APTD-1100
FIELD OPERATIONS
AND ENFORCEMENT
MANUAL FOR
AIR POLLUTION
CONTROL
VOLUME I:
ORGANIZATION AND
BASIC PROCEDURES
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Programs
Stationary Source Pollution Control Programs
Research Triangle Park, North Carolina 27711
-------
APTD-1100
FIELD OPERATIONS
AND ENFORCEMENT MANUAL
FOR AIR POLLUTION CONTROL
VOLUME I:
ORGANIZATION AND BASIC PROCEDURES
Prepared by
Melvin I. Weisburd
Pacific Environmental Services, Inc.
2932 Wilshire Boulevard
Santa Monica, California 90403
for
System Development Corporation
2500 Colorado Avenue
Santa Monica, California 90406
Contract No. CPA 70-122
Prepared for
ENVIRONMENTAL PROTECTION AGENCY
Office of Air Programs
Stationary Source Pollution Control Programs
Research Triangle Park, North Carolina 27711
August 1972
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ii
The APTD (Air Pollution Technical Data) series of reports is issued by the
Office of Air Programs, Environmental Protection Agency, to report technical
data of interest to a limited number of readers. Copies of APTD reports are
available free of charge to Federal employees, current contractors and
grantees, and non-profit organizations - as supplies permit - from the Air
Pollution Technical Information Center, Environmental Protection Agency,
Research Triangle Park, North Carolina 27711 or may be obtained, for a
nominal cost, from the National Technical Information Service, 5285 Port
Royal Road, Springfield, Virginia 22151.
This report was furnished to the Environmental Protection Agency by Pacific
Environmental Services, Inc. of Santa Monica, California (pursuant to a
subcontract with System Development Corporation) in fulfillment of prime
Contract No. CPA 70-122. The contents of this report are reproduced herein
as received from Pacific Environmental Services, Inc. The opinions,
findings, and conclusions expressed are those of the author and not neces-
sarily those of the Environmental Protection Agency.
Office of Air Programs Publication No. APTD-1100
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ill
FOREWORD
The Field Operations and Enforcement Manual for Air Pollution Control presents
field'surveillance and enforcement techniques that can be applied by state
and local air pollution control agencies to meet ambient air quality
objectives. Inspection and enforcement techniques are described to
reflect current air pollution control technology and specified sources
of air pollution. It is intended as a guide for air pollution control
agencies in carrying out their responsibilities in field surveillance,
facility inspection, emission source evaluation and enforcement activities.
This manual draws heavily upon such publications as the Air Pollution
Engineering Manual, Control Techniques Documents, Air Pollution (Academic
Press) and numerous reports and documents produced by, and under contract
to, the Environmental Protection Agency. It also updates and expands
much of the material which appeared in the original Air Pollution Control
Field Operations Manual prepared by the Los Angeles County Air Pollution
Control District in 1960 and published by the U. S. Public Health Service
in 1962. In addition, much new material was compiled from visits to nine
air pollution control agencies and selected industrial facilities in 1970
and 1971 under Contract CPA 70-122 with the Environmental Protection
Agency.
In establishing the scope of the manual, the following questions were
considered:
• What are the activities and functions performed by field
personnel?
• What do enforcement personnel need to know about their role
in attaining and maintaining emission standards to achieve
air quality objectives?
• What do enforcement personnel need to know about industrial
source operations and control technology in order to perform
effectively?
• What "inspection points" should be covered by enforcement
personnel when observing and inspecting processes and
equipment at specific sources of air pollution?
• What skills and equipment do enforcement personnel need in
order to perform effectively?
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iv
• What systems and procedures are required for the collection
and management of field data and successful execution of
enforcement actions in order to attain and to verify the
degree of source compliance desired?
These questions suggest that the scope of the manual is necessarily broad.
Knowledge of air pollution control technology has greatly expanded since
the publication of the original manual in 1962, with the result that the
traditional distinction between the enforcement officer and the air
pollution control engineer has become blurred. Field enforcement officers
require far more than an inspection check list. They must possess
knowledge of modern-day technology, manufacturing and production processes
and the nature of air pollution problems. They also are in a reporting
role and must relate to, and communicate with, the owners and operators
of industrial facilities. Without such knowledge and skills enforcement
personnel would lack the necessary confidence and understanding to observe
and enter plants, obtain relevant information from interviews and process
data, record instrument readings and inspect equipment to establish
compliance with emission standards and equipment certification requirements.
This manual concentrates on the information and skills that are needed to
accomplish the above. It can be used as a training document, a reference
manual or as a guide to field activities. Although certain inspection
techniques and enforcement practices have been used as "models," no
attempt has been made to codify them. These must be developed or modified
by the agencies responsible for controlling air pollution in the individual
air quality control jurisdictions of the United States.
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ACKNOWLEDGMENTS
Much of the information contained in this manual was obtained from inter-
views and materials supplied by staff members of state and local air
pollution control agencies as a part of the field work performed under
CPA 70-122. The authors are particularly indebted to the following
agencies and individuals:
Bay Area Pollution Control District, San Francisco, California
J. T. Donovan M. Brunkhorst
T. Brennan D. Nelson
Los Angeles County Air Pollution Control District, Los Angeles,
California
B. Lunche T. Wilkes
R. George N. Zlasney
Division of Air Quality Control, State Department of Health and
Mental Hygiene, Maryland
J. J. Schueneman R. Lipinski
G. P. Ferreri
Air Pollution Control Division, Wayne County Department of
Health, Detroit, Michigan
M. Sterling A. Bush
C. Andrus B. Wagar
Division of Air Pollution Control, Department of Public Safety,
St, Louis, Missouri
C. M. Copley F. Ross
P. T. Mydler B. Rhoades
State Bureau of Air Pollution Control, Division of Environmental
Quality, Department of Environmental Protection, State of New Jersey
W. A. Munroe B. Sullivan
H. Wortreich E. Landres
L. Marshall E. Mancini
W. Hart
Department of Environmental Quality, Portland, Oregon
F. R. Skirvin R. O'Dell
C. A. Ayer
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vi
Columbia-Willamette Air Pollution Authority, Portland, Oregon
W. Hanson D. Fuller
Department of Ecology, Redmond, Washington
R. Stockman J. Knudson
H. Droege B. Johnson
Puget Sound Air Pollution Control Agency, Seattle, Washington
A. R. Dammkoehler R. L. Busby
The authors also wish to thank Norm Edmisten and Tom Williams, EPA, OAP,
Control Agency Procedures Branch, for the invaluable guidance and
assistance given in supplying the information required in the preparation
of this manual.
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vil
The Field Operations and Enforcement Manual for Air Pollution Control ±s
divided into three separate volumes.
Volume I, Organization and Basic Procedures, contains Chapters 1 through 4.
Volume II, Control Technology and General Source Inspection, contains
Chapters 5 and 6.
Volume III, Inspection Procedures for Specific Industries, contains
Chapter 7.
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viii
ABSTRACT
The Field Operations and Enforcement Manual for Air Pollution Control,
Volume I, explains in detail the following: sources and classification of
pollutants; meteorological influence on air quality; the air pollution
control agency; the field enforcement officer; the enforcement process;
prosecuting violation; and inspection techniques including plume evalua-
tion, collection of evidence, handling of complaints, and operation of
field equipment.
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ix
TABLE OF CONTENTS FOR VOLUME I
LIST OF FIGURES xii±
CHAPTER 1. AIR QUALITY MANAGEMENT
I.
II.
III.
IV.
V.
VI.
VII.
INTRODUCTION
THE AIR POLLUTION POTENTIAL
A. Sources of Air Pollutants
C. Particulate Matter
1. Particulate Size Ranges
2. Properties of Particulates
2. Carbon and Carbon Oxides
METEOROLOGICAL INFLUENCES ON AIR QUALITY
C. Vertical Mixing
F. Visibility
AIR POLLUTION CONTROL STRATEGIES
LEGAL AUTHORITY AND RULES AND REGULATIONS
B. Rules and Regulations
THE AIR POLLUTION CONTROL AGENCY
A. Objectives
C. Organizational Structure
D. Staffing Patterns
THE FIELD ENFORCEMENT OFFICER
A. Scope of the Field Operations Program
B. The Field Enforcement Officer
C. Training
REFERENCES
1.1
1.1
1.2
1.3
1.4
1.5
1.8
1.9
1.10
1.11
1.11
1.13
1.15
1.16
1.18
1.2C
1.21
1.22
1.23
1.25
1.26
1.27
1.27
1.29
1.29
1.30
1.35
1.35
1.37
1.38
1.A2
1.46
1.48
1.48
. . . . 1-49
. . . . 1.51
1.53
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Page.
CHAPTER 2. THE ENFORCEMENT PROCESS 2.1
I. INTRODUCTION 2>1
II. OVERVIEW OF THE ENFORCEMENT PROCESS 2>1
2 1
A. Field Operations
B. Enforcement Actions 2.4
C. Relationship to Other Control Functions 2-6
(1) Source Registration 2-6
(2) Emission Inventory 2.7
(3) Permit System or Other Plan Review or
Certification Systems 2.7
III. FIELD SURVEILLANCE PROCEDURES 2'8
A. Field Patrol 2.9
B. Field Surveillance Coverage 2.12
1. Unitization of Field Work 2.12
2. Inspection Scheduling 2.14
IV. INSPECTION OF AIR POLLUTION EMISSION SOURCES 2.15
A. Facility Inspection 2.16
B. Equipment Inventory Inspection 2.18
1. Source Coverage 2.19
2. Initial Inventory Inspections 2.20
3. Inventory Reinspections 2.21
4. The Equipment List 2.23
5. Preparation of the Equipment List 2.30
a. Business and Ownership Data of the Source Activity . . 2.32
b. Description and Location of Each Equipment Unit ... 2.33
c. Itemization of Equipment Units 2.35
d. Location of Equipment, Plant Layout and Flow Charts. . 2.38
e. Determining Permit Status 2.40
C. Compliance Plan Status Inspections 2.41
D. Inspections Relating to Emergencies 2.42
1. Local Emergencies 2.42
2. Episode Management 2.45
V. ENFORCEMENT METHODS AND FORMS 2.46
A. The Inspection Report . ., 2.47
B. Notice of Violation 2.48
C. The Citation 2.52
D. Defect Notice Follow-up System 2.58
E. Sealing of Equipment 2.58
F. Work Reports 2.61
VI. PROCESSING OF REPORTS 2.61
VII. MANAGEMENT OF ENFORCEMENT DATA 2.65
REFERENCES 2.70
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xi
CHAPTER 3. PROSECUTING VIOLATIONS
3.1
I. INTRODUCTION 3>1
O o
A. Criminal Sanctions
B. Civil Procedures 3'3
II. THE ADMINISTRATIVE HEARING PROCESS 3-3
III. HEARING BOARDS 3>6
A. Variances 3-'
B. Appeals of Permit Denial 3-8
C. Review of Abatement Orders 3.8
n Q
D. Issuance of Abatement Orders ->'°
E. Revocation and Suspension of Permits 3'9
IV. THE COURTS 3-9
o Q
A. Case Investigation J'y
B. Preparation of Case for Court Trial 3.U
C. Role of Field Enforcement Officer as Witness and
Courtroom Procedure 3.15
REFERENCES 3-18
CHAPTER 4. INSPECTION TECHNIQUES 4.1
I. INTRODUCTION 4.1
II. IDENTIFICATION OF EFFLUENT PLUMES 4.1
A. Air Pollution Configurations 4.2
1. The Plume 4.3
2. The Cloud 4.6
3. The Haze 4.7
B. Types of Effluent Plumes 4.8
1. Smoke 4.9
2. Fumes 4.10
3. Dusts 4.12
4. Mists 4.13
5. Gases 4.13
6. Vapors 4.15
III. PLUME EVALUATION 4.16
A. Description and Use of the Ringelmann Chart 4.17
B. Smoke Measuring Methods 4.21
C. Principles of Smoke and Opacity Reading 4.22
D. Costs and Benefits of Plume Evaluation Training 4.25
E. Smoke Reading School 4.28
1. Smoke Generating Equipment 4.28
2. Training Procedure 4.31
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xii
Page
F. Reading Smoke in the Field 4'32
1. Reading Air Contaminants 4.32
2. Recording Air Contaminants 4.35
3. Smoke from Moving Sources 4.36
IV. COLLECTING EVIDENCE . . . . 4'36
A. Establishing the Prima Facie Case
B. Documentation of Evidence
1. The Nature and Extent of the Violation .......... 4>38
2. The Time and Location of the Violation .......... 4'39
3. The Persons Responsible for the Violation ........ 4>49
4. The Equipment ...................... 4-4°
5. Operational and Maintenance Factors ........... 4.43
C. Types of Evidence ...................... 4.44
V. COMPLAINT HANDLING ........................ 4'46
A. Receiving the Complaint ................... 4.47
B. Complaint Investigation ................... 4.47
C. Inspection of the Source ................... 4.52
1. Mediation ........................ 4-54
2. Nuisance Action ..................... 4-54
VI. FIELD EVALUATION AND ENFORCEMENT EQUIPMENT ............ 4.55
A. Mobility and Personal Protection ............... 4.55
B. Facilitating, Verifying or Recording Observations ...... 4.56
C. Assessment of Weather Conditions and Measuring Ambient
Air Flow .......................... 4.57
D. Measurement of Process Air Stream Flow ............ 4.57
E. Sampling Contaminants in Ambient Air and Process Streams ... 4.59
F. Equipment for On-the-Spot Testing .............. 4.62
G. Fuel Sampling ........................ 4.65
1. Gaseous Fuel ....................... 4.66
2. Liquid and Solid Fuels .................. 4.67
VII. COMMUNICATIONS EQUIPMENT ..................... 4.68
REFERENCES ............................... 4.71
GLOSSARY ................................ G.I
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xiii
LIST OF FIGURES
Page
Figure 1.1. Characteristics of Particles and Particle Dispersoids 1-. 6
Figure 1.2. Diurnal Variation of Vertical Mixing 1.24
Figure 1.3. Organizational Structure of Colorado Division of
Air Pollution Control 1.41
Figure 1.4. Department of Environmental Quality, State of Oregon 1.43
Figure 1.5. Suggested Organization of an Air Pollution Control Agency 1.44
Figure 1.6. Typical Organization Chart for a Local Governmental
Air Pollution Control Agency 1.45
Figure 2.1. Overview of the Enforcement Process 2.2
Figure 2.2. Surveillance Inspection Record 2.10
Figure 2.3. Equipment List Used for Inventorying the Sources of
Pollution at an Industrial Facility 2.24
Figure 2.4. Automated Version of Equipment List 2.25
Figure 2.5. Notice to Apply for APCD Permit 2.26
Figure 2.6. Diagram of Basic and Control Equipment for Two Brass
Furnaces Served by Cooling Columns and Cloth
Filtering Systems 2.36
Figure 2.7. Plot Plan on Reverse of Equipment List to Illustrate
Positioning of Equipment 2.39
Figure 2.8. Proposed Compliance Schedule Format, Puget Sound
Air Pollution Control Agency 2.43
Figure 2.8. Continued 2.44
Figure 2.9. Narrative Type of Inspection Report 2.49
Figure 2.10. Example of Inspection Report, Structured Form, Used
for Gathering Information for Fuel Burning Process
Equipment, Wayne County Department of Health,
Air Pollution Control Division 2.50
Figure 2.11. Example of Inspection Report, Structured Form, Solvent
Usage Survey-Ovens, Los Angeles County Air Pollution
Control District 2.51
Figure 2.12. Notice of Violation Written for Excessive Fumes from
Five Brass Furnaces, Face Side, Los Angeles County
Air Pollution Control District 2.53
Figure 2.12a. Notice of Violation Written for Excessive Fumes from
Five Brass Furnaces, Back Side, Los Angeles County
Air Pollution Control District 2.54
Figure 2.12b. Continuous Observation Sheet for Five Brass Furnaces
Supporting Violation Notice FA6127 (Figure 2.12) 2.55
Figure 2.12c. Emission Observation Sheet, Supporting the Notice of
Violation, Figure 2.12 2.56
Figure 2.13. Vehicle Notice 2.57
Figure 2.14. APCD Vehicle Citation Quadruplicate 2.59
Figure 2.15. Enforcement Officer's Daily Report, Los Angeles County
Air Pollution Control District 2.62
Figure 2.16. Processing of Written Notices of Violation 2.64
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xiv
Figure 3.1. Request for Complaint
Figure 3.2. Misdemeanor Complaint
Figure 4.1. General Structure of Continuous and Detached Plumes
Figure 4.2. Ringelmann's Scale for Grading the Density of Smoke
Figure 4.3. Plume Observation Record Form
Figure 4.4. Design of Black Smoke Generator
Figure 4.5. Design of White Smoke Generator
Figure 4.6. Smoke School Training Form
Figure 4.7. Light Source Should Emanate from the Rear of Observer
During Daylight Hours
Figure 4.8. During Darkness, the Light Source Should Emanate from
Behind the Plume
Figure 4.9. Readings Should be Made at Right Angles to Wind
Direction
Figure 4.10. Example of Radiophone Message Log
Figure 4.11. Standard Pitot Tube
Page
3.11
3.12
4.5
4.18
.27
.29
.30
4.
4.
4.
4.33
4.34
4.34
4.34
4.48
4.58
LIST OF TABLES
Table 1.1. Estimated Nationwide Emissions, 1969 (10 tons/year)
Table 1.2. Emission Limits Attainable by Available Technology
Table 1.3. Typical Division of Responsibilities Between State
and Local Air Pollution Control Agencies
Table 1.4. Summary of Functions for Air Pollution Control Programs
Table 2.1. Major Basic Equipment Classification
Table 2.2. Primary Activity Classifications
Table 2.3. Code of Causes of Smoke Violations
Table 2.4. Standard Abbreviations
Table 4.1. Contaminants Which Can Be Tested in the Field with
Portable Devices
4.60
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1.1
CHAPTER 1
AIR QUALITY MANAGEMENT
I. INTRODUCTION
Air pollution control field operations consist of those surveillance and
enforcement activities conducted by an environmental or air pollution
control agency to secure certain and continuing control over the sources
of air pollution. The mission of the field operations program as a
whole is to implement the plans that have been adopted to achieve accept-
able levels of air quality.
The role of field operations in air pollution control has changed
considerably over the many years that air pollution has become a problem
to civilization. Early efforts to control air pollution were largely
concerned with the abatement of black smoke emitted from the inefficient
combustion of coal used to generate power and heat homes. Smoke abatement
agencies were organized in the United States and abroad around the turn
of the century. These gave rise to the first smoke or combustion inspec-
tors and set the pattern for air pollution control for many years.
The 20th Century experienced a profound change in the nature and extent
of air pollution. Unlimited production; accelerated consumption of
products, fuels and energy; the introduction of new chemical and petro-
chemical processing industries and atomic energy; the vastly increased
use of the automobile; the growth of urbanization, all greatly increased
the varieties and volumes of pollutants, thereby presenting new threats
to health., plant life, property and the environment.
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1.2
To cope with the current forms of air pollution, environmental control
agencies must employ strategies and management tools that are at least
equal to the inherent difficulties of the problem. While much progress
has been made in improving our scientific and technical understanding of
air pollution and its control, the major challenge of implementing the
best of the technology available to control air pollution on a national
scale is still before society.
The responsibility for fulfilling air pollution control objectives belongs
to the enforcement branches of air pollution control agencies across the
nation. Enforcement staffs will require highly trained and dedicated
personnel. For this reason, the title "inspector," a carry-over from
the industrial pollution era, is no longer adequate. The term "field
enforcement officer" more accurately describes the scope of responsibility
that must be fulfilled in the field.
This chapter offers an overall presentation of the nature and extent of
contemporary air pollution problems, and describes the elements of an
effective air quality management program in terms of control strategies,
legislation, organization and staffing. The bulk of the manual presents
specific surveillance and enforcement methods and administrative systems
and procedures that can be implemented to achieve air quality objectives.
II. THE AIR POLLUTION POTENTIAL
The air pollution potential may be defined as the capacity of human
activities conducted within any defined community or geographical area to
pollute the atmosphere. It is sometimes referred to as emission rates or
source strength, and is expressed in terms of the specific contaminants
and the rates at which they are emitted from their sources. Air quality
is a pattern, or profile, of the concentrations of contaminants in the
ambient atmosphere and is expressed in terms of frequencies, averages or
other statistical measures.
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1.3
Air quality is not a function of source strength alone, but rather of the
source strength and intervening meteorological and environmental influences
This section describes the major categories of sources of air pollution
and the types of contaminants found particularly in metropolitan areas of
the United States. Section III describes the major meteorological
influences on air quality.
A. Sources of Air Pollutants
Air pollutants may be classified in two broad categories: natural
and man-made.
Natural sources of air pollutants include:
wind blown dust
volcanic ash and gases
ozone from lightning and the ozone layer
esters and terpenes from vegetation
smoke, gases and fly ash from forest fires
pollens and other aeroallergens
gases and odors from natural decomposition
natural radioactivity.
Such sources constitute background pollution and that portion of the
pollution problem over which control activities can have little, if
any, effect.
Man-made sources cover a wide spectrum of chemical and physical
activities, and are the major contributors to urban air pollution.
Air pollutants in the U.S. pour out from over 90 million vehicles,
from the refuse of over 204 million people, the generation of billions
of kilowatts of electricity and the production of innumerable products
demanded by every-day living. Almost 300 million tons of air
pollutants are generated annually in the United States alone. The
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1.4
five main classes of pollutants, particulates, carbon monoxide,
hydrocarbons, nitrogen oxides and sulfur oxides are summarized for
(2)
the year 1969 in Table 1.1. '
TABLE 1.1. ESTIMATED NATIONWIDE EMISSIONS, 1969 (10 tons/year)
Source
Transportation
Fuel combustion in
stationary sources
Industrial processes
Solid waste disposal
Miscellaneous
Total
CO
111.5
1.8
12.0
7.9
18.2
151.4
PART
0.8
7.2
14.4
1.4
11.4
35.2
SO
X
1.1
24.4
7.5
0.2
0.2
33.4
HC
19.8
0.9
5.5
2.0
9.2
37.4
NO
X
11.2
10.0
0.2
0.4
2.0
23.8
(SOURCE: EPA, Reference 2)
B. Classification of Air Pollutants
For convenience, all air contaminants may be classified in two
physical states: particulate matter and gaseous substances. The
former is often subdivided into solid and liquid particulates while
the latter is divided into true gases and vapors.
Particulate Matter
Solids: dust
fumes
smoke
aerosols
Liquids: droplets
mists
fogs
aerosols
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1.5
Gases
True Gases: sulfur dioxide
nitrogen oxides
ozone
carbon monoxide
Vapors: gasoline
paint solvents
dry cleaning agents
Characteristic properties of the various airborne contaminants are
important in considering their potential role in air pollution. Among
these are:
a. Physical properties such as particle size, shape, surface area,
density, electrical charge, radioactivity and vapor pressure.
b. Chemical properties such as acidity, alkalinity, solubility,
hygroscopicity, reactivity and corrosiveness.
c. Biological properties such as toxicity, taste and odor.
Particulate Matter
A particle is any dispersed matter, solid or liquid, in which the
individual aggregates are larger than single molecules, but smaller
(3)
than about 500 micro-meters in diameter. A continuous spectrum of
sizes occurs among the particles in the atmosphere, with corresponding
gradations in physical and chemical properties. Figure 1.1 illustrates
(4)
the size range and some common characteristics.
Variations in size confer different physical and chemical properties
on the particles. It is important, therefore, to be familiar with
the scale and size ranges of common particulate substances and
corresponding changes in properties. For example:
• A micro-meter* is equal to 1/1,000 of a millimeter, or
1/25,000 of an inch.
*The term micron is also frequently used in the literature.
-------
Particle Diameter, microns (p)
0.0001 0.001 0.01 0.1 1 10
Equivalent
Size*
Electromagnetic
Wave*
Technical
Definition*
Common Atmospheric
Ditpersoids
Typical Particle*
and
Gas Dicpertoid*
Gil
teptrso*
Soil:
i 10 U
Angstrom Units. J
1
SoM: |-
Liquid [-
0 1,0
• - Ultravtok
Fume-
Mist
Mkrtwi « imfnMoMl SM Clasvliulwi System
•dopfcd by Mtmit Sot Sol Sci. Since 1834 '
- - -
i-
0, CO, C.H.
CO HA HO Ufa
ttom nutty
-------
Methods for
Particle Size
Analysis
Types of
Gas Cleaning
Equipment
Terminal
Gravitational
Settling1
[for spheres,]
sp. gr. 2.0 J
Particle Diffusion
Coefficient,"
cm V*ec.
In Air
»25C
latm.
In Water
25' C.
In Air
latm.
In Water
at
25'C.
factor included in 0.0
values given for av
•but not included for mar
Reynolds Number
Settling Velocity.
cm/sec.
Reynolds Number
Settling Velocity,
cm/sec.
1 c 10"
HI
lOT" 10" "3 1
23* ,
Kr'*io-'4io-'3
1 3 ! 7 ! 7
10-" ,10-' ,
1 777! 77?
J,, io-'io-
' ?? i 77? i r TT i 7 r: i
io-s 1
001 O.C
(in
[• Impinge
I* — 1 Centrifuge—
Ray Diffractioni-
^ i ^ Elect roformed , ^
s "" Sieves "'
H* 1
-H
— Elutriation
3n
Ught Scattf
Ultrasonics
(very limited indu
High Eflicie
Thermal P
(used only
fSlr.il appliution)
ncy Air Filters —
recipitation
or samphngl
Electrical Precipit
0" "j 10"'3 If
' , . 10"4
... 1
icr'!io-"io-10
10-' 10-' , ,
1 , , V 1 Z7 7
io-4 10
ioj'
) , 10 , 10 •
, 3 s I0"'
1 . . 1 : 7 :
io"' io"' 10"!
1 7 1 7 1 7
10"' . 10"s
1 , 7 , 1 ,77
5 10-'
? ? ? 1 1*7
10-.
[- — -Electrical Conductivity +
\
'
h Collectors
Common Air Filters — *
"T
10' 5 10" * 10''
IO"2, , 10"'
10"' 10-* IO-.4
1 7 1 7 1 7
10"4 ,10"3
1 777 1 ?? ,
, f'...,
4 3 2 10"'.
i i i IIMI
io", 10'! 10°
10°,, . 10' .
iov^;io-;
10'* 10"' ,
1 ,77 1 , 7 7
» T'vt4'
10" 10
M
* Furnishes average particla
diameter but no size
distribution.
++Sue distribution may be
obtainad by special
calibration.
i-._
Machine Tools (M
Settling Chan
arators — rt
.313
102 . , 5
1,1.
io°3 10' 3 10
10° 10
? 1?"*!?:f
10""
i . . \'in
icrometers, Calipe
103 3 10'
1 IS?
' 3 101 ,
. i i
2345
2 . 6543
10" 12
rs, etc.)-
1 S
}-, *
10" ,
1
6 7 8 S
, 10-"
f 1
101 0.01 0.1 1 10 100 1,000 10
>•) (Imm.) Ill
Particle Diameter, microns (/i) ncMncn n c
i ,
000
m)
Figure 1.1. CHARACTERISTICS OF PARTICLES AND PARTICLE DISPERSOIDS. (continued)
-------
1.8
• Viruses are between 0.01 and 0.1 micro-meter in size.
• Bacteria are between 1 and 25 micro-meters in size.
• Fog droplets are between 5 and 60 micro-meters in size.
• Raindrops are between 400 and 5,000 micro-meters in size.
• Particles approximately 10 micro-meters in diameter are
barely visible to the naked eye.
1. Particulate Size Ranges
Coarse dust particles larger than 10 micro-meters in diameter and
fly ash, composed of the impurities remaining after coal is
burned, settle out of the air quickly. They are, therefore,
usually troublesome only near their source. Fume, dust, and
smoke particles range in size from under 1 to 10 micro-meters.
They tend to travel farther than coarser particulates, depending
on their size.
Particles less than 1 micro-meter in diameter (generally referred
to as aerosols because they are small enough to remain suspended
in the air) move as easily and as far in wind or air currents as
gases do.
Polluting particles are composed of a variety of substances
originating from the myriad activities conducted by man. Because
their size and, to a lesser degree, their physical state influence
their behavior so greatly, they are commonly identified by the
appearance and behavior of the emissions in which they are
contained. For example:
• Smoke describes unburned carbonaceous particles mostly 1
micro-meter in diameter produced as a result of combustion.
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1.9
• Fume indicates the solid particles under 1 micro-meter in
diameter that are formed as vapors condense or as chemical
reactions take place. Fumes are emitted by many industrial
processes, including metal smelting and refining,
distillation, and removal of solid impurities by boiling
liquid materials and condensing the vapors.
• Dust is a more general term than fume. When solid
particles are more than 1 micro-meter in size they are
generally referred to as dust. Dust may be formed by
natural processes or in innumerable mechanical operations
conducted at industrial and agricultural facilities.
• Mist consists of liquid particles up to 100 micro-meters
in diameter. They may be released in such industrial
operations as spraying and impregnating, or formed by the
condensation of vapor in the atmosphere. As mists
evaporate, more concentrated liquid aerosols may be formed.
2. The Properties of Particulates
When a liquid or solid substance is emitted to the air as particu-
late matter, its properties and its effects may be changed. As
a substance is broken up into smaller and smaller particles more
of its surface area is exposed to the air. Under these circum-
stances, the substance—whatever its chemical composition—tends
to physically or chemically combine with other particulates or
gases in the atmosphere. The resulting combinations are
frequently unpredictable. For example:
• Very small aerosols (from 0.001 to 0.1 micro-meter in
diameter) can act as nuclei on which vapor condenses. Fogs,
ground mists and rain may thus be increased and prolonged.
-------
1.10
• Particles less than 2 or 3 micro-meters in size—about
half (by weight) of the particles suspended in urban air
are estimated to be that small—can penetrate into the part
of the lung which is unprotected by mucous, and can attract
and carry such harmful chemicals as sulfur dioxide with them.
Sulfur dioxide alone would be dissolved on the mucous
before it reached that vulnerable tissue.
• Particulates can act as catalysts. (Catalysis is the
process in which a chemical reaction is speeded up by a
substance that remains unchanged itself. The unchanged
substance is known as the catalyst.) An example of this
is the change of sulfur dioxide to sulfuric acid, aided
by the catalytic action of iron oxides.
• Aerosols can absorb radiant energy and conduct heat
quickly to the surrounding gases of the atmosphere. These
are gases that are incapable of absorbing radiant energy
by themselves. As a result, the air in contact with the
aerosols becomes much warmer. Some scientists fear that
the increasing aerosol emissions of jet planes high in
the troposphere may eventually form a heat-absorbing layer
that will diminish the penetration of the sun's rays to
the earth.
3. The Prevalence of Particulates
The urban atmosphere is comparatively dense with particulates.
Los Angeles estimates its aerosol emissions from gasoline-powered
vehicles at 40 tons a day. An average winter day in New York City
produces an estimated 335 tons of particulate matter. In Kansas
City, dustfall in the winter measures more than 67 tons per square
mile each month. In the most heavily polluted parts of major
cities from 50 to more than 100 tons of particulates fall each
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1.11
month per square mile. In general, the concentration of aerosols
in the air over a city is related to the size of its population.
Automobile exhaust emits especially large amounts of very fine
aerosols. More than two-thirds of automobile emissions are
between 0.02 and 0.06 micro-meters in size. One hundred billion
particles per cubic meter of air may be produced from chemical
reactions which occur between these emissions and other atmospheric
contaminants.
D. Gaseous Contaminants
The gases of importance as air pollutants come from a wide range of
organic and inorganic compounds. The most common are carbon monoxide,
sulfur oxides, nitrogen oxides and hydrocarbons. These are tabulated
in Table 1.1. These estimates also show that gaseous contaminants
represent over 88 percent by weight of all pollutant emissions. Carbon
monoxide is the most significant, since it amounts to almost 55 percent
by weight of all pollutant emissions.
1. Sulfur and Its Compounds
Sulfur, (S), the oxides of which are a major reason for many
cities' pollution troubles, is itself a nonmetallic element found
in nature either in free form or combined with other elements.
It is almost invariably present as an impurity in the coal and
fuel oils that are basic to most combustion and power sources.
a. Sulfur Oxides
When fuels containing sulfur are burned, the sulfur joins with
the oxygen of the air and gaseous oxides of sulfur are formed.
Fuel combustion is the major source of the polluting sulfur
oxides, although they are also produced in chemical plants and,
to a lesser degree, by processing metals and burning trash.
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1.12
The major oxide of sulfur that is produced in combustion is
sulfur dioxide (SO.), a heavy, pungent, colorless gas that
dissolves easily in water vapor to form a solution of sulfurous
acid (H.SO ). Sulfurous acid, mildly corrosive, is used as a
bleaching agent in industry. It joins slowly with the oxygen
in the air (or quickly if catalysts are present) to become
the even more corrosive, irritating mist, sulfuric acid (l^SO,).
Sulfur acid can also be formed by a different route. Sulfur
dioxide can be oxidized directly (changed chemically by
combining with oxygen) to sulfur trioxide (SO.) , which can be
either a colorless liquid or a white solid aerosol. Sulfur
trioxide is a likely product when combustion takes place with
excess oxygen. The change is abetted by the catalytic action
of some of the ash residue, especially the iron oxides that
form on boiler tubes and walls. As sulfur dioxide leaves the
smoke stack it usually diffuses rapidly, so that oxidation to
sulfur trioxide takes place rather slowly. But, with time,
sulfur trioxide can build up substantially and react very
quickly with water vapor to form sulfuric acid.
Sulfur oxides can damage vegetation, fabrics and building
materials, limit visibility, cut down the light from the sun,
and affect human breathing. At sufficiently high concentra-
tions, sulfur dioxide irritates the upper respiratory tract.
At lower concentrations and when carried on particulates, it
appears able to cause still greater harm by injuring lung
tissue.
b. Other Sulfur Compounds
Other undesirable sulfur compounds include hydrogen sulfide
gas (H-S), which gives off the foul odor of rotten eggs, and
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1.13
two classes of sulfur compounds called mercaptans and sulfides,
which are associated with unpleasant odors such as garlic,
onions, skunk or decayed cabbage. These gases are familiar
by-products of petroleum refining, kraft pulping for paper
production and various chemical processes.
In addition to giving off an annoying smell, hydrogen sulfide
can tarnish silverware and copper bowls and, by darkening the
lead in paint, it can ruin the exteriors of houses. Fortunately,
there is rarely enough hydrogen sulfide in the air to harm
either vegetation or man.
Carbon and Carbon Oxides
Carbon (C) is a nonmetallic element found either in its pure state
or as a constituent of coal, petroleum, limestone and other
organic and inorganic compounds. (The term organic is used to
describe most carbon-containing compounds.) Carbon compounds are
most frequently used as fuels, and the combustion process liberates
much of the carbon, either as unburned or partly burned particles
or as carbon monoxide or carbon dioxide.
a. Carbon Monoxide
One product of incomplete combustion is carbon monoxide (CO),
a colorless, odorless, very toxic gas. No other gaseous air
pollutant is found at such relatively high concentrations in
/ o\
the urban atmosphere.
Its effects in the metropolitan air are uncertain. Controlled
laboratory experiments show that at exposures of approximately
100 ppm (parts per million) most people get dizzy, develop
headaches and feel other symptoms of poisoning. A concentration
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1.14
of 100 ppm is not uncommon today in heavy traffic. Some
studies have measured 370 ppm inside vehicles in traffic jams.
Yet a study of 237 people involved in traffic accidents in
Detroit failed to show that their driving ability was impaired
by the carbon monoxide in the atmosphere of that city at the
time of their accidents.
The fate of carbon monoxide in the atmosphere is unknown.
Although more than 300 million tons of carbon monoxide are
formed each year throughout the world, enough to double the
global concentration in about 5 years, careful measurements
have shown that the average concentration has not changed
over the last 50 years. What happens to carbon monoxide is a
mystery.
b. Carbon Dioxide
Carbon dioxide (C0_), a heavy, colorless, odorless gas, is
formed during combustion; the more complete the combustion,
the more CO is formed. It is also formed in nature by the
decomposition of organic substances and it is absorbed from
the air by plants through the mechanism of photosynthesis.
Carbon dioxide is not normally considered an air pollutant
because it performs a necessary function in life processes.
Even the increasing amounts produced by man's activities are
far from enough to endanger him.
The presence of sufficient quantities of carbon dioxide,
however, can have undesirable side effects. In the presence
of moisture it converts to carbonic acid and erodes stone.
It is partially responsible for the corrosion of magnesium
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1.15
and perhaps of other structural metals as well. And it is
believed that the huge amounts of carbon dioxide emitted
each day are very slowly heating the earth's atmosphere. In
time, some scientists fear, this scarcely perceptible rise in
temperature may cause the partial melting of the polar icecaps
and extensive flooding throughout the world.
3. Hydrocarbons
Hydrocarbons are a class of compounds containing carbon and
hydrogen in various combinations. They are found most abundantly
in petroleum, natural gas and coal. Some are gaseous, some liquid,
some solid, and all in all they make up a vast family of chemicals.
There are, in fact, thousands of hydrocarbon compounds. Most of
these compounds, fortunately, are harmful only in very high
concentrations. A few may be extremely toxic, however, and need
(9)
to be examined very carefully.
Two groups of hydrocarbon compounds are of great importance in
air pollution: (1) the olefin or ethylene series and (2) the
aromatic, benzenoid or benzene series.
a. Olefins
The olefins are a group of unsaturated hydrocarbons. (Un-
saturated compounds react easily with other chemicals.) Most
olefins in small concentrations appear to have no direct
effect on animal life, although some cause a general reduction
in plant growth. In addition, olefins take part in photo-
chemical reactions with nitrogen oxides and several other
classes of compounds. The deleterious effects of these
reactions are described later in this chapter.
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1.16
b. Aromatics
Included in the aromatics are a number of compounds believed
or known to be carcinogenic (cancer-producing). The most
potent of these is benzpyrene (often written benzo(a)pyrene
or 3, 4 benzpyrene). A primary source of these carcinogens
is the incomplete combustion of organic materials. In fact,
most polluting hydrocarbons are discharged into the air by
incomplete combustion. And the major source of this kind of
contamination is the burning of gasoline in automobiles.
Hydrocarbons can also be released into the atmosphere by
evaporation. The oil industry encompasses many operations
that produce hydrocarbon vapors. Among these are cracking
(the chemical decomposition of oil under intense heat),
gasoline storage and tank truck filling. Some hydrocarbon
vapors have objectionable odors; some take part in photo-
chemical reactions; some have toxic properties. Other
constant vapor emitters include alcohols, esters and paint
and lacquer thihners.
4. Nitrogen Oxides
Nitrogen (N) itself is a colorless, tasteless, odorless gas that
constitutes 78 percent of the atmosphere. A number of oxides of
nitrogen occur, but only nitric oxide and nitrogen dioxide are
considered pollutants. These have been called status symbol or
jet-age pollutants, because, ironically, only a highly advanced
country is likely to suffer seriously from them.
a. Nitric Oxide
The colorless, somewhat toxic gas, nitric oxide (NO) is formed
when combustion takes place at temperatures sufficiently high
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1.17
to cause a reaction between the nitrogen and oxygen of the
air. Temperatures this high are reached only in efficient
combustion processes or when combustion takes place at high
pressure. Thus, nitric oxide is formed primarily in auto-
mobile cylinders, electric power plants and other very large
energy-conversion processes.
In most cities the automobile is the largest single source
of this compound. The nitric oxide formed at the high
temperatures of the cylinder air moves so rapidly to the
cooler exhaust pipe that it is prevented from decomposing
back to nitrogen and oxygen, as it would if cooling were
slower.
b. Nitrogen Dioxide
Nitric oxide, which is relatively harmless, is the form
generally emitted into the atmosphere. But varying amounts
of nitric oxide are converted to nitro'gen dioxide (NCO,
which causes considerably more trouble.
The oxidation of nitric oxide to nitrogen dioxide is very
rapid at high concentrations in air, but is slow at low
concentrations except in the presence of hydrocarbons and
sunlight. Thus, although more nitric oxide is formed in
Chicago than in San Francisco because of the more abundant
sunshine in the latter city, San Francisco has a higher
atmospheric concentration of nitrogen dioxide than Chicago.
Since nitrogen dioxide is formed so readily by photochemical
action, it is usually thought of as a product of the photo-
chemical process. But actually it may be formed whenever
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1.18
nitric oxide is a by-product of sufficiently high burning
temperatures, with or without photochemical action. It is
also a product or by-product of a number of industries,
including fertilizer and explosives manufacturing.
Nitrogen dioxide is the only important and widespread
pollutant gas that is colored (yellow-brown). As a result,
it can significantly affect visibility. It has a pungent,
sweetish odor detectable at 1 to 3 parts per million,
fortunately a level seldom reached in polluted atmospheres*
At sufficiently high concentrations, nitrogen dioxide can be
fatal, but such amounts are highly unlikely. Prolonged
exposures at ordinary concentrations may also be harmful to
the lungs, though little experimental data are available.
Nitrogen dioxide reacts with raindrops or water vapor in the
air to produce nitric acid (HNO ), which, even in small con-
centrations, can corrode metal surfaces in the immediate
vicinity of the source. Vegetation, too, can be injured when
it grows close to factories handling large amounts of nitric
acid. The nitrogen oxides present in the ordinary community's
air, however, are probably always too low to damage plant
life.
5, Photochemical Products
The numerous references to photochemical reactions indicate their
importance in the air pollution problem. Once they were thought
to be of concern only in Los Angeles; now they are observed even
(11)
in the smaller cities throughout the nation.
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1.19
Photochemical reactions are a complex series of atmospheric
conditions involving hydrocarbons and oxides of nitrogen. The
chemical reactions are initiated by the action of sunlight on
nitric oxide. Many of the resulting products have been identified,
others have not. Two major characteristics of this complex
reaction system are the general haziness imparted to the atmosphere
and eye irritation. The name "smog" was early given to this
condition, since it was thought to be a combination of smoke and
fog. Subsequent studies have shown that neither smoke nor fog
is involved, but the name has remained.
