United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/3-78-042b
May 1978
Air
Emission Inventory/
Factor Workshop
Volume  2

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                                      EPA-450/3-78-042b
                   Emission
Inventory  / Factor Workshop

                  Volume  2
                        Moderator

                    James H. Southerland
                        OAQPS,
                Monitoring Data and Analysis Division


                      Co-Moderators
                       Richard Burr
                        OAQPS,
              Emission Standards and Engineering Division

                       Dale Denny
                          ORD,
              Industrial Environmental Research Laboratory

                      Charles Masser
                        OAQPS,
                Monitoring Data and Analysis Division

                   September 13-15, 1977
                       Raleigh, NC

                      Co-Sponsored by
      Air Pollution Training Institute and Air Management Technology Branch

                U.S. Environmental Protection Agency
              Office of Air Quality Planning and Standards
                 Research Triangle Park, NC 27711

                        May 1978

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This report is issued by the Environmental Protection Agency to
report technical data of interest to a limited number of  readers.
Copies are available free of charge to Federal employees,  current
contractors and grantees, and nonprofit organizations - in limited
quantities - from the Library Services Office (MD-35), U.  S. Envir-
onmental Protection Agency, Research Triangle Park, North Carolina
27711; or, for a fee, from the National Technical Information
Service, 5285 Port Royal Road, Springfield, Virginia 22161.
       USEBV
           This is not an official policy and standards docu-
       ment.  The opinions,  findings, and conclusions are
       those of the authors  and not necessarily those of the
       United States Environmental Protection Agency.  Any
       mention of products,  or organizations, does not consti-
       tute endorsement by the United States Environmental
       Protection Agency.
                             ii

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                            FOREWORD




     Emission inventories and emission factors are major components




of an air pollution control program.   The inventory is perhaps




one of the most important planning tools available to an air




pollution control agency.  Emphasis on these inventories and fac-




tors, the procedures used, and the use of the information has often




been lacking, however.  On September 13-15, 1977, the Office of Air




Quality Planning and Standards hosted a workshop with both prepared




topics and open discussion in Raleigh, N. C. to focus attention to




some of the aspects of such emission inventory and factor activi-




ties particularly as related to the timely  aspect of organic




emissions.  This document constitutes the proceedings of that




workshop and will be distributed to the approximately 130 attendees.




Additional copies are available from EPA Library Services Office.




     Papers prepared for and presented at the workshop have been




finalized by the authors and are included with no additional




editorial or technical modifications.  Papers presented do not




necessarily represent policies of the Agency but may provide a




basis for development or discussion of such policies.  The workshop




also provided a forum for various criticism which may appear to be




unanswered but hopefully helped to create an open atmosphere




conducive to constructive change.




     The discussions during and following the papers were condensed




and edited to the extent possible.  Many important discussions may




have been left out due to inadequate clarity of the recording and

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transcription.  Some of the topics of discussion may also have been




more clearly addressed by the authors when the final manuscripts -v



were prepared.  It was felt, however, to be worthwhile to include




the condensed discussions to indicate where the attendees felt



emphasis or clarification were needed.




     Following this workshop the A±r Pollution Control Association's



(APCA) newly formed committee; TP-7;  Emission Factors and Inven-



tories, developed plans for an APCA Specialty meeting on Inventories




and Factors which will be held in Anaheim California the week of




November 13, 1978, and hosted by the West Coast, APCA Section. Pa*tici-




pants at this workshop are especially invited to submit papers for



possible presentation at the meeting in California and/or be present




to participate in the discussion.  It has been suggested that the




concept of a forum for this general topic become an  annual under-




taking of EPA and/or APCA.  Discussion of this point and general



comments on the content of this document or the need for an annual




conference of some sort can be addressed to the Office of Air



Quality Planning and Standards, Environmental Protection Agency,




Research Triangle Park, N. C. 27711.  More detail on specific




papers would best be obtained by directly contacting the author(s).




     As prime moderator of the workshop, I would like to express




my thanks to the Air Pollution Training Institute and their




contractor Northrop Services, Inc. who provided the arrangements,




taping, transcription, and related work that made the workshop
                                 iv

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possible.  Especially, I would like to thank the authors, co-




moderators and attendees for their hard work and participation




which made the workshop, I feel, to be a success.
                                 James H. Southerland, Moderator.

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                           Table of Contents
     Emission Inventory/Factar Workshop
     Volume 1

     Foreword                                                    iii

1    Organic Emission Inventory                                  1-1
     Considerations and Purposes                                 to
     C.P. Bartosh, W.J. Moltz, and B.P. Cerepaka                 1-14

2    Analysis of Data for Hydrocarbon                            2-1
     Sources in Non-Attainment Areas                             to
     in Louisiana                                                2-40
     B.C. McCoy and K.J. Guinaw

3    Documentation of Emission Inventories                       3-1
     in Region IX                                                to
     B.C. Henderson                                              3-14

4    Methodologies and Problems Encountered                      4-1
     in a Level 3 Multi-State/County Hydrocarbon                 to
     Area Source Emissions Inventory                             4-26
     T.A. Trapasso and W.K. Duval

5    Air Force Emission Inventories                              5-1 to
     B.C. Grems                                                  5-14

6    A Format for the Storage of Area                            6-1
     Source Emission Data                                        to
     S.R. Tate, N.L. Matthews, D.J. Ames                         6-35
     R.A. Bradley

7    Maryland Special Factors and                                7-1
     Inventory Techniques                                        to
     E.L. Carter and J.W. Paisie                                 7-22

8    Panel Discussion of Inventory                               8-1
     Methodology Procedures and Applications                     to
     to Oxidant Control                                          8-26
                                     vii

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 9    Hydrocarbon Emissions from Households                       9-1
      in New York and New Jersey                                  to
      E.Z. Finfer                                                 9-20

10    Hydrocarbon Carrier Emissions                               10-1
      from Atmospheric Dye Becks                                  to
      R. Hawks                                                    10-25

11    Air Quality and Energy Conservation                         11-1
      Benefits From Using Emulsions to                            to
      Replace Asphalt Cutbacks in Certain                         11-21
      Paving Operations
      F.M. Kirwan

12    Commercial Bakeries as a Major                              12-1
      Source of Reactive Volatile Organic                         to
      Gases                                                       12-18
      D.C. Henderson

13    Reactive Organic Gas Emissions                              13-1
      from Pesticide Use in California                            to
      F.J. Wiens                                                  13-53

      Emission Inventory/Factor Workshop
      Volume 2

14    Volatile Organic Compound Emissions                         14-1
      From Architectural Coatings                                 to
      R.A. Friesen, R.E. Menebroker,                              14-12
      D.R. Saito

15    NO  Reducations in the Portland Cement                      15-1
      Industry with Conversion to Coal-Firing                     to
      R.J. Hilovsky                                               15-26

16    Current API Emission Measurement                            16-1
      Programs                                                    to
      J.G. Zabaga                                                 16-26

17    Hydrocarbon Emissions From                                  17-1
      Floating Roof Storage Tanks                                 to
      R.L. Russell                                                17-22

18    Emission Inventory of Petroleum                             18-1
      Storage and Handling Losses                                 to
      (A Case History)                                            18-29
      J.T. Alexander
                                 viii

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19    Inventorying Hydrocarbon Emissions                          19-1
      From Small Gasoline Bulk Plants                             to
      R.L. Norton and R.J. Bryan                                  19-39

20    An Organic Specie Emission                                  20-1
      Inventory for Stationary Sources                            to
      in the Los Angeles Area - Methodology                       20-49
      H.J. Taback, T.W. Sonneschen,
      N. Brunetz, and J.L. Stredler

21    Highway Motor Vehicle Emission                              21-1
      Factors                                                     to
      Motor Vehicle Manufacturers                                 21-80
      Association of the United States, Inc.

22    FTP Emission Factor Development:                            22-1
      Correction for Non-FTP Conditions                           to
      J. Becker and M. Williams                                   22-34

23    Land Use Based Emissions Factors                            23-1 to
      F. Benesh and T. McCurdy                                    23-27

24    Emission Rates for Biogenic NO                              24-1 to
      H.C. Ratsch and D.T. Tingey   X                             24-28

25    Procedures for Conducting Hydrocarbon                       25-1
      Emission Inventories of Biogenic                            to
      Sources and Some Results of                                 25-32
      Recent Investigations
      P. Zimmerman
                                     ix

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      VOLATILE ORGANIC COMPOUND
EMISSIONS FROM ARCHITECTURAL COATINGS
            Prepared by,

        Ronald A. Friesen
       Raymond E. Menebroker
            Dean K. Saito
      Presentation Given at the
 Emission Inventory/Factor Workshop
          Sponsored by the
   Environmental Protection Agency
         September 14, 1977
                  14-1

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                            ABSTRACT








     By using the data in this paper, estimates can be made of




Volatile Organic Compound (VOC) emissions from the use of




architectural coatings and associated solvents.  These emissions




contribute significantly to air pollution in California.  In an




effort to reduce these emissions, the staff of the California Air




Resources Board (CARB) developed a model rule to regulate the




solvent content of architectural coatings.  Essential to the




development of the model rule was a data base.  This data base was




established by use of responses to questionnaires that were




mailed to coatings manufacturers.  These responses provided data




on the sales volume of coatings and solvents and the VOC content




of these coatings and solvents for a given year, 1975.  With




this data, the CARB staff determined the level of VOC emissions in




California for 1975.  In addition, by dividing the level of VOC




emissions by the 1975 population of California, the CARB staff has




devised a method to estimate VOC emissions when sales data are




not known.  Thus, two methods of computing VOC emissions are given




in this document, and for each method, the effect of the model




rule is shown.
                                14-2

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                    VOLATILE ORGANIC COMPOUND
              EMISSIONS FROM ARCHITECTURAL COATINGS
             by R. Friesen, R. Menebroker, D. Saito
Introduction

     Little information has been generated with regard to emissions

of Volatile Organic Compounds (VOC) from the use of architectural

coatings.  The staff of the California Air Resources Board has

conducted an extensive inventory of such emissions in California,

and the data gathered are presented herein.  Using the data contained

in this paper it is possible to estimate emissions from the use

of architectural coatings with varying degrees of accuracy

depending on the preciseness of information available.  Such

information includes population, total gallons of architectural

coatings sold, or gallons of architectural coatings sold by coating

category.

     The methods of computing VOC emissions, presented here, are

preceded by brief explanations of the research involved and the

background of the study.


Background

     Volatile Organic Compound emissions from the use of architectural

coatings are a significant contributor to the air pollution problem

in California.  Based on this fact the California Air Resources

Board (CARB) embarked on a program to control such emissions.
                               14-3

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As part of this program, on July 7, 1977, CARB approved a model




regulation to control emissions of VOC from the use of




architectural coatings.  The data base upon which an architectural




coating rule could be developed, however, was nonexistent prior




to CARB activity in this area.  The first step in developing a




rule, therefore, was to establish a sound data base.  Recognizing




this need, CARB staff developed a questionnaire that would ascertain




the volumes of various waterborne and solvent-borne coatings sold




in California and the VOC content of each.  The VOC was requested




by average and maximum for each coating category for the 1975 calendar




year.






Industry Survey




     The questionnaire was mailed to 446 potential paint manufacturers,




260 of which responded.  Of these, 122 completed the questionnaire,




and 138 reported that they did not manufacture architectural




coatings.  The responses received indicated that about 50 million




gallons of architectural coatings were sold in California in 1975.




A national sales survey prepared for the National Paint and




Coatings Association indicates that about 435 million gallons of




coatings were sold throughout the United States and that




approximately 10 percent of the nationwide total, or 43.5 million




gallons, was sold in California.  A comparison of the two estimates




indicates that the CARB survey is reasonably complete.  The




results of the CARB conducted industry survey are presented in Table I.
                               14-4

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                             Table 1


               Architectural Coatings Sales and VOC
                   Emissions In California 1n 1975
COATING
TYPt
Interior Wall
Exterior Hall
Aerosols
*
Roof
••H*HO»HH^^V^^^^B.^^4^».^^^HMHMMM^«M
Clears
Stains
Primers, Sealers
and Undercoats
High Performance
Topcoats
Traffic
Sash, Trlfii
and Trellis
Metallic
Pigraented
Porch, Deck
and Floor
High Performance
Primers
Barn and Fence '
Mobile Home
Hot Classified
Subtotal
Other Solvent**
Total
1975,
SALES (103 GAL)
Solvent
Borne
2572
1694
1940
2316
••^•^^^^•^^b^B^BM
1820
1368
1617
1678
1604 •
1182
492
498
294
100
48
1707
20930

?fi7Rl
Water
Borne
11445
8375
-0-
2354
18
1205
1084
27
44
891
3
339
15
298
4
2604
29216
-0-
•M»1R
EMISSIONS (TOHS/DAY)*
Solvent
Borne
12.0
7.1
13.4
10,1
-9.4
8.0
7.0
7.3
7.1
4.6
2.6
2.5
1.4
0.4
0.2
8.2
101.3
69.0
170.3
Water
Borne
5.4
5.4
-0-
-0-
^^^^^^^K^M^WtBBVB
0.008
1.3
.69
0.03
0.03
1.3
.001
0.1
0.007
0.1
0.005
1.5
15.9
-0-
15.9
Total
17.4
12.3
13.4
10.1
••••^•.^••^•MMMBBHV
9.4
9.3
7.7
7.3
7.1
5.9
2.6
2.S
1.4
0.5
0.2
9.7
117.2
69.0
186.2
\
\
    * From thinning and cleaning up.
                                14-5

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VOC Content of Architectural .Coattogs




     Average VOC content and range of VOC content by volume for




various coating categories are listed in Table 2,  The average




VOC contents listed in Table 2 are weighted by sales in each




category.  The ranges given are the lowest and highest maximum




VOC content indicated on the returned questionnaires.




     Low-solvent coatings are essentially waterbome latex (or




emulsion) types, although water-dispersion type coatings, which




are partially soluble in water and organic solvent mixtures, are




not becoming commercially available.




     While latexes do contain some VOC, concentrations are usually




much less than in solvent-type coatings.  Average VOC concentrations




are eight percent by volume for latexes and 54 percent by volume for




solvent-borne coatings.




     From the returned questionnaires the staff was able to use the




sales data and the weighted average solvent content to assess the




emissions of VOC from each coating category.  The VOC content for




each coating category was calculated by multiplying the volume of




coatings sold by the average VOC content.  For each specific coating




category the total of these estimates yields the volume of VOC




released to the atmosphere.  The volume of emissions was converted




to weight by multiplying by the appropriate density  (6.5 pounds per




gallon for solvent used in solvent-borne coatings; 8.6 pounds per




gallon for solvents used in waterborne coatings).  The total weight
                               14-6

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               Table 2
  Average VOC Content and Range  of
VOC Content for Various  Architectural
         Coating Categories
Architectural
Coating
Category
Exterior Wall
Interior Wall
'Roof
Sash, Trim, and Trellis
Barn and Fence
Porch, Deck, and Floor
Mobil Home •
Traffic
Primers, Sealers and
Undercoaters
Stains
Clears
Metallic Pigmented
Aerosals
High Performance Primers
High Performance Topcoat
Not Classified
Overall Average
Average VOC (%)
Solvent
Borne
47
52
49 .
44
45
. 56
47
50
50
66
58
59
78
53
49
54
54
Mater
Borne
10
7
8
13
4
3


9
9


0


5
8
Range of VOC (%)
Solvent
Borne
17-66
30-75
33-80
17-75
26-68
48-83
35-71
25-76
20-92
50-95
35-95
43-80
48-99
36-94
49-90


Water
Borne
1-15
2-38
0-10
3-23
1-39
.3-5
.3-5
1.5-5
.1-32
2-36
2-77
1.4-74
—
3.6-17
1-36


                 14-7

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per year was converted to an average emission rate in tons per day




(TPD) based on 365 days per year.  The total VOC emissions from the




use of architectural coatings was determined to be 117 TPD in 1975




in California.




     VOC emissions from thinning and cleanup was accounted for based




on an average of one-half gallon of solvent per gallon of solvent-




borne coating (except aerosols, roof, and traffic coatings).  This




figure is derived from estimates obtained from the industry and from




local air pollution control districts.  Estimates from the industry




ranged from one gallon of thinner for each 10 gallons of coating to




one to one.  For traffic and roof coatings a ratio of one to five




was used because these coatings are typically applied in large




quantities, and their usage does not entail much solvent for




cleanup.  No solvent usage was assumed for cleanup and thinning of




aerosols.  The volume of solvents used for thinning and cleanup




in California totaled over seven million gallons in 1975 or 69 TPD.




Therefore, the total emission of VOC associated with the use of




architectural coatings in California was 186 tons per day in 1975.






Emission Factors




     Perhaps the most useful way of expressing findings in terms of




an emission factor is pounds of VOC emitted per capita.  Official




State of California Department of Finance figures indicate that the




state population as of January 1, 1975, was 21,030,245.  Based on




the 1975 data of VOC emissions of 186 tons per day, the California
                                14-8

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per capita emission factor for 1975 is therefore 6.5 pounds per

capita.

     Reasonably detailed emission inventories for emissions from

architectural coatings have been conducted in California by the

San Diego County and the San Francisco Bay Area Air Pollution

Control Districts (APCDs) for 1975 and 1976 respectively.  As can

be seen from Table 3 the results of the Bay Area APCD survey

compare favorably with the ARB survey.  The San Diego County APCD

survey is significantly different; no explanation of this

discrepancy could be found.


                            Table 3

  Comparison of Air Resources Board and San Diego and Bay Area
         Air Pollution Control Districts Inventories for
                      Architectural Coatings

Population*
Total VOC
Emission
(T/D)
Yearly Per
Capita
Emissions
(pounds)
APCD
ARB
APCD
ARB
Bay Area APCD
4,767,032
= 41
42.5
6.3
6.5
San Diego County APCD
1,541,500
17.8
13.7
8.4
6.5
* Bay Area Inventory conducted for 1976, San Diego Co, Inventory
  conducted for 1975,  Population figures from California Department
  of Finance, SB 90 population data.
                               14-9

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 Effect of ARB Model Rule on _Emisgign Factor




      As indicated earlier the Air Resources Board has developed a




 model regulation to control VOC emissions from the use of architectural




 coatings.  The regulation limits the VOC content of architectural




 coatings to 250 grams per liter of coating less water except that




 interior coatings are permitted to contain 350 grams per liter of




 container less water.  The following coatings are exempt until 1982:




 1.  Varnishes, lacquers, or shellacs;




 2.  Semitransparent stains;




 3.  Opaque stains on bare wood, cedar, fir, and mahogany;




 4.  Primers, sealers, and undercoaters;




 5.  Wood preservatives;




 6.  Fire retardant coatings;




 7.  Tile-like glaze coatings;




 8.  Waterproofing coatings;




 9.  Industrial maintenance finishes;




10.  Metallic pigmented coatings;




11.  Swimming pool coatings; and




12.  Graphic arts coatings.




      The emission reduction expected from the model rule is 53




 tons per day in 1978.  Potentially an emission reduction of 156




 tons per day can be achieved in 1982 if adequate substitutes are




 available for those coatings which are initially exempted.  These




 emission figures were derived based on the assumption that all




 solvent-borne coatings that are required to meet the model rule would
                               14-10

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be replaced by waterborne coatings of the same avenge VOC content




as those waterborne coatings now in use.  This assumption may be




conservative, because many waterborne coatings currently contain




more VOC than is allowed by the model rule.  Implementing the model




jrule wil}. bring about a reduction in the VOC content of waterborne




coatings and an accompanying reduction in emissions attributable




to such coatings.  Therefore, the net reduction in VOC emissions will




be greater than 53 tons per day, but exact figures cannot be




determined at this time.




     Based on a reduction of 53 tons per day, the total emissions




of VOC to the atmosphere in 1975 would have been 133 tons per day




instead of 186 tons per day if the model rule had been in effect.




Therefore, the emission factor if the ARB's model rule had been in




effect in 1975 would have been 4.6 pounds of VOC emitted per capita.






Summary




     The level of VOC emissions from architectural coatings can be




determined by using sales data or per capita emission factors.




     When sales data are known for a state or anyother geographical




area, the volume of solvent for each coating category can be calculated




by multiplying the volume of coatings sold by the average solvent




content.  For each specific coating category the total of these




estimates yields the volume of organic released to the atmosphere.




The volume of emissions can then be converted to weight by




multiplying by 6.5 pounds per gallon for the solvents used in
                               14-11

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solvent-borne coatings or 8.6 pounds per gallon for the solvents used




in waterborne coatings.  In addition, similar computations should




be made to estimate the VOC emissions from the solvents used for




thinning and cleanup, and these emissions should be added to the




emissions attributable to the coatings.




     Data compiled by the GARB indicate that in 1975 the VOC emissions




attributable to architectural coatings was 117 TPD, and the VOC




emissions from solvents used for thinning and cleanup was 69 TPD,




thereby giving a total of 186 TPD.  Had the model rule been in




effect, the total would have been 133 TPD.




     A quicker method, and one that works in the absence of sales




data, is to compile VOC emissions on a per capita basis.  According




to figures compiled by the CARS and San Francisco Bay Area APCD,




yearly per capita emissions from architectural coatings and the




solvents used for thinning and cleaning approximately 6.5 pounds per




capita without the model rule and 4.6 pounds with the model rule.




Multiplying the per capita figure by state or area population




will yield an annual emission amount that can be converted to TPD




by dividing by 365 (*g|} and 2000 founds).



     Either method will yield acceptable accuracy when computing




emissions of VOC associated with architectural coatings.

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NOX REDUCTIONS IN THE PORTLAND CEMENT INDUSTRY

        WITH CONVERSION TO COAL-FIRING
             Presented at the 1977
        Environmental Protection Agency
      Emission Inventory/Factor Workshop
Raleigh, North Carolina - September 13-15, 1977
                      By

           ROBERT J. HILOVSKY, P.E.
        Supervisor, Source Test Section
      Engineering Division, Eastern Zone
  South Coast Air Quality Management District
              Col ton, California
                     15-1

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Introduction
                            i
     The cement industry is one of the nation's most energy-
intensive industries - where more energy is consumed producing a
dollar's worth of product than for any other major product.  A
report issued by the Cost of Living Council in 1973 shows that
the energy cost for cement was 43 percent of the product.  This
figure has continued to rise with the increasing cost of fuel.
The cement plants of Southern California have used natural gas as
fuel, with oil as a standby energy source.  The high availability
of natural gas, ease of handling and its cheap cost compared to
other fuels were the major factors for continuing its use.  How-
ever, with the growing shortage of natural gas, estimates by the
California Public Utilities Commission that no gas supplies will
be available to major industries by 1980 and large price increases
(38 percent in 1975) for gas, the cement industry began conversion
to fuel oil and coal.
     The South Coast Air Quality Management District (SCAQMD) has
four cement companies (operating six different facilities) under
its jurisdiction.  All of these facilities are located in the
Eastern Zone of the District, with five plants in San Bernardino
County and one plant in Riverside County.  The SCAQMD was formed
on February 1, 1977, as a successor agency of the Southern
California APCD.  That APCD, in turn, had been formed on
                               15-2

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July 1, 1975, from the Los Angeles, Orange, Riverside and San
Bernardino County APCD's.  All data referenced in this report was
collected by the same group of personnel - although the organiza-
tion changed names.
Background
     The San Bernardino County APCD began source testing for NOx
emissions in 1969-70 for all industries in the county for both
compliance and emission inventory information.  The larger indus-
tries in the county were also tested on an annual basis, begin-
ning in 1972.  Variations in NOx emissions from one facility
were observed, but investigation as to the cause was not pursued
at that time.  The emission inventories showed that the cement
industry comparatively was a very large NOx emitter (Table I)
in San Bernardino County.
                              15-3

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                             TABLE I

                       NOX Emissions from
               San Bernardino County Cement Plants
                                                   NOx Emissions
               Facility                             (Tons/Day)*

California Portland Cement Co., Col ton                 19.10
Riverside Cement Co., Oro Grande                       25.66
Kaiser Cement & Gypsum Corp., Lucerne Valley           20.42
Southwestern Portland Cement Co., Victorville           7.0
Southwestern Portland Cement Co., Black Mountain       13.44

                                           TOTAL       85.62

*Based on an average rate of 80% production, natural gas for fuel
 NOx is reported as N02-
Fuel Changes and Effects Upon Pollutants

     Riverside Cement Company and California Portland Cement

Company filed applications in 1974 with the District to convert

their rotary kilns to coal-firing.  Review of these applications,

in considering the possible changes in emissions, led to the

analysis of the data collected from source tests on cement kilns.

Analysis of these data revealed:

     (1) The sulfur in the fuel oil was absorbed in the
         clinker manufacturing process (as sulfates or
         sulfides) and only very small amounts of sulfur
         dioxide would be emitted to the atmosphere.  It
         was expected, therefore, that the sulfur in the
         coal also would be absorbed and would not cause
         any violation (500 ppm limit) of the District's
         S02 rules.
                              15-4

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     (2) Existing air pollution control  equipment could
         adequately control  any increase in particulate
         matter expected from coal  use.
     (3) The use of fuel oil  showed a reduction in NOx
         emissions, compared to NOx from natural  gas.
     It is believed that when burning fuel  oil  in the cement kiln
that it can more readily be burned with a flame that is less
oxidizing than the flame resulting from natural gas combustion.
(It would appear to be a "lazy" flame pattern when viewed through
flame ports.)  With these differences in the kinetics of combus-
tion in the kiln, the result is lower NOx generation when burning
fuel oil in the cement kiln - compared to natural gas.  The use
of coal for fuel should result in an even further reduction of
NOx emissions since it typically produces a longer, "lazier"
flame (with lower temperature in the center of the flame) than
does fuel oil combustion in the cement kiln.  In reviewing appli-
cations from the cement plants, the "Permits to Construct" were
approved since it was calculated that an overall reduction in
emissions into our air basin would occur.
     The conversion to coal was completed by November 1974 for
the Riverside Cement Company and by May 1975 for the California
Portland Cement Company.  Southwestern Portland Cement Company
and Kaiser Cement & Gypsum Corporation switched over from
                              15-5

-------
natural gas to fuel oil combustion in 1976.  Source testing of
these units has indicated that a substantial reduction occurred
in NOx emissions into the atmosphere.
                            TABLE II
                 NOx Reductions in Cement Kilns
                       Due to Fuel Changes
FACILITY
California Portland Cement
Riverside Cement
kaiser Cement & Gypsum
Southwestern Portland Cement
(Victorville)
Southwestern Portland Cement
(Black Mountain)
- TOTAL
NOX EMISSIONS^1)
(TONS/DAY)
Gas
19.10
25.66
20.42

7.0

13.44
85.62
Oil Coal
4.58<2) 3.50
	 7.75
15.46 	

4.30 	

12.06 	
43.07
PERCENT
REDUCTION
76^^/81.7
69.7
24.2

38.2

10.2
49.7
 U)Based on 80% production rate.   NOx  is measured as  N02-
       used at this facility since conversion  to coal.
                               15-6

-------
     Table II shows that larger reductions in N02 emissions are
accomplished with conversion to coal-firing versus oil-firing.
With the growing scarcity of petroleum products, there would be
more advantages in the long run for cement plants to convert to
coal-firing (directly from natural gas) rather than to oil-firing;
even though a conversion to oil-firing would somewhat reduce NOx
emissions into the atmosphere.  Kaiser Cement & Gypsum Corporation
has filed an application for coal  conversion with the District,
and Southwestern Portland Cement Company has approved funds for
coal conversion.
Test Methods and Procedures
     Two test methods were used in obtaining the data (Appendix A)
presented in this report.  The Phenoldisulfonic Acid (PDS) method,
which is the approved California Air Resources Board and U. S.
Environmental Protection Agency reference method, was used along
with a continuous electrochemical cell analyzer (Envirometrics)
and recorder.  Both methods well complimented each other although
the analyzer was not obtained until 1972.  Some early PDS data
was considered invalidated when it was indicated that NOx concen-
trations were over 1,000 ppm.  For NOx values near or over 1,000
ppm, the chemist performing the PDS analysis must be aware of the
                              15-7

-------
potentially high concentration so proper steps in the preparation
of aliquot portions can be taken to assure accuracy in the analy-
sis.
     The continuous analyzer revealed variations in emissions
throughout the process operations (Figure 1).  For example, the
concentration range for one test was 950 to 1,650 ppm NOx, with
an-average of 1,490 ppm.  For this example, the PDS values could
vary greatly depending upon when the "grab sample" was taken,
with respect to hitting "peaks" or "valleys" in the NOx versus
time curve.
Emission Factors
     The five plants tested have different configurations of ex-
haust gas ducting and different types of control systems.  This
resulted in different excess-air concentrations for each test
site.  To obtain a correlation of NOx emissions into the atmos-
phere, emission factors were generated.  These are listed in
Tables III, IV and V and divided into categories dependent upon
(1) fuel use, (2) type of process and (3) production rate.
                               15-8

-------
Conclusions and Recommendations

     Table VI is a summary of the emission factors generated, and

Figures 2, 3 and 4 are plots of the emission factors versus kiln

capacity.  The following conclusions are indicated from this data:

     (1) Emission factors vary greatly depending upon fuel,
         type of process and kiln size.
     (2) There is a significant reduction in N02 emissions
         when either oil  or coal  is used for fuel,  versus
         natural gas.  It appears that greater reductions
         in emissions are available for coal-firing versus
         oil-firing (Table II).
     (3) The emission factors for wet-process operations
         tend to be lower than for those with dry-process
         operations (Table VI).
     (4) As the capacity of the kiln increases, the emission
         factor decreases for dry-process operations (Figures
         2 and 3) while the reverse is indicated for wet-
         process operations (Figures 2 and 4).   There can,
         however, be a larger NOx variation between kilns
         of the same size - especially the smaller units
         (Figures 2 and 3).
     (5) The emission factor and NOx reduction from natural
         gas-firing versus oil-firing,  for dry-process kilns
         of 100,000 Ibs/hr of clinker,  were much greater
         than for a 175,000 Ibs/hr kiln (respectively 4.58
         Ibs/ton and 76% reduction versus 12.06 Ibs/ton and
         10.2% reduction).
     (6) The NOx emission factors depend upon a number of
         variables, and the use of only one factor should
         be discouraged in estimating NOx emissions from
         cement kilns.
                              15-9

-------
     Some of the more important variables have been covered in
this paper although other factors, such as diameter of kiln,
length of fire zone and dwell-time before emitting into the atmos-
phere, should be investigated  before developing a family of curves
for cement kiln NOx emission factors.
                              15-10

-------
                           TABLE III

               Emission Factors for Cement Kilns
                       Using Natural Gas
Kiln
Raw Material Feed
(1,000 Ibs/hr)
Dry Process Units*
RC1
RC2
RC3
RC4
RC5
RC6
CP1
CP2
BM
BM
64
64
64
64
64
65.7
161
161
264
240
Wet Process Units
SW5
SW6

SW7

SW8

SW9

KC1
KC2
KC3

29
39
49
40
50
38
46
40
41
92.4
92.4
184
184
Emission Factor (Ibs.
Raw Material Feed |

14.3
13.9
12.6
13.7
12.5
15.8
13.6
11.9
10.9
11.7

18.7
3.9
9.5
3.3
5.2
5.6
6.5
8.3
15.3
3.2
4.1
6.6
6.0
NOx/tonl
Clinker

22.4
21.8
19.7
21.4
19.6
24.7
20.5
18.7
16.9
18.1

28.9
6.1
14.6
5.1
8.1
8.6
10.0
12.7
23.6
5.0
6.4
10.3
9.4
*RC = Riverside Cement, Oro Grande;  CP = California Portland
 Cement, Col ton; BM = Southwestern Portland Cement, Black
 Mountain; SW = Southwestern Portland Cement, Victorville;
 KC = Kaiser Cement & Gypsum, Lucerne Valley
                             15-11

-------
            TABLE IV

Emission Factors for Cement Kilns
         Using Fuel Oil
Kiln
Raw Material Feed
(1,000 Ibs/hr)
Dry Process Units
CP1

CP2

BM
168
168
168
168
240
Wet Process Units
SW7
SW8
SW9
KC1

KC2

KC3
49
49
41
92
92
92
92
184
Emission Factor (Ibs.
Raw Material Feed I

1.6
4.1
2.9
2.8
10.5

3.7
7.9
2.3
2.8
2.9
3.0
3.1
5.1
NOx/ton)
Clinker

2.6
6.9
4.9
4.6
16.1

5.7
12.2
3.5
4.4
4.5
4.7
4.8
7.9
              15-12

-------
             TABLE V

Emission Factors for Cement Kilns
           Using Coal
Kiln
Raw Material Feed
(1,000 Ibs/hr)
Dry Process Units
RC2

RC3

RC4

RC5

RC6
CP1

CP2

64
64
64
64
64
64
64
64
65.7
161
171
159
157
Emission Factor (Ibs.
Raw Material Feed [

1.4
3.6
4.4
4.9
5.4
5.6
6.2
6.2
4.1
2.0
2.9
2.4
1.9
NOx/ton)
Clinker

2.2
5.7
6.9
7.6
8.5
8.6
9.7
9.6
6.4
3.3
4.7
3.7
3.1
              15-13

-------
                         TABLE VI

              Summary of N02 Emission Factors
        for Cement Kilns (Ibs. NOx/ton of Clinker)
               Type  of
         Cement-Manufacturi ng
Fuel     	Process                Range        Average

Gas               Dry             16.9 to 24.7       20.4
Gas               Wet              5.0 to 28.9       11.5
Oil               Dry               2.6 to 16.1        7.0
Oil               Wet               3.5 to 12.2        5.9
Coal              Dry               2.2 to 9.7         6.2
                          15-14

-------
       APPENDIX A





TEST DATA USED FOR REPORT
          15-15

-------
Capacity Test
Unit Bbl/day Date
Dry Process
CP1 6,500 12/28/76
6/15/76
10/12/73
1/28/70
4/28/70
? CP2 6,500 12/28/76
t—
O\
6/15/76
10/12/73
4/28/70
1/28/70
Raw Material
Ibs/hr
151,000
(+ 20,400 coal)
161,000

168,000

159,000
157,780

168,000

Clinker
Production
Tons/hr Fuel
50 Coal
50 Coal
Gas
Oil
Oil
50 Petroleum
Coke & Oil
49 Coal
Gas
Oil
Oil
Emission Factor
Flowrate
DSCFM
138,555
150,000
140,500
127,900
127,900
139,597
135,000
146,600
188,041
188,000
N02 Emi
PPM |
220
150
1,000
142
372
183
157
880
178
169
ssions
Ibs/hr
221.9
165.1
1,023.2
132.3
346.5
186.0
154.7
939.4
243.7
231.4
Raw Material
(Ibs/ton)
2.94
(2.6)
2.0
13.5
1.6
4.1
2.4
1.96
11.9
2.9
2.8
Clinker
4.7
(4.2)
3.3
20.5
2.6
6.9
3.7
3.1
18.7
4.9
4.6

-------
                                                                                                              Emission Factor
I
I—I
•VJ
Capacity
Unit Bbl/day
Wet Process

KC1 4,000



KC2 4,000



KC3 8,000



Test
Date


3/5/76

5/2/72

12/14/76

5/2/72

12/16/76

10/15/73
5/2/72
Raw Material
Ibs/hr


136,400

142,588

136,137

142,588

273,100

292,786
276,255


Solids
(92,300)


Solids
(92,300)


Solids
(184,615)



Fuel


Oil
Oil
Gas

Oil

Gas

Oil

Gas
Gas
Flowrate
DSCFM


77,939
78,630
60,933

57,100
57,012
55,185

119,072
108,443
99,600
90,973
N02 Emissions
PPM 1


493
503
770

710
780
1,082

1,180

2,000
1,880
Ibs/hr


279.8
288.0
341.7

294.9
324.0
434.3

1,023.0

1,450.6
1,245.5
Raw Material
(Ibs/ton)


