GUIDE
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GUIDE FOR CONTROL
OF AIR POLLUTION EPISODES
IN MEDIUM-SIZED URBAN AREAS
Prepared under Public Health Service
Contract No. PH-22-68-32
ENVIRONMENTAL PROTECTION AGENCY
Office of Air Programs
Research Triangle Park, North Carolina
June 1971
For sale by the Superintendent of Documents, TI.S. Government Printing Office
Washington, D.C. 20402 - Price 40 cents
Stock Number 5503-0013
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The AP series of reports is issued by the Office of Air Programs,
Environmental Protection Agency, to report the results of scientific and
engineering studies, and information of general interest in the field of
air pollution. Information reported in this series includes coverage of
Air Program intramural activities and of cooperative studies conducted
in conjunction with state and local agencies, research institutes, and
industrial organizations. Copies of AP reports are available free of
charge to Federal employees, current contractors and grantees, and
nonprofit organizations as supplies permit -from the Office of Tech-
nical Information and Publications, Office of Air Programs, Environ
mental Protection Agency, P. 0. Box 12055, Research Triangle Park,
North Carolina 27709. Other requestors may purchase copies from the
Superintendent of Documents, Washington, D.C. 20402.
Office of Air Programs Publication No. AP-77
11
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CONTENTS
Section page
LIST OF FIGURES v
LIST OF TABLES v
1. INTRODUCTION 1
1.1 OBJECTIVE 1
1.2 SCOPE 1
1.3 EPISODE POTENTIAL 2
2. DEFINITION OF EPISODE FACTORS 5
2.1 ATMOSPHERIC POLLUTANTS 5
2.1.1 Particulates 5
2.1.2 Sulfur Oxides 6
2.1.3 Carbon Monoxide 7
2.1.4 Oxidants 7
2.1.5 Oxides of Nitrogen 8
2.1.6 Other Pollutants 8
2.2 FORECASTING AIR POLLUTION POTENTIAL 9
2.2.1 High Air Pollution Potential Advisories 9
2.3 AIR QUALITY DECISION CRITERIA 12
2.4 DATA REQUIREMENTS 12
2.5 DATA COLLECTION 13
2.5.1 Emission Source Inventory 13
2.5.2 Meteorological Monitoring 14
2.5.3 Air Quality Monitoring 15
2.6 COMMUNICATIONS 16
2.7 SOCIO-ECONOMIC FACTORS 18
2.7.1 Social Considerations 18
2.7.2 Economic Considerations 18
3. EMERGENCY ACTION PLAN 21
3.1 INTRODUCTION 21
3.2 EMERGENCY ACTION PLAN FORMULATION 21
3.2.1 Responsibility and Authority 21
3.2.2 Emergency Action Criteria 22
3.2.3 Background Information 23
3.2.4 Emergency Source-Curtailment Actions 23
3.2.5 Communications 23
3.2.6 Reporting 23
111
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3.3 EMERGENCY ACTION PLAN IMPLEMENTATION 24
3.3.1 Emergency Action Plan Criteria 24
3.3.2 Emission Curtailment 25
4. EMERGENCY ACTION SYSTEM 29
4.1 INTRODUCTION 29
4.2 MODES OF EMERGENCY ACTION SYSTEM 29
4.3 ORGANIZATION OF EMERGENCY ACTION SYSTEM ... 30
4.3.1 Routine Surveillance Mode 30
4.3.2 Partial Activation Mode 32
4.3.3 Full Activation Mode 34
4.4 EMERGENCY ACTION CENTER 36
4.4.1 General 36
4.4.2 Data Display 36
4.4.3 Operations Room 37
4.4.4 Estimated Costs 37
4.5 STANDARD OPERATING PROCEDURES 38
4.5.1 Routine Operation 38
4.5.2 Reports of Poor Air Quality 39
4.5.3 HAPPA Reports 39
4.5.4 Preparation for Partial Activation of Emergency
Action Center 39
4.5.5 Partial Activation 39
4.5.6 Full Activation 40
4.5.7 Termination of an Emergency 40
APPENDICES
A. GLOSSARY OF AIR POLLUTION TERMS 41
B. EMERGENCY EMISSION-REDUCTION POSSIBILITIES ... 49
IV
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LIST OF FIGURES
Figure Page
2-1 Forecast High Air Pollution Potential Days 10
2-2 Weather Service Stations in United States 11
2-3 Sample Press Release 17
2-4 Flyer Published by the National Tuberculosis and Respiratory
Disease Association 19
3-1 Elements of an Emergency Action Plan 22
3-2 Alternate Emergency Control Actions 27
4-1 Emergency Action System 31
4-2 Information Flow During Routine Surveillance Mode 32
4-3 Information Flow During Partial Activation Mode 33
4-4 Information Flow During Full Activation Mode 35
4-5 Typical Emergency Action Center Layout 37
LIST OF TABLES
Table Page
4-1 Estimated Costs of Equipment for Emergency Action Center. . 38
B-l Sulfur Content of Oil, by Grade 51
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GUIDE FOR CONTROL
OF AIR POLLUTION EPISODES
IN MEDIUM-SIZED URBAN AREAS
1. INTRODUCTION
1.1 OBJECTIVE
This manual has been made available through the efforts of the Air Pollution
Control Office's (APCO's) Emergency Operations Control Center (EOCC)
and is intended to assist local air pollution control officials concerned with the
design and implementation of emergency action plans for the avoidance of air
pollution episodes. In this document, an air pollution episode is defined briefly
as the occurrence of stagnant air masses during which air pollutants accumulate,
so that the population is exposed to an elevated concentration of airborne con-
taminants. It is not specifically designed for utilization in the "man-made" type
incident in which an accident or spill results in a localized fumigation of emer-
gency proportions. Much of the direction provided herein, however, will be ap-
plicable to such a situation.
1.2 SCOPE
This manual is directed toward the needs of medium-sized to relatively
large urban areas and, possibly, to many state air pollution control programs.
Currently, agencies in this broad classification can be expected to have both
the staff capabilities and resources to design a basic effective episode control
effort. These agencies vary widely in the total number of staff, equipment,
facilities, and support. Through the use of outside resources, however, both
affiliate and voluntary, a program in sufficient depth to meet their individual
responsibilities can be implemented. Obviously, these responsibilities vary
relative to the severity of the episode problem, but currently, few United
States urban areas can claim that their situation does not warrant a specific
action plan for pollution incident control.
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The manual is "geared" to aid and assist these local control officials in the
development of an Emergency Action Plan (EAP) for recognizing and coping
with potentially severe episodes. Regardless of the size of the control
authority, effective control actions can be taken in any area if proper
procedures are developed before the episode occurs.
This guide describes the planning steps necessary to forestall the adverse
effects of air pollution episodes. Different regions have varying legal and
administrative frameworks, as well as different meteorological, topographical,
and emission source characteristics. There are common elements, however,
such as the need for knowledge of emission sources, an understanding of the
behavior and conditions of the atmosphere, and the development of action
plans for recognizing and coping with potentially severe episodes.
Because essentially the same elements must be considered for episode
control as for long-range or chronic control, and because, therefore, this
manual could cover an enormous spectrum of information, some practical
limitations are set:
1. This guide emphasizes episode control; items not specifically concerned
with this objective have been de-emphasized.
2. "Accidental episodes," such as emergencies resulting from the rupture
of chemical vessels or transport lines, have not been considered.
3. Detailed technical information needed in the practice of specialized
technological or legal disciplines has been excluded.
As indicated, this guide is directed toward a large and diverse group.
Although the character of a town with a population of 30,000 is quite
different from that of a city populated by 300,000, moderately sophisticated
plans are proposed that win serve the needs of cities that fall within this size
range. Certainly, the city capable of supporting a competent, full-time staff
and operating the latest automatic sampling devices should do so, if such are
required. On the other hand, if proper channels have been established, a city
should be capable of implementing effective episode emergency actions with
merely a handful of trained personnel. A joint planning effort is required by
the control authority and those that operate emission sources. This manual
provides the structure to create such a plan.
1.3 EPISODE POTENTIAL
High Air Pollution Potential Advisories (HAPPA), issued daily by the National
Weather Service, were initiated on a regular basis in August 1960. Advanced
warnings of meteorological conditions that can lead to the accumulation of air
pollutants are provided by this system. To provide this service, a set of
semi-arbitrary conditions has been selected for defining high air pollution
potential. These advisories, plus their possible utilization, will be described
later in this guide.
In general terms, a description of weather conditions conducive to air
pollution episodes is as follows:
2 GUIDE FOR CONTROL OF AIR POLLUTION
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1. A stationary or slow-moving, high-pressure weather system prevails over
the area.
2. No precipitation occurs.
3. Winds are light and variable, generally less than 7 miles per hour near
the surface, and relatively light aloft.
4. Air in the low levels is stable, exhibiting little motion or mixing in the
vertical layers.
5. Temperature increases with height (inversion).
From a meteorological standpoint, a weather situation conducive to the
accumulation of high concentrations of air pollutants is said to have "high
pollution potential," regardless of the number and type of pollution sources
existing in the affected area.
Introduction
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2. DEFINITION OF EPISODE FACTORS
High concentrations of man-made pollutants in the air have produced the
following observed effects:
1. Reduction of visibility.
2. Deterioration of fabrics, metals, and building materials.
3. Damage to vegetation and animals.
4. Injury to man.
If, under chronic conditions, the pollutant levels are sufficient to produce
some of these manifestations, then, under acute (episodal) conditions, these
effects can interact to create an emergency or, perhaps, a disaster. When the
population is subjected to these extreme pollution levels, public concern and
cooperation are at a maximum. Compulsory and voluntary emission reduction
is most easily justified and obtained, provided proper direction is available
from the local authority. Thus, this section deals with information that should
help the local authority to understand and define the factors that constitute an
air pollution episode. A glossary of air pollution terminology can be found in
Appendix A.
2.1 ATMOSPHERIC POLLUTANTS-THEIR NATURE AND
EFFECTS
Additional information on the effects of air contaminants is contained in
the Air Quality Criteria Documents published by the Air Pollution Control
Office.
2.1.1 Participates
Particles of solid—and occasionally liquid—matter in the air constitute an
important portion of community air pollution in most cities and towns in the
United States. Sources of particulates include such activities as fuel com-
bustion, various manufacturing and processing operations (production of steel,
cement, and petroleum products), and open burning and incineration of refuse.
Participate air pollution is widely regarded as objectionable because it is
often aesthetically bothersome. It interferes with visibility and is associated
with the soiling and corrosion of metals, fabrics, and other materials. Its
adverse effects on health are far more subtle but, nonetheless, significant. In
general, concern about the health effects of particulates is related to (1) the
ability of the human respiratory system to remove particulates from inhaled air
and retain them in the lung, (2) the presence in particulates of mineral
substances having toxic or other physiologic effects, (3) the presence in
particulates of polycyclic hydrocarbons having demonstrated carcinogenic
(cancer-producing) properties, (4) the demonstrated ability of some fine
particles to increase the harmful physiologic activity of irritant gases when
both are simultaneously present in inhaled air, and (5) the capacity of some
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mineral particulates to increase the rate at which sulfur dioxide in the
atmosphere is converted by oxidation to the far more physiologically active
sulfur trioxidc.
