EPA-450/3-75-034
March 1975
MANPOWER PLANNING MODEL
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
.'.'.*"* i
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EPA-4 50/3-75-034
MANPOWER PLANNING MODEL
by
David A. Lynn and Gordon L. Deane
GCA Corporation/GCA Technology Division
Bedford, Massachusetts
Contract Nos. 68-02-0041, Task Order 24
and 68-02-1376, Task Order 16
EPA Project Officers: Fred H. Renner and John I. Eagles
Prepared for
ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, N. C. 27711
March 1975
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This report is issued by the Environmental Protection Agency to report
technical data of interest to a limited number of readers. Copies are
available free of charge to Federal employees, current contractors
and grantees, and nonprofit organizationss - as supplies permit - from
the Air Pollution Technical Information Center, Environmental Protection
Agency, Research Triangle Park, North Carolina 27711; or, for a
fee, from the National Technical Information Service, 5285 Port Royal
Road, Springfield, Virginia 22161.
This report was furnished to the Environmental Protection Agency by
GCA Corporation, Bedford, Mass. , in fulfillment of Contract Nos. 68-02-
0041, Task Order 24 and 68-;02-1376, Task Order 16. The contents of
this report are reproduced herein as received from GCA Corporation.
The opinions, findings, and conclusions expressed are those of the author
and not necessarily those of the Environmental Protection Agency. Mention
of company or product names is not to be considered as an endorsement
by the Environmental Protection Agency.
Publication No. EPA-450/3-75-034
11
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CONTENTS
Page
Disclaimer ii
List of Figures iv
List of Tables v
Sections
I INTRODUCTION AND SUMMARY 1
II DATA BASE DEVELOPMENT 7
III MODEL DEVELOPMENT 31
IV INITIAL MODEL APPLICATION 109
V CONCLUSIONS AND RECOMMENDATIONS 121
Appendices
A ANNOTATED BIBLIOGRAPHY 129
B AGENCY VISIT QUESTIONNAIRE . 141
iii
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FIGURES
No. Page
1 Field Operation of Monitoring Equipment (Hi-Vols) 37
2 Calibration and Maintenance of Monitoring Equipment
(Hi-Vols) 41
3 Sample Preparation (Hi-Vol Filters) 46
4 Sample Analysis (Hi-Vol Filters) 50
5 Data Handling 53
i
6 Travel Time for Monitoring 59
7 Data Analysis 62
8 Program Management 96
9 Control Strategy and Regulation Development . 99
iv
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TABLES
No.
1 Typical Existing List of Agency Activities 10
2 Final Activity List Used in Model 11
3 Air Pollution Control Agencies Visited - 20
4 Field Operation of Monitoring Equipment Man-Hours Per
Cycle for Each Sampler Type (Number of Samplers in
Parentheses) 36
5 Calibration and Maintenance of Monitoring Equipment
Man-Years per Year for Each Sampler Type (Number of
Samplers in Parentheses) 40
6 Sample Preparation In Man-Years for Each Sampler Type
(Number of Samples per Year in Parentheses) 45
7 Sample Analysis In Man-Years for Each Sensor (Number
of Samples per Year in Parentheses) 49
8 Monitoring Network Design and Planning (Time in
Man-Years) 56
9 Final List of Source Categories Used in Stationary
Source Matrix 66
10 Aggregation of SCC's Into 23 Source Type Categories
for Model . 69
11 Aggregate Manpower by Activity from Agency Visits 75
12 Number of SCC's in NEDS Data Base by 23 Source Type
Categories 76
13 Empirical Data From Agency B on Manpower by Source
Type for Plan Review and Permit Systems 77
14 Summary of Data in Response to Questions on
Inspections 80
15 Source Surveillance Manpower Breakdown by Activity
From Agency B 82
16 Premise-Based Manpower Factors for Stationary Source
Activities Time (Hours) per Unit Performance per
Premise 84
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TABLES (continued)
No.
17 SCC-Based Manpower Factors for Stationary Source
Activities Time (Hours) per Unit Performance per SCC 85
18 Proportional Applicability Factors for Stationary
Source Activities Percentage of Sources (SCCs)
Subject to Activity 86
19 Frequency Factors for Stationary Source Activities
Number of Performances per Year 88
20 Data Relative to Complaint Investigation and Small-
Source Enforcement 89
21 Data Relative to the Review of Development Plans 91
22 Factors for Estimating Manpower Needed for Inspection
Program 93
23 Data Relative to Estimating State-Local Liaison Manpower 102
24 Data Relative to Training Activities 103
25 Data Relative to Estimating Manpower Spent in
Professional Activities 105
26 Data Relative to Estimating Manpower Spent in Public
Information Activities - 107
27 Data Relative to Estimating Library Manpower 108
28 Ratios of Clerical Support to Professional Staff 108
29 Number of Samplers for Each State Agency, From the Visit
and in the Model 116
30 Comparison of Different Projected Manpower Requirements
for Monitoring Oriented Activities (In Man-Years) 118
31 Comparison of Projected Manpower Requirements for
Stationary Source-Oriented Activities 120
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SECTION I
INTRODUCTION AND SUMMARY
This report presents a manpower planning model developed by GCA/
Technology Division for the Control Programs Development Division of
EPA. The model is a computerized system designed to estimate the man-
power requirements of nonfederal air pollution control (APC) agencies
and thereby to serve as a planning tool for projecting the effects on
manpower levels of various policy options and other decisions.
MODEL DEVELOPMENT PERSPECTIVE
This model is intended to build upon and to replace the simpler model
in current use, which was developed, over a number of years, from an
original DHEW-NAPCA study in the late 1960's. That initial study made
use of experience from the major agencies in existence at the time to
project manpower requirements for each of 17 categories of agency
activities. The projections were based on empirical information
relating the manpower of an agency to several economic-demographic
characteristics of the geographic region within which the agency had
responsibility - specifically population, land area, number of manu-
facturing establishments, and the rate of new capital expenditures for
industrial plants.
Since the development of the first manpower model, several changes in
the philosophy of air pollution control have taken place. The Clean
Air Act placed primary program responsibility on the states, and there-
fore on the state agencies, whereas formerly the most active programs
had been carried out by the local agencies in the large urban areas.
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When the first model was formulated, the nature of the typical control
program was necessarily a matter of assumption; it was assumed, for
instance, that all agencies would operate complete construction and
operating permit systems. Subsequently, the approach in some agencies
has been to work with no permit system, and other agencies are working
with only one of the two systems. In other areas, such as monitoring,
minimum program standards were developed and set forth by EPA. When
possible, these concerns were met by making modifications to the model.
Ultimately, however, continuing experience with air pollution control
programs unavoidably raised concerns about the model that could not
easily be accommodated by adjustments within the existing structure.
Consequently, it was decided to undertake the development of a wholly
new model, based on newly-gathered data from a larger group of agencies;
the model described herein is the result of that effort.
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The aspects of the existing model that had raised questions fall
generally into one of two types. Some of the existing predictive re-
lationships were becoming less applicable, largely because agency
practices were changing (such as the decreased emphasis on field pa-
trol), and because of regional differences in the applicability of
relationships that were developed from urban agencies' experience (such
as the extra time consumed in travel in sparsely-developed parts of
the country). Beyond this, it seemed an appropriate time to undertake
the effort because there were a growing number of relatively-new
agency functions that were not provided for in the existing model -
functions such as transportation control planning, "indirect source"
review, air quality maintenance, and so on. And a final requirement
of the new model was that it be computerized; this would provide
greater usefulness of the model and would also permit greater sophisti-
cation in detail and complexity than was possible with manual calcula-
t ions» '.
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OVERVIEW OF STUDY APPROACH
As had been done before, the relationships to be formulated for use in
the model were to be based on empirical information determined from
the experience of existing agencies. The two primary aspects of such
an effort are the development of the empirical information and the
formulation of the relationships to be used. Both of these were given
extensive consideration, as is discussed subsequently. However, in
order to achieve, the maximum reliability and utility of the data to b^
gathered, special attention was given to the data gathering process,
the delineation of the activities for which information was sought,
the selection of the agencies to be visited, and the format and con-
duct of the visits themselves.
The selecting and defining of activities was an iterative process,
thoroughly involving EPA staff members, aimed at ensuring that all
current and potential functions of a nonfederal control agency were
included, and that the definitions of the activities were clear and
unambiguous. This effort resulted in a comprehensive listing of 72
activities categorized according to whether they were expected to be
predicted from a relationship dependent on the monitoring network, on
the number of pollutant sources in the agency's jurisdiction, or on
some other parameter, such as those support activities which are func-
tions of the overall size of the agency staff.
As there were constraints on the number of agencies that could be con-
tacted in the course of the study, the selection of the agencies to
be visited was also extremely important. With the increased emphasis
on the role of the States in air pollution control, seven state and two
local APC agencies were chosen for review. All of these agencies
were among those considered by the EPA Regional offices to be doing
an overall adequate job. The final selection of these agencies, from a
larger list, was made with regard to the characteristics of each agency
and its jurisdiction to help provide a balanced view in the data
gathered.
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The actual conduct of the visits to the agencies relied heavily upon
a questionnaire-style data form developed for use in the visits. The
questionnaire defined each activity, to the exclusion of other similar
or related ones, and asked questions pertaining to the total manpower
used in this activity, its adequacy, reasons for changes, etc; the
questions were directed to the senior person in each agency immediately
familiar with the specific activities under consideration.
Following the study visits, the empirical data was analyzed to for-
mulate the predictive relationships. Although care had been taken in
the data gathering to achieve the best available information, it
proved necessary to exercise a certain amount of judgement in the
interpretation of the data; for instance, there was significant re-
arrangement of the activity list, usually by combining separate
activities to larger ones. The types of predictive relationships that
evolved ranged from simple linear or directly proportional ones, to
very nonlinear expressions, usually as a result of economics of scale,
to step-type functions which provided increments of manpower based on
the number and characteristics of the Air Quality Control Regions
(AQCR's) in the state.
The model which resulted from these efforts consists of three major
sets of such predictive relationships, corresponding to the three
major groupings of agency activities. The first group of air quality
monitoring-related activities includes five activities applied to 12
types of sensors in a matrix format, and a few additional activities
not related directly to the number of sensors. The second group, the
source-related activities, involves six activities applied to 23
source-type categories in a matrix, plus others not directly based on
the number of sources. The third major group, administrative and
support activities, is comprised of 12 specific activities involving
management, training, and clerical support functions. The projections
for these activities are based on the manpower estimates made for the
activities in the first two groups. There are in addition a few
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activities which do not fit into this three-group structure because
they are most appropriately- estimated from other predictor variables
(e.g., travel time, estimated in part from land area); these are esti-
mated wherever appropriate in the model and are discussed correspond-
ingly in the text.
The computer application of the model is designed to provide estimates
of manpower by State, with EPA Regional and National summaries. Basic
calculations are made for each separate AQCR or state portion of an
AQCR, based on AQCR-level information entered into the program from an
input file and State-level information built into the program by data
initialization (DATA) statements. The majority of the manpower projec-
tions are made at this level, with others made at the State level, and
some made at both levels, depending on the nature of the relationships
involved. The AQCR-level results are first accumulated into State
totals, and when a State is completed, the additional activities are
estimated and the manpower included, and then a detailed State summary
is printed. EPA Regional and National summaries are accumulated and
printed in turn; no additional activities are considered at the EPA
Regional or National levels.
SUMMARY ASSESSMENT
In general, the gathering of the empirical information and the develop-
ment of projection relationships proceeded satisfactorily, and the re-
sulting model appears to be an adequate tool, both for projecting aggre-
gate manpower needs and for use in studying the impact of proposed
hypothetical changes in agency practice.
The portion of the model that is least firm J,s the set of relation-
ships concerning stationary source surveillance and enforcement
activities, due to some inadequacies in the information obtained.
Another area where less-than-optimum information and relationships
were obtained is in the often-intricate interactions between state
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and local agencies, although this area involves only small amounts of
manpower. The only difficulty that is expected to significantly
affect the on-going usefulness and accuracy of the model is the
quality and format of the data bases on which it operates, particularly
the NEDS file of emission sources. The most urgent recommendations
for further development involves ameliorating this problem.
STRUCTURE OF REPORT
The subsequent sections of this report present the complete develop-
ment of the model and discuss the various considerations inherent in
this development^ the model itself and its applications. The report
is organized as follows:
Section II - The process of the development of the empir-
ical data base is presented, outlining the
methodology of the study, the delineation of
activities and the development of the ques-
tionnaire used in the agency visits; the con-
duct of the agency interviews, including the
process of selecting the agencies; and a
general discussion of the handling and inter-
pretation of the data gathered.
Section III - This section discusses in detail the develop-
ment of the actual activity projection re-
lationships used in the model and the inter-
actions which occur within the model structure;
i.e. data inputs and the model operations.
Section IV - The data inputs and results of a trial applica-
tion are described and analyzed in this section
to provide a better understanding of the out-
puts expected and a rough validation of the
model.
Section V - An overall assessment of the data-gathering and
model development process, with some recommen-
dations for further development and future
improvements in the data base on which the model
operates.
Appendices
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SECTION II
DATA BASE DEVELOPMENT
The purpose of the model developed under this study effort is to utilize
predictive equations that project the manpower needed for various activ-
ities of nonfederal air pollution control agencies. These predictive
equations were to be based on appropriate predictor variables for which
data was readily available and could be input. The relationships uti-
lized in the equations were to be derived from empirical information
determined from the experience of existing agencies.
From the outset, there were several elements of the design of this study
which needed to be properly addressed before the determination of the
predictive relationships could be made: the study methodology, the se-
lection of agencies to be visited, and the interpretation of the data
collected. The approach and the considerations involved in handling
these elements are discussed in this section.
STUDY METHODOLOGY
Activity Delineation
The initial task in the study was the development of a comprehensive
list of the functional activities of nonfederal air pollution control
agencies, with their corresponding definitions. This task was felt to
be an integral part of the study methodology as the selection and defi-
nitions of the activities, as well as the resvilting structure, provide
the basis from which quantitative data on manpower requirements would
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be sought from the various agencies. The information gathered on these
activities, together with a base of other data on parameters relevant
to the agencies and their jurisdictions, are what were used to formulate
the quantitative manpower planning model used for projecting agency
staffing requirements.
The selection of a functional activity framework for activity delinea-
tion, rather than a people-oriented occupational category framework, was
made because it was felt that the more abstract functional approach would
be less constrained by the existing personnel structure of the agencies
and would be more flexible for any new responsibility and any future
decisions regarding these responsibilities. Nonetheless, the underlying
awareness that real people will perform the activities did have some
influence on the way the activities were defined. This approach to the
activity delineation therefore provides a functional rather than an oc-
cupational view of the manpower requirements of an air pollution con-
trol agency and decisions on staffing can be more accurately made by
matching the functional requirements of the agency with the applicable
experience of potential employees.
Activity Determination - While the determination of activities to be
included in this study and the defining of such activities are an inte-
grated process, to some extent, the selection of the activities can be
considered separately. To ensure a comprehensive listing of the activ-
ities of nonfederal air pollution control (APC) agencies, the task of
compiling the list was approached by considering both those activities
that have traditionally been performed by almost all APC agencies,
termed "current" activities, and those that arise primarily from rela-
tively recent developments in national pollution control policy, termed
"anticipated" activities. As expected, the division between the two
classes was not distinct; in particular, there are a number of activities
performed by some agencies for some time past that are recommended to
other agencies for the future.
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In general, there was little disagreement over the list of current
activities, and they were compiled on the basis of general knowledge
and a search of the literature. There was, in contrast, little readily-
available material and little detailed consensus on what further activ-
ities should be anticipated as a result of recent developments. The
approach to including these activities was to first identify those
general areas of new agency responsibility, primarily those defined by
federal regulation, then to attempt to develop a detailed list, of activ-
ities needed for.the satisfactory accomplishment of these areas of re-
sponsibility. The reasonableness of this latter list was tested, where
possible, against the experience of those agencies that have conducted
such activities; facilitating such consultation and feedback was in
fact a major purpose in the questionnaire development as discussed later.
Current agency activities - The definition of a list" of traditional, or
currently-performed, agency activities was primarily based on general
knowledge in the field and a literature search, conducted on the APTIC
data base. The annotated Bibliography in Appendix A lists the sources
most useful for the entire manpower planning model study. The principal
sources used in defining the current agency activity list were the
following:
1. Rifkin, K. I. et al. (ASA). Task Analysis of State and
Local Air Pollution Control Agencies and Development of
Staffing Guidelines. Manpower Development Staff, Environ-
mental Protection Agency, Research Triangle Park, North
Carolina. Seven volumes and Technical Report. November
1972.
2. Eagles, John. Method for Estimating Manpower Resources
for Air Pollution Control. Environmental Protection
Agency, Research Triangle Park, North Carolina. July
1972. 14 pages.
3. Stein, Arnold. Guide to Engineering Permit Processing.
Environmental Protection Agency, Research Triangle Park,
North Carolina. APTD-1164. July 1972. 368 pages.
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4. Jutze, George A. Guidelines for Technical Services of
a State Air Pollution Control Agency. Office of Air
Programs, Stationary Source Pollution Control Programs,
Environmental Protection Agency, Research Triangle Park,
North Carolina. APTD-1347. November 1972. 302 pages.
5. Several State Implementation Plans. Primarily those of
New York (Transportation), North Carolina, Maryland,
Colorado, and Connecticut.
The level of detail and the scope of the activities included in these
references is typified by the list of agency activities given in
Table 1. This list provided the initial delineation of current agency
activities, with further subdivisions then being made where they
seemed warranted for ultimate projection purposes. For comparison,
the final list used in the model is in Table 2.
Table 1. TYPICAL EXISTING LIST OF AGENCY ACTIVITIES
Management:
Policy and administration
Training
Liaison and community relations
Clerical support
Engineering:
Permit system operations
Source testing and emissions estimates
Engineering reports
Miscellaneous
Clerical support
Enforcement:
Inspections and schedule monitoring
Complaint handling and field patrol
Training
Clerical support
Technical Services:
Laboratory operations
Monitoring network operations
Data processing
Special projects
Clerical support
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Table 2. FINAL ACTIVITY LIST USED IN MODEL
MONITORING-ORIENTED ACTIVITIES
Field operation
Calibration and maintenance
Sample preparation
Sample analysis
Data handling
SOURCE-ORIENTED ACTIVITIES
Stationary source inspection
Stationary source testing
Observe stack testing
Complaint investigation and
small source enforcement
Tax exemption certification
Review of development plans
Travel time for enforcement
MANAGEMENT AND SUPPORT ACTIVITIES
Program management
Strategy and regulation
development
Interstate liaison
Local APC agency liaison
In-house training
EPA training
Network design and planning
Special monitoring studies
Travel time for monitoring
Laboratory quality control
Air quality data analysis
Compliance schedule monitoring
Formal legal action
Equipment plan review
Mobile source inventory and TCP
Motor vehicle inspection
Oversee motor vehicle inspection
Episode prevention
Graduate school training
Professional activities
Public information
Library and archives
Clerical
Administrative management
Anticipated agency activities - The effort of defining those agency
activities that are recommended or anticipated in the future was ap-
proached by first considering the broad areas of new responsibilities
thrust upon or undertaken by the agencies> largely as these responsi-
bilities are expressed in federal regulations relating to agency ac-
tivities. Specifically, this approach was based on the uncodified
Federal Register entries, which offer related amendments in a single
source, and with the typical preamble, often offer a deeper insight
into the intent of the regulations. Of the many promulgations and
proposed rulemaking entries, those were selected that generally embody
the new areas of agency responsibility with which we were concerned:
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Transportation Controls and Land Use Planning
Stationary Source Review (direct, indirect emissions)
Periodic Reports to Environmental Protection Agency
Environmental and Economic Impact Statements
Prevention of Significant Deterioration
Supplementary (Intermittent) Control Systems
Air Quality Maintenance Planning was not considered as a separately
identifiable set of SIP revisions because it is expected to consist
of extensions of the normal planning responsibilities involved in the
original SIP and the transportation planning and, as such, would not
influence the delineation of the activities.
Each of these areas was surveyed to detail its FR entry listing, the
general thrust of the policy, the inherent responsibilities, and the
implications for control agency activities.
Organization of Activity List - In considering the various possible
ways of grouping or organizing the agency activities into a small number
of meaningful categories, the obvious options were to utilize the cat-
egories of Table 1 or to develop new ones specifically for the model.
The traditional categories noted in Table 1 have developed historically,
and are almost universally used, with perhaps slight variations in
phrasing. They are fairly closely identified with organization units
in many agencies, as they have followed the changing roles of the agen-
cies over the years. The advantages of such a structure would be all
the advantages usually associated with traditional patterns recogni-
tion, familiarity, etc. Similarly, a disadvantage would be the lack of
recognition of the emerging new areas of agency activities. Another
disadvantage would be the unwieldly growth of the "Technical Services"
category. This category has always included the newer activities, being
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usefully vague, but to now further add the wide variety of anticipated
activities would severely strain the logical arrangement.
The other option of completely revising the categories was the approach
ultimately chosen. The decision was to organize the activities accord-
ing to how they relate to the specific quantitative aspects of a con-
trol program, especially source control and ambient air monitoring.
In such an organization, activities would be grouped to reflect the
functions involved in each of these categories and further breakdown
would be provided by considering the different elements involved in
each of the categories, such as different types of monitoring equipment,
in an array versus the related functional activities (e.g., sample
preparation, etc.). The primary advantages of this approach are that
new agency responsibilities can be interpreted in the light of the in-
cremental additions they cause in the various functional areas (such
as a certain number of additional monitoring sites), and that predic-
tive relationships based on such tangible factors were considered more
likely to be reliable than relationships based on indirect variables,
such as population or economic activity. The primary disadvantage of
this structure is that the data bases needed for such an approach,
especially data on the numbers of stationary sources of various types,
have not matured to the point that they permit good absolute estimates.
The structure that was finally chosen organizes the agency activities
into three groups a matrix of source-oriented activities versus
source type, a matrix of monitoring-oriented activities versus sensor
type, and a simple list of other activities. This approach kept the
list of activities to a manageable size (72), and the use of matrices
over monitor and source types also permits summaries by these cate-
gories, a useful way to consider hypothetical situations.
As anticipated, it did develop that the agencies visited were unable
to provide information at the level of detail of the activity list
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prepared, so that it was adjusted to provide the condensed list pre-
sented in Table 2; the overall structure of having three groups, two
of them matrices, however, did prove appropriate and was preserved.
Activity Definitions - As is necessary with any delineation and cate-
gorization of functions, the activities were defined concurrent to the
above tasks. Careful attention was paid to each definition to ensure
that there would be no overlap or missing areas between activities or
any misunderstanding as to exactly what particular items were under
consideration.
The process of defining the activities included several iterations with
much input and review by the EPA Project Officer and others in the Con-
trol Programs Development Division (CPDD) of the Office of Air Quality
Planning and Standards (QAQPS). The result of this effort was that the
definitions more accurately reflected the functional characteristics of
the activities rather than the occupational ones, a format deemed more
desirable as discussed above. Although previous delineations of activ-
ities were considered, the finer breakdown and functional direction of
the study meant that the definitions were either prepared afresh or
carefully reexamined and reconstructed to reflect the scope of the study.
The definitions were not meant to be exact explanations of all of the
details which may be involved in the performance of each activity, as
this would make them harder to accept due to the different approaches
to problems by the various agencies. Instead, they were of a more
exclusionary nature, outlining the activity under consideration by
bordering it with other similar activities and specifically excluding
those activities which may have been suggested by the activity heading
but were, for the purpose of the study, to be considered separately.
While this may not provide the best form of conveying the activity to
the public, it helps a person engaged in a set of activities Identify
exactly what components are being discussed. As a part of the ques-
tionnaire, in which these definitions were to be incorporated, it has
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the added advantage of requiring the reader to review all related ac-
tivities, and their subsequent questions, before proceeding to answer
any in the set.
Questionnaire Development
In order to apply the study methodology in the most systematic manner,
an extensive questionnaire was developed for use in the study visits to
the agencies. This questionnaire was formulated primarily to be used
as a tool for the investigator to ensure that all relevant questions
would be asked of each agency in the same fashion. In addition, several
copies of the questionnaire were mailed to all agencies prior to the
visit so that requested information not readily available could be
compiled in time for the visit.
Objective of Questionnaire - The questionnaire was decided on as the
best method of obtaining the maximum amount of detailed information in
the shortest possible time, thereby producing less disruption of the
normal activities of the AFC agencies. This was used instead of long
site visits, in which one or two GCA personnel would spend a week at
each agency reviewing the actual activities, which was suggested in
the course of the study. It was felt that the added time spent in
careful questionnaire development would be much smaller than the man-
power needed to conduct the more intensive visits.
As already mentioned, the questionnaire was meant to serve as a tool
for the interviewer, especially useful for providing the complete gamut
of questions that needed to be asked. Some thought was given to having
the questionnaire developed to the stage of a public opinion poll where-
by the questions could be asked strictly from the questionnaire with no
interpretation or explanation; however, this option was not pursued as
it was felt to be not pertinent to this type of survey, where a pro-
fessional's opinion was being sought.
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Questionnaire Structure - The type of questionnaire which was eventually
decided upon was one which was aimed at exactly defining each activity
under consideration through incorporation of the above definitions and
then determining the manpower needed to perform such an activity through
a slightly less structural format than would be necessary in a public
opinion poll. The general format of the questions would then be to ask
who or how many people were engaged in each activity, the percentage of
each person's time involved, and the adequacy of the current effort.
Questions regarding how the interviewee expected this effort to change
over the next 5 years and the reasons for these changes were also to be
included. These latter questions were to help primarily in the identifi-
cation of predictor variables and the formulation of the manpower pre-
diction relationships; the answers were also expected to provide an in-
sight into how the model should be structured to be able to incorporate
future developments.
Again, this was an iterative process with continuing review and input
from the EPA Project Officer and other staff in the CPDD. The final
result of these efforts was a highly developed questionnaire with ques-
tions relating directly to the specific details involved in each .activ-
ity, asking not only about the manpower requirements but the procedures
followed and tasks performed by the agencies. The structure was such
that the information was requested at the highest degree .of .resolution,
with provisions for collecting the data at a lower level of detail if
necessary. The reader is referred to the questionnaire in Appendix B
for further understanding of the format. The final step in the ques-
tionnaire development was a pilot application in one of the State air pol-
lution control agencies. This involved a 2-day meeting between the
GGA personnel and CPDD Project Officer who would be engaged in the
study visits and the director and certain members of the agency. The
project and the APC agency's activities were discussed at length and the
questionnaire was used as it was expected to be in the following
interviews.
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While the trial application, especially through the general activity
discussion, identified a .few missing activities, which were subsequently
incorporated, it did not suggest that any significant changes were
needed in the structure of the questionnaire or the suggested format
of the interviews.
AGENCY INTERVIEWS
Although much preliminary data had already been gathered in the course
of the development of the study methodology, the empirical data base
for utilization in the model formulation was to be obtained through
interviews with specific non-federal air pollution control agencies.
In compliance with the Office of Management and Budget (OMB) regulations
and in consideration of the available time frame, the number of agencies
to be interviewed was limited to nine. Since the resultant data pro-
jections can be no better than the aggregate empirical information used
to produce them, the selection of the agencies and the actual conduct
of the meetings were of paramount importance.
Agency Selection
The previous manpower planning models had been necessarily rooted in
local, urban-area agencies, because they were the only source of accu-
mulated experience available at the time. More recently, of course,
responsibility under the Federal Clean Air Act has been placed clearly
with the states, to be administered through the Air Quality Control Re-
gions (AQCR's).
Consequently, it was determined that the focus of the new model should
be on sta.te agencies and their total responsibility within their geo-
graphic boundaries, regardless of whether the activities directed at
meeting those responsibilities were conducted by state, regional, or
local agencies. Accordingly, the list of agencies to be visited was
to include seven state agencies and only two local agencies, with the
, ,17
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two locals being within the seven states and selected to reflect good
state-local integration and cooperation.
The seven state and two local agencies visited were not selected via a
randomized procedure, but were selected deliberately in full knowledge
of their size, philosophy, their strong and weak points, and the nature
of the area within which they have responsibility, The reason for this
is because the intent of the study was not to project manpower utiliza-
tion as it actually occurs, that is, to use a sample of agencies to
estimate "national average manpower utilization" or some such parameter;
rather, the intent was to project manpower utilization as It should be,
that is, to estimate the manpower needed to operate an agency in an
adequate fashion, meeting all its responsibilities in a satisfactory
manner. Consequently, the agencies chosen were selected to provide ah
appropriate mixture from within a set of agencies that had been selected
as meeting the adequacy criterion.
The impact that this selection criterion had on the total manpower levels
projected as a result of the model cannot be estimated directly from
this study. It would be necessary to conduct a second, similar study
using agencies randomly selected in terms of adequacy. However, some
idea of the total manpower impact may be derived from comparing the
total manpower requirements on a national level with current air pol-
lution control personnel staffing levels. The advantage of choosing
agencies judged to be performing their activities adequately, as opposed
to a random selection, is in avoiding those agencies which overemphasize
or are overstaffed in particular areas and those which are not, for one
reason or another, currently carrying on an appropriate level of effort.
This further aids in the formulation of reasonable manpower projection
relationships. .
As the initial step in agency selection, the EPA Project Officer in
CPDD at Research Triangle Park, North Carolina, requested from the
18
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program advisors in each EPA Regional Office a list of agencies that
were viewed as meeting the adequacy criterion. Additional criteria
for selection of the agencies were to be the following:
1. The agency's program should be comprehensive, that
is, it should incorporate a wide range of services
and activities. Such comprehensive agencies would
offer the most efficient data collection in that
all of the activities of interest could be covered
with the fewest agency visits.
2. Each of the activities of the agency should be
performed thoroughly, that is, the tasks should
be performed at an adequate level of detail.
3. The agency's activities and methods should be
relatively effective in accomplishing the goals
of air pollution control.
Roughly two dozen agencies were so suggested by the Regional Offices
and from this list the CPDD Project Officer selected the agencies
to be visited. This final selection was done with the intent of
providing a cross sectional range of agencies. The following fac-
tors were considered in determining the best possible balance of
agency characteristics:
» nature of pollution problem in jurisdiction
geographical size of jurisdiction
climate and geographic location
age and structure of agency
The agencies eventually selected for interviews are coded A to I for iden-
tification herein; certain of the characteristics of their jurisdictions
are listed in Table 3. .