In general, one or more photochemical smog products, either alone
or in combination, can cause eye irritation, breathing difficulty,
vegetation damage, deterioration of materials and decreased
visibility. Some of the principal features and components of
this system are described below*
a. Oxidant
Oxidant is a term used by many air pollution control experts
in two ways: one describes the capacity of certain oxygen-
containing substances to react chemically in polluted air to
form new products* In this sense, oxidant is a general
measure of smog formation activity. The term is also used to
describe the chemical substances that make oxygen available
for this reaction*
Any oxygen-bearing compound, such as nitrogen dioxide, that
takes part in the photochemical reaction can be termed oxidant*
But ozone is the substance whose name is used almost inter-
changeably with oxidant. This is because ozone usually
comprises the bulk of the measured oxidant and is an early and
continuing product of the photochemical smog reaction.
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1.20
b. Ozone
Early in the photochemical process ozone (CO, a colorless,
pungent gas, is formed. Ozone is an allotropic form of
oxygen; i.e., it is composed of oxygen and will react
chemically to form the same compounds, but its composition
and properties are different. A molecule of ozone consists
of three atoms of oxygen instead of two as in ordinary oxygen.
And, quite unlike oxygen, ozone can cause coughing, choking,
headache and severe fatigue. It can damage the leaves of
plants, crack rubber, deteriorate fabrics and fade colors.
c. PAN and Aldehydes
Another smog product often mentioned is PAN, short for
peroxyacyl or peroxyacetyl nitrate. Although it has been
studied for only a few years, it is known to make the eyes
burn and tear. It has the same irritating effect on the
lungs as ozone and other oxidants, and it can damage plants.
Still another group of photochemical products is the aldehydes.
These result from the union of certain hydrocarbons with
oxygen. They are colorless and, in high concentrations, have
a suffocating, pungent, irritating odor. Aldehydes are strong
irritants of the eyes, skin and respiratory tract.
Aldehydes are also present in the exhaust emissions of
automobiles as products of incomplete combustion of fuel.
III. METEOROLOGICAL INFLUENCES ON AIR QUALITY
The elimination of, or large reductions in, air pollution can only be
accomplished by controlling the sources of emission. The practical
problem that must be dealt with, however, is balancing the costs of
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1.21
reducing air pollution emissions against the amount of reduction that is
required to achieve acceptable air quality levels. This amount of emission
reduction is a function of meteorological conditions and their variations
(12)
in time and space.
The atmosphere is the medium by which air pollutants are transported away
from their sources of emission. For a given source strength, atmospheric
motions govern the length of time and the frequency to which receptors
(humans, materials, vegetation, etc.) will be exposed at varying distances
from a source. Principal meteorological influences include air flow,
topography, vertical mixing, dispersion and others described below.
While these influences are discussed individually, they generally act in
concert. In some situations a combination of influences (for example,
limited vertical mixing together with low wind speeds) may set the stage
for a serious air pollution episode.
A. Air Flow
The most important parameter in the movement of contaminants by the
atmosphere is the wind. The greater the wind speed, the greater the
turbulence and the more rapid and complete is the dispersion of
contaminants in the atmosphere.
Since temperature gradients, both horizontal and vertical, increase
during the winter season, the speed of the wind flow is generally
increased during this time of year. However, occasions occur in
winter when prolonged periods of little or no air motion may occur.
(13)
A study of the frequency of prolonged periods of light air flow
east of the Rocky Mountains in the continental U.S.A. shows that
such situations happen most often in late spring and early autumn.
In addition to the seasonal change, diurnal changes in wind flow
occur at many locations. Night hours are usually periods of low-level
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1.22
stability at most areas within the continental U.S.A. As a result
of the effects of negative buoyancy and the increased energy required
for vertical motions, pollutants disperse slowly and may be confined
in relatively small volumes. The concurrent light, variable wind
may even result in a return flow of material across the original
source. In contrast, the daytime winds are apt to be more turbulent,
of higher speeds, and the vertical motions are enhanced, so that the
maximum dilution of material occurs on clear, sunny days.
The local winds may differ markedly from the general air flow that
characterizes the region. Along the coasts of continents or of the
larger lakes, the temperature differential between the land and
water is sufficient to establish local circulations from sea to land
during the day and from land towards sea during the night. At most
locations, these sea-breeze regimes are well marked only during the
summer and are masked by the general wind flow during the other
seasons. However, in subtropical areas, such as southern California
coastal areas, they may be the dominant weather pattern and occur
with almost clock-like regularity from day to day.
B. Topography
In addition to the sea-breeze conditions of coastal areas, the
topography of an area may be important. Where the air flow is
markedly restricted by terrain, the flow may be persistently and
continuously channeled to a single direction or confined in a
relatively small area. Within a fairly narrow valley, the characteristic
daily wind pattern is a flow up the valley and the slopes in the
daytime, due to solar heating, while just before or just after
sunset, the wind reverses flowing down the slopes and into the
valley. Contaminants released within the valley may be effectively
trapped within a small area for long periods. In addition, the
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1.23
shielding from the effects of general circulation patterns afforded
by the valley walls will result in lower wind speeds along the
valley floor than would be the case in comparably level terrain.
C. Vertical Mixing
Turbulence, or eddy motion, consists essentially of mechanical and
thermal turbulence. Mechanical turbulence is induced by the movement
of wind over the aerodynamic rough surface of the earth and is pro-
portional to the roughness of the surface and to the wind speed.
Thermal turbulence is solar-induced and is a function of latitude, the
radiating surface and the stability of the atmosphere. It is at a
maximum during the summer on clear days and at a minimum during the
long winter nights. When the vertical temperature gradient of the
lower atmosphere is greater than the adiabatic lapse rate, vertical
motions are enhanced, and dispersion, particularly in the vertical,
is more marked. On the other hand, in a stable atmosphere, when the
temperature gradient is isothermal or positive with altitude,
considerable energy must be expended in achieving vertical motion.
Figure 1.2 depicts the diurnal variation of vertical mixing.
A typical daily cycle of temperature gradient over open country on a
cloudless day begins with the build-up of an unstable lapse rate,
which increases during the daytime owing to strong solar heating and
associated well-developed turbulence conditions. Just before or
shortly after sunset, the air near the ground cools rapidly and a
stable lapse rate or temperature inversion (temperature increasing with
altitude) begins to form. The inversion increases with time in
intensity and in depth during the night, reaching a maximum between
midnight and the time of minimum surface temperature. During this
period, contaminants are effectively trapped within or below the
inversion layer with little or no vertical dispersion. It should be
-------
TEMPERATURE
CLOUDY
CLEAR
NEARLY _
NEUTRAL
LAPSE
RATE
o
t-
>
I I I I I I
°F
NIGHT
CLOUDS
MODERATE DISPERSION
NEARLY
NEUTRAL
LAPSE
RATE
DAY
CLOUDS
MODERATE DISPERSION
DAILY TEMPERATURE RANGE
GENERALLY SMALL
DAILY TEMPERATURE RANGE
GENERALLY LARGE
1.2. DIURNAL VARIATION OF VERTICAL MIXING .
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1.25
noted that contaminants released during stable conditions at the
surface are not transported aloft; conversely, contaminants released
aloft from tall chimneys, etc., are not generally transported to the
ground under these conditions.
With the coming of daylight, the ground begins to heat and the in-
version is gradually destroyed. This may result in "fumigation," the
rapid mixing downwards of contaminants which were released aloft
during the night. This condition often leads to high concentrations
during the early forenoon, before the vigorous mixing of fully developed
turbulence re-establishes itself to complete the daily cycle. This
cycle may be broken or modified by the presence of clouds or precipi-
tation, which serves to inhibit the vigorous convection of the
daytime, but also may prevent the formation of strong inversions
during the night.
In urban areas where pollution is most likely, the typical lapse
rate regime of the open countryside is modified, particularly at
night. Industrial processes, increased heat capacity of urban areas
and roughness of the buildings contribute to thermal and mechanical
turbulence, and the enhanced mixing prevents the formation of a surface
inversion. This mixed layer, usually 100-500 feet (about 30-150m)
thick, is capped by an inversion whose base in open country would
have been at ground level. Such a condition may neutralize the
advantage of emission from tall stacks, since the pollutants emitted
will be confined within this relatively shallow layer.
D. Trajectory Analyses
In most discussions of air flow, it is assumed for convenience that
the wind remains steady in direction and velocity over a considerable
period of time and an extensive area. Actually, this is not the case
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1.26
and detailed analyses of wind flow must take these variations into
account. Where the wind flow differs from place to place or with
time, owing to pressure gradient differences or topography, meteoro-
logical trajectory analyses are extremely useful in air pollution
investigations in following the action of contaminants released, or
in tracing measured contaminants to their probable source. The
computation of exact trajectories requires a large number of accurate
wind data, but approximate trajectories can often be evaluated from
only a few wind observations and still serve useful purposes.
E. Atmospheric Dispersion
Atmospheric dispersion does not remove air pollution but merely dilutes
it through an increasing volume. The processes involved are very
complicated and only limited knowledge is available at the present
time. Because the use of a formula or technique for quantitatively
evaluating atmospheric dispersion requires a detailed knowledge of
the meteorological processes involved, it is strongly recommended
that all such evaluations be made by a meteorologist.
Contaminants may be effectively removed from the atmosphere by
gravitational settling if the particle size is sufficiently large.
The smaller particles, which often constitute a large fraction of the
material, may be removed by impaction on the surfaces of the earth,
on vegetation or on buildings, etc. Perhaps the most efficient
cleansing agent of the atmosphere is precipitation. The larger
particles are readily scavenged from the atmosphere by the falling
raindrops. Smaller particles, too, may be accumulated in raindrops
and thus removed from the atmosphere. Some evidence exists that air
pollution may itself slow precipitation-forming processes.
The gaseous contaminants released into the atmosphere will primarily
be removed by absorption, particularly in the oceans and in
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1.27
precipitation. There may be other means of chemical combinations
and subsequent removal, but these are likely to be much less
important.
The character of pollutants may be modified by photochemical or
chemical reactions or combinations which may accelerate (or retard)
the effects of the pollutants on plants, animals or structures.
F. Visibility
Historically, one of the main objections to atmospheric pollution
was the reduction of visibility due to the pall that often hung over
industrial regions. This reduction of visibility is an important
handicap to commercial transportation, particularly aircraft, and
occasionally, in extreme conditions, to automobiles. Visibility is
not, however, a reliable direct measurement of total air pollution
levels, since it is reduced only by the particulate material, such as
smoke and fly ash, sufficient to intercept and scatter visible light.
Gaseous emissions or radioactive pollutants could conceivably cause
more undesirable pollution levels without ever affecting visibility.
Fundamentally, however, the effect of lowered visibility resulting
from pollution is important not because of the reduction of seeing
distance but because of the reduction in the transmission of solar
energy to the ground. During conditions of extreme stagnation, such
as the Donora or London smog episodes, the pollution reached such
high concentrations that a major decrease in solar radiation occurred.
This, in turn, permitted the lower atmosphere to remain stable for
longer periods, creating a "feed back" effect.
IV. AIR POLLUTION CONTROL STRATEGIES
An air pollution control strategy is a measure or combination of measures
selected to reduce mass emission rates to achieve and maintain an adopted
air quality standard.
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1.28
Air pollution control strategies represent methods by which air pollution
control can be rationally planned, taking into account the constraints,
economic and social costs and the technological difficulties that may be
encountered. The development of control strategies contributes to deter-
mining the air pollution control priorities and hence the legislation,
organizational structures, control programs and manpower required to
achieve air quality objectives. The elements of the control strategy
concept include the following:
(1) The existing air quality as measured in the region and
projections of future air quality based on population and
economic growth.
(2) The existing emission levels of stationary and mobile sources
as expressed in an emission inventory, and projected emission
inventories based on population and economic growth.
(3) The ambient air quality standards to be attained for specific
contaminants or classes of contaminants (e.g., sulfur oxides,
particulates, carbon monoxide, hydrocarbons, photochemical
oxidants and nitrogen dioxide).
(4) Demonstration of the degree of emission reduction required of
point and area sources to achieve and maintain the air quality
standards, or to prevent the air quality standards from being
exceeded. Calculations are accomplished by means of a propor-
tional model, diffusion model or other procedures such as the
Air Quality Implementation Planning Program (IPP)(1^) or Air
Quality Display Model (AQDM).(15) Background conditions and
emission increases resulting from projected growth in, population,
industrial activity, motor vehicle traffic and other factors
must be taken into account. Control strategy exercises, usually
part of this process, are applied to select that measure or
combination of measures which achieve maximum benefit at minimum
cost.
(5) Establishment of emission limitations or emission performance
standards by classes of contaminant and source activity, taking
into account the control technology that is available.
(6) Establishment of legally enforceable compliance schedules which
set forth the dates by which all stationary and mobile sources
or categories of such sources must be in compliance. Compliance
schedules are negotiated by the agency with the owners or
operators of individual sources.
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1.29
The control strategy concept thus relates air quality objectives to the
selection, implementation and scheduling of the control measures to be
applied to individual sources of air pollution. The control strategy
process leads to the development of emission reduction plans (compliance
plans) for specific sources. These plans provide the compliance
objectives that must be fulfilled by the owners and operators of the
sources of air pollution. Assurance that compliance is achieved by
specified dates, and thereafter maintained, is the responsibility of the
enforcement program of the air pollution control agency.
V. LEGAL AUTHORITY AND RULES AND REGULATIONS
Effective control of air pollution emission sources requires adequate
legal authority under which enforcement and abatement actions can be
effected. This legal authority derives from the police powers delegated
to the states by the U.S. Constitution and the specialized application
of accepted principles of administrative law. The legal authority may
be divided into two major parts, state enabling legislation and the
rules and regulations of the individual air pollution control agencies
within any state.
A. State Enabling Legislation
Sound enabling legislation at the state level is an essential pre-
requisite in establishing the legal and administrative framework
necessary to organize, staff and fund agencies, provide procedures
for the passage of rules and regulations as they may be required and
to authorize enforcement actions. Imperfections in any enabling
provision may cause delays and even failures in implementing air
pollution control programs. Some essential provisions include:
(1) A comprehensive policy of air resource management intended
to attain and
of the state.'
to attain and protect acceptable air quality in all areas
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1.30
(2) Adequate authority to adopt rules and regulations for all
sources of concern.
(3) Adequate authority to obtain pertinent source data and
information and require periodic reporting of emission
information.
(4) Authority to make emission reports and information available
for public inspection.
(5) Authority to enter and inspect the premises of emission
sources and to conduct and/or require the conduct of
emission tests.
(6) Authority to prevent construction or modification of sources
in accordance with emission and air quality requirements.
(7) Authority to compel compliance with rules and regulations
supported by civil or criminal penalties.
(8) Provisions for injunctive relief where deemed necessary.
(9) Authority to implement emergency episode actions.
B. Rules and Regulations
Regulations which specifically limit emissions of pollutants to the
atmosphere are the heart of air pollution programs. The nature and
extent of emission control regulations are determined by the desired
air quality and the types and sizes of emission sources in the area.
The preparation and application of emission regulations requires
extensive technical knowledge about source operations and conditions.
This is especially critical in documenting source violations by the
field enforcement staff for the purpose of legal actions. Inadequate
understanding in concepts and applications can result in the loss of
critical court decisions, thus weakening the entire enforcement
operation.
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1.31
Rules and regulations are generally comprised of the following:
(1) Emission Limitations
These prohibit the rate of emission in excess of specified
standards and include: (a) stack concentration standards
tested on the basis of weight or volume of emitted pollutant
per unit weight of the carrier gas or per unit of process
quantity or rate (process weight); (b) visible emissions
evaluated on the basis of visual observation, e.g.,
Ringelmann or opacity standards; (c) plant boundary or
downwind concentration limits; and (d) public nuisance
prohibition. (Odor nuisances may be based on measurement
of odor units.)
(2) Equipment Design Standards
These are a class of regulations which specify permissible
features, specifications or standards relating to the design
of equipment or the prescribed use of certain control equip-
ment. Such standards apply, for example, to multiple chamber
incinerators, fuel-burning equipment, fume burner requirements
for residence time and temperature, and requirements for
floating roof tanks and vapor recovery systems for petroleum
product storage and transfer. Regulations concerning minimum
stack height may also fall under this category.
(3) Prohibition of Use of Equipment or Operation
This type of regulation prohibits the use of certain equip-
ment, or the conduct of certain operations such as single
chamber incinerators, beehive coking ovens, hand-fired
combustion equipment, dump burning and various forms of
open and agricultural burning.
(4) Regulation of Fuels and/or Raw Material Composition
These standards regulate the type of fuel, fuel properties,
fuel preparation, fuel grades, fuel handling, fuel supply
and use, fuel treatment, the use of standby fuels and fuel
substitution. Most regulations of this type are directed
at limiting the sulfur, ash and volatile content of fuels.
(See Chapter 6, Section II, Fuel-Burning Equipment.)
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1.32
(5) Emergencies
This is a special type of regulation which enables the
control agency to prepare and use contingency plans in the
event of a potential or an actual air pollution emergency.
The elements of such regulations generally include (a)
establishing emergency air quality standards, generally at
several levels of severity, the attainment or immediate
likelihood of which calls for emergency powers to be exer-
cised, (b) the joint preparation by the agency and industry
of emergency curtailment or shutdown plans to take effect
under stipulated conditions or upon recommendation of
emergency advisory bodies, and (c) in some cases the
installation of emergency communication equipment connecting
the air pollution control agency and selected industries.
(6) Powers
These are a group of supporting rules and regulations enacted
to establish right of entry, police powers, requirements for
the submission of information on pollutant emissions, access
to facilities for source testing and prohibition of
circumvention or evasion of other regulations.
Most of these regulations embody an explicit or implicit emission
limit or design parameter which relates to a quantifiable emission
limit.
The type of standard and the emission limit adopted are based on
control strategies and agency policies. These dictate whether the
standards are to be performance oriented, industry oriented, equip
ment and fuel oriented, or some combination of these. Recommended
standards attainable by current technology are shown in Table 1.2.
The emission limit adopted may be derived by several or a
combination of methods: (a) derivation from air quality
standards, using dispersion models, (b) derivation from rollback
and distance proportional techniques, based on the reduction in
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1.33
Table 1.2. EMISSION LIMITS ATTAINABLE BY AVAILABLE TECHNOLOGY
Type of Emissions
Source
Limits Attainable
Visible emissions
Particulate matter
Sulfur oxides
Industrial stacks
Gasoline powered
motor vehicles
Diesel powered
motor vehicles
Incinerators
Fuel burning equip-
ment (solid fuel)
Process industries
Fuel combustion
(Solid fuel)
(Liquid fuel)
Sulfuric acid
plants
Sulfur recovery
plants
Less than No. 1 Ringelmann or 20
percent opacity except for periods
up to 3 minutes in any 60 minute
period.
No visible emissions except for
periods up to 5 seconds.
No. 1 Ringelmann or 20 percent
opacity except for periods up to
5 seconds.
0.1 pounds per 100 pounds of refuse
charged.
0.1 pounds per million Btu.
Emission rate, 13, in pounds per hour,
given in terms of process. Weight
rate P_, in pounds per hour, is
E=3.59P°-62
if P is 60,000 or less;
E = 17.31 P°'16
if P is more than 60,000.
1.2 pounds SO. per million Btu.
0.8 pounds SO. per million Btu.
6.5 pounds per ton of 100 percent
acid produced.
0.01 pound S02 per pound of sulfur
processed.
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1.34
Table 1.2. EMISSION LIMITS ATTAINABLE BY AVAILABLE TECHNOLOGY (continued)
Type of Emissions
Source
Limits Attainable
Sulfur oxides
(continued)
Total reduced
sulfur
Oxides of nitrogen
Non-ferrous smelters
Copper
Zinc
Lead
Sulfite pulp mills
(certain sources)
Refinery process
gas streams
Kraft pulp mills
(recovery furnace)
Fuel-burning
equipment
(gas-fired)
Fuel-burning
equipment
(oil-fired)
Nitric acid
manufacture
Y = 0.2 X
Y = 0.564
Y = 0.98 X1
0'77
where X_ is total sulfur fed to the
smelter and Y_ is sulfur dioxide
emissions, both in pound per hour.
9 pounds per air-dried ton of pulp
produced (with new recovery systems)
20 pounds per air-dried ton (with
existing recovery systems).
Equivalent to 10 grains of hydrogen
sulfide per 100 standard cubic feet
of gas.
0.1 pounds TRS per air-dried ton of
unbleached pulp (new recovery furnace)
0.5 pounds TRS per air-dried ton of
unbleached pulp (existing recovery
furnace).
0.2 pounds (calculated as N0_) per
million Btu.
0.3 pounds (calculated as NO.) per
million Btu.
5.5 pounds (calculated as N02) per
ton of 100 percent acid produced.
(SOURCE: BASED ON FEDERAL REGISTER, Reference 18)
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1.35
per unit of source necessary to roll back the future pollutant level
to known or presumed pollutant levels in the past., (c) derivation
from process and equipment considerations, considering the
performance of a range of the best constructed and operated plant,
(19)
or the best state-of-the-art technology available. A rational
and realistic approach is one which takes all of these factors into
account. Control strategy exercises play an important role in this
process.
VI. THE AIR POLLUTION CONTROL AGENCY
A. Objectives
The basic objective of air pollution control programs is to protect
the health and welfare of man from the harmful effects of air
pollution. Other objectives include the protection of plant and
animal life, protection of property and prevention of interference
with the normal use, enjoyment and safety of our air resources.
Until recently, local air pollution control programs were oriented
along two major lines: (1) control of smoke and particulates from
combustion sources and (2) control of emissions that were deemed a
"nuisance" by virtue of citizens' complaints. Significant progress
was made in the late 1930's and 1940's in the reduction of smoke
from the combustion of high content matter bituminous coal. These
reductions were made by regulating fuel quality and fuel use.
The air pollution problems of today and the future are concerned
with the complexities of the emissions from more exotic sources,
new and rapidly expanding technology and larger unit operations.
All of these factors are compounded by the achievements of higher
standards of living, consumption of ever increasing goods and energy
and the demand for a healthier environment.
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1.36
This challenge requires a new and highly intensified approach in the
prevention, control and management of all factors contributing to air
pollution problems. The major elements^ in carrying out such
programs include:
(1) Development of a public policy for the improvement and
preservation of air quality.
(2) An organizational framework and staff capable of operating
along functional lines (e.g., engineering, technical services,
field services) supported by adequate funding.
(3) Delineation of realistic long and short range goals that
can be effectively met in reasonable time periods. This
can be presented as an implementation plan calculated to
achieve desired air quality.
(4) Continual assessment of existing air quality and preparation
of estimates of future conditions.
(5) Continual assessment of source emissions, present and future.
(6) Development of the necessary information about factors that
influence the transport of air pollutants.
(7) Assessment of the effects of ambient air quality of a
community or region on man and his environment.
(8) Establishment of program coordination and support with other
governmental organizations such as the state attorney general's
office, fire prevention bureaus, police departments and
planning organizations.
(9) Development of an effective information and educational
program to inform the community of the need to solve air
pollution problems promptly and effectively.
The mechanisms for reaching decisions on a community (or state) level
are of key importance to the success of an air resource management
program. They must provide for the assimilation of information, and
the establishment of goals and policies concerning the management of
the community's air resource. Appropriate communltv -fnvnlvpmAnt- -in
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1.37
the decision-making process must be encouraged to ensure a base of
public support for action.
The degree of success achieved in reaching decisions and developing
policy will depend upon the clear delegation of responsibility to a
key individual. Full support by top management (including chief
elected executives) is essential.
B. Agency Functions and Responsibilities
The organization and elements of an air pollution control program
should be based on the requirements that must be satisfied to
achieve air quality objectives in the given area of jurisdiction.
Knowledge of the requirements arises from a thorough investigation
of the nature and extent of the air pollution problem and the
applicable air pollution control technology or control strategies.
The organization of the air pollution control agency must reflect
the following considerations:
(1) The scope or jurisdiction of the agency with respect to its
responsibility for air pollution and environmental control.
(2) The types, complexities and number of air pollution sources
within the area of jurisdiction.
(3) The role of the agency in planning, rule-making, enforce-
ment, engineering, technical support services, information
dissemination, research, health effects studies, inter-
jurisdictional coordination and other functions.
(4) The level of government at which the agency operates: local
(municipal, county, city-county), regional, state, inter-
state and federal.
(5) The authority of the agency to adopt and enforce regulations
and measures necessary for the attainment and maintenance of
air quality and emission standards.
(6) Work functions or tasks within each program element including
such activities as air monitoring, facility inspections,
source registration, source testing, data handling and
engineering evaluations.
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1.38
(7) Division of responsibility in technical and administrative
functions necessary to carry out the work to be done by
the agency.
The responsibilities assumed by states, local and regional jurisdic-
tions depend on many factors, most notably existing governmental
structures and state-local relationships. In general, state agencies
are assuming increasing authority and responsibility over local
sources of air pollution. Municipalities and counties with large
urban populations tend to have strong, comprehensive air pollution
control programs. However, in accordance with the Clean Air Act,
as amended in 1970, state agencies are assuming increasing respon-
sibility and authority for air pollution control and the support and
coordination of local agencies in their efforts. State agencies
that are responsible for large geographic areas are in a position to
develop balanced, comprehensive programs and to make efficient use
of the total available resources. The intent, however, is for program
activities to remain within the governmental jurisdiction that can
most effectively assume the responsibility. Routine enforcement
actions, for example, are usually most effectively operated at the
regional, county or municipal level.
A suggested division of responsibilities (Table 1.3) can be used as
a basis for developing an organizational pattern.
C. Organizational Structure
The organization of air pollution control agencies varies considerably
depending on the hierarchy of the state or local government. Agencies
located within health departments are generally organized as sub-unit
functions served by laboratory and administrative services provided
by other sub-units (e.g., Figure 1.3). Separate agencies such as
Departments of Air and Water Programs are generally organized as self-
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1.39
Table 1.3. TYPICAL DIVISION OF RESPONSIBILITIES BETWEEN STATE
AND LOCAL AIR POLLUTION CONTROL AGENCIES
STATE AGENCY
LOCAL AGENCY
Possesses legal authority to
implement a plan for attainment
of air quality objectives.
Prepares statewide standards
and regulations.
Prepares emergency episode action
procedures.
Assigns responsibilities to other
governmental agencies (e.g., fire,
police, and planning departments)
to carry out portions of the con-
trol plan.
Enforces statewide standards and
regulations.
Institutes legal action where local
action is deficient or unauthorized;
Provides legal assistance to local
agencies where necessary to support
local enforcement action.
Develops a statewide program for
source compliance.
Defines compliance schedule policy
and monitors for adequate
implementation.
Develops and implements a statewide
permit system of operation.
Develops and maintains a statewide
emission inventory.
Coordinates statewide complaint
handling activities.
Possesses legal authority necessary
to implement any portion of the
state control plan.
Adopts standards and regulations
consistent with, or more stringent
than, those of the state.
Enforces state approved emergency
procedures within local
jurisdiction.
Develops cooperative agreements with
other local government agencies to
carry out control responsibilities.
Enforces appropriate state or local
regulations.
Initiates legal action to support
enforcement and abatement needs.
Develops compliance schedules with
local sources in accordance with
state policy and procedures.
Monitors local sources for progress
in achieving compliance.
Assists the state in the operation
of the permit system.
Provides local source emission
data.
Provides local complaint handling
service.
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1.40
Table 1-3. TYPICAL DIVISION OF RESPONSIBILITIES BETWEEN STATE
AND LOCAL AIR POLLUTION CONTROL AGENCIES (continued)
STATE AGENCY
LOCAL AGENCY
Operates a statewide air
surveillance system.
Provides statewide laboratory-
services .
• Assures consistency of all
analytical and calibration
procedures in state and local
laboratories.
• Conducts source testing on a state-
wide basis.
• Prepares statewide diffusion
climatologies and meteorological
summaries.
• Provides meteorological
consultation.
Develops and maintains statewide
data handling system which
facilitates the retrieval of
•pertinent data for all program
operations.
Operates a local air surveillance
system in accordance with the state
plan.
Provides local laboratory services
to the extent authorized by state
agency.
Provides assistance to state source
test efforts.
Collects and analyzes meteorological
data in accordance with state and
local needs.
Operates local data handling system
compatible with state system.
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r
STATE BOARD OF HEALTH \--
— — — — — — GOVERNOR
STATE DEPARTMENT OF HEALTH
AIR POLLUTION CONTROL COMMISSION
DIRECTOR OF HEALTH
AIR POLLUTION CONTROL
DIVISION
DIRECTOR
ASSISTANT DIRECTOR
| ADMINISTRATIVE SUPPORT] ... | LEGAL COUNSEL
r
ENGINEERING
SERVICES AND
EVALUATION
SECTION
ENFORCEMENT
AND EVALUATION
SECTION
METEOROLOGY
AND TRANSPORT
SECTION
AIR POLLUTION
LABORATORY
ADMINISTRATIVE SERVICES
DIVISION
DIRECTOR
HEALTH EDUCATION
SECTION
AIR POLLUTION EDUCATOR
Figure 1.3. ORGANIZATIONAL STRUCTURE OF COLORADO DIVISION OF AIR POLLUTION CONTROL (JANUARY 1970)
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1.42
supporting entities with functional responsibilities aligned within
the program (e.g., Figure 1.4).
In theory, the organizational configuration of the agency has minimal
influence on the effectiveness of the operation. In practice, however,
a significant number of functional weaknesses can be traced to poor
organizational structure which are frequently compounded by poorly
defined responsibilities. An effective control agency needs:
(1) capable and competent staff, (2) a clearly defined organization
aligned with functional responsibilities, (3) clearly defined lines
of authority and (4) adequate support. Figure 1.5 is a suggested
organization that best satisfies these requirements for effective
operations.
All state agencies in accordance with the responsibilities outlined
in the Clean Air Act, as amended in 1970, would have comprehensive
responsibilities for the prevention and control of air pollutant
emissions. The organization and functional responsibilities of local
agencies will vary depending on their role in the state's total
control plan. In the larger urban areas, the local control agency
will generally assume comprehensive responsibility (see Figure 1.6)
similar to the state agency. At the other end of the scale, minimal
agencies will assume responsibility for specified field surveillance,
inspection and enforcement activities. The organization should
reflect the functional responsibility. In all instances the state
agency must fill all program voids in addition to prescribing guidance,
leadership and coordination to the local agencies.
D. Staffing Patterns
The scope and organization of an air pollution control agency is
customarily expressed in terms of manpower and functional staffing
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State of Oregon
DEPARTMENT OF ENVIRONMENTAL QUALITY
ENVIRONMENTAL QUALITY COMMISSION
OFFICE OF THE DIRECTOR
WASTE DISCHARGE PERMIT
& TA* CREDITS SECTION
HATER QUALITY CONTROL DIVISION
MUNICIPAL SEWERAGE SECTION
Opera t ! on , Ma i ntenance
and Training Program
Plan Review Program
Construction Grants Program
INDUSTRIAL WASTE SECTION
WATER QUALITY STUDIES SECTION
SOLID WASTE PROGRAM
AIR QUALITY CONTROL DIVISION
ENGINEERING £ TECHNICAL
ASSISTANCE SECTION *
FIELD SERVICES SECTION
LABORATORIES & TECHNICAL
SERVICES DIVISION
AIR QUALITY MONITORING
WATER QUALITY MONITORING
TECHNICAL SERVICES PROGRAM
J_
DISTRICT OFFICES
PORTLAND
EUGENE
HEDFORD
PENDLETON
BEND
* Includes enforcement activities.
Figure 1.4. DEPARTMENT OF ENVIRONMENTAL QUALITY, STATE OF OREGON (JANUARY 1971)
-------
Governor
or
Parent Organization
[Division of Air Pollution Control|~
Air Pollution Control,
Commission
Advisory Board
Administrative Services
—[Engineering Services]
—Emission Inventory
— Source Testing
— Industrial Surveys
— Regulation Development
—Permit System
Compliance Schedules
— Special Studies
1—Local Agency Assistance
-Legal Counsel
-Training, Information and Education
—{Field Services!
-Field Surveillance
Source Inspection
"Complaint Handling
•Prosecution
-Compliance Monitoring
-Local Agency Assistance
j—(Technical Services)
— Laboratory Operations
— Instrument Calibration
— Data Analysis
—Meteorology
—Air Monitoring
— Special Studies
— Local Agency Assistance
Note: Local agency assistance and coordination may be elevated to a fourth program unit
if warranted.
Figure 1.5. SUGGESTED ORGANIZATIONAL STRUCTURE OF AN AIR POLLUTION CONTROL AGENCY.
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1.45
MAYOR, MANAGER,
COMMISSION, BOARD OR
MUNICIPAL DEPARTMENT
AIR POLLUTION
CONTROL OFFICER
HEARING OR APPEALS
BOARD
MANAGEMENT
TECHNICAL ADVISORY
COMMITTEES
PUBLIC INFORMATION
AND EDUCATION
TECHNICAL
SERVICES DIVISION
Air quality measurement
Laboratory analyses
Data processing
Meterology
Effects studies
FIELD SERVICES
DIVISION
Patrol
Source inspection
Complaints
Court cases
Plume evaluation
training
ENGINEERING
DIVISION
Construction permits
Source testing
Industrial surveys
Regulation development
Emission inventory
Figure 1.6. TYPICAL ORGANIZATION CHART FOR A LOCAL GOVERNMENTAL AIR POLLUTION
CONTROL AGENCY
CSOURCE: SCHIJENEMAN, Reference 17)
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1.46
(staffing to perform prescribed tasks). A systematic approach to
agency development quantitatively relates staffing to the expected
work required to achieve reductions in emission rates necessary to
meet air quality objectives within prescribed periods of time.
In the initial stages of program development, control agency manage-
ment must establish a priority system of operation as a part of its
program planning. As funds and positions are made available,
competent staff members must be selected who possess the specific
skills that will contribute to satisfying these priorities. Early
priorities will likely include data gathering activities, which will
require the establishment of an air quality monitoring program, and
assembling information on the sources of pollution in order to assess
their contribution to air quality and to prepare reasonable compliance
schedules. Field operations are then implemented to monitor compliance
and to develop effective control and enforcement procedures.
Table 1.4 summarizes functions associated with air pollution control
programs. Each function or group of functions requires a specific
category of skills.
E. Intergovernmental Relationships
The complexities of air pollution problems necessarily involve many
governmental agencies, frequently at different levels of operation.
For example, the operation of a permit system may require the parti-
cipation of a department of public works. Construction of a new
facility capable of emitting air contaminants is of interest to zoning
and planning organizations. The use of wet collection devices is of
concern to water pollution and solid waste control agencies. The
issuance of an open burning permit requires the attention of the fire
department. Many control agency activities, therefore, must interface
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1.47
Table 1.4. SUMMARY OF FUNCTIONS FOR AIR
POLLUTION CONTROL PROGRAMS
1. Management Services
a. Policy
b. Administration and fiscal management
c. Public information and education
d. Intergovernmental liaison
e. Legal counsel
f. Staff training and development
g. Program planning and evaluation
h. Clerical support
2. Field Enforcement Services
a. Inspections and compliance monitoring
b. Complaint handling
c. Field surveillance
d. Preparation for legal actions
e. Implementation emergency episode procedures
f. Source identification and registration
g. Clerical support
3. Engineering Services
a. Emission inventory
b. Permit system and compliance scheduling
c. Source testing
d. Technical development of control regulations
e. Preparation of technical reports, guides and criteria on control
f. Design and review of industrial emergency episode procedures
g. Clerical support
4. Technical Services
a. Laboratory operations
b. Operation of monitoring network
c. Data acquisition, processing and reporting
d. Special field studies
e. Instrument maintenance and calibration
f. Clerical support
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1.48
with one or more external agencies. This interface may extend to
governmental agencies above or below the agency initiating the action.
For example, a regional air pollution control agency may require
involvement of a state water pollution control commission in decisions
regarding scrubber effluent 'discharges.
As cooperative program activities are established it is important
that a clear understanding of responsibilities and operating
procedures be established. A protocol document or memorandum of
agreement serves as an excellent means of providing clear understanding
for such joint relationships. Written agreements in field
operations should be generated with such agencies as public works,
fire and police departments. The contents of such documents should
be reviewed periodically for the purpose of upgrading working
relationships and eliminating obsolete arrangements.
VII. THE FIELD ENFORCEMENT OFFICER
Field enforcement personnel assume that portion of the control agency
function which is directly responsible for the implementation of control
strategies designed to achieve desired air quality levels. They constitute
the primary field operations arm of the air pollution control agency.
A. Scope of the Field Operations Program
The major external determinants of the field operations program are
the types and numbers of stationary sources that require inspection,
as determined from source registration and the emission inventory
(See Chapter 2, The Enforcement Process). The major internal
determinants are the number and types of rules and regulations that
must be enforced, the source registration support required, permit
and certification systems support and the operating policies and
problems of the agency. Field personnel also must deal with
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1.49
motivations, needs and problems of individuals and with other environ-
mental, economic, legal and social considerations that are encountered
in the field.
Enforcement activities fall into four categories: (1) field surveil-
lance and patrol, (2) engineering and source inspections, (3) general
investigations and complaint handling and (4) administrative,
supervisory, clerical and other support functions. Smaller agencies
may combine the functions of field inspectors, engineering inspectors
and case investigators. Agencies concerned with an extensive and
diversified stationary source population will have larger and more
varied work loads, and will require a greater degree of specialization
in the work force.
B. The Field Enforcement Officer
The background and degree of special training required of field
enforcement personnel depend on the major responsibilities to be
assigned to a particular individual. The scope of these responsibilities
are influenced by the size of the agency, the number and types of
sources to be observed and inspected and the availability of support
services. The smaller agencies, by necessity, combine field
enforcement functions and usually rely on assistance from other
related governmental agencies or organizations.
(21)
The field enforcement officer is in a position of constantly
meeting people, solving problems, obtaining information, conducting
investigations and issuing violation notices. An unusual person is
required to handle such varied duties with skill and diplomacy.
Accordingly, a field enforcement officer should possess:
(1) A mature personality capable of dealing with the public in
an efficient, business-like manner, often under strained
conditions.
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1.50
(2) Ability to gather facts and information and organize such
material in a concise and informative manner.
(3) Sufficient background and training in the physical sciences
and the ability to communicate in the field of air pollution
and source technology.
(4) Potential in legal enforcement and ability to provide court
testimony.
(5) Ability to function as an effective member of an air
pollution control team.
These requirements relate to skills and aptitudes and may, in many
cases, be independent of experience and education. They can be deter-
mined, to some extent, by aptitude test and job screening. Some of
the skills, given basic aptitudes, can be further developed through
on-the-job training. Some specific capabilities that are particularly
important in enforcement are:
(1) High general intelligence (arithmetical and verbal)
(2) Ability to comprehend engineering and legal information
(3) Objectivity, judgment and emotional stability
(4) Motivation
(5) Approach and appearance
(6) Ethics and sense of responsibility.
Field enforcement officers must be able to comprehend the law and to
relate code sections or rules to corresponding problems encountered
in the field. They should be able to discriminate from the facts
gathered in the field among flagrant, chronic, borderline or accidental
violations and to recognize sincerity and motivation on the part of
plant operators. They must be able to analyze situations for the
objective facts and be able to enforce the law equally and firmly.
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1.51
The ability of the field enforcement officer to express himself
completely and accurately, orally and in writing, is important since
his findings are always being reported for proper action. Particularly
is this important when an enforcement officer testifies in court or
explains a law or policy to a plant operator.
The greater the technical background of enforcement officers, the more
the field operations program will be able to probe field problems.
The technical background that will be required will vary according to
the responsibilities assigned. Enforcement officers should have or
be able to acquire a basic knowledge of combustion processes and
equipment operation. They should be able to identify and classify
equipment and processes for source registration and emission inventory
purposes, and to determine the causes of air pollution problems. The
enforcement officer may be required to correlate such data as excessive
pouring temperatures, alloys, fluxes used and relative volatilities
of metals with the opacities or densities of emissions he observes.
Enforcement officers specializing in complex industries will generally
require greater technical background in chemistry, chemical engineering
or mechanical engineering.
C. Training
Training of field enforcement officers is an essential part of the
field operations program. It currently plays an indispensable function
in certain enforcement functions, such as the certification of field
enforcement officers as expert smoke readers, preparation of enforce-
ment officers as court witnesses, orientation to industrial processes
(22)
and control technology and on-the-job field training. In
addition, a number of different types of courses are available at
the state level, Office of Manpower Development, Environmental
Protection Agency and a number of universities. Such courses serve
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1.52
the important purpose of transmitting ever-expanding information on
environmental control technology to where it is most needed—in the
field.
The training of field enforcement officers, however, is an area of
professional development that has been largely overlooked. The field
enforcement officer has been isolated in the field and isolated from
other professionals working in air pollution and environmental control.
This situation tends to result in the absence of communication of
enforcement technique and experience among air pollution control
agencies which is necessary to the evolutionary development of the
state-of-the-art. This condition is illustrated by the paucity of
published information available on enforcement technique as compared
to other facets of air pollution control.
Training of field enforcement officers in the future, therefore,
should include training which is conducted by the field enforcement
officers themselves in the form of seminars and conferences which
will permit the exchange of information on enforcement and the
development of future curricula and areas of investigation.
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1.53
REFERENCES
1. Air Pollution Primer. National Tuberculosis and Respiratory Disease
Association, New York City, 1969.
2. Inventory of Air Pollutant Emissions. Environmental Protection Agency,
DAP. Raleigh, N.C. 1971.
3. Air Quality Criteria for Particulate Matter. G.P.O. AP-49. January 1969.
4. Sheehy, J. P., W. C. Achinger, and R. A. Simon. Handbook of Air Pollution.
DREW, PHS, NCAPC. P.H.S. No. 999-AP-44. (No date).
5. Corn, M. Nonviable Particles in the Air. In: Air Pollution,
A. C. Stern (ed.). New York City, Academic Press, 1968.
6. Tebbens, B. D. Gaseous Pollutants in the Air. In: Air Pollution,
A. C. Stern (ed.). New York City, Academic Press, 1968.
7. Air Quality Criteria for Sulfur Dioxide. G.P.O. AP-50. January 1969.
8. Air Quality Criteria for Carbon Monoxide. G.P.O. AP-62. March 1970.
9. Air Quality Criteria for Hydrocarbons. G.P.O. AP-64. March 1970.
10. Air Quality Criteria for Nitrogen Oxides. G.P.O. AP-84. January 1971.
11. Air Quality Criteria for Photochemical Oxidants. G.P.O. AP-63. March 1970.
12. World Health Organization, Expert Committee on Environmental Sanitation (ed.)
Air Pollution. New York City, Columbia University Press, 1961.