4.1 (2.8)*
4.3
4.8

4.4 (3.0)*
4.8
6.1

7.5 (5.1)*

9.9 (6.6)*
9.0 (6.0)*
Clinker


6.4
6.7
7.5


7.5
9.5

11.69

15.4
14.0
      *Raw material  feed of dry product excluding water

-------
Capaci ty
Unit Bbl/day
Dry Process
RC1 2,600
RC2 2,600
RC3 2,600
•— >
£ RC4 2,600
oo
RC5 2,600
RC6 3,000
3,000
Test Raw Material
Date Ibs/hr
3/19/74
5/25/76 64,000
3/19/74
5/25/76 64,000
3/19/74
5/25/76 64,000
3/19/74
5/25/76 64,000
3/19/74
11/12/75 63,000
7/28/74 65,700
Clinker
Production
Tons/hr Fuel
Gas
20.51 Coal
Coal
Gas
20.51 Coal
Coal
Gas
20.51 Coal
Coal
Gas
20.51 Coal
Coal
Gas
20.19 Coal
21.05 Gas
Emission Factor
Flowrate
DSCFM
48,917
45,990
44,478
44,478
46,520
40,295
40,295
59,940
^59,000
^44,000
58,794
58,800
•»- 48,900
44,462
36,710
17,997
N02 Emissions
PPM I
1,288
135
360
1,382
(1,050-1,640)
417
535
1,380
(990-1,520)
398
170
1,375
(1,160-1,400)
465
460
1,128
(920-1,200)
400
1,158
1,609
Ibs/hr
458.6
45.2
116.6
447.6
141.2
156.9
404.9
173.7
73.0
440.0
199.1
196.9
401.6
129.5
520.4
Raw Material
(Ibs/ton)
14.3
1.4
3.6
13.9
4.4
4.9
12.6
5.4
5.6
13.7
6.2
6.2
12.5
4.1
15.8
Clinker
22.4
2.2
5.7
21.8
6.9
7.6
19.7
8.5
8.6
21.4
9.7
9.6
19.6
6.4
24.7

-------
Capacity Test
Unit Bbl/day Date
Solids - Wet Process
SU5 1,300 4/26/74
SW6 2,200 3/21/74
5/12/70
SW7 2,200 5/12/70
b/1/70
4/29/76
K SW3 2,200 5/12/70
,1 3/21/74
* 4/29/76
SW9 2,200 3/21/74
4/29/76
6/11/75
Dry Process
Blk 9,500 7/12/74
Mtn 0/11/75
4/30/76
Raw Material
Ibs/hr
29,150
49,300
39,720
40,610
50,240
49,318
38,610
46,200
49,641
40,400
41,603
41,600
264,000
240,000
240,000
Clinker
Production
Tons/hr
9.5
16.0
12.9
13.1
16.2
16.0
12.5
15.0
16.1
13.1
13.5
13.5
85.3
77.5
77.9
Emission Factor
Fuel
Gas
Gas
Gas
Gas
Gas
Oil
Gas
Gas
Oil
Gas
Oil
Gas
Gas
Gas
Oil
Flowrate
DSCFM
25,319
38,373
29,681
30,948
42,821
38,240
27,747
32,500
40,900
36,333
37,459
36,200
86,340
86,340
86,340
N02 Emissions
PPM |
1,490
(950-1,650)
836
(700-900)
362
297
420
330
535
636
659
631
179
1,212
2,300
2,230
2,000
Ibs/hr
274.7
233.6
78.2
66.9
130.9
91.9
108.1
150.4
196.3
166.9
48.8
319.4
1,445.6
1,401.6
1,257.1
Raw Material
(Ibs/ton)
18.7
9.5
3.9
3.3
5.2
3.7
5.6
6.5
7.9
8.3
2.3
15.3
10.95
11.68
10.47
Clinker
28.9
14.6
6.1
5.1
8.1
5.7
8.6
10.0
12.2
12.7
3.5
23.6
16.9
18.1
16.1

-------
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QUESTION:
HILOVSKY:
QUESTION:
HILOVSKY:
QUESTION:
HILOVSKY:
CONDENSED DISCUSSION
 What is  the difference in tests on kilns
 using natural gas and coal as fuel?
 There is no  difference in running coal
 versus natural gas.  The dust loading from
 the cement process is so high that actually
 the ashes absorb in the cement.  It actually
 makes a better cement product.
 Do the production rates change when you change
 fuels?  What are the heat release rate differ-
 ences?
 Let's  see if I can go back to the charts.
 There is a slight change in the total raw
 materials going in.  On gas they were running
 around 161 thousand pounds of raw material in
 that particular kiln.  They are running 151
 thousand pounds of raw material on 20 thou-
 sand pounds of coal.  Approximately the same
 out-put.  Still 15 tons per kiln.
 When were these tests run?
 All the way from '69 through two or three
 weeks ago.  I might say that we run, or we
 have had a  policy  of testing all of our
 large companies at least on an annual basis
                               15-25

-------
QUESTION:
HILOVSKY:
QUESTION:
HILOVSKY:
and sometimes two times a year depending upon
how good they have been in terms of compliance.
We have more test on this one in the south
coast basin because  it's closer to us and we
have done some research work with them.  We
have tested our instruments there and a few
other things.
Do you have a significant amount  of carbon
monoxide fluctuation?
We have been taking samples and didn't notice
any significant difference.  I don't have that
with my data here, but when we go out and
sample, we take everything.  We take carbon
monoxide, S02, and NO  and particulate matter
all at the same time.
Do you have a wet process estimate?
There is no  wet process on coal yet.  One of
the companies running a wet process has the
application already approved to construct
coal handling facilities.  At present though,
it is not in  business.
                               15-26

-------
   CURRENT API EMISSION MEASUREMENT PROGRAMS
             Presented at the 1977
        Environmental Protection Agency
      Emission Inventory/Factor Workshop
Raleigh, North Carolina - September 13-15, 1977
                      By

                 J. G. Zabaga
              Associate Engineer
   Mobil Research & Development Corporation
         Princeton, New Jersey  08540
                      16-1

-------
Introduction



     My name is J. G. Zabaga.  I represent the



American Petroleum Institute, and specifically, the



Committee on Evaporation Loss Measurement (CELM).  I



am the Chairman of CELM.



     A great deal of current interest is being focused



on the evaporation loss bulletins that have been



published by the American Petroleum Institute over a



period of years.  Publication of the bulletins preceded



the Clean Air Act Amendments of 1970, and it has now



become clear that both industry and regulators need



updated emissions data to properly respond to the Act.



     To start, I would like to review the function of



the Committee on Evaporation Loss Measurement.  Figure



1 shows the organizational structure of the American



Petroleum Institute  (API).  There are a number of



technically oriented departments, one of which is



Non-Departmental/Industry Affairs.  Within that



Department, as shown in Figure 2, is the Committee on



Petroleum Measurement  (COPM), a free-standing API-



based committee.  Titles of the standing committees



describe, in general, the scope of the Committee's



responsibilities, all ultimately resulting in the es-



tablishment of standards  for measurements of all types
                            16-2

-------
of petroleum products throughout the industry.  This
includes production, refining, distribution and
marketing activities.
     The CELM is one of COPM's standing committees.
CELM deals only with the measurement of evaporation
loss, which is quite different from the finite measure-
ment considerations of the other committees in
developing standards for inventory control or custody
transfer.
     Figure 3 lists the publications of the CELM that
were developed over a 12-year period from 1957-1969.
These bulletins were the first industry-published data
on quantifying evaporation loss of hydrocarbon liquids,
and they have been widely accepted.  To this day they
remain, or are the basis for, virtually all data
sources dealing with hydrocarbon evaporation loss.
The several editions of the EPA's AP-42 Compilation of
Air Pollution Control Factors, have emission factors
derived from these bulletins.
     It is important to realize that all of the
bulletins were published prior to the U. S. Clean Air
Act and do not necessarily comprehend the accuracy
levels required by the Act.  In fact, the bulletins
were originally developed to enable oil company
                           16-3

-------
operating divisions to prepare cost benefit studies



for evaluation of alternative conservation techniques.



When the data and estimating methods became one of the



tools used by regulators for control strategies,



industry requested that API review the content of all



of the bulletins for suitability in this new application,



     Figure 4 shows the present organization of CELM,



including active subcommittees.  Figure 5 is a pictorial



view of the equipment involved within each subcom-



mittee 's responsibility-  The five subcommittees and



any ad hoc task groups are staffed by 31 members, 21



from oil companies and 10 from supplier companies.



     Referring to Figure 5, the petroleum liquids of



concern to the Committee, and the basic equipment and



handling characteristics are as follows:



     1)  Open top floating-roof tanks have been in



         use since 1880 and in their present form



         since 1923.  The concept is to curtail



         evaporation by floating a disc, the movable



         roof, in the liquid.  Under certain



         conditions, some emissions result from the



         perimeter sealing ring area.  Floating-roof



         tanks are usually used for liquids with



         storage vapor pressures between about 1.5
                           16-4

-------
    to 11 psia i.e., motor and aviation gasolines,



    and some crude oils.



2)   Internal floating covers or covered floating-



    roof tanks are a logical combination of open



    top and fixed-roof tanks, providing weather



    protection to the roof and contents, and



    evaporation control by use of a floating



    deck.  Liquids generally stored are the same



    as open top floating-roof tanks.



3)   Fixed-roof tanks have been used for many years



    to store all types of petroleum.  Recognition



    by industry that product could be conserved



    by use of one of the floating-roof systems.-



    and later, regulations to limit use to liquids



    with less than 1.5 psia storage vapor pressure,



    have generally restricted use of fixed-roof



    .feanks to low volatility liquids, i.e.,



    distillates, residuals and some crude oils.



4)   Tank truck and tank car considerations are



    confined primarily to motor gasolines.  Some



    crude oil and other finished product are also



    transported by these means.  The method of



    loading is apparently the feature most
                      16-5

-------
         affecting evaporation loss.



     5)   Marine vessels transport crude oils and all



         types of finished product.  The depth of the



         loaded compartment is a major factor affecting



         evaporation loss as we will see later.



     When evaporation loss data were developed by the



original committee, the resulting bulletins were not



intended for use as a means to determine emission



factors for conducting emissions inventories nor for the



evaluation of regulatory strategies.  Their use for



such purposes may be both, impractical and improper.



The subcommittees that developed:and/or subsequently



revised the bulletins recognized that the estimating



methodology and data had precision appropriate only



for comparative correlations among varying hardware



designs and different hydrocarbon liquids.  The



estimating techniques in the bulletins were/ for the



most part, originally developed and standardized from



data collected in the period 1930-1950.  Within the



specific purposes of allowing the industry to evaluate



on a cost/benefit basis, with a limited precision,



alternative vapor conservation devices, these



techniques were entirely adequate.  However, the



techniques are not satisfactory in a regulatory
                           16-6

-------
climate demanding data that comprehends technical
advancements in both testing methods and equipment
design.
     In most applications, the present bulletins have
been found to overstate losses when compared to new,
detailed tests.  This will be amplified in the
discussions that follow.  I do want to emphasize now
that the API Committee on Evaporation Loss Measurement,
consistent with current Institute policy and direction,
is charged with regularly revising its publications
to incorporate technological improvements in the state
of the art on vessel and hardware design, and testing
methods.
Marine Terminal Emissions
     In 1976, CELM updated Bulletin 2514A, Hydrocarbon
Emissions from Marine Vessel Loading of Gasolines.
A small but important point in the bulletin title is
the use of the term emissions.  API distinguishes
between the terms evaporation loss and emissions.  The
industry has traditionally required loss data
expressed as a volumetric change, i.e., barrels per
year, for use in inventory control.  This volume
change is defined as evaporation loss.  Regulators are
properly interested in mass quantity of hydrocarbon
                          16-7

-------
released per unit of time, i.e.,  pounds per day; this



is defined as emissions.  API bulletins published



subsequent to 1976 will include factors for both



purposes.



     Figure 6 shows a summary of emission factors from



83 tests performed by four companies loading motor



gasoline into ships and barges.  These factors average



about 40 percent of previously published data.  The



chart format also suggests the parameters that were



found to dominate the evaporation phenomena.  Filling



a container with petroleum product produces emissions



by displacement of the existing vapor space.  The



hydrocarbon concentration in the vessel vapor space



was found to consist of two distinct components:



vapors that existed before loading started - the



arrival vapors, and vapors generated by the loading



operation.  Figure 7 depicts this phenomenon.  Arrival



vapors in ships were found to be quite lean, averaging



about two to seven percent hydrocarbon, while the



average hydrocarbon content of emitted vapors for the



entire loading sequence was only five to 11 percent.



     The generated vapors form a rich blanket, about



four to eight feet deep, that floats on the liquid



level in the arrival vapors.  Tankers have compartments
                           16-8

-------
typically 50 to 60 feet deep.  Loading terminates
within a few feet of the deck.  Therefore, displaced
vapors reflect about 45 feet of arrival vapors and two
to six feet of the rich blanket.
     Barge loading is similar to tanker loading except
that the shallow compartment depths, about 12 feet,
permit more of the rich blanket to escape.  The emission
profile is similar, with slightly higher hydrocarbon
levels, but still lower than previously anticipated.
     The concentration of arrival hydrocarbons reflects
the history of each vessel compartment since the
previous unloading.  Low levels generally indicate that
the compartment was cleaned on the return voyage,
perhaps to accommodate an unleaded gasoline in a
compartment that previously held leaded product, to
switch to heating oil from gasoline service, or indirect
cleaning by ballasting the compartment for navigational
reasons.  For any specific marine terminal, the
percentage of compartments that arrive clean annually
can be determined by analysis of ships Togs and
terminal records.  With this information the factors in
Figure 6 can be used with confidence in predicting
emission levels when loading motor gasolines.
     Other factors are still required for loading crude
                           16-9

-------
oils and for emissions resulting from water ballasting



of vessels after unloading either gasoline or crude.



     The Western Oil and Gas Association has just



completed a test program on loading California crudes



and will publish a report shortly.  Preliminary test



results indicate phenomena similar to gasoline loading,



with emission factors generally lower than gasoline.



Also, eight oil companies, acting in response to an



EPA 114A letter, have started a joint program to



develop new data on ballasting emissions, plus any



information necessary to fill gaps in the previously



described API and WOGA studies.  Correlation of all of



these efforts should provide the data base necessary



for publication of new, comprehensive marine terminal



emission factors by mid-1978.



Floating-Roof Tanks



     Emissions from floating-roof tanks have been



under intensive investigation since last summer.  While



much of the data in the original API Bulletin  (2517)



was about 40 years old, the relatively slow evaporation



rate from floating-roof tank seals and the difficulty



in measuring the evaporation loss have generally



frustrated any new in-depth studies.



     Figure 8 depicts a floating-roof tank and the
                           16-10

-------
perimeter seal area through which losses occur.  The
amount of evaporation occurring in a reasonable amount
of time, say several months with the tank dormant, is
too small to detect reliably with conventional
measuring techniques.
     Two methods have been used within the last year in
an attempt to overcome this problem.  As shown in the
figure, a field tank with product in it is taken out of
active service and permitted to weather.  Separate
testing has established that any evaporation due to
tank wall wetting as the roof descends in normal
operations is insignificant.  Therefore, any emissions
are those that result from loss of lighter gasoline
components through the seal area.  Further, tests have
also shown that natural convective mixing maintains
a homogeneous liquid in the tank.  This establishes the
format for one test approach.  Periodic samples are
taken and the density of the bulk liquid remaining is
determined with an extremely precise densitometer.
Sensitivity is required, in grams per millilitre, to
five decimal places.  Establishing a time rate of
density increase (increase due to loss of the lighter
components) permits calculation of decrease in bulk
volume.
                          16-11

-------
     A test program, using the density change method



and involving 13 gasoline tanks, was completed in



January by the Western Oil and Gas Association.



Average evaporation loss was about half of previously



published values.



     A second test program, also completed recently,



was conducted by Chicago Bridge and Iron Company and



Standard Oil of Ohio.  Here a 20 foot covered pilot



tank, designed to simulate climatic and product



variables, was used to capture and account for all



hydrocarbon losses.  This was a unique and pioneering



effort.  Being capable of isolating individual



variables, the study program developed a clearer



understanding of the significance of the parameters



affecting evaporation.  Wind in particular was



determined to play a dominant role in the evaporation



process.  The test program was designed for a specific



client's application, and within that framework -



the latest in tank and seal technology for storage of



crude oil - indicates emission levels at about 10 to



20 percent of previously published values.



     These programs cannot be extrapolated to a data



base adequate to provide a comprehensive emission



predicting method for all types of floating-roof tanks
                           16-12

-------
in all geographical and service conditions.  CELM has



started a program to complement, correlate and conclude



the two efforts just described and to develop new



bulletins 2517, Evaporation Loss from Floating-Roof



Tanks, and 2519, Use of Internal Floating Covers and



Covered Floating Roofs to Reduce Evaporation Loss,



applicable to any open top or covered floating-roof



tank.  That work is scheduled for completion by early



1979.



Fixed-Roof Tanks



     Current correlations for fixed-roof tanks are



confined to products with a vapor pressure greater than



two psia, and due to a limited data base, to tanks with



diameters less than about 150 feet.  Therefore, some



crude oils, residuals and distillates stored in larger



modern tanks are excluded.  It is desireable to



establish emission levels for these products.  The



Western Oil and Gas Association has just completed a



46-tank test program on crude and distillate liquids



that provide some new data on emission levels.  The



study demonstrates the apparent significance of the



way a tank is operated, e.g., continuous in-out flow,



fast filling and-slow emptying, etc., and the



importance of vapor pressure on loss, and generalizes
                          16-13

-------
that emission levels are about half of API 2518
estimates.  This agrees roughly with work done last
year in Germany indicating that filling losses are 88
percent and breathing losses 11 percent of API 2518
estimates.  However, no new emission formulae were
developed by either program.
     Two API committees, including CELM, are advancing
a joint program, building on these recent studies, to
produce a new comprehensive prediction method
applicable to all service conditions.  A revised
Bulletin  2518, Evaporation Loss from Fixed-roof Tanks,
is planned for publication in 1978.
Truck and Tank Car Emissions
     Emissions from these mobile sources are the  final
area of CELM's immediate concern.  Advancements in
loading methods, e.g., bottom filling vs. submerged
fill pipes or splash loading, and the effect of vapor
recovery  units must be evaluated.  The effects of
Stage 1 service station return vapors will also affect
evaporation loss.  Much information on these items has
already been collected by industry and regulators.
Emission  levels calculated by Bulletin 2514 again
appear to be overstated, particularly for the
increasingly popular bottom loading.  Bottom loading
                           16-14

-------
was not common when Bulletin 2514 was published in 1959.



The industry has traditionally used correlations for



the apparently similar submerged loading which have



been found to produce emission estimates about one-



third higher than the current testing of bottom



loading systems indicates.



     CELM is analyzing the latest test data to verify



its adequacy for new vehicle loading correlations.



Any additional testing required to ensure a comprehen-



sive data base should be completed this year.  A



totally re-written Bulletin 2514B is scheduled for



publication in early 1978.



Summary



     The CELM organization chart in Figure 9 shows



the major areas of evaporation loss activity of



immediate concern to regulators and industry-



     The existing evaporation loss bulletins, originally



prepared for economic comparisons, have been shown to



generally overstate emissions, restricting their proper



use to industry and for control strategies.  All of



the pertinent bulletins are in some stage of updating,



with publication schedules being expedited to make



the new information available as soon as possible.



These programs are expensive and extensive.  Total
                         16-15

-------
cost of testing will approach $2 million.  During the



data accumulation period, cooperation by industry and



government will be required to ensure a comprehensive



data bank satisfactory to each-
                         16-16

-------
An'if;iirini Petroleum Institute
      MAI 1  OUGANIZATION
                                                         ASST. TO EXECUTIVE
                                                          VICE PRESU1CNT   I
SENIOR AOVIXOH,
LABOR RELATIONS
MM Hntock


iiiiii.cr-.ii-. of
MA.'MOl'Ml'NI
AMI DUUC.ni
" " Will. I-'.
U Ki'i.li-
GOVT. AFFAIRS
•«•

VICE PRESIDENT
S. P.
Pottor

FEDERAL RELATIONS
C. E. Sandier
TAXATION
T. A. Mllrlin

STATE RELATIONS
F J. Jandrowitz

1
CENTRAL REGION
E. H. Slcarns


EASTERN


REGION
N C L Brown
1
II Mo
Ind Nob
lo NO
Kins SO
Mich Wise
M-nn


Ct Mass Pa
Del NH Rl
NJ VI
Mo NY Va
Md On VWo





1
SOUTHERN REGION
W. S. Haga

J
	 1

1
Ala Ga NC
AiK Ky SC
Fla Miss Tcnn
+
VICE PRESIDENT
C 1 Sawyer

EXPLORATION
AFFAIRS
W. M U.'J
MMIKI.IING
Q W Cycil

ni.l'INING
n. M. wnfliu

V. K Leonard
PRODUCTION
R. F. Cartoon

NCN-Di PAOTMENTAL
W. N lii-vs.irrt


—

—

                                                     VICE PRESIDENT
                                                      D. B. Ha'.hbun
                                                     ENVIRONMENTAL
                                                       AFFAIRS
                                                      A. £
                                                    FEOLRAL AGENCIES
                                                      A. I) Mooro
                                                     FINANCE AND
                                                     ACCOUNTING
                                                      H H, Slowafl
                                                   MED. & CIO. SCIENCE

                                                      N. K. Weaver
                                                     FIRE & SAFETY
                                                     COORDINATION
                                                      j 0. Mannjy
                                                     POLICY ANALYSIS

                                                       0. T. Palton
             Figure   1
                                                                                            SEPT 1977

-------
                                                             API COMMITTEE ON PETROLEUM MEASUREMENT
                                                                                   MAY 31,197?
                                                                                COMMITTEE ON
                                                                          PETROLEUM MEASUREMENT
                                                                                    CHAIRMAN
                                                                                 fl.A HAHTMANN
                                                API BOARD COMMITTEE ON
                                                   PUBUC ISSUES
                                                     CONTACT
                                                     R THOMAS
API NON DEPARTMENTAL
WDUSTRY AFFAIRS STAFF
    HW. SEW/WO
    M. WALTERS
                                        STANDARDIZATION

                                           VICE-CHAIRMAN
                                           B.MESSER.JR
         SPECIAL PROJECTS
            VICE-CHAIRMAN
             AE aflvscw
00


COMMITTEE ON
STATIC
MEASUREMENT
CHAIRMAN
U. HILLBURN


S/C ON NBS
PHYSICAL PROP.
DATA PROJECT
CHARMAN
RMECKEfl





COMMnTEE ON
DYNAMIC
MEASUREMENT
CHAIRMAN
EAfcAlUSTEH


API/ISO/OIML
S/C ON PS.5
CHAIRMAN





COMMITTEE ON
NATURAL GAS
FLUIDS
MEASUREMENT
CHAIRMAN
0. KEMP

*
S/CONAGA3
ORIFICE METER
PROJECT
CHAIRMAN
e.BUXTON
/
\

X
"N
COMMITTEE ON
EVAPORATION
LOSS
MEASUREMENT
CHAIRMAN
J.ZABABA
\L
^
**
S/C ON DATA
FLOATING
ROOF TANKS
CHAIRMAN
a GOOD
                                                                                            COMMITTEE ON
                                                                                             MARINE LOSS
                                                                                              CONTROL
                                                                                               CHAIRMAN
                                                                                              A. GRIFFITH
COMMITTEE ON
  PERSONNEL
   TRAINING
   CHAIRMAN
   Fl. BOYLE
                                                                                                      ADVISOR TO US
                                                                                                        A/COIML

                                                                                                         Ml. HALL
COMMITTEE ON
  US. INT1.
   TRADE
 COMMISSION

   CHAIRMAN
  LOOOGION
 TASK GROUP
ON LONG RANGE
   PLANNING
   CHAIRMAN
    K. BAILEY
          ADVISOR TO API
              METRIC
            TRANSITION
            COMMfTTEE
          COMMITTEE ON
            PROGRAM
           AND AWARDS
            CHAIRMAN
           MMOASSIFED RESEARCH PROJECT MANAGEMENT OROUP
          * *UNCLASSIHED fCSEARCH PROPOSAL GROUP

-------
                       API EVAPORATION LOSS  BULLETINS

           API BULLETIN 2512: TENTATIVE METHODS OF MEASURING EVAPORATION LOSS
            FROM PETROLEUM TANKS AND TRANSPORTATION EQUIPMENT (1957)	
           API BULLETIN 2513: EVAPORATION LOSS IN THE PETROLEUM INDUSTRY—CAUSES
            AND CONTROL (1959)	
           API BULLETIN 2514: EVAPORATION LOSS FROM TANK CARS, TANK TRUCKS, AND
            MARINE VESSELS (1959)	
           API BULLETIN 2515: USE OF PLASTIC FOAM TO REDUCE EVAPORATION LOSS (1961)
           API BULLETIN 2516: EVAPORATION LOSS FROM LOW-PRESSURE TANKS (1962)	
           API BULLETIN 2517: EVAPORATION LOSS FROM FLOATING-ROOF TANKS (1962)	
j?          API BULLETIN 2518: EVAPORATION LOSS FROM FIXED-ROOF TANKS (1962)	
           API BULLETIN 2519: USE OF INTERNAL FLOATING COVERS FOR FIXED-ROOF TANKS
            TO REDUCE EVAPORATION LOSS (1962)	
           API BULLETIN 2520: USE OF VARIABLE-VAPOR-SPACE SYSTEMS TO REDUCE EVAP-
            ORATION LOSS (1964)	
           API BULLETIN 2521: USE OF PRESSURE-VACUUM VENT VALVES FOR ATMOSPHERIC
            PRESSURE TANKS TO REDUCE EVAPORATION LOSS (1966)	
           API BULLETIN 2522: COMPARATIVE METHODS FOR EVALUATING CONSERVATION
            MECHANISMS FOR EVAPORATION LOSS (1967)	
           API BULLETIN 2523: PETROCHEMICAL EVAPORATION LOSS FROM STORAGE TANKS
            (1969)	,	

                                     Picture 3

-------
                             API STAFF
NJ
O
           S/CON
         FLOATING-
        ROOF TANKS

           2517

         G.J. GOOD
 S/CON
INTERNAL
FLOATING
 COVERS
  2519

R.C.KEftN
                                            COMMITTEE ON
                                            EVAPORATION
                                                 LOSS
                                            MEASUREMENT
                                              CHAIRMAN
                                              J.G.ZABAGA
  S/CON
FIXED-ROOF
  TANKS

   2518
                                   SPECIAL LIAISON
                                     J.R. ARNOLD
    S/CON
  TANK CARS,
 TANK TRUCKS,
MARINE VESSELS
    2514

 R.L.JOHNSON
 S/CON
  TEST
METHODS

  2515

A.D. WHITE
                                                Figure 4

-------
   FLOATING ROOF
                                   S/C 2517
 o o   o  o  00
   INTERNAL DECK
                                   S/C 2519
     FIXED ROOF

    CLOSEDTOP &
  NO FLOATING ROOF
TRUCKS OR TANK CARS
    I    I
    SPLASH
   LOADING
                                   S/C 2518
                                   S/C 2514
                                    OR
 I     I
BOTTOM
LOADING
  I    T
SUBSURFACE
 LOADING
    BARGES
                                   TANKERS
                  Figure 5

                     16-21

-------
                        API 2514A
           MARINE VESSEL LOADING OF GASOLINES
   SUMMARY OF AVERAGE HYDROCARBON EMISSION FACTORS
T   VESSELS
to
     SHIPS
     BARGES
 ARRIVAL
CONDITIONS

CLEANED
UNCLEANED

CLEANED
UNCLEANED
NO. OF COMPART-
 MENTS TESTED

      50
      21

      1
      11
EMISSION FACTORS
   (lbs./1000
GALLONS LOADED)

      1.3
      2.5

      1.2
      3.8
                           Figure 6

-------
          MASTVENT
          FLAME ARRESTER
                                          VENT
                                              I
                                        BARGE LOADING
           SHIP LOADING
                TYPICAL SHIP LOADING EMISSION PROFILE
          40

  VOLUME %
HYDROCARBON
          20
                   T
 T
T
T
T
              AVERAGE % HC AT END
              OF LOADING *=48% TO 55%
AVERAGE % HC=5.4% T011 %
     AVERAGE ARRIVAL % HC=2% TO 7%
                   10      20      30       40       50
                DISTANCE FROM TOP OF COMPARTMENT
                        Figure 7

                          16-23

-------
   A. FRT EMISSIONS
        FLOATING ROOF
          SEAL AREA
TANK
SHELL
                                              EMISSIONS
                                                    ROOF
                                        LIQUID LEVEL
    B. TESTING METHODS
      1. DENSITY CHANGE
        DORMANT FIELD TANKS
             6-12 SAMPLES
               2-4 WEEKS
                        7
DENSITY
GM/ML
              TIME
      2. PILOT TANK
                                       AIR
HC&CFM


f H
     • VARY PRODUCT, TEMPERATURE,
      PRESSURE, WIND EFFECT & SEAL
      CONDITIONS
     • COLLECT & ANALYZE EMISSIONS
                               Figure 8
                                16-24

-------
    PLANNED PUBLICATION
    OF UPDATED BULLETINS
Ul
         EARLY 1979
                        API STAFF
EARLY 1979
             COMMITTEE ON
             EVAPORATION
                 LOSS
             MEASUREMENT

               CHAIRMAN
              J.G. ZABAGA
                               SPECIAL LIAISON

                                J.R. ARNOLD
LATE 1978
TRUCKS - EARLY 1978
 MARINE-MID-1978
LATE 1979
                                                                            J
I
S/CON
FLOATING
ROOF TANKS

2517
G.J. GOOD






I
S/CON
INTERNAL
FLOATING
COVERS
2519
R.C.KERN






I
. S/C ON
FIXED-ROOF
TANKS
• •
2518







I
S/CON
TANK CARS,
TANK TRUCKS,
MARINE VESSELS
2514
R.L JOHNSON








S/CON
TEST
METHODS


2515
A.D.WHITE
                                        ' Fiqure .9

-------
             HYDROCARBON EMISSIONS
       FROM FLOATING ROOF STORAGE TANKS
             Presented at the 1977
        Environmental Protection Agency
      Emission Inventory/Factor Workshop
Raleigh, North Carolina - September 13-15, 1977
                      By

             Dr. Robert L. Russell
   Research Chemist, Union Oil Research and
        Chairman of Western Oil and Gas
   Association Floating Roof Tank Task Force
                 P. 0. Box 76
            Brea, California 92621
                      17-1

-------
Summary




     The Western Oil and Gas Association has funded several projects




designed to quantify the hydrocarbon emission rate from floating-roof




tanks in which volatile petroleum products are stored.  These projects




have involved measurements of emissions from petroleum product storage




tanks in Southern and Northern California, and from a pilot scale test




tank in Illinois where the environmental factors are controllable.




Several important conclusions were drawn from these studies:




(1)  Emissions from in-service floating-roof tanks are lower than




     predicted by the American Petroleum Institute Bulletin 2517




     equation.




(2)  Wind is the major driving force causing emissions from




     floating-roof tanks.




(3)  Good metallic shoe seals control emissions better than good




     toroidal seals which do not contact the stored liquid surface.




(4)  Gaps between a toroidal seal and the tank shell can sub-




     stantially increase the emission rate.




(5)  Gaps between a shoe seal and the tank shell result in an




     appreciably increased emission rate only when the gaps




     extend continuously over about 50% or more of the tanks




     circumference.




(6)  The inherently low emissions from floating-roof tanks can




     be further reduced by placing secondary seals above the




     primary seals.
                                  17-2

-------
(7)  Secondary seals reduce emissions effectively even when

     gaps are present in both primary and secondary seals.

(8)  With reasonably well fitting secondary seals extending

     from the roof to the tank shell one can expect about the

     same emission rate for equivalent tanks of either welded

     or riveted construction.



History of Floating-Roof Tank Seal Controversy
in Southern California	

     The Los Angeles County Air Pollution Control District had a rule

for many years Which required that floating-roof tanks storing a

petroleum distillate with a vapor pressure greater than 1.5 psia must

have a seal which "closes the space" between the floating roof and

the tank shell.  Early in 1976 California Air Resources Board (CARS)

Personnel inspected floating roof petroleum storage tanks at a

Southern California refinery.  As a result of these inspections, CARB

alleged that these tanks were causing "massive violations" of air

pollution control laws and that the district's rule and enforcement

procedures were not adequate to deal with the situation.

     The latter allegation was based on CARB's interpretation of the

phrase "closes the space".  CARB interpreted this phrase to mean

that there should be no gap between the seal and the tank shell,

while the district had traditionally interpreted it to mean that a

reasonably well functioning seal was present.  Following a public

hearing CARB ruled that the enforcement procedures were inadequate
                                 17-3

-------
and consequently assumed joint enforcement authority with the




district.




     The allegation of excessive emissions was based on a GARB




calculation which purported to show floating-roof tank hydrocarbon




emissions from this one particular refinery to be 3000 tons per year.




This number was obtained by using an American Petroleum Institute




(API) equation for floating-roof tank evaporation loss    and




arbitrarily increasing the calculated amount of emissions obtained




for tanks with "poor" seals by up to four-fold.




     Both GARB and the Southern California Air Pollution Control




District (SCAPCD) conducted public hearings which involved the




District's "Storage of Organic Liquids" rule (Rule 463).  By mid-1976




GARB decided that gaps between a floating-roof seal and the tank




shell anywhere along the circumference could not be greater than 1/8"




in width.  However CARB delayed enforcement of this extremely strin-




gent gap criterion (referred to as a "no-gap" criterion) until




February 1, 1977.  The delay was allowed because of testimony that




the Western Oil and Gas Association  (WOGA) was initiating an experi-




mental  study of hydrocarbon emissions from floating-roof tanks.




CARB indicated that Rule 463 might be changed if the study demon-




strated that the CARB staff calculations were erroneous.  If the




study indicated that the CARB calculations were reasonably accurate,




then all floating-roof tanks would have to immediately comply with




the extremely strict gap criteria.
                                  17-4

-------
     During the course of the WOGA studies GARB and other environ-




mental agencies personnel were invited to regular monthly status




report meetings.  These meetings provided for a free and open dis-




cussion by all interested parties.  All suggestions received at




these meetings were carefully reviewed and incorporated within the




program if they were reasonable and achievable within the time and




cost constraints.  This free exchange of information proved to be




very beneficial in ensuring that all important factors were considered




and tested during the study.




     As soon as each of the project final reports was completed it




was made available to GARB and all interested parties.  The openness




with which these studies were conducted contributed to their credibil-




ity with GARB and other environmental agency personnel.  GARB subse-




quently used some of the conclusions, but in the opinion of WOGA




personnel they did not use all of the pertinent conclusions, in their




justification of recommended modifications to Rule 463.




     The data from the WOGA study revealed that the original GARB




calculations were erroneous.  However, the study also revealed that




a secondary seal could reduce the already low emissions.  Therefore




GARB decided to relax the gap criteria slightly and to require




installation of secondary seals on all floating-roof tanks.  WOGA




and petroleum company representatives noted that the new GARB gap




criteria were still not justified by the.available data.  GARB




subsequently proposed gap criteria equivalent to the gaps tested in
                                 17-5

-------
a pilot scale test tank and made it clear that any further



relaxation of the gap criteria would require more data from the



pilot scale test tank.  Although WOGA was convinced that the data



base was broad enough to justify larger gaps than had been tested,



they contracted for additional tests to unequivocally prove this.





The WOGA Studies



     Industry personnel generally agreed that the API Bulletin 2517



equation overestimated floating-roof tank emissions for modern



floating-roof tanks.  This belief was based on the following facts:



(1) the equation is based on data obtained by many different



companies between the 1920's and the 1950's, and  (2) the data were



obtained to demonstrate the superiority.of floating-roof versus
                                       j


fixed-roof storage rather than to quantify emission levels.  WOGA



decided that obtaining new, hard data was the only way to ensure



adoption of a rational rule.       . *



     WOGA appointed a Task Force and established  three objectives:



(1) to determine hydrocarbon emissions from floating-roof tanks as



a function of seal gap size, vapor pressure, wind velocity and other



important variables;  (2) to determine what constitutes best available



seal technology and to estimate hydrocarbon emissions from use of



that technology; and  (3) to compare hydrocarbon emissions from exist-



ing floating-roof tanks with estimated hydrocarbon emissions from



the use of best available seal technology.
                                  17-6

-------
     Part (1) of the objective was further subdivided into three



tasks:  field test of actual floating-roof tanks, pilot-scale testing,



and laboratory testing.  Standard Oil of Ohio (SOHIO) generously made



available data gathered in a pilot-scale study performed for it by


                                         (2)
the Chicago Bridge and Iron Company (CBI).     That study involved



measuring emissions from a model floating-roof tank, equipped with



a toroidal primary seal, under controlled conditions.  WOGA subse-



quently contracted with CBI to investigate the level of emissions in



the model floating-roof tank when equipped with a shoe primary seal.