The size of airborne particles has an important bearing on whether and to
what extent they will reach the lungs. Most coarse particles—those about 5
microns or more in diameter-lodge in the nasal passages. Smaller particles are
more likely to penetrate into the lungs; the rate of penetration increases with
decreasing particle size. Particles smaller than 2 to 3 microns usually reach the
deeper structures of the lungs, where there is no protective mucous blanket.
The capacity of particles to accentuate the adverse physiological effects of
simultaneously inhaled gas is one of the most important aspects of the health
hazard of particulate air pollution.
2.1.2 Sulfur Oxides
The sulfur oxides (SOx) that are of concern as atmospheric pollutants are
sulfur dioxide, sulfur trioxide, and their acids and acid salts. Fossil fuels such as
coal and petroleum contain elemental sulfur; when the fuel burns, the sulfur is
converted to sulfur dioxide and, to a lesser degree, sulfur trioxide. Because
fossil fuels are burned abundantly in the United States to heat buildings and to
generate electric power, pollution of the atmosphere with SOX is widespread
and is especially prevalent in cities. Petroleum refineries, smelting plants,
coke-processing plants, sulfuric acid manufacturing plants, coal-refuse banks,
and refuse-burning activities are also major sources of sulfurous pollution.
The evidence is considerable that SOX pollution aggravates existing
respiratory disease in humans and contributes to their development. Sulfur
dioxide alone irritates the upper respiratory tract; adsorbed on particulate
matter, the gas can be carried deep into the respiratory tract to injure lung
tissue. Sulfuric acid, when inhaled in a certain particle size, can also deeply
penetrate the lungs and damage tissue.
The documented severe air pollution episodes had common factors: they
occurred in heavily industrialized areas for relatively brief periods during high
pressure atmospheric conditions; sulfur dioxide levels were excessively high, as
were levels of other gaseous and particulate pollution. Although the pattern of
effects was not perfectly uniform in all these episodes, generally the elderly,
the very young, and those with pre-existing cardiorespiratory disease were most
affected.
Epidemiological and clinical studies substantiate the evidence that certain
portions of the population are more sensitive than others to SOX pollution. For
example, prolonged exposures to relatively low levels of sulfur dioxide have
been associated with increased cardiovascular morbidity in older persons;
prolonged exposures to higher concentrations of sulfur dioxide have been
associated with an increase in respiratory disease death rates and an increase in
complaints of nonproductive cough, mucuous membrane irritation, and
mucous secretion by school children; the residual air in the lungs of
6 GUIDE FOR CONTROL OF AIR POLLUTION
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emphysematous patients has been reduced significantly when the patients
breathed ambient air that had been .filtered of pollutants.
Sulfur oxides pollution can also adversely affect the more robust segments
of the population. Experiments in which healthy human volunteers were
exposed to sulfur dioxide concentrations several times higher than the
taste-threshold concentration indicate that such exposures will produce
pulmonary function changes including increased respiration rates, decreased
respiratory flow rates, and increased airway resistance. The impairment of
function was greater when the sulfur dioxide was administered together with
particulate matter.
2.1.3 Carbon Monoxide
Carbon monoxide (CO) is one of the most common of all urban air
pollutants and can be one of the most harmful to man. Its ability to impede
the oxygen-carrying capacity of the blood makes it lethal in high concen-
trations. Though all processes involving combustion of carbonaceous material
produce CO, the motor vehicle is by far the most important source from which
this pollutant gas reaches the atmosphere. The wide use of motor vehicles,
coupled with the fact that they discharge pollutants from points close to the
ground, makes them the prime contributor to most people's daily exposure to
CO.
Carbon monoxide poisoning is a well-understood phenomenon. As with
many other harmful gases, the degree of damage that man sustains as a result of
exposure to CO is related to the concentration of the gas in inhaled air and the
length of exposure. The hazards of CO arise mainly from its strong affinity for
hemoglobin, which carries oxygen to body tissues. The effect of CO combining
with hemoglobin is to deprive the tissues of needed oxygen. At concentrations
of slightly more than 1,000 parts per million (ppm), CO kills quickly. Fifty
parts per million is now recommended as the upper limit of safety for healthy
industrial workers exposed for an 8-hour period. At approximately 100 ppm,
most people experience dizziness, headache, lassitude, and other symptoms.
It is quite possible that during episodes, the levels of CO that are reached
both in vehicles and close to highways are frequently high enough to affect
some especially susceptible persons, such as those already suffering from a
disease associated with a decrease of oxygen-carrying capacity of the blood
(e.g., anemia), or those suffering from cardiorespiratory disease. The extra
burden that is placed on the body by the reduction of the oxygen-carrying
capacity of the blood induced by CO may cause injury to vital organs. People
already burdened by the presence in their blood of unusual amounts of CO
because of tobacco smoking or occupational exposure, may also adversely be
affected by the extra amount of CO they inhale from contaminated air.
2.1.4Oxidants
Oxidants are a major class of compounds found in photochemical smog-a
major air pollution problem caused by atmospheric reactions of gases derived
from the combustion of organic fuels. Emissions from motor vehicles are a
prime factor in the formation of photochemical smog in virtually all parts of
Definition of Episode Factors 7
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the country. Other factors that contribute to smog formation are the
combustion of fuels for heat and electric power, burning of refuse, evaporation
of petroleum products, and handling and use of organic solvents. The principal
identifiable oxidants in polluted urban air are ozone, the peroxyacyl nitrates
(PAN), and the oxides of nitrogen (NOx), primarily nitrogen dioxide CN02).
The most commonly experienced effect of photochemical smog is eye
irritation. The components causing eye irritation have not been completely
identified, but there is some correlation between the occurrence of eye
irritation and overall levels of oxidant in the atmosphere. There is a
characteristic pungent odor associated with photochemical smog. Ozone is an
acrid component of this odor.
Studies have shown that it is harder for humans, particularly patients
suffering from chronic respiratory disease, to breathe in areas having even a
moderate level of photochemical air pollution (0.10 ppm total oxidant or
higher).
2.1.5 Oxides of Nitrogen
Oxides of nitrogen (NOX) are an important group of atmospheric
contaminants in many communities. They are produced during the high-
temperature combustion of coal, oil, gas, and gasoline in power plants and
internal combustion engines. The combustion fixes atmospheric nitrogen to
produce the oxides. At the high temperatures, nitric oxide (NO) forms first; in
the atmosphere it reacts with oxygen and is converted to N02. While this
oxidation is very rapid at high concentrations, the rate is much slower at low
concentrations. In sunlight, especially in the presence of organic material as
typified by Los Angeles type photochemical smog, the conversion of NO to
N02 is greatly accelerated.
Nitrogen dioxide, an acutely irritating substance, is considerably more
toxic than NO. In equal concentrations, it is more injurious than CO. The
proven effects of N02 on man and lower animals are confined almost entirely
to the respiratory tract. With increasing dosage, acute effects are expressed as
odor perception, nasal irritation, discomfort in breathing, acute respiratory
distress, pulmonary edema, and death. The relatively low solubility of N02,
however, permits penetration into the lower respiratory tract. Delayed or
chronic pulmonary changes may occur from high but sublethal concentrations
and from repeated or continuous exposures to lesser concentrations.
It should be noted, however, that combined effects with other air
pollutants may be more critical than the adverse health effects of NO2 alone.
2.1.6 Other Pollutants
There are, of course, many air pollutants other than those mentioned here;
and these may. be of prime importance in specific localities. Since episode
criteria have not yet been developed for these pollutants, they are not included
here.
8 GUIDE FOR CONTROL OF AIR POLLUTION
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2.2 FORECASTING AIR POLLUTION POTENTIAL
The meteorological character of a region is determined by geographical
location and local topography. Location identifies the broad-scale weather
patterns that dominate the area, and topography accounts largely for local
variations during particular weather situations.
Observations over the United States have indicated that when certain
meteorological conditions are met in the vicinity of a source or sources of air
pollution, the pollutants tend to disperse slowly with respect to the usual rates
of atmospheric diffusion and transport. The intensified pollution continues
until meteorological conditions change so as to provide better ventilation for
the affected area. Air pollution potential, therefore, may be defined from the
meteorological standpoint as a set of weather conditions conducive to the
accumulation of high concentrations of air pollutants.
2.2.1 High Air Pollution Potential Advisories
High Air Pollution Potential Advisories (HAPPA) are prepared at the
National Meteorological Center (NMC) in Suitland, Maryland, by meteo-
rologists of the National Oceanographic and Atmospheric Administration
(NOAA), Department of Commerce.
Advisories are based both on reports received hourly via teletype from
Weather Service stations in the United States and on numerous analyses and
forecasts prepared by the NMC. With its electronic computer facilities, the
NMC prepares mixing-depth and wind-speed data from all upper-air-observing
stations in the contiguous United States (about 70 stations). These data are
analyzed, interpreted, and integrated with other meteorological information.
National air pollution potential advisories based on these data are
transmitted daily at 12:20 p.m., E.S.T., to Weather Service stations via
teletype service "C." When meteorological conditions do not warrant issuance
of a HAPPA, the teletype message is "none today." When the forecast indicates
that an advisory of high air pollution potential should be issued, the message
designates the affected areas. The daily message indicates significant changes in
the boundaries of advisory areas, including termination of an episode.
After extensive experimentation and testing, the High Air Pollution
Potential Advisory Program went into routine daily operation on August 1,
1960, to service the portion of the United States east of the Rocky Mountains.
On October 1, 1963, the program was expanded to include all of the
contiguous United States.
Figure 2-1 presents a summary of the total number of days and episode events
recorded by this service through October 31, 1969. Of the episodes (advisories
on consecutive days for an area) that have bepn evaluated in detail, most have
been verified by air quality data taken concurrently in the forecast areas.
Because conditions of atmospheric transport and dispersion typically vary
with location and time, the forecasting staff cannot prepare advisories for each
city in the United States. For this reason, the NOAA meteorologists limit their
Definition of Episode-Factors 9
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o
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Figure 2-1. Forecast high air pollution potential days.
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0
8,
Figure 2- 2, National Weather Service Stations In United States.
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forecasts to areas at least as large as 75,000 square miles (roughly the size of
Oklahoma), in which stagnation conditions are expected to persist for at least
36 hours. Individual Weather Service stations may modify these generalized
forecasts on the basis of local meteorological conditions.
Users of the service should realize that boundaries of the forecast areas of
high air pollution potential cannot be delineated exactly. For practical
purposes, the lines defining the advisory areas should be interpreted as bands
roughly 100 miles wide.
To be notified of these advisories, air pollution control or research officials
must initiate arrangements with the nearest Weather Service station shown on
Figure 2-2. Once arrangements have been made, the local Weather Service
office will notify the officials when their area of interest is included in an
advisory. Since the forecasts are issued for a given area only when
meteorological conditions warrant, it is possible that some affiliates of the
program will not receive any notifications at all, and many will receive them
only rarely.
Because the forecasts are for special purposes, NOAA suggests that they be
disseminated through local air pollution control agency channels. Any public
announcements should be made in terms of expected pollution conditions
rather than as weather news, and should relate to the issuing agency rather than
to the Weather Service office.
