire without emitting black smoke substanti-
ally in excess of No. 2 Ringelmann, the cause of the
violation is self-explanatory. In such cases, that aspect
of cause which relates to intent and responsibility of
persons who ordered and lit the fire are of prime
importance.
In more complex cases, however, a more detailed
explanation may be necessary. In refinery operations,
for instance, schematics of flow processes and material
flow with notations of vapor pressures and tempera-
tures, etc., are drawn to locate and estimate the pos-
sible losses of vapors and gases. In still other cases,
the inspector indicates, where appropriate, whether or
not combustion equipment operated at too low or too
high a temperature in degrees Fahrenheit, as against
normal operating temperatures; whether dampers are
stuck, flame ports are blocked, or auxiliary burners for
multiple chamber incinerators were firing, etc.
The inspector checks the equipment and deter-
mines by interview and observation the actual condi-
tions under which the equipment in question has been
operated during the time of the violation. The cause
of the violation may also be substantiated by state-
ments made by the plant operator under interview,
such as declarations regarding equipment failure, mal-
adjustment, poor maintenance, and variation in oper-
ating procedures. (See "Operational and Maintenance
Practices" Chapter Two). The causes which enter into
each of the categories of violation, of course, vary. In
establishing unauthorized construction, for example, it
is necessary to describe the actual physical status of
-------
Collecting and Reporting Evidence of Violation
219
construction, per cent completion, date construction
begun and completed, etc.
In establishing the cause of the violation, demon-
stration evidence may be gathered such as samples of
fuels used, smoky materials burned, metals melted,
odorous materials. Photographs can also be taken. As
a matter of fact, it is a routine enforcement procedure
to photograph visible violations observed.
II REQUIRED EVIDENCE FOR THE VIOLATIONS
The elements of the violation discussed in the
previous section are general principles which apply to
all violations observed by inspectors in the field. De-
termining the time, location and the persons responsi-
ble for the violation is virtually the same for almost
every violation. Obtaining evidence for determining
the nature, extent and the cause of the violation, how-
ever, varies somewhat according to the Rule being
enforced and the air pollution problem encountered
at each source. The additional evidence which must
be collected to substantiate the individual categories of
violations will now be considered. In some categories,
the primary evidence is obtained by the techniques
used to identify and evaluate source emissions, which
were treated separately for study in this manual.
A. Excessive Emissions
1. Section 24242, Smoke and Opacity
a. Stationary Sources
For excessive emissions of smoke, fumes and other
contaminants, the accurate use of the approved smoke
reading method as described in Chapter Ten, "Reading
Smoke in the Field," must be shown on the report or
notice. This will include not only an accurate record-
ing of each reading and the time intervals, but the
following as well:
1. Point of Observation: Direction and distance of
observer from the source, or the actual location
of the observer. If the exact location is not
known, the approximate distance can be given.
2. Weather: Designated as "clear," "overcast,"
"cloudy," "rainy" or "hazy"
3. Wind: The direction from which the wind blows,
recorded by circling the appropriate designation
on the Notice. If no wind is present, this fact
should be indicated. If the wind changes direc-
tion, all directions and the time of change are
noted.
4. End of Observation: Check "yes" or "no" to indi-
cate whether source was emitting visible dis-
charge at end of observation. Note last recorded
opacity or Ringelmann Number here. This in-
dicates the time at which the observation re-
corded on this Notice was completed.
5. Emission From: Circle appropriate source,
BASIC, CONTROL or OPEN FIRE.
1. Observing Emissions
The observation of the emission should not be
interrupted. During the observation period, the in-
spector should study the emission carefully, and note
the periods during which plume colors change and
densities or opacities fluctuate. The inspector should
note, as well, whether the volumes of smoke emitted
appear to consist of unusually large quantities of air
contaminants and whether the emissions fanned or
spread over a neighborhood. General remarks as to
the reduction in visibility in the community can be
noted.
Sharp changes in the physical characteristics of
the plume may indicate changes in operating proce-
dures, cycles or feeding of material to the equipment.
The times these changes become apparent can be later
correlated with the data gathered in making the physi-
cal inspection of the equipment.
Problems in determining the source and the cause
of the observed violation may be encountered in large,
complex plants. These problems arise when plants
with numerous pieces of equipment operate under
heightened production conditions. Many pieces of
equipment may contribute to the pollution emitting
from the roof monitors or stacks of a building. It is
desirable, therefore, that the interior and the exterior
of the plant be observed simultaneously by two or
more inspectors to determine the responsible equip-
ment and the operating conditions which resulted in
the violation. In conducting coordinated inspections of
this type it is important that the watches of all inspec-
tors concerned be synchronized, and that observations
of significant time and cycle factors be accurately
recorded.
In conducting a coordinated inspection it is per-
haps best to use a continuous observation sheet, such
as the "Engineering Division—Field Report" for the
opacities or densities of visual emissions observed out-
side of the plant. The continuous observation sheet can
be appended to the report or violation notice form.
Changes in the plume characteristics can also be noted
on this form. Another continuous observation sheet
can be designed on-the-spot by the inspector for re-
cording operational data inside of the plant. Such
sheets are designed to obtain the precise types of data
desired from the physical inspection. A sample ob-
servation sheet which might be used for a non-ferrous
foundry is shown in Figure XIII-2.
-------
220
Air Pollution Control Field Operations
76N634A— 1/35
Air Pollution Control District — Los
NOTICE
Blunthead Brass Products
OF
8965 East Warren Blvd., Los Angeles
4332 Mark Road, Los Aneeles
YOU ARE HEREBY NO1
24242 OF THE 1
STATE OF CALIFORNIA
MITTED THROUGH TH
Angeles County
VIOLATIO
14
12
^J Date 4-14-58
MO- 5- 635 2
•IFIED THAT PURSUANT TO SECTION
HEALTH AND SAFETY CODE OF THE
I A MISDEMEANOR HAS BEEN COM-
^ f ™f ~m;^ „„,;„„ f,,^..
POINT OF OBSERVATION: e. . ,
50 feet past of
WEATHER: Clear
ARRIVAL: 2: 25 %M
DEPARTURE: 5: 00 *JJ ST
WAS SOURCE EMITTING
VISIBLE DISCHARGE AT
YES B NO D
R. No. OR
OPACITY
EMISSiON ^RQL
FR°M: OPEN FIRE
(\J0i Rule 13 TOT/
TITLE President
No. F 2413
roof
WIND
VISIBLE
ART STOP
SUE
FIEl
\L
By
SE
»TTAI
n™
monitor
N
E
© W
EMISSIONS OBSERVED
WIN.
HHXE
rnr ([
16
R. No.
%OP.
1GMEER
COLOR
MG
MIN.
LLOYD H. McEWEN
Director of Enforcement
Robert Henderson
John Snith
CTOR
8
OPERATOR: An,nl,l H.i,«,n 5*2.1 P»»l, Avxnnit
HIS REMARKS: fc melt yellow bra3s ^^ about 2S% zinc. The scrap metal
WAS MANAGEMENT CONTACTED YES ffl NO D
NAME: William Sin,pSon TITLE: Pres.
HIS REMARKS: u
-------
Collecting and Reporting Evidence of Violation
221
AIR POLLUTION CONTROL DISTRICT--COUNTY OF LOS ANGELES
434 South San Pedro Street, Los Angeles 13, California. Telephone MAdison 9-4711
ENGINEERING DlVISION—FIELD REPORT
NAME OF APPLICANT DATE OF INSPECTION
Blunthead Brass Products U-ll;-58
EQUIPMENT LOCATION (ADDRESS) PERMIT '"» . NO.
U332 Mark Road, Los Angeles 12, California
SOURCE OF AIR TYPES OF AIR _
CONTAMINANTS Five Brass Furnaces CONTAMINANTS Fumes
OBSERVATION 50 feet east of roof vent D°SCHARSE Roof monitor
WEATHER __
Clear
"IN°From south OBSERVAT.ON: FROM 2:30 P.M. T°li:13 P.M.
OBSERVATIONS OF VIS
TIME
FROM
2:20
2:51t:30
2:58:30
3:00
3:02
3:05:30
3:10:30
3:12
3:15
3:17
3:30:30
3:35
3:38:30
3:UO
3:la:30
3:ii5
U:00:30
U:03
U:10:30
•COLOR
"B" MEANS
"W" MEANS
TO
2:5U:30
2:58:30
3:00
3:02
3:05:30
3:10:30
3:12
3:15
3:17
3:30:30
3:35
3:38:30
3:ltO
3:U.:30
3:U5
U:00:30
li:03
It: 10: 30
lit 13
CODE:
BLACK
WHITE
Bluish-Mu
MEANS
INTERVAL
MIN-
UTES
1
2
3
5
l
2
It
2
3
?
2
21
.te
SEC-
ONDS
30
30
30
30
30
30
30
30
% OPAC 1 TV
OR
RlNGEL-
MANN NO.
0
30£
Wo. UJ
60%
5o^
60$
70$
30$
55$
20$
80$
30$
75$
20$
60$
30$
65$
20$
100$
COLOR
* (SEE
CODE
BELOW)
Bl
B
Bl
Bl
Bl
Bl
Bl
Bl
Bl
Bl
Bl
Bl
Bl
Bl
Bl
Bl
Bl
Bl
BLE AIR CONTAMINANTS
Trace emissions observed only.
Color change.
16 minutes total violation time
for first hour.
5 minutes total violation time
for second hour.
TOTAL TIME OF DISCHARGE OF AIR CONTAMINANTS OF DENSITY
^~ (OR opftfiTY) OF ?ij R and i)0$ OR RREATER
SI
P»
-------
222
Air Pollution Control Field Operations
Air Pollution Control District-Los Angeles County
Olfense 1234
DATE June 6t 1960
Time.-L-3~5.iil— —...
NOTICE TO APPEAR
Exhibit A
Oper. No.
B100001
C- 9403
A.P.C.D.
Sex
M
Height
Dale of Birth
Oct. 3, 1929
Weiqht
165
Color Eyes
Brown
Black
Driver ..John .Albert JBroan
Res. Add. .._L6AQ_Eask-:M_n.-Street____
Ciiy.Los. Angel es.X-Cal if,
Bus. Add..J.fl01.WesL.12th.5t Cily...Downey.
VIOLATION,!
VC Sec. 27153 On..._Hari>or-.Creeway-
Inspecto
Detail..
Bodge No 1Q-.
Vac to
YOU ARE HEREBY NOTIFIED TO APPEAR AT THE TIME AND
PLACE CHECKED BELOW:
Before the
the__..22nd
at 833 South Wall Street, Los Angeles.
Municipal Court Judge in Div. 50 at 9 A.M. on
the__..22nd day of June , 19.6Q_...
/tuvenile/Court Traffic Div. ay
/
between / M. and
/ 19 /. Accompanied byYarent or Guardian.
WITHOUT ADMITTING GUILT. I PROMISE TO APPEAR AT THE
TIME AND PLACE ABOVE NOTED.
Signed... John. Albert. _Br aim. Driver
Address.-J.6u4(l-E..Main.Sti:eet
___
.--.-Emit ting, white, -smoke., of .-7D%.-Opaci-ty.-contirmQusJ.y.—
VIOLATOR'S COPY
IMPORTANT READ CAREFULLY
The Original of this Notice to Appear will
b>;- Med with the Municipal Court. You are re-
quired to appear in the court indicated on the
face of this citation.
FAILURE TO APPEAR AS PROMISED WILL
CONSTITUTE ADDITIONAL VICXATIQN WITH
ADDITIONAL PENALTY.
PERSONAL CHECKS cannot be accepted as
payment of f^nes or deposits for bail.
Sec. 27153V. C. EXHAUST PRODUCTS. No
motor vehicle shall be operated in a manner re-
sulting in the escape of excessive smoke, flame,
gas, oil, or fual residue.
B.
%
w
CC
E-
O
r-r—
fef^ J°hn Albert Brown
Address .16.40.E,.Afein.St,J..L«.A,.2J..Calif:
Lie. No -HSK-3aO Year-.lS&Q
Veh. Yr. 1 Make Body Type
IQ^Q 1 FnrA 2 Hr. Sprlan
Passengers
CAB NO M 2 F 1
_ Weather Street TraiHc
E
Defendant is to be admitted to bail in
the sum of $
Judge of the Municipal Court
-guilty, personally waives
Defendant pleads
jury trial. Trial set
Sentence:
Count 1 $ or days
c.
Figure XIII - 4. A.P.C.D. Vehicle Citation quadruplicate: A—Completed face of citation registering on all four copies, B—reverse of the
court complaint copy, (the first copy), C—reverse of violator's copy (third copy), A.P.C.D. copy and inspector's copy are identical to the
above.
Note that on the continuous observation sheet for
visible contaminants, Figure XIII-3, the greatest opaci-
ties were observed from 2:54:30 to 3:10:30, when the
brass scrap was being charged to the furnaces and that
at 2:58:30 a gray emission was observed due to the
oily scrap charged to the No. 2 furnace. Opacities also
heightened momentarily with each pour during the
pouring period, 3:30 to 4:10. From 3:15 to 3:17 the
opacity of the fumes also increased as a result of an
excessive temperature being reached in the No. 2
furnace.
In this fashion, the two continuous observation
sheets can be compared to determine the exact cause
of the violation in each instance and all of the equip-
ment and operating conditions which contributed to
the generation of excessive emissions.
During such observations, a third inspector might
take photographs of the exterior and interior of the
plant and interview plant management.
For night observations the vehicle spotlight should
be trained on the plume in the absence of a sufficient
amount of street or moonlight, from a point opposite
the inspector, and as near to the line of the observer's
sight as possible, i.e., between the observer and the
spotlight. This procedure is intended to avoid as much
as possible errors resulting from the reading of reflected
light. It is preferable that readings be made without
the use of artificial light source.
b. Moving Sources
(1) Motor Vehicles
The method of observing .excessive emissions from
motor vehicles was described previously in Chapter 10,
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Collecting and Reporting Evidence of Violation
225
Air Pollution Control District — Los Angeles County
434 3D. SAN PEDRO ST., LO9 ANOELEB 13, CALIFORNIA
Date __I4kL _ LQ __ I960
Time ___ PM _3l05 _ AM
V 8258
_
Veh. Lie. No. jS__Li LO. I _________ State _ .CALJ.E, _ . Cab No. 1 9 __
Reg Owner TRI-WAV TRUCKING C.O . INIC. _____
Address 9601 LOW EM RD.
City or Community CQMPTOM, TALlF.
n,iv»r JOHN PRESTON
Res. Address
LM ST. Ci
City
MAILING ADDRESS
36O5 LO\AlE-M RD,
COMPTOM
SEX
M
HEIGHT
6' Q'I
-2
COLOR OF EYES
BLUE
DATE OF BIRTH
DEC, 10, 1930
COLOR OF HAIR
WEIGHT
194 UK.
VEH. TYPE - COLOR
J;L
W 1 E
WEATHER TYPE OF OPERATION TRAFFIC
FOG RAIN THR-GEAR ' ^-^^
YOU ARE CHARGED WITH A VIOLATION OF SECTION 24242 OF THE
HEALTH AND SAFETY CODE OF THE STATE OF CALIFORNIA BY
**" ^4 SLAC.K
EMITTING
SMOKE AGGREGATING
_8 _ MINUTES IN ONE HOUR FROM 8'. 5O d M TO
_9,'O2- _ AM _ WHILE TRAVELING ON ALAN[JE.DA _ ££ _
FROM -4LONDRA BL.(&oMPTQH>o VERNON AV, fL./l^
>..J.
13/3
61
Address Inspector UaU(ie .\'n
NOTE: PARTIES CONCERNED WILL BE NOTIFIED BY MAIL OF
THE ACTION TAKEN ON THE ABOVE CHARGE.
Figure XIII - 5. Vehicle Notice.
Reading Visible Emissions, "Reading Smoke in the
Field." But the procedures for reporting violations
from automobiles used as private passenger vehicles,
and commercial trucks, vary.
Passenger vehicles emitting excessive smoke are
cited under Section 27153 of the Motor Vehicle Code
of the State of California which states that "no motor
vehicle shall be operated in a manner resulting in the
escape of excessive smoke, flame, gas, oil, or fuel res-
idue". The term "excessive" in this law is not defined,
but it can be taken to mean any quantity of smoke
which is outstanding enough to draw attention to the
vehicle emitting it.
The inspector should be prepared to define what
he thinks is "excessive" in each situation. Normally,
as a matter of policy, the inspector will employ a 40%
opacity standard without the time element. But if the
smoke plume obscures the traffic area, is continuous
through more than one gear, is outstanding, or is a
nuisance, he can take action under Section 27153.
The citation used in Section 27153 cases is similar
to those used by police officers for citing moving viola-
tions (see Figure XIII-4). The first copy serves as the
court complaint, the second is reviewed and filed for
record, the third is served to the defendant, and the
fourth is retained in the citation book to refresh the
inspector's memory should a court appearance be
necessary.
The citation must be made out accurately the first
time. Section 40505 of the Vehicle Code requires that
all written information set forth upon the original
(pink copy) shall also appear on the Violator's Copy.
Where errors due to inaccuracy and omission on
the citation occur, a special Citation Correction Request
is prepared. This is usually stapled to the citation.
Since violators are cited directly to court it is im-
portant that the inspector insert on the Citation the
proper court jurisdiction. For the purpose of identify-
ing the jurisdiction, the inspector consults a specially-
prepared map.
For trucks and commercially-owned vehicles, the
citation can be used, or the special V-type Written
Notice (Figure XIII-5), but never both for the same
vehicle. The V-type Vehicle Notice parallels the
Notice of Violation used for stationary sources in that
the Section 24242 standard is applied. The inspector
must follow the vehicle until he obtains an emission
which exceeds more than No. 2 Ringelmann for a
period totaling more than three minutes in one hour.
The variation in emissions exceeding the No. 2 Ringel-
mann standard, however, need not be itemized. The
inspector uses the accumulative stop watch method by
totaling the periods of time in which Ringelmann dens-
Figure XIII-6.
operator.
Serving a Vehicle Notice to a diesel truck
-------
224
Air Pollution Control Field Operations
ities of No. 2 or more are observed. To allow for mar-
gins of error, the violation observed should exceed No.
3 black smoke and total more than 4 minutes in any
one hour.
The V-Notice differs from the C-Notice in that it
does not cite the violator directly to court. Legal action
is taken by preparing a Request for Complaint in the
same manner as for stationary sources. The parties
concerned are notified after filing of complaint. The
V-Notice thus can be used for charging owners of the
commercial vehicle with the violation and is particu-
larly useful when a trucking firm operates vehicles in
poor condition. The C-Notice, for commercial vehicles,
is used only when the driver appears responsible for
the violation as a result of poor operation of the equip-
ment. The decision to use either of the two violation
forms, therefore, must be based on the merits of each
violation.
(2) Ships
The problems encountered in citing ships for vio-
lations differ greatly from those found in other areas
of enforcement due to such factors as mobility, and the
special laws, customs and mechanics involved in their
operation. However, the inspector must be able to
analyze the circumstances surrounding ship violations
to determine whether or not a Written Notice is to be
issued and to compile the evidence necessary to estab-
lish a sound legal case.
With the exception of U. S. Government ships and
foreign men of war, over which the A.P.C.D. has no
jurisdiction and which should not be boarded, all ships
are required to comply with A.P.C.D. Rules and Reg-
ulations.
Ships of foreign registry, manned by foreign
nationals, may be boarded and the boiler room in-
spected only with the consent of the captain. If objec-
tions are raised to the investigation, the inspector
should conclude his business quickly and depart. Since
the ship represents a foreign nation, the inspector must
maintain a diplomatic attitude while on board.
Although the inspector may legally serve a notice
to a foreign ship, it is well to establish by questioning
before proceeding with the investigation whether by
previous visits to the port, or through notification by
their agents, the officers of the ship understand the
Rules and Regulations of the Air Pollution Control
District. With few exceptions, informed personnel on
foreign ships are willing to comply with local rules
and regulations. If it is determined that the ship does
not have this information, the A.P.C.D. Rules and
Regulations and the need for them are briefly ex-
plained by the inspector.
When recording opacity readings from the smoke-
stacks of ships, the inspector should, if practicable, be
in such a position that:
(1) The source is within 500 yards.
(2) The sun is perpendicular to the line of ob-
servation, if possible.
(3) The line of sight is at right angles to the
direction of the plume.
Before boarding, the ship may be identified from
the following:
(1) Name of ship painted on either side of bow.
(2) Registry (nationality) determined by flag at
ship's stern.
(3) The name of the ship's home port customar-
ily painted across the stern.
The inspector consults a card file maintained in
his vehicle for previous record of violation and other
information at hand, or contacts the regular ship's
inspector or the office of the A.P.C.D., in the event that
procedural questions should arise.
In boarding ships, the following contingencies
should be noted:
(1) A ship should not be boarded which flies the
yellow quarantine flag.
(2) Access to the ship is usually gained by means
of the gangway normally located about half-
way between the ship's bow and the stern.
(3) U. S. ships requiring U. S. Coast Guard Se-
curity do not allow anyone on board without
a U. S. Coast Guard Port Security Card.
(4) Once aboard, the inspector does not attempt
to proceed through the ship unaccompanied.
The inspector contacts the nearest ship's offi-
cer or crew member and asks to be directed
to the Captain. All A.P.C.D. business should
be conducted with the captain or, in his ab-
sence, with the next senior officer.
(5) The inspector then identifies himself and
states the nature of his visit.
Since a ship may not remain long at the location
at which the violation occurred, a full and correct
identification of the ship, her owners and responsible
persons must be obtained and recorded on page one of
a special questionnaire form completed during the
inspection of the ship, along with the written notice of
violation (see Figure XIII-7).
In establishing identity and responsibility, the
ship's document should be examined. It contains a
complete description of the legal owner and the official
number of the ship. The number, usually found in the
upper right-hand corner, rather than the name (since
several ships may bear the same name) serves to posi-
tively identify the ship. Documents for ships required
to clear through U. S. Customs may be found at the
U. S. Customs Office, Federal Building, San Pedro until
sailing time. The inspector requests from the captain
the information required to complete the question-
naire, and verifies the information so obtained by
calling at the customs office for the purpose of citing
the ship's document. However, if the document is
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Collecting and Reporting Evidence of Violation
225
INSPECTORS' QUESTIONNAIRE FOR STEAMSHIPS
WRITTEN NOTICE NO. -F-7U BERTH NO.
I, NAME OF •="!" S. S. Neversail
December 31. 1960
2. REGISTRY (NATION) Republic of Panajpj HOME
3. REGISTERED OWNER Nonesuch Banana Company ( ]M
ADDRESS 15 Pftseo del Paaeo. Panama City. [Y]c
Republic of Panama Qp_
EBilEccn
K ENG. WATCH
FIREMAN
<) r-HiqTCBCD
FIRST
Leslie
Ernest
John
h 456. San Pedro.
(N
Jo
Ri
LE LAST N
AD Smith
LE LAST H
hard Henrv t
LE LAST N
ornla INCORPORATION
T ION
T ION
T 1 ON
ITY
ADDRESS 16 Slippery Street. Los Angelea 14. Calif.
Berth 654. San Pedro. California [5] CORP OH AT I ON
BOILER NO.
TE«F.I«C.I -MS— 74.
i] W 650
17. CONTROL. MANUAL^ AUTOMATIcO NAME AND TYPE. IF AUTOMATIC
18. DRAFT- FOHCEoH INOUCEoQ NATURAL^ NO. BLOWERS ON BOARD 4
NO. BLOWERS IN USE ! STEAM OBIVE[3] ELECTRIC DRIVEQ
19. REMARKS: (AGENTS NOT IF I EO )(BREAKDOWN INFO.)
Three electrically driven endless belt avatemg in operation. No other
equipment noted which could cause surge demands on boilers. Agent, owners and
agent notified.
Figure XIII - 7. Inspector's Questionnaire for steamships. This
form is used to obtain evidence relating to the ownership of the
ship (home port, charter agent, etc.) and the operational data of
the fireroom (hoilers, burners, draft control methods, light-off
methods and breakdown information) in establishing the facts of
the violation.
aboard the ship it should be produced for inspection so
that the information may be directly obtained.
Certain conditions occur which normally exempt
ships from violation. During periods when ships are
maneuvering in confined waters, many sudden
changes in the demand for steam from the boilers
occur. At such times, the fireroom personnel are
obliged to cut burners on and off as fast as possible.
Special, large, maneuvering tips are used in the burn-
ers to insure maximum power, if required. It is usually
impractical to maneuver the average merchant ship
without making smoke, a fact which can be substanti-
ated by expert testimony in court. Therefore, Section
24242 and Section 24243 are not applicable for ships
while underway in the harbor or maneuvering to get
underway or alongside. In this connection it should be
mentioned that it usually takes not less than one-half
hour for a newly arrived ship to change her boiler
plant setup, i.e., put in smaller burner tips from
maneuvering to "in port" during which period of time
some smoke is unavoidable, although the usual pre-
cautions may have been observed.
Blowing tubes to eliminate soot is also considered
necessary to avoid a serious fire hazard, and a citation
for violation of Section 24242 should not be served.
However, ships are required to blow tubes at such
times when the wind will carry the resulting soot
emissions away from such shore installations as park-
ing lots, yacht harbors, cafes, warehouses, etc. If an
inspector observes a ship blowing tubes in such a man-
ner that a public nuisance is committed, he may serve
a Notice for violation of Section 24243. If complain-
ants are available and are willing to appear in court
they should be given nuisance complaint forms for
completion.
In all cases where a written notice is to be served
and in cases where there is doubt in the mind of the
inspector as to the actual cause of the violation, per-
mission to inspect the fireroom of the ship to obtain
information for completion of the questionnaire should
be requested. When the investigation discloses that a
smoke emission was the result of a mechanical break-
down or engineering casualty beyond control of oper-
ating personnel (such as burned-out blower motors,
water in fuel oil, pump casualty, etc.) service of a
written notice is inadvisable. Courts do not as a rule
convict steamship companies when equipment break-
downs can be demonstrated. However, a complete in-
spector's report should be submitted.
If, after inspection, there is reasonable doubt in
the inspector's mind that an engineering casualty
occurred, he should serve the written notice to the
captain or officer acting in his place. The completed
questionnaire is then submitted to describe the circum-
stances of the violation and substantiate the notice.
After leaving the ship, the inspector proceeds to
notify the office of the owner's agent and/or charterer
of the fact that the ship has been issued a written no-
LOS ANGELES COUNTY AIR POLLUTION CONTROL DISTRICT
NOTICE TO SHIPS
WHILE IN LOS ANGELES °* LONG BEACH HARBORS
EXCESSIVE SMOKE
CALIFORNIA PROVIDES THAT A PERSON SHALL NOT DISCHARGE INTO
THE ATMOSPHERE SMOKE OF 40% OPACITY OR GREATER FROM ANY SOURCE
WHATSOEVER FOR MORE THAN 3 MINUTES IN ONE HOUR.
BOILER TUBE BLOWING
IF BOILER TUBES ARE BLOWN WHILE ALONGSIDE DOCK IN A MANNER THAT
RESULTS IN SOOT BEING DEPOSITED ON SHORE IN SUCH QUANTITIES AS
TO CREATE A NUISANCE. SECTION 24243 OF THE HEALTH AND SAFETY
CODE OF THE STATE OF CALIFORNIA WILL BE ENFORCED.
SECTION 24243 PROVIDES THAT A PERSON SHALL NOT DISCHARGE FROM
ANY SOURCE WHATSOEVER SUCH QUANTITIES OF AIR CONTAMINANTS OR
OTHER MATERIAL WHICH CAUSE INJURY. DETRIMENT. NUISANCE OR
ANNOYANCE TO ANY CONSIDERABLE NUMBER OF PERSONS OR TO THE PUB-
LIC OR WHICH ENDANGER THE COMFORT. REPOSE, HEALTH OR SAFETY OF
ANY SUCH PERSONS OR THE PUBLIC OR WHICH CAUSE OR HAVE A NATURAL
TENDENCY TO CAUSE INJURY OR DAMAGE TO BUSINESS OR PROPERTY.
VIOLATORS OF SECTIONS 24212 Oft 2^243 ARE GUILTY
OF A MISDEMEANOR AND SUBJECT TO COURT ACTIOH.
MAXIMUM FINE $500 OR 6 MOUTHS IK JAIL OR BOTH
FOR EACH OFFENSE
Figure XIII - 8. Informational poster for ships.
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226
Air Pollution Control Field Operations
tice. The agent is given any of the pertinent facts "fallout" area, may be sufficient. A "large" number
surrounding the violation which appears on the face of of persons residing in proximity to the source, or along
the written notice. This notification is considered an attenuated pattern of fallout or prevailing wind pat-
necessary so that the agent has time to prepare a tern, may also be sufficient. Legal action, however,
written statement from the captain and/or notify the cannot .be taken by the District for one or a few per-
insurance underwriters before the ship sails. The fact sons adversely affected, since they are not a "consider-
that the agent has been notified is included in the able number" of persons. If the nuisance involves one
inspector's report. or a few persons quite close to the source, the problem
is viewed as a legal dispute confined between the
(3) Railroad Trains parties involved. The person, or the few persons in-
Special data pertinent to responsibility and cause volved, must initiate civil suit privately.
are also required for locomotives which smoke ex- The question can be asked, does the number of
cessively. Since locomotives cannot be halted, the persons involved appear to represent a significant por-
inspector reports his findings on the general report tion of the community capable of being affected by the
form, The Inspector's Field Report. The following
- -111 AIR POLLUTION CONTROL DISTRICT - COUNTY OF LOS ANGELES
data are included: at SOUTH ,.„ PEDRO STREET. LOS ANGELES 13. c.LiFomi.
1. The street on which the train was observed and ^'SANCE ""•""-*"" F°™
followed and the intersections and cities where the '' "!!"" """"•""" °F: n.nn|..n Benderin, P1.nt 0>TE
observation began and ended. 2. £;;;;.— 34672 Bandi"i B°°'""J' '"" A"f""
2. Periods of excessive smoke either by interval or ""«« 3026i*so!thPw"dlrd st ~n HOW^ON.^^"*!!!!^
accumulated stopwatch method. n>°"i»Ess HLI.ED
3. Name of railroad and locomotive number. *• °^S"J|"S™°" *°"""—2Yl " 3""" °i««"o« ™°» "««" s<"ltl""t
4. Direction traveling. f™""" -^^T^^ "EVAIL'"G W'"D °'"ECTIOB JUu±tsjuli-
5. Whether the train was going upgrade, downgrade "°" °FT" J""B'Q''^ TIBE or Etrly evenin(r
or level, whether it was stopped or moving. Give s ^ ^ ^ s"OST ™"U«T »«« —Mo'"'*Y ..j T^*^ ^^ r.voitin. odor,
approximate speed and number of cars. »-i>» uia_mun m* inm.in.
6. Was engine being sanded?
^ b. DISTRESS OR ILL EFFECTS: H ft U a e. ft... a n d ___H.B.g_S ); fl t Q HI_flgh _i
2. "Invisible Contaminants" OHE ^"l" OUW AN ATTEMPT TO S5U1 THAT THE VALUE OF
' HIS PROPERTY DECREASED BECAUSE OF THE NUISANCE? No
permissible" Standards in all reSpeCtS eXCept that re- "• »«° COMPLAINANT DEFINITE EVIDENCE, «, INCREASE >N COST OF CLEANING OR LAUNDRY! .
suits of laboratory testing are required. These proce- 12. ...T „•,»,.....« ™ ..„...,»,
dures were described in detail in Chapters 10 and 11. ,3. .„. „„ ym, rn..,rr Tlll.,,,~. Tn .„,.„, Tr.i=ed od<,r ^ .„„,.
Preliminary inspections involving these rules are u- ""LL COMPLAINANT APPEAR IN COURT' -Jf£S
J I O (5. SIGNATURE OF COMPLAINANT
reported on the general form, the Inspector's Field Re- ">• «««««< —
port. A Notice of Violation usually cannot be written _
under these rules without evidence furnished from
INSPECTOR , NOTICE NO.
source tests and laboratory analysis. If the test results "on26.
disclose a violation, a Violation Notice may be written FigUre xill - 9. Nuisance complaint form prepared by com-
and issued. plainants for information and use of the District or City Attor-
ney.
3. Public Nuisance
The nature and extent of a public nuisance viola- nuisance? Does the inspector himself feel that an
tion are determined by the community affected. Any undesirable or obnoxious nuisance exists? If he does,
quantity of air contaminants emitted which affect the the inspector himself is automatically one of the wit-
health, comfort and property of any considerable num- nesses. Also those persons who complain, or express
ber of persons is prohibited by this rule. Although the a strong attitude of annoyance towards the nuisance
District initiates legal action in public nuisances and do not materially count in establishing the nuisance if
makes every effort to compile the necessary evidence, they are incapable or unwilling to give testimonial
it is incumbent upon the witnesses to prove that they evidence in court.
are adversely affected by the contaminants. In any public nuisance actiorj5 therefore, the in-
What constitutes a "considerable number of per- spector interviews potential witnesses. It is not his
sons" depends on conditions. A relatively small num- purpose to urge, force or persuade witnesses into court.
ber of persons adversely affected by the air contami- The inspector is limited to determining (1) whether
nants and confined to a definitely limited "effect" or the complaint is justified, (2) whether or not the com-
-------
Collecting and Reporting Evidence of Violation
227
plainant will testify. If the complainant is willing to
testify in court, the inspector gives the complainant
a District Attorney form (see Figure XIII-9) to com-
plete in his or her own handwriting. When a sufficient
number of these forms are collected—at least enough
to represent the community—a Section 24243 Public
Nuisance Notice is written and served to the responsi-
ble parties at the source. The Inspector's Notice must
show the manner in which he has tracked and identi-
fied the contaminants as discussed in Chapter Twelve.
The operating conditions, the cause of the emissions of
the undesirable air contaminants should be noted as in
any other violation involving the emission of excessive
air contaminants.
B. Unauthorized Construction or Operation
of Equipment
The authority behind the operation and enforce-
ment of the permit system consists of the following:
(See also pages 252-254, Chapter 14.)
Rule 10—requires authority to construct and per-
mit to operate and posting of operating
permits.
Rule 11 and Section 24265—exempt many pieces
of inconsequential equipment.
Rule 12—permits are nontransferable.
Rule 13—blanket permits for equipment operated
between December 1, 1947 and Febru-
ary 1, 1948.
Rule 14—requires submission of applications for
permit and authority to construct.
Rule 18—governs action on applications.
Rule 19—requires provision for sampling facilities.
Rule 20—standards for granting permits.
Rule 21—conditional approval.
Rule 22—denial of application.
Rule 23—further information which may be re-
quired.
Rule 24—applications deemed denied.
Rule 25—appeals.
Regulation III deals entirely with the subject of
permit fees.
Section 24278—unauthorized operation under a
suspended or revoked permit.
Section 24279—unauthorized construction and
operation of equipment.
Section 24280—operating contrary to provision of
permit.
1. Section 24279
In Los Angeles County the inspector is not
directly concerned with the processing of permit appli-
cations or engineering analysis — this is the function
of the Engineering Division — but rather with the
enforcement of Sections 24278, 24279 and 24280 of
the State Health and Safety Code which deal with
unauthorized construction and operation of equipment.
When the inspector finds such equipment, he serves
either a Notice of Violation and a Request for A.P.C.D.
Permit (see Figure XIV-17) or the Request alone, de-
pending on the "extent" of the violation. The Notice
leads to direct court action whereas the Request allows
the owner or operator to apply for his permit within
10 calendar days.
a. Determining Permit Status
In determining unauthorized construction and op-
eration (Section 24279), the following standards and
tests are applied in determining the "permit status" of
each piece of equipment, i.e., the exact status of com-
pliance with respect to those rules and regulations
which govern the operation and procedures to be fol-
lowed in the permit system. If all three of the follow-
ing conditions obtain, then the equipment comes within
the jurisdiction of the permit system.
1. The equipment is capable of emitting air contam-
inants as defined by Section 24208. (See Chapter
9, Identifying Effluent Plumes.)
2. The equipment was constructed, altered, replaced,
or was involved in a change of ownership or
change of address location anytime subsequent to
the effective dates when permits were required by
the Rules and Regulations. (See page 252, Chap-
ter 14.)
3. The equipment is not legally exempted by Rule 11
or Section 24265, or it is not administratively or
temporarily exempted.
The second step in determining permit status
concerns an accurate determination of 2 above — the
exact reason a permit is required. This is accomplished
by determining the status of construction, the status of
ownership, the status of location, and the structural
status of equipment. Should there be a change in any
of these statuses and Conditions 1 and 2 above apply,
then the status of the equipment with reference to the
permit system is one of noncompliance.
(1) Determining Status of Construction
(a) If the construction or installation of the equip-
ment was completed more than six months pre-
viously, and no change of ownership was involved
since the construction date, then the status of the
equipment is administratively considered as "new
construction." Equipment with this status requires
a permit to operate and the inspector issues a RE-
QUEST TO APPLY FOR A.P.C.D. PERMIT.
(b) If the equipment was constructed or installed
within an approximate previous six-month period,
or is now being installed, it is administratively
considered as involving "recent" or "current con-
struction", and will require a permit. (An F-
NOTICE usually is issued.)
(c) If new equipment is partially constructed on the
premises of the company, but is not being con-
-------
228
Air Pollution Control Field Operations
(d)
structed during the inspector's observation, and if
the responsible person claims that the equipment
is not being constructed or used, and that the
company does not intend using the equipment in
the immediate future, a permit is not required.
The person should be informed that any further
construction is illegal unless he applies for and
receives an "Authority to Construct" from the
A.P.C.D.
If new equipment is on the premises and the per-
son claims that no additional construction is un-
derway, but the inspector on subsequent visits
observes construction of equipment taking place,
or observes progressive completion of construction,
then an "Authority to Construct" is necessary and
the inspector serves an F-Type Notice.
(2) Determining Status of Ownership
The number of different situations in which own-
erships can change among partnerships, individual
owners and corporations are numerous. These are
listed in Table XIII-1.
TABLE XIII-1
CHANGE OF OWNERSHIP SITUATIONS
PARTNERSHIP AND INDIVIDUAL OWNERS
1. Any change from individual ownership to partnership or from partnership to individual owner
2. Individual ownership or partnership purchases equipment Irom another individual, partnership, or
corporation
3. Individual owner or partnership incorporates
4. Individual owner or partnership changes name of business only.
5. A partnership with more than two partners is operating a business and the partnership loses one or
more of the partners, and a partnership still exists.