13. Korshover, J. Climatology of Stagnating Anti-cyclones East of the Rocky
Mountains, 1936-1965. DHEW, PHS. PHS No. 999-AP-34. 1967.
14. Air Quality Implementation Planning Program (IPP), Vol. 1, Operator's Manual.
DHEW, National Air Pollution Control Administration, Washington, D.C.
November 1970.
15. Air Quality Display Model (AQDM). DHEW, National Air Pollution Control
Administration, Washington, D.C. November 1969.
16. State Air Laws. Environmental Reporter. Bureau of National Affairs, Inc.,
1971.
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1.54
17. Schueneman, J. J. Air Pollution Control Administration. In: Air Pollution,
Vol. Ill, A. C. Stern (ed.). New York City, Academic Press, 1968.
18. Requirements for Preparation, Adoption, and Submittal of Implementation
Plans. Federal Register, Vol. 36, No. 158. August 14, 1971. [Tablel.2 is
expanded from this source.]
19. Stern, A. C. Air Pollution Standards. In: Air Pollution, Vol. Ill,
A. C. Stern (ed.). New York City, Academic Press, 1968.
20. Guide Class Specifications for Air Pollution Control Positions in State and
Local Programs. Environmental Protection Agency, GAP. July 1971.
21. Weisburd, M. I. Air Pollution Control Field Operations Manual. DREW, DAP.
P.H.S. No. 937. 1962.
22. Manpower and Training Needs for Air Pollution Control. Report of the
Secretary, DHEW to the Congress of U.S. June 1970.
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2.1
CHAPTER 2
THE ENFORCEMENT PROCESS
I. INTRODUCTION
The responsibility for reducing or curtailing air pollution falls on the
enforcement branch of the air pollution control agency. This mission can
only be accomplished by means of direct and frequent contact with the
owners and operators of the sources of air pollution in order to ensure
the widespread use of the best of the available control technology.
Enforcement of the rules and regulations is the primary mechanism for
achieving this goal. Both the standards contained in the rules and
regulations and the procedures used in their enforcement, therefore, should
be clear and certain from the standpoint of both voluntary and compulsory
compliance.
II. OVERVIEW OF THE ENFORCEMENT PROCESS
Many administrative, legal and technical factors must be considered in
attempting to achieve mass compliance on a large scale at the earliest
possible time. To help visualize the interrelationships of these factors,
Figure 2.1 presents an overall view of the functional elements of the
enforcement process and identifies variations in practices among a number
of major air pollution control agencies.
A. Field Operations
Field operations (top center of Figure 2.1) initiate the enforcement
process by establishing whether or not individual emission sources
comply with the rules and regulations. To meet this objective, enforce-
ment personnel perform the following functions:
• Notification. Apprise all affected owners and operators of
compliance requirements.
• Surveillance. Detect, observe and identify all emission
sources.
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2.2
FIELD OPERATIONS
Scheduled Inspections
General Surveillance
Follow-up Inspections
Special Inspections
urce Registration Questionnaire Processing Subsystt
B j Permit Application Processing Subsystem
Emission Inventory Preparation
©
Appeals
EMISSION INVENTORY
ENFORCEMENT
MANAGEMENT SYSTEM
(EI/EMS)
Figure 2.1. OVERVIEW OF THE ENFORCEMENT PROCESS. ALTERNATIVE 1: ADMINISTRATIVE CON-
FERENCE; ALTERNATIVE 2: NOTICE-TO-COURTS; ALTERNATIVE 3: PETITION FOR
VARIANCE BY SOURCE; ALTERNATIVE 4: REVOCATION OF PERMIT.
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2.3
• Inspection. Enter facilities and inspect all emission sources
to determine compliance and gather information pertinent to
factors causing emissions, conduct necessary emission and
other tests, collect evidence, issue violation notices or
citations and promote voluntary compliance.
The term "compliance" means that a source does not violate any rule
and regulation. At least 3 statuses of compliance should be
distinguished:
• Continuing Compliance—the realization of a source emission
reduction plan or emission limit requirements on a continuing,
long-term basis. Continuing compliance implies confidence
that the facility is operating with little or no risk of
violation and requires minimal surveillance.
• Functional Compliance—the status of a facility only at the
time it is observed or inspected by a field enforcement officer.
A facility is in technical compliance whenever insufficient
information or evidence is available to justify serving a
violation notice or citation even though non-compliance may
be suspected. This includes situations where source testing
or special investigations may be required to make a definitive
compliance determination.
• Non-Compliance—any violation of a rule or regulation supported
by valid information and evidence and justifying the issuance
of a violation notice or citation.
Thus, any individual observation or inspection of an emission source,
as shown in Figure 2.1, results in 1 of 2 determinations: (1) compliance,
(2) non-compliance (violation). These necessitate two distinct
processing procedures. Reports of compliance (both continuing and
functional) are reviewed, processed and rescheduled for inspection.
Functional compliance cases, particularly those where violations are
suspected, are assigned higher surveillance and inspection frequencies,
or require special follow-up action, such as source testing. Where
non-compliance is established, violation notices are issued, reviewed
and processed towards legal action until continuing compliance is
achieved.
The handling of functional compliance cases is the greatest problem
facing enforcement personnel. While violations of visible emission
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2.4
standards and permit infractions are relatively easy to demonstrate,
violations due to grain loading, process weight, fuel composition or
standards regulating gaseous contaminants are more difficult and
require special handling. Compliance determinations in these cases
are made after sufficient information is gathered by the field
enforcement officer on the design, operation and maintenance of the
equipment. This is accomplished by gathering information on the
inspection points appropriate to each class of source, as described
in the inspection points sections of Chapters 5, 6 and 7. The infor-
mation collected may establish the requirement for fuel and material
sampling, review of facility plans and operational data, and the
performance of special emission source tests or ambient air monitoring.
The enforcement officer should recommend appropriate sampling methods
in order to obtain data that show whether or not the emission
source is in continuing compliance through all ranges of its
operation.
B. Enforcement Actions
Enforcement action is indicated whenever a notice of violation or
citation has been issued or whenever a report has been written that
establishes all of the facts and evidence necessary to prove the
occurrence of a violation of the rules and regulations. The objective
of enforcement is to bring all sources which are in violation into a
continuing compliance status as soon as possible.
Common variations in the processing of violation notices and reports
among a number of air pollution control agencies are shown in the
vertical information flow down the center of Figure 2.1. Even within
one agency, alternative paths to compliance short of, and/or including,
legal action may be provided for. These will depend on the history of
the agency, the powers delegated to it, the stage of its development
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2.5
and its administrative skills.
Alternative 1. Administrative Conferences and Hearings.
The owner or operator of a facility in violation is requested to
attend an administrative conference or hearing, usually at control
agency headquarters. Informal or preliminary hearings are presided
over by enforcement agency staff members. Formal hearings may be
presided over by the air pollution control officer, a hearing
master or hearing board. The owner may cooperate by agreeing to
correct the problem or to prepare a compliance plan or schedule.
The facility is periodically inspected by field enforcement
officers to establish if the problem has been corrected according
to schedule. If repeated violations occur, the case may be prose-
cuted in the courts. Administrative conferences may also be
conducted at the facility. (See Administrative Hearing Process,
Section II, Chapter 3.)
Alternative 2. Notice-to-Courts Route.
In this procedure, the preparation of a written notice auto-
matically leads to the preparation of a misdemeanor complaint and
prosecution in the courts. Investigation is generally conducted
to confirm field evidence and source ownership and responsibility.
(See Section III, Hearing Boards, and Section IV, Courts, Chapter
3.)
Alternative 3. Variance.
This alternative is a procedure which is initiated by a facility
which has knowledge of compliance requirements and wishes to
obtain a variance from the affected rules and regulations in
order to correct an air pollution problem. The owner petitions
a hearing board for a variance from an affected rule or regulation
to correct its emission problem. The hearing board may either
grant or deny the variance. The granting of the variance usually
will depend on the nature of the problem, the equities involved
and the preparation of a compliance plan. Compliance with the
terms of the variance is checked by the field enforcement officer.
Alternative 4. Permit Systems.
This alternative is employed by enforcement agencies that operate
permit systems. Where a permit or certificate to operate equip-
ment is granted, but the equipment is found later to repeatedly
violate the rules and regulations, the air pollution control
agency may petition the hearing board to revoke the permit.
Similarly, the owner of the equipment may petition a hearing
board, with cause, if an agency denies a permit application.
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2.6
The compliance path that should be used depends on the nature of the
violation. Some violations may be due to negligence and are easily
corrected through improved equipment operation or maintenance. Others
may be due to difficult engineering problems which may be costly and
difficult to correct. In the latter case, some form of negotiated
compliance plan should be prepared by the owner of the equipment and
evaluated by the control agency.
The compliance plan thus may be the result of an administrative
conference, a hearing board action or a court action. The procedure
selected should be one which provides for decisiveness and speed in
reaching the desired compliance. Care must be taken, however, in
adopting enforcement procedures which, because of appeals and court
reversals, ultimately diminish the legal authority of the agency.
The legal history and precedents established by an air pollution
control agency are as much an integral part of the legal authority
as the written laws which it enforces.
C. Relationship to Other Control Functions
The enforcement activity is interrelated with certain information
gathering, planning and regulatory functions carried on by other
branches of the air pollution control agency, such as engineering,
technical and administrative services. The principal elements of
concern to the enforcement function are shown as data gathering
and processing subsystems on the left side of Figure 2tl. These
include the following:
(1) Source Registration. Source registration is the process of
gathering, usually for the first time, data on the name,
location, nature of business, ownership, number of employees,
fuel use, refuse disposal practices and other information
from all industrial, commercial and governmental facilities
that conduct activities that cause the emission of air
contaminants. It is conducted for the purpose of identifying,
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2.7
locating and assessing the stationary source emission problems
of an area. The information is usually gathered by means of
a questionnaire sent to industrial and commercial establishments
and is verified, updated or supplemented by field inspection
reports, as shown in Figure 2.1. The equipment inventory
procedure, described in Section IV B, is, in effect, a source ,..,
registration process performed by field enforcement personnel.
(2) Emission Inventory. The emission inventory is a process
whereby available data on source activity and source tests
are collected and evaluated to quantify the emission potential
of an area. The emission inventory is a tabulation of emission
rates in weight units by contaminant, time interval and grid
area. All significant categories of emission sources are
accounted for: Moving sources (motor vehicle and other trans-
portation sources), area sources (residential and other widely
distributed sources), and stationary sources (fixed or point
sources of high emission rate). The emission inventories are
used to rank emission sources by the importance of their
contribution to air quality and specific air pollution problems.
The emissions inventory thus establishes emission reduction
priorities and a basis for scheduling of field enforcement
inspections and activities.
(3) Permit System or Other Plan Review or Certification Systems.
These are engineering plan-review systems which regulate the
construction and operation of equipment capable of emitting
air contaminants. In the permit system, an applicant wishing
to construct or operate new equipment capable of emitting air
contaminants submits information on the design, location,
performance and operation sufficient to making an engineering
determination of the potential of the equipment to comply with
the rules and regulations. If operation of the equipment is
likely to result in compliance, the permit to construct or
to operate is granted. If the equipment is not likely to
comply, the permit is denied. Some agencies require authority
to construct and a separate permit to operate. Other agencies
limit their requirements to permits to operate. Permits are
frequently separately required for basic and air pollution
control equipment. The term "certificate" is sometimes used
in lieu of "permit." The permit system is usually conducted
by the engineering services branch of the agency. It is
enforced by field enforcement officers who may also participate
in approval or denial decisions. (2,3)
Depending upon the policies and programs of any given agency the
above functions may be coordinated through the administration of a
permit system, or by an Enforcement Management System (EMS) or
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2.8
Emission/Inventory/Enforcement Management System (EI/EMS), as shown
in Figure 2.1. The latter will tend to be employed where permit
systems are not practiced or the permit system is not employed as
the principle means of achieving source reductions.
Each of the subsystems (A), (B) and (C) shown in this figure are
stand-alone systems usually operated by the engineering services
branch of the agency. Pertinent field inspection reports, particularly
those which have been prepared to follow-up on source registration
and permit system actions, are input to these systems as required.
Principal data storage and retrieval may be accomplished by an
automated data processing system which maintains separate data bases
from information extracted from each of the subsystems shown. The
EI/EMS should have the ability to schedule field inspections, conduct
selective data retrievals, conduct data analysis and to generate
summary and other status reports as may be required.
The following sections of this chapter further describe the elements
of the enforcement process that are of most concern to enforcement
personnel.
III. FIELD SURVEILLANCE PROCEDURES
Field surveillance is a field operations activity which provides for the
systematic detection and observation of emission sources in all areas of
the control jurisdiction. Observations are made of whole industrial areas
and the exteriors of facilities for visible emissions, odors, contaminant
damage, new facility construction or expansion and other visual or sensory
manifestations of air pollution.
Surveillance is conducted mostly by means of vehicle patrol. Aircraft,
television, ambient air-sampling devices and pollutant-detection instru-
ments can be used as aids in source detection, as discussed in Chapter 4
and other chapters of this manual.
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2.9
A. Field Patrol
Vehicle patrol is the principal surveillance method. Field enforce-
ment officers drive their vehicles throughout a defined area such as
a zone, sector or district,* and major traffic arteries, to observe
visible and other evidence of emissions and to detect possible
violations of the rules and regulations. The field enforcement
officer patrols in a manner that will bring the greatest area of his
district under view while taking the shortest route. He observes
both specific industrial plants and whole source areas at a time
within the radius of his vision. Each location is patrolled at
different times each day and maximum use is made of vantage points.
When a visible emission is observed, the enforcement officer gets as
close as possible and in proper position to read the emissions (see
Section III, Plume Evaluation, Chapter 4).
As the enforcement officer becomes familiar with his district, he
concentrates on sources requiring the greatest attention, and on
areas of high source density. He may employ a check list of facilities
that are currently involved in permit cases, hearing board actions,
recurrent violations or complaints. (See Figure 2.2.)
Patrols should be conducted with the awareness of the probability of
observing violations. The chance of observing recurrent visible
violations increases with the interval of time during which the
facility is under observation if the observation is randomized with
(o)
time. J For a facility observed 1 hour during each 8-hour day, the
probability of observing instantaneous violations in a district during
an 8-hour period is 1 in 8. The chance, however, that any instantaneous
violation will escape detection in 20 violations is 1 in 16. A district
The term district or inspection or enforcement district will be used for
zones or sectors throughout this discussion.
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2.10
AIR POLLUTION CONTROL DISTRICT - COUNTY OF LOS ANGELES
ENFORCEMENT DIVISION - SURVEILLANCE INSPECTION RECORD
Inspector's Name Donald Jordan
Date March 15, 1972
Total
No. Insp.
Plant R. No. Odor j
! Time or
1NO.
096
013
7:30
8:00
% Opac.
24%
Intensity!
(0-5) I
|
* !
Remarks
Cupola hatch open
Heavy shipments of offal
452
9:00
70%
See breakdown report
613
072
Oil
132
045
10:00 50%
11:30
3: 00pm 30%
4:30 80%
i
i
!
i
3
4
M/C incinerator overloaded. F-notice issued.
Cannery odors. Inventory inspection.
Galvanizing operation.
Accidental fire. Fire Department notified.
Mercaptan odors, S.W. of sour water treatment.
—
..
Figure 2.2. SURVEILLANCE INSPECTION RECORD (Courtesy of Los Angeles County Air Pollution
Control District)
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2.11
which enables a field enforcement officer to detect all sources
experiencing recurring violations within any month may be considered
to be providing adequate surveillance coverage.
The main thrust of the field operations program is directed at
activities conducted during normal working hours when most of the
air pollution takes place. It is particularly critical to reduce
emissions during this time in order to minimize peaks in contaminant
concentrations and to prevent episodes.
Some large stationary sources such as power plants, Kraft mills and
oil refineries operate continuously, and may gear maximal releases
of contaminants during the late afternoon, evening and morning hours
to increase productivity. Some of this activity may be deliberate
to evade surveillance. Other activities, such as open burning,
the use of unapproved incinerators or unpermitted processes may also
be conducted at this time.
Air pollution during the evening is in itself undesirable. Fog and
atmospheric stagnation, and sometimes air pollution conditions can
occur during the evening and early morning hours. Many nuisance
complaints are reported at these times since individuals wish to
enjoy respite from any form of pollution during their leisure hours.
The scheduling and deployment of enforcement personnel to after-hours
surveillance will depend on information on complaints, knowledge of
the sources in the individual districts and data on hours of operation.
(This information can be retrieved from the source registration
system.) During evening hours, travel conditions are such that any
point in the community can be easily reached. Therefore, minimal
manpower is required during these hours. It is important, however,
that contact be maintained with enforcement officers in the field by
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2.12
means of a 2-way radio communications system. Observation and in-
spection of source activities requiring special attention should be
made.
B. Field Surveillance Coverage
Certain administrative activities contribute to the surveillance
function. These include the unitization, scheduling and assignment
of field work. These determine the degree to which the area is to
be kept under observation and the frequency with which emission
sources are to be observed and inspected in the field, in relation to
available manpower and resources.
1. Unitization of Field Work
The field enforcement officer divides his time among facility
inspection, patrol, complaint investigation and other office
and field activities. The time available for surveillance is
thus related to overall enforcement assignments and work loads.
Field assignments may be made on the basis of any one or
combination of the following factors:
• Geographic district assignment
• Source emission classification and relative importance
• Facility inspection schedules.
(3)
The following units comprise the basis of assignment of field
operations activities:
(a) Equipment Unit—a functionally whole piece of basic or
air pollution control equipment that is subject to
inspection. It is used as a basis for tabulating sources
of air pollution as definable points of emission.
(b) Work Unit—a work unit represents a unit of effort of
engineering or enforcement activity associated with a
specific class of equipment, process or facility. It
may represent a range of values (e.g., 1-18) reflecting
the complexity of equipment to be inspected and evaluated,
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2.13
or it may be based on expenditures of time (e.g., 15-minute
intervals). The work unit is a basis for balancing man-
power.
(c) Facility Address-Location—the premises at which a
facility is observed and/or inspected. Each address
location is subject to a separate inspection report.
(Note: a firm may operate facilities at more than one
address-location.)
(d) Grid Assignments—this is a coordinate reference system
superimposed on a map of the area. The system is usually
based on the Universal Trans Mercator (UTM) system which
provides for basic unit squares of equal area. Grid
systems of this type are used primarily for referencing
emission source information (e.g., emission inventory).
It can also be used as a basis for establishing enforce-
ment district boundaries and to pinpoint emission sources
subject to observation and inspection.
(e) Enforcement Districts—these are administratively defined
geographic areas that are used for the assignment of field
enforcement personnel. One or more enforcement officers
are assigned to each district. The area of the district
is based on the number of estimated work units
(see above) that can be managed by 1 enforcement officer
over a period of time, such as a year. Allowance is made
for field patrol and time off for holidays, vacations,
sick leave, etc. A given district will be comprised of a
combination of grid squares which provide information
used in sizing the district.
(f) Surveillance Measures—these include the number of odometer
miles driven on patrol of any enforcement districts in any
one day together with the time spent in general and specific
surveillances of areas and facilities.
The size of an enforcement district is, therefore, associated with
equipment units, work or inspection units, number of facility address-
locations and the vehicle miles and time required to maintain
comprehensive surveillance. The quantitative relationships among
these factors are entirely dependent upon the needs, resources and
experience of the air pollution control agency.
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2.14
2. Inspection Scheduling
Inspection scheduling represents another systematic method for
effecting the required surveillance since an important part of
the inspection process includes source observation. Source
inspections, which are treated in the next section, fall into 2
broad categories:
• Unscheduled inspections are a direct result of field
surveillance activities. For example, if a field
enforcement officer observes a visible emission
violation, responds to a citizen's complaint or a report
of equipment breakdown, he then conducts a physical
inspection of the facility as soon as possible. These
types of inspections generally assume priority over
scheduled inspections.
• Scheduled inspections are inspections intended to be con-
ducted on or by a certain date, or represent an assigned
annual frequency of inspection, which the enforcement
officer schedules at his convenience.
Inspection scheduling may be based on source registration,
emission inventory and permit system follow-up requirements as
shown in Figure 2.1. Frequencies of reinspection also depend on
recommendations of field enforcement officers and supervisors made
on previous inspections. Ideally, scheduled inspection frequencies
should be proportional to the emission potentials of the emission
sources, as determined by the emissions inventory and the enforce-
ment management system, shown in Figure 2.1. Accordingly,
facilities can be assigned priority inspection categories, for
example:
Priority Inspection Examples of
Category and Frequency Emission Sources
I: 4-6 times per year Steel mills, Kraft mills, aluminum reduction
plants, refineries, chemical plants.
II: Twice per year Plating plants, printing plants, apartment
houses, mining operations, woodworking industries
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2.15
Priority Inspection Examples of
Category and Frequency Emission Sources
III: Once or less per year. Commercial establishments, office
buildings, warehouse facilities, etc.
Inspection frequencies employed in any given agency may be less
or greater than those shown in the above examples.
The scheduling process should not be completely automated. It
must rely heavily on the recommendations of the field enforcement
officer and the report review process. The management of air
pollution problems involves factors that are not always directly
related to emission potential. These include, for example,
frequency of complaints, equipment breakdowns, violations, number
of equipment units, and the complexity of any given facility.
IV. INSPECTION OF AIR POLLUTION EMISSION SOURCES
An inspection of an air pollution emission source consists of the entry
of a facility for the purpose of obtaining information to establish the
compliance of specific equipment or processes with the rules and regula-
tions of the air pollution control agency.
A variety of inspections are conducted depending on the reason for the
facility visit. These are made to gather evidence in relation to: a
violation; follow-up of a previous inspection; a check on equipment for
permit or compliance plan status, obtaining source registration; engineer-
ing, air or source emission monitoring information; complaint investigation;
or providing owners and operators with information on legal requirements.
Many inspections are conducted for a single purpose such as checking to
see whether construction is continuing after a permit application has been
denied. Other inspections are comprehensive and are conducted to inspect
and gather information on all equipment and processes located within the
facility.
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2.16
The types of inspection described below illustrate procedures for conduct-
ing the comprehensive type of inspection.
A. Facility Inspection
The facility inspection is a comprehensive inspection made of equipment
and processes. Facility inspections are sometimes referred to as
"plant inspections," "source inspections," "annual inspections,"
"inventory inspections," and "scheduled inspections." While
terminology and procedures may vary among control agencies, all
inspections of this type are concerned with accounting for all
possible sources of air pollution located at a facility and with
assessing the facility's capability to comply with the rules and
regulations.
Facility inspections may also be employed to:
• Ascertain compliance with permit or certification system
requirements, where these are in force. In these cases the
facility inspection may be referred to as an equipment inventory
inspection, described more fully in the next section of this
chapter.
• Verify, expand and update all source registration information
on hand for the facility. The facility inspection procedure
may also be employed as a source registration system in its
own right.
• Initiate or check the status of all plans developed by the
facility for emissions reduction, episode prevention, air and
source monitoring and facility expansion.
The elements of a facility inspection include the following:
(1) Environmental Observations—examination of possible effects
of emissions on property, persons and vegetation adjacent to
the source and collection of samples or specimens that exhibit
possible pollution-related damage.
(2) Observation of the Exterior of the Facility—observation of
all possible points of emission, all visible emissions, odors
and pollution-related activities.
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2.17
(3) Entry of Facility and Interview—interview with facility
managers and equipment operators. The interview establishes
corporate identity, ownership of the organization, operation
and air pollution control performance of the facility.
Where extensive or complex manufacturing processes are
involved, the interview should be conducted in the facility
manager's office. At that time, the facts of the corporation
and the responsible individuals are established. The depart-
mental organization, throughputs and outputs, explanation of
processes, progress in control, source problems, equipment
capacities, source reduction plans, operational practices and
fuels and material specifications are discussed. Pertinent
facts are noted. The field enforcement officer also works
out with the person he is interviewing a plan for conducting
a systematic inspection of the plant, including interviews
of operators and others who may be most familiar with the
equipment. Where possible, the enforcement officer establishes
the identity and make of the equipment.
(4) Equipment Inspections—after the interview, the enforcement
officer conducts the physical inspection, accompanied by a
plant official. At each piece of equipment or process he
establishes:
• Identification, number and location of the equipment.
• Principal design features and capacities of the
equipment.
• Principal components of the equipment, including
blowers, standby equipment, hooding, condensers, air
pollution control equipment, air pollution monitoring
and process instrumentation, ventilation systems and
established or potential effluent sampling points.
• Pertinent process control and air and source monitoring
data as may be obtained from instruments, performance
logs and records.
• Equipment operating schedule.
• Fuel-firing or material charging or processing rates.
• Emission points, visible emissions, dusts, and odors
and deposits that may be noted from within the facility
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2.18
• Operational practices or other indicators of the
quality of equipment operation and maintenance.
• Evidence of fall-out, property damage or other air
pollution effects on the premises.
The field enforcement officer prepares a plot plan showing
the location of the equipment and/or a flow chart, especially
where complicated processes are involved (see Chapter 7,
Section VI D, Petroleum Refineries). Some agencies use
special forms, or equipment lists to itemize equipment located
in each plant inventory. The plot plan may be made separately.
Where source registration or permit systems are involved,
the enforcement officer may check listings, plot plans and
flow-charts submitted by the applicant.
(5) Provide Information—in promoting future voluntary compliance,
the field enforcement officer provides facility management
with such useful information as copies or extracts of rules
and regulations, permit applications and source registration
ques tionnaires.
(6) Violation Notices—the field enforcement officer issues notices
or citations where violations of rules and regulations are
observed. Where permits are required, the owner is
ordered to submit permit applications by a certain date.
(7) Preparation of Report—the field enforcement officer prepares
a narrative report in which he summarizes inspection findings
and renders recommendations on actions to be taken and re-
inspections. (See Section V.) Calculations of estimated
emission rates, flow charts and equipment lists may be
attached with the reports.
Items 1 through 4 above may be referred to as general inspection points.
Specific inspection points and procedures are followed for each category
of emission source, as described in Chapters 5, 6 and 7 of this manual.
B. Equipment Inventory Inspection
(o)
The Equipment Inventory Inspection J is a form of comprehensive
facility inspection which evolved specifically for the purpose of
enforcing compliance with permit systems. Equipment inventory
inspections obtain complete records of all equipment and processes
-------
2.19
capable of emitting air contaminants that are located at all facilities
within the jurisdictional area. Provided adequate field enforcement
manpower is available, the equipment inventory inspection can also be
used as a source registration system, as a comprehensive method of
inspection and enforcement or other method for rigorously accounting
for equipment and processes capable of air pollution.
As in any accounting inventory, the value of the equipment inventory
depends on its completeness of application. The completeness possible
is problematical and depends on whether the number of emission sources
located in the area is infinite or finite with respect to the
inspection capability of the agency. An area inventory can be con-
sidered to be infinite when all sources of air pollution cannot be
inspected in any one year. The number of individual sources located
in the area may be so large that before all facilities in the area are
inspected, the sources may have undergone significant change. In such
cases, the area inventory must be a form of perpetual inventory.
A frequency of inspection should be adopted which reflects industrial
turnover and discourages operators from taking risks, especially with
respect to permit requirements. Permit infractions can result in the
taking of serious risks on the part of management, since investment
in equipment discovered to have been constructed and operated illegally
may be lost.
1. Source Coverage
A procedure for source coverage should be adopted for inventorying
the sources of air pollution that will compensate for the
incomplete data resulting from a perpetual inventory system.
Source coverage may be random or scheduled, or a combination or
sequence of both. In random coverage, the source-locations within
-------
2.20
any enforcement district are inspected at the enforcement
officer's discretion. Although he may systematically schedule
his own inspections, the inspections conducted in all districts
are randomized. Random inspection is in a sense equivalent to a
painter who employs the technique of working the "whole canvas
at once." The design of such a canvas becomes 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 in each enforcement district discloses a source
pattern from which emission potentials and mass compliance may be
extrapolated. Here the initiative of the enforcement officer and
the quality of his work become statistically important.
2. Initial Inventory Inspections
The initial inspection is conducted at a facility for which no
previous inventory inspection has been conducted. The following
discussion assumes that a district 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 inspect all facilities on a block-by-
block basis, since valuable time is wasted on many inconsequential
sources of air pollution. To increase the effectiveness of the
field operations program it is best to conduct inventory inspections
first in those plants complained about, those responsible for
visible emissions and those involved in variances and violations.
All facilities actively involved in enforcement actions should be
carefully inventoried. Those industries whose emissions are quite
obvious to one observing them from a patrol, such as foundries
and steel mills, should be inspected next. Industries under
-------
2.21
construction, or those recently completed, or appear to have been
involved in a change of ownership should be inspected. 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. Finally, the enforcement officer should
locate all of the areas of high source concentration, first
inspecting those sources which appear to be most important, and
so on. The final completeness of coverage may be checked against
the yellow pages of the telephone directory, which lists industries
in categories similar to those employed by the control agency.
Each inspection district 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,
it is desirable to systematically inspect all boiler installations.
Because of the complexity of the petroleum industry, unit processes
must be inspected frequently and systematically. In other
districts, enforcement officers may be concerned primarily with
the type of industry predominating in that area.
A field enforcement officer who has become familiar with his
district will have accumulated an excellent knowledge of the
principal types of source activities and the names and histories
of the industrial plants. When he changes districts and encounters
industries with which he is unfamiliar, he can consult the
agency files and library for any information he may require. A
good method of familiarizing oneself with an industry is to
concentrate inspections in that industry for a short time.
3. Inventory Reinspections
Inventory reinspections are scheduled. The frequency of reinspection
is determined from the findings of the initial inspection and the
-------
2.22
recommendations of the field officer and his supervisor. The sched-
ules are printed monthly for each district or special assignment and
forwarded to the district officer. The reinspections are scheduled
so that they can be completed within a month. The number of re-
inspections assigned per district is based on the estimate that
all required inspections can be completed within one year.
The enforcement officer may have occasion to inspect plants out-
of-schedule because of complaints or violations. In these cases,
he does not make a formal inventory reinspection, but uses the
copy of the previous inventory record (equipment list, see below)
from his files as a check on the permit, compliance or other
status. When a specific air pollution problem is involved, it is
best to concentrate on that problem rather than on the inventory
of the entire plant. The equipment list can thus be updated
during unscheduled inspections.
The equipment list can be used as a tool in gathering evidence.
This is especially true in public nuisance cases where it is
desirable to eliminate from suspicion all equipment that do not
contribute to the nuisance. In such instances, the equipment
list serves as a check list.
On an assigned inspection, the enforcement officer must check all
equipment units in the plant against those on the equipment list.
He is careful to note not only that all equipment listed is
identical in important respects, but are not replacements, since
permit regulations can be affected by replacements. This is
usually determined by comparing manufacturers' serial numbers.
He 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 an inspection report.
-------
2.23
4. The Equipment List
The record of the equipment inventory is referred to as an equipment
list. The equipment list enumerates all items of equipment capable
of emitting air contaminants that are located on the premises of a
company at a given address-location, and the status of the equipment
with respect to compliance with the permit system and the rules and
regulations.
The use of the equipment list reflects the practices of the Los
Angeles County Air Pollution District and is illustrated in
Figures 2.3 through 2.5 and Tables 2.1 and 2.2. It is used by the L.A.
District as a method of enforcing the permit system, the effective-
ness of which depends on (1) a high degree of coordination between
the engineering and enforcement branches of the District (the
Engineering Division is responsible for the administration of the
system) and (2) data processing and management systems to handle
the large volumes of data generated by the system, to schedule
both engineering and enforcement inspections and to retrieve any
data required.
Information from the equipment list is input to the permit system
data base whenever an enforcement officer makes out a new or updates
an old equipment list of a facility. It outputs data from the
permit system to schedule inventory inspections, and, while doing so,
prints out the exact permit descriptions of the equipment.
From the standpoint of agencies that do not operate permit or
data management systems, it is useful to illustrate the version
of the equipment list used prior to the introduction of automation
(see Figure 2.3). This figure best illustrates the systematic
inventory technique and the descriptive skills required of the
-------
A R PO
TYPES OF
CONTAM 1 -
NANTS
A ™
8 X
C
D
E
f
G
0
CODES
a
A
s
i
c
C
0
N
T
R
0
L
2
^
/
X
X
2
>/
2
X
.LUTION CONTROL DISTRICT - COUNTY OF LOS ANGELES - AREA GRID"
FIRM NiMF Los Anaeles Brass Products. Incorporated
ADD
PRE
DAT
NAT
RES
Ll<
T
M
1
?
;,
4
5
fi
7
8
9
10
MO. M.R.NO, 05 3_
TEL. BL 4-5321 i.P.C.I). 70NE 8
RESS OF PREMISES 35161 Larksour Road
SENT LEQAL OWNER National Enterprises, Incorporated
E BUSINESS ACQUIRED BY PRESENT OWNER Jeb._ 1 9 47_ NAME OF FORM
"RE OF BUSINESS Plumbine fixture and hardware products, see List for Platin
CITY
.CORP
FB OVNFR None
Los Angeles
N.S PART.QlHOIV. D
e Dei>artm>nf. 07-5 —
PONSIBLF PERSON TO CONTACT H. L. Henderson TITLE Work Manago.r
JT 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 EQUIPMENT-SYSTEM
OR PROCESS INCLUDING MANUFACTURERS NAME i MODEL NO.
1-Sraith automatic baehouse with 32 orlon bags, 8' x 6" Dia., with 15 H.P.
flower collection system to hoods serving the furnaces in Items No. 2 and 3.
1-Hendej-son 500-lb. hydraulic tilt reverberatory furnace for vellow brass meltine
14%-tiiK^fna fired. Vented to Item No. 1.
1-Henderson 750-lb. hydraulic tilt reverberatorv furnace for vellow brass. 14%
zinc, ffas fired. Vented to Item No. 1.
1-Forrestal 100-lb. crucible pit furnace for pure ingot aluminum.
1-Oonker sand conditioning device equipped with one 4' dia. cvclone.
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,
l_ served by 1 Patterson 24-cloth bag filter, Serial No. 8931.
1-Sinsle chamber incinerator 4' W. x 3' D. x 4' H. Not in use.
APPROXIMATE
LOCATION
ON PREMISES
Hear E corner
of hldg.
Eastmost in
ffear E corner
Westmost in
Rear E corner
fear center
Front west
Front west
Center west
inter 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. REINSM
STATUS 1 2 } i)
A- 1891
Rule 13
Rule Hi
A-361
Incon.
A-425
A-426
Banned
ICTION NO.
to
NJ
DATE March 10
!Nc;pcrTORS NAME J. S. Jason .
I6-40DI5I USE BACK OF SHEET FOR FLOW DIAGRAM ft REMARKS
I 9 _72 CHECKED BY
SHEET _!___ OF _!_
Figure 2.3. EQUIPMENT LIST USED FOR INVENTORYING THE SOURCES OF POLLUTION AT AN INDUSTRIAL FACILITY
-------
ENFORCEMENT DIVISION INFORMATION
IDENTIFICATION
Name, Premises address, Mailing address
Organization Code: Corporation. Partnership, Gov't, Individual
INSPECTED BY
FIELD ENFORCEMENT OFFICER N0._
CHECKED BY
LOCATIONAL CODES
Street Cod_e_: Map coordinate reference numbers
AlphaL_No_. ; Code used to generate alphabetical
and locational listings of facilities
by computer
_Se_c_tor No. ; Inspection District No. Code.
I.D. Number: Grid number + code for the specific
facility or unit operation
M.R. Number: Master Record Number, references to
master source files. Industry
classification code used is similar
to Table 2.2.
INSPECTION INFORMATION
EQUIPMENT LIST STATUS BOX
Inspection
Frequencies:
EDP
As sig nment:
EDP List No..
Work
Accomplished:
e.g. 4 times per year
e.g. 1111, one Inspection for
each quarter of the year
Facility place on list for
each quarter
Summary of work of the
enforcement officer on the
current list for permit and
non-permit items in terms of
number of items S, work units.
Continue:
New:
New-Non__Spurce_:
Vacant:
Change Owner:
Continue the present list
New list for facility with
pollution sources.
New list for facility having
no sources, but potential to
acquire sources
Building Vacant
Ownership of facility has
changed. (New owners must
apply for permits.)
Out of Business: Firm went out of business.
Became N.S.:
Non-Source. Air pollution
sources no longer on premises.
REMARKS: Brief narrative report by the enforcement officer explaining or summarizing inspection findings
PER'-IITTED EQUIPMENT INFORMATION
ITEM NO.
1
2
3 etc.
ACTION
y
1
EQUIPMENT
CATEGORY NO.
013344
(See Table
PERMIT
DESCRIPTION
Boiler, scotch
marine, com-
bination gas-
oil (PS-300)
1
TYPE OF PERMI
EQUIPMENT
B A4356
J
Numerical Action of the enforcement ^ • B = Basic
order of officer • Description C = Control
T NO. PERMIT
CONDITIONS
01 X
1
PERMIT
DATE
June 15,
1971
APPLICATION
NO.
598971
WORK
UNITS
4
J
Whether permit On scale of
has been complexity,
equipment ^ = continue, no changes as given on N = Gasoline tank conditioned 1-18
moved from list Notice to
+ = new piece of equipment
added to list
Find = permitted equipment on
premises was omitted
from list.
apply for
permit for
new equipment
(see Figure
NA
./
• v
N3
•
ro
Ratio total number
items/total work ^
units, last in-
spection
Work load
-factor
Figure 2.4.
AUTOMATED VERSION OF THE EQUIPMENT LIST. CODE ELEMENTS AND COMPONENTS.
supplied by the Los Angeles County Air Pollution Control District.)
(From information
-------
2.26
AIR POLLUTION CONTROL DISTRICT COUNTY OF LOS ANGELES
434 SOUTH SAN PEDRO STREET. LOS ANGELES. CALIFORNIA 9OOI 3/629•471 I
NOTICE TO APPLY FOR APCD PERMIT
Townsend Plumbing Works 1532-171?
Albe
5379
FO,ir-.'i\T ARJK
s_am£
HIS BEEN CODI
rt E. Townsend- TnHiv.
E. Blank Rd.. L.A. 90052
as above . _
Martin Contractors
410 X. Mix St., L.A
S1A-17RR
. . 90032
One JffQ Ib^^lgtary yP] ir»j
WITHOUT AH AIR POLLUTION CONTROL DISTRICT PERMIT SO TO DO. IF AN APPLICATION FOR THE ABOVE EODIPWEBT HAS HOT BEEN ACCEPTED BY
THE AIR POLLUTION CONTROL DISTRICT HMTHIK 14 CALENDAR DAYS OF THE DATE OF SERVICE OF THIS MTICE. A NISDEMEAHOR COMPLAINT MAY
BE FILED IN A MUNICIPAL COURT IN THE COUNTY OF LOS ANGELES.
SERVED TO: Albert E. Tovnsend
SEB\£D BY: Donald Jordon
ITE ^B.Fn._April 1. 1972
RALPH E. GEORGE
DIRECTOR OF ENFOHCEMEMT
.EFT HEREftlTM:
C3t PERMIT INSTRUCTION. 400C
001612
GRMER PEfMi7 NO.
None
April 1. 1972
Equipment intended co augment plant capacity to manufacture bathroom fixtures
by producing additional 3000 Ibs/day for mold pouring. Plant involved in
nuisance actions on existing equipment and defective control systems. (See
L.R. of 1/15/72) No visible emissions observed from plant at this time.
£H3 QNO ijYis
SECIIOH 2. •-, -: co
1 SECTION 4, B OH c Jf*
ON D= DsXI*
Figure 2.5. NOTICE TO APPLY FOR APCD PERMIT (Los Angeles
County Air Pollution Control District)
-------
2.27
Table 2.1. MAJOR BASIC EQUIPMENT CLASSIFICATION
Unit
Combustion
Equipment
Metallurgical
Incinerators
All
All
Type of Equipment
Equipment in which the major air pol-
lution problem is due to the combustion
system and not the materials processed;
i.e., boilers, heaters, kilns, not
handling fine solids, etc.
Metal melting furnaces.
Incinerators (trash) and other
incineration equipment.
Equipment which is primarily used to
process unit material; i.e., ovens, dip
tanks, sheet coating, dry cleaning,
smoke houses, and degreasers.
Equipment which is primarily used to
process bulk material. The first three
digits specify the major material
processed and the last three, the major
unit operation(s) performed in the per-
mit unit. Includes refineries, chemical
processing, sand handling, reactors,
spray dryers, coffee roasters, feed
and grain, rendering, etc.
Code Numbers
01XXXX series
001XXX series
0001XX series
0002XX series
1XXXXX series
Example of Code:
Combustion series
code
Boiler,
scotch Marine
— 1
0
1
3
3
4
4
Oil or steam
atomized
1
601 to 1200 H.P.
Combination gas oil
(PS300)
-------
2.28
Table 2.2. PRIMARY ACTIVITY CLASSIFICATIONS
PETROLEUM AND PETRO-
CHEMICAL DEVELOPMENT,
PROCESSING AND
MARKETING -01
I 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
G 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
6 Petro-Chemical Manufacturing
9 Sulfur Recovery Plants
INDUSTRIAL CHEMICAL
MANUFACTURING AND
PROCESSING (EXCLUDING
PETRO-CHEMICAL)-02
1 Soapx and Detergents
2 Insecticide] 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
S Manufacturing and Packaging
of Gases
G Explosives. Rocket Propellanti
and Pyrotechnics
7 Radio Active Materials, liotopd
and Related Materials
8 Chemical PrDcenu Involving
CnlorlnatKM
9 Catalysts
10 Organic Chemical*
11 Imriink Chtmiealt
PAINTS AND RELATED
MATERIALS, MANUFAC-
TURING AND HANDLINfi-03
1 Paint Type Products e g. Lacquer,
Varnish, Shellac, Ink. Enamel.
Powder Paints. Water Emulsion
Pemti, etc.
2 Paint Additives e g Pigments.
Dryert. Surfactants, etc.
3 Polymers and Resinous MaterUb
4 Marketing of Solvents and
Liquid Chemical!