19
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Table 3. AIR POLLUTION CONTROL AGENCIES VISITED
Agency
10
O
Pollution
problem
Hotor vehicles - CO, Ox,
NO;
Oil - SO2, TSP
Oil and coal - S02, TSP
Hotor vehicles - CO, Ox,
Oil - TSP, S02
Hotor vehicles - CO, Ox,
Motor vehicles - CO, OK
Fugitive dust - TSP
Gas, some .coal
Coal - TSP, some S02
Hotor vehicles - CO, Ox,
Fugitive dust - TSP
gas. some coal
Partlculates, aoae SOW,
Oil CoBhustlon - TSP.
SO*
Motor vehicles - Ox,
Fugitive dust - TSP
Characteristics
Region
Industrial/suburban,
cold, ocean, 6070 dd,a
14 in.b
Industrial, suburb,
rural, cold, midwest
5690 dd,a 37 in.b
Industrial/rural,
shipping, cool .- ocean
4790 dd,» 43 ln.b
Tourist, agricultural,
cold-warm, high
altitude 6130 dd,a 14 in.b
Mining, heavy industry,
rural, cold, 4420 dd,a
Tourist, warm, dry
4390 dd,a 9 in.b
Agricultural, no big
city or industry, cold,
6450 dd,a 31 in.b
Suburban area, cool,
light industry
4790 dd,* 43 in.b
Metropolitan area,
growth-oriented,
warm, dry, 4390 dd,a
9 in.b
Agency
Separate environmental
agency, new and fast
growing
Separate environmental
agency, new but with
older city agency
In health department,
older but progressive,
comprehensive program
In health department,
older but progressive,
commission
Separate air pollution
agency, older, traditional
Separate environmental
agency, new
Separate environmental
agency, new, no older
urban APC agencies
In health department,
new, growing
In health department,
new, .growing
Local
agencies
12 - screen permit
applications
11 - help in
monitoring and
enforcement
10 - own programs,
enforcement coor-
dinate with state
7 - help in
monitoring
1 - own program
1 - own program,
part of study
2 - some assistance
in monitoring
Hot -applicable
"Wot applicable
for vajor centrally located city.
Enche* dC'prcclpitatUto for ftjor centrally Ideated city.
-------
Study Visits
Prior to the study visits, the air pollution control agencies were con-
tacted regarding the proposed visit, explaining the purpose and scope of
the study. Several copies of the questionnaire were provided with the
request that, should time allow, the questionnaire be reviewed by the
appropriate personnel so that data, relevant to the study though not
readily available, be assimilated before the interviews were conducted.
This was to serve to shorten the time needed for the study visits and
thereby cause less disruption of the routine operation of the agency;
unfortunately, in only a few instances was sufficient time provided to
allow for more than a preliminary review of the questionnaire.
In addition, this initial contact by GCA requested that information on
the structure of the agency and the positions and responsibilities of
the pertinent AFC agency personnel to be interviewed regarding the work
in their particular division be provided prior to the site visit. This
was to aid the GCA personnel in the understanding of the agency's or-
ganization and in preparing for the meetings and questions. Here again,
the agencies were not always able to respond to the request before the
visit though most of them had this information available when the inter-
viewers arrived.
The study visits were generally conducted by two people from the staff
of GCA and were completed within one normal working day. In addition,
the CPDD Project Officer, and occasionally an EPA Regional Office con-
tact, was present for the interviews. The GCA team,consisted of those
personnel actively engaged in the development of the manpower model and
therefore they were thoroughly familiar with the goals and approaches
of the program. The APC agency personnel interviewed were usually
various division or departmental heads, and the GCA interviewer was
assigned the particular APC personnel based upon the team member's own
area of expertise. To the extent possible, an attempt was made to have
the same person conduct the interviews on the same activities throughout
the study visits to help maintain consistency in data collection.
, 21
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Visit Schedule - The study visits were generally begun with a short
(about 1 hour) meeting to provide ample opportunity for the participants
to get to know each other and the game plan for the day. The CPDD Project
Officer and GCA presented the project, answered questions on it, and
determined the general staffing and budget levels, functional respon-
sibilities, planning and evaluation techniques, etc. of the whole agency.
Any previously obtained information was confirmed at this meeting.
The appropriate GCA personnel then teamed up with the corresponding staff
of the AFC agency for in-depth consultations (1-2 hours) on the activities
of interest. During this time, general and detailed questions relating
to the various activities were posed as they appeared in the question-
naire although in many cases the flow of the discussion did not follow
the structure outlined in the questionnaire. Thorough notes pertaining
to the individual characteristics of the agency were taken for later
reference and available supporting data and material that appeared to
be helpful in the understanding of the manpower requirements and/or for
use in the later model development were acquired.
i .
Upon conclusion of these interviews, the GCA team reconvened privately
to discuss the answers briefly and to try to determine if any major
holes had been left unfilled. A meeting of the involved personnel was
then reconvened, if possible, to present some summary of the day's ac-
tivities and to try to fill in any of the holes left as a result of
the varying agencies' structures.
Study Visit Data Review
After each study visit, each team member reviewed the data gathered on
the questionnaire to determine the completeness and record any further
impressions not recorded at the time of the interview. General comments
and an evaluation of each data set was completed and attached to these
raw data sheets. Detailed study visit summary sheets were completed for
each agency listing the specific activity, the total manpower requirements
22
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for each activity, and any comments that were made regarding the man-
power level, especially its adequacy or any expected changes. In ad-
dition any holes or discrepancies in the data which were not resolved
before the end of the study visir or which were discovered upon further
review and analysis were noted.
These summary sheets and specific questions regarding the data collected
were sent to each APC agency director, or principle study visit contact,
with the request that the summary sheets be reviewed by the appropriate
staff and the questions answered. In general, the response to this mail-
ing was of little value and where it was deemed important for the model
development, follow-up phone calls were made to ask the specific questions.
EMPIRICAL DATA BASE
The empirical data collected during the interviews with the air pollution
control agencies provided the basis for the determination of the predictor
relationships used in the manpower planning model. Although the inter-
pretation of the data and the resulting relationships are discussed in
detail for each of the activities in Section III of this report, several
characteristics pertaining to the data and the interpretation thereof
were found to be recurrent throughout the analysis process. A review of
the characteristics is felt to be important to provide an understanding
of how the data was handled and thereby set the framework for the dis-
cussions on the specific activities provided in the following section.
Data Completeness
There were two potential problem areas that were inherent in the
data collected the completeness of the data and the exactness
of the manpower estimates and both did in fact prove to be
problems. The handling of both of these problem areas involves,
to a large extent, the final interpretation given to the data
and therefore the resulting relationships. In a real sense, the
23
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completeness of the data can not be separated from the problem of the
data quality; however, the exactness of the data collected was felt to
more severely impact on the interpretation and, as such, is discussed
later under the appropriate heading.
As already mentioned, an appreciable effort was made to ensure the
maximum possible completeness of the data base through careful ques-
tionnaire development, interviews, and follow-up correspondence where
some data appeared to be missing when the interview data was reviewed.
Despite these efforts, it was not possible to obtain data on every
activity from every agency; i.e., nine data points for each activity.
The reasons for this lack of information were normally one of the
following:
The agency did not perform the activity and
could not estimate the manpower require-
ments if it should perform it.
The agency could not separate the activities
to the level they were subdivided by the
questionnaire and therefore the data was
included in some agglomeration of activities.
The agency did not respond directly or in-
directly to the questions on the activity,
especially true of the post-interview
follow-up questions.
In cases where the particular activity was not performed by the AFC
agency and the interviewee could not estimate the total manpower needed
if it was performed, there was little that could be done to establish
a data point so the particular agency was dropped from consideration for
that activity. When the activity was performed but the agency could not
separate out its manpower requirements from some other activities, the
manpower for the individual activities was estimated based upon the aver-
age percentage share given to each activity for the other agencies; how-
ever, where these percentage contributions were not similar among the
other agencies, such a procedure could not be followed. This lack of
comparableness was deemed to be a problem in the exactness of the data
provided and was handled as discussed under the interpretation of data.
24
-------
In a few instances, the data could not be gathered during the study visit
either because the data was not immediately available or the person with
the best knowledge of the manpower requirements was not at the APC agency
during the visit. In the most common case that occurred, laboratory
related services, the data was not available because it was performed
by the state laboratory which was not at the site of the APC agency.
These circumstances dictated follow-up correspondence, both written and
by telephone, which was not always fruitful. The effort applied to
\
gathering the data was proportional to the perceived need of the data
points. For instance, in the case of laboratory services, the data
gathered tended to indicate a high degree of agreement on the time per
sample for the laboratory work and there was no reason to suspect that
there would be any differences found in those states that did not report
this data.
interpretation of Data
The data collected was not, in most cases, in a format which allowed for
the development of predictor relationships without some prior interpre-
tation of the data. One indication of the need to interpret the data
has already been given above in regards to those activities which could
not be discussed separately from others by some agencies. . The other
major reason for interpretation of data was where one or more agencies
presented data which was not consistent with the pattern established
by other agencies or would tend to indicate a relationship contrary to
logical expectations. Explanations of the general considerations involved
in handling those incidents is provided here to provide an overview of
the data handling process. More specific discussions relating to the
individual activities are given in the following section as they are
needed.
Combined Activities - Where the agency was not willing or could not
separate one activity from another or from a related group for manpower
25
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requirements, data was provided as a single manpower level for the com-
bination of activities. In some cases, this single manpower level could
be broken down into the component levels for each activity by reviewing
the percentages attributed to each by other agencies. More often, how-
ever, it was found that, within groups of activities which were related
and for which one or more agencies had difficulty in providing a manpower
breakdown, the data provided for the individual activities were hard to
correlate among the agencies. On the other hand, the combined manpower
requirements for all agencies would usually establish a reasonable
relationship.
Two reasons can be cited for this occurrence: (1) the definitions,
though prepared carefully, still left some room for overlap and inter-
pretation upon the part of the interviewee; and (2) the interviewee,
while having a good idea of the total manpower expended on the general
group of activities, could only guess at the manpower for each one.
This was not felt to reflect any deficiency in the study methodology
but rather these developments were expected to occur to help in the
final formulation and definitions of the activities. Since this specific
problem of combined activities typically arose in those types of activi-
ties which were closely related, it was felt that the resulting agglom-
eration of activities could be made without any loss of specificity in
the final model.
As an example, the largest combinations of activities occurred within
the program management related activities and also within the calibra-
tion and maintenance of monitoring equipment. In this latter case, the
very fine breakdown as to which activities were performed at the site
of the monitor or at the lab or AFC agency and which tasks were considered
maintenance as opposed to calibration was either handled or interpreted
differently by different agencies. However, what was apparent was the
total time spent on this general group of activities was fairly consis-
tent for each monitor. Therefore, it was possible to relate the manpower
26
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to perform the group of activities to the monitor type and the require-
ments of the model; i.e.; to predict changes in manpower with changes
in the monitoring network, were met.
Inconsistent Data - A more common problem in data interpretation was
that there were often inconsistencies among the data collected from the
different agencies. A strict use of the raw data would have either dis-
allowed the possibility of any relationship being developed or provided
relationships that were contrary to logical expectations. It was there-
fore necessary to analyze the data collected, its source, and any rea-
sons for the variations.
The reasons for the inconsistencies were usually the same as those cited
above; i.e., misinterpretation of definition or lack of knowledge as to
the manpower breakdowns requested, with the latter reason being the most
prevalent. Not only was this study requesting information that is not
given much thought (the manpower for specific activities) but also the
detail of the data required, due to the breakdown of activities, .was
much finer than ever considered before.
Therefore, the data review needed to have the following elements of
consideration:
Logicalness - Was each element of data within the range
which could logically be expected?
Comparability - How did the data compare with similar
data collected from the other agencies?
Reliability - Did the interviewee seem sure of the
data he was providing; had such data been prepared
and reviewed by the APC agency before?
Activity Performance - Did the agency appear to do
a more or less complete and thorough job for the
activity; how did they rate their own adequacy of
performance?
Such a review of the data implies that a direct quantitative analytical
approach was not fully appropriate. The review needed to involve the
27
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qualitative and judgmental consideration of the persons who collected
and analyzed the data. .More weighting was given toward those agencies
who had done extensive, detailed analyses of their manpower requirements
and toward those agencies who were determined to be doing a better job
on an individual activity. Where data was illogical or not comparable
with other data provided, the reasons behind these discrepancies were
reviewed and, if no satisfactory explanation could be found, they were
generally given less weight in the determination of the relationships.
Man-Year Equivalents - One of the more minor problems in the interpreta-
tion of data, which deserves mention, was the determination of equiva-
lent units for discussing manpower. While the manpower requirements
for an air pollution control agency are generally discussed in terms of
man-years, the detail of the questions asked generally led to much
smaller units which, when multiplied by the relevant parameters, end up
as man-years in the model. The conversion of these other units to man-
years needed to be based upon the assumptions of a certain number of
hours, days, or man-months to a man-year.
Though some consideration was given to using each agency's interpreta-
tion of a man-year in terms of these other units, this was discarded
as being not open to projection to other agencies and also beyond the
accuracy of the study. With time off for holidays, vacations, and sick
leave varying, it was decided to use a normal 40-hour working wee^ftor
50 weeks in the year so that a man-year was considered to be equivalent
to 2000 man-hours, 250 man-days, or 50 man-weeks. In the cases where
the agencies responded in terms of a man-month, the ratio of 12 man-
months to one man-year was used.
Determination of Relationships
Not wholly separate from the interpretation of the data was the detH^
mination of the predictor relationships based upon the empirical data
base. Obviously, the review of the data for comparability and logicalness
28
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must take into account the relationships expected or being developed,,
This type of judgmental review continues into the determination of the
relationships.
The types of relationships which are dealt with can be broken into the
dichotomy of linear and nonlinear. A linear relationship in this type
of study implies that, no matter how many times the tasks in an indi-
vidual activity are performed, it will always take the same amount of
time to do each task. Such an activity would be the field operation of
monitoring instrument; it takes twice as long to change 50 hi-vol fil-
ters as it does to change 25 filters. A nonlinear relationship implies
that the level at which the activity is performed determines the time to
handle each task in the activity, normally due to efficiencies of scale.
An example of a nonlinear relationship would be data handling where the
more data one handles, the more efficiently one can handle it, especially
as one goes from a manual to an automated handling system as the data
volume grows.
Careful attention was directed toward which relationships are linear
and which are nonlinear in the formulation of the relationships. The
following were considered in determining how a relationship should be
expressed.
Data collected - whether the data indicated a linear
or nonlinear relationship and whether this was logical.
Range of the data collected - whether sufficient informa-
tion was available to determine an expect'ed nonlinear
relationship and the impact of extrapolating a particular
relationship beyond the range of data collected.
Complexity of the relationship which would be needed -
whether the data appeared to warrant a complicated
relationship when a linear one adequately addressed
the manpower within the accuracy of the data.
Range of usage of the relationship - whether a com-
plicated relationship was only pertinent at the end
points of the expected range of usage (especially at
the lower range above which all agencies were expected
to be operating).
29
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SECTION III
MODEL DEVELOPMENT
The predictive relationships which were developed from the empirical
data base provided the final step before the formulation of the equa-
tions and the actual development of the manpower planning model. The
formulation of the equations needs to account for the data inputs and
the desired structure of the model. The predictive relationships have
already taken into account, to some extent, the data inputs when they
were being developed.
This Section of the report presents a complete review of each of the
activities for which projection equations have been included in the
model; included are the definitions of the activity, the empirical in-
formation from which the estimates were developed, and of course the
projection equations themselves. In addition, the structure of the
model is discussed to provide a general understanding of its data in-
puts and operations.
ACTIVITY PROJECTION RELATIONSHIP
The model which resulted from the data analysis consists of three major
sets of predictive equations, corresponding to the three major groupings
of agency activities. The first group, monitoring-related activities,
includes five activities applied to 12 types of sensors, for a potential
total of 60 manpower projections depending on the number of sensors of
each type operated, and a few additional non-sensor related activities.
The second group, the source-related activities, involves six activities
31
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applied to 15 source types, for a potential total of 90 individual pro-
jections, each based on the number of sources. The third major group,
administrative and support activities, is comprised of 17 specific activ-
ities grouped under the four categories: Management, Technical Planning
and Support, Training, and Clerical Support. The projections for these
activities are based on the manpower estimates made for the activities
in the first two groups. There are also a few activities which do not
fit into this structure because they need to be estimated from predictor
variables other than the ones in the matrices (e.g., travel time, esti-
mated in part from land area); these are estimated separately wherever
appropriate in the model and discussed correspondingly in the text.
The structure of this presentation does not follow chronologically
either the conduct of the project or the development of the model;
rather, it is organized for increased ease of reference to information
on specific activities.
Monitoring-Oriented Activities
The monitoring activities of an air pollution control agency are based
on the requirement to provide information on the air quality within its
area of jurisdiction. Such activities include the planning, design, and
set-up of the surveillance network; the operation, calibration, and
maintenance of various types of equipment pertinent to the pollutants
of interest; the analysis of collected samples; and the data processing,
summarization, analysis, and reporting. As some monitoring networks
also gather meteorological information for use in modeling and forecast-
ing of area quality, especially for emergency episodes, and the handling
of such instruments is often done by those responsible for the air qual-
ity sensors, meteorological surveillance is similarly included under
these activities.
The manpower requirements for these activities are primarily dependent
upon the scope of the network; i.e., number and types of instruments and
32
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the size of the region, the latter as it relates to travel time. The
total manpower necessary to conduct an air quality monitoring program
may be a significant portion of that of the control agency, depending
upon the depth of the other activities which may be undertaken. If the
pollution problem is not severe, so that there is little need for en-
forcement activities, monitoring-related activities may be a major por-
tion of the total effort.
There are five principal agency activities for which projection relation-
ships are developed under this heading. These are the monitoring and
laboratory efforts that are generally proportional to the number of am-
bient sensors and the frequency at which they are operated, and they are
projected in a matrix based on the numbers of the various sensor types
utilized:
Field Operation of Monitoring Equipment
Calibration and Maintenance of Monitoring Equipment
Sample Preparation
Sample Analysis
Data Handling
Other specific monitoring-oriented activities proved not to be predict-
able based upon sensor counts and were therefore estimated by other
means. These include:
Network Design and planning
Special Monitoring Studies
Travel Time
Laboratory Quality Control
Air Quality Data Analysis
For each of the activities listed above, the following discussion de-
fines the activity, outlines the data gathered for analyzing the in-
dividual manpower requirements, and gives the particular relationships
developed.
33
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Field Operation of Monitoring Equipment - This activity is defined as
the various efforts required to conduct the day to day operation of
automatic monitoring equipment, mechanized sampling equipment, and static
sensors. The majority of the time spent on this activity is in the op-
eration of automatic samplers, as they are inherently more complicated
and require more careful attention. However, they are the only type of
instrument that can give continuous, hourly readings, as is necessary
for the enforcement of some of the National Ambient Air Quality Stan-
dards. They are.actually the most efficient on a manpower per measure-
ment basis and at the same time need no additional manpower for labora-
tory analysis; however, more highly trained personnel is necessary for
the operation of automatic instruments. A field visit to an automatic
instrument normally includes a zeroing and purge (in which an inert gas
is fed into the sampling branch) and also, as necessary, the removal of
recent strip chart data and the insertion of a new chart roll. In ad-
dition, depending upon the instrument type and procedures of the agency,
a calibration at two or three check points may be made and the reagent
and gas supplies checked and changed as needed.
The operation of hi-vol samplers and bubbler samplers involves the ex-
changing of sample collection media, making airflow measurements, and
inspecting the equipment for wear and damage. The mechanics of the op-
eration are fairly sample and require only a small amount of effort for
each sample change. The field operation of static sensors involves only
the periodic changes of sensors (dustfall buckets, sulfation candles and
plates, corrosion panels, etc.). Chemical or gravimetric determination
of samples and preparation of the sampling media are included under the
laboratory operations.
Although this activity and the following one, Calibration and Mainte-
nance of Monitoring Equipment, are both dependent upon the types of in-
struments being used, they were investigated separately to allow for
the prediction of manpower needed if the frequency of visit is changed.
34
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The total amount of time spent on field operations is directly propor-
tional to the frequency of visits, while the need for calibration and
maintenance can be expected to vary only slightly with the frequency of
usage.
As expected, the experience of the various state and local agencies in-
dicated that the amount of time spent on the field operation of the dif-
ferent instruments was dependent primarily upon the type of monitor being
considered. While there are some differences in time that relate to the
particular model of the sampler, greater differentiation was found in the
type of sensor automatic, mechanical, static and the pollutant which
was being measured. The latter results from the complexity of the in-
strument, which in turn is related to the type of pollutant.
The man-hours spent on the total number of samplers for each agency during
each cycle (one visit to each instrument) are given in Table 4. A re-
view of this table indicates that there appear to be many differences in
the time spent by each agency during each visit and also that there are
many holes in the data gathered. The problem of interpretation of this
data can be understood from looking at the plot of hi-vol data in Fig-
ure 1 which indicates the type of data gathered and the equation that
was chosen to represent the data. From the data points themselves it
would have been possible to establish some form of a non-linear rela-
tionship indicating that the more hi-vols that were operated, the more
manpower per hi-vol it would take for the routine field operation. This
is contrary to any nonlinearity which might be expected to result due
to efficiency of scale.
A more logical relationship, as shown, is a linear one which indicates
that the time spent in the field operation of each instrument is constant
regardless of the total number of instruments. The relationship drawn
goes through agency B which was given more weighting in the review of
data as it had conducted an extensive review of the time spent in this
35
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Table 4. FIELD OPERATION OF MONITORING EQUIPMENT - MAN-HOURS PER CYCLE
FOR EACH SAMPLER TYPE (NUMBER OF SAMPLERS IN PARENTHESES)
Agency
A
B
C
D
E
F
C
H
I
Sampler type
Hl-vol
IS
(75)
32.5
(65)
7.3
(31)
27.6
(83)
B.I
(32)
45
(60)
2.0C
(25)
2.6
(9)
3.5
(U)
S02
bubbler
2.7
(32)
18.5
(24)
7.5
(30)
3-4
(12)
13.3
(40)
1.1
(13)
1.5
(6)
N02
bubbler
2.7
(32)
18.5
(24)
7.5
(30)
13.3
(40)
0.2
(2)
1.5
(6)
Sequential
tape
2.9
(35)
3.2
(16)
8.4a
(3)
1.6
(8)
1.7
(10)
10
(10)
2.3
(9)
0.2
(1)
0.25
(3)
Continuous
S02
6
(24)
30.4
(13)
243
(8)
0.2
(D
0.5
(3)
12
(12)
1.5
(2)
1.2
(3)
Continuous
NO?
3.5-7
(7)
8.4
(4)
39. 5a
(8)
1.0
(5)
3
(3)
Continuous
HC
0.5-1
(D
6.3
(3)
30*
(8)
1.0
(5)
1.5
(1)
1.2
(3)
Continuous
CO
2.3
(7)
7.9
(5)
12a
(8)
1.0
(5)
6
(6)
- -
1.2
(3)
2.0
(4)
Continuous
oxldant
2.7
(8)
4.7
O)
6a
(8)
0.8
(M
(0.3)
(D
11.3
(9)
0.2
(2)
Meteorological
equipment
10.5
(40)
0.5
(3)
5.8
(10)
2.4
(6)
0.5
(2)
Du&tfall
bucket
2.5
(30)
(20)b
7.7
(46)
4.7
(56)
1.7
(13)
Sulfation
plate
1.1
(13)
(80)b
7.7
(46)
1.5
(H)
u>
* includes travel tine
used for special studies
.c sacpling done by paid volunteers
-------
40 60 SO 100
NUMBER OF SENSORS
120 UO
Figure 1. Field operation of monitoring equipment
(hi-vols)
37
-------
particular activity. Agency H had also kept a log of the time spent on
its field operations and. was in fairly close agreement with the line
drawn. The dashed symbol for agency F indicates a range estimate.
The equation representing the linear relationship for the total manpower
(in man-years) needed by an air pollution control agency for the field
operation of its monitoring equipment (MY201 in the computer program)
was determined to be given by the following relationship:
12
MY201 =^T NSR(k) * M201(k)/F201(k)
k=l
where NSR(k) = the total number of sensors of category k
M201(k) = man-years to do the field operations for sensor k
if done daily
F201(k) = the frequency of visits to sensor k given as the number
of days between visits
The particular manpower requirements for each sensor type, as derived
from the interviews, and the most common frequency of visits, for each
of the sensor categories included in the study, are given below:
Sensor No.(k) Sensor - category M201(k) F201(k)
1 Hi-vol 0.09 6
2 S02 Bubbler 0.12 6
3 N02 Bubbler 0.12 6
4 Sequential Tape Sampler 0.039 6
5 Continuous S02 0.26 2
6 Continuous N00 0.42 2
z
7 Continuous HC 0.30 2
8 Continuous CO 0.21 2
9 Continuous Ozone/Oxidant 0.22 2
10 Meteorological Equipment 0.10 6
11 Dustfall Bucket 0.015 30
12 Sulfation Plate 0.015 30
38
-------
Calibration and Maintenance of Monitoring Equipment - The manpower in-
cluded under this heading applies to the various activities which are
normally required to ensure the continued proper calibration and opera-
tion of the monitoring equipment. These are activities that, though
performed periodically as well as when necessary, are not generally per-
formed during each visit to the sensor and, in some instances, may even
require the return of the instrument to an operations base or lab af-
filiated with the air pollution control agency. The specific activities
involved include:
1. Periodical on-site checking of the calibration of
automatic sampling equipment.
2. Periodic on-site maintenance of mechanized and auto-
matic sampling equipment.
3. Rebuilding or extensive repair of mechanized or auto-
matic sampling equipment, in-house or by outside services
(e.g., under guarantee or service contract), which re-
quires down-time for the instrument.
4. Performing a dynamic calibration check, by running known
samples through the instrument to ensure accurate measure-
ments, especially on automatic samplers.
The four components cited above were originally investigated indepen-
dently in the interviews with the agencies, though they were given the
opportunity to combine the individual activities. There was considerable
difficulty getting definitions of these four activities involved in up-
keep and maintenance that the agencies could agree on. Therefore, the
various components could not be predicted separately, and it was de-
cided that these activities would be combined under the above title to
provide only one measure of the relevant manpower levels. It is felt
that this alteration of the earlier definition of activities did not
seriously affect the goals of the project, as predictions are still pos-
sible on a per sensor basis.
The raw data collected for this activity is presented in Table 5 and
plotted, for hi-vols only, in Figure 2. Again, it is necessary to have
39
-------
Table 5. CALIBRATION AND MAINTENANCE OF MONITORING EQUIPMENT - MAN-YEARS PER YEAR
FOR EACH SAMPLER TYPE (NUMBER OF SAMPLERS IN PARENTHESES)
Agency
A
B
C
D
E
P
G
H
I
Sampler type
Hi-vol
0.35
(65)
0.20
(3D
0.75
(83)
0.04
(32)
0.57
(60)
0.05
(25)
0.04
(9)
0.01
(U)
S02
bubbler
0.41
(24)
0.05
(30)
0.03
(12)
0.55
(40)
0.04
(13)
N02
bubbler
0.41
(24)
0.05
(30)
0.55
(40)
0.04
(13)
Sequential
tape
0.73
(16)
0.06
(8)
0.02
(10)
0.1
(10)
J.26
(9)
0.08
<3)
Continuous
S02
1.09
(24)
0.74
(13)
0.12
(1)
o.ia
(3)
0.1
(12)
0.05
(2)
0.18-0.32
(3)
Continuous
N°2
0.26
(*)
0.52
(5)
0.1
(3)
Continuous
HC
0.22
(3)
0.17
(5)
0.1
(D
0.6
(3)
Cont Inuous
CO
0.32
(5)
0.17
(5)
0.1
(6)
0.04
(3)
0.03
(4)
Continuous
oxldant
0.18
(3)
0.03
(4)
0.06
(D
0.4
(9)
0.004
(2)
Meteorological
equipment
1.07
(40)
O.I
(10)
0.04
(6)
0.02
Dustfall
bucket
0.006
(46)'
-
Sulfation
plate
0.006
(46)
-p-
o
-------
1.0
0.9
0.8
0.7
o 0.6
a>
X
I
c
O
E Q5
<
O
04
0.3
0.2
O.I
_L
J_
20 40 60 SO 100
NUMBER OF SENSORS
120 140
Figure 2. Calibration and maintenance of
monitoring equipment (hi-vols)
41
-------
an understanding of the data collected and also the expected relation-
ship; i.e., it would not. be plausible to have a line which intersects
either axis at any point other than the origin. As already noted, the
investigation of manpower requirements and resulting predictions for
these efforts were found to be dependent upon the type of monitoring
instrument and that, while differences in manpower requirements for
calibration and maintenance by instrument model exist, the calcula-
tions could be adequately based on the type of sampler, including the
pollutant for which it is designed. The major amount of time again
is used for the automatic instruments, especially the hydrocarbon,
ozone, and sulfur dioxide monitors; and only a minimal level of effort,
about 1 hour per monitor per year, is applied to the maintenance of
static sensors.
The equation which represents the sum of the family of lines that re-
flect the total manpower (in man-years) needed by an air pollution con-
trol agency for the calibration and maintenance of its monitoring equip-
ment (MY202 in the computer program) was determined to be given by the
following:
12
MY202 - ^ NSR(k) * M202(k)
k=l
where NSR(k) = the number of sensors of category k
M202(k) = manpower (in man-years) to calibrate and maintain each
sensor k each year
42
-------
Sensor No.(k) Sensor Category M202(k)
1 Hi-vol 0.012
2 S02 Bubbler 0.015
3 NO. Bubbler 0*015
4 Sequential Tape Sampler 0.03
5 Continuous S02 0.08
6 Continuous N02 0.05
7 Continuous HC 0.09
8 Continuous CO 0.04
9 Continuous Ozone/Oxidant 0.08
10 Meteorological Equipment 0.03
11 Dustfall Bucket 0.0005
12 Sulfation Plate 0.0005
Sample Preparation - This activity is defined as that effort necessary
for the proper preparation of sampling media (static sensors, bubbler
solutions, filter paper) befora use in ambient samplers. Hie only
types of static sensors which require any sample preparation are dust-
fall buckets, which need solutions prepared, as devices for measuring
sulfation (sulfation plates, lead peroxide candles) are commercially
available. The preparation of sampling media for wet chemical analysis
is limited to the maintenance of the required reagents and solutions;
particulate samplers require that the filter paper be dried and weighed
prior to use. The level of effort for all of these efforts is directly
related to the number of sensors and the sampling frequency.