6. Partnership of two or more partners obtains an additional partner or partners.
7. Partnership of two persons is dissolved by one partner dying, or otherwise leaving, and business con-
tinues operation as an individual ownership.
8. Man and wife operate a partnership and:
a. One dies.
b. They are divorced and one takes over operation as an individual owner
9. Individual owner or partnership sells all assets of business and it then changes from a subsidiary
company to a corporation without change in name of subsidiary.
10. A trustee is operating a business and another trustee, for any reason, is appointed in his place.
CORPORATIONS
1. Corporation sells equipment to another corporation, individual or partnership.
2. "A" Corporation builds a new plant and obtains permits. Plant is then leased to another organization.
3. Lessee in situation #2 above gives up lease and Corporation "A" operates the same equipment.
4. Corporation changes name, but not corporate structure.
5. Individual sells 100% of stock in Corporation "A" to another corporation. Corporation "A" continues
to operate with no change in structure. (Note that this is only a sale of stock, and not equipment.)
6. One corporation forms another corporation and equipment from old (but still existing) corporation is
sold to the new corporation.
7. The corporation selling the equipment in #6 above repurchases the equipment originally sold and
resumes operation of that equipment.
8. A corporation merges with another corporation.
NOTE: Only corporations can merge. On the merger, the corporation can take either name and
may continue to operate equipment without a new permit. A change in name permit can be
issued without a fee. In determining corporation compliance with permit requirements, offi-
cial merger records should be checked.
CHANGE
X
X
X
X
X
X
X
X
X
X
NO CHANGE
X
X
X
X
X
X
X
X
X
(3) Determining Change in Location
(a) A change of location made by moving equipment
on the same premises will not require a permit as
long as no structural changes are involved.
(b) The movement of equipment from one address-
location to another requires permits.
(4) Determining Alteration
Alteration may be considered as any structural
change which changes the quality, nature or
quantity of air contaminant emissions such as:
alteration of combustion chamber, vents, ports,
stack, charging doors, etc.; substitution of burners,
-------
Collecting and Reporting Evidence of Violation
229
change in type of fuels used; alteration of load
capacities, reduction or increase of blower capaci-
ties; substitution of chemicals, etc.
When the permit status is one of non-compliance
for any of the above reasons, then a violation of Section
24279 is indicated. The enforcement action to be taken
then depends on the inspector's findings as to the "ex-
tent" of the violation, that is, was the equipment
constructed with the knowledge of the A.P.C.D. law?
Are there extenuating circumstances involved? The
District policy in this regard considers recency of
construction as a standard of "extent", since plant
operators are expected to have full knowledge of the
requirements of the control program as the control
program becomes better known. On the other hand,
a more lenient enforcement policy is applied when
failure to apply is clearly a result of ignorance or con-
fusion. Determination of flagrancy is simply a matter
of assessing all of the factors involved. The District has
the option to take any form of enforcement action
which is reasonably necessary, once a violation of Sec-
tion 24279 is confirmed. The action taken will consist
of one of the following:
Issuance of the F-Type Permit Notice:
Generally speaking, this Notice is issued only
when the violation is flagrant, due to recency, in-
tent and past history of violation, or other con-
tributing factors. It is also issued for operation
after issuance of denial, failure to submit applica-
tions within the "due-date", and in conjunction
with notices issued for any other violation of the
Rules and Regulations incurred at the same time.
The written Notice should establish when con-
struction began and was completed, the actual
cause of the noncompliance as outlined above, the
name, home and business address of the contract-
ors involved, etc. and all pertinent data which
establishes responsibility as described under "Es-
tablishing Persons Responsible for the Violation",
this chapter. The findings of the Notice will also
note the exact stage of completion of the equip-
ment and observations of any visible emissions
noted.
Should equipment, for which an application for
operating permit has been denied, be observed in
operation, the inspector should note the time and
date of operation and the degree to which the
equipment is being operated as well as any visible
emissions observed.
The Request for A.P.C.D. Permit is also written
and issued together with an appropriate set of
applications.
This form, together with appropriate permit ap-
plication forms, is usually issued without the F-
Notice when stringent action is not being taken.
It is generally issued for equipment involved in a
change of ownership and change of location.
Issuing the Request to Apply for APCD Permit Only.
The Request is made out in triplicate. The first
copy is the plant manager's copy, the second is a
report of the permit status for engineering review
and the third is maintained in a suspense file until
the applications are submitted to the Engineering
Division.
The Request form is for the most part a blank
completion type form containing the special ele-
ments of Section 24279 violation.
2. Section 24280, Operation or Erection Contrary
to Provision of Permit
Section 24280 states that "Every person is guilty
of a misdemeanor who builds, erects, alters, or replaces,
operates or uses any such article, machine, equipment,
or other contrivance contrary to the provision of any
permits issued under regulations adopted pursuant to
this article." (Article 4, Rules and Regulations, Health
and Safety Code.)
This is a very useful rule in enforcement since
continued control of pollution is assured by condition-
ing the operation of permitted equipment. Should such
equipment be operated contrary to the permit condi-
tions, a misdemeanor is committed. When the viola-
tion is committed in a public nuisance case or is in-
volved with a violation of excessive emissions, effective
enforcement action can be taken.
When inspecting equipment, the inspector reads
any permits that may have been granted by the
A.P.C.D. and notes the conditions under which the
equipment may or may not be operated. If the equip-
ment involves a complex flow process, or its operating
conditions are concealed from direct observation, the
inspector should refer to flow diagrams of equipment
descriptions in the Engineering Division File.
The inspector may issue a Notice under this sec-
tion of the law provided his findings are definitive. The
inspector should demonstrate in detail the extent to
which the operation of the equipment deviated from
the conditions on the permit. Where no violations of
other rules or sections of the law are involved, issu-
ance of a Notice under Section 24280 may be discre-
tionary. In such cases an appropriate warning should
be issued, and a follow-up made. Where violations
involving the emission of air contaminants, or public
nuisances are involved in connection with failure to
comply with the permit conditions, the appropriate
notice should be written and served, together with the
Section 24280 F-Type Notice.
A list of typical permit conditions is shown in
Figure XIII-10.
-------
230 Air Pollution Control Field Operations
AIR POLLUTION CONTROL DISTRICT---COUNTY OF LOS ANGELES
434'SOUTH SAN PEDRO STREET, LOS ANGELES 13, CALIFORNIA
GENERAL STANDARD CONDITIONS FOR PERMITS
I. Operation of this equipment must be conducted in compliance with all data and speci-
fications submitted with the application under which this permit is issued unless
otherwise noted below.
2. The equipment must be properly maintained and kept in good operating condition at
3. This equipment must not be operated unless it is vented only to air pollution control
equipment which is in full use and which has been issued an operating permit by the
Air Pollution Control Officer. _ . .
4. Fuel oil supplied to the burners of the must be at the following minimum
temperature: Grade jAmbient temperature
;Grade , °F
;Grade , °F.
5. Chlorine, aluminum chloride or aluminum fluoride must not be used in this furnace.
6. This tank must not be operated unless an effective amount of mist inhibitor is used
or unless vented only to air pollution control equipment which is in full use and which
has been issued an operating permit by the Air Pollution Control Officer.
7. Sal ammoniac must not be used in this furnace.
8. Alloys containing more than 7 per cent zinc must not be poured from this furnace.
9. This furnace must not be operated unless an effective slag cover is maintained over
the molten metal during all melting and pouring operations or unless vented only to
air pollution control equipment which is in full use and which has been issued an
operating permit by the Air Pollution Control Officer.
10. Metal contaminated with organic material must not be charged to this furnace.
II. The (incinerator) (equipment) must be operated by personnel properly trained in its
ope rat i on.
12. The ignition chamber burner(s) must be used when burning refuse of hi^h moisture
content.
13. The mixing chamber burner(s) must be used throughout the burning period.
14. The mixing chamber burner(s) must be used during the first 30 minutes of operation
and as needed thereafter to prevent violations of ait pollution control statutes.
15. Only clean dry paper (and) (or) wood scrap may be burned (during the first
minutes of operation).
16. A temperature of not less than °F must be maintained in the (afterburner)
(combustion chamber) when the equipment it serves is in operation.
17. All chute doors must be locked (and chimney damper closed) throughout the burning
pe ri od.
18. This equipment shall be used only for loading mixer-type trucks equipped with re-
ceiving hoppers.
19. Not less than gallons per minute of water must be supplied to this scrubber
when the equipment it serves is in operation.
20. Aggregate feed must be kept sufficiently moist to prevent dust emissions.
21. The material charged to the drier in any hour shall not contain more than
pounds of fines which wiI I pass a 200 mesh sieve.
22. Polyvinyl chloride compounds must not be baked in this oven.
23. Oven temperature while baking polyvinyl chloride compounds must not exceed °F.
24. This oven must not be operated at temperatures above °F.
25. Whenever any rendering cooker (smokehouse) is in use the exhaust system must be
operated in a manner which will insure maximum collection of air contaminants vented
from the cookers (smokehouses) and maximum delivery of these air contaminants to the
firebox of this boiler (and) (or) (of boiler no. ).
26. This equipment must not be used for loading more than 20,000 gallons per day of
petroleum distillates having a Reid vapor pressure of four pounds or greater.
27. When storing petroleum distillate having a vapor pressure of 1.5 PS IA or greater
under actual storage conditions, this tank must be connected to a vapor control
system approved by the Air Pollution Control Officer.
28. This equipment must not discharge to +he atmosplare radioactive materials in excess
of the permissible limits established by existing authorities.
Figure XIII - 10. General standard conditions for permits.
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Collecting and Reporting Evidence of Violation
211
3. Section 24278, Operation or Erection Under
Suspended or Revoked Permit
According to Section 24278, every person who
builds, erects, alters, replaces, uses or operates any
source capable of emitting air contaminants when his
permit has been either suspended or revoked is guilty
of a misdemeanor.
The Air Pollution Control Officer can suspend a
permit for a period of time, but only the Hearing
Board can revoke a permit.
On suspension, the sector inspector is issued a
written notification of such action, including the date
involved.
On revocation, the sector inspector is issued a writ-
ten report of the Hearing Board's action and another
written reminder of the effective date of revocation.
The inspector in these cases inspects to determine
whether or not the equipment is being operated. If he
observes the equipment in operation he issues a Section
24278-F-Type Notice setting forth both the facts as to
revocation or suspension and the time, date and de-
scription of the operation he has observed.
C. Uncontrolled Equipment
This violation category includes Rule 56, Uncon-
trolled Storage of Petroleum Products; Rule 59, Un-
controlled Oil-Effluent Water Separators; Rule 61,
Uncontrolled Gasoline Loading into Trucks, Tanks and
Trailers; Rule 62, Fuel Oil Burning; Rule 63, Gasoline
Composition, and Rule 64, Reduction of Animal Matter.
The evidence required for these violations was dis-
cussed previously in Chapters 11 and 12.
D. Bans: Rule 57, Open Fires; Rule 58, Single-Chamber
Incinerators
A complete description of these Rules is con-
tained in the Rules and Regulations, which should be
consulted for detailed conditions and exceptions.
1. Rule 57, Open Fires
Because the elements of an open fire, Rule 57,
violation are involved, the entire rule is quoted as
follows:
Rule 57* (Amended 1-16-58.) OPEN FIRES. A person
shall not burn any combustible refuse in any open outdoor fire
within the Los Angeles Basin, except:
a. When such fire is set or permission for such fire is given in
the performance of the official duty of any public officer,
and such fire in the opinion of such officer is necessary:
1. For the purpose of the prevention of a fire hazard which
cannot be abated by any other means, or
2. The instruction of public employees in the methods of
fighting fire.
b. When such fire is set pursuant to permit on property used
for industrial purposes for the purpose of instruction of
employees in methods of fighting fire.
c. When such fire is set in the course of any agricultural oper-
ation in the growing of crops, or raising of fowls or animals.
These exceptions shall not be effective on any calendar day
on which the Air Pollution Control Officer determines that:
1. The inversion base at 4:00 a.m., Pacific Standard Time,
will be lower than one thousand five hundred feet above
mean sea level, and
' Emphasis supplied.
2. The maximum mixing height will not be above three thou-
sand five hundred feet, and
3. The average surface wind speed between 6:00 a.m. and
12:00 noon, Pacific Standard Time, will not exceed five
miles per hour.
The investigating inspector proceeds to investigate
violations according to standing instructions as ex-
tracted from the following joint agreements between
fire departments and the Air Pollution Control District.
a. Contact person who is burning the refuse to determine if he
has a permit issued by a Fire Department.
b. If burning is performed under oral or written permit, but
in violation of the terms and conditions of the permit, the
person performing such burning may be cited by the in-
spector.
c. If burning is performed according to oral or written permit,
but, in your opinion, conditions under which burning is per-
formed are not satisfactory, the inspector shall contact the
Fire Department from which the permit was issued. If,
after consultation with Fire Department personnel, the open
burning is found contributing to the smog condition, the
Fire Department personnel will order the fire extinguished
and cancel the permit. Decision as to whether permittee
shall be served a notice will be made in coniunction with
and upon the advice of Fire Department personnel.
d. If no oral or written permit was given to person performing
the burning, a Notice should be issued.
e. If permit does not conform to details of joint agreement
mentioned above, contact Fire Department issuing permit
and attempt to obtain their cooperation on these points.
f. The A.P.C.D. issues no fire permits. The fire departments
in Los Angeles County and some local communities will
issue permits subject to the following:
1. No permits will be issued on days when a Smog Warn-
ing is forecast.
2. The words "This permit not valid on a smog forecast
day" should be checked on the permit.
3. Permits for weed abatement will be issued where weed
removal cannot be feasibly disposed of by some other
method. The permittee will be informed that the per-
mit is only for the burning of grass and weeds and not
for any other combustible material.
4. Before issuing a permit to eliminate a fire hazard every
effort will be made, where practicable to have the person
find an alternate method of disposal. Sound considera-
tion should be given to all factors involved so that the
most reasonable degree of cooperation can be given the
Fire Departments.
5. Permits in connection with training in the methods of
fire control may be issued when no smog is forecast.
6. Permits for bonfires for amusement purposes may be
issued under specified conditions. For example: Hal-
loween bonfires at playgrounds, homecoming bonfires,
etc.
When writing a Notice of Violation, the follow-
ing points should be kept in mind:
1. When the observation of the emission from an
open fire does not disclose a violation of Section
24242, but visible emissions are observed, the in-
spector should record the actual emission observed
in the visible emissions box on the Notice, but
should not total the emissions. The box should
then be crossed out lightly.
2. In collecting data for open fires, it is important
that the persons responsible for, and lighting, the
fire be definitely established. In addition, the
contents of the fire should be accurately described.
The following check points apply.
a. Size—diameter and height.
b. Location—distance from any near structure.
-------
232
Air Pollution Control Field Operations
c. Materials being burned — describe whether
green, wet, etc.
d. Permit from local Fire Department.
Has date expired?
Does permit have a stamped or written condi-
tion concerning burning of "heavies" or
A.P.C.D. Regulations?
Does permit have clause making it invalid on
smoggy days?
Are terms of permit adhered to?
Who issued the permit?
e. Are means available to extinguish fire?
f. Is there someone in attendance at the fire?
g. Did you see anyone throw anything onto the
fire or stir, rake or control the fire in any
manner?
h. Was attempt being made to put fire out:
Upon arrival? Not at all?
i. Are there any signs or other information in
the area that would indicate who is doing the
burning?
j. Was the fire in view at the time of the ob-
servation?
k. Was any attempt made to segregate the
heavies?
2. Rule 58, Single-Chamber Incinerators
Rule 58, in effect, makes it illegal to burn com-
bustible rubbish within the Los Angeles Basin in any
incinerator other than an approved multiple-chamber
incinerator.
The necessary elements of this violation which
must be established are: (1) the burning of combustible
rubbish (i.e., not fuels), (2) in a single-chamber in-
cinerator or any other incinerator which does not have
an operating permit from the Air Pollution Control
District and (3) within the Los Angeles Basin, the
boundaries of which are defined in Rule 2g.
Under the "Findings" section of the Notice, the
exact type of incinerator should be described by using
the following terms, whichever is appropriate: "single-
chamber", "multiple - chamber", "brick", "steel",
"concrete", "hopper-type", "box-type", "chute-type",
"cylinder", "conical", "tapered", etc. The inside di-
mensions of the combustion chamber should be in-
cluded.
The materials burned and approximate quantities
should be accurately described.
The persons responsible for charging and lighting
the incinerator should be indicated and identified as
well as all facts which establish responsibility.
E. Noncooperation and Circumvention
1. Refusal of Entry; Refusal to Halt Vehicle.
Section 24246 of the California Health and Safety
Code, Chapter 2, Division 20, sets forth the powers of
the control officer as follows:
The Air Pollution Control Officer, during reasonable hours,
for the purpose of enforcing or administering this chapter
or of any order, regulation or rule prescribed pursuant
thereto, may enter every building, premises, or other place,
except a building designed for and used exclusively as a
private residence and may stop, detain, and inspect any
vehicle, designed for and used on a public highway but
which does not run on rails. Every person is guilty of a
misdemeanor who in any way denies, obstructs, or hampers
such entrance, or such stopping, detaining, or inspection of
such vehicle, or who refuses to stop such a vehicle upon the
lawful order of the air pollution control officer.
For the practical purpose of enforcing this section
in the field "refusal of entry" may mean not only re-
fusal to permit entrance into any building or premises
described above, but also refusal or failure to stop
vehicles upon lawful order.
Several restrictions are imposed upon the Air
Pollution Control Officer, however. First, an inspector
may not enter a building "designed for and used ex-
clusively as a private residence". If, however, a build-
ing designed as a private residence were used as a
machine shop, the exemptions would not apply and an
inspector would be empowered to enter for inspection
purposes.
Secondly, the inspector must enter the building
during "reasonable hours". The interpretation of "rea-
sonable hours" would be in most instances confined to
that time when the business or enterprise was open for
business or was in operation. Under no circumstances
may inspectors of the Air Pollution Control District
enter any building, premises or other place at such
times as the business would be considered closed or its
activity suspended. At no time may an inspector use
any force on any part of the premises to effect
entrance.
The power of the Air Pollution Control Officer to
stop, detain and inspect vehicles contains an exception
with respect to those vehicles which run on rails. At
no time may an inspector stop such a vehicle running
on rails for the purposes contained in Section 24246.
In addition to the exception set forth in this section, it
is the policy of the Air Pollution Control District not
to stop passenger-carrying buses for the purpose of
enforcing the provisions of the Health and Safety Code,
Rules and Regulations of the Air Pollution Control Dis-
trict or Vehicle Code.
If an inspector is refused entrance to any building,
premises or other place after properly and lawfully
identifying himself, he first requests permission to
speak to top management or to the responsible person
in charge at the time. If he succeeds in contacting top
management, he courteously explains the reasons for
the inspection of the premises and attempts to secure
cooperation. If he is still unable to gain entrance, he
attempts to obtain the identification of the person who
has denied permission to enter or who has obstructed
or hampered such entrance. The inspector then calls
his head inspector and requests advice and instruc-
tions on procedure.
The head inspector or his representative then
attempts to contact top management to effect the
inspector's entrance. If entrance is still refused, the
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Collecting and Reporting Evidence of Violation
233
Figure XIII -11. Halting of diesel cab and trailer on the highway. The patrol vehicle pulls behind the truck, clear of the highway.
head inspector consults the chief inspector. When
they have determined the course of action, the in-
spector in the field is advised and instructed. It should
be noted that at all times there is no urgency which
would ever require immediate action by the inspector.
If it is determined that a Notice of Violation
should be issued, this may be accomplished immedi-
ately by the inspector in the field, or at a later date,
depending upon the need for further investigation. In
no event is it considered necessary for the inspector in
the field to attempt to effect a physical arrest.
Substantially, the same conditions exist with
reference to stopping and inspecting motor vehicles.
Every effort is made by the inspector to effect the
lawful halting of the violating motor vehicle with
complete regard to the rules of the road as defined in
the Vehicle Code, and to the safety and protection of
other motorists using the highway. In all cases the
halting of a motor vehicle is accomplished by a uni-
formed inspector in a black-and-white patrol car,
equipped with red lights and siren. (See page 127,
Chapter 7.)
If the driver of the vehicle which the inspector
wishes to halt refuses to follow or ignores the instruc-
tions of the inspector, the inspector secures the vehicle
license number, cab number or other identification of
the vehicle and observes the driver for the purpose of
later identification in court if necessary. A full written
report of the occurrence is then made by the inspector
to his head inspector. If it appears that such informa-
tion is sufficient to warrant the issuance of a complaint,
the application for complaint is made by an investi-
gator of the Enforcement Division.
a. Administrative Restrictions:
Certain administrative restrictions to entry of any
premises are made in the following cases:
1. Only inspectors assigned to or accompanied by
members of the Refinery and Chemical Section
shall enter a refinery, tank farm, bulk loading
station, gas or gasoline plant, petrochemical,
chemical, paint or other plant for which that
Section is responsible.
2. Only inspectors in possession of a U. S. Coast
Guard port security card may board ships hand-
ling government material.
3. Only inspectors who have security clearance may
enter plants requiring security checks.
4. Only inspectors driving emergency vehicles in the
Patrol Section shall stop vehicles.
2. Rule 60, Circumvention
Rule 60, relating to reducing or concealing emis-
sions, states that "A person shall not build, erect,
install, or use any article, machine, equipment or other
contrivance, the use of which, without resulting in a
reduction in the total release of air contaminants to
the atmosphere, reduces or conceals an emission which
would otherwise constitute a violation" of the Rules
and Regulations or the State Health and Safety Code.
This rule does not apply to those cases in which the
only violation involved is a public nuisance (Section
24243 or Rule 51).
In establishing a violation of this Rule it is nec-
essary that the investigating inspector acquire detailed
information of the operation in question both before
and after the alteration of the device. The inspector
must demonstrate from data of operating conditions
-------
Air Pollution Control Field Operations
that the total quantities of emissions both before and
after the alteration remain the same, and that the
violation resulted from the deliberate attempt to avoid
prosecution under any of the other rules and regula-
tions which may be violated. For example, when the
emission from a single source is in excess of that al-
lowed, it is a violation of Rule 60 to distribute the
emission over several stacks in such a manner as to
reduce the emissions from each stack below 40 per
cent opacity, or to distribute the effluent over two or
more stacks placed in such close proximity that it is
impossible to make a smoke reading from either. A
Rule 60 violation is also involved when visible emis-
sions are otherwise rendered invisible before discharge
into the atmosphere by such methods as heating con-
taminants in the source system above the dewpoint,
dilution of emissions by means of blowers and fans,
etc.
F. Noncompliance with Emergency Regulation
and Alert Instructions
The purpose, scope and administration of Regula-
tion VII, Emergencies, are described in Chapter 3,
Law of Air Pollution Control. For a complete and
accurate understanding, this regulation should be
studied in the official Rules and Regulations of the
A.P.C.D. Here we shall consider only the rules which
require immediate action on the part of the enforce-
ment operation. (The rules quoted here are con-
densed and paraphrased.)
Rule 161 of Regulation VII, EMERGENCIES,
states that "When an alert has been called the Air Pol-
lution Control Officer, the Sheriff, their deputies, and
all other peace officers within the Basin shall enforce
the appropriate provisions of this regulation and all
orders of the Air Pollution Control Board or the Air
Pollution Control Officer made pursuant to this regu-
lation against any person who, having knowledge of
the declaration of an alert, refuses to comply with the
rules set forth in this regulation or any order of the
Air Pollution Control Board or the Air Pollution Con-
trol Officer made pursuant to this regulation"
To enforce this regulation, the Enforcement Di-
vision of the A.P.C.D. maintains an accurate record of
air contaminant readings as received directly by land-
line from the Air Monitoring Control Center so that
it may alert all enforcement personnel to approaching
alert stages. When an alert level is reached, the En-
forcement Division acts in accordance with its admin-
istratively assigned role which is, in part, dictated by
the following Rules:
RULE 155, DECLARATION OF ALERT. The
Air Pollution Control Officer shall declare the ap-
propriate "alert" whenever the concentration of
any air pollution contaminant at any sampling
station has been verified to have reached an
amount set forth in Rule 156.
FIRST
ALERT
100
3
3
0.5
SECOND
ALERT
200
5
5
1.0
THIRD
ALERT
300
10
10
1.5
RULE 156, ALERT STAGES FOR TOXIC AIR
POLLUTANTS.
(IN PARTS PER MILLION OF AIR)
CARBON MONOXIDE
NITROGEN OXIDES
SULFUR OXIDES
OZONE
FIRST ALERT: Close approach to maximum al-
lowable concentration for the population at large.
Still safe but approaching a point where prevent-
ive action is required.
SECOND ALERT: Air contamination level at
which a health menace exists in a preliminary
stage.
THIRD ALERT: Air contamination level at
which a dangerous health menace exists.
RULE 155.1, NOTIFICATION OF ALERT. Fol-
lowing the declaration of the alert, the Air Pollu-
tion Control Officer shall notify: the Sheriff's office
and substations; city police department; Cali-
fornia Highway Patrol; local public officials and
public safety personnel; air polluting industrial
plants and processes; the general public; all Air
Pollution Control District personnel.
The Enforcement Division is specifically responsi-
ble for contacting all law enforcement agencies, all
A.P.C.D. field personnel via radio, and all air polluting
industrial plants and processes. The Sheriff's depart-
ment so notified contacts all local public officials and
public safety personnel. The Public Information Di-
vision of the District contacts all Civil Defense person-
nel and communication media—press, radio, television,
etc.—by landline and by teletype.
\SHERIFF'S OFFICE-
2 Minutes
AP
UP
INS
7 BAYS A WEEK
Ccrlfrol Panel-
1 Minute
Telephone.-— | S/6ALERT
30 Seconds
APCD Radio Dispatch
3O Seconds
45 CITY POLICE DEPTS.
12 SHERIFF'S SUB STATIONS
CALIFORNIA HIGHWAY PAT/POL
SHERIFFS RADIO CARS
KADIO STATIONS
TELEVISION STATIONS
PtfESS
BOARD of SUPERVISORS
CIVIL DEFENSE
COUNTY FKE DEPK
INDUSTRY
CONSTITUTED AUTHORITY
9 RADIO STATIONS-
ALL APCD KADIO CARS
Figure XIII - 12. Alen notification system.
The air polluting industries are contacted by
means of selective call facilities located in the Enforce-
ment Division Communications Center.
RULE 155.2, RADIO COMMUNICATION
SYSTEM. This rule requires the Air Pollution
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Collecting and Reporting Evidence of Violation
235
Control Officer to install and maintain a radio
transmitter for the purpose of broadcasting the
declarations of alerts and information and instruc-
tions. This rule also requires certain specified
categories of industrial plants to install radio re-
ceiving equipment with decoding devices capable
of receiving broadcasts from the Air Pollution
Control Officer of the declaration of alerts, infor-
mation and instructions.
1. Enforcement of Regulation VII
The principal provisions of Regulation VII en-
forced are Rule 154.1, requiring submission of shut-
down plans from air polluting industries, Rule 155.2,
requiring installation of radio receiving equipment by
specified air polluting industries, Rule 157, First Alert,
Rule 158, Second Alert, and Rule 159, Third Alert,
and any "order of the Air Pollution Control Roard or
the Air Pollution Control Officer made pursuant to this
regulation" as stated in Rule 161. Rules 154.1 and
155.2 are administratively enforced, that is, they do
not normally involve the field inspector as they are
handled in terms of compulsory submission of shut-
down plans. Persons failing to submit plans within
60 days after they have been officially requested can
be prosecuted under this regulation. Rule 154.1 is
quoted in part here to reveal this procedure:
RULE 154.1, PLANS, a. (Revised 7-26-56). If
the Air Pollution Control Officer finds that any
industrial, business or commercial establishment
or activity emits hydrocarbons or any of the con-
taminants named in Rule 156, he may give writ-
ten notice to the owner or operator of such indus-
trial, business or commercial establishment or
activity to submit to the Air Pollution Control
Officer plans for immediate shutdown or curtail-
ment, in the event of an air pollution emergency,
all of the sources of hydrocarbons or any of the
contaminants named in RULE 156, including
vehicles owned or operated by such person, his
agents or employees in the scope of the business
or operation of such establishment or activity.
Such plans shall include, in addition to the other
matters set forth in this rule, a list of all such
sources of hydrocarbons and any of the contami-
nants named in RULE 156, and a statement of the
minimum time and the recommended time to
effect a complete shutdown of each source in the
event of an air pollution emergency. Such notice
may be served in the manner prescribed by law
for the service of summons, or by registered or
certified mail. Each such person shall, within
sixty (60) days after the receipt of such notice,
or within such additional time as the Air Pollu-
tion Control Officer may specify in writing, submit
to the Air Pollution Control Officer the plans and
information described in the notice.
The enforcement procedure and the data gather-
ing activities involved in enforcing Rules 157, 158,
and 159 are dependent upon the conditions which
obtain during the state of emergency and the exact
nature of the orders given by the Air Pollution Con-
trol Officer.
a. "Standby"' Alert
When any contaminant reading closely ap-
proaches the first alert level, the field inspectors are
notified by radio to "stand by" and to remain on the
air. During a "standby" alert inspectors refrain from
making any investigations, unless specifically ordered
to do so by the Communication Dispatcher. The in-
spector then waits for further instructions, and for
cancellation of the "standby" alert, or a calling of the
First Alert.
b. Rule 157, First Alert
The first alert itself is a "warning" alert. When
called, upon the order of the Director of Enforcement
or his authorized agent, the field inspectors are notified
as follows:
"All Units. A first alert has been called. Repeat
— a first alert has been called. All units will take
the appropriate action provided for in Rule 157.
All units acknowledge."
A parallel message is delivered to the Regulation
VII industries over the selective-calling facilities.
The field inspectors acknowledge when their unit
number is called. All field personnel then remain on
the air and stand by for any further instructions.
During a first alert, it should be noted, no burning
of combustible waste material is allowed in open fires
and incinerators, except in an approved multiple
chamber incinerator, and those which are required by
law for the disposal of certain types of waste materials,
i.e., hospitals, sanitariums, etc. (see Rule 162).
Inasmuch as Rules 57 and 58 outlaw all open
burning and incinerators (all types of open burning
are outlawed on days when an alert occurs) operators
can be cited under either Rule 57'or 58, whichever is the
case, as well as Rule 157. The effect of Rules 57 and 58
has been, however, to reduce the necessity of Rule
157 enforcement during alert periods.
c. Rule 158, Second Alert
In the event the toxic concentration of air pollu-
tion continues to rise and a second alert is necessary.
the action provided for in Rule 158d may require the
curtailment or complete shutdown of business and
industry,) and the maximum restriction of vehicular
traffic.
Rule 158 describes a "preliminary health hazard
alert" The specific action to be taken by field in-
spectors is dependent upon the nature of the instruc-
tions to be received from the air pollution control
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216
Air Pollution Control Field Operations
officer. For both the second and third alerts, field per-
sonnel may be called upon to conduct supplementary
on-the-spot sampling, visit air monitoring stations,
verify shutdown, coordinate curtailment of vehicular
traffic, and perform messenger and communications
services as required. (See Emergency Response Capa-
bility, Chapter 6.)
d. Rule 159, Third Alert
Rule 159 describes a "dangerous health hazard".
The specific action to be taken by field inspectors is
dependent upon the nature of the instructions to be
received from the air pollution control officer.
2. End of Alerts.
The Air Pollution Control Officer declares termi-
nation of the alert when the concentration of any
contaminants which caused the calling of the alert
falls below the Rule 156 standard.
Termination of the alert is broadcast to all units
by the Radio-Telephone Operator upon direction of
the Director of Enforcement or his authorized agent.
Ill COMPLETING AND SERVING NOTICE
FORMS
The data constituting the elements of the corpus
delicti are accurately completed on the appropriate
investigative report (see Chapter 6, "Reporting Results
of Inspection"). These data are essentially the same
for all of the forms used though they are treated and
disposed of according to the action initiated. In the
case of violations, each Notice contains a statement
which charges the person responsible for the violation
with committing a misdemeanor. This consists of a
standardized completion statement which is used to
charge the person with a violation of the pertinent
section of the State Health and Safety Code or the
Rules and Regulations, or both, if multiple violations
are involved. A blank is provided for the insertion of
the appropriate section numbers violated and space is
provided to enable the inspector to complete the
wording of the charge. When the Notice is issued on
the basis of the Rules and Regulations, the wording of
the charge pertaining to the state law is crossed out
and replaced by the wording of the rule. The pro-
cedure for the Citation is somewhat different (see
"Motor Vehicles" in previous part of this chapter).
Once the Notice of Violation is written in dupli-
cate, the yellow second sheet of the Notice is served to
the person most responsible, i.e., the person in highest
authority. The first copy, the pink Notice, with the
"Findings" on the reverse side completed, is brought
to Headquarters for review and action. The Notice is
served according to the following conditions:
A. If the responsible person refuses the Notice, the
inspector may leave the Notice on desk or any
portion of the premises of the source in view of
the responsible person, or the Notice may be
brought to Headquarters for mailing.
B. If no responsible person is on the premises and
location of the responsible person cannot be ob-
tained, return the Notice to Headquarters for
service by other means.
C. If no responsible person is on the premises and
another location for the responsible person is ob-
tained outside of the inspector's sector, forward
the Notice to the appropriate section inspector via
Headquarters.
D. If the owner resides outside of Los Angeles County
and there is a manager being compensated for his
services, the Notice should be left with the
manager.
E. If the owner resides and works outside of Los
Angeles County and no manager lives on the
premises, return the Notice to Headquarters for
service by mail.
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CHAPTER FOURTEEN
REGISTERING THE SOURCES OF AIR POLLUTION
The immediate goal of registering the sources of
air pollution is to place in the files of the control
agency a record of each piece of equipment in the
pollution zone capable of emitting air contaminants.
The data compiled must be sufficient to enable an
analytical engineering review, so that air pollution
potentials and statutory compliance can be determined,
as follows:
REGISTRATION REQUIREMENTS
1. Corporate or individual ownership or responsi-
^ bility.
o „, 2. Location of the equipment source.
§ | 3. Complete identification and description of the
g equipment, including all important constituents,
« appurtenances and devices which affect the
emission of air contaminants.
O
fc 3
•a FH
4. All data relevant to expressing the air pollu-
tion potentials of the equipment, such as nature
of process, size of outlets, rate of emission, com-
position of effluent.
5. Actual and potential degrees of compliance with
the air pollution laws.
The amount of information required to accom-
plish an equipment and operation analysis will obvi-
ously vary among equipment units. Complexity, size
of pollution potentials and other variables must be
taken into account. In order for the registration
process to efficiently cope with the magnitude and
diversification of all of the equipment units which
may be found in the pollution zone, and the changes
which take place in both of these with time, infor-
mation standards must be adapted to the following
rough groupings of equipment:
1. MAJOR SOURCES OF AIR POLLUTION:
All sources of air pollution which require extensive design
and operational information, as well as field tests, such as
power plants, process units within refineries, large metal-
lurgical furnaces, municipal incinerators.
2. TOTAL SOURCES OF AIR POLLUTION:
All equipment units and processes whether minor or major
sources of air pollution, mobile or stationary, which must
be accounted for in making total pollution surveys.
3. PERMIT-REQUIRED SOURCES OF AIR POLLUTION:
All equipment and processes which require a permit from
the A.P.C.D. These will require a definite minimum quan-
tity of information as specified by the control agency before
permits are granted or denied.
4. PERMIT-EXEMPT SOURCES:
Equipment and processes which may be minor sources of
air pollution but which are legally and administratively
exempted from permits. The amount of information re-
quired for this equipment should be far less than most of
the equipment involved above.
Minor sources, for example, should require less
information, especially when the design characteristics
of standard equipment — such as some types of incin-
erators or spray booths — are well-known. To register
permit-exempt sources it is sufficient to obtain points
*1, #2 and #3 of the Registration Requirements only.
Permit-required equipment, on the other hand, will
require the satisfaction of all registration requirements
and, in particular, points #4 and #5, i.e., plans, speci-
fications and other engineering data as will permit a
practical review of equipment design and operational
capabilities as they affect air pollution potentials.
It should be noted that the difference in the facil-
ity of gathering infomation for the first three points of
the Registration Requirements, and points numbered
four and five, as indicated by the arrow cut-off point
above, is considerable. For example, an inspector can
enter a plant and readily determine by interview and
observation corporate and individual responsibility, the
location of the equipment source, and the identification
and description of the equipment. He cannot, however,
accurately determine the size of outlet, flow rates of
effluents, design characteristics, etc., necessary to cal-
culate quantitatively the rates of emission under both
normal and a variety of operating conditions. This
can only be done by a studied analysis of plans, speci-
fications, design, operation, process materials and fuels.
On the basis, then, of the applicability of each
source of emission to the permit system, we may divide
responsibility for registering the sources of air pollu-
tion into two distinct, but complementary phases:
1. Inspection and inventory of all of the sources of
air pollution to satisfy the first three registration
requirements.
2. Administration of the permit system, i.e., process-
ing applications for A.P.C.D. permits.
The Enforcement Division of the A.P.C.D. locates
and identifies all equipment sources of air pollution in
all industrial, commercial and governmental establish-
ments in the pollution zone, whether they are minor
or major, permit-exempt or permit-required. The pro-
cess consists of preparing Equipment Lists for each
industrial, commercial or governmental address-
location. For each equipment unit entry, the permit
status is noted. This is a designation of compliance
with respect to Rule 10, Permits Required. Equipment
units which are sources of pollution and in operation
without required permits are either cited under Section
24279, in the case of flagrant violations, or A.P.C.D.
Permit Requests are issued to force direct permit ap-
plication. Thus the inventory inspection generally
leads to the second phase of the registration process,
the filing of permit applications.
The Engineering and Evaluation and Planning
Division of the A.P.C.D. administers the permit sys-
tem by receiving and reviewing applications, and issu-
ing authorities to construct and permits to operate for
equipment which meets control standards or denying
such approval when these standards are not met. The
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238
Air Pollution Control Field Operations
applications received may arrive as a result of the
inventory process above, or are submitted voluntarily
by responsible and cooperative plant managers. As a
matter of fact, the effectiveness of the inventory pro-
cess can be directly related to the increase in voluntary
applications for permits in the pollution zone, since
the number of "voluntary" and "compulsory" appli-
cations filed with the control agency are both directly
proportional to the amount of inventory activity. Over-
all compliance with the control authority can be sim-
ilarly related to the inventory activity.
Because the inventory is a function of field control
operations, and the review of permit applications an
engineering function, we shall deal mostly with the
former.