S Vegetable and Animal Oil
Processing (excluding Rendering
and Food Processing)
G Adhesives e.| Sealants. Puttm,
Calking Compounds. Masking
Compounds, (le.
PLASTIC, RUBBER AND
RESIN PROCESSING -04
1 Rubber Products Processing
e.g Molding, Dipping, Coaling.
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 R«m Fabrication
e g. Laminating, Coating,
Embedding, Sheet Forming, etc
G Tire Manufacturing
METAL MELTING AND
RECLAIMING-05
1 Grey-Iron Foundry Facilities
2 Steel Foundry FacUttiu
3 Bran F«MtVy FadCtit*
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 AlllnstrumentManulactunng,
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. Blacksmith ing. 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
eg 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. Parkeruing. Bonderliing.
Corrosion Preventive Coatings.
Vacuum Coating, Metallizing,
Anodizing, etc.
7 Surface Grinding and Polishing
e.g. Ctnterleu, Surface. Lapping,
Honing, etc.
8 Painting and Enameling,
Major Users
9 Display Sign Manufacturing
and Servicing
MINERAL PROCESSING -0<
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 ( Brick.
Tile, Clay Products,
Refractories, etc.
4 Glass, Frit and Rock Wool
Manufacturing, including
¥ermiculite 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 fief i mining,
Including the Use of all Materials
3 Casket and Cabinet Shops
4 Wood Treating Facilities e g.
Termite Proofing. Creosotmg,
name Proofing, etc
5 Pattern Shops, all Type!
6 Wood Turning Facilities
7 Wooden Shipping Material! eg,
PalleU. Crating. Skidi.
8 Hood iMHAatlnf • i Plywood
VeflMTiit Formica Bon dim. Me.
9 Wood Byproducts PUi>tae.g,
Sawdust. Wood Flour. Shaving,
FOOD PROCESSING- 10
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
inc udmg Dried Milk, Condensed
Milk. Le 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 Specially Packaging eg
Spices. Condiments,
Flavorings, etc.
11 Margenne and Oleaginous
Products
INEDIBLE ANIMAL AND
VEGETABLE BY-PRODUCT
PROCESSING-11
1 Rendering
2 Fertilizer Processing and
Packaging
3 Fish Cannery By Products
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 Hospital! e g
Sanitariums. Hospitals, Clinics,
Rest Homes, etc
3 Private and Religious Schools,
Colleges, etc
4 Motels, Courts and Trailer Parka
S Apartment Hotels and
Apartment Buildings
6 Scientific Research and
Development Facilities
7 Scientific Laboratories c g
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, Warehouse*
and Contractors' Yards
3 Electrical and Electronic
Repairing, Rebuilding and
Servicing
4 Motion Picture and Television
Production Facilities
S 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,
Photoengraven, Electrolypers,
Mat-makers. Silk Screening,
Printed Circuits, etc.
11 Dry Cleaning Plants
12 lunk Yards. Salvaging and
Converting of Industrial
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-1*
1 Public Oflice 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 lor Public Use
5 Publicly and Privalely Owned
Public Utility Facilities e.g
Telephone Co. Gas Co,
Waterworks, etc
6 Governmental^ Owned Hospitals
7 Cut and Fill Dumps
6 Transportation Facilities,
lor all Transportation Media
9 Governmentally Owned Shipyards '
VEHICLE MANUFACTURING
AND SERVICING
FACILITIES-15
1 Airframe Production including
Guided Missiles
2 Aulo and Truck Assembling
3 Trailer Manufacturing and
Assembling
4 Aircraft Overhaul Facilities
5 Automotive Component
Rebuilding Facilities eg
Carburetors, Starters, Generators,
Water Pumps, etc
G 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 Governmenlally
Owned)
11 Railroad Service and Repair
Facilities, Yards, Roundhouses,
«tc. (excluding Stations, Depots
and Warehouses)
TEXTILE, FABRIC, FIBER,
MONOFILAMENT
MANUFACTURING AND
PROCESSING- 16
1 Garment Manufacture
2 Textile and Fabric Coverings
Manufacturing e.g Seat Covers.
Tents. Tarpaulins, Draperies,
Awnings, etc
3 Textile and Fabric Processing
eg Sponging, Shrinking.
Waterproofing, Dyeing,
Flameproof ing. Printing, etc.
4 Mattress, Cushion and Pad
Manufacturing and Renovating
(excluding Furniture
Manufacturing)
5 Paper Products
6 Shoe and Luggage
7 Brush Manufacturing
8 Special Textiles e g Felt,
Webbing, Rope. Cordage,
Packings, Oakum, Belt ing. etc.
9 Weaving of Textile Materials r|
Braid, Tape, Lact, Blndinp.
RuW, etc.
(SOURCE:
-------
2.29
field enforcement officer. With the use of supporting report
forms this procedure could be employed by some agencies in
administrating a source registration-plan review system.
Figure 2 3 also illustrates the experience in manual procedures
that an enforcement agency may need prior to the introduction of
Electronic Data Processing.
Figure 2.4 and Tables 2.1 and 2.2 illustrate the components of a
printout of an automated version of the equipment list, which is
more sophisticated and complex than the earlier version. In this
procedure, the inventory inspection has been fully incorporated
into the permit system, and the enforcement officer interacts
directly with the data base of the permit system. Information
on applications received for permits, and the status of permits
(approvals, denials, variances, etc.) are quickly and accurately
relayed to the enforcement officer on each scheduled printout of
the equipment list. Equipment descriptions and coding elements
are completely standardized, so that the permit system can perform
listings, tabulations, and statistical analyses on the entire
equipment source population at any time.
Figure 2 .4 illustrates the components and elements printed out by
the system and the data that must be updated by the enforcement
officer. Whenever equipment is found at a facility which does not
have a permit, a Notice to Apply for Permit (Figure 2.5) is issued.
This notice initiates the permit application procedure.
The procedures for preparing equipment lists, described below, are
generalized for the purpose of illustrating principles and methods of
the inventory inspection whether or not these are incorporated as
automated procedures or field enforcement techniques.
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2.30
5. Preparation of the Equipment List
The inventory unit for which one equipment list is made may be
referred to as an activity. The activity is an industrial plant or
a commercial enterprise occupying one address-location, or unit
operation capable of standing alone as an independent source activity,
but which is integrated into a large industrial plant at one address-
location. Industrial facilities that are highly diversified or
contain so many equipment units that they cannot be inventoried in
one continuous inspection are unitized for the purpose of establish-
ing equipment list boundaries. The individual units are scheduled
for separate reinspections. These particularly include plants with
elaborate departmental flow structures, such as oil refineries,
aircraft plants, chemical plants, large steel mills and metal
fabricating plants.
Source activities may be classified by means of a primary and a
secondary activity classification system (see Table 2.2). The
Primary Activity Classification breaks the industrial economy of
the region down into general technological or commercial activities
grouped according to similar emission potentials. This classifica-
tion may be based on the Standard Industrial Classification System
(SIC), or other systems.^
Each primary activity is composed of the secondary "source activities"
which would be found at individual 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
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2.31
The brass foundry facility (05-3), for example, is a source
activity, whether it is a complete self-contained plant or an
independent commercial activity, as it is usually found, or a
department within a large industrial plant such as a large
plumbing products manufacturing plant. In the example of a large
plumbing products plant, additional source activities may be
found such as a plating department or a machine shop. These are
coded as separate source activities under other primary and
secondary activity classifications. Specific types of equipment,
such as a rotary furnace, boiler, oil-water separator, electrical
precipitator, can be further coded by means of Basic Equipment
Classification (EEC) and Control Equipment Classification (CEC)
codes. (See Table 2.1.)
If an industrial unit within a plant at one address-location can
be conveniently 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 or a data management system can be used to recombine these
source activities alphabetically.
The equipment list is prepared for an activity only if there are
sources of air pollution on the premises. The "non-source"
activity may still be accounted for in 2 ways. First, the
enforcement officer reports the name and location of the company,
the nature of business, the expansion potential of the company,
or any indication of the likelihood of the establishment installing
equipment capable of air pollution in the future. This indication
is important for scheduling a reinspection. If the plant is a
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2.32
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 and should be inspected at least once each
year.
The equipment list (Figure 2.3) is broken down into four basic
parts: business and ownership data of the source activity,
description and location of each piece of equipment, permit
status of each equipment unit, and coded equipment data.
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 ownership, its owners, officers or managers, are the
same as for handling of violation notices. 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
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2.33
acquired by the present owner and (3) the name of the former
owner.
On the line entitled "Nature of Business," an inclusive
description of the general purposes and processes of the
enterprise and the products produced should be recorded. The
terminology listed in the activity classification such as
"office building," "brass foundry facilities," "plating
facility," 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, for example:
(1) End product manufactured, processed or produced
(2) Raw materials used
(3) Approximate size of plant in terms of production
volume, men employed, square feet of plant area, etc.
(4) Number of shifts worked and normal working hours
of plant
(5) Flow sheets of process plants.
Where several primary activities are carried on at the same
premises, separate equipment lists are made to cover each source
activity of substantial magnitude.
b. Description and Location of Each Equipment Unit
The main purpose of the inventory is to list, itemize and to
identify by description each equipment unit in the source activity,
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
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2.34
equipment, appurtenances, controls, heating elements
or equipment parts. Equipment units can either stand
alone or be a component of a battery or process by
interconnection with other equipment units. With
respect to the inventory process, equipment units may
or may not constitute sources of air pollution.
A source of air pollution 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 equipment unit and discharged
through the stack or exhaust system serving that equip-
ment unit, or are generated by a number of equipment
units and are exhausted through 1 stack effluent system,
or into the general atmosphere through a louvre, roof
monitor, vent, etc.
The description of an equipment unit includes all
auxiliary equipment, appurtenances, etc., which are
relevant to a description of the equipment as a source
of air pollution. 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.
Equipment units capable of emitting air contaminants
fall into 2 classes:
(1) Basic Equipment
This class includes any articles, machine,
equipment or other contrivance, the use of
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2.35
which may cause the issuance of air contaminants.
(2) Air Pollution Control Equipment
This class includes any article, machine, equip-
ment or other contrivance, the use of which may
eliminate or reduce or control the issuance of
air contaminants.
Figure 2.6 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 2 basic equipment
units in battery.
The control unit consists of the entire collection system:
hoods, cooling ducts, motor and fan, baghouse and hopper.
A description of the control unit includes the number of
bags, the material used, the size, whether the baghouse is
automatically or manually rapped, the blower horsepower
and type of precooling system. (In this case, radiational.)
In this example, _1 unit of collection equipment serves _2
units of basic equipment.
Itemization of Equipment Units
The itemization of equipment units on the equipment list
comprises the actual inventory or accounting process. The
item column may be noted in the left-hand column of the
equipment list in Figures 2.3 and 2.4. Equipment units are
itemized in counting order. Only those equipment units, the
use of which may cause the emission or reduction of air contam-
inants, are itemized. All equipment which may be sources of
air pollution but exempted are also listed. Equipment units
-------
,ir
c
^
f-
,-HOOO- ,
SOO-KXXTFi
/
FURNACE
r
*
COOLING
DUCTS
\
SETTLING
CHAMBERS
/
r^
x
x
V
R)
^ i r^
COLO AIR
DAMPER —
FAN-13000 CFM,
12.5' S.f
^
R-50HP\
200>
BAfi HOUSE-APPROXIMATELY
7600 SO. FT. CLOTH AREA —
D
m
CONVEtOR-;
!/
D
Figure 2.6. DIAGRAM OF BASIC AND CONTROL EQUIPMENT FOR TWO BRASS FURNACES SERVED
BY COOLING COLUMNS AND CLOTH FILTERING SYSTEMS
(SOURCE: WEISBURD, Reference 3)
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2.37
which are clearly non-sources are not itemized. Equipment
which emits very small amounts of air pollution is listed,
but is noted as "inconsequential."
The enforcement officer has considerable latitude in itemizing
equipment to fit the groupings which he encounterd and the
relative importance of each piece of equipment. An important
piece of equipment may be handled as a separate itemization
and with considerably more detail than one which is of
little consequence. Generally, the description is based on
one of the following equipment groupings: (1) individual
equipment units, (2) more than 1, but exactly identical
equipment units, (3) control-basic equipment combinations,
(4) equipment battery combinations and (5) process unit
combinations.
Individual equipment units are described according to their
mechanical or chemical function as "boiler," "incinerator,"
"furnace," "spray booth," etc. In a detailed description
all auxiliary equipment are included.
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.
The battery or series of equipment units refers to a group
of similar (but not always) individual equipment units not
contributing to a process, but exhausting through 1 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 1 blower or control system.
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2.38
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 petro-
chemical plant. The product moving through the unit is
progressively transformed towards a desired end point. All
of the equipment in the process may exhaust into one local
exhaust or control system.
d. Location of Equipment, Plant Layout and Flow Charts
The location of the equipment should be indicated under the
"Approximate Location on Premises" column of the equipment
list. The approximate location 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." In large complex plants
with many kinds of sources, these descriptions may not suffice.
An equipment location drawing (plot plan) should be prepared
on the cross-hatch backing of the equipment list (see
Figure 2.7). The plot plan should show clearly the general
outline of the plant floor, the intersecting streets around
the plant, the departmental organization, and the location
of each specific piece of basic and control equipment. Where
the industrial plant has multiple stores and the equipment is
interconnected by means of blower and duct systems, each
floor plan should be shown.
In the case of complicated process units, a flow chart
showing the flow of materials through a production 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 engineering drawings.
-------
LOS ANGELES BRASS PRODUCTS, INC. ^ (METALS DIVISION)
C)5
SAND CONVEYOR
o o o o
MOLD MAKING MACHINES
METAL POURING AREA
FURNACES
2 P d 3
O
SAND
CONDITIONER
SAND SHAKE OUT
TUMBLEBLAST
m
SHOT BLAST BOOTHS
OFFICES
PLATING DEPT.
(See List 07-5)
\
BAGHOUSE
BAGHOUSE
Figure 2.7. PLOT PLAN ON REVERSE OF EQUIPMENT LIST TO ILLUSTRATE POSITIONING OF EQUIPMENT
tSOURCE: WELSBURD, Reference 3)
-------
2.40
Flow diagrams and plot plans are of particular importance in
accounting for all equipment in a production sequence which
otherwise might be overlooked. They are of value in showing
the potential of an existing production system for growth
or change. They also show the capacity for such systems to
accommodate increased production. 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 exactly how the process may have changed.
e. Determining Permit Status
The factors affecting the permit status are (1) new con-
struction of equipment, (2) change of ownership, (3) change
in address-location and (4) alteration of equipment. The
equipment list is constructed to provide reference data which
will enable enforcement officers on subsequent inventory
reinspections to determine whether or not the permit status
has changed. For (1) above, any equipment found in the plant
capable of air pollution, but not listed on the previous
equipment list, will require a permit. For (2) above,
change of ownership, any change in the ownership as indicated
on the heading of the equipment list, affects the permit
status of all equipment in the plant. A new equipment list
is then required for the new owner or lessee, who is required
to apply for permits for all of the equipment capable of air
pollution in the plant. The equipment list of the older,
defunct company is stricken from the files by means of a
status report. Similarly a change in address-location, (3)
above, also requires that applications be made for all of the
equipment in the plant.
-------
2.41
In the case of (A) above, alteration is frequently deter-
mined either by a change which has taken place in the
equipment description, or the flow chart, or by changes
noted with reference to engineering applications in the
permit file.
C. Compliance Plan Status Inspections
Air pollution control agencies in the early stages of their develop-
ment and those that do not employ permit systems may employ a
combination of negotiated compliance plan and code enforcement
procedures. Compliance plans may be the result of administrative
orders or court or hearing board actions. Once such plans are
negotiated, their implementation is subject to verification by
inspection.
Compliance plans provide time for compliance with either existing or
new rules. A source reduction plan is prepared by the source and
negotiated with the enforcement agency, a hearing board or the
courts. The time schedule is the enforceable feature of the plan.
The compliance plan approach is particularly taken where important
questions of technological and economic feasibility are involved.
The milestones of the schedule may include:
(1) Completion of engineering evaluations.
(2) Completion of plans and equipment design.
(3) Completion of equipment procurement.
(4) Completion of equipment fabrication.
(5) Completion of equipment installation, modification and
adjustment.
(6) Completion of testing and start-up of equipment.
-------
2.42
A negotiated compliance plan may call for the submission of written
progress reports. Some compliance programs may call for the review
of construction plans, as in the permit system, with or without the
authority to approve or deny the plans.
Engineering studies and plans should be subject to review by the
agency. Facility inspections assure that plans are submitted as
required by any order and deadline, and that scheduled milestones
are met. The enforcement officer is also present during any source
tests or start-up of equipment. His reports will generally describe
the status of construction and statements made by management with
regard to problems encountered. Example of a format for a compliance
schedule is shown in Figure 2,8.
D. Inspections Relating to Emergencies
Emergencies are of two types: (1) local emergencies—incidents
involving the untoward release of contaminants that may be toxic or
have the potential for other undesirable health or environmental
effects and (2) air pollution episodes in which the buildup of
contaminants in the atmosphere approaches or exceeds predetermined
alert stages and which may necessitate the curtailment or shutdown
of source activities on a large scale. These conditions will require
swift response on the part of enforcement officers and performance
of special inspections.
1. Local Emergencies
Local emergencies may be observed during field patrol, may occur
as a result of citizens complaints or result from reported
breakdowns of equipment. Examples of these emergencies include
emergency dumping of ammonia from commercial refrigeration
systems; explosions from a chlorine manufacturing plant;
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2.43
Puget Sound Air Pollution Control Agency
Serving King, Pierce and Snohomish Counties
901 Tacoma Ave. S. 410 W. Harrison St. 2730 Colby Ave.
Tacoma, Wn. 98402 Seattle, Wn. 99119 Everett, Wn. 98201
FU3-5851 AT4-2050 AL9-0288
PROPOSED COMPLIANCE SCHEDULE
Agency use only
Grid 0005
Sic 339-01
File Al Red
Bee 939
Accepted LFP
Instructions:
Date Left 1-2-72 Date pue 2-1-72
Inspector
Responsible William Percy
1. Please complete and return forms for each source on or before due date.
2. For technical assistance to complete this form, call AT 4-2050.
To: Puget Sound Air Pollution Control Agency
The following information is submitted as an assurance of discon-
tinuance of alleged violations of Regulation I of the Puget Sound
Air Pollution Control Agency within the time limits contained herein.
The Agency is requested to consider this assurance in determining
action with regard to such violations. A NOTICE OF CONSTRUCTION is
attached or will be submitted upon completion of engineering and be-
fore procurement.
A. General Information:
Business Name
Onyx Aluminum Products, Inc.
Mailing Address 4321 Walgrove Street
City Everest, Washington
Zjp 98999 Telephone M 4-5621
Plant Location 415 EasC Anita Street, Tacoma, Washington
(if other than above)
Major Activity Ingot Production
B. Source Description:
Type of Equipment Reduction Cells year Installed
1945
Manufacturer flantinn Fnnnrfrv Unrk«.
Description and Details 2 identical Soderberg potlines each served by
a
4000 CFM local exhaust system and 18 gal/min packed tower scrubber. Potlines
consist of 20 cells each.
Type and Quantity of Material Processed per Month 50° tons/day
Aluminum ingot produced consuming 1300 tons /day raw materials.
PSAPCA 40-10J-R-2
Figure 2.8. PROPOSED COMPLIANCE SCHEDULE FORMAT, PUGET
SOUND AIR POLLUTION CONTROL AGENCY (Courtesy
Puget Sound Air Pollution Control Agency)
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2.44
PROPOSED COMPLIANCE SCHEDULE Continued
Q3 Natural Gas
| | Garbage
|^| Wood Residue
1 1 Plastics
( ^ Paper
Qc] Other (describe)
Electrical Energy
D. Control Methods:
Describe the emission and proposed method for controlling it. The des-
cription should be sufficient in detail to enable the Agency engineers
to evaluate methods, of control. HF, CO, HC, carbon and pitch dust, S0~. crvoliti
from scrubber, and potroom vents. Source test findings (attached) indicate 12-1/2
tons particulates emitted/day. Calculated control efficiencies of scrubbers about
202!. Dry emissions from scrubber and potroom vents exceed 60% opacity.
Present Status :
Describe action already taken, if any, to correct t-h e
elude names of suppliers of services and equipment . )
PES, Inc. to perform engineering evaluation and design of a fl
electrical precipitator combination and roof collectors.
emissions . ( In-
Contracted with
ratine bed scrubber-
F. Compliance Schedule:
Engineering
Procuremen t
Fabrication
Installation
Adjustment
Note: This schedule
formation requested
Start ing Date
March 1, 1972
June 1, 1972
July 1, 1972
January 1, 1973
February 1, 1973
will not be considered for
in this section is supplied
Completion Date
July 1, 1972
September 1, 1972
November 1, 1972
February 1, 1973
March 1, 1973
approval unless the in-
Signature William Percy Date 1-2-72
40-103-R-2.2
Title Field Operations Officer
Figure 2.8. PROPOSED COMPLIANCE SCHEDULE FORMAT, PUGET
SOUND AIR POLLUTION CONTROL AGENCY (continued)
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2.45
accidental emissions of poisonous gases or fumes such as phosgene,
hydrogen cyanide, etc.; refinery breakdowns and fires; the spread
of noxious or malodorous gases; radiation accidents.
Equipment which can be used in the field include explosimeters,
geiger counters, test papers, tutweiler apparatus, midget
impingers, gas absorption cells, halide leak detectors, sling
psychrometers, etc. (see Chapter 5). The effective use of this
equipment and interpretation of results is open to question and
depends on the training of field enforcement personnel. Far
more reliance should be placed on the field enforcement officer's
advanced knowledge of the source and the properties of the toxic
gases that may be involved. He should know whether potential
hazards to life or health exist in the plant. Benefit of the
doubt should be given to the possibility of a hazard and
appropriate assistance should be sought from health, fire or
police authorities. A full report of any incident should be
made including any determination as to whether it was due to
accidental or deliberate causes. Industries which have a
potential to create hazards to health under accidental or
abnormal conditions should be required to install and continuously
maintain source monitors.
2. Episode Management
Episode management consists of the following elements:
(1) Industries identified in the emergency prevention plan
are required to submit plans for the shutdown or
curtailment of emissions during the calling of an
alert. Certain specified industrial plants may be
required to install radio receiving equipment with
decoding devices capable of receiving broadcasts
from the enforcement agency of the declarations of
alerts, emergencies and information and instructions.
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2.46
(2) An integral part of episode management is a region-
wide air monitoring network and the ability to conduct
mobile sampling, to obtain meteorological data and to
make forecasts.
(3) A rapid alert or episode notification system that in-
volves police authorities, highway patrols, public
officials, safety personnel, defense personnel and the
general public may be required. Communications may be
by landline, radio, television and teletype.
The notification procedure should be planned so that
all parties are notified within less than two minutes.
(4) Deployment and direction of all field operation
personnel by means of a radio communications system.
In conducting facility inspections, the enforcement officer:
(1) Determines if emergency prevention plans have been
submitted, are up-to-date and can be implemented on
short notice.
(2) Checks sources of pollution through observation and
inspection to see that shutdown plans are being
quickly implemented.
(3) Cites all violations of the rules and regulations as
well as pertinent provisions of the emergency regula-
tions . All open burning and incineration should be
curtailed.
(4) Coordinates, as instructed, with other agencies parti-
cipating in source reduction efforts during the
emergency.
V. ENFORCEMENT METHODS AND FORMS
After the field enforcement officer completes his inspection, he reports
his findings and makes appropriate recommendations for action on an
appropriate report form. Examples of specific actions that might be
taken include:
(1) No violation observed at this time, date recommended for next
inspection, file report.
-------
2.47
(2) Owner requested to submit permit applications by due date,
forward report to engineering services.
(3) Supplemental source registration information obtained, infor-
mation forwarded to evaluation and planning unit.
(4) Specific equipment identified as source of odor complaints,
owner made operational changes, date recommended for next
inspection.
(5) Facility inspection completed, no violation observed at this
time, equipment list attached, date recommended for next
inspection.
(6) No violation observed at this time, violation of equipment
suspected, surveillance recommended for late afternoon hours.
(7) Violation of grain loading suspected, source tests recommended
under specified conditions. Request for source test attached.
(8) Violation observed, notice written and served.
Actions resulting from an inspection thus take two general forms:
(1) No enforcement action, recommendations for further field or
administrative action where applicable, scheduling of next
inspection, filing of report. Findings and recommendations
are reported on an appropriate form of inspection report.
These may be of a general report or special report type.
Special reports are frequently of the pre-structured blank
completion type. Items 1-7 above, for example, are reported
on an inspection report.
(2) Enforcement action in the form of administrative, hearing board
or court action. A notice of violation, citation or other
enforcement instrument is employed, as in item (8) above.
Types of report forms and enforcement methods commonly employed are
described in the following sections.
A. The Inspection Report
The inspection report is a general report made of the results of an
inspection. It does not initiate enforcement action. It develops
ownership data, location and identification of the source of air
-------
2.48
pollution, responsible parties contacted, findings of inspection
points checked, recommended action and referral notations. The
elements of the narrative type of report are shown in Figure 2.9.
When filed, these reports evolve into case histories for use in
future enforcement work. Standards of information for inspection
reports should therefore be as exacting as those required of
violation notices, described below. (See Collecting Evidence,
Section IV, Chapter 4.)
Various forms of the inspection report are used (see Figures 2.9 to
2 .1]) to cover investigations made of complaints, reported breakdowns
of equipment, permit-denial and permit follow-up inspections and
other situations in which the findings may be briefly reported.
Special inspection report forms are also used to report results of
specialized inspections such as those made of complicated flows of
processes or products, changes in permit status, equipment inventories
or compliance plan status.
Some forms of the inspection report may be designed to cover the
inspection of just one type of equipment or compliance with a
specific rule or regulation of interest (see Figures 2.10 and 2»ll).
These tend to be mostly of the standardized-blank-completion type.
B. Notice of Violation
A notice of violation is a form completed by the field enforcement
officer which notifies an owner or operator or other responsible
person that he has violated a specific provision of the rules and
regulations through the commission of the acts detailed in the
notice. The charge portion usually contains a record of the
emissions observed or other elements of the violation (see Collecting
Evidence, Section IV, Chapter 4).
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2.49
INSPECTION REPORT Onyx State Environmental Control Agency
Enforcement Branch
FULL BUSINESS NAME: Onyx Aluminum Products, Inc.
SOURCE ADDRESS-LOCATION: 426 East Henry Street, Colby, Onyx
MAILING ADDRESS: 4532 Matson Street. Hudson, Onyx
PREMISES USED FOR: Primary Aluminum Ingot Production
FINDINGS: Observed 40% opacity dry emissions for 30 minutes from a #2
18/gal/min packed tower scrubber serving the southmost of two Soderberg pot-
lines. All pots were in operation at this time. Two "sick" pots noted with
line voltage running about 7 volts, and hooding shields removed from 6 pots.
Unusually large volumes of fumes noted in workroom area. No further progress
on construction of plumbing and electrical system for new control system (see
previous report). Installation of control systems is approximately one month
behind compliance schedule. New samples of possible fluoride damage
collected 300 feet south of plant. Specimens attached in Exhibit A.
PERSON CONTACTED AT PREMISES: Barney Wilde TITLE: Production Manager
STATEMENT OF PERSON CONTACTED: We've hired new cell operators who have not
been proving out too well. We should have the pots fixed by tonight. Our
subcontractor informs us that recycling pumps ordered for the new scrubber
have not been received, so that installation had to be delayed. We've
written a letter to your agency about this and have consulted with our lawyer
about enforcing our contract with the XYZ Company, the subcontractor.
NAME OF COMPLAINANT: John Fitch TITLE: Owner, Fitch Farms
ADDRESS OF COMPLAINANT: 417 Adlebarle St. CITY: Takomah. On.
STATEMENT OF COMPLAINANT: I noticed the fumes are greater than usual. I
was afraid that my cattle would get sick again. If they do, I'm going to
take some action.
FIELD ENFORCEMENT OFFICER'S RECOMMENDATION: Facility is in compliance with
Regulation 25, Compliance Plans. However, possibility of a nuisance exists
Will reinspect tomorrow to check on hood shieldings, and once weekly. Will
check with Engineering Services to see if interim or alternate recycling pump
can be used, and with lab on results of analysis of forage samples. Will
continue investigation to establish if violations of Regulations 5 and 25 are
occurring.
ELAPSED TIME ON INSPECTION & REPORT: 8:30 a.m. to 9:45 a.m.
TIME LEFT SOURCE PREMISES: 9:45 a.m.
REASON FOR REPORT: Compliance Plan (x ) Hearing Board ( ) Permit ( )
Plant Damage ( ) Smoke ( ) Fumes ( x)
Dust ( ) Odor ( x) Gases/Vapors ( ) Mists ( )
ENFORCEMENT OFFICER SIGNATURE: Donald Jordan INSPECTION DISTRICT:
REFERRED TO: Metallurgical Section, Engr.; Technical Services
AGENCY USE ONLY: GRID # 005 SIC 3339-01 BEG 939 CEC 413
MASTER FILE NO. Aired 5.4.75
Figure 2.9. NARRATIVE TYPE OF INSPECTION REPORT
-------
LOCATION
3 James Road
INVOICE TO Hot Asphalt Paving Co.
CITY
DISTRICT .
Lakeshore
ORIGINAL CS
FOLLOW-UP C3
SHEET 1 OF
MAI LINE ADDRESS
P. 0. Box 25925
CITY
Lakeshore
ZIP 10002
500 M
TYPE OF PROCESS EQUIPMENT Asphaltic Concrete Batching Plant
EQUIPMENT: MAKE t MODEL ^^ Company Model No. UR12
BLDG DESIGNATION
FEE $
75.00
. BTU/HR
NO OF IDENTICAL UNITS
DNA
BLDG USE .
DNA
FLOOR
OFFICIAL
DNA
AREA
DNA
DATE
1-2-72
Eric Stone
TITLE
Owner
MATERIAL USED Aggregate, asphalt
PROCESS
PROCESS
EXHAUST SYSTEM.
STACK
wr 6.700 pounds/hr; 5% asphalt. 70% 3/8" age.. 20% No. A Avg.. 5% No. 200
MATERIAL Steel SIZE40" dla HT OR L Ht
See above
CLEAN
our
Yes
CONDITION
good
OPACITY
OF PLUME
30%
BREECHING
DNA
0 30% at inspection
DNA
OTHER EQUIPMENT ON STACK
BURNERS: NO. 1 LOCATIC* at rotary Uner
FUEL
natural gas
MFGR t MODEL ABC. Model 0-3 RATIN6 500M
CONTROL EQUIPS: TYPE <*clon& and sibber
„„ Lo-Hi
BTU/HR EA STACK DIMENSION .
50'
Ul
o
MODEL
SIZE
12
CONDITION Good - Burner changed during last 6 months
BASIS OF APPROVAL No violation of opacity or maximum allowable emissions
APPROVED 1-2-72 HOURS OF OPERATION 5 a.m. tO 2 p.m. DAYS/WEEK
TEST REQUESTED: DATE 11~15-71
VIOLATION None
TEST PERFORMED: DATE 12-10" 71
DATA REC'D
12-28-71
INSPECTOR G. Smart
FUEL BURNING PROCESS EQUIPMENT RECORD - WCAPC
AFC 11*
Figure 2.10. EXAMPLE OF INSPECTION REPORT, STRUCTURED FORM, TJSED FOR GATHERING
INFORMATION FOR FUEL BURNING PROCESS EQUIPMENT, WAYNE COUNTY DEPART-
MENT OF HEALTH, AIR POLLUTION CONTROL DIVISION
-------
AIR POLLUTION CONTROL DISTRICT - COUNTY OF LOS ANGELES
J.34 SOUTH SAN PEDRO STREET, LOS ANGELES, CALIF. 90013
RULE 66 SOLVENT USAGE SURVEY - OVEM3
1640D435
Sector 3
NOTE: Use a separate sheet in duplicate for each piece of equipment.
Firm Name
Medio Coating Co.
NEW (_) FOLLOU-UP
I.D. No.
8-13Y
Equipment Location 13855 Yule Avenue
Mailing Address
Name of person supplying information
_City_
Same
_ZiP_
Title Plant Manager
Phone Ho. 014-5554
_D ryAngOven
Make Good Oven
P-389426
Model
3-J
Serial No.
7777
11-30-70
1. Equipment
2. Permit No._ ^_
3. Date this equipment began operation__
4. Articles processed in oven Toys
5. Coating applied ahead of this unit in spray booth (30; in coater (_J; in dip tank)L.J
(Fill out & attach a current solvent survey form for ea:h coater served by this oven and indicate materials
and quantities processed in this oven.)
6. Timn botwecn application of coating ftnd heat in oven 2 Min. (if coated articles are preflashed at
ambient temperature with high velocity air or with preheated air explain under comments and include time
and temperature involved.)
Is oven electrically heated (__}; steam heated CJj gas fired (JQ
Does solvent vapor recirculate through the oven gas burner flame. Yea CD No QD
On reverse side of this sheet, draw a schematic diagram of the oven air flow system indicating
burner locations, fresh air inlets, plenum, circulating fans, exhaust fans, etc., or indicate standard
type Continuous drying oven ,
10. Are coatings baked, heet cured or heat polymerized in the oven. Yes (Y) No d) Unknown (_-).
11. '//ill coating redissolve in the original solvent after passing through the oven Yes CO No (Xj
12. Oven temperature 250 F°, Oven operation batch C) Continuous (JQ
13. Time coated products in °ven___3 Min.
1A. Air Pollution Control equipment installed or in process of installation vapor incinerator
15. Comments: This is a high volume PToduction_prQces3_.__ The articles coate3 a^r^^o^v^eyer^ ^ tn^^verr
where the finish is baked. The vapor incinerator was in operation with combustion chamber temperature
recorder showing nearly constant 1250°F. No noticeable solvent vapors at exhaust stack.
Inspector^
Engineering Division Use Only: Rule 66 Compliance Rule 66 Violation
Page_ 1 of 1 Pages
Engineer
Figure 2.11. EXAMPLE OF INSPECTION REPORT, STRUCTURED FORM, SOLVENT USAGE
SURVEY OVENS, LOS ANGELES COUNTY AIR POLLUTION CONTROL DISTRICT
-------
2.52
A rigorous description of the facts of the violation is usually
supplied on the reverse of the original or separate copy of the
notice. The notice may also include a matrix for recording visible
emissions as they were read. The charge portion of the notice (minus
the inspection report) is served directly to the responsible person
on the premises. A copy (or copies) of the notice containing the
inspection findings is delivered or sent to the agency and reviewed
and processed towards court or other legal action. The violation
notice may take two forms; one for stationary sources and one for
vehicular sources, as shown in Figures 2-12, 2.12a, 2.12b, 2.12c and 2.13.
Notices are issued only if the field enforcement officer has
collected evidence sufficient to prove the occurrence of the
violation. The notice deals with facts and avoids presumptive types
of information. It should not be issued as a warning or to prescribe
remedial action or to order correction of defects. (These actions
are usually handled by other inspection procedures.)
Notice forms are usually sequentially numbered and are subject to
strict accounting procedures. If the evidence provided by the
notice and attached inspection report is sufficient, a complaint
can be filed in the appropriate court. If the evidence
is incomplete or defective, no action is taken. Where
corporations and partnerships and other complex business entities
are involved, investigation may be required to establish the chain
of authority responsible for the violation. (See Prosecuting
Violations. Chapter 3.)
C. The Citation
The citation is similar to the notice in purpose and function with
the exception that it cites violators directly to court on a
-------
2.53
76N634A 4/71
Air Pollution Control District—Los Angeles County
434 S. SAN PEDRO ST., LOS ANGELES, CALIFORNIA 9OOI3
NOTICE OF VIOLATION 1-13-72
Blunthead Brass Products, Inc.
NAME PHONE
8965 East Warren Blvd., Los Angeles, 90014
ADDRESS
4332 Mark Road, Los Angeles, 90012
CITY
RE PREMISES AT CITY
Williams Contractors, Los Angeles, California
INSTALLING CONTRACTOR CITY
YOU ARE HEREBY NOTIFIED THAT PURSUANT TO SECTION
2A242
Of THE HEALTH AND SAFETY CODE OF THE
STATE OF CALIFORNIA A MISDEMEANOR HAS BEEN COM-
MITTED THROUGH THE Discharge of air contaminants
of an opacity in excess of that allowed from the
eastmost roof monitor venting fumes from 5 brass
furnaces.
POINT OF OBSERVATION: 50 feet east of roof monitor
WEATHER: Clear
WIND
w
ARRIVAL: 9 '25 5?
PM
DEPARTURE: 5:00 JJ
WAS SOURCE EMITTING
VISIBLE DISCHARGE AT
END OF OBSERVATION?
YES H NO D
R. No. OR
OPACITY
EMISSION ^S?OL
EPnU. L.UNIKUL
FROM" OPEN FIRE
Per.mlt A4351
No.
VISIBLE EMISSIONS OBSERVED
START
STOP
SEE
OBSI
ATT,
RVA'
MIN.
LCHED
CION
R. No.
% OP.
FIEL
SHEET
COLOR
)
TOTAL MIN.
SERVED TO William Simpson
TITLE_
President
Date of Service.
Sector 8
By.
RALPH E. GEORGE
Director of Enforcement
Robert Henderson 35
No. FA 6127
By-
John Smith
Badge No.
42
FROM T
Figure 2.12. NOTICE OF VIOLATION WRITTEM FOR EXCESSIVE FUMES
FROM FIVE BRASS FURNACES, FACE SIDE, LOS ANGELES
COUNTY AIR POLLUTION CONTROL DISTRICT
-------
2.54
OPERATE Arnold Henson, 5623 Peak Avenue
{Nurr.a & Adores*] __ _ ~-
His REMARKS: we melt yellow brass with about 25% zinc. ^he_
scrap metal we have been getting has been unusually oily.
The operator on the No. 2 furnace is inexperienced.
WAS MANAGE: "••IT CONTACTED YES is NO n
NAiviE: William Simpson TITLE: President
His KEMA?.*S: The furnaces were installed in April 1947. We
have expanded our operation so fast that we have not had
time to organize our floor operation properly. We are now
considering a baghouse to control fumes.
FINDINGS (INCLUDING INSPECTOR'S FULL EXPLANATION OF ViOLV.'.O:,)
Excessive emissions observed from roof vent 20' L x 3' W
venting 2-300 Ibs., 2-250 Ibs., and 1-500 Ibs. gas-fired
hydraulic tilt, yellow-brass, melting furnaces. Continuous
observation sheets of furnaces and emissions attached.
Excessive fumes aggregate from charging of oil scrap,
excessive pouring temperatures, general pouring operations
and fluxing and slagging. Since metal is charged and
poured continuously excessive emissions occur continuously.
Borax used as flux.
CORPORATE OFFICER:
DRIVER'S LICENSE NO.:
VACATION FROM TO
REQUEST FOR COMPLAINT SIGNED:
BACK
Figure 2.12a. NOTICE OF VIOLATION WRITTEM FOR EXCESSIVE FUMES
FROM FIVE BRASS FURNACES, BACK SIDE, LOS ANGELES
COUNTY AIR POLLUTION CONTROL DISTRICT
-------
FURNACE NO. FBOM
EAST TO WEST AND
CAPACITY
Light-off
Charge
Quantity
Time
Max. Temp.
Flux added
Slagging
Pouring
1
300#
2:30
3:01
40#
3:25
2225°
3:28
3:30
3:41
2
300#
2:25
2:58
50# (oily)
3:15
2500°
3:18
3:27
3:38
3
250*
2:20
2:54
45#
3:10
2300°
3:13
3:16
3:30
4
250#
2:32
3:05
38*
3:30
2230°
3:33
3:45
4:00
5
500#
2:36
3:10
40#
3:35
2230°
3:38
3:50
4:10
to
Ln
Figure 2.12b. CONTINUOUS OBSERVATION SHEET FOR FIVE BRASS FURNACES
SUPPORTING VIOLATION NOTICE FA6127 CFigure 2.12)
-------
2.56
QDQ D
NAME OF APPLICANT DATE OF IN5PECTIU
Blunthead Brass Products 1/13/72
EQUIPMENT LOCATION (ADDRESS) PERMIT . NO.
Ii332 Mark Road, Los Angeles, California 90012
SOURCE OF AIR TYPES OF AIR ^
CONTAMINANTS Tf±vK Brass Furnaces CONTAMINANTS flames
X^!i,S: 50 feet east of roof vent K^Kc Roof monitor
•"THE" Clear
"""From south ".*",«,«, FROM 2:30 P.M. "UiU P.M.
OBSERVATIONS OF VISIBLE AIR CONTAMINANTS
TIME
FROM
2:20
2:51:30
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:itO
3:1*1:30
3:U5
1;:00:30
U:03
U:10:30
TO
2:&: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
3:1*0
3:las30
3:li5
lt:00:30
U:03
lt:10:30
li:13
•COLOR CODE;
"8" MEANS BLACK
"W" MEANS »HITE
Bl !»!..< Bluish-Wttf
MFAX
INTERVAL
Ml N-
UTES
1
2
3
5
i
2
It
2
3
2
2
21
SEC-
ONDS
30
30
30
30
30
30
30
30
% OPACITY
OR
RlNGEL-
MANN NO.
0
3055
No. 1)1
60%
50%
60%
70%
30%
552
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
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 OPACITY) OF 2^ R and lid? OR GREATER
te si
pAor • 01
Q^Xrv^
Inspector John amltn
— = '«ES 16-500108 R1-55-S
Figure 2.12c. SUPPORTING EMISSION OBSERVATION SHEET TO
THE NOTICE OF VIOLATION, Figure 2.12
-------
2.57
Air Pollution Control District — Los Angeles County
434 BO. BAN PEDRO BT., LOB ANOELEB 13. CALIFORNIA
Date CM M . 10 __ 19 _ __
Time _______ PM _9.'OS _ AM
V 8258
.- _
Veh. Lie. No. _S_LJ LO. I . _____ State _ CALiE. _ Cab No. 1 9/2.
Reg. Owner TRI-WAN TRUCKING CO. INIC, ___
Address 960f LOWEN> RD- ____
City or Community COM P TQM, _ C*L|F. ___
Driver JDHM PRESTON 1-iOWARD __________
Res. Address 1315 ELM ST. City LONG .