2.3 AIR QUALITY DECISION CRITERIA
Deciding which pollutants in a given locality require control depends
mostly on past research, historical occurrence, and a common-sense view of
existing and forecast emission source contributions to the atmosphere. Sulfur
dioxide, carbon monoxide, hydrocarbons and their photochemical products,
oxides of nitrogen, and particulate matter are of universal interest; any one
may be the principal problem in a given area at a given time. Reduction of
these air contaminants—mostly associated with fuel combustion-will have an
impact on air concentrations of "trace metals" and other low-concentration
pollutants. Individual sources may contribute fluorides, chlorides, and many
kinds of participates in specific receptor areas, but these are a minor factor in a
"first attack on episodes" where the concern is protecting general health in
whole cities and regions.
2.4 DATA REQUIREMENTS
Three major categories of data are required to support an Emergency
Action Plan (EAR). These categories are:
1. Emission source inventory.
2. Meteorological monitoring.
3. Air quality monitoring.
An emission source inventory should be conducted during formulation of
the EAP to identify the area sources and the types and quantities of pollutants.
12 GUIDE FOR CONTROL OF AIR POLLUTION
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Detailed information on production schedules and control techniques is also
needed for the control authority. With this information, abatement schemes
can be created for the various phases of an alert.
Meteorological monitoring is essential; an examination of existing atmo-
spheric conditions can be used to predict the conditions during future periods.
As pollutant concentrations continue to increase during an episode, additional
predictions of the expected atmospheric conditions are essential. Such
forecasts will be used to predict the severity and duration of an episode; they
also can be used to determine the effects of control actions that are required to
reduce the possibility of hazardous pollutant concentrations.
Air quality monitoring data complement the meteorological data in
predicting future conditions during an episode. Alert stages are determined by
the reported concentrations of various pollutants. To effectively respond to the
conditions of an episode, near-real-time data describing the quality of the
atmosphere are essential.
2.5 DATA COLLECTION
2.5.1 Emission Source Inventory
If the impact of emissions from specific sources of pollution is to be
estimated, such emissions must be quantified. More importantly, if emissions
are to be reduced during episodes, the possible means of curtailment must be
identified. It is therefore recommended that the authority obtain as much of
the following information, in as much detail as possible, that is available. A
questionnaire may be used; but, if the number of sources is not too great,
visitation and consultation is the method suggested for gathering the following
information:
1. General information.
a. Location and property boundaries.
b. Plant capacity, normal and maximum.
c. Fuel usage by shift, day of week, month, and season.
d. Fuel type and composition, especially sulfur and ash content.
e. Fuel heating value.
f. Input-material flow rates.
g. Number and frequencies of operating levels if process is continuous.
h. Number and frequencies of "batches" if process is "batch."
i. Source emission height and stack diameter.
j. Emission rate of pollutants per unit of input material.
k. Emission gas flow rates and temperatures, including variation.
1. Individuals (and telephone numbers) to be contacted on air pollution
matters.
m. Type, efficiency, and cost of pollution control equipment.
n. Plant and expansion.
o. Process flow diagrams.
p. Interruptability of batch processes.
2. Dual fuel capability.
a. Advance notice desired.
Definition of Episode Factors 13
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b. Alternate fuel, ash and sulfur content.
c. Time required to switch fuel.
d. Seasonal availability of alternate fuel.
e. Added costs of dual fuel capabilities.
3. Process curtailment capability.
a. Advance notice required.
b. Curtailment methods.
c. Emission rate after curtailment.
d. Number of employees released on curtailment.
e. Estimated economic loss per day of curtailment.
In some cases, the source management will not be able to supply pollutant
emission rates; if not, rates may be estimated by techniques described in
Duprey's Compilation of Air Pollutant Emission Factors, available from the
Environmental Protection Agency's Air Pollution Control Office as PHS
Publication No. 999-AP-42.
2.5.2 Meteorological Monitoring
During potential episodes, the control agency will require special mete-
orological data that provide a more detailed understanding of local atmospheric
conditions than can be derived from routine Weather Service reports. HAPPA
data from nearby Weather Service airport offices seldom represent conditions
in the city, particularly at night. The control office should have a means for
providing supplementary up-to-the-minute data from locations within its area
of concern. This will require a plan for data acquisition and processing. The
plan could be a simple, cooperative arrangement with privately equipped
facilities such as schools, power plants, newspaper offices, and industrial
establishments. For reliable data reporting and control, however, a permanent
observational network operated by the local agency is advisable.
Of primary importance are measurements of wind direction, speed, and
gustiness. Surface temperature measurements are useful, but measurements of
temperature differences with height, to indicate atmospheric stability, are more
valuable.
The number of reporting sites required depends upon local topography,
including urban structures. Many practical considerations govern the plan of a
reporting network; a grid spacing of 2.5 miles within city limits and 5 miles in
adjacent suburbs is fine for research needs, but excessive for control needs.
Reporting sites should include one or more installations atop tall buildings and
on hilltops.
Because wind flow is marked by rapid fluctuations that are of little
individual importance in transporting air pollutants, wind data should cover
specified periods between 10 and 30 minutes. A wind record is important,
however, because:
1. Trends may be observed.
2. Atmospheric stability can be estimated from wind-direction fluctuations.
14 GUIDE FOR CONTROL OF AIR POLLUTION
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If available wind-measuring equipment provides only for visual readings
from meters or flashing-light indicators, a minimal record should consist of
hourly wind data with remarks about observed gustiness.
2.5.3 Air Quality Monitoring
For episode avoidance purposes, one fact emerges clearly when air
monitoring requirements are examined: data are needed quickly—in no less than
a few hours after the sensor is contacted by the pollutant. While it is possible
to obtain data rapidly by manual methods with telephone reporting, there is a
trend toward automated monitoring networks. Obviously, the severity of the
problem, size of the receptor area, and availability of resources influence both
the scope and sophistication of the system.
It is necessary to utilize continuous air samplers because an episode lasts
only a few days and the control actions taken must be based on "real-time"
measurements correlated with the decision criteria.
The collection and analysis must be accomplished rapidly if the data are to
be useful immediately. There is no time to check out the methods, run blanks,
calibrate, etc., after the onset of episode conditions. In general, either
personnel must be stationed at the sites during the episode or automated
equipment must be operated that can provide automatic data transmission to a
central location.
The commonly used instruments for measuring the pollutant parameters
utilize wet chemical techniques (such as colorimetry, coulometry, or conduc-
tivity) for SC>2, or physical methods for CO (infrared absorption) and soiling
particulates (filtration followed by optical density).
Chemical analysis always involves the use of consumable supplies. The
chemicals must be replaced on a schedule that is determined by the rate at
which samples are taken. Currently used instruments store adequate supplies of
chemicals for operation for periods of from 3 days to 1 month. In some cases,
analytical reagents for specific air contaminants deteriorate rapidly and should
have protective storage.
Physical methods of measurement are performed with relatively complex
equipment. These instruments must be installed correctly and cared for by
trained personnel. Their accuracy is affected by mechanical shock, ambient
temperature extremes, voltage supply stability, dirty or dusty atmospheres, and
corrosive chemicals.
Designing a sampling network presents a difficult problem because the
measure of effectiveness is elusive. Confining the problem to episode avoidance
rather than chronic air pollution control objectives, the measure of effective-
ness is the success in avoiding the public health "disasters," given adequate
emission curtailment methods. If concentrations are uniform in the area, a
single station might be sufficient. Although there is some evidence that
concentrations are more uniform within a given area during episodes than
Definition of Episode Factors IS
-------
during nonepisode conditions, the extent to which this is true in all areas
obviously depends on many factors.
Generally speaking, a minimum of three monitoring sites is required. As
many as ten might be justified, however, in a large, complex region with a high
frequency of episode conditions.
2.6 COMMUNICATIONS
A potential or actual episode requires rapid control response to changes in
meteorological conditions and pollutant levels. This requirement means that
the design of a communications plan is one of the most important elements in
the implementation of an EAP. A major portion of the communications
network is used to transmit status reports and control actions to non-control-
agency personnel. Individuals and agencies needing such information include:
1. Public Officials-Mayor, Governor, city council, health commissioner,
etc., who may be called upon to participate in a decision-making
process.
2. Personnel at Major Emission Sources—Personnel at major emission
sources require alert status reports to effect source control plans
designated to reduce emissions. If execution of such plans is mandatory,
a formal system may be required for legal notification of the alert
status.
3. Public Safety Agencies—The police, fire, civil defense, and public health
departments, may be assigned definite tasks during an alert and need to
be kept informed on the status of the event. In some locations, existing
civil defense, disaster, or emergency networks and procedures may be
available for use. The telephone company, though not a public agency,
similarly needs to be informed, mainly because of the possibility of
overloading facilities.
4. Sensitive Persons—Those people who are most susceptible to acute
health problems must be kept advised during an episode. Thus there
must be a coordinated effort between the local air pollution officials,
public health officials, physicians, hospitals, and the public. It may be ill
advised to notify these sensitive people via the public news media as it is
important that the physician be able to detect whether a particular
patient is reacting physiologically to the pollution levels or psychologi-
cally to the episodes. Communicating information through the local
health agency or medical society may be more advisable.
5. General Public and News Media—A direct communications link to major
local news media in the area is required. The use of good judgment in
dealing with news media is extremely important, and consultation with
those experienced in this procedure is highly desirable.
An example of a typical episode news release is shown in Figure 2-3.
16 GUIDE FOR CONTROL OF AIR POLLUTION
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NEWS RELEASE - (Date) Agency
Department of A1r Pollution Control
(Address)
(City)
fOR I WED I ATE RELEASE CONTACT: (Staff Member - Phone No.)
At 12:30 p.m. today (date), the local Weather Service notified the City's
Department of Air Pollution Control that weather conditions consisting of a
high pressure area and low wind speeds were developing 1n the metropolitan
(city) area. These are the same weather conditions that are
being formed over the Eastern seaboard from Maine to the Carolinas. These
weather conditions are expected to continue until late tomorrow (date) and
•may result 1n an Increase In the levels of some air pollutants.
"There has been some Increase In the levels of sulfur dioxide, but the
proportions of other contaminants have not reached a point at which calling of
an 'air pollution alert1 1s necessary or required," stated Mr. ,
(title).
Mr. also announced that the Air Pollution Control
Department's laboratory had been placed on a 24-hour operational basis.
Normally, the staff works a 40-hour week while the instruments measuring
air quality record their results continually without attention around
the clock. "However") the (title) sald/in order to be fully cognizant
of the problems as they arise, we shall maintain a close watch on the
conditions and report to the public if there is need for any specific
activity." Mr. , air pollution specialist for the (city)
Weather Service, stated that because cool air at the surface was trapped by
a I1d of warm air aloft, 1t would remain stagnant over the (city) area.
It Is expected, that the Department of A1r Pollution Control will issue another
statement within 24 hours.
Figure 2-3. Sample press release.
Definition of Episode Factors 17
-------
2.7 SOCIO-ECONOMIC FACTORS
2.7.1 Social Considerations
In the broadest sense, social considerations encompass all those factors that
relate to human society, the welfare of human beings as members of society,
the interaction of the individual and the group, and the cooperative and
interdependent relationships of members of the group. This section is restricted
to a rather narrow field of human behavior. There are several social factors that
the episode planner must prepare for:
1. It must be realized that any action whatsoever that is taken will have a
social effect.