I THE EQUIPMENT INVENTORY
An inventory is an accounting device employed
in the administration of a business. It is a means of
taking "stock" of the categories of merchandise, the
number of "items" in each category, and the purchase
price. This information is necessary in computing the
assets of a company. It is of value to the accounting
operation only to the degree that an accurate and
complete record is made. A partial or incomplete
inventory of any stock is of relatively little value.
In general, the inventory employed in air pollu-
tion control enforcement is an accounting method em-
ployed to enforce compliance with the permit system
and, ultimately, the Rules and Regulations of the
A.P.C.D. It is also a statistical device for comparing
source growth and determining air pollution potentials.
Like the accounting inventory, the value of the en-
forcement inventory depends directly on its complete-
ness of application.
In the enforcement inventory, however, it is nec-
essary to recognize the limitations of an area inventory,
as opposed to that of an individual enterprise, with
respect to the possibility for completeness. The area
inventory is an attempt to obtain a complete inventory
of all of the equipment units capable of air pollution
in the pollution zone at any one time. The complete-
ness possible is problematical, and depends on whether
the number and kinds of sources of pollution in the
pollution zone are "infinite" or "finite" with respect
to the inventory capability of the control agency. An
area inventory is infinite when the inventory capabil-
ity is such that not all of the sources of air pollution
can be inventoried at any one time. The categories and
number of individual items contained in the pollution
zone may be so large that before any inventory cycle
is completed, that is, before all of the establishments in
the zone are inspected, the numbers and categories of
pollution have undergone significant change. In such
cases, the area inventory must be a form of perpetual
inventory, as opposed to the calendar or fiscal inven-
tory, which is a complete inventory of items made
within a specified inventory period. The inventory of
a single establishment, on the other hand, represents
a record of a "finite" number of sources, since changes
in the number and kinds of sources generally do not
take place either during or immediately after the tak-
ing of the inventory. The plant or activity inventory
for each address-location may be planned on a periodic,
calendar or fiscal inventory basis, even though the area
inventory cannot be simply treated in this fashion.
In an area the magnitude of Los Angeles County
containing about 16,000 establishments with stationary
sources of air pollution*, the number of sources is large
and variable, and the inventory record can never truly
be said to be complete. How can such inventories be
administer 3d so that the information on hand is rea-
sonably representative of the pollution zone? How
valid is the data now in the files covering equipment
which has been inventoried in the initial part of the
current inventory cycle? How many sources of air
pollution in the pollution zone comply with the permit
system, and how many do not at any given time?
The answers to these questions involve the develop-
ment of an efficient perpetual inventory system based
on an optimum inventory cycle or inspection fre-
quency.
The time interval between inventory and re-
inventory of each of the industrial establishments in
the pollution zone may be referred to as the inventory
cycle. It can be said that the area inventory is of little
value, if the inventory cycle is overly long. Both pol-
lution potentials and degree of compliance from such an
inventory cycle cannot be reasonably extrapolated at
any one time, since many changes affecting gross
pollution potentials and mass compliance have prob-
ably taken place in the interim. On the other hand,
a monthly inventory reinspection, while guaranteeing
continuous up-to-date information, would require an
excessive number of enforcement personnel.
The optimum frequency of inventory reinspection
should thus reflect some compromise which bears a
significant control force, and which minimizes the
margins of error of current inventory information. As
will be recalled, there is a frequency of inspection (or
length of inventory cycle) which may not only ac-
curately reflect conditions of industrial turnover, but
may discourage an operator from taking calculated
risks, especially with respect to the permit require-
ments. In fact, permit infractions can result in serious
risks on the part of management, since investment in
equipment discovered to have been constructed and
operated illegally may be lost.
Each control agency must determine for itself the
optimum frequency of inventory. Such criteria as the
size of the air pollution potential itself, the number of
* We are omitting from consideration motor vehicles and other
mass domestic sources of air pollution such as incinerators,
open-fires, gas-heaters, stoves, etc., as such inventories are
arrived at by population statistics, and the control of these
sources is accomplished by other means.
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Registering the Sources of Air Pollution
219
equipment units at each address-location, and the
general complexity of the plant may be taken as
criteria for determining the proper inventory inspec-
tion cycle, for example:
1. Air Pollution Potential: Industrial or commercial estab-
lishments with a relatively large air pollution potential
should be inspected frequently, since any change, however
subtle, may affect that potential.
2. Number of Equipment Units and Complexity of Plant:
Industrial establishments containing a large' number of
equipment units or complex processes possess a greater
tendency for change, and hence are subject to permit in-
fractions. These should be inspected frequently.
In Los Angeles County, where saturation coverage
is required, the basic frequency of inspection for aver-
age industrial or commercial establishments is once
each year. More significant establishments, those with
large air pollution potentials and many equipment
units, are inventoried two and even three times per
year. On the other hand, some small or commercial
establishments such as warehouses, automobile dealers,
supermarkets with single pieces of equipment
(multiple-chamber incinerator or spray booth, etc.)
whose use and design are not likely to change or which
emit small amounts of air pollution, or other establish-
ments with no sources of air pollution or no expansion
potential, are inspected less than once each year, or at
the discretion of the field inspector.
Needless to say, plants inspected on an optional
basis should be inspected within a reasonable period
of time. Depending upon work loads which may en-
gross field time in other control problems of higher
priority, such sources should be inspected within a
reasonable period of time.
A. functions of the Inventory System
The air pollution control enforcement inventory
may be further distinguished from the business inven-
tory by the specific functions it must perform. These
are (1) categorization and itemization, (2) enforce-
ment of the permit system, (3) determination of air
pollution potentials, and (4) determination of work
load and organizational strength. Where saturation
coverage is required, as in Los Angeles, the inventory
system is employed for multiple purposes to maximize
the utility of the data.
1. Categorization and Itemization
The inventory system employed should be capable
of itemizing and categorizing all sources of air pollu-
tion relevant to the air pollution potential of the
community. The categories employed are major sub-
divisions or groupings of equipment or activities basic
to the pollution problem and comprising the industrial
economy. A community experiencing only a smoke
problem may employ a finer categorization of combus-
tion equipment for the purpose of comparing relative
contributions of smoke, than will a community with
a more varied type of air pollution problem. In the
case of the former, boilers and incinerators might be
categorized by horsepower, combustion chambers, fuel
used, etc., while other sources of air pollution are
ignored. The more complex the contributing industrial
economy, however, the greater and more varied will
be the number of categories of the sources or activities
producing air pollution.
Itemization refers to the number of individual or
other subgroupings of the sources of air pollution (such
as activities, plants, or processes) which may be found
in each of the relevant source categories. Itemization
may be used for statistical compilations, or for refer-
ence as in "2" below.
2. Enforcement of the Permit System
The inventory can be used as an enforcement
tool in two basic ways: (a) to locate all equipment
which has i or which doles not have valid permits or
licenses to operate, in order to bring all equipment
in the pollution zone in compliance with the control
authority, and (2) to assure uniformity of treatment
in obtaining compliance. The inventory record may
be used both as a field reference file carried in the
vehicles of sector inspectors, and as a headquarters file
for use in selective and statistical analyses. Each in-
ventory thus constitutes a reference for future inven-
tory checks and compliance determinations.
3. Determination of Air Pollution Potentials
In an inventory system, the equipment capable of
emitting air pollution may be categorized and itemized
so as to provide accurate statistical data necessary to
compute the air pollution potentials of the source
categories, individual equipment or plants, and the
entire industrial economy. In the case of individual
pieces of equipment, the determination of air pollution
potentials is necessary in ascertaining compliance or
non-compliance with the legal authority. In the case
of the relative contributions of the categories, and of
the pollution potential of the entire industrial econ-
omy, data will reveal what progress has been accom-
plished as a result of the control program, and,
conversely, what remains to be done to control the
uncontrolled sources. The inventory system thus
contributes to a continuous or cumulative record of the
present, past and future, and can be used to compare
progress or growth of sources.
The inventory system should yield such factors or
units along with established emission factors as will
enter into a computation of the various air pollution
potentials. For example:
Air Pollution Po- = No. Controlled units X emission factor for
tential in weight controlled units
units per day of a +
given category of No. Uncontrolled units X emission factor
equipment for uncontrolled units
Thus the inventory system may participate in
establishing a meaningful basis for prohibition by dem-
onstrating conclusively before legislative bodies what
would be accomplished by such prohibition. In testi-
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240
Air Pollution Control Field Operations
mony made before a legislative body on behalf of pro-
posed rules, it is necessary, for example, to determine
how many sources of air pollution are in the category
to be affected by a proposed prohibition, what the total
air pollution and nuisance potentials are, their rela-
tionship to the overall air pollution problem, how they
can be controlled to meet the standards in the proposed
rule, the cost of control, and an overall estimate of the
feasibility of such control. Such a record also serves
as a basis for modifying rules or prohibitions which are
not in keeping with newly disclosed air pollution
potentials.
In ascertaining the air pollution potential of each
source of air pollution, the inspector is of the utmost
importance. The potential cannot always be deter-
mined by a premeditated type of inventory record, but
often must be presented in terms of an original organic
description of equipment, the quality of which depends
on the inspector's training, background, powers of ob-
servation, and understanding. Therefore, inventory
systems must provide not only for the compilation of
certain standard categories of information, but also for
adaptation of information to unpredictable situations.
It is frequently most important for the inspector to
determine the air pollution potential through his own
devices rather than conform to strict procedures which
engineer the information required.
4. Determination of Work Load and Base Line
of Enforcement Actions
The inventory system lends itself as a basis for
determining work-loads, sector assignments and fore-
casts of man-hour availability for the purpose of main-
taining a balanced saturation and selective coverage
program. Inventories directly disclose the number and
kinds of industrial establishments which must be re-
inspected, and, by correlation with Inspectors' Daily
Reports, the average time required to inspect each of
them. The inspection time may be expressed in terms
of a standard inspection unit, or time factor unit. In
the A.P.C.D., an inspection unit is an expenditure of
15 minutes of continuous inspection time. The assign-
ment of inventory reinspections weighted by inspection
units has the effect of balancing priorities in practically
all phases of the field operations program, thus pro-
viding an indirect "base-line" from which the increase
or decrease in such enforcement actions as the number
of Written Notices and Citations issued, the number of
new and revised Equipment Lists, the number of court
cases filed and completed, etc.,I reliably indicates trends
in compliance.
B. Types of Inventory Systems
The selection of an inventory system depends on
the requirements of the field operations program.
Since emphasis on one function may mean compro-
mising or sacrificing another, each of the possible
systems described below possesses certain inherent ad-
vantages and disadvantages. For example, the inven-
torying of equipment to obtain reference data for the
enforcement of a permit or license system may be
accomplished at the expense of accurate, specific air
pollution potential data.
It is perhaps unwise to place the burden of obtain-
ing all field data which may be required by the control
agency on the inventory system. Total pollution
studies should be compiled from other sources of infor-
mation, such as census statistics and market informa-
tion. The inventory system, therefore, should be
limited to as few manageable functions as possible.
1. Cumulative Alphabetical-Chronological
This is a cumulative dossier file of all records and
documents which may pertain to each establishment,
filed alphabetically by the name of the establishment,
and chronologically by the dates reports enter the file.
Inventory records, permits, or licenses, permit applica-
tions, inspectors' reports, variances, court and Hearing
Board records, etc., are maintained in chronological
order within each file record. The whole system, being
alphabetically arranged, will require a cross-index
card system in order to compile from the master record
any categories of data or sources of air pollution re-
quired for any given purpose by the agency.
The advantage of such a system is that it estab-
lishes one central filing system. The inventory record
is, in fact, compiled from many sources of information
rather than from just inspection. In this way, the
multiplicity and duplication of filing systems and op-
erations are eliminated.
The disadvantages may consist in lack of uniform-
ity and consistency in coverage, and the fact that the
inventory records as such are "hidden" and must be
gleaned whenever required. Because the inventory
information is not grouped to meet the requirements
of categorization and itemization, auxiliary reference
files are required. Other forms of administrative con-
trol may be required to maintain consistency, useful-
ness and accessibility to the information.
2. Equipment Classification System
This is an inventory system based directly on the
filing of categories of equipment units which may be
legal sources of air pollution, and then alphabetically
by name of company operating such equipment. In
this system equipment classifications may be developed
which are relevant to both determining air pollution
potential and case histories of the sources. For example,
categories might encompass such types of equip-
ment as "afterburners", "absorption towers", "boilers",
"incinerators", "shakers", etc. The file of this type of
inventory system is capable of yielding instantly the
amount of equipment in a precise category of sources
of air pollution. The information has direct and con-
tinuous impact in maintaining accurate statistical
analyses of the pollution potentials of the community.
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Registering the Sources of Air Pollution
241
It provides at any given time the amount of equipment
in each category, the companies operating the equip-
ment, location, and the amount of equipment con-
trolled and uncontrolled.
A disadvantage of such a system is that the num-
ber of categories is probably excessive and indefinite.
Problems always arise as to where a given piece of
equipment belongs, or how it is to be classified. Some
equipment does not fit conveniently into established
categories as they appear in a changing technology.
Perhaps the most important disadvantage is that it is
cumbersome for an inspector to make separate inven-
tory records on each category or source of air pollution,
especially in a large plant containing many pieces of
dissimilar equipment. Also, to acquire information
concerning all of the equipment which may be con-
tained in any one industrial plant may require that
either the files be gleaned painstakingly or that
another master record system be developed. This sys-
tem, thus, does not lend itself well to multiple uses
of data.
3. The Activity Classification System
This is an inventory system based primarily on a
comprehensive categorization of the technological acti-
vities which make up the industrial economy of the
pollution zone. These activities include such industrial
classifications as "metallurgical or metal melting and
reclaiming", "petroleum and petrochemical", "indus-
trial chemical manufacturing, etc." Industrial plants,
commercial enterprises and governmental establish-
ments are appropriately grouped within such techno-
logical activities, and classified and filed accordingly.
Each unit of inventory, that is, the Equipment List, is
made up of all the equipment units comprising a par-
ticular activity at one address-location. If an industrial
enterprise conducts several technologically distinct
activities, such as metal melting (foundry) and metal
plating (surface coating) at one address-location, an
individual inventory for each activity is made at the
address-location. This system lends itself fairly well
to the logical accounting procedure which would be
naturally employed by the inspector, since the in-
spector is interested in production cycles, production
objectives, and material and product volumes of a
complete activity.
The activity classification system may be primar-
ily concerned with determining compliance with re-
spect to the permit system, since itemization on Equip-
ment Lists lends itself to permit status reference,
rather than to statistical compilations of equipment
units. There are several distinct advantages to such
a system which relate to the multiple uses which can
be made of the data developed by this system. For one
thing, because the inventory system is based on that
activity which would occupy the inspector's interest
during one inspection, it provides a work unit, a basis
for distributing work loads and scheduling inspections.
Secondly, it lends itself well for sector analyses in the
location of all activities which may contribute to a
nuisance or air pollution problem. Thirdly, it develops
the number of industrial plants (or activities) which
make up the air pollution potential of any technologi-
cal classification in determining the relative contribu-
tion of an industry to the overall air pollution problem.
The activity classification system is described in
greater detail later in this chapter, as it is the pro-
cedure employed by the Enforcement Division of the
A.P.C.D. Its use permits the development of a limited
dossier inventory file, built up from Activity Status
Reports submitted subsequent to the original Equip-
ment List inventory. (See also "Maintaining Record
Systems" in Chapter 6.)
Several disadvantages to this system derive from
the fact that it does not break the sources of air pollu-
tion, that is, the equipment units themselves, down into
statistically useful classifications as does the equipment
classification system above. The broad technological
classifications employed in an activity system tend to
be nebulous. Questions may arise as to the location of
specific units and operations in the overall inventory
record system. Moreover, it is administratively difficult
to compute the number of equipment units in equip-
ment categories from Equipment List files. It thus
cannot be used for evolving units or factors for deter-
mining air pollution potentials or for directly deter-
mining the number of controlled and uncontrolled
equipment in any given category. Secondly, it sepa-
rates a number of integrated activities which might be
found at one address-location into activities which have
remote positions in the file, thus requiring a reference
finding file to recombine the activities back into
address-locations, or the use of special files.
* * * *
Despite disadvantages which may be foxmd in any
system, all are possible, and all may achieve sound
results provided that proper administrative control is
maintained over the records and a high quality of field
activity is achieved through training and constructive
supervision. Many systems require cross-referencing
to various other informational files. Activity based
files, furthermore, can be coded and otherwise refer-
enced for convenience, especially in connection with
selective analysis. Data can always be translated or
converted from one form to another in any system.
C. Source Coverage of Inventory Inspections
Source coverage refers to the extent or complete-
ness with which all sources are inventoried in the pol-
lution area. A procedure of source coverage must be
developed for inventorying the sources of air pollution
which will compensate for the incomplete data result-
ing from a perpetual inventory system. Source cover-
age may be random, or scheduled, or a combination or
sequence of both. In random source coverage, the
source-locations within any inspection sector are in-
-------
242
Air Pollution Control Field Operations
spected at the inspector's discretion. Although the
inspector may systematically schedule his own inspec-
tions according to a strategy he has adopted for that
sector, the inspections conducted in all sectors of the
pollution zone are still randomized. Random inspection
is in a sense equivalent to a painter who employs the
technique of working the "whole canvas at once". The
design or composition of such a canvas becomes readily
apparent much sooner than in the case where the
artist proceeds from one of the corners and works
systematically from that point without any break in
the emerging continuity. Similarly, the practice of
random inventory occurring simultaneously in each of
the inspection sectors of the area discloses an industrial
source pattern from which pollution potentials and
mass compliance can be reasonably extrapolated. Here
again the initiative of the inspector and the quality of
his work in his sector is statistically of the utmost
importance.
On the basis of the initial inventory inspections,
reinspections can then be scheduled or planned. The
scheduling accomplishes control over consistency, uni-
formity, non-repetition, etc., in order that the data in
the files at any given time possess the highest degree of
completeness and accuracy possible under the cir-
cumstances.
We may then speak of source coverage as em-
ployed by the A.P.C.D. in terms of the random (1)
initial inventory inspections, and the scheduled (2)
inventory reinspection.
1. Initial Inventory Inspections
The initial random inspection is conducted at a
plant for which no previous inventory inspection has
been conducted. We shall assume here that a sector
is being approached for the first time to locate all
address-locations where sources of air pollution may be
found.
It is obviously not wise to merely inspect plants
on a block-by-block basis, since valuable time is wasted
on many inconsequential sources of air pollution. To
maximize the usefulness of all field control operations,
it is best to conduct inventory inspections first in those
plants complained about, those responsible for visible
emissions, citizens' complaints, and those involved in
public nuisances, variances, or violations of the law.
All plants actively involved in enforcement actions
should be carefully inventoried as a part of the prac-
tice of enforcement at those plants. Those industries
whose air pollution potentials are quite obvious to one
observing them from a patrol, such as foundries, steel
mills, etc., should be inspected next. Industries under
construction, or those which appear to have been just
recently completed, or appear to have been involved
in a change of ownership should be inspected, since all
equipment units capable of air pollution in such plants
immediately come under the jurisdiction of the permit
system. Information as to where new construction or
changes in ownership may be taking place may be
obtained from the Business License Bureau, and/or
from business lead services. And, finally, the inspector
should locate all of the industrial communities or areas
of high source concentration in his sector, first in-
specting those sources which appear to be more im-
portant and so on. The final completeness of coverage
may be checked against the yellow pages of the tele-
phone directory, which lists industries in categories
similar to those employed by the control agency.
Of course, each inspection sector may call for a
different emphasis in coverage. In the downtown area,
for example, where virtually every office building has
a heating or steam generating plant with oil-standby
facilities, it is desirable to contact all boiler operators
on a block-by-block basis. Because of the complexity
of the petroleum industry, unit processes must be in^
spected systematically and periodically in sectors con-
taining petroleum industries. In other sectors, inspect-
ors may be concerned primarily with one or another
type of industry predominating in that area.
An inspector who has become familiar with his
sector will have accumulated an excellent knowledge
of not only the principal types of source activities, but
the names and histories of the industrial plants. When
an inspector changes sectors and encounters industries
with which he is unfamiliar, he can consult the
A.P.C.D. library for any information he may require.
An excellent method of familiarizing oneself with any
industry is to concentrate inspections in that industry
for a short time.
2. Inventory Reinspections
In the A.P.C.D., all subsequent inventory rein-
spections are scheduled. The frequency of inventory-
inspection is determined from the findings of the initial
inspection and the inspector's recommendations. The
schedules are typed up monthly for each inspection
sector and are forwarded to the sector inspector. The
sector inspector then schedules these reinspections so
that he can complete them within a month. The num-
ber of reinspections assigned per sector are based on
the fact that all annual, semi-annual, and tri-annual
inspections (the inventory cycle) must be completed
within one year.
The inspector, however, may have occasion to
inspect plants out-of-schedule because of complaints or
violations. In such instances, the inspector does not
make a formal inventory reinspection, but uses the
copy of the inventory record (Equipment List) from
his files as a check on the permit status as well as the
description and operation of the equipment. When a
specific kind of an air pollution problem is involved, it
is best to concentrate on that problem rather than on
the inventory of the entire plant. However, formal
change can be made on the Equipment List during an
unscheduled inspection if the Equipment List itself
can be used as a tool in gathering evidence. Especially
-------
Registering the Sources of Air Pollution
243
TABLE XIV- I.
PRIMARY ACTIVITY CLASSIFICATIONS
PETROLEUM AND PETRO-
CHEMICAL DEVELOPMENT,
PROCESSING AND
MARKETING -01
1 Refineries
2 Bulk Gasoline Marketing
Facilities, Rule 61 Actual or
Potential
3 Petroleum Production and
Related Operations
4 Bulk Storage of Petroleum
Distillates, Rule 56 Tank Farm
and Marine Terminal
5 Asphalt Manufacturing and
Felt Saturators
6 Heavy Hydrocarbons e.g.
Blending, Compounding and
Marketing of Fuel Oils, Asphalt,
Grease. Lube Oils, Road Oils, etc
7 Re-refiners, Solvents and
Lube Oil
8 Petro-Chemical Manufacturing
9 Sulfur Recovery Plants
INDUSTRIAL CHEMICAL
MANUFACTURING AND
PROCESSING (EXCLUDING
PETRO-CHEMICAL) -02
1 Soaps and Detergents
2 Insecticides and Herbicides,
Compounding and Packaging
3 Chemical Specialties e.g.
Compounding and Packaging of
Pharmaceuticals, Cosmetics,
Aerosols, Household and
Janitorial Chemicals, etc.
4 Industrial and Automotive
Chemicals
5 Manufacturing and Packaging
of Gases
6 Explosives, Rocket Propellants
and Pyrotechnics
7 Radio Active Materials, Isotopes
and Related Materials
8 Chemical Processes Involving
Chlohnation
9 Wood By-Products Plants e.g.
Sawdust, Wood Flour, Shaving,
Briquets, etc.
FOOD PROCESSING- 1°
1 Meat Smoking. Packing, Canning,
including Lard Rendering
2 Fish Smoking and Canning
(excluding by-products)
3 Bakeries
4 Coffee Roasting
5 Dairy Products Processing
including Dried Milk, Condensed
Milk, Ice Cream, etc.
6 Gram and Feed Milling, Flour
Milling, Cereal Packaging, etc.
7 Fruit and Vegetable Canning
and Packaging
8 Beverage Manufacturing
9 Pet Foods, All Types
10 Food Specialty Packaging e.g.
Spices, Condiments,
Flavorings, etc
11 Margerine and Oleaginous
Products
INEDIBLE ANIMAL AND
VEGETABLE BY-PRODUCT
PROCESSING -I*
1 Rendering
2 Fertilizer Processing and
Packaging
3 Fish Cannery By-Products
Processing
4 Tanneries and Hide Processing
5 Wool Processing
6 Dehydrating Food By-Products
HOTELS, APARTMENTS
AND OFFICE BUILDINGS
(EXCLUDING
GOVERNMENTAL)-12
1 Office Buildings
2 Private Medical Facilities and
Private Hospitals eg.
9 Catalysts
10 Organic Chemicals
11 Inorganic Chemicals
PAINTS AND RELATED
MATERIALS, MANUFAC-
TURING AND HANDLING - 03
1 Paint Type Products e.g. Lacquer,
Varnish, Shellac, Ink, Enamel,
Powder Paints, Water Emulsion
Paints, etc.
2 Paint Additives e.g. Pigments,
Dryers, Surfactants, etc.
3 Polymers and Resinous Materials
4 Marketing of Solvents and
Liquid Chemicals
5 Vegetable and Animal Oil
Processing {excluding Rendering
and Food Processing)
6 Adhesives e.g. Sealants, Putties,
Calking Compounds, Masking
Compounds, etc.
PLASTIC, RUBBER AND
RESIN PROCESSING -04
1 Rubber Products Processing
e.g Molding, Dipping, Coating,
etc. (excluding Tires)
2 Rubber Reclaiming
3 Tire Recapping
4 Plastic and Resin Molding e.g
Injection Molding, Compression
Molding, Extrusion Molding,
Permanent Molding, etc.
5 Plastic and Resin Fabrication
e.g. Laminating, Coating,
Embedding, Sheet Forming, etc.
6 Tire Manufacturing
METAL MELTING AND
RECLAIMING-05
1 Grey-Iron Foundry Facilities
2 Steel Foundry Facilities
3 Brass Foundry Facilities
4 Aluminum Foundry Facilities
Sanitariums, Hospitals, Clinics,
Rest Homes, etc.
3 Private and Religious Schools,
Colleges, etc
4 Motels, Courts and Trailer Parks
5 Apartment Hotels and
Apartment Buildings
6 Scientific Research and
Development Facilities
7 Scientific Laboratories eg.
Testing, Metallurgical,
Bacteriological, etc. (excluding
Medical and Dental and Film
Processing)
COMMERCIAL ACTIVITIES-13
1 Retailing Activities, Consumer
Sales and Equipment Rentals
2 Wholesalers, Jobbers, Warehouses
and Contractors' Yards
3 Electrical and Electronic
Repairing, Rebuilding and
Servicing
4 Motion Picture and Television
Production Facilities
5 Photographic Arts and Processing
e g. Studios (excluding Motion
Picture and TV), Film
Laboratories, Commercial Artists,
Photo Duplicating including
Blueprinting and Ozalid
6 Laundries, Rug Cleaning, etc.
7 Cafes, Restaurants and Bars
(excluding those in hotels)
8 Printing Shops, Newspapers
and Publishers
9 Mortuaries, Crematories and
Cemeteries
10 Graphic Arts Specialties and
Services e g, Engravers,
Photoengravers. Electrotypers,
Mat-makers, Silk Screening,
Printed Circuits, etc.
11 Dry Cleaning Plants
12 Junk Yards, Salvaging and
Converting of Industrial
5 Magnesium Foundry Facilities
6 Miscellaneous Non-Ferrous
Foundry Facilities
7 Secondary Refiners
8 Core Making Facilities
9 Die Casting Facilities
METAL FABRICATING-06
1 Electrical and Electronic
Equipment Manufacturing
2 All Instrument Manufacturing,
Repairing and Rebuilding
3 Structural Metal Fabricating
and Forming
4 Sheet Metal Fabricating e.g.
Punch Pressing, Drawing, Metal
Spinning, Tube Drawing, etc.
5 Welding, Blacksmithing, Forging,
Swaging, Cold Heading,
Upsetting, etc.
6 Heavy Machinery Manufacturing
and Reconditioning
7 Metal Cutting e.g. Machine
Shops, Tool and Die Shops,
Oil Tool Manufacturing and
Reconditioning, etc.
8 Battery Manufacturing,
Assembling and Rebuilding
9 Wire Products Manufacturing
e.g. Springs, Cables, Wire Forms,
Metal Cloth, Wire Drawing, etc.
10 Powdered Metal Processing
SURFACE FINISHING
AND COATING-07
1 Galvanizing Facilities and Plants
including Dip Tinning
2 Sand Blasting and Abrasive
Blasting Facilities
3 Heat Treating Plants
4 Printing on Metal
5 Plating Facilities
6 Surface Coating and Protective
Treating of Materials e g.
Pickling, Parkenzmg, Bonderizing,
Corrosion Preventive Coatings,
Materials (excluding Secondary
Metal Refining)
13 Business Machines, Sales and
Servicing
14 Household Appliances, Sales and
Servicing
15 Amusement and Recreational
Facilities
16 Agricultural Operations
GOVERNMENTAL AGENCIES
AND PUBLIC UTILITIES-14
1 Public Office Buildings
2 Public Schools, Colleges,
Universities, etc.
3 Municipal Incinerators and
Disposal Facilities including
Sewage Treatment Facilities
4 Publicly and Privately Owned
Power Plants Generating Power
and/or Steam for Public Use
5 Publicly and Privately Owned
Public Utility Facilities e.g.
Telephone Co., Gas Co.,
Waterworks, etc.
6 Governmental!]/ Owned Hospitals
7 Cut and Fill Dumps
8 Transportation Facilities,
Terminals, Depots, Stations, etc.,
Tor all Transportation Media
9 Governmentally Owned Shipyards
VEHICLE MANUFACTURING
AND SERVICING
FAClLITIES-15
1 Airframe Production including
Guided Missiles
2 Auto and Truck Assembling
3 Trailer Manufacturing and
Assembling
4 Aircraft Overhaul Facilities
5 Automotive Component
Rebuilding Facilities e.g
Engines, Transmissions,
Carburetors, Slarters, Generators,
Water Pumps, etc.
Vacuum Coating, Metallizing,
Anodizing, etc
7 Surface Grinding and Polishing
e.g. Centerless, Surface, Lapping,
Honing, etc.
8 Painting and Enameling,
Major Users
9 Display Sign Manufacturing
and Servicing
MINERAL PROCESSING- 08
1 Sand and Gravel Plants, Rock
Plants, Concrete Batch Plants,
Cement Storage and
Handling Facilities
2 Asphalt Paving Plants e.g
Hot Plants
3 Ceramic Processing e.g. Brick,
Tile, Clay Products,
Refractories, etc.
4 Glass, Frit and Rock Wool
Manufacturing, including
Vermiculite and Perlite Plants
5 Mixing, Grinding, Blending and
Packaging of Miscellaneous
Mineral Base Products
WOODWORKING AND
FURNITURE
MANUFACTURING- 09
1 Lumber Yards, including Sash
and Door Mills
2 Furniture Manufacturing,
Repairing and Refinishmg,
including the Use of all Materials
3 Casket and Cabinet Shops
4 Wood Treating Facilities eg.
Termite Proofing, Creosoting,
Flame Proofing, etc.
5 Pattern Shops, all Types
6 Wood Turning Facilities
7 Wooden Shipping Materials e.g
Pallets, Crating, Skids,
Cooperage, etc.
8 Wood Laminating e.g. Plywood
Veneering, Formica Banding, etc.
6 Custom and Special Vehicle
Manufacturing (excluding Trucks
and Trailers)
7 Auto Wreckers
8 Vehicle Dealers
9 Vehicle Repair Facilities
including Vehicle Body Repair
Shops
10 Shipyards, Boat Building, Boat
Repair, Dry Docks, etc
(excluding Governmentally
Owned)
11 Railroad Service and Repair
Facilities, Yards, Roundhouses,
etc. (excluding Stations, Depots
and Warehouses)
TEXTILE, FABRIC, FIBER,
MONOFILAMENT
MANUFACTURING AND
PROCESSING-IG
1 Garment Manufacture
2 Textile and Fabric Coverings
Manufacturing e.g Seat Covers,
Tents, Tarpaulins, Draperies,
Awnings, etc.
3 Textile and Fabric Processing
e.g. Sponging, Shrinking,
Waterproofing, Dyeing,
Flameproofing, Printing, etc.
4 Mattress, Cushion and Pad
Manufacturing and Renovating
(excluding Furniture
Manufacturing)
5 Paper Products
6 Shoe and Luggage
Manufacturing, etc.
7 Brush Manufacturing
8 Special Textiles e g. Felt,
Webbing, Rope, Cordage,
Packings, Oakum, Belting, etc.
9 Weaving of Textile Materials eg.
Braid, Tape, Lace, Bindings,
Rugs, etc.
-------
244
Air Pollution Control Field Operations
is this true in a public nuisance case where it is
desirable to eliminate from suspicion all equipment
which does no1 contribute to a public nuisance. In such
instances, the Equipment List serves as a kind of check
list, and may in itself indirectly figure in a court case.
The Equipment List should then be formally revised.
On an assigned inventory inspection, the inspector
must check all equipment units in the plant against
thos&of the Equipment List. The inspector is careful
to note that the equipment listed is not only identical
in important respects, but is not a replacement, since
permit regulations are affected by replacements. This
is usually determined by comparing manufacturer's
serial numbers. The inspector also checks for new
equipment, alteration of equipment, posting of permits,
operation contrary to conditions of permit, etc. Any
discrepancies noted are recorded in detail on the Activ-
ity Status Report. (See Figure XIV-9.)
D. Preparation and Maintenance of Equipment Lists
for Industrial and Commercial Activities
In the Enforcement Division of the A.P.C.D., the
Equipment List is the inventory: it is a list of the
equipment units capable of emitting air contaminants
contained on the premises of a company located at one
address-location. The Equipment List is titled and filed
according to the name and address of the company.
For example, the "ABC Company", located at "340
Johnson St., Los Angeles 2, California"
A modification of this procedure is made with
respect to industrial plants which are in themselves so
diversified, and contain so many equipment units that
they cannot be inventoried in one continuous inspec-
tion. These particularly include plants with elaborate
organizational structures, such as an oil refinery, or a
large aircraft plant, chemical plants, large steel mills
and metal fabricating plants, etc. Such plants are
"unitized" for the purpose of establishing Equipment
List boundaries. The individual "units" are then
scheduled for separate inventory reinspections.
The Enforcement Division refers to the inventory
unit or group for which one Equipment List would be
made as an Activity. The Activity is defined as an
industrial plant or a commercial enterprise occupying
one address-location, or a unit of production capable
of standing alone as an independent source activity in
the industrial economy, but which is integrated into a
large industrial plant at one address-location. The
latter represents unitization. Unitization, however, is
always dictated by necessity. It is preferable, wher-
ever possible, to maintain a complete inventory record
of one address-location. The basis of record-keeping
and classification should attempt to remain as consis-
tent as possible with the legal entity — the company-
address-location which would be involved in a legal
proceeding.
The Source Activities are classified in the
A.P.C.D. by means of a Primary and a Secondary
Activity Classification System (see Table XIV-1). The
Primary Activity Classification breaks the industrial
economy of the pollution zone down into some sixteen
general technological or commercial activities grouped
according to similar air pollution potentials. The pur-
pose of such a classification system, ultimately, is to
disclose those source activities within each of these
technological categories which have air pollution po-
tentials, and those which do not, or have little. With
such a classification system a complete area inventory
can be approached.
Each primary activity is composed of the second-
ary "source activities" which would be found at indi-
vidual address-locations. For example, the "Metal
Melting and Reclaiming Activity", a primary activity
classification, is coded as "05", while the secondary
Source Activities comprising the classification are as
follows:
1. Gray Iron Foundry Facilities
2. Steel Foundry Facilities
3. Brass (Red and Yellow) Foundry Facilities
4. Aluminum Foundry Facilities
5. Magnesium Foundry Facilities
6. Miscellaneous Non-ferrous Foundry Facilities and Die
Cast
7. Secondary Refiners
8. Core Making Facilities
The Brass Foundry Facility (05-3), for example,
is a Source Activity, whether it is a complete self-
contained plant or an independent commercial activ-
ity, as it is usually found, or a department within a
large industrial plant, such as a large plumbing prod-
ucts manufacturing plant. In the example of a large
plumbing products plant, additional source activities
may be found such as a plating department or a ma-
chine shop coded as separate source activities under
other Primary and Secondary Activity Classifications.
We can see from this system that if an industrial
unit within a plant at one address-location can be con-
veniently classified and given a primary and secondary
classification code number which differs from those
which may be assigned to the remaining departments
or units within the plant, a separate Equipment List
is made. In order to locate all the source activities with
different classifications which may be found at one
address-location, a visible reference cross-indexed file
is used to recombine these source activities alphabeti-
cally.
1. The Manila Envelope and Field Inventory File
The inspector completes the Equipment List in
duplicate. The original is brought to Headquarters for
review and filing. The duplicate, the inspector's field
copy, is maintained inside of a Manila File Envelope.
(See Figure XIV-1.) This envelope is designed to con-
tain the Equipment List, duplicates of permits issued,
variances, records of court cases, office and field hear-
ings, photographs and any other documents of use in
the field. It is maintained in a sector file in the in-
spector's vehicle, and is filed either alphabetically by
name of company, or by street and number.
-------
Registering the Sources of Air Pollution
245
Fl
AD
N/>
SC
RE
07
RM NAMF Jjos Aneeles Brass Products. Incorporated
DATF March
A.P.C.
10 1 P, 59
n 7riNF
DRFSS rip PRFMISFS 35161 Larkspur Road r|TY Los Angeles 8
TIIRF OF pnsiNF^ Plumbine Fixtures & Hardware Products PHOWF BL4-5321
HJRCE OF AIR POLLUTION -
SPONSIBLE PERSON TO CON
HER PERSON WHO MAY BE C(
EC
INSPECTED BY
1
2
3
4
5
6
7
8
9
10
R. P. Hendricks
H. Forbes
YES@ NO[] NORMAL BUSINEJ
rArj H. L. Henderson
;q HniiRq 7:00 AM 8:00 PM
TITI p Work Manager
TNTArTFD R- Bottom TIT|F Asst. Work Manager
3UIPMENT LIST & PERMIT DATA INSIDE
INSPECTION RECORD MADE
DATE
11-5-59
5-3-60
CHAI
YES
X
IGES
NO
X
PERSON CONTACTED
H. L. Henderson
R. Bottom
3Y J. Jason
INSPECTOR
TITLE
Wks. Manager
Asst. Wks. Mgr.
AIR POLLUTION CONTROL DISTRICT-LOS ANGELES COUNTY
Figure XIV - 1. Manila envelope field inventory file.
The face of the Manila envelope provides the
inspector with preliminary data he can check at a
glance, such as ownership, address and nature of the
business.
The Manila envelope is made for each business
location only when sources of air pollution are present
on the premises.
On the face of the envelope, the entire heading
involving plant data is completed in full. All blanks
are answered either positively or negatively.
In preparing the envelope, the inspector places
his signature and date of preparation in the space pro-
vided immediately to the right of the words "Inspec-
tion Record".