Field Testing of Floating-Roof Tanks



     The WOGA Task Force decided that the density change method


                              (3)
described in API Bulletin 2512    would be used for the field test



work.  Engineering Science, Inc. (ES) from Arcadia, California was



selected to perform the study.  CARB, Environmental Protection Agency,



SCAPCD, and the San Diego APCD accepted WOGA's invitation to fully



participate in the study.



     The density change method relies on the fact that lighter ends



evaporate faster than heavier ends from a hydrocarbon mixture.  There-



fore in a storage tank, with no liquid flow in or out, the weathering



process increases the stored liquid's density.  By use of a density-



evaporation curve and with knowledge of the initial and final density



and the Volume of stored liquid the evaporation losses can be deter-



mined.  It proved to be necessary to use a highly precise Mettler-Parr



density comparator to measure densities to five decimal places.
                                  17-7

-------
     Because of the expected low emission levels it was necessary




to float a 3 to 5 foot layer of hydrocarbon on water to ensure that




the density change over the expected three to four month storage




could be observed.  Extensive laboratory testing demonstrated that




the water had no significant influence on the hydrocarbon density



                         (4)
during the storage period .•




     In general, samples were taken via water displacement into




narrow neck.8-ounce bottles at 12 different roof leg support sleeves.




The 12 sampling positions were selected to represent approximately




12 equal volume elements within a tank.  The data demonstrated that




vertical and horizontal stratification, if it does occur, is so




slight that it does not affect calculation of the average stock




density.




     Tanks in the field study represented a variety of different




seals, products, roof heights, gaps, and tank wall types.  Typical




seal designs represented in the field study are shown in Figures I




and II.




     The average observed hydrocarbon emission rate from 13 of the




study tanks is compared in Figure III to the API 2517 calculated




emission rate.  It can be seen that the observed emissions are




approximately 1/2 of the calculated emissions instead of the 2 to 4




times greater that the GARB staff originally estimated.
                                  17-8

-------
.Pilot  Scale Testing of Floating-Roof Tank Emissions



     Chicago Bridge & Iron Company (CBI)  built an insulated,



 temperature-controllable,  20  foot  diameter,  9  foot high tank  with


                                                  (2a)
 a double deck floating-roof and  a  cone  roof  cover.      The tank is



 designed to permit  blowing air through  the space  between the  floating



 and cone roof.   A flame ionization detector  is used to determine the



 hydrocarbon concentration  in  the outlet and  inlet air.   The differ-



 ence between these  two numbers is  a direct emission measurement at



 the preset operating conditions.


                               /2)
     The SOHIO/CBI  experiments     demonstrated that wind speed had



 a pronounced effect on emissions from a floating-roof  tank equipped



 with a toroidal type seal.  As Figure IV  shows, subsequent WOGA/CBI



 experiments    demonstrated that while  emissions  from  a floating-roof



 tank equipped with  a shoe  seal are wind speed  dependent, the  effect



 is much less pronounced than  with  a toroidal seal.



     The SOHIO/CBI  and WOGA/CBI  data also demonstrated the effect



 of introducing gaps between the  seals and the  tank shell,  and the



 effect of placing a secondary seal from the  roof  to the shell above



 the primary seal.   (Typical examples of secondary seals are shown in



 Figure V.)  Figure  VI shows a data summary depicting the effect that



 various size gaps in primary  and secondary seals  have  on emissions.



     Several important conclusions can  be drawn from the data



 presented in Figure VI:




 (1) If no secondary seal  is  present, toroidal seal gaps increase
                                 17-9

-------
     emissions substantially over a "no-gap" toroidal seal.




(2)   If a secondary seal is present above a toroidal seal, the




     emissions can be lower than with the "no-gap" toroidal seal




     even when overlapping, diametrically opposed 1/2" wide gaps




     over 6.4% of the tank circumference are present in both seals.




(3)   If no secondary seal is present the emissions from a shoe seal




     system are less than from a "no-gap" toroidal seal system even




     when gaps up to 1-3/4" for 39.6% of the tank circumference are




     present in the shoe seal system.




(4)   Emissions from a shoe seal system increase appreciably only




     when the gaps extend continuously for a considerable percentage




     of the tank circumference.




(5)   If a secondary seal is present above a shoe seal the emissions




     can be lower than the "no-gap" shoe seal even when substantial




     gaps are present in both seals.




(6)   A secondary seal on a riveted tank is an effective emission




     control device even under worst-case conditions.






Emissions Comparisons




     Figure VII shows some comparisons between predicted emissions




using the API-2517 equation and the CBI data base.  Bars numbered 1




through 3 and 8 are for a welded tank equipped with a shoe seal.




Bars numbered 4 through 7 are for a riveted tank equipped with a




shoe seal.  Bars 9 and 10 are for a welded tank equipped with a




toroidal seal.
                                17-10

-------
     Bars numbered 1, 4, 5 are calculated by the API-2517 equation


for a welded tank with or without a secondary seal, a riveted tank


without a secondary seal, and a riveted tank with a secondary seal,


respectively.  Bars numbered 2, 3 and 6, 7 are calculated by using


appropriate emission values from the CBI data for various ranges of


circumferential gap openings between the primary shoe seal and tank


shell, and weighting these emission values by the percent of time the


respective gap openings are expected to be encountered in a field


tank.  The latter numbers were determined from the tank survey data

                                   (4)
in the Engineering Sciences reports.    For bars 3 and 7, the CBI data


for 3/4" gaps over approximately 10% of the tank circumference in the


secondary seal were used.  Bars numbered 8, 9 and 10 use the CBI data


for a "no-gap" shoe seal, "no-gap" toroidal seal, and a 1/2" x 6.4%


of circumference gap in both the toroidal and secondary seals,


respectively.


     The following conclusions can be drawn from Figure VII:


(1)  Emissions from shoe seal equipped floating-roof tanks are


     considerably lower than predicted by the API-2517 equation.


(2)  The average emission levels from welded or riveted tanks


     equipped with shoe seals and no secondary seals are low and


     differ only slightly between the two tank types.


(3)  The presence of a reasonably well fitting secondary seal which


     goes from the roof to the tank shell can further reduce the low


     emissions of a shoe-sealing system.
                                 17-11

-------
(4)  The average emissions expected from a sealing system which

     employs both a primary and a secondary seal, with gaps in both

     seals, are lower than the emissions from a "no-gap" primary

     seal alone.

(5)  When a reasonably well fitting secondary seal, which goes from

     the roof to the tank shell is used, the average emissions from

     equivalent welded and riveted tanks should be about the same.
Acknowledgments

     The efforts of the WOGA Task Force members are gratefully
acknowledged.  These members were:
Jerry Adams
Earl K. Dewey, Jr.
Dennis Dykstra
John A Glaser
Gordon J. Good
Hayden H. Jones
Peter E. Jonker
Peter L. Mehta
Richard A. O'Hare
William J. Porter
Robert M. Stoneham
Fletcher Oil & Refining Co.
Continental Oil Company
Chevron U.S.A., Inc.
Gulf Oil Company, U.S.
The Standard Oil Co. of Ohio
Union Oil Co. of California
Union Oil Co. of California
Atlantic Richfield Company
Shell Oil Company
Chevron, U.S.A., Inc.
Texaco, Inc.
Wilmington, CA.
Ponca City, OK.
El Segundo, CA.
Santa Fe Springs, CA.
Cleveland, Ohio
Wilmington, CA
Los Angeles, CA.
Carson, CA.
Carson, CA.
El Segundo, CA.
Wilmington, CA.
                                 17-12

-------
                        References

API Bulletin 2517, Evaporation Loss From Floating-Roof Tanks,
American Petroleum Institute, New York, 1962.
(a)  SOHIO/CBI Floating Roof Emission Test Program,
     Preliminary Information, Chicago Bridge & Iron Company,
     August 27, 1976.

(b)  SOHIO/CBI Floating Roof Emission Test Program, Interim
     Report, Chicago Bridge & Iron Company, October 7, 1976.
(c)  SOHIO/CBI Floating Roof Emission Test Program, Final
     Report, Chicago Bridge & Iron Company, November 18, 1976.
API Bulletin 2512, Tentative Methods of Measuring Evaporation
Loss From Petroleum Tanks and Transportation Equipment, American
Petroleum Institute, New York, 1957.
(a)  Evaluation of Hydrocarbon Emissions From Floating-Roof
     Petroleum Tanks, Interim Report, Engineering Science, Inc.
     December 1, 1976.

(b)  Hydrocarbon Emissions From Floating Roof Petroleum Tanks,
     Engineering Science, Inc. January 1977.

(a)  Western Oil and Gas Association, Metallic Sealing Ring,
     Emission Test Program, Interim Report, Chicago Bridge &
     Iron Company, January 19, 1977.

(b)  Western Oil and Gas Association, Metallic Sealing Ring,
     Emission Test Program, Final Report, Chicago Bridge &
     Iron Company, March 25, 1977.
(c)  Western Oil and Gas Association, Metallic Sealing Ring,
     Emission Test Program, Supplemental Report, Chicago Bridge
     & Iron Company, June 30, 1977.
                           17-13

-------
(-«
JS
TANK SHELL
                                Figure I

                        TYPICAL SHOE SEAL
                             SHOE
                               SEAL FABRIC
                                                ROOF
                                     ^ -*—*- -**•*•
PANTAGRAPH HANGER
                                   LIQUID LEVEL
                                                   COUNTER WEIGHT

-------
                                        Figure II

                              TYPICAL TOROIDAL SEAL
-4

>-•
Ul
               TANK SHELL
            SEAL ENVELOPE
RESILIENT
URETHANE FOAM
                                          CURTAIN SEAL
                                           LIQUID
                                           LEVEL
                                                 ROOF
                                                       HANGER BAR
SEAL SUPPORT RING
                                                       RIM
                                                       BUMPER

-------
                             Figure III

            EMISSIONS FROM 13  GASOLINE TANKS
                WOCA /ENGINEERING - SCIENCE STUDY
AVERAGE
HYDROCARBON
EMISSION RATE
LB/DAY/TANK
               125
               100
                75
               50
               25
                   EMISSIONS ESTIMATE USING
                   API 2517 EQUATION
                   (TIGHT FITTING SEALS)
ACTUAL MEASURED EMISSIONS
FROM ENGINEERING —
SCIENCE STUDY

-------
X
o
-o

J!
o
E
to
O
u

z
g
to
   .28
.24
.20
   •'«
   .12
.08
   .04
                    Figure IV

          EFFECT OF WIND SPEED

          CBI PILOT SCALE TANK
                       TOROIDAL

                       SEAL
                       SHOE
                       SEAL
           2    4    6     8    10

          WIND SPEED, MILES PER HOUR
                                   12
                  17-17

-------
                                  Figure V



                      TYPICAL SECONDARY SEALS
H-

00
          TANK SHELL
         TANK SHELL
                                  SEAL FABRIC  .
                                    POLYURETHANE LOG
                                                MINI-TOROIDAL
                                          ROOF
1
1
                                   RUBBER WIPER
                                                         WIPER

-------
I—
vo
                                                Figure VI

      EFFECT OF  GAPS AND SECONDARY SEALS CBI PILOT SCALE TANK DATA
65







~ 60








-
a -^
A ~-
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Z 25
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IK
a. 20
«
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7 15
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5 10
s
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5




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X
X
X
X
X
X
X
X
?









TOROIDAL
SEAL


—


—






—




—



















^
X"

^
^
X

X






















^
^
x
^
X
^^
1
X
X
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^
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^

DATA




















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bd





















,_
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p£








































SHOE SEAL DATA



















Cxi
IX
|x
K























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txt Pxl
p^j K3
Pd 0 Ixl


















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^
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^




















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ixj
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WORST CASE
RIVETED
TANK DATA




















X
X
x
X
X

X
x
X
^
X
X
X
X
;>
x
^
^
X
^











^
X
X
^
1
^

X ^d
X ^j
^ ^
PRIMARY SEAL
MAXIMUM GAP, IN.


•/. OF CIRCUMFERENCE
 NO  1   J_   NO       111
GAPS  7   2  GAPS  1222
                                                              NO
                                                             GAPS
 ^  ]J   ^  4^2
33  13  13  1
                                  6.4  6.4
                13.6 52.0 52.0 52.0
39.6 39.6 39.6 100  100   100
            SECONDARY SEAL
            MAXIMUM GAP, IN.

            Y. OF CIRCUMFERENCE
                 Non« Non«  2  Nona None None  4   y  Non« None  "J"   "J
                          6.4
                         9.3   7.4
     11.1  4.3
  Nona  4"   •4"



       21.2  9.5

-------
                                                       Figure VII

                  EMISSION COMPARISON FOR 150 FOOT DIAMETER TANK STORING 5 PSIA STOCK
               EMISSIONS
               (Ib/DAY)
ro
o
                          300 r
                          250
                          200
                          150
100
                           50
                                 -1

                                              M
                   TANK TYPE
           WELDED
     RIVETED
                 WELDED
                PRIMARY SEAL
            SHOE
      SHOE
            SHOE   TOROIDAL
             SECONDARY SEAL  YES or NO  NO    YES
                          NO
    YES
NO
YES
NO
NO
YES
                CALCULATION
                METHOD
      API-  CBI TEST DATA
      2517  WEIGHTED BY
            OCCURRENCE
            OF GAP OPENINGS
            IN FIELD TANK
            PRIMARY SEALS
API-      CBI TEST DATA
2517      WEIGHTED BY
        v OCCURRENCE
         OF GAP OPENINGS
         IN FIELD TANK
         PRIMARY SEALS
CBI
TEST
DATA,
NO
GAP

CBI
TEST
DATA,
NO
GAP

CBI
TEST
DATA,
1/2" GAP
6.4% IN
EACH SEAL

-------
QUESTION:
RUSSELL:
QUESTION:
RUSSELL:
QUESTION:
CONDENSED DISCUSSION
 I have no problem in inspecting a floating
 roof seal.  I have a great deal of trouble
 inspecting the seal on an internal  floater.
 Could you explain how you got in there
 and measured all  those gaps on internal
 floaters?
 We didn't.  We haven't done it on the inter-
 nal floaters.  Not that I am aware  of anyway.
 Originally you started out and said that
 because of the gaps, the  California board
 evaluated that emissions were  four times
 higher.  With your new data would the emiss-
 ions be two times or three  times higher
 now?
 The new data shows that the emissions are
 50% less than what would be calculated using
 the straight forward API equation.   CARB was
 using the API  equation and then increasing
 it by two to four times, so the new data says
 that we are considerably less than  by four to
 eight times what  CARB originally estimated.
 I noticed in one   of your emission  loss
 factors for breathing loss that you used a
 constant breathing loss factor for I assume
 your used control tanks without any vapor
 returns.
           17-21

-------
RUSSELL:
COMMENT:
RUSSELL:
COMMENT:
RUSSELL:
QUESTION:
RUSSELL:
The vapor return wasn't installed to control
breathing losses.  Breathing losses are more
or less uncontrolled.
But you used one factor and you said you  based
it upon API.  API is based upon the breathing
loss as a function of the amount of tempera-
ture rise during the day.
We had to make some assumptions based upon
the survey data as far as average tank size.
Most tanks were in the same size range.
Well, regardless of size it depends on what
the average temperature was.
Yes, I think we used 15 degree daily tempera-
ture variation.
In the work did you establish the relative
estimated condition level from small bulk
plants as compared to bulk terminals?
No.  The studies that we performed were deal-
ing only with bulk plants - less than 20,000
gallons.  This data was submitted to EPA to
formulate or to determine how proposed vapor
recovery regulations will effect small bulk
plants.  So we weren't really concerned with
large terminals.
                                17-22

-------
              EMISSION INVENTORY
   OF PETROLEUM STORAGE AND HANDLING LOSSES
               (A CASE HISTORY)
             Presented at the 1977
        Environmental Protection Agency
      Emission Inventory/Factor Workshop
Raleigh, North Carolina - September 13-15,  1977
                      By

            James T. Alexander,  Jr.
               Regional Engineer
  Virginia State Air Pollution Control  Board
           Northern Virginia  Office
         Falls Church, Virginia  22043
                       18-1

-------
Abstract




     Gasoline and distillate products emissions were calculated




for the Northern Virginia sector of Metropolitan Washington for




the peak oxidant month of July using factors adjusted for specific




July weather conditions.  Sources included floating roof and fixed




roof storage, bulk terminal loading racks, service station deliv-




ery and sales, airports, and small bulk plants.




     Calculations were made in Ibs/day and lbs/6-9 a.m. peak period




under  summer weather  conditions typical for the high oxidant peri-




ods experienced in the region.  The basis for emission factors was




the Radian Corporation Study of August 1976 by Burklin and




Honerkamp.  Their version of the API empirical equation for float-




ing roof  losses was used in the absence of a better predictive




model, recognizing the lack of correlation shown in January 1977




by Engineering-Science.




     As expected, this method of inventory produces a great deal




more emissions compared with year-around averaging of gasoline




throughput and nationwide temperatures.  Nearly all the differ-




ences  are additive.   Some are quite large.  For example, gasoline




vapor  pressure at 79°F is 36% higher than it is at 60°F.




     An earlier  inventory for 1972 was re-calculated and the




emissions were 70% greater using the July-specific inventory pro-




cedure.   The  effect of vapor control measures was determined.




Overall reductions of 38% are shown on a Ibs/day basis and 42% on
                              18-2

-------
a Ibs/peak period basis.




     Correction by the Radian Study of the apparently  erroneous



data in AP-42 for properties of distillate fuels results  in very




small emissions from those products in the Northern Virginia



region.
                             18-3

-------
                      EMISSION INVENTORY

           OF PETROLEUM STORAGE AND HANDLING LOSSES

                       (A CASE HISTORY)

          James T. Alexander, Jr., Regional Engineer
          Virginia State Air Pollution Control Board



     Background

     The cities and counties of Northern Virginia included in the

National Capital Interstate Air Quality Control Region contain

eight pipeline terminals and fourteen small bulk plants serving a

greater metropolitan area of about three million people.  Air

quality exceeds the photochemical oxidant standard by 25% or more

for about 35 days each summer.  The Virginia portion of the region

has very little industrial activity and comprises suburban and

rural development characterized as "bedroom" communities.  Gaso-

line vapor control measures were initiated in 1973.

     Inability to apply, up to this time, an air quality simula-

tion model that relates hydrocarbon and nitrogen oxides emissions

to oxidant concentrations highlighted a need for better emission

inventory of pollutants as an interim yardstick of control effec-

tiveness during continued population growth.  One portion of this

inventory effort covered petroleum storage and handling emissions

in Northern Virginia.  These were calculated for 1976 and recal-

culated for 1972 using best available emission factors adjusted

for local conditions.  The paper describes how this was done and
                              18-4

-------
compares the results with an earlier, less precise,  inventory.


     The work involved two steps.   First,  the calculation of emis-


sion factors based on local conditions and second,  the inventory


of individual Virginia sources using those emission factors.


     Local Meteorological Conditions


     At the outset it was decided  to calculate emissions in Ibs/


day for July conditions and to convert those emissions to lbs/6-9


a.m. period.  July was determined  to be the peak oxidant month.


Based on 30-year weather observations at National Airport,  July


has 30% more days with maximum temperature 90°F or higher than


either June or August.  Studies have shown maximum  temperature to


be a useful surrogate for numerous meteorological variables that


relate to peak oxidant formation in the Eastern U. S.    Data  for


the 6-9 a.m. period was sought so  as to facilitate  subsequent use


of the Dodge-Demitriades smog chamber curves as an air quality


simulation model.  It will be recalled that the units  of NMHC

                                                            o
concentration plotted on those curves are  in ppmC (6-9 a.m.)


     Table I shows local July meteorological factors for Washington


National Airport compared with the nationwide annual values nor-


mally used in calculating evaporative emission factors for  use in


the National Emissions Data System (NEDS).   Local values for  the


6-9 a.m. period were taken for July 1976,  a month which happened


to conform quite closely to the 30-year mean for July.


     Above ground storage temperature at 6-9 a.m. was  assumed to
                              18-5

-------
coincide with the ambient daily mean.  It was considered that




early morning temperature depression from the ambient mean is




probably offset by heating due to delivery of hot products from




the pipelines.  Products are known to be received in summertime




as high as 90°F.  This assumed product temperature was backed by




sampling delivery truck loading tickets.




     For below ground storage, the 6-9 a.m. ambient mean was used.




That value is comparable with a number of local summertime tank




measurements made during Stage I vapor balance testing.  Many ser-




vice station tanks are subject to external heating from absorption




through black-top paving, and do not cool down during the pre-dawn




period to the temperature of grass or dirt-covered subsurfaces.




     Gasoline Distillation Properties




     The largest distributor in the region, EXXON Company (U.S.A.),




was asked to furnish data on Reid vapor pressure and API° gravity




that could be considered typical for summertime gasoline products.




They reported data for their three grades of gasoline that were




marketed locally in July 1976.  The sales-weighted values were:




RVP-9.7 and liquid density - 6.16 Ibs/gal.




     Table II shows the resulting values of true vapor pressure




at the assumed temperatures shown in Table I.  The column titled




"multiple" indicates the local value compared with the nationwide




value as 1.  In equations where emissions vary directly with true




vapor pressure, or in the exponential form shown, the summertime
                              18-6

-------
temperature effect is pronounced.




     Empirical Equations for Evaporative Losses




     Initial attempts to use the empirical equations developed by




the American Petroleum Institute in 1962, cited in the Air Pollu-




tion Engineering Manual, AP-40 (2nd Edition),3 to derive localized




emission factors were unsuccessful.  The losses expressed in the




API equations are in volumetric units (barrels of vapor emitted




per year or per million barrels throughput).   Physical properties




of the vapor which are needed to convert emissions to a weight




basis were not available.




     Additionally, the empirical equations cited in AP-42 (Supple-




ment One)  could not be used to calculate the "standard" evapora-




tive factors contained in Section 4.3 of that document.  Although




those equations express losses on a weight basis, the vapor prop-




erties used in the equations apparently differ from those used to




calculate the standard factors in Table 4.3-2.  Values for true




vapor pressure of distillate products used in AP-42 are apparently




in error.




     As a result of these shortcomings,  the Federal EPA awarded




a contract to the Radian Corporation, Austin, Texas to upgrade and




refine the information presently contained in AP-42.  Their report,




prepared by C. E. Burklin and R. L. Honerkamp,5 was obtained and




the empirical equations contained therein were used to derive July




emission factors for Metropolitan Washington.  (This document is
                             18-7

-------
hereafter cited as "EPA-450/3").




     Since the empirical equations contain factors for tank geome-




try as well as vapor pressure, local data was collected for tank



diameters and tank vapor space height and estimates were made for




paint condition.  Average storage tank sizes at the eight bulk



terminals in Northern Virginia were found to be slightly smaller



than the nationwide average used for calculating standard factors




in EBk-450/3.  Table III shows these differences.  Since tank dia-



meter appears as an exponential function in the equations, these



tank size differences are significant.




     Emission Factors for Bulk Terminals




     Local emission factors were computed for floating roof stor-




age, fixed roof storage and loading rack emissions using the



pressure, density, temperature, wind speed, and tank paramenters




described above.




     A  comparison of the local values with the "standard" values



in the  Radian  study, EEA.-450/3, is shown in Table IV.  The column



titled  "multiple" shows the ratio of the local factor divided by



the standard factor.  The local gasoline factors are 1.15 to 1.30



times the standard factors.  This has an important bearing on the




precision of an overall inventory.



     The local fixed roof factors for breathing loss are smaller




than standard values because of the smaller average tank diameter



used in the equations.  As will be shown, jet kerosene and No. 2
                              18-8

-------
fuel oil emissions are quite small in comparison with gasoline, so




an emission factor refinement for those products is not as impor-




tant as it is for gasoline.  This was not the case when AP-42




standard emission factors were used.  The values in Table 4.3-2




of that document for distillate products are 8 times larger for




breathing and 37 times larger for working losses than correspond-




ing values in EPA-450/3.




     It is recognized that floating roof emission factors based on




empirical relationships must be regarded with some skepticism.  The




Radian Study did not correct basic inadequacies in the API empiri-




cal equation for floating roof standing storage emissions.  Recent




tests by Engineering-Science, Inc. on thirteen tanks in California




revealed a marked lack of correlation between observed and calcu-




lated emissions.   It appears likely that further testing will




show that well-designed internal floating pans result in less emis-




sions than external floating decks that are subject to more wind




effect.




     Efficiency of Gasoline Vapor Recovery Systems




     The empirical equations in EPA-450/3 provide a means to




include the effects of gasoline vapor recovery at a known level of




efficiency.  Loading rack losses are effected by:   (1) whether




trucks return vapor collected by vapor balance at service stations,




and (2) whether the loading racks themselves are controlled by  on-




site processing equipment.
                             18-9

-------
    Northern Virginia has Stage I vapor balance control on under-


ground storage tanks at nearly all service stations.  It is esti-


mated that 90% of the gasoline throughput is so controlled.  Vapor


processing units are installed at each bulk terminal to liquify or


incinerate the vapors displaced from truck compartments during re-


loading .


    While the efficiency of these processing units was measured at


92-95%, extensive leakage is currently being experienced at truck


compartment dome covers and truck vapor manifold fittings such that


a significant amount of vapor is discharged during re-loading.  For


emissions factor calculation it was assumed that only 76% vapor


recovery occurs at the loading racks.  Applying .92 unit efficiency


to .76 recovery efficiency yields an estimated .70 for overall


loading rack efficiency for Northern Virginia terminals.


    With that efficiency inserted in the empirical equation for


loading rack losses, the local factor with dedicated trucks in

                                        o
vapor balance service becomes 3.3 lbs/10  gal.


    The same computations for 70% loading rack efficiency, but

                                                               o
without vapor balance at the service stations, yield 2.0 lbs/10


gal for local temperature conditions.


    Table V shows gasoline loading rack losses under each of the


various conditions.


    Emission Factors for Service Stations


    The passenger car refueling loss equation developed by Scott
                               18-10

-------
Laboratories in 1972  was not used by Radian Corporation in EPA-




450/3 nor are any empirical equations suggested in that report.  It




simply states certain values for service station losses without




defining the standard ambient conditions for which they apply.




     If it is assumed that the values in EPA-450/3 for service




station losses are more accurate than earlier references »  and




that they are based on the same 60°F conditions used for above-




ground storage, one could factor them up to 75.5°F by applying the




vapor pressure multiplier (1.29), the number shown in Table II.




That of course assumes the losses are directly proportional to true




vapor pressure.  For purposes of this inventory, that procedure was




followed and local values were derived as shown in Table VI.




     Conversion to the 6-9 a.m. Period




     The development of factors to convert emissions in Ibs/day to




lbs/6-9 a.m. period is not susceptible to rigorous derivation.  It




is difficult to determine, for example, how much of the total ser-




vice station monthly throughput is handled daily, let alone during




the exact hours between 6 and 9 a.m.  Table VII shows the conver-




sion factors estimated for petroleum storage and handling operations




in Northern Virginia during summertime.  The percentage is the




portion of 24 hour emissions that occurs during the three hours 6




to 9 a.m.




     Storage Capacities and Volume Throughput




     One final step before emissions can be computed is to deter-
                              18-11

-------
mine, for each source and each product, the storage capacities and




volume throughput.  Gasoline volumes are greater in summertime and




heating oil volumes are smaller, so for this analysis, source owners




were asked to report volumes for the 31 calendar days of July 1976.




     Using July data in the Eastern U. S. has an appreciable effect.




Statewide gasoline tax data for Virginia over the past four years




shows that July sales are between 6% and 10% higher than the 12-




month average.




     Volumes were converted to a daily basis by considering July




a 31-day month for 7-day a week operations and a 26-day month for




6-day operations.




     Inventory Results




     Table VIII shows the inventories for July 1972 and July 1976




based on the local emission factors described herein.  Gasoline




sales during the four-year period were up 23%.  Control measures




resulted in an overall emission decrease of 35%.




     Table IX shows  the comparison with an earlier 1972 inventory




based on AP-42 emission factors calculated on a tons  per year




basis.  The total emissions are 71% greater using the procedure




described in this paper.




     Table X shows the July 1976 inventory for the three bulk




terminal locations by petroleum products.  The effect of the very




small emission factors for jet kerosene, diesel and No. 2  fuel




oil is  shown.  Although distillate products account for 22%  of the
                               18-12

-------
throughput they generate less than 2% of the emissions.  As noted




previously, floating roof standing storage losses were calculated




from an empirical equation known to be inadequate.  Those emissions




are 9% of the bulk terminal losses.




     Table XI shows the effect of vapor recovery control measures




in Northern Virginia.   Without Stage I vapor balance at service




stations and without vapor processing units at the terminals,




emissions would be increased by 6343 lbs/6-9.  This represents




overall control of 42%.




     Table XII shows the July 1976 emissions on a 24-hour basis in




Ibs/day instead of lbs/6-9 a.m.  Comparing these figures with the




previous data, Table VI, indicates the degree to which a 6-9 a.m.




computation enhances overall control effectiveness.  On a 6-9 basis




it is 42%, while on a 24-hour basis it is 38%.




     Conclusions




     Two general conclusions may be drawn from this analysis.




First, assuming the vapor properties of distillate fuels have been




correctly specified by the Radian Corp. study, evaporative emis-




sions from those products are hardly worth the effort to inventory,




at least in the quantities they are handled in Northern Virginia




in summertime.




     The second conclusion is that gasoline evaporative emissions




should be computed for the same ambient temperature and weather




conditions that prevail at the time those emissions have the most
                              18-13

-------
pronounced,effect oh air quality during the peak oxidant season.




     It is to be hoped that future revision of Sections 4.3 and




4.4 of AP-42 will a^id standardized, national average (NEDS)




emission factors for gasoline evaporative emissions and portray




the factors based on regional peak oxidant season conditions.




This could be done with temperature correction factors similar to




those used in calculating vehicle emissions.
                              18-14

-------
                          References
1.  Meteorological Conditions Conducive to High Levels  of Ozone,
    T. R. Karl and G.  A.  DeMarrais,  EPA (RTF)  Paper  Presented
    Sept. 12, 1976 at  International  Conference on PCOX  Pollution
    and its Control, Raleigh, N.C.

2.  Alternatives for Estimating the  Effectiveness of State Imple-
    mentation Plans for Oxidant. Draft  Paper,  January 1977, OAQPS,
    EPA (RTF).

3.  Air Pollution Engineering Manual (AP-40, Second  Edition), J. A.
    Danielson, Los Angeles APCD, May 1973,  (pp.  632-642).

4.  Compilation of Air Pollutant Emission Factors (AP-42, Second
    Edition), February 1976,  OAQPS,  EPA (RTP)  (Sections 4.3 and
    4.4 by W. M. Vatavuk  and  R. K. Burr, dated July  1973).

5.  Revision of Evaporative Hydrocarbon Emission Factors, (EPA-450/
    3-76-039) C. E. Burklin and R. L. Honerkamp,  Radian Corpora-
    tion, Austin, Texas,  August 1976 (EPA Project Officer:  C. C.
    Masser; Contract No.  68-02-1889).

6-  Hydrocarbon Emissions from Floating Roof Storage Tanks,
    Engineering-Science,  Inc., Arcadia, California, Jan. 1977
    (Report prepared for  Western Oil and Gas Association).

7.  Investigation of Passenger Car Refueling Losses. (APTD-1453)
    M. Smith, Scott Research  Labs, San  Bernadino, California,
    Sept. 1972, (CRC Project  CAPE 9-68).
                             18-15

-------
                         TABLE I
Ambient daily mean temp.

Ambient daily A T

Ambient 6-9 am mean temp.

Ambient 6-9 am A T

Average daily wind speed

Average 6-9 am wind speed
Nationwide
  Annual

  60°

  15°
  10 mph
 Local
  July

 78.7°

 15°

 75.5°
/

 6°

 8.1 mph

 7.3 mph
Assumed aboveground
  product temperature (6-9 am)

Assumed belowground
  product temperature (6-9 am)
  60°
  60C
 78.7°


 75.5°
                 Meteorological Factors
                           18-16

-------
                TA.BLE II
Above Ground Storage
P (psia)
f P V'7
^14.7 - Pj
Belowground Storage
P (psla)
Nationwide
60°F
5.2
.6558
60°F
i
5.2
Local
78.7°F
7.1
.9535
75.5°F
6.7
(Multiple
(1.36)
(1.45)
(1.29)
True Vapor Pressure of Gasoline  (RVP  9.7)
                  18-17

-------
                          TABLE III
                         Nationwide                Local



                       103 gal  D (ft)        103 gal D  (ft)






Floating Roof            2814     110           2298     94.2




Fixed Roof               2814     110           2098     87.1
               Average Sizes of Storage Tanks
                             18-18

-------
                           TABLE  IV
                              EPA-450/3    Local     (Multiple)
Floating RooJ
Gasoline
Fixed Roof
Kerosene
No. 2 FO
Loading Rack
Gasoline
Kerosene
No. 2 FO
E
Storage
Withdrawal

Breathing
Working
Breathing
Working

(uncontrolled)



.033a
.023

.0045a
.027
.0040a
.023

5.0
.02
.01

.038a
.029

.0038a
.044
.0034a
.037

6.5
.03
.02

(1.15)
(1.26)

(.84)
(1.63)
(.85)
(1.61)

(1.30)
(1.50)
(2.00)
a - lbs/day/103 gal;  all others  in lbs/103  gal
                Bulk Terminal Emission Factors
                             18-19

-------
                            TABLE V
(lbs/103 gal)            EPA-450/3       Local       (Multiple)


Uncontrolled,
w/o vapor balance           5.0           6.5          (1.30)

Uncontrolled,
with vapor balance          8.0          11.0          (1.38)

70% control
w/o vapor balance           	           2.0            	

70% control
with vapor balance          —           3.3            —
        Gasoline Loading Rack Factors (Submerged Fill)
                             1&-20

-------
                       TABLE VI
(lbs/103 gal)                  EEA.-450/3          Local
Subm. Fill U. G. Tanks
 (w/vapor balance)                .30              .39

Breathing Loss U. G. Tanks
 (after fill)                     1.0              1.3

Vehicle Refueling                 9.0             11.6

Nozzle Drip and Spill              .7               .7
           Service Station Emission Factors
                          18-21

-------
                   TABLE VII
Gasoline                      6-9 a.m.  Factor
   Loading Rack                     24




   Filling U. G. Tanks              24



   Filling Vehicle Tanks            18






Jet Kerosene



   Loading Refuelers                18



   Loading Aircraft                 18






Jet Kero, Diesel. No. 2 FO




   Loading Rack                     24



   Filling U. G. Tanks              24
All Products
   Storage                          12.5
         Peak Period Conversion Factors
                    18-22

-------
No. Virginia


Bulk Terminals

Bulk Plants

Airports

Controlled Serv. St.

Uncontrolled Serv. St.

           Totals
                            TABLE VIII
    July 1972
lbs/6-9      °
    July 1976
lbs/6-9      %
6377
349
209
0
6365
13,300
47.9
2.6
1.6
-
47.9
100.0
3764
195
37
3877
784
8657
43.5
2.3
.4
44.7
9.1
100.0
                     THC Evaporative Emissions
                               18-23

-------
            TABLE IX
No. Virginia



Bulk Terminals

Bulk Plants

Airports

Controlled Serv. Sta.