Few of the agencies investigated were found to be conducting their lab
work in-house; five out of the seven states had the labs do sample
preparation (and analysis) for the state and local agencies. In one
sense this tends to eliminate this manpower usage per se from the air
pollution control agency, although the burden is usually reestablished
through charges for the lab's services. For this reason, the model
projections of total manpower requirements for lab activities are still
43
-------
made for each agency but they are summarized as a separate total to
allow for their proper assignment to the APC agency or state lab.
Table 6 presents the data gathered from the states who supplied informa-
tion and the data (for hi-vol samplers) is presented graphically in Fig-
ure 3. As already noted, the data on this activity was not usually
available during the visit and the follow-up correspondence did not
prove to be fruitful; however, the correlation in the data received
was high and it was decided not necessary to actively pursue further
data. None of the agencies visited considered the use of continuous
instruments to involve the preparation and standardization of reagents
other than that included under calibration and maintenance so no time
was allotted under this activity.
The relationship determined to predict the manpower (in man-years) needed
!
by an air pollution control agency, or its associated lab, for the proper
preparation of the sampling media (MY210 in the computer program) relates
to the frequency of sample change and the number of sensors (i.e., the
number of samples) and is given as follows:
12
MY210 =5^ NSR(k) * M210(k) * (365.0/F210(k))
where NSR(k) = the total number of sensors of category k
M210(k) = the manpower (in man-years) to prepare each sample
for the sensor of category k
F210(k) = the frequency of sample change in number of days
between changes.
The particular manpower requirements for each sensor type, as derived
from the interviews, and the most common frequency of sample change,
for each of the sensor categories included in the study, are as follows:
44
-------
Table 6. SAMPLE PREPARATION - IN MAN-YEARS FOR EACH SAMPLER TYPE
(NUMBER OF SAMPLES PER YEAR IN PARENTHESES)
Agency
C
D
E
F
G
Sampler type
Hi-vol
0.20
(4780)
0.34
(6720)
0.14
(1940)
a
1
(3650)
0.06
(1440)
S02 bubbler
a
(6817)
b
0.07
(730)
0.30 '
(5200)
0.03
(780)
N02 bubbler
a
(6817)
b
b
0.23
(3900)
0.005
(120)
Dustfall bucket
b
b
0.009
(552)
b
0.005
(600)
Manpower estimate not supplied by agency
Sampler type not routinely used by agency
45
-------
1000 2000 3000 4000 5000 6000
NUMBER OF SAMPLES PER YEAR
7000
Figure 3. Sample preparation (hi-vol filters)
-------
Sensor No.Ckl Sensor category M210(k) F210(kl
1 Hi-vol 5xlO"5 6
2 SO. Bubbler 5.8xlO~5 6
3 N02 Bubbler 3.8xlO~5 6
4 Sequential Tape Sampler 0 30
5 Continuous SO, 0 1
6 Continuous N02 ° 1
7 Continuous HC 0 1
8 Continuous CO 0 1
9 Continuous Ozone/Oxidants 0 1
10 Meteorological Equipment 0 1
11 Dustfall Buckets IxlO"5 30
12 Sulfation Plates IxlO"5 30
Sample Analysis - This activity involves the chemical analysis of the
sampling media for the eventual determination of the ambient air quality.
Hie particular operations involved depend upon the types of sampling uti-
lized. The effort and considerations involved in this activity closely
parallel those under sample preparation.
This activity was originally broken down into two separate activities
to be able to discuss analysis by manual or automated means. This was
determined to be neither necessary nor possible after the discussions
with the agencies. This arises partly due to the small amount of time
involved in routine analysis.of ambient air concentrations and also be-
cause only a very few if any agencies use automatic analysis techniques;
none of the agencies visited did. ,
Again there were problems in getting the data for the various AFC agen-
cies due to the fact that labs were not usually located at the APC agen-
cies; however, the data from the state labs were comparable and these
were given more weighting. The only type of analysis considered under
this heading, where more than one may be performed on the sample, is
that directly germane to the monitoring of the ambient air quality to
47 -
-------
ensure compliance with the NAAQS. Therefore, the sample analysis for
hi-vols refers only to the gravimetric determination of concentration
and not any heavy metals, benzene solubles, or other analyses which
could be performed on the hi-vol filter.
Table 7 provides the raw data that was assimilated from the study, in
terms of the total effort spent (in man-years) by each agency to handle
a year's supply of samples. In the case of a sequential tape sampler,
one sample refers to a 1-month tape. Figure 4 provides a plot of the
data and the relationship utilized for projecting the manpower require-
ments for handling hi-vol filters.
The relationship, which relates the total number of samples (number of
sensors and frequency of sample change) to the total manpower (in man-
years) needed by an air pollution control agency, or its lab, for sam-
ple analysis (MX211 in the computer program) , was determined to be given
by the following equation:
MY211 = NSR(k) * M211(k) * (365.0/F210(k))
where M211(k) = the manpower (in man-years) to analyze each sample
for the sensor of category k.
The frequency factor F210 (and the number of sensors) is the same as
under Sample Preparation; the manpower per sample (M211) is as follows;
Sensor No.(k) Sensor category M211(k)
1 Hi-vol 13x10"5
2 S02 Bubbler 16xlO~5
3 NO, Bubbler 16xlO"5
^ .5
4 Sequential Tape Sampler 75x10
5 Continuous S00 0
48
-------
Table 7. SAMPLE ANALYSIS - IN MAN-YEARS FOR EACH SENSOR
(NUMBER OF SAMPLES PER YEAR IN PARENTHESES)
Agency
C
D
E
F
G
Sampler type
Hi-vol
0.80
(4780)
0.72
(6720)
0.09
(1940)
0.15
(3650)
0.06
(1440)
S02
bubbler
0.85
(6817)
b
'0.19
(730)
0.04
(5200)
0.065
(780)
N02
bubbler
0.85
(6817)
b
b
0.03
(3900)
0.01
(120)
Sequential
tape
sampler
b
a
(5)
0.005
(10)
. a
(D
0.012
(12)
Dust fall
bucket
0.19
(893)
b
0.24
(552)
b
0.05
(600)
Sulfation
plate
0.59
(548)
b
0.24
' (552)
b
b
Manpower estimate not supplied by agency
^Sampler type not routinely used by agency
49
-------
1000 2000 3000 4000 5000 6000
NUMBER OF SAMPLES PER YEAR
7000
Figure 4. Sample analysis (hi-vol filters)
50
-------
Sensor No. 00 Sensor category M211QO
6 Continuous NO- 0
7 Continuous HC 0
8 Continuous CO 0
9 Continuous Ozone/Oxidant 0
10 Meteorological Equipment 0
11 Dustfall Bucket 25xlO~5
12 Sulfation Plates SOxlo"5
Data Handling - This activity is defined as that effort required to
process monitoring data from the sensor to the data storage system,
including data validation, and to prepare routine summaries in one or
more standard formats. Included under this heading is the effort ex-
pended in preparing, on appropriate SAROAD data forms or in other
SAROAD-compatible format, the quarterly air quality data reports to
EPA that are required by regulation. The total manpower engaged in
handling data depends upon the total amount of data being handled and
the degree of computerization of the data processing system; i.e.,
whether it is a totally manual system; semi-automatic, partially com-
puterized; or totally automated, including telemetering.
The questionnaire was structured to pursue these three degrees of com-
puterization so that, if possible, projections could be made with the
knowledge of the type of data handling system each APC agency had. As
it turned out, this was not necessary since, from the information gath-
ered in the study, the more data that an agency handled, the more likely
they were to handle it effectively. This implies an efficiency of scale,
which is expected in this type of operation, with agencies going toward
more efficient means of handling the data as the data volume increases.
The amount of data, or number of data bits, can be derived from knowing
the number of monitors and their sampling frequency. Obviously, con-
tinuous monitors, producing hourly readings, will be consuming the
51
-------
majority of effort In this area for any agency which has more than a
few in operation. The average number of data bits per day (DB) pro-
duced by a monitoring netowrk can be determined from the following
equation:
3 10
DB = 2 NSR(k)/F210(k) + 12 * NSR(4) + 24 * £ NSR(k)
k=l k=5
+ (NSR(11)/F210(11) + NSR(12)/F210(12))
where NSR(k) refers to the number of sensors of the appropriate type,
and F210(k) refers to the number of days in the scheduled sampling
cycle, as described previously. The equation also assumes that
tape samplers produce 2-hour values and other continuous in-
struments 1-hour values.
A plot of the number of data bits handled by each agency versus the
total manpower expended on data handling during the year is given in
Figure 5. This plot is expressed in the number of data bits per 6-day
period, rather than the average number per day, since the standard
sampling cycle was every 6 days at the time of the agency visits, and
the data was gathered in that form.
The data in Figure 5 reflect an efficiency of scale that results from
the increase in the volume of data handled. It was decided to repre-
sent this relationship through the use of two straight lines which
then produce two equations when expressed solely in terms of the total
man-years to handle the data from an air monitoring network (MY220 in
the computer program):
52
-------
I I
n i r
2.
2.2
2D
I I
J I
0 I 2 3 4 3 6 7 0 9 10 II 12 13 14
1000 DATA BITS/6 DAYS
Figure 5. Data handling
53
-------
if DB < 520
then MY220 = 0.0114 * DB - 1.8 x 10"5 * DB2
if DB > 520
then MY.220 » 0.00186 * DB
The data also indicated that those agencies that had telemetered continu-
ous monitors experienced some savings in total manpower because the
telemetered monitors required only minimal data handling. It was found
that subtracting 0.04 man-years for every telemetered monitor brought
those agencies more closely in line with actual manpower usage projected.
At the current time this is included in the model's predictive relation-
ship, although the number of telemetered sensors (NTEL) is zero until
data becomes available.
The manpower used for data processing is in most cases divided between
the state agency and any local agencies in the AQCR in question, de-
pending of course on the nature of the network and the data handling
procedures utilized. This has been accommodated in the model by first
estimating the manpower at the AQCR level, if any local agencies exist
(if NLA / 0), and thus estimating additional manpower on the state
level. At the state level, the much larger accumulated value of DB
serves to reduce the apparent overlap, because of the nonlinearity of
the relationship, although estimating the manpower in this way still
provides higher estimates than if it were assumed the state agencies
did it all. This additional effort is not viewed as being unnecessary,
but rather as contributing to the overall quality of the data, since the
local personnel who operate the network have an intrinsically better
opportunity for effective data validation.
Monitoring Network Design and Planning - Because ambient pollution levels
and meteorological parameters are not the same throughout the region, it
is necessary to carefully plan and periodically reconsider where the mea-
surements should be made, how many should be taken, etc. Design of a
54
-------
monitoring network is often assisted by dispersion modeling and a com-
plete emission inventory. However, these aids are seldom available in .
initial phases of the network design and much design needs to be based
on judgment, with subsequent reconsideration as more information becomes
available. This activity includes the on-going effort involved in this
designing and also includes such efforts as site selection and negotia-
tion and operating schedule analysis.
This type of low-rlevel, on-going activity is intrinsically difficult to
estimate, and did prove to be so with the agencies visited (see Table 8),
This was further complicated by the fact that two states (A and D) were
involved in major equipment changes in their networks. There did seem
to be good consensus on the fact that planning monitoring activities in
currently undeveloped areas was the major effort, as opposed to modifying
existing metworks in urban areas. Consequently, since it is only a small
amount of the manpower, it was decided to estimate this activity as a
function of the AQCR characteristics and to use the EPA-assigned priority
rating as an indicator of the urban development characteristics of the
AQCR. In the program, the priority classifications for SCL and TSP are
summed (using 1A equal to 4) and if the total is 2 or 3 the AQCR is viewed
as urban; otherwise, it is considered to be nonurban. Based on the aver-
age of estimates from all such AQCR's included in the study, urban AQCR's
are estimated at 0.05 man-years for network planning. The nonurban AQCR's
are estimated to require 0.15 man-years; this estimate is based primarily
on the experience of twp states that are actually developing network oper-
ations in such AQCR's. States that are not now monitoring such areas did
recognize a need to do so, based to a large extent on the needs of air
quality maintenance planning and analysis. The raw data and the man-
power requirements for each state as derived from this relationship are
given in Table 8.
55
-------
Table 8. MONITORING NETWORK DESIGN AND PLANNING
(TIME IN MAN-YEARS)
Agency
A
B
C
D
F
G
Stated
manpower
3
0.60
0.08
1.5
l.'O
0.8
Number of
urban AQCR's
2
4
3
0
1
1
Number of
nonurban AQCR's
2
7
3
8
7
11
Projected
manpower
0.4
1.25
0.60
1.2
1.1
1.7
Special Monitoring Studies - From the discussions with the agencies, it
was determined that an appreciable amount of time was spent on moni-
toring activities that were not part of the routine, on-going ambient
monitoring. This activity, usually called special studies, was en-
gaged in for determining ambient concentrations only during special
times and/or at particular locations. Often such studies were per-
formed as part of new indirect or direct source review procedures as
a means of deriving ambient concentrations for use in emission models.
Some studies were also carried out as a means of testing new equip-
ment or in-use equipment; other reasons for special studies included
episode monitoring, determining the impact on air quality of specific
sources, and special requests.
It was not felt that these special studies should be regarded as ex-
traneous activities and therefore left out of the model because they
were not part of the EPA-required activities. The incorporation of
this activity implied an additional manpower requirement for the air
pollution control agencies, drawing upon the monitoring and laboratory
personnel. These special studies were not immediately predictable due
in part to the wide range of such studies which were engaged in, with
different agencies placing emphasis in different areas, and the fact
56
-------
that the questionnaire had not been structured to investigate this
area. Therefore, the determination of a relationship was a much more
qualitative Judgment in this instance,
For those agencies for which data on special studies were broken out
to some degree, the amount of effort involved in this activity ranged
from 15 percent (agency B) to 40 percent (agencies C, D, I) of the
manpower expanded in the other monitoring and laboratory activities.
While it is felt that a more careful investigation would indicate
that the additional burden on personnel engaged in monitoring activi-
ties would be more heavily weighted toward those performing laboratory
activities, since more than one analysis can be performed on only one
sample (e.g., benzene solubles, metals analyses, particle sizing, etc.,
on hi-vol filters), the data available indicated that the amount of
manpower involved in special studies could be stated as an additional
30 percent burden on the total manpower engaged in Field Operations,
Calibration and Maintenance, Sample Preparation, and Sample Analysis,
Travel Time for Monitoring » The amount of travel time needed for
covering the monitoring network is directly related to the design and
extent of the network. Such factors as average speed, total area
covered, and the frequency of visits would be expected to be the de-
termining factors. In regard to the area covered, it would have to
be correlated with whoever is conducting the field operation; i0e.,
whether the field operation was handled by a local health board, a
regional office of the state, or directly from the state APC agency°s
headquarters. Unfortunately, there is np immediately available data
base for inputting this type of information.
The agencies visited reflected this mix in the conduct of their field
operations, making it hard to arrive at a relationship that would be
broadly applicable. A review of the data compiled from the visits
with the agencies indicated a fairly good relationship based upon
57
-------
only the square root of the area of the state, which could be inter-
preted to be proportional to the total miles traveled. The data
gathered is plotted in Figure 6 along with the following relationship
which was used in the model for projecting the manpower for this
activity:
1/2
Travel Time - 0.0154 * (area in miles) '
In deriving this relationship, those agencies using local manpower
(D and G) and those with regional offices (F and B) were discounted
to varying degrees, depending upon the impact that they had. Agency
E only visited the samplers half as often as the other agencies;
agency C covered only the metropolitan area (the area plotted on the
graph) with local health offices handling the rest of the state,
As the above relationship assumes a 6-day cycle for visiting the
sampling stations and it may be desirable in the future to consider
changing the sampling frequency, the equation in the model that .
represents the travel time needed for monitoring (MY404 in the com-
puter program) contains the frequency of visit for hi-vols, which is
usually the determining factor:
MY404 = 0.0924 * SQRT(AREA(ISTATE))/F201(1)
The application of this relationship in the actual computer program
is not done on an AQCR basis but at the state level so that the travel
time would not be disproportionately high for states with many smaller
AQCR's. If more information on local agencies becomes available,
their area of jurisdiction and who is responsible for the monitoring,
these inputs could probably also be included and a new relationship
determined.
58
-------
15
3.0
xB
s
>.
I
c
o
2.5
2JO
xC
xF
<
o
1.5
10
0.5
I
_J
280
40 SO 120 160 200 240
N/AREA , miles
Figure 6. Travel time for monitoring
320
360
400
-------
Laboratory Quality Control - This activity is defined as that effort
to ensure the proper determination of pollutant samples and levels in
the laboratory, such as systems of running known samples blindly
through the wet chemical analysis techniques at periodic intervals.
This activity does not include the calibration of ambient samplers or
automatic analyzers, which is considered under "Calibration and Main-
tenance of Monitoring Equipment."
All agencies visited expressed the desire to have more time for the
assurance of quality control for the laboratory activities. Since these
were selected as some of the better agencies and they did engage in some
quality control efforts, it was felt especially important that some ad-
ditional time be provided in the model specifically for an expanded
quality control effort. Discussions with the Quality Assurance and En-
vironmental Monitoring Laboratory (QAEML) suggested that an effort equiv-
alent to 10 percent of the activity in the laboratory would be required
for adequate quality control operations. Therefore, the estimate of
additional manpower for this activity was estimated as 10 percent of
the total manpower estimated for Sample Preparation and Sample Analysis.
Air Quality Data Analysis - This activity is defined as the effort in-
volved in analysis of the air quality data, including the necessary
adjunct use of meteorological data, either from the agency's network
or from other sources; e.g., study of the temporal and locational
variations in pollutant, levels in conjunction with meteorological
data and knowledge of pollutant sources. Particular areas of data
analysis include:
AQ trends
AQ patterns
Source identification
Monitoring of known sources
Transportation planning
Indirect source planning
60
-------
The interviews with the agencies indicated that, naturally enough,
those agencies that had more data to analyze spent more time in this
activity. By relating the total manpower spent in this activity
with that spent solely in the handling of the data, factors such as
the total amount of data and the use of computers are automatically
taken into consideration. Figure 7 provides a plot of these two man-
power levels as determined from the study visits. The manpower for
agency B was much higher than would be expected as it was still
handling data analysis by hand, with plans for programming it in the
near future. Agency C is low, probably due to the fact that much of
its data analysis is done throughout the agency to help in their
various planning activities and could not be very well estimated by
one interviewee; agency G has done little analysis to date.
The line plotted on the graph reflects the relationship used in the
computer program for projecting the manpower requirements for data
analysis (MY322 in the computer program), a function of the manpower
used in data handling (MY220):
MY322 m 0.5 * M5T220
Source-Related Activities
The second major group of agency activities includes those that are
quantitatively related to the number and type of pollutant sources
in the area under consideration. These include the enforcement and
source surveillance activities that are traditional, and also other
compliance and planning activities that are relatively new. This
group of activities has proved to be the one for which it was most
difficult to obtain reliable empirical information and to develop
satisfactory predictive relationships. There were a variety of
causes for this difficulty. In the case of mobile sources, for in-
stance, the difficulty was simply that actual transporation control
activities were and still are only beginning, so there is little ex-
perience in even the most advanced agencies.
61
-------
10
O
0)
c
O
E 7
to
_J
Z
< 5
QC
O
3
1 -
xB
_L
12 3 4 5 6 7
TOTAL TIME FOR DATA PROCESSING, mon-yeors
Figure 7. Data analysis
62
-------
The primary difficulties in the case of stationary source activities,
beyond those simply resulting from the lack of data, were the lack of
homogeneity in the agencies1 approach to stationary source enforce-
ment and in the definition of some of the major activities. The first
of these, nonhomogeneity of overall program thrust or control approach,
is a problem fundamental to the entire concept of a planning model; it
cannot be completely resolved, other than by homogenizing the agencies,
and on an aggregate basis one can only hope to avoid any very severe
effects and then-temper model usage with judgment. (On a single-state
basis, better estimates can be obtained by adjusting model parameters
to values appropriate for the specific state.)
The second problem noted above, the varying definitions of the activi-
ties, would seem to be amenable to standardization in the model, and to
a large extent is so. However, fundamental difficulties relating to
the definitions used in the entire air pollution field make it more com-
plex than just developing standard definitions for use in the manpower
model development. An example is the idea of a compliance schedule, an
agreement negotiated between a source and an agency relative to the time-
table for installing control equipment on the source. Several agencies
did not utilize such a concept and, although the ultimate purpose seemed
to be served, discussing the idea and allocating manpower to it proved
difficult.
With these general cautions in mind, the following text discusses the
specific activities defined for the'model, the data gathered, and the
relationships utilized in the model.
Stationary Source Activity Matrix - Six activities that account for
much of an agency's manpower in the area of stationary source control
were defined in such a way as to.be used in a matrix of activities
versus source counts, much as was done with monitoring activities and
sensor counts. These activities are;
-------
Stationary source inspection
Conduct stationary source testing
Observe conduct of stack test
Overseeing of compliance schedules
Formal legal action
Technical review of equipment plans
Definitions of these activities follow immediately, and the predictive
relationships are presented afterwards.
101. Stationary Source Inspection - These activities include the
effort needed to conduct inspections, either routine or extensive,
excluding any effort involved in associated stack testing or in
travel time. Routine inspections are those that are typically
performed in less than 1/2 man-day (exclusive of travel time),
where visual inspection of equipment and operation, by a technician-
level person, is adequate. This type of inspection might be per-
formed for routine permit purposes, for on-going surveillance to
help maintain the emissions inventory, or for other reasons. Ex-
tensive engineering inspections, in contrast, may involve one or
more professional staff for perhaps several days, and will be much
more thorough and detailed.
It was originally intended to utilize two activity definitions,
one for routine inspections and one for engineering inspections.
The information developed from the agency visits, however, in-
dicated that the differences in these inspections were only dif-
ferences in the complexity of the source being inspected. There
were no cases, for instance, when a major source was inspected
in a brief routine manner and no agency recommended such a
practice. Consequently, a single category for all inspections
is used, and the differences in manpower required are included
in the different factors used for the various source types.
104. Conduct Stationary Source Tests - This activity includes
the field and source-oriented effort involved in planning and
conducting actual measurements of emissions. If the stack test
is conducted in conjunction with an inspection, this activity
includes only the effort needed to prepare and set-up the equip-
ment, conduct the test, make necessary field calculations, and
replace the equipment; access to sampling ports is presumed, and
any subsequent calculations or data processing conducted in the
office is also included.
64
-------
103. Observe Conduct of Stack Test - To save manpower, agencies
may require sources to conduct stack tests, using their own staff
or an approved contractor, with the agency observing to the
extent necessary to maintain the integrity of the process. This
activity includes the effort to observe one such test.
107. Monitoring of Compliance Schedules - This activity includes
the efforts involved in maintaining surveillance over and con-
ducting negotiations about the definable increments of progress
in the compliance schedules.
110. Formal Legal Action - This activity is defined as the time
involved in actual court cases, hearings, etc., including
assimilation and preparation of supporting documents, notifica-
tion of the polluter of impending action, and actual time in
court in prosecution. The time of both legal and engineering
or other technical staff is included.
130. Technical Review of Equipment Plans - This activity is defined
as the effort involved in reviewing equipment plans for proposed
or existing sources to verify their compliance with established
regulations pertaining to direct emissions prior to issuance of a
permit. Review of the air quality impact of a proposed source is
not included. Review of equipment plans for ta credit or adjust-
ment purposes is considered as a separate activity; review of con-
struction proposals relative to their indirect emissions, and ad-
visory reviews, are also considered in subsequent activities.
Stationary Source Categories Used in Matrix - The stationary source
categories used in the matrix are listed in Table 9. This list was
condensed from a more extensive list in the questionnaire, based on
the results of the agency visits and subsequent study of the source-
count data base available for initial use with the model.
Ah initial list of 68 source types was developed for the questionnaire
based on general knowledge of the nature of stationary sources and con-
trol activities, along with the list of source types for which New '
Source Performance Standards (NSPS) were either promulgated or being
considered. (This initial list is included subsequently in Table 13.)
One rather clear result of the agency visits was that such a list was
too extensive - few of the agencies could provide much information at
that detail, and most felt it riot feasible. Accordingly, it was
65
-------
Table 9. FINAL LIST OF SOURCE CATEGORIES USED IN
STATIONARY SOURCE MATRIX
1. Electric power plant boilers over 10 MMBtu/hour
2. Coal- or residual oil-fired boilers over 100 MMBtu/hour
3. Coal-fired industrial boilers 10-100 MMBtu/hour
4. Coal-fired commercial/institutional boilers 10-100 MMBtu/hour
5. Residual oil-fired boilers .10-100 MMBtu/hour
6. Coal-fired boilers < 10 MMBtu/hour
7. Small and miscellaneous boilers
8. Chemical manufacture
9. Food and agricultural
10. Iron and steel industry
11. Primary non-ferrous metallurgy
12. Secondary metallurgy
13. Portland cement manufacture
14. Stone quarrying
15. Other mineral products.
16. Petroleum processing
17. Wood products
18. Other industry
19. Petroleum storage
20. Other evaporative HC sources
21. Open burning dumps
22. Industrial incineration
23. Other incineration
66
-------
concluded that the list needed to be compressed, although this would
necessarily require aggregating some relatively disparate source
categories.
Subsequently, it was determined that the best available data base on
the number of sources was in the form of Source Classification Codes
(SCO), rather than emission points (e.g., stacks) or premises (e.g., an
entire steel mill, refinery, etc.). This proved to be somewhat incon-
sistent with the way in which information was available from the agen-
cies, but nonetheless it was necessary to use the source information in
this form. Accordingly, the compressed list of source types (Table 9)
was designed so that the various categories are aggregates of the SCC
data available from the NEDS data system; Table 10 presents the aggre-
gation scheme used, which necessarily makes use of the structure of .the
SCC coding scheme.
Empirical Information Sought During Agency Visits - The portion of the
questionnaire devoted to stationary-source-related activities was in-
tended to gather information in two forms -the per-unit time required
for each activity applied to each particular source type; e.g., the
effort needed to inspect that source type once, and the aggregate man-
power applied to a particular activity, such as total time for
inspections.
The first of these types of information, the data specific to source
type, was sought for direct use in the activity versus source type
matrix. It was decided in. advance to attempt to develop a consistent,
simple format of relationship between the number of sources and the
manpower, so.as to permit its ready adaptation to the differing phi-
losophies adopted by various agencies* The general form of the pre-
dictive relationship, for source type k, which was in fact ultimately
used, was to be:
67
-------
designed so that the various categories are aggregates of the SCC data
available from the NEDS data system; Table 10 presents the aggregation
scheme used, which necessarily makes use of the structure of the SCC
coding scheme.
Empirical Information Sought During Agency Visits - The portion of the
questionnaire devoted to stationary-source-related activities was in-
tended to gather information in two forms - the per-unit time required
for each activity applied to each particular source type; e.g., the
effort needed to inspect that source type once, and the aggregate
manpower applied to a particular activity, such as total time for in-
spections.
The first of these types of information, the data specific to source type,
was sought for direct use in the activity versus source type matrix. It
was decided in advance to attempt to develop a consistent, simple format
of relationship between the number of sources and the manpower, so as to
permit its ready adaptation to the differing philosophies adopted by
various agencies. The general form of the predictive relationship, for
source type k, which was in fact ultimately used, was to be:
Manpower = Mxxx(k) * Cxxx(k) * Fxxx(k) * NSRC(k) / Constant
where Mxxx(k) is a manpower factor for an activity, in time per single
performance of that activity for source type k,
Cxxx(k) is a factor indicating the proportion of the sources in
category k that is subject to the activity in question,
Fxxx(k) is a frequency factor providing an ability to specify the
frequency of performance of each activity per year, and
NSRC(k) is the number of sources in category k;
The constant is for possible use to adjust the resultant manpower
from man-days, man-hours, etc., into man-years.
68
-------
Table 10. AGGREGATION OF SCC's INTO 23 SOURCE TYPE CATEGORIES FOR MODEL
NEDS
Source type category I II
1. Electric Power Plant 1 01
Boilers over n.
10 MM Btu/hr
01
01
01
01
2. Coal- or Residual Oil- 1 02
Fired Boilers over .'.
100 MM Btu/hr-
- ' 02
02
02
02
source
III
classification code (SCC)
IV
ELECTRIC POWER -GENERATION
001 Anthracite Coal
001
001
002
002
002
003
003
003
004
004
004
005
01-02 > 100 KM Btu/hr
03-04 10 - 100 MM Btu/hr
Bituminous Coal
01-05 > 100 KM Btu/hr
06-09 10 - 100 MM Btu/hr
Lignite
01-06 > 100 MM Btu/hr
07-11 10 - 100 MM Btu/hr
Residual Oil
01 > 100 MM Btu/hr
02 10 - 100 KM Btu/hr
Distillate Oil
005 01 > 100 MM Btu/hr
005 02 10 - 100 MM Btu/hr
INDUSTRIAL
001 .Anthracite Coal
001
002
002
003
003
004
004
005
01-02 > 100 KM Btu/hr
Bituminous Coal
01-04 > 100 MM Btu/hr
Lignite
01-06 > 100 KM Btu/hr
Residual Oil
01 > 100 KM Btu/hr
Distillate Oil
NCOS *
Source type category I II
02
02
02
02
4. Coal-Fired Conocrclal/ 1 03
Institutional Boilers
10 - 100 KM Btu/hr OJ
03
03
03
03
2 01
01
01
01
2 02
02
02
02
S. Residual 011-Fired ' 1 02
Boilers n.