The information requested on the bottom half of
the envelope pertains to reinspections only. The first
line is for the use of the sector inspector remspecting
the location. After completing the inspection, the in-
spector enters on this line his name and the date. He
checks "Yes" or "No" if changes involving the equip-
ment list are noticed, and enters the name and title of
the person contacted,
2. When Equipment Lists Are Made
Both the Equipment List and Manila Envelope
are prepared by the inspector for an activity, only if
there are sources of air pollution on the premises. If
there are no sources of air pollution, the Equipment
List and Manila Envelope are not prepared. The
"non-source" activity, however, is still accounted for
in two ways. First, the inspector reports on an Activity
Status Report the name and location of the company,
the nature of the business, etc., and the expansion po
tential of the company, or some indication as to the like-
lihood of the establishment to install equipment capable
of air pollution in the future: such indication is im-
portant for scheduling a reinspection. If the plant is
A.P.C.D. ZONE
1
2
19
20
LOCATIONS INSPECTED AND FOUND TO HAVE NO SIGNIFICANT SOURCE OF AIR POLLUTION
INSPECTED
BY DATE
FIRM NAME ADDRESS OF PREMISES r 1 TY
.- _ _^~- ' -—
— "^^ "" ~~~" ^^ ' ~^~^
AIR POLLUTION CONTROL DISTRICT—LOS ANGELES COUNTY
Figure XIV - 2. Non-source inventory card.
16. 40D 1 9f
-------
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9
10
riON CONTROL DISTRICT - COUNTY OF LOS ANGELES - AREA GRID
M NAME Los Angeles Brass Products, Incorporated
RFS$ OF PRFMISFS 35161 Larkspur Road POS
$PNT LEGAL OWNER National Enterprises, Incorporated
E BUSINESS ACQUIRED BY PRESENT OWNER Feb. 1947 NAME OF FORM
URE OF BUSINESS Plumbing fixture and hardware products . see List for Platin
sin.
TEL.
M.R.Kin. 05
BL 4-5321 A.P.C
JTAL ZONE_S_CITY
CORP
ER OWNER
e DenartmeiLt_J
PONSIBLF PFRSON TO CONTACT H.L.Henderson TITLE
None
Los Angeles
3
B. 70ME 8
N. 0 PART.QIHDIV. D
17-5
Work Manager .
>T OF ALL EQUIPMENT & PROCESSES THAT MAY BE SOURCES OF AIR POLLUTION
ASSIGNED INSPECTION D REVISED FROM INSPECTOR'S EQUIPMENT LIST D NO PREV. RECORD H LINEDEX TYPED D
DESCRIPTIVE-GENERAL USAGE NAME OF EQU 1 PMENT- SYSTEM
OR PROCESS INCLUDING MANUFACTURERS NAME! MODEL NO.
1-Smith automatic baghouse with 32 orlon bags, 8' x 6" Dia. , with 15 H.P.
feiower collection system to hoods serving the furnaces in Items No. 2 and 3.
l-Hefndf»rson 500-lb. hydraulic tilt reverberatory furnace for yellow brass melting
14SLzinc^gas fired. Vented to Item No. 1.
1-Henderson 750- Ib. hydraulic tilt reverberatorv furnace for yellow brass. 14%
zinc, gas fired. Vented to Item No. 1.
1-Forrestal 100- Ib. crucible pit furnace for pure ingot aluminum.
1-Crocker sand conditioning device equipped with one 4' dia. cvclone.
1-Sanrl shakenut.
1-Columbia air filter cloth screen collector, Serial No. 5672, serving Item No. 8.
1-Patterson tumbleblast, 8' x 5' W. x 3' D.
4-identical Patterson shot blast booths, Serial No. 100-1, 100-2, 100-3, 100-4,
served by 1 Patterson 24-cloth bag filter, Serial No. 8931.
1-Single chamber incinerator 4' W. x 3' D. x 4' H. Not in use.
APPROXIMATE
LOCATION
ON PREMISES
Hear E corner
of bldg.
Eastmost in
near E corner
Westmost in
Rear E. corner
Rear center
Front west
Front west
inter west
jenter west
Center rear
Yard west
DATE
INST.
1955
3-59
1947
1949
1955
1955
1955
1955
1947
A.C.
OR
P.R.
PR
PR
A.P.C.D.
STATUS
A- 1891
Rule 13
Rule Hi
A-361
Incon.
A-425
A-426
Banned
RE INSPECT ION NO.
1 2
1
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Registering the Sources of Air Pollution
247
LOS ANGELES BRASS PRODUCTS, INC. ^ (METALS DIVISION)
CT)5
SAND CONVEYOR
OOOO
MOLD MAKING MACHINES
SAND
CONDITIONER
METAL POURING AREA
FURNACES
o
SAND SHAKE OUT
TUMBLEBLAST
SHOT BLAST BOOTHS
OFFICES
PLATING DEPT.
(See List 07-5)
BAGHOUSE
BAGHOUSE
Figure XIV -3.1. Plot plan on reverse of Equipment List to illustrate positioning of equipment.
a type of activity such as a warehouse in which no
sources of air pollution can be expected to be added to
the premises, it should be scheduled for reinspection
on a frequency "0" basis. If, on the other hand, the
plant is a small plating shop with a few plating tanks
but a great deal of unoccupied floor space, that plant
might expand its manufacturing operation to include
other tanks or operations subject to A.P.C.D. permit
requirements, and should be inspected at least once
each year. Second, the inspector lists the company on
a Non-Source card. The Activity Status Report is for-
warded to Headquarters and is filed in the Equipment
Inventory Dossier File (see Chapter 6). The Non-
Source card remains with the inspector's Field Inven-
tory File.
If the Source Activity has equipment which is a
significant source of air pollution, both a Manila En-
velope and an Equipment List are made out for the
initial inspection. The Equipment List is made out in
duplicate, the original is sent to Headquarters and the
duplicate is filed by the inspector in the Manila File
Envelope.
On the inventory reinspection, the inspector re-
vises or confirms the correctness of the existing Equip-
ment List. The list is revised to incorporate any
changes which have taken place since the last visit. If
the revision is extensive, a new Equipment List in
duplicate is prepared. If the change is minor, an Activ-
ity Status Report need only be made to account for
the change. The status report is always made in
duplicate, like the Equipment List. The original is
sent to Headquarters, and the copy is maintained in
the Manila Envelope File.
An exception to this procedure is made in the case
of inspections of refineries and petrochemical plants.
Such inspections are made according to process rather
than equipment units, and are inventoried in a some-
what different manner, as will be described later.
3. Preparing the Equipment List
The Equipment List is broken down into four
basic parts: (1) business and ownership data of the
source activity; (2) description and location of each
piece of equipment, (3) Permit Status of each equip-
ment unit, and (4) coded equipment data. For con-
venience the Equipment List in Figure XIV-3 should
be referred to. This discussion is concerned with mak-
ing an Equipment List on an initial inspection.
a. Business and Ownership Data of the
Source Activity
All business and ownership data are contained on
the heading of the Equipment List. The heading is
usually filled out during the initial interview with
plant management, in order to gather the background
data necessary for the determination of the permit
status of each piece of equipment to be inspected. The
procedures for identifying the company, its type of
-------
248
Air Pollution Control Field Operations
ownership, its owners, officers or managers, are the
same as described in "C. Persons Responsible for Vio-
lation", in Chapter Thirteen. Here also the inspector
seeks legal definition of ownership. The information
called for on the Equipment List, however, is broken
down in detail so that all of the data which may affect
the permit status of the equipment in the plant are
included.
The elements of the data pertinent to the Permit
Status are (1) the present legal owner, (2) the date
the business was acquired by the present owner, and
(3) the name of the former owner.
Under Firm Name, the business or fictitious
name — if one is used — is entered. If the business
uses the owner's personal name, then only the name of
the owner (and co-owner, if any) is entered. In cases
where a corporation operates a business under a name
different from the corporate name, i.e., "Western Fur-
niture Co.", owned by "American Furniture Mfg.,
Inc.", the "Western Furniture Co." is recorded under
Firm Name and "American Furniture Mfg. Co., Inc."
under the Present Legal Owner. The Name of Former
Owner should also be given. If this information is un-
obtainable, state: "unknown". If new construction is
involved write "New" in this space.
On the line entitled "Nature of Business" an in-
clusive description of the general purposes and pro-
cesses of the enterprise and the products produced
should be recorded. The terminology listed in the
Primary Activity Classification such as "office build-
ing", "brass foundry facilities", "plating facility", etc.,
should be included. A more detailed explanation of
the nature and size of the business can be given on the
reverse of the Equipment List such as:
(1) End product manufactured, processed or produced.
(2) Raw materials used.
(3) Approximate size of plant in terms of production vol-
ume, men employed, sq. ft. of plant area, etc.
(4) Number of shifts worked and normal working hours
of plant.
(5) Flow sheets for process plants.
Where several primary activities are carried on
in the same premises, separate Equipment Lists are
made to cover each Source Activity of substantial mag-
nitude. Note on the Equipment List (Figure XIV-3)
the reference to the plating department under "Nature
of Business".
b. Description and Location of Each
Equipment Unit
The main purpose of the inventory is to list, item-
ize and to identify by description each piece of equip-
ment in the source activity. For our purposes here we
shall call this "piece" or "item" of equipment an
Equipment Unit, which may be defined as follows:
An Equipment Unit is an identifiable piece of
equipment which operates as a complete functioning
unit either as a solitary piece of equipment or as a
cluster of related equipment, consisting of a primary
operating unit equipped with or served by auxiliary
equipment, appurtenances, controls, heating elements,
or equipment parts. Equipment Units can either stand
alone or as a contributing member of a battery or
process by interconnection with other equipment units.
With respect to the inventory process, equipment units
are of two types. Those which may be sources of air
pollution, and those which are not.
A source of air pollution, it should be recalled, is
that specific outlet, stack or other opening from which
air pollutants may be emitted into the atmosphere.
The pollutants emitted are generated by the Equip-
ment Unit and discharged through the stack or exhaust
system serving that Equipment Unit, or are generated
by a number of Equipment Units and are exhausted
through one stack effluent system, or into the general
atmosphere through a louvre, roof monitor, vent, etc.
The inspector identifies Equipment Units which
are capable of being sources of air pollution when he
inventories. The description of an Equipment Unit
which may be a source of air pollution includes all
auxiliary equipment, appurtenances, etc., which are
relevant to a description of the equipment as a source
of air pollution. (See Chapter 13, "D. Equipment".)
All equipment appurtenances which are of a minor
character, or are irrelevant to characterizing the
Equipment Unit as a source of air pollution are
omitted from the cluster description. The ability to
describe equipment reflects an understanding of the
variables affecting the air pollution potential of the
Equipment Unit.
For example, Figure XIV-4 below gives a com-
plete schematic of an oil-fired boiler.
Among many components of equipment which
might be noted are those shown below:
firebox, oil lines, Pierson rotary type oil-burner, electric
pre heater, fan housing, pressure gauges, oil strainer, ther-
mostat, automatic controls on burner, damper, fire-tube
section, name given as Rodney Iron Works boiler, rated at
250 H.P., Serial No. 12345, etc.
SAFETY VALVE-
HOTARY BUHNER
IGNITION-
ELECTRIC OIL
HEATER „ 1O q
STEAM OIL HEATER
DAMPER
"OIL LINE FROM TANK
Figure XIV - 4. Simplified drawing of a fire-tube boiler and es-
sential accessories. Suggested inspection points: oil heaters,
dampers, fan housing, ignition mechanism, fire box and rotary
cup oil burner.
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Registering the Sources of Air Pollution
249
From such details this boiler could be described in
many of several ways. All that is required are those
significant facts and items which clearly identify the
equipment unit and describe something of its character
as a source of air pollution. For example, the boiler
could be described as:
1—250 H.P. Fire-Tube, Rodney Iron Works, Boiler, Serial
No. 12345, equipped with one automatic Pierson Rotary
Cup Oil Burner, Serial No. 3526, and one electric 95 °F.
oil preheater.
Other equipment, gauges, thermostats, etc., are
obviously not significant in the description. Also, it is
unnecessary to include devices or portions of devices
which may always be found with the class of equip-
ment. For this reason, the firebox, fan housing, oil
strainer, oil lines (since we know this an an oil-fired
boiler) and even the stack need not be mentioned,
though on occasion the height and diameter of the
stack is given, especially when two or more boilers are
breeched to a common stack. Here we may note, that
the terms "equipped with", "served by", or "consisting
of" are the key words found in most cluster descrip-
tions.
(1) Basic Equipment and Control Equipment
Equipment Units capable of air pollution, in turn,
fall into two classes.
Basic Equipment: This class includes any articles, machine,
equipment, or other contrivance, the use of which may
cause the issuance of air contaminants.
Air Pollution Control Equipment: This class includes any
article, machine, equipment, or other contrivance, the use
of which may eliminate or reduce or control the issuance
of air contaminants.
Figure XIV-5 diagrams a control system for two
brass furnaces of the reverberatory rotary type.
Each reverberatory furnace is a basic unit of
Equipment, equipped with shell, refractory, rotary
and tilting devices, and oil or gas burners. Thus, there
are two basic equipment units in battery.
The control unit consists of the entire collection
system: hoods, cooling ducts, motor and fan, bag-
house, and hopper. A description of the control unit
includes the number of bags, the material used, the
size, whether the baghouse is automatically or man-
ually rapped, the blower horsepower, and type of pre-
cooling system. (In this case, radiational.) In this
example, one unit of collection equipment serves two
units of basic equipment.
Under the Rules and Regulations, basic and con-
trol equipment require separate permits, and are usu-
ally itemized separately on the Equipment List.
(2) Permit Unit and Equipment Unit
In order to establish criteria governing the sub-
mission of applications for permits under the permit
system, the Engineering Division of the A.P.C.D. has
established a "permit unit". A permit unit is that basic
or control equipment, or grouping of such equipment,
for which one application would be made and, upon
approval of the application, one permit would be
issued. It is defined as a "functionally whole article
or machine or equipment or contrivance as a group.
The functional whole is determined on the basis of
either (1) a specific pollution problem, or (2) the
association of individually identifiable items of equip-
ment to accomplish a process or manufacture. A Per-
mit Unit may consist of one individual item or a group
,— HOOO ---<
/ eoo-iocWFi
COOLING
DUCTS
A
FURNACE
SETTLING
CHAMBERS
COLD AIR
DAMPER —
FAN-12000 CFM.
12.5' S.P.
MOTOR-50HP.
ZOO'F
BAG HOUSE-APPROXIMATELY
7600 SO. FT. CLOTH AREA —
~n
CONVEYOR
~7
Figure XIV - 5. Diagram of basic and control equipment for two brass furnaces served by cooling columns and cloth filtering system.
-------
250
Air Pollution Control Field Operations
of two or more items."* Generally, the permit unit
applies to all equipment which must operate together
to perform a specific function. In most instances final
approval as to the organization of the permit unit must
be made by a member of the Engineering Division,
rather than the Enforcement Division.
Permit and Equipment Units may frequently be
identical, i.e., refer to the same grouping, cluster or
piece of equipment, particularly when the equipment
unit is "functionally whole determined on the basis
... of (1) a specific pollution problem". A single
boiler, for example, not part of a process, is a Basic
Equipment Unit as well as a Permit Unit, and is listed
as a separate item on the Equipment List. A gray iron
cupola in a foundry is another Basic Equipment Unit,
as well as a Permit Unit. The entire control system
serving the cupola, including the evaporative cooler,
duct, blowers, fan and motor and cloth filtering unit
is considered as a separate equipment unit as well as
a separate permit unit. The inspector has the option of
listing equipment according to Permit Units or sepa-
rate Equipment Units which might be contained in
one permit unit, according to which makes the
clearest reference for enforcement purposes.
Both types of units, then, are a matter of con-
venience to the person who must decide how to group
equipment, the inspector in the case of the inventory,
and the engineer in the case of the permit. The defi-
nition of the equipment unit is amenable to delinea-
tions of reference for purposes of enforcement whereas
the permit unit is a guide in making decisions with
respect to how equipment shall be grouped on permit
applications. The permit unit is more of aicriterion for
unusual cases than it is for typical cases where such
grouping is logically dictated in both systems. In the
case of the permit unit, the engineer must also consider
electric motor horsepower, heating values, and other
factors that affect the permit fee.
Several circumstances in which it is convenient
for enforcement purposes to break what would be
Permit Units down into smaller Equipment Units may
occur. One of these covers such circumstances in which
any change in any one of the equipment units is tanta-
mount to alteration of the entire permit unit, requir-
ing reapplication for equipment under Rule 10. It is
thus desirable to make a strict accounting of all equip-
ment components which may affect the permit status
within the Permit Unit. Especially is this true in
the case where Part 2 of the Permit Unit definition,
"the association of individually identifiable items of
equipment to accomplish process or manufacture,"
applies. Here for "Items of Equipment" read "Equip-
ment Units"
Also, in complex cases only the Engineering
Division is capable of making formal definitions of
* A.P.C.D. Engineering Division, Administration of the Permit
System, December 1958, Page 10.
"permit units" on the basis of policy and previous
experience. It is safer, then, for the inspector to list
equipment units when he is in doubt.
The difference between the Permit Unit and the
Equipment Unit is thus a matter of form. It is a
question of whether such equipment should be de-
scribed as a cluster unit as one itemization, or whether
that cluster should be broken down into individual
items on the Equipment List. If they are broken down
on the Equipment List, they must be listed consecu-
tively so that the same "A.P.C.D. Permit Status" can
apply to the units comprising the permit unit.
(3) Itemization of Equipment Units.
The itemization of equipment units on the Equip-
ment List comprises the actual inventory or accounting
process. The Item Column may be noted in the left-
hand column of the Equipment List in Figure XIV-3.
Equipment units are itemized in normal consecutive
counting order, that is "1", "2", "3", "4", "5", etc.
Only those equipment units, the use of which may
cause the emission or reduction of air contaminants,
are itemized. All equipment which may be sources of
air pollution but exempt by Rule 11 or otherwise ad-
ministratively exempt are also listed. Equipment units
which are clearly non-sources, including those speci-
fically exempted by Rule 11, are not itemized. Equip-
ment which emits very small amounts of air pollution
is listed, but is noted as "inconsequential" (see Item
#6 on Figure XIV-3).
The inspector has considerable latitude in item-
izing equipment to fit the groupings which he encoun-
ters, and the relative importance of each piece of
equipment. An important piece of equipment may be
handled as a separate itemization and with consider-
ably more detail than one which is of little conse-
quence. Generally, the inspector's description of his
itemization is based on one of the following equipment
groupings: (1) individual equipment units, (2) more
than one, but exactly identical equipment units, (3)
control-basic equipment combinations, (4) equipment
battery combinations, and (5) process unit com-
binations.
Individual equipment units are described accord-
ing to their mechanical or chemical function as
"boiler", "incinerator", "furnace", "spray booth", etc.
In a detailed description all auxiliary equipment
parts with which the equipment is equipped or which
it serves or is served by are included. Such auxiliary
equipment as burners, motors, etc., are described with
the equipment unit if they are essential. They are
never itemized separately. Most industrial situations
outside of refinery and chemical plants are made up of
individual equipment units, and most Equipment Lists
are made along the lines of those of the brass foundry
shown in Figure XIV-3. Equipment units are still con-
sidered to be individual units even when a product
moves from equipment to equipment on a moving belt
-------
Registering the Sources of Air Pollution
251
or chain-type conveyor. Process units pneumatically
connected are treated differently, however.
Exactly identical equipment units may be grouped
together as long as the equipment is identical as to
structure and use and the exact number of equipment
units is given (see Item 9, Figure XIV-3).
Although control and basic equipment in combi-
nation are generally itemized separately, it is some-
times economical to make a single listing of relatively
minor equipment. A good rule is to consider whether
or not they comprise an original combination, that is,
a mixture of equipment types or makes, etc., or
whether they form a manufacturer's "package unit".
The air pollution potentials of the individual equip-
ment units are also taken into account. For example,
Item 9 is itemized together as a package unit by one
manufacturer, even though five equipment units are
involved. On the other hand, the inspector chose to
separate Items 7 and 8 because of the relatively unique
combination of equipment normally found in separate
"package units".
Items 1, 2 and 3 cannot be combined into one
listing under any circumstances, however, because of
(1) the relatively high air pollution potentials of the
individual equipment units as indicated by their capac-
ities and the character of the melt, (2) the uniqueness
of such equipment in the combination, and (3) the
variations in the permit status of the individual equip-
ment units.
The battery or series of equipment units refers to
a group of similar (but not always) individual equip-
ment units not contributing to a process, but exhaust-
ing through one system. For example, a power plant
may consist of 5 boilers in battery exhausting through
one exhaust system or stack. A plating plant may have
several plating tanks in series which exhaust through
one blower or control system.
Equipment units involved are generally listed
separately, particularly when they are large or impor-
tant pieces of equipment. In such instances the same
rules apply to the battery as to identical or combined
units. Note that Items 2 and 3 in Figure 3 actually
constitute a battery. Item 9 is also a battery consisting
of identical pieces of basic equipment. Since the equip-
ment is identical, one listing can be made. Whenever
a battery situation is involved, each itemization should
note its connection to the common exhaust system by
referring to the proper Item number. (Note again,
Items 2 and 3.)*
The Process Unit may be defined as a group of
equipment or process vessels which are interconnected
by sealed or ducted flow systems, such as might be
found in a refinery or petrochemical plant. (See Fig-
ure XIV-10.) The product moving through the unit
is progressively transformed towards a desired end
' However, equipment in battery, such as abrasive blast booths,
may individually constitute separate Permit Units.
point in the individual equipment in the system. All
of the equipment in the process may exhmist into one
local exhaust or control system. That is, a gas or vapor
gathering system for the entire unit may exhaust
either to a control device or into the general atmos-
phere. The basis for considering the process is made
in terms of one specific pollution problem, or in terms
of those identifiable items of equipment necessary to
accomplish a process or manufacture.
In itemizing the process unit, the inspector also
has a choice. He may either list each piece of equip-
ment in the process as a separate item, or he may list
the entire process as one item, including in the descrip-
tion a list of the individual equipment units making
up the process. (An entire process unit can be listed
as one item as long as it does not involve more than
one permit unit.) Whichever he does, the inspector
must indicate in some way the relationship of the
equipment in the process. Generally, the key words
are " process (or system) consisting of the
following: etc." Sometimes this
grouping may also be accomplished by bracketing all
of the items or units of equipment. The more complex
the process, the more the description will require sup-
port and clarification from an attached flow chart.
(a) Order of Equipment Listing
When breaking equipment combinations down for
listing, it is best to list the control equipment first, then
the basic equipment in a consecutive or logical order,
and to cross-reference the item numbers as in Items 1
through 3 on Figure XIV-3 of the Equipment List. The
order of listing is guided by the logic of the most prom-
inent situation encountered, i.e., by production se-
quence, relative floor position or plant location number,
order of size or capacity, etc.
(4) Location of Equipment, Plant Layout and
Flow Charts
The location of the equipment should be indi-
cated under the "Approximate Location on Premises"
column of the Equipment List. The approximate loca-
tion can be merely designated according to the position
of equipment relative to the front of the plant and the
direction north, i.e., as it would appear on a plot plan.
Designations may be made as follows: "Rear",
"Front", and "Rear-west", etc. In large complex plants
with many kinds of sources of air pollution, these
descriptions may not be sufficient. An equipment
location drawing (plot plan) should be prepared on
the cross-hatch backing of the Equipment List (see
Figure XIV-3.1. The plot plan should show clearly the
general outline of the plant floor, the intersecting
streets around the plant, the departmental organiza-
tion, and the location of each specific piece of basic and
control equipment. Where the industrial plant has
multiple stories and the equipment is interconnected
by means of blower and duct systems, each floor plan
should be shown.
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252
Air Pollution Control Field Operations
In the case of complicated process units, a flow
chart showing the flow of materials through a produc-
tion sequence should be prepared for clarification. In
general, both the process flow drawings and the plant
layout are carefully drawn sketches, rather than
accurately scaled mechanical engineering drawings.
These drawings are included to supplement the data
on the front side of the Equipment List, and should be
sufficient to identify equipment for inventory purposes
and to indicate the type of contaminants emitted and
the possible air pollution potentials.
Flow diagrams and plot plans are of particular
importance in accounting for all equipment in a pro-
duction sequence which otherwise may be overlooked.
They are of value in showing the potentiality of an
existing production system for growth or change as a
result of addition, change or replacement of individual
equipment units. They also show the capacity for such
systems to accommodate increased production quotas.
Comparison of existing conditions at the time of an
inventory reinspection with the flow chart and plot
plans made on a previous inventory inspection show.s
exactly how the process was changed.
Also, the process or box-flow system is important
in providing inspectors and all other personnel who
may examine the Equipment List with important in-
formation regarding the industry in question. Inven-
tory records serve as a cumulative file of technical
information. For example, the inspector conducting
the initial inspection gathers basic facts and informa-
tion about the process. The next inspector, by studying
the Equipment List, is armed with important informa-
tion, enabling him to gather further information and
to augment the Inventory Dossier File.
A more detailed description of process flow pro-
cedures is described in the Refinery and Petrochemical
Inventory in this chapter. (See Figure XIV-10.)
c. Permit Status of Each Equipment Unit
The Permit Status is the status of equipment made
with respect to compliance with the permit sections of
the entire A.P.C.D. authority. The essentials of this
authority in the State Health and Safety Code are
quoted here in part.
24263. (Amended—effective 9-11-57.) The Air Pollu-
tion Control Board may require by regulation that before
anj- person either builds, erects, alters, replaces, operates,
sells, rents, or uses any article, machine, equipment, or
other contrivance specified by such regulation the use of
which may cause the issuance of air contaminants, such
person shall obtain a permit to do so from the Air Pollution
Control Officer.
Insofar as the regulations do not grant an automatic
permit for the operation or use of any article, machine,
equipment or contrivance in existence upon the effective
date of such regulations, a permit shall not be required
without first affording the owner, operator, or user thereof
a reasonable time within which to apply for such permit,
and to furnish the Air Pollution Control Officer the in-
formation required pursuant to Section 24269.
24269. The air pollution control officer at any time
may require from an applicant for, or holder of any permit
provided for by the regulations of the air pollution control
board, such information, analyses, plans, or specifications as
will disclose the nature, extent, quantity, or degree of air
contaminants which are or may be discharged by such
source.
24204. The air pollution control board may require
that before the air pollution control officer issues a permit
to build, erect, alter, or replace any equipment, that the
plans and specifications show, and that the permit issued by
the air pollution control officer require, that such building,
erection, alteration, or replacement will be done in such a
manner, and that such approved equipment be used as the
air pollution control board finds will eliminate or reduce
the discharge of any air contaminants.
(1) When Permits Are Required
The Rules and Regulations were first approved
on February 1, 1948, and have since been periodically
amended. Rules 10 through 13 which follow should be
studied carefully by the inspector as they are basic to
any action he will take in the field.
Rule 10 (Amended 12-4-58) PERMITS REQUIRED.
a. Authority to Construct. (Amended 12-4-58) Any per-
son building, erecting, altering or replacing on or after
February 1, 1948, any article, machine, equipment or other
contrivance, the use of which may cause the issuance of air
contaminants or the use of which may eliminate or reduce
or control the issuance of air contaminants, shall first obtain
authorization for such construction from the Air Pollution
Control Officer. An authority to construct shall remain in
effect until the permit to operate the equipment for which
the application was filed is granted or denied or the appli-
cation is canceled.
b. Permit to Operate. (Amended 11-16-54.) Before any
article, machine, equipment or other contrivance described
in Rule 10(a) may be operated or used, a written permit
shall be obtained from the Air Pollution Control Officer.
No permit to operate or use shall be granted either by the
Air Pollution Control Officer or the Hearing Board for any
article, machine, equipment or contrivance described in
Rule 10(a), constructed or installed without authorization
as required by Rule 10(a), until the information required
is presented to the Air Pollution Control Officer and such
article, machine, equipment or contrivance is altered, if
necessary, and made to conform to the standards set forth
in Rule 20 and elsewhere in these Rules and Regulations.
Subparagraph "c" of Rule 10 requires that per-
mits be displayed adjacent to operating equipment,
while "d" prohibits alteration or counterfeiting of
permits. Subparagraph "f" of this Rule requires a per-
mit to sell or rent incinerators.
Permits are not transferable,according to Rule 12.
RULE 12. (Amended 1-16-58) TRANSFER. An author-
ity to construct, permit to operate or permit to sell or rent
shall not be transferable, whether by operation of law or
otherwise, whether from one location to another, from one
piece of equipment to another, or from one person to
another.
All equipment owned and operated prior to Feb-
ruary 1, 1948, has blanket permits. This is sometimes
known as the "Grandfather Clause".
RULE 13. BLANKET PERMITS. Every person who,
at any time between December 1, 1947, and the effective
date of Rule 10, operated or used any article, machine,
equipment, or other contrivance for the operation and use
of which these rules require a permit, and so operated or
used such article, machine, equipment or other contrivance
in compliance with all laws, statutes, and ordinances appli-
cable thereto, is hereby by these rules granted a permit to
continue or resume such operation or use.
Thus all equipment capable of emitting air con-
taminants, or capable of reducing or controlling air
contaminants, constructed after February 1, 1948,
requires an Authority to Construct and a Permit to
Operate from the Air Pollution Control District. All
equipment constructed and operated prior to that date
-------
Registering the Sources of Air Pollution
253
is automatically granted a permit. Air contaminants
are defined by Section 24208 of the Health and Safety
Code as smoke, charred paper, dust, soot, grime, car-
bon, noxious acids, fumes, gases, odors, particulate
matter or other air contaminants.
(2) Exceptions to the Permit Requirements
In determining permit status, the inspector should
ascertain whether the equipment in question is legally
excepted by any provisions of the State Health and
Safety Code or the Rules and Regulations of the Air
Pollution Control District, or is exempt under current
Administrative Directive.
The legal exceptions applied to the permit require-
ments are contained in State Code Sections 24251,
24254, 24265 and District Rules 11 and 13.
Although District Rule 11 and State Code Section
24265 were essentially identical for enforcement pur-
poses prior to March 28, 1957, the exceptions contained
in Section 24265 were not included in Rule 11 until
November 16, 1954. On March 28, 1957, Rule 11 was
amended to include additional exemptions. Both Sec-
tions 24265 and Rule 11 are quoted here for compre-
hensiveness.
SECTION 24254—Although permits are required from
governmental agencies, this section states that there is no
liability for their officers or employees for failure to apply
for permits to operate, nor for violations. Civil actions,
however, can be brought against governmental agencies in
the name of the people of the State of California to force
compliance with permit requirements.
24265. A permit shall not be required for:
(a) (Amended—effective 9-11-57.) Any vehicle as de-
fined in the Vehicle Code.
(b) Any structure designed for and used exclusively as
a dwelling for not more than four families.
(c) An incinerator used exclusively in connection with
such a structure.
(d) (Amended—effective 9-11-57.) Barbecue equip-
ment which is not used for commercial purposes.
(e) (Amended—effective 9-11-57.) Equipment de-
scribed in Section 24251; except that the Air Pollution
Control Board of any county, any part of which lies south
of the Sixth Standard Parallel South, Mount Diablo Base
and Meridian, may at its discretion require operations
described in Section 24251 (b) to obtain permits. The board
may promulgate such rules and regulations, as herein pro-
vided for, but in no event shall a permit be denied an
operator, operating orchard or citrus grove heaters, if such
heaters produce unconsumed solid carbonaceous matter at
the rate of one (1) gram per minute, or less.
(f) Repairs or maintenance not involving structural
changes to any equipment for which a permit has been
granted.
As used in this section, maintenance does not include
operation.
(Effective 9-11-57.) This section does not limit the
powers granted to the Air Pollution Control Board by Sec-
tion 24260 and Section 24262 of this code.
RULE 11. (Amended 12-4-58) EXEMPTIONS. An
authority to construct or a permit to operate shall not be
required for:
a. Vehicles as defined by the Vehicle Code of the State
of California.
b. Vehicles used to transport passengers or freight.
c. Equipment utilized exclusively in connection with
any structure, which structure is designed for and used
exclusively as a dwelling for not more than four families.
d. The following equipment:
1. Comfort air conditioning or comfort ventilating
systems which are not designed to remove air
contaminants generated by or released from spe-
cific units of equipment.
2. Cold storage refrigeration equipment.
3. Internal combustion engines.
4. Vacuum producing devices in laboratory opera-
tions and vacuum producing devices which do not
remove or convey air contaminants from another
source.
5. Water cooling towers and water cooling ponds
not used for evaporative cooling of process water
or not used for evaporative cooling of water from
barometric jets or from barometric condensers.
6. Equipment used exclusively for steam cleaning.
7. Grain, metal, mineral or wood processes used ex-
clusively for extruding.
8. Porcelain enameling furnaces or porcelain enam-
eling drying ovens.
9. Presses used for the curing of rubber products
and plastic products.
10. Equipment used exclusively for space heating,
other than boilers.
11. Unheated solvent dispensing containers, unheated
solvent rinsing containers or unheated dip tanks
of 100 gallons capacity or less.
12. Blacksmith forges.
13. Equipment used for hydraulic or hydrostatic
testing.
14. All printing presses other than rotogravure print-
ing presses.
e. The following equipment or any exhaust system or
collector serving exclusively such equipment:
1. Blast cleaning equipment using a suspension of
abrasive in water.
2. Bakery ovens where the products are edible and
intended for human consumption.
3. Kilns used for firing ceramic ware, heated exclu-
sively by natural gas or liquefied petroleum gas,
any combination thereof or heated electrically.
4. Laboratory equipment used exclusively for chem-
ical or physical analyses.
5. Equipment for inspection of metal products.
6. Confection cookers where the products are edible
and intended for human consumption.
7. Drop hammers or hydraulic presses used for
forging or metal working.
8. Die casting machines.
9. Atmosphere generators used in connection with
metal heat treating processes.
10. Photographic process equipment by which an
image is reproduced upon material sensitized to
radiant energy.
11. Brazing, soldering or welding equipment.
12. Equipment used exclusively for the sintering of
glass or metals.
13. Equipment used for carving, cutting, routing,
turning, drilling, machining, sawing, surface
grinding, sanding, buffing or polishing of ceramic
artwork, leather, metals, plastics or rubber.
14. Equipment used for drilling, carving, cutting,
routing, turning, sawing, grinding, shredding,
planing or sanding of wood or wood products.
15. Equipment used for surface preparation of metals
by use of aqueous solutions.
16. Equipment used for washing or drying products
fabricated from metal or glass, provided that no
volatile organic materials are used in the process
and that no oil or solid fuel is burned.
17. Laundry dryers, extractors or tumblers used for
fabrics cleaned with only water solutions of
bleach or detergents.
18. Containers, reservoirs, or tanks used exclusively
for electrolytic plating with, or electrolytic pol-
ishing of, or electrolytic stripping of the following
metals: Brass, Bronze, Cadmium, Copper, Iron,
Lead, Nickel, Tin, Zinc, Precious Metals.
19. Foundry sand mold forming equipment to which
no heat is applied.
20. Ovens used exclusively for curing potting materi-
als or castings made with epoxy resins.
-------
254
Air Pollution Control Field Operations
{. Boilers, water heaters or steam generators that are
fired exclusively with natural gas or liquefied petroleum
gas or any combination thereof.
g. Natural draft hoods, natural draft stacks or natural
draft ventilators.
h. Containers, reservoirs or tanks used exclusively for:
1. Dipping operations for coating objects with oils,
waxes or greases.
2. Dipping operations for applying coatings of nat-
ural or synthetic resins which contain no organic
solvents.
3. Storage of liquefied gases.
4. Heat treatment quench operations.
5. Unheated storage of organic materials with an
initial boiling point of 300°F. or greater.
6. The storage of fuel oils with a gravity of 25° API
or lower.
7. The storage of lubricating oils.
8. The storage of fuel oils with a gravity of 40°
API or lower and having a capacity of 10,000
gallons or less.
9. The storage of organic solvents, diluents or thin-
ners and having a capacity of 6,000 gallons or less.
10. The storage of liquid soaps, liquid detergents,
tallow, or vegetable oils, waxes or wax emulsions.
11. The storage of asphalt.
i. Furnaces for heat treating glass or metals, the use
of which does not involve molten materials.
j. Crucible furnaces, pot furnaces or induction furnaces,
with a capacity of 1000 pounds or less each, in which no
sweating or distilling is conducted and from which only the
following metals are poured or in which only the following
metals are held in a molten state:
1. Aluminum or any alloy containing over 50 per
cent aluminum.
2. Magnesium or any alloy containing over 50 per
cent magnesium.
3. Lead or any alloy containing over 50 per cent
lead.
4. Tin or any alloy containing over 50 per cent tin.
5. Zinc or any alloy containing over 50 per cent zinc.
6. Copper.
k. Vacuum cleaning systems used exclusively for in-
dustrial, commercial or residential housekeeping purposes.
1. Structural changes which cannot change the quality,
nature or quantity of air contaminant emissions.
m. Repairs or maintenance not involving structural
changes to any equipment for which a permit has been
granted.
n. Identical replacement in whole or in part of any
article, machine, equipment or other contrivance where a
permit to operate had previously been granted for such
equipment under Rule 10.
These exemptions do not apply to any article, machine,
equipment, contrivance or their exhaust systems, the dis-
charge from which contains airborne radioactive material
and which is emitted into the atmosphere in concentrations
above the natural radioactive background concentration in
air. "Airborne radioactive material" means any radioactive
material dispersed in the air in the form of dusts, fumes,
smoke, mists, liquids, vapors or gases.
(3) Determining Permit Status
As will be recalled from Chapter 13, the factors
affecting the permit status are (1) new construction of
equipment, (2) change of ownership, (3) change in
address-location, and (4) alteration of equipment. The
Equipment List is so constructed as to provide refer-
ence data which will enable inspectors on subsequent
inventory reinspections to determine whether or not
the permit status has changed. For number "1" above,
any equipment found in the plant capable of air pollu-
tion, but not listed on the previous Equipment List,
will require a permit. For #2 above, change of owner-
ship, any change in the ownership as indicated in the
heading of the Equipment List affects the Permit
Status of all the equipment in the plant. A new Equip-
ment List is then required for the new owner or lessee1,
who is also required to apply for permits for all of the
equipment capable of air pollution in the plant (Rule
12, permits are non-transferable). The Equipment List
of the older, defunct company is stricken from the files
by means of an Activity Status Report, Similarly a
change in address location, #3 above, also requires that
applications be made for all of the equipment in the
plant. In the case of #4, above, alteration is frequently
determined either by a change which has taken place
in the equipment description, or the flow chart, or by
changes noted with reference to engineering applica-
tions in the Permit File.