Uncontrolled Serv. Sta.
    Original
   Annual 1972
lbs/6-9 _ %
                                   Re-calculated
                                     July 1972
                                 lbs/6-9 _ %
3200
180
200
0
4220
41.0
2.3
2.6
0
54.1
6377
349
209
0
6365
47.9
2.6
1.6
0
47.9
                               7800
            100.0  13,300
                                             100.0
Re-calculation of 1972 Inventory
               18-24

-------
                             TABLE X
No. Virginia                 Emissions (lbs/6-9) from
Bulk Terminals
Fairfax
New ing ton
Manassas
Totals
L. R. Volume (103 gals)
Gasoline
1813
1674
225
3712
4105
Distillate
28
23
1
52
1170




(1.4%)
(22.2%)
             July 1976 Inventory for Bulk Terminals
                              18-25

-------
                            TABLE XI
No. Virginia
  July 1976
Bulk Terminals

Bulk Plants

Air pert: ts

Controlled Serv. Sta.

Uncontrolled Serv. Sta,



Control Effectiveness
Present
Emissions
(lbs/6-9)
3764
195
37
3877
784
8657

If
Uncontrolled
(lbs/6-9)
6821
266
51
0
7862
15000






(46343)
42%
         Effect of Vapor Control Measures (6-9 am basis)
                              18-26

-------
                           TABLE XII
No. Virginia
  July 1976
Bulk Terminals

Bulk Plants

Airports

Service Stations

          Totals


Control Effectiveness
Present
Emissions
Ibs/day
17,060
878
160
24,480
42,578
If
Uncontrolled
Ibs/day
29,800
1,157
220
37,820
68,997
(+26,419)
 387.
       Effect of Vapor Control Measures (24-hour basis)
                             18-27

-------
QUESTION:
ALEXANDER:
QUESTION:

ALEXANDER:
QUESTION:
ALEXANDER:
CONDENSED DISCUSSION
 At your terminals 1n  airports, you had
 uncontrolled emissions.  Is that looking at
 a tank without an internal floating roof?
 Yes, I took the Internal floaters and just
 factored them off as though they weren't
 there.  We've got other parts of the state
 in Virginia that have no hydrocarbon regula-
 tions at all and it's kind of useful for them
 to see what would happen if they had the same
 regulations that we have in northern Virginia.
 You did the analysis for July for the petrol-
 eum storage, etc?
 That's right.
 Now to put those emissions into prospective
 with other sources of hydrocarbons.  Did you
 also calculate hydrocarbons from other sources
 for  July?  Namely automobiles, natural
 sources, what have you?
 This is a very very good point.  If you are
 going to run a July Inventory for one source
 you should run it for all sources.  I regret
 to say that we simply don't have the technique
 to do this.
                                18-28

-------
QUESTION:
ALEXANDER:
Do you record any  relationship between July
inventory and the  rest of the other eleven
months of that year?  Is it 102, 20% higher
than an average month?
By comparing the 72 inventories that we had
made - the old July to new July 76 hydro-
carbons were up 70% on the basis of using
the July weather conditions as opposed to
averaging the month of July out of a 12
month inventory.
                               18-29

-------
       INVENTORYING HYDROCARBON EMISSIONS
         FROM SMALL GASOLINE BULK PLANTS
             Presented at the 1977
        Environmental Protection Agency
      Emission Inventory/Factor Workshop
Raleigh, North Carolina - September 13-15, 1977
                     By
        R.L. Norton and R.J. Bryan
    Pacific Environmental Services, Inc.
               1930 14th Street
       Santa Monica, California 90404
                      19-1

-------
      This paper describes the technique used to inventory hydro-




carbon emissions for nearly four hundred gasoline bulk plants in the




San Joaquin Valley and San Diego County areas of California, the




Metropolitan Denver area, and the Houston/Galveston and Baltimore/




Washington, D.C. air quality control regions.  Updated throughput




information and complete inventories of bulk plant operations were




obtained.  Emission estimates were generated for potential as well




as controlled hydrocarbon losses within each study region.  The




paper describes the emission factors used and the methodology for




presenting the emission estimates.




      Problems encountered while attempting to obtain the inventory




data are discussed and include: 1) the lack of an existing inventory,




2) the variation in the applicability of state regulations which in




turn effected the quality of the data available  (i.e. if the state




did not regulate the bulk plants, there would be no information on




them in their files), 3) inability to obtain operating data from some




sources because of confidentiality claims, 4) problems in verifying




all inventory entries from the various sources as bulk plants defined




by the study.
                                 19-2

-------
I.  Introduction




     Environmental Protection Agency (EPA) regulations for the




storage and transfer of gasoline require bulk plants in certain




specified air quality control regions to control hydrocarbon emis-




sions from their operations.  A recent Federal Register (June 7,




1977) defines these air quality control regions and gives background




information on the proposed regulations.  These regulations require




vapor recovery systems to be installed and operated in a manner




that will prevent release to the atmosphere of no less than 90 per-




cent by weight of organic compounds in vapors generated during gaso-




line transfer operations.  Individual states have submitted control




strategies in State Implemention Plans and enacted laws which fre-




quently provide for the exemption of small bulk plants from hydro-




carbon emissions control regulations.  Conditions for granting these




exemptions are not uniform among the states, e.g., throughput limits




often differ.  The rationale for allowing exemptions has generally




been based on the anticipated adverse economic impact to the indus-




try or on the estimated minor contribution of bulk emissions to the




area wide hydrocarbon/oxidant levels.




     In order to determine whether Federal vapor recovery regula-




tions need revision, the Division of Stationary Source Enforcement




(DSSE) contracted with Pacific Environmental Services, Inc. (PES)




to perform a preliminary investigation of the impact of vapor re-




covery regulations on small bulk plants.  This first study focused
                               19-3

-------
on bulk plants in the San Joaquin Valley and San Diego areas in

California and the Denver, Colorado area.  A similar survey of bulk

plant operations in the specific areas surrounding Baltimore, Mary-

land and Washington, D.C. and Houston/Galveston, Texas was also per-

formed to determine whether the descriptive, market and economic

data presented in the first report could be adequately applied to

other areas of the country.  The tasks completed for both studies

were quite similar:

     1.  Provide an inventory of bulk plants.

     2.  Describe facilities and vapor recovery equipment
         at the bulk plants.

     3.  Classify these bulk plants by throughput.

     4.  Determine types of customers and volume dis-
         pensed to non-exempt accounts, agricultural
         accounts and accounts with small tanks.

     5.  Determine the financial profile of typical
         bulk plants.

     6.  Estimate the long and short term economic
         effects of installing and maintaining vapor
         recovery equipment, particularly with respect
         •to the number of anticipated plant closures
         or plant start-ups.

     7.  Estimate emissions from bulk plant operations
         and the decrease in emissions if controls are
         adopted.

     This paper describes the survey techniques employed to inven-

tory nearly four hundred bulk plants in the study areas.  Methods

for formulating emission estimates and problems associated with

information gathering will also be discussed.  Because of the
                                19-4

-------
current EPA interest in bulk plants, sections have been included




on definition of emission sources and applicable hydrocarbon con-




trol concepts.








II.  Description of Bulk Plants




     A gasoline bulk plant lies in the gasoline marketing chain




between the large terminal and the ultimate end user.  The bulk




plant, normally found in the rural areas, serves small customers




where either the large truck transports cannot or will not deliver.




The studies, within which the inventories were conducted,  defined




the small bulk plant to be one whose daily throughput was less than




twenty thousand gallons of gasoline and one where all deliveries




are made to and from the bulk plant by road.  Although bulk plants




may handle a variety of products, including gasoline, fuel oil,




diesel fuel, etc., the derived emission estimates were only deve-




loped for gasoline.




     The typical facility, as defined by the surveys, consisted of




three or four above ground storage tanks, one delivery truck load-




ing facility, two delivery trucks and a. gasoline throughput of from




five thousand to eight thousand gallons per day.
                              19-5

-------
III.  Inventory of Bulk Plants




      A.  Information Sources




     The first step in inventorying the bulk plants in the five




study areas was to determine the quality of the existing data base.




The applicable EPA regional offices were contracted but little or




no data on gasoline bulk plants existed in their files.  Contacts




at the state agencies in the study area were obtained from the




applicable EPA offices.




     The quality of the data available at these agencies was usually




dependent upon whether or not the bulk plant emissions were covered




under an applicable State Regulation.  A fairly complete inventory




of bulk plants was provided by the Virginia State Air Pollution




Control Board and by the Maryland Bureau of Air Quality and Noise




Control for work in the Baltimore/Washington, D.C. AQCR.  The infor-




mation provided included:  1) plant name and location, 2) plant




gasoline throughput, 3) number and types of tanks, and 4) number and




types of trucks, but the Maryland data was from 1974 arid the Vir-




ginia data was from a 1972 survey.




     The California Air Resources Board was also contacted as to




the extent of data available on the number of bulk plants in the




San Joaquin Valley AQCR and in San Diego County.  The Air Resources




Board supplied a summary of bulk plant operations for each county




but did not indicate specific locations.  Since the purpose of the




studies was more than just an inventory and data was needed from the
                                19-6

-------
individual bulk plant operators, the ARE was again contacted and




asked if they could supply the data from which the summary was




made.  The resultant information supplied consisted of copies of




letter heads, business cards, return addresses and hand written




notes.  This information, which consisted of over 200 entries, was




then organized by counties and the totals checked against the sup-




plied summary data.




     An initial inventory of bulk plants was supplied by the Colo-




rado Department of Health, Air Pollution Control Division and supple-




mented by information from the Oil Inspectors Office.  PES was in-




formed that this inventory was the most up-to-date possible, but it




was later found to be inaccurate.  For example, the supplied list




consisted of approximately twenty bulk plants.   Four of these plants




were out of business and approximately twenty-five additional bulk




plants were identified.




     The Texas Air Control Board was also contacted.   There was no




data available in the Texas office since the State Regulations were




not applicable to bulk plants in the size range studied.




     When there was no available information from the State offices




or it was felt that the data might not be complete, the local air




pollution agencies in the study areas were contacted.  This includ-




ed fourteen agencies in California, two in Texas and one  in the




Washington, D.C. area.  The data obtained ranged from excellent to




none at all, aga^n, due mostly to the applicability of the local
                               19-7

-------
regulations.  In some cases, written requests or personal visits

were required to determine the availability of the data and to en-

sure that the data obtained was pertinent to the project.  Written

data requests for each bulk plant included the following:

     Bulk Plant Name
     Location
     Plant Contact (Owner/Operator)
     Gasoline Throughput
     Storage Tanks:  Number of Tanks
                     Above/Below Ground
                     Tank Capacity
                     Physical Size of Tanks
                     Splash/Submerged Fill
                     Vapor Recovery Apparatus (If Any)
                     Pressure-Vacuum Vent Setting & Type
     Plot Layout
     Delivery Trucks:  Size
                       Vapor Return
                       Splash/Submerged/Bottom Loading
     Loading Rack Controls:  Vapor Recovery System
                             Size of Vapor Return Line
     Accounts Breakdown  (% Commercial, % Agricultural,
                         And Percentage Exempt Under
                         Vapor Recovery Regulations

Letters were sent to the San Joaquin, Stanislaus and Tuolumne

County California Agencies and visits were made to the King and

Kern County Agencies in California, The Texas Air Control Board,

Houston Office and the Galveston County Health District in Texas,

and the Colorado Health Department.

     Governmental agencies were not the only sources of information

and often times not the most productive.  In each state Involved,

the applicable trade associations were contacted.  These included

the California Oil Marketers Association, Texas Oil Marketers

Association, Maryland Oil Jobbers Council, Virginia Petroleum
                              19-8

-------
Jobbers Association and the National Oil Jobbers Council.  In many




cases, the trade organizations were hesitant at first to supply the




information because they were not sure as to the ultimate use of




the data.  Once they were assued that the information and the pur-




pose of the project was not enforcement oriented, the data was




generally supplied on the location of bulk plant operations in their




regions.  However, this data was limited to operations or operators




that were members of these organizations.




     Representatives from the major oil companies operating in each




region were contacted as to the location of bulk plant operations.




In most cases, the oil companies would not release the information




because they felt that this was confidential.   Others could not




release the requested data because the operations were run by pri-




vate businesses and the oil companies did not have the details of




the business operations.  Where information was provided by the oil




company, (Standard Oil of California and Continental Oil Company in




Denver) the data was included in the respective county inventories.




     As a supplement to the sources of information already des-




cribed, telephone directories in the study regions were consulted




to ensure that all bulk plant facilities would be included in the




inventory survey.  The facilities developed from the several infor-




mation sources were arranged into county groups to constitute the




initial bulk plant inventory.
                              19-9

-------
      B.  Verification of Bulk Plant Inventory

     Once the initial list had been generated, it was decided that

a verification of the operations as bulk plants, as defined by the

studies, was necessary.  Types of information obtained from the

verification procedures included:

     •  identity of bulk plants which had shut down

     •  identity of plants included in the initial inventory
        which were not bulk plants as defined by the study

     •  identity of plants which had ceased handling gasoline

     •  identity of plants which had moved to locations not
        within the study boundaries.

     Verification procedures were performed by on-site visits, by

off-site visual verification or by telephone contact.  In the five

study areas, over eighty on-site visits were conducted and nearly

300 telephone contacts and visual verifications made.  Visual veri-

fications were often originally scheduled to be on-site visitations

but time restraints in the field would not allow interviews to be

conducted at each location.  These visual verifications were

followed up by telephone contacts to obtain additional data.

      C.  Data Gathering

     To obtain updated information on the bulk plants and to pro-

vide a current data base for the emission estimates, data gather-

ing was performed in conjunction with the various verification

procedures described previously.  The requested data included in-

formation on 1) plant gasoline throughput 2) storage tank number,
                               19-10

-------
size, contents and capacity, and 3) capacity and number of delivery




trucks owned by the bulk plant operator.  Forms were developed to




obtain the pertinent operating data, to obtain information on con-




trol approaches employed, and to obtain other data which was neces-




sary to complete the study.  A copy of the inventory questionnaires




is shown in Appendix A.




     The data gathering was conducted by on-site interviews with the




bulk plant operators and through telephone conversations.  As can




be expected, many of the operators and through telephone conversa-




tions.  As can be expected, many of the operators were reluctant




to release operating information on their particular businesses.




This was especially true of the independent operator.  The bulk




plants which were operated through the major oil companies, either




as consignees or as independent agents, were much more willing, on




the whole, to divulge throughput information.  In the case of a few




major oil company operated bulk plants, though, the requested infor-




mation would only be released after the operator received clearance




from his marketing manager.  This usually required PES to submit a




written description of the project and to describe the need for the




operating data.  In all cases it was considerably easier to obtain




operating data than it was to obtain financial data or the finan-




cial status of the operations, which was needed to complete the




study.




     When the verifications and data gathering tasks were completed,
                               19-11

-------
the county inventories were edited to include the most recent and




accurate operating data.  Tables I, II and III indicate summaries




of the bulk plant inventories.  Table I shows the average values




for all bulk plants within the California and Colorado study areas




and Tables II and III depict data from the actual interviews per-




formed by PES in the Houston/Galveston and Baltimore/Washington,




D.C. areas.  Table IV summarizes the data obtained in the PES bulk




plant inventories.




      D.  Problem Areas




     Several problems arose in obtaining the inventory data from




the numerous sources described above.  The lack of an existing in-




ventory in many areas made it- difficult to generate a basis for the




surveys.  The wide variability of the regulations from state-te-




state and county-to-county made data gathering very inconsistant.




While one county may have a detailed list of bulk plants, the




neighboring county may have no data at all.  In many cases, the




bulk plants were identified but the operators would not release any




operating data because of confidentiality claims.  Some operators




would not release data because they were unhappy with Federal vapor




recovery regulations and did not want to release information that




they felt might be used for enforcement purposes.




     Other problems arose in attempting to verify the initial en-




tries into the inventories as bulk plants defined by the study.




Since a bulk plant which had gone out of business could not be
                               19-12

-------
                    Table  I.   SMALL GASOLINE  BULK PLANT  INVENTORY,  SUMMARY
                                 OF  CALIFORNIA AND  COLORADO STUDIES


County




California
taador
Calaveras
Fresno
Kern
tings
Hadera
Harlposa
Merced
San Joaojjln
Stanislaus
Tulare
Tuoluane
San Diego
Colorado
Utm
Arapahoe
(oulder
Denver
Jefferson
Totals
California
Colorado
Survey
No.* of
Bulk
Plants





1
4
47
35
10
11
)
18
21
24
31
3
10

7
4
19
13
2

218
45
263
Avg.
Gasoline
Through-
put
Liters/
dtyb'




16,600
20,900
26,800
13,100
11,100
20,600
12.700
23.800
11.700
34.400
25.500
14,500
17,400

19.700
38,000
13,800
23,600
8.900

21,400
19.200
21.100
GASOLINE STORAGE TANKSC

Avo.
No. Of
Tanks




3.0
3.0
3.6
2.6
3.2
2.6
3.0
3.1
2.9
3.9
3.2
3.3
2.4

3.6
5.3
3.8
2.9
4.0

3.2
3.5
3.2
I of
Plants
with
Above-
Sround
Tanks
Only

100
67
66
77
80
73
33
71
67
73
52
100
40

8C
<7
94
50
100

66
79
68
V of
Plants
with
Under
Ground
Tanks
Only

0
33
21
23
20
27
67
29
22
9
45
0
60

14
33
6
50
0

28
21
27
Avg.
Storage
Capact ty
Liters"
xlO-3



101
113
227
144
165
163
156
196
177
204
178
2M
115

117
179
142
146
155

183
142
177

I of
with
Vapor
Recovery
On In-
eating
Loads


0
0
42
91
N.O.
0
33
78
29
100'
72
50
80

20
0
14
22
0

58
18
S3
OUTGOING LOADS

t of
Top
Load-
Ing



100
100
89
100
100
100
100
89
75
N.O.
97
100
40

100
100
93
90
50

90
92
90
Bottoa
Load-
ing



0
0
11
0
0
0
0
11
25
n.o.
3
0
60

0
0
7
10
50

11
8
10
Avg.
No. of
Trucks




N.O.
3.0
2.4
2.1
2.2
1.7
2.0
2.1
2.0
2.0*
2.2
2.0
2.2

1.7
2.0
1.4
2.1
l.S

2.2
1.7
2.1
I of
Plants
with
Sub-
Fill


100
N.0.0
70
90
100*
88
50
25
78
N.O.
79
100
90

N.D.
100
75
100'
N.O.

74
86
74
t of
Plants
with
Vapor
De-
covcry


0
0
5
0
0
0
0
11
0
N.O.
7
0
60

0
0
20'
0
0

9
7
9
CUSTOMER ACCOUNTS11

Avg. t
Sull
Agri-
cultural



60
S3
67
49
73
69
75
74
13
63
73
30
57

78
IB
60
1
15

64
44
61
Avg. I
Service
Stations




40
33
27
N.O.
13
31
13
17
44
16
15
52
43

1
57
39
18
50

23
31.
2$
MTES:  I - Plants stated to be operating at tlK of survey
       b - Divide by 3.785 to obtain gallons
       e - Where totals do not equal 100,  Indicates plants with
             both above- and underground  tanks
       t • N.D. • no data
• > Only one response
f - Only three responses
  S- Only four responses
  > Where totals do not equal 100, Indicates other types of
   accounts served (coaaercial. large agriculture, etc.)
                                                   19-13

-------
Table II.  SUMMARY OF DATA OBTAINED ON BULK PLANTS IN HOUSTON/GALVESTON AREA
- Clint Throughout
6*1 /Day
3.200
5.700
18.200
9.100
7,600
11.400
11.400
11.400
9,100
6.400
6,800
4,500
7,400
9.100
3.200
4,500
2.300
8,300
11.400
3.200
3.400
5.000
3.000
I/Day
12.100
21.500
68,800
34,400
28,800
43.000
43,000
43,000
34,400
24,100
25,800
17,200
28.000
34,400
12,100
17.200
8.600
31,500
43,000
12.100
12,900
18.900
11.200
Exempt Accounts
Farm
X
60
60
10
20
-
40
40
50
5
70
25
50
25
1
2
5
-
33
10
SO
80
25
80
Non-Fain
Tanks
X
40
40
90
10
-
20
40
40
85
29
40
30
65
20
2
0
-

80
48
20
75
20
Storage Tanks
Tanki
No.
3A*
3A
4A
3A
4A
3A
4A
5A
4A
3A
3A
3Uf
3U
3U
2U
2U
2U
3A
3A
3A
2A
3A
2A
Capacity
Thousand
Gal
29
38
50
51

55
48
60
50
36
SO
24
30
26
36
20
20
38
42
52
35
47
56
L
110
143
190
193

208
182
227
190
136
190
91
114
98
136
76
76
143
159
197
132
178
' 212
Vapor
Recovery

III"
Ic
I. IId, III
I. II. Ill
-
I. II, III
I. Ill
I. II, III
I. II. Ill
i. nr
i. ii. in
in
i. in
i. ii. in
i
None
-
None
I, III
I
None
I. Ill
None
Account
Trucks
Hater
3
2
2S«
3 S
2
2 S
2
3 S
2 S
2
3S
2
3
2 S
1
2
-
2
2
1
1
1
1
                                19-14

-------
    Table  II.  SUMMARY OF DATA OBTAINED IN BULK PLANTS IN HOUSTON/GALVESTON AREA (continued)
Plant Throughput
Gal/Day
7,700
19,000
12,500
2,300
21,600
4,500
7,300
18,200
UD«y
29,200
71.900
47,300
8,600
81,700
17,200
27,500
68.800
Exempt Accounts
Ftra
I
5
-
5
33
15
40
40
-
Non-Farm
Tanks
X
IS
-
30
67
25
0
0
-
Storage Tanks
Tanks
No.
4A
-
5A
3U, 6A
4A
4A
3A
4A
Capacity
Thousand
Gal
63
-
70
17
53
52
36
56
I
238
-
265
64
201
197
136
212
Vapor
Recovery

I, III
I. II. Ill
I. II. Ill
None
I. Ill
I, II
I, III
-
Account
Trucks
Number
2
-
3 S
1
3
2
2
-
*A • Abovegrotmd tank
bIII • Vapor Recovery Installed on tt leut one account truck
CI • Phase I Vapor control (Control of Inconlng gasoline transfers)
dlt • Hunt II Vapor control (Control of outgoing gasoline transfers)
*5 • Submersed fill
fU • Underground tank

-------
Table III.   BULK PLANTS  IN BALTIMORE/WASHINGTON  D.C. AREAS  INTERVIEWED  BY PES
PLANT
THROUSUPUT
Gal/Day
15.400
700
700
3.300
4.500
10.800
1.600
2.700
4.800
2.000
6.800
5.800
3.600
1,900
3,000
1,250
7.700
4,800
17.300
900
1.500
1.500
1.900
8.000
5.500
1,000
8,300
I/Day
58,000
2,600
2.600
12,000
17,000
41,000
6,000
10,000
18.000
7,500
26.000
22.000
14.000
7.300
11,000
4,700
29,000
18,000
66,000
3.300
5,500
5,800
7.300
30.000
21.000
3.900
32.000
RACK SALES
FARMS
I
0
75
0
75
7
25
95
3
75
?
15
75
75
78
65
10
5
30
?
80
25
85
70
5
50
75
50
SHALL TANKS!
I
70
85
60
100
97
71
99
20
95
7
25
95
75
99
100
95
90
30
75
80
45
99
90
50
100
99
99
GASOL
TANKS
Number"
2U
2U. 2A
6U
3D
3D
3A
2U
4A
4A
2U
3A
2A, 1U
3A
1U.3A
2U
3D
2A
2U
3D
1A.1U
2U.1A
2A.1U
2A
ZA
3U
5A
3A
NE STORAGE
CAPAC
THOUS
Gal
40
41
34
22
34
61
30
80
80
24
51
58
45
50
40
26
240
30
90
35
50
34
20
40
90
69
45
ITY,
AND
1
151
155
129
83
129
231
114
303
303
91
193
219
170
190
151
98
908
114
341
133
189
129
76
151
341
261
170 ,
VAPOR h
RECOVERY"
+


-
+

-
». i
.


»

-
+
+
.
+
+
+
.
-
-
-

.
+
ACCOUNT
TRUCKS^
Nusber
2
3S
IS
IS
IS
5S
IS
2*
•4S
1
5
1
IS
2S
IS
IS
45
35
IS
IS
1
2S
3S
1
2
4S
25
   'Tanks less  than 2,000 gal capacity  (7600 1)
   h/apor recovery systems  for control of Incoming loads. + • yes.  - - no; for control  of outgoing loads. I • yes
   CA11 plants  surveyed, except one marked with asterisk, used only top-loading account trucks.  S: lubccrged filling
    U - underground tanks;  A • abovegroimd tanks
                                               19-16

-------
                                       Table  IV.   SUMMARY  OF SHALL GASOLINE BULK  PLANT OPERATIONS

Ami
SU UliCUVU JU-
qvln Villir Anu
OMwr Art*
liltlion/
ItttMngton. D.C
KO-.ittO*/
G*lv«ttn Art*

M. «r
n«nu
21t

M

70

feultiw Stengt Tttiki
Throughput
llun/tty*
21,400
19,200
1(,900

11 ,(00

AM.
Mo. of
unit
1.2
l.S
1,0

3.S

I dull
tilt*
Starcgt
M
n
4!

to

1 Plinu
Kith
SUrtgi
21
tl
15

to


Storigt
Ctptcltjt
lltfjl'
1B3
142
1H

IK


•Ith Viper
M Inco^ng
U
11
n

?i

Outgotng lotos
1 J?
90
»1
M

M

t totui
10
I
4

M

AVI.
Ho. of
Trvckt
2.2
l.J
1.1

1.0

< Plinu
fllllnj
71
U
a

>4*

< riuitt
with Viper
fttcevtry
1
I
0

41

Cust«Mn Actounts
S Throtishptit
(4
44
44

-IS

"IT
~n
"«t
n

^>so

       l fill plpt> In ait traeU w« MI M O> lu«tx ricu.  If «)/
 praptrly «ul««a tnicki 
-------
contacted, this information had to come from other operators in




the area.  Some entries derived from local telephone directories




could not be located or contacted and the information again had to




come from a cooperative bulk plant operator in the respective area.








IV.  Estimating Emissions Based on Bulk Plant Inventory




     A.  Sources of Emissions




     Before the actual emission estimates could be performed, the




sources of the emissions had to be defined.  The hydrocarbon emis-




sion sources described here were determined from the numerous on-




site inspections and interviews performed by PES personnel.




     Emissions from bulk plants consist of vapor which can escape




from storage tanks, even when there is no transfer activity, be-




cause of changes in temperature of the tank wall and stored mater-




ials which vary the pressure in the vapor space.  Variation forces




vapor-laden air out of the tank and aspirates fresh air into the




vapor space, allowing further vaporization of gasoline into that




space.  The amounts of vapor escaping under these conditions are




referred to as "breathing losses."  Losses of vapors due to liquid




transfer forces air-hydrocarbon vapors out during filling of the




tank and ingests air (promoting evaporation) during draining.  Mis-




cellaneous or fugitive losses are primarily related to spillage and




leakage during gasoline handling.
                                 19-18

-------
     1.  Breathing Losses




     Factors affecting breathing or standing losses for fixed roof




tanks include the amount and volatility of the gasoline stored,




type and condition of tanks and appendages, and the prevailing




meteorological conditions.  If there are no leaks or direct open-




ings, temperature fluctuation is the major cause of breathing




losses.  As the temperature of the liquid rises, the vapor pressure




increases and evaporation takes place.  The overall pressure in the




gas space increases and when the vent pressure set point is exceed-




ed, a mixture of air and hydrocarbons is discharged into the air.




As the temperature decreases, gases partially condense, contract,




and fresh air is drawn into the vapor space.   This permits addi-




tional hydrocarbons to vaporize.  Since hydrocarbons are emitted,




but generally not drawn back into the tanks,  a continued loss of




hydrocarbon results from the daily changes in ambient temperature.




     2.  Working Losses




     The principal cause of vapor loss during liquid transfer is




displacement of the gas (air laden with hydrocarbon vapors) in the




vapor space by the liquid entering the tank.   Other causes include




the entrainment of liquid droplets in the displaced gas and post-




withdrawal pressure increase caused by evaporation.




     Certain operating conditions can increase or decrease these




vapor losses.  Splash loading in which gasoline is dumped onto the




surface of the liquid causes turbulence which increases evaporation
                              19-19

-------
rates and entrainment of droplets in the vapor being displaced.




A short interval between emptying and filling of storage tanks can




decrease losses by minimizing the time allowed for evaporation.




Also, storage tanks can be emptied in increments over a period of




several days or can be emptied in one operation prior to refilling,




with resultant differences in vapor loss.




     Assuming no controls, each time a gasoline tank is filled, the




vapors above the liquid surface are emitted to the atmosphere.  The




quantity of hydrocarbon vapors emitted is a function of the volume




displaced, type of loading, temperature and the degree of saturation




of the vapor space with gasoline vapors.  At any given temperature,




the amount of vapor in the vapor space cannot exceed a limit imposed




by the saturation pressure corresponding to that temperature.  This




limit, however, increases as the temperature increases.




     In a quiescent state, the approach of saturation and pressure




increase of a vapor space with gasoline vapors is a slow process.




Since hydrocarbon vapors are heavier than air and diffusion is slow,




a saturated blanket of vapor initially forms over the liquid sur-




face, decreasing the driving force for further vaporization.  Also,




with evaporation of the lighter hydrocarbon molecules, the tendency




of the components in the stagnant surface to vaporize decreases.




Thus, the degree of saturation in the overall gas space of a tank




can be decreased by minimizing liquid surface and vapor space mix-




ing during the filling operation.
                                19-20

-------
     Splash loading not only creates droplets which can be en-

trained in the outgoing effluent and exposes fresh liquid surfaces,

but results in mixing of the vapor space as well.  This mixing of

the vapors disturbs the saturated blanket near the liquid surface,

increasing the driving force for further vaporization.  Hydrocarbon

emissions under splash filling conditions can significantly exceed

that calculated by assuming saturation.

     Another factor which can affect the quantity of hydrocarbons

emitted is the interval between drainage and filling.  When a tank

is drained and immediately refilled, the air drawn into the tank

during draining may be expelled with relatively little hydrocarbon

content.  In a tank allowed to sit after draining, the air drawn

into the vapor space becomes saturated with hydrocarbons, thus,

increasing pressure (and emissions)  and resulting in the maximum

loss of vapor during refilling.

     Another operational procedure which may increase losses is the
\
small sequential withdrawals of gasoline from a storage tank over

a period of several days rather than one continuous large with-

drawal.  After a small withdrawal, the post-transfer emissions

caused by evaporation tend to be high in hydrocarbons since little

air is ingested during the withdrawal.   After a large withdrawal,

the initial post transfer emissions are low in hydrocarbons since

large amounts of air are ingested during the withdrawal.
                               19-21

-------
     3.  Miscellaneous Losses



     Miscellaneous losses have been found to be highly variable.



These losses Include spillage, liquid and vapor leakage and opera-



tional losses which occur when opening tank hatches for visual



inspection or measuring liquid levels with dip sticks.  Leakage can



occur and has been observed at dry breaks, pressure vacuum valves,



hatches, manholes, pump seals, shut-off valves and piping joints.



It has been visually observed that some spillage (on the order of



half liter) occurs when connecting and disconnecting transfer lines.



Visible liquid leakage at dry breaks (few milliliters of gasoline)



was observed from the connections after transfer.  Opening of



hatches of an empty truck to verify that they have received all the



gasoline expected.



      B.  Control Concepts




     When estimating emissions from an operation it is imperative



that knowledge of the control concepts and how they effect the



emissions are available.  The controls that were used as determined



by the survey are discussed  in this section.



     1.  Breathing Losses




     Storage tanks are subject to evaporation or standing losses



due to volatility of the material stored, type and condition of the



tank and its appendages and  prevailing meteorological conditions.



The simplest methods for reducing these venting  losses are to  (1)



inspect and repair leaks in  the  tank and  fittings,  (2) paint the
                               19-22

-------
tank with white paint where possible, (3) assure that vent valves




do not leak and (4) set the pressure and vacuum relief settings to




minimize breathing.  The broader the band for the vent valve set-




tings, the lower will be the breathing losses.




     Another method for preventing vapor loss is to install vapor




recovery equipment at the vent valve.  For vapor recovery, the




vented vapor must be able to be condensed and recycled to the tank




or be collected and regenerated.  For prevention of pollution only,




the vapors can be combusted or collected and disposed of in some




approved manner.




     2.  Working Losses




     Excluding spillage, the two major sources of loss of gasoline




vapor during transfer are .1) venting to the atmosphere the volume




of gases—air and hydrocarbons—displaced by the entering liquid




and 2) filling in a manner which creates turbulence which results




in increased vaporization rates and liquid droplet entrainment in




the vapor space.




     The most common current methods of reducing working losses are




to use submerged filling for the loading of gasoline and to install




a vapor balance system between the vapor spaces of the tanks con-




nected during the gasoline transfer.




     a.  Submerged Fill




     Submerged fill is the introduction of liquid gasoline into the




tank being filled with the transfer line outlet being below the
                               19-23

-------
liquid surface.  This is compared to splash loading, where the




transfer line outlet is at the top of the tank.  Submerged filling




minimizes droplet entrainment, added vaporization and turbulence.




If a fill port is located at the tank top, submerged fill is accom-




plished by either extending the nozzle (commonly referred to as




stingers) or permanently attaching to the fill port a pipe extending




to within 6 inches  (15 cm) of the tank bottom.  This permanent




installation is commonly referred to as a drop tube.




     Aboveground storage tanks normally include submerged fill.




Submerged fill for underground storage tanks can be accomplished by




attaching a pipe to the fill port.  These installations were common




on underground tanks in surveyed areas.




     Bottom loaded  trucks by definition include submerged filling.




Top loaded trucks utilize an extension such as a pipe or flexible




hose on the loading arm, or a pipe can be permanently attached to




the trucks.




     Submerged filling of customer tanks can be accomplished with




either nozzle extension or a permanently attached drop tube.  Some




difficulties have occurred with the installation and use of per-




manent drop tubes.  One problem is "spit back."  "Spit back" is the




return flow and spillage of gasoline at the fill port during trans-




fer.  This appears  to be primarily related to  the smaller fill port




and drop tube sizes in customer tanks, compared to service station




tanks, and the lack of a coupling at the fill  port interface.  Use
                               19-24

-------
of a nozzle extension with or without a permanently Installed drop




tube or a coupling should solve the "spit back" problem.




     b.  Balance System




     Probably the most common vapor recovery system currently in use




is the vapor balance system.  Efficiency is good for the control of




working losses, but not significant in controlling breathing losses.




A pipeline between the vapor spaces of the truck and storage tanks




essentially creates a closed system permitting the vapor spaces of




the tank being filled and the tank being emptied to balance with




each other.  The net effect of the system is to transfer vapor dis-




placed by liquid into the tank in which draining of the liquid




creates additional vapor space.  This prevents the compression and




expansion of vapor spaces which would otherwise occur in a filling




operation.  If a system is leak tight, very little or no air is




drawn into the system and venting dur to compression also is re-




duced substantially.  The system is applicable to underground and




aboveground storage facilities equipped with either bottom or top




loading, and are applicable to both incoming and outgoing transfers.




     c.  Secondary Control Systems




     Secondary control systems, such as refrigeration, oxidation,




adsorption, etc., were found in only one of the study areas, San




Diego.  Many systems had been initially installed but only one such




system was operating.  This vapor recovery system employed a re-




frigeration unit to reduce pressure in the storage tanks and there-
                               19-25

-------
by to minimize venting.  In this system, vapors were drawn from the




storage tanks by a blower, passed over cooling coils in the re-




frigeration unit and exhausted back to the storage tanks through




an insulated return line.  The system made no effort to condense




vapors but was designed strictly to maintain a constant temperature




in the storage tanks (in this case 60°F) and thereby maintain a




pressure below the venting level.




     3.  Efficiencies




     For determination of the emission quantities, efficiencies




corresponding to the described control concepts had to be generated.