2. Generally, these effects will increase with the duration of the episode.
3. Initially, the effects will be of the nature of inconveniences.
4. The effects are primarily those related to restrictions on normal activity,
and the anxieties associated with a pervasive hazard from which there is
no escape.
5. Finally, with some exceptions, these effects disappear at the termi-
nation of the episode.
The principal means available to the local authority to minimize these
types of social effects is through a program of public education. The episode
planner must provide for an effective public information program before,
during, and after an episode. The public must be prepared to endure the
inconveniences of personal restrictions and to assess calmly the nature of the
hazard. Figure 2-4 displays a sample public information approach.
While the public in smaller communities will face only minor incon-
veniences, such as restriction of backyard refuse burning, certain emotional
individuals and some citizens with severe heart or respiratory disease will
undoubtedly become alarmed. The agency must be able to reassure such persons
that they will be protected from possible injurious effects by either a reduction
of source emissions or a warning to leave the immediate area of high pollution
until the episode terminates.
2.7.2 Economic Considerations
It is important to appreciate the fact that the benefits of improved air
quality are as difficult to assess as are the many costs of air pollution control.
As with any health-related control program, the costs involve human factors
that are difficult to express as equivalent dollars. For "episode control," the
benefits include the avoidance of acute illness and death. The duration of much
of the economic impact is a few days; when human lives are concerned, the
costs involved in control are relatively slight compared to the possible benefits.
During the source inventory, information can be gathered that will assist
the authority in evaluating part of the economic impact of emergency action
options. It is to industry's advantage to release accurate economic and emission
data to help insure that designed actions are realistic and effective. The
necessary information may be supplied voluntarily or regulations may be
18 GUIDE FOR CONTROL OF AIR POLLUTION
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WHEN AIR POLLUTION IS HEAVY
Here's what you can do to help yourself and your neighbor
Use public transportation wherever possible. Use your
automobile only If absolutely necessary. If you must
drive, try to team up with neighbors or co-workers.
AIR POLLUTION FROM AUTOMOBILES
IS A MAJOR PROBLEM
Reduce room temperatures to the legal minimum, unless
health considerations prevent such action.
AIR POLLUTION FROM HEATING EQUIPMENT
IS A MAJOR PROBLEM
Stop all outdoor burning.
AIR POLLUTION FROM OPEN OR REFUSE BURNING
IS A MAJOR PROBLEM
Use as little electricity as possible, either for
lighting or appliances.
AIR POLLUTION FROM POWER PLANTS
IS A MAJOR PROBLEM
Observe the restrictions recommended by your health department
or air pollution control agency.
IF YOU SUFFER FROM A RESPIRATORY AILMENT OR HEART CONDITION--
Remain Indoors with the windows closed.
Don't smoke. Avoid rooms where others are smoking.
Eliminate unnecessary physical exertion.
Stay under your physician's care.
AIR POLLUTION CONTRIBUTES TO RESPIRATORY DISEASE
Figure 2-4. Flyer published by the National Tuberculosis
and Respiratory Disease Association.
Definition of Episode Factors 19
-------
required. The agency should observe industrial proprietary rights to economic
and technical information.
The costs incurred by industry during an episode will be a combination of
the fixed or recurring costs associated with being prepared for an episode, and
costs approximately proportional to the duration of emergency abatement
action during an episode. Both of these classes of costs will vary widely in
magnitude and nature from place to place, among types of industries, and
among various plants within each industry. Consequently, data should be
collected from each individual plant or plant classification.
20 GUIDE FOR CONTROL OF AIR POLLUTION
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3. EMERGENCY ACTION PLAN
3.1 INTRODUCTION
This section discusses the formulation and operation of a "typical"
Emergency Action Plan (EAP). The intent is not to spell out a universal model
plan, but to provide a worklist of items that should be considered in designing
and implementing a plan. Each area or region contains special conditions and
limitations, and each planning item must be considered in the light of local
requirements.
The necessity for careful and detailed pre-planning cannot be over-
emphasized; the time for reaction may be a matter of hours. Planning is
necessary to insure that the required equipment, resources, personnel, and
procedures are available and the desired communications and control actions
are ready to be implemented. An air pollution episode is an unusual event; the
emergency actions may be appreciably more drastic than the normal abatement
activities undertaken to meet long-term air quality goals.
The major elements of an EAP are shown in Figure 3-1.
In preparing the subsequent material in this section, the following
generalization has been made:
The existence of a central air pollution control agency, either municipal,
county, or state, is essential. This entity possesses, or can obtain, sufficient staff
and resources to implement its specific air pollution episode action plan.
3.2 EMERGENCY ACTION PLAN FORMULATION
There are actually two phases involved in the creation of an EAP. One
phase must be formulated for activities within the air pollution control
authority itself, while the second relates to the interactions between the
authority and others such as governmental agencies, sources of pollution, and
news media. The integration of these two elements into a single "master plan"
involves the following considerations and activities.
3.2.1 Responsibility and Authority
1. Determine the boundaries of the control area and explore cooperative
relations with adjoining areas; decide on interagency strategies in calling
alerts; examine special boundary problems.
2. Establish the lines of authority for emergency actions. Local agencies
often have authority that has been delegated by the State; but in such
cases, the final responsibility still lies With the State._
3. Determine whether an advisory emergency committee will be part of
the plan; if so, each member should have an alternate.
4. Establish the legal authority to exercise emergency control actions,
including civil or criminal law enforcement tools.
21
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WEATHER
FACTORS
AIR
QUALITY
OBSERVATION
SOURCE
INVENTORY
SOCIO-
ECONOMIC
FACTORS
DECISION
CRITERIA
EMISSION
CURTAILMENT
EMERGENCY ACTION
PLAN
Figure 3-1. Elements of an Emergency Action Plan.
5. Obtain the approval of the Mayor, appropriate State authority, and
APCO (if a federally designated region).
3.2.2 Emergency Action Criteria
1. Assemble the available emission source and air quality information to
define the local situation.
2. Establish a committee to review and recommend criteria; the committee
should include the disciplines of medicine, meteorology, air pollution
engineering, government, and law and public safety (police,).
3. Review the criteria that have been adopted in other similar areas, if any;
prepare arguments for revising them or developing new criteria,
considering episode-proneness, local air quality status, and controllable
elements.
22
GUIDE FOR CONTROL OF AIR POLLUTION
-------
4. Determine the responsibility and establish procedures for emergency
actions.
5. Plan for annual review of criteria, or special review following a major
episode.
3.2.3 Background Information
1. Develop emission inventory data, using records of other agencies
(Planning, etc.) where possible; develop means for updating periodically.
2. Define the air quality observation program necessary to recognize
pre-episode conditions.
3. Define the physical data to be obtained during potential and actual
episodes.
4. Establish procedures for reviewing data during potential and actual
episodes.
3.2.4 Emergency Source-Curtailment Actions
1. Establish the emission-curtailment actions to be taken for:
a. Power generation.
b. Other industrial sources, by class and size.
c. Commercial sources, by class and size.
d. Incineration and open burning: municipal, commercial, construction,
and residential.
2. Establish which actions should be voluntary and which should be
mandatory.
3. Define inspection and enforcement procedures, including personnel and
equipment requirements.
3.2.5. Communications
1. Establish direct communications with personnel at major emission
sources; establish contacts and alternates for each.
2. Determine the information desired by State and Federal authorities, and
the form in which it is desired.
3. Design the local information system, utilizing police, civil defense,
public safety, and private communication links; coordinate with each to
define their roles. (Police and taxicab radios can serve as emergency
communication networks.)
4. Prepare sample news releases; consult with other control agencies
experienced in problems of dealing with the public in these matters.
5. Develop recommendations to local medical groups on advising their
patients.
3.2.6 Reporting
1. Determine whether legal documentation of data is required; if so,
the HAPPA bulletin plus local sampling station measurements may
suffice.
2. Prepare an outline for a technical summary report; include a record of
the times of emission-curtailment actions, air quality observations, and
observed effects, as well as the climatology of the event.
Emergency Action Plan 23
-------
3.3 EMERGENCY ACTION PLAN IMPLEMENTATION
The EAP provides for the flow of information between different elements
and allows for appreciable interaction between the elements. The information
flow into the authority includes data on the current status of the atmosphere.
Information is also required on both pollutant emissions and the availability of
control actions. The authority interprets the incoming information and, using
judgment in conjunction with such tools as atmospheric dispersion estimates,
predicts the present and future status of the atmosphere. The prediction is
then compared with the air quality criteria established. If the defined levels of
pollutant exposure and expected persistence of meteorological conditions are
reached, the authority calls an alert.
When an alert has been called, information then flows outward from the
authority as planned actions for control of emissions and information
dissemination are executed. Typical communications at this point include:
1. Notification to pertinent personnel of requirements for increased air
quality observations, meteorological measurements, and inspection.
2. Notification to those people most susceptible to acute health problems.
3. Notification to the public (through news media), interested public
officials, and public agencies of the present status.
4. Notification to management of pollutant sources of the requirement to
reduce emissions in accordance with the EAP.
As the pollution sources reduce emissions into the atmosphere, the effects
are detected by air quality observations; depending on local conditions,
pollutant levels either hold, continue to rise, or decrease. If the pollutant levels
rise, it may be necessary to take more drastic control actions. Surveillance of
air quality and effects continues until the episode terminates. At that point,
communications similar to those listed above are utilized to reduce or stop
observations, inform all interested public parties, and allow sources to resume
normal operating conditions.
3.3.1 Emergency Action Plan Criteria
Following are the suggested EAP criteria that trigger the pre-planned
episode emission-reduction scheme:
1. Status: Forecast—The Forecast level indicates that an internal watch
will be activated by a Weather Service HAPPA or equivalent report
stating that a high air pollution potential will exist for the next 36
hours.
2. Status: Alert—The Alert level is that concentration of pollutants at
which short-term health effects can be expected to occur. An Alert will
be declared when any one of the following levels is reached:
S02—0.3 ppm, 24-hour average
Particulate—3.0 Coh, 24-hour average
S02 and Particulate combined—Product of 24-hour SO2 average (ppm)
and Coh equal to 0.2
24 GUIDE FOR CONTROL OF AIR POLLUTION
-------
CO—15 ppm, 8-hour average
Ox—0.1 ppm, 1-hour average
and adverse meteorological conditions are expected to continue for 12
or more hours.
3. Status: Warning—The Warning level indicates that air quality is
continuing to deteriorate and that additional abatement actions are
necessary. A Warning will be declared when any one of the following
levels is reached:
SO2—0.6 ppm, 24-hour average
Participate— 6.0 Coh, 24-hour average
Combined S02 and Coh-Product of 24-hour SO2 average (ppm) and
Coh equal to 1.0
CO—30 ppm, 8-hour average
Ox—0.4 ppm, 1-hour average
and adverse meteorological conditions are expected to continue for 12
or more hours.