The pen nit status is noted on the Equipment List
as follows:
The date of installation of each Equipment Unit is
recorded in the "Date Inst." column. This date shows
whether equipment may be covered by Rule 13, or
whether a permit has been issued or is required under
Rule 10, if the equipment is not exempted by Rule 11.
In the "A.P.C.D. Permit Status Column", the per-
mit status is noted even if the equipment is not being
used, or is exempt under any of the provisions de-
scribed above. If a permit has been granted, the permit
number is written in this column. If a permit has not
been granted, then the following are the proper entries
to be made in this column.
1. RULE 13 —equipment installed prior to February 1,
1948.
2. DENIED —(shown in red) equipment for which a
denial has been issued.
3. NON-USE—equipment requiring a permit but exempt
by virtue of voluntary non-use.
4. RULE 11 —indicate subparagraph applicable to this
legal exemption. (If the equipment was
operated under Rule 13 prior to the effec-
tive date of Rule 11 exemption to both Rule
11 and Rule 13 is indicated.)
5. BANNED—Use of incinerator banned by reason of
Rule 58. (If one is still on premises.)
6. INCON. —An inconsequential source of pollution
potential.
When the inspector is informed of the final dispo-
sition of the equipment involved in pending permits,
originally designated by the inspector under "A/C"
or "P/R", the permit number or the fact of denial is
recorded in the A.P.C.D. Permit Status column.
The copy of the permit is kept in the manila envelope.
d. Coded Equipment Data
After the main portions of the Equipment List
have been completed, the coded control and equipment
data located in a corner of the Equipment List (see
Figure XIV-3), is completed.
The M.R. NO. (Master Record Number) in the
upper right-hand corner refers to the primary and
secondary classification number of the activity de-
scribed under "Nature of Rusiness" in the heading.
In the upper left-hand corner, "Types of Con-
taminants", the inspector writes in the primary types
-------
Registering the Sources of Air Pollution
255
of contaminants, known or suspected, which may
possibly be emitted by any of the equipment units con-
tained in the activity. An "X" is inserted in the box
opposite the code representing the contaminant. The
code is as follows:
A—Smoke and Combustion Products.
B—Liquid Particulates,e.g., aerosol mists and droplets.
C—Solid Participates, e.g., dust and aerosols.
D—Gases and Vapors.
E—Sulphur Compounds.
F—Odors.
G—Radiation Derivatives.
In the vertical Control column, the inspector
records for each item of Equipment Unit the code for
the appropriate control device. If the basic equipment
is not equipped with any air pollution control devices,
an "X"' is placed in the appropriate space in the col-
umn. If the basic equipment has control equipment,
but is listed separately, a "V" is placed in the CON-
TROL column. The control coding is as follows:
1—Settling chambers.
2—Dry filters, e.g., baghouse, etc.
3—Dry inertial separators,e.g., cyclones, etc.
4—Water scrubbers, e.g., spray chambers, wet cyclones, etc.
5—Electric precipitators.
6—Afterburners, e.g., flame, catalytic, flares, fuel gas sys-
tems, etc.
7—Absorbers, chambers or towers packed or baffled, etc.
8—Adsorbers, activated charcoal, silica gel, etc.
9—Condensers and/or compressors.
10—Surface controls, including vapor controls.
The BASIC equipment column is for use by the
Engineering Division to convert the activity file into
a count of individual equipment units.
E. Preparation of Refinery and Petrochemical
Inventories
In the Enforcement Division of the A.P.C.D.,
inventories of refineries and allied activities are not
recorded on the standard Equipment List. For such
industries it is necessary to prepare technical reports
of processes in terms of both written and graphic pre-
sentation to describe and determine the air pollution
potentials of the process units being inspected. Special
inventory forms for various types of equipment, opera-
tions, processes, or plants are helpful at inspections to
insure coverage of specific points. This procedure is
required for these reasons:
1. Because process vessels are grouped in interde-
pendent relationships in refineries and allied
plants, attempts to individually itemize pieces of
equipment usually lead to confusion and dis-
orientation.
2. Air pollution potentials can often be determined
from an inventory of functions of process vessels,
rather than itemization of equipment units. Pro-
cess inventories, therefore, may require field
surveys of product flows, throughput capacities,
and emission factors.
3. Refinery and chemical plant inventories thus cat-
egorize, itemize, and present data as will directly
determine not only compliance with Rule 10, but
compliance with such equipment-regulation rules
as 56, 59, 61, and 62. The Equipment List de-
scribed previously is used only for compilation of
data to show compliance with Rule 10.
To collect such information, a special inventory
system is adapted to each refinery. In order to ade-
quately cover each of the multiple operations of a
refinery or large petrochemical plant, a system of unit-
ization is used in which the plant area is subdivided
into process units. Those units with the greatest air
pollution potentials are given added emphasis by
assigning higher rates of inspection. A brief listing of
some of these process units is given in Chapters 2 and
6. A diagram of all such processes as they are typi-
cally integrated in a refinery is shown in Figure
XIV-6.
The inventory records of each refinery or petro-
chemical plant consist of a group of file folders, each
folder dealing with one of the process units. One or
more process units may constitute what has been de-
fined as the Source Activity. Hence, one inspection or
inventory is made of one or more process units pro-
grammed as a unit for reirispection. At the head of
each refinery file group is a numbered index of all
distinct source activities within the refinery. Each
number is cross-referenced to the location of the folder
containing the appropriate source activity.
1. General Inspection Procedures
Due to the operational complexity of petroleum
refineries, petrochemical and chemical plants and
other allied activities, a degree of specialization, train-
ing, and considerable experience is required on the
part of an effective refinery inspector. This manual
cannot possibly present the extensive technical rami-
fications of the air pollution problems in these indus-
tries. For those engaged in refinery enforcement, the
following represent a few of the references which may
be used as guides:
1. Los Angeles County Air Pollution Control District, Enforce-
ment Division, Refinery Inspection and Processing Manual,
as well as other pertinent District technical publications.
2. Any reliable current petroleum reference book in the field,
such as Bell's American Petroleum Refining, or Nelson's
Petroleum Refinery Engineering, or Bureau of Naval Per-
sonnel's (U.S. Navy) Fundamentals of Petroleum.
3. Petroleum trade journals such as the Oil and Gas Journal,
The Petroleum Refiner, Petroleum World (Western), or any
other suitable publication which chronicles current develop-
ments in this field.
Most inspections of process units in refineries are
arranged in advance, as a part of the systematic pro-
gramming of inspections. Such arrangements are nec-
essary in order to assure that the process unit is in
operation, that the appointed specialist in the plant is
available, and for safety precautions and guidance.
The inventory data are not maintained within the
inspector's vehicle as in the case of the Manila Envel-
ope and Equipment List File. When the process unit
is ready for reinspection, the inspector checks out the
field file and reviews the previous reports, and then
proceeds to the inspection.
-------
OS
FUEL G*S
O
3
o
3
<*•*.
a,
2
§'
APCD 1957 J.R.MCOMNELL
Figure XIV - 6. Refinery flow sheet.
-------
Registering the Sources of Air Pollution
257
Ihe objectives of the air pollution inspector are
not only to determine which elements of the operation
are affected by the Rules and Regulations but to deter-
mine as well the degree of compliance to them. His
inspection procedures are adapted to the specific air
pollution requirements governing the type of unit
being inspected.
Safety is a prime consideration and all refineries
have standard safety procedures for employees and
visitors. Accordingly, the inspector is equipped with
a hard hat, goggles, safety flash light; H2S indicator!;
any other safety device the specific type of unit being
inspected calls for.
The inspector is accompanied to the unit or units
to be inspected, by the air pollution representative
within the plant or by such other informed refinery
personnel as he might indicate.
General unit or plant compliance is determined
through sensory evidence, examination of current and
past records, plans, recorder charts and gauges, obtain-
ing samples for laboratory analysis, on-the-spot testing
or calling for a mobile field test unit for more extensive
determination of suspected sources of non-compliance.
The lines of approach**) which generally yield the
most effective results are:
(1). Investigation of the methods used and the
general efficiency achieved in controlling the release
of pollutants to the atmosphere from process (basic
equipment} units.
The inspector determines plant procedures em-
ployed during start-ups, shut-downs and equipment
malfunctions, to control or eliminate the discharge to
atmosphere of noxious or malodorous emissions
through the purging or depressuring of tanks or
vessels. These include the installation of special in-
strumentation, e.g., high level or high pressure alarms,
liquid knock-out drums on fuel gas systems, pressure
relief or manually controlled discharge from process
equipment to blow-down vessels of either variable or
fixed capacity which are served by vapor recovery
compressors, flare systems or both, and, where emis-
sions are a factor, fixed roof tankage tie-in to properly
sized vapor recovery or fume disposal systems. Loading
racks should be tied to vapor control systems when the
product being loaded has a significant vapor pressure.
(2) Determination of quality of maintenance on
such points as manual, pressure relief and pressure
vacuum valves, flanges, pump glands, gauge hatches,
etc., which may be a source of leakage.
Such emissions are primarily recognized by sens-
ory evidence and their detection depends on the ability
of the inspector to recognize the odor and to trace it to
its point of origin.
The inspector must also note any air turbulence
caused by light hydrocarbon leakage, frosting of a
valve or pump gland caused by light hydrocarbon
evaporation, liquid leakage, local area discolorations
caused by vapor condensate, visible emissions or
changes in flow (surging) of an emission, extinguished
flare pilot lights or detection of audible gas leaks.
These may disclose a violation or a potentially critical
situation that could be corrected in time.
(3) Procedures used in controlling air contami-
nants and odors resulting from disposal of process
waste effluents:
The refinery inspector should thoroughly survey
the sour water, waste water, sour gas, spent caustic and
acid sludge gathering and processing and fume disposal
systems.
While in a modern refinery most of these streams
are "treated", from an air pollution standpoint, their
extremely noxious and malodorous characteristics
make even the most isolated uncontrolled streams a
potential source of air pollution problems.
Wherever possible, the inspector should point out
conditions having a high degree of air pollution poten-
tial so that the refinery technical staff may have the
opportunity to assess the problem and arrive at a
solution that will keep the source in question within
the bounds of the regulations governing it. More ef-
fective use of existing control equipment is achieved
by extending its service to as many uncontrolled
sources as is possible without overloading its capacity.
The inspector may find isolated streams of sour
(H2S laden) gas fuel untreated for H2S removal and
recovery, sour water discharged to open drains with
live steam which has not been first deodorized by
processing in sour water oxidation or H2S stripping
facilities.
Odors and hydrocarbons emitted to the atmos-
phere from oil-water separators may be limited by
using a floating roof or an air-tight fixed roof vented
to a vapor recovery system on primary compartments,
as prescribed by the A.P.C.D. Rules and Regulations.
Malodorous or noxious acid sludge, stored in un-
controlled tanks which release fumes and odors due to
breathing and filling losses, or loaded into tank cars
and trucks with similar results, may be treated by
caustic scrubbing. Where several forms of control are
available, the adoption of the most effective in reducing
release of contaminants to the atmosphere will gener-
ally meet with the results which will best assure a
complaint-free community.
Disposal of malodorous fumes rich in H2S or mer-
captans, such as from the spent caustic regeneration
and handling operation, formerly accomplished
through incineration which released S02 and other
fumes to the atmosphere, has been limited through
regulations by the A.P.C.D. and is now treated for
recovery as H2S or oxidized to non-noxious form.
Similarly, S02 and S03 discharge to the atmosphere in
the flue gas resulting from burning of high sulfur fuel
oil has been limited by the A.P.C.D. Rules and Regu-
lations.
(4) Investigation of efficiency, operating load
and maintenance of control equipment:
-------
258
Air Pollution Control Field Operations
The effective operation of various control systems
in a refinery is of basic importance to efficient air
pollution control. Such equipment as cyclones, electro-
static precipitators, vapor recovery compressors, pres-
sure vent valves, regulators and headers, variable
capacity gas holder diaphragms, tank truck loading
arm vapor closures, floating roof vapor seals, fume and
odor scrubbers, H2S absorbers and sulfur recovery
plants are subject to severe corrosion and other de-
structive forces which reduce air pollution control
efficiency. In addition, a change in feed or feed rates
due to increased or altered product requirements at
process units or tankage, may also result in over-
loaded or otherwise upset operating conditions at its
air pollution control system.
In the case of a vapor recovery system serving
tankage, peak loads develop in the morning hours
when the heat of the sun produces maximum volumes
of hydrocarbon vapors in the space above the liquid.
Uneven loading schedules at tank truck loading facil-
ities tend to create a similar situation.
Since a gradual reduction in control efficiency
does not always alter the effective operation of the
process unit, it may not be noted by operating person-
nel until a major breakdown occurs accompanied by a
serious air pollution situation such as a public nui-
sance. It is therefore essential for adequate air pollu-
tion control that added stress be placed on such areas
RULE 62 SUHVEY
BOILER DATA WD RECORD QF OIL FUEL USED
A and B R»rHr"nf Company
ADDRESS OF PREMISES 10B5Q S. I
PRESENT LEGAL OWNER Above Co.
NATURE OF BUSINESS Rendering
RESPONSIBLE PERSON M. Burns
OIBPOBATI™ V PARTNERSHIP,
TITLE Plant Superintendent.
^INDIVIDUAL OWNER GOVERNMENT AGENC
LIST ON BACK OF SHEET OIL BURNING EQUIPMENT OTHER THAN BOILERS
BOILERSilDENTIFV EACH)
( HER)
STACK <»T .«. n,,M OF E.CHi
TV
GRADE OF OIL USED
USED PER YR IN DOILERS
R.TIOH (v.s «0l
KS5"Sl
"!&'!'
F. T,
SS Ibs.
100 H.P.
Fiti28.i
Combo.
Air
None
Natural
None
100'H. 3'D.
Gas & oil
P.S. 200
90
100 bble.
Yes
feJt'Si"
"IE.''!'
F. T.
5% Its.
100 H.P.
F re
Oil only
Air
None
Natural
None
Common stack
Oil
P.S- 200
200
400 bbls.
Yes
DATE OF INSPECTION 7 -6
INSPECTOR - R- J°'
Figure XIV - 7. Front side of Boiler Data and Record of Oil
Fuel Used Sheet used to survey compliance with A.P.C.D. Rule
62.
by both refinery and A.P.C.D. as regards the frequency
of inspection.
This type of inspection is sometimes more com-
plex. Sensory evidence such as visible discharge and
odors may be disclosed by thorough physical inspection
and may be sufficient in some situations to determine
non-compliance or abnormal operation (breakdown),
i.e., Ringelmann number readings, excess hydrocarbon
vapor discharge from vapor controlled tankage, etc.
However, in other cases, sensory evidence may only
be a preliminary or corroborating step to the investi-
gation, either because the regulations affected call for
evidence not obtainable in this manner, e.g., percentage
sulfur in the fuel oil, H2S grain loading in gaseous
products burned and its btu value, weight of particu-
late discharge, concentration of S02 in discharge of flue
gas, etc., or because the control equipment does not
discharge a waste effluent directly to the atmosphere.
In such cases the inspector must either rely on data
indicating temperature, density, pressure, vacuum or
throughput recorded on gauges, continuous recorders,
high level or density alarms, voltmeters and ammeters
or tests made of samples taken by him or a test team
using explosimeters, squeeze-bulb gas analyzers, tut-
weilers or impingers, etc., from test points selected by
the inspector in earlier investigations.
Another aid to the inspector is the data submitted
by the refinery and the evaluation of that data by the
OTHER EQUIPMENT USING OIL FUEL
ITEM
*.. TOT
/
/
/
/
./
/
y
V
*/
/
/
/
1,005 1PO 1.195 ,,,,v 1,120
950 UAV 980 AIIR 1,180
nr-T 9
wnu 9
7
90
85
95
16'40M343
HEV. 5-80
Figure XIV - 8. Back .side of Boiler Data and Record of Oil Fuel
Used Sheet used to survey compliance with A.P.C.D. Rule 62.
-------
Registering the Sources of Air Pollution
259
A.P.L.D. in the existing application for permit to
operate the equipment.
The permit status of the equipment should be
investigated to determine any changes in process or
equipment that might invalidate the existing permit.
Inspection should also determine compliance to permit
or variance conditions.
2. Preparation of Refinery and Petrochemical
Inventories
a. Activity Status Reports, Plot Plans, and Flow
Charts. The refinery inspector reports all inventory
and inspection findings on an Activity Status Report,
supported by a flow diagram and plot plan of the
process. These reports and diagrams include the fol-
lowing:
1. A general description of the process including an analysis
of its purpose and function in the order of the flow or
processing sequence. Generally, the analysis traces the
flow of materials (feed stocks, etc.) from introduction
through various sidestreams to final effluents.
2. A list of the various pieces of equipment contained in the
process unit and their function, incorporated in the above
description unless they are presented to better advantage
on the process flow diagram or plot plan.
3. The air pollution potentials of the process or the equipment
should include an analysis of any important problems. This
discussion should include, if possible, an actual estimate of
the contaminants emitted and the approximate quantities,
chemical designations, odor quality and intensity, opacities,
or physiological effects, as well as the potential hazards of
the stocks or products released should equipment failure
occur. Such equipment breakdowns are reported to the Dis-
trict by industry. (See Chapters 11 and 12 for sampling
procedures, and Table XIV-2.)
4. Throughput of volatile materials and estimates of emissions
from known sources. This may be determined from results
of "material balances," i.e., estimates of sulfur derivatives
lost as calculated from the differences between input and
final output.
5. Results of any tests made of effluents such as industrial
wastes or air pollutants or samples taken of fuels or other
materials.
6. A process flow chart and plot plan, if an adequate one is
not supplied by the refinery representative, which can be
used for reference and verification on followup inspections
and which indicate the flow rate of materials, pressures,
temperatures, etc., in process vessels and lines, where nec-
essary, to estimate air pollution potentials and to locate
points of emission.
Flow charts and plot plans are systematically
drawn according to conventional engineering rules. All
pertinent liquid or gas feed lines are shown on the left-
hand side of the flow chart, and all gas or liquid efflu-
ents on the right-hand side, if the flow lends itself to
such a structure. In the case of refineries, overhead
discharge and drainage from columns or vessels are
generally shown by vectors indicating method of dis-
posal. All features not essential to the understanding
of the air pollution problem are omitted.
Flow lines are drawn in straight lines and
at right angles, and are broken when it is necessary
for a continuous flow line to cross another. The
flow lines are clearly labeled and vectored as to direc-
tion and content. For example: "Refinery Gas in,"
"To Fuel Gas System," "To Oil-Water Separator," etc.
The process lines indicate whether the flow originated
in, or entered at the top, side, or bottom of columns or
equipment. Equipment or columns should be clearly
labeled as to function unless they can be depicted by
symbols (such as heat exchangers, condensers, etc.,
and by plant number as shown in Figure XIV-11).
It is of utmost importance in a flow diagram to clearly
illustrate all sources of air pollution, whether they be
stacks, flares, or pressure relief valves, etc., and to
identify the problem areas and the contaminants which
might be emitted. Process vessel and line operating
conditions recorded on pressure and temperature
gauges, manometers, continuous recorders, and relief
valve pressure settings, should be indicated wherever
pertinent.
A sample of an Activity Status Report covering a
sour water treatment and disposal plant, and accom-
panying flow charts, is shown in Figures XIV-9 and
XIV-10. To assist the inspector both in evaluating and
illustrating the process, symbols may be employed in
chart preparation as shown in Figure XIV-11.
b. Plant Card. Plant ownership data, equivalent
to that supplied on the heading of the Equipment List,
is recorded separately on a Plant Card. Such data need
not accompany every inventory form used in a re-
finery and petrochemical plant, since there is seldom
a change of ownership in this industry. It is most
important to know who the responsible officials are
and how they can be quickly contacted either by
a field inspector or by telephone. Where accurate field
data exist in the inventory files, it is possible to make
a preliminary investigation of refinery problems by
telephone.
c. Refinery Check Sheet. To insure that the other
refineries in the area continue to receive surveillance
when the inspector is busy at one refinery, the areas in
which the refineries are situated are sectioned and
carefully checked by patrols using a Refinery Check
Sheet. On this sheet each refinery to be checked is
listed. The time of observation is noted, along with
any pertinent remarks concerning significant observa-
tions of each refinery. Such remarks include notations
of odor, visible emissions, wind direction, etc. If longer
reports are required for any given plant, the inspector
writes on the reverse of this form, or an Inspector's
Green Field Report, or an Activity Status Field Report.
d. Bulk Plant Data: Rules 56, 59 and 61. This
inventory form (Figure XIV-13) is used to record
data obtained from inspection of loading racks, storage
tanks, pumps, vapor controls, and associated equipment
located at bulk plants. Bulk plants are used to store
and distribute various petroleum products such as
kerosine, gasoline, diesel oil, solvents, lube oil, etc.,
and may be found at airport facilities, distributing
centers, marine terminals, etc. Because these plants
contain equipment which may be subject to Rules 56,
59, and 61, in addition to Rule 10, the form is used to
emphasize compliance of equipment and operation
with the requirements of these rules. This Bulk Plant
-------
260
Air Pollution Control Field Operations
ACTIVITY STATUS REPORT
M.R.No. | 01
FIRM NAME: Sunrise Oil Company, Inc., Unit II
ADDRESS OF PREMISES; 1325 Court Street
RESPONSIBLE PERSON CONTACTED: J. R. Hickeson
NATURE OF B1SINFSS: Petroleum refining
SECTOR: 13
CITY: Onvx
TITIF:Plant Engineer
ASS I (MED INSPECT I ON CH NEW ACT IVITY CD CHANGE OF STATUSD
DESCRIPTION - GENERAL USAGE • NAME OF EQUIPMENT SYSTEM OR PROCESS
INSPECTED: Sour water oxidizing unit - Unit II
INSPECTOR'S NAVE: J. R. Hardy
riATF: 10-15-59
INSPECTOR'S CONCLUSIONS AND RECOMMENDATIONS I The odors detected at this
time were not great enough to result in a public nuisance. This unit
remains, however, one of the greatest potential sources of odor problems
in this refinery since it comprises the processing area for sour waste
water containing malodorous components formed during the cracking
operation.
Modifications made for compliance with Rule 62 have reduced the
possibility of excessive S02 emissions from the vacuum heater. Since the
materials processed are both highly malodorous and corrosive, the
present inspection frequency of three times per year should be continued
to insure adequate maintenance.'
INSPECTOR'S FINDINGS: The purpose of this unit is to deodorize the
sour water pumped from the accumulators at the crude, thermal, and cat-
alytic cracking units. This consists of the following equipment:
(1) a 10,000 barrel cone-roof tank, (2) a neutralizing column tower,
AIR POLLUTION CONTROL DISTRICT COUNTY OF LOS ANGELES PAGE 1 OF 4
(3) a waste-water stripper, (4) an aeration column,. (5) a waste-water
cooler, (6) a sour water degasifier drum, and (7) necessary pumps,
piping, and instrumentation. These are shown in the attached flow
diagram.
The sour water is pumped from the accumulators to the degasifier
drum. The gas removed from this drum flows through a back pressure reg-
ulator valve to a low pressure H2S removal plant.'
The sour water and waste caustic are collected in the 10,000 bbl.
capacity tank venting to the vapor recovery system.
The sour water is pumped from the tank to the neutralizing column
where it contacts 98% sulfuric acid. The mercaptans released from the
water by the sulfuric acid, along with other waste gases in the over-
head line from the caustic regeneration unit, .are condensed and fed
into the cracking unit for conversion to H2S and recovery. This ac-
counts for the disposal of most of the mercaptans in the system.
The neutralized water is then pumped to the waste-water stripper,
and live steam is introduced in the column to strip out H2S and mer-
captans.' Sweet gas with 7 or less grains of H2S per 100 CF from the
secondary scrubber at the H2S removal plant is introduced into the bot-
tom of the stripper at the rate of 350,000 to 500,000 CF/T> to sweep the
released gases from the water. This sour gas from the stripper goes to
the H2S absorption plant.'A pressure relief valve on the stripper vents
to the flare.
The stripped water then flows to an aeration column where it is
contacted counter-currently with an air stream and caustic and is oxi-
dized to non-odorous thiosulfate. i The resulting foul air from this
vessel is sent to the firebox of the vacuum unit heater for deodorizing.
AIR POLLUTION CONTROL DISTRICT COUNTY OF LOS ANGELES
PAGE 2 OF 4
Figure XIV - 9. Activity Status Report of an inspection made of a sour water oxidizing unit at an oil refinery.
TABLE XIV-2
HYDROCARBON EMISSION FACTORS FOR REFINERY SOURCES
SOURCE OF EMISSION
Fluid catalytic cracking unit
Thermofor catalytic cracking unit
Crude oil storage tanks
Petroleum distillate storage tanks
Oil-water separators
Oil-water separators
Vacuum jets
Loading tank trucks & trailers (avg.)
Motor gasoline, 8-12 Ibs. RVP
Aviation gasoline, 4-8 Ibs. RVP
Other distillates, 1-4 Ibs. RVP
Pump seals
Mechanical seals
Packed seals
Compressor seals
Compressor seals
Valves (flow)
Valves (flow)
Relief valves
Relief valves (on process vessels)
Cooling towers
Cooling towers
Treating units
Compressor exhausts
Blowdowns, turnarounds, vessel & tank
EMISSION FACTOR
NO CONTROL
200
50
500
670
400
300
150
150
375
170
90
125
—
5.0
6
8.5
28
0.5
80
2.9
10
6
8
1
25
CONTROL
10
75(b)
100(b)
8
5
0
2
5
2
1
20(c)
3.2
—
— .
—
—
—
5
—
—
—
2
—
5
UNITS (a)
Lbs. per 1,000 bbls. feed
Lbs. per 1,000 bbls. feed
Lbs. per 1,000 bbls. refinery crude throughput
Lbs. per 1,000 bbls. refinery crude throughput
Lbs. per 1,000 bbls. refinery crude throughput
Lbs. per 1,000 bbls. waste water
Lbs. per 1,000 bbls. refinery crude throughput
Lbs. per 1,000 bbls. loaded
Lbs. per 1,000 bbls. loaded
Lbs. per 1,000 bbls. loaded
Lbs. per 1,000 bbls. loaded
Lbs. per 1,000 bbls. refinery crude throughput
Lbs. per seal per day
Lbs. per seal per day
Lbs. per 1,000 bbls. refinery crude throughput
Lbs. per seal per day
Lbs. per 1,000 bbls. refinery crude throughput
Lbs. per valve per day
Lbs. per 1,000 bbls. refinery crude throughput
Lbs. per valve per day
Lbs. per 1,000 bbls. refinery crude throughput
Lbs. per 1,000,000 gals, cooling water
Lbs. per 1,000 bbls. refinery crude throughput
Lbs. per 1,000 cubic feet gas burned
Lbs. per 1,000 bbls. refinery crude throughput
(a) Factors are expressed in units of pounds per 1,000 barrels of refinery crude throughput where, in the opinion of the authors, the
magnitude of the same source in different refineries is related approximately to their throughputs. In some cases the factors are
expressed in a second unit which might prove more convenient.
(b) Floating roof controls. The factor would theoretically be zero for vapor recovery controls.
(c) Control consists of using mechanical seals in place of packed seals for light hydrocarbon service.
Source: Reference 1.
-------
Registering the Sources of Air Pollution
261
The water flows from the bottom of the aerater through a cooler to the
covered waste-water separator.
Prior to the introduction of the air pollution control program,
the principle sources of air pollution at this unit resulted from the
introduction of (1) mercaptans from the neutralizing tank to the burn-
ers of the vacuum unit heater,' and (2) the tt%S from the waste-water
stripper column to the refinery fuel gas system.'The APCD test team
determined that previously 0.5 ton/day of H2S was contributed by this
unit to the refinery fuel gas system. This is equivalent to a loss of
2000 Ibs/day of S02 to the atmosphere.'After studying data disclosed by
extensive physical inspection,' testing, and industrial cooperation on
waste gas streams throughout the refinery, Rule 62 was introduced to
control those waste gas streams to be incinerated and containing sig-
nificant quantities of sulfur derivatives. To comply with this rule,
this refinery adopted the following solutions to meet the problems
resulting from its particular operating methods:
a. Enlarged its H2S absorption facility.'
b. Made provision for introduction of condensable mercaptans into
the cracking plant for conversion of H2S and its eventual recovery.
The waste gas stream now burned in the vacuum unit heater was
found to comply with Rule 62 during « test conducted by the APCD test
team on 10-13-59.'
Negligible mercaptan odors were noted in the vicinity of equip-
ment at this time. Equipment was in good condition and operating under
permit conditions and requirements. No visible emissions were observed
at this time from the vacuum heater.' A sample of treated water taken
from the cooler (after oxidation) was free of noxious odors.
AIR POLLUTION CONTROL DISTRICT - COUNTY, OF LOS ANGELES
PAGE_2_OF_4_
Data Sheet, supported by the inventory forms noted
in d, f, and g., presents a master inventory for each
bulk plant.
Notice (in the sample shown in Figure XIV-12.)
that by increasing the number of spouts observed dur-
ing the 7-8-57 reinspection the permit status changed.
A Permit Request was appropriately written ("P.R.").
e. Truck Loading Inspection Data Sheet (Rule
61). This inspection sheet is made for each truck load-
ing facility subject to Rule 61. It lists the number of
racks and spouts, the permit status of each rack, and
throughputs of tank truck loading racks to determine
compliance with Rule 61, as well as Rule 10. To be
affected by Rule 61, the premises must be used to load
20,000 gallons or more of gasoline in one day into
tank trucks and trailers (see Chapter 11).
On this form, the total losses of hydrocarbons are
determined from the following emission factors:
Emission of hydrocarbons in gallons from uncontrolled
equipment—Approximately 1/10 of 1 per cent of the
average gallon throughput per day.
Emission of hydrocarbons in gallons from controlled
equipment—8 per cent of the above.
f. Oil-Effluent Water Separator Inspection: Rule
59. This inventory form is used specifically with ref-
erence to the requirements of Rule 59. The example
shown in Figure 14 is of a single refinery oil-effluent
water separator which derives its influent from treat-
PRESSURE
VACUUM VALVE
WASTE
H,0 TANK
10006
(10,000 BBL.)
WASTE CAUSTIC
SOUR H20
1950 B/D FROM
VARIOUS ACCUM.
*
1
1
TO
MERCAPTAN
DISPOSAL
UNIT.
SOUR WATER
FLOW PUMP
MM
90% H2S04 ---
)t>
PRV
V
OL.LA.
r
NEUTRALIZING COLUMN
0130
SOUR WATER PUMP
0.5 TON/DAY H2S
lL
i
'IL
ui
ui
FOUL AIR
17' RINGS
STEAM
«—
SWEET
^GAS FROM
2DDEA
SrRIIRRPR
JL
U
_/
_/7V
r~\/ r
Y-s
• PLANT AIR 1
1
-*-
* FLARE
L.P. H,S ABSORBER
,
DEGASIFIER DRUM
350,000
I TO 500,000
r CF/D.
WASTE WATER
STRIPPER C-132
3' x 35'H
(WATER)
OXIDIZING
COUJMN c.131
-* VAPOR RECOVERY
SYSTEM
TO CRACKING
UNIT
ABSORBER.
VAC. HEATER
T0 COVERED
WASTE WATER
SEPARATOR
COOLER
E-409
NAME OF REFINERY.
NAME OF UNIT
DATE INSPECTED —
FLOW DIAGRAM
Sunriae Oil Company, Inc. |ADDRESS .
Sour water oxidizing UNIT NO
1325 Court Street,
II
10/15/59
Hardy
REVISIONS
' DATE OF REVISION
4/3/60
PERMIT NO.-MODIFICATIONS
63897
Figure XIV - 10. Process flow diagram of a sour water oxidizing unit from a field drawing (page 4 of the Activity Status Report).
-------
262
Air Pollution Control Field Operations
SYMBOLS USED IN PETROLEUM FLOW DIAGRAMS
Chart Number One
RECIPROCATING
PUMP
CENTRIFUGAL
PUMP
WAIECH SEAL OR
PACKED GLANDS.
HEAT EXCHANGER
STEAM OR HOT OIL
UEDIUU
REGULATING
VALVE
VALVES
SMALL VALVES
BOOT
(GAS SEP-)
PRESSURE VACUUM VENT
COMBINATION
"VENT AND GAUGE
HATCH
PRESSURE RELIEF
VALVE (P.R.V.)
HEAT EXCHANGERS
EQUIPMENT CODING
E Heal Exchanger
V Vessel
P Pwp
K Cwrpressor
MS Mech^cal-Slal
PG Pa*ed Gland
LLA .J-iquid Level Alam
Y y
U^ ^J LIQUID LEVEL
\^\ | / CONTROL f-
I SUMP I / ,-n
STEAM EJECTOR
Figure XIV-11. Symbols used in petroleum flow diagrams.
TYPES OF FLOATING ROOFS
Chart Number Two
10
11
SHADE
VAPOR DAM
ft>
iANOPY ROOF
:ANOPY ROOF
PAN TYPE
TRUSSED
PAN TYPE
TRUSSED WITH
SHADE OVER 50%
& VAPOR DAM.
DOUBLE DECK
HIGH DECK
PONTOON WITH
CENTER PONTOON
HIGH DECK
PONTOON WITHOUT
CENTER PONTOON
LOW DECK
PONTOON WITH
CENTER PONTOON
LOW DECK
PONTOON WITH
CENTER WEIGHT
PONTOON "DAY"
TYPE WITHOUT
CENTER PONTOON
CLEAR DECK
VENTILATED
PAN WITHOUT
SEAL
VENTILATED
PAN WITH
WIPER SEAL
ing vessels, south tank farm, thermal and catalytic
cracking units, and No. 2 and 3 alkylation plants in
the general cracking area of the refinery. The influent
waste water is traced on the flow diagram by the in-
spector. Note that the description of the controls, i.e.,
"floating roof on primary compartment," and other
information reveals the equipment to be in compli-
ance with Rule 59. (For elements of compliance, see
Chapter 11.)
g. Tank Inspection Report: Rule 56. Figure 16
illustrates an example of a Tank Inspection Report
made for a group of tanks located at the Los Angeles
Petroleum Co. This inventory form records the cat-
egory, vapor control, function, dimensions, products
stored, Reid vapor pressure, storage temperature, etc.,
of each tank to determine compliance with Rules 10
and 56. (See Chapter 11 for determining Rule 56 com-
pliance.)
h. Summaries or Surveys of Natural Gasoline, Gas,
and Cycle Plants. The Natural Gasoline, Gas, and
Cycle Plant Survey Summary is an inventory of natu-
ral gasoline plants located near or in connection with
oil field production. It not only determines the type of
plant, the source of material processed, the throughput,
and type of equipment involved, but it records the
equipment affected by Rules 56 and 59. Note Figure
XIV-16.
In order to determine the full extent or status
of refinery and petrochemical problems, it is nec-
essary to conduct summaries or surveys on a periodic
or temporary basis. Some of the surveys are con-
ducted for interdivisional projects, or in cooperation
with other agencies working in the field. The general
purpose of such surveys is to provide data on various
categories of air pollution sources to evaluate their air
pollution potentials. These include, at the present time,
-------
Registering the Sources of Air Pollution
263
AIR POLLUTION CONTROL DISTRICT - COUNTY OF LOS ANGELES
434 SOUTH SAN PEDRO STREET. LOS ANGELES 13. CALIFORNIA
TRUCK LOADING INSPECTION DATA SHEET
RE: RULE 61
COMPANY
Sunrise Oil
Company
> >
> 1
, i
^x^V_
LOCATION
1325 Court St.
Onyx, Calif.
t i
1 1
1 1
RACK
NO. OR
NAME
1
2
1
2
--~
GAL/DAY GASOLINE
TO TRUCKS
AVERAGE
23.000
26,000
24,500
26,000
^~\>
MAXIMUM
28,500
30,000
47 , 000
30,000
^^^
SPOUTS
TOTAL
5
6
5
7
*-\
OVER
4tt
RVP
2
2
2
2
.
UNDER
4#
RVP
3
4
3
5
^
RULE
61
2
2
2
2
\
PERMIT
STATUS
A-7432
A- 473 3
A- 473 2
P.R.
^^
RECHECK
7-8-59
7-8-59
•^— _
DATE
CONTROLS
FIRST
USED
12- 1- 56
t t
^-\
INSPECTED
BY
J.R.H.
J.R.H.
J.R.H.
J.R.H.
—- \^
Figure XIV - 12. Truck loading inspection data sheet used for surveying compliance with Rule 61.
all industrial activities which handle organic solvents,
oil field production facilities comprising oil wells,
pumping stations, storage facilities, and gasoline filling
stations, etc. Each survey is designed for the special
needs of the project and are provided with special
instructions.
F. Preparing and Issuing the Request to Apply
for A.P.C.D. Permit
The most direct result of equipment inventory is
the finding of all equipment operating illegally with-
out A.P.C.D. permits. A written Section 24279 Notice
may or may not be written, depending on the circum-
stances. (See "B. Unauthorized Construction or Oper-
ation of Equipment," Chapter 13.) However, an
A.P.C.D. Request is always written and served by the
inspector whenever such equipment is found.
The Request does two things: (1) it advises the
plant management to file applications for a permit
with the District by a certain date, and (2) it is a
report of the exact permit status for the Engineering
Division. It is always issued for equipment which has
already been illegally constructed. It is never issued
when construction of equipment is contemplated only
by plant management. In such instances, management
is properly advised to apply for an Authority to Con-
struct before actual construction. Thus, whenever the
inventory inspection culminates in the issuance of a
permit request, the inventory process ties in with the
permit system as a whole, as described in the intro-
duction to this chapter.
1. Preparing and Issuing the Permit Request
A separate Request to Apply for Permit (Figures
XIV-17 and 18) is issued for each piece of basic or
control equipment requiring a permit. However,
where two or more pieces of equipment are identical
as to structure and use, a single Request form may
be written. Before preparing such forms, the inspector
checks with the Engineering Division by phone in
order to determine, in doubtful cases, the permit unit
boundaries. If this is impractical at the time, the in-
spector issues such permit requests as seems logical to
him, as adjustment can be made later by the Engineer-
ing Division.
The front of this form is completed in triplicate.