These were based upon test results, emission factors and litera-




ture.  Submerged fill resulted in an emission reduction of 58.6%




from transfer losses based upon emission factors used.  The balance




system efficiency was estimated at 90% based upon actual test re-




sults.  The efficiency used for the secondary system was also 90%




based upon test data.  This perhaps is low but only one such system




was in operation out of the nearly four hundred bulk plants surveyed




,and it was felt that this error was very minor.




     C.  Development of Emission Factors




     The actual hydrocarbon emission factors were determined by




using emission formulas, such as API formulas for storage tank




losses, and data on typical bulk plants, as described by the inven-




tories.  For example, the API equation for the breathing losses



from fixed roof tanks is:
                                19-26

-------
     L = 2.21 X 10-*M (U.7P. p )°'68 a1'" H°-51 I°-5°Fp CK
     Where:
     L = Fixed roof breathing loss (Ib/day)
     M = Molecular weight of vapors lost (Ib/lb mole)
     P = True vapor pressure of liquid at bulk liquid temperature
         (psia)
     D = Tank diameter (ft)
     H = Average vapor space height (ft)
     T = Average daily ambient temperature change ( F)
     F = Paint factor (dimensionless)
      P
     C = Adjustment factor for small diameter tanks (dimensionless)
     K = Adjustment factor dependent on product stored
         (Dimensionless = 1 for gasoline)
Typical values for bulk plants in the study areas were as follows:
     M = 66
     P = 42,800 newtons/sq meter (6.2 psia, for RVP-10 gasoline
         at 70°F)
     D = 3.2 meter (10.5 ft survey average)
     H = 4.0 meter (13 feet, 1/2 survey average tank height)
     T = 8.3°C
     F = 1.24 for white roof and specular aluminum shell in poor
         condition, condition based on survey observations)
     C = 0.55
By substituting these values into the equation, an emission factor
of 6.7 Ib/day/tank was obtained.  In many of the counties surveyed,
actual throughput data was not obtained for each bulk plant loca-
tion.  Since the purpose of the emission inventory was to develop
total emissions from bulk plants in the study regions, an average
throughput for the particular county or region was determined from
the survey data and applied to all bulk-plant operations within the
study areas.
                                19-27

-------
     The emission factors derived for the estimating procedures
were:
     Fixed Roof Storage Tanks:  Breathing Loss  6.7 Ib/tank/day
                                Working Loss    9.7 lb/1000 gal.
     Truck Loading Losses:      Splash Fill    14.0 lb/1000 gal.
                                Submerged Fill  5.8 lb/1000 gal.
     Miscellaneous Losses:                      3.2 lb/1000 gal.

      D.  Emission Estimates
    . Emission estimates based upon the bulk plant inventories were
generated for all regions.  As an example, emission estimates for
the bulk plants in the Houston/Galveston area were calculated for
uncontrolled sources, for emissions from bulk plants with current
vapor recovery controls, and emissions from bulk plants with poten-
tial control under the existing Texas SIP regulations.  For esti-
mating uncontrolled  emissions, it was assumed that no vapor re-
covery equipment was installed and that all tank fillings and trans-
fers to account trucks were by splash filling.  This would amount
to the worst case emissions.  For the purposes of these calcula-
tions, the  average annual throughput of gasoline through each bulk
plant was 2,203,000  gal  (8,338,000.1), based upon the PES bulk
plant sample.  Also  for  the purposes of these calculations, seventy
bulk plants were assumed to be operating in the area.
     The uncontrolled emissions from the bulk plants in the
Houston/Galveston area were:
                               19-28

-------
     Breathing losses from aboveground tanks -
          236 tons/year (214 metric tons/year)

     Working losses from all bulk plant storage tanks -
          737 tons/year (tt8 metric tons/year)

     Transfer losses from filling account trucks -
          1063 tons/year (964 metric tons/year)

     Transfer losses from filling account storage tanks -
          1063 tons/year (964 metric tons/year)

     Miscellaneous losses -
          243 tons/year (220 metric tons/year)

     Total uncontrolled hydrocarbon emissions -
          3342 tons/year (3031 metric tons/year)

The emission factors used for these emission estimates were the

same as those listed in the previous section.

     To determine current emissions from bulk plants, data on
                             *
Phase I and Phase II controls  installed were obtained from the

PES bulk plant survey.  From this data, it was found that 75% of

all the bulk plants had installed Phase I vapor recovery.  Phase

II controls were installed at 36% of all the bulk plants.  Vapor

recovery had been installed on at least one truck at 68% of the

facilities.  For calculation purposes, it was assumed, since most

bulk plants had one truck with vapor recovery and one without, that

the deliveries which went to exempt accounts, i.e., farm accounts

and tanks less than 2,000 gal (7,600 1.), were made with the

delivery truck which had no vapor recovery.  From the PES survey,

the average bulk plant delivered 50% of its gasoline — 67% of its
*Definition of Phase I and Phase II controls found in Table II
                              19-29

-------
accounts — to exempt accounts.  An efficiency of 90% for the

Phase I and Phase II controls was used.

     The hydrocarbon emission estimates for the bulk plants in the

Houston/Galveston area incorporating current vapor recovery control

installations were:

     Breathing losses from aboveground tanks -
          236 tons/year  (214 metric tons/year)

     Working losses from all bulk plant storage tanks -
          239 tons/year  (217 metric tons/year)

     Transfer losses from filling account trucks -
          791 tons/year  (718 metric tons/year)

     Transfer losses from filling account's storage tanks -
          638 tons/year  (579 metric tons/year)

     Miscellaneous losses -
          243 tons/year  (1948 metric tons/year)

     Total hydrocarbon emissions incorporating current control
     practices -
          2148 tons/year (1948 metric  tons/year)

Under current control practices, a 67.5% reduction in working

losses,  a 25.6% reduction in transfer  losses involving account

trucks and a 40% reduction in  transfer losses involving account

tanks served have been accomplished.   This is an overall hydro-

carbon emission reduction of 35.7% representing 1,194 tons/year

 (1,083 metric tons/year) from  all bulk plant emission sources.

     To  determine the amount of potential reduction of the hydro-

carbon emissions, the vapor recovery and emission controls as out-

lined in the Texas SIP regulations were extrapolated for the gaso-
                               19-30

-------
line throughput used above.  This would mean that Phase I controls

would be installed on all bulk plants, Phase II controls on the

racks would be used on all non-exempt deliveries and submerged fill

pipes would be installed on all non-exempt tanks.  The SIP regula-

tions, as written, do not require any controls to limit storage

tank breathing losses and miscellaneous losses (i.e., spillage) so

these emissions levels do not vary.

     The hydrocarbon emission estimates for the bulk plants in the

Houston/Galveston area incorporating potential vapor recovery con-

trols were:

     Breathing losses from aboveground tanks -
          236 tons/year (214 metric tons/year)

     Working losses from all bulk plant storage tanks -
          74 tons/year (67 metric tons/year)

     Transfer losses from filling account trucks -
          585 tons/year (530 metric tons/year)

     Transfer losses from filling account's storage tanks -
          585 tons/year (530 metric tons/year)

     Miscellaneous losses -
          243 tons/year (220 metric tons/year)

     Total hydrocarbon emissions incorporating potential emission
     controls under Texas SIP regulations -
          1723 tons/year (1562 metric tons/year)

Under potential control strategies presented in the Texas SIP

regulations, a 90% reduction in hydrocarbon working losses from

bulk plant storage tanks and a 45% reduction of transfer losses to

both account trucks and account tankage would be experienced.
                              19-31

-------
This would yield an overall bulk plant emissions reduction of




48.5% or 1620 tons/year (1469 metric tons/year).  If it is assumed




that all deliveries made from the bulk plant would require Phase II




controls, not just non-exempt deliveries, a further reduction in




bulk plant emissions would occur.  The overall bulk plant hydro-




carbon emissions would then be reduced to 1244 tons/year (1128




metric tons/year).  This would then indicate an overall emissions




reduction of 63% or 2098 tons/year (1903 metric tons/year).




     Not only were emission estimates supplied to show the effect




of control strategies, but also to illustrate how proposed or




possible regulatory strategies would effect the emission quantities.




An example of this is shown in Table V, illustrating how potential




regulatory actions would effect emissions from bulk plants in the




Houston/Galveston area.
                              19-32

-------
                                                 Table V.   SUMMARY  OF DECREASE IN  EMISSIONS FROM BULK PLANTS IN HOUSTON/GALVESTON AREA AS  FACILITIES
                                                                            COMPLY WITH HYDROCARBON VAPOR RECOVERY REGULATIONS
£
U)



Facility Description

Vapor recovery on all bulk
plant operations and account
tanks
Total compliance with currant.
approved 5IP Regulations.
Total Gasoline Throughput
220,000 Gal/Mo.
Total Gasoline Throughput
24,000 Gal/Day
Throughput to Non-Exeupt
Accounts 22.000 Gal/Day
Throughput to Non-Exempt
Accounts 22,000 Gal/Day or
Total Gasoline Throughput
24,000 Gal/Day
Total Gasoline Throughput
28.000 Gal/Day
Total Gasoline Throughput
28,000 Gal/Day or Throughput
to Non-Exempt Accounts 22,000
Gal/Oay
Total Gasoline Throughput
212.000 Gal/Day
Total Gasoline Throughput
212,000 Gal/Day or Throughput
to Non-Exempt Accounts
22,000 Gal/Oay
Total Gasoline Throughput
220,000 Gal/Dayd
No Plants In Compliance
Nunber
of
Plants
Affected


70

70

70

54

36

34



29

20


11

9



2

0
EMISSION ESTIMATE

TOTAL

T/Yrb
765
1723


1723

2095

2499

2566



2678

2872


3084

3132



3294

3342
MT/Yrc
693
1563


1563

1900

2266

2326



2428

2604


2796

2840



2986

3030
Breathing
Losses
From Above
Ground Tanks

T/Yr
236
236


236

236

236

236



236

236


236

236



236

236
KT/Yr
214
214


214

214

214

214



214

214


214

214



214

214
Working
Losses from
All Storage
Tanks

T/Yr
74
74


74

226

392

419



465

545


631

651



717

737
HT/Yr
67
67


67

206

356

380



422

494


672

590



650

668

Transfer Losses To
Account Trucks

T/Yr
106
585*


585

695

814

834



867

924


987

1001



1049

1063
MT/yr
96
531


531

630

738

756



786

838


895

908



951

964
Account Tanks

T/Yr
106
585


585

695

814

834



867

924


987

1001



1049

1063
MT/yr
96
531


531

630

738

756



786

838


895

908



951

964

Losses

T/Yr
243
243


243

243

243

243



243

243


243

243



243

243

MT/Yr
220
220


220

220

220

220



220

220


220

220



220

220
                                        'it Is assumd that deliveries to exeapt accounts are done with trucks without vapor recovery
                                        ""T/Yr • Tons/Years
                                        cMT/Yr • Metric Tons/Year
                                        ''Current Texas State Regulation V Incorporates this exemption

-------
V.  Conclusions




     Based on the inventories completed in the five study areas,




it can be concluded that data on small bulk plants in other areas




of the county are very limited.  Specific bulk plant inventories




would be necessary in these areas.  Even if an inventory exists,




it may be quickly out-dated because of the rapid changes in




current gasoline marketing trends.




     The direct inquiry approach to obtaining inventory data was




very successful especially for obtaining information on control




concepts currently employed in the field.  Enough information to




successfully complete the study objectives was gathered without




having to resort to Form 114 letters.




     Finally, the current hydrocarbon emission levels from small




bulk plants can vary considerably from region to region.  (For




example, hydrocarbon emissions from the seventy bulk plants in the




Houston/Galveston area are currently 2148 tons/year while the




hydrocarbon emissions from the .fifty-six bulk plants in the Balti-




more and National Capital AQCR's totalled only 725 tons/year).




The variation is due mostly to the number of operating bulk plants,




the accompanying throughput, and the controls currently being used.
                              19-34

-------
Bibliography

R.J. Bryan, M.M. Yamada and R.L. Norton.  "Effects of Stage I Vapor
     Recovery Regulations on Small Bulk Plants and on Air Quality
     in the Washington, D.C., Baltimore, Maryland and Houston/
     Galveston, Texas Areas."  Pacific Environmental Services, Inc.
     under EPA Contract No. 68-01-3156, Task No. 28, March 1977-

R.J. Bryan, R.L. Norton and P.S. Bakshi.  "Compliance Analysis of
     Small Bulk Plants."  Pacific Environmental Services, Inc.
     under EPA Contract No. 68-01-3156, Task No. 17, October 1976.

R.J. Bryan, W.O. Jacobson and R.R. Sakaida.   "Study of Gasoline
     Vapor Emission Controls at Small Bulk Plants."  Pacific
     Environmental Services, Inc. under EPA Contract No. 68-02-
     3156, Task No. 15, October 1976.

"Revision of Evaporative Hydrocarbon Emission Factors."  Radian
     Draft Report No. 100-086-01, June 15, 1976.

Applicable SIP Regulations on Gasoline Transfer Vapor Control:

     40 CFR52 - Subpart F - California    52.255

     40 CFR52 - Subpart G - Colorado      52.336

     40 CFR52 - Subpart V - Maryland      52.1101

     40 CFR52 - Subpart SS - Texas        52.2285
                                          52-2286

     40 CFR52 - Subpart W - Virginia
                               19-35

-------
        APPENDIX A




SMALL BULK PLANT EVALUATION
           19-36

-------
                   SMALL BULK PLANT EVALUATION




1.    Owner Operator 	




      Address
      Contact 	Phone (   )
2a.   Gasoline throughput 	 gallons/month




2b.   Grades of gasoline 	
3a.   Other products sold
3b.   Percentage of business selling gasoline




4.    Underground tanks - number 	




        Capacities 	
5.    Aboveground tanks - number




        Capacities 	




6.    Top loading 	
      Bottom loading




      Submerged fill
7.    Supply vehicles owned by




        Number
        Capacity
        Frequency of delivery
8.    Delivery vehicles owned by




        Number 	




        Capacity 	
        Time to fill
                               19-37

-------
 9.   Fugitive emissions
10.   Vapor Recovery, Deliver Vehicle




      Date installed 	by whom




      Cost 	




      Bottom or Top Load 	




      Operating Problems 	
11.   Vapor Recovery Storage Tank/incoming loads




      Date installed 	by whom	




      Cost 	




      Operating Problems 	
12.   Vapor Recovery, Storage Tank/Loading Rack (Delivery)




      Installed 	by whom	




      Installation Cost 	, Operating Cost	




      Maintenance Cost 	




      Operating Problems 	
13.   Vapor Recovery, Delivery Vehicle




      Installed 	by whom
       Installation  Cost	Operating Cost



       Maintenance Cost 	



       Operating Problems 	
 14.    Percent Deliveries  to Exempt Customers



       Type  of Exemption:  Agricultural 	
                           Small Tanks 	 Size



                           Other
                                 19-38

-------
      Of Non-exempt customers, what vapor control techniques




      are being used 	
15.   Assume vapor recovery will initially cost $20,000 and opera-




      ting costs increase 20%.




      a) Would you stay in business




      b) Could you obtain loan 	Down payment required 	




      c) Comments




      Repeat for $10,000 	$30,000	
16.   What could you sell your trucks,  facility,  accounts receivable




      and good will for $	




      What did you originally invest $	




17.   Present margin 	




      Annual sales $	Gallons 	




      Profit $	




      Debts $	




18.   Debt-equity or debt-total assets  ratio 	
      Rate of return on total assets or net worth




      Break even point 	
      Assessed valuation
19.   Comments - Closures,  Competitors,  bottom loading,  etc.
                                19-39

-------
                                               P-193
 AN ORGANIC SPECIE EMISSION INVENTORY FOR
         STATIONARY SOURCES IN THE
      LOS ANGELES AREA - METHODOLOGY
                    By

        Harold J. Taback, KVB, Inc.
       Tim W. Sonnichsen, KVB, Inc.
        Nicholas Brunetz, KVB, Inc.
Joan L. Stredler, Abacus Programming Corp.
                   For

    EMISSION INVENTORY/FACTOR WORKSHOP
           September 13-15, 1977
                Raleigh, NC
                   20-1

-------
                              TABLE OF CONTENTS

Section                                                           Page No.
 1.0    INTRODUCTION                                                  1
 2.0    INVENTORY DATA PROCESSING                                     4
        2.1  Data Sources                                             4
        2.2  Data Management                                          9
 3.0    EMISSION PROFILES                                             13
        3.1  Description                                              13
        3.2  Methodology                                              14
 4.0    EMISSION FACTORS                                              18
        4.1  Point  Sources                                            18
        4.2  Area Sources                                             23
 5.0    FIELD  TESTING                                                31
        5.1  Field  Measurements and Sampling                          32
        5.2  Laboratory Analysis                                      38
        5.3  Quality Control                                          42
        REFERENCES                                                    43
                                      20-2                     P-193

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                                 SECTION 1.0
                                 INTRODUCTION

        To provide detailed data on which to model the photochemical formation
of atmospheric oxidants and haze and to provide information on which to base
comprehensive control strategy, an inventory of gaseous organic emissions
from stationary sources was conducted for a district in California known as
the South Coast Air Basin.  This region includes portions of Santa Barbara/
Ventura, Los Angeles, Orange, Riverside, and San Bernardino Counties.  Unlike
most organic emissions inventories in the past, this study included the de-
velopment of emission profiles, i.e., a breakdown of the individual organic
species which contributed at least 1% of the total organic emissions from
each source.  From one to 30 different species were identifed in the emission
profiles which were developed for 200 sources by a comprehensive field samp-
ling and laboratory GC-MS analysis program.
        The  inventory accounted for all known stationary source organic
emissions including major and minor point sources and area sources (oil pro-
duction fields, architectural coatings, domestic solvent usage, etc.).*  The
inventory was prepared in the EPA's Emission Inventory Subsystem (EIS)  format.
All sources were located by Universal Transverse Mercator (UTM) coordinates.
        A three-phase approach wastaken in conducting the program.  First,
a preliminary inventory of total organics (without specific species)  was pre-
pared to identify the major sources and to determine the distribution of emis-
sions among the various source types.  Next, a field test program was con-
ducted to characterize emissions from sources selected on the basis of the
preliminary findings, emphasizing those source types comprising the greater
amount of the emissions.  Test results were augmented by questionnaire
*A major point source was  defined as  any emission source  belonging to  a
 point with total organic  emissions of more than 25 tons  per  year.

                                     20-3                       P-193

-------
responses and literature data in establishing both emission factors and
emission profiles  (% composition by weight).  In the third phase, a final
 inventory will  be created from the preliminary  inventory by  the  addition of
 emission profiles and new sources  (especially area sources)  and  the updating
 of emission factors.
        'ro appreciate  the approach taken in this inventory, it is important
to understand the potential magnitude of the task and the budget which was
allocated  for the program.   There were over 50,000 active permits cover-
ing the sources in  the various  county districts.   The final inventory
will account for over  8,000 major point sources of organic emissions plus
minor point sources (which include gasoline stations) and area sources.  The
total effort budgeted  for-this  program, including  field  testing, laboratory
analyses,  other data collecting, data analyses and processing, as well as
the overall program management, was only eight people for one year plus
expenses  (computer, travel, equipment, etc.).  Thus, maximum use was made of
existing  information.  The new  research performed on the program was to:
         1.  Provide information where none existed
         2.  Check  the  validity  of  existing data, and
         3.  Update  existing data to reflect current trends.
         The characterization of refinery emissions was an example of  how
 judiciously the test program was designed.   In the late 1950's the Los
 Angeles APCD and EPA  spent an 8-10 person effort for more than two
years to characterize  total hydrocarbon emissions  from  the refineries  in the
 Basin.   The EPA is currently  sponsoring a program  to measure refinery  emis-
 sions alone with a budget that is'three times greater than the one available
 on this program in which all  of the emissions in one of the  largest industrial
 areas of the  country  has to be  characterized.  This program  afforded a total
 refinery testing effort  of five weeks with a  crew  of  four.   Thus  testing was
 primarily directed at obtaining emission profile data and checking the emis-
 sion  factors  developed on the 1950's project.
                                       20-4

-------
        The  inventory was conducted by KVB,  Inc.  under sponsorship of the
 California Air  Resources Board (ARE)* as part of a total program which also
 included a study  of control systems and a  10 year projection of emissions.
 Preliminary  inventory data, EIS  format data  and technical advice on emissions
 and data processing were received  from the South  Coast Air Quality Management
 District  (SCAQMD)  and the APCD's of Ventura  and Santa  Barbara Counties.
GC/MS analyses of emission samples and advice on  the development of the field
sampling train were provided by Analytical  Research Laboratories, Inc. (ARLI)
of Monrovia,  CA,  Mr. M. L.  Moberg, President and Chief Chemist.  Data
quality and evaluation was performed by EcoScience Systems, Inc. of Riverside,
CA, Dr. James N. Pitts, Jr., President and  Principal Consultant.  Data manage-
ment and computer programming were provided by Abacus Programming Corporation
of Santa Monica, CA, Mr. Calvin Jackson, Vice President and Director of Pro-
duction.  The Western Oil and Gas Association provided guidance and assistance
in the petroleum industry aspects of the program.   A special measurement of
refinery emissions using ambient testing and  diffusion modeling techniques
was performed by Aerovironment, Inc. of Pasadena,  CA, Mr. Ivar Tombach,  Vice
President and Program Director.
        At this writing the final emission  inventory had not been compiled
pending the completion of EIS data entry and  checkout by the SCAQMD and  the
APCD's.  In this paper the methods used to  collect, formulate and process
the inventory data are presented.  It is estimated that the inventory itself
will be published by the end of 1977 along  with a  comprehensive engineering
report.
*Dr. John R. Holmes, Research Division,  Chief,  and Mr.  Jack Paskind,  Research
 Project Officer.
                                     20-5
                                                                P-193

-------
                                 SECTION 2.0
                          INVENTORY DATA PROCESSING

2.1     DATA SOURCES
        The data used in this organic emission inventory were obtained from
the following sources:
        1.  Various government agency files
        2.  Field testing
        3.  Questionnaires
        4.  Literature
        5.  Engineering analyses
        6.  Personal contacts with government and industry personnel.

        All county enforcement agencies were in the process of a total recom-
pilation of their permit files using the EPA's EIS/P&R*  (Ref. 1) format
 (referred  to as EIS hereafter) during the period of this inventory.  The
computerized permit file from Los .Angeles County and  the permit files from
the other  counties were used to obtain data for the preliminary inventory.
It was planned that the final inventory would be compiled using the new EIS
data base  for the major point sources as soon as data entry was completed
and checked  for all counties in the inventory.  The following key data were
contained  in the EIS  data  base:
         1. Plant name, address,  ID No., etc.
         2.  Standard  Industrial Code  (SIC)
         3.  Source Classification Codes  (SCC)
         4.  UTM Coordinates
         5.  Stack Height
         6.  Pollutant Identification
         7.  Emission  Factor
         8. Throughput Rates
*Emission  Inventory Subsystems/Permit and Registration
                                      20-6                      p-193

-------
        9.  Estimated emissions
       10.  Seasonal variations
       11.  Operating period  (hr/day, day/week, week/yr)

        For minor sources in  LA County, the original permit file was used.
Also a computer tape file of gasoline station locations in LA County was
received from the  SC AQMD.  Both of these files had location coordinates on
a one mile square grid basis.  The ARE provided an algorithm for converting
the one-mile grid to UTM coordinates (Ref. 2).
        The ARE also provided a tape file of population by UTM coordinates
which was used to distribute population related area source emissions.
        Field test data were used to formulate emission profiles and to
develop emission factors for new sources or check those factors on sources
already characterized by the districts or the EPA in AP-42 (Ref. 3).
        Questionnaires were received from approximately 100 industrial
sources with comprehensive data on their solvent and fuel usage.  Data
received were used to develop emission profiles  and to check values con-
tained in the district files.
        There was a great deal of activity in the area of organic emission
assessment by other agencies and contractors.  A list of those programs which
provided valuable data for this inventory are summarized in Table 1.  Excellent
cooperation and data exchange were maintained with those contractors and
agencies listed.
        Other sources of information included personal contacts with various
industry associations (dry cleaning, refinery,  asphalt, printing, etc.)  and
government agencies (especially the ARB, California Division of Oil and Gas,
EPA Office of Air Quality Planning and Standards in Durham, EPA Region 9,
local air pollution districts and the Southern California Association of
Governments, SCAG).
        From data received from the above sources, comprehensive analyses were
conducted to derive emission profiles in a form compatible with the inventory
format.  Analyses of test data from this and related programs listed in Table
1 were performed to create or evaluate existing emission factors.
                                                              P-193
                                     20-7

-------
                           TABLE   1.
                                   RELATED STUDIES ON ORGANIC COMPOUND EMISSIONS
          Project Title
                                 Scope
                                                      Sponsor*
                                         Contractor
Status (as of Mid 1977)
K>

?
00
Air Quality Impacts of
Outer Continental Shelf
Oil Development in the
Santa Barbara Channel

Fugitive Emissions from
Oil Field Production
Operations
     Assessment of the
     Environmental Effluents
     from Oil Refining
     Emissions from Ships
     and Shipping Operation
     including Transfer of
     Oil
Assess the impacts of     OPR
OCS development on the
environment
Determine emission        API
factors on a compon-
ent basis for onshore
and offshore facilities

Determine validity of     EPA
refinery emission
factors currently used
in AP-42

Determine emissions       ARB
from shipping opera-
tions in the SCAB
                                                                        OPR Staff
                                                                        S ERT, Inc.
                                                                        Rockwell
                                                                        Air Monitor-
                                                                        ing Center
                                                                   Radianr Inc.
                                                                   Scott
                                                                   Research
                                                                   Laboratory
                                                                                  Final Report Draft
                                                                                  issued March 1977
                                                                                  Work plan  being
                                                                                  developed
                                                                                  Tests are currently
                                                                                  being conducted in
                                                                                  second refinery
                                                                                  Work plan being
                                                                                  developed
Hydrocarbon Emissions
from Floating Roof
Petroleum Tanks

Hydrocarbon Emissions
from Fixed Roof Tanks

Hydrocarbon Emissions
from Tanker Loading
Operations
                          Determine validity of     WOGA
                          AP 2517
                          Assess  the  validity        WOGA
                          of AP 2518

                          Determine HC  emissions     WOGA
                          resulting from crude  oil
                          loading off Ventura and
                          Santa Barbara counties
                                         Engineering
                                         Science,
                                         Inc.

                                         Engineering
                                         Science,  Inc.

                                         Chevron
                                         Research,
                                         Inc.
                                                                                       Final Report released
                                                                                       Jan. 1977
                                                                                       Final Report released
                                                                                       July, 1977

                                                                                       Final Report originally
                                                                                       scheduled for May 1977
                                                                                                  P-193

-------
                    TABLE  1.
  RELATED STUDIES ON ORGANIC COMPOUND EMISSIONS  (Continued)
          Project Title
    Scope
Sponsor *
Contractor
Status (as of Mid 1977)
     Floating Roof Tank
     Metallic Sealing Ring
     Emission Test Program
     Organic Compound Emis-
     sions From Natural
     Sources

     Emission Factors from
     Burning Agricultural
     Wastes Collected in
     California
Determine effects of      WOGA
wind, ring quality, gap
size and secondary seals
on HC emissions

Determine natural ends-   EPA
sion rates from forest
vegetation

Determine emission        ARE
factors from burning
31 field and orchard
crops
             Chicago
             Bridge and
             Iron
             Washington
             State
             University

             UCR State-
             wide Air
             Pollution
             Research
             Center
               Final Report issued
               March 1977
               Final draft completed
               Final Report, January
               1977
VO
     ORGSOL Regulation
     Study Group.
     Architectural Coatings
     Survey

     A Methodology for
     Reactive Organic Gas
     Emissions:  Assessment
     of Pesticide Usage in
     California

     Gasoline Marketing
     Vapor Recovery System
     Development
Determine potential       ARE
reduction of  organic
emission using H20
borne paints

Determine HC emissions    ARB
from pesticide applica-
tions
Determine test procedures SDAPCD
to assess the effective-
ness of vapor recovery
techniques applied to
petroleum marketing
             ARB Staff
             ARB  Staff
               Staff report  issued
               June 1977
               Report  due  August 1977
             SDAPCD
                Test continuing
                                                                             Continued
                                                                                                 P-193

-------
                 TABLE 1.  RELATED STUDIES ON ORGANIC COMPOUND EMISSIONS  (Continued)
     Project Title
    Scope
Sponsor*
Contractor
Status (as of Mid 1977)
Measurement of Atmos-
pheric Organic Emission
from Natural Sources

Control of Volatile
Organic Emissions for
Existing Stationary
Source
Determine HC emission        EPA
factors from asphalt
operations and landfills

Preparation of documents     EPA
for control of organic
emissions
             Midwest
             Research
             Institute

             EPA Air
             Program
             Staff
               Preliminary tests
               underway
               Volume 1 issued November
               1976.  Future volumes to
               be released late 1977.
 *Abbreviation code:  OPR
                      API
                      EPA
                      ARE
                     WOGA
                   SDAPCD
  California Governor's Office of Planning and Research
  American Petroleum Institute
  U.S. Environmental Protection Agency
  California Air Resources Board
  Western Oil & Gas Association
  San Diego Air Pollution Control District
                                                                                              P-193

-------
2.2     DATA MANAGEMENT
        The data to be processed as part of the final organic emission
included:
        1.  EIS data for major point sources for SCAQMD
        2.  Minor point source data from the SCAQMD (Metro Zone)
        3.  Gasoline station data for SCAQMD (Metro Zone)
        4.  EIS data for Ventura and Santa Barbara County (major and
            minor sources including gasoline stations)
        5.  Petroleum production field
        6.  Additional area data for sources such as forests, landfills,
            architectural coating, domestic solvent use, etc.
        7.  Emission profiles
        8.  Population distribution by one kilometer grid
        9.  Emission factor adjustments to EIS data
        The available EIS data processing software was incorporated for
processing the EIS data.   In this system individual sources  could be modified,
added or deleted.   KVB added a feature which also permitted  the data to be
modified by SCC number.   For example,  the emissions in the EIS data base
from certain fixed roof tanks (identified by a specific SCC  number) were be-
lieved to be too high based on recent  test data.   The  emissions from those
tanks were modified by one correction  factor applied to all  the emissions of
that specific SCC number.
        The profile data was organized with SCC number as the key.   The
specific organic specie emissions for  any source  were  determined by factoring
the total source emissions by the profile of specie weight percentages.
        In describing organic emissions, the point source data were a minor
portion of the emissions, whereas natural emissions, architectural surface
coatings and gasoline marketing constitute the major portion of the emissions.
Since a standard format was not yet available for describing emissions not
meeting the EIS point source criteria, KVB choose to develop an area source
data base for this purpose.  The format was designed to allow description
of emissions by their one kilometer grid location and  process (or activity).
                                                              P-193
                                    20-11

-------
Gasoline marketing data for this data base were acquired in three different
ways.  In Los Angeles County, information concerning 10,000 stations in the
Basin was computerized; however, individual station through-puts were missing.
KVB chose to take the total sales for Los Angeles County and apportion the
through-put by the total storage tank volume at each station.  For Ventura
County the gas station data were included in the EIS file.  For consistency,
KVB chose to take these EIS data and format them as the Los Angeles County
data with the gas station locations and through-puts retained.  KVB assigned
new emission factors to the data.  For the remaining counties the gas station
emissions were apportioned by residential area based on the total county
sales.  These gas station data were formatted in the KVB area source format.
        Since the EIS. point source data base did not contain the organic
emissions for minor point sources under permit in L.A. County (Metro Zone),
these data were acquired from Metro Zone's permit files and formatted in the
KVB area source format.  Data on the emissions from minor point sources not
under permit were also obtained and included in the KVB area source data
base.
        Finally the KVB area source data base contained data from all area
sources identified by the KVB engineers.  These emission sources included
waste disposal, petroleum operation other than refining, domestic and agri-
cultural sources, geogenic  sources and natural emissions.
        All sources in the  inventory were given an SCC number which was
occasionally qualified by the SIC number.   (SCC numbers for area sources were
created after consultation  with ARB personnel.)  A file was created with all
information relative to these SCC numbers, the emission correction factors to
be applied to all sources with the given SCC/SIC number, the profile key to
identify the profile for this source type, the relevant ARB application cate-
gory, and summer or winter  differentials to be used to alter emissions
seasonally if warranted by  the  source  type.  This SCC file was used as the
major system link between  sources  and  their profiles.
                                      20-12

-------
        Within each ARE application category only unique profiles were

identified.  The profile records contained information concerning the method

of determining the profile and estimated error.  In addition, each profile

contained the SAROAD code and percent by weight of each specie in the profile.

Where the SAROAD coding was not comprehensive enough, KVB and their subcon-

tractor, ARLI, added SAROAD codes in a logical manner.  Since SAROAD codes

were the only specie  identifier in the profile data base, a separate tabular

file was created to contain SAROAD codes, species name, molecular weights

and ARE reactivity class.


        From the data files used in this inventory nine reports were to be

produced.  They included:

    1.  A Total Organic Emission Report containing:

        a.  Source information (county, APCD Point ID No.,  SSC No.,
            SIC No.)

        b.  Total organic emissions, ton/year

        c.  Summer emissions, ton/day,  broken down into weekday
            emissions and weekend emissions

        d.  Winter emissions, ton/day,  broken down into weekday
            emissions and weekend emissions
        e.  Emission profile key which will relate to an emissions
            species breakdown in Item 2 below.

        These data were reported in two sorted orders:

        a.  According to the ARE application categories and including
            point and area sources (Report #1)

        b.  According to location in 10 Km UTM grid  squares and
            including point and area sources (Report #2)

        Two plant identification indexes were also provided as in the
        preliminary inventory, one in alphabetical order by company
        name (Report #3)  and one by point ID no.  (Report #4).