HAILING ADDRESS
9605
RD.
C.OMPTQM
BEX
M
HEIGHT
6-a"
COLOR OF EYES
BLUE
DATE OF BIRTH
DEC. IO, 1930
B^OMO
^_^ WEATHER
^Lj^ OVC8T
FOG RAIN
WEIGHT
(94 t-Bf.
DIAMOND T
fGREEW1)
(LEVeT^ UP-MILL
THR-GEAR
JL
W I E
h!r
TRAFFIC
HVY ^EO) LT
YOU ARE CHARGED WITH A VIOLATION OF SECTION MM2 OF THE
HEALTH AND SAFETY CODE OF THE STATE OF CALIFORNIA BY
EMITTING ** *f 6LAC.K. SMOKE AGGREGATING
8 MINUTFS IN ONE HOUR FROM 8'. 5O AM TO
9:02. AtA WHILE TRAVELING ON ^UrtNAEDA 5T.
ALONDRA B
VERNON AV/.fL,^
6/
' Drlve^SlKDiture
J3/3
CL.&oe.
Badee No
7/
Addreu Iiupector lindge No
NOTE: PARTIES CONCERNED WILL BE NOTlrlED BY MAIL OF
THE ACTION TAKEN ON THE ABOVE CHARGE.
70N835--10/56
Figure 2.13. VEHICLE NOTICE
-------
2.58
specified date similar to procedures followed in handling traffic
citations or tickets.
The citations are generally limited to sources in which the elements
and responsibility for commission of the violation are relatively easy
to standardize and process. Citations have been ised to handle smoke
violations for motor vehicle exhausts (see Figure 2.14). They
are beginning to be used for certain types of stationary sources,
i.e., incinerators.
The citation is usually rendered in multiple copies. For example,
the first copy may serve as the court complaint, the second is
reviewed and filed for the record, the third is the violator's copy
and the fourth is retained in the citation book to refresh the field
enforcement officer's memory, should he be required to appear in
court.
D. Defect Notice Follow-up System
Some agencies employ a defect inspection system which uses a check-
off form containing a classification of possible defects, such as
those shown in Tables 2.3 and 2.4. Detection of a major defect in
a plant results in an order to correct the defect and in withholding
renewal of the annual certificates of operation until such
correction is made. A minor defect results in a recommendation
for correction.
E. Sealing of Equipment
Authority to seal equipment and thus prevent its use and continued
violation of emission regulations can be an effective enforcement
tool. Application of this punitive and preventive power can be more
damaging than fines levied by a court. This procedure is often
-------
2.59
Air Pollution Control District - Los Angeles County
NOTICE TO APPEAR
C- 28127
June 6
19 71
TIME
l;35pt
NAME (FIRST, MIDDLE. LAST)
John Albert Brown
RESIDENCE ADDRESS
1640 E. Main Street
Los Angeles 90002
BUSINESS ADDRESS
1001 W. 12th Street
CITY
Downey, Calif.
DRIVER'S LICENSE NO.
B 100001
Calif.
CLASS BIRTHDATE
(M)
Black
EYES
Brown
10-3-29
5'10"
165
VEHICLE LICENSENO. STATE
Smog-1 California
PASSENGERS
YEAR
1969
MAKE
Matson
BODY STYLE
Coupe
COLOR
Red
REGISTERED OWNER OR LESSEE
John Albert Brown
ADDRESS OF OWNER OR LESSEE
1640 E. Main St.
CITY
1 L.A. 90002
VIOLATION(S)
V.C. 27153 V.C. 27153.51
Emitting white smoke of 70% opacity
continuously _from exhaust pipe.
LOCATION OF VIOLATION(S)
Sepulveda
Pico and Olympic
I CERTIFY UNDER PENALTY OF PERJURY THAT THE FOREGOING
IS TRUE AND CORRECT. EXECUTED AT THE PLACE AND ON THE
DATE SHOWN ABOVE.
lnSpecto,..RoJ?ert.M. MaSOn Badge No. ..A3.
Inspector..Donald Jordan Bodge No....25.
WITHOUT ADMITTING GUILT, I PROMISE TO APPEAR AT THE TIME
AND PLACE LIST&Q BELOW.
Municipal Court, Division 50
833 S. Wall Street
CITY OR TOWN Los Angeles. California
ON THE 20 DAY OF June
OR YOU MAY
ATTEND NIGHT Jime 22
COURT ON ° mic <-*-
71
9:00
A.M.
YOUR COURT
OF APPEARANCE _
P.M. DOES NOT HOLD [")
NIGHT SESSION
FORM APPROVED BY THE JUDICIAL COUNCIL
OF CALIFORNIA (s) 7-13-71 v.c. 40Si3(b).
(SEE REVERSE SIDE)
76C462-4-7!
Figure 2.14. APCD VEHICLE CITATION QUADRUPLICATE
-------
2.60
Table 2.3. CODE OF CAUSES OF SMOKE VIOLATIONS
Improper Operation Improper Kiicl
I. Rodding fire (S)* 60. Using high volatile co.il wiiliout
2. Firing by hand (S) proper equipment (II)
3. Air-lncl ratio out of adjustment (S) 61. Fuel too large—Not enough slack
-I. Not using steam air jeLs (II) (S)
5. Careless liring (S & 11) 62. Fuel too small—too much slack
6. Sianing fire in cold boiler (H fc S) 63. Bar! load of coal—general
7. Cleaning fire- (H & S) 64. Other
8. Banking fire (II & S)
9. Binning trash (H & S)
10. No one assigned to firing job (H & S)
1 1. Fireman doing other work
12. Regular fireman oil'—Relief man firing
13. Other
Improper K<|uipment Miscellaneous
30. Kmei gency breakdown or service (S) 90. Unahlc to determine caus-e
31. Oveifne air needed (S) (H & S)
32. Oveifire air system not effective (S) 91. Junk fire
33. F.quipmcnt dirty (II &: S) 92. Incinerator
34. F.quipmcnt in disrepair (H & S) 93. Other
35. Kc|uipment loo small or improper
design (II &S)
36. Insullicicnt draft (H S: S)
37. No smoke indicator
38. Smoke indicator not effective
39. Other
*See Table 2.4.
Table 2.4. STANDARD ABBREVIATIONS
A. Action B. Equipment
RB = Report back i>K = (>,m.n. ,„. protess
NTA = Notice to appear H = Heating
WAF = \Vaim air furnace
S = Stoker
HF = Hand-fired
OB = Oil burner
1'F = Powdered fuel
W = Wood
(SOURCE: Gruber, Reference 1)
-------
applied to ensure correction of defects in space heating equipment
by sealing units at the end of the heating season. Thus the owner
is not deprived of its use when needed but he knows he must get it
corrected during warm weather. It is also a useful took in preventing
further construction on a unit being built in a manner different from
that prescribed in approval plans.
F. Work Reports
The work report or daily report, as it is sometimes called, is a
daily record made by the field enforcement officer of all inspection
stops and reports made, in chronological order of performance and
other field or office work performed (see Figure 2.15).
The daily report is used for review purposes, to check completion of
assignments, work efficiency and to tabulate the number of in-
spections or man-hours spent in the field in the various categories
of field duties. The daily report also shows district coverage in
terms of areas patrolled, facilities observed and miles driven.
VI. PROCESSING OF REPORTS
The review process is intended to maximize and validate the data and
evidence collected by enforcement officers since important legal use
may be made of this information at any time.
All of the reports, together with the daily report, are assembled usually
by an enforcement supervisor for review, correction and disposition. The
supervisor performs the following:
(1) Checks for accuracy, completeness of data or evidence of
violation.
(2) Corrects or returns reports to enforcement officers and
instructs or trains the officers accordingly.
-------
INSPECTOR'S 'ST'3 '• (117
NAME IPRINTI DONAT.n timpAN COM NO ; U3/
TIME
IN
PM
7:50
8:15
9:15
9:45
11:20
12:30
1:10
2:15
3:40
4:05
5:30
t'O-42
OUT
10-57
-
8:50
9:30
10:50
12:20
1:00-
2:00
3:20
3:55
5:30
6:00
Jl
NAME OF COMPANY OR LOCATION OF
INSPECTION OR NON INSPECTION STOP
Home - Patrol
Jones Poultry
Mr. Harry Jones
South Pasadena Mfg. Co.
Mrs. J. Smith (coapl)
Lunch
APCD Hq.
Arrowhead Products
Consolidated Truck Co.
James Burner Co.
Patrol
Home
CITY OR
COMMUNITY
L.A.
Hi.Pk.
L.A.
S.Pas.
Alh.
L.A.
L.A.
Vernon
L.A.
L.A.
INSPECTOR'S • CHECKED-
SIGNATURE | Donald Jordan DY • A.S.
40D4d9
L.A. CO. A.P.C.D. - ENFORCEMENT DIVISION - DAILY R
EPORT
• MO. • DM • YH. i J
«« i 4 as [ 72 Lr™.| -
ACTIVITY
SURV. -COMP.-
VAfi. -DENIAL -
B.D. LIST NO.
—
Smoke viol-
Vehicle
Eq. List
Compl.
Compl.
™
Supplies
Eq. List
Vehicle
Engr. Final
TOTALS — *
NO.
NSP.
TOP*
13-4
NO.
NSP.
e-i
© N
DOCUMENT S
R
1
1
1
1
4
•'-
KA
2
2
3-3
SS
n-E
EF
1
1
a-3
1
1
2
i-
*-
1
1
c
1
1
iZ-
1
1
0-
Sl
1
1
2
«•
19-0
tND OF MONTH CJGM-ir •:••<.
DATA FOR CAH NO.: 516 f AD ):f,: 30,153
N)
ON
Figure 2.15. ENFORCEMENT OFFICER'S DAILY REPORT, LOS ANGELES COUNTY AIR POLLUTION CONTROL DISTRICT
(Codes: IR=Inspector's Report, NA=Notice to Apply, SS=Solvent Survey, EF=Engineering
Final, L=Equipment List, F=Stationary Source Notice, V=Vehicle Notice, CV=Commercial
Vehicle, C=Citation, Passenger Vehicle, SI=Visual Observations for Possible Emissions.)
-------
2.63
(3) Checks the completion of all assigned inspections.
(4) Approves or establishes reinspection schedule.
(5) Refers report and/or supplies coding for computer processing.
(6) Files report or takes other action.
Reports should be carefully checked, especially for completeness of the
specific facts of the violation: the names and addresses of responsible
parties, opacity and Ringelmann values and time intervals of violations,
as well as a record of all persons involved. 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 and exemptions, should be accurately ascertained and described.
The disposition of most reports is predetermined since routine processing
is set up for each report. The action to be taken is initiated by the
enforcement officer. The review process is concerned with confirming,
or correcting, his judgment. If the field enforcement officer 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 should be processed towards legal action. If the field
enforcement officer does not observe a violation, or he is unable to
gather the necessary evidence, then he must use the proper form of the
inspection report. The function of the report determines the disposi-
tion and routing procedure, as follows:
(1) If the report is a citation, notice of violation, or report
recommending legal action, it is forwarded to the investiga-
tion or legal staff for possible legal action. (See Figure 2-16.)
(2) If the report is a request to apply for permit, or other
inspection 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
engineering services to the forthcoming applications and to
provide data essential to permit processing.
-------
2.64
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.
Files "Request for Com-
plaint" with the prosecut-
ing attorney.
Files both "Request for
Complaint" and the "Mis-
demeanor Complaint" in
the court of proper juris-
diction.
serves copy
to VIOLATOR
SENIOR
CLERK
INVESTIGATOR
Inspector's
Notice
Filed
4)
5)
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 2.16. PROCESSING OF WRITTEN NOTICES OF VIOLATION
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2.65
(3) If the report calls for further investigation or surveillance
before the matter can be resolved, it is referred to the
appropriate district or special enforcement officer.
(4) If the report resulted from an assignment, it is referred to
the assignor.
(5) If the report involves a policy decision, it is referred to
the appropriate staff member.
(6) If the report requires no further action due to resolution of
the problem or lack of evidence, it is filed for reference.
VII. MANAGEMENT OF ENFORCEMENT DATA
The enforcement process, shown in Figure 2.1, by its nature must continuously
generate considerable quantities of data on the sources of air pollution.
At the same time, it must retrieve and use much of this data in the daily
conduct of the field operations and enforcement program. The smooth and
effective functioning of the enforcement process thus depends on the flow
of information among the various work units. Both record-keeping and
data management systems are essential.
(1) Record-Keeping Systems—record keeping maintains original field
reports, court and hearing board and other important documents
in their original form in the event that legal use may be made
of them at any time. They are usually kept in the form of
dossiers or case histories, filed by the name of the source and
assigned a master record number to permit cross-referencing to
other data files and listings.
The record system should provide the capability to retrieve
original documents and individual case histories of prior
compliance or violation and other factual information which
might be submitted as evidence in a court of law, such as:
frequency of violation
causes of pollution problems
emission potentials
process flows
equipment maintenance and operational practices
fuels and materials employed
products manufactured
permit applications received
permits issued
permit denials
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2.66
The record system also provides information concerning field
and administrative practices that can be evaluated from the
standpoint of program improvement. Records disclose the
judgments, decisions and techniques applied at each processing
step and level of responsibility.
(2) Information Management—information management systems provide
two broad types of functions: (a) information management itself—
input, storage, maintenance and output of information required
by enforcement personnel; (b) summaries of information
needed in the management, planning and evaluation of the enforce-
ment program (management information). Inspection and enforcement
reports provide the data elements which, when extracted and
structured into a data base, are available for selective retrieval,
listings, generation of management reports, data conversion and
statistical analysis.
Management information is of particular importance to the direction of the
enforcement program. It is needed for the purposes of:
(1) Work scheduling and work load balancing.
(2) Evaluation of performance with respect to the assigned enforce-
ment mission.
(3) Evaluation of performance with respect to air quality goals
and control strategies.
Management information of types (1) and (2) above provide information on
categories of work performed by enforcement personnel such as the number
of firms inspected, notices written, and complaint investigations conducted,
and schedules much of this work. This information is routinely gener-
ated in periodic and summary report form by many air pollution control
agencies.
Management information of type (3) is the type of information that would
be generated for the air pollution control officer and his staff which
relates enforcement activities to changes in calculated emission rates by
grid squares in the control jurisdiction and hence to changes in air
quality. Output of this type requires the use of sophisticated computer
software in order to integrate the pertinent data processing activities
and information flows of the air pollution control agency. This may be
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2.67
accomplished through a highly developed permit system or through an
Emission Inventory and Enforcement Management system (EI/EMS), as
shown in Figure 2. 1.
The function of the latter is to summarize data on emission rates by
pollutant classes and grid squares such that estimation of air quality
can be made, on the one hand, and the relative contributions of the
emission sources to air quality can be assessed on the other. Such
systems are at the frontier of the state-of-the-art because of the
mathematical modeling and the extensive source and air monitoring
required to quantitatively relate changes in emission rates to changes
in air quality and enforcement performance. Where permit systems are
used, emission rates are calculated and assigned to individual facilities
at the time of the processing of the permit. These data are input to
the data bases for each grid square.
Work-scheduling, balancing and evaluation must be conducted by all
agencies. The following types of management reports are usually required.
(1) Work Accomplishment Reports—these summarize work performed by
each enforcement officer, enforcement subunit (industrial,
specialized, patrol, etc.) and the enforcement branch as a
whole, for each reporting period (monthly, quarterly and annual).
This summary information is usually consolidated from the
enforcement officers'daily reports, an example of which is
shown in Figure 2.-15.
(2) Inventory Inspections-Projected Work Load Statistics—this
report compares the number of firms and their number of per-
mitted and non-permitted items and associated work units, as
stored in the current information management system data base,
with a forecast of the number of inspections to be conducted
in the next reporting period. The forecast is based on a
multiplication of the current inspection frequency assignments
times the number of inspection items currently on file. This
comparison may be output by grid, sector (or district) or for
the entire control jurisdiction. This information is used for
adjusting manpower and work assignments and schedules to meet
projected equipment inventory requirements.
-------
(3) Inventory Inspections-Accomplished Inspections vs. Scheduled
Inspections—this type of report establishes the number of
inventory inspections conducted by the number of facilities
and the associated number of inspection items and work
units in each of 7 inspection frequency categories. These
categories include 4 times per year, 3 times per year, 2 times
per year, 0 times per year (once every other year), "X,"
no assignment, but record maintained and "*," low priority equip-
ment to be inspected when manpower is available. Two status
categories also include: "non-source" and "out of business."
For each of the above categories, current quarterly assignments
are compared with inspections performed, and new and past
assignments.
(4) Complaint Load Statistics—complaints made to the control
agency are also compiled daily, quarterly and annually from
message logs and inspection reports. This information will
show trends by facility and equipment over periods of time.
(5) Enforcement Statistics—include reports made of numbers of
violation notices and citations issued by source category,
the number of cases handled by the courts and hearing boards
and convictions and penalties assessed.
Filing and retrieval systems may be operated on a manual, semi-automatic
or fully automated basis. Except for the dossier files, the total
enforcement system, or key or high-use portions of it, can be committed
to electronic data processing (EDP). Once such a system is designed,
it can be programmed and installed. EDP requirements will depend on
the volume of data to be handled by the agency. Actually, some use of
EDP should be within reach of all enforcement agencies. Options open
are batch, remote batch, time-sharing, general purpose software,
combination microfilm/EDP or other manual/EDP combinations. Off-the-shelf
software for smaller agencies in batch or time-sharing modes are available.
Data management systems should not be considered as a panacea; they will
not fulfill, on demand, any request for information that might be made
of them. Output is limited to the functions for which the information
-------
2.69
system is designed and the scope, format and quality of the input data.
Data management systems are thus optimized around one or a small number
of basic functions. A system may be oriented to emission inventories,
source registration, inspection scheduling) defect correction or
management reports.
-------
2.70
REFERENCES
1. Gruber, C. W. Source Inspection, Registration and Approval. In: Air Pollu-
tion, Vol. II, A. C. Stern (ed.). New York City, Academic Press, 1968.
2. Lunche, R. J. , E. E. Lemke, R. L. Weimer, J. Dorsey, and J. A. Verssen.
Administration of the Permit System. Los Angeles County Air Pollution
Control District. January 1968.
3. Weisburd, M. I. Air Pollution Control Field Operations Manual. DREW,
PHS, DAP. P.H.S. No. 937. 1962.
4. Loquercio, P., and W. J. Stanley. Air Pollution Manual of Coding. DHEW,
PHS, National Center for Air Pollution Control. 1968.
5. Schueneman, J. J. Air Pollution Control Administration. In: Air Pollu-
tion, Vol. Ill, A. C. Stern (ed.). New York City, Academic Press. 1968.
-------
3.1
CHAPTER 3
PROSECUTING VIOLATIONS
I. INTRODUCTION
In the earliest times, remedies against damage from air pollution (at
least in Great Britain and the United States) were based on prohibitions
against public nuisances. This is a term which describes a miscellaneous
group of conditions which cause annoyance, inconvenience, discomfort,
damage or harm to the general public. In most countries, such con-
ditions are prohibited and punishable by criminal law. Each case is
usually decided on its own merits, but this approach, although still
available, has become unwieldy.
Even though under common law, smoke and other contaminants were not con-
sidered to be nuisances per se, it is now well-established that legislative
bodies can declare air contaminants to be a public nuisance. The courts
will not invalidate such acts provided that the declaration is reasonably
(2)
clear and certain. The increasing number of gaseous and particulate
substances which may be considered to be pollutants has made this recourse
more uncertain because of the difficulty of proof and the complexities
of prevention and control associated with the less obvious forms of
pollution.
Increased reliance, therefore, is being placed on specific statutes
under legislation based upon the police power of the state. This is
a power granted under the 10th Amendment to the United States Constitution
and which may be conferred upon municipalities by statute or charter.
It empowers the state to pass appropriate laws intended to regulate
specific conditions which affect the comfort, health, convenience, good
order and welfare of the inhabitants.
-------
3.2
The landmark case of Northwestern Laundry vs. Des Moines (239 U.S. 486,
1961) confirmed the power of local government to adopt and enforce
specific air pollution abatement ordinances. Air pollution statutes
thus are in the same category as food adulteration in that they are
strict liability offenses; i.e., proof of actual injury to health or
property is not necessary to support conviction of violation of the
statute.(1)3)
A. Criminal Sanctions
Maintenance of a public nuisance is a crime in most countries and
punishable by criminal sanctions. The two common categories of
crimes are misdemeanors and felonies. Where violations of public
nuisance or other air pollution statutes are declared to be a crime
they are inevitably treated as misdemeanors. Misdemeanor penalties
may involve both fines and imprisonment with a common maximum
penalty being $500 or a year in jail. State prison sentences are
not allowed for misdemeanors. It is possible in some states, however,
to impose felony penalties on conviction of conspiracy to commit a
misdemeanor.
In criminal cases, the defendant has a right to a speedy trial, an
attorney and a jury trial. The evidence burden for the prosecution
is beyond a reasonable doubt and in the case of a jury trial the
jurors must be convinced of this proof although the 5th Amendment
protection has been cited as a possible hindrance to prosecution.
This practice, however, has not proven to be a problem. ' The 5th
Amendment privilege, also, does not extent to corporations.
The use of criminal laws tends to minimize length of litigation,
involves straightforward procedures and utilizes existing legal
structures.
-------
3.3
B. Civil Procedures
The use of civil procedures to secure enforcement of air pollution
statutes serves as an alternative or supplementary approach to that of
criminal sanctions in many jurisdictions. The injunction is one of
the traditional tools available. It seeks to prevent a future action
by a polluter rather than punish a past action. While a very powerful
C2)
tool, Kennedy suggests that it is the "big gun" to be used mainly
when dealing with a large and continuing violation. Also procedures
can become very lengthy. Brecher and Nestle^ state that the courts
often assert that a permanent injunction is an extraordinary remedy
to be granted sparingly. The courts also "balance the hardships" in
injunction cases.
Another civil approach is available when the legislature provides for
monetary forfeiture following a determination that an abatement order
or regulation has been violated. Some states have provided for very
heavy monetary penalties, particularly for violation of an abatement
order issued by an air pollution control or hearing board following a
hearing. In some states these actions take precedence over many other
civil matters and, therefore, the delay in enforcement is minimized.
In civil procedures a person may be required to testify against him-
self and there is no right to a jury trial. Decisions are based upon
the preponderance of evidence. The major types of enforcement
procedures, based upon criminal and civil sanctions, are described
in the following sections of this chapter.
THE ADMINISTRATIVE HEARING PROCESS
The administrative hearing is a civil procedure wherein an owner of a
facility responsible for a violation of the rules and regulations or an
air pollution problem requiring abatement is ordered to attend a
-------
3.4
hearing. Depending on agency practices, the hearing may be conducted
by the enforcement agency or a quasi-judicial body appointed by an air
pollution commission, board, or equivalent. The hearing may be re-
quested by the agency, or by an owner seeking relief from an order of the
agency.
The administrative hearing process is usually employed where the intent
of the basic legislation is to exhaust all administrative remedies be-
fore taking any case to court. It is particularly suited where strong
programs for voluntary compliance are in force. This procedure gives
the agency powers to issue cease-and-desist orders, levy fines and
negotiate settlements such as source compliance plans and schedules.
This procedure differs from hearing boards of the type described in the
next section in that it involves cases (such as code violations) that
would not be heard before these boards, and it confers upon the
enforcement agency powers that would ordinarily be handled by the
courts and hearing boards in criminal actions. It should also be
distinguished from informal conferences and meetings, involving
participation of the owner, such as those commonly conducted during the
processing of permit applications to discuss technical content and
standards of judgment.
A possible chain of events where administrative hearing procedures are
employed is as follows:
1. The field enforcement officer observes a violation in the
field, collects information and informs the highest person
in authority at the facility that a violation has occurred.
In some of the agencies that use this procedure, violation
notices are not served in the field.
2. A copy of the violation notice, signed by the air pollution
control officer, is sent to the facility by registered mail.
-------
3.5
3. Conferences are held, as required: (a) with responsible
representatives of the facility and/or (b) among enforcement
agency staff. Decisional options include: (a) no action,
(b) return to the field enforcement officer for further
investigation or additional information, or (c) prosecution.
4. The air pollution control officer, after considering the
case, or as a result of an administrative hearing (below),
may issue an abatement order outlining the steps to be taken
to attain compliance. This order may be reviewed by a hearing
board or hearing master to confirm the order.
5. If a decision is made to process the case towards prosecution,
a formal administrative hearing is scheduled at which both
parties are allowed to present their positions and evidence.
While the testimony taken at any hearing is under oath,
the parties are not bound by the strict rules of evidence
prevailing in courts of law and equity.
6. Taking into account the history of the plant, the agency
and/or hearing board may have the option of ordering correction
and/or levying a fine as a settlement in lieu of court
action. If an administrative penalty is not paid, the matter
is reported to the courts for proper action. If the penalty
is paid, and satisfactory compliance is achieved within a
prescribed period of time, a portion of the penalty may be
rebated to the owner.
7. A first violation may result in the issuance of a cease-and-
desist order with a date by which the violation must be
corrected.
8. If repeated violations occur, increased administrative
penalties are assessed or the case is taken to court.
The administrative hearing approach presents advantages of flexibility
in handling each case on its merits, and the capability to achieve
compliance on a voluntary basis and to employ legal remedies when re-
quired. This procedure can be very time-consuming and require frequent
conferences with the industries concerned, thus limiting the number of
cases that can be handled at any time. Also, systems which combine
judicial and enforcement functions within the same administrative
-------
3.6
entity may be undesirable. The administrative hearing procedure,
however, can be made to work well by applying objective criteria, by
court validation and by clear-cut policies favoring uncompromising
compliance and speed of action.
III. HEARING BOARDS
Hearing boards are usually quasi-judicial bodies provided for by the basic
state acts dealing with air pollution control. In many cases, members
are appointed by an air pollution control board or equivalent body at
the state, regional or local level but operate at a distinctly different
level from the administrative arm of the agency. In a few cases, the air
pollution control board may also act as a hearing or appeals body.
Procedures governing the operation of hearing boards may be contained in
the state administrative procedures act or may be established by
basic air pollution control legislation. These procedures may be quite
informal or as formal as those of actual judicial bodies including power
of subpoena, provision for cross-examination, and strict rules of evidence.
Most often the procedures are intermediate in informality, allowing, for
example, the introduction of hearsay evidence. This level of quasl-
formality contributes to one of the advantages of a hearing board
procedure as compared to a courtroom trial, that is, the relative speed
at which issues are decided.
Review by the courts of hearing board actions is generally provided in
the basic legislation although the courts do not lightly reverse hearing
board decisions.
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3.7
Hearing boards have a variety of functions depending upon basic legislation
and the type of rules and regulations utilized in the control of air
pollution. Several of the main functions are discussed below:
A. Variances
Variances are temporary authorizations to discharge air contaminants
in excess of the statutory limit. Usually they are issued for periods
of time not to exceed a year without additional review and in no case
is a public nuisance allowed to exist as a result of a variance.
Submission of attainable plans for, or progress towards, controlling
the particular air pollution problem is the usual condition for granting
a variance.
Hearings on variances are equity proceedings to the extent that private
losses are balanced against the public good in each case. A typical case
in which a variance might be justified could involve a manufacturing
plant employing several hundred people and producing a product sold
in a highly competitive market. Air pollution in excess of mass
emissions standards is discharged, but no public nuisance appears to
exist. The plant has definite attainable plans for installing control
equipment, but installation will take 3 months. The plant asks for a
variance to operate during this period on the grounds that several
hundred people will be put out of work if the facility is forced to close
for this period and it may also face the permanent loss of at
least a portion of the market for their product. The granting of a
variance for a 3-month period on the condition that suitable
control equipment be installed would be a likely outcome of such a
hearing.
The advantage of hearing board procedures for variances is that the
administrative officer does not have to compromise his role as the
-------
3.8
person responsible for enforcing the rules and regulations. He has little
excuse for not acting in a vigorous manner to secure abatement of all
air pollution sources. The variance procedure can be abused, of course,
if inordinately long periods are authorized in the variance or if
variances are renewed on insufficient technical or economic grounds.
B. Appeals of Permit Denial
While a permit system provides the air pollution control officer a
great deal of power to take preventive action against emission sources, it
also gives him substantial responsibility to exercise this power wisely.
It is conceivable that judgmental mistakes of a technical nature may
be made by agency engineers reviewing permit applications, particularly
authorities to construct. The appeal procedure gives the person seeking
to install a process or item of control equipment an avenue of appeal
not involving a more costly court procedure if he feels an incorrect
decision has been made.
C. Review of Abatement Orders
In those agencies where abatement orders may be issued by the executive
head of an air pollution control agency, the hearing board may be
authorized or required to review such orders before they can be
enforced. In a similar manner, findings of violation by the air
pollution control officer may have to be confirmed by a hearing board
before court action can be taken.
D. Issuance of Abatement Orders
In some states hearing boards are authorized to issue abatement orders
following a hearing requested by the air pollution control officer.
This is a highly variable situation at present as air pollution control
officers and air pollution control boards are authorized in some
jurisdictions to issue such orders.
-------
3.9
E. Revocation and Suspension of Permits
Whenever a facility which has been granted a permit develops a
history of repeated non-compliance, the air pollution control
officer may petition the hearing board for a revocation of the
permit.
Permits may also be suspended by the agency if the permittee fails
to furnish required information, analyses, plans or specifications.
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 suspended. 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 reinstate a suspended permit on his
own discretion.
IV. THE COURTS
In the case of enforcement agencies that enforce rules and regulations
based on criminal sanctions, notices of violation are usually served in
the field to the alleged violators and the case is decided in a court
of law.
Most air pollution cases are misdemeanor actions and are tried in
municipal or justice courts in the locality in which the violation
occurred. Cases which are appealed from municipal or justice court
decisions may be further heard in an appellate court.
A. Case Investigation
Once the violation notice is issued, the case must be investigated
to complete the facts required and to present the case in a format
suitable for legal handling. This aspect of the case is usually
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3.10
managed by legal counsel attached to the agency; a district, city
or civil attorney; a special investigation unit of the agency, or
some combination of these. In some instances, although not usually,
cases may be prepared and presented directly to a prosecuting
attorney by a field enforcement officer.
After the notice is issued, it is reviewed for sufficiency of
evidence. If the evidence is complete and valid, a Request for
Complaint (Figure 3.1) is filed with the prosecuting attorney
having jurisdiction and, if satisfactory, a Misdemeanor Complaint
(Figure 3;2) is filed with the court. A summons or arrest warrant
is then issued by the court and a date is set for the person or
persons filed upon to hear and answer the charges made.
In establishing the case, the elements of the violation are
abstracted from the field enforcement officer's reports. 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 enforcement officers observing the violation and (7)
the names and titles of the owners and operators of the equipment.
The types of evidence generally required to successfully prosecute
cases involving operation of equipment without a permit and other
non-opacity type violations are shown below. In these cases, not
all of the evidence required need be supplied by the enforcement
officer. Some evidence is supplied by the investigator handling
the case and, in other cases, expert opinion is obtained from
specialists employed by the agency.
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3.11
AIR POLLUTION CONTROL DISTRICT - COUNTY OF LOS ANGELES
434 South San Pedro Street, Los Angeles, California 90013
Tel. 629-4711,-ext. 66071
REQUEST FOR COMPLAINT
DATE OF VIOLATION June 27, 1972
APCO NUMBER 59842
NOTICE NUMBER F-Afl'SS
A. B. C. Laundry Company, a Corp. AnoRFSSI««l 7320 N. Broadway. Long Beach. Ca.90359
and Morgan Smoklev 1560 E. 55th St., Long Beach, Ca. 90355
PLACE OF VIOLATION.
7320 North Broadway. Long Beach. California
CHARGE: VIOLATION OF SECIs I
24242 of the Health and Safety Code of Che State of California
_FOINT OF OBSERVATION approx. 20' east of source
. WlND south
.PHYSICAL EVIDENCE (LIST)_
PHOTOGRAPHS three
DRIVER
S
DESCRIPTION-
HEIGHT
•EIGHT
VISIBLE EMISSIONS OBSERVED
INSPECTOR'S REPORT
START
pm
1:15
1:17
1:19
TOTAL
WITNESSES
STOP
pm
1:17
1:19
1:20
MIN.
2
2
1
5
"f-f rpr
R.NO.
•? OP.
#4 R
fllk R
13 R
MIN.
COLOR
lark
black
black
On June 27, 1972, enforcement officer Donald Jordan re-
fired boiler located on the above premises owned and
advised the enforcement officer that he was employed by
the corporation as Engineer and Fireman, and that he
comes on duty at 12:30 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 comple ion of his observation, the enforcement
officer iss ed a notice charging a violation of Section
24242 of th Health and Safety Code of the State of
California o the corporation through Mr . L . E . Read ,
General Man ger, who confirmed that Mr. Smokley was
434 South San Pedro Street
Los Angeles, California 90013
employed by the corporation and stated that he did not
know how the boiler could have smoked.
APPROVED.
Ralph George, Director of Enforcement
JBM:un
. RECOMMENDED.
Thomas Wilkea, Engineering Inspector
16-40D70
Figure 3.1. REQUEST FOR COMPLAINT, LOS ANGELES COUNTY
AIR POLLUTION CONTROL DISTRICT
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3.12
IN THE MUNICIPAL COURT OF JUDICIAL DISTRICT
COUNTY OF LOS ANGELES, STATE OF CALIFORNIA
THE PEOPLE OF THE STATE OF CALIFORNIA,
Plaintiff,
COMPLAINT - Misdemeanor
A. B. C. LAUNDRY COMPANY, a Corp.,
and MORGAN SMOKLEY
Defendant.
M.C. No. 15321
D.A. No. 234
The undersigned declarant and complainant states that he is informed and believes and upon
such information and belief declares that based upon the Declaration filed herewith which is incor-
porated by reference as if fully set forth herein: on or about June 27 , 1972 , at and
in the above-entitled Judicial District, in the County of Los Angeles, State of California, a misde-
meanor, to wit,
was committed by A. B. C. LAUNDRY COMPANY, a Corp., 7320 North Broadway, Long Beach,
California, and MORGAN SMOKLEY, 1560 East 55th Street, Long Beach,
California
who did unlawfully discharge into the atmosphere from « single source of 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. 1 on the Ringelmann
Chart as published by the United States Bureau of Mines; and (b)
of auch opacity as to obscure an observer's view to a degree equal
to and greater than does smoke described in (a) above.
Said declarant and complainant therefore prays that based upon the Complaint and Declaration
a warrant may be issued for the arrest of said defendant who may then be dealt with according to
law.
Executed on July 25, 1972 m the County of Los Angeles, State of California.
I declare under penalty of perjury that the foregoing is true and correct.
Declarant and Complainant
INVESTIGATING AGENCY: AIR POLLUTION CONTROL DISTRICT
WITNESSES
Enforcement Officer, Donald Jordan, 434 South San Pedro Street Los Aneeles
California 90013.
Figure 3.2. MISDEMEANOR COMPLAINT, LOS ANGELES COUNTY
AIR POLLUTION CONTROL DISTRICT
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3.13
(1) A certified copy of the resolution of the enforcement
agency regarding the adoption of the rules and regulations,
and a certified copy of the rules and regulations.
(2) Stipulation or testimony given as to the ownership and
location of the plant in violation.
(3) Testimony by the enforcement officer and defendant as
to the construction, use and operation of the equipment
in question.
a. Date of construction, if known, or determined in the
course of the inspection. 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 enforcement
officer's observation.
c. Expert testimony as to the capability of the device
to emit air contaminants.
d. Testimony as to the enforcement officer's determination
that the equipment emitted air contaminants at the
time of his inspection.
(4) Testimony by an official of the agency of the non-existence
of permit or authority to construct, determined from a
records search.
Legal action can be taken on the basis of any enforcement
officer's report provided that the evidence contained in
the report is sufficient to establish the case. Action
can be taken on reports which disclose:
(1) A public nuisance involving signed statements from
complainants.
(2) Non-compliance warranting revocation of permits.
(3) Excessive smoke from private residences.
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3.14
(4) Violations observed in connection with exemptions, break-
downs, 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 prove to have been deliberate.
When terms of variances are violated, reports are rendered
on inspection reports and are forwarded to the prosecutor.
Should an important element of the evidence be lacking, special
investigations may be conducted. Generally such investigations
establish ownership and responsibility, employer and employee
relationships, etc. Equipment in question may be inspected to
obtain any data needed to positively identify the air contaminants
and to determine design characteristics and operational practices
to establish the cause of the violation. In obtaining proof of
continuity of ownership, a check may be made of corporate files,
the business license bureau or the department of motor vehicles.
Proof of employer-employee relationships must usually be obtained
from direct testimony of the defendants, the enforcement officer's
testimony or the owner's admission. Proof of the dates of con-
struction of unauthorized equipment may be obtained from contractors,
installers and sellers.
B. Preparation of Case for Court Trial
The proceeding at which the charges are read and answered is called
an arraignment, Constitutional rights are extended at this time
and an opportunity for plea given. The defendant can have the
choice of a judge or jury trial if he pleads not guilty. A trial
date is set if a not-guilty plea is made.
In general the procedure that is followed involves (1) opening
arguments, (2) presentation of the people's case, (3) cross-
examination of prosecution witnesses, (4) presentation of the
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3.15
defense case, (5) cross-examination of the defense witnesses, (6)
rebuttal of both parties and (7) closing arguments.
Assuming a complaint has been filed and the case is scheduled for
trial, the prosecutor and/or the agency will determine what
evidence is going to be introduced and which witnesses are to be
called. If subpoenas for witnesses or records are necessary they
will be issued. In some cases exhibits will be prepared which are
designed to clarify and summarize the evidence. For example, in
a public nuisance case, maps may be prepared showing the location
of the alleged source, the addresses of complainants and the wind
speeds and directions at the time of complaints. Any photographs
that are to be used will be carefully reviewed to be certain that
they correctly represent the observations made at the time.
The past record of the defendant should be examined and the current
status of the emission source determined just prior to trial.
The enforcement officers should review all the facts
obtained at the time of the alleged violation and should have
available all information bearing upon their qualifications. In
the case of an opacity or smoke case, they should be prepared to
give information on the time they last attended smoke school and
their score.
C. Role of the Field Enforcement Officer as a Witness and Courtroom
Procedure
The field enforcement officer in many cases will be the key and
perhaps only witness for the prosecution. His testimony will have
a major bearing upon the outcome of the case. It is his role to
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3.16
respond accurately and clearly to those questions asked of him
under direct examination and cross-examination. Several of the
factors bearing upon the enforcement officer's success as a witness
are discussed below:
The enforcement officer requires training in being a witness.
The air pollution agency should develop training sessions
based upon suggestions from the prosecuting attorney or
legal counsel. It is particularly useful for a portion
of this training to be in the form of a mock trial and
attending actual trials.
Each witness who must be qualified as an expert should be
prepared to give a full account of his training and experience
which relates to his qualifications to testify on the matters
involved. He should not omit significant facts or play down
his experience out of false modesty. It is helpful to keep
an up-to-date biographical sketch and have the details in
mind at the time of a trial.
The enforcement officer should be thoroughly familiar with
all aspects of the law as it pertains to his responsibilities.
This would not only include prohibitions, but procedural
matters and definitions as well.
Do's and don't's for witnesses:
1. Questions should be answered directly.
2, Extended qualifications or explanations in response to
questions should be avoided.
3. The witness should think before answering a question.
The attorney may use this opportunity to raise valid
objections.
4. The witness should be honest and not stretch facts.
5. The witness should not interpret facts unless called
upon to do so as an expert witness.
6. The witness may refresh his memory from notes even
though he may not read directly from them.
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3.17
7. The witness should make judicious use of technical
terms and use straightforward language wherever possible.
Descriptive terms should be used that will convey a
picture.
8. The witness should not "talk down" to the judge or jury.
The proceedings in a judicial hearing or court follow strict rules
which the officers of the court are bound to follow. The prosecuting
attorney and/or the legal counsel of the agency are such officers
and are responsible for the conduct of the case.
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3.18
REFERENCES
1. Edelman, S. Air Pollution Legislation. In: Air Pollution,
A. C. Stern (ed.). New York City, Academic Press, 1968.
2. Kennedy, H. W. The Formulation and Adoption of Reasonable Rules and
Regulations. 55th Annual Meeting of the APCA, Chicago. May 20-24, 1962.
3. Mix, 0. D. The Misdemeanor Approach to Air Pollution Control. Arizona
Law Review, Vol. 10, p. 90.
4. Brecher, J. J., and M. D. Nestle. Environmental Law Handbook.
California Continuing Education at the Bar, Berkeley, California. 1970.
5. Weisburd, M. I. Air Pollution Control Field Operations Manual.
DHEW, PHS, DAP. PHS No. 937. 1962.
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4.1
CHAPTER 4
INSPECTION TECHNIQUES
I. INTRODUCTION
The success of any field enforcement program ultimately depends on the
specific techniques employed by field enforcement personnel to inspect
the sources of air pollution. Inspection techniques consist of the
methods employed to observe processes and equipment, collect and evaluate
data and evidence, interview owners, operators and citizens, use field
testing equipment and prepare reports.
The importance of technique cannot be overly emphasized. Air pollution
control agencies with adequate enforcement powers, but defective in-
spection and enforcement procedures may lose some of these powers as a
result of adverse court decisions. Control agencies beginning operations
with inadequate enforcement powers may gain needed powers through proof
of the need for new rules based on data and evidence compiled through
the use of expert inspection techniques.
II. IDENTIFICATION OF EFFLUENT PLUMES
The ability to identify, describe and evaluate air pollution emissions
and the factors contributing to their formation is a fundamental
inspection technique. Three important levels of understanding, or
points of view, must be considered:
1. The Microscopic. The properties and behavior of the smallest units
of air pollution measured by instruments and techniques of
scientific analysis. This point of view is generally assumed by
the chemist and physicist.
2. The Megascopic. Aggregated source activities, mass emission rates
and large-scale behavior of polluted air masses. This point of
view is assumed by the meteorologist.
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4.2
The Macroscopic. Observations and evaluations of the behavior of
individual source emissions, effluents and air pollution effects
made by means of the sense perceptions and by inductive and de-
ductive techniques. This point of view may be based on assumptions
concerning microscopic and megascopic phenomena and available source
and environmental measurement data. This point of view is assumed by the
field enforcement officer and the air pollution control engineer.