The white copy is issued to the responsible manager
or individual owner of the equipment for which the
permit is required, along with the correct application
blanks and special instruction sheets. After the back
of the form is completed, the pink and green copies are
forwarded to Headquarters with the Inspector's Daily
Reports.
The completion of the report heading and descrip-
tion of the equipment is similar to procedures previ-
ously described. The form number of the applications
issued should be shown on the face of the advice copy.
On the bottom of the face of the form the date to
be entered on the "To Arrive By" line is ten calendar
days subsequent to the date of the Request. This
"grace" period gives the plant manager a reasonable
period of time in which to apply for the permit. The
-------
264
Air Pollution Control Field Operations
AIR POLLUTION CONTROL DISTRICT COUNTY OF LOS ANGELES
434 SOUTH SAN PEDRO STREET. LOS ANGELES 13, CALIFORNIA
BULK PLANT DATA
Sunriae Oil Cn.p^v
DATE 12-1-56
1325 Court Street
CONVERSATION WITH .
NO. OF STORAGE TANKS £
REID V.P. OR GASOLINE 11 Iba.
MAX. GAL/DAY SB. 500
: NO. STORING GASOLINE .
-, AV. GAL/DAY 49.000
, PLANT THROUGHPUT 980.OOP
UNITS LOADED Ad. 150
, NO. OF LOADING RACKS .
LENGTH OF RACKS 20 ft.
LOADING SCHEDULE
PEAK OPERATION HOURS: 6-11 A.M.
NO. OF FILLER SPOUTS:__2
METHOD OF FILLING (X SPLASH AND/OR BOTTOM FILL} Through yapor closures
RATE OF FILLING 250 GAL/MIN.
VAPOR RECOVERY ON LOADING: YES
-------
Registering the Sources of Air Pollution
265
AIR POLLUTION CONTROL DISTRICT COUNTY OF LOS ANGELES
434 SOUTH SAN PEDRO STREET, LOS ANGELES 13. CALIFORNIA
NATURAL GASOLINE. GAS. AND CYCLE PLANT
SURVEY SUNWARY
COMPANY S.nri.« Oil Co. of Calif. . Ing. «3
ADDRESS 1400BH33 St.
_ CITY Otw*. Califoi
PHONE HA 6-3251
INFORMATION BY L. M. Black
_ TITLE Productii
TYPE OF PLANT: HA'
SPECIFY:
SOURCE OF MATERIAL PROCESSED Wet ttfta from oil wella TOTAL NO. OF WELLS .
THROUGHPUT: WET GAS 20 i*j SCFD| nBV 2 UM SCFD
N*TU»«L S«SOLIN£(8BLl 475/jaY PROP«NE(BBL) 0 ,
N-BUTANE(BBt) Q BUTANE - PROPANE MIXTURE(eSL) Q_
tsoeuTANE(BBL)
BOILERS: NUfcBER 5 TYPE HRT HEATERS: NUMBER 2 TYPE Steam
TYPE FUEL Plant gaa
IS FLOW DIAGRAM AVAILABLE Xj
STORAGE ft HANDLING:
TANKS
NO. OF TANKS S
SOURCE Plant residue QUANTITY <
.1 CAN IT BE OBTAINED? Attached
JEL USED .
OIL-EFFLUENT WATER SEPARATORS
NO. OF SFPflpflTnpi 1
VAPOR RECOVERY—
NO. UNDER RULE 56 .
PRESSURE
NO. QUESTIONABLE 1
TYPE OF CONTROI fili
FLOATING ROOF Noni
OTHER(SPECIFY) .
NO. CONTROLLED .
NO. UNDER RULE 59 None
NO. CONTROLLED UNDER RULE 59 Jtoffe _
TOTALLY ENCLOSED None
VAPOR RECOVERY SYSTEM —Hone _
OTHER(SPECIFY)
INSPECTOR'S REMARKS RE EQUIPMENT ft PLANT CONDITIONS:
Q "• "*" Z
-
Figure XIV -15. Natural gasoline, gas, and cycle plant survey
summary.
the inspector's date book, and any other notes taken.
3. Follow-up on Service of Section 24279 F-Notice
Generally speaking, the same procedure as de-
scribed above should be followed after an F-Type
notice for violation of Section 24279 has been served
in those cases in which the construction of equipment
is completed. If the equipment is in operation, a
notice is written each day the equipment is operated
after the due date. If the equipment, however, is under
construction, the inspector returns the day following
the issuance of the notice to determine whether con-
struction is continuing. If further construction is ob-
served, another F-Notice is issued for construction
without a permit. The inspector then issues an F-
Notice for each day he observes unpermitted construc-
tion underway.
4. Writing the Report for Permit Follow-up
Follow-ups are prepared on the Inspector's Field
Report. In the blank "This Report Covers", the in-
spector writes in "Permit Follow-up". Under "Find-
ings", the date applications were issued, the date due,
and any extension of time allowed by Headquarters
are shown. The number and description of equipment
concerned with the permit follow-up should also be
mentioned, as well as any facts relative to operation of
the equipment.
Under Statements and Remarks, the Inspector's
Report should show if the applicant did or did not sub-
AIR POLLUTION CONTROL DISTRICT COUNTY OF LOS ANGELES - AREA GRID NO._JJS.
M.R.NO. 011 -l
TYPES OF
CONTAMI-
NANTS
A
8
C
0
t.
r
e
0
X
FIRM
ADDRE
NATUf
RESP(
NAME Los Anaeles Petroleum Company (XXI) TEL . T A 4. -2 3 5 9 ._ A . P
"SS OF PREN
*E OF BUSU
DNSIBLE PEF
TANK GROUP NO
Tank No.
—
54
Ht.
30'
51'
4
USES
jrco
12486 S. Oil Road POSTAL ZONE-- C 1 TY Torrance
.C.D. ^ONE_25_
D«»,^I n»f;«; —
«SON TO COt'
. TJ
Dia.
40'
40'
Type
c
c
F
Gen.
Cond.
G
G
G
JTAOT John Doe TITIF Fjieineer
INSPECTION REPORT
VNK LIST PREPARED BY George Smith
. DATE rw. 11 19 so_
Reinspection Record on Back of Sheet
Product
Stored
Gasoline
Stove Oil
Aviation Gaso.
Diesel
RVP
9
negl.
6
9
_negL_
Prod.
Stg.
Temp.
ambient
,,
ambient
, ,
"
Service
storage
.,
storage
, .
••
Vapor
Control
VR
N
N
VR
F (SS)
PW-VR
F (SS)
Permit
Status
Rule 13
Rule 13
Rule 13
«19463
Rule ll-h-3
4-,L"?i-h-5
Rules
Affected
Rule 10, 56
_None
None.
Rule 10. 56
JMone
Rule 10
Remarks
Vapor Recoverv
nut- of ssrvirp
si. odors
gasoline
Roof; P-Pressure; O-Open Top; S-Spheroid; H-Horizonml; U-Underground
Cond.: G-Good; P-Poor; B-Bad
Service- Rundown; Storage; Blending or Mixing
Control:' N-None; PVV -Conservation Vents; F-Floating Roof (SS-Single Seal; DS-Double Seal); V. R. -Vapor Recovery;
V. D. -Vapor Disposal; V.B. -Vapor Balance.
40D330
Figure XIV - 16. Tank inspection report.
Sheet
of
-------
266
Air Pollution Control Field Operations
REQUEST TO APPLY FOR A.P.C.D. PERMIT
FIRM NAME
Anderson Products (a corporation)
ADDRESS OF PBFMISES *537 W.Struthers Road
TEL. .
CITY.
ET 3-5169
Burbank
DESCRIPTION OF EQUIPMENT 1-Lancer, Dry Type Paint Spray Booth, 15' Wide x 8' H. x 5' D.
Model A22
THIS EQUIPMENT SHOULD BE EVALUATED TO DETERMINE IF IT CAN BE OPERATED WITHOUT
VIOLATING THE HEALTH & SAFETY CODE OF THE STATE OF CALIFORNIA & THE RULES &
REGULATIONS OF THE AIR POLLUTION CONTROL DISTRICT • LOS ANGELES COUNTY.
YOUR COOPERATION IS HEREBY REQUESTED TO FURNISH INFORMATION FOR THIS EVALUATION
SO THAT A PERMIT MAY BE ISSUED TO YOU TO OPERATE TH IS EQUIPMENT WITHOUT VIOLATION.
FOR YOUR CONVENIENCE THE FOLLOWING LISTED FORMS HAVE BEEN LEFT HEREWITH:
400AQ2 3 COPIES: 400B L^D 1 COPY; SPECIAL INSTRUCTION SHEET 400C-
1 COPY.
MAIL APPLICATION AND SUPPORTING DATA TO ATTENTION OF "ENGINEERING"
AW POLLUTION CONTROL DISTRICT—LOS ANGELES COUNTY
434 South Son Pedro Street UAdison 9-4711 LOS ANGELES 13, CALIFORNIA
A .. , „ LOUIS J. FULLER
ftPrli a 19-21 DIRECTOR Of, ENFORCEMENT
TO ARRIVE BY
THIS REQUEST GIVEN TO.
16-4OD169 TITLE _
Mr.Fred Aiken
BY
Vice President
.DATS
AIR POLLUTION CONTROL DISTRICT - COUNTY OF LOS ANGELES
434 SOUTH SAN PEDRO STREET. Los ANGELES 13. CALIFORNIA. MADISON 9-4711
DATA FOR ENGINEERING FILE
DATE
April 5 io 57
CONSTRUCTION OR i — i i — , i — ,
INSTALLATION CLASS: NOT STARTED | | PARTLY COMPLETE | | ESTIMATED % COMPLETE % COMPLETE | |
STARTING DAT
REASON PERMIT NEW CONSTRUCTION | ] ALTERATION [ | OF CONSTRUCT
IS REQUIRED: CHANGE OF CHANGE OF CHANGE OF DAT
OWNERSHIP |x] LESSEE [ ] LOCATION | | BEC
FORMER PERMIT: NONE | ] RULE 13 [ ] RULE 10 | ) FORMER PERMIT No
E COMPLETION
ION: Unknown DATE: Unknown
E PERMIT
AME NECESSARY: Dec. 15, 1955
• 3567
NAME OF FORMER PERMITTEE: Gordon Furniture Co., Inc. (a corporation)
WAS EQUIPMENT i 1 i 1 ANY VISIBLE , , , , VIOLATIONS .,
IN OPERATION? YES [Xj NO | | CMISSfrOMS? YES|X| No| | RECORDED: "One
DESCRIPTION OF PRO-
CESS:(IN SOME DETAIL) Used to spray paint and lacquers on small
VIOLATIONS M
SUSPECTED: None
wooden objects.
^AoC^^TriNSI?LFEo^Rir°NS Light overspray and solvent odor.
POSSIBLE OR OBSERVED
EMISSIONS INCLUDE: SMOKE |_ ] DUSTs| | FUMEs| | MISTs[jt| VAPORS|x] ODORSL
NUISANCE — —
POTENTIAL? YES| | NO| X |
x] ACIDs| | GASESJ^"]
40D169
R-6-60
Figure XIV - 17. Request and office copies of the A.P.C.D. Permit Request.
-------
Registering the Sources of Air Pollution 267
RULE 10 AND RULE 14
OF THE RULES AND REGULATIONS - AIR POLLUTION CONTROL DISTRICT
COUNTY OF LOS ANGELES
RULE 10. PERMITS REQUIRED, a. Authority to Construct. Amended 11-16-54. Any person building, erecting,
altering or replacing on or after February 1. 1948. any article, machine, equipment or other contrivance,
the use of which may cause the issuance of air contaminants or the use of which may eliminate or reduce pr
control the issuance of air contaminants, shall first obtain authorization for such construction from the
Air Pollution Control Officer. b. Permit to Operate. Amended 11-16-54. Before any article, machine equip-
ment or other contrivance described in Rule 10(a) may be operated or used, a written permit shall be obtained
from the Air Pollution Control Officer. Ho permit to operate or use shall be granted either by the Air Pollu-
tion Control Officer or the Hearing Board for any article, machine, equipment or contrivance described in
Rule 10(a), constructed or installed without authorization as required by Rule 10(s), until the information
required is presented to the Air Pollution Control Officer and such article, machine equipment or contrivance
is altered, if necessary, and made to conform to the standards set forth in Rule 20 and elsewhere in these
Rules and Regulations.
RULE 14. APPLICATIONS. Amended 11-16-54. Every application for an authority to construct or for a permit
to operate required under Rule 10 shall be filed in the manner and form prescribed by the Air Pollution Con-
trol Officer, and shall give all the information necessary to enable the Air Pollution Control Officer to
make the determinations required by Rule 20 hereof.
16-400169
Figure XIV - 18. Reverse side of the advice copy of the A.P.C.D. Permit Request.
-------
268
Air Pollution Control Field Operations
mit applications. The reasons for failure to submit
them should be shown, together with any subsequent
warnings or observations.
G. Denials and Denial Follow-up Inspections
If the applications submitted to the A.P.C.D. by
the plant manager are not approved, then a letter of
denial is sent to the applicant. Upon receipt of this
letter, the applicant may, if he desires, petition the Air
Pollution Control Hearing Board to review the denial.
The petition must be filed by the applicant within 10
days after receipt of denial. (See Chapter 6.)
Initial denial inspections are made immediately
and continued every two or three days, and on the
tenth day, when the privilege for petition has expired,
to determine the status of the equipment. The inspec-
tor receives a Denial Check Slip containing the follow-
ing information as a guide to inspecting and reporting
the status of denied equipment:
1. Application number and a notation as to whether applica-
tion was made for an authority to construct (A/C), or for
permit to operate (P/0), or both.
2. Name and address of legal owner or company and DBA
(Doing Business As) title.
3. Address at which equipment is located, and type of equip-
ment.
4. Name and title of person to whom, denial was served, date
and method of service (certified mail or served in person).
5. Sector number.
6. Reinspection Dates—If no date is inserted by Headquarters
in this column, the inspector should follow up on denial, as
outlined in this chapter. If a date or dates appear here, the
inspector should make an inspection on or about the last
date shown.
At the time the initial inspection follow-up of the
denial is made or on the first occasion that the in-
spector contacts management, he should check the
equipment for any indication of operation, if the
equipment is still present. The inspector then prepares
an Inspector's Field Report setting forth the results of
his inspection and all pertinent remarks made at the
time by management.
If the inspector finds the equipment in operation
at any time after the tenth day denial follow-up, he
issues an F-Type Notice for violation of Section 24279.
If on that and subsequent follow-up inspections the
inspector determines that management has completely
removed the equipment, or the equipment is otherwise
definitely secured against future use, the inspector may
then recommend filing of the Inspector's Report and
the denial check slip.
If the equipment is not in operation on the in-
spector's initial follow-up, but evidence indicates the
equipment is being used, it should be reported. The
inspector then reinspects at times he suspects oper-
ation.
In preparing a report for denial follow-up, the
general report procedures should be employed as dis-
cussed elsewhere in the chapter. In particular the
following should be complied with:
THIS REPORT COVERS:
The words "Denial Follow-Up "should be used.
NOTICE ISSUED:
If F-Notices are issued, so indicate.
FINDINGS:
This portion of the Report should also include a refer-
ence to the application number and the type of equip-
ment. Example: "Re: Application B-34567 for dry
type Force Spray Booth." Any evidence as to use or
non-use of the equipment should be accurately recorded.
HIS STATEMENT:
This should include a statement by management show-
ing whether or not equipment is being used.
Inspector recommends whether the case should be filed,
or whether further observation is necessary. He also
records any warnings given and laws explained.
II ADMINISTRATION OF THE PERMIT SYSTEM
The Engineering Division of the A.P.C.D. takes
up that portion of the task of registering the sources of
air pollution that the inspector cannot adequately per-
form in the field, namely, the careful engineering
review of permit applications. This involves a detailed
engineering analysis of plans and specifications in
order to determine as exactly as possible emission rates
under optimum, minimal and maximal equipment
operating conditions. The actual engineering design
parameters of equipment, i.e., the various capacities of
equipment to operate in compliance with the Rules
and Regulations, are computed. The results should
lead directly either to prevention of future air pollu-
tion problems, or correction or elimination of an exist-
ing problem.
The permit system involves, then, under Rule 10,
the orderly filing of applications for authority to
construct (including alteration and relocation) and
permits to operate, together with all necessary infor-
mation, plans and specifications which may be re-
quired, for certain classes of equipment located in all
cities and unincorporated areas of Los Angeles County.
The Permit System is governed by Rules 10 through
25 in the official Rules and Regulations of the Los An-
geles County A.P.C.D.
A.—Application for A.P.C.D. Permit
The A.P.C.D. distributes application forms and
instruction sheets to assist firms in applying for the
Authority to Construct and Permit to Operate. These
forms are issued by the Engineering or Enforcement
Divisions whenever they are requested, or they are
automatically issued by inspectors whenever a Request
to Apply for A.P.C.D. Permit is written or an F-Notice
for Violation of Section 24279 is served.
The application consists of two parts. The first
part is the application which requests the authority to
construct (if the equipment is not yet constructed) and
the permit to operate, proper (see Figure XIV-20).
The application identifies the individual, company,
lessee, partnership or corporation operating the equip-
ment, requesting all information necessary for a proper
definition of the person(s) involved. (See page 216,
Chapter 13.) The application also gives a description
of the equipment, the estimated cost of equipment or
-------
Registering the Sources of Air Pollution 269
AIR POLLUTION CONTROL DlSTRICT---COUNTY OF LOS ANGELES
434 SOUTH SAN PEDRO STREET, Los ANGELES 13, CALIFORNIA. MADISON 9-4711
APPLICATION INSTRUCTIONS
GENERAL
A filing fee of $10.00 must accompany each application. Checks or money orders should
be made payab e to the Air Pollution Control District, County of Los Angeles. The
filing fee will be applied to the final *ee for permit to operate. A separate applica-
tion is required for each unit of basic equipment (equipment the use of which may cause
the issuance of air contaminants). Such a unit may consist of one individual item or a
group of twoormore items. A separate application is also required for each air pollu-
tion control system (equipment which eliminates or reduces the emission of air con-
tami nants ).
With each application for authority to construct and permit to operate, the following
data, specifications, plans and drawings must be submitted in DUPLICATE:
'• EQUIPME NT ^ LOCAT I ON DRAW ING. The drawing or sketch submitted must be to scale (suggested
scale: I inch = 100 feet; accuracy of measurements to the nearest 5 feet will be satis-
factory) and must show at least the following:
a. The property involved and outlines and heights of all buildings on it. Identify
property lines plainly.
b. Location and identification of the proposed equipment on the property.
c. Location of the property with respect to streets and all adjacent properties.
Identify adjacent properties. Show location of al I buildings outside the property
that are within 150 feet of the equipment involved in the application. Identify
all such buildings (as residence, apartment house, machine shop, warehouse,
etc.), specifying heightofeach building (numberofstories). Indicate direction
(north) on the drawing.
2. DESCRIPTION OF EQUIPMENT. State make, model, size and type for either the entire
unit or for its major parts.
3. DESCRIPTION OF PROCESS.The application must be accompanied by a written description
of each process to be carried out in the equipment and of the function of the equip-
ment itself in the process. The descriptions must be complete and in detail con-
cerning all operations. Particular attention must be given to explaining all stages
in the process where the discharge of any materials might contribute in any way to
air pollution. All obtainable data must be supplied concerning the nature, volumes,
particle sizes, weights and concent rations of alI types of air contaminants that may
be discharged at each stage in the process. Similarly, control procedures must be
described in sufficient detail to show the extent of control of air contaminants
anticipated in the design, specifying the expected efficiency of the control devices.
4. OPERATING SCHEDULE. Specify the hours per day and days per week the equipment is to
be operated.
5. PROCESS WEIGHT. Detail type and total weight of each material charged into the
equipment or the process on the basis of pounds per hour or per other specified
unit of t ime.
6. FUELS AND BURNERS USED. Indicate for fuel gas-type and cubic feet per hour; for
fuel oil-grade and gallons per hour (specify temperature to which oil is preheated);
for solid fuels-type and pounds per hour; Indicate for burners-make, model, size,
type, number of burners, and capacity range of each burner (from minimum to maximum).
7. FLOW DIAGRAM. For continuous processes, show the flow of materials either on a
separate flow diagram or on the drawings accompanying the application.
I6-50DI9 R4-58-9 (Continued on reverse side) Form 400-C
Figure XIV - 19. General permit application instructions.
-------
270 Air Pollution Control Field Operations
8. DRAWINGS OF EQUIPMENT. (See NOTE below.) Supply an assembly drawing, dimensioned
and to scale, in plan, elevation and as many sections as are needed to show clearly
the design and operation of the equipment and the means by which air contaminants
are controlled. The following must be shown:
a. Size and shape of the equipment. Show exterior and interior dimensions and
features.
b. Locations, sizes and shape details of all features which may affect the pro-
duction, collection, conveying or control of a i r contaminants of any kind; lo-
cation, size and shape details concerning all materials handling equipment.
c. All data and calculations used in selecting or designing the equipment.
d. Horsepower rating of all electric motors driving the equipment.
9. RADIOACTIVE MATERIAL. Describe any use or processing of radioactive material.
NOTE: Structural design calculations and details are not required. When standard
commercial equipment is to be installed, the manufacturer's catalog describing the
equipment may be submitted in lieu of the parts of Item 8 that it covers. All in-
formation required above that the catalog does not contain must be submitted by the
applicant. ADDITIONAL INFORMATION MAY BE REQUIRED.
After authority to construct or to install is granted for any equipment, deviations from the
approved plans are not permissibl e without first securing additional approval for the changes
from the Air Polliution Control Officer.
Further i nformat ion or clarif icat i on concern! ng permits can be obtained by writing or cal I ing
the Permit Application Receiving Unit, MAdison 9-4711, Ext. 69.
ENGINEERING AND EVALUATION & PLANNING DIVISION
ROBERT L. CHASS
DIREC/TOR OF ENGINEERING
I6-50DI9 R4-58-9 Form
-------
Registering the Sources of Air Pollution
271
AIR POLLUTION CONTROL DISTRICT - COUNTY OF LOS ANGELES
434 SOUTH SAN PEDRO STREET, Los ANGELES 13, CALIFORNIA. MADISON 9-4711
APPLICATION
AUTHORITY TO CONSTRUCT AND PERMIT TO OPERATE
INSTRUCTIONS
A. A FILING FEE OF $10.00 MUST ACCOMPANY EACH APPLICATION. CHECKS OR MONEY ORDERS SHOULD BE MADE PAYABLE TO THE AIR
POLLUTION CONTROL DISTRICT, COUNTY OF Los ANGELES.
B. THIS APPLICATION MUST BE FILLED OUT COMPLETELY AND MUST BE FILED IN TRIPLICATE.
C. APPLICATIONS ANE INCOMPLETE UNLESS ACCOMPANIED BY DUPLICATE COPIES OF ALL PLANS, SPECIFICATIONS AND DRAWINGS
REQUIRED. DETAILS REQUIRED FOR SPECIFIC EQUIPMENT ARE LISTED ON SEPARATE FORMS WHICH ARE AVAILABLE UPON REQUEST.
0. THIS APPLICATION MUST BE SIGNED BY A RESPONSIBLE MEMBER OF THE ORGANIZATION THAT IS TO OPERATE THE EQUIPMENT FOR
WHICH APPLICATION IS MADE. INCOMPLETE APPLICATIONS ARE NOT ACCEPTABLE.
ENGINEERING AND EVALUATION 4 PLANNING DIVISION
ROBERT L. CHASS
DIRECTOR OF ENGINEERING
APPLICATION INFORMATION
1. PERMIT TO BE ISSUED TO (BUSINESS LICENSE NAME OF CORPORATION, COMPANY, INDIVIDUAL OWNER OR GOVERNMENTAL AGENCY
THAT IS TO OPERATE THE EQUIPMENT):
2. MAILING ADDRESS:
CITY OR COMMUNITY
3. ADDRESS AT WICH THE EQUIPMENT IS TO BE OPERATED:
CITY OR COMMUNITY
4. TYPE OF ORGANIZATION: CORPORATION CD
PARTNERSHIP I I
INDIVIDUAL OWNER C3 GOVERNMENTAL AGENCY
5. GENERAL NATURE OF BUSINESS:
6. EQUIPMENT DESCRIPTION. PURSUANT TO THE PROVISIONS OF THE STATE HEALTH AND SAFETY CODE AND THE RULES AND
REGULATIONS OF THE AIR POLLUTION CONTROL DISTRICT, APPLICATION is HEREBY MADE FOR AUTHORITY TO CONSTRUCT AND
PERMIT TO OPERATE THE FOLLOWING EQUIPMENT:
AIR POLLUTION
7. ESTIMATED COST OF EQUIPMENT OR OF ALTERATION: CONTROL EQUIPMENT: $
BASIC
EQUIPMENT: $
8. PRESENT STATUS OF EQUIPMENT (CHECK AND COMPLETE APPLICABLE ITEMS):
ESTIMATE
STARTING DATE
ESTIMATE
COMPLETION DATE
CONSTRUCTION OR INSTALLATION NOT STARTED.
CONSTRUCTION OR INSTALLATION PARTLY COMPLETED.
CONSTRUCTION COMPLETED.
EQUIPMENT is TO BE ALTERED.
EQUIPMENT is PARTLY ALTERED.
EQUIPMENT HAS BEEN ALTERED.
TRANSFER OF OPERATOR.OWNER OR LESSEE.
TRANSFER OF LOCATION.
9. IF THIS EQUIPMENT HAD A PREVIOUS WRITTEN PERMIT GIVE NAME OF CORPORATION, COMPANY OR INDIVIDUAL OWNER
THAT OPERATED THIS EQUIPMENT AND STATE PREVIOUS AIR POLLUTION CONTROL DISTRICT PERMIT NUMBER,IF KNOWN.
NAME
10.SIGNATURE OF RESPONSIBLE
MEMBER OF FIRM:
11. TYPE OR PRINT NAME
AND OFFICIAL TITLE
OF PERSON SIGNING
THIS APPLICATION.
NAME
TITLE
PHONE NUMBER
PERMIT
NUMBER
DATE OF APPLICATION:
A-
I6-50D5 R9-60-I F°™ 400-A
Figure XIV - 20. Application for authority to construct and permit to operate equipment capable of air pollution.
-------
272 Air Pollution Control Field Operations
AIR POLLUTION CONTROL DISTRICT - COUNTY OF LOS ANGELES
434 SOUTH SAN PEDRO STREET, Los ANGELES 13, CALIFORNIA. MADISON 9-4711
APPLICATION INSTRUCTIONS
FOR
METAL-MELTING FURNACES (INCLUDING SWEAT FURNACES)
A filing fee of $10.00 must accompany each application. Checks or money orders should be made
payable to the Air Pollution Control District, County of Los Angeles. The filing fee will be
appl led to the final fee for permit to operate.
With each application for authority to construct and permit to operate any type of metal melt-
ing or sweat furnace, the following data, specifications, plans and drawings must be submitted
in DUPLICATE:
I. EQUIPMENT LOCATION ORAWI NG. The drawing or sketch submitted must be to scale (suggested scale:
I inch = 100 feet; accuracy of measurements to the nearest 5 feet will be satisfactory) and
must show at least the following:
a. The property involved and outlines and heights of at I buildings on it. Identify property
Iines plainly.
b. Location and identification of each furnace on the property.
c. Location of the property with respect to streets and all adjacent properties. Identify
adjacent properties. Show location of all buildings outside the property that are within
150 feet of the equipment involved in the application. Identify all such buildings (as
residence, apartment house, machine shop, warehouse, etc.), specifying height of each
building (number of stories). Indicate direction (north) on the drawing.
2. DESCRIPTION OF FURNACE. State make, model, size, type and catalog number.
3. DESCRIPTION OF PROCESSES. The application must be accompanied by a written description of
each metal Iurgical operation to be carried out in the furnace. The descriptions must be com-
plete and in detail concerning al I stages of the operations, particularly where the discharge
of any materials might contribute.in any way to air pollution. Supply all the following In-
fo rmat i on:
a. Name and give percentage composition of all metals and/or alloys to be poured from or
produced in the furnace.
b. Name and describe all solid materials which may be charged into the furnace, including
metals, alloys, scrap, additives, fluxes, dross, cleaning agents, solid fuels, etc. De-
scribe the physical nature of each material (i.e., dust, powder, granules, chips, borings,
shavings, briquettes, ingots, broken scrap, compressed scrap, large pieces, motor blocks,
etc. ).
c. Specify the general chemical composition of these materials, percentage wise, including
all metals, alloys and non-metals. If impurities (e.g., dust and dirt, acids, oils or
greases, other combustible materials, sulfur-bearing materials, etc.) are present, de-
scribe and supply an estimate as to the maximum amounts of each that may be present in
each of the materials charged. Describe any pre-cleaning provided for materials charged
and the relationship of this pre-cleaning to the production or control of ai r contaminants.
d. For each sol id material charged into the furnace in each type of heat to be made, specify
the weight in pounds. State the length of time required for one heat of each type, from
the time the fire (or electric current) is first applied to the furnace until the last
tap of molten metal is complete. If either weights or time or both vary from one heat to
another, describe the amounts of variation.
e. Describe the method of charging the furnace. Include data concerning the number and rela-
tive sizes of charges per heat and time elapsed between charges. If different materials
are charged at one time during the heat as compared with another time, give explanatory
detalIs.
f. State maximum temperature the metal will reach in each type of heat. Describe the number
of taps per heat, method of tapping and temperature of the metal at time of tapping. De-
scribe completely the sequence or cycle of operations and a typical heat of each type,
on a time basis.
I6-50D7I R2-58-9 (Continued on reverse side) rorm 400-C-ll
Figure XIV-21. Sample application instructions for typical equipment capable of air pollution: "Metal-Melting Furnaces (including
sweat furnaces)". Special application instructions are issued to applicants by the A.P.C.D. for such equipment as ovens, concrete batch
plants, multiple-chamber incinerators, organic solvent degreasers, spray booths, storage tanks for liquids and/or gases, and asphalt paving
plants, exhaust systems utilizing such control equipment as dry filters (baghouses), scrubbers or other wet collectors, cyclones or other
dry centrifugal or inertial separators, electrical precipitators, vapor incinerators or afterburners, and vapor adsorbers.
-------
Registering the Sources of Air Pollution 273
g. If air or any other gas (oxygen, nitrogen, chlorine, etc.) is blown or bubbled through
the molten metal, name the gas used and describe the method of use. Specify amount used
(cubic feet or pounds) and the length of time required for this operation. State tempera-
ture of the metal at time of this operation.
h. If any other refining methods are used, describe the operations on a time sequence basis.
i. Describe all operational means to be used in controlling air contaminants. Information
submitted must be specific concerning procedures, amounts, time, supervision to be pro-
vided, etc.
j. If more than one furnace is to be connected to any type of air pollution control equip-
ment, specify all combinations of furnaces that are to be operated at the same time.
4. DRAWINGS OF FURNACE. I See NOTE below.) Supp I y an assembly drawing, dimensioned and to scale,
in plan and elevation. Show all of the following details which apply, using auxiliary draw-
ings if necessary:
a. Over-all size and shape of the furnace, showing breeching (If any), stack and other ex-
ternal features.
b. Locations, sizes and shapes of all internal chambers, baffles and similar features.
c. Locations, sizes and shapes of all doors, holes, explosion or other vents, stacks, burner
openings, tap-holes and spouts, slag-holes and spouts. Describe methods of sealing any
vents other than the main stack.
d. Locations, sizes, shapes and means of controlling all dampers and similar devices.
e. Locations of all burners and all blowers supplying air to burners.
f. Location, size and shape detai I s concerning any materials-handling and/or conveying equip-
ment used in connection with the process carried out in the furnace.
5. OPERATING SCHEDULE. Hours per day and days per week the furnace is to be operated.
6. FUELS AND BURNERS USED. Indicate for fuel gas-type and cubic feet per hour; for fuel
oil-grade and gallons per hour (specify temperature to which oil Is preheated); for
solid fuels-type and pounds per hour; indicate for burners-make, model, size, type,
number of burners, and capacity range of each burner (from minimum to maximum).
If air is supplied to the burner by a blower, specify the amount of air (cubic feet
per minute) and the delivery pressure. Give following data on the blower set: name
of manufacturer, model, size, type, blower speed in rpm, horsepower of connected
motor. Describe any equipment to be used to control the input of air to the furnace.
If furnace is electrically heated, specify whether heating is by direct arc, indirect
arc or induction.
1. RADIOACTIVE MATERIAL. Describe any use or processing of radioactive material.
NOTE: Structural design calculations and details ore not required. When standard com-
mercial equipment is to be installed, the manufacturer's catalog describing the equip-
ment may be submitted in lieu of the parts of Item 4 that it covers. All information
required above that the catalog does not contain must be submitted by the applicant.
ADDITIONAL INFORMATION MAY BE REQUIRED.
After authority to construct or to install Is granted for any equipment, deviations from the
approved plans are not permissible without first securing additional approval for the changes
from the Air Pollution Control Officer.
Further information or clarification concerning permits can be obtained by writing or calling
the Permit Application Receiving Unit, MAdison 9-4711, Ext. 69.
ENGINEERING AND EVALUATION & PLANNING DIVISION
ROBERT L. CHASS
DIRECTOR OF ENGINEERING
16-50D7 I R2-58-9 Fo""
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274
Air Pollution Control Field Operations
AIR POLLUTION CONTROL DI STRICT---COUNTY OF LOS ANGELES
434 SOUTH SAN PEDRO STREET, Los ANGELES 13, CALIFORNIA. MADISON 9-4711
SPRAY BOOTH SUMMARY
(SEE REVERSE SIDE FOR INSTRUCTIONS)
ONE COPY OF THIS FORK MUST BE FILLED OUT COMPLETELY FOR EACH BOOTH
AND MUST ACCOMPANY THE TRIPLICATE APPLICATION FOR PERMIT (FORM 400-A).
1. BUSINESS LICENSE NAME OF CORPORATION, COM3ANY, INDIVIDUAL 0«NER OR GOVERNMENTAL AGENCY UNDER
WHICH APPLICATION (FORM 400-A) IS SUBMITTED:
2. BOOTH MANUFACTURER, MODEL NUMBER & SERIAL NUMBER: (SEE ITEM 2 ON REVERSE SIDE)
3.
BOOTH TYPE:
AUTOMOTIVE l~~1
FLOOR II
4. BOOTH DIMENSIONS: :
WIDE X
5. EXHAUST FAN DATA:
NUMBER OF FANS:
MODEL NUMBER:
HORSEPOWER:
MANUFACTURER
FAN SPEED (RPM):
VOLUME (CFM) :
6. OPERATIONAL DATA:
USUAL OPERATING SCHEDULE:
ARTICLES SPRAYED:
. HRS/DAY
.DAYSAlcEK
7.
EXHAUST CONTROL:
WATERWASH CH EXHAUST FILTERsd] NONE d)
IF WATERWASH, GIVE PUMP CAPACITY IN GALS./MIN.
MOTOR HP..
IF FILTERED, SIVE NUMBER 4 SIZE OF EXHAUST FILTERS.
B. NAME ALL TYPES OF COATINGS SPRAYED:
ENAMEL.
LACQUER:
OTHER:
(DESCRIBE)
GALS./DAY
GALS. /DAY
GALS./DAY
ADDED THINNER:
ADDED THINNER:
ADDED THINNER:
GALS./DAY
GALS./DAY
SALS. /DAY
THE ABOVE INFORMATION IS SUBMITTED TO DESCRIBE THE USE OF THE BOOTH FOR WHICH
APPLICATION FOR PERMIT IS BEING MADE ON THE ACCOMPANYING FORM 400-A.
SIGNATURE OF RESPONSIBLE
MEMBER OF FIRM:
TYPE OR PR INT NAME
AND OFFICIAL TITLE
OF PERSON SIGNING
THIS DATA FORM.
NAME
TITLE
DO NOT WRITE BELOW THIS LINE
BOOTH CROSSDRAFT VELOCITY:
2. BOOTH FACE INDRAFT VELOCITY:
APPL. NO.
PROCESSED BY
DATE
CHECKED 9Y
3. SCRUBBING OR FILTERING RATIO:
4. AVG. DAILY SOLVENT LOSS TO ATMOSPHERE:
COMMENTS:
I6-50D40 R5-58-9
Form 400-C-l
Figure XIV - 22. Reverse of application instructions for spray booths. For commonly used equipment such as spray booths, ovens, de-
greasers, etc., involving standard data and dimensions which may be readily supplied for calculations to determine air pollution poten-
tials and compliance, a data summary similar to the above is included on the reverse of the special instructions for completion by the
applicant.
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Registering the Sources of Air Pollution
275
alteration, the present status of equipment, signature
of responsible persons, etc. In general it secures data
similar to that collected by the inspector on an inven-
tory inspection. Because it is prepared under the
owner's or operator's signature, however, the operator
is legally responsible for the correctness of all informa-
tion furnished.
The second part consists of engineering data nec-
essary for a thorough evaluation of the design of the
equipment in order to determine whether or not the
equipment is so designed, controlled or equipped that
it can operate without violating any provision of the
Rules and Regulations. For this purpose a number of
standardized application instructions have been devised
to collect the data required for evaluation of certain
types of equipment. Such forms not only guide the
applicant in supplying the specific data required, but
also greatly facilitate the engineering review of appli-
cations. For special equipment, or equipment which
requires unique handling, the applicant must supply
data as required from the General Application Instruc-
tions (Figure XIV-19) and by inquiry from the
District.
A separate application must be filed for each
"permit unit" of basic and air pollution control equip-
ment. Upon review of applications, the A.P.C.D. may
require additional information, or regroup equipment
on applications in order that the correct number of
permit units are applied for. A written authority to
construct must be received by the applicant before any
construction, erection, installation, alteration, or re-
placement is undertaken.
The person (corporation, company, lessee, part-
nership or individual owner) operating the equipment
is obligated to file the application, along with a filing
fee of $10.00. In addition to the filing fee, the appli-
cant, when notified by letter, must pay a fee for the
issuance of each permit in the amount prescribed in
Rule 40. The filing fee is applied to the fee prescribed
for the issuance of the permit to operate. This latter
fee is based on the ratings and capacities of equipment
associated in the permit unit. The schedules in Rule
40 are grouped according to the following:
1. Electric motor ratings, in horsepower.
2. Design fuel consumption,in Btu.
3. Electrical energy ratings, in Kva.
4. Incinerator and refuse burner grate size rat-
ings, in square feet.
5. Stationary container capacities, in gallons or
cubic equivalent.