4. Status: Emergency—The Emergency level is that level at which a
substantial endangerment to human health can be expected. These
criteria are absolute in the sense that they represent a level of pollution
that must not be allowed to occur. An Emergency will be declared when
it becomes apparent that any one of the following levels is imminent:
SO2—1.0 ppm, 24-hour average
Particulate—10 Coh, 24-hour average
Combined SO2 and Coh—Product of 24-hour S02 average (ppm) and
Coh of 2.4
CO—50 ppm, 8-hour average
75 ppm, 4-houi average
125 ppm, 1-hour average
Ox—0.4 ppm, 4-hour average
0.6 ppm, 2-hour average
0.7 ppm, 1-hour average
It should be made clear that an Air Pollution Alert, Warning, or Emergency
can be declared on the basis of deteriorating air quality alone; a High Air
Pollution Potential Advisory need not be in effect. The appropriate episode
"status" should be declared when any monitoring site records ambient air
quality below that designated in the criteria. The criteria should be applied to
individual monitoring sites and not to area-wide air quality.
The levels used to designate an Air Pollution Emergency are those that
pose an imminent and substantial endangerment to public health. Because
these levels should not be permitted to occur, an Air Pollution Emergency
should be declared when it appears imminent that these levels may be reached.
3.3.2 Emission Curtailment
The reduction of pollutant emissions as a measure to avoid potential
episodes requires information not ordinarily available to the local authority.
Emergency Action Plan 25
-------
Information pertaining to fuel switching, power interchange, curtailment, and
postponement operations can only be obtained through the development of a
close and knowledgeable contact with the source management. These data
should be obtained as part of the emission inventory. In many instances, the
switching to a lower-sulfur-content fuel, postponement of refuse combustion,
and curtailment of nonessential operations such as the filling of reservoirs are
adequate emission-reduction procedures. Each source management should be
required to submit curtailment plans covering the elements as described in the
source inventory section, and the operations changes to be made in curtailing
emissions.
The public may be requested to help reduce emissions by keeping heating
and electrical loads to a minimum. All private incineration and open burning
should be curtailed.
The curtailment of major sources can be planned to be implemented on a
voluntary basis. The voluntary actions to be taken should be known to the
authority, and surveillance should be conducted as though the curtailment
were mandatory. Experience to date with voluntary compliance by major
emitters has been excellent, and indicates that pollution control is more easily
achieved in the "emergency" case than in the "chronic" case. It is not
difficult, however, to obtain legal authority in the form of a court order for
curtailment of emissions in an emergency situation. In fact, it is recommended
that the legal groundwork be previously laid if a state of extreme nonco-
operation by personnel at major emission sources is found to exist.
Figure 3-2 lists alternate emission control actions that could be imple-
mented as various EAP criteria levels are reached.
Appendix B presents a more detailed discussion of emergency emission-
reduction possibilities.
26 GUIDE FOR CONTROL OF AIR POLLUTION
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SOW«C« TYP S
T HO
GlT
EstDU
STAW
o
I I 3 l
(«C
*.CTI¥t
^
gl
it£
SOVtRNMSHT
qOMMyw CATION?
(ill) $^« 441^ ,«il
Figure 3-2. Alternate emergency control actions.
Criteria levels; 1 - alert status; 2 = warning
status; and 3 = emergency status.
Itaetpacy
21
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4. EMERGENCY ACTION SYSTEM
4.1 INTRODUCTION
An extremely flexible organization is needed to implement an Emergency
Action Plan. This organization merely conducts surveillance during normal
nonepisode periods, yet is capable of expanding to satisfy the demands of
episode conditions. The Emergency Action System (EAS) is the tool that
responds to the needs of episode and surveillance conditions. This section
presents the EAS and describes its role in implementing an EAP.
An EAS is the organization of equipment, technical experts, and
administrators in an effort to analyze and combat the conditions of an
episode. The equipment is comprised of the tools required to sample and
analyze air quality and meteorological conditions, transmit information to a
control terminal, and disseminate instructions to the public and those
responsible for sources within the city. The technical experts are the engineers,
meteorologists, lawyers, technicians, and physicians who analyze data for the
decision-making process. The administrators coordinate the essential activities,
determine the emergency action, announce abatement requirements, and deal
with the public. The organization that coordinates all these efforts into an
effective package is discussed in Section 4.3. Before turning to this
organization, there are some assumptions pertaining to the minimum resources
of the air pollution control authority that must be established.
The EAS will likely be developed from an existing air pollution control
agency that is equipped with certain minimum resources. Some of the
resources that are normally used during nonepisode conditions will be required
to fill the needs of the EAS. The minimum resources assumed for the EAS are
as follows:
1. Routine manning—The services of one individual (perhaps only part-
time) knowledgeable in air quality surveillance to perform under
nonepisode conditions.
2. Air quality monitoring network-At least three air-sampling stations
that regularly monitor particulates, SOX, and CO. They should be
capable of short-interval-sampling during an episode.
3. Emergency Action Center—A room or area that has been designated for
conducting emergency action activities.
These are considered to be the minimum resources for any EAS. The EAS
also incorporates other resources that, together with these, produce an
effective episode-avoidance tool.
4.2 MODES OF THE EMERGENCY ACTION SYSTEM
The EAS will have three modes of operation; each mode becomes
progressively more complex. The modes are based on the degree of activation
of the EAS as it responds to the severity of an episode. The three modes are:
29
-------
1. Routine Surveillance—The period between emergencies when the only
activity is surveillance.
2. Partial Activation-The period of response to increased ambient
pollutant concentrations or to a forecast of stagnant meteorological
conditions.
3. Full Activation-The period during an episode in which the entire EAS
is responding to the emergency.
The EAS will develop from the least complex mode to full activation as the
atmospheric conditions progress from nonepisode to episode. Additional
equipment and manpower are drawn into the EAS as it progresses from one
mode to the next higher mode. Figure 4-1 shows how the different modes are
coordinated to determine an EAS.
4.3 ORGANIZATION OF THE EMERGENCY ACTION SYSTEM
The Emergency Action System is the organization that responds to the
needs of the three operational modes. As described previously, the EAS is a
flexible system for conducting emergency procedures during an episode. The
core of this system is the Emergency Action Center (EAC). The EAC is the
central organization that receives and analyzes air quality and meteorological
data, determines recommended actions based on these and other input data,
and stimulates abatement activities under episode conditions. The EAC
encompasses the operations of the air pollution control agency and other
invited specialists who are prepared to respond to episode conditions. The EAC
is presented as part of the EAS in Figures 4-2, -3, and -4. The functions within
each block are considered part of the EAC.
It is evident from the three figures that the EAC becomes more complex as
it progresses from the Routine Surveillance Mode to the Partial Activation
Mode and, eventually, to the Full Activation Mode. This progression is essential
since the minimal required resources should be used whenever possible.
4.3.1 Routine Surveillance Mode
The Routine Surveillance Mode (Fig. 4-2) is in effect during nonepisode
periods. This is the normal mode of operation and its essential tasks are
receiving, evaluating, and recording air quality and meteorological data. This
act of surveillance examines ambient conditions in search of episode indicators.
When no episode indicators are observed, the input data are recorded; no other
activities are required. When increased ambient pollutant concentrations are
observed or when a High Air Pollution Potential Advisory is announced,
procedures for the Routine Surveillance Mode are abandoned; then procedures
for the Partial Activation Mode are initiated.
The Routine Surveillance Mode can be handled by a part-time junior
engineer or meteorologist. Channels should be established for contacting the
sources of air quality and meteorological information. It is likely that the
source of air quality data for a medium-sized city will be one technician
operating the field monitoring network. The Weather Service will likely be used
30 GUIDE FOR CONTROL OF AIR POLLUTION
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NON-EPISODE
EPISODE
FORECASTS
EPtSOOE
ROUTINE 1
SURVEILLANCE
MODE
PARTIAL 2
ACTIVATION
MODE
POOR
AIR
QUALITY
^
HAPPA
FULL ACTIVATION MODE
I PUBLIC
A»« QUALITY
MONITORING
NETWORK
WEATHER
SERVICE
LOCAL
^METEOROLOGY
EMERGENCY ACTION CENTER
Figure 4-1. Emergency Action System.
Emergency Action System
31
-------
AIR
QUALITY
MONITORING
NETWORK
WEATHER
SERVICE
INPUT
RECEPTION
AND
ANALYSIS
ENGINEER
OR
METEOROLOGIST
EMERGENCY ACTION CENTER
Figure 4-2. Information flow during Routine Surveillance Mode.
for meteorological information. The common channel for communication will
be the telephone.
It is important that an operating procedure be established. The Routine
Surveillance Mode operator in charge of data input should know the precise
conditions that stimulate the Partial Activation Mode of the EAS. He should
know how and where to contact the Coordinator of the EAC when alert
conditions are forecast. Standard operating procedures are presented at the end
of this section.
4.3.2 Partial Activation Mode
Activities within the EAC expand when indicators of an episode are
32
GUIDE FOR CONTROL OF AIR POLLUTION
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m
n
o3
3
•3
r>
p*
o'
ft
I
AIR QUALITY
MONITORING
NETWORK
WEATHER
SERVICE
PUBLIC
DECISION-MAKER
(MAYOR, etc.)
LOCAL
METEOROLOGIST
KJ INPUT
Hd RECEPTION
^1 AND
1 AINU
IJI ANAI Y^IS
I/
• ENGINEER
'j METEOROLOGIST
1 CLERK
1 1 1
4
f
COORDINATION
ENGINEER
OR
ucTPnoni npi^T
N\C. 1 CUKULUulo 1
ABATEMENT
NOTIFICATION
ENGINEER
"T
L
X
^.
\T
i
^,
h
1 ITII ITI P^
U 1 IL.I 1 ICO
PUBLIC
FACILITIES
PRIVATE
INDUSTRY AND
COMMERCE
INCINERATION
OPEN BURNING
EMERGENCY ACTION CENTER
Figure 4-3. Information flow during Partial Activation Mode.
-------
forecast. Additional manpower will be required to satisfy the requirements of
the Partial Activation Mode. The latter is presented in Figure 4-3.
The Partial Activation Mode corresponds to the alert phase of the
Emergency Action Plan. A Coordinator (or supervisor) and an additional
engineer join the staff. The expanded staff is needed to handle the increased
rate of inputs and communicate with relevant parties outside the EAC,
including the public and managers of emission sources.
The individual responsible for monitoring inputs will contact the air-
sampling network and the source of meteorological data (i.e., the Weather
Service), and request an increased frequency of reporting. Hopefully, air-
sampling stations will be located near municipal buildings (i.e., firehouses or
public stations) where frequent reports can be volunteered with minimal
additional burden. Advanced planning in sampling-site selection and advanced
training of municipal servants will enhance the transition from nonepisode to
episode procedures.
If the closest Weather Service is outside the area, a local meteorologist may
assist during episode periods with micrometeorological data. Local airports and
private industry should be surveyed in advance for voluntary meteorological
assistance during episodes.
The input data should be recorded and displayed in the EAC. Adequate
staff should be provided for receiving, evaluating, and displaying the relevant
input data.
The Coordinator should assist in analyzing the situation, direct the
activities within the EAC, plan for requirements of the Full Activation Mode,
and communicate with outside authorities and the public. During this Mode, an
alert should be announced. The Coordinator then requests voluntary abatement
of nonessential activities and imposes selected controls. An engineer may assist
the Coordinator in notifying the management of emission sources and also
provide technical assistance if required.