10 - 100 MM Btu/hr OZ
rarce classification code (SCC)
III IV
003 Lignite
003 07-11 10 - 100 KM Btu/hr
009 XX Wood/Bark Waste
Oil XX Bagasse
012 XX Solid Haste
COKMERCIAL/ INSTITUTIONAL
001 Anthracite Coal
001 05-07 10 - 100 MM Btu/hr
002 Bituminous Coal
002 05-10 10 - 100 MM Btu/hr
003 Lignite
003 05-09 10 - 100 KM Btu/hr
009 XX ' Hood/Bark Waste
Oil XX Solid Waste
ELECTRIC POWER GENERATION
003 XX Diesel Fuel
004 XX Residual Oil
006 XX Crude Oil
INDUSTRIAL
004 XX Diesel Fuel
005 XX Residual Oil
007 XX Crude Oil
INDUSTRIAL BOILERS
004 Residual Oil
3. Coal-Fired Industrial
Boilers
10 - 100 KM Btu/hr
005 01 > 100 KM Btu/hr
1 03 COMMERCIAL - INSTITUTIONAL
03 004 Residual Oil
004 01 > 100 KM Btu/hr
03 005 Distillate Oil "
005 01 > 100 KM Btu/hr
1 02 INDUSTRIAL
02 001 Anthracite Coal
001 03-04 10 - 100 KM Btu/hr
SO 002 Bituminous Coal
002 05-09 10 - 100 MM Btu/hr
004 02 10 - 100 MM Btu/hr
02 005 Distillate Oil
005 02 10 - 100 KM Btu/hr
1 03 COMMERCIAL/INSTITUTIONAL BOILERS
03 004 Residual Oil
004 02 10 - 100 KM Btu/hr
03 005 Distillate Oil
005 O2
10 - 100 KM Btu/hr
-------
Table 10 (continued). AGGREGATION OF SCC's INTO 23 SOURCE TYPE CATEGORIES FOR MODEL
KEDS source classification code (SCC)
Source type category I II
6. Coal-Plred tollers 1 01
10 KM Btu/hr ^
01
01
1 02
02
02
02
1 03
03
03
03
7. Small and 1 01
Miscellaneous Boiler* .
01
01
01
01
01
01
01
01
01
01
01
III IV
ELECTRIC POWER GENERATION
001 Anthracite Coal
001 05-06 < 10 MM Btu/hr
002 Bituminous Coal
002 10-12 < 10 KM Btu/hr
003 Lignite
003 07-11 < 10 KM Btu/hr
INDUSTRIAL BOILERS
001 Anthracite Coal
OO1 05-07 < 10 KM Btu/hr
002 Bituainous Coal
002 10-14 < 10 KM Btu/hr
O03 Lignite
003 12-16 < 10 MM Btu/hr
COMMERCIAL/ INSTITUTIONAL BOILERS
001 Anthracite Coal
001 08-10 < 10 KM Btu/hr
002 Bltuainous Coal
002 11-14 < 10 KM Btu/hr
OO3 Lignite
003 10-14 < 10 KM Btu/hr
ELECTRIC POWER GENERATION
001 Anthracite Coal
001 99 Unclassified
001 Bituminous Coal
001 99 Unclassified
004 Residual Oil
004 03 < 10 KM Btu/hr
005 Distillate Oil
005 03 < 10 MM Btu/hr
006 XX Natural Cas
007 XX Process Gas
008 XX Coke
009 XX Wood/Bark Waste
Oil XX Bagasse
012 XX Solid Waste
013 XX Liquid Waste
999 XX Unclassified
NEDS source classification code (SCC)
Source type category I II
2 01
01
01
01
01
01
1 02
02
02
02
02
02
02
02
02
02
02
1 03
03
03
03
03
03
0)
03
03
03
III IV
ELECTRIC POWER GENERATION
001 XX Distillate Oil
002 XX Natural Cas
005 XX Jet Fuel
007 XX Process Gas
999 XX Unclassified
INDUSTRIAL
001 Anthracite Coal
001 99 Unclassified
002 Bituminous Coal
002 99 unclassified
004 Residual Oil
004 03 < 10 MM Btu/hr
005 Distillate Oil
005 03 < 10 MM Btu/hr
006 XX Natural Gas
007 XX .Process Gas
008 XX Coke
010 XX Liquid Petroleum
Gas
013 XX Liquid Waste
999 XX Unclassified
COMMERCIAL/ INSTITUTIONAL
001 Anthracite Coal
001 99 Unclassified
002 Bituminous Coal
002 99 Unclassified
004 Residual Oil .
004 03 < 10 MM Btu/hr
005 Distillate Oil
005 03 < 10 KM Btu/hr
006 XX Natural Cas
007 XX Process Cas
010 XX Liquid Petroleum
Gas
013 XX Liquid Waste
999 XX Unclassified
(Continued)
-------
Table 10 (continued). AGGREGATION OF SCC's INTO 23 SOURCE TYPE CATEGORIES FOR MODEL
NEDS source
Source typ* category I II
7. (Continued) 2 02
02
02
02
02
02
02
8. Chemical Manufacture 3 01
*. Food and Agricultural 3 02
10. Iron and Steel 3 03
Industry OJ
03
.;.:.:' 03
03
03
03
11. Primary Boo- Ferrous 1 03
Metallurgy nj
03
03
03
03
03
03
03
03
03
03
03
03
0}
III
classification cod* (SCC)
IV
INDUSTRIAL
001
002
003
006
008
999
XXX
XXX
XX
XX
XX
XX
XX
XX
XX
XX
PRIMARY
003
004
006
007
008
009
XX
XX
XX
XX
XX
XX
PRIMARY
000 XX
001
002
003
010
Oil
012
013
014
015
02 5
026
030
999
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
Distillate Oil
Natural Caa
Gasoline
Jet Fuel
Process Ga*
Unclassified
All Processes
All Sources
METALS
Coke - Byproduct
ovens
Coke - Beehive
ovens
Ferroalloy -
Open Furnace
Ferroalloy -
Semi-covered
Iron Production
Steel Production
METALS
Aluminum Or* -
Bauxite
Aluminum Ore -
Electroreductloa
Aluminum Ore -
Calcium Aluminum
Hydrate
Copper Saelter
Lead Smelter
Molybdenum
Titanium
Cold
Barium
Beryllium Ore
Mercury Mining-
Mercury Ore
Processing
. Zinc Shelter
Unclassified
BEDS source
Source typ* category I II
12. Secondary Metallurgy 3 04
13. Portland Cement 3 05
Manufacture
OS
14. Stone Quarrying 3 OS
15. Other Mineral Products 3 OS
OS
OS
OS
05
05
05
05
05
05
OS
OS
OS
.05
05
OS
OS
05
05
05
05
05
05
OS
OS
05
05
05
05
III
XXX
006
007
020
classification coo* (SCC)
IV
XX
XX
XX
XX
MINERAL
001
002
003
004
005
DOS
009
010
Oil
012
013
014
015
016
017
016
019
021
022
023
024
025
026
030
031
032
040
999
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
XX
xx
XX
XX
All Source*
Cement Manufacture -
Dry
Cement Manufacture -
Wet
All Sources
PRODUCTS
Asphalt Roofing
Asphaltic Concrete
Brick Manufacture
Calcium Carbide
Cast able Refractory
Ceramic/Clay
Clay/Fly Ash
Coal Cleaning
Concrete Batching
Fiberglass
Frit Manufacturing
Class Manufacturing
Gypsum Manufacturing
Lin* Manufacturing
Mineral Uool
Perlite Manufacturing
Phosphate Rock
Salt Mining
Potash Production
Calcium Borate
Magnesium Carbonate
Sand - Gravel
Diatoaaceoua Earth
Ceramic Electric Ft*
Asbestos Mining
Asbestos Milling
Unspecified Mining
Unclassified
-------
Table 10 (continued). AGGREGATION OF SCC's INTO 23 SOURCE TYPE CATEGORIES FOR MODEL
MEDS source
Source type category
16. Petroleum Processing
17. Wood Products
18. Other Industry
19. Petroleum Storage
20. Other Evaporative
HC Sources
I
3
3
3
3
3
3
3
4
4
4
II
06
07
09
09
20
20
30
30
90
90
99
99
03
01
01
02
III
XXX
XXX
classification code (SCC) NEDS source classification code (SCO
IV
XX
XX
All
All
Sources
Sources
METAL FABRICATION
XXX
XX
LEATHER
XXX XX
TEXTILE
XXX
XX
All
Sources
PRODUCTS
All Sources
MANUFACTURING
All
IN-PROCESS FUEL
XXX XX All
UNCLASSIFIED
XXX XX All
XXX
XX
All
Sources
Sources
Sources
Sources
CLEANING SOLVENT
XXX XX All Sources
SURFACE
COATING
Source type category I II
4 04
04
4 05
05
21. Open-Burning Dumps 5 01
22. Industrial Incineration 5 03
23. Other Incineration 5 01
01
01
01
5 02
02
III
IV
MISCELLANEOUS ORGANIC
STORAGE
XXX XX All Sources
PRINTING
XXX
002
XXX
XX
XX
XX
PRESS
All Sources
All Sources
All Sources
GOVERNMENT
001
005
900
XX
XX
XX
Municipal
erator
Inc In-
Other Government
Incinerator
Auxiliary Fuel
COMMERCIAL/INSTITUTIONAL
xxx
XX
All Sources
-------
The second type of information sought, the aggregate manpower used by
the agency in conducting each activity for all sources, was intended
as a supplement to the source-type-spec!fie data and as a means of
checking the completeness with which all the agency's manpower was
accounted for.
As it developed, relatively little reliable source-type-specific in-
formation was obtainable from the agencies, and it was necessary to
also make use of,a variety of the aggregated information, as well as
general knowledge and judgment, in order to develop the required co-
efficients. Consequently, this is likely the portion of the model that
will most need additional effort in the future. On an aggregated level,
either for activities or source types, the manpower estimates are expected
to be quite adequate, but the individual source-type activity coefficients
are probably not supportable in isolation from the rest of the matrix.
Given these difficulties, consideration was given to abandoning the use
of a matrix in favor of some simpler option. However, the original op-
tion had two advantages: the reasonableness of the idea that agency effort
should be proportional to the magnitude of the problem, and the ability to
represent changes in enforcement policies with simple coefficient changes,
both features of the matrix structure. These were judged too valuable
to give up in exchange for some additional simplicity, so the final de-
cision was to retain the original .concept. It was further judged that
no indirect predictor variable, such as population or dollar volume of
industrial output, was likely to be any more precise than the matrix
relationships, even with imprecise coefficients, and it was also recog-
nized that future improvement in the empirical coefficients could be
readily accommodated in the matrix structure.
Data Obtained Purina Agency Visits - The empirical Information ob-
tained from the agency visits will be summarized here in some detail
before turning to discussion and tabulation of the coefficients ulti-
mately utilized in the model.
73
-------
The aggregate manpower allocated by the agencies to the six activities in
the stationary source matrix is summarized in Table 11. It should be noted
that the activity numbers used in the table are from the final computer
program, and differ slightly from the numbers originally used in the
questionnaire: activity 101 (inspections) includes both 101 and 102 from
the questionnaire, while 103 (observing stack tests) is an addition to
the activity 104 (conducting stack tests) as defined prior to the visits.
It will also be noted that there is no information in table 11 on the
predictor variables (i.e., numbers of sources), such as was presented
in the previous discussions of the monitoring activities. Detailed in-
formation on numbers of sources was not strenuously sought during the
agency visits because it was expected it would not be available in a
format consistent with the list of source types being used. This judg-
ment was confirmed during the visits; in fact, most agencies had rela-
tively little ready data on numbers of sources, as opposed to emissions,
etc. The numbers of sources (SCCs) from the NEDS data base are sum-
marized in Table 12, along with the abbreviated category identifiers used
in the computer program.
The source-type-specific data was sought by means of a list of 68 source
types included with the questionnaire sections on inspections (activi-
ties 101 and 102) and equipment plan review (130), and by open-ended
questions whenever relevant. Responses that utilized the bulk of the
extensive source-type list were received from two agencies concerning
their plan review-permit systems. Some of this data, along with the list
of 68 source types, is presented in Table 13. The responses concerning
source inspections, while not utilizing the full range of the source-
type list, did include some reliable estimates of manpower required for
certain specific types; these responses are summarized in Table 14.
Agency B was also able to provide data on the breakdown by activity of
their regional field enforcement/source surveillance staff; these per-
centage breakdowns, tabulated in Table 15, were also utilized in de-
veloping the matrix coefficients.
74
-------
Table 11. AGGREGATE MANPOWER BY ACTIVITY FROM AGENCY VISITS
Activity3
101 . Inspec t ions
103. Observe
stack test
104 . Conduct
stack test
107. Compliance
schedules
110. Legal action
130. Equipment
plans
Agency
A
18.0
5.0
c
1.0*
3.9
5.6
B
9.36
b
1.57
9.33
16.9
32.0
C
13.5+
b
2.33
2.0
1.0
4.0
D
3.0
c
0.25
*
b *
2.88
E
2.0
c
c
0.5
0.2
1.5
F
0.37
c
5.5
b
0.75
1.32
G
0.40
0.50
2.6
0.08
0.8
1.03
H
1.52
c
0.1
c
0.005
0.03
I
0.69
c
0.03
b
0.25
0.01
See pages 64-65 for definitions.
Not definable separately.
Activity not performed by agency.
Anomalous computer system development.
-------
Table 12. NUMBER OF SCO's IN NEDS DATA BASE BY
23 .SOURCE TYPE CATEGORIES
Source type
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
ELEC PP BOILERS >10
COAL, RES ID OIL >100
COAL INDSTRL 10-100
COAL C/I 10-100
OIL-FIRED 10-100
COAL-FIRED <10
SMALL, GAS, MISC.
CHEMICAL MANUFACTURE
FOOD AND AGRICULTURE
IRON/ STEEL INDUSTRY
NON-FE PRIM METLURGY
SECONDARY METALLURGY
PORTLAND CEMENT MFR
STONE QUARRYING
OTHER MINERAL PROD
PETROLEUM PROCESSING
WOOD PRODUCTS
OTHER INDUSTRY
PETROLEUM STORAGE
OTHER EVAPORATIVE HC
OPEN BURNING DUMPS
INDUSTRL INCINERATOR
OTHER INCINERATION
TOTAL
Number of entries
national total
3,312
1,994
1,182
1,828
4,159
518
13,525
4,921
13,952
1,367
800
3,144
782
3,130
7,311
4,224
3,132
8,559
4,789
4,200
987
2,566
1,189
91,571
76
-------
Table 13. EMPIRICAL DATA FROM AGENCY B ON MANPOWER BY SOURCE TYPE
FOR PLAN REVIEW AND PERMIT SYSTEMS
Source type
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
Power plant boiler,
coal-lignite, > 100 MMBtu/hr
, 10-100
, <10
, oil, > 100 MMBtu/hr
, 10-100
, 100 MMBtu/hr
, 10-100
, <10
, oil, > 100 MMBtu/hr
, 10-100
, <10
, gas-coke
, misc.
Commercial-Institutional boiler,
coal-lignite, > 100 MMBtu/hr
,10-100
, < 10
, oil, >100 MMBtu/hr
, 10 - 100
, < 10
, gas-coke
, misc.
Internal Combustion (Stat. sources)
Nitric acid mfg.
Unit manpower estimated
(man-days per review)
Agency B
0.5
0.1
0.05
a
na
0.1
0.05
0.05
0.01
0.5
0.1
0.05
0.05
0,01
0.05
0.01
0.01
na
0.8
0.05
0.05
0.01
0.01
0.01
0.02
0.01
2.0
77
-------
Table 13 (continued). EMPIRICAL DATA
BY SOURCE TYPE
PERMIT SYSTEMS
FROM AGENCY B ON MANPOWER
FOR PLAN REVIEW AND
Source type
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
50.
51.
52.
53.
54.
Paint & varnish mfg.
Sulfuric acid mfg.
Phosphate fertilizer mfg.
Other chemical mfg.
Feed grain handling
Other food & agriculture
Aluminum reduction
Copper smelters
Ferroalloy
Electric arc steel furnace
Other iron and steel
Lead smelters
Zinc smelters
Other primary metals
Secondary aluminum
Gray iron foundry
Other secondary metals
Portland cement mfg.
Coal cleaning
Other mineral products
Petroleum processing
Kraft (sulfate) pulp processing
Other wood products
Metal fabrication
Leather products
Textile mfg.
In-process coal use
In-process oil use
Unit manpower estimated
(man-days per review)
Agency B
0.05
1.0
1.0
1.0
0.3
0.3
0.5
na
1.0
1.0
1.0
0.5
0.5
0.5
0.3
1.0
0.5
2.0
0.5
0.3
2.0
2.0
0.5
0.2
0.1
0.1
na
na
78
-------
Table 13 (continued).
EMPIRICAL DATA FROM AGENCY B ON MANPOWER
BY SOURCE TYPE FOR PLAN REVIEW AND
PERMIT SYSTEMS
Source type ;
55.
56.
57.
58.
59.
60.
61.
62.
63.
64.
65.
66.
67.
68.
In-process gas use
Other in-process fuel use
Dry cleaning
Other solvent usage
Surface coatings
Petroleum storage .
Other evaporative losses
Municipal incinerator
Open burning dumps
Other gov't. incineration
General commercial-institutional
incineration
Flue-fed apartment incineration
Other commercial-institutipnal
incineration
Industrial incineration
Unit manpower estimated
(man-days per review)
Agency B
2.0
na
0.1
0.3
0.3
0.1
0.2
1.0
0.1
1.0
0.1
na
0.05
0.1
na indicates not applicable * no estimate possible.
79
-------
Table 14. SUMMARY OF DATA IN RESPONSE TO
QUESTIONS ON INSPECTIONS
Agency A
No categorization into routine/extensive; most less than 1/2
man-day, some up to 3 to four man-days; frequency/extent
matter of judgment. Not able to provide estimates by source
type; effort determined primarily by familiarity of staff
with process involved and by number of emission points on
premise; following types significantly above average effort:
27 - paint and varnish 35 - ferroalloy
30 - chemical mfg. 36 - electric arc furnace
33 - Al reduction 42 - gray iron foundry
34 - Cu smelters
Agency B
Bulk of inspections handled by regional field staff who also
handle all other contact with sources; hence, not thoroughly
separate from other activities and not estimable by source
type. Following exceptions are handled on statewide basis
by source type:
0.61 man-year for 58 metallurgical facilities (inadequate)
0.28 man-year for 34 power plant facilities
0.42 man-year for 43 petrochemical facilities
Agency C
Inspections generally divided by source size into two groups
routinely handled by the state or by the local agencies, with
flexibility in unusual circumstances. Possible to estimate
by source type only for following types handled on statewide
basis by same individuals (time generally includes most time
with source, not merely inspections).
0.33 man-year for 16 gasoline distribution facilities
0.4 man-year for 84 asphalt batching plants
0.5 man-year for 12 organic solvent facilities
0.25 man-year for 15 to 20 rendering plants
1.0 man-year for 12 major, 8 smaller, power plants
1.0 man-year for one major, two other, steel mills
80
-------
Table 14 (continued). SUMMARY OF DATA IN RESPONSE TO
QUESTIONS ON INSPECTIONS
Agency D
Relatively few major sources; routine structured inspection
program in process of being implemented; routine inspections
by local agencies; long driving time complicates time esti-
mation, no reliable estimate possible by source type.
Agency E
Few major sources; inspections made by regional field staff,
largely on field patrol/complaint basis; no reliable esti-
mates by source type possible.
Agency F
Inspections made on informal, ad hoc basis; no reliable man-
power estimate possible.
Agency G
Relatively new agency with few major sources; inspection
time not significantly affected by source type within set of
source types included in jurisdiction; estimates, including
travel time, follow:
2 man-days for: 2, 3, 10, 11, 18, 19 - coal boilers
< 100 MMBtu
3 man-days for: 1 - coal-fired power plant> 100 MMBtu
9 - coal-fired industrial boiler
>100 MMBTU
31 - feed grain handling
42 - gray iron foundry
44 - portland cement mfg.
68 - industrial incineration
Agency H
Local agency; handles only routine inspections and small
sources; hence, little difference by source type.
Agency I
Local agency; handles all types of inspections, but rela-
tively few different source types within jurisdiction;
specific estimates:
3 man-days - portland cement mfg.
2 man-days - asphalt .batching plant
81
-------
Table 15. SOURCE SURVEILLANCE MANPOWER BREAKDOWN BY
ACTIVITY FROM AGENCY B
Source
Variances
Citizen complaints
Annual inspections
Ad hoc inspections
Requested inspections
Eng. report preparation
Litigation
Emission inventory
Permit workshop
Add. permit workshop
Other activities
Percentage
As reported
15
10
10
2
3
23
19
6
2
9
1
Distributed8
23
15
18
3
4
19
6
2
9
1
23 percent in report preparation distributed to other
activities.
Development of Manpower Coefficients - From the information tabulated in
Tables 11 through 15, it was necessary to develop the manpower factors
(Mxxx) for the various cells in the source type versus activity matrix.
As has been suggested above, this was necessarily a fairly judgmental
operation; this is not as serious, however, as it might at first seem.
While there was relatively little data to use, in comparison to other
activities, and what data there was is relatively inconsistent, the very
existence of the structure which the matrix form provides made it possible
to develop a consistent set of factors that appear to be adequate for the
purpose. As an example, the percentage breakdown in Table 15 could be
used roughly to proportion the coefficients among activities, with the
magnitude of the factors being provided from other data. The matrix
structure also permitted the utilization of the qualitative, "greater-
than-average," type data in adjusting the relative values of factors for
various source types.
82
-------
The largest difficulty with the factor development, and one with which
the matrix features above cannot assist, is the necessity to develop
factors appropriate for the SCO-level data that is available, rather
than for premises. The use of premises as the unit for prediction would
be much more consistent with actual agency practice, and hence would
make it much easier to estimate accurately. This difficulty was isolated
by first developing a matrix of factors applicable to premises, and then
converting this to a matrix of factors applicable to SCO counts by means
of estimates of the typical number of SCCs per premise. Tables 16 and 17
present these two sets of manpower factors; for convenience, the abbre-
viations used for the source types are the same as are used for the com-
puter printout.
Development of Other Matrix Factors - Beyond the factors expressing man-
power per unit performance of an activity, the matrix form prediction
relationship involves an applicability factor (Cxxx) and a frequency
factor (Fxxx). The Cxxx factors represent the percentage of the total
number of sources of a certain type to which activity xxx is applied.
While this factor will in many cases be 100, Indicating the activity
is applicable to all sources, having such a factor in the relationship
provides the ability to adjust the relationship to suit specific poli-
cies. Table 18 presents the factors initially provided in the program.
This table illustrates two different situations involving the use of non-
unity values for this factor. The factor for legal action repre-
sents the obvious fact that all sources do not go to court every year;
the 1 percent figure was estimated from the agency visits. The non-
unity factors for conducting and observing stack tests reflect two dif-
ferent aspects of stack testing - the fact that the observation and the
conduct of such tests are in a sense mutually exclusive activities, and
the fact that such testing is not likely to be universal for smaller
sources. All the factors in Table 18 represent more matters of policy
decision than matters of empirical knowledge; the values provided repre-
sent an amalgamation of EPA policy and the technical judgment and opinion
83
-------
Table 16. PREMISE-BASED MANPOWER FACTORS FOR STATIONARY SOURCE
ACTIVITIES - TIME (hours) PER UNIT PERFORMANCE PER
['REMISE
Source type
1. ELEC PP BOILERS >10
2. COAL, RES ID OIL >100
3. COAL INDSTRL 10-100
4. COAL C/I 10..- 100
5. OIL-FIRED 10-100
6. COAL -FIRED <10
7. SMALL, GAS, MISC.
8. CHEMICAL MANUFACTURE
9. FOOD AND AGRICULTURE
10. IRON/STEEL INDUSTRY
11. NON-FE PRIM METLURGY
12. SECONDARY METALLURGY
13. PORTLAND CEMENT MFR
14. STONE QUARRYING
15 . OTHER MINERAL PROD
16. PETROLEUM PROCESSING
17. WOOD PRODUCTS
18. OTHER INDUSTRY
19. PETROLEUM STORAGE
20. OTHER EVAPORATIVE HC
21. OPEN BURNING DUMPS
22. INDUSTRL INCINERATOR
23. OTHER INCINERATION
Source
insp.
24
10
10
10
8
3
2
24
10
20
20
6
16
10
16
20
6
10
10
16
2
4
2
Stack
test
128
80
64
64
48
32
32
160
32
64
64
32
64
16
32
96
32
32
16
16
16
16
16
Observe
test
32
16
16
16
8
8
8
32
8
16
8
8
16
8
8
16
8
8
8
8
8
8 .
8
Compl.
sched.
Legal
action
Plan
review
Not applicable
to premises
*
84
-------
Table 17. SCC-BASED MANPOWER FACTORS FOR STATIONARY SOURCE
ACTIVITIES - TIME (hours) PER UNIT PERFORMANCE
PER SCC
Source type
1. ELEC PP BOILERS >10
2. COAL, RESID OIL >100
3. COAL INDSTRL 10-100
4. COAL C/I 10-100
5. OIL-FIRED 10-100
6. COAL -FIRED <10
7. SMALL, GAS, MISC.
8. CHEMICAL MANUFACTURE
9. FOOD AND AGRICULTURE
10. IRON/STEEL INDUSTRY
11. NON-FE PRIM METLURGY
12. SECONDARY METALLURGY
13. PORTLAND CEMENT MFR
14. STONE QUARRYING
15 . OTHER MINERAL PROD
16. PETROLEUM PROCESSING
17. WOOD PRODUCTS
18. OTHER INDUSTRY
19. PETROLEUM STORAGE
20. OTHER EVAPORATIVE HC
21. OPEN BURNING DUMPS
22. INDUSTRL INCINERATOR
23. OTHER INCINERATION
Source
insp.
12
5
5
5
4
3
2
5
3
4
5
6
4
3
4
3
2
4
2
3
2
4
2
Stack
test
64
40
32
32
24
32
32
32
3
16
16
32
16
8
8
" 16
8
16
3
3
16
16
16
Observe
test
16
16
8
8
8
8
8
8
2
3
2
8
4
4
2
1
4
4
1
1
8
8
8
Compl.
sched.
8
8
8
8
6
6
2
2
2
3
4
3
3
2
3
2
2
2
1
1
2
2
2
Legal
action
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
120
Plan
review
4
4
8
4
2
2
1
8
2
8
8
8
8
2
8
2
2
6
1
2
1
4
4
85
-------
Table 18. PROPORTIONAL APPLICABILITY FACTORS FOR STATIONARY
SOURCE ACTIVITIES - PERCENTAGE OF SOURCES (SCCs)
SUBJECT TO ACTIVITY
Source type
1. ELEC PP BOILERS >10
2. COAL, RES ID OIL >100
3. COAL INDSTRL 10-100
4. COAL C/I 10-100
5. OIL-FIRED 10-100
6. COAL-FIRED <10
7. SMALL, GAS, MISC.
8. CHEMICAL MANUFACTURE
9. FOOD AND AGRICULTURE
10. IRON/STEEL INDUSTRY
11. NON-FE PRIM METLURGY
12. SECONDARY METALLURGY
13. PORTLAND CEMENT MFR
14. STONE QUARRYING
15 . OTHER MINERAL PROD
16. PETROLEUM PROCESSING
17. WOOD PRODUCTS
18. OTHER INDUSTRY
19. PETROLEUM STORAGE
20. OTHER EVAPORATIVE HC
21. OPEN BURNING DUMPS
22. INDUSTRL INCINERATOR
23. OTHER INCINERATION
Source
insp.
100
100
100
100
100
100
10
100
30
100
100
100
100
50
80
100
80
50 '
100
100
100
100
100
Stack
test
50
50
50
50
50
20
10
30
40
30
30
40
40
10
20
10
10
30
10
10
0
10
30
Observe
test
50
50
50
20
20
10
0
20
10
20
20
10
10
0
10
10
0
30
10
10
0
0
10
Compl.
sched.
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
Legal
action
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Plan
review
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
86
-------
of EPA, GCA, and the agencies visited. In particular, the factors for
stack testing are a matter of EPA judgment, as none of the agencies ac-
tually had a full-fledged, routine stack test program implemented.
The frequency per year factors (Fxxx), presented in Table 19, are like-
wise largely a matter of policy rather than empirical fact. It would be
possible to combine these frequency factors along with the manpower fac-
tors into a single annual manpower factor for each activity' and source
type. This was not done because the separation of the information
into two factors was felt to provide a useful increase in flexibility,
improving the model's ability to evaluate the effect of hypothetical
policy changes.
Other Stationary Source Activities - In addition to the six major activ-
ities that are incorporated into the source-type matrix, there are several
other stationary-source-oriented activities that are projected on the
basis of simpler predictor variables. These include complaint investiga-
tion and small source enforcement, tax exemption certification, the re-
view of development plans, and the travel time involved in enforcement.
Complaint Investigation and Small-Source Enforcement - Beyond the man-
power identified for specific inspections, compliance negotiations, etc.,
all of the agencies identified some manpower as being expended on mis-
cellaneous enforcement activity directed at small or intermittent sources.
These efforts include such things as the investigation of complaints,
supervision of open-burning permits, field patrol and general surveillance,
etc. The data obtained are tabulated in Table 20, along with population
data. It is clear that the agencies in "clean-air" states (D, F, and I)
expend much greater proportional effort in these activities; this is
apparently because they have fewer or no large sources within their
jurisdiction, so that the smaller sources are a larger share of the
problem. Accordingly, the variable FTE, developed for the public informa-
tion activity, was utilized as an indicator of the states with such a
87
-------
Table 19. FREQUENCY FACTORS FOR STATIONARY SOURCE ACTIVITIES -
NUMBER OF PERFORMANCES PER YEAR
Source type
1. ELEC PP BOILERS >10
2. COAL, RESID OIL >100
3. COAL INDSTRL 10-100
4. COAL C/I 10-100
5. OIL-FIRED 10-100
6. COAL -FIRED <10
7. SMALL, GAS, MISC.
8 . CHEMICAL MANUFACTURE
9. FOOD AND AGRICULTURE
10. IRON/STEEL INDUSTRY
11 . NON-FE PRIM METLURGY
12. SECONDARY METALLURGY
13 . PORTLAND CEMENT MFR
14. STONE QUARRYING
15 . OTHER MINERAL PROD
16. PETROLEUM PROCESSING
17. WOOD PRODUCTS
18. OTHER INDUSTRY
19. PETROLEUM STORAGE
20. OTHER EVAPORATIVE HC
21. OPEN BURNING DUMPS
22. INDUSTRL INCINERATOR
23. OTHER INCINERATION
Source
insp.
1
1
1
1
0.5
0.5
0.3
1
1
1
1
1
1
1
1
0.5
0.3
0.5
0.3
1
1
1
0.5
Stack
test
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Observe
test
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Compl .
sched.