    2.  An Emission Profile Listing which lists each organic specie
        (by name and code no.) emitted by a particular  source or
        source type, the reactivity class (according to the ARB's
        3-class system)  of that specie, and the percent by  weight
        of the total emitted hydrocarbons that the specie contri-
        butes (Report #5).
                                                              P-193
                                      20-13

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3.  An Emission Summary consisting of the following data for each
    1 Km grid square in the Basin  (Report #6) :
    a.  Total organic emissions, ton/year
    b.  Individual specie emissions by code no., Ib/year
    c.  Emissions for each reactivity class:  I, II, and III,
        ton/year
4.  An Individual Organic^ Specie Report showing the emission of
    each specie broken down by ARE Application Categories  (Report #7).
5.  An SCC report listing the profile keys, application and emission
    correction factors for all SCC codes encountered in the source files.
    These data were reported in two sorted orders:
    a.  By SCC code  (Report #8)
    b.  By profile key in order to reference all SCC codes
        attributed to a given profile  (Report #9).
                                                          P-193
                                   20-14

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                                 SECTION 3.0
                              EMISSION PROFILES

3.1     DESCRIPTION
        A unique aspect of the current program was the development of emis-
sion profiles, the identification of the organic compound species represented
by the total hydrocarbon emission rates currently given in emission measure-
ments.  Only one other study  (Ref. 4) had previously attempted a breakdown
into generic classes.  That was done primarily for the purpose of dividing
emissions into reactivity classes.  The results of that previous study have
been widely used in the Basin.
        A primary objective of this program was to identify the organic
compound emissions for each stationary source type in the Basin and develop
a data management system capable of applying this information to the total
hydrocarbon emissions in order to calculate the emissions of the individual
organic compounds.  Thus an emission profile was formulated for each Source
Classification Code  (SCC) emitting organic compound species in the Basin.
Both point and area sources were included.   In certain instances a further
breakdown was made into individual industries identified by Standard Industrial
Codes  (SIC).
        Another objective of this program was to predict future emission
trends.  Satisfying this objective required emission profiles based on SCC
number rather than individual plant profiles based on individual plant
characteristics.  All plant devices identified by the same SCC and SIC
number were given the same emission profile.  Conversely, it was important
that profiles be truly representative of the device in general.  Additional
advantages of developing aggregate profiles by SCC number were that:
(1) estimations based on larger data samples were more statically reliable
than single data samples, (2) the profiles were compatible with the EIS
concept by describing devices by the SCC number system, and (3) the volume
of profile data was reduced to a more manageable level.
                                                              P-193
                                    20-15

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        In  each profile  the organic species were identified by  their  ap-
propriate SAROAD  code  and molecular weight.  The ARE three class reactivity  .
scheme, which describes  reactivity by photochemical smog  formation  level, was
also included.  Associated with each emission profile was a subjective
estimate of its relative error.   Sources of the data for  the  development
of  these profiles included KVB test data,  KVB source questionnaires,  the
relevant  literature,  and private communications with government, industry
and academic personnel.
3.2    METHODOLOGY
        Two general approaches were used to formulate the emission  profiles,
one where  only one data point was available to characterize many sources
and another where multiple  data points  were available.   In cases where  a
profile was available from only one source and that source was  believed
to  be  representative of all such source types in the Basin, then that
                                       •
particular source emission profile was  used.  An appropriate  error  estimate
was given to reflect the relative confidence level of these data.   It was
anticipated early in the program that a significant number of source  types
would  fall into this category due to  the  limited amount of field tests
available.   Therefore, test locations were carefully selected on the  basis
of  the representative nature of their emissions to all  other  devices  of that
particular type.   In this way, data  from  this source could be correctly
 applied to other  non-tested  sources.  Similarly, questionnaires were
 submitted to and received from selected solvent users.   Follow-ups  were
 made to assure that the data from these large and  representative  sources
 were obtained.
         Two examples of formulating profiles based on one data point  from
 a selected source are the following.  The emission profile typical  of
 residual oil fuel combustion was obtained by  (1)  recognizing that  95% of
 all residual oil combustion in the Basin  occurs  in utility boilers,
 (2) selecting a boiler that was "typical" of  such devices in the  Basin  and
 finally (3) conducting a test on this unit.  Multiple  samples were  taken
 and the profile was based on an average composition.   Data from questionnaires
 were used  similarly.  One source in the Basin,  according to  the SCAQMD  files,
 was responsible  for 90% of the emissions from adhesive use.   A questionnaire
                                                               P-193
                                      20-16

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was mailed to this source and follow-up contacts were made to assure  that
information from this source was received.  The questionnaire contained  a
comprehensive breakdown of the composition of the solvent composition and
usage which formed the basis for the emission profile.
        The second approach used was to develop emission profiles based  on
data from several sources within a particular source type.  This involved
(1) acquiring the data, (2) determining the relative magnitudes of each
source compared to the total emissions from the source type and finally.
(3) forming a composite profile by factoring the data from each source by
an appropriate weighing factor.  In this manner, emission profiles were
developed for individual source types that in actuality represented the
average emissions from sources of that category (SCC number).
        An example of this approach was the formulation of a profile for
"Miscellaneous Organic Storage" in the Basin.   There were SCC numbers assigned
to storage tanks for gasoline, jet fuel, crude oil,  various solvents, etc.
This miscellaneous category covered those products not specifically identified.
Table 2 presents a summary of the calculation procedures employed to determine
this profile.   Listed across the top are the various organic products iden-
tified and the fraction of the emissions from fixed roof tank storage for each
based on information compiled from the SCAQMD file.   Listed down the page
are the various organic species that have been identified in  emissions from
these products.   The weight percentages of each specie associated with the
product is listed in the appropriate column.  The weight percentage for
asphalt and Stoddard solvent were determined from KVB test data.   The
adhesive percentages came from questionnaire data.   The remainder of the
percentages were specified (e.g.  100% for acetone)  or estimated  based on
                                                                       \
contacts with industry (e.g.  the breakdown of alcohols and ketone).   The
weight percent of each organic compound in the composite profile was determined
by multiplying the weight percents by the appropriate fractions  and are listed
in the right hand side.
        Given in Table 3 are the emission profiles generated  for this study
for 20 of the major source types in the Basin.
                                      20-17                        P-193

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                             TABLE  2.    COMPOSITE  PROFILE FOR MISCELLANEOUS PETROLEUM  STORAGE
                                                          (Fixed  Roof Tanks)
 Product Stored
                   Acetone   Adhesive   Alcohol   Asphalt  Perchloroethyleno
                                                          Ethylene
                                                         Dichloride
                                        Formaldehyde  Xatona   Stoddard   Xylane   Others   CoppoiUe
 Fraction of
 Emission*
 Organic Compounds
 Acetone
 Perchloroe thylene
 Ethylene
   Dlchloride
 Formaldehyde
 H£K
 HIHK
 Xylene
 Toluone
 Ethane
 Ethylone
 Propane
 H-Butane
 I-Butane
 N-P«ntane
 I-P*ntano
 Htxane
 I-Hexane
 Heptane
 I-Heptane
 I-Octane
 I-Monana
 I-Oecane
 X-Undeeane
 Ethyl  Acetate
C-7 Cycle-
  paraffins
 iBOpropyl Alcohol
 Ethyl  Alcohol
 Iiobutyl Alcohol
  0.163
100.0
            0.022
            4.0
                     0.084
            5.6
           84.6
           5.8
                    40.0
                    10.0
                    30.0
                               0.078
 1.0
 2.0
13.0
16.0
 8.0
18.0

 2.0
12.0
14.0
11.0
 1.0
                                             0.051
                                           100.0
                                                            0.004
                                                                        0.004
                                                                                    0.191
                                                                                              0.071    0.057
                                                                                                               0.275
                                                          100.0
                                                                       100.0
                                                                                  65.0
                                                                                  35.0
                                                                                                     100.0
                                                                                                              31.0
12.5
25.0
                                                                                             0.8
                                                                                             27.3
                                                                                             69.4
                                                                                             2.4
                                                                                                             1S.S

                                                                                                             15.5
16.4
 S.I

 0.4
 0.4
12.4
 6.7
 5.7
 8.6
 0.1
 0.2
 1.0
 1.4
 0.6
 1.4
 3.4
 8.9
 0.9
 l.l
 1.0
 0.1
 1.9
 4.9
 0.2
 4.4

 4.2
 3.4
 2.6
 2.6
                                                                                                                             P-193-

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TABLE 3.  EMISSION PROFILES




















IO
?
\o












nj
i
to
w










O C 3 C HI
° ^2 2
rH -rl >s -H n
Id »J M 4* •-<

"OS 63 M
• HA -rl A V '
w E "" C .WO*
. . Q> O WO -H w
J c 5 S
u nation u c E >-i cue
•I U C Cl «1 0. -rt V •Hfll 3 - -I «l C « _
rH > O «l > — U > UV >IU Oil C-Ht>Ol
*•< >ri~te«rtu -H Q)*H i-i6 cn -HU c
Q iJ w -H u ui p n x; u oo «« i-i«i  , 4Jr-l 30 UK 310
O 9ECC3.HM 'O SH VO U4J lOrt MO
O t, |3 — li M p. « W Q P. iX UU) OX UK)
36.0 28.6 62.0 6.2 10.2

S.8 17.8 3.9 5.6 3.6

11.5 11.1 17.6 1.8 23.4
0.1

18.3 4.4 27.1 19.8 26.5
1.8
7-4 2.9 1.5 6.6 5.4
7.7 0.7 14.6 10.6 7.3
7-8 1.1 1.5 29.0 8.0
6.2
3'4 59.0 7.9 2.5 5.6

1.4 9.2 0,6 5,6
1-8 6.9 o.l 3.0
'0.60 Ii0

13.0 1-6 0.3 8.9

0.0 2.0
0.3

0.4 0.8 1.9
Q.I 0.1 2.1
0.1

°-5 27.3 0.2

0.3 69.3

2.6

°'2 1.3 0.2

0.5

0.1




M rH **
9g U <0 «l 3
a ." n H « o
KC C 5' ° * =
Pub) 0. ? " <* DIKE
a > U rH « 3
4 fl I8O* flM **OC fl *H rt^HCn
M M hO U^-HIQ-HM M 41O4
U U VX UOXIMW3 T) UhX
c c c«i c u uhiof c nuo
01 « QJrH VQ U3QIO Q •HU«'
ij u Ob. o£>
-------
TABLE 3.  EMISSION PROFILES (Continued)
Profile (» Height)
1 N
M «
rt « H D< M S
•*< H S • ** C « -H
ocucn -~ fl *» e -3 i K
•* .3 >, 8 * " *t*°" u^§ IH * S *
S«J W *J ^ t«l > O «l > *"• ** > W 01 V4* Oil S -5 t« ** *•<
W II M CP ^4 ^4*4C>HU -H WiHiHC Oi -HV I; <«
^3 C3 W b «IM'^4J«3 M f]U °S| ^S M«i)«4 h
Lactol Spirits
Nothyl Alcohol 1.0
Ethyl Alcohol 0.8
Iso Propyl
Alcohol 2.8
H- Butyl Alcohol , 4.0
Iso Butyl
Alcohol
Glycol Ether 11.5
Propylene Glycol
Ethylene Glycol
Ethyl Acetate 4.1 0.9
Propyl Acetate
Q H-Butyl Acetate . 9"5
iJj Cellosolve
O Acetate
Isopropyl 0 .
Acetate
Isobutyl
Acetate
Dimethyl
Formanide
Isobutyl I«o-
butyrate
Formaldehyde 42.0 7.6 51.0
Acetone 28.0 3-° 7<1
Methyl Ethyl 7 ?
Ketone
Methyl H-Butyl
Ketone
Methyl Isobutyl 3 x
Ketone
,_, Ethylene
1 Bichloride
ID Peetnvlene 3°'° I00-0

S - "
s u * «
3 -H 41 H U
I J J I «, J
« igot aki 4JUC 4
h MO WD>.»«^i M
V WX VO X!^4^* ?
c c« cu u w n u
« vi-t VQ H30 4
(5 Ofx (3« 
-------
                                                   TABLE 3.   EMISSION PROFILES  (Continued)
to
                                                                            Profile  (% Height)



Chemical Name
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JC 
-------
                                 SECTION 4.0
                              EMISSION FACTORS

        There has been considerable interest in the development of emission
factors that can be employed to estimate emissions from specific sources
based upon a knowledge of the pertinent operating characteristics of the
source.  Such procedures are in common use throughout the country by local
control agencies to estimate air pollution emission rates for point and area
sources.  One of the primary objectives of the ARB organic compound emission
study was to critically evaluate these emission factors and to develop new
emission factors applicable to the South Coast Air Basin.  The following
discussion outlines the methodology employed during this analysis.  Emission
factors for point and area sources were separated as they represent signifi-
cantly different approaches.
4.1     POINT SOURCES
        A comprehensive listing of point source emission factors was found
in the EPA publication, "Compilation of Air Pollution Emission Factors"
 (Ref.  5), hereafter referred to as "AP-42."  The SCAQMD had their own emis-
sion factors which had been employed in the process of estimating emission
rates  for industrial point sources contained in the EIS data file.  To a
certain extent, these emission factors were the same, because frequently
SCAQMD data were used as the basis for the development of AP-42 emission
factors.  In other instances the emission factors differed because the SCAQMD
often  based their emission factors on their own test data in preference to
using  AP-42 values.
        It was recognized that the emission factors presented in AP-42 were
never  intended to be totally representative of all such units within a specific
source type.  Their widespread use, however, has generated several investiga-
tions  by the EPA and others to broaden their data base and thereby increase
their  usefulness and accuracy.
                                                              P-193
                                      20-22

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        A specific objective of this study was to examine the point  source
emission factors used by the SCAQMD and AP-42.  This was done for three
reasons.  First, much of the data used to generate emission factors  for
specific source types such as petroleum operations and the combustion of
fuels stemmed from studies conducted as far back as the 1950's.  Considerable
debate has been raised about their continued applicability in view of
improved technology, sampling procedures, etc.  Second, certain emission
factors listed in AP-42 intended for use nationally may not necessarily
represent conditions in the Basin.  Finally, it was necessary to generate
entirely new emission factors where none had existed previously.
        Field tests were conducted to provide data to assist in emission
factor evaluation and development.  In addition, data from several related
projects specifically oriented to improving AP-42 emission factors have been
incorporated into this analysis.  In most cases, these studies had been
directed at conditions within the Basin making them directly applicable to
the current study.
        Comparisons have been made between the emission factors  used by
the SCAQMD,  those contained in AP-42 and those generated in  this and related
studies.  Where the SCAQMD emission factors have been shown  to be in error,
correction factors have been applied to the emission rates  listed in the
EIS data system to update these emission estimates.   The intent  was  to
have the EIS data system reflect the best and  most  recent information avail-
able.  This was a vital part of the improvements incorporated into the final
data base.
        Since it was the intent of this paper  to present general methodology,
the analysis used to investigate emission factors for the combustion of fuels
and establish correction factors will be discussed  in detail as  an example
of the approach.   A similar analysis for petroleum  operations including
marketing,  storage and fugitive emissions will be incorporated into  the final
report.
                                                             P-193
                                      20-23

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        It was appropriate to investigate the organic compound emission
factors for the combustion of fuels used in the Basin.  Emission factors
used by the SCAQMD stem from data generated in the 1950's  (Ref. 6) and
were currently under revision during the study using more up-to-date test
data.
        AP-42 emission factors represented data accumulated over the last
several years and generally had an emission factor rating of A.  These
emissions factors, however, are still subject to revisions for specific
sources.
        Emission factors developed during the current program were themselves
subject to  error due to the broad nature of the test program and the limited
number of samples that could be obtained for any one source type.  Sources
tested were therefore carefully selected so that the tests were as representa-
tive as possible of sources of that general type.  In addition, a thorough
evaluation  of the test data was made to assure its accuracy.
        The approach for this fuel combustion analysis was, therefore, to
compare the emission factors from the three sources  (AP-42, SCAQMD and KVB)
and thereby ascertain the  "best" emission factor.  In cases where this
emission factor differed from that employed by the SCAQMD, an appropriate
correction  factor was formulated and applied to the EIS data tape.
        Table 4 presents a summary of the sources and emission factors for
the combustion of  fuels that were evaluated.  The table provides a descrip-
tion of the source, the appropriate SCC numbers, the units employed, emis-
sion factors  listed in AP-42, those used by the SCAQMD, those resulting
from field  tests conducted during this program and the emission factor used
in the  final  data processing.  Also included is the correction factor used
to update the EIS  data files as described above.
        The analysis of the data presented in Table 4 resulted in some
interesting conclusions discussed in the following paragraphs.
                                                              P-193
                                      20-24

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                                TABLE  4.   ANALYSIS OF EMISSION FACTORS
                                           Combustion of Fuels
in

Emission Factor
EIS
Applicable Emission Factors Used in the Correction
Description
Residual Oil
Combustion
Power Plants
Natural Gas
Combustion
Power Plants
Refinery Gas
Combustion
Natural Gas
Industrial
CO Boiler
Natural Gas
1C Engines
*Added to the
SCC Codes Units AP-42 SCAQMD KVB/ARB Current Study Factor
1-01-004-XX Ib THC/103 Gal. 1.0 2.6 0.7 1.0 0.40




1-01-006-XX Ib THC/106 ft3 1.0 8.8 - 8.8 1.00




3-06-001-02 Ib THC/106 ft3 30.0 21.9 20.0 21.9 1.00
3-06-001-04

1-02-006-XX Ib THC/106 ft3 3.0 7.0 12 7.0 1.00


3-06-002-01 lb/103 Bbl Feed 200 1.6 1.1 1.6 1.00
2-02-002-02 Ib THC/106 ft3 1400 - 1850- 1400 NA*
11600
data base by KVB
\ GscxyO) «= ^


.
                                                                                           P-193

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        Among the most important of the emission  factors  investigated was
that from the combustion of residual oil in utility boilers.  This represented
one of the  largest uses of fossil fuels in the Basin.  The  emission factor
used by the SCAQMD was approximately 2.5 times that listed  in AP-42.  For
                                                       \
this source type, the results of the KVB test program  conducted on a utility
boiler firing low sulfur residual oil tended to support the lower figure.
Consequently a  correction factor was incorporated into the  data management
program.
        Similarly, the SCAQMD emission  factor  for natural gas combustion
in utility  boilers was nine times that  of AP-42.   However,   in this case,
since the quantity of natural gas used  by utilities has decreased dramat-
ically in recent years, a decision was  made to forego  emissions testing of
this source type.  Since this represented a relatively insignificant source
of organic  compounds, the SCAQMD emission factor  was not  changed.
        Refinery gas combustion, on the other  hand, represents an important
industrial  source of organic compounds.  In this  case, good agreement
between the three emission factor sources was  obtained and  no correction
factor was  necessary.
        Industrial natural gas  consumption also represents  an extremely
large energy use in  the Basin.  As shown in Table 4, the  emission factor
used by the SCAQMD was between  the AP-42 and KVB  emission factors so that
again no  correction  factor appeared warranted.
        Emissions  from CO boilers treating exhaust gases  downstream of an
FCC unit  were  also evaluated.   Since the SCAQMD used test results from
these units for emissions estimates rather than emission  factors, the
comparison between SCAQMD values and those obtained in this program has
been made for a particular unit.  Again, the  SCAQMD value appeared to be
reasonably close to  that obtained during this  study and no  correction
factor was necessary.
                                                               P-193
                                      20-26

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        Natural gas combustion in 1C engines represented  another  somewhat
unique case.  At the time of the study, sources of this type were not
included in the EIS data file although a preliminary  inventory of 1C
engines in the Basin had been made.  This inventory was incorporated into
the area source data base for this study.  A decision on  an appropriate
emission factor was somewhat difficult to make.  Data presented in AP-42
represented emission factors of 800 hp units much larger  than those typically
found in the Basin.  The results of the tests conducted by KVB on 1C engines
also resulted in large emission factors however insufficient data were
obtained to generalize an emission factor.  The AP-42 value was used as it
was somewhat conservative, although it was fully recognized that the emis-
sion rates from these sources may be higher.
        In conclusion, the emission factors for the SCAQMD appeared
reasonably good, requiring only one correction factor be applied for the
sources listed in the EIS data file.  Emission factors employed for natural
gas and refinery gas combustion appeared to be adequate for this program.
Emission estimates for CO boilers made by the SCAQMD also were verified.
There seemed to be additional data required to improve the emission factors
used for natural gas 1C engines.
4.2     AREA SOURCES
        An important aspect of the KVB organic compound inventory was the
identification of sources of organic compound emissions not under permit
and generally not included or adequately characterized in previous inven-
tories.  These sources were grouped as waste disposal, petroleum operations
other than refining, domestic and agricultural sources, geogenic sources
and natural emissions.  Because these were diffuse sources,  not concentrated
like industrial point sources, they were referred to as area sources.
Emission factors for these sources were therefore based on land area,
population, land use or other criteria characteristic of the area source.
        Table 5 presents a summary of total organic emission estimates  from
each of the area sources considered.  Precise emission rates were difficult
to estimate due to the complex nature of each source type.  A discussion of
inventory and emission factor development for some of the larger area sources
is included in subsequent sections.
                                                             P-193
                                      20-27

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         TABLE 5.  EMISSION ESTIMATES FOR AREA SOURCES (TOTAL ORGANICS)
Waste Disposal
        Agricultural Burning
        Sanitary Landfills
Petroleum Operations
        Production Operations
        Marine Terminals
        Gasoline Marketing
        Natural Gas Transmission
Domestic and Commercial Sources
        Architectural Surface Coatings
        Solvent Use
        Fuel Consumption
Agricultural
        Natural Emissions
        Orchard Heaters
        Animal Wastes
Geogenic Sources
        Natural Seeps
Forest Emissions
        Natural Emissions
        Forest Fires
Other Sources
        Dry Cleaning
        Asphalt Paving Operations
Tons/Day

     2
   930

    60
     3
    83
    83

    93
    31
     5

    14
     3
    77

    11

   1150
    38

    26
     1
                                                               P-193
                                     20-28

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         It must be pointed out that the emission factors and  inventories
presented were developed for use in this study of the California  South
Coast Air Basin and caution must be exercised in their application to other
study areas.
4.2.1    Sanitary Landfills
         Over 15 million tons of liquid and solid wastes were deposed annually
in the 45 major landfill sites within the Basin.  Several studies (Refs. 7,
8f 9) indicated that appreciable amounts of methane rich gas were generated
due to the biological anerobic decomposition of these wastes.  These gases
represented not only a potential source of useful energy but a large,
currently uncontrolled source of organic compounds to the atmosphere.
         No precise estimate of the emissions from landfill operations for
the study area existed.  Results from the above mentioned references and
field tests conducted as part of this program were used to estimate the
emissions from these sources.
         The approach used was to estimate the rate of carbon escape over the
"life" of the fill as presented in a study by the California State Water
Quality  Control Board (Ref.  10).  In this study, it was found that
                             177
                         3.75 + 1.95t
where r = rate of carbon escape (Ib/ton refuse-yr)
      t = age of refuse (years)
Note that it was assumed that carbon is released as both methane and carbon
dioxide gas.  Using this relation and a gross estimate of the total quality
of wastes presently "alive" in the Basin,  an estimate of the current organic
 compound  emission rate of  930  tons per day was made.
4.2.2    Petroleum Production Operations
         Extensive petroleum production operations were underway in the Basin.
Nearly 150 million barrels of crude oil and 115 billion cubic feet of natural
gas were produced in 1975.  For this inventory only onshore production opera-
tions were considered.
              -*

                                                              P-193
                                      20-29

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         Prior to the  current study,  the magnitude and composition of organic
compound emissions  fron production operations other than  tank  storage was
essentially unknown.   Tests were conducted at two locations  recommended'by
the Western Oil and Gas Association as typical of such operations  in the
Basin.  Since only  brief test programs were possible during  the  current pro-
gram, the emission  factors developed should be considered as representative
and useful for estimating purposes only.
         A summary  of  the emission factors and inventories used  in the current
study are given in  Table  6.   These inventories were made based on data from
the California Department of Oil and Gas (Ref.  12), data from local control
agencies  (Ref.  13) and numerous discussions with representatives  of the major
petroleum production companies operating in the Basin.  It must  be reemphasized
that  the data represented the study area only and conclusions  should not be ap-
plied arbitrarily to any other situation.  Confidence factors  on a scale of A
to E  (A-high, E-poor)  were also assigned to assist in the evaluation .of these.data.

          As shown in Table   5, petroleum production operations represented
 approximately 67 tons per day  of which  50% were  from storage tanks.  The
 balance were primarily  fugitive emissions from leaking valves and metal con-
 nections and evaporation from  standing  oil.
 4.2.3    Gasoline Marketing
          Orgariic compound emissions  from the  transfer of  gasoline to automobile
 tanks has been recognized as a major source of emissions  to the atmosphere and
 has been studied extensively.  Control  measures  were implemented in counties
 in Southern California  to reduce  these  emissions through  vapor recovery
 techniques at both the  tanker  truck  to  storage tank transfer  (Phase I) and the
 nozzle to vehicle  tank  transfer operations  (Phase II).  Phase I had been
 essentially completed within the  Basin.  Phase II had  just  been initiated.
          Emission  factors  have been  recently  revised  (Ref.  14) to  reflect
  additional test data  on gasoline  marketing operations  and the effectiveness
  of these control measures.   The emission factors used  in  this study  (given
  in Table 7) represent not only information from Reference 14  but  also

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                     TABLE  6.    PETROLEUM PRODUCTION EMISSION  FACTORS AND INVENTORIES
       Source
                       Units
                            Emission
Emission   Inventory        Estimate(2)    Confidence
 Factor   No. in Basin     (tons per day)	Level (3)
N>
      Crude Oil  Storage
      Tanks (Fired Roof)
                                                 (1)
Process Drains      Ib THC/rod pump well-day     2.0
Oil/Water
Separators

Fugitive Leaks
from Valves

Pump Engine
Exhausts

Heaters and
Boiler Exhausts

      TOTAL
                    Ib THC/ft -day
Ib THC/valve-day
                    Ib THC/106 ft3
                    Ib THC/106 ft3
                                                      1400
                                                        30
           1650 tanks
                                                                8000 rod pump
                                                                  wells
                                                                              34
                                                                           B
                                                       0.1       184,000 ft
                                                       0.10     150,000 valves
           4250xl06 ft3/yr
           SlOOxlO6 ft3/yr
                                                                               8
                                                B
                                                                                    60
       (1)   Emissions adjusted to 60% of API Bulletin 2518 values based on the  Engineering
            Sciences report,  (Ref.  11).

       (2)  Emissions have  been rounded  to the nearest ton per day.

       (3)  Confidence Levels;  A - high, E - poor
                                                                                            P-193

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               TABLE  7.     GASOLINE MARKETING EMISSION FACTOR
          Emission Source	lb/103 Gal Throughput^
         Submerged Filling of Underground                0.7
           Tank (Controlled)
         Underground Tank Breathing                      1.0
         Vehicle Refueling Displacement                  9.0
           Loss
         Vehicle Refueling Spillage Loss                 0.7
discussions with representatives of the EPA and the San Diego County APCD,
one of the most active of the local control agencies in assessing the validity
of these emission rates and effectiveness of Phases I and II control measures.
         These emission factors have been incorporated with an estimated
gasoline sales of 5.3 billion gallons per year  (1975) resulting in an average daily
emission rate of organic compounds from this source of 83 tons per day for the
Basin.
4.2.4    Architectural Surface Coatings
         Estimates of the total volume of coatings applied to the surfaces of
stationary  structure and marketed within the Basin was difficult to make due
to the large number of manufacturers and suppliers involved.  The most effective
approach was to use marketing questionnaires.   This  approach proved to be a
very time-consuming and costly operation without the legal  authority  to require
responses  by those  questioned.
         Surveys  that were performed by the local control agencies in
California showed that emissions of organic compounds from  architectural
surface  coating applications were  from 3.4  to  3.7 tons/1000 people/year.
The  ARE  estimated that 93 tons per day of emissions  result  from architectural
coating  within the  Basin  (Ref.  15) for annual  emission factor of 3.3  tons per
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                                       20-32

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 1000 people.   In the same  study  it  was estimated that total emissions from
 architectural coating for  the  entire  state amounted to 186  tons per day
 or an  annual  emission factor for the  state of 3.3 tons per  1000 people con-
 sistent with  the estimate  for  the South Coast Air Basin.  Thus 3.3 tons/1000
 people/year was  used in  this inventory.
 4.2.5    Natural Forest  Emissions
         Studies (Refs.  16,   17) had  shown that there was  considerable
 organic interaction  between plant life common to the  forest areas in  Southern
 California and the surrounding atmosphere.  These emissions are in the form
 of a-pinenes,  3-pinenes  and isoprenes  generally  termed terpenes.
         Estimates of the  emission  rate from  typical  forest plant life groups
 had been made by Zimmerman (Ref.  17) .  A  summary of  forest group emission
 rates  are presented  in Table   8.
         Inventories of  both the total average and the  geographical distribu-
 tion of forest vegetation  were obtained from  the  National Forest Service
 (Ref.  18).   TO  these were added estimated  acreage of private lands assumed
 to have similar  forest vegetation compositions as  in the National Forests.
 Table  8 also  presents a  summary of the total  acres of each  forest group within
 the study area.
        Applying the emission factors and inventory results  presented  'in
Table 8 resulted in a total emission rate from these sources of approximately
1150 tons per day.  This amount was  at least equal to that from all anthro-
pogenic sources within the study area.   These results were not surprising
since nationally it was estimated that the natural emissions from  such vege-
tations are 3-4 times the man-made emissions  (Ref. 17).
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               TABLE   8.   SUMMARY OF NATURAL FOREST EMISSIONS
Forest Type
Total Acreage
  in Basin
 (1Q3 Acres)
Annual Emission
    Factor
 Tons/Acre•Yr
Emissions
   Tons
Hardwoods
Douglas Fir
Mixed Conifer
Pines
Pinjon Juniper
Brush
  Total
     671
     372
     107
     130
     166
    2147
    3593
    0.0211
    0.0186
    0.0782
    0.0963
    0.0353
    0.172
   38.8
   19.0
   22.9
   34.3
   16.1
 1011.7
 1142.8
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                                  SECTION 5.0
                                FIELD TESTING
        Field  testing was  conducted to determine the rate  and  chemical  com-

position of organic  emissions of representative sources  in the Basin.   Over

600 samples were  collected and analyzed from various equipment in  the

following locations:
Adhesives Mfg. Plant
Aircraft Plant  (2)
Appliance  Plant  (2)
Asphalt Plant
Auto Body Shop  (2)
Automobile Plant  (2)
Chemical Plant  (2)
Dry Cleaning Plant
Equipment Mfg.  (2)
Gas Compressor Plant
Gas Pumping Station
Gasoline Station

        Equipment tested included:

Adhesive Spray Booth
API Separator (6)
Asphalt Paving
Basic Oxygen Furnace
Blast Furnace
Charcoal Adsorbers  (4)
Chemical Mill
Chemical Process
Chemical Transfer
Coke Oven
Compressors (28)
Cooling Tower (2)
Degrease Tank (11)
Dip Tank
Dry Clean Tumbler
Drying Ovens (8)
Fiberglass Impregnation (2)
Filling Rack
Flow Coater (2)
Gravure Press (5)
 Landfill
 Magnetic  Tape Plant
 Oil Field (2)
 Oil Refinery  (3)
 Packaging Mfg.  Plant
 Printing  Plant (2)
 Roofing Kettle
 Rubber Mfg.
 Solvent Mfg.  Plant
 Steel Mill
 Utility Boiler
 Utility Gas Turbine
Heater Treater
I.C. Engines  (6)
Incinerator  (10)
Lithograph  (3)
Open Hearth Furnace
Paint Booth  (32)
Precip. Outlets
Printed Circuit Board Proc.
Process Heater  (3)
Pumps (200)
Rubber Process  (3)
Sintering Plant
Sludge Incinerator
Storage Tank  (5)  (Species only)
Sumps (6)
Valves (24,000)
Vapor Recovery Tank to Car  (8)
Vapor Recovery Truck to Tank
Well heads  (5)
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5.1     FIELD MEASUREMENTS AND SAMPLING
        In the field,organic emission rates from stacks and from fugitive
emission sources like leaking seals, open ponds or spills were determined.
The general approach was either to measure the emission rate or to determine
it by calculations  from process data or by experiment.  From ducted sources,
such as stacks, emissions were determined by conventional velocity determi-
nations.  Where information was available on the amount of product lost from
a process, this was used to determine emissions.  Where fugitive emissions
due to leaks or spills were involved they were either measured or estimated.
In some instances special experiments were conducted to obtain estimates of
emission rates.  An example of the type of experiments that were conducted
involved the determination of the amount of solvent which was emitted from an
architectural coating as it was drying or curing.  Investigation in this area
has revealed that in some instances as much as 30 or 40 percent of the solvent
is actually retained in the paint after it is cured, and is not emitted.
        For analytical purposes, samples of emission gases were collected in
one or more of  the  following  type of containers:
           tubes  filled with  activated charcoal
           borsilicate glass  bottles
           Tedlar bags
           glass bulb containing 1% sodium bisulphite solution
            (aldehyde determinations).
        The charcoal sorbent  tubes were used to collect aliphatic organic
compounds with  carbon numbers of six or greater and all other compounds  from
C  -  up.  The gas  collection  jars and bags were used to collect aliphatic
compounds with  carbon numbers less  than six.  On most major  sources, a combina-
tion  of sorbent tubes  and  either bags or bottles were used.  Bags or bottles
were  used  for  the entire  compound range when used  for  grab sampling.
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                                       20-36

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5.1.1   Sampling Equipment
        Two identical portable sampling units were designed and built  with
the following capabilities:
           measuring stack temperature and velocity
           filtering out particulates larger than 2 microns
           collecting samples in sorbent tubes, glass jars or polybags.
        Figure  1  illustrates the assembled sampling trains.  Materials of
construction are as follows:
           all metal components are stainless steel
           seals are Viton or Teflon
           containers are borosilica glass
           flexible connections are latex rubber of minimal length.
The general flow diagram illustrated in Figure  2  illustrates all components
of the assembly which are available to be switched into several sampling
modes to conform to requirements dictated by the source to be tested.  The
components are:
        1.  a sample nozzle
        2.  a filter holder with 2.5 micron pore size glass fiber filter
        3.  a filter and line heater and thermostatic control
        4.  an impinger train containing LiOH crystals
        5.  a borosilicate (Pyrex)  gas collection bottle
        6.  a charcoal tube train with thermometer and vacuum gauge
        7.  a Brooks flowmeter with needle valve flow control
        8.  various interior and exterior valves and connectors as
            indicated in Figure 2
        9.  a meter connection to PD gas meter
       10.  a Magnehelic velocity gauge and pyrometer for use with a
            pitot tube.
        The lithium hydroxide in the dry impinger train was used only on
combustion sources and was selected for use based on experience gained  on
the Apollo space capsule.   Initially an ice water impinger was considered
for moisture,' NOx, SOx,  and CO removal.   The problem with this approach was
that it was felt that the alcohols  and some other oxygenates would form
                                                             P-193
                                     20-37

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                   KVB
Figure   1.   KVB hydrocarbon sampling trains.
                     20-38

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to
                       Heater
                                                                 Gas Collection
                                                                 Bottle
                                                           cxo-C
                                   KX3	,
                                                                    Activated
                                                                    Charcoal	*
                                                                    Sorbent Tubes
                                                             Gas Stream
                                                             Splitting Valve
                                                                                                    Plow
                                                                                                  Regulator
                                               Sorbent
                                               Gas Temp.
                                                              Flow
                                                              Meter
                                                         Sorbent
                                                         Pressure
                                                         Drop
                    Total Hydrocarbon
                    Analyzer
Aldehyde
Bulb
Sampler
                                                                                                             System Flow
                                                                                                             Throttle
                                                                                                    Gas Stream System
                                                                                                    Pressure Drop
                                                                                                    (Meter Vacuum)
                                                                    Vacuum
                                                                    Source
                                          Gas Meter
               Figure   2.    Complete  hydrocarbon  sampling  train as set up for a  hot combustion source
                             (> 180  °F).
                                                                                                       P-193

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azeotropes with water and would not be easily separated for analysis.  (The
impinger solution was analyzed for hydrocarbons.)   LiOH was used in the
Apollo life support system to absorb primarily CO.  In the sampling train it
also neutralized NOx and SOx which would react with the hydrocarbons.  Also
the LiOH is hygroscopic and would absorb most of the condensed moisture.
Furthermore the LiOH would not adsorb hydrocarbons according to Apollo data.
CS  extractions and hydrocarbon analyses were made on the impinger contents
and they were found to contain no hydrocarbons.  On non-combustion sources
where moisture was no problem the dry impinger was not employed.
        The suitability of several different types of sorbent materials
was investigated.  The materials tested included:  Tenax Gc, Carbosieve
B, activated charcoal, and XAD-2 resin.  The criteria observed in the
selection of the sorbent included quantitative retention and recoverability
of every analyte possible.  These qualities are dimensionalized by measure-
ment of breakthrough volumes and recovery efficiencies.  Table 9 presents
the breakthrough volumes of the sorbents  (25 °C) for hexane and benzene.
These analytes were considered to represent about the upper limit of
materials that can be analyzed in gas grab samples.  Carbosieve B and
activated charcoal showed particularly high retention capacities.
        Another important parameter  in sorbent selection was the analyte
recovery efficiency.  High temperature thermal stripping  (with a purge gas
or in a vacuum) of the adsorbed components on Tenax, Carbosieve B and XAD-2
was considered but later rejected because the entire sample must be  committed
in a single determination.  Recovery efficiencies using the thermal/purge-gas
techniques also showed high molecular weight discrimination  (see Table 10  ).