The Partial Activation Mode continues until the episode forecast is
retracted or until episode conditions are declared. When the episode forecast is
retracted, the EAC returns to the Routine Surveillance Mode. A report should
be prepared that documents the actions taken during the Partial Activation
Mode; it also should include the air quality and meteorological conditions that
developed.
4.3.3 Full Activation Mode
The Full Activation Mode begins once an episode has been declared. During
this Mode, the EAC should be operating at full capacity. All required air
pollution control agency personnel should be actively participating in
implementing emergency activities. Pre-selected specialists from the fields of
medicine, law, engineering, communications, and transportation should be at
the EAC or on-call for consultation. See Figure 4-4 for the organizational
structure that coordinates the efforts of such a body of diverse talents.
34 GUIDE FOR CONTROL OF AIR POLLUTION
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CITY SOLICITOR
ANP/OR-
STATE
ATTORNEY GENERAL
AI8 QUALITY
MONITORING
NETWORK
WEATHER
SERVICE
{PUBLIC SAFETY
AGENCIES
LOCAL
METEOROLOGIST
INPUT
RECEPTION
AND
AN ALT 5lb
ENGINEER
METEOROLOGIST
CLERK
COORDINATION
ENGINEER OR
METEOROLOGIST
COMMUNICATIONS
ENGINEER
PUBLIC RELATIONS
SPECIALIST
CONSULTATION
METEOROLOGIST
ABATEMENT ENGR.
PHYSICIAN
LAWYER
TRANSPORTATION
SPECIALIST
CLERK
ABATEMENT
NOTIFICATION
POWER ENGINEER
PROCESS ENGINEER
EMERGENCY ACTION CENTER
HOSPITALS
PHYSICIANS
TELEPHONE
COMPANY
POWER
GENERATION
PUBLIC
FACILITIES
PRIVATE
INDUSTRY AND
COMMERCE
INCINERATION
OPEN BURNING
Figure 4-4. Information flow during Full Activation Mode.
-------
Air quality and meteorological inputs for this Mode should either remain at
the level determined for the Partial Activation Mode or be increased. If
additional air monitoring equipment and voluntary manpower are available, an
extension of the network should be considered.
The Coordinator receives increased assistance during this Mode. The
specialists provide inputs and recommendations as emission sources within the
city curtail operations. These specialists should also be capable of providing
assistance in evaluating input data as well as devising emergency plans for
reducing pollutants from specific area emission sources.
In this stage, there should be direct communication between the
Coordinator and the decision maker of the area. The decision maker, in most
cases, is responsible for direct contact with the public and authorizing
necessary emergency actions. The City Solicitor, or equivalent, and the State
Attorney General may also be involved in certain decisions. Channels that
incorporate the participation of these functions outside the EAC should be
established as part of the Standard Operating Procedures. Abatement notifi-
cation to area emission sources may be transmitted by telephone or in person.
The police department may be used to assist curtailment of both stationary
and mobile source activity.
The Full Activation Mode remains operational until the episode period
passes. Following this Mode, the Partial Activation Mode is required until an
episode report is prepared and conditions justify Routine Surveillance.
Naturally, all sources are to be notified to return to the normal rate of activity
when such is advisable. The public also should be notified that the episode has
terminated.
4.4 EMERGENCY ACTION CENTER
4.4.1 General
The essential consideration here is to have an identifiable location that will
serve as the Emergency Action Center (EAC). The EAC will function during
the minimal action periods or Routine Surveillance as well as during hectic
periods of Full Activation. The EAC should provide resources for all
predictable activities of the EAS; it should not be a makeshift conversion of
someone's office during an actual episode, and then relegated to a desk drawer
in between episodes. The displays of trends and other data should be
maintained up-to-date between episodes, not only in a ready-to-go status, but
to help keep the organization episode-oriented. The EAC should be con-
veniently located.
4.4.2 Data Display in the Emergency Action Center
The data display for the EAC should be maintained manually. Charts with
movable markers are recommended. The design should be inexpensive and easy
to maintain. For example, magnetic markers could be used for plotting data.
One wall of the EAC could be covered with sheet metal (iron) display
36 GUIDE FOR CONTROL OF AIR POLLUTION
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WALL MAPS
x"
METEOROLOGIST COORDINATOR
DISPLAYS
ENGINEER
U I
IZ_]
0
CONFERENCE
TABLE
D
CLERK
FILE
AsTELEPHONE
Figure 4-5. Typical Emergency Action Center layout.
panels, painted, or papered in a solid color. A time-history graph for sampling
locations around the city could appear on this wall. The coordinate axes of
each graph would consist of %-inch, colored plastic tape.
Each graph would contain space for 28 days of data. Data should be
recorded daily, except during episodes when more frequent recordings are
recommended. As new figures are reported for a particular day, the new data
would replace the oldest.
4.4.3 Operations Room
A room as large as 20 by 30 feet could be utilized. While the actual layout
will depend on the size, shape, door and window locations, and other features
of the room finally selected, a representative plan is shown in Figure 4-5.
The layout is designed to accommodate the recommended Full Activation
Mode and equipment. At least one wall should be free from windows or other
obstructions to facilitate the mounting of display panels. A 30-foot wall should
accommodate the maximum required air quality monitoring and meteoro-
logical displays. The desks of the staff should face the displays and be far
enough away (about 6 feet) to allow wide-angle observation.
A conference or work table, files, and space for a clerk-typist make up the
rest of the room.' Four telephones are required to meet maximum communi-
cation needs.
4.4.4 Estimated Costs
The estimated costs of equipment for the EAC are shown in Table 4-1.
Emergency Action System
37
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Table 4-1. ESTIMATED COSTS OF EQUIPMENT FOR EMERGENCY
ACTION CENTER
Equipment
Desk chairs
Folding chairs
Conference table
Telephone lines
Displays
Desks
File
Map file
Typewriter
Total
Number
needed
4
10
1
4
9
4
1
1
1
Estimated
unit cost, $
50
15
150
10
50
100
50
150
400
Total cost, $
200
150
150
40
450
400
50
150
400
1,990
Monthly operating costs would be comparable to those of a small, partially
used business office because the only expenses would be local phone calls,
expendable office supplies, etc.
4.5 STANDARD OPERATING PROCEDURES
4.5.1 Routine Operation
4.5.1.1 Hours of Operation
During nonemergency conditions, the EAC needs to be manned briefly
once a day. A total of approximately 10 hours per week should suffice to
receive and record data. On weekends, emergency phone calls from the
Weather Service or from the Air Monitoring Program could be received by the
engineer-in-charge at home.
4.5.1.2 Communication Procedures
The EAC should be equipped with four telephone lines to retrieve the daily
data reports. (During emergencies, the phones should be used to accept the
inward flow of data as well as to distribute essential curtailment requests and
public announcements.)
4.5.1.3 Communication Schedule
The team manning the field monitoring network should be called each day
for air quality on particulates, SOx, and CO. The Weather Service also should
be called daily. Input data should be recorded in a log book and displayed on
the wall charts. Data from weekends could be recorded on Monday. The high
and low measured concentrations for particulates, SOx, CO, or other selected
pollutants should be displayed daily.
38
GUIDE FOR CONTROL OF AIR POLLUTION
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4.5.2 Reports of Poor Air Quality
A report of poor air quality is defined as a scheduled or nonscheduled
report of a contaminant reaching or exceeding the predetermined criterion for
the first level of alert. After receiving a report of poor air quality, the person
on duty at the EAC should:
1. Alert the EAC Coordinator.
2. Check the meteorological situation and, if an advisory is in effect,
determine the area affected.
3. Check air quality reports of contiguous areas to determine the extent of
the potential emergency.
4. Check with local authorities of the affected area(s) for any information
on the seriousness of the potential emergency.
5. Arrange for more frequent reports from the monitoring stations.
6. Be prepared to recommend that the EAC be partially activated.
4.5.3 HAPPA Reports
The HAPPA is defined as a High Air Pollution Potential Advisory from the
National Meteorological Center, which forecasts stagnant meteorological
conditions. After receiving a HAPPA, the person on duty at the EAC should:
1. Ale,rt the EAC Coordinator.
2. Check the air quality reports from the surrounding areas.
3. Arrange for more frequent meteorological contacts with the cooperating
Weather Service office.
4. Arrange for more frequent air quality reports from the monitoring
stations.
5. Be prepared to recommend that the EAC should be activated.
4.5.4. Preparation for Partial Activation of the Emergency Action
Center
After any one of the above events, the person on duty should:
1. Refresh himself on activation procedures.
2. Insure that current personnel duty rosters, with telephone numbers, are
available.
3. Be prepared to remain on duty at the EAC until either relieved or a
decision has been made not to activate the EAC.
4.5.5 Partial Activation
When the EAC is partially activated, the person on duty in the EAC
should:
1. Tell the Coordinator to report to the EAC.
2. Call personnel on the on-call duty roster to advise them of the situation.
3. Advise the field air quality monitoring personnel and the local
meteorologist that the EAC is operational and arrange for increased
frequency of reporting.
4. Advise the EAC decision makers of the city that the EAC is operational.
Emergency Action System 39
-------
5. Request municipal and nonessential sources of emissions to curtail
activity.
6. Prepare news releases.
7. Maintain a log of all significant events during the Partial Activation
Mode.
8. Notify the telephone company of conditions and request activation of
planned emergency telephone communications.
4.5.6 Full Activation
When the EAC becomes fully activated, the Coordinator and the person on
duty should:
1. Call those persons on the duty roster whose presence is required at the
EAC.
2. Call personnel on the on-duty roster to advise them of the situation.
3. Advise the decision makers of the city that the EAC is fully operational.
4. Advise police of appropriate actions.
5. Prepare a news release informing the public of conditions and public
activities that must be curtailed.
6. Advise the City Solicitor, or equivalent, and the State Attorney General
of the situation.
7. Notify management of emission sources of abatement procedures.
8. Communicate with hospitals in the city.
9. Coordinate inspection of major sources to assure compliance.
10. Predict future trends of pollutant levels.
11. Maintain a log of all significant events during the emergency.
4.5.7 Termination of an Emergency
When the criteria of "all clear" are met, the Coordinator shall:
1. Notify the decision makers, legal authorities, hospitals, the public, and
others that the emergency is over.
2. Notify the management of emission sources in the area that emergency
abatement procedures can be terminated.
3. Notify the telephone company of return to normal procedures.
4. Revert the EAC to the Routine Surveillance Mode.
5. Assemble all appropriate data and prepare an episode report.
40 GUIDE FOR CONTROL OF AIR POLLUTION
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APPENDIX A.
GLOSSARY OF AIR POLLUTION TERMS
1. Acute
2. Aerosol
3. Air Pollution
4. Air Pollution Index
5. Ambient Air Quality
6. Anticyclone
7. Atmosphere, The
8. Atmosphere, An
9. Breathing Zone
Having a sudden onset and a short and
relatively severe course.
A dispersion of solid or liquid particles of
microscopic size in gaseous media. Examples
are smoke, fog, and mist.
The presence of unwanted material in the air.
The term "unwanted material" refers to
material in sufficient amount and under such
circumstances as to interfere significantly with
comfort, health, or welfare of persons, or with
full use and enjoyment of property.
One of a number of arbitrarily derived mathe-
matical combinations of air pollutants that
gives a single number attempting to describe
the ambient air quality.