B. Engineering Review
After all such data have been received, the next
step is to determine the actual pollution potentials of
the equipment as a means of determining compli-
ance with the control regulations. This is done by
(1) analysis of the data submitted with the applica-
tion, performing the necessary calculations, determin-
ing capacities, design factors and emission rates, and
(2) engineering field inspection to confirm at first-
hand the performance of such equipment and air
pollution potentials under critical operating conditions.
An application number is assigned to the applica-
tion folder of the permit unit. This folder contains the
applications for authority to construct, permit to oper-
ate, engineering calculations, engineering reports, all
correspondence involved, inspector's permit requests,
inspection reports made with reference to engineering
requests, plot plans, drawings and check sheets for
final inspections, etc., as well as Engineering Final
Reports of visible emissions. These records trace the
process of evaluation, and provide the bases of judg-
ment necessary for approval or denial in each case.
The actual evaluation, of course, involves the various
engineering disciplines, and is beyond the scope of this
manual.
During the final engineering field inspection, the
following steps are taken: *
1. The engineer checks against the blueprint specifications and
other data to determine whether or not the equipment is
exactly aS'shown.Otheriimportant items are also checked off
against a prepared check sheet.
2. The person designated as the operator operates the equip-
ment in the presence of the engineer. The engineer, who is
trained to read visible emissions, judges the opacities
or densities of the emission and otherwise checks the equip-
ment. If there is a problem involving "invisible" contami-
nants, source testing may be required. On the basis of
previous tests, the engineer determines the quantity of
product flow or material and estimates the losses to the
atmosphere, material discharged in pounds per day, with
and without the use of the control device.
In general, the entire cycle of operation, from initiation to
conclusion is observed. If combustion equipment is involved,
it is generally observed from a cold start. All types of
material which would be used by the company in the equip-
ment is run for the engineer. In some instances, the equip-
ment might be purposely over-loaded in order to determine
quantities of contaminants that would be emitted under
extreme conditions.
3. The engineer prepares a final field report in accordance
with the check sheet. Any deviation from applications, plot
plans, etc., are noted.
4. The engineer then writes up a final engineering field report
which (1) describes use of equipment, (2) shows source of
information, (3) accounts for all components, capacities and
materials or fuels employed, (4) analyzes critical phases of
operation, (5) notes total pounds lost of all categories of
pollution, and (6) recommends one of the following:
a. Hold for reinspection.
b. Issuance of conditional permit.
c. Issuance of unconditional permit.
d. Denial of the application.
The engineer is guided by Rule 20 which states
that the Air Pollution Control Officer shall deny an
authority to construct or a permit to operate if the ap-
plicant does not show that the equipment is so designed
or controlled that it may be expected to operate without
emitting air contaminants in violation of the Rules and
Regulations.
Should a denial be indicated, the applicant is
notified and a conference is held between the engineer
* On occasion Engineering Inspectors of the Enforcement Division
perform engineering final inspections, particularly for de-
greasers, spray booths, and multiple chamber incinerators.
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276
Air Pollution Control Field Operations
and the applicant at the volition of either party in
order to discuss the reasons for the denial. If at that
time the operator can modify his equipment, he may
be permitted to do so by altering or modifying the
application. If, however, the application has been
formally denied after direct action by the Engineering
Division, a new application must be filed and the pre-
vious application canceled.
C. Issuing the Permit
Should the engineer recommend that a permit be
issued, his findings are reviewed by a Senior Engineer,
and the actual permit is issued. This permit is assigned
a number, which then remains valid as long as the
operator continues to operate the equipment in compli-
ance both with any conditions which may have been
noted on the permit, and the Rules and Regulations of
the A.P.C.D.
The conditions applied to permits greatly facili-
tate subsequent enforcement. Operation contrary to
conditions of permits is a violation of Section 24280.
If equipment violates Section 24280 and chronically
violates maximum permissible emission standards (in-
cluding public nuisances) legal action can not only be
taken on a number of counts, but the permit itself can
be revoked (see "Revocations or Suspensions of Per-
mits" page 113, Chapter 6). Therefore subsequent
enforcement can often correct for errors in judg-
ment which may have been made in the original grant-
ing of the permit.
D. Evaluation and Planning
It is quite clear from the foregoing that air pollu-
tion control is basically an engineering science. The
data compiled through the process of engineering re-
view can be used to determine with a relatively high
degree of validity and certainty what control standards
and practices are required to achieve the "air quality"
desired by the community. As will be recalled, in a
severe and changing air pollution situation, the stand-
ards necessary to reduce air pollution potentials do not
remain fixed, but change with the community. The
standards also change as new technologies and control
techniques develop. Furthermore, revelations in sci-
entific knowledge pertaining to toxicity may alter air
quality standards, thus changing the entire picture.
A permit system is thus well-adapted to control a
changing and growing problem. An evaluation and
planning operation based pyramidally on a permit-
inventory structure can proceed with the utmost con-
fidence. The permit system, through case-by-case
engineering evaluation, controls the input, relevance
and accuracy of data. Upon this structure, the evalua-
tion and planning staff of the agency puts all data to
their maximum possible use. It may, through special
statistical techniques, keep emission factors up-to-date
for all source categories, and refine limits of statistical
error to facilitate accurate diagnoses and prognoses
of air pollution problems. The data can be used for
continuous maintenance of total pollution surveys, and
hence, improve control standards, not only for legisla-
tion, but for equipment manufacturers as well. The
evaluation staff may also compile extra-engineering
data, especially with regard to the availability and cost
of control equipment and fuels, to demonstrate the
feasibility of proposed control methods. Members of
the staff may also be assigned to the evaluation of new
inventions and special i problems'and to the study'of the
prevention of future air pollution problems.
REFERENCES
1. Chambers, Leslie A., Technical Developments Pertaining to Smog,
presented at the Fourth Annual Waste Disposal and Stream Pol-
lution Conference of the Western Petroleum Refiners Association,
Wichita, Kansas, October 7-8, 1959, Table II on Page 7.
2. Los Angeles County Air Pollution Control District, Administra-
tion of the Permit System, Engineering Division, Pages 3-13,
December, 1958.
3. Los Angeles County Air Pollution Control District, Inspector's
Manual, May, 1957.
4. Duran, A., L. A. Co. A.P.C.D., Enforcement Division, 1961.
-------
Air Pollution Control Field Operations
SUBJECT INDEX
277
Absorption, 48, 50. See, also, Gases
Acidity, measurement of, 207
Acid-sludge burning, Rule 62 exception, 189
Acids, damage from, 206-208. See, also, under separate
entries, e.g. sulfuric acid
Acrolein: as contaminant, 142; properties, 177
Activity: definition, 244; unitization of, 244, 255; industrial
inventory of, 238; classification, 114, 241 Tab XIV-1
243
Activity Status Report: investigative, 104; data source,
115; preparation and use, 244, 245, 247; for permit
status, 254, 255; in refinery and petrochemical inven-
tories, 260-261; Fig. XIV-9, 260. See, also, Reports
Adsorption, 50. See, also, Gases
Address, as item in Violation Notice, 216, 217
Address-location: in inventory, 244; change of, affecting
permit status, 254
Aerial observation, 93, 100, Fig. VI-4, 101, 102
Aerosols:, description, 1-2; in visibility reduction, 4; sig-
nificance in air pollution, 26-30, 142, 143, 153. See, also,
Particulates, Sampling
Afterburners: direct-fired, Fig. 11-13; tangentially-fired,
Fig. 11-14, 47; operation, 48; for hydrocarbons in re-
finery, 53; auto-exhaust type, Figs. II-24, H-25, 55; in
solvent control, 56. See, also, Flares, Waste-gas Incin-
erator, Waste-Odor Incinerator
Agricultural operations: exception to Health and Safety
Code provisions, 63; areas, 95
Air contaminants: in L.A. atmosphere, Tab. 1-7, 26, 30;
concentrations and threshold levels, 32-36, 167; Tab.
1-14, 33; defined in Sec. 24208, 63; relation to combus-
tion, 68; identification, 73, 109, 211-212; maximum
allowable concentrations, 75, 76; invisible, 100; in
Equipment Inventory Master Record, 115; properties,
176-181; portable devices for testing, Tab. XI-2, 185;
inventory classification, 254-255. See, also, entries un-
der individual contaminants
Aircraft industry, 95, 209
Air monitoring: of key contaminants, 33-36, 72, 92; auto-
matic sampling, Tab. 1-16, 34; sampling stations, Fig.
1-10, 33; required by air pollution law, 62; provision of
Regulation VII, 69; nationally, 83; zoning, 39; in re-
search division services, 88; location of stations, 92,102;
instrumentation, 167; control center, 234. See, also,
Sampling
Air pollution: definition, 1; public attitudes toward, 7;
trends, 141. See, also, Sources of Air Pollution
Air pollution configuration: 132, 141-142, 175, 196; in nui-
sance, 195
Air pollution control boards, 60, 85, Tab. V-3, 86, 87
Air Pollution Control Board (Los Angeles County), 63, 64,
69, 86, 88, 126
Air pollution control districts: provision for in Health and
Safety Code, 62-63; unified, 64
Air Pollution Control Hearing Board. See Hearing Board
Air Pollution Control Officer: powers of, 62, 64, 126; pro-
vision for in Sec. 24246, 232; in Regulation VII, 69, 235,
236; in control organization, 87, 88, 89; in revocation
and suspension of permits, 113, 231; in Rule 64, 205
Air pollution levels, 32-36, 72, 74, 84, 241
Air pollution potentials: of metropolitan economy, 1, 26-47;
secondary, 30-36; of equipment, 41; in zoning, 39; in
source registration, 61, 71, 78; in setting control stand-
ards, 75, 77; from inventories, 79; in field operations,
91; as enforcement objective, 93; determination of, 238,
239, 240, 241, 242, 255, 257, 259; from refineries, 255;
as function of registration system, 239-240; recording
on Equipment Lists, 252. See, also, Emission Factors
Air-Quality Standards, adopted by California Dept. of
Health, Tab. 1-1, 3
Air space, characteristics, 7
Aldehydes: in Los Angeles atmosphere, 26, 27, 28, 29, 30;
in smog formation, 31, 33; in smoke, 144; source-
testing of, 174; properties, 177; on-the-spot testing, 183,
185; in odors, 199
Alerts: in smog forecasts, 13, 15; stages, Tab. 1-15, 33,
Tab. 1-16, 34; in Regulation VII, 69, 70; broadcasting of,
102; non-compliance with, 215; notification, Fig.
XIII-12, 234; instructions during, 234-236; termination
of, 236
Alkylation unit, 52, 189, 208
Alloys, in metal melting, 151, 152. See, also, Metallurgical
Industries
Alundum thimble, Fig. XI-6, 173
Ambient air quality, definition, 2, 3
American Conference of Governmental Hygienists, 176
American Society of Mechanical Engineers, (ASME), 76;
power code, 159, 160
American Society for Testing Materials (ASTM), 74; Stand-
ard Methods: Kerosine, D-86-56, 186; gasoline D1159-
57T, 190, D1159-59T, 192; odors, D1391-57, 205
Ammonia, emergency dumping, 91; classified as contami-
nant, 142; source testing of, 173; properties, 153, 177;
on-the-spot sampling, 184, 185
Amortization of air pollution equipment, 39
Animal rendering operations: in food-products industry, 22;
nuisance potential of, 37; problems of control, 40; use of
afterburners in, 48, 205; Rule 64, 68, 205; facilities in
Los Angeles, 96; captive and independent, 200; as odor-
source, 200-201; control of, 205, 206
Appeals, procedure, 62. See Hearing Board
Applications, permit, 249; fee, 275. See, also, Permits
Arsine: properties, 177; testing for, 185
Asphalt: mists, 46; in refineries, 52; air-blowing of, 53;
batch plants, 53, 95, 153; paving plants, 96; manufac-
turing plants, 99; roofing, 99; saturators, 96, 211;
mixes, 213
Assembly Bills, California Legislations, No. 1, 62-64; No.
17, 55. See, also, California State Health and Safety
Code
Atomic radiation, 183
Authority to Construct: in permit system, 79; in applica-
tion denial, 113, 268; in illegal construction, 228; in
source registration, 237; when required, 252; handling
by Engineering Division, 268-275; application for, Fig.
XIV-20, 271. See, also, Permits, Denials
Authorized emergency vehicle, 127. See, also, Emergency
Vehicles
Automobiles: in decentralized communities, 16; industry,
20, 96; damage to finishes, 206, 207; paint spraying of,
209; dealers, 239. See, also, Vehicles
Automobile exhaust: contaminants found in, 28, 30-32; as
source of olefins, 32; control of, 54-56; laboratory, 55,
88; blow-by emissions, 55; fuel cut-offs, 55
B
Baghouses: description of, 45-46, Figs. II-7, II-8, 45; gen-
eral source control, 54; in foundry operations, 152; in
collection of dusts, 213; diagram of, Fig. XTV-5, 249.
See, also, Control Devices
Baking enamel, 208, 209
Bans, on equipment, 215, 231-232, Tab. III-2, 67
Batch processes, 6, 41, 42
Beaufort system, 197
Beckman oxidant recorder, 34, Fig. 1-15, 35
Bee droppings, 183, 210
Bleach manufacturing, 185
Blood-spray dryers, 201
Blow-down vessels, 257
Blower equipment, portable, 197
Board of Supervisors. See Los Angeles County
Boilers: control of, 41; in fefinery, 53; gas-fired, 143; as
smoke source, 145-147; diagrams of, Figs. IX-3, IX-4,
IX-5, IX-6, 145; causes of poor combustion, 146; de-
scription, 218; in ships, 225; types, 239; inventory in-
spection, 242; oil-fired, Fig. XIV-4, 248, 249. See Com-
bustion
Brazing spelter, 152
Bromine, in plume, 142
Bromine Number. See Olefins, tests for
Bureau of Mines, 160; Information Circular 7718 ( as smoke
regulation authority), 155
Buses. See Vehicles
Business management staff, 87, 88
C
Calcination, 151, 152, 153
California, state of, jurisdiction in air-pollution control, 84
California Department of Health: standards for ambient air
quality, Table 1-1, 3; joint project, 52
California Disaster Act, 70
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278
Air Pollution Control Field Operations
INDEX (Continued)
California Government Code, Sec. 24100, 126
California Health and Safety Code, 59, 62-64, 91, 102, 121,
126
Sections:
24198, preamble, 63
24199, findings, 63
24203, public hearing, 63
24204, public hearing, 63
24205, need for A.P.C.D., 63
24208, air contaminants, 63, 144, 197, 227, 253
24223, delegation of powers, 126
24242, visible emissions, 63, 65, 105, 155, 159, 160,
175, 215, 216, 218, 219-226, 225
24243, public nuisance, 63, 139, 175, 213, 225, 227
24245, exceptions from 24242, 215
24246, right of entry, halting of vehicles, 63, 126,
129, 232-233
24251, exceptions from 24243, 63, 215
24253, violation of provisions, 215
24254, governmental exemptions, 253
24263, 24264, permits required, 252
24265, permit exceptions, 64, 215, 253
24269, information from applicant, 252
24276, revocation of permits, 113
24278, operation after revoked permit, 114, 227, 231
24279, construction without permit, 113, 132, 195,
216, 227-229, 237, 263, 264, 265
24280, permit conditions, 130, 195, 227, 229, 276
24281, violation of rules and regulations, 215
24296, variances, 64, 112
California Motor Vehicle Code, 126, 233; in Rule 63, 190;
Sec. 27153, 91, 102, 105, 223; Sec. 120, 102; Sees. 454,
22105, 22107, 22108, 127; Sec. 40505, 223
California Motor Vehicle Pollution Board, 55
Canada, treaty with U. S. on air pollution, 61
Carbon dioxide: presence in atmosphere, 31; combustion
end-product, 144; in calcination process, 152; sampling
and measuring, 172; effect of excess, 176; properties,
178; testing for, 185; collection bottle Fig. XI-5, 172;
threshold values, Tab. XI-2, 185
Carbon monoxide, 153; emission factors, 27, 28, 29; quan-
tities emitted, 30; from catalyst regenerator, 52; from
auto exhaust, 55; California air-quality standards, 3;
quantities in L.A. atmosphere, 31; contaminant level
range, 33; alert levels, 33, 34; automatic sampling of,
34, Fig. 1-14, 35; properties, 178; tests, 182
Carcinogens, 3
Cascade impactor, 169, 170
Case histories, 114, 240
Catalyst: collection of dusts, 46; platinum, 48; burning
residue on, 153
Catalytic cracking, 189; regenerators, 52, 173; units, 262.
See Refining Processes
Caustics: in wet collection, 49, 257; regeneration of, 53;
damage from, 206, 208
Cement manufacturing and handling, 37, 54, 153, 213
Chaney auto sampler, 34
Chemical processing industries, 89, 95, 99, 255; allied prod-
ucts, 21; chem-milling, 208
Chicago, smoke ordinance, 57
Chief Engineering Inspector, 91, 126, 233
Chlorine: as contaminant, 26, 153; flux in fusion process,
152; properties, 178; field testing, 183, Tab. XI-2, 185;
as deodorizer, 206
Chromic acid, 153, 207
Cincinnati, Ohio, 57, 83, 84; Bureau of Air Pollution Con-
trol, 202
Circumvention, 62, 67, 215, 233-234
Citation: preparation, 103, 105, 223; processing, 109; dis-
position of copies, 223; correction request, 223. See, also,
Vehicles, Violations
Citizens' comittees, 59, 62
Citrus grove heaters, 69. See. also Agricultural Operations
Civil defense, 89, 184, 234
Clouds: of pollution, 141, 142, 143; of aerosols, mist drop-
lets, 153
Coal, 17, 41; soft, 39; pulverized, 43; burning, 76
CO-boilers, 52, 53, 206
Coke, 17, 43, 52
Collectors, 44-45; centrifugal, 52; centrifugal wash, Fig.
11-11, 47; gas and vapors, 48-50; wet, 48. See, also,
Cyclones, Control Equipment
Color as detection device: of plumes, 216; gases, smoke,
143, 144; stain length, 185
Colorimetric reactions, 34, 74, 171, 184, 185, 190
Combustible gas indicator, 190; on refinery waste-gas line,
Fig. 1-16, 191
Combustion: as air-contaminating process, 2; equipment,
40, 239; burning cycle, 41; burn-down, 41, 144; pro-
cesses, 123; incomplete, 144; in boilers, Tab. IX-1, 146;
chamber, 147, 151; rate, 151; in smoke-generating
equipment, 161; contaminants, sampling of, 172; con-
taminants, in Rule 53b, 174; contaminants, 176; meters,
184; odors from, 200; in odor control, 205; zone, alter-
ation of, 205. See, also, Boilers, Incinerators
Communications Center, 112; Figs. VI-5, VI-6, 101
Communications Section, 92
Complaint log, 119
Complaint i: in common nuisance, 57; investigation of by
state, 84; as field operations function, 92, 96, 100-102;
source detection through, 93-95; reporting of by in-
spector, 194; interview of complainants, 111, 137, 196,
216; in Patrol Inspector's duties, 125; night investiga-
tion of, 126; responding to general smog, 135-136; in-
vestigation of specific source, 136-139; in nuisance sur-
vey, 197; in tracking sources, 203; in enforcement of
nuisance, 227; sources involved in, inventory priority,
242. See, also, Public Nuisance, Nuisance Complaint
Form
Compliance with air-pollution laws: through source regis-
tration, 62, 78; with grain-loading and gas-volume
standards, 77; status of, 78, 79; as control objective, 81;
voluntary, 82; as enforcement objective, 91; obtaining
representative, 93; determining, 98, 275; changes af-
fecting, 100; as inspector's objective, 121; use of permit
system in obtaining, 239; source coverage in obtain-
ing, 242.
"Condensed fumes," definition, 151
Construction of equipment. See Equipment
Contractor, as responsible party, 216
Control agencies, 83-90, 135; advisory, 83; character of, 88;
levels of jurisdiction, Tab. VI-1, 83; types of, Tab. V-2,
86; organizational pattern of, 87-88; Fig. V-2, 87
Control equipment, 40, 184, 219, 255, 257, 258, 263, 275;
general principles, 43, 44; deficiencies of, 77; in odors,
205, 206; definition, 249. See, also, Equipment, and in-
dividual control equipment entries, viz., Baghouses
Control programs, 50-56; elements of, 72-82; engineering
development, 54; authority and jurisdiction, 58, 60,
61, 84
Control standards, 71; promulgation of, 74-77; legality, en-
forceability, 77; per se, 195, 196
Copper, metallurgy, 151; alloys, 152
Corporation, as responsible party, in reports, 216, 217, 228,
237
Corpus delicti, in inspector's reports, 104, 105; elements of in
violation, 109; determination of in plant inspection, 130,
132; in air pollution configuration, 141, 142; in evidence
of violation, 215; on violation notice, 236
Corrosion, caused by contaminants, 7, 142, 154, 176, 206
Courts, 81; federal, 58; appellate, 58, 108; justice, 108; mu-
nicipal, 58, 108
Court action, 92, 163, 216; complaint, 81, 105, 223; liaison,
92; cases, 108-112, 127; disposition of cases, 115; pros-
ecution of violators in, 107, 215; documents required.
114; jurisdiction of, 216, 223; arraignment, 111; expert
testimony, 109, 215; fines, 219
Crude oil, 52; distillation, 189
Cyclone separators, 54, 153, 213, 258; Fig. H-4, II-5, 44;
high efficiency, Fig. II-6, 44; with electrical precipi-
tators, 46; in contaminant sampling, 169; glass, Fig.
XI-8, 173
Daily Report, Fig. VI-7, 105, 106
Defendants, in court actions, 107; case history, 115
Degreasing, 56, 209
Denial check slip, 113, 268
Denials: as permit status, 254; appeal from, 113; follow-up
on, 103, 132, 268; of permits in Los Angeles County, 79.
See, also. Permits, Applications
Deposits, 195; liquid, 206-213; solid, 213-214
Detroit-Windsor area, 13, 61, 83
-------
Air Pollution Control Field Operations
279
INDEX (Continued]
Dilution capacity: of air space, 29; in zoning, 39
District Attorney, 108; in complaints, 139
District Attorney forms, 196, 213; Fig-. XIII-9, 226, 227. See,
also, Nuisance Complaint Forms
Doing Business As (D.B.A.), 268
Donora, Pennsylvania, smog disaster, 6, 9
Driver's identification, 217
Dumps: cut-and-cover, 26, 51, 95; burning at, 39, 147
Dusts: 26, 36, 155, 195, 213-214; control of, 44, 48; cata-
lytic, 52; in maximum permissible emission standards,
61; Sec. 24208, 63; Rule 4, 68; Ringelmann standard, 76;
loading of, 79, 95; in fumes, 151, 153
Dust fall, 169; collection jar, Fig. XII-8, 212
Dust sampler, 170; in Rule 54, 174
E
Effects of air pollution: 4-7, 83, 142; monitoring of, 33, 34;
analysis of, 73
Effect Areas: 15, 197, 203, 212, 226; in zoning, 39; deter-
mination of in nuisance, 196
Effluent, 142, 143, 155; velocity, 43; sampling, 167; measur-
ing of, 168; system, 197. See, also, Plume, Emissions,
Smoke
Electrostatic Precipitators: catalytic dust collection, 52; in
metallurgy, 54, 152; collection of dusts and mists, 153;
in refinery operations, 258, Figs. II-9,11-10, 46
Emergencies, 91; in field operations, 91, 102; Tab. III-2, 67
Emergency: disaster powers, 84; enforcement of Rule 161,
70; prevention program, 88; responsibility of A.P.C.D.
in Regulation VII, 89; provisions, in air-pollution con-
trol law, 62; Regulation VII, 69-70; regulations, viola-
tion, 234-236
Emergency-Action Committee, 88
Emergency vehicles: need for, 102; inspectors' use of, 127;
on-the-spot test vehicle, 183; in halting vehicles, 233;
Fig. VH-4, 125
Emissions, 219; prohibitions of visible, 67, 190, 216; dilution
of, 234. See Smoke, Plumes
Emission factors, 26-29, 239, 255; fuels, 26; fuels from
stationary sources, Tab. 1-8, 27; automobiles, 26, Tab.
1-11, 28, metallurgic and mineral processing operations,
Tab. 1-9, 28; petroleum refining sources, Tab. 1-9, 28;
petroleum refining sources, Tab. 1-10, 28; of combusti-
ble rubbish, Tab. 1-12, 29; hydrocarbons, 260, 261
Enforcement: of control standards, 50; powers, 62; in con-
trol program, 80-82; agencies, 84-85; specialized, 98-99;
selective, 99-100; summary of data on, 119; actions,
base-line of, 240. See, also, Field Control Operations
Enforcement Division, A.P.C.D., 91-93; functions, 88, 89,
98-100; Director of, 91, 100, 107, 111, 124; organization,
Fig. VI-1, 92; policies of, 126, 127; in alerts, 234
Engineering Division: functions of, 87, 88, 89; source test-
ing, 169; field reports, 219, Fig. XIII-3, 221; registra-
tion, 237; handling of permit units, 250; administration
of permit system, 268-276
Engineering Final Reports, 275
Engineering Inspector, 91, 96, 98; duties of selective en-
forcement, 99; prerequisites, 122; duties of, 125; re-
finery inspection, 125-126, 127
Entry of industrial plants: administrative restrictions, 233;
refusal of, 232-233; right of, 63, 129, 126
Equipment capable of air pollution: design of, 40, 41, 217-
218, 275; control of basic, 41-42, 43; definition of basic,
249; operation cycle of, 40, 41, 76; identification of, 78,
79, 105, 217, 218; failure of, 91, 207; description of, 130-
132; construction, alteration and operation of, 103, 215,
227, 229, 254, 265; inspection of, 196; in violation, 215,
217-218, 231; location of, 239, 248, 251, 252; classifica-
tion of, 240; replacement, 244; process, battery, 248,
250, 251; control, definition of, 249; control, basic com-
binations, 250, 251; non-use of, 254. See, also, Inventory,
Permit, Permit Status
Equipment breakdowns: in Inspector's Report, 104; in dis-
patch files, 119; in refineries, 91, 102, 103, 258, 259; on
ships, 225
Equipment and fuel regulations, 75, 76, 196; in law, 91,
Tab. III-2, 67
Equipment Lists: as descriptive report, 105; filing of, 114,
115; in source registration, 237; in activity classifica-
tion system, 241; preparation of, 242, 244-45, Fig.
XIV-3, 246; plot plan on, Fig. XTV-3.1, 247; name of
responsible party on, 248; nature of business, 248, 254;
order of equipment on, 251
Equipment Units, frequency of inspection based on, 98, 239;
classification of, 241; listing of, 244, 247; definition and
description of, 103, 248-255; identification and location
of, 104, 129
Evaporation, as air-contaminating process, 2
Evidence, assembling of, 109; collecting and reporting, 215-
236; physical, 111; admission of hearsay before Hearing
Board, Rule 86, 112; demonstration, 197, 215, 219; from
source-testing, 167; in public nuisance cases, 195; re-
quired for violations, 219-236; samples of, photographs,
204
Exceptions, 215, 253-254; to Health and Safety Code, Sec.
24245, 24251, 63; Sec. 24265, 64
Excessive emissions, Tab. III-2, 67, 215; in maximum per-
missible emission rate, 75; inside plant, 217; in viola-
tions, 219-227. See, also, Emissions, Smoke
Exhaust systems, 208, 248, 251; description of blower, 218
Explosimeters, 41, 182, 184, 185, 258
Eye-irritation, 6-7, 29, 34, 36; in complaints, 137; in air pol-
lution configuration, 142; from chromic acid, 207; rela-
tionship to contaminants, 31; in smog forecast, 13;
survey of, 73
F-Notice (See Violation Notice)
Fallout, 138, 212; -jars, 169
False documentation, 62
Fertilizer, 200; plants, 213
Field control operations, 71, 91, 108; definition, 91; monitor-
ing, 114; emergency-response capability of, 102; cover-
age, 100; groups, 91-93; work assignments, 93; planning
criteria, 95; in control program, 80-82; of control
agency, 87; coverage: 79, 241-244; saturation coverage,
93, 190, 239, 240, 241; selective coverage, 93, 240
Files, 98; selective analyses of, 92, 98, 203, 239; punch card,
98; administrative, 114; numerical, 114; operational,
114; dispatch, 114, 119; suspense, 114, 119; permit ap-
plication, 114; quick-reference, 115; statistical, 119;
inventory-alphabetical, chronological, 240; cumulative,
252; central, 240; reference, 240, 241. See, also, Inven-
tory, Master Punch Card and Key-Sorting System
Filters, as control devices, 45-46; cloth, 153; in sampling
equipment, 169; dry-type, 207; in paint booths, 209, 210.
See, also, Baghouses
Findings, of investigative reports, 104; review of, 108; in
cause of violation, 217, 218; in Sec. 24279, violation, 229;
Rule 58, violations, 232; on violation notice, 236; on
denial follow-up, 268; of report, 130-132; as to existence
of air pollution, 60. See, also, Reports
Fire department, 83, 135; agreement with, 231; permits, 232
Fire hazards, 40, 63
Fish-processing plants, 95, 200, 205; control of, 48
Flare, 48, 52; Figs.. 11-21, 11-22, 53; pilot lights, 257
Floating roof, Fig. H-15, 47; Fig. 11-16, 49; 48, 52, 68;
double-deck type, 186, 257, 258
Flow Chart, 213, 251, 259; Fig. XIV-10, 261; symbols used,
Fig. XIV-11, 262
Flow processes, of equipment, 105, 218, 229, 255
Fluorides, 142, 153, 208
Fluxes, 152
Fly ash, 151, 195, 213
Food-products industries, 22
Formaldehyde, 142; as eye-irritant, 31; measurement of,
174; properties, 177
Foundries, 37, 152, 211; odors from, 200; aluminum, 96;
brass, 96; steel, 96; steel mills, 37-40; steel smelting,
169. See, also, Furnaces
Fuel, 144, 175; determining heat value of, 190; composition,
control, 43; in air pollution configuration, 142; economy,
16-17; preheaters, 41; improper use, 41; sampling of,
167, 190; regulation, 61; sulfur content, 189-190; in
crude, 154; sulfur content, in Rule 62, 68; solid, liquid,
gaseous, 17, 257; viscosity, 41; distillates, 17, 43; jet,
186, 189. See, also, Natural Gas
Fuel oils: residual, 43; specifications of, 190; burning of,
145-147; plumes from, 143
Fuel-oil consumption in Los Angeles, 17, Tab. 1-6, 25
Fume-burners. See Afterburners
Fumes, 4, 26, 36, 40, 155; control of, 48; metallic, 19; control
in metallurgy, 45; of metallic oxides, 46; sampling, 170;
in Rule 54, 68, 174; in common nuisances, 57, 59; Sec.
24208, 63; ground concentration, 76; Ringelmann stand-
ard, 76; accidental emission, 91; plumes, 143, 151-153
-------
280
Air Pollution Control Field Operations
INDEX (Continued]
Furnaces, electric-steel, Fig. H-2, 42; brass, 218; Fig. XTV-5,
249; zinc distillation, Fig. IX-18, 152; observation of,
220; Bessemer, 46; description of, 248; open hearth,
46; reverberatory, Fig. H-3, 42, 249. See, also, Foundries
Fyrite tester, 178; COS and O2 analyzer, 182, 184, 185
G
Galvanizing, 151; kettle, Fig. IX-19, 152; plants, 96
Gas-absorption cells, 184
Gas chromatography, 74
Gas sample bottle, 172, 190; on waste-gas line, Fig. XI-18,
191, Fig. XH-5, 204
Gaseous fuel, Rule 62, testing of, 189, 190. See, also, Fuels
Gasoline: storage of in Rule 56, 186; survey of natural gas-
oline, 265; absorption plants, 99; aviation, 32, 52, 186;
consumption in Los Angeles, 17, 25; determining un-
saturates of, 55, 190, 192-193, Fig. VI-19, 192; filling
stations, 263; fumes effect, 176; loading into tank
trucks and trailers, 52, 189; Rule 61, 68; production, 95;
stabilization, 189; vapors, 154; Rules, definition of, 190;
specifications, Rule 63, 68, 190; octane rating of, 52
Gas-absorbing media, 50
Gases: absorption of, 44, 48, 189; accidental emission of
poisonous gases, 91, 142; adsorption of, 48, 171; anal-
ysis, 174, 175; containing hydrocarbon solvents, 56;
control of dilute concentrations, 40; description of gas-
eous contaminants, 153-154; detection and measure-
ment, 168-169; emission factors of gaseous contami-
nants, 26, 29, 30; high-pressure storage, 186; in plumes
and effluents, 142-144; maximum permissible emission
standards, 61; measurement of combustion contami-
nants, 172; on-the-spot testing, 183, 184, 185; sampling
of, 171, 204; significance in air pollution, 2; specificity
of collection methods, 44; waste-gas incineration in
odor control, 205. See, also, Sampling Procedures, in-
dividual gases
Geiger counters, 128, 184
Glass-container manufacturing, 54
Grain and feed mills, 22, 96, 213
Grain loading, 61, 77, 79, 155, 167; in Rule 58, 68; determi-
nation of, 169
Greenburg-Smith impinger, 169
H
Halide leak detector, 182, 184
Hazards, 176, 177; response to, 91. See, also Emergencies
Haze, 143-144
Head Engineering Inspector, 91, 98, 232
Health departments, in air pollution control, 83, 86, 87
Hearing Board: as air pollution control authority, 62; rights
of applicants before, 80; in A.P.C.D. organization plan,
85,88; cases before, 108; petitioning, 113, 268; review
of denial, 133 268, Regulation V, 68; handling of cases,
112-114; filing of documents from, 114. See, also, Vari-
ances, Denials, Permits
Hydrocarbons: description and classification, 31-32; in Cal-
ifornia air, 26-30; air-quality standards for, 32, 33;
emission from refineries, Tab. XTV-2, 260; sampling,
174, 199, 201, 257; vapors, 52, 53, 184; damage to veg-
etation, 6; unsaturated, 55; chlorinated, 26, 56, 184
Hydrogen chloride, 153; in public nuisances, 207
Hydrogen cyanide, 153; properties, 179; on-the-spot testing
of, 183, 185
Hydrogen fluoride, 153; control of, 50; in nuisance cases,
208; tests, 182, 185; properties of, 177
Hydrogen sulfide: absorbers, 50, 190, 258; control, 48, 50;
properties, 179; testing, 182, 183, 184, 185; in Rule 53,
175, in Rule 62, 189; tests, 190; in grain-loading, 258;
test for at refinery site, Fig. XI-17,191; from refineries,
54; as coal gas, 153, 154; in odors, 199, 201; as deposits,
206; in waste-refinery effluent, 257
Impingers, 169, 171, 172, 212
Incineration of rubbish, 26, 51, 147
Incinerators: single-chamber, elimination of, 39, 51, 144,
147; multiple-chamber, "in-line", Fig. H-l, 42, Fig.