By applying understanding of the principles and processes of air pollution,
any emission source problem may be broken down into the following elements.
1
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.
2
The air pollution
plume or effluent
as emitted, and
rate or quantity.
3
The possible
taminants in
emission.
con-
the
4 5
The effects of the contain- The effects of contaminants
inants in the atmosphere— on life and property such as
clouds, hazes, reduction of odor, corrosion, toxicity, de-
visibility, photochemical posits, and eye-irritation.
effects, etc.
The field enforcement officer must demonstrate that observations and
data required on the macroscopic level prove the presence of an air
contaminant, that is, an effluent that is not water vapor or a natural
constituent of the atmosphere, and that the emission violates a standard.
He must also establish the factors which caused the emission to violate
the standard. To accomplish this, he should be prepared to describe the
events occurring in each stage or element of the air pollution problem.
A. Air Pollution Configurations
Any substance emitted from any process into the atmosphere may be
termed an "effluent." On emerging from a stack, the effluent
flows in rather concentrated form through a moving and often
ill-defined region of the atmosphere called a plume, which is
frequently made manifest by the presence of visible components
in the effluent that move through it. Visible effluents are
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4.3
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 (greenish-
yellow) . With the exception of these gases, however,
virtually all contaminant gases significant in air pollu-
tion are colorless.
(2) Aerosols, i.e., entrained particulate matter.
In the case of aerosols, the visual threshold depends on the
intensity and the direction of the light source with respect to the
observer, and the position and concentration of the effluent. The
maximum visibility reduction occurs when the light source is directly
opposite the observer and behind the effluent. As the observer changes
his angle of position, the visual effect of the light scattering
diminishes until, at a change of 180° of position, the visual effect
is at a minimum.
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 observed.
Three basic configurations of contaminants may be observed by the
field enforcement officer.
1. The Plume
The plume is the contaminant-laden gas stream from a specific
outlet such as a stack or vent. The plume, particularly when it
is distinctly visible, is characterized by (1) a point of release
and formation just at the outlet of a stack or opening of a closed
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4.4
system, or a few feet above the outlet in the case of a "detached"
plume, (2) the body or stream, carrying relatively concentrated
contaminants, confined by the momentum of the escaping gases and
sometimes (3) a point at which the plume appears to dissipate
(see Figure 4 .1).
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. The stream of pollution provides some relative
notion of quantity and velocity of the escaping contaminants, as
well as other characteristics such as color and particle size which
help identify the plume. The point of dissipation is impor-
tant in determining whether or not the plume is a contaminant,
water vapor or steam, or some combination of both. Depending on
wind velocity, humidity and temperature, condensed water vapor or
steam may dissipate more rapidly than contaminants contained
in the plume. The greater the humidity, generally speaking,
the longer the steam plume. Where most of the effluent
appears to consist of water vapor, the opacities or densities of
the contaminants are read at the point of dissipation or evapora-
tion of the steam.
General atmospheric conditions may also be indicated by the behavior
of the plume, and may be of significance in assessing a nuisance
potential. A plume which rises rapidly indicates
rapid vertical mixing of contaminants favorable to the dispersion
of the contaminants. Horizontal plumes may cause fumiga-
tion of an area down-wind from the source of emission. The direc-
tion 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
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4.5
STRUCTURE OF A PLUME
POINT OF
RELEASE
Figure 4.1. GENERAL STRUCTURE OF CONTINUOUS AND DETACHED PLUMES
(SOURCE: WEISBURD, Reference 3)
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4.6
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
turbulent or gusty atmospheres and, in general, results in good
dispersion and only sporadic fumigation. A fanning plume
generally results from a steady and sometimes 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 smokes and
mists by color, behavior and dissipation point. He can distinguish
between emissions of smoke resulting from rubbish burning, 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.
Invisible plumes, i.e., escaping gas streams, can frequently be
inferentially detected by sound of gases escaping from high
pressure systems and light refraction (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 the physiological responses of those near the source.
Some gases may be detected by odor or by irritation of the
mucosa or eyes.
The Cloud
A cloud of air pollution is an emission of air contaminants which
has become completely divorced from its source, or sources, and
is gradually being dissipated by the processes of dilution,
sedimentation and diffusion, but may still retain visible
boundaries. The cloud is snaped by the direction of air flow,
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4.7
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 relative
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 a cloud remains coherent.
Noting the appearance of clouds in reports, especially as to
height, length, breadth and thickness, can be important in
determining the severity of a general or local problem.
Pollution clouds may be invisible. These may sometimes be de-
tected by smell, if the contaminants are odorous gases, and
their extent can be investigated by a field enforcement officer
(or a team of officers) as described in Chapter 6, Section V,
Odors.
3. The Haze
Hazes are frequently formed by condensation of vapors on
atmospheric particles, or by aerosol production in smog for-
mation, 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 condition
of atmospheric stagnancy. Notation of the existence of the
haze is important, particularly when it is peculiar to a
community, since an acute local problem may be present.
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A.8
B. Types of Effluent Plumes
The plume represents the form of the air contaminant of primary
interest. It is the "discharge" or "emission" regulated or
prohibited in most statutes or rules.
Since all substances become liquid, solids and gases at certain
temperatures, the plume may consist of a variety of contaminants
in various states of matter. Smoke, for instance, contains
visible aerosols—carbon particles and solid or liquid particles
of partially burned fuels—and such gases as sulfur dioxide, oxides
of nitrogen, and unburned vapors.
The identity ascribed to the plume is usually made in terms of
its outstanding visual characteristic. For example, even though
sulfur dioxide may be the most significant of the pollutants
emitted from a given stack, the effluent in which it is contained
is frequently described as smoke due to the visible soot, carbon
particles and fly ash contained in the plume.
The mere observation of a plume, however, does not result in its
conclusive identification. Knowledge of the specific conditions
which caused the contaminants is required. The distinction
between smoke and fumes cannot be made unless the processes by
which they are generated are described.
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4.9
1. Smoke
Smoke is the visible effluent resulting from incomplete combustion.
It consists mostly of soot, fly ash and other solid or liquid
particles less than one micro-meter 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, nitrogen 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 con-
siderable distances from the source and many submicro-meter particles
will be permanently dispersed in the atmosphere.
Smoke will vary in color, but will be generally observed as grey,
blue, black, brown and white, and sometimes yellow, depending upon
the conditions under 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 encountered.
Smoke which is grey or black in color may indicate that material
is being burned with insufficient air or inadequate mixing of fuel
and air.
White smoke usually results when combustion is cooled by excessive
drafts of air, or when the materials being burned contain ex-
cessive amounts of moisture.
Brown or yellow smoke may result from the burning of semi-solid
tarry substances such as asphalt or tar paper, resulting from inade-
quate temperature and mixing.
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4.10
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 due to sulfide treated paper and
wood tar constituents. The blue plume contains little or no
carbon or soot particles.
2. 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, distilla-
tion, calcination or chemical reaction when these processes create
air-borne particles. Fume particles are generally less than one
micro-meter in diameter and will behave like smoke. Fumes will more
commonly consist of metals and metallic oxides and chlorides. Also
contained 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 enforcement officer will probably be mostly concerned with
metallurgical fumes. 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 at about 2000°F.
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4.11
Some metals may contain alloys with extreme differences in vola-
tility. Copper-based alloys such as 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 will volatilize. Copper alloys with high
zinc contents may lose from 2 to 15 per cent of their zinc through
fuming.
When vented to the atmosphere, fumes may 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.
Other processes which will produce fumes include calcination, sub-
limation and distillation.
Calcination consists of heating, roasting or smelting to decompose
minerals. Calcination is commercially 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 lime-
stone to form carbon dioxide gas and calcium oxide, or to reduce
minerals by oxidation.
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4.12
Sublimation is the process in which a solid substance is converted
to a gas without a change in composition and without first going
through the liquid state. Iodine, carbon dioxide (dry ice) and
many metallic and nonmetallic crystals are examples of sublimed
materials. Sublimation of these materials may be accomplished by
lowering the pressure, raising the temperature or by changing
both temperature and pressure.
Distillation is a cycle of vaporization and condensation in which
a liquid is converted to a vapor and condensed to a liquid. Dis-
tillation is generally employed to purify a liquid or to segregate
components according to relative volatility.
3. 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 sucn as ceramic and cement manufacturing,
calcining, and wood-working and feed and flour industries.
Dust particles mainly exceed one micro-meter in diameter and are readily
controlled by centrifugal separators, cloth filters and electro-
static precipitators.
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4.13
4. Mists
Mists consist of liquid particulates or droplets, less than the
size of raindrops, such as fog, and are formed by condensation of
a vapor or atomization of a liquid by mechanical spraying. Mist
droplets may contain contaminant material in solution or suspension.
The impregnation and coating of building materials with asphalt
or the manufacture or heating of asphalt at batch plants may pro-
duce 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 control devices such as cyclones and scrubbers, using a liquid
air cleaning medium. Acid particulates, such as chromic and
sulfuric acid produced from chrome plating operations, may also
form mists when exhausted to the atmosphere.
In large oil-burning installations, sulfur trioxide is formed as
a gas, and, after contact with sufficient moisture in the air,
forms as a white-to-blue plume several feet above the stack
(detached plume). After further contact with moisture in the air,
the sulfur trioxide is transformed to a sulfuric acid mist.
5. Gases
A gas is a non-coherent state of aggregated matter, i.e., 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, malodorous, toxic or corrosive effects, or which
may have an effective smog-producing potential. These include
carbon monoxide (CO), ozone (CO, oxides of nitrogen (NO, N0_) ,
sulfur dioxide (SO ), hydrogen sulfide (H-S), hydrocarbons and
their oxidation products, halogens (chlorine, bromine, fluorine,
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4.14
iodine) and their derivatives such as hydrogen fluoride (HF), and
various chlorinated solvents such as those used in industrial
degreasing and dry cleaning. Other important toxicants include
ammonia (NH-), arsine (AsH~), fluorine (F-), hydrogen chloride
(HC1), phosgene (COC12) and hydrogen cyanide (HCN).
Two gases which commonly occur in air pollution problems as a
result of direct emission to the atmosphere are described below.
a. Sulfur Dioxide
Sulfur dioxide is a common stack gas produced from the com-
bustion of sulfur-containing fuels such as coal and fuel oil,
the burning off of residue on catalyst in oil refining opera-
tions, the burning of tail gases from the recovery of sulfur
from refinery waste gases, and various other chemical and
metallurgical processes. A major source of sulfur dioxide is
the burning of coal and fuel oil by refineries and power plants.
Crude oil with sulfur content contains from less than 1 percent
sulfur to 5 percent in some of the heavier fuels. S0_ has a
noticeable odor at comparatively low concentration and will
damage certain species of vegetation at 1/4 ppm. Sulfur dioxide
gases and sulfuric acid mists are capable of accelerating the
corrosion of wires, metals and other materials.
b. Hydrogen Sulfide, Organic Sulfides and Mercaptans
Both thermal and catalytic cracking processes in oil refining
operations convert the sulfur contained in the crude oil into
hydrogen sulfide in the heavier materials and mercaptans in the
gasoline fractions. The same substances are also produced in
Kraft paper mill processes. When hydrogen sulfide is released
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4.15
to the atmosphere 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 concentrations. Hydrogen
sulfide is detectable at .12 ppm and mercaptans from .001 to
.041 ppm. H.S will also discolor some painted surfaces with
lead pigments under humid conditions.
A vapor is the gaseous phase of a substance which at normal temp-
erature and pressure is a liquid or solid.
The most important vapor 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 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 appli-
cation.
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4.16
III. PLUME EVALUATION
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 law has occurred, or it must be evaluated to de-
termine the size or severity of a given air pollution problem.
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
section is concerned with the evaluation of visual emissions by the
use of the Ringelmann standard and equivalent procedures.
Visual observation of plumes by field personnel can be
an effective and economical method of determining compliance
with air pollution regulations, provided the regulations are based
on the visual aspect of plumes or on other properties that can be
shown to be directly related to the visual aspect.
The benefits of basing smoke statutes on opacity or density are
quite evident, even though equipment and fuel regulations have
increasingly assumed precedence in control legislation. When the
visual standard is specific with reference to a cut-off point and time
interval, it is simply and directly enforced. All enforcement officers
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. Although the visual standard is limited to
estimations of particulate pollution which obscures vision, its
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4.17
application simultaneously tends to reduce grain loading and gaseous
contaminants. (As the grain loading in the plume increases, the
light transmission decreases exponentially.) In order to comply
with the opacity standard, more efficient combustion or equipment
operation is necessary. The Ringelmann standard, therefore, is
most versatile in accomplishing gross reductions of atmospheric
pollutants in a community, and can be applied not only to smoke,
but to fumes, dusts and mists arising from a variety of problems.
It should be cautioned, however, that while such benefits can be
assumed, they cannot always be precisely predicted or evaluated.
Determination of opacity and shade of any emission alone gives no
specific measurement of the quantities of contaminants being emitted.
A. Description and Use of the Ringelmann Chart
The history, description and general use of the Ringelmann Chart
is discussed in the Bureau of Mines Information Circular #7718
(August, 1955). Since this document has formed the basis of
smoke regulations in many cities and is used as evidence in many
court actions, it is quoted extensively here.
Introduction
The Ringelmann Smoke Chart (Figure 4.2) , giving shades
of gray by which the density of columns of smoke rising
from stacks may be compared, was developed by
Professor Ringelmann of Paris. Maximilian Ringelmann,
born in 1861, was professor of agricultural engineering
at 1'Institute National Agronomique and Director de la
Station d'Essais de Machines in Paris in 1888, and held
those positions for many years thereafter.
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Figure 4.2. RINGELHANN'S SCALE FOR GRADING THE DENSITY OF SMOKE
(SOURCE: DUKLICH, Reference 1)
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4.19
The Ringelmann Chart was used by the engineers of the
Technologic Branch of the Federal Geological Survey
(which later formed the nucleus of the present Bureau
of Mines) in their studies of smokeless combustion
beginning at St. Louis in 1904. By 1910, 4 had been
recognized officially in the smoke ordinance for Boston
passed by the Massachusetts Legislature.
The chart is now used as a device for determining
whether emissions of smoke are within limits or standards
of permissibility (statutes and ordinances) established
and expressed with reference to the chart. It is widely
used by law-enforcement or compliance officers in juris-
dictions that have adopted standards based upon the chart.
Description and Method of Preparing the Chart
The Ringelmann system is virtually a scheme whereby
graduated shades of gray, varying by five equal steps
between white and black, may be accurately reproduced by
by means of a rectangular 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 repro-
duced 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.
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4.20
Use of Chart
For the process of instruction, the chart is supported on a
level with the eye, at such a distance from the observer 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 corresponding 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 percent dense, the percentage
"density" of the smoke for the entire period of obser-
vation is obtained by the formula:
Equivalent units of No. 1 smoke X 0.20 percentage
= smoke
Number of observations density
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 ordinance.
There are two general methods of using the chart. One
is for the observer to make actual reference to it, as
previously described, while judging the smoke shade.
The other method is based on the fact that, with proper
experience, it is unnecessary for an observer to con-
tinue to refer to the chart. By repeated reference to
the chart, during a suitable training period, the shades
of the Ringelmann scale become fixed in the observer's
memory. 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 certified, are easily made and are
accepted as evidence in courts, this latter method of
using the chart is preferred by most authorities.
-------
4.21
B. Smoke Measuring Methods
Although most control agencies have employed the Ringelmann
Chart as a means of defining smoke standards, other methods
are available for use in the field. 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 devices 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 instrument
is probably not significantly more effective than a
trained sight-reader.
(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 falling on the reference disc
may be influenced by objects nearly in line with
the smoke. Judgment and skill are required in its
use.
-------
4.22
(4) Photoelectric Cells
Photoelectric smoke metering equipment measures
variations in the intensity of a beam of light
passing through the effluent in the stack, thus
directly measuring 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
inspectors to the stacks. However, they may be
required either by permit condition or law to be
constructed, and are of particular importance in
training air pollution inspectors to sight-read
effluents.
(5) Smoke Comparison Charts
Several smoke comparison charts were reported in
the A.S.M.E. (1963) Power Code. One of these was
a circular chart with radial lines of various 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 produced on photographic film for smoke
comparison charts. Another device consists of black
lines photographed on celluloid film which is seen
partly by transmitted light and partly by reflected
light.
(6) Smoke Inspection Guide
A film strip presenting optical densities of 80, 60,
40 and 20 percent transmission has been developed
by the Public Health Service. Film strips meeting
the design and test specifications announced by the
Public Health Service may be identified by a state-
ment to that effect, citing "smoke inspection guides
developed by the U.S. Public Health Service (42 CFR
Part 75)."(2)
C. Principles of Smoke and Opacity Reading
The Bureau of Mines pamphlet, quoted previously, describes the
various cards of the chart. The terms "density" and "opacity,"
however, as used in the literature are only inferentially
-------
4.23
defined. The semantics of these have been the subject of much
controversy and have been confused by defense attorneys attempt-
ing to invalidate the 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.
(1) Smoke Density
"Density" means the "quantity 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 repro-
duced 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 percent 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 degree of opacity. This
definition does not imply any relationship with the
definition which might be made in terms of "weight
per unit volume."
(2) Opacity
The term "opacity" means the degree to which trans-
mitted light is obscured. The degree of opacity is
usually rated directly in percentage of perfect
opacity, 0 percent opacity being equivalent to perfect
transparency, and 100 percent opacity being perfectly
opaque. In air pollution work opacity is actually
judged by the degree to which an observer's view is
obscured. This manner of observing and recording the
opacities of visible emissions should be implicit in
the law. For instance, typical regulations prohibit
smoke of periods totaling more than three minutes in
any one hour . . .
• ... as dark or darker in shade as that
designated as No. 1 on the Ringelmann
Chart . . .
-------
4.24
• Of such opacity as to obscure an observer's
view to a degree equal to or greater than
does smoke...(described above)
It is obvious that the Ringelmann Chart and the
Opacity method are measured in direct equivalents.
The determination of density is actually the deter-
mination of opacity. The difference is that the
Ringelmann Chart is a recognized standard applied
only to shades of gray smoke. The opacity system
is applied only to the shades of white or colored
emissions.
(3) Other Principles
In reading smoke it is not necessary 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 experience find it unnecessary to con-
tinue to refer to the chart." The Superior Court of
Los Angeles County 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, enforce-
ment personnel are made proficient in applying
standard Ringelmann reference readings to field
determination of both the shade and density or
opacity of any visible emission, without regard to
its basic color—whether black, white, yellow or
any other color.
The A.S.M.E. Power Test Code^ 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 con-
ditions of visibility and positive identification of
the source. The 1955 revision of the Bureau of Mines
circular does not specify any required distance from
the smoke.
-------
4.25
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 the sun while the
face of the chart is shaded. About the same amount of
light should be reflected 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 transmitted light.
Thus, with a properly placed chart, 60 percent of the
light reflected from a No. 2 Ringelmann Chart is equal
to 60 percent of the light transmitted through a No. 2
black smoke plume.
(4) Steam Condensation in Plumes
In a plume containing sizable quantities of water
vapor, condensation will frequently start either in
the stack or very shortly above it, and will greatly
increase the opacity of the plume. The ordinance to
be enforced may specify that opacity exceeding the
designated limit is prohibited only if it is caused
by a contaminant. Under some conditions it may not
be possible to determine this question visually,
unless water vapor is considered a contaminant.
However, if opacity exceeds the limit in any part
of the plume in which condensed steam is not present,
the source is clearly in violation of the ordinance.
Costs and Benefits of Plume Evaluation Training
The use of the Ringelmann Chart and equivalent opacity principle
is within the means available to state and municipal health and
air pollution agencies, since the cost is normally only that of
training existing personnel. After the initial intensive train-
ing of 24-32 hours, only about 24 hours per year are necessary
to test and refresh personnel in the techniques of evaluating
plumes. An efficient portable smoke generator can be built or
purchased commercially for about $3,000 and the operation of it
is very inexpensive, about $1.50 per hour. Besides this, many
smoke reading courses are now being offered throughout the
-------
4.26
country by various municipal, state and federal agencies. Most
of these courses are open to enforcement personnel at a very
nominal charge or no charge whatsoever.
Once trained and qualified, one field enforcement officer can make
many observations in one day. A particulate source test takes a
minimum of one day for testing plus the time needed for laboratory
analysis and report writing at a minimum cost of $1,000 per source.
While it is not feasible, because of cost and time, to test
every available source, it is feasible to evaluate each source
many times by visible observation. A field enforcement officer
can normally choose a vantage point where more than one source
can be viewed at one time. Also these sources can be evaluated
under varying operating conditions, while a source test is only
valid at the conditions in force at the time of sampling.
Since it has been shown that with proper training under varying
conditions, that a field enforcement officer can evaluate plumes
within an average deviation of not more than 10 percent and
most can even come closer to 5 percent, the courts have upheld the
Ringelmann and Opacity principles when used by qualified personnel
and with good judgment. It is necessary to have accurate records
of the field enforcement officer's readings on the smoke generator
to offer as evidence of his qualifications. Also, it is necessary
to have an accurate and complete record of his readings at the
source of complaint, as well as support data on sky conditions,
wind speed and direction, and general meteorological conditions
(see Figure 4.3) during the time the source was observed. Plume
evaluation training confers on the field enforcement officer the
necessary expertise to realize these benefits.
-------
4.27
ENVIRONMENTAL PROTECTION AGENCY
Date
Observer j0hn Fitch
Checked by Tom Hathauay
Start Time 9:0" AM
Observation polnt_
South of stack
751
Stack-distance from Ht._
H1nd-speed_5MPH_D1rect._w_
Sky condition clear
Type of installation Ua
heat boiler
Fuel Sau Dust
Observ. Ended 10:00 AM
Smoke Density idbulation
No. Units X Equiv. No. 1
113 Units No,
Units No,
Units
0
52 Units No.
Units No.
52
34 Units No. 2
Units No. 2-l/2_
27 Units No. 3
Units No. 3-l/2_
7 Units No. 4
Units No. 4-l/2_
7 Units No. 5
68
81
28
35
140 Total Units
Total Equiv. No. 1 Units
264
Aver. Smoke Density •
Equiv. No. 1 Units X 20t
Total Units
. 22!
Remarks:
Violation Notice Issued
Source location S.W. Corner of Premises
Address 434 So. Faloma Street
\5ec.
H1n7\^
0
1
2
3
4
5
6
7
8
9
10
Hi
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
0
--
__
.-
1
1
2
2
3
2
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—
--
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—
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--
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2
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4
5
4
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15
.-
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2
3
4
5
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45
--
,_
.-
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1
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2
2
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4
5
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1
1
vSec.
Mi>x^
30
31
32
33
34
35
36
37
38
39
40
41
12
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
0
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1
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-_
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45
1
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1
-_
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2
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2
1
1
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--
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—
—
—
--
--
Figure 4.3. PLUME OBSERVATION RECORD FORM
(SOURCE: ROM, Reference 6)
-------
4.28
E. Smoke Reading School
With these principles clearly and legally established, it is now
possible to train personnel 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 1/2 Ringelmann or 10 percent
opacity in a significant number of readings during both the hours
of light and darkness and from any given view of the emission.
1. Smoke Generating Equipment
In the design of smoke generating equipment, attention is
given to a means of regulating air fuel ratios, to preventing
horizontal distortion of the smoke plume through the action of
wind and to make accurate determination of the actual smoke
density or opacity being observed by trainees.
The systems now utilized consist of 2 smoke generating units,
each with a vertical stack and a density or opacity detection
system (see Figures 4. 4 and 4- 5).
(1) Black Smoke System
Black smoke may be created by incomplete combustion
of fuel oil or other liquid fuels; benzene is espe-
cially suitable for the purpose. The combustion
chamber may consist of a steel box, perhaps 10 to 50
cubic feet in volume, lined with firebrick. Smoke
density is varied by adjusting fuel flow rates, using
a constant air supply rate. The combustion products
are ducted to a cooling chamber, thence to the
vertical stack from which the plume emerges. A
forced-draft fan supplies dilution air at the base
of the stack, providing adequate plume exit velocity
to prevent excessive distortion by air currents.
-------
DENSITY DETECTION SYSTEM
STACK —»•
12" Diameter x 16' High
OIL BURNER
COMBUSTION CHAMBER
43" x 43" x 61" OD
COOLING
CHAMBER
300 Watt
Proj. Lamp
AIR 25 CFM
Weston
5 Phototronic
Cell
AIR SUPPLY TUBE
*-
•o
Figure 4.4. DESIGN OF BLACK SMODE GENERA.TOR
(SOURCE: WEISBURD, Reference 3)
-------
OPACITY DETECTION SYSTEM.
OIL PRESSURE GAUGE
MANUAL OIL CONTROL VALVE
STACK
12" Diameter x 16' High
OIL SPRAY NOZZLES
SUPPLY LINE
OIL SUPPLY PRESSURE PUMP
DILUTION AIR
VAPORIZING CHAMBER
VAPORIZATION
" HOT PLATE"
HEATING CHAMBER
DISTILLATE OIL BURNER
I
AIR DILUTION FAN
1200 CFM
COMBUSTION GAS VENT
- REFRACTORY LINING
U)
o
Figure 4.5. DESIGN OF WHITE SMOKE GENERATOR
CSOURCE: WEISBURD, Reference 3)
-------
4.31
(2) White Smoke System
White smoke may be created by vaporizing a light
distillate oil, such as number 2 fuel oil, and
diluting it with air. The opacity is varied by
adjusting the rate of supply of oil through a spray
nozzle to the heated vaporization chamber, which may
be, for example, an exhaust manifold of a gasoline
engine. Again, dilution air maintains the necessary
stack velocity.
(3) The Transmissometer System
The transmissometer, or opacity meter, consists of a
simple light source and photocell combination, to
measure the light transmission permitted by the par-
ticular smoke being produced. The percent trans-
mission is read from a scale calibrated from 0 to
No. 5 Ringelmann and 0 to 100 percent equivalent
opacity. The light to photo-cell path is approx-
imately 4 feet in length, but only 1 foot of
length is exposed to the smoke. The remaining 3
feet are continually flushed with ambient air to
prevent smoke buildup. The apparatus may,be
calibrated using neutral density filters.
2. Training Procedure
Training in plume evaluation begins with the familiarization
of the personnel with known densities of black and white smoke.
Trainees are positioned at a reasonable distance from the
plume—say, 50 feet. On signal, they observe the plume and
are simultaneously or subsequently informed as to its opacity,
as measured by the transmissometer. Variations in lighting
and background color are introduced during such training runs,
as familiarity with these effects may be critical to the
accurate estimation of opacity.
-------
4.32
In testing trainees for proficiency in plume evaluation,
they are required to record (Figure 4. 6) a series of
readings, on signal, for comparison with unannounced trans-
missometer readings. The records are then evaluated by deter-
mining the average relative deviation of the trainee's readings
from the true values. Satisfactory performance criteria, used
by the Los Angeles County Air Pollution Control District,
include an average deviation not exceeding 10 percent, with
no individual deviations greater than 1 Ringelmann number
(20 percent opacity).
Additional training is necessary if the trainee does not
meet these standards. Analysis of the proficiency record may
indicate whether the trainee is guessing and whether his
readings are consistently too high or too low.
F. Reading Smoke in the Field
On the basis of the training given in the smoke school, and the
accepted methods by which visual determinations are made, the
(3)
following general rules apply to sight-reading in the field.
(See Figures 4-7, 4.8 and 4.9.)
1. 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.
-------
A.33
ENVIRONMENTAL PROTECTION AGENCY
1.
2.
3.
4.
5.
6.
name of Observer j0h.n
Affiliation Onyx State
Date June 15. 1972
Wind Speed 4 MPH
Observers Position 40'
Fitch
Department
Direction
of Environmental Control
Time
s.w.
8:00 A.M.
Sky Condition
Cloudy
South of Stack
Corrected By Robert Brandon
(Record Black of Gray Smoke 1n Rlngelmann No. 1/4 Unit Smallest Division)
(Record All Other Smoke 1n 1 Opacity - 5Z Smallest Division)
RUN NO. 1 B
o
z
I
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1
1
2
i
4
5
6
7
8
9
10
11
12
i_
0) -O
wi to
.a v
o a;
2
t V2
3
1 J4
1/2
V4
1
2
3
3 i/<
4
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ometer
9
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10
10
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t
s Dt
us C
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tlon
is 2
O
z
T3
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13
14
15
16
17
18
19
20
21
22
23
24
25
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10
5
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--
c
o
aj
o
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5
10
10
10
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-o
a>
C£
13
14
15
16
17
18
19
20
21
22
23
24
25
u
ttJ -O
n
Sum of Plus Deviations
a>
••- TJ
i/i aj
c az
10
41
^
?">
15
5
25
35
15
55
65
75
85
70
No. of Plus Deviations
Sum of Minus Deviations
No. of Minus Deviations
jf Plus Deviations) + (Sum of Minus Deviations)
Total No. of Readings
Ot Deviation and Duo-
c
o
-------
4.34
Figure 4.7. LIGHT SOURCE SHOULD EMANATE FROM THE REAR OF OBSERVER
DURING DAYLIGHT HOURS (REFLECTED LIGHT)
(SOURCE: Weisburd, Reference 3)
Figure 4.8. DURING DARKNESS, THE LIGHT SOURCE SHOULD EMANATE FROM BEHIND
THE PLUME, OPPOSITE THE OBSERVER (TRANSMITTED LIGHT)
(SOURCE: Weisburd, Reference 3)
Figure 4.9. READINGS SHOULD BE MADE AT RIGHT ANGLES TO WIND DIRECTION AND FROM ANY
DISTANCE NECESSARY TO OBTAIN A CLEAR VIEW OF STACK AND BACKGROUND
(SOURCE: Weisburd, Reference 3)
-------
4.35
(3) All opacity readings are related to corresponding
densities on the Ringelmann Chart in the following
manner:
RINGELMANN OPACITY
//I 20%
#2 40%
#2 1/2 50%
#3 60%
#3 1/2 70%
#4 80%
#4 1/2 90%
#5 100%
(4) Light source should be from rear of observer during
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.
(7) An inspector should not study the plume as this will
soon produce fatigue and cause erroneous readings.
Instead, he should glance at the plume and record
his observation immediately, looking away from the
plume between readings.
2. 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 minutes
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 the emissions exceed
the regulation.
-------
4.36
(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 the legally
specified time limit in any 1 hour. Continuing
emissions should be recorded for at least 6 minutes
of violation.
(8) Any 1 hour means any period of 60 consecutive
minutes.
(9) Photographs should be taken before or after but not
during visual determinations.
3. 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 pur-
suing a vehicle, however, should avoid reading
directly into the plume, if possible. The 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) A stop watch should be used to record accumulated
violation time.
IV. COLLECTING EVIDENCE
Much of the time spent by field enforcement personnel will be in the
collection and reporting of data and evidence. In fact, most of the
data collected by such personnel are of an evidentiary nature. Whether
such data are used in an emission inventory or in the prosecution of a
violation, they will consist for the most part of facts and findings
acquired through direct observation. They should be stated in such a manner
as to be clear, concise and free of prejudices and other subjective factors.
-------
4.37
The data collected by an enforcement officer is written down on a report
form. This report will be filed with, and used by, the enforcement
agency, but is not usually submitted as evidence in any possible legal
action. Should a field enforcement officer testify in court to the
facts obtained by his observations and inspections, he will be examined
directly, but may use his written report to refresh his memory. This
type of evidence is designated as testimonial evidence. Physical
evidence such as photographs, recorder charts, samples of fuel submitted
and damaged materials may also be used.
A. Establishing the Prima Facie Case
To provide sufficient basis for court prosecution in a criminal case
(such as where misdemeanor penalties are to be invoked) each and all
the elements of the crime (in legal terminology, the corpus delicti)
must be proved. To do so the enforcement office or other principal
witnesses must gather the evidence for a prima facie case, i.e.,
a case which on the face of it shows guilt and which, unless rebutted,
adds up to the commission of a violation of a rule or regulation.
In a criminal court case the burden of proof of rebuttal is placed
on the defendant after presentation of such evidence by the
plaintiff (usually the people of the state).
Thus, if the rule alleged to have been violated is the prohibition
that "a person shall not discharge into the atmosphere from any single
source....any air contaminant" of any particular quality or quantity
for more than the maximum permissible 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 single element is missing (for example, it was not a single
source), the corpus delicti is not established and there is no case.
-------
4.38
B. Documentation of Evidence
The evidence required in court in order to establish a violation should
be documented in carefully prepared reports. The information most
commonly required is as follows:
• The nature and extent of the violation.
• The time and location of the violation.
• The person(s) responsible for the violation.
• The equipment involved with the violation.
• The operational, design or maintenance factors which caused
the violation.
Further detail on each of these elements is treated below:
1. The Nature and Extent of the Violation
This element requires that the field enforcement officer
determine the exact rule which has been violated. He must
be familiar with all the rules he may be called upon to
enforce in the field. This discussion is concerned largely
with violations which are due to excessive emissions (all
maximum permissible emission standards, including public
nuisance).
The severity or extent of the violation must be determined before
a violation of an emission standard 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 phrasing of the prohibition in the rule.
Most rules stipulate a single standard of compliance. The "extent"
in a smoke or opacity violation, for example, is measured in terms
-------
4.39
of the Ringelmann standard. In a violation relating to unauthorized
construction of equipment, the extent is determined according to
the date construction took place and the degree of completion.
The fact that a violation is observed must be accompanied, in
the report, by the methods used to measure the extent of the
violation. The procedures used in making visual determinations
must be accurately recorded. For example, in the case of a smoke
or opacity violation, the following data are required to confirm
accurate use of the approved smoke reading method:
• Point of observation from source.
• Weather conditions during observation.
• Wind direction.
• Visible emissions observed showing continuous time intervals
for each opacity and density, color change and total
violation time in minutes.
• Status of plume at end of the recorded observation.
The Time and Location of the Violation
The exact date and time the violation occurred are a necessary
element. The time of violation is generally noted in terms of
(1) the time the field enforcement officer arrived to investigate
the violation and the time he departed from the scene and (2) the
specific time interval(s) of the violation.
The location is the actual address at which the violation was
observed. 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, (e.g., 105 Martin Ave., 2510 Burton Rd.,
1010 So, Western Blvd.).
-------
4.40
The city or community name must be that of the post office de-
livering mail to the location. Should the location of the
violation be in unincorporated territory, the post office or
other legal designation must be used.
3. The Persons Responsible for_the Violation
The "persons" include all individuals responsible for the equip-
ment by reason of legal operations and the individuals who may
be responsible for the specific act which resulted in the
violation. The persons associated with the violation will con-
sist of the owners of the company and the employees immediately
responsible. Court action in most cases is filed against the
owners and sometimes against both the owners and the employees
immediately responsible for the operation of the equipment, de-
pending on the circumstances. In all investigations of
violations, the field enforcement officer must report the name
of the company, its form of ownership (company, partnership,
individual, corporation, etc.), the highest authority 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.
4. The Equipment
The cause of the violation may often times be ascertained from the
physical inspection of the source of emission or the equipment in-
volved in the violation. The first important 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
-------
4.41
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 enforcement officer observes plant conditions closely
for those operating cycles which result in excessive emissions.
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 identi-
fication 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 generation 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.
• The number of equipment units taken as the single source.
• The function or application of the equipment.
• 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 identification.
• Size, charge or feed capacity of equipment, if these are
pertinent.
• The commercial name of the equipment and the manufacturer's
serial number, if any.
• Plant's equipment location number or relative or approxi-
mate location of equipment within the plant.
• Important equipment appurtenances which would qualify its
permit status, such as type of heating element, blower
-------
4.42
motors, etc., together with manufacturer's name and serial
number.
• Other equipment serving or served by the equipment identified
as the source.
• Description, manufacturer's name and serial numbers of all
control equipment involved.
Examples of four types of source descriptions are shown below,
based on the guide points listed above:
• One (1), horizontal return type, Smith Iron Works, Serial
No. 2345, eastmost of two boilers, served by 2 Ray Rotary
Cup oil burners, Serial Nos. 2000-1, 2000-2. Both boilers
are breeched to a common 4-foot diameter x 30-foot high
stack. Westmost boiler not in operation at this time.
• One(l), open fire, 5 feet diameter x 3 feet high, con-
sisting of eucalyptus tree cuttings, tar paper, creosoted
lumber, rubber tires, oil rig timbers and paint cans.
• Three (3), 350-pound, yellow brass, hydraulic tilt,
melting furnaces, venting directly through one roof
monitor, 20 feet long x 3 feet wide. Melt contains 14
percent zinc, poured at 2200°F. All furnaces in full
operation at this time.
• One (1), local blower exhaust system, XYZ Pipe, ductwork,
24 inches diameter, 15 HP blower capacity, served by one
3-foot diameter cyclone, and serving 4 belt sanders,
1 sticker, 1 tenoner, 2 planers and 1 cross-cut saw. Only
the belt sanders were in operation at this time.
Although the descriptions of the hundreds of different types of
equipment vary considerably, the above 4 examples are sufficiently
typical to illustrate the elements necessary in the proper
-------
4.43
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 characteristics which
affect the air pollution problem. The notations 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 3 furnaces were in operation at the time of observation is
included. The findings may also include observations of emissions
within the plant. In the last example, 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. Similarly, in the first example the source is
tied to 1 of 2 boilers, the eastmost, both breeched to 1 stack,
since the westmost boiler, presumably used for standby purposes,
was not in operation at the time of the inspection.
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 sufficient. For example, in the
case of excessive smoke (the second example), the fact that an
open fire was conducted is in itself a violation of open burning
restrictions. In these cases, that aspect of cause which re-
lates to intent and responsibility of persons who ordered and
lit the fire are most important.
In more complex cases, however, a more detailed explanation may
be necessary. In refinery operations, for instance, schematics
-------
4.44
of flow processes and material flow with notations of vapor
pressure and temperature, etc., are drawn to locate and estimate
the possible losses of vapors and gases. In still other cases,
the enforcement officer indicates, where appropriate, whether
or not combustion equipment is operated at too high or too low 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 are
firing.
The enforcement officer checks the equipment and determines by
interview and observation the actual conditions 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 statements made by the plant operator under interview, such
as declarations regarding equipment failure, maladjustment,
poor maintenance and variation in operating procedures. The
causes which enter into each of the categories of violation,
of course, vary.
C. Types of Evidence
The types of evidence used in court cases or administrative hearings
include: (1) testimonial evidence, that is direct testimony by
witnesses, (2) demonstrative evidence, or physical evidence used to
support the testimonial evidence, and (3) evidence presented by
expert witnesses.
The enforcement officer will be most concerned with the presentation
of testimonial evidence as to observations made directly by him.
Typical examples would include observations made on visible emissions,
on odors, on presence or status of construction, on items of equipment,
-------
4.45
on process or operational conditions and on conditions under which
he secured certain samples, such as fuel oil. He will often
testify as to statements made directly to him by operators of equip-
ment and plant owners, or by complainants. He may also testify on
such external factors as atmospheric and weather conditions, in-
cluding temperature, relative humidity, sky condition, visibility,
lighting, and wind speed and direction. In some cases he will be
called upon to interpret demonstrative evidence such as photographs.
Testimonial evidence will also often be given by laboratory personnel
reporting on pertinent tests that they have conducted.
Demonstrative evidence is almost any physical evidence used to
support direct testimony. It may include damaged property or
vegetation, samples of fuel or process materials, records of
analyses and photographs. In many cases this type of evidence needs
description or interpretation by an expert.
Damaged materials or vegetation samples may often be brought
directly into a courtroom, provided the specimen is small enough to
be transported or the damage pattern is not altered or disturbed.
In some cases, test specimens may be placed in a preplanned pattern
around the suspected source and retrieved for laboratory examination
after a suitable time for exposure. These specimens could include
test fabrics of differing materials and dyestuff, metal plates and
greased glass slides or plates. In some cases the damage pattern may
be apparent to even the casual observer such as a gross deposit of
a material readily identified by eye. Most often, however, testimony
of an expert witness will be required. In some cases supplementary
evidence such as photomicrographs and laboratory analyses will be
necessary.
-------
4.46
Test data may include reports of source analyses, ambient sampling
conducted in the vicinity of a source and on materials charged to
the process in question. Source tests may range from rather simple
tests for solid particulates at the process discharge to complex
multi-point sampling for a variety of particulates, gaseous con-
taminants and ancillary data such as flue gas composition, temperature
and moisture content. Environmental sampling data collected in the
vicinity of a source may include reports of analyses from manually
operated sampling devices or recorder charts from continuous
analyzers. Recorder chart data which can be correlated with the
time of complaints and with meteorological data, such as wind speed
and direction and atmospheric stability, can be very useful.
Analyses conducted on process materials or fuels might include
sulfur and ash content of fuels, metal charge composition, particle
size distributions and composition of incinerator feed.
Photographic evidence is usually used to give a graphic illustration
of descriptions presented in direct testimony. Examples might in-
clude still or motion pictures of visible stack effluents; photographs
showing the construction status of equipment, illustrating the con-
dition of control equipment, or showing the effectiveness of fume
hood pickup; pictures of damaged materials, and photomicrographs
of finely divided particulate matter.
V. COMPLAINT HANDLING
Complaints against general air pollution conditions or specific sources
of air pollution are either reported to field personnel, reported in
correspondence or phoned into the air pollution control agency. Com-
plaints are frequently communicated by phone at or near the time of some
kind of air pollution incident or episode.
-------
4.47
A. Receiving the Complaint
The switchboard operator of the agency determines whether the com-
plaint is concerned with a specific source or with general smog
conditions. It it is the former, the call is forwarded to the
appropriate member of the enforcement staff or to a dispatch center.
The names and addresses of the source and the complainant are
noted on a message log (Figure 4-;10). The validity of the
complaint as well as the nature of the problem are deter-
mined. In some instances, it is unnecessary to dispatch
an enforcement officer since the location may already be
under investigation. In other cases the source may already have
been reported by the enforcement officer in the field.
If enough facts are obtained to dispatch the enforcement officer
either to a specific source location or to the complainant, in-
vestigation is warranted.
After the message log is completed, a complaint number is assigned,
the time is stamped on the log and a field enforcement officer is
dispatched immediately to the scene. Complaints are investigated
as speedily as possible to ensure that the reported source may be
reached while the violation or nuisance is still in progress.