A physical and chemical measure of the
concentration of various chemicals in the
outside air. The quality is usually determined
over a specific time period (for example, 5
minutes, 1 hour, 1 day).
An area of relatively high atmospheric pres-
sure. In the northern hemisphere, the wind
blows spirally outward in a clockwise direc-
tion.
The whole mass of air—composed largely
of oxygen and nitrogen—that surrounds the
earth.
A specific gaseous mass, occurring either
naturally or artificially, that can contain any
number of constituents and in any pro-
portion.
That stratum of the atmosphere in which
people breathe.
41
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10. Coh
11. Collection Efficiency
12. Collector
13. Combustion
14. Density
15. Diffusion, Molecular
16. Dispersion
17. Diurnal
18. Dust
19. Dust Fall
20. Dust Loading
21. Droplet
Abbreviation for coefficient of haze, a unit of
measurement of visibility interference.
The percentage of a specified substance re-
tained by a gas-cleaning or gas-sampling de-
vice.
A device for removing and retaining contami-
nants from air or other gases. Usually this
term is applied to cleaning devices in exhaust
systems.
The reaction of carbon-containing substances
(or other oxygen-demanding materials) with
oxygen, producing a rapid temperature in-
crease in a flame.
The mass per unit volume of a substance.
A process of spontaneous intermixing of
different substances, attributable to molecular
motion, that tends to produce uniformity of
concentration.
The most general term for a system consisting
of particulate matter suspended in air or other
gases.
Daily, especially pertaining to actions or
events that are completed within 24 hours and
that recur every 24 hours.
A term loosely applied to solid particles
predominantly larger than colloidal and capa-
ble of temporary suspension in air or other
gases.
The amount of large particulate matter de-
posited per month per square mile of land.
An engineering term for "dust concen-
tration," usually applied to the contents of
collection ducts and the emissions from
stacks.
A small liquid particle of such size and density
as to fall under still conditions, but which
may remain suspended under turbulent con-
ditions.
42
GUIDE FOR CONTROL OF AIR POLLUTION
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22. Efficiency
23. Emissions
24. Emission Inventory
25. Emission Mixture
26. Environment
27. Episode
28. Fly Ash
29. Fog
30. Fume
31. Gas
The ratio of attained performance to absolute
performance, commonly expressed in percent.
The total substances discharged into the air
from a stack, vent, or other source.
A list of primary air pollutants emitted into a
given community's atmosphere, in amounts
(commonly tons) per day, by type of source.
The total mixture in the atmosphere of
emissions from all sources.
The aggregate of all external conditions and
influences affecting the life, development,
and, ultimately, the survival of an organism.
The occurrence of stagnant air masses during
which air pollutants accumulate, so that the
population is exposed to an elevated concen-
tration of airborne contaminants.
The finely divided particles of ash entrained in
flue gases, arising from the combustion of
fuel. The particles of ash may contain incom-
pletely burned fuel.
Visible aerosols in which the dispersed phase
is liquid. In meteorology, a visible aggregate of
minute water droplets suspended in the air
near the earth's surface.
Properly, the solid particles generated by
condensation from the gaseous state, generally
after volatilization from melted substances
and often accompanied by a chemical reaction
such as oxidation. Fumes flocculate and some-
times coalesce. Popularly, the term is used in
reference to any or all types of contaminants
and, in many laws or regulations, with the
added qualifications that the contaminant
have some unwanted action.
One of the three states of aggregation of
matter, having neither independent shape nor
volume, and tending to expand indefinitely.
Glos.sary of Air Pollution Terms
43
-------
32. Grab Sample
33. Impaction
34. Impinger
35. Inversion
36. Isokinetic
37. Mass Concentration
38. Mist
39. Month
40. Odor
41. Odor Unit
42. Odorant
43. Opacity Rating
A sample of an atmosphere obtained in a very
short period of time, such that the sampling
time is insignificant in comparison with the
duration of the operation or the period being
studied.
A forcible contact of particles (often used
synonymously with impingement).
Broadly, a sampling instrument using impinge-
ment for the collection of particulate matter.
A layer of air in which temperature increases
with height.
A term describing a condition of sampling, in
which the flow of gas into the sampling
device, at the opening or face of the inlet, has
the same flow rate and direction as the
ambient atmosphere being sampled.
Concentration expressed in terms of substance
per unit volume of gas or liquid.
A term loosely applied to dispersions of liquid
droplets, the dispersion being of low concen-
tration and the particles of large size. In
meteorology, a light dispersion of water drop-
lets of sufficient size to be falling.
For reporting analyses of ambient air on a
monthly basis, rate results are calculated to a
base of 30 days.
That property of a substance that affects the
sense of smell.
Unit volume of air at the odor threshold.
Odorous substance.
A measurement of the opacity of emissions,
defined as the apparent obscuration of an
observer's vision to a degree equal to the
apparent obscuration of smoke of a given
rating on the Ringelmann Chart.
44
GUIDE FOR CONTROL OF AIR POLLUTION
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44. Oxidants
45. Particle
46. Particle Concentrations
47. Particle Size
48. Precipitation,
Meteorological
49. Precision
50. PoDutant
51. Receptor
52. Ringelmann Chart
A measure of the presence of organic oxi-
dizing chemicals, such as ozone, in the am-
bient air. An indicator of photochemical smog.
A small discrete mass of solid or liquid matter.
Concentration expressed in terms of number
of particles per unit volume of air or other
gas. Note: In expressing particle concentra-
tions, the method of determining the con-
centration should be stated.
The size of liquid or solid particles expressed
as the average or equivalent diameter.
The precipitation of water from the atmo-
sphere in the form of hail, mist, rain, sleet,
and snow. Deposits of dew, fog, and frost are
excluded.
The degree of agreement of reported measure-
ments of the same property. Expressed in
terms of dispersion of test results about the
mean result, obtained by repetitive testing of
a homogenous sample under specified condi-
tions.
Any matter that, upon discharge to the ambi-
ent air, creates or tends to create a harmful ef-
fect upon man, his property, convenience or
happiness, or that causes the contamination in
ambient air to exceed legally established limits,
or that is defined as a pollutant by a regulatory
agency.
Any person or piece of property upon which
an air pollutant creates an effect.
Actually a series of charts, numbered from 0
to 5, that simulates various smoke densities by
presenting different percentages of black. A
Ringelmann No. 1 is equivalent to 20 percent
black; a Ringelmann No. 5,100 percent. Used
for measuring the opacity of smoke arising
from stacks and other sources by matching
with the actual effluent the various numbers,
or densities, indicated by the charts. Ringel-
mann numbers are sometimes used in setting
emission standards.
Glossary of Air Pollution Terms
45
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53. Sampling
54. Smog
55. Smoke
56. Soot
57. Synergism
58. Tape Sampler
59. Thermal Turbulence
60. Topography
61. Vapor
62. Volume Concentration
A process consisting of the withdrawal or
isolation of a fractional part of a whole. In air
analysis, the separation of a portion of an
ambient atmosphere, with or without simul-
taneous isolation of selected components.
A combination of "smoke" and "fog." Ap-
plied to extensive atmospheric contamination
by aerosols arising partly through natural
processes and partly from human activities.
Often used loosely for any contamination of
the air.
Small gas-borne particles that are produced by
incomplete combustion, consisting predomi-
nantly of carbon and other combustible mate-
rial, and present in sufficient quantity to be
detectable independently in the presence of
other solids.
Agglomerations of particles or carbon impreg-
nated with "tar" that are formed in the
incomplete combustion of carbonaceous
material.
The cooperative action of separate substances,
such that the total effect is greater than the
sum of the effects of the substances acting
independently.
A device used in the measurement of both
gases and fine particulates. It allows air
sampling to be done automatically at prede-
termined times.
Air movement and mixing caused by con-
vection.
The configuration of a surface, including its
relief and the position of its natural and
man-made features.
The gaseous phase of matter that normally
exists in a liquid or solid state.
Concentration expressed in terms of gaseous
volume of substance per unit volume of air or
other gas, usually expressed in percent or
parts per million.
46
GUIDE FOR CONTROL OF AIR POLLUTION
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63. Week For reporting analysis of ambient air on a
weekly basis, results are calculated to a base
of seven consecutive 24-hour days.
64. Year For reporting analysis of ambient air on a
yearly basis, results are calculated to a base of
twelve 30-day months.
Glossary of Air Pollution Terms 47
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APPENDIX B.
EMERGENCY EMISSION-REDUCTION
POSSIBILITIES
The following paragraphs briefly discuss representative emission-reduction
actions and some of the factors that must be considered in developing the
plan.
REDUCTION OF EMISSION RATES WITH MINOR CHANGES
IN THROUGHPUT
A number of actions may be taken to reduce the quantity of emissions
from industrial processes without appreciably affecting the overall throughput
of the operation. Typically, these are steps that may be economically
undesirable for normal operation at the time, but which represent the most
economical solution during potential episode conditions.
DUAL FUEL CAPABILITY (FUEL SWITCHING)
Dual fuel capability, or provision for temporary use of a lower sulfur fuel,
will be determined separately for each class. Ordinarily, power production is
the largest single fuel consumer in a given area. Industries of all kinds use fuel
for both space and process heating and may have dual fuel capability.
Whether a specific source is already equipped to switch fuels depends on
the economic advantage to the source, or on "chronic" air pollution regula-
tions. The operating cost of burning low-sulfur coal or oil is now between 10
and 25 percent more than that of using grades with high-sulfur content; the
cost differential may decrease, and will be related to the market value of
sulfur. This cost is not an obstacle for the avoidance of air pollution episodes.
Switching from oil or coal to gas may have an economic advantage, however,
and, therefore, be independent of regulations, except for timing that may
result from emergency requirements such as potential episodes.
Some factors that must be considered in fuel-switching actions are:
1. Availability of substitute fuels:
a. Relative scarcity of alternate fuels.
b. Competitive demands.
2. Availability of storage:
a. Space requirements.
b. Handling facilities.
c. Turnover of stockpile.
3. Technical features:
a. Alternate burners.
b. Ash compatibility.
c. Particulate emissions.
d. Auxiliary equipment (heaters, pumps).
49
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Low-Sulfur Coal
Coal contains from about 0.4 to 10 percent sulfur; that coal having 1
percent or less is classified as low-sulfur. The average sulfur content for coal
used in the United States is about 2.4 percent. Most of the high-sulfur coal is
consumed by the power industry. Most anthracite and some bituminous coals
have low-sulfur content. The sulfur in coal may be pyritic, organic, or as
sulfate. Sulfate is usually a minor form; pyritic may be removed mechanically
(but not necessarily economically); and organic sulfur usually appears as S02
in the flue gas.
The steel industry is a strong competitor for the limited supplies of
low-sulfur coal. Combined with its lower natural occurrence, this makes
low-sulfur coal more costly than high-sulfur coal. Depending upon the
geographical location of the consumer relative to the high- and low-sulfur coal
sources, transportation changes can alter the cost differential resulting from
competition.
The cost of storing low-sulfur coal will be determined primarily by the
interest and taxes on the land and the losses due to weathering of the coal,
assuming the stockpile is located so that the normally used handling equipment
can service it. The stock should be turned over periodically, i.e., used and
replaced, when episodes have not occurred.