            TABLE  9*   RETENTION  EFFICIENCIES OF VARIOUS SORBENTS

                                      Breakthrough Volumes,* 1/g sorbent
                                      Benzene                     Hexane
      Carbosieve B                       47                         65
      Tenax GC                            3                          4.4
      XAD-2 Resin                        12                         20
      Activated Charcoal                 30                         43

 *Measured as the volume of gas/grams of sorbent in cartridge to give a 0.1%
  FID response to gas stream containing 50 ppm of test component.
                                                                P-193
                                         20-40

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               TABLE   10.  RECOVERY EFFICIENCY OF PURGE-THERMAL
                        STRIPPING OF SELECTED ANALYTES

Benzene
n-C?H16
n-C8H18
n-C9H20
n-C10H22
n~CHH24
n"C12H26
n-C13H28
n"C14H30
n"C15H32
n-C17H34
TENAX Carbosieve B
% Recovery % Recovery
105
100 11
99 <1
94 <1
72 <1
67 <1
67 <1
58 <1
56 <1
61 <1
46 <1
XAD-2
% Recovery
—
—
—
—
62
60
—
; 	
--
	
	
        Solvent stripping for analyte elution prior to chromatographic
analysis was investigated.  Carbon disulfide was found to be an attractive
solvent because of its excellent solvent properties.  Many of the other
common solvents, such as methylene chloride, chloroform, hexane, benzene,
etc., tend to swamp the chromatogram, obliterating any signals of components
that have boiling points even decades higher.
        Unfortunately, it was found that Tenax GC is soluble in CS  as well
as in CH Cl .  Carbosieve B showed poor recoveries with solvents.  Testing
was therefore primarily focused on solvent extraction of- activated charcoal
with CS  and XAD-2 resin extraction with CH Cl  (CS  also dissolved XAD-2).
       ^                                   £  £    £
Table 3-4 presents the results.  Mueller and co-workers (Ref.  19 ) have
reported similar efficiencies for halogenated and oxygenated hydrocarbons
using charcoal adsorption followed by CS  elution.  Based on the data they
presented and the precedent set by the National Institute for Occupational
Safety and Health (NIOSH) in the selection and published (Refs. 20 to 22)
characterization of the charcoal/CS  analysis scheme, the' use of coconut-
derived activated charcoal as supplied i>y Mine Safety Appliances or SKC, Inc.
was selected as the material of choice for source sampling.
                                       20-41
                                                               P-193

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        The total hydrocarbon analyzer shown in Figure   2  is the Bacharach
TLV Sniffer which was used to provide an indication of hydrocarbon concentra-
tion levels and process variations.  At under $1000 in price it served its
purpose well.
5.1.2   Sampling Method
        The sampling train shown  in Figure  2   was used  or modified for each
sampling.  It was already mentioned that the LiOH impingers were removed for
other than combustion tests.  On  some simple one solvent sources even the
charcoal was omitted and  only a gas bottle  sample was obtained.
        On fugitive sources  the approach taken is shown  in Figures  3  through
6.    Figure   3  shows the setup  for measuring leak rates when the rate is so
great that it will  drive  the meter itself.  Most large pipeline leaks are of
this type.  Figure  4  shows the  setup if the leak will  not drive the meter.
A pump is added to  draw filtered  air through the bag.  The measured flow rate
times the hydrocarbon concentration measured by sampling the gas provided
a measure of the hydrocarbon emission rate.
        Figures   5  and   6  illustrate  test setup for sampling a high
temperature fugitive emission source.  In Figure   5  aluminum foil was
substituted for polyfilm  and rates were measured as Figure  3 or 4.  When
the source was too hot,  the  foil  could not  be attached and  the setup in
Figure   6 was used. The temperature of the source was  measured, a grab
sample was obtained in a  gas collection bottle, and the  concentration of
total hydrocarbons  was measured.   The leak  rate was then obtained by applying
engineering judgments.
5.2      LABORATORY ANALYSIS
         Most  ambient pressure gas samples were analyzed  within 2-3 days
following receipt,  except for a  small number that were processed as long
as two weeks  later.  Several tests were made with synthetic samples to
evaluate storage  effects  on  the  contents of capped charcoal sampling tubes.
Recoveries did not change, within experimental error, between 24 hours and
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                                      20-42

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      4 nil »»ty«thyl«m
                                                                 <*«n top
                                                                Surga Boetia
                                                                 J  L
Cinooj- tMt«d)   V.lv.
                                                      O O
                                               Tout Hydroeubo*
SugiU
•ottlt
    Figure 3.  Leak rate and concentration measurement of ambient temperature
               fittings.  High leak rates.
Mil
(*«OOS* H.t.dl   V.lve
               fucp
                                                                                         Open Top
                                                                                            tottl*
                              Figure 5.  Leak rate measurement and concentration measurement of high
                                         temperature fitting.
      Figure 4.  Leak rate by dilution  sweep and sampling of ambient hydrocarbon
                 fitting.  Low leak rates.
                                                                                                     Figure 6.  Hydrocarbon sampling from hot oil or solvent  transfer.
                                                                                                                                                            P-193

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30 days.  Therefore, the charcoal samples could stand for longer periods
without fear of losses, and were not usually analyzed until after the gas
samples in the same sets had been analyzed.  The charcoal eluates were
usually run within an hour after the carbon disulfide was added to displace
the sample components.
        Initial analysis of all samples was conducted using a gas chromato-
graph (GC).   Lower boiling component identifications were based on retention
times established by repeated analyses of standards.  If there were questions
as to the positive identity of a GC peak, the sample was rerun using GC/MS
methods for the identification.  This approach was often necessary because
a number of chromatographic peaks contained at least two and sometimes three
components.  The mass spectra also provided a basis for determining ratios
of the  components in the GC peak being examined.  These data were then used
in making quantitative measurements of the contents of chromatographically
unresolved but computer-integratable peaks.
        A Beckman Model GC-55 equipped with a precision temperature programmed
column oven and a flame ionization detector  (FID) was used for most of the
GC work performed on the program.  The column used was 1/8" O.D. by 6 ft.
long stainless steel tubing containing a stationary phase of 100-200 mesh
Poropak Q.  Using the analtyical conditions described below, this, column
furnished good resolution of the lowest boiling materials encountered while
still eluting with good results the higher boiling hydrocarbons representing.
the top of the range of interest.
        Analyses were performed using helium as the carrier gas at a flow
rate of 30 cc/min.  Detector gas flows were:  H  - 40 cc/min; air - 300
cc/min.  The following conditions were used for GC analyses:  6 min. at 40 °C
followed by temperature programming at 10  °C/min to 190 °C and isothermally
held at 190 °C for approximately one hour.
        The GC column effluent of the Beckman GC-55 gas chromatograph was
split into two streams.  One stream was directed to the FID of the GC, the
other to a heated transfer line which carried the stream to a Finigan Jet
Separator and into the mass spectrometer.  The separator provided a twenty
fold concentration of the material of interest in the gas stream.

                                     20-44

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        The mass spectrometer used on this program was  a Consolidated
Electrodynamics Corporation  (CEC) Model 21-104.  This was a  180 degree
magnetic sector instrument having an electron impact ion source and an
electron multiplier detector system which permitted moderately high-speed
mass scanning.
        Multiple MS scans were taken when a GC signal was observed on the
strip chart recorder.  Multiple scan studies indicated  that  approximately
2 seconds were required for the maxima to be observed by the MS.  Multiple
scans were required to insure representative ion pair formation.
        Mass spectra were interpreted manually using such reference works
as:
           "Compilation of Mass Spectral Data," Cornu, A. and R. Massot,
           Heyden & Son, Ltd., London, England, 1966.
           "Index of Mass Spectral Data," AMD II, American Soc.  for
           Testing and Materials, Philadelphia, 1969.
           "Eight Peak Index of Mass Spectra," Atomic Weapons Research
           Establishment, Aldermaston, England, 1970.
           "Atlas of Mass Spectra Data," Stenhagen,  E.,  et al.,  Inter-
           science, New York, NY, 1969.
           "API Project 44 Selected Mass Spectra Data,"  Thermodynamics
           Research Center, Texas ASM University.
        When an unknown peak could not be positively identified  by this
means, the spectrum was compared with the mass spectra of some  27,000
different compounds in the library of the Cyphernetics Corp.  Mass  Spectral
Search System.  This computerized search system is directly accessible on
a time-shared basis.  It was successfully used to verify assignments made
during the earlier work on this program.
        A spectrophotometric method similar to that  specified by the NIOSH
was used for the determination of aldehydes.   The total  volume of  liquid in
the aldehyde sample bulbs was measured,  and an aliquot taken  for the de-
termination.  The sample was allowed to react with a modified Schiff's
reagent prepared from rosanaline hydrochloride and sodium bisulfite.   After
a suitable development time,  the adsorbance was read at  580 my against a
                                                              P-193
                                    20-45

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reagent blank on a UV-vis spectrophotometer.  Concentration  was read from
a calibration curve.  The same determination was performed on a sample of
the sodium bisulfite used for collecting/stabilizing the aldehydes and a
1 yg/ml formaldehyde standard.  Results were calculated and reported as total
micrograms of formaldehyde equivalent in the sample.  The minimum amounts
of aldehydes that can be detected by this method are typically 1-3 yg total
 (as formaldehyde).

5.3     QUALITY CONTROL
        Despite a program budget which limited  the  special tests designed
for quality assessment every effort was taken in the field and laboratory  to
obtain as accurate and precise data as possible.  A consulting firm,
EcoScience Systems, Inc. of Riverside, California*  was  retained to supervise
the quality program, i.e. specify  tests to  be conducted and  procedures
to be followed and determine the overall error  in data.  Calibration  gas
mixtures, round robin testing, unknown blank samples, redundant samples
were techniques used to determine  the measurement error which was assessed to be
as follows:
           the calculated total hydrocarbon emissions were good to
           within +_ 25%
           values for the emissions of individual hydrocarbons, however,
           were  less certain than  that for  total hydrocarbons
           the sum of the errors in sampling and analyses for individual
           alkanes probably was in the range of 25-50%, and
           the concentrations of oxygenates, aromatics  and halogenates
           must  be  considered lower limits  only with the possible error
           being a  factor of three or more.
 *Principals included:   Dr.  James N. Pitts, Jr., Dr.  Daniel Grosjean and
  Dr. Barbara Finlayson-Pitts
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                                 REFERENCES
 1.     Environmental Protection Agency, "Comprehensive Data Handling Systems,
        Emissions Inventory/Permits and Registration Subsystem  (EIS/P&R) Program
        Documentation and Users Guide," February 1975.

 2.     Grisinger, J. E., "Development of Coordinate System Transformation
        Equations Required for Air Quality Modelling in the SCAB," GARB Staff
        Report, July 1977.

 3.     Environmental Protection Agency, "Compilation of Air Pollution Emission
        Factors," Supplements 1-7, Publication AP-42, April 1977.
 4.     Trijonis, J. C. and Arledge, K. W., "Impact of Reactivity Criteria
        on Organic Emission Control Strategies in the Metrolopitan Los Angeles
        AQCR," Report for EPA Contract 68-02-1735, July 1975.

 5.     Environmental Protection Agency, "Compilation of Air Pollution
        Emission Factors," Supplements 1-7, Publication AP-42, April 1977.

 6.     Personal communication with Wayne Zwiacher, SCAQMD.

 7.     Mery, R. C. and R. Stone, "Sanitary Landfill Behavior in an Aerobic
        Environment," Public Works, January 1966.

 8.     MacFarlane, I. C., "Gas Explosion Hazards in Sanitary Landfills,"
        Public Works, May 1970.

 9.     Dair, F. R. and R. E. Schwegler, "Energy Recovery From Landfills,"
        Waste Age, March/April 1974.

10.     California State Water Quality Control Board, "In-Situ Investigation
        of Movements of Gases Produced From Decomposing Refuse," Publication
        No. 31, 1965.

11.     Engineering Science, Inc., "Hydrocarbon Emissions from Fixed-Roof
        Petroleum Tanks," Western Oil & Gas Association,  July 1977.

12.     California Division of Oil and Gas, "Sixty-first Annual Report of
        the State Oil and Gas Supervisor,"  Report Number PR06, 1975.

13.     Personal communications with Robert Murray (SCAQMD) and Greg Barbaric,
        (VCAPCD) and John Laird (SBAPCD).

                                                              P-193
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14.     Burklin, C. E. and Honnckamp, R. L. , "Revision of Hydrocarbon
        Evaporative Emission Factors," EPA  450/3-76-039, August 1976.

15.     Air Resources Board, "Consideration of Model Organic Solvent Rule
        Applicable to Architectural Coatings," Staff Report, June 1977.

16.     Rasmussen, R. A., "What Do Hydrocarbons from Trees Contribute to
        Air Pollution," Journal of the APCA, Vol. 22, No. 7, July 1972.

17.     Personal Communications with Pat Zimmerman, Washington State
        University.

18.     Personal Communications with Mike Welsh, San Bernardino National
        Forest, National Forest Service.

19.     Mueller, F. X. and Miller, J. A., "Determination of Organic Vapors
        in Industrial Atmospheres," Amer. Lab., 49-61, May 1974.

20.     Levache, B.'and MacAskill, S. M., "Analysis of Organic Solvents
        Taken on Charcoal Samplers," Anal.  Chem., 48,  (1), 76-78, 1976.

21.     Nelson, G. O., et al., "Respiratory Cartridge Efficiency Statistics;
        VII.  Effect of Relative Humidity and  Temperature," Amer. Ind. Hyg.
        Assoc.  J., 37,  (5), 280-288, 1976.

22.     Parkes, D. G., et al., "A Simple Gas Chromatographic Method for the
        Analysis of Trace Organics in Ambient  Air," Amer. Ind. Hyg. Assoc. J.
        37,  (3), 165-173, 1976.
                                                                   P-193
                                      20-48

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QUESTION:
ANSWER:
CONDENSED DISCUSSION
 What provisions do you have for updating the
 i nventory?
 KVB does not have any contract or any respon-
 sibility for updating  it, per se.  We have
 turned over a data system in EIS format on
 tape.   If one wanted to update and change
 emission factors, the program is written in
 this way.   If someone wants floating roof
 tanks, for example,  reduced by 60%,  we can
 do that.  The  program is set up that it can
 be done.  We will give to ARB a complete set
 of documentations so they will  know  how to do
 it. Not being a programmer myself,  I don't
 really know how easy that is done.   Also
 emission profiles can be  changed by  source
 classification code.
                             20-49

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    "HIGHWAY MOTOR VEHICLE EMISSION FACTORS"
             Presented  at the 1977
        Environmental Protection Agency
      Emission Inventory/Factor Workshop
Raleigh, North Carolina - September 13-15, 1977
                      By
    Motor Vehicle Manufacturers  Association
             of the United  States,  Inc.
         For Presentation at  EPA Emission
             Inventory/Factor Workshop
              300 New Center  Building
              Detroit, Michigan   48202
               September 13-15,  1977
                  Presented by
               Walter S. Fagley, Jr.
               Chrysler Corporation
                 P. 0. Box 1118
                 Detroit, MI  48288
                      21-1

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Abstract



     The MVMA commends the holding of this workshop



intended to bring together information on the current



status, uses and needed improvements relating to



emission factors and inventories.  The emission factors



and inventory data are a necessary part of information



to relate the complex phenomena of emissions and air



quality.



     The purpose of this paper is to provide MVMA's



comments on the June, 1977, EPA Interim Document



entitled "Mobile Source Emission Factors" eventually



to be published as a supplement to AP-42.



     The EPA document represents a monumental effort



and consequently these comments are not intended



to be exhaustive.  While the  Interim Document provides



substantially improved discussions of the methodologies



used to derive the emission factors, it lacks complete



and detailed documentation of the experimental data



base and the computational and judgmental methods



used for translating those data into emission factors.



     The major thrust of this paper is on passenger



car exhaust and evaporative emission factors.  The



paper reviews data from past  emission surveillance



programs and compares the results to the emission
                           21-2

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factors contained in the Interim Document.   It  is



concluded that emission levels from uncontrolled cars



varied with model years.  However, a single  set of



"benchmarks" from which to judge progress is needed



and the 1960 model year was selected for this purpose.



Analysis shows that the 1960 model year baselines are



19 g/mi HC  (10.6 exhaust, 4.3 evap., and 4.1 crankcase),



84 g/mi CO and 4.1 g/mi NOx.  Exhaust emission  values



are based on the 1975 Federal Test Procedure.



     In estimating the contributions of vehicle



emissions to overall air quality, the emission



factors for controlled cars—past, present, and



future—are more significant than emissions from



uncontrolled cars.  The EPA Interim Document appears



to substantially overstate emissions from controlled



cars.  The overstatement of expected emission rates



for future cars is very large,  if one concedes even



moderate success by both manufacturers  and regulators



to improve emission performance of in-use vehicles.
                          21-3

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Introduction

     The purpose of this paper is to comment on the

motor vehicle emission factors contained in the June,

1977 EPA Interim Document entitled "Mobile Source

Emission Factors"  (Reference 1).  This EPA Interim

Document has been proposed to eventually revise the

previous mobile source emission factors that are

contained in the October, 1975 Supplement No. 5 to

AP-42.  In commenting on the proposed revision to

Supplement 5, it should be pointed out that the basic

purpose of AP-42 is to provide a compilation of

emission rate data without attempting to relate the

complex phenomena of emissions and ambient air quality.

Because air quality models are continually being

revised and improved, it is entirely proper to place

the responsibility of correctly applying the emission

factors with the user of AP-42.

     However, we believe the users of AP-42 should be

aware of the uncertainties involved in the emission

factors.  Data can only be intelligently applied if

the user is fully  aware of the associated questions
              *—
and qualifications.  It is to the credit of EPA that

this workshop allows airing of any controversy related

to its published emission factors.  In this same
                          21-4

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spirit, we appeal throughout  this  paper  for  more



complete documentation of the bases  for  emission



factors to be published in the  future.   Such



documentation would afford all  future users  some of



the advantages which will accrue to  the  attendees of



this workshop.



     This paper deals with mobile  source emission



factors and discusses some of the  problems and



uncertainties in the application of  emission factors.



Most of the discussion centers on  data related to the



1975 FTP certification driving cycle and procedures



developed to simulate urban driving, low average



speed, under conditions which may  contribute to peak



oxidant pollution.  There are, however, other urban



driving cycles and procedures characterized by low



average speed (under 20 mph), such as the US 7-mode,



the European ECE Regulation 15 and the Japanese hot



10-mode and cold 11-mode cycles.



     Although the low speed urban FTP cycle is the



basis for U.S. certification, some effort has gone



into characterizing emissions under other conditions.



Emission data are sometimes available on special



purpose cycles such as the EPA highway and sulfate



cycles; the SAE urban, suburban, and interstate
                          21-5

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driving cycles; and on various short test cycles that



are under investigation to find a less expensive way of



measuring emissions.  Since emission rates can be quite



different on each of these cycles, care should be



exercised in deciding which cycle and what adjustments



are necessary for the particular application at hand.



In practice, one usually selects the cycle for which



there are data and then may make appropriate adjust-



ments if needed.  Suggested procedures for adjustments



are included in AP-42 related to the 1975 FTP



certification cycle which is usually the cycle



selected for current applications in the United



States.  The validity of such adjustments is still



under investigation.



     As one example, EPA is currently studying the



possibility that the emission factors generated using



the 1975 FTP driving cycle overestimate the relevant



CO emissions.  This would be due to the fact that the



1975 FTP cycle has a cold start causing FTP CO



emission factors to be relatively high compared to hot



vehicle operation, particularly for catalyst cars.



Since most vehicles are usually warmed up by the time



they reach  (and have influence on) a CO "hot-spot"



in a city, the  1975 FTP cycle would not be appropriate
                         21-6

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and should be adjusted for such cases.  Since traffic



flow varies during the day and during the year, speed



correction factors and other adjustments should be



based on the conditions leading to high ambient CO



concentrations rather than blindly using only the FTP



cycle emission factors.



     When applying emission factors, one has to deal



with the definition of "ambient air" which is not



precisely defined.  At the tailpipe, CO emissions



are concentrated.  Somewhere between the tailpipe



and people the air quality standard is intended to



be achieved.  Exactly where this point occurs depends



primarily on judgment.  For example, New York City is



reported to have the worst carbon monoxide pollution



problem in the United States, based on EPA and New



York City measurements.  However, part of the reason



for the relatively high CO measurements is due to



differences in the location of the measurement



equipment.  In New York City the sampling probe is



closer to automotive tailpipes than sampling probes



in other cities allowing less time for dilution of



carbon monoxide.   According to the President's Council



on Environmental Quality (Reference 2):
                        21-7

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          "The New York City location of the


          sampling probe was at 8 feet above the


          curb; all other sites measured CO at


          heights of 8 to 18 feet, but at the


          building face several feet back from


          the curb.  One would expect that if the


          New York measurements were made at the


          building face, as in other cities, the


          measured CO levels and their frequencies


          of occurrence would be somewhat lower.


          Mobile monitoring data taken by the


          local New York agency, support this


          conclusion."






     It would be extremely unfortunate if trans-


portation control plans were established from


measurements based on the shortest distance between


sampling probe and tailpipe without considering


public health impacts.


     It has been assumed in the past that the exhaust


emissions from cars built prior to first exhaust


control in 1968  (1966 in California) could be


represented by a single set of emission rates
                                i

irrespective of model year.  Such values have been
                          21-8

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important not only as emission factors used  in



calculation of emission inventories, but as



"benchmarks" from which progress in emission control



could be based.  Analyses developed later  in this



paper lead us to conclude that this assumption  is



incorrect.



     As time progresses, the fraction of total



vehicle miles traveled  (VMT) represented by  pre-



controlled cars becomes smaller and smaller.



Furthermore, the proliferation of air monitoring



equipment has substantially decreased the possibility



of interest in selecting "base years" for air quality



projection calculations which would involve  a dominant



fraction of total VMT accounted for, by uncontrolled



cars.  Therefore it might be argued that concern over



the emission levels from such cars is academic.



While this may be largely true for the emission



factors use of uncontrolled car emission levels,



there remains a need for a set of benchmarks from



which to judge progress.  It has little meaning to



the layman to state that today's cars are controlled



to carbon monoxide emission levels of 15 g/mi.



However, one can make a reasonable judgment from the



statement that passenger car CO emissions are
                          21-9

-------
controlled to 82% of the level from uncontrolled cars.



We therefore believe it is desirable to have the best



possible assessment of emission levels from uncon-



trolled cars from available information.



     However, since the best information argues



against a single set of uncontrolled car emission



rates, it is necessary to select a model year



definition of the desired benchmark.  We have chosen



to define this benchmark as a 1960 model year



passenger car.  The reason for this choice is that



1960 was the most recent model year for which there



were no emission controls.  The positive crankcase



ventilation system  (PCV) to control blow-by crankcase



emissions was introduced in 1961 in California.



Nationwide installation began in 1963.  To complete



the history, exhaust emission control was first



established in California for 1966 model year vehicles



Federal exhaust emission control was first applied



for model year 1968 vehicles.  In 1970, evaporative



emission control was added to California vehicles



and nationwide in 1971.  Therefore, an uncontrolled



evaporative vehicle could be defined as a 1969 or



older  vehicle.
                          21-10

-------
     Due to the different dates for implementing



emission controls, a number of possible definitions of



uncontrolled vehicles could be made.  Although model



year 1960 was selected to represent baseline emissions



for completely uncontrolled passenger cars, data from



other model years are also presented for comparison



should a different definition be desired.



     Uncontrolled Crankcase Emissions



     Uncontrolled crankcase emissions were listed



as 4.1 g/mi hydrocarbon in EPA's Interim Document.



It appears that the 4.1 g/mi crankcase emission rate



for 1959-1962 cars was obtained from the work of



Kramer and Cernansky (Reference 3).   This value was



estimated by assuming an average blow-by volume of



1.1 cfm and an average hydrocarbon concentration of



15,000 ppm (as hexane)  and an average urban area



speed of 25 miles per hour.   Blow-by flow depends



not only upon vehicle speed but also upon fuel



tetraethyl lead concentration and mileage



(Reference 4).  We are aware of no data which would



indicate the 4.1 g/mi rate is not a  good estimate;



therefore, we endorse that value.
                         21-11

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     Uncontrolled Exhaust Emissions
     Sources of data on in-use exhaust emissions from
1965 and older vehicles are listed in Table 1.  Since
the Federal Test Procedure for exhaust emissions has
changed several times over the past, some of the
earlier data must be converted in order to compare
to more recent data using the 1975 FTP (see the
Appendix for a discussion of conversion factors).
There are uncertainties in this conversion process.
However, since the largest body of data on uncontrolled
passenger cars (over 1,200 vehicles) was taken using
tailpipe concentration measurements, this estimation
of 1975 FTP emissions was considered worthwhile.
The conversion was found to compare favorably with
measurements on uncontrolled vehicles using the 1975
FTP procedures directly.
     Data on uncontrolled exhaust levels are contained
in Table 2 and are plotted in Figures 1, 2 and 3.
The "mean line" in each Figure was plotted based
on a 2nd degree regression analysis according to the
methodology outlined in the Appendix.  It is
interesting to note that uncontrolled exhaust emissions
appear to have changed over time.  Hydrocarbon and
carbon monoxide emissions appear to have decreased
                          21-12

-------
from 1947 to 1965 while NOx increased.  One  reason



for this change can be attributed to a  shift in  model



mix incorporating greater numbers of automatic



transmissions.  Other changes in engine design



(e.g., increasing compression ratios and the shift



from L-head to overhead valve engines)  also  had  their



effect.



     Based on the "mean line" in Figures 1,  2 and 3



the uncontrolled (model year 1960) baseline  exhaust



emission level on the 1975 FTP is 10.6  g/mi  HC,  84



g/mi CO, and 4.1 g/mi NOx.  Emission levels  in EPA's



Interim Document for model year 1960 cars driven



in calendar year 1970 were listed as 9.9 g/mi HC,



124.8 g/mi CO, and 3.4 g/mi NOx.  The basis  for EPA's



numbers is not clear.  Carbon monoxide  emissions



appear excessively high.   There appears to be an



obvious need for better documentation of the basis



for that value.



     Uncontrolled Evaporative Emissions



     Table 2-13 in EPA's  Interim Document includes



evaporative emission rates in grams per mile for light



duty gasoline powered vehicles.   A value of 2.53 g/mi



was used for cars without evaporative emission



controls through and including model year 1970.
                          21-13

-------
There is a preponderance of evidence demonstrating
that this emission rate for cars without controls
is incorrect.  This rate errs on the low side as
a result of neglecting fuel tank running losses.
     In addition, there is a less serious but still
important controversy over conversion of the regulatory
gram per test basis for expressing evaporative
emissions to the more useful g/mi basis.  The first
apparent publication of such a conversion was made
by Professor John B. Heywood of MIT  (Reference 5).
Professor Heywood proposed the following formula:
     EVAP g/mi  = PS g/day      HS g/test
                  27 mi/day  +  7.5 mi/test
     Where DS = Diurnal Soak Emissions
     Where HS = Hot Soak Emissions

The EPA Interim Document, on the other hand, used
the following formula:
     EVAP  g/mi = DS g/day +  3.3 trips/day x HS g/test
                              29.4 mi/day
                          21-14

-------
The 3.3 trips per day and 29.4 miles per day values



are indicated to be national averages.



     To illustrate the magnitude of the difference



between these computational methods, the EPA Interim



Document uncontrolled value of 2.53 g/mi would become



2.92 g/mi under the MIT method.  While there is a



difference of approximately 2-1/2 miles per day



between these two methods, the more important



discrepancy is the effective miles per trip difference,



The Interim Document 29.4 mi/day with 3.3 trips



per day amounts to 8.9 mi/trip compared to the 7.5



mi/trip of the MIT method.  While numerically smaller



than the mi/day discrepancy, this is fractionally a



larger difference.  In the case of controlled cars,



the daily mileage divisor generally operates on a



substantially smaller g/test value, thus it makes



little difference in the diurnal soak contribution



to the g/mi value, whether one assumes a daily total



of 27 or 29.4 miles.



     Since urban emissions are of concern,  it would



appear that urban statistics rather than national



average statistics should be the basis of emission



computations.  Urban statistics are presumably the



basis of the exhaust emission 7.5 mile "test trip"
                         21-15

-------
and since this is the actual trip which "drives"
the measured hot soak emissions, it seems more
reasonable to us to select the 7.5 mile per trip
value.
     The Interim Document emission factor of 2.53
g/mi is based on data from EPA's Emission Factors
Surveillance Programs, primarily the FY 71 program
(Reference 9).  The FY 71 program unexplainably
neglected to include measurement of tank running
losses on uncontrolled cars.  Virtually all gasoline
powered passenger cars built in the last 40 years
used vented fuel tanks  (prior to evap. control).
Since automobile fuel tanks are heated during operating
of vehicle as a result of engine heat rejection, the
tank vapor space will necessarily exhale HC vapors
 (and air) through the tank vent during driving periods.
However, for the purpose of emission factors, 10 g/test
is a representative value  (Reference 8).  Therefore,
we recommend the following formula be used:
      EVAP  g/mi  =  PS  g/day   +    HS  +  RL  g/test
                  27  mi/day         7.5 ml/test
                          21-16

-------
     Published values of running losses from



automobile fuel tanks (References 6 and 7) vary  from



8 to 52 g.  If this latter value is added to the 14.7



g/test hot soak value of EPA's Interim Document  for



the uncontrolled car and the MIT method of conversion



is applied, a "correct" value for the uncontrolled



car of 4.3 g/mi is obtained.



     It is recommended that first the regulatory



test-to-g/mi emission rate conversion be based on the



MIT method; secondly, that the emission factor for



cars without evaporative emission controls be



corrected to include tank running losses, specifically



a value of 10 grams for the LA 4 test.  This would



result in an uncontrolled emission rate of 50.6  grams



per test or 4.3 g/mi.



     Uncontrolled Baseline Summary



     Based on the above analysis, the following base-



line was determined (1960 model year):



             HC             CO            NOx



Exhaust    10.6 g/mi      84 g/mi       4.1 g/mi



Evap        4.3            	            -—



Crankcase   4.1            —-            	
  TOTAL    19.0 g/mi      84 g/mi       4.1 g/mi
                          21-17

-------
Emissions from Controlled Vehicles
     Controlled Crankcase Emissions
     It is indicated in the Interim
     Document that "...crankcase hydrocarbon
     emissions from post-63 vehicles are
     negligible."  The values in Table 2-13
     of that document, on the other hand,
     imply a crankcase emission rate for
     MY 1963-1967 of 0.8 g/mi.  This is
     consistent with the information in
     Reference 3 that  the so-called open
     crankcase ventilation system applied
     during those model years was 80%
     effective in controlling crankcase
     hydrocarbon emissions.

     We believe the implied 0.8 g/mi rate
     for MY 1963-67 is a reasonable estimate
     and suggest the text be altered to
     correct the associated error.  A sep-
     aration of the tabular values for crank-
     case and evaporative emission factors
     in the Interim Document would further
     clarify the situation.
                          21-18

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We concur with the post-1967 crankcase
emission factor of zero, as given in the
Interim Document.  The "closed positive
crankcase ventilation system" used since
that time vents both the crankcase air
inlet and the ventilation outlet to the
engine induction system.  Since crankcase
blow-by emissions can only occur with the
engine operating, and the engine induc-
tion system is under negative pressure
when the engine is operating, it is
not possible for emissions to escape
from the crankcase directly to the
atmosphere.

Controlled Exhaust Emissions
Sources of data on in-use exhaust emissions
from controlled passenger cars are listed
in Table 3.  Most of these data come from
EPA's in-use surveillance programs.   Analysis
of these data will be divided into 1968 to
1974, and post-1974 model year categories.
                     21-19

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-  Post 1974 Cars
Tables 2-1 and 2-2 in EPA's Interim
Document list a common set of HC
and CO exhaust emission factors
 Cover the life of the car) for model
years 1975 through 1978.  The tabu-
lation on page II-9, on the other hand,
lists equations for computing emission
factors as a function of chronological
age for several standards scenarios
which might apply to post-1978 cars.
These emission factors reflect extremely
high additive "deterioration rates",
particularly with respect to the appli-
cable emission standards.  The accom-
panying text  (pages II-6 and II-7)
 indicates that these emission factors
were obtained from mileage regressions
 of FY 1974 program data of 1975 cars —
with some adjustments made (in the case
 of CO) to compensate for "... bias due
 to the rapid deterioration of the mal-
 adjusted vehicles..."
                21-20

-------
On Figures 4 and 5 the HC and CO



emission factors are plotted from



EPA's Tables 2-1 and 2-2 as a



function of miles based on the Interim



Document's indicated assumption of a



constant 10,000 miles per year.  The



figures also contain linear regressions



of the individual 1975 car data from



the FY 1974 program  (Reference 10).



In the case of exhaust HC, there is



virtually a perfect match of the least



squares straight line fit of the data



with the Interim Document emission



factors of Table 2-1.  In the case of



the CO data (Figure 5)  the change



stated in the Interim Document made



to the slope of the linear fit for



the "maladjustment bias" is evident.







The actual mileage extent of the test



data in Figures 4 and 5 was only



slightly over 40,000 miles.   Thus,



the extension of those lines to the



entire life of the car represents
                21-21

-------
substantial extrapolation — and
possible large errors.  Furthermore,
the data are assumed to be represented
by a straight line.  The corre-
lation coefficients of .195 and
.127 for the HC and CO data respec-
tively suggest that this is an
arbitrary assumption.

Also shown in Figures 4 and 5 are
the plot of a least squares fit of a
logarithmic mathematical model,
perhaps as equally arbitrary as a
linear model but, on the other hand,
just as rational  (correlation
coefficients with the log model are
also low at .164 and  .133 for HC and
CO respectively).  The logarithmic
model of these alternate curves
is similar to that employed by the
California Air Resources Board for
a number of years in analyzing its
surveillance data  (Reference 11
for example).  The logarithmic
                21-22

-------
model suggests substantially lower
emission factors, particularly
at the higher mileage associated
with vehicle ages beyond four or
five years.  The logarithmic model
assumes that the rate of deterioration
of exhaust emissions will be a con-
tinually decreasing function of miles.
It is suggested that this is con-
sistent with the assumption made in
the Interim Document that emission
levels cease to deteriorate after
10 years or 100,000 miles.  At
some point emissions would cease
to increase with age.

Data on NOx are plotted in Figure 6.
The linear regression line through
the FY 74 data has a significantly
lower slope than that of the Interim
Document emission factors.   Further,
the logarithmic fit of the FY 74 data
shows very low deterioration beyond
the initial 20,000 miles.   It is
                21-23

-------
believed the latter is more consistent
with actual observations of high
mileage NOx emissions.  It is a
common observation that if CO emissions
increase with mileage as a result of
air/fuel ratio richening, NOx emissions
are expected to decrease concurrently.

The brief analysis represented by
Figures 4 to 6 strongly suggests
that the very large deteriorations
assumed by the emission factors —
even for 1975 cars — are unrealistic.
Furthermore, the assumption that such
levels of deterioration will continue
indefinitely for future model years is
even more unrealistic.  While any
assessment of the FY 74 data indicates
that CO emission levels from 1975
cars are unfavorable relative to the
applicable standard, it is reasonable
to expect that situation to improve
as a result of the normal "learning
curve" process.
                21-24

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Moreover, there is activity underway
both by the manufacturers and within
the regulatory community to reduce
the probability and magnitude of
field maladjustment which appears
to be contributing so substantially
to this discrepancy between in-use
car emissions and their certification
levels (References 12, 13, 14).

Given the present statutory and
regulatory climate for air pollution
control,  the consequences of grossly
overstating probable emissions from
future passenger cars is profound.
MVMA, therefore, strongly urges that
the analytical bases and assumptions
used to generate the post-1974 model
year exhaust emission factors of the
Interim Document be re-examined.
                21-25

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-  1968 through 1974 Cars
It is disconcerting that the emission
factors for these model years listed
in Tables 2-1 and 2-2 of the Interim
Document show the same levels of
exhaust hydrocarbon and carbon monoxide
control throughout.  The HC and CO
standards, on the other hand, represent
three levels of control with stringency
of the original 1968 standards  (1966
in California) having been increased
in 1970 and again in 1972.  The oxides
of nitrogen emission factors of Table
2-3 appear to be at least directionally
consistent with the certification
standards throughout these model years.

These emission factors are indicated
by the Interim Document to be based
on the data from EPA's Emission Factors
Surveillance Programs of Fiscal Years
1971, 72, 73 and 74.  The data for
those programs prior to the FY 74
                21-26

-------
program have not been available to
us in the form which facilitated the
analysis of Figures 4 through 6 for
the 1975 cars — data for which were
included only in the FY 74 program.
However, test data for some vehicles
of the 1968 through 1974 model years
were included in the FY 74 program.
We have consequently performed
similar analyses of those data com-
paring the logarithmic with the
linear model.