B, Complaint Investigation
Upon arrival in the vicinity, the enforcement officer first observes
the alleged source to determine if a violation is involved. If a
violation is observed, he investigates, writes and serves a notice,
if warranted. Then he visits the complainant. However, if no
violation is immediately apparent, the complainant is contacted.
-------
TIME RECEIVED
1972 JAM 2.O PlVl
1 o-
REC'D. FROM: Jl- v/ *C
930 vX 931
DO NOT CONTACT
961 -SMOKE
962-OPEN FIRE
963-ODORS
96^-DUST
967- BREAKDOWN
968-REPORT TO COURT
969-REPORT TO H.BD.
980-CAR SERV CE
TEN 19-COME TO HDORS.
TEN 21 -TELE. HDORS.
JEN .88- TELE. NUMBER?
JEN 91-ROLL CALL CHG.
CODE:
?_
\/
Air Pollution Control District— County of L°s Angeles T|>
Enforcement Division
RADIOPHONE MESSAGE LOG
ASSIGNED TO: P-2~7 OPR. ^
SOURCE: ALWE^i '~Bi=NlD<=-£_lr4cS C^oV
ADDRESS: 1 i~) N)D, /-\L_\\/£cSi ^— Vfet2-r^)o^l
COMPLAINANT: |4e:kM2.y ^>MIT)4
ADDRESS:*? ?.l N! O, A <- \VtE~cSi ^T. Ve£.^Oi\i
ADDITIONAL INFORMATION:
z_oivc^ o JQ - . ^_ ^^_
trM^'-^Vc- es t4 D
\4o^^ •
TE»< 98 - COMPLAINT NO:
SOURCE: A^NN'6^. ~E-'=MDt IZitv'G <- -7 Z
• t— m
§ rxj ^
- i^3
s iA»
'> _ -\D g
O >
*-
CX3
Figure 4.10. EXAMPLE OF RADIOPHONE MESSAGE LOG
-------
4.49
The enforcement officer makes every effort possible to avoid obvious
identification of the complainant. He is particularly 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
identities of all complainants should be considered to be confidential
and should not be disclosed to anyone who is not an employee of the
enforcement agency.
If the complainant is not at home the enforcement officer should
leave a message. If the complainant is at home, the enforcement
officer identifies himself by name and agency in a friendly manner,
and proceeds with the interview.
The enforcement officer is friendly, but dispassionate. He generally
employs a "non-directive11 interview technique in that he allows
the complainant to get the matter off his chest so that the facts
of the situation can be calmly discussed. He should also appreciate
the fact that a person who is angry may be honestly motivated by a
serious or chronic air pollution condition.
In permitting the complainant to speak his mind, it is well for the
enforcement officer not to interrupt. It is particularly effective,
however, that when facts appear the officer repeats them aloud for
verification and then jots them down.
After the complainant has expressed himself, the enforcement officer
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 supplied
by the complainant.
-------
4.50
The cause of the complaint may not always involve air pollution.
Although most complaints are justified, some will concern problems
over which the 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 low
concentrations of contaminants which may affect illness or allergy
in an individual. Although the enforcement officer may have no
legal powers in such cases, he thoroughly investigates and attempts
to correct all air pollution problems. If such complaints are un-
substantiated, he 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 order to obtain the necessary data, the following should be
obtained:
(1) Name and location of source complained of.
(2) Frequency of annoyance or occurrence 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.
-------
4.51
In an air pollution problem which appears to involve toxicity, the
enforcement officer records 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 appear serious, a physician and the health authorities
should be contacted. The enforcement 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.
It should be noted that only a physician can make a diagnosis. The
enforcement officer records reported symptoms in his report. The
enforcement officer can note the name of the physician conducting
the diagnosis and treatment. This information is important if public
nuisance action should be initiated.
While interviewing complainants, the enforcement officer does not
promise legal action nor does he commit himself 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 cooperation on the part of those who may be
responsible.
If odors, soiling or other property effects are involved, the
enforcement officer examines the citizen's property. 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,
-------
4.52
the wind direction can be determined for the purpose of tracing the
odor to its source.
As a rule, enforcement officers do not solicit opinion in a neighbor-
hood regarding the behavior of any plant, but confine themselves to
those persons volunteering complaints. It is usually citizens who
do the canvassing and who supply the information. The enforcement
officer may then interview all complainants involved. The canvassing
of complainants is usually discouraged. The enforcement officer
does not sample, nor act on, opinion, but on sincerely motivated
complaints. The canvassing of the neighborhood can be construed in
a court of law as being prejudicial to the plant.
The enforcement officer, on the basis of his knowledge of air
pollution, however, evaluates the consistency, correspondence and
intensity of remarks made by possible witnesses. He attempts to
find some degree of unanimity regarding the objectionability of the
problem among those who might be equally affected. Diverse opinions
and inconsistencies are first signs that a public nuisance case may
not be easily developed.
C. Inspection of the Source
From the facts gathered so far, the enforcement officer may have a
notion of the specific or type of source responsible, especially
if he has identified contaminants and has observed 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. In still other cases, the contaminant may be
completely unknown.
-------
4.53
To establish a public nuisance, a source within a certain facility
responsible for the offending emission must be proved. In some
cases, the equipment involved 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, each piece of equip-
ment must bfi inspected in detail. Those which do not contribute to
the problem are eliminated from consideration.
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 unpermitted 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 Regula-
tions, a public nuisance will have to be proven.
When the enforcement officer contacts the plant operator, he ex-
plains that he is investigating a complaint, unless, in the individual
instance it should be strategic not to do so. The enforcement
officer 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 enforcement officer is
not yet committed to any action. As with the complainant, he 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 times of operation with the
times and frequencies of complaints.
-------
4.54
1. Mediation
Because the enforcement officer is an indifferent observer between
2 parties in conflict, he has a natural tendency to act as
mediator and will attempt to find that solution to a problem
which will satisfy both the complainant and the operator. For
example, if the complaint is made of an operation conducted in
the evening when the complainant is at home, the operator may
agree to shift the operation to a daytime schedule. The company
may also agree to relocate equipment, 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," if these acts do not involve violations of the
rules and regulations. It is important, however, that such
agreements do not compromise the law. The enforcement officer
does not agree to a maintenance of a violation.
2. Nuisance Action
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 problem 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 "consider-
able number of persons'1 or a reasonable cross-section of the immedi-
ate community affected is handled as an enforcement action.
-------
4.55
Once the enforcement officer determines that a public nuisance
is involved, he must assume an attitude of objective 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 con-
flict in equities which may only be resolved in court. The
burden of proving the public nuisance ultimately rests on the
testimony of the complainants themselves. The enforcement
officer is also a witness in that he can, in his opinion, verify
the existence of the nuisance.
The appropriate legal forms are completed and signed by the
complainants in their own handwriting. These documents, together
with enforcement officer's findings, may be filed as a violation
in the courts to test whether or not a public nuisance exists.
VI. FIELD EVALUATION AND ENFORCEMENT EQUIPMENT
In the process of evaluating air pollution problems in the field, field
enforcement officers can be most effective when aided by various types
of equipment, as described below.
A. Mobility and Personal Protection
The first requirement for mobility is an automobile. Enforcement
vehicles should be equipped with 2-way radio communication.
Control agencies should have the capability to respond to emergencies
Some agencies use vehicles equipped as emergency vehicles including
sirens and flashing lights. Other agencies seek cooperation from
fire and police departments.
-------
4.56
Under routine conditions, the automobile serves to transport the
enforcement officer and his equipment quickly to any routine or
special assignment.
Personal protection is necessary in many of the industrial locations
an enforcement officer may be required to visit. Although many
industrial firms are prepared to provide such equipment for
visitors on request, much time may often be saved by equipping each
enforcement officer with permanently issued items such as safety
hats, safety glasses or goggles, steel-toe shoes, ear plugs for
sound attenuation, heavy gloves and gas masks or canister-type
respirators.
B. Facilitating, Verifying or Recording Observations
For assistance in gathering evidence in the field, it is useful
to have an inspection kit which includes the following items: camera,
binoculars, stop watch, flashlight, maps, compass, smoke tube, re-
quired forms and miscellaneous accessories.
Cameras are used primarily to photograph excessive emissions from
stacks and vehicles and to photograph equipment and operating
personnel for identification purposes. Cameras which permit rapid
development of photographs at the site of an investigation are
especially useful. Moving picture cameras may be desirable for
special investigations.
Stopwatches should be of the accumulative type for use in recording
total time of excessive emissions within a given period of
observation.
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4.57
C. Assessment of Weather Conditions a.nd Measuring Ambient Air Flow
Data relevant to determining the speed and direction of dispersion
of contaminants in the atmosphere include temperature, humidity,
wind speed and wind direction. Such measurements are continuously
provided at weather observing stations, but may be required at other
locations during special investigations.
Equipment suitable for such purposes includes various types of
thermometers; some psychrometers, especially the "sling psychrometer;"
and various anemometers or "wind gauges." Such equipment has recently
been discussed in detail by Hewson. For measuring surface wind
speeds, rotation anemometers are most satisfactory, on the whole;
a particularly convenient type is the totalizing cup anemometer, in
which the passage of each 1/10 or 1/60 mile of wind and each 1 mile
of wind past the instrument is counted and recorded. Other
anemometers are based on the use of pitot tubes or vanes to register
pressure differences caused by wind, and on the use of electrically
heated elements which are cooled by wind. Such devices are likely
to prove more convenient for measuring air flow in controlled systems,
such as ducts and exhaust hoods than for the open atmosphere.
D. Measurement: of Process Air Stream Flow
For checking flow in exhaust systems, air velocities are determined
by instruments similar to those described above, but usually without
orienting vanes. Careful determination of velocities in ducts
requires the use of a pitot tube, with a considerable degree of
(81
engineering expertise. A standard pitot tube (Figure 4.11) con-
sists of 2 concentric tubes: the inner tube measures the impact
pressure, which is the sum of the static and kinetic pressures,
while the outer tube measures only the static pressure. When the
-------
4.58
IMPACT PRESSURE CONNECTION
TUBING ADAPTER /
STAINLESS STEEL TUBING ^T ^STANDARD BELL REDUCERS
/STATIC PRESSURE CONNECTION
_STATIC PRESSURE HOLES STAINLESS STEEL PIPE NIPPLES
OUTER PIPE ONLY
IMPACT PRESSURE OPENING
Figure 4.11. STANDARD PITOT TUBE (WESTERN PRECIPITATION,
DIVISION OF JOY MANUFACTURING CO., LOS ANGELES,
CALIF., FROM ASHRAE GUIDE AND DATA BOOK, 1963)
(SOURCE: D'Imperio, Reference 8)
Two tubes are connected across a U-tube manometer or other suitable
pressure-measuring device, the static pressure is nullified
automatically and only the velocity pressure (kinetic pressure) is
registered. The velocity is correlated to the velocity pressure
by the equation:
h
1096.5 J p
where
v = velocity, fpm
hv = velocity pressure (manometer reading), in WC
P = density of air, lb/ft3
-------
4.59
Clearly, below 1,266 fpm, the velocity pressure becomes extremely low
and is, therefore, difficult to read accurately on a manometer. With
a U-tube manometer, the accuracy is low for velocities below 2,500
fpm. With a carefully made, accurately leveled, inclined manometer,
velocities as low as 600 fpm can be determined satisfactorily, but
field conditions ordinarily make this procedure difficult (ASHRAE
Guide and Data Book, 1963). A more convenient velocity meter, incor-
porating a swinging-vane pressure indicator, is described in detail
/Q \
by D'Imperio. The factors that make the swinging-vane velocity
meter an extensively used field instrument are its portability,
instantaneous reading features and wide-range scale. The instrument
is fairly rugged and its accuracy is suitable for most field velocity
determinations.
The meter consists of a pivoted vane enclosed in a case, against which
air exerts a pressure as it passes through the instrument from an up-
stream to a downstream opening; movement of the vane is resisted by a
hair spring and damping magnet. The instrument gives instantaneous
readings of directional velocities on the indicating scale.
Sampling Contaminants in Ambient Air and Process Streams
Estimates of pollutants are made in the field by means of commercially
available portable test devices. Table 4.1 lists some gaseous air
(3)
pollutants which can be easily detected by means of these devices.
The devices shown are among the numerous ones on the market today.
"Grab samples" are often obtained by filling gas sampling tubes or
inert plastic bags with air by means of motor or hand-powered pumps.
The collected air sample is analyzed in the laboratory.
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Table 4.1. CONTAMINANTS WHICH CAN BE TESTED IN THE FIELD WITH PORTABLE DEVICES
r-nxTT- A Tv/rrM- A XTT- REASON FOR TESTING REAGENT OR
CONTAMINAN 1 OR SOURCE TEST EQUIPMENT USED
Aldehydes
Ammonia
Eye Irritation
Complaints
Odor Complaints
Aromatic Hydrocarbons
1. Benzene Odor Complaints
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
a. Prepare
b. Test or
Odor Complaints
Plating Operations
Exhaust Complaints
Exhaust Complaints
Cylinder Loading &
Bleach Mfg.
Venting Storage Tanks
Odor Complaints
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
ition in minutes
Sampling
Absorption in Sodium
Bisulfite
M.S.A. Midget Impinger
Red Litmus & Stop Watch
M.S.A. Aromatic Hy-
drocarbon Detector
M.S.A.Arsine
Detector
Fyrite CO., Analyzer
M.S.A. CO Detector
0-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
TREATMENT OR TIME REQUIRED CONCENTRATION EIGHT-HOUR" 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
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
Change 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
- 1000 ppm
- 1 00 ppm
0- 100 ppm
0 - 400 ppm
0- 400 ppm
Qualitative
0
0
0
0
0
0
.5
0
0
0
0
1
1
- 100 ppm
• 20%
• 1000 ppm
70 ppm
- 20 x LEL
- 50 ppm
5 ppm
50 ppm
10 ppm
- 100 ppm
- 21%
• 1 00 ppm
1 0 ppm
1 - 150 ppm
O- loot) ppm
50 Grains /ft3
.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%
Ippm
Spphm
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. Calculation and Interpretation
d. Laboratory Analysis
*•
o
(SOURCE: Weisburd, Reference 3)
-------
4.61
Absorption techniques are available whereby quantitative estimation
of gaseous pollutants can be made easily by using bubblers and
reading with photometer or pH meters.
Systems used for the collection of particulate contaminants include
sedimentation and settling devices, such as fallout jars and gummed
paper stands, miniature cyclone collectors, blower and filter
systems, impingers and impactors, electrostatic samplers and thermal
precipitators. It is becoming more important to obtain size-
discriminating samplers in place of total mass samplers.
The sampling of gaseous contaminants involves separating them from the
air in which they are entrained. Such techniques are adapted either
to the sampling of specific gaseous compounds or to the determination
of gross total concentrations of gaseous contaminants. Specific
methods are available for sampling for many inorganic gases and some
reactive organic compounds. In most cases these methods involve
absorption by bubbling the air through a reactive liquid agent. Mixed
gases are usually trapped by adsorption or freezeout techniques. In
any event an appropriate sampling train must be devised, usually
augmented by a suction pump and a meter (either a wet or a dry gas
meter).
For sampling of liquid fuels, as may be required in order to enforce
fuel composition regulations, special containers approved for flammable
liquids may be required. Fuel oils of low volatility can be collected
in quart or half-gallon tins.
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4.62
F. Equipment for On-the-Spot Testing
At times, the enforcement officer will be called upon to make quick,
and sometimes crucial, estimates of air pollution problems in any
environment. While he cannot make accurate determinations of concentra-
tion on the basis of sense perceptions only, he may be able to identify
pollutants, allow for hazardous concentrations and trace them to a
logical source. In order to eliminate guesswork and to establish
identity and concentration 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 be
substantially accurate.
In a petroleum refinery surveillance program, on-the-spot testing may
be conducted by teams manning specially equipped emergency test vehi-
cles. Radio-equipped automobiles are especially useful in tracing
and identifying transient emission sources which may be otherwise
difficult to locate. A noxious or malodorous gas may originate 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 prepared 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 labor-
atory analysis are aldehydes, ammonia, aromatic hydrocarbons (benzene,
toluene, styrene, xylene) atomic radiation, carbon dioxide,
carbon monoxide, chlorine, combustible gases and vapors, organic
halides, humidity, hydrogen cyanide, hydrogen sulfide, mercaptans,
oxygen (deficiency) and sulfur dioxide.
-------
4.63
Operation of such equipment is beyond the scope of this manual.
Instructional manuals are issued with the equipment on purchase.
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 4. 1. This equipment includes
the following:
(1) Test Papers
Certain types of simple sensitized papers will change
color in the presence of physiologically significant
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, ammonia reacts with
litmus to produce a red to blue color change. Concen-
trations of ammonia from 0 to 1,000 ppm can be detected
by this method. Similarly, hydrogen sulfide may be
detected with lead acetate, phosgene with diphenylamine,
etc.
(2) Squeeze Bulbs and Ampules
These generally consist of 2- or 3-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 are the mine safety appliance gas
testers constructed for specific contaminants, as shown
in appropriate places in Table 4.1.
(3) Tutweiler Apparatus
This apparatus is used to determine concentrations above
150 ppm of hydrogen sulfide, sulfur dioxide, 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
-------
4.64
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.
(4) Reich's Test
This test is performed specifically to make volumetric
determinations of S0_ 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 percent of SO- in 1000 ml. of air is used in the
solution, providing a calibration point.
(5) 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" x 5"
hand-operated pump, as in the case of the M.S.A. midget
impinger. These employ the impingement principles
described earlier in this chapter. The samples collected
are analyzed in the field.
(6) Halide Leak Detector
This equipment is used for the determination of the con-
centration of halogenated hydrocarbon vapors such as
Freon, carbon tetrachloride, trichlorethylene and per-
chlorethylene. It consists of a small LPG fuel tank
fitted with a microburner that has a copper ring reaction
plate above the flame tip. A rubber tube sampling line
feeds the contaminated 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 estimate
the concentration.
(7) Measurement of Volume Change
These include principally the Fyrite CO and 0 analyzers
shown in Table 4.1. Carbon dioxide is measured by the
volume change resulting from absorption in caustic and
oxygen by absorption in pyrogallic acid.
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4.65
(8) Exglosimeters 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 metal tube
probe is connected to the portable meter by a length of
rubber tubing. The meter is operated on self-contained
batteries and uses a squeeze bulb to aspirate samples
through the reaction chamber.
(9) Geiger Counters and Ion Chambers
These are for use in radiological monitoring in the field
in the event of disaster. In some agencies enforcement
personnel are trained to use them, and vehicles are
equipped with them, pursuant to responsibilities assigned
to the agency for civil defense and disaster preparedness
programs.
G. Fuel Sampling
In some instances it is desirable to sample and test liquid, solid
or gaseous fuels in the field, particularly to test compliance
with fuel composition regulations. Such rules may, for example,
limit the sulfur and ash content of solid and liquid fuels, the
sulfur content of gaseous fuels, including refinery make-gas, and
lead content and olefin content in, and organic vapors from,
petroleum products and gasoline and other motor vehicle fuels to
be marketed in the community. Some instances of field testing are
as follows:
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4.66
1. Gaseous Fuel
To determine compliance with such rules regarding gaseous fuels
two separate tests are required: (1) determination of heat value
(Btu) and (2) determination of sulfur loading.
Two types of refinery gas fuels will require the enforcement officer's
attention. These are: (1) refinery "make" gas derived from light
ends from processes and sweetened or diluted in mixing drums and
(2) refinery waste gases generally arising from tail gases from
H^S absorption and waste water stripping systems, 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. Sulfur loading tests are con-
ducted 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 connected to a combustible gas indicator is
inserted for testing of heat value. The combustible gas indicator
acts as a thermocouple that has been previously calibrated for
on-scale readings by use of a proper size dilution orifice.
o
If the gross heating value exceeds 300 Btu/ft , then the sulfur
loading must be determined. The testing is accomplished in the
field by applying an l^S tester which gives colorimetric
reactions. The H,,S tester 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. The sulfur loading of this gas is determined by measur-
ing the length of the stain on the impregnated granules. If the
-------
4.67
reading is in excess of 25 grains with 5 squeezes of the bulb, an
excess of 50 grains is indicated. A sample should be taken to the
laboratory to determine actual grain loading so that the necessary
enforcement action can be taken.
Waste gases under less than atmospheric pressure, usually those
originating from sour water stripping operations and introduced
into combustion zones by jet or stream 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.
2. Liquid and Solid Fuels
To determine compliance with rules for solid or liquid fuels an
adequate sample must be collected from the fuel line or supply
and taken to the laboratory for analysis 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 °Be
Btu/lb.
Dens. Ib/Gal.
Specific Gravity
-------
4.68
The specific sulfur content should be ascertained from purchase
receipts or through inquiry.
If the enforcement officer cannot, through interview of the operator
or examination of fuel oil receipts, determine the API gravity, he
ascertains some other fuel specification which he correlates with
sulfur content. If he is in doubt and cannot acquire any specifi-
cations, he should take a sample. Fuel oil should be sampled with
an "oil thief" and collected in 1- or 2-quart tins. A coal shovel
is used to sample coal or other solid fuels from chute feeding
systems. Sampling techniques are further described in Fuel-Burning
Equipment, Chapter 6, Section IIG.
VII. COMMUNICATIONS EQUIPMENT
An important aid to the detection and control of the sources of air pollu-
tion is the use of a radio-communications system for the instruction,
dispatch and location of all field units. This equipment is required to
operate for the following reasons:
(1) Need to enforce emergency prevention regulations.
(2) Necessity to reach complainants and violators quickly to obtain
the essential evidence.
(3) Field units require certain types of data needed to execute their
assignments. Such information may pertain to the status of
variances or breakdowns which have been reported to the agency.
(4) Headquarters may require the immediate disposition of any complaint
handled or any air pollution problem of special interest.
(5) Need to arrange meetings of field units for coordinated types
of inspections or handling of emergencies in the field.
(6) In order for aerial observation to be of any practical use, a
radio-communications system is necessary to transmit information
from aerial to ground units.
-------
4.69
(7) Field units must be able to receive special instructions
and assignments as may be required.
Equipment available for these operations varies from devices which simply
notify field employees that contact is desired to those instruments which
permit complete and lengthy conversations.
In the former category are basic paging devices in use by many doctors
today. These are small portable receivers, about the size of a small
radio, that may attach to the user's belt. When activated, it produces a
beep or whistle-type sound that indicates to the enforcement officer that
he should call his office.
In order to carry on conversations, 2-way radios or telephones must be
employed. Two-way radios operate over a communications frequency in the
business band. A large investment in equipment (or leasing arrangement)
is required for the mobile units, a base-station transmitter, an antenna
and possibly a repeater station. The antenna must be placed on a tall
building or on high terrain. Repeater stations are necessary if the area
to be covered is not relatively flat. If many hills or mountains are in
the region, the signals will have to be reproduced by a repeater station
located at a high elevation.
The 2-way radios may be augmented through the use of hand-held portable units
(walkie-talkies) that the enforcement officer may carry. Devices with long
enough range to operate within the main radio system are very expensive
and very likely unnecessary for most applications. However, less expen-
sive, short range walkie-talkies are quite useful for a team checking
out a plant. One member may be outside reading the smoke, while others
are inside the complex, observing the operation of equipment.
-------
4.70
Mobile telephones operate about as simply as home telephones and do not
involve large equipment expenditures. The telephone company will place a
unit in a truck, van or automobile for a flat installation fee. The user
is not charged for repairs and has no additional expenses other than use
charges. These could become rather prohibitive if the units are used a
great deal and are expensive. Telephone systems can provide complete
area coverage.
The telephone companies will shortly have available 1-way portable
devices similar to the paging units discussed earlier. When a particular
phone number is dialed, the portable device will beep, alerting the user
to call his office.
In addition, the state or local agency may install a radio transmitter to
be used specifically to notify selective industrial plants of alert or
emergency conditions and to relay instructions and information. Accord--
ingly, certain designated categories of industry would be required to have
radio receiving equipment capable of monitoring agency broadcasts. They
might be ordered to curtail or halt their operations for the duration of
an air pollution episode.
-------
4.71
REFERENCES
1. Kudlich, R. Ringelmann Smoke Chart. Bureau of Mines Information
Circular No. 7718, No. 8333, revised. Department of the Interior.
May 1967.
2. Smoke Inspection Guides. DREW, PHS. 42 CFR Part 75.
3. Weisburd, M. I. Air Pollution Control Field Operations Manual, A Guide
for Inspection and Enforcement. DREW, PHS, DAP. PHS No. 937. 1962.
4. People vs. Plywood Manufacturers of California (CRA 3284-5). Shell Oil
Company (CRA-3286). Union Oil Company (CRA 3303-06). Southern California
Edison Company (CRA 3327). Memorandum Opinion of Superior Court, County
of Los Angeles. November 21, 1955.
5. Power Test Codes Determination. American Society of Mechanical Engineers.
1936.
6. Rom, J. J. Reading Visible Emissions. DHEW, PHS, National Center for
Air Pollution Control. April 1968.
7. Hewson, E. W. Meteorological Measurements. In: Air Pollution,
A. C. Stern (ed.). New York City, Academic Press, 1968.
8. D'Imperio, J. Checking an Exhaust System. In: Air Pollution Engineering
Manual, J. A. Danielson (ed.). Cincinnati, DHEW, PHS, National Center for
Air Pollution Control and the Los Angeles County Air Pollution Control
District. PHS No. 999-AP-40. 1967.
-------
G.I
GLOSSARY
A
ABSORBER: A device utilized to extract selectively one or more elements of a
gas stream from others by absorption in a liquid medium. Usually the
process is performed in cylindrical towers packed with an inert material
thus providing a large surface area for intimate contact between the rising
gas and the falling liquid. (The process may also be carried out in a
tower containing perforated trays in which the rising gas bubbles through
the layer of liquid on the trays.)
ABSORPTION: A process in which one or more constituents are removed from a
gas stream by dissolving them in a selective liquid solvent. This may
or may not involve a chemical change.
ACCUMULATOR: A vessel for the temporary storage of a gas or liquid; usually
used for collecting sufficient material for a continuous charge to a
refining process.
ACID SLUDGE: The residue left after treating petroleum oil with sulfuric acid
for the removal of impurities. It is a black, viscous substance contain-
ing the spent acid and impurities which have been separated from the oil.
ACID TREATMENT: An oil-refining process in which unfinished petroleum pro-
ducts, such as gasoline, kerosene, diesel fuel, and lubricating stocks,
are contacted with sulfuric acid to improve color, odor, and other
properties.
ACIDULATE: To make acid, especially slightly acid; to treat with acid.
ADDITION REACTION: Direct chemical combination of two or more substances to
form a single product, such as the union of ethylene and chlorine to form
ethylene dichloride:
C H + Cl —> C H. Cl
24 2 242
ADIABATIC LAPSE RATE; The rate at which a given mass of air lifted adiabatical-
ly (without loss or gain of heat) cools due to the decrease of pressure
with increasing height, 5.4°F/1000 ft (9.7°C/km).
ADIABATIC PROCESS: A thermodynamic change of state of a system in which there
is no transfer of heat or mass across the boundaries of the system.
-------
G.2
ADIABATIC TEMPERATURE: (Combustion) The theoretical temperature that would
be attained by products of combustion provided the entire chemical energy
of the fuel, the sensible heat content of the fuel, and combustion air
above the ambient temperature were transferred to the products of combus-
tion. This assumes (1) that combustion is complete, (2) that there is no
heat loss, (3) that there is no dissociation of the gaseous compounds
formed, and (4) that inert gases play no part in the reaction.
ADSORPTION: A reaction in which one or more constituents (adsorbates) are re-
moved from a gas stream by contacting and adhering to the surface of a
solid (adsorbent). Periodically the adsorbent must be regenerated to re-
move the adsorbate.
AEROSOL: A colloidal system in which particles of solid or liquid are sus-
pended in a gas. There is no clear-cut upper limit to the particle size
of the dispersed phase in an aerosol, but as in all other collodial sys-
tems, it is commonly set at 1 micro-meter. Haze, most smoke, and some fogs
and clouds may be regarded as aerosols.
AFTERBURNER: A burner located so that combustion gases are made to pass through
its flame in order to remove smoke and odors.
AGGLOMERATION: Groups of fine particles clinging together to form a larger
particle.
AIR ATOMIZING OIL BURNER: A burner in which oil is atomized by compressed air
which is forced into and through one or more streams of oil thus breaking
it into a fine spray.
AIR CURTAIN DESTRUCTOR: A device employing an air blower with pit incinerator.
Excess oxygen and turbulence result in apparent complete combustion, leaving
no residue unburned carbon (smoke) nor odorous hydrocarbons. The device
has been satisfactorily demonstrated for disposal of low-ash, high-Btu
waste, such as trees, tree trunks, brush (but not leaves), and wooden
crating material. Excessive pollution results when materials such as
automobile tires, cushions, and other non-wood wastes are burned.
AIR HEATER OR AIR PREHEATER: Heat transfer apparatus through which, combustion
air is heated by a medium of higher temperature, such as the products of
combustion or steam.
ALKYLATION: In petroleum refining, usually the union of an olefin (ethylene
through pentene) with isobutane to yield high-octane, branched-chain paraf-
finic hydrocarbons. Alkylation may be accomplished by thermal and catalytic
reactions. Alkylation of benzene and other aromatics with olefins yields
alkyl aromatics.
ALUMINA: Aluminum oxide (Al-O ), an intermediate product in the production of
aluminum. This oxide also occurs widely in nature as corundum.
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G.3
AMBIENT AIR: That portion of the atmosphere, external to buildings, to which
the general public has access.
ANODE: In aluminum production, the positively charged carbon terminal in the
reduction cell or pot. Oxygen is attracted to the anode where it combines
with carbon plus any impurities, such as sulfur, which may be present. The
anode is consumed by this process and must be replaced periodically.
ANTHRACITE COAL: A hard, black, lustrous coal containing a high percentage of
fixed carbon and a low percentage of volatile matter. Commonly referred
to as "hard coal," it is mined in the United States, mainly in eastern
Pennsylvania, as well as in small quantities in other states.
AREA SOURCE: Any small residential, governmental, institutional, commercial,
or industrial fuel combustion operations, as well as on-site waste disposal
and transportation sources (see point source).
ASH: The noncombustible solid matter in fuel.
ASH-FREE BASIS: The method of reporting fuel analysis whereby ash is deducted
and other constituents are recalculated to total 100 percent.
ASME: The American Society of Mechanical Engineers.
ASPIRATING BURNER: A burner in which the fuel in a gaseous or finely divided
form is burned in suspension. The air of combustion is supplied by drawing
it through one or more openings by the lower static pressure created by
the velocity of the fuel stream.
ASTM: The American Society for Testing and Materials.
ATOMIZER: A device by means of which a liquid is reduced to a very fine spray.
ATMOSPERIC PRESSURE: The pressure due to the weight of the atmosphere. Normal
atmospheric pressure at sea level is approximately 14.7 p.s.i. or 29.92
inches of mercury.
AVAILABLE HEAT: The quantity of useful heat per unit of fuel available from
complete combustion after deducting dry flue gas and water vapor losses.
B
BAGASSE: Sugar cane from which the juice has been essentially extracted.
BAG FILTER: A device containing one or more cloth bags for recovering particles
from the dust-laden gas which is blown through it.
-------
G.4
BAGHOUSE: Structures containing several bag filters Csee bag filters).
BAG-TYPE COLLECTOR: A filter wherein the cloth filtering medium is made in the
form of cylindrical bags.
BANKING: Burning solid fuels on a grate at rates sufficient to maintain igni-
tion only.
BARK BOILER: A combustion unit designed to burn mainly bark and wood residues,
used to produce steam for process or electrical energy.
BAROMETRIC CONDENSER: An inexpensive direct contact condenser used when con-
densate recovery is not a factor. In this type of condenser, steam rises
into a rain of cooling water, and both condensed steam and water flow out
of the bottom of the condenser, maintaining a partial vacuum in the con-
denser .
BASE STOCK: A sheet, usually produced from unbleached kraft pulp, formed into
linerboard on a fourdrinier machine.
BATCH FED INCINERATOR: An incinerator that is charged with refuse periodically,
the charge being allowed to burn down or burn out before another charge is
added.
BINDER: See core binder.
BITUMINOUS COAL: Soft coal, dark brown to black in color, haying a relatively
high proportion of gaseous constituents and usually burning with a smoky
luminous flame.
BLACK LIQUOR: Spent chemical solution which is formed during the cooking of
wood pulp in the digester. The black liquor is burned as a fuel in the
recovery furnace.
BLAST FURNACE: A shaft furnace in which solid fuel is burned with an air blast
to smelt ore.
BLEEDER: A bypass or relief valve used to relieve excess pressure.
BLISTER COPPER: An impure intermediate product in the refining of copper, pro-
duced by blowing copper bearing material in a converter; the name is
derived from the large blisters on the cast surface that result from the
liberation of SO and other gases.
BLOWBACK: The difference between the pressure at which a safety valve opens
and at which it closes, usually about three percent of the pressure at
which the valve opens.
SLOWDOWN: Hydrocarbons purged during refinery shutdowns and startups which are
-------
G.5
manifolded for recovery, safe venting, or flaring.
BOILER: A closed pressure vessel in which the liquid, usually water, is vapor-
ized by the application of heat.
BOILER HORSEPOWER: A unit of rate of water evaporation. One boiler horsepower
equals the evaporation of 34.5 Ib. of water per hour from a temperature of
212°F into dry saturated steam at the same temperature (equivalent to
33,472 Btu per hour).
BRASSESS: Copper-based alloy of 60-65% copper. Alloying material is usually
zinc.
BREAKER: In anthracite mining, the structure in which the coal is broken, sized,
and cleaned for market. Also known as a coal breaker. Atmachine used for
the primary reduction of coal, ore, or rock.
BREECHING: A sheet-iron or sheet-metal casing at the end of boilers for
conveying the smoke from the flues to the smokestack.
BRIGHTENING: The process of producing bright stock (see bright stock).
BRIGHT STOCK: Refined high viscosity lubricating oils usually made from resi-
dual stocks by suitable treatment, such as a combination of acid treatment
or solvent extraction with dewaxing or clay finishing.
BRITISH THERMAL UNIT (Btu): The mean British thermal unit is 1/180 of the heat
required to raise the temperature of one pound of water from 32°F to 212°F
at a constant atmospheric pressure. It is about equal to the quantity of
heat required to raise one pound of water 1°F. A Btu is essentially 252
calories.
BRONZES: Copper based alloy of 85-90% copper. Alloying material is usually tin.
BUNKER C OIL: Residual fuel oil of high viscosity commonly used in marine and
stationary power plants (No. 6 fuel oil).
BURNER: A device for the introduction of fuel and air into a furnace at the
desired velocities, turbulence, and concentration to establish and main-
tain proper ignition and combustion of the fuel.
BUSS (BUSBAR): A heavy metal conductor, usually copper, for high amperage
electricity.
BUSTLE PIPE: In steel making, a metal tube of large diameter which surrounds
a blast furnace at a level a little above the tuyeres; it is lined with
refractory material and distributes the hot air from the blast stoves to
the pipes (goosenecks) which carry the air to the tuyeres.
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G.6
CALCINE: Ore or concentrate which has been treated by calcination or roasting
and which is ready for smelting.
CALCINING: Roasting of ore in an oxidizing atmosphere usually to expel sulfur
or carbon dioxide. If sulfur removal is carried to practical completion,
the operation is termed "sweet roasting"; if all CO is removed, the opera-
tion is termed "dead roasting."
CALORIE: The mean calorie is 1/1000 of the heat required to raise the tempera-
ture of one gram of water from 0°C to 100°C at a constant atmospheric
pressure. It is about equal to the quantity of heat required to raise one
gram of water 1°C.
CARBONIZATION: The process of converting coal to carbon in the absence of air
by using intense heat to remove volative ingredients.
CARBON LOSS: The loss representing the unliberated thermal energy caused by
failure to oxidize some of the carbon in the fuel.
CARCINOGENIC: Producing or tending to produce cancer.
CARRYOVER: The chemical solids and liquid entrained in the steam from a boiler
or effluent from a fractionating column, absorber, or reaction vessel.
CATALYST: A substance capable of changing the rate of a reaction without itself
undergoing any net change.
CATALYTIC CRACKING: The conversion of high boiling hydrocarbons into lower
boiling substances by means of a catalyst which may be used in a fixed
bed, moving bed, or fluid bed. Natural or synthetic catalysts are employed
in bead, pellet, or powder form. Feedstocks may range from naphtha cuts
to reduced crude oils.
CATHODE: In aluminum production, the negatively charged terminal of the reduc-
tion cell to which the aluminum migrates. The terminal consists of the
carbon lining that makes up the bottom of the cell.
CAVING: In metal mining, caving implies the dropping of the over-burden as
part of the system of mining.
CHARGING: Feeding raw material into an apparatus, for example, into a furnace,
for treatment or conversion.
CHLOROSIS: A diseased condition in green plants marked by yellowing or blanch-
ing of the leaves.
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G.7
CINDERS: Particles not ordinarily considered as fly ash or dust because of
their greater size; these particles consist essentially of fused ash and/
or unburned matter.
CLEANING FIRES: The act of removing ashes from the fuel bed or furnace.
CLINKERS, CEMENT: The glassy, stony, lump-like product of fusing together clay
and limestone as the first stage in the manufacture of portland cement.
COAL DESULFURIZATION: See desulfurization.
COAL GAS: Gas formed by the destructive distillation of coal.
COAL TAR: A black viscous liquid formed as a by-product from the distillation
of coal.
COKE: Bituminous coal from which the volatile constituents have been driven
off by heat so that the fixed carbon and the ash are fused together.
COKE BREEZE: Fine coke particles leaving the coke quencher with the quenched
coke by conveyor. The particles are very fine and may be blown away.
COKE, PETROLEUM: The solid carbonaceous residue remaining as the final product
of the condensation processes in cracking. It consists of highly poly-
cyclic aromatic hydrocarbons very poor in hydrogen. It is used extensive-
ly in metallurgical processes. Calcination of petroleum coke can yield
almost pure carbon or artificial graphite suitable for production of
electrodes, motor brushes, dry cells, etc.
COKING: 1. Carbonization of coal by destructive distillation. 2. In petro-
leum refining: any cracking process in which the time of cracking is so
long that coke is produced as the bottom product; thermal cracking for
conversion of heavy, low-grade oils into lighter products and a residue
of coke; or the undesirable building up of coke or carbon deposits on
refinery equipment.
COLLECTION EFFICIENCY: The ratio of the weight of pollutant collected to the
total weight of pollutant entering the collector.
COLLOID: 1. A substance composed of extremely small particles, ranging from
0.005 micro-meters to 0.2 micro-meters, which when mixed with a liquid
will not settle, but will remain suspended. The colloidal suspension thus
formed has properties that are quite different from the simple solution of
the two substances. 2. In fuel burning, a finely divided organic sub-
stance which tends to inhibit the formation of dense scale and results in
the deposition of sludge, or causes it to remain in suspension, so that it
may be blown from the boiler.
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G.8
COLLOIDAL FUEL: Mixture of fuel oil and powdered solid fuel.
COMBINATION BOILER: A combustion unit used to produce steam for process or
electrical energy which is designed to burn bark and at least one other
fuel.
COMBUSTION CONTAMINANTS: Particulate matter discharged into the atmosphere from
the burning of any kind of material containing carbon.
COMBUSTION TOWER: Refractory graphite-lined or water-jacketed stainless steel
tower in which phosphorus is burned to phosphorus pentoxide.
CONDENSED FUMES: Minute solid particles generated by the condensation of vapors
from solid matter after volatilization from the molten state, or generated
by sublimation, distillation, calcination, or chemical reaction when these
processes create airborne particles.
CONDENSER BOILER: A boiler in which steam is generated by the condensation of
a vapor.
CONTACT CONDENSER: A condenser in which coolant, vapors, and condensate are
mixed.
CONTINUOUS-FEED INCINERATOR: An incinerator into which refuse is charged in a
nearly continuous manner in order to maintain a steady rate of burning.
CONTROL STRATEGY: A combination of measures designed to achieve the aggregate
reduction of emissions necessary for attainment and maintenance of a
national ambient air quality standard.
CONVECTION: The transmission of heat by circulation of a liquid or a gas. Con-
vection may be natural or forced.
CONVERTER: 1. A furnace in which air is blown through a bath of molten metal
or matte, oxidizing the impurities and maintaining the temperature through
the heat produced by the oxidation reaction. 2. In nitric acid produc-
tion, the chamber in which ammonia is converted to nitric oxide and water
by reacting it with air over a platinum-rhodium catalyst.
CONVERTING: The process of removing impurities from molten metal or metallic
compounds by blowing air through the liquid. The impurities are changed
either to gaseous compounds, which are removed by volatilization, or to
liquids or solids which are removed as slags.
CORE: The central part of a sand mold as used in foundries. The device placed
in a mold to make a cavity in a casting.
CORE BINDER: Organic material added to foundry sand to aid in formation of a
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G.9
strong core for casting. Flour, linseed oil, starch, and resins are among
materials used.
CRACKING: Chemical reaction by which large oil molecules are decomposed into
surlier, lower-boiling molecules. At the same time, certain of these
molecules, which are reactive, combine with one another to give even larger
molecules than those in the original stock. The more stable molecules
leave the system as cracked gasoline, but the reactive ones polymerize,
forming tar and even coke. Cracking may be in either the liquid or vapor
phase. When a catalyst is used to bring about the desired chemical reac-
tion, this is called "catalytic cracking11; otherwise, it is assumed to be
"thermal cracking" (see catalytic cracking).
CRACKLINGS: The crisp residue left after the fat has been separated from the
fibrous tissue in rendering lard or frying or roasting the skin of pork,
turkey, duck, or goose.
CRUSHER: A machine for crushing rock or other materials. Among the various
types of crushers are the ball mill, gyratory crusher, Hadsel mill, ham-
mer mill, jaw crusher, red mill, rolls, and stamp mill.
CRYOLITE: Sodium aluminum fluoride CNa A1F,) used as an electrolyte in smelting
of alumina to provide aluminum.
CULM: The fine refuse from anthracite coal production.
