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
                                 vi

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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.
                                               i

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.
                              3

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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
                               10

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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:
                                 11

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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
                                 12

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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
                                  13

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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

                                14

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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.
                                15

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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.
                                16

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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.

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 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

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 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

-------
 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

-------
 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

-------
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

-------
                     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

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 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

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   1000   2000    3000    4000    5000   6000
       NUMBER OF SAMPLES PER YEAR
7000
Figure 4.  Sample analysis (hi-vol filters)
                  50

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 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

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 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

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         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

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                         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

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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

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           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

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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

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   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

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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

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 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

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        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

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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

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 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

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                      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

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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

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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

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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

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 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

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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

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         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

-------
        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.
                                91

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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

-------
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.

-------
 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

-------
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

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 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.

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  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.
                                   104

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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.
                                 107

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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.
                             108

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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.
                                 109

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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
                               111

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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.
                               112

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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
                               113

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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.
                                114

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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.
                                 115

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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.

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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
                                117

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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.
                                         118

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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.
                                 119

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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.
                               120

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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.
                                121

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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

                                122

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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

                               123

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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.
                               124

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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.
                                125

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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
                                126

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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

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                                                                    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

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                                                                           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

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                                                                           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

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                                                                       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

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                                                                       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

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                                                                       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

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                                                                       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

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                                                                          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

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                                                                       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

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                                                                    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

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                                        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

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 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

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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

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                                                                        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

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                                                                     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

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                                                                         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

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                                                                       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

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                                                                       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

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                                                                       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

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                                                                           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

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                                                                    150  (2)
7.   Manpower usage (estimate or  actual)
                             Kan-years
    Computer staff           	
    Transportation engineers  	
                                                             J150 	my

                                  177

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                                                                        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

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                                                                      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

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                                                                        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

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                                                                           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

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                                                                       !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

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                                                                        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

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                                                                             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

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                                                                            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

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                                                             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

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                                                                    ARRAY 210
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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

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                                                                             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

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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

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                                                                        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

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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

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                                                                            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

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                                                                          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

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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

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                                                                          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

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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

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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

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                                                                          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

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                                                                          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

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                                                                          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

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                                                                          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

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                                                                          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

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                                                                          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

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                                                                       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

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                                                                          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

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                                                                          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

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                                                                          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

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                                                                          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

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                                                                          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

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                                                                          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

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                                                                       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

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                                                                       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

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                                                                          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

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                                                                          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

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                                                                          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

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                                                                          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

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                                                                          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

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                                                              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

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                                                              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

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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

	
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Man-weeks
301 	
315 	
322
360
362 ___________
371
373 	
	
	

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212 364
220 372 Total my
221 	 390 _______
222 _ 391 	
314 392
320 	 . 393 	
321 394
343 	 . 	
361





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111 ; 	
112 	
113 	 	
120
130 	
131
132 ______
160 	 	
230 	
231
340

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311 	
312
313
363 	
370
374 	
	
	

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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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