Not
appli-
cable
Legal
action
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Plan
review
1
1
1
1
0.5
0.5
0.3
1
1
1
1
1
1
1
1
0.5
0.3
0.5
0.3
1
1
1
0.5
83
-------
Table 20. DATA RELATIVE TO COMPLAINT INVESTIGATION AND
SMALL-SOURCE ENFORCEMENT
Agency
A
B
C
D
E
F
G
H
I
Manpower
3 +
4.7
53
8a
1.6
5.6
3.8
0.52
2.6
Population
(millions)
3.032
11.114
3.922
2.207
1.744
1.016
2.825
0.298
0.316
Ratio
1.0 +
0.42
1.28
3.63
0.92
5.5
1.35
1.75
8.2
Including estimated contributions from local agencies.
situation. The variable FTE serves to double the estimate for agencies
in states with a "clean-air", tourist image. The predictor relationship
used is MY105 = 0.0015*POP*FTE(ISTATE), that is, an estimate of 1.5 per
million population.
Tax Exemption Certification - This activity includes the effort required
to evaluate and process applications for tax exemption or other adjustment
on pollution control hardware purchases. Three of the seven state agencies
visited had enough of such effort to make a meaningful estimate of the
time required. Agency A spent 1.0 manyears in an extensive review of such
applications, including followup site visits. Agency B reported 0.9 man-
years, and agency G only 6 mandays, in less extensive efforts. Since it
was not possible to project the.number of applications, due to variations
in the laws, it was decided to use a simple estimate based on the total
number of sources (SCC's). .The relationship used was 0.0003 manyears per
source, which is about midway in the range of responses.
89
-------
Review of Development Plans - This activity was originally posed as four
separate activities, derived in the questionnaire as follows:
131-134* As a group, these next few activities are meant to include the
efforts to review proposals for new sources, both direct and indirect, to
assure their being consistent with the achievement and maintenance of the
NAAQS.
131. Review of Development Plans - This activity is defined as the review
of specific development plans with respect to their direct and indirect
emissions, the emissions from associated development, and the generation
of displaced emissions, including the selection of sites for stationary
sources. This activity includes the receipt and processing of a permit
application, the examination and evaluation of the projected air quality
impact for consistency with on-going plans for achieving and maintaining
the NAAQS, and the ultimate decision. The quantitative analysis required
for the projections are included separately as activities 132-134. The
compliance of stationary source equipment with emission standards, as op-
posed to siting, is covered in activity 130.
132. Microscale Modeling and AQ Estimation - This activity includes the
microscale modeling or other procedure used for estimating the AQ impact
of a proposed source of either direct or indirect emissions. If the source
is very large, regional-scale modeling may be more appropriate, and in such
cases, is also included in this activity.
133. Review of Source-Conducted AQ Estimation - This activity involves the
review by the APC Agency of modeling, monitoring, or other estimation
procedures conducted by an applicant for a permit to construct a proposed
source.
134.. Technical Land Use Planning - This activity includes the effort
needed to provide technical planning support to the agency management in
guiding the land use planning functions. It also provides technical sup-
port for the analysis of the developmental implications of various al-
ternate policies, their other ramifications, likely obstacles to their im-
plication, and so on, as well as the technical planning expertise necessary
to support the review of development proposals.
No agency was able to provide a good, reliable breakdown of their efforts
into this structure, in large measure because their plans were not yet
complete and operational. Consequently, the activities were aggregated
into one, called in the computer program MY131 - Review of Development
Plans. The combined manpower reported for these activities is tabulated
in Table 21.
90
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Table 21. DATA RELATIVE TO THE REVIEW OF DEVELOPMENT PLANS
Agency
A
B
C
D
E
F
G
H
I
Manpower
7.16
4.2
0.83
2.0
0
0.31
0.36
a
0.06
Population
(millions)
3.032
11.114
3.922
2.207
1.744
1.016
2.825
0.298
0.316
Ratios
2.36
0.38
0.21
0.91
0.0
0.31
0.13
a
0.19
Not perfprmed.
The value of the ratios in Table 21 are relatively consistent with the
exception of that from Agency A. This is because only Agency A had any
kind of a functioning program to review development plans on a reasonably
on-going basis; the other agencies were all still in one stage or another
of developing their plans to undertake this responsibility. The agency
visits were conducted during a period when EPA regulations impacting on
these efforts were not available, with several divergent possibilities
under active consideration. A common response from interviewees was that
the final definition of their plans was contingent on EPA policy.
The manpower spent by these other agencies (Table 21) consisted primarily
of planning efforts and of irregular situations where some effort on these
tasks was expended. Most of the agencies felt that regular performance of
these reviews would require greatly increased efforts on the part of one
agency or another, depending on the ultimate decisions to be made. Con-
sequently, the manpower factor was chosen to be essentially that experi-
enced by agency A; the relationship used is MY131 » 0.00235*POP, or 2.35
per million population.
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Travel Time for Enforcement - Information was sought during the agency
visits that would relate the travel time involved in enforcement activities
in some empirical way to the parameters of the agency or its jurisdiction.
No satisfactory empirical information could be developed, however, for a
variety of reasons. Accordingly, the projection is made on the basis of
the square root of the area, as a rough measure of the typical trip lengths,
and the number of trips, estimated from the stationary source matrix activ-
ities. In order to adjust as accurately as possible to the differences
between areas with and without local agencies, this estimation is done in
two ways: If there are local agencies in an AQCR, half the number of
trips are used, with the area of the AQCR, to estimate part of the time
spent in travel. The other half of the number of trips, plus those origi-
nating in AQCR's with no local agencies, are used with the area of the
state to estimate the balance.
Mobile Source Control Activities - Because the serious undertaking of mobile
source control has only begun very recently, and only in the more urban
states, the final structuring of the activities and projections in this
area was done only following the visits to the agencies and the evaluation
of their responses. It was then concluded that the activities separately
identified should be the on-going development and refinement of the trans-
portation control plan (a set of revisions to the SIP to provide for auto-
mobile pollutants), including the required extensive traffic study/emission
inventory, and the actual control activities themselves, although most of
them are not yet implemented.
Transportation Control Plan and Emission Inventory - An estimated manpower
requirement of 0.30 manyears has been provided in AQCRs that are priority
I for either CO or photochemical oxidants. This amount of manpower is not
adequate to develop a transportation control plan (TCP); additional man-
power would need to be estimated in any urban area that might be required
to prepare a plan in the future. Rather, the manpower estimated is for
the efforts involved in on-going concern with revisions, appeals, updates,
92
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and so on. The effort that is required was estimated from discussions
with Agency C and experience with TCPs in other areas.
Mobile Source Control - The current status of the actual control of mobile
sources is such that no sizable amount of experience is available on which
to draw. Estimates have been included in the model for only the one most
common control measure - a periodic motor vehicle inspection system with
required maintenance. There are three general types of inspection pro-
grams - visual inspection, idle emissions testing, and loaded or dynamom-
eter testing. The model contains, for each state, a code (INSTYP) iden-
tifying the type of inspection system, if any, adopted by that state, and
associated manpower factors (FMVINS) per vehicle. The codes and the man-
power factors are tabulated in Table 22.
Table 22. FACTORS FOR ESTIMATING MANPOWER NEEDED FOR INSPECTION PROGRAM
INSTYP (ISTATE)
1
2
3
4
5
6
7
Type of inspection
None
Annual visual
Annual idle-mode
Annual dynamometer
Semi-annual visual
Semi-annual idle-mode
Semi-annual dynamometer
Factor
(manyears per 1000 vehicles)
0.000
0.008
0.016
0.024
0.016
0.032
0.048
Episode Prevention
The final source-oriented activity is one that is not classifiable as
either entirely stationary - or mobile-source oriented. The episode pre-
vention activity is defined to include any effort involved in maintaining
surveillance for periods of unusually-adverse dispersion, plus the effort
required to conduct episode avoidance activities when required.
93.
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The relationship used depends on the priority classification of each AQCR,
the total number of sources involved (NTSRC), and the number of days per
year (NODAYS) of adverse dispersion forecast by the APPF program,, If the
AQCR is priority I for oxidants only, the manpower is estimated as MY160 =
0.03 + 0.002*NODAYS. If the AQCR is priority I for SC>2, TSP, or both, the
estimate is MY160 = 0.03 + 0.002*NODAYS + 0.0005*NTSRC. If both situa-
tions apply, the estimates are added together.
Management and Support Activities
The functions included under this heading are those that do not relate
directly to either the air quality monitoring activities or the source
surveillance and enforcement activities of an agency. They include the
overall administrative and technical management of a control program,
training activities, professional support efforts, and clerical support
activities. In most cases, they are estimated with empirical relation-
ships based on the size of the technical staff they support, referred to
as total technical personnel, or TTP in the computer program.
Program Management - This activity includes the various efforts required
for overall program management, Including the development of agency
policies, the planning of activities and resource allocations, and the
determination of the general direction and thrust of the agency's
pollution control program. The efforts of an Air Pollution Control Board
or Commission, originally asked about separately, were combined into this
activity. Activities relating to liaison with other state agencies, also
originally considered separately, were included to the extent they could
not be assigned elsewhere for specific tasks (e.g. liaison re transporta-
tion controls). Those activities, generally staff activities, that are
specifically directed at developing new or revised regulations or overall
control strategies or "implementation plans" are not included but rather
are considered separately under Strategy and Regulation Development.
94
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Reliable estimates were obtained from eight agencies. As indicated in
Figure 8, the results proved, not unexpectedly, to be very closely
related to the size of the technical staff of the agency. The curve is,
however, highly nonlinear, with very dramatic reductions in the manage-
ment/staff ratio with increasing agency size. This is quite a reasonable
phenomenon, and the points define the curve quite precisely (even the
slight departure of agency C is interpretable in terms of their organiza-
tional structure). Consequently, the relationship as plotted in Figure 8
was used for the-projection relationship, even though it is mathematically
more complex than most of the others. The relationship is:
Management = 1.433 x (technical staff)0
or, as expressed in the computer program,
MY301 = 1.433 * TTP ** 0.175.
Because of the striking non-linearity of this relationship, it makes a
significant difference at what geographic scale the projections are made.
In contrast to the linear relationships, this projection cannot be made
on an AQCR scale and accumulated to provide a total for a state agency.
Neither, however, can a single projection based on total state require-
ments adequately account for the management required if there are a sig-
nificant number of local agencies. In the model, this conflict is re-
solved, albeit probably imperfectly, in the following manner. At the
AQCR level, a projection of manpower for local agency management is made
if there is at least one local agency in the AQCR (i.e. if variable NLA 4 0);
the technical staff (TTP) used in the projection is noted. When the
state totals are being summarized and projected, the estimate of state
agency management manpower is made based on the total technical staff re-
quired for the state, less one-half of the accumulated technical staff
(if any) that was used as a basis for local agency management estimates.
The factor of one-half simply embodies the concept that the existence of
local agencies does not preclude the requirement for a substantial state
involvement in the AQCR; the quantitative value of the factor would need
95
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vO
0.36
0.32 h
028
2 Q24
o
o
g 0.20
LU
0.16
0.12
0.08
0.04
T I
\ I
«c
I
10 20 30 40 50 60 70 80 90 100
TOTAL TECHNICAL PERSONNEL (TTP)
1
_L
110 120
Figure 8. Program management
-------
to be refined if the specific issue of state versus local management
were of primary concern.
Strategy and Regulation Development - This activity includes the effort
required to develop and evaluate possible alternative approaches or
strategies for the control of pollutant sources, such as effort in operat-
ing a diffusion model and in conducting economic and sociological impact
analysis of alternative strategies. It also includes the effort involved
in developing the detailed technical and legal form of proposed regula-
tions and any required supporting documentation. In the questionnaire
and interviews, these activities were pursued as six separate functions.
The following are the specific definitions of these activities (310 through
315), as extracted from the questionnaire:
310. Development of New or Modified Control Strategies - This activity is
defined to be the effort required to develop possible policies or control
strategies for consideration by the agency management; it is expected that
this effort will be conducted by staff members working very closely under
the direction of the agency director, although the ultimate policy de-
cisions are considered separately in activity 301 (program management).
The quantitative analysis of such control strategies is also considered
separately in activities 310-313. If manpower was separated into these
activities, this (314) includes the balance; if not, it includes the total.
311. Climatological Dispersion Modeling
312. Economic Impact Analysis
313. Community Interaction and Social Impact Analysis
314. Quantitative Evaluation of Alternate Strategies - These activities
provide for the quantitative assessment of the effectiveness and other
impacts of proposed alternate control strategies, for purposes of assist-
ance in decision-making, attempting to anticipate public reaction and
avoiding difficulties, etc. Activities 311-313 represent specific major
tools or capabilities that are a part of an overall assessment; activity
314 includes primarily the assessment of the strategy effectiveness in
conjunction with the emission inventory. The development of the alternate
strategies is considered in Activity 310; activity 310 can be used to In-
clude the entire manpower in 310-314 if quantitative subdivision is not
possible.
Activity 311 is defined as the effort needed to maintain and use a cli- -
matological-scale dispersion model for purposes of control strategy
97
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planning, etc., including the gradual adaption of existing standard com-
puterized models to the topographic and other idiosyncrasies of the
area(s) in question.
Activity 312 involves the preparation of economic analysis to provide
reasonable estimates of the impact of regulations on impacted industries
and the economic viability of the region as a whole.
Activity 313 is limited to the programmed interaction with survey panels
of "unorganized" citizens as well as citizen interest groups and the
analysis of the impact of proposed AFC agency actions on the lifestyles
of the community. Public hearings are included separately under activity
315.
315. Development and Adoption of New or Modified Control Regulations -
This activity is defined as the efforts involved in developing the de-
tailed technical and legal form of proposed regulations to implement the
policies selected in activity 314, preparing the required supporting docu-
mentation, and seeing the regulations through the adoption procedure, in-
cluding legislative liaison. It includes the manpower involved in pre-
paring and conducting public hearings, except for the small effort in pu-
blicizing them, which is in activity 370 (public Information).
The majority of respondents in the agencies felt that the breakdown of
activity 310 into items 311-314 was too detailed to permit separate estim-
ation (although the extra items did help bring into focus the overall con-
cept of control strategy development, which had not been seen by most of
the agencies as an identifiable function). Of the nine agencies, one
could provide a breakdown into the several functions, and two others were
able to isolate at least one activity; all nine, however, could provide
an aggregate estimate for all six combined, including one estimate of 0.
Consequently, the six have been aggregated into one for projection.
The information on the combined activity (called MY310 in the computer
program) is plotted in Figure 9 as a function of total technical staff.
The relationship is similar to that for program management, although less
precisely defined. The general opinion of the agencies visited was that
these functions were essentially state responsibilities, although one
local agency did invest nearly 1 man-year in this type of activity. Con-
sequently, the manpower expended by the one local agency (the other re-
ported none) was included with its state agency, and the relationship Is
98
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0.36
VO
vo
10 20
30 40 50 6O 70 8O 90 100
TOTAL TECHNICAL PERSONNEL,TTP
HO
120
Figure 9. Control strategy and regulation development
-------
used in the model for state-level projections. The expression for the
relationship is:
Strategy development » 0.871 x (technical staff) '
or, as expressed in the computer program,
» 0.871 * STTP ** 0.45
Liaison Activities - Anticipating that a significant share of the time of
various agency staff members might be spent in the communication and co-
ordination among various agencies that necessarily characterize complex
governmental programs, a number of types of liaison were identified as
specific activities in the questionnaire and during the agency visits.
While agreeing that such activities could consume a measurable amount of
time, most of the agency staff interviewed felt it was not possible or
useful to try to estimate separately the time spent. Consequently, any
effort along these lines was implicitly included with other activities,
with the two exceptions of liaison with other states concerning policies,
episodes, etc. in interstate AQCR's, and the liaison with local agencies.
Interstate Liaison - Agencies were asked about time spent in coordinating
with EPA and other air pollution control agencies. Aside from communication
with local agencies within their jurisdiction, the state agencies identified
two areas where time was spent - contact with EPA and contact with other
states over interstate AQCR's.
The estimates of time, spent In contact with EPA were very erratic, ranging
from zero to half the agency director's time. The variation seemed to be
caused mainly by highly individualistic differences in the people involved
and the current status of agency activity relative to important EPA policy
matters, such as transportation control planning. After considering various
ways of handling this Information, it was ultimately concluded that it
should be included within the agency management activity, since that ap-
propriately covered the substance of the EPA contacts and the precision
of the resultant relationship lent credence to the decision.
100
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In contrast, the time spent in liaison with the other states'involved in
interstate AQCR's is separately incorporated in the computer model at the
AQCR level. The relationship used is:
MY340 - 0.025 * INTERS,
where INTERS is an input indicator variable that is set to one if the
AQCR is interstate, and to zero otherwise. Thus the relationship simply
serves to add 0.025 man-year (50 hours) for each interstate AQCR involved
in the State's jurisdiction. This estimate is based on estimates from
two state agencies, one of which spent the time in monthly planning com-
mittee meetings, the other of which spent much of the time in interstate
consultation during potential emergency episodes.
Local Agency Liaison and Assistance - The other category of liaison ac-
tivity specifically included in the model is the liaison with, and pro-
vision of assistance to, local agencies within the state agency's Juris-
diction. This effort is estimated, at the AQCR level, as 0.10 man-year
for each local agency in the AQCR. The data on which this estimate is
based is tabulated in Table 23. The highest ratio, from agency C, re-
flects the fact that the local and state agencies in that state are
operating a coordinated, well-integrated control plan in which each has a
significant defined role. The low ratio from agency D reflects the fact
that the local agencies there do very little except operate monitoring
sites. Similarly, the fact that two states felt unable to estimate any
manpower reflects the small effort prompted by the small number of local
agencies in those states.
Training Activities - Information was solicited during the agency visits
on three types of training activity: in-house training, training at EPA
courses, and graduate school training, with the former divided initially
into time spent by trainees and time spent by teachers. Table 24 sum-
marizes the data gathered.
101
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Table 23. DATA RELATIVE TO ESTIMATING STATE-LOCAL
LIAISON MANPOWER
State
A
B
C
D
E
F
G
Manpower
(man-years)
1.0
1.0
1.89
0.20
a
a
0.19
No. of local
agenc ies
12
11
10
7
1
1
2
Average
Ratio
0.083
0.090
0.189
0.029
a
a
0.095
0.097
Not separately definable.
In-house training - The separate information on trainees and teachers
presented several inconsistencies, as is apparent in the table. In some
cases (e.g., agencies A and C) this was because training was offered by
state agencies to local agency staff personnel or others outside the
agency, while in other cases (e.g., agencies B and I) the informal or
seminar approach utilized precluded a clear delineation of teacher and
trainee. Consequently, the data were totaled and used in this combined
form. As such, the resulting relationship is an amalgamation of formal
training (primarily for new employees) and informal sessions; several
agencies also emphasized that much training necessarily takes place in a
passing manner and is thus not accountable. The ratio of manpower spent
on in-house training to total technical staff ranged from 0.16 percent
(agency A) to 7.5 percent (agency I), and averaged 2.67 percent. Since
there was no evident economy with respect to size of staff, it was deter-
mined to use a simple relationship with an average ratio. However, there
were only four estimates that were believed to be complete, with both
trainee and teacher time included fully, and also to represent a stable,
adequate level of training. These four (B, F, G, and I) averaged
102
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Table 24. DATA RELATIVE TO TRAINING ACTIVITIES
Agency
A
B
C
D
E ...
F
G
H
I
In-house training
Teachers
0.16
a
0.30
a
a
0.05
0.24
a
0.48
Trainees
a
a
a
a
0.25
0.42
0.38
0.06
0.24
Total
0.16
4.49
0.30
a
0.25
0.47
0.62
0.06
0.72
EPA
training
courses
1.80
0.12
0.05
0.46
b
0.40
0.38
b
0.20
Graduate
school
training
0.75
b
1.25
b
b
1.00
0.30
b
b
Total
technical
staff
97
91.8
47.95
32.75
40.94
21.48
14.3
9.62
5.75
Not separately definable.
Activity not performed.
-------
3.2 percent and this figure was used for the projection relationship;
i.e., MY360 = 0.032*TTP.
EPA Training Courses - The manpower expended in sending staff to EPA
training courses was solicited, and figures were provided by all agencies,
including two that had not sent anyone recently. The apparent relation-
ship found was a nonlinear one, with a higher proportion of manpower spent
by the smaller agencies. This appears to reflect the fact that the
smaller agencies tend both to be the newest and to have the least in-
house resources for training of new staff.
The relationship used is:
MY362 = (0.04 - 0.001 * TTP) * TTP for TTP < 30;
for TTP of 30 or more, MY 362 is estimated at 0.01 * TTP.
The difficulty arising in applying such a nonlinear relationship to state
and local agencies of greatly varying size is handled in much the same
manner as for activity 301, Program Management. The calculation is made
at the AQCR level if there are local agencies, and at the state level
otherwise.
Graduate School Training - Four of the nine agencies released employees
for a significant share of time, up to full-time for 1 year, to undertake
graduate training programs. The other agencies all supported this ac-
tivity, but had not done so themselves either because there were regula-
tions preventing it, or more commonly because adequate part-time, after-
hours training was available locally. The relationship utilized is a
nonlinear one similar to the one for EPA training:
MY363 = (0.04 - 0.0003*TTP)*TTP for TTP < 100;
for TTP of 100 or more, MY 362 is estimated as 0.01 * TTP.
The interaction between the nonlinearity and the scale of area for which
the estimates are made is again handled in the dual manner described
under Program Management.
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Professional Activities - Under the heading of professional activities,
the questionnaire inquired about time involved in conferences, professional
meetings, etc., including time for travel and .preparatory activities. The
data elicited is tabulated in Table 25; the predictor relationship used
is MY364 = 0.005 * (TTP + MY301 + MY310). Since the time involved was
very frequently the time of the most senior members of the staff, the
predictor relationship is based not solely on the number of technical
staff members, but on that number (TTP) plus the manpower involved in
program management and regulation development (MY301 and MY310). As
such, it is also calculated on a dual AQCR - state basis, contingent on
the existence of local agencies in an AQCR, although the relationship
itself is linear.
Table 25. DATA RELATIVE TO ESTIMATING MANPOWER SPENT IN
PROFESSIONAL ACTIVIIES
Agency
A
B
C
D
E
F
G
H
I
Manpower
0.20
0.76
0.06
0.34
0.06
b
0.08
b
0.14 , x:;;
Staff3
100.7
95.0
50.0
34.4
41.5
23.9
16.7
11.9
7.7
Ratio (%)
0.20
0.80
0.12
0.99
,6.14
. b
0.48
b
1.83
Includes program management.
Not separately definable.
105
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Public Information - The activity labeled public information is defined as
"the active, organized dissemination of information on the APC
agency, the air pollution problem, and proposed agency actions.
Press releases, prepared articles, school and community groups
presentations would be included in this activity. The conduct
of public hearings is not included, although dissemination of
public notices is."
The data obtained is tabulated in Table 26, along with the values of
three supplementary variables utilized in the projection relationship.
The public information manpower, when studied in light of what was actually
done with the time, proved to be more related to the nature of the state
and their pollution problem than to agency size. Consequently, the pro-
jection relationship was designed to include these factors, represented
by various other variables. The relationship as determined for states is:
MY370 0.20 * FTE(*ISTATE) * NPRIl + 0.2 * lORG(ISTATE)
The FTE variable is used as a carrier of information on the clean air/
tourist image of a state. It was clear from the discussions with the
agencies that this was an important factor; "clean-air" states spent a
much greater effort in proportion to their pollution problem than did
other states. The variable FTE in the program is given a value of 1 or 2
for each of the states, thus effectively doubling the estimate for those
states that make clean air an important part of their tourist image. The
variable NPRIl is simply a count of the number of AQCR's with TSP priority
1 within the state; it is used as a rough measure of the severity of the
state's pollution problem. The IORG variable is an indication of how the
air pollution agency fits into the state organizational structure; it is
set to 0 if the agency is par>t of a much larger Health or Environmental
Protection Department, and to 1 if it is an independent commission or
agency. The inclusion of the IORG variable reflects the fact that there
are efficiencies in utilizing a large, departmental, public information
operation for such things as press releases and newsletters; that portion
of the relationship has the effect of adding 0.2 man-years for those
agencies that do not have access to such a departmental operation.
106
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Table 26. DATA RELATIVE TO ESTIMATING MANPOWER SPENT IN PUBLIC
INFORMATION ACTIVITIES
Agency
A
B
C
D
E
F
G
H
I
Manpower
0.43
1.18
0.50
0.80
1.20
1.00
0.75
0.01 (+)
0.90
Supplementary variable*
FTB
1
1
1
2
1
2
1
1
1
MPRI1
2
7
3
3
6
2
6
IOBC
0
0
0
0
1
0
0
0
0
*Not applicable to local agenclea.
Library and Archives - The latter portion of this activity was included
in the questionnaire as a possible activity that may be emerging as states
become more involved with the public hearings required under the Clean Air
Act. None of the agencies visited had made any particular arrangements
for maitaining documents for public inspection, though several felt it a
good idea; consequently, the manpower reported (see Table 27) was .essen-
tially only library service. Actually, the effort involves only the
semi-clerical maintenance of a library, the filing, purchasing, etc.,
rather than any technical library work, such as literature searching;
such effort was left to the technical staff and to such outside assistance
such as EPA's APT1C searches. The people actually involved are generally
clerical or administrative staff, rather than professional librarians.
The manpower required is estimated at 0.3 percent of the total technical
staff, including program management.
Clerical Support - This activity involves the manpower required for general
secretarial support; any routine clerical activity involved in such things
as data processing or permit handling is included with those activities.
The information was sought for separate groups of professional staff, in
the belief that the ratios would be different, and they did in fact prove
to be so. The clerical support ratios are tabulated in Table 28, along
with the ratios used in the program. The ratios selected are based prim-
arily on the data from the state agencies.
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Table 27. DATA RELATIVE TO ESTIMATING LIBRARY MANPOWER
Agency
A
B
C
D
E
F
G
H
I
Manpower
a
0.3
0.1
0.2
0.04
0.10
0.75b
0.037
a
Staff
100.7
95.0
50.0
34.4
41.5
23.9
16.7
11.9
7.7
Ratio (7.)
a
0.32
0.20
0.58
0.10
0.44
4.5b
0.31
a
None separately defined.
Abnormally high for special one-time reason.
Table 28. RATIOS OF CLERICAL SUPPORT TO PROFESSIONAL STAFF
Agency
A
B
C
D
E
F
G
H
I
Model
Management
0.67
1.00
0.67
0.80
0.75
1.00
0.43
0.50
0.50
0.80
SS enforcement
0.24
0.20
0.33
0.22
a
a
a
a
a
0.24
Other technical
0.100
0.123
0.127
0.148
0.183
0.125
0.133
0.083
0.091
0.125
Not separately definable-included in other technical.
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SECTION IV
INITIAL MODEL APPLICATION
As part of the model development effort, an initial version of the data
base used by the model was prepared and used in testing the computer
program. The model in its final form was then exercised on this data,
both to provide an initial set of manpower estimates for EPA and to
permit an overall rough check of model performance. This section de-
scribes the data and data sources that were utilized for this initial
application, and discusses the rough check of the manpower estimates
obtained.
DATA BASE UTILIZED
The data required to operate the model can be conveniently classified
into four groups - three types of AQCR-level data and one group con-
sisting of State-level information. The three types of AQCR-level data
are associated with three different card inputs to the computerized
model, while the State-level data are provided to the program via data
initialization instructions (DATA statements) within the program source
deck itself.
AQCR Monitoring Data
The model requires, for each AQCR or State portion thereof, the number
of sensors of various types operated within the area in question. The
list of the 12 sensor types used can be seen in the array of monitoring-
based activities in Table 4.
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Data on the numbers of hi-vols, bubblers, and continuous instruments
(except hydrocarbons) were provided by EPA from tabulations that were
originally based on the various State Implementation Plans. Data was
available in computerized format by state portion of AQCR for both the
minimum required numbers of sensors and the number proposed in the
SIP's; the initial application used the latter, which are generally
larger and closer to the numbers being actually operated in the field.
Data on numbers of tape samplers, continuous hydrocarbon analyzers,
and dustfall collectors were obtained from an inventory of the National
Aerometric Data Bank (NADB). An inventory of all stored data on the
relevant pollutants was provided by NADB, and from this was determined
the number of sites that appeared to be operated in a routine, on-going
manner. Because the data bank is known to be incomplete with respect
to noncriteria pollutants, these numbers are presumably low.
The input format also calls for the number of the continuous sensors
that are telemetered, for use in estimating data processing efforts.
This variable (NSRT) is currently set at 0 for every AQCR, lacking any
complete data base. This information, along with some other data, will
need to be supplied by the EPA Regional Offices, as is discussed in the
next section.
AQCR Source Data
The source data required for the operation of the model consists of
counts, in 23 categories, of the number of SCO-coded emission-producing
processes in the AQCR. These data were summarized -from an SCC Report
by County, one of the routine NEDS retrieval formats, which was provided
as a computer tape by NADB. The NEDS summary format was primarily direct-
ed at summarizing emissions of the criteria pollutants by county, but it
also included a count by SCC of the sources in each county. A series of
110
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computerized routines was developed to summarize the counties by state
portion of AQCR and the SCC's by the 23 categories utilized in the man-
power model program;
It should be emphasized that the source data input format was developed
to fit this particular NEDS summary, as being the only way to obtain the
counts of sources that the NEDS data base should provide. Using SCCs
in 23 categories is not necesszrily the way in which to make maximum use of
the empirical data on manpower usage available from agencies. As is
discussed further elsewhere, this interface with the NEDS system is the
area of the greatest need for further systems development to support the
manpower program. In particular, the use of the number of premises,
possibly categorized by the number of SCC's or emission points con-
tained, rather than just the number of SCC's, should be incorporated
into the manpower model if and when an adequate data base can be pro-
vided by NEDS.
Quite beyond the manner in which the nature of the system is dictated
by the availability of NEDS information, the degree of completeness of
the data base in the NEDS system also has a direct bearing on the re-
liability of the manpower estimates made with the manpower model.
While no thorough survey of the completeness of NEDS was made (or
indeed is even possible) within this effort, occasional comparisons
that occurred in the process of handling the tape files suggested that
the data base is seriously incomplete. Ihis of course merely confirms
what is generally recognized by the NADB staff and others involved
with the NEDS system.
As a consequence of this incompleteness, the aggregate manpower esti-
mates must be viewed with some caution; the national projections are
most likely low to some unknown degree. The subtotals for any given
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State or EPA Region, however, can be interpreted in the light of know-
ledge of the status of the emission source data base for that State or
Region. If the NEDS data base is up-to-date and complete, the estimates
for that State or Region will be quite adequate.