CUPOLA: A vertical shaft furnace used for melting metals, especially grey
iron, by having the charge come in contact with the hot fuel, usually
metallurgical coke. Metal, coke, and flux are charged from the top of the
furnace onto a bed of hot coke through which air is blown.
CURTAIN WALL: A partition wall between chambers in an incinerator under which
combustion gases pass.
CYCLONE: A structure without moving parts in which the velocity of an inlet
gas stream is transformed into a confined vortex from which centrifugal
forces tend to drive the suspended particles to the wall of the cyclone
body. The particles then slide down the cyclone wall and are collected
at the bottom.
CYCLONE SCRUBBERS: Devices ranging from simple dry cyclones with spray nozzles
to multistage devices. All feature a tangential inlet to a cylindrical
body.
CYCLONIC SPRAY TOWER: Liquid scrubbing apparatus where sprays are introduced
countercurrent to gases for removal of contaminants.
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G.10
D
DEHYDROGENATION: The removal of hydrogen from a chemical compound; for example,
the removal of two hydrogen atoms from butane to make butylene, and the
further removal of hydrogen to make butadiene.
DEMISTER (COLLECTOR): 1. A mechanical device used to eliminate finely divided
liquid particles from process streams by impaction and agglomeration.
2. Apparatus made of wire mesh or glass fiber and used to eliminate acid
mist as in the manufacture of sulfuric acid.
DESTRUCTIVE DISTILLATION: 1. A process of distillation in which an organic
compound or mixture is heated to a temperature high enough to cause de-
composition. 2. The heating of organic matter when air is not present,
resulting in the evolution of volatile matter and leaving char consisting
of fixed carbon and ash.
DESULFURIZATION: 1. In coal processing, the removal of sulfur from the coal,
often by mechanical cleaning processes. 2. In petroleum refining, remov-
ing sulfur or sulfur compounds from a charge stock Coil that is to be
treated in a particular unit).
DIFFUSION: The spreading or scattering of a gaseous or liquid material.
1. Eddy diffusion: diffusion caused by turbulent activity in a fluid
system. 2. Molecular diffusion: a process of spontaneous intermixing
of different substances, attributed to molecular motion and tending to
produce uniformity of concentration.
DIRECT-FIRED BOILER: Commonly used to denote a boiler and furnace fired by
pulverized coal.
DISPERSION: The dilution of a pollutant by diffusion, or turbulent action, etc.
Technically, a two-phase system of two substances, one of which (the dis-
persed phase) is uniformly distributed in a finely divided state through
the second substance (the dispersion medium). Either phase may be a gas,
liquid, or solid.
DISTILLATE: The product of distillation obtained by condensing the vapors from
a still.
DISTILLATE FUELS: Liquid fuels distilled usually from crude petroleum, except
residuals such as No. 5 and No. 6 fuel oil.
DISTILLATE OILS: The lighter oils produced by distilling crude oil.
DISTILLATION: The process of heating a substance to the temperature at which
it is converted to a vapor, then cooling the vapor, and thus restoring it
to the liquid state.
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G.ll
DOCTOR TREATMENT: Treatment of gasoline with sodium-plumbite solution and sul-
fur to improve its odor.
DOPES FOR GASOLINES: Materials added in small amounts to gasoline to increase
the octane number and thus help to prevent knocking.
DOUBLE DECOMPOSITION: A chemical reaction between two compounds in which part
of the first compound becomes united with the remainder of the second, as:
AB + CD = AD + BC.
DRAFT: A gas flow resulting from the pressure difference between the incinera-
tor, or any component part, and the atmoshpere, which moves the products
of combustion from the incinerator to the atmosphere. 1. Natural draft:
the negative pressure created by the difference in density between the hot
flue gases and the atmosphere. 2. Induced draft: the negative pressure
created by the vacuum action of a fan or blower located between the in-
cinerator and the stack. 3. Forced draft: the positive pressure created
by the action of a fan or blower, which supplies the primary or secondary
air.
DROP ARCH: A refractory construction or baffle which serves to deflect gases
in a downward direction.
DROSS: 1. Impurity formed in melted metal. A zinc-and-iron alloy forming in
a bath of molten zinc, in galvanizing iron. 2. The scum that forms on
the surface of molten metals usually due to oxidation, but occasionally
due to the rising of impurities to the surface.
DRUM, FLASH (OR FLASH TOWER): A drum or tower into which the heated outlet
products of a preheater or exchanger system are conducted, often with some
release in pressure. The purpose of the drum is to allow vaporization and
separation of the volatile portions for fractionation elsewhere.
DRY BOTTOM FURNACE: A furnace designed to burn pulverized coal at temperatures
low enough to prevent the ash from fusing or slagging.
DUST: Generally particles from 1 to 100 micro-meters in size that become air-
borne by natural or mechanical means. These particles do not diffuse but
will settle under the influence of gravity (see also particle).
DUST COLLECTING FAN: A centrifugal fan which concentrates dust and skims it
into a cyclone or hopper.
DUSTLESS LOADING: The amount of dust in a gas, usually expressed in grains per
cubic foot or in pounds per thousand pounds of gas Csee also grain load-
ing) .
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ECONOMIZER: A heat recovery device designed to transfer heat from the products
of combustion to a fluid, usually feedwater for a steam boiler. The water
flows through a bank of tubes placed across the flue gases and is heated by
these gases prior to entering the boiler.
EFFICIENCY: The ratio of output to input. The efficiency of a steam generating
unit is the ratio of the heat absorbed by the water or steam to the heat in
the fuel fired, expressed in percent.
EFFLUENT: Any waste material Csolid, liquid, gas) emitted by a process.
EFFLUENT WATER SEPARATOR: A container designed to separate volatile organic
compounds from waste water prior to discharge or reuse.
ELECTROLYSIS: 1. Chemical change resulting from the passage of an electric
current through an electrolyte. 2. Transfer or transport of matter
through a medium by means of conducting ions (positively or negatively
charged particles). The medium may consist of fused salts or conducting
solutions which permit free movement of ions toward the countercharged
electrodes immersed in the system.
ELECTROSTATIC PRECIPITATOR: Devices that separate particles from a gas stream
by passing the carrier gas between two electrodes across which a unidirec-
tional, high-voltage electrical charge is placed. The particles pass
through this field, become charged and migrate to the oppositely charged
electrode. Single-stage precipitators are those in which gas ionization
and particulate collection are combined into a single step. In the two-
stage unit, ionization is achieved by one element of the unit and the col-
lection by the other. Electrostatic precipitators are highly efficient
collectors for minute particles.
ELUTRIATOR: A vertical tube through which a gas or fluid passes upward at a
specific velocity while a solid mixture whose separation is desired is fed
into the top of the column. The large particles which settle at a veloci-
ty higher than that of the rising fluid are collected at the bottom of the
column, and the smaller particles are carried out of the top of the column
with the fluid.
EMISSION: The total amount of a solid, liquid, or gaseous pollutant emitted
into the atmosphere from a given source in a given time, and indicated in
grams per cubic meter of gas, pounds per hour, or other quantitative
measurement.
ENDOTHERMIC REACTION: A reaction which requires the addition of heat for its
continuation.
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G.13
ENTRAINMENT: The process of particulates or other materials being carried
along by a gas stream.
EVAPORATOR: Usually a vessel which receives the hot discharge from a heating
coil and, by a reduction in pressure, flashes off overhead the light pro-
ducts and allows the heavy residue to collect in the bottom (see flash
tower).
EXCESS AIR: Air supplied for combustion in excess of that theoretically re-
quired for complete combustion, usually expressed as a percentage of
theoretical air, such as "130 percent excess air."
EXOTHERMIC REACTION: A reaction which produces heat.
FABRIC FILTER: See bag filter.
FIXED CARBON: That part of the carbon which remains when coal is heated in a
closed vessel until the volatile matter is driven off. It is the nonvola-
tile matter minus the ash.
FEEDSTOCK: Starting material used in a process. This may be raw material or
an intermediate product that will undergo additional processing.
FLOATING ROOF: A special tank roof which floats upon the oil in a storage tank.
FLUE: Any duct, passage, or conduit through which the products of combustion
are carried to a stack or chimney Csee also breeching).
FLUE GAS: The gaseous products of combustion passing from the furnace into the
stack.
FLUIDIZED ROASTING: Oxidation of finely ground pyritic minerals by means of
upward currents of air, blown through a reaction vessel Cfluid bed roaster)
with sufficient force to cause the bed of material to expand (boil). Re-
action between mineral and air is maintained at a desired exothermic level
by control of oxygen entry, by admission of cooling water, or by addition
of fuel.
FLUOROSIS: A chronic poisoning resulting from the presence of 0.9 milligrams
or more per liter of fluorine in drinking water. Teeth become brittle and
opaque white with a mottled enamel.
FLUOROSPAR: A natural calcium fluoride (CaF ) used as a flux in open hearth steel
furnaces and in gold, silver, copper, and lead smelting.
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G.14
FLUX: 1. In chemistry and metallurgy, a substance that promotes the fusing
of minerals or metals or prevents the formation of oxides. 2. A substance
added to a solid to increase its fusibility. 3. A substance to reduce
melting temperature. 4. Any chemical or rock added to an ore to assist
in its reduction by heat, such as limestone with iron ore in a blast fur-
nace.
FLY ASH: In incineration, suspended incombustible particles, charred paper,
dust, soot, or other partially incinerated matter, carried in the gaseous
products of combustion.
FOOD-GRADE ACID: Phosphoric acid that has been treated for removal of heavy
metals and is suitable for use in food products.
FORCED DRAFT: See draft.
FRACTIONAL DISTILLATION: The separation of the components of a liquid mixture
by vaporizing and collecting the fractions which condense in different
temperature ranges.
FUEL: Any form of combustible matter—solid, liquid, vapor, or gas, excluding
combustible refuse.
FUEL-BURNING EQUIPMENT: Any furnace, boiler, apparatus, stack, and all appur-
tenances thereto, used in the process of burning fuel for the primary pur-
pose of producing heat or power by indirect heat transfer.
FUGITIVE DUST: Solid airborne particulate matter emitted from any source other
than a flue or stack.
FUME: Fine solid particles predominately less than 1 micro-meter in diameter
suspended in a gas. Usually formed from high-temperature volatilization
of metals, or by chemical reaction.
FUMIGATION: Fumigation is an atmospheric phenomenon in which pollution, which
has been retained by an inversion layer near its level of emission, is
brought rapidly to ground level when the inversion breaks up. High con-
centrations of pollutant can thus be produced at ground level.
FUMING NITRIC ACID: A mixture of 98 percent nitric acid and an equilibrium
mixture of nitrogen tetroxide (NO ) and nitrogen dioxide CNO ).
FURNACE OIL: A distillate fuel primarily intended for domestic heating use.
No. 1 commercial standard grade is intended for "vaporizing" burners re-
quiring a volatile fuel, whereas No. 2 and No. 3 commercial standard
grades are less volatile, and are thus usable in the "atomizing" type of
burners.
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G.15
GAGE PRESSURE: The pressure above atmospheric pressure, expressed as pounds
per square Inch, gage Cpslg).
GOB PILES: Large piles of low-combustible refuse from coal mine preparation
plants. Fires may develop in these waste material piles by liberation of
heat through slow oxidation, until ignition temperature is reached (see
also culm).
GRAIN LOADING: Concentration of particulates in exhaust gas, expressed as
grains per standard cubic foot (7000 grains = 1 pound) (see also dust
loading).
GRAVITATIONAL SETTLING: Removal of material from the atmosphere due to the ac-
tion of gravity.
GREEN COKE: Coke that has not been fully cooked. Green coke produces exces-
sive emissions when pushed from a coke oven.
GREEN FEED (CALCINED FEED): Not fully processed or treated feed.
GROUT (GROUTING): A pumpable slurry of portland cement or a mixture of port-
land cement and fine sand commonly forced into a borehole to seal crevices
in a rock to prevent ground water from seeping or flowing into an excava-
tion or for extinguishing underground fires.
H
HEAT ISLAND EFFECTS: Meteorological characteristics of an urban area or large
industrial complex which differentiates it from its surroundings. Gener-
ally, the urban area has (1) higher temperatures, (2) a less stable noc-
tournal lapse rate immediately above the surface, (3) lower relative
humidities, (4) greater cloudiness, (5) more frequent fogs, (6) less in-
coming radiation, (7) lower wind speeds, and (8) greater precipitation.
HEAT RELEASE RATE: The amount of heat liberated during the process of combus-
tion and expressed in Btu per hour per cubic foot of internal furnace vol-
ume in which the combustion takes place.
HOG FUEL BOILER: See bark boiler.
HOT BLAST MAIN: A duct lined with refractory material, through which hot air
passes from a hot blast stove to the bustle pipe of a blast furnace.
HOT WELL: A reservoir for receiving warm condensed steam drawn from a con-
denser.
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G.16
HYDRATOR-ABSORBER: A single or double tower in which phosphorus pentoxide is
hydrated to phosphoric acid and the resulting acid mist is absorbed.
HYDRAULIC FLY ASH HANDLING: A system using water-filled pipes or troughs in
which fly ash is conveyed by means of gravity, water jets, or centrifugal
pumps.
HYDROCARBONS: Organic compounds which consist solely of carbon and hydrogen
and occur in petroleum, natural gas and coal.
HYDROCRACKING: A low-temperature catalytic method of converting crude oil,
residual oil, petroleum tar, and asphalt to high-octane gasoline, jet fuel,
and/or high-grade fuel oil. The process combines cracking, hydrogenation,
and isomerization.
HYDRODESULFURIZATION: A desulfurization process in which the oil is heated
with hydrogen.
HYDROGENATION: The chemical addition of hydrogen to a material at high pres-
sure in the presence of a catalyst.
HYDROMETALLURGY: The treatment of ores, concentrates, and other metal-bearing
materials by wet processes, usually involving the solution of some compo-
nent, and its subsequent recovery from the solution.
HYDROTREATING: A treating process using hydrogen for the desulfurization of
cracked distillates.
IMPINGEMENT: In air sampling, impingement refers to a process for the collec-
tion of particulate matter in which the gas being sampled is directed
forcibly against a surface. 1. Dry impingement: the process of impinge-
ment in the gas stream where particulate matter is retained upon the sur-
face against which the stream is directed. The collecting surface may
be treated with a film of adhesive. 2. Wet impingement: the process of
impingement in a liquid which retains the particulate matter.
IMPINGEMENT SEPARATORS: Devices using the principle that when a gas stream
carrying particulate matter impinges on a body, the gas is deflected
around the body, while the particles, because of their greater inertia,
tend to strike the body and be collected on its surface. The bodies may
be in the form of plates, cylinders, ribbons, or spheres.
INCINERATION: The process of burning solid, semi-solid, or gaseous combustible
waste.
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G.17
INCINERATOR: An apparatus designed to burn solid, semi-solid, or gaseous waste
leaving little or no combustible material (see multiple chamber incinera-
tor) .
INERTIAL SEPARATOR: The most widely used device for collecting medium and
coarse sized particles. Inertial separators operate by the principle of
imparting centrifugal force to the particle to be removed from the car-
rier gas stream.
INTERRUPTIBLE GAS: Gas sold whereby the seller may curtail or stop delivery,
generally at his option. The gas customer under these conditions is ex-
pected to have standby equipment capable of taking over 100% of his needs
by an alternate fuel.
INVERSION: A stratum in the atmosphere through which the temperature increases
with height. The layer is thermally stable and vertical motion within the
layer is suppressed.
INVERSION BASE: The lowest height in the atmosphere at which the temperature
ceases to decrease with height.
ISOMERIZATION: A reaction which alters the fundamental arrangement of the
atoms in a molecule without adding or removing anything from the original
material. In the petroleum industry, straight-chain hydrocarbons are con-
verted catalytically to branched-chain hydrocarbons of substantially high-
er octane number by isomerization.
JIG: A device which separates coal from foreign matter by means of their dif-
ference in specific gravity in a water medium. The water pulsates up and
down causing the heavy material to work to the bottom.
K
KETTLE: 1. An open-top vessel used in carrying out metallurgical operations
on low-melting-point metals; for example, in dressing and desilverizing
lead. 2. An open or (usually) closed vessel for preparing paints, var-
nishes, and resins.
KILN: A furnace in which the heating operations do not involve fusion. Kilns
are most frequently used for calcining, and free access of air is permit-
ted. The raw materials may be heated by the combustion of solid fuel with
which they are mixed, but more usually they are heated by gas or the waste
heat from other furnaces.
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G.18
KILN GAS: Hot effluent gases from a kiln. Unless controlled, these gases can
be the largest source of particulates in a plant.
KNOCKOUT DRUM: A drum or vessel constructed with baffles through which a mix-
ture of gas and liquid is passed to disengage one from the other. As the
mixture comes in contact with the baffles, the impact frees the gases and
allows them to pass overhead; the heavier substance falls to the bottom of
the drum.
LAPSE RATE: The decrease of temperature with altitude.
LAUNDER: A trough, channel, or gutter usually of wood, by which water is con-
veyed. Specifically, in mining, a chute or trough for conveying powered
ore, or for carrying water to or from the crushing apparatus.
LEACHING: Extracting a soluble metallic compound from an ore by selectively
dissolving it in a suitable solvent, such as water, sulfuric acid, hydro-
chloric acid, etc.
LIGNITE COAL (BROWN COAL): A brownish-black variety of coal, usually high in
moisture and low in Btu's. Lignite is one of the earlier stages in the
formation of bituminous coal.
MANIFOLD: A pipe or header for collecting a fluid or gas from, or distributing
a fluid or gas to, a number of pipes or tubes.
MANUFACTURED GAS: Fuel gas manufactured from coal, oil, etc., as differenti-
ated from natural gas.
MATERIAL BALANCE: An accounting of the weights of material entering and leav-
ing a process.
MATTE: A metallic sulfide mixture formed in smelting sulfide ores of copper,
lead, and nickel.
MECHANICAL, CENTRIFUGAL SEPARATORS: A device for separating particulates. A
rotating fan blade exerts a large centrifugal force on the particulates,
ejecting them from the tips of the blades to a skimmer bypass leading into
a dust hopper.
MECHANICAL SCRUBBER: A scrubber in which the water spray is generated by a ro-
tating element or disk Csee also scrubber).
MECHANICAL TURBULENCE: In meteorology, the induced eddy structure of the at-
mosphere due to the roughness of the surface over which the air is passing.
The height and spacing of the elements causing the roughness will affect
the turbulence.
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G.19
MERCAPTANS: Organic compounds having the general formula R-SH (where R repre-
sents any hydrocarbon radical) which are analogous to the alcohols and
phenols but which contain sulfur in place of oxygen. The simpler mercap-
tans have strong, repulsive odors.
MESH: The number of holes per linear unit in a sieve or gauze, or the space
between the wires of the sieve expressed in inches or millimeters.
METRIC TON: 2204.6 pounds or 1000 kilograms.
MIST: A suspension of any finely divided liquid in a gas.
MODIFIED COAL: Coal of a stoker size containing a controlled percentage of
fines.
MULTICYCLONE CALSO MULTIPLE CYCLONE OR MULTICLONE): A dust collector consisting
of a number of cyclones, operating in parallel, through which the volume
and velocity of gas can be regulated by means of dampers to maintain dust-
collector efficiency over the load range.
MULTIPLE-CHAMBER INCINERATOR: Any incinerator consisting of a primary combus-
tion chamber, mixing chamber, and secondary combustion chamber in series.
The chambers are separated by refractory walls, and interconnected by gas
passage ports.
MULTIPLE-HEARTH TYPE ROASTER: See roasting furnace.
MUNICIPAL INCINERATOR: An incinerator owned or operated by government or by a
person who provides incinerator service to government or others; a device
designed for and used to burn waste materials of any and all types.
N
NATURAL GAS: Gaseous forms of petroleum occurring in nature and used directly
as a fuel. Natural gas consists of mixtures of hydrocarbon gases and va-
pors, the THore important of which are methane, ethane, propane, and butane.
NET TON: 2000 pounds (sometimes known as a "short ton").
NITROGEN OXIDES: A general term pertaining to a mixture of nitric oxide (NO)
and nitrogen dioxide (NO ).
0
ODORANT: A gaseous nuisance that is offensive or objectionable to the smell.
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G.20
ODOR INTENSITY: The numerical or verbal Indication of the strength of an odor.
ODOR PERVASIVENESS: The ability of an odor to diffuse into a large volume of
air and still continue to possess a detectable intensity. A pervasive odor
is one whose odor intensity changes very little on dilution.
ODOR QUALITY: A verbal description of an odor. The quality may be described
in terms of such familiar odorants as coffee, onions, lemons, or by asso-
ciating an unfamiliar odor with a familiar odor.
ODOR THRESHOLD: The lowest concentration of an odor in air that can be detected
by a human.
ODOR UNITS': That quantity of odor necessary to contaminate one cubic foot of
air to threshold or barely perceptible level. The number of odor units
is equal to the volumes (scf ) of air necessary to dilute the concentration
of odorant in one volume (scf) of air to the threshold concentration.
OIL BURNER: Any device for the introduction of vaporized or atomized fuel oil
into a furnace.
OIL-EFFLUENT WATER SEPARATOR: Any tank, box, sump, or other container in which
any petroleum product entrained in water is physically separated and re-
moved prior to out-fall, drainage, or recovery of the water.
OITICICA (OIL): A drying oil obtained from the kernels of the fruit of the
oiticica tree that is similar to tung oil in many properties and is used
chiefly in varnishes, paints, and printing inks.
OLEORESIN: A varnish or paint vehicle, made of plant oils and resins, usually
cooked.
OLEUM (FUMING SULFURIC ACID): A heavy, oily, strongly corrosive liquid that
consists of a solution of sulfur trioxide in anhydrous sulfuric acid. It
fumes in moist air and reacts violently with water.
ONSTREAM TIME: The length of time a unit is in actual production.
OPACITY: The degree to which emissions reduce the transmission of light and
obscure the view of a distant object.
OPEN BURNING: The burning of any matter in such a manner that the products of
combustion are emitted directly into the ambient air without passing
through a stack, duct, or chimney.
OPEN HEARTH. FURNACE: Reverberatory furnace, containing a basin-shaped hearth,
for melting and refining suitable types of pig iron, iron ore, and scrap
for steel production.
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G.21
ORE AND LIME BOIL: Reactions which occur in an open hearth furnace when carbon
monoxide is produced by the oxidation of carbon. Ore boil is a violent
agitation of the metal as it escapes during this process; lime boil occurs
when the limestone decomposes and the carbon dioxide gas escapes. The
second reaction begins before the first is completed.
ORGANIC SULFUR: The difference between the total sulfur in coal and the sum of
the pyritic sulfur and sulfate sulfur.
ORGANOLEPTIC: Affecting or making an impression upon one or more of the sense
organs.
ORIFICE SCRUBBERS: Devices for the removal of particulates from gas, streams in
which the flow of air through a restricted passage partially filled with
water causes the dispersion of the water and consequent wetting and col-
lection of the particulates.
ORSAT: An apparatus used for analyzing flue gases volumetrically.
OVERBURDEN: Material of any nature, consolidated or unconaolidated, that over-
lies a deposit of useful material, ores, or coal, especially those deposits
that are mined from the surface by open cuts.
OVEKFIRE: Air for combustion admitted into the furnace at a point above the
fuel bed.
OXIDATION: The act or process of combining oxygen with a substance, with or
without the production of a flame.
OXYGEN LANCING: In steel making, a procedure in which oxygen is injected into
the bath of molten metal through a water cooled lance. The oxygen oxidizes
carbon, silicon, manganese, and some iron in exothermic reactions. The
procedure materially shortens the time needed to tap the furnace.
PACKED COLUMN (PACKED SCRUBBER OR PACKED TOWER): A vertical column used for
distillation, absorption, and extraction, containing packing; e.g., Raschig
rings, Berl saddles, or crushed rock, which provide a large contacting
surface area between phases. Normally, gas flow is countercurrent to
liquid flow.
PAN: Peroxyacyl nitrates. Secondary pollutants formed in photochemical oxida-
tion and major eye irritants of photochemical smog.
PARTICLE CONCENTRATION: Concentration expressed in terms of number of particles
per unit volume of air or other gas.
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G.22
PARTICULATE MATTER: Any dispersed matter, solid or liquid, in which the indi-
vidual aggregates are larger than single small molecules (P.0002 micro-
meters) but smaller than 500 micro-meters.
PERCOLATOR: A device used in rendering plants for the separation of dry pro-
teinaceous crackling from the clear moisture-free tallow. They are gener-
ally perforated pans which allow the tallow to drain away from the crack-
lings .
PERFORMANCE TEST: Measurements of emissions used for the purpose of determin-
ing compliance with a standard of performance.
PETROCHEMICAL INDUSTRY: A branch of the petroleum industry in which refined
crude oil is -manufactured into various chemicals.
PETROLEUM COKE: See coke, petroleum.
PHOTOCHEMICAL REACTION: A chemical reaction which involves either the absorp-
tion or emission of radiation in the form of light energy.
PLUME: The path taken by the continuous discharges of products from a chimney
or stack. The shape of the path and the concentration distribution of
gas plumes is dependent on turbulence of the atmosphere.
POINT SOURCE: Any stationary emitting point or plant/facility whose summation
of emitting points totals 100 tons (or some other fixed amount) per year
of any pollutant in a given region.
POLYCYCLIC MOLECULE: A molecule containing two or more fused rings (as in
anthracine).
POLYMERIZATION: 1. A reaction combining two or more molecules to form a
single molecule having the same elements in the same proportions as in the
original molecules. 2. The union of light olefins to form hydrocarbons
of higher molecular weight. The process may be thermal or catalytic.
POLYNUCLEAR AROMATIC HYDROCARBONS: Compounds consisting of two or more aro-
matic rings which share a pair of carbon atoms. The simplest and most
important is naphthalene (C H ; also polycyclic).
10 8
PRECLEANERS: Collectors of limited efficiency used ahead of the final cleaner.
If the gas contains an appreciable amount of hard, coarse particles, a
precleaner can materially reduce erosive wear of the more efficient final
collector.
PRECURSORS: Gaseous air pollutants which react with other substances in the
atmosphere to produce different pollutants; e.g., photochemical reactions
of NO and NO with the oxygen of the air which produce ozone.
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G.23
PRILLING: A combination spray drying and crystallization technique used in the
production of ammonium nitrate. A hot ammonium nitrate solution is sprayed
in the top of a tower, and air is blown in at the bottom. The liquid is
converted into spherical pellets.
PRIMARY AIR: In incineration, air which is introduced with the refuse into
the primary chamber.
PRIMARY EMISSION: Pollutants emitted directly into the air from identifiable
sources.
PRIMARY STANDARD: The national primary ambient air quality standard which, de-
fines levels of air quality which are necessary to protect public health.
PROCESS WEIGHT: The total weight of all materials introduced into a source
operation, including solid fuels, but excluding liquids and gases used
solely as fuels, and excluding air introduced for purposes of combustion.
PUG MILL: A machine for mixing water and clay which consists of a long hori-
zontal barrel within which is a long longitudinal shaft fitted with knives
which slice through the clay, mixing it with water which is added by
sprayers from the top. The knives are canted to give some screw action,
forcing the clay along the barrel and out one end.
PUMP, RECIPROCATING: A positive-displacement type of pump consisting of a
plunger or a piston moving back and forth within a cylinder. With each
stroke of the plunger or piston, a definite volume of liquid is pushed
out through the discharge valves.
PYRITIC SULFUR: Sulfur combined with iron, found in coal.
PYROLYSIS: Chemical change brought about by the action of heat upon a sub-
stance.
PYROMETER: An instrument for measuring temperatures beyond the range of thermo-
meters.
R
RECOVERY BOILER: In wood pulping, a combustion unit designed to recover the
spent chemicals from the cooking liquor and to produce steam for pulping
and recovery operations.
REDUCTION: 1. The addition of hydrogen or the abstraction of oxygen from a
substance. 2. The extraction of any metal from its ore.
REFINERY GAS: Any form or mixture of still gas gathered in a refinery from the
various stills.
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G.24
REFINING: In metallurgy, the removal of impurities necessary to produce an
ingot or alloy of desired specification. In petroleum, the process of
separating, combining, or rearranging petroleum oil constituents to pro-
duce salable products.
REFORMING: The thermal or catalytic conversion of naphtha into more volatile
products of higher octane number. It represents the total effect of nu-
merous reactions, such as cracking, polymerization, dehydrogenation, and
isomerization, taking place simultaneously.
REFRACTORY: A ceramic material of a very high melting point with properties
that make it suitable for such uses as furnace and kiln linings.
RERUN OIL: Oil which has been redistilled.
RESIDUAL: Heavy oil left in the still after gasoline and other distillates
have been distilled off, or residue from the crude oil after distilling
off all but the heaviest components.
RESISTIVITY: The property of a body whereby it opposes and limits the passage
of electricity through it. Resistivity of dust is an important factor in
the performance of electrostatic precipitatgrs. If the resistivity of the
collected dust is higher than about 2 x 10 ohm-cm, excessive arcing or
reverse corona can occur, thereby limiting precipitator performance.
REVERBERATORY FURNACE: A furnace with a shallow hearth; having a roof that de-
flects the flame and radiates heat toward the surface of the charge. Fir-
ing may be with coal, pulverized coal, oil, or gas.
RINGELMANN CHART: A standardized chart giving shades of gray by which the
densities of columns of smoke rising from stacks may be compared.
ROAST: To heat to a point somewhat short of fusing, with access to air, so as
to expel volatile matter or effect oxidation. In copper metallurgy, ap-
plied specifically to the final heating which causes self-reduction to oc-
cur by the reaction between the sulfide and the oxide.
ROASTER: 1. A contrivance for roasting, or a furnace for drying salt cake.
2. A reverberatory furnace or a muffle used in roasting ore.
ROASTING: 1. Heating an ore to effect some chemical change that will facili-
tate smelting. 2. The heating of solids, frequently to promote a reac-
tion with a gaseous constituent in the furnace atmosphere.
ROASTING FURNACE: A furnace in which finely ground ores and concentrates are
roasted to eliminate sulfur; heat is provided by the burning sulfur.
RUN OF MINE COAL: Unscreened bituminous coal as it comes from the mine.
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G.25
SALAMANDER: A small portable incinerator, or a small portable heater burning
coke or oil.
SCRUBBER: A device used to remove entrained liquids and solids from a gas
stream by passing the gas through wetted "packing" or spray Csee absorber)
SECONDARY AIR: Air introduced into a combustion chamber beyond the point of
fuel and primary air introduction for the purpose of achieving more com-
plete oxidation.
SECONDARY STANDARD: The national secondary ambient air quality which defines
levels of air quality judged necessary to protect the public welfare from
any known or anticipated adverse effects of a pollutant.
SINTERING: A heat treatment that causes adjacent particles of material to
cohere or agglomerate at a temperature below that of complete melting.
SKIMMING PLANT: An oil refinery designed to remove and finish only the lighter
constituents from the crude oil, such as gasoline and kerosene. In such a
plant the portion of the crude remaining after the above products are re-
moved is usually sold as fuel oil.
SKIP HOIST, INCLINED: A bucket or can operating up and down, receiving, ele-
vating, and discharging bulk materials.
SLAG: The non—metallic top layer which separates from the metallic products in
smelting of ores.
SLOP OR SLOP OIL: A term rather loosely used to denote odds and ends of oil
produced at various places in a plant, which must be rerun or further pro-
cessed in order to get in suitable condition for use. When good for noth-
ing else, such oil usually goes into pressure-still charging stock, or to
coke stills.
SMELT: In wood pulping, the molten chemicals from the kraft recovery furnace
consisting mostly of sodium sulfide and sodium carbonate.
SMELTING: Any metallurgical operation in which metal is separated by fusion
from impurities with which it may be chemically combined or physically
mixed, such as in ores.
SMOKE: Small gas-borne particles resulting from incomplete combustion, con-
sisting predominantly but not exclusively of carbon, ash, and other com-
bustible material, and present in sufficient quantity to be observable.
SMOKE CANDLE(S) : Apparatus used in collecting acid mists. Tubes or candles
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G.26
made from glass or plastic fibers are pressed into pads with, thicknesses
up to 2 inches and mounted in banks. Efficiency is much increased when
the glass Is treated with silicone oil to repel water, or when normally
water-repellent plastic is used.
SMOKE UNIT: The number of "smoke units" is obtained by multiplying the smoke
density in Ringelmann numbers by the time of occurrence in minutes. For
the purpose of this calculation, a Ringelmann density reading is made at
least once per minute during the period of observation. The sum of the
Ringelmann density readings (made once per minute) during the period of
observations would equal the number of smoke units.
SOILING: Visible damage to materials by deposition of air pollutants.
SOOT: Agglomerated particles consisting mainly of carbonaceous material.
SOUR: Gasolines, naphthas, and refined oils are said to be "sour" if they show
a positive "doctor test"; i.e., if they contain hydrogen sulftde and/or
mercaptans. Sourness Is directly connected with odor, while a "sweet"
gasoline has a good odor.
SOURCE: Any property, real or personal, or person contributing to air pollution.
SOURCE SAMPLE: A sample of the emission from an air contamination source, col-
lected for analysis from within a stack.
SPARK ARRESTOR: A screenlike device to prevent sparks, embers, and other ig-
nited materials larger than a given size from being expelled to the atmos-
phere .
SPEISS: Metallic arsenides and antimonides smelted from cobalt and lead ores.
SPRAY CHAMBER: The simplest type of scrubber consisting of a chamber in which
spray nozzles are placed. They are used extensively as gas coolers be-
cause they have a low collection efficiency for anything but coarse particles.
STABILITY (STATIC STABILITY): The state of the atmosphere when it is stable
relative to vertical displacements.
STACK OR CHIMNEY: Any flue, conduit, or duct arranged to conduct an effluent
to the open air.
STACK SPRAY: A nozzle or series of nozzles installed in a stack, above the
breeching, used to inject wetting agents at high, pressure to suppress the
discharge of particulate matter from the stack.
STANDARD CONDITIONS: For source testing, 70°F (21.1°Cl and 24.92" Hg (76Qnm
Hg) ; for air quality measurements, 77°F (25°C) and 29.92" Hg (760mm Hg);
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G.27
for chemistry, 273.1°KL (0°C) and one atmosphere (76Ctem Hg); for petroleum
refining, 60°F (15.55°C) and 14.7 psi (760mm Eg).
STATIONARY SOURCE: Any non-mobile bunding, structure, facility, or installa-
tion which emits or may emit any air pollutant.
STEAM DISTILLATION: Introduction of "open" steam into the liquid during dis-
tillation to assist in vaporizing the volatiles at a lower temperature.
STILL: A closed chamber, usually cylindrical, in which heat is applied to a
substance to change it into vapor, with or without chemical decomposition.
The substance, in its vapor form, is conducted to some cooling apparatus
where it is condensed, liquefied, and collected in another part of the unit.
STOCK: In general, any oil which is to receive further treatment before going
into finished products.
STOKER: A machine for feeding coal into a furnace, and supporting it there
during the period of combustion. It may also perform other functions,
such as supply air, control combustion, or distill volatile matter. Modern
stokers may be classified as overfeed, underfeed, and conveyor. Any mech-
anical device that feeds fuel uniformly onto a grate or hearth within a
furnace may be termed a "stoker."
STOPING: In mining, any process of excavating ore which has been made acces-
sible by shafts and drifts.
STRAIGHT-RUN DISTILLATION: Continuous distillation which separates the products
of petroleum in the order of their boiling points without cracking.
STRIPPER: Equipment in which the lightest fractions are removed from a mixture.
In a natural-gasoline plant, gasoline fractions are stripped from rich oil.
In the distillation of crude petroleum, light fractions are stripped from
the various products.
SUBSTITUTION: A chemical reaction in which one or more atoms or groups of a
molecule are replaced by equivalent atoms or groups to form at least two
products, especially the replacement of hydrogen in an organic compound by
another element or group.
SULFIDITY: An expression of the percentage makeup of chemical kraft cooking
liquor obtained by the formula
Na S x 100
Na S + NaOH
where the sodium compounds are expressed as Na.O.
SUPERPHOSPHATE: Products obtained by mixing phosphate rock with either sul-
furic or phosphoric acid, or both.
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G.28
SURFACE CONDENSERS: A condenser in which the coolant does not contact the
vapors or condensate. Most are of the tube and shell type. Water flows
inside the tubes and vapors condense on the shell side.
SURGE TANK: A storage reservoir at the downstream end of a feeder pipe to ab-
sorb sudden rises of pressure and to furnish liquid quickly during a drop
in pressure.
SWEETENING: The process by which petroleum products are improved in odor and
color by oxidizing or removing the sulfur-containing and unsaturated com-
pounds .
SYNERGISM: Cooperative action of discrete agents such that the total effect is
greater than the sum of the two effects taken independently.
SYNTHETIC CRUDE: The total liquid, multi-component mixture resulting from a
process involving molecular rearrangement of charge stock. Term commonly
applied to the product from cracking, reforming, visbreaking, etc.
TAIL OIL: That portion of an oil which vaporizes near the end of the distil-
lation; the heavy end.
TAIL GAS: The exhaust or waste gas from a process.
TALLOW: The rendered fat of animals that is white and almost tasteless when
pure, composed of glycerides of fatty acids containing a large proportion
of palmitic acid and stearic acid, and that is used chiefly in making
soap, glycerol, margarine, candles, and lubricants.
TAPPING: Removing molten metal from a furnace.
TEMPERATURE INVERSION: An atmospheric layer in which temperature increases
with altitude. The principal characteristic of a temperature inversion is
its marked static stability, so that very little turbulent exchange can
occur within it (see also inversion).
THEORETICAL AIR: The exact amount of air (stoichiometric air) required to sup-
ply the oxygen necessary for the complete combustion of a given quantity
of a specific fuel or refuse.
THERMAL TURBULENCE: Air movement and mixing caused by temperature differences.
TOPPED CRUDE PETROLEUM: A residual product remaining after the removal, by
distillation, of an appreciable quantity of the more volatile components
of crude petroleum.
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G.29
TOPPING: The distillation of crude oil to remove light fractions only.
TOTAL REDUCED SULFUR COMPOUNDS (TRS}: Malodorous gases produced in the wood
pulping industry exclusive of sulfur oxides. TRS usually includes hydro-
gen sulf ide (tt S) , methyl -mercaptan (p^SK) , dimethyl sulf ide (C!L,SCH3) ,
and dimethyl disulfide CCH-jSSCH^) . The concentration of TRS is usually
expressed as H2S regardless of the constituent compounds.
TURBULENCE: Atmospheric motions which produce a thorough horizontal and verti-
cal mixing of the air.
TURNAROUND: The time between shutting down and starting up of process equip-
ment for repair or maintenance.
TUYERES: Openings or nozzles in a metallurgical furnace through which, air is
blown as part of the extraction or refining process.
TWADDELL DEGREES (°TW): A measure of acid density and strength:
°W= sp. gr. (60°/60°F) - 1
0.005
Each twaddell degree corresponds to a specific gravity interval of 0.005.
ULTIMATE ANALYSIS (OF COAL) : Contains the following, expressed in percent by
weight :
Carbon
Hydrogen
Sulfur
Oxygen
Nitrogen
Moisture
Ash
(C) %
/TT \
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G.30
UNIT PROCESS: 1. Reactions where raw materials undergo chemical change. 2.
See unit operation (2).
UREA FORMS: A urea-formaldehyde reaction product that contains more than one
molecule of urea per molecule of formaldehyde.
VACUUM JET (STEAM JET EJECTOR): A fluid nozzle that discharges a high velocity
jet stream across a section chamber that is connected to the equipment to
be evacuated. The gas in the chamber is entrained by the jet stream.
VAPOR: The gaseous phase of a substance that generally exists as a liquid or
solid at room temperature.
VAPOR PLUME: The stack effluent consisting of flue gas made visible by con-
densed water droplets or mist.
VAPOR RECOVERY SYSTEM: System used in petroleum refining for separating a
mixed charge of miscellaneous gases and gasolines into desired intermedi-
ates for further processing.
VENTURI SCRUBBER: A type of high energy scrubber in which the waste gases pass
through a tapered restriction (yenturi) and impact with low-pressure water.
Gas velocities at the restriction are from 15,000 to 20,000 fpm and pres-
sure drops from 10 to 70 inches water gage.
VISBREAKING: Viscosity breaking; lowering or "breaking" the viscosity of resi-
dual oil by cracking at relatively low temperatures.
VISIBILITY: In United States weather observing practice, the greatest distance
in a given direction at which it is just possible to see and identify with
the unaided eye (a) i*1 the daytime, a prominent dark object against the
sky at the horizon, and (J>) at night, a known, preferably unfocused,
moderately intense light source. After visibilities have been determined
around the entire horizon circle, they are resolved into a single value
of prevailing visibility for reporting purpose.
VISIBLE EMISSION: An emission of air pollutants greater than 5 percent opacity
or 1/4 Ringelmann.
VOLATILE OR VOLATILE MATTER: 1. The gasoline constituents, that can be driven
off liquids and solids by the application of heat. 2. Specifically for
coal, that portion which is driven off in gas or vapor form when coal is
subjected to a standardized temperature test.
VOLATILE ORGANIC COMPOUNDS: Any compound containing carbon and hydrogen or
containing carbon and hydrogen in combination with any other element which
has a vapor pressure of 1.5 pounds per square inch absolute or greater
under actual storage conditions.
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G.31
W-X-Y-Z
WASTE HEAT BOILERS: Boilers which utilize the heat of exhaust gas or process
gas to generate steam or to heat water.
WEAK WASH: In wood pulping, a liquid stream in the kraft process which results
from washing of the lime mud.
WET COLLECTORS: Devices which use a variety of methods to wet the contaminant
particles in order to remove them from the gas stream (see scrubbers).
WET FILTERS: A spray chamber with filter pads composed of glass fibers, knit-
ted wire mesh, or other fibrous materials. The dust is collected on the
filter pads.
WHITE LIQUOR: Cooking liquid used in the wood pulping industry. Kraft process:
consists of approximately 1/3 sodium sulfide (Na S) and 2/3 sodium hydroxide
(NaOH) . Sulfite process: consists of sulfurous acid plus one of the fol-
lowing: calcium bisulfite, sodium bisulfite, magnesium bisulfite, or
ammonium bisulfite.
tT U. S. GOVERNMENT PRINTING OFFICE: 1973 746766/4134
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