The substitution of low-sulfur coal imposes two potentially significant
technical problems: ash and particulate handling. Low-sulfur coals often have
high ash-fusion temperatures. So-called wet-bottom furnaces are designed to
discharge the ash as a molten stream. If the ash-fusion temperature is too high
(above about 2,600° F), the ash may pile up as a semifused or solid mass in the
furnace bottom; this mass could force the plant to shut down in 12 to 18 hours
and also cause extensive damage to the furnace. High-sulfur coals provide a
good electrolyte in the flue gas so that the resistivity of the fly ash is relatively
low. If the plant has electrostatic precipitators designed for low-resistivity fly
ash, a change to low-sulfur coal may significantly increase the particulate
emissions because of lower collection efficiency. If switching to low-sulfur coal
is to be the emergency control action, it may be necessary to modify the
particulate control devices by adding more precipitators or by installing a
mechanical separator in series with the electrical precipitators, or to arrange to
decrease the flue gas temperature (and hence increase S02 absorption by the
precipitated dust) to compensate for the reduced resistivity during the episode.
A 10 to 15° F change is significant. On the other hand, an increase in flue gas
temperature, while not economical as a chronic control measure, has the effect
of increasing the effective stack height, which, if it penetrates the base of the
inversion, may discharge the gases outside the stagnant region, depending on
stack height and the height of the inversion. Increasing the stack temperatures
by bypassing the air heaters would require plant modification. The trade-offs
must be examined by experienced power plant engineers for the specific cases
at hand.
50 GUIDE FOR CONTROL OF AIR POLLUTION
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Low-Sulfur OU or Gas
Plants that are normally either coal- or oil-fired can conceivably switch to
low-sulfur oil or gas. Natural gas is practically sulfur-free, but oil, however, may
contain sulfur. During the refinery processes, sulfur tends to be concentrated in
the heavier residual fractions. The sulfur content of oils may be specified as
shown in Table B-l.
Distillate oils are usually used for residential heating and, industrially, in
heat treatment and nonferrous glass and ceramic furnaces, and residual oils are
used in large space heaters and industrial furnaces.
Local availability of low-sulfur oil and gas is more a question of location
with respect to source and the means of transportation than one of inherent
scarcity. With advances in the technology of desulfurizations, low-sulfur oil is
likely to be more plentiful. Oil, like coal, may be stockpiled for use during an
episode, but storage costs will be incurred. At the well, gas compares favorably
with other fuels on a cost per unit heat content. Away from the well, sufficient
pipeline facilities are required to distribute gas. Consequently, in localities
distant from the gas fields, the use of gas as a dependable alternate fuel may
not be practical. Its availability must be determined locally.
The substitution of low-sulfur oil or gas for other fuels usually requires the
provision of special burners, especially for coal-fired furnaces. For oil-fired
furnaces, the fuel-handling equipment (including heaters) and the burners are
designed for high-viscosity residual oils rather than for low-viscosity distillate
oils or gases. In addition, the ignition characteristics and safety features of the
furnace must be compatible with the substitute fuel; serious explosions can
occur in a furnace with improperly operated burners.
The feasibility of substituting low-sulfur oil for high-sulfur coal must be
examined by experienced plant engineers for each specific situation. In
addition to differences in burners and auxiliary equipment, the impact on
particulate emissions should be examined if electrostatic precipitators are used.
COMBINATION ACTIONS
For power systems, complete shutdown is generally impractical because
electric power is required to maintain public health and safety. The local
Table B-1. SULFUR CONTENT OF OIL, BY GRADE
Grade
1
2
4
5
6
Type
Distillate
Distillate
Residual )
Residual /
Residual )
Maximum sulfur, %
0.05
0.10
No limit specified;
range is 0.34 to 4.0;
average is about 1 .6.
Emergency Emission-Reduction Possibilities
51
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situation may, however, permit some steam-generating plants to either
shut down or curtail their outputs if the balance of the connected system can
pick up the load. For other industries, it may be possible to combine
curtailment and fuel substitution by providing substitute fuel only to those
elements of the industry that are technically difficult or otherwise impractical
to shut down or curtail.
POWER INTERCHANGE
The electric power industry must have reserve capacity to handle peak
demands and to provide for the maintenance of equipment. During a potential
episode, it may be possible to shift the electrical load within and between
power systems to reduce the quantity of pollutants emitted in a particular
region. Power interchange is a complex system-wide procedure involving a
continuous equalization of generation and load. As a result of the Northeast
blackout in 1965, power interchange by portions of a power system is now a
generally accepted procedure during crises. Since the capacity to shift loads is
very sensitive to the geographical extent of the episode, this emergency action
will require interregional coordination as well as detailed engineering by the
power systems' technical staff.
Typical actions might include maximum use of hydroelectric power,
shifting to plants utilizing low-sulfur fuel, shifting to plants with superior
pollutant-removal or dispersion capability (scrubbers, taller stacks), shifting to
more favorably located plants (downwind), and maximum use of nuclear
plants.
PROCESS CURTAILMENT OR ADJUSTMENT
The factors involved for some processes used in industry are discussed
below. The possibilities are practically endless, and will have to be explored for
each major pollutant source. Cooperative analyses with engineers of each
company may turn up a great many possibilities. In a large city, with thousands
of sources, this is likely to be possible for only the major point sources. While
process shutdown is an obvious curtailment action, any measure contributing
to reduced exit loadings or to better dispersion must be considered. Delay of
certain noncritical functions, temporary (presumably less profitable) adjust-
ment of control "set-points", and increasing stack temperatures or velocities are
suggestions of possible general approaches to be investigated. Soot blowing,
cleaning, and painting may be temporarily deferred.
High-Temperature Continuous Processes
This category includes such activities as the operation of blast furnaces,
manufacture of glass, oil refining and other petrochemical operations, coking,
acid manufacturing plants, calcining operations such as the manufacture of
cement, some food processing operations, and many chemical manufacturing
processes.
52 GUIDE FOR CONTROL OF AIR POLLUTION
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The two primary problems encountered in the curtailment of any
continuous process are how to stop the process efficiently and how to purge
the system of in-process material. These problems are aggravated when the
process involves high temperatures. Generally, neither hot nor cold in-process
material can be left in the furnace, oven, or reactor. Another problem is that of
keeping the equipment in standby condition, since it may be severely damaged
if allowed to cool. For example, blast furnaces and continuous glass furnaces
are usually operated until their linings fail, and cannot be allowed to get cold
without severe economic loss.
Electrolytic processes such as are used in aluminum and magnesium
production also incur severe damage if allowed to cool, although the power
requirements may be reduced temporarily.
In refineries, in-process materials are often toxic or hazardous volatile
liquids and gases. Refineries are designed with vapor-disposal systems as both
safety features and to handle normal turnaround operations for various pieces
of equipment. Because the refinery is such a close-coupled system, a complete
shutdown is a technically difficult and perhaps unrealistic undertaking,
particularly for a short-period transient situation.
High-Temperature Batch Processes
This category includes such processes as the manufacture of steel in
electric, open hearth, basic oxygen, and Bessemer furnaces or converters; some
primary nonferrous and all secondary smelting; batch glass manufacturing;
paint and varnish manufacturing; and a multitude of chemical manufacturing
processes.
In batch processing, the process is usually terminated at the completion of
each batch. Consequently, the primary problem associated with shutdown is
that of putting the equipment in standby condition. Batch processes vary in
time per batch from a few minutes to as many as 36 to 48 hours. Thus, time is
a significant consideration in shutdown plans involving batch process indus-
tries, since the potential economic loss may be severe.
Processing of Perishable Materials
This category includes many of the food-processing industries, and others
involving biological and active chemical systems. Processing or storage of
photographic materials, leather, and electrical batteries, for example, could be
included in this class.
There may be at one or more points in a process a possibility of spoilage or
decay of the raw material, an intermediate product, and the final product. In
addition to causing economic loss, the spoilage could contribute to local air
pollution. The situation can arise in a plant being shut down if the flow of
incoming raw material is not adjusted or if no allowances are made for refuse
disposal. Of course, only those operations contributing to air pollution will be
directly curtailed, except when all "nonessential" activities are ceased.
Emergency Emission-Reduction Possibilities 53
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Other Point-Source Processes
This category includes other processes or unit operations not included in
the above classes, such as materials handling, evaporation, crystallization,
agitation, heat transfer, and packaging.
Some processes may be incidental to the primary purpose of the industry,
yet be significant. An example is evaporation at points where large volumes of
volatile materials are handled, such as petroleum loading-and-storage facilities
and dry cleaning plants. Others of these processes may be "in-line" with
processes that cannot be readily curtailed; a water cooling tower that is
emitting hydrocarbons must be phased with associated equipment; waste
gases—such as SO2—supplied as raw materials to neighboring plants must be
managed carefully.
REDUCTION OF EMISSION RATES BY CURTAILMENT OF
OPERATIONS
Curtailment of industrial and commercial operations without actual
shutdown of the operation may sometimes represent the most effective means
of reducing the quantity of pollutants emitted. Care must be taken to ensure
that the curtailment will really result in an overall pollutant reduction. The
purposes of such curtailment may include:
1. The reduction of pollutants directly emitted by the affected operation.
2. The reduction of power demands upon utilities to enable them to
reduce their emissions.
3. The reduction of natural gas usage to enable gas to be used in more
essential operations such as power generation.
4. The reduction of transportation requirements with resulting lower
power demands and lower mobile source emissions.
Refuse Disposal
The incineration of solid waste by municipalities and individual operations
(such as lumber mills, construction sites, and large apartment buildings) may be
curtailed completely or combined with fuel shifting, particularly as a control
measure in low-level alert stages. The curtailment of individual residential
backyard burning poses no problem other than communication and enforce-
ment. The shutdown of incinerators can cause increased emissions for a short
time when the episode is over. In all cases, there will be the problems of
accumulating raw waste, and of higher throughput following the period of
curtailment.
Advance Notice Required
The advance notice needed by emitters concerning curtailment may vary
from an hour to several days. This information can be supplied best by persons
with knowledge of the process and its relationship with other processes, either
internal or external to a given operation, e.g., reduction of power demand. The
advance notice required by various industry classes will be determined.
54 GUIDE FOR CONTROL OF AIR POLLUTION
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Time-Histories of Pollutant Emissions
It is desirable to know the change in total emissions with time, for the
following reasons:
1. Curtailment causes some emissions to increase temporarily.
2. The time to achieve a reduction in concentrations will be important for
future planning.
3. Emissions during restart may influence the decision to curtail.
The preparation of curves summing the total emissions against time in a
specific city would, of course, depend on cumulating individual source
emissions; this would be difficult because emissions under changing operational
conditions are not known. Representative time-histories for each industry class,
based on knowledge and observation of the operations, will be developed
during the preparation of the EAP.
The overall time required for curtailment may be the most useful data
produced from time-histories. In the absence of estimated emission rates during
curtailment, the overall time required can always be estimated. Even if
emissions rise before descending to a new reduced level, the effect-may not be
severe if the time period of elevated emissions is brief.
Side Effects
Some important side-effect considerations in preparing the emergency
plans are:
1. Releasing employees at unusual times to spread out traffic flow.
2. The suppliers and customers of each emission source may be affected.
3. Overloading of communications systems.
Emergency Emission-Reduction Possibilities 55
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