AQCR Background Information
Ihe third set of AQCR-level input data, contained on the third input
card format, consists of background information; the third card also
provides the alphabetic name of the AQCR to the computer. Sources for
the data used for these variables for the initial model application
are as follows.
Number of Local Agencies - Determined from the APCA Directory of Air
Pollution Agencies, 1973-1974 Edition.
Priority Classification - Used as reported in August 1973 Air Quality
and Emissions Trends Report, except for nitrogen oxides priority, for
which subsequent Federal Register promulgation was used.
Stagnation Days - The average number of days with APPF was read, to
the nearest whole day, from Holzworth (AP-101).
Area and Population - The land area and population for each AQCR was
taken from the August 1973 Air Quality and Emissions Trends Report,
which utilized information stored in the NADB data system; population
data was from the 1970 census.
State-level Input Information
The final set of variables in the data base are those providing infor-
mation at the State level. These are provided to the program with data
initialization statements included in the manpower program itself.
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Beyond the alphabetic name of the states and their land areas and
populations, these variables provide the motor vehicle registration
figures and coded information on the agencies' organizational place
in the state government and the type of motor vehicle inspection
program, if any, they operate.
Vehicle Registration Data - The number of light-duty and heavy-duty
vehicles registered in each state was taken from the Census Bureau's
Statistical Abstracts. 1973 Edition. The data (in Table 902) repre-
sent 1972 registrations. The heavy-duty vehicle data is not currently
utilized by the model.
Type.of Motor Vehicle Inspection - The type of motor vehicle inspection
utilized in each state is entered as the array INSTYP, with coded values
representing the case of no inspection or one of three types (visual,
idle, dynamometer) either annually or semi-annually. The list of states
proposing inspection programs was determined from tabulations in the
semi-annual SIP progress reports. Lacking adequate information on the
type of programs being proposed, all were presumed for the interim to
be code 4 - annual dynamometer systems.
Organizational Position - The location of the State APC agency, either
in a major department or as a separate agency, is used in a small way,
providing additional administrative management manpower for agencies
without the support of a large department. The variable IORG is set
to 0 if the agency is in a department, to 1 if isolated. The structure
is each state was identified from the APCA Agency directory booklet,
1973-4 Edition.
FTE Variable - Another variable used only in a minor fashion involves
< ' .
the significance of tourism and related industries in a state. It was
found that those states where environmental considerations were part
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of a dominant tourist or retirement climate expended a significantly
greater effort in public information than other states. The variable
FTE is set to 1.0 except for states with such a tourist, retirement,
or "clean-air" image. In the initial data base, values greater than
1.0 were assigned to: Arizona, Colorado, Florida, Hawaii, Maine, New
Hampshire, New Mexico, and Vermont.
MODEL OUTPUT
Because the agency visits have provided manpower utilization information
similar to the output from the model, it seemed obviously useful to com-
pare that data with the results of the trial application, as a rough
check on how well the model predicts aggregate manpower requirements.
Detailed comparisons of individual activities are of course not meaning-
ful, as they merely reflect the differences among agencies that have
already been illustrated in the discussions of the development of the
individual relationships. However, some rough checks involving aggre-
gates of a number of activities will serve to provide a feel for the
extent to which the fluctuations among activities and agencies will
"average out" at the various scales of aggregation, and also as a check
against programming idiosyncracies.
The most obvious check on the output of the model, a comparison with the
data from the states visited, is considered in greater detail in the
balance of this section. There are two major groups of activities that
are both distinct enough from each other and coherent enough from agency
to agency that it is judged they provide a meaningful comparison of the
data from the visits with the output of the initial model application.
These are the large groups of monitoring-oriented activities and source-
oriented activities.
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Monitoring-Oriented Activities
The projections of manpower levels for these activities are based upon
the number of the various types .of monitors, along with other variables
such as frequency of sample change or site visit. For the purposes of
the model, the information on the number of sensors was obtained from a
summary of the SIF's as explained earlier. Since this data is a major
determinant of the projected manpower, it is useful to first review this
data to try to understand how it affects the manpower comparisons.
Table 29 gives the number of samplers of each type, both as used in the
trial application of the model and as determined from the visit to the
agency. Obvious from this table is the fact that there are numerous
discrepancies between the two sets of data, ranging from those agencies
(A and F) that, according to the visit, had many more samplers than
listed in the data bank, and those agencies (B, C, and G) that had fewer
samplers than listed. In addition, the discrepancies are not usually
consistent within any one agency; e.g., agency D had 17 more hi-vols than
were projected in the SIP's, but none of the seven S0~ bubblers.
These differences have not been fully investigated to determine the
reasons for their existence; however, several may be suggested.
Probably the major reason for these differences is that the SIP data
base represents not the actual number of monitors in the state, but
rather the number they were planning to have in operation by this
time. Changing needs and budgets could easily account for the dif-
ference between the expected and the actual number of monitors. This ef-
fect could be minimized in the future by utilizing counts of monitors
obtained from the SAROAD data bank; this, however, will require an im*- .
proved flow of data from the agencies into the data bank. In a similar.
vein, the monitoring data base used in the model trial relates to the
total number of monitors in the state, regardless of whether they are
operated by the state agency or other local health or APC agencies.
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Table 29. NUMBER OF SAMPLERS FOR EACH STATE AGENCY, FROM THE VISIT AND IN THE MODEL
Agency
A
B
C
D
1
V
6
Data
base
Model*
Visit
Model
Visit
Model
Visit
Model
Visit
Model
VI* it
Model
Visit
Model
Visit
Sampler type
Hi-vol
67
75
12S
65
74
31
66
83
37
32
52
60
44
25
S02
bubbler
11
32
50
34
38
30
7
0
21
12
22
40
13
13
BOj
bubbler
22
32
16
24
34
30
0
0
0
0
18
40
4
2
Sequential
tape
39
35
19
16
14
8
5
8
0
10
1
10
12
9
Continuous
S02
24
24
32
13
26
8
7
5
2
3
5
12
3
2
Cont inuous
W>2
2
7
11
4
4
8
6
5
0
0
0
3
0
0
Continuous
HC
0
1
1
5
21
8
5
5
0
1
0
1
0
0
Continuous
CO
6
7
16
3
20
8
6
5
1
1
3
6
1
0
Continuous
03/oxldant
7
8
12
40
19
8
6
4
3
0
3
9
2
0
Meteorological
equipment
0
0
0
0
0
0
0
5
0
3
0
10
0
0
Dustfali
bucket
0
0
0
0
0
30
0
20
0
46
0
0
0
56
Sulfation
piste
0
0
0
0
0
13
0
124
0
46
0
0
0
0
data or* tk» coosits u**d la the Initial trial application of the nodal.
-------
The model is designed to project the total manpower needed in a state for
the handling of the monitoring.
Table 30 gives the projected manpower requirements for seven of the
monitoring-oriented activities for the state agencies as currently
specified in the model. The three rows of manpower levels give those
manpower requirements projected from the trial application of the
model with the corresponding monitoring inputs, the manpower levels
from the study visits, and the projected manpower requirements if the
relationships in the model were applied to the number of sensors
determined from the study visits (called "adjusted model" in the
table). The last column in the table, Comparison Subtotal, gives the
sum of man-years expended on those activities for which the agencies
provided data, which is the significant number for comparing the two
results.
Except for agencies A and F, this table indicates that the manpower
levels projected from the adjusted model are closer to those deter-
mined from the study visits than those projected from the data base
^
in trial application. This change from the trial application model
to the adjusted model meant a change of as much as 50 percent in the
manpower levels at the subtotal level, indicating that these data
base differences can have a substantial impact on the manpower
projected from these activities. While there are still some differ-
ences in the visit versus the adjusted totals, they can be explained
by going back to the raw data discussed in Section III of this report
and reviewing how each agency's data compared to the derived relation-
ship. As an example, it is worthwhile to review the circumstances
which tend to make agencies A and F further off than the rest of the
agencies. Both agencies A and F are relatively new agencies under-
going rapid expansion and, at the time of the study visit, they were
performing extensive reviews of and increases in their monitoring
systems. This tended toward an underestimation bias when discussing
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Table 30. COMPARISON OF DIFFERENT PROJECTED MANPOWER REQUIREMENTS FOR
MONITORING ORIENTED ACTIVITIES (IN MAN-YEARS)
A Model
Vlilt
Adjusted
odel
B Model
Via It
Adjusted
odel
C Model
Visit
Adjusted
model
D Model
Visit
Adjusted
model
B Model
Visit
Adjusted
model
t Model
Visit
Adjusted
model
C Model
Visit
Adjusted
model
Field
operation
6.86
2.43
8.98
12.94
4.29
6.64
14.20
1.97
7.38
5.37
4.39b
4.89
1.67
0.48°
1.40
2.88
2.38 .
6.72
1.79
d
1:63
Calibration
and
maintenance
5.29
2.5
' 6.32
7.86
4.79
5.13
8.88
0.30
4.26
3.08
1.90
3.11
1.20
0.34
1.38
2.01
2.67
4.68
1.58
0.44
0.96
Sample
preparation
0.32
0.46
0.61
0.38
0.48
0.20
0.32
0.23
0.34
0.25
0.19
0.22
0.13
0.30
0.53
0.48
0.19
0.10
0.11
Sample
analysis
1.21
1.59
1.81
1.11
1.41
3.28
1.06
0.64
0.72
1.55
0.50
0.73
0.88
0.81
0.22
1.33
0.62
0.47
1.41
Data
>roce8ain|
2.69
3.0
2.79
3.70
2.00
3.43
4.38
4.53
2.00
1.47
0.8
1.54
1.33
3.05
1.79
1.79
2.55
1.83
1.80
0.52
1.39
Lab qual
control
0.15
0.21
0.24
0.15
0.19
0.14
0.09
0.18
0.07
0.10
0.11
0.18
0.08
0.15
Special
studies
4.10
5.21
6.96
3.98
7.49
3.91
2.79
2.94
1.07
1.14
1.80
3.96
1.26
1.05
Comparison
Subtotal
14.84
7.93
18.09
24.50
11.08
15.20
29.35
10.28
15.02
10.79
8.15
9.80
4.89
4.82
3.79
7.79
8.35
15.04
5.98
1.53
4.90
*Model relationships applied to number of sensors from study visits.
Includes estimate of 3 m-y local help.
°VlBlt sites half as often.
Performed solely by local manpower.
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their monitoring activities, because the number of monitors referred
to was often the number immediately current or expected to be opera-
tional shortly, while the manpower levels related to the time that
had been spent in the past on these activities.
Source-Oriented Activities
The varying manner in which the several agencies conduct their source
surveillance and enforcement activities precludes any useful compari-
son with the model's hypothetical approach on a task-by-task basis.
However, since the overall goal of each agency is the same, there is
some reason to expect that the projected aggregate manpower applied to
these activities should agree roughly with the totals determined dur-
ing the visits. Table 31 presents a summary of this comparison for
the seven states visited. None of the data include mobile source
figures, since no actual mobile source effort was underway. A com-
parison of the first pair of columns, for total stationary source
manpower, indicates that the model does not agree closely with the
levels determined from the visits, generally over-predicting rather
than under-predicting, with an aggregate over-prediction of 39 percent.
One obvious difference between the model's hypothetical control ap-
proach and the actual approach of the agencies is in stack testing;
none of the agencies was actually conducting a stack test program of
the magnitude envisioned in the model. Consequently, a second com-
parison was made with stack test manpower excluded; in this case, there
is an under-estimation of the aggregate manpower by about 2 percent.
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Table 31. COMPARISON OF PROJECTED MANPOWER REQUIREMENTS
FOR STATIONARY SOURCE-ORIENTED ACTIVITIES
State
agency
A
B
C
D
E
F
G
Manpower (man-years)
Total stationary
source activities
Visit
46.0
88.3
25.6
32.2
a
11.4
11.8
Model
19.6
83.8
41.0
20.1
o.ob
19.6
47.2
Stationary source activities
less stack testing
Visit
41.0
86.7
23.3
31.9
a
5.9
8.7
Model
16.6
71.8
33.4
18.3
0.0b
17.3
37.1
Total
215.3
231.3
197.5
194.5
No estimate provided by Agency E.
Results are not obtained because NEDS data base is absent.
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SECTION V
CONCLUSIONS AND RECOMMENDATIONS
The previous sections of this report have presented the Manpower Planning
Model, as developed to date by GCA/Technology Division for EPA, by pro-
viding an extensive review of the procedures for the empirical informa-
tion development, the considerations involved in the formulation of the
manpower projection relationships, and the actual structure of the model.
In addition, a discussion of a trial application of the model has been
given. By way of conclusion, this Section summarizes briefly the ways
in which the model can be put to use, and offers a brief assessment of
the model development effort. Then a few recommendations are presented
with respect to what different or further investigations would be re-
quired, to allow for the development of the model when experience and
improved input data bases warrant.
POSSIBLE APPLICATIONS OF THE CURRENT MODEL
The purpose of developing the model was primarily to provide a means of
estimating current manpower requirements. In addition, it was planned
to have a model which was usable for some time so that it could project
manpower requirements for future years. To provide this latter compo-
nent, it was necessary to provide a model which could project changes
in manpower with changes in the duties performed by an agency due per-
haps to new regulatory requirements.
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Current Manpower Requirements
While there are still areas of improvement which should be made in the
model, as discussed later, it does allow for reasonably good projections
of the manpower levels needed in a state air pollution control agency
for a wide range of activities. The model provides some selection in
whether the activity is being conducted by each agency, usually by re-
viewing the pollutant priority classifications of the AQCR, and as to
the degree of performance of the activity; for instance, by including
the number of monitors.
The data inputs for the projection of current manpower requirements are
the pertinent data inputs as they are presently known. Often, as noted
several times earlier, these are not entirely accurate or up-to-date
and may lead to some inaccuracies for individual activities. However,
as no pattern for these differences has yet been established, it is
assumed that these are approximately random, so that they will come
close to averaging out on a state level, with increased accuracy as
totals are accumulated at the regional and national levels. Where par-
ticular concern is warranted is the situation where a state does not
maintain up-to-date NEDS or SAROAD files. As the model bases the bulk
of the manpower estimates on the fundamental counts of sources and moni-
tors, the accuracy of projections can be no better than the reliability
with which the States and Regional Offices submit such information.
As the model is presently structured, the manpower levels projected .for
each state are primarily those which are necessary for one central
agency to handle all the air pollution activities within the state.
Therefore, the manpower requirements projected for each state from the
model must be reviewed in light of the actual character of the air pol-
lution control activities of the state. While some additional manpower
is allocated in the area of management and support activities for
additional agencies within a state, there was no way of thoroughly
addressing the increased manpower requirements or the savings that may
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result from having either local agencies or regional offices of the
State agency;
In summary, the use of this model for projecting current manpower re-
quirements can be expected to provide reasonably accurate projections
of the total manpower needed by a central state agency if data input
for the state is current. The resolution for the manpower levels for
each individual activity cannot be expected to be as accurate as the
aggregate for the state. Care must also be taken in applying these
projections to noncentral APC agencies and regional offices, or the
States themselves would have to be consulted in reviewing and allocat-
ing the projections to the various agencies within the state.
Protecting Impact of Policy or Regulatory Changes
A key factor considered in the development of the model was to make it
flexible in the context of the scope of activities and relationships
used. The model would have application not only for projecting current
or immediate future manpower requirements, but also for projecting what
may be expected in the more distant future as the role of the agencies
changes, and for considering the manpower impact of possible or hypoj
thetical changes. The role of an APC agency may change as new regul
tions are passed, as sources come into compliance, or as areas reach
the NAAQS. Other changes may result from external events, such as
changes in EPA regulatory policy, and so on.
It would be far too lengthy to try to identify all the possible changes
which could occur in the future and, even then, more would surely arise.
Instead, the following discussion indicates how the model may adjust to
such changes in the three main sections of the model.
Mtonitoring Oriented Activities - Two types of changes can be reasonably
expected for these activities: 1) changes in the number of sensors to
be operated, and 2) changes in the frequency of sample collection. The
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former of these is fairly straightforward, since the model allows any
number of monitors to be input and these will be changing over time
anyway. The only problem that might arise is in the travel time, which
would need to .be modified if the overall density of the network were
changed dramatically. Changing the frequency of the sample collection
for one or more sensor types is also fairly easy, as the sample-change
frequencies are present as separate, explicit variables, readily change-
able in the program.
It must be remembered with both of these changes, as with most others,
that the numerous interactions between activities in the model require
that the total model be rerun if the aggregate manpower required of the
agency is to be considered. While doubling the sample collection fre-
quency for a hi-vol obviously doubles the field operation, sample prep-
aration, and sample analysis time, it affects such things as the time
needed for handling and analysis of the data in a different way; and
the increased manpower for hi-vols in turn also impacts on those manage-
ment level activities which are estimated as a function of the size of
the technical staff.
Source-oriented Activities - Changes which may be expected in the source-
oriented activities cover a wide range from the inclusion of new sources
to the requirement for more motor vehicle inspection programs. Again,
all of the considerations mentioned above must be given in projecting
changes in these areas. Because the source-oriented activities are sub-
ject to much greater variation in structure among agencies than are the
monitoring activities, it is probably less likely that clear policy
changes, like the frequency of inspection, will be meaningful; but be-
cause of the matrix structure, the changes could be easily made.
Management and Support Activities - The management and support activi-
ties are ones which, if they relate at all to the other sets of activi-
ties, are dependent on the other activities and will not impact on them.
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Therefore, changes which affect them can be applied directly to this
level only. However, much more thought and information may have to be
involved in the changes, since beyond just changing the number of moni-
tors or sources, the relationships themselves will likely have to be
altered.
These changes can actually be very easy, as in expressing a policy of
encouraging graduate studies by simply increasing the pertinent coeffi-
cient. A more policy-level change would be to decide to discourage all
local APC agencies or, conversely, to require local or regional offices.
While the model as it is could make estimates of the impact on manpower
of these changes, and careful analysis of data and re-interpretation of
relationships could perhaps provide better estimates, in general, as
mentioned earlier, the model is not really adaptable, as presently for-
mulated, to consider such a change accurately. To do so would require
either a data base on the precise sharing of responsibilities in each
state, or a homogenized definition of the state/local roles that could
apply to all states; neither is in the model as it currently exists.
ASSESSMENT OF THE MODEL DEVELOPMENT
As with any project, there are some possible improvements that can be
suggested from the benefits of hindsight; in the case of the development
of the manpower planning model, the agency visits and the data base used
are the only areas where the conduct of the effort might be different,
although there are a number of areas where additional development effort
is warranted, with the goal of a more complete and accurate model than
has been provided under this work, or a more generally applicable, more
subtle, sophisticated model. These development efforts are discussed
in the next sub-section.
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Data Gathering Process .
One of the areas that requires some assessment is the manner in which
the empirical data was gathered. Following the collection of the data
from the agencies during the study visits, and during the subsequent
analyses, it was concluded that, although most of the shortcomings of
the data were unavoidable, some of the difficulties in the data base
were related to the manner in which the data was gathered (i.e., a
1-day visit using a detailed questionnaire). Sometimes the interviewee
was placed in a position of providing an immediate estimate of manpower
expended in minor areas which had not been given serious consideration
previously, In addition, the interviewer was required to make an as-
sessment of the adequacy of the level of performance of each activity
for use in formulating the relationships, but the short time generally
precluded any more than a qualitative judgment.
It is therefore urged that when the model is revised, the visits to
agencies be made more flexible, and probably for a longer duration,
perhaps a minimum of 3 days. It probably would also be efficient to
consult with the agencies more extensively in advance of the format
design, or to leave the visit and data formats open.
Input Data Base
The other area which requires some assessment is of course the input
data base used. The model is, of course, highly dependent upon the
number of monitors and sources as given in the SIP's and NEDS, respec-
tively. The former of these would seem to be as good as would be possi-
ble to obtain. As discussed earlier, however, the NEDS-based source
data inputs used are often not as complete as would be desired, nor do
they contain precisely the type of information needed for the best
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development of the model. In addition, the NEDS system apparently does
not always contain consistent data (e.g., some states have only 100 tons/
year or larger sources, while other states may have much smaller sources).
It is not likely that either the format or the content of the data bases
will be improved for the primary purpose of the manpower projection
model, since this would take an inordinate amount of effort. However,
the needs of the model should be taken into account in any future deci-
sions on updating and refining these data bases. In particular, some
consideration should be given to writing a NEDS retrieval routine thft
would provide the summaries specifically for the manpower model.
Aside from the major data inputs, there are several less detailed inputs
that would be desired for a more sophisticated application of the model
(e.g., information on whether the agency has regional offices). The
model, as presently structured, cannot account for all of the variations
found in the study visits which are due to specific characteristics of
an agency because there was no data base on which to apply the pertinent
relationships. It is likely that this information could be readily ob-
tained from the EPA Regional Offices.
FUTURE STRUCTURAL DEVELOPMENT OF THE MODEL
There are several areas where it is expected that increased flexibility,
sophistication, or accuracy could be built into the model by making fur-
ther structural developments that were not possible in the current effort.
Several of the most important of these are reviewed briefly below.
Data Base Development
The desirability of revising the way in which the model interfaces with
the NEDS system has been mentioned several times. This is a high pri-
ority, In our judgment.
127
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Compliance Status
The model as it now exists does not distinguish between sources in
varying compliance status. The anticipated interfacing with the com-
pliance data system (CDS) was ultimately rejected, based on the un-
availability of CDS in many Regions.
State-Local Agency Interactions
Because of the limitations in the data base, and the lack of definition
on which agencies perform what functions, the model operates on a state-
by-state basis, rather than on an agency-by-agency basis, and the abil-
ity to make good projections for local agencies or to explore subtle
state-local interactions is minimal.
Flexibility Among Agencies
The computer system, as opposed to the model as a conceptual entity,
could be modified to permit deliberate variation of such factors as
inspection or stack test frequency from state to state, to provide for
variations in policy.
128
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APPENDIX A
ANNOTATED BIBLIOGRAPHY
129
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1. Blair, Roger, and Catewood, William B., Automation of Emissions
Surveillance through Computer Applications. Air Pollution Control
Association, Pittsburgh, Pa., 18p., 1972. APTIC # 44482.
General discussion on how a computer could be used to schedule necessary
activities. Data for Kentucky.
2. Boisseree, Klausj Structure and Work of the Air Pollution Control
Administration in the Federal Republic of Germany - Experiences.
Problems. International Comparisons. International Union of Air Pollution
Prevention Associations, 17p., 1970. APTIC /> 25551.
Overview of agencies in Germany.
3. Colorado, State of, The State of Colorado Air Pollution Control Transpor-
tation and Land Use Plan; Colorado Department of Health, Air Pollution
Control Commission, Denver, Colorado, 198p., May 1973.
Chapter 7, Control Strategy'Implementation, contains much Information pertaining
to present and anticipated manpower requirements. In particular, Section
7.1.1, Agency Staff and Budget Requirements, pp.7-1, 7-10, was the basis
for the input from this Plan to the matrix shown in the Appendix to the
present report.
4. Connecticut, State of, A'ir Quality Implementation Plan. Department of
Environmental Protection, Hartford, Connecticut, 320 pp., undated (early
1972).
This plan contains an excellent summary and listing of State and local
agency functions and associated manpower requirements. Tables 11-2
through 11-6, pp. 240-244, are reproduced in part in the Appendix to
this report, along with the lists from the other plans reviewed for this
project.
130
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5. Cooper, J.S., Dunfee, N.L., and Townsend, R., State and Local Air
Pollgclor. Control Agency Salary Levels. 1971. Air Pollution Control
Association, Pittsburgh, Pennsylvania, 22p., 1972. APTIC #44810.
More up-to-date information is provided on salary levels than In other
\
reports reviewed. The report shows that salaries have risen and are
more competitive. Much salary data is included.
6. Doyle, Kathleen F., "Manpower for Pollution Control," 'Environment
Reporter, Monograph No. 7, 17 pp., 8 January 1971.
Treats the funding and training aspects of the overall manpower problem
in the areas of water, air, and solid waste pollution control.
7. Dunfee, Norman L., Career Opportunities in the Public Sector for
Environmental Managers. Institute for Management Sciences, Pleasantville,
New York, 8p., 1971. APTIC # 43549.
Provides data on state and local air pollution agencies: number of
personnel, positions, educational backgrounds, salaries, career
opportunities.
8. Eagles, John, Method for Estimating Manpower Resources for Air Pollution
Control. Environmental Protection'Agency, Research Triangle Park, North
Carolina, 14 p., July, 1972.
«
Provides a good simplified model for estimating manpower requirements.
Inputs are well defined and this provides a good background for future
development.
9. Faith, W.L.,''A Suggested Program, for the Sacramento Region" The Air
Pollution Threat. Sacramento Regional Area Planning Commission,
California, 59p., October 1969. APTIC #' 24059.
131
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Provides a short summary of functions of an air pollution control agency
and the suggested staffing and budget for the Sacramento region.
10. Gartner, Irvin, Air Polluticn Control Salaries in Today's Competitive
Labor Market. Pennsylvania State University, Center for Air Environment
Studies, 349p., 1968. APTIC # 10648.
Provides a comprehensive compilation and comparison of annual salaries
of government employees in air pollution and those salaries offered by
industries. Emphasis is on what is being offered to recent college
graduates. The need to make government salaries more competitive is
concluded.
11. Gartner, Irvin, Levels of Program Development of Regional. State and
Local Air Pollution Control Agencies. Pennsylvania State University,
Center for Air Environment Studies, 35p., 1968. APTIC # 11071.
Provides good data from a preliminary investigation on air pollution
agencies' directors' evaluations of their respective programs. A systems
framework with numerous components and idea of questions is included.
12. Hillison, John Howard, Manpower Needs in Environmental Management. Ohio
State University, Columbus, Ohio, 212p., 1972. APTIC # 49468.
Basically emphasis is on wastewater manpower needs with only a very
small part on air pollution present and future manpower requirements in
Ohio. Some of the questionnaires may be useful.
13. Jutze, George A., Guidelines for Technical Services of a State Air
Pollution Control Agency. APTD-1347, Office of Air Programs, Stationary
Source Pollution Control Programs, Environmental Protection Agency,
Research Triangle Park, North Carolina, 302p., November 1972.
132
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Covers the requirnents for support to an AFC agency by a Ttchnieal
Service Group. This document stresses laboratory operations. The
information presented therein is based on existing agencies - state,
regional, and local. The vertical links between successive strata of
agencies as well as the horizontal relationships among other agencies at
the same level as the APC agency are enumerated. It is emphasised that
"the State is in the middle." Major areas of agency activity discussed here
include: 1. organization, 2. management, 3. program element definition,
4. legal considerations, 5. technical functions, 6. quality control.
14. Keitz, E.L., and Mongan, T.R., Analysis of Requirements for Air Quality
Monitoring Networks. Air Pollution Control Association, Pittsburgh, Pa.,
25p., 1970. APTIC # 28191.
Interview of local and national agencies indicated a Justification for
local data gathering on a delayed and immediate response basis, but a
national scale data gathering on a delayed response basis only.
15. Leduc, E.G., et a1.,"Manpower Policies in Selected Air Pollution Control
Agencies." J. Air Pollution Control Assoc.. 18(4): 211-214, April 1968.
APTIC # 14832 (09555).
Provides a look at employment problems and policies in air pollution control
agencies in 1968. Case studies of four governmental units (at the major
metropolitan city, smaller core city, large metropolitan county, and state
level) concerned with air pollution control are included.
16. Maryland, State of., Plan for Implementation of the Ambient Air Quality
Standards of the Metropolitan Baltimore.Intrastate Air Quality Control
Region (State Air Quality Control Area III)t Maryland State Department
of Health & Mental Hygiene, Environmental Health Administration, Bureau
of Air Quality Control, Baltimore, Maryland, 375p., May 1972.
133
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A very comprehensive plan that Include* sections on manpower resource
requirements and transportation/land use planning as well as a wealth
of information on some of the more important input parameters needed to
quantify the manning requirements. Among these are the material in
Chapter 1, "Description of the Region", Appendix H, "Functional Statement-
Bureau of Air Quality Control," and Appendix K, "Air Pollution Episode
Plan, State of Maryland." Examples of some of the more highly technical
activities for which trained manpower support is needed are contained in
Appendices C, "Data Base for Computer Simulation Exercise," and D,
"Diffusion Model Verification." The list of agency functions and the
corresponding manpower requirements derived from the Plan are included in
the appendix to this report.
17. State of New York, New York City Metropolitan Area Air Quality Imple-
mentation Plan - Transportation Controls. New York State Department of
Environmental Conservation, 344p., April 1973.
Because this plan is so forward-looking, the entire document contains a
great deal of useful information that is suggestive of new or expanded
activities to be undertaken by state and local AFC agencies. Chapter 9 -
Maintaining Air Quality Standards Beyond 1975, is especially fruitful in
this area.
18. North Carolina, State of, Implementation flans for the State of North
Carolina (in two volumes): Vol. I, The North Carolina Plan for Ipiple-
nenting National Air Quality Standards, and Vol. II. Report on Public
Hearings on Adoption of Proposed Plan for Implementing National Air
Quality Standards. The Michie Company, Charlottesville, Virginia, 91 p;,
January 1972.
In Volume I, the sections on actions to be taken in air pollution'episodes,
and those dealing with resources and intergovernmental cooperation
(Sections V, IX, and X, respectively) were found to contain much useful
134
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Information as to the implications for skills and numbers of staff required
to discharge properly the responsibilities of the state and local air
pollution control agencies. The descriptive material on the physical,
geographical, and meteorological characteristics of the region contained
data needed as basic input to a manpower planning model. Several parts
of Appendix C, "Regulations Governing the Control of Air Pollution,"
implied manpower requirements, both qualitative and quantitative.
19. Piotkin, Steven E., Proposed Permit System for Sources of Air Pollution
In the State of Alabama. Resources Research, Inc., McLean, Virginia,
lllp., November, 1971. APTIC # 39457.
(
Good sample of state-wide permit system. Includes a small section on
staffing for the permit system.
20. Puget Sound Air Pollution Control Agency, Proposed Regulation I of the
Puget Sound Air Pollution Control Agency. Seattle, Washington, 52p.,
July 18, 1967. APTIC # 09302.
Provides a good guide to activities of one agency in regards to areas of
control and procedure. '.!
21. Public Health Service, National Air Pollution Control Administration,
Manpower and Training Needs for Air Pollution Control. Durham, North
Carolina, 97p., June, 1970. APTIC # 22874.