IX-15, 149, retort, Fig. IX-16, 149; operating instruc-
tions, Fig. DC-17, 150; in apartment houses, 48; in
Rule 58, 68, 232; in court cases, 111; box-type, 147, 148;
flue-fed, 147, Figs. DC-13-14, 149, 205; types, 147-151,
Figs. K-9-12, 148; municipal, 147, 148
Industrial Engineering Inspection Section, 92, 98, 125
Information, from plant operators, 78; failure to supply,
113; from interview, 124; confidential industrial, 127
Infrared spectrophotometry, 34, 74, 174, 203
Injunction, 71
Inspection: of equipment sources, 81, 82, 88, 91, 92; fre-
quency of, 93, 98, 115, 238-239, 242, 247; inventory, 98;
of ships, 98; in control program, 80-82; of agricultural
burning, 99; inventory, follow-up, reinspection, com-
plaints and miscellaneous, 103; reporting of, 104-105;
conduct of, 128-133; of equipment, 129; technique, 122;
tabulation of activities, 119-120; scheduling of assign-
ment, 241; coordinated, 212, 219-222; engineering field,
275; of refineries, 255-263; elapsed time of, 216; follow-
up, 100. See, also, Complaints, Inventory, Reinspection,
Violations
Inspection Unit, defined, 240
Inspectors, in field operations, 96, 121, 133, Fig. VII-1, 122;
duties of, 111-126, 167; public health, safety, 121; qual-
ifications of, 123; in court, 111; training of, 123, 124,
Tab. VII-1, 124, in smoke reading, 163, 166; powers of,
126; field equipment of, 127-128; ethics of, 127; as wit-
ness in nuisance, 226; in identifying plumes, 141; co-
ordinated inspections, 219; right of entry of, 10; con-
duct in inventory inspection, 242; refinery, 255, 257
Inspector's Daily Report, 240
Inspector's kit, Fig. VII-6,128
Inspector's Report, 92, 104, Fig. VII-7, 131; in variances,
109, 112, 137, 226, 264, 268. See Reports
Inspector's Questionnaire for Steamships, 104, Fig. XIII-7,
225
International Joint Commission, Windsor-Detroit area, 61
Interstate compacts, 61, 83
Inventory: of equipment, 79, 91, 92, 98, 99, 238-268; inspec-
tion, 96, 103, 105, 128, 131, 203; records, 114, 203, 240,
252, 255; master record, 115, Fig. VI-15, 118; by indus-
trial inspectors, 125; by patrol inspectors, 125; data on,
129, 237; of area, 238, 244; calendar, 238; itemization
in, 239, 240, 250, 251; nonsource card, 245, 247; of
process vessels, 255, 259; refineries, petrochemical, 255-
263. See, also, Equipment Lists, Filing, Inspection
Inventory Cycle, 238, 239, 242
Inversion. See Temperature Inversion
Investigation Detail, 92, 107, 108, 109
Invisible contaminants: defined, 167; in violations, 226
Ion chambers, 128, 182, 184
Kerosine, 17, 52, 186; lighter-oil treating, 189. See, also,
Petroleum Products, Reid Vapor Pressure
Kiln operations, 21
Key sorting files, 98, 155, 203; Fig. VI-13, 115
Ketones, quantities emitted to L. A. atmosphere, 26-30
Kjeldahl distillation, for ammonia determination, 173
Laboratory methods, employed by District, 73-74
Lacquer thinners, in paint nuisances, 56, 209
Law, construction of on air-pollution, 60-62. See, also, Pub-
lic Nuisance, Legal Aspects
Lead, 151; alloys, 152; -based paints, 176; in California air-
quality standards, 3; oxide emissions, 22; effect on
vegetation, 6; in paint products, 208
Legal Advisory Committee, for citizens' smog committee, 62
Legal aspects, air pollution control, 57-59. See, also, Courts
Legal standards. See Control Standards
League of California Cities, iri air pollution control, 62
Licensing, of sources, 61-62, 79-80
Light-scattering, by aerosols in visibility reduction, 2, 4
Light sources, of plume, 163, 165, 166, 222
Liquefied Petroleum Gas (L.P.G.), 17, 32, 43, 184, 186, 189
Lithographic ovens, control of vapors from through after-
burners, 48
Los Angeles Basin, 23, 95, 100; population density of, 17;
defined by Rules and Regulations, 24; jurisdictional
areas of, Fig. V-l, 85
Los Angeles County, 71, 83, 84, 85, 95; population density
of, 17; industrial activities, 19; economy of, 23-26; pol-
lution zone of, 23; population and industrial growth
trends, 23; vehicle registration, 23-24, Tab. 1-4, 23; cur-
rent statistics for, 25; public sources of pollution in, 51;
early control jurisdictions, 62; industrial areas of, 95
-------
Air Pollution Control Field Operations
INDEX (Continued)
281
Los Angeles County Air Pollution Control District, 61;
activation of, 64; organization, 88-89, Fig. V-3, 88; jur-
isdiction, 23, 95, Fig. VI-2, 94
Los Angeles County Air Pollution Control District, Rules
and Regulations of, 64-70, 91; effect of on emissions
from stationary sources, 65, Tab. III-l, 66
Regulation I— General Provisions, 64
Regulation II — Permits, 64-65
Regulation III — Fees, 65
Regulation IV — Prohibitions, 65
Regulation V — Hearing Board, 68-69
Regulation VI — Orchard or Citrus Grove Heaters,
69
Regulation VII — Emergencies, 69-70, 92, 95 102
234-236
Rule2b— Person, 216
Rule 2j — Process Weight per Unit Hour, 174
Rule 2k — Dusts, 153
Rule 21—"Condensed Fumes", 151
Rule 2n — Atmosphere, 217
Rule 3 — Temperature and pressure, 168
Rule 10 — Permits Required, 104, 113, 130, 227, 237,
250, 252, 254, 255, 259
Rule 11 — Exemptions, 215, 227, 250, 253-254
Rule 12 — Transfer, 227, 252, 254
Rule 13 — Blanket Permits, 99, 113, 195, 215, 227,
252, 254
Rule 14 — Applications, 227
Rule 18 — Action on Applications, 227
Rule 19 — Sampling Facilities, 196, 227
Rule 20 — Permit Standards, 227, 275
Rule 21 — Conditional Approval, 227
Rule 22 — Denial of Application, 227
Rule 23 — Further Information, 227
Rule 24 — Applications Deemed Denied, 227
Rule 25 — Appeals, 227
Rule 40 — Permit Fees, 275
Rule 50 — Ringelmann Chart, 65, 76, 151, 213. See,
also, Calif. Health and Safety Code,
Sec. 24242, and Public Nuisance
Rule 52 — Particulate Matter, 67, 151, 169, 174, 196,
213, 226
Rule 53 —Specific Contaminants, 68, 151, 169, 171,
174, 175, 176, 185, 196, 213, 226
Rule 53.1—Scavenger Plants, 68
Rule 54 — Dusts and Fumes, 68, 151, 169, 174, 175,
196, 213, 226
Rule 56 — Storage of Petroleum Products, 68, 184,
186, 231, 255, 259, 262
Rule 57 — Open Fires, 13, 16, 68, 95, 196, 218, 231
Rule 58 — Incinerator Burning, 68, 95, 196, 231, 232
Rule 59 — Oil-Effluent Water Separator, 68, 184,
186, 189, 231, 255, 259, 261, 262
Rule 60 — Circumvention, 233-234
Rule 61 — Gasoline Loading into Tank Trucks and
Trailers, 68, 231, 255, 259, 261
Rule 62 — Sulfur Contents of Fuel, 68, 100, 175,
184, 185, 189, 196, 226, 231, 255
Rule 63 — Gasoline Specifications, 55, 68, 184, 190,
193 231
Rule 64 — Reduction of Animal Matter, 68, 184,
196, 205, 226, 231
Rule 86 — Evidence, 112
Rule 154.1—Plans, 235
Rule 155 — Declaration of Alert, 234
Rule 155.1 — Notification of Alerts, 234
Rule 155.2 — Radio Communication System, 70,
234-235
Rule 156 — Alert Stages for Toxic Air Pollutants,
33, 34, 234. See, also, Alerts
Rule 157 — First Alert Action, Rule 158 — Second
Alert Action, Rule 159 — Third Alert,
70, 235-236. See, also, Alerts
Rule 161 — Enforcement, 70, 234
Los Angeles County Board of Supervisors: role in develop-
ment of air pollution control legislation, 62; delegation
of powers from state legislature, 63, 64; comprise Air
Pollution Control Board, 86
Los Angeles County Counsel: development of control leg-
islation, 62; legal adviser to the District, 108
M
Machinery manufacturing, 19
Management, of industrial plant, interviewing, 128, 218
Man-hour availability, 109
Manufacturing industries, Tab. 1-3, 19, 125
Master Control Log, 107
Master Control Record System, 115
Master Punch Card and Key Sorting System, 98. See also
Files
Material balances, 259
Maximum Allowable Concentrations (M.A.C.): obligation
of government to set up, 50; for atmospheric contami-
nants, 75; use in industrial hygiene and air-pollution
control, 176
Maximum Permissible emissions, 57, 155; mathematical de-
terminations, 75-76. See, also, Control Standards
Meat-packing plants, 48; slaughter houses in, 200
Mercaptans: as atmospheric contaminant, 142; treatment
through combustion, 53; odor and source, 154, 183, 199,
201. See, also, Sulfur
Metal fabricating plants, as source, 19, 96, 209
Metallurgical industries, 19, 40, 41, 51, 54, 153; ferrous
metals, 99; fumes from, 151; furnaces in, 42, cost of
controls, 71; operations, 199; process relative volatili-
ties of non-ferrous metals, Tab. IX-2, 152; yellow brass,
152; in Rule 62, 190; melting temperatures of alloys,
Tab. IX-2 152; secondary metal plants, 96; smelting, 19,
152
Meteorological code, Fig. XII-2, 197
Meuse Valley, Belgium, smog disaster, 6, 9
Midget impingers, 169, 170, 184, 185. See, also, Impingers
Mineral process industries, 21, 37, 54, 153, 213
Mining industry, 20
Mine Safety Appliances (M.S.A.), 184, 185, 190, 204; hydro-
cyanic gas, 179; hydrogen fluoride, 179. See, also,
Sampling
Misdemeanors, 57, 62, 108, 229, 236; H&S Code, 63
Misdemeanor Complaint, 107, 108, 109, Fig. VI-11, 110
Mist droplets, 206, 211; in paint, oil, grease, 208-211
Mists, 22, 153, 155, 184, 207, 211-213; acid, 206, 207, 201,
208, 212; caustic, 208; chromic acid, 207; control of, 46,
48; Ringelmann Standard, 76
Monthly Accomplishment Report, 119, Fig. IV-17, 120; sum-
mary of activities, 119, Fig. VI-18, 120
Motor Vehicles. See Vehicles
N
Natural gas, 17; use of in Los Angeles County, Tab. 1-6, 25;
43, 143, 184, 190. See, also, Fuels
Natural gasoline, Gas and Cycle Plant Survey, Fig. XIV-16,
265
New Jersey, 61, 83; Air Sanitation Division, 87
New York City, Department of Air Pollution Control, 60,
71, 83, 84
New York-New Jersey-Washington, D. C., pollution zone, 23
New York-New Jersey area, 13
Nitrogen oxides, 2, 40, 42, 52, 55, 69, 145, 153; in California
air-quality standards, 3; control of, 50; sampling of,
168, 174; quantities emitted to L. A. atmosphere, 27-30;
in photochemical process, 31, 32; contaminant level
range, 33; alert stages, 33, 34; automatic sampling of,
34, Fig. 1-13, 35; contaminant effect, 142; on-the-spot
testing of, 185; determination of, 174
Nitrogenous compounds, 199
Nitric acid, 207
Noncooperation, 62, 215, 232-233
Nonferrous industries, 19, 96, 99, 152. See, also, Metallurgi-
cal Industries
Notice of Violation. See Violation Notice
Nuisance, 155; absolute, 57, 60; complaint form, Fig. XIII-9,
226; common-law, 57; deposits, 206-214; common, in
England, 71; potentials of plumes, 143; surveys, 197.
See, also, Public Nuisance
O
Observation, of sources, 103; of plant exterior, 128; time of,
166; of emission, 219; end of, in violation, 219
Observation Sheet, 219; Fig. XIII-2, 220; 221, 222
-------
282
Air Pollution Control Field Operations
INDEX (Continued)
Odors: general problems in air pollution potential, 36; in
common nuisances, 57, 196; in Sec. 24208, 63, 91, 95,
142, 143; in handling complaints, 137; in public nui-
sance, 195; in control standards, 196; most frequently
reported, Tab. XII-1, 200; dissipation of, 203; control
of, 205-206
Odors, types and sources of: animal rendering, 22, 200, 205;
from refineries, 53, 257; from agricultural operations,
63; of selected contaminants, 177-181; characteristic,
199, 201; description of, 201-203; classification of, 202;
odor chart of, Fig. XII-4, 202; from chrome plating,
207; of paints, 208
Odors, physiology of: odor threshold defined, 176, 205;
sensitivity, 197-198; as warning agent, 199; definition
of, 199; perception of, 199; fatigue in, 201, 204
Odors, measurement of, 201-203; survey of, 73; with port-
able sampling equipment, 185; of quality, 196, 199, 201-
202, 203, 204; of odor route, 199, 203, 204; of intensity,
201, 202-204, 196, 199, 204-205; odor unit defined, 201;
pervasiveness, 201; sampling apparatus, Fig. XII-5, 204
Oil burners, 145-146; Figs. IX-7, IX-8, 146; atomizing type,
146, 147. See, also, Boilers
Oil-effluent water separators: vapor recovery from, 48, 52;
regulated by Rule 59, 68, 186; refinery inspection of,
257; Fig. 11-17, 49; Fig. XI-14, 188; Fig. XIV-14, 264;
inspection of, 261-262
Oil refineries. See Refineries
Oil refinery and petrochemical inventories, 255-263
Olefins, 31, 32; in reforming process, 52; exhaust studies,
55; test for in gasoline, 192
On-the-spot sampling: in emergencies, 102, 167; training in,
124; procedures, 183-185; during alert, 236. See, also,
Sampling
Opacity: of smoke and fumes, 155, 159, 175; of dust, 213;
and densities, 109, 216; of visible emissions, 65; detec-
tion systems, 161-163; definition of, 160; in maximum
permissible emission standards, 61; point of maximum,
142, 143; reading, 163, 166; standard, 76
Open fires, 99, 147, 219, 231-232, 235; brush fires, 143;
elimination of, 39; weed burning, 101; Rule 57, 68; in
court cases, 111; description of, 218. See, also, Rule 57
Operation and maintenance practices, 129-130; in control of
equipment, 40-41, 227-231; effect of volume production,
40; at refineries, 257-258; in violation, 215, 218, 219
Organic acids, 2; quantity emitted to L.A. atmosphere, 28,
31; sampling of, 173; —and inorganic acids, 26; halides,
183; peroxides, 206
Organic solvents, 56, 96, 153, 263; control of, 48, 50; mists,
19; consumption in L.A. County, 25; handling of, 40; in
paints, 208, 209, 210
Orsat analysis, 172. See, also, Gases
Ownership, of air pollution equipment, 78, 104, 107, 109, 216,
254; change of, in zoning cases, 40; identification of,
109; data, 105, 247-248; individual, 217, 228; subsidiary,
217; data, refineries, 259; of plants, 129; partnership,
216, 217, 228; status of, 228; of ships, 224, 225; situa-
tions, change of, Tab. XIH-1, 228. See, also. Equip-
ment, Responsibility Permit Status of
Oxidant: in Calif, air-quality standards, 3; as smog index,
32; contaminant level range, 33; automatic sampling of,
34; Fig. 1-15, 35; precursor, 35. See, also, Ozone, Nitro-
gen oxides
Oxygen: deficiency, 180, 183, 185; in photochemical process,
31; in combustion, 144; as property damage, 7; proper-
ties, 180
Ozone, 2, 69, 142, 153, 176, 185, 206; high altitude formation,
2: in California air-quality standards, 3; photometer,
32, 34; properties, symptoms, toxicity, tests for, 180,
181; as photochemical end product and oxidant, 31, 32;
contaminant level range, 33; alert stages, 33, 34
Paints, 154, 199; thinners, 56, 189; lead-based, 206; binders,
pigments, 208; drying rate of, 208; primers, 208, 209;
spots from, 208-210, 212; water-based, 208-209; enam-
els, 209; nuisance properties of, Tab. XII-2 209. See,
also, Solvents
Paint spraying, 153; open, 209, 210; booths: filter type, Fig.
XH-6, 210; 125, 209, 239; permit application for, 274;
wet type, Fig. XH-7, 210
Paint, varnish and related industries, 48, 96, 99, 205, 208;
odors from, 200
Paper and allied products manufacturing, 22
Particles, liquid, 1, 26, 195; collection of by control devices,
40, 43-48; conglomeration of, 43; impingement of, 43;
electrostatic precipitation of, 43; size of, 167, 169, 173
Particulate matter, Sec. 24208, 63; Rule 52, 67; legal defini-
tion, 68, 144
Particulates: size of, in air pollution, 1, 2; in California air-
quality standards, 3; automatic sampling of, 34, Fig.
1-12, 35; control of, 43, 48; properties of, affecting con-
trol design, 43; (Km) levels of, 33; measurement of,
168; sampling of, 167, 169-171, Fig. XI-10, 182; samp-
ling train for, 173; in Rule 54, 174; tracking of liquid,
206, 2111-213. See, also, Sampling, Aerosols
Patrol, in field operations, 81, 82, 88; surveillance, 93, 95
Patrol inspectors, 91, 92, 96, 98, 124; prerequisites, 122;
Fig. VII-2, 123; duties, 124-126; Fig. VII-4, 125, 127
Patrol Section, 98
Peace officer, 126, 127
People v. International Steel Corp., 65; People v. Plywood Man-
ufacturing Co., 65; People v. Shell Oil Co., 65; People y.
Southern California Edison Co., 65; People v. Union Oil
Company, 65
Permit System: Provisions of Regulation II, 64-65; re-
quirements, 79-80; administration, 88, 268-276; pro-
cedures outlined by H&S Code, 227-231; administration,
238; exceptions, 253-254; in control law, 61-62; infrac-
tions, 98; enforcement provisions, 268-276; registration
of air-pollution sources, 237
Permit applications: failure to submit, 62, 268; denial of,
113; engineering review of, 237, 275-276; effect of in-
ventory on submission of, 238; as permit units, 249,
250; A.P.C.D. Request for, 263; extension of time to
submit, 264; in engineering, 268-275; instructions, Fig.
XIV-19, 269-270; instructions for specific equipment,
Fig. XIV-21, 272-273; for spray booth, 274. See, also,
Denials
Permit to Construct and/or Operate air-pollution equip-
ment: fees for, 65, 227, 250, 275; A.P.C.D. Request for,
103, 104, 109, 132, 227, 229, 263-268, Fig. XIV-17, 266,
Fig. XIV-18, 267; follow-up on, 264; suspensions of,
113, 231; conditions, 195, 229, Fig. XIII-10, 230; in ren-
dering equipment, 205; sources exempt from, 237, 253-
254; sources requiring, 237, 252; blanket, 252; transfer
of, 252; issuance of, 276. See, also, Authority to Con-
struct
Permit status: in follow-up inspections, 104, 132, 264; re-
porting, 105, 130; in identification of equipment, 217,
218; in violations, 227-229; reference, inactivity classi-
fication system, 241; as affected by ownership, 248; of
equipment units, 252-254
Permit Unit, 249-250, 275
Permit violations: suspensions and revocations, 82, 231;
follow-up on, 103; court handling of, 109; hearing board
cases, 112-114; public nuisance cases, 195; reporting,
227-229; risk of, to management, 238
Peroxides, organic, as photochemical product, 31
Persons: legal definition of, 275; in violations, 215, 216-217,
219
Petroleum and Petrochemical Industry, 17, 25, 208. See,
also. Refineries
Petroleum products, 20, 52; bulk loading stations, 96, 99;
lubricating oils, 52; bulk plant data, 259, Fig. XIV-13,
264; storage and handling, 48; marine terminals, 96,
98, 99, 259; manufacturing of, 99; breathing losses, 48,
257; storage of, Rule 54, 68; loading facilities, 189;
storage, 186; loading rack, 53, 259, 261. See, also, Vapor
Recovery System
Phosgene: as minor atmospheric constituent, 153; detection
of with test papers, 183-184; properties, 181
Phosphine, 185; properties, 181
Photochemical smog reactions, 31, 206
Photoelectric cells, 34, 159, 161, 163
Photoelectric smoke detection equipment, 41
Photographic analysis, 73
Photographs, 128, Fig. VII-5, 128; in obtaining evidence,
166, 209, 219, 222
Physiological response, 2, 6-7, 137, 167, 176-181. See, also,
Toxicity
Plant Card, 257, 259
Plant layout, 197, 251, 252
Plant operators, 138-139
Plastics industry, 21, 99, 200
Plating processes, 185, 201; chrome—, 22, 153, 207
Plating tank, hard-chrome, Fig. Xn-5, 207
-------
Air Pollution Control Field Operations
INDEX (Continued)
283
Plea, "not guilty," 111
Plot Plan, 251, 252, 259, 275, Fig. XTV-3.1, 247
Plumbing metals, 152
Plumes, 52, 155, 175, 214; formation and photographic anal-
ysis, 73, 76; aerial observation of, 100; identification,
141-154; definition, 142; Fig. IX-2, 143; types of, 144-
154; sulfur trioxide, 153, 154; colored, 160; detached,
142, 143, 153, 154; invisible contaminants, 167; fumiga-
tion from, 143; wind direction in, 165, 166; dissipation,
point of, 213; observation of, 163, 166, 216; in violations,
219; from ships, 224; effect of light transmission, 155,
159, 160, 165. See, also, Smoke
Point observations, 203, 205, 212, 219; from source, 216
Policies, 107, 126-127; public policy, 135
Police powers, 57, 58; delegated to states, 60
Pollution zone: defined, 15; jurisdiction, 84; field control
operations in, 91, 95, 96, 100; inventory of, 238; regula-
tion of, 60
Population densities, of major cities, 15, Tab. 1-2, 17
Pottery and ceramic manufacturing, 213
Power Plants, 24, 40, 54, 95, 96, 154, 214; sampling at, 169,
175; burners used, 147
Poza Rica, Mexico, 6
Precipitators, thermal, 171
Primary and Secondary Activity Classifications System,
114, 115, 243, 244
"Prima-facie case: definition of, 109; notices of violation in,
103, 104, 109; establishing of, in field, 215-219
Printing and Publishing, 22; rotogravure presses, 56
Private residence, 232
Process Weight, 174, Tab. XI-1, 174
Prohibition, 239, 240; types, 67
Property damage, 7,137
Prosecution of violators, 82, 108-112
Public Information and Education, 51, 87, 88, 135-136, 138,
139; relations with industrial plants in, 100; public re-
lations of inspectors, 123
Public nuisance: influence of pollution zone on, 15; as pollu-
tion potential, 36-37; in common law, 57-58; local enact-
ments, 60, 61; Sec. 24243, 63, 67, 213; Rule 51, 65, 67, 76,
77; application of permit system in, 96, 99, 103; data
from complainants in, 137; investigation of complaints
in, 138-139; physiological response in, 177; "consider-
able number of persons," 195, 226; as enforcement
problem, 195-197; multiple sources in, 195, 213;
employer-employee situation, 206; from paints, 209;
violations, 226-227; at refineries, 235. See, also, Com-
plaints, Sources of Air Pollution
Public opinion, 59
Pumps, 154, 259; centrifugal, 53
Pyrometers, 41, 205
R
Radioactive contaminants, 18, 197; emergencies arising
from, 89, 102; monitoring of, 184
Radio communications system, 100, 102, 234-235; in Rule
155.2, 70; transmitter, 92, 101, 102; Radiophone Mes-
sage Log in, Fig. Vin-1, 136; 101, 119. See, also, Regu-
lation VII, Emergencies
Radiological Defense and Disaster Service, 89
Recorder chart, of air-sampling device, 34. See, also, Air
Monitoring, Sampling
Record systems, 114-119. See, also, Files
Refinery Check Sheet, 259
Refineries: as contaminant source, 154, 175, Tab. XIV-2,
260; control of emissions, 52-54; fuel usage, 95, 190;
inspection procedure, 125; in L. A. County, 96; natural
gasoline plants, 262; role in industrial economy, 17, 25,
208; sampling procedure, 169; tail gases, 153, 175;
throughput capacities, 95, 255, 258, 259; tracing efflu-
ent water from, 189, 257; violations, 218
Refinery and Chemical Inspection Section, 92, 98, 99, 2.66
Refinery air-pollution control methods: afterburners, 47,
48 53, 56; electrostatic precipitators, 46, 52, 258; oil-
effluent water separation, 186, 187; smokeless flares,
48 52 53, 257; sulfur-recovery plants, 54, 68, 153, 258;
vapor recovery, 48-50, 189; waste-heat boilers, 52, 53,
206
Refining processes: alkylation, hydrogenation, hydroform-
ing, isomerization, reforming, platforming, polymeriza-
tion, 52; flow sheet of, Fig. XIV-6, 256; distillation, 151;
sour gases from, 201, 203, 257; sour-water oxidizing
unit, 261, Fig. XIV-10, 261; sour-water stripping opera-
tions, 190; thermal cracking, 189, 262; light-oil redis-
tillation, 189
Regulation VII, 33, 34. See, also, Emergencies, L.A. Co.
A.P.C.D.
Reich Test, for sulfur dioxide, 184, 185
Reid vapor pressure, 186, 189, 262; bomb and gauge, Fig.
XI-11, 186
Reinspections 132-133, 211, 242, 244, 245, 252; date due, 115,
211; record of, 105. See, also, Inspection, Inventory
Rendering.. See Animal Rendering
Reports: types of field operations, 104-105; conclusions in,
104, 132; investigative, 104, 236; statements, 104, 132,
217, 218, 265; descriptive, 105; review and disposition
of, 105-108; inconclusive and terminal, 107, 108; referral
of, 108; inspection, filing of, 114; falsification of, 127;
writing of, 130-132; heading of, 130; of odor nuisances,
205; in gathering evidence; 215; elapsed time in, 216;
"Re Premises at:" in, 216; Time of Arrival in, 216; fic-
titious name in, 217; "His Remarks," in,217; of permit
—follow-up, 265-266; remarks in, 265. See, also, Activity
Status Report, Citations, Equipment Lists, Inspector's
Daily Report, Inspector's Report, Inventories, Violation
Notices
Request to Apply for A.P.C.D. Permit, 263-268. See, also,
Permits
Request for Complaint, court, 107, 108, 109, 111; Fig. VI-10,
110. See, also, Courts
Request for Complaint, vehicle violations, 224. See, also,
Vehicles
Request for Test and/or Analysis, 175; Fig. XI-9, 176
Research, 37, 71-74, 83; functions in control agency, 87, 88,
89
Respiratory diseases: related to air pollution, 6, 137; from
selected toxic contaminants, 176-181
Responsibility for air pollution equipment: corporation, in-
dividual, 104, 236; of lessee, 254. See, also, Ownership,
Person
Revocation. See Permits
Ringelmann Standard, 58, 61, 155, 157, Fig. X-2, 158, 167,
Sec. 24242, 63; Rule 50, 65; determination of panel
standards, 76, 77; as evidence, 111, 112, 160. See, also,
Smoke
Rock and gravel crushing, 54, 213
Roofing industry, 54, 213
Rubber products manufacturing, 21
Rubbish: burning of, 51, 69, 95, 143; collection services, 51,
151; pick-up truck, Fig. 11-20, 52; combustible, 232
Rules and regulations, of local agency, 60, 61; Article 4,
Calif. H&S Code, 64; in court cases, 109. See, also, L.A.
Co. Air Pollution Control District
Sampling and testing of air contaminants: of stack gas,
73, Fig. IV-1, 73; filter device for aerosols, 147; efflu-
ents and fuels involved, 167, 184-193; use of probe in,
168, 175, 190, 204; measurement of velocity of stack
gas, 168, Fig. XI-1, 168; sample collection bottle, Fig.
XI-2, 168, 171, 175, 190, 203, 204; sample line, 168, 169;
sampling point, 169; electrostatic devices in, 170, 171,
212; portable devices for, Fig. XI-2, 170, 183-184, Fig.
XI-10, 182, Tab. XI-2, 185; freeze-out methods, 171, 203;
of specific contaminants, 174; at stationary facilities,
175, 196; test papers in, 178, 181, 182, 183, 184, 185,
207; measurement of gas volume change in, 184; field
time required to test, 185; sampling conditions in nui-
sance, 197; of odors, 204-205; portable device for aero-
sols, 212. See, also, Air Monitoring, On-the-Spot Samp-
ling, Source Testing
Sampling train for air contaminants, 168, 169; for specific
and gaseous contaminants, 171; for combustion con-
taminants, Fig. XI-4, 172; for particulates, 173, Fig.
XI-7, 173
San Francisco Bay Area Air Pollution Control District, 61,
83, 84, 86
Scavenger plants (sulfur), 54, 153; in Rule 53.1, 68; hydro-
gen-sulfide absorption in, 258
Scentometer, 202
-------
284
Air Pollution Control Field Operations
INDEX (Continued)
Scienter, in law, 215
Scientific and Technical Committee, 70, 86, 88
Scrubbers: water, 54, 153, 206, 207, 208, 258; Venturi, Fig.
II-12, 47; 210, 211, 213
Sectors: inspection, 96, 98; L. A. County map of, Fig. VI-3,
97; coverage, 105; analysis of equipment in, 115, 241;
assignments, 240; location of sources in, 242; inspec-
tor's inventory file in, 244, 245. See, also, Field Control
Operations, Inspection, Inventory
Senior Engineering Inspector: in reviewing reports and no-
tices, 105, 107; handling of inconclusive reports, 108;
handling complaints, 136; in requesting source testing,
175. See, also, Inspectors
Separators, centrifugal and inertial, 44-45. See, also, Cy-
clones
Service Groups, in field control operations, 92
Settling devices, 44, 169; with electrostatic precipitators, 46
Sheriff's Department, 234
Ships: in specialized enforcement, 98; location of, in viola-
tion, 216; identification of, 217; reading of smoke from,
224; violations from, 224-226; informational poster for,
Fig. XIII-8, 225
Sight-reading, of plumes, 159, 165, 166. See, also, Plumes
Single-source of emission: as equipment unit, 103; as ele-
ment of air pollution violation, 215; number of equip-
ment units comprising, 218; altering emissions from,
in Rule 60, 234. See, also, Air Pollution Configuration,
Emissions, Equipment Unit, Plumes, Violations
Slag, in metallurgical operations, 40, 152, 201
Smog, formation of, 1, 29; end effects of, 7; appearance of,
Fig. 1-6, 12; forecasts, 13-15, Fig. 1-8, 14, 72; relation
of, to metropolitan economy, 16; photochemical, 31, 206;
as haze, 144; average wind speed in, Kule 57, 13
Smoke: 144-151; control of, 48; abatement ordinances,
57-58, 59, 156; in Sec. 24342, 63; in Kule 50, 65; ground
concentration, 76; as plume, 143; blue, brown, 144;
white 144, 146; density of, 155, 156, 159; gray, 155, 156,
160; comparison charts, 159; colored, 161; excessive,
from vehicles, 223; or opacity violation, 216, 219-226.
See, also, Plumes
Smokehouses, 48, 205
"Smokeless zones," 39
Smoke-reading, 155-166; principles of, 159-160; reflected
and transmitted light in, 159, 161, 165, 166; proficiency
in, 163-166; distance from source, 160, 163; recording
of, 163-166; during evening hours, 165; change of color
in, 166; positions, 166, Figs. X-7, X-8, X-9, 165; from
vehicles, 223; from ship stacks, 224. See, also, Plumes
Smokescope, 159
Smoke School, A.P.C.D.: 161-166, Fig. X-3, 161; smoke
generators, 161-163, Figs. X-4, X-5, 162; Proficiency
Examination Sheet, Fig. X-6, 164. See, also, Inspectors
Smoke tintometer, 156
Sodium hydroxide, 173, 174, 208
Solvents. See Organic Solvents
Solid deposits, 213-214
Sonic collector, 45
Source Areas: defined, 15; zoning of, 29; in Los Angeles
County, 95; in public nuisance, 196, 197; in tracking
odors, 203, 204; in dusts, 212. See, also, Effect Areas
Sources of air pollution — moving: smoke from, 166; loca-
tion of, 216; violations from, 222-226. See, also, Auto-
mobiles, Railroads, Ships, Vehicles
Sources of air pollution—stationary: types of, 2; density
of, in metro area, 15, 96; elimination of, 39; control of,
industrial, 40-50, 54; public, 51; liability in joint nui-
sance, 59; in control program, 71, 77-80; detection of,
91, 93; in Los Angeles County, 95-96; inspection of, 98,
103; exposure to public of, 100; single-source, defined,
103; uniqueness of, 121; enforcement policy towards,
126; description of, 128; in complaints, 138-139; in pub-
lic nuisances, 195; unknown in public nuisances, 211,
212, 213, 214; of dusts, 213; identification of, 237;
major, 237; permit-required, 237; registration of, 61-62,
237-276; inventory categorization of, 239, 240; of
equipment unit, 248; inconsequential, 250, 254; at re-
fineries, 259. See, also, Equipment, Inventory, Permits
Sources, tracking of. See Tracking
Source-testing: purpose of, 73; in source registration, 79,
87; in air pollution configuration, 142; of invisible con-
taminants, 155; request for, 174-176. See, also, On-the-
Spot Testing, Sampling
Specific Contaminants, 169; in Rule 53, 68; sampling of,
171-174; in Rule 53b, 174
Spectroradiometer, Fig. 1-17, 36
Spotting, by paints, etc., 7, 206, 208-211
Squeeze-bulb analyzers, 171, 175, 178, 180, 182, 184, 190,
258. See, also, Sampling
Standard Temperature and Pressure, 171
Status charts, in field operations, 100, 103
Storage tanks, 48, 186, 201, 259, 263; vapor losses from, 52;
vents on, 185. See, also, Floating Roof, Petroleum Prod-
ucts, Vapor Recovery
Strict liability, 215
Sublimation, 74, 151, 152
Subpoena, 111; from hearing board, 112
Sulfur compounds: emission factors, 28; in fuels, 61, 175,
189-190, 258; in Rules 53 and 62, 68; odors of, 199
Sulfur dioxide: in California air-quality standards, 3; in
petroleum economy, 17; quantities emitted to L. A. at-
mosphere, 26-30; as non-photochemical product, 31;
contaminant level range, 33; principles of Thomas
Autometer, 34, Fig. 1-16, 36; absorption of, 50; control
of in L. A. County, 54; in emergency program, 69; in
air pollution configuration, 142; in smoke, 144; in
fumes, 151; as gas, 153-154; in Rule 53a, 174; as plume
constituent, 175; tests for, 173, 182, 184, 185; properties
of, 181; burning of, in Rule 62, 189; from refineries,
257, 258. See, also, Hydrogen Sulfide, Mercaptans
Sulfuric acid: in California air-quality standards, 3; effect
of aerosol on vegetation, 6; in mists, 31, 153; in nui-
sances, 206, 207, 208
Sulfur oxides, 52, 69, 144, 145; in L.A. atmosphere, 26-30;
classification among contaminants, 26; daily emissions
by source, 30; monitoring requirements, 33; concentra-
tion range, 33; automatic sampling technique, 34
Sulfur-Recovery plants, 54, 68, 153, 258
Sulfur trioxide: In plume, 153, 154, 175, 257; sampling of,
173; from refineries, 257
Superadiabatic lapse rate, 8
Surface coating, 19, 20, 56, 206, 208, 209. See, also, Paints
and Plating
Surveillance: in field control operations, 81, 93; in com-
plaints, 100; during night and morning watches, 126;
in odors, 204. See, also, Field Control Operations
Surveys: of materials and fuels, 29; industrial, 73, 88; in
source registration, 78; by state, 84; of refineries, 255,
262. See, also, Inventories
Tank Inspection Report, 262, Fig. XIV-15, 265
Tank trucks and trailers, 189, 257, 258. See, also, Vapor Re-
covery, Petroleum Products
Temperature distribution: inversions in, 9-11; of Los An-
geles air space, Fig. 1-5, 11; base of, Rule 57, 13
Testimony, 109, 111, 196, 215, 226; of complainants in court,
139; in public nuisance, 195. See, also, Courts
Textile goods manufacturing, 21
Thermal precipitation, 2, 43; sampling device, 171
Threshold pollution levels, defined, 4, 176; visual, 142; odor-
dilution ratio, 201
Time Factor Units, of inspections, 96, 115, 240
Tinning plants, 96
Tire manufacturing plants, 96
Topography and geography, effect on pollution retention,
11-13; map of Los Angeles County, Fig. 1-7, 12
Toxicity, 6; specific contaminants, 176-181. See, also, Air
Contaminants, Air Quality, Physiological Response,
Emergencies
Tracking, sources of air pollution: in nuisances, 196-197;
tracer studies in, 182, 197; in odors, 203-205; liquid
particulates, 211-213; use of test panels in, 212, 213
Trade associations, 54
Trains, violations from, 226
Transportation-equipment manufacturing, 20
Trial, conduct of, 111-112. See, also, Courts
Truck Loading Inspection Data Sheet, 261, Fig. XIV-12,
263
Trucks, 95, 98; violations from, 223, 224. See, also, Vehicles,
Violations
Turbulence, 7, 146, 204; in combustion, 41, 144; in after-
burners, 48
Tutweiler method, 175
-------
Air Pollution Control Field Operations
INDEX (Continued)
285
u
Ultraviolet light, influence of, on smog formation, 31; ab-
sorption of, in air sampling, 34
Umbrascope, 159
United States Coast Guard Port Security Card, 223, 224
United States Customs Office, in ship identification, 217
United States Congress, 61, 83
United States Constitution, 58, 77; Tenth Amendment, 58,
Fourteenth, 58
United States Department of Health, Education, and Wel-
fare, Public Health Service, 83, Joint Project, 52
United States Government, agencies concerned with air
pollution, 83
United States Government ships, 224
Vapors. See Gases
Vaporization, as air contaminating process, 2
Vapor pressure, 61, 167, 257, 186, 204; of hydrocarbons, 32,
154, 186, 218; true, conversion of, from Reid to True,
Fig. XI-12,187; effect of, on odors, 199
Vapor recovery, 44, 48, 52, 186, 189, 259; vaporsphere in,
48; systems, Fig. II-18, 11-19, 49, 257, 258; Greenwood
vapor closure, 53; collecting adaptor, Fig. XI-15, 189,
Fig. XI-13, 188. See, also, Floating Roofs, Petroleum
Products, Storage Tanks
Variances, 62, 64, 69, 92, 100, 102, 103, 119; conditions, 112,
259; memo of abstract of, Fig. VI-12, 113; in hearing
board cases, 112-114; in Sec. 24296, 112; petition for,
132. See, also, Hearing Board
Vegetation, damage to, 6, 15, 31, 195
Vegetative and plant response: fumig, chamber, Fig. 1-18,
36
V-Notice. See Vehicles-Notice
Vehicles, 95, 103, 105; registration in Los Angeles County,
23, 25; traffic, curtailment of, 102; halting and inspec-
tion of, 102, 126, Fig. Xm-6, 223, Fig. XIII-11, 233;
reading smoke from, 166; location of, in violations, 216;
identification of license no, & registered owner of, 217;
Citation, Fig. XHI-4, 222; in violations, 222-224; Notice,
103, Fig. Xm-5, 223, 224; passenger and commercial,
223, 224; refusal to halt, 232
Violations, of air pollution laws: in field development, 93;
in patrol inspectors, 96, 98; investigation of, 86, 88;
marginal, 99; inspection, 103, 123, 128, 130; in com-
plaints, 136, 137; time in, 109, 166, 215, 216; meaning
of hour in, 166; nature and extent of, 215-216, fla-
grancy, 229; location of, 100, 102, 215, 216, 219; Sec.
24279, 215, 218, 227-230, 231; weather in, 216 219-
causes of, 217, 218, 222; operation under suspended or
revoked permits, 231
Violation Notices: charge of, 104; review and disposition of
105-108; processing of, Fig. VI-8, 107, 108; assembling
evidence from, 109; filing of, 114; recording contami-
nant readings on, 166; serving of, 196, 236; titles of
responsible persons, 216; mailing address on, 217; Sec.
24242, evidence required for, 219; for ships, 225, Fig.
XIII-1, 220; Sec. 24279, evidence required for, 227, 229,
264, 265, 268; open fires, 231. See, also Inspections, Per-
mits, Reports, Smoke
Violation Record, 115; Figs. VI-14, 14.1, 116-117
Violation Finding File, 119
Violators, detection and prosecution of, 81-82; prosecution
of, 82, 108-112; enforcement policy towards, 126; pur-
suit of, 127
Visibility reduction, 2, 142; sky-darkening, light scattering,
4; in Los Angeles, Fig. 1-1, 5; trends, Fig. 1-2, 5, 6;
measurement of, 6; effect of increasing sulfur content
in fuels on, 23; as end-effect of smog, 31
Voire dire, 111; for hearing board, 112
Volatilization, 40, 151, 189
W
Warehouses, 239
Washington, D. C., population density of, 17
Waste-heat boilers, 52, 53, 206. See, also, Boilers
Waste-gas incinerator, 205 206
Waste-water stripping systems, 190
Weather measurements, 73
Weber-Fechner Psychophysical Law, 202
Western Oil and Gas Association, joint project, 52
Wet collectors. See Scrubbers
"Wind corridors," 39
Wind rose, 196,; Fig. XH-1, 197; 211
Wind speeds and patterns, effect on pollution retention, 8-9;
in public nuisance, 212
Witnesses, 111; identification of, 81
Woodworking industries, 20, 93, 96, 153, 209, 213
Zinc: fume constituent, 151; metallurgy, 152; —alloys, 152
"Zone of discontinuity," 9
Zoning, 39-40, 100
* U.S. GOVERNMENT PRINTING OFFICE : 1962 O—639903
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