Provides data on present (1970) requirements as well as projections of
manpower needs for 1974 in the publir and private sectors. Recruitment
and training is emphasized.
22. Rifkin, K.I., et al., (ASA), Task Analysis of State and Local Air
Pollution Control Agencies and Development of Staffing Guidelines.
Manpower Development Staff, Environmental Protection Agency, Research
Triangle Park, North Carolina, 7 Volumes and Technical Report, November,
1972.
135
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Generally, the titles of the volumes are descriptive enough:
Volume A - Guidance and Supporting Information for Staffing and
Training Decisions in an Air Pollution Control Agency - Introduction
and Directions for Using These Guidelines
Volume B - Guidance and Supporting Information for Staffing and
Training Decisions in an Air Pollution Control Agency - Engineering
Volume C - Guidance and Supporting Information for Staffing and
Training Decisions in an Air Pollution Control Agency - Field
Enforcement
Volume D - Guidance and Supporting Information for Staffing and
Training Decisions in an Air Pollution Control Agency - Laboratory
Support
Volume E - Guidance and Supporting Information for Staffing and
Training Decisions in an Air Pollution Control Agency - Air Monitoring
and Meteorological Support
Volume F - Guidance and Supporting Information for Staffing and
Training Decisions in an Air Pollution Control Agency - Source Testing
Volume G - Detailed Task Data, and Staffing Guidance - Agency Manage-
ment, Program Development, and Public Information Support
23. Schueneman, Jean J.,"Organizational and Operational Techniques for
Relieving Manpower Shortages in Air Pollution Control Agencies" J. Air
Pollution Control Assoc.. 17 (10) .-670-672, October 1967. APTIC 0 05559.
Lays out some of the common sense methods of conserving manpower require-
ments when staffing is not adequate. ,
24. Senew, Michael J., A Systems Approach to Manpower Development to
Seate and Local Air Pollution Control Agencies, Air Pollution Control
Association, Pittsburgh, Pa., 26p., 1972. APTIC # 43189.
Describes a system for estimating manpower development. Includes a good
definition of air pollution control personnel.
136
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25. Stein, Arnold, Guide to Engineering Permit Processing. Environmental
Protection Agency, Research Triangle Park, North Carolina, 368p., July,
1972.
Treats the design and administration of permit systems, engineering
evaluation of pollutant sources and equipment inspection procedures, and ''
methods for acquiring and processing technical and legal information on
the sources of air pollution. Work units are used for estimating man-
power need for the permit system.
26. Thompson, Meredith H., "Coordination in Environmental Planning'.' Regional
Planning, Challenge and Prospects. Chapter 3: 103-105, Maynard M.
Hufschmidt (Ed.), Frederick A. Praeger, New York, 1969. APTIC # 41884.
Stresses the need for integrated approaches to the problem of environ-
mental planning so all aspects of the environment are adequately covered.
27. Walsh, G.W., and Von Lehmden, D.J., Estimating Manpower Needs of
Air Pollution Control Agencies. Air Pollution Control Association, New
York City, 22p., 1970. APTIC # 19406.
Provides a reasonable model for estimating manpower needs of air pollution
control agencies. Includes a general description of basic functions of
different services of an agency.
28. Weisburd, Melvin I., Field Operations and Enforcement Manual for Pollution
Control. Volume I: Organization and Baste Procedures, Pacific Environ-
mental Services, Inc., Santa Monica, California, 258p., August, 1972.
APTIC # 49355.
Chapter 1 provides a concise introduction to the major components of
air pollution control. The organizational configurations of an agency,
as separation of state and. local control, are discussed, as are staffing
137
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needs. Emphasis is on the field enforcement officer's duties and
background. :
" ' - , \
Chapter 1 provides a concise introduction to the major components of
air pollution control. The organizational configurations of an agency,
as separation of state and local control, are discussed, as are staffing
needs. Emphasis is on the field enforcement officer's duties and
background.
Chapter 2 gives more detailed enforcement procedure. What an inspection
should entail and what is of primary consideration in different industries
is delineated. Sample forms for activities ranging from inspection to
court appearances are filled out. Systematic filing of reports is
discussed. .
Chapter 3 deals further with prosecuting violations. Court procedures
and the need for training enforcement officers as witnesses are
mentioned.
Chapter 4 provides information on inspection of emissions. Perhaps
too much emphasis is based on the actual visibility of the emission.
The need to record all times and conditions is noted. Complaint
investigation and mediation is suggested. Field equipment is reviewed.
»
A very good glossary of technical and industrial terminology is provided.
29. Welsh, Gene B., and Mathews., Dean S., Staffing Requirements of Air
Pollution Control Agencies - A Regional Overview. Public Health Service,
Cincinnati, Ohio, 19p., 1968. APTIC # 10729.
Discussion of need to change training and hiring policies to attract
more qualified personnel.
138
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30. Williams, J.D., and Gaulding, C.I.,*The Air Resource Management Concept
and Its Application in the Southwestern Ohio - Northern Kentucky Air
Pollution Survey" J. Air Pollution ControlAssocI6(6);308p.. June,
1966. APTIC # 01173.
The report describes how one interstate region set up an air pollution
. survey. Emphasis vas being placed on developing a long range compre-
hensive plan for an air resource management program.
139
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APPENDIX B
AGENCY VISIT QUESTIONNAIRE
141
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Activities Prelected from
Source Information
101. Routine Inspection of Stationary Source
102. Engineering Inspection of Stationary Source
103. Inspection of Hazardous Pollutant Source
104. Stationary Source Testing
105. Complaint Investigation and Field Patrol
106. Development of Compliance Schedules
107. Monitoring of Compliance Schedules
.108. Oversee Required Source Record-Keeping
109. Oversee Conduct of Supplementary Control Strategy
110. Formal Legal Action
111. Enforcement Reports to EPA
112. Semi-Annual Reports to EPA on Progress In Plan Enforcement
113. Semi-Annual Emissions Reports to EPA
120. Review of Application for Tax Exemption
130. Technical Review of Equipment Plans
131. Review of Development Plans
132. Microscale Modelling and AQ Estimation
133. Review of Source-Conducted AQ Estimation
134. Technical Land Use Planning
135. Environmental Impact Statement Review
150. Establishment of Mobile Source Emissions Inventory
151. Performance of Dynamometer Emissions Testing Program
152. Performance of Idle-Modes Emissions Testing Program
153. Performance of Emission Equipment Inspection Program
154. Oversee Motor Vehicle Emissions Testing Program
155. On-going Surveillance of Mobile Source Emissions
156. Mobile Source Enforcement
160. Episode Control Plan
142
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Activities Projected from
Monitoring System Information
201. Field Operation
202. Routine Calibration
203. Equipment Maintenance
204. Equipment Repair
205. Dynamic Calibration
210. Sample Preparation
211. Sample Analysis: Manual
212. Sample Analysis: Automated
220. Data Processing and Summarization: Manual
221. Data Processing and Summarization: Seml-Automatlc
222. Data Processing and Summarization: Automated
230. Preparation of. Quarterly AQ Data Reports to EPA: Manual
231. Preparation of Quarterly AQ Data Reports to EPA: Computerized
143
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Activities Prelected from
Other Staffing Levels
301. Air Pollution Control Board
302. Overall Program Management
310. Development of New or Modified Control Strategies
311. Climatological Dispersion Modelling
312. Economic Impact Analysis
313. Community Interaction and Social Impact Analysis
314. Quantitative Evaluation of Alternate Strategies
315. Development and Adoption of New or Modified Control Regulations
320. Network Design and Planning
321. Laboratory Quality Control
322. Statistical and Engineering Analysis of Air Quality Data
340. Liaison with EPA and Other APC Agencies
341. Liaison With Transportation Agencies
342. Liaison With Land-Use Planning Agencies
343. Provide Technical Assistance to Local APC Programs
350. Liaison With Other Non-APC Governmental Agencies
351. Staffing
360-361. In-house Training
362. Training at EPA
363. Graduate School Training
364. Professional Activities
370. Public Information
371. Library and Archives
372. Editing and Graphic Services
373. Effects Surveillance
374. Photographic Services
390. Clerical Support for Administrative Staff
391. Clerical Support for Laboratory Staff
392. Clerical Support for Stationary Source Inspectors
393. Clerical Support for Legal Staff
394. Clerical Support for Other Technical Staff
144
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101
102
101. Routine Inspection of Stationary Source
102. Engineering Inspection of Stationary Source
These activities include the effort needed to conduct inspections,
excluding, any effort involved in associated stack testing. Routine
inspections, activity 101, are those that are typically performed in less
than 1/2 man-day (exclusive of travel time), where'visual inspection of
equipment and operation, by a technician-level person, is adequate. This
type of inspection might be performed for routine permit purposes, for on-
going surveillance to help maintain the emissions inventory, or for other
reasons. Engineering inspections, activity 102, are, in contrast, those
that nay involve one or more professional staff for perhaps several days,
and will likely be much more thorough and detailed. These inspections are
aimed at the major pollutants only; hazardous pollutants are covered in
activity 103.
1. Does such a division into two types of inspection seem consistent
with your usual procedures? yes no, only one type
no, we have several
types
Explain:
2. Do the types or frequency of inspections vary with the size or
type of industry? no; yes, by size only; yes, by
type. (Explain)
3. Under what circumstances do you conduct Inspections of each type?
Routine Eng'g.
_____ Operating permit (frequency )
Begin compliance schedule
Complete compliance schedule
________ When complaint received
. On request
______ Informal
______ Other (explain)
145'
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101 (2)
102 w
4.. Are there any significant differences in time spent on routine
inspections by type of source? ___ i">t _____ y&s (explain)
5. We'd also like to consider differences in inspection require-
ments for various type sources. Here is an extensive list of
source types; (see array 100). For the source types you're
familiar with, could you estimate the typical manpower require-
ment for engineering inspections? Give number of inspections,
man-days each, and/or total nanyears.
6. In total, could you summarize the manpower spent on inspections?
Manpower levels; total man-years ____________
by type: No. man-days
Inspection each man-years
routine (or ) . i .. (101)
engineering (or ) _________ f (102)
?. Instead of (or in addition Co) source type, what factors affect
the time required?
Emission volume . Other (explain)
8. Do the above estimates reflect travel time? ____ Yes, No
Average travel time hours/week
Average distance miles/week
146
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101
102 (3)
9. How much extra time do you spend if the source being inspected
for che criteria pollutants is at the same time inspected for
hazardous pollutants? manhours or % extra.
Number of such sources:
101 my
102 ^my
147
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LIST OF SOURCES
FOR SOURCE-ORIENTED ACTIVITY ARRAY (100)
I. Power plant, coal-lignite,>100 MMBTU/Hr.
2. , 10-100
3. , <10
4. , oil, >100 MMBTU/Hr.
5. , 10-100
6. , <10
7. , gas-coke
8. , misc.
9. Industrial boiler, coal-lignite,>100 MMBTU/Hr.
10. , 10-100
11. ySlO
12. , oil,> 100 MMBTU/Hr.
13. 10-100
14. , * 10
15. , gas-coke
16. , mice.
17. Coram.-Institutional boiler, coal-lignite,
18. > 10 MMBTU/Hr.
19. ,<10
20. , oil,>100 MMBTU/Hr.
21. , 10-100 MMBTU/Hr.
22. ,<10
23. , gas-coke
24. , misc.
25. Internal Combustion (Stat. sources)
148
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26. Nitric acid mfg.
27. Paint & varnish mfg.
28. Sulfuric acid mfg.
29. Phosphate fertilizer mfg.
30. Other chemical mfg.
31. Feed grain handling
32. Other food 6. agriculture
33. Aluminum reduction
34. Copper smelters
35. Ferroalloy
36. Electric arc steel furnace
37. Other iron and steel
38. Lead smelters
39. zinc smelters
40. Other primary metals
41. Secondary aluminum
42. Gray iron foundry
43. Other secondary metals
44. Portland cement mfg.
45. Coal cleaning
46. Other mineral products
47. Petroleum processing
4.8. Kraft (sulfate) pulp processing
49. Other wood products
50. Metal fabrication
51. Leather products
52. Textile mfg.
53. In-process coal use
54. In-process oil use .: ; .
55. In-process gas use /.
56. Other in-process fuel use
57. Drycleaning
58. Other solvent usage
59. Surface coatings
149
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*Q- Petroleum storage
<*! Other evaporative losses
62. Municipal incinerator
63. Open burning dumps
64- Other gov't incineration
65. General comm.-institutional incineration
66. Flue-fed apartment incineration
67. Other comm.-inst. incinerator
68. Industrial incineration
150
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103
103. Inspection of Hazardous Pollutant Source
This activity is the effort to inspect a source of a hazardous pollutant
which would not be inspected for criteria pollutant emissions. Those sources
which emit both criteria and hazardous pollutants are covered under activities
101 and 102.
1. Do you (or do you expect to) conduct inspections of sources of
hazardous pollutants - Be, Hg, Asbestos?
No. none here
No, not inspected
No, agency does it
Yes. we plan to
Yes, we do now
2. Under what circumstances do you conduct such inspections?
Routine Eng'g.
Operating permit (frequency )
Begin compliance schedule
Complete compliance .schedule
When complaint received
On request
Other (explain)
3. Would you estimate the typical manpower requirements for this effort?
No. of insp. Man -days each Man-years
Asbestos _________ _____________ _______
Beryllium ___________ ______________ ' ________
Mercury ___________ ___________
4. Do these estimates reflect travel time? Yes. No.
Average travel time hours/week
distance miles/week
103 my
151
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104
104. Stationary Source Testing
This activity includes the field and source-oriented effort Involved in
planning and conducting actual measurements of emissions. The chemical analysis
efforts are included in activity 211. If the stack test is conducted in con-
junction with an inspection, this activity includes only the effort needed to
prepare and set up the equipment, conduct the test, make necessary field calcula-
tions, and replace the equipment; access to the sampling ports is presumed, and
any subsequent calculations or data processing conducted in the office in con-
sidered separately. Any time spent observing others' stack tests is included in
this activity.
1. Does your agency conduct/observe source tests? Yes, both
Yas. conduct only
_____ Yes, observe only
. No, agency does
_____ No, contract for
Testing
Other, (specify)
2. Does our definition seem to agree with your operating
conducting source tests?
Yes
No, can't separate from inspection
No, all calc's should be included
No, other
3. In what circumstances do you conduct/observe tests?
conduct observe
, ______ verify compliance-agency regulation
verify compliance - NSPS
______ .-_.,. Part °* inspection (frequency: )
15,2
-------
104 (2)
conduct observe
evidence for enforcement action
on request
_____ _____ other (specify)
4. What test procedure do you use? Please estimate time required.
SO,
2 Perticulate
Ho. testa/year Time per test
EPA train
ASTM train
Bag sampling
Other
5. In the aggregate, what is your overall manpower usage for conducting/
observing stack testing?
Conduct
Observe
jnan-years;
jnan-years;
6. What factors influence the time required?
tests
tests
7. Do these figures include travel time? Yes,
Average travel time hours/week
Average distance miles/week
No
jny
153
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105
105. Complaint Investigation and Field Patrol
Complaint investigation includes the effort expended to conduct field investi-
gations of citizen complaints, including preparation of reports, letters, or other
material serving to terminate the investigation phase. The effort required to
receive the complaint, by telephone or by mail, ia included in activity 392. The
appropriate agency action in response to the complaint may be legal enforcement,
nor* careful engineering investigation, etc; In these cases the effort to conduct
the follow-on activity is considered separately. It is presumed that the staff
occassionally note apparent violations on their own initiative; this is also included
here, whether conducted as an incidental activity or by a separate staff.
1. To what extent does your agency conduct such activities?
None-done by . agency
Complaint investigation only
Complaint investigation and occassional patrol
_____ Complaints and field patrol separately
2. Aggregate manpower usage
Complaints
Patrol . man-years or
________ man-years.
man-years or %
3. How many complaints handled?
Rough distribution:
_last year
105
154
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106
106. Development of Compliance Schedules
Activity 106 includes those efforts involved in the development of legally
enforceable compliance schedules to meet the requirements of the State Implementa-
tion Plans as undertaken by negotiations between designated sources and the
staff of the appropriate APC agency.
1. Will all of the compliance schedules be developed by the end of FY 1974
(June 1974)7 Yes, . No, # completed , # remaining
2. What manpower was required to develop these schedules? man-months
106 mm
1
I
155
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107
107. Monitoring of Compliance Schedules
This activity includes those Administration efforts Involved in main-
taining surveillance over the accomplishment of definable increments of pro-
gress in the compliance.schedule.
1. Do you maintain this surveillance by making use of EPA's computer-
ized Compliance Data System? Yes, No
2. If yes, what manpower is utilized? man-months
3. If no, what procedure do you use?
4. What manpower is required for these procedures? man-months
5. Of the manpower utilized for inspections (activities 101-103) and source.
testing (104), how much is directly attributable to monitoring com-
pliance schedules?
7, of routine inspections
% of engineering
% of source tests
6. Do any of the manpower requirements change dependent upon source type?
Yes - HOW? No
107
156
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108
108. Oversee Required Source Record-Keeping
This activity consists of the effort expended in maintaining sur-
veillance over the record keeping required of major sources. Such record
keeping, when federally required for sources making use of supplementary
control strategy, is included in activity 109; this activity covers cases
where it is under the AFC agency, and is an on-going process;
1. Do you attempt to oversee the production of these records?
No Yes Mo. Sources Man-months
Process data ___________
Emission data __________ _____
Air quality data
No. sensors per source
108 lrjn
157
-------
109
1'09. Oversee Conduct of Supplementary Control Strategy
This activity is defined as the effort required to oversee the record-keeping,
monitoring, modelling, and forecasting required of a source permitted to operate a
supplementary control strategy, and to tniiure emission reduction.
1. Are any of the sources in the region planning to operate a supplementary
control strategy? ' '
No - none eligible
No - agency policy
Maybe - some eligible ( eligible)
Yes - permission requested ( sources)
2. What manpower do you anticipate being required to oversee such efforts?
roan-months more than otherwise
same as otherwise needed for source
man-months less than otherwise
109 my
158
-------
110
110. Formal Legal Action
This activity is defined as the actual court cases, hearings, etc., including
assimilation and preparation of supporting documents, notification of the polluter
°f impending action, and actual time in court in prosecution.
1. Is this performed by: Local APC agency , State APC agency .
other governmental (e.g., D.A.) office (specify): \
2. Number cases per year current year
expected next year
expected in 2 years
expected in 5 years
3. Manpower usage (in man-years)
APC Agency Other Legal Staff
preparation _____________
briefing
in court
A. Estimate percentage of sources likely to require legal action
5. Are any industry types more likely to require legal action? Yes, (which
ones, explain), No.
159
-------
Ill
111. Enforcement Reports to EPA
This activity provides for the effort expended in preparing and sub-
mitting the required semi-annual enforcement reports to EPA on the legal
enforcement actions taken that result In civil and criminal penalties.
1. How will these reports be prepared? ^ _ manually
______ computerised existing
program
new
program
combination (what)
2. Time required to prepare one semi-annual report in (man-days)
3. Number of enforcement actions reported __________
111 _
md
160
-------
112
112. Semi-Annual Reports to EPA on Progress In Plan Enforcement
This activity provides for the effort expended in preparing and sub-
mitting the required semi-annual reports to EPA on the status of source
control.
1. How will these reports be prepared? ___ manually
_____ computerized existing
program
new
program
. combination (what) _____
2. Time required to prepare one semi-annual report In (man-days)
3. Number of sources
112 md
-------
113
113. . Seml-Annual Emissions Reports to EPA
This activity provides for the effort expended to update the emissions
inventory and submit the semi-annual emissions report to EPA, based on the
information in the reports prepared under activity 112.
1. Man-days required for report preparation t
2. Number of sources reported on ________
113 »d
162
-------
120
120. Review of Application for Tax Exemption
This activity is primarily one of checking the tax exemption appli-
cation for accuracy and completeness, and determining percentage eligible
for write-off. The technical evaluation of the control equipment has .
usually been done prior to construction (see 130).
1. Is such an activity done with the help of your AFC agency?
Yes No .
2. How many per year?
3. Average review time per application _____ man-days
120 _
md
163
-------
130-134
A* -a group, these next few activities are meant to 'include the efforts to
r«y>tew*8sclp,osals for new sources, both direct and Indirect, to assure their being
cdn*l«>tr«nt' with the achievement and maintenance of the KAAQS.
doijtpu^have a specific portion of your staff assigned to this overall
pjweposer?
Yes Ho Ho. of stiff . .
164
-------
130
130. Technical Review of Equipment Plans
This activity is defined as the effort involved in reviewing plans for
p-oposerf sources t-o verify their compliance with established regulations per-
taining to direct emissions prior to issuance of a construction permit. Re-
view of such plans for tax credit or adjustment purposes is considered
separately as activity 120; review of construction proposals relative to
their indirect emissions, and advisory reviews, are considered in subsequent
activities in this group.
1. Performed by: APC agency Other
2. Is the technical review best described as:
a cursory review of sufficient supporting specifications
provided by applicant
an extensive review, including calculation checking of
the above
a study undertaken by the agency' to completely estimate
emissions from equipment specifications .
3. Total number of reviews per year average
current year
______ expected next year
expected in 2 years
expected in 5 years
4. We'd also like to consider differences in review require-
ments for various type sources. For the source types you're
familiar with, could you estimate the typical manpower re-
requirements for technical reviews? (See Array 100) Give
nan-days per review and number of each expected.
5. In total, could you sunparize the manpower spent on technical
reviews.
Manpower levels; total man-years
165
-------
130 (2)
6. Does manpower required vary with alee, type of emissions, etc.?
Ho . Yes (Explain)
7. Do you foresee that a "best available control technology" requirement
would change manpower requirements?
No
Yes How?
130 rad.
166
-------
LIST OF SOURCES
FOR SOURCE-ORIENTED ACTIVITY ARRAY (100)
1. Power plant, coal-lignite,>100 MMBTU/Hr.
2. , 10-100
3. , <10
4. , oil, >100 MMBTU/Hr.
5. , 10-100
6. , <10
7. , gas-coke
8. , misc.
9. Industrial boiler, coal-lignite,>100 MMBTU/Hr.
10. , 10-100
11. *10
12. , oll,> 100 MMBTl/Hr.
13. 10-100
W. , < 10
15. , gas-coke
16. , misc.
17. Comm.-Institutional boiler, coal-lignite,
18. > 10 MMBTU/Hr.
19. . ,<10
20. , oil,>100 MMBTU/Hr.
21. , 10-100 MMBTU/Hr.
22. ,<10
23. , gas-coke
24. , misc.
25. Internal Combustion (Stat. sources)
167
-------
26. Nitric acid mfg.
27. Faint & varnish mfg.
28. Sulfuric acid mfg.
29. Phosphate fertilizer mfg.
30. Other chemical mfg.
31. Feed grain handling
32. Other food & agriculture
33. Aluminum reduction
34. Copper smelters
33. Ferroalloy
36. Electric arc steel furnace
37. Other iron and steel
38. Lead smelters
39. Zinc smelters
40. Other primary metals
41. Secondary aluminum
42. Cray iron foundry
43. Other secondary metals
44. Portland cement mfg.
45. Coal cleaning
46. Other mineral products
47. Petroleum processing
48. Kraft (sulfate) pulp processing
49. Other wood products
50. Metal fabrication
51. Leather products
52. Textile mfg.
53. In-process coal use
54. In-process oil use
55. In-process gas use
56. Other in-process fuel use
57. Drycleaning
58. Other solvent usage
59. Surface coatings
168
-------
60. Petroleum storage
61- Other evaporative losses
62 Municipal incinerator
63. Open burning dumps
64- Other gov't incineration
65. General count.-institutional incineration
66. Flue-fed apartment incineration
67. Other comm.-inst. incinerator
68. Industrial incineration
169
-------
131
131. Review of Development Plans
This activity is defined as the review of specific development plans with
respect to their direct and indirect emissions, the emissions from associated
development, and the generation of displaced emissions, including the selection
of sites for stationary sources. This activity includes the receipt and processing
of a permit application, the examination and evaluation of the projected air quality
impact fcr consistency with on-going plans for achieving and maintaining the KAAQS,
and the ultimate decision. The quantitative analysis required for the projections
are included separately as activities 132-134. The compliance of stationary source
equipment with emission standards, as opposed to siting, is covered in activity
130.
1. How do you expect this activity will be performed, or how is it now
performed?
______ APC agency program
. APC veto In planning agency
_______ APC input to planning agency
' No APC agency involvement
Other _________________________
2. Status of plans:
presently in force, adopted;
______ being adopted, expected by;
anticipated only, expected by:.
3. Is (will) the authority cover one or more of the following types of
emissions? ______ Unknown
______ direct
_ indirect (vehicular)
' associated development
_____ displaced emissions
other
170
-------
131 (2)
4. What criteria is (will be) used to define the magnitude of project
required to apply for a permit? Unknown
(describe)
5. How many applications do you expect this will generate?
Unknown ' per year
6. Estimated manpower per application man-days
7. Is the time required for the review related to anything, such as the
type or size of source, location, etc.?
No Unknown
Yes (describe) ;
131 md
in
-------
132
132-134. These activities are quantitative support efforts, conducted in support
of activities 130 and 131 and, more generally, in support of overall policy and
control strategy development.
132. Mtcroscale Modelling and AQ Estimation
This activity includes the microscale modelling or other procedure used for
estimating the AQ impact of a proposed source of either direct or indirect emissions.
If the source is very large, regional-scale modelling may be more appropriate, and
in such cases, is also included in this activity.
1. Number of proposed source applications requiring this activity:
2. Manpower per application man-days
3. Proportion of effort conducted by:
X APC agency
% Planning agency
% Other (specify) '. . ; .
4. How is (will be) modelling conducted? Unknown
. In-house
what nodal()
EPA facility
what model(s).
other (pecify).,
what model
132 rod
172
-------
133
133. Review of Source-Conducted AQ Estimation
This activity involves the review of the APC Agency of modelling,
monitoring, or other estimation procedures conducted by an applicant for
a permit to construct a proposed source.
1. Do you now, or will you in the future, require proposed
sources to conduct modelling prior to construction?
No Yes (Which ones? On what basis?)
2. Do you now, or will you in the future, require proposed
sources to operate cionitoring systems before construction?
No. Yes (Which ones? On what basis?)
3. Are they, or will they, be required to operate monitoring
systems after construction? No Yes (Which ones?
On what basis? For how long?)
4. Agency manpower usage:
No. Sources/ Man-days/
. Year Source or Man-years
Review of modelling
Review of monitoring before
Review of monitoring after
Other review
133
my
173
-------
134
134. Technical Land Use Planning
This activity Includes the effort needed to provide technical planning
support to the agency management in guiding the land use planning functions.
It also provides technical support for the analysis of the developmental
implications of various alternate policies, their other ramifications. likely
obstacles to their implementation, and so on, as well as the technical
planning expertise necessary to support the review of development proposals.
1. Manpower man-years
2. Proportion of effort conducted by:
7. APC Agency
X Planning Agency
% Othar (specify) .
3. How Is (will be) technical land use planning conducted?
Unknown APC staff professional planners ______
Non-APC staff professional planners _____
APC staff (familiar with land use planning)
Other (specify) _.
134
174
-------
135
135. Environmental Impact Statement Review
This activity involves the effort spent in reviewing and providing
comments on EIS's prepared by other groups. In contrast to activity 131,
this would involve projects or actions ovnr which the APC agency has no
direct review authority; otherwise, the analysis required may be quite-
Similar to other activities in this group.
1. Manpower usage in man-days (per EIS) and number of EIS's per
year:
Man-days EIS's Total man-years
Indirect source review
New source review
Transportation review
Other
135
my
175
-------
150
150. Establishment of Mobile Source Emissions Inventory
This activity is meant to include the effort required to initially de-
velop a mobile source emissions inventory based on vehicle use and speed esti-
mates, vehicle age, and per-mile emission factors; on-going surveillance and
updating of such estimates is included in activity 155. This activity In-
cludes the effort required to develop the required data (primarily vehicle-
use data) in conjunction with the appropriate transportation planning agencies;
coordination with such agencies for other purposes, such as the development of
control measures, is included in activity 341.
1. Is this activity currently completed , being performed ,
under consideration , or not considered '
2. Is it (will it be) based on VMT ' or fuel usage
3. Computer ; manual
A. The VMT or fuel usage data, available: good , poor
none .
How and where obtained? .
S. Which of the following motor vehicle types were included?
light-duty gas vehicles (< 6000 Ib)
medium-duty gas vehicles (< 10,000 Ib)
______ heavy-duty gas trucks
light-duty diesel vehicles (< 6000 Ib)
hsavy-duty diesel vehicles (> 6000 Ib)
_____ gaseous fuel vehicle?
motorcycles
buses
6. Which fuels .
gasoline
diesel
' other (specify LNG, etc.) ______________,___.
176
-------
150 (2)
7. Manpower usage (estimate or actual)
Kan-years
Computer staff
Transportation engineers
J150 my
177
-------
151
152
153
154
151. Performance of Dynamometer Emissions Testing Program
152. Performance of Idle-Modes Emissions Testing Program
153 Performance of Emission Equipment Inspection Program
154. Oversee Motor Vehicle Emissions Testing Program
These activities involve the actual conducting by the APC agency of
a vehicle inspection and testing program (151-3), or the effort required
to oversee such a program conducted by another agency. When the testing
program is conducted in conjunction with a vehicle safety inspection pro-
gram, the manpower included is only that required for the emission test-
ing portion.
1. Is thif activity on-going _____ project (give da'te expected) ._
or not expected ?
2. Is this conducted on a local or statewide basis? (Which one
and why?)
3. Nature of APC agency involvement:
no role
_. advise transportation agency
_____ supervise, oversee
collaborate
. . perform tests
4. What type(s) of inspection is (are) carried out?
Dynamometer , idle . emission equipment inspection
- ~
5. "Are these tests performed at local service stations .or
public inspection stations 7
6. Pollutants of interest - CO, HC, other ?
7. Vehicles of interest!
__ light-duty vehicles (< 6000 Ib)
medium-duty gas vehicles (< 10,000 Ib)
_____ heavy-duty gas trucks
light-duty diesel vehicles (< 6000 Ib)
178
-------
151
152
153
154
heavy-duty diesel trucks (> 6000 Ib)
gaseous fuel vehicles
motorcycles
buses
8. Age range
9. Fuel of interest
gasoline
diesel
other
10. Frequency & Timing of inspections?
annual staggered
semi-annual confined period
quarterly
other
11. Who pays for cost of inspection?
Percentage
APC Agency
Transportation agency
Vehicle Owner
Other
12. Manpower for each type of inspection?
Per Vehicle
Dynamome ter
Idle
Equipment inspection
Supervision of inspections, manpower requirements5 APC Agency (134)
(Other) agency
151
152
153
154
my
my
my
my
179
-------
155
155. On-going Surveillance of Mobile Source Emissions
1 This activity Includes the efforts Involved In maintaining surveillance
over the various Inputs to the mobile source emission calculations; these
Include primarily the efforts Involved In analyzing the data from the emis-
sion testing program (151-3) and any effort required In maintaining sur-
veillance over' trends In vehicle usage (e.g., VMT).
1. Does your agency have a program to maintain on-going sur-
veillance of mobile source emissions? Yes No
2. Is (will) the activity associated with this surveillance pri-
marily (be) undertaken by the APC agency . transportation
agency (specify) . or other
(specify) I ; ?
i
3. If a surveillance program Is operational, what Is the primary
data utilized?
(a) VMT trends
(b) Age distribution of mobile sources ..
(c) Gasoline sales _____
(d) other (specify) .
4. Is the analysis of emission testing data a computer or
manual operation?
5. What Is the purpose of the emission testing analysis:
. failure rate analysis
; mobile source emission factors
other
_ other _
6. Manpower usage:
Computer staff '
Engineering analyist
Other '.
155 my
180
-------
156
156. Mobile Source Enforcement
This activity Includes any mobile source enforcement efforts conducted
by the AFC agency, as well as liaison and coordination efforts in conjunction
with other agencies' enforcement efforts.
1. Which of the following activities arc performed for enforcement
of mobile source regulations, and by whom? Give man-hour estimates
APC Agency Transportation Enforcement Other
State CT local Agency Agency Specify
Specify Specify
Spot testing
Field patrol
Sticker
Inspections
Complaint
Investigation
Other (specify)
156 _
nw
181
-------
!6G
160. Episode Control Plan '
This activity includes all effort used to maintain surveillance for
periods of unusually adverse dispersion and to exercise the episode avoidance
plan when required.
1. What is the total number of people involved in episode type
activities?
2. Do you maintain on-going Met surveillance?
No, weather service only; Yes, __% of man-year
3. During an episode, how much additional effort (per day of alert)
is placed on monitoring? man-days, _____ % increase in
sampling '
On compliance checking? man-days
On data processing? man-days .
On forecasting & modeling? _____ man-days
On other (specify)? man-days
4. How many alerts last year? alerts.' days
How were -episodes handled?
_____ .people from other jobs
_____ overtime
permanently assigned
'' other in-house (specify)
highway patrol
other outside agency (specify)
160
182
-------
201-205
210-212
These'activities cover monitoring and laboratory efforts that are generally
proportional to the number of source tests conducted or ambient samplers operated,
etc.
The quantitative information has been arranged into two arrays for convenience,
and the definitions arc presented separately.
183
-------
201
202
203
204
205
201. Field Operation
This activity Is defined as the various efforts required to conduct the
day-to-day operation of automatic monitoring equipment, mechanized sampling
equipment, and static sensors. As automatic equipment needs less field time,
this activity is aimed more at the operation of hi-vol samplers and bubbler
.samplers, including exchanging sample collection media, making airflow measurer
ments, and inspecting the equipment for wear and damage. The field operation
of static sensors basically Involves the periodic changes of sensors (dustfall
jars, sulfation candles and plates, corrosion panels, etc.) and chemical or
gravimetric determinations or sensor preparation are Included in activities 210-
212.
202, Routine Calibration
This activity is defined as the effort required to periodically check che
calibration of mechanized and automatic sampling equipment and is performed on-
site, usually during the routine field operation.
1. Is it possible to separate out this activity from 201 - Field
Operations? yes, no (why not?)
203. Equipment Maintenance
Thin activity is defined as that effort to check and provide periodic
maintenance of mechanized and automatic sampling equipment on-site.
1. Is it possible to separate out this activity from 201 - Field
Operations? yes, no (why not?)
204. Equipment Repair
This activity is defined as that effort necessary to rebuild or exten-
sively repair mechanized or automatic sampling, equipment which cannot be per-
formed on-site.
1. Is this done in-house or by outside services? _ Explain
184
-------
201
202
203 (2)
2C4
205
2. Is it reasonable, given your procedures, Co separate this from
activity 203 - Maintenance? Yes, No
205. Dynamic Calibration ' - .
This activity is defined as that effort required to insure the proper
measurement of samples, especially on automatic samplers. This is usually per-
formed by running known samples through the sampling equipment.
1. Consider the 11 types of samplers as given in Array 200, is it possible
to estimate separately the time to perform Activies 201-205 as defined?
yes, station vs. separately only, ' not at all (why not?)
2. What other samplers are used and are they In stations or employed
separately? (Enter in blanks of Array 200)
3. Complete Array 200 to the fullest extent possible.
What is the travel time spent and mileage travelled each week visiting
the monitors?
time , miles
185
-------
ARRAY 200
# ef each
?Rl TtflA ftnoration
Frequency of Visit
Frequency of Sample Change
(stations only)
202 Routine Calibration
Preauencv of 202
203 Equipment Maintenance
Jfpauencv of 203
7|p4 . pqiiin-nonf Ronalr
Precuencv Of 204
205 Dvnaaiic Calibration
Fr,«iuencv of 205
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210
211
212
.210. Sample Preparation
This activity in defined as that 'effort necessary for the proper prepar-
ation of sampling media (static sensors, bubbler solutions, filter paper)
before use in ambient samplers and source test trains.
211; Sample Analysis; Manual
This activity is defined as that effort necessary for the manual analysis
of samples from both ambient samplers and source test trains.
212. Sample Analysis; Automated
This activity is defined as that effort necessary for the automated analysis
of samples from wet chemical bubblers.
1, Consider the 8 sample types as given in Array 210, is it possible to
estimate separately the time needed to perform activities 210-212 as
defined. Yes, by dry or wet only, by ambient or stack
only, not at all (why not)
2. What other types of samples are used?
3. Complete Array 210 to the fullest extent possible.
4. Give the method of analyst? of each sample - only if it differs from
standard EFA procedures. (This can be subscripted in and recorded
beneath Array 210.)
187
-------
ARRAY 210
oo
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< < v<
!10 Scruple Prpoaration
* of 210 per day
t of 210 per year
Method of 210
211 Saraole Analysis: manual
t of 211 ocr day
. # of 211 per year _-.'_
Method of 211
gljt Samole Analysis: automated
# of 212 per day
# of 212 per year
Method of 212
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220
221
222
220. Data Processing and Summarization: Manual
221. Date Processing and Summarisation; Semi-Automatic
222. Data Processing and Summarization; Automated
These activities are defined as the effort required to process monitoring
data fron the sensor to the data storage system, including validation, and to
prepare routine summaries in one or more standard formats. The subdivisions are
according to the degree of computerization of the data processing system:
220. total manual system
221. semi-automatic, partially computerized
222. totally Automated, including telemetering
As different types of data processing and summarization may be used for
different types of data, more than one of the above activities may be practiced
by any one agency.
1. Do you engage in more than one of the above activities for data processing
and summarization? Yes, No
if yes, describe which types of data are handled by which system.
manua1:
semi-automatic:
automatic:
2. What is the manpower usage on each of these activities (In manyears)?
Manual
Semi-automatic,
Automatic
jnanyears (220)
manyears (221)
manyeara (222)
220 my
221 my
222 my
189
-------
230
231
130. Preparation of Quarterly AQ Data Reports to EPA; Manual
231. Preparation of Quarterly AQ Data Reports to EPA; Computerised
This activity Involves th« effort required to prepare, on appropriate
SAROAD data forms or in other SAROAD-compatible format, the quarterly air
quality data reports to EPA that are required by regulation. These can be
recorded manually (230) or through use of a computer (231).
1. Which of the above two activities describes your method of preparation
of AQ data reports for submission to EPA? manual (230), computer (231)
2. Are SAROAO data forma employed? Yes, No
if no, what type of form?
3. What is the manpower required to prepare and submit each quarterly
report? mandays/quarter.
230
231
red
md
190
-------
301. Air pollution control board
This activity is meant to incorporate the efforts of any air pollution
control board, commission, etc. which may be part of the legal framework of
the air pollution control activities in the jurisdiction of the agency.
1. Does your jurisdiction have an Air Pollution Control Board,
Commission, etc.
No
Yes, advisory only (part-time) man-hours/mo._
Yes, regulatory (part-time) man-hours/mo._
Yes, regulatory (full-time) man-hours/mo._
2. Briefly describe the duties of the board and its interactions with
the APC agency.
191
-------
302
302. Overa11 Pr ogram Management
This activity includes the various efforts required for overall program
manageeent, including the development of agency policies, the planning of
activities and resource allocations, and the determination of the general
direction and thrust of the agency's pollution control program. Those activities,
probably staff activities, that are specifically directed at developing new
or revised overall control strategies or "implementation plans" are considered
separately in activity 310. '
1. Are these functions carried out by anyone besides the director?
Director nan-weeks or % of time
Other man-weeks or t of time
Other man-weeks or 7, of time
302 mw
192
-------
310. Development of New or Modified Control Strategies
This activity is defined to be the effort required to develop possible
policies or control strategies for consideration by the agency management; it
is expected that this effort will be conducted by staff members working very
closely under the direction of the agency director, although the ultimate
policy decisions are considered separately in activity 301. The quantitative
analysis of such control strategies is also considered separately in activities
310-313. If manpower was separated into those activities, this (314) includes
the balance; if not, it includes the total.
1. Given your organization, is it reasonable to separate the activities
302 and 310
No; Yes: man years in '31i I
2. Could you describe briefly the way in which you conduct these efforts?
my
193
-------
311
312
313
311. Cllmatolosical Dispersion Modelling .
312. Economic Impact Analysis
3 13.- Community Interaction and Social Impact Analysis
314. Quantitative Evaluation of Alternate Strategies
These activities provide for the quantitative assessment of the effective-
ness and other impacts of proposed alternate control strategies, for purposes of
assisting in decision-making, attempting to anticipate public reaction and avoid-
ing difficulties, etc. Activities 311/-31 3 represent specific major tools or
capabilities that are a part of an overall assessment; activity 314 Includes pri-
marily the assessment of the strategy effectiveness in conjunction with the
emission inventory. The development of the alternate strategies is considered in
Activity 310; activity 310 can be used to include the entire manpower in 310-314
if quantitative subdivision is not possible.
Activity 311 is defined as the effort needed to maintain and use a
climatological-scale dispersion model for purposes of control strategy planning,
etc., including the gradual adaptation of existing standard computerized models
to the topographic and other idiosyncrasies of the area(s) in question.
Activity 312 involves the preparation of economic analyses to provide
reasonable estimates of the impact of regulations on impacted industries and the
economic viability of the region as a whole.
Activity 313 is limited to the programmed interaction with survey panels
of "unorganized" citizens as well as citizen interest groups and the analysis
of the impact of proposed APC agency actions on the lifestyles of the community.
Public hearings are included separately under activity 315.
1. Is it possible to separate all of these activities out from activity
310? _ yes, _ no, only activities __ _ ,
_ not at all.
2. Is a climatological-scale dispersion model used for purposes of control
strategy planning? extensively, seldom, never.
3. To what extent is it adapted to the topographic and other factors of
the region? adapted, in progress, _planned, do not
plan to.
4. Discuss briefly how you undertake the quantitative evaluation of
alternate control strategies? (314)
194
-------
317
312
313
5. For each of the activities which can be predicted separately,
indicate whether it is done by the APC agency or another (specify)
group and what the manpower usage is:
(2)
Activity
Cllmatologi-
cal Disper-
sion Model-
ling
Economic Im-
pact Analysis
Community
Interraction
Social Impact
Analysis
APC agency Other tf people % time manhours
(311)
(3U)
(313)
Quantitative
Evaluation
of Alterna-
tive Control
Strategies
(314)
311
312
313
314
tnh
_ mh
mh
mli
195
-------
315. Development and Adoption of New or Modified Control Regulations
This activity is defined as the efforts involved in developing the detailed
technical and legal' forui of proposed regulations to implement the policies
selected in activity 314, preparing the required supporting document at ion, and
seeing the regulations through the adoption procedure, including legislative
liaison. It includes the manpower involved in preparing and conducting public
hearings, except for the small effort in publicizing them, which is in activity
370.
Stationary Source Regulations
1. How is this activity conducted in your agency?
_. by specifically-defined group of people '.
_ on ad hoc basis, with contributions from:
_ T, management
_ % engineers
_ % legal staff ( _ in-house or )
2. What effort goes into developing and adopting regulations for
stationary source control?
. new regulations /year; .. man -weeks total
distribution: 7, mgmt., _ ;X engineers, % legal
Transportation Source Regulations-
3. Status of transportation regulations?
______ none required
_ transportation control plan developed, regulations not yet adopted
______ transportation regulations adopted
4. What effort goes into developing and adopting regulations for
transportation source control?
______ new regulations /year; ______ man -weeks total .
distribution: % mgmt., % engineers, ______% legal
315 _ m>
196
-------
320
320. Network Design and Planning
In urban regions, where agencies already have an air quality/meteorological
network in cxistance, this activity includes the effort to make the required
decisions on rearranging and extending the network, including site selection,
negotiation, and operating schedule analysis. In rural or outlying regions,
the development of new networks is also included. Short-term source-oriented mon-
itoring effort arc not included.
1. How is (if at all) the re-evaluation of the AQ/meteorological
network conducted? none; routine, systematic;
periodically as needed.
2. Briefly describe how and why the re-evaluation system is done:
(include stimulant for re-evaluation - AQ, Met, SS, MS, IS, land
use planning, political considerations - and any method used -
modeling, emission inventory, etc.)
3. Manpower usage: _____ man-years per year
A. Are you now, or do you envision, developing a network for presently
uncovered area; e.g., in response to requirements to prevent deteri-
oration of air quality In unpolluted areas? mo Yes
Nature of plan ' .'.
5. Would you estimate the manpower needed for this effort?
man-weeks per year.
320
197
-------
321. Laboratory Quality Control
This activity is defined as that effort to ensure the proper determina-
tion of pollutant'samples and levels in the laboratory, such as systems of
running known samples blindly through the wet chemical analysis techniques at
periodic intervals. This activity does not include the calibration of
samplers or automatic analyzers.
1. Considering the above definition, does your agency engage in this
already? yes; _____ no, agency does It lor us
no, not done at ail..
2. Are there other activities which you conduct that you would consider
"Laboratory Quality Control"? Briefly describe: (If any o£ these
are included under other activities, pull them out of consideration
before manpower questions.)
3. Number of known samples run
(If not run periodically, find out how frequently the checking
occurs.) '
4. Manpower usage '
Task Man-years
Checking wet chemical
Other ______
321
198
-------
322. Statistical and Engineering Analysis of Air Quality Data
This activity is defined as the effort involved in analysis of the air
quality data, including the necessary adjunct use of meteorological data,
either from the agency's network or from other sources; e.g., study of the
temporal and directional variations in pollutant levels in conjunction with
meteorological data and knowledge of pollutant sources. This activity does
not include the preparation of routine data summaries (activity 220).
1. Which (if any) of the following is done by your agency?
AQ trends and non-deterioration
AQ patterns
Source identification
Monitoring of known sources
Transportation planning
Indirect source planning
Other:
2. How much of this analysis is done by computer?
_ all, most, half, _____ little, _____ none
3. What overall level of manpower is used in this activity?
man-weeks
322 _
mw
199
-------
340
340. Liaison with EPA and Other APC Agencies
This activity is defined ae that Intercommunication necessary for
establishing and maintaining mutual understanding, unity of action, and
prompt and effective mutual support, particularly among agencies sharing
a single AQCR. It includes any meetings or extensive communications with
EPA or other APC agencies, including STAPPA and ALAPCO meeting, etc.
1. Do you find that a defineable amount of tine is spent on the
activity as defined above? yes, _____ no.
2. If yes, manpower usage:
: Man-days
Problem - specific meetings ________
General policy meetings _________
Other
or Total
340 md
200
-------
341
341. Liaison With Transportation Agencies
(From comments made on activities at the 130 level, you should know
whether or not the review of mobile sources is (or will be) at the transpor-
tation planning agency . . joint review , or AEC agency level.
If there appears to be no significant liaison with other agencies, omit the
following activity.)
This activity is specifically directed at the various meetings, communi-
cations, and joint-decision making processes necessary to coordinate the air
quality reviews of proposed transportation projects and develop transporta-
tion control measures. This latter aspect would include the time needed for
obtaining data from transportation agency records or jointly developing the
needed data base. .
1. Transportation control plan? s no, complete,
in process.
2. Given the above definition, estimate man-months spent with
the different agencies concerned with mobile sources.
Agency Man-months
JH 1 iron
1
201
-------
342
342. Liaison with Land-Use Planning Agencies
(From comments made on activities at the 130 level, you should know
whether or not the review of development proposals is (or will be) done by
the planning agency , joint review . or APC agency '
If there appears to be no significant liaison with land use planning
agencies, -omit the following activity.)
This activity is specifically directed at the various meetings, com-
munications, and joint-decision making processes necessary to coordinate
the air quality review of proposed construction and development projects
with other review procedures.
1. Are regulations yet in effect concerning review of indirect
sources, etc.? .. yes, ^^^ no.
2. Given the above definition, estimate man-months spent with each
of the different agencies concerned with land use planning.
Present Anticipated
Agency Man-months Man-months
342
202
-------
343
343. Provide Technical,Assistance to Local APC Programs
This activity is restricted to state or possibly large regional agencies
and includes the manpower required to provide support to, and oversight of,
local or regional control programs that operate in a fashion subsidiary to
the larger program. The technical assistance may include things such as direct
laboratory support, computer data processing, and modeling.
1. Does your agency conduct any such activities? yes (see below)
p.o:
2. If yes, which ones: Lab support . _. , computer data processing
modeling , other (specify) .
3. Describe briefly the extent of each:
4. Manpower usage:
At state At local Man-years travel cays/year
Lab support
Computer data
processing ,
Modeling _______ . _
Other
5. Is the travel time a responsibility of the state or local
agency?
6. In general, do you feel that the state or local agencies increase
or decrease your total work load? J increase, decrease
Explain, especially in which areas the other agencies make a
difference. . ,
343 my
203
-------
350
,350. Liaison With Other Non-APC Governmental Agencies
Ihis activity is specifically directed at the various meetings and com-
munications with other public agencies in the area of the agency's jurisdic-
tion, such as Governors' or Mayors' offices, legislative bodies, administra-
tive (e.g., purchasing) offices, Attorney Generals, and other enforcement
bodies.
1. Is it possible to divide out the amount of time in this activity
.from the others (e.g., legislative liaison office or administra-
tive assistant)? ___. yes, _____ no: (if no, omit
balance).
2. Is it possible to separate out the amount of time spent on liaison
with each of the above agencies? __^_ yes, no;
3. Manpower usage: .
Agency or Office Man-months
Governor or Mayor _.
Legislature
Purchasing and other administrative .
Attorney General or other enforcement __________
Other '
Total
350 _
mm
204
-------
351
351. Staffing
This activity includes the Identification of personnel requirements and
selection criteria, and recruitment and hiring, as well as the review of cur-
rent job specifications. It also includes the time -spent in moderating em-
ployee disputes, supervising employee benefit programs and the administration
of a personnel performance evaluation system.
1. Is there a defined individual or group with responsibility for
staffing and personnel matters? no, yes (who),
' man-years
2. Who is usually responsible for each of the above decisions and
how much time is spent on each.
Person 7. of time Man-months
Identification of
personnel require-
ments
Recruitment and
Hiring
Employee benefits,
et al.
Evaluation of
personnel
351 mm
205
-------
360
361
360-361. In-house Training
These activities involve the development, administration, and eval-
uation of a. training effort administered within each individual AFC agency.
Activity 360 includes the identification of the training requirements and
objectives (e.g., smoke school, engineering assistance), the preparation of
required materials (e.g., ASA study, EPA training course manuals), and the admin-
istration of the program (e.g.,. formal class instruction, on the job training.)
Activity 361 includes the manpower spent by the trainee.
1. Is a formal training or orientation program (as suggested above)
carried out? no. yea; how long ? mwk./yr.
Are short courses carried out? wks./yr
2. Is training conducted "on the Job" yes. no
How long before one is working at full steam? weeks
3. Is measurable time contributed by supervisors and co-workers?
No; Yes, how much? (360) mwk/yr.
4. Manpower in training (Activity 361)
No. of people/ Length of
year x Course or Man-years
Administrative _____ . ..
Lab support _______
Stationary source ______
Legal ,
Other
360
361
mw
my
206
-------
362
362. Training at EPA
This activity is defined as the release of personnel to take part-in
EPA training and refresher courses offered at Research Triangle Park and
around the country.
1. Do any of your personnel take courses from EPA? yes, no.
2. Are there any major differences by type of staff? yea,
no. Explain.
3. Manpower usage
No. of People Weeks/Year Man-weeks
Administrative
Lab support
Stationary source
Legal staff
Other
362 mw
207
-------
363
363. Graduate School Training
This activity is defined as the release of personnel, either new or
existing, to undertake relevant graduate school programs. These may range
from a limited number of evening courses up to a full load of courses taken
for an advanced degree.
1. Do any of your personnel take part-time courses at graduate
schools? no, yes. Describe.
2. Are there any differences by type of staff? no, . yes.
Explain.
3. Manpower usage:
Administrative
Lab support
Stationary source
Legal staff
Other
Day or Evening
Courses For semester
4. How much of this is time lost from work? _______ man-hours/year
5. DC you now, or do you anticipate, releasing staff for full-time
t
study? no. yes. Describe
363 mh
208
-------
364
364. Professional Activities
This activity is defined as the time allotted for the release of person-
nel to attend conferences and exchange ideas with other professionals.
1. Are personnel ever released for professional activities (as de-
fined above)? no, yes: APCA meetings
Other national meetings
Local meetings
Other
\
2. Tivne in travel and meetings, etc.
No. of People x Weeks/Year or Man-years
Management _____ _ . _____
Laboratory staff __
Er^ineers ______ _
Legal staff ______ .
Other technical:
Non-technical:
3. How much time is expended in preparatory activities, such as writ-
ing papers, planning programs, etc. nan-years.
364
209
-------
370
370. Public Information
This activity is defined as the active, organized dissemination of In-
formation on the APC agency, the air pollution problem, and proposed agency
actions. Press releases, prepared articles, school and community group pre-
sentations would be included in this activity. The conduct of public hear-
ings is not included, although dissemination of public notices is.
1. Do you currently have anyone on your staff specifically engaged
in this type of activity? yes, no
If no, how is this handled? Not at all or by other ______
2. Would you consider this an accurate definition of the way the
activity is undertaken? yes, no. How different?
3. Is it possible to break up the time spent on each of the various
forms of public information dissemination -- press releases,
prepared articles, school presentations, community group pre-
sentations? yes, no. How or why not?
4. Is it possible to break up the time spent on ecch of the various
topics -- APC agency, general information, proposed agency
actions? yes, _____ no.- How or why not?
5. Manpower usage (in manhours)!
Press releases
Prepared articles
School presentations
Community group
presentations
0 the r
or Total.
370 __
mh
210
-------
371
371. Library and Archives
This activity is defined as the maintenance of a library of references,
current publications, and in-house documents, including required maintenance
of plans and documents for public use. It also includes any technical service
of reviewing periodicals and alerting others to appropriate material.
1. Do you currently have anyone on staff engaged in this type of
activity? yes, no.
If no, how is this handled? not at all , by other
2. Would you consider this an accurate definition of the way the
service is provided? yes, no. How different?
3. Manpower usage:
No. of people x 7. time or Man-weeks
APC Agency
Other
371 mw
211
-------
372
372. Editing and Graphic Services
This activity is defined as the editorial and graphic arts assistance in
technical report production and the preparation of public information materials.
1. Do you currently have anyone on staff engaged in this activity? Yes No
If no, how is this activity handled?
2. Manpower usage
0 people . x I time or manyears
APC Agency
Other
372
212
-------
373
373'. Effects Surveillance
This activity is defined as that effort aimed at surveying the effects
of pollution on humans, vegetation, livestock, soiling of buildings, corro-
sion, etc. Time spent in cooperation with national effects surveillance
efforts arc included, as are local efforts, aimed either at unique local pol-
lution problems or at simply providing local estimates for planning and public
information purposes. Static sensor field monitoring of materials effects is
included elsewhere.
1. Do you conduct, or expect to conduct, any activities of this type?
None
Would cooperate, if asked
Which activities
______ Summarize local health statistics
Compile local economic statistics
Other (specify)
2. Manpower usage: ______ man-weeks per year
373 _
mw
213
-------
374
374. Photographic Services '
This aeitivty is defined as that effort expended in pictorally documenting
violations, hearings, conferences, etc. or in other public relations activities
involving use of photographic services. It would include any time spent in
taking and processing pictures.
1. Do you currently have anyone on your staff engaged in this type of
activity? yes, full time
yes, man-hour ,
no, professional outside help
no, not done at all
2. Does the time given above include processing of pictures?
__________ no, done by regular services
_________ ves» % of total time spent
3. For what purpose are photographic services performed?
________ violation documentation 7. of time
_________ public relations 7. of time
other % of time
374 _
mh
214
-------
390
390. Clerical Support for Administrative Staff
1. How many secretaries (clerks) are responsible to your administra-
tive and management staff? Number of staff
2. Is all their time spent on support for this category?
yes, no, only 7,
390 my
215
-------
391
391. Clerical Support for Laboratory Staff
1. How many secretaries (clerks) are responsible to your laboratory
staff? Number of staff?
2. Is all their time spent on support for this category?
. yes, ______ no, only , %
391 my (
216
-------
392
392. Clerical Support for Stationary Source Inspectors
1. How many secretaries (clerks) are responsible to your stationary
Source Inspectors staff? ' Number of staff?
2. Is all their time spent on support for this category?
yes, no, only \
392 my
217
-------
393
393. Clerical Support for legal Staff
i I
1. How many secretaries (clerks) are responsible to your legal staff?
Number of staff?
2. Is all their time spent on support for this category?
yes, no, only 7.
393 my
218
-------
394
394. Clerical Support for Other Technical Staff
1. How many secretaries (clerks) are responsible to other technical
staff? Number of staff?
2. Is all their time spent on support for this category?
yes, no, only 7.
394
219
-------
Activity
Are there any anomalous instances or events (particular source, episode,
etc.) which accounts for more than a normal share of the manpower require-
ments. Yes No
State instance, % of time, and reasons:
Ideal manyears for this task
At present: my's or % change
Reasons for difference from actual usage:
In two years: my's or % change
In five years; my's or % change
Reasons for changes (increased development, compliance achievement,
control equipment requirements, current new Federal Requirements, etc.).
State reasons and how and why you expect them to affect manpower.
Are there any other factors not previously mentioned which you feel
have a direct or indirect relationship to the amount of manpower needed
for the proper completion of this.task? State factors and give any known
(or felt) relationships. . .
Are there any anomalous factors concerning your agency or area of
jurisdiction which may make the manpower requirements strikingly difficult
from other AFC agencies? Yea No
State the factor (s), reasons, and effect on manpower:
220
-------
Activity #_
Rate this activity's importance on a scale of 1 to 10 (1 least important)
for each of the following categories.
attainment of air quality standards
maintenance of air quality standards
prevention of significant deterioration
public PR value
political PR value
industrial PR value
221
-------
Man-years
101
102 __
103
104
105 _
109
110 _
133 _
134
135
150
151 _ _
152 __
153 r
154 ^__ ._
155
156
201 _
202
203
204 _
205
210
211
Man-months
106
107
108
341
350
351
'
Total mm
Man-weeks
301
315
322
360
362 ___________
371
373
Total mw
212 364
220 372 Total my
221 390 _______
222 _ 391
314 392
320 . 393
321 394
343 .
361
Man-days
111 ;
112
113
120
130
131
132 ______
160
230
231
340
'.^_^«B»
_-_--__
Total rod
Man-hours
310
311
312
313
363
370
374
Total mli
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TECHNICAL REPORT DATA
(Please read InsJjnictiom on the reverse before completing)
\. REPORT NO.
EPA-450/3-75-034
4. TITLE AND SUBTITLE
Manpower Planning Model
7. AUTHOR(S)
David A. Lynn and Gordon L.
2.
Deane
9. PERFORMING ORGANIZATION NAME AND ADDRESS
GCA CORPORATION
Burlington Road
Bedford, Massachusetts 01730
12. SPONSORING AGENCY NAME AND ADD
EPA, Office of Air and Wast
Office of Air Quality Plann
Research Triangle Park, N.
RESS
e Management
ing and Standards
C. 27711
3. RECIPIENT'S ACCESSIOWNO.
5. REPORT DATE
March 1975
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT NO.
GCA-TR-74-33-G
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-0041
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This report presents a computerized manpower planning model designed to estimate the
manpower requirements of nonfederal control agencies and to project the effects on man-
power levels of various policy options and other decisions. In contrast to the model
in current use, the new model is based on data primarily from states rather than urban
areas, utilizes about 40 functional activities compared to 17, and is based as much an
possible on direct air pollution characteristics of the geographic region within which
the agency has responsibility, such as number of sources and level of monitoring ac-
tivity, rather than economic and demographic characteristics.
The predictive relationships formulated for the model are based on empirical informa-
tion obtained from nine existing agencies seven state agencies and two local agencies
within two of the seven states. The agencies to be studied were not selected via a
randomized procedure, but were selected in full knowledge of their size, philosophy,
strong and weak points, and the nature of the area within which they have responsibili-
ty. This was because the intent of the'model is not to project manpower utilization
as it actually occurs, but rather to project manpower utilization as it should be,
that is, to estimate the manpower needed to operate an agency in an adequate fashion,
meeting all its responsibilities in a satisfactory manner.
7.
KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Air Pollution
Control Programs
Manpower
Computer Model
18. DISTRIBUTION STATEMENT
Unlimited
b.lDENTIFIERS/OPEN ENDED TERMS
Air Pollution Control
Control Agencies
Manpower Resources
19. SECURITY CLASS (This Report)
UNCLASSIFIED
20. SECURITY CLASS {This page)
UNCLASSIFIED
c. COSATI Field/Group
21. NO. OF PAGES
232
22. PRICE
EPA Form 2220-1 (9-73)
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