Figures 7 through 9 depict those
analyses for the 1974 model data
illustrating that the relationship
of the logarithmic to the linear
models are generally similar to
that shown in Figures 4 through 6
for the 1975 model year — again
suggesting that the linear model
overstates the emission rates at
relatively high mileages.
                21-27

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An interesting relationship is



depicted by Figure 10 which shows



the analysis for exhaust hydrocarbon



emissions from 1973 model year cars.



Here the linear model shows a



decreasing emission rate trend with



increasing miles, whereas the



logarithmic model shows the normally



expected, albeit very modest, increase



in HC emission rate with miles.







As with the prior discussion of the



1975 model year data analysis, the



correlation of the emission data with



miles is very poor whether the linear



or the logarithmic model is chosen.



Correlation coefficients for these 21



data sets vary from  .006 to .327.



In some cases, the logarithmic model



displays slightly better correlation



coefficients whereas in other cases



the linear model appears to be a



better fit.  While MVMA does not
                 21-28

-------
          consider the "score" significant,
          the logarithmic model shows a better
          correlation for 12 out of these 21
          data sets.

          We believe these limited analyses
          of a portion of the data, which is
          indicated to support the emission
          factors for the 1968 through 1974
          model years, strongly suggest that
          those emission factors overstate
          the emission rates, particulary
          for HC and CO at high mileages.
          We therefore urge the EPA to re-
          analyze the total body of Emission
          Factor Surveillance data considering
          alternates to the linear model which
          could provide a significantly improved
          expression of the emission factors
          as a function of miles.

     Controlled Evaporative Emissions
     Table 2-12 of EPA's Interim Document indicates
evaporative emission rates for controlled light duty
                          21-29

-------
gasoline powered vehicles to be 1.76 g/mi for 1971
through 1977 cars, and .60 g/mi for 1978 and 1979
vehicles.  The value stated for the first generation
of evaporative controls  (though 1977) appears to
be incorrect.  That rate errs on the high side
because of reliance on a single data body which
apparently involves erroneous measurements.
In addition, there is the less serious but still
important controversy over conversion of the
regulatory gram per test basis for expressing
evaporative emissions to the g/mi basis as dis-
cussed earlier.  The 1.76 g/mi value would
become 2.05 g/mi under the MIT method  (Reference 5).
     The Interim Document emission factors are based
on data from EPA's Emission Factors Surveillance
Programs, primarily the FY 71 program  (Reference 9).
The indicated emission levels from first generation
controlled cars  (1971 through present) appear exces-
sively high.  Table 5 compares similar data from
three separate independent programs with the FY 71
data.  The independent data referenced in that
Table indicate that the EPA Emission Factor
Surveillance Program measurements of 24-27 grams per
test are high by more than a factor of 2.  The
                          21-30

-------
California Air Resources Board  (GARB) program involves



several times more in-use cars than did the EPA



program.  Furthermore, the GARB program was begun in



calendar year 1975 and benefitted by the mistakes



made in the earlier EPA programs.



     These high values obtained in the EPA surveillance



programs have not been explained.  However, from



available information it appears probable that



installing the fuel tank thermocouple through the



fuel tank cap may have resulted in vapor leaks.  This



assumption may explain both the larger discrepancy of



the diurnal soak values (diurnal soak emissions are



virtually 100% tank emissions) and the agreement



of the FY 71 results from uncontrolled cars with the



previously accepted values.  Such a vapor leak would



not affect emissions from uncontrolled vehicle tanks



which are already vented to atmosphere.



     Another possible explanation for the high



emissions from the FY 71 program is the difficulty



of proper placement of the tank fuel thermocouple



with the lead-through-the-cap approach.  With that



approach the thermocouple junction can easily lodge



in the fill pipe or the tank vapor space.  Attempts



to drive the resulting vapor temperature, rather
                          21-31

-------
than the intended liquid temperature, through the
prescribed excursion by heating the tank liquid,
results in unrealistically high emissions.
     A weighted average of the data from the first
three test programs of Table 5 yields 7.4 g/test
as representative of the first generation of emission
controls.  Similar treatment of the modal values
yields .81 g/mi by the MIT method  (i.e., 1.8 g diurnal
and 5.6 g hot soak).  The 1978 6 g/test standard,
on the other hand, assuming a 1.5/4.5 gram diurnal
soak to hot soak distribution results in .65 g/mi.
     Truck Exhaust Emission Factors
     The subject of truck emission factors is so
complex that an attempt will not be made to provide a
detailed treatment in this paper.  However, a few
brief comments are in order since there are serious
questions about the validity of the truck emission
factors contained in the Interim Document.
     Actually, there are three discrete populations -
the light duty vehicle  (less than  6000 Ibs. GVW),
the intermediate truck  (6001-8500 GVW), and the heavy
duty truck  (over 8500 Ibs. GVW).
     Because of differences in driving patterns,
load factors, N/V ratio, weight/power ratio and other
                          21-32

-------
factors, the use of passenger car deterioration rates
to the intermediate class of vehicles cannot be
justified.  The intermediate vehicle will not be
subjected to a chassis dynamometer certification test
until the 1979 model year, so there is almost a
total absence of vehicle data to provide an
uncontrolled baseline.
     The heavy duty truck is not subjected to
certification testing.  In this category, the engine
is tested and certified.  A separate MVMA panel is
currently engaged in a project to develop factual
heavy duty engine baselines.  As with the inter-
mediate vehicle, the extensive data and deterioration
rates determined for passenger cars and intermediate
trucks to the heavy truck category cannot be justified.
Data are simply not interchangeable between the
three populations.
     As  an example,  our concern  over  the  validity
of the truck data, Table 3-1 of the Interim
Document shows higher than precontrol carbon monoxide
emissions for the 1970-78 model year trucks C6001 to
8500 Ibs. GW) .  By contrast, an analysis of the test
results  from the same program, as shown in Figure 11
(Reference 15), indicates more than a 60% control of
                          21-33

-------
CO from 1972-73 trucks.  This discrepancy between
two analyses is not explained.  Figure 11 also raises
a similar question on exhaust hydrocarbon emissions.
In the case of hydrocarbons, the new vehicle emission
rates of Figure 3-1 indicate a control of about 33%,
whereas, the data in Figure 11 suggests control
of more than 50%.
     It. is further indicated in the Interim Document
that the average age of the uncontrolled 6001-8500
Ibs. GVW trucks used in the program was seven years
and that the new truck emission factor was
extrapolated back from the deterioration rate of
precontrolled passenger cars.  In view of our earlier
comments on passenger car deterioration rates, the
application of these deterioration rates to a
completely different class of vehicles is unjustified.
                          21-34

-------
Summary



  The following summarizes the major conclusions of



this paper:



     .  Emission factor data in AP-42 are based on



        the 1975 FTP cycle used for U.S. certification.



        In applying such data the user should first



        check to see if this cycle is applicable



        to his analysis.   If not, appropriate



        adjustments should be made.



        Emission levels from uncontrolled cars was



        found to vary with model year.  Model year



        1960 was selected as the uncontrolled



        "benchmark".  Uncontrolled emissions from



        1960 model year passenger cars were found



        to be 19 g/mi HC (10.6 exhaust, 4.3 evaporative



        and 4.1 crankcase), 84 g/mi CO and 4.1 g/mi NOx.



        The AP-42 uncontrolled CO emission rate



        of 124.8 g/mi for 1960 cars driven in calendar



        year 1970 appears to be excessively high.



        Better documentation of the basis for AP-42



        emission numbers  is needed.



        The AP-42 evaporative emission rate for



        uncontrolled cars errs on the low side as a



        result of neglecting fuel tank running losses.
                         21-35

-------
  It  is recommended  that  the  regulatory
  evaporative  test-to-g/mi  emission rate
  conversion be  based  on  the  MIT method
   (Reference 5).
  Emission  factors in  AP-42 for controlled
  vehicle exhaust emissions reflect extremely
  high additive  deterioration rates extrapolated
  beyond the set of  data  used to estimate these
  rates.  It is  recommended that some credit
  be  given  to  the activity  by both manufacturer
  and regulator  to reduce the probability and
  magnitude for  high deterioration in future
  vehicles.
.  Controlled evaporative  emissions for the
   first  generation of  emission controls  are
   estimated to be 0.81 g/mi.   The AP-42  appears
   to  be  excessively  high  (1.76 g/mi).
   Trucks of different  Gross Vehicle Weights
   have been categorized as  light, medium and
   heavy  duty.   All of  these categories have
   emission  related  characteristics different
   than passenger cars.  The application by EPA
   of  passenger car  emission deterioration rates
                     21-36

-------
and other characteristics to these vehicles



is therefore inapproriate and appears to have



resulted in substantial understatement of



current levels of control.
                 21-37

-------
                      REFERENCES

1.   "Mobile Source Emission Factors," EPA Interim
     Document, OTLUP, Washington, D.C., June, 1977.

2.   Seventh Annual Report to the President's Council
     on Environmental Quality, 1976.

3.   R. L. Kramer and H. P. Cernansky, "Motor Vehicle
     Emission Rates," U.S. Department of Health,
     Education and Welfare, Durham, N.C., August 15,
     1970.

4.   J.C. Gagliardi and F.E. Ghannam, "Effects of
     Tetraethyl Lead Concentration on Exhaust
     Emissions in Customer Type Vehicle Operation,"
     SAE 690015, January, 1969.

5.   John B. Heywood, "Statement to the Subcommittee
     on Public Health and Environment,"  Interstate
     and Foreign Commerce Committee, U.S. House of
     Representatives, Washington, D.C.
     December 4, 1973.

6.   D.T. Wade, "Factors Influencing Vehicle
     Evaporative Emissions," Society of Automotive
     Engineers Paper No. 670126, January, 1967.

7.   "Fuel System Evaporative Losses," issued by the
     Automobile Manufacturers Association, AMA
     Engineering Notes 616, September, 1961.

8.   S.W. Martens and E.E. Nelson, "Current Status
     of Vehicle Evaporative Emission Control,"
     presented at Fourth Annual North American
     Motor Vehicle Emissions Control Conference,
     Anaheim, California, November 5, 1975.

9.   CALSPAN Corporation, "Automobile Exhaust Emission
     Surveillance - A Summary," Document No. APTD-1544,
     prepared for Environmental Protection Agency,
     Office of Air and Water Programs, Office of
     Mobile Source Air Pollution Control, Ann Arbor,
     Michigan, May, 1973.
                          21-38

-------
10.  "Automobile Exhaust Emission Surveillance
     Analysis of the FY 1974 Program," EPA-460/
     3-76-019.

11.  "Exhaust Emissions from Privately Owned 1966-
     1973 California Automobiles, A Statistical
     Evaluation of Surveillance Data," Supplement
     of Progress Report No. 34, Surveillance of Motor
     Vehicle Emissions in California, California Air
     Resources Laboratory, El Monte, California,
     May 1974.

12.  Statement of General Motors Corporation to EPA -
     Waiver Hearing on Adjustability of Idle Mixture
     Mechanism, San Francisco, California, May 18, 1977,

13.  State of California Air Resources Board
     "California Exhaust Emission Standards and Test
     Procedures for 1980 and Subsequent Model
     Passenger Cars, Light Duty Trucks, and Medium
     Duty Vehicles" - Adopted November 23, 1976,
     amended June 22, 1977.

14.  "New Motor Vehicle Certification, Intent to
     Develop Rulemaking," EPA, Federal Register,
     Volume 42, No. 104, May 31, 1977.

15.  "Historical Development of Heavy Duty Gasoline
     Engine Dynamometer Emissions Test Cycle and
     Emissions Standards," Motor Vehicle Manufacturers
     Association, Detroit, Michigan.

16.  "Los Angeles Auto Exhaust Test Station Project -
     A Joint Agency Report, 1961-1963", Air Pollution
     Control District, County of Los Angeles,
     California, Automobile Club of Southern
     California, Automobile Manufacturers Association,
     Detroit, Michigan California Department of
     Public Health, California Motor Vehicle Pollution
     Control Board, California Highway Patrol,  United
     States Public Health Service.

17.  "Baseline Reactivity Survey,"  California Air
     Resources Board, Los Angeles,  California,
     February, 1968.
                         21-39

-------
18.  "Surveillance of Motor Vehicle Emissions in
     California, Quarterly Progress Report No. 15,
     January-March, 1969", California Air Resources
     Board, Los Angeles, California.

19.  "A Study of Mandatory Engine Maintenance for
     Reducing Vehicle Exhaust Emissions," CRC-APRAC
     Project CAPE-13-68 and EPA by TRW and Scott
     Research Laboratories, July, 1973.

20.  D.W. Houser, R.F. Irwin, L.J. Painter, G.H.
     Amberg, "Field Tests Show Gasoline Deposit
     Control Additives Effective in Emission
     Reduction," APCA Meeting June, 1971.

21.  The Great Plains Surveillance Program, FY 69.

22.  The National Surveillance Program — Phase I,
     FY 70.

23.  The National Surveillance Program — Phase II,
     FY 70.

24.  Marcia E. Williams, John T. White, Lois A.
     Platte, Charles J. Domke, "Automotive Exhaust
     Emission Surveillance - Analysis of the FY 72
     Program," EPA - 460/2-74-001, U.S. Environmental
     Protection Agency, Ann Arbor, Michigan,
     February, 1974.

25.  Jeffrey Bernard, Paul Donovan, H.T. McAdams,
     "Automobile Exhaust Emission Surveillance
     Analysis of the FY 73 Program," EPA -
     460/3-75-007, Prepared by CALSPAN CORPORATION
     for the U.S. Environmental Protection Agency,
     Ann Arbor, Michigan, July, 1975.

26.  H.A. Ashby, R.C. Stahman, B. H. Eccleston,
     R.W. Hurn, "Vehicle Emissions - Summer to
     Winter," Society of Automotive Engineers
     Paper No. 741053, Presented at Toronto,
     Ontario, Canada, October, 1974.
                          21-40

-------
27.  Study of Emissions from Light-Duty Vehicles
     in Seven Cities, FY 75 (unpublished).

28.  P.J. Clarke, "Investigation and Assessment
     of Light Duty Vehicle Evaporative Emission
     Sources and Control," Document No. EPA-
     460/3-76-014, prepared for Environmental
     Protection Agency, Office of Air and Waste
     Management, Office of Mobile Source Air Pollution
     Control, Ann Arbor, Michigan, June, 1976.

29.  T.M. Fisher, Letter to Eric O. Stork of the U.S.
     Environmental Protection Agency, General Motors
     Corporation Warren, Michigan, May 14, 1976.

30.  "Surveillance of Evaporative Emissions from 1970
     to 1976 Year Model Vehicles by the SHED Method,"
     Project E. Progress Report No. 5, Air Resources
     Board, 9528 Telstar Avenue, El Monte, California,
     March, 1976.

31.  California Department of Public Health, Progress
     Report - Motor Vehicle Emissions and Proposed
     Standards, January 8, 1964.

32.  Thomas A. Huls, "Evolution of Federal Light
     Duty Mass Emission Regulations," Society of
     Automotive Engineers paper 730554, presented
     at the Automobile Engineering Meeting, Detroit,
     Michigan, May 1973.

33.  S.H. Mick and J.B. Clark, Jr., "Weighing
     Automotive Exhaust Emissions," Society of
     Automotive Engineers paper 690523, May 1969.

34.  "California Test Procedure and Criteria for
     Motor Vehicle Exhaust Emission Control,"
     State of California, Motor Vehicle Pollution
     Control Board,  January 23, 1964.

35.  "1975 Emission Standards  for Hydrocarbons and
     Carbon Monoxide Applicable to Light Duty
     Vehicles," Notice of Proposed Rulemaking,
     U.S. EPA, Federal Register, Vol. 36, No. 39,
     February 26, 1971.
                          21-41

-------
36.  "Exhaust Emission Standards and Test Procedures",
     U.S. EPA, Federal Register, Vol. 36, No. 128,
     July 2, 1972.

37-  A.J. Hooker, "Summary of Oxides of Nitrogen
     Test Methods and Test Data," California Air
     Resources Board, Los Angeles, California,
     May 26, 1969.
                          21-42

-------
                                TABLE I
              Exhaust Emission Data on 1965 and Older Vehicles
                              Number of Vehicles
Source

1962 California
  Program
Baseline
  Reactivity
  Survey

CARS Study
Rose Bowl Study
Year
Completed
1962
1968
1969
1965
and Older
1000
212
12*
Driving
Cycle
Hot 8-
Mode
Hot 7-
Mode
Hot 7-
Node
Reference
Dumber
16
17
18
                    1971
EPA FY 71
  Program by AESI** 1973
CRC - Maintenance
  Study
161
                                      337
                    1973
7-Mode
          1975 FTP
          1972 FTP
20
                   19
 *  Includes HC and CO data only  for  a  substantially
      larger number of 1965 cars.

 ** FY 71 program included  uncontrolled 1966/67 49 state cars.
                                  21-43

-------
                          TABLE 2
Model
Year

1947

1948

1949

1950

1951

1952

1953

1954

1955

1956

1957

1958

1959

1960

1961

1962

1963

1964

1965
otive
HC
16.6
15.9
15.3
14.7
14.1
13.6
13.1
12.6
12.2
11.8
11.4
11.1
10.8
10.6
10.4
10.2
10,1
10.0
9.9
Exhaust Emissions
Mean Line
Exhaust Emissions g/mL
(1975 FTP)
CO
108
105
102
100
97
95
93
91
90
88
87
86
85
84
84
83
83
83
84
NOV
i
2.8
2.9
3.1
3.3
3.4
3.5
3.7
3.8
3.9
3.9
4.0
4.1
4.1
4.1
4.1
4.1
4.1
4.1
4.1
                            21-44

-------
                                 TABLE 3
In-Use Exhaust Emission Data on Controlled Vehicles
Source
CRC Vehicle
Emission
Tests
EPA FY 69
EPA FY 70-1
EPA FY 70-11
EPA FY 71
CRC Main-
tenance
Study
EPA FY 72
EPA FY 73

EPA FY 74
EPA FY 75
Model Number of Driving Evap.
Years Vehicles Cycle Emissions
1967-1968
1968-1969
1970
1971
1957-1971
1960-1971
1966-1972
1967-1974
1967-1975
1965-1975
1968-1976
188
2029
2101
369
1020
486
1020
1080
26
1968
2220
7-mode
7-mode No
7-mode No
7-mode No
1972/1975 FTP Yes
1972 FTP,
loaded mode-
idle
1972/1975 FTP Yes
1972/1975 FTP, Yes
short tests,
and modal
1975 FTP No
1974 FTP, HWFET, No
short tests, and
modal
1975 FTP, HWFET,
short tests, and
modal
Reference
Number
*
21
22
23
8
18
24
25
26
9
27
* Unpublished data generated in  the program summarized
  in Reference 19
                                21-45

-------
                                TABLE  4
Evaporative Emissions from In-Use Cars
Measured by the SHED Techniques
Model
Laboratory Year
Exxon 1973-75
GM 1970-72
CARB 1970-76
AESI(PY 71) 1970-71
Number
of
Cars
20
20
109
31
Mean
Emission
Total
g/test
8.99*
8.7
6.9
27.2
Diurnal
Soak
9
1.6*
3.37
1.5
16.28
Hot
Soak
g Reference
7.9* 28
5.36 29
5.4 30
10.92 8
* Exxon data uncorrected for non-fuel background emissions,
  modal average based on 18 of the 20 test care.
                                 21-46

-------
                                                    FIGURE I



                                                UNCONTROLLED AUTOMOTIVE HC
ro
Y->
                                  IS
  HC

g/ml by


1975 FTP
                                  10
                                  0
                                                                         •ToI Iplp* Dolo
                                                             MEAN LINE
                                                                       V—FY71  Dot*
                                                           i
                                    1945
                      1950
 I8S5       I960

MODEL YEAR
tees
1970

-------
                                                              FIGURE 2
                                                        UNCONTROLLED AUTOMOTIVE CO
N>
e*
s
          126


          100

  CO
Q/nl  by    75
1875 FTP

           S0


           25
                                                                                              MEAN UZNB
                                             liiiitii  iJt  it  tit  ill  1  I  t  i . i _. I
                                         104S       I960        1866        IO60        1966

                                                            HOOEL YEAR
                                                                      IQ7«

-------
                                                              FIGURE 3


                                                       UNCONTROLLED  AUTOMOTIVE NOx
NJ
h-

4N
VO
 NOx

8/ml  by

 1975 FTP
                                      e
                *•*
                                                                                      / Tollplp* Doto
                                                                                         Doko
                                                               1
              I  I  I  I  I  I  I  I  I  I  I  I  I  I  I  I  I  I  I  i  lilt
                                       1948
                     I860
1856        1868

 MODEL YEAR
1866
1878

-------
HC
     3—
     2—
     f irmnni
                                       FIGURE 4
                                    LOV EMISSION KATES
                                    MODEL YEAR 1975
                                  EXHAUST HYDROCARBONS
                                                       UiwarFtt
                                                                    0f FY74 Data
                I      I      I      I      I      I      II      II
       8.8   8.1    8,2   9.3   8.4   8.5   8.6   8.7    8,8    8.9    1.8
                                        MILES/10s
                                       21-50

-------
     80 —
     60 —
CO
•/ml
     40 —
    20 H
      0
                                        FIGURE 5
                                     LDV EMISSION RATES
                                      MODEL YEAR 1975
                                     CARBON MONOXIDE
                                                     Ufwar Fit
                                                 X DMlonatw toimlnal mlUag* of FY74 Data
                 T     T      T
        0.0   0.1    0.2   0.3
 I       I       I       II      I       I
B..4   0.5   0.6   0.7   0.8    0.9    1.0
     MILES/105
                                         21-51

-------
      3 —
NOv
a/ml
      2 —
                                             FIGURE 6
                                        LDV EMISSION RATES
                                          MODEL YEAR 1975
                                        OXIDES OF NITROGEN

                                           Emiulon Focton
                                                        Logarithmic Fit
                                                  X DMignatw Terminal MiUaa* of FY74 Data
                 I       I       I        I        I        1        I       I       I        I
        0.8   e.l    0.2   8.3    0.4    0.5    0.6    8.7   8.8   8.8   1.8
                                           MILES/105
                                           21-52

-------
 HC
g/mi
                                          FIGURE 7

                            Automotive Exhaust HC Emission Levels
                                     Fits of FY 74 Data
                                          1974 Models
                                                   Logarithmic Model
                  I      I      I      I      I      I      I      I      I
          e.e   e.i   9.2  0.3  e.4   e.s   e.o   8.7   e.e  a.9   t.e
                                                                         HC74/HC74A
                                       21-53

-------
                                         FIGURE 8

                                Automotive CO Emission Levels
                                       Fits of FY 74 Data
                                	1974 Models
      68—1
      48—
 CO
g/ai
      28-
       8-
         8.8
  I
8.1
8.2   8.3
  I
8.4
       I
     8.5

Miles/(8S
 I      I      I      I      I
1.6  8.7  8.8  8.8   1.8
                                                                       C074/C074A
                                       21-54

-------
                               FIGURE 9
                        Automotive NOX Emission Levels
                             Fits of FY 74 Data
                                 1974 Models      	
5—
3-
1 —
         I      I      I      I      I      I      I      I      I      I
  0.0   0.1    8.2   0.3   0.4   0.5   0.0   0.7   0.8   0.9   1.0
                           Miles/18~
                                                            NOX74/NOX74A
                              21-55

-------
                                    4—1
                                    3 —
                                    2 —
(Jl
                                                                  FIGURE 10

                                                         Automotive Exhauat HC Emission Levels

                                                               fit* of r* 74 Bata

                                                                 It?3 Model*
                                                                                U)q«rithrai-c Model
                                                                                              Una«r
                                              i       i      i       i       t      i      i       i       r    I
                                     8.8   0-t    8,2    8.3   8.4   8,5   8.8   8.7   8.8   8.9   1.8
                                                                         »6
                                                                      X18*
                                                                                                    HC73/HC73A

-------
§
M
Bh
II
So
   *    i
£83   '
tan   a
 M T>
24

22.

20

18

16

U

12

10

 8

 6

 4

 2

 0
                                   MC
                          1963 - 69 Unoootrolled
                  1969 Calif. 1970 - 71 Fed
                     HC std - 275
                                1972 - 73 HC St
-------
      APPENDIX
  Uncontrolled Car

Exhaust Emission Data
         and

  Their Adjustment
        21-58

-------
     Huls formally published in 1973  (Reference  32}



the EPA development of uncontrolled car baseline



exhaust HC and CO values for the 1972 Federal  Test



Procedure (FTP).  The 1972 FTP and its successor,



the 1975 FTP, obtain a direct mass rate of emissions



by diluting the vehicle exhaust stream  (with air)



to a constant fixed flow rate and measuring the



pollutant concentrations in that stream—hence the



term Constant Volume Sampler (CVS); see for example



Reference 33.  Huls1 values, 16.8 g/mi HC and  126



g/mi CO were obtained by correcting a large bank of



7-mode (Reference 34)  and similar tailpipe test  data



to the CVS procedure via empirical factors



developed from tests of 30 uncontrolled cars.  These



values further adjusted to 15 g/mi HC and 90 g/mi



CO when a correction was made for the "cold/hot



weighted" 1975 FTP—References 35 and 36 list



"statutory"  HC/CO standards of .46/4.7 and .41/3.4



based on the 1972 FTP and the 1975  FTP respectively.



The HC and CO 1975 FTP/1972 FTP corrections are



therefore .891 and .723.



     At about the same time as the  Huls' publication,



EPA released results of a field survey in which
                         21-59

-------
customer cars were actually directly tested using the
CVS method and included a substantial number of
uncontrolled cars  (Reference 9).  Data from those
uncontrolled cars averaged 8.7  g/mi exhaust HC and 87
g/mi CO over the 1975 FTP.  This latter exhaust HC
level represents a very large discrepancy compared
to the above 15 g/mi value.  We are aware of no
previous attempt to rationalize the difference between
these two sets of  "baseline" values.
     It seems apparent to us from the plot of the
two bodies of data in Figure 1  that the major
difference in the  two "baselines" is the model year
make up of the two car populations involved.
Although to our knowledge EPA has never formally
published the sources of the data body which made up
the 7-mode cycle baseline values, we believe that
the HC data we have assembled from the literature
represents essentially all that is available and
therefore must be  roughly equivalent to the data body
used by Huls.
     Note in Figure 1 that the  so-called tailpipe
data  (primarily 7~mode cycle data) have been
corrected to the 1975 FTP basis.  Table A-l details
the actual tailpipe data from the various surveys
                          21-60

-------
together with the corresponding 1975 FTP value.
In addition, it lists the weighted average of the
latter values which were used to form the "tailpipe
data" plot of Figure 1.
     Huls showed that the average car over the 7-mode
cycle, at the 2.2 g/mi HC standard of 1970, would have
a composite concentration value of 180 ppm.  Conse-
quently, the correction factor from composite tailpipe
concentration values to 1970 FTP g/mi values is .0122.
This value is then adjusted to the 1972 FTP by a
multiplying correction factor according to Huls of
1.38, and in turn by a factor of 0.891 as indicated
above to correct to the 1975 FTP.  It is shown in
Reference 31 that the average car tested on the cold
start 7-mode cycle (1970 FTP)  produced HC values
1.101 times that of the hot7-mode cycle.  All of the
concentration data as indicated on Table A-l were
based on test from a hot start because of the
practical problems of testing very large numbers of
cars.  In addition, Reference 30 details the basis
for an adjustment factor of 1.212 to the 8-mode cycle
hot start HC concentrations of the Los Angeles Test
Station Project (Reference 16).   Thus, the latter
data have been corrected to the 1975 FTP basis through
                         21-61

-------
multiplication by correction factors of 1.212
x .0122 x 1.38 x .891.  The Baseline Reactivity
survey  (Reference 17) and the 194 Car Survey data
were corrected to 1975 FTP by a multiplicitive
correction factor of 1.101 x .0122 x 1.38 x .891.
Finally the Rose Bowl survey performed on the 1970
FTP basis was corrected simply by multiplication
of 1.101 x 1.38 x .891.
     While it is obvious from Figure 1 that the
direct  1975 FTP measurements of the FY 1971 program
are similar to the older tailpipe data for the same
model years, there does remain a small discrepancy.
Since we have no basis to choose one set of values
over the other, we have assumed in Table A-2, whose
values  generated the mean line of Figure 1, that the
true value for the average emission rate of the
"overlapping" model years is midway between the
corrected tailpipe values and the FY 71 values.  To
be specific, the corrected data of Table A-2 were
obtained by averaging the 1957 through 1965 values
from both data bodies, and adjusting the tailpipe
data downward by half the difference and the FY 71
data upward by half the difference.  The mean line
of Figure 1 then is a least-^s^uaresr fit ef a second
                          21-62

-------
degree polynomial to that corrected data.
     The carbon monoxide tailpipe data of Table A-3
were similarly obtained from the correction factors of
Huls*~-23.0 from tailpipe concentrations to 1970 FTP
g/rai and 1.58 from 1970 FTP to 1972 FTP and from
References 35 and 36 the adjustment from 1972 FTP
to 1975 FTP for carbon monoxide is .723.  Reference
31 indicates that the tailpipe carbon monoxide
values for uncontrolled cars from hot start compared
with cold start were not significantly different
and consequently no hot start to cold corrections
factor is required.  Similarly, Reference 31
further states that the test cycle and other
corrections made to the Los Angeles Test Station
HC data are unnecessary for carbon monoxide.
Consequently, the tailpipe concentration CO data
for the Los Angeles Test Station Project, the Baseline
Reactivity Survey and the 194 Car Survey have been
corrected to the 1975 FTP by multiplication of 23.0
x 1.58 x .723.  The Rose Bowl Survey data,  on the
other hand, were simply corrected by adjustment from
the 1970 FTP to the 1975 FTP, i.e., by a multiplication
of 1.58 x .723.
                         21-63

-------
     Analogous to Table A-2, the data detailed in
Table A-4 show the adjustment made to the tailpipe
CO data and the FY 71 1975 FTP data to a common
1957-1965 average value.  The latter finally resulted
in the mean line of Figure 2 which is, similar to the
HC mean line of Figure 1, a least-squares second
degree polynomial fit of the Table A-4 data.
     Published documentation for conversion of
tailpipe concentration NOx data from one test type
to another and from the tailpipe to the CVS basis
is less complete than the foregoing conversion
procedures for exhaust HC and CO.  As far as we
are aware, there has been no publication of back-
to-back 1970 FTP measurements versus 1975 FTP
measurements for NOx—of the type described by Huls
for HC and CO.  However, the conversions used for
Table A-5 require such relationship.
     An experimental program was conducted by
General Motors using 27 pre-1968 cars.  That test
program, which involves back-to-back tests on the
1970 FTP and the 1972  (CVS) FTP, is summarized in
Table A~7.  The indicated weighting of those
"equivalence ratios" for a realistic distribution
of the cars in the population of the early 1960's
                          21-64

-------
 (by manufacturer) is indicated to produce a correction



 factor of 1.082.  As indicated on Table A-7 References



 35 and 36 indicate that this conversion factor should



 be in turn multiplied by the ratio 3.1/3.0 to result



 in the final correction factor of 1.118 to obtain



 1975 FTP values from 1970 FTP data.



     Analogous to the previously described relationship



 developed by Huls for converting tailpipe concentration



 values to 1970 FTP g/mile values for HC and CO, the



 NOx tailpipe concentration from the average car should



 be multiplied by the factor .0037 to obtain the 1970



 FTP value. Reference 31 indicates that there is not



 an appropriate correction factor for converting the



 8-mode cycle tailpipe concentration values of the



 Test Station Project, nor the hot start test to the



 1970 FTP basis. Consequently, these values have been



 assumed to be related to 1970 FTP values by a factor



 of 1.



     The Test Station Project tailpipe NOx concentration



 values have consequently been multiplied by an overall



 correction factor of .0037 x 1.118 x 3.1/3.0 to



 convert to the 1975 FTP g/mile basis.   It was necessary,



 in addition, to divide the resulting values for the



Baseline Reactivity Survey data by 1.5 since those NOx
                          21-65

-------
data were obtained by "bagging" the entire exhaust of



the 7-mode cycle which includes some normally unsampled



heavy load operation  (Reference 37).  The Rose Bowl



survey, on the other hand, which is originally given



in 1970 FTP g/mile, has simply been multiplied by



1.118 x 3.1/3.0.



     As a final note, it is well to acknowledge that



the tailpipe data used in these analyses does not



include the  "GARB Study" (Reference 18) included in



Table I.  As indicated in Table I, only 12 of the 1965



test cars involved NOx measurements.  Furthermore,
      »-


the only other model years accounted for by that



"study" were 1966 and 1967.  Exhaust controls were



required for both those model years in California.



We understand that the 1966/67 cars considered



"uncontrolled" in that program were "imports" from



outside the state.  Nonetheless, their inclusion



raise questions for which satisfactory documentation



is unavailable.  Consideration of  those questions,



and the fact that a single model year from one test



program could unduly  influence the "shape" of the



final emissions--vs.—model year relationship, led us



to reject the "CARS Study" data for this analysis.
                          21-66

-------
to
H*
                                                                                                Table A-l
                                                                         Exhaust HC Tailpipe Measurements from Uncontrolled Cars
Model
Year
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
Test
Los Angeles ,*
Station Project16
Reactivity Survey
Cone.. 1975 FTP,
N
4
6
7
23
25
16
39
50
89
100
112
72
109
109
108
151
13
»
.
PUB
862
1148
918
896
932
900
832
805
780
732
629
625
657
646
731
635
563
»
.
g/ml
15.7
20.9
16.8
16.1
16.9
16.5
15.2
14.7
14.2
13.4
11.4
11.3
11.9
11.8
13.4
11.5
10.3
.
-
N
.
»
1
„
..
»
2
2
1
1
6
5
6
9
16
21
51
45
46
1974 Car Survey31
Cone., 1975 FTP,
ppm

M
795
.
.
M
987
841
617
509
834
912
635
1987
942
711
628
937
763
3/ml _
.
„
13.1
_
.
.
16.3
13.9
10.2
8.4
13.8
15.1
10.5
32.8
15.6
11.7
10.4
15.5
12.6
N
.
2
5
8
13
9
12
13
26
22
15
n
17
16
19

.
.
-
Cone., 1975 FTP.
ppm

957
854
1028
951
1083
914
900
774
1008
1005
732
718
757
751

.
.
-
g/ml
—
15.8
14.1
17.0
15.7
17.9
15.1
14.9
12.8
16.7
16.6
12.1
11.9
12.5
12.4

_
.
-
Rose BOM! Survey
1970 FTP,
N










.
5
3
12
14
24
30
38
35
o/m1










.
7.00
6.52
6.94
5.93
6.06
8.15
7.14
7.21
1975 FTP,
a/ml










-
9.5
8.8
9.4
8.0
8.2
11.0
9.7
9.7
Weighted
Average
1975 FTP,
g/m1
15.7
. 19.6
15.5
16.3
16.5
17.0
15.2
14.7
13.9
13.9
12.1
11.5
11.6
13.0
13.0
11.1
10.6
12.8
11.3
                                               Notes  o Superscripts on each survey title  Indicate associated reference number.
                                                      ON- Number of cars tested.
                                                      o LA Test Station data were obtained using  an 8-mode cycle—from hot start.
                                                      o Reactivity Survey data were obtained using the  7-mode cycle—from hot start.
                                                      o 194 Car Survey data Mere obtained  via weighted  7-mode/11 -mode cycle—from hot start.  (Listed
                                                        reference Includes only summary data, details obtained  from raw data.)
                                                      o Rose Bowl Survey data were  obtained using 1970  FTP—except tests run from hot start.

-------
                              Table A-2

            Exhaust HC Measurements from Uncontrolled  Cars

                           Adjusted Data

                     All data are 1975 FTP g/ra1


                                                 Data Corrected* to
             Htd.  Avg.             FY 71         Common 1957-1965 Mean
Model      Tailpipe Data          CVS Data      Tailpipe
Year      From Table A-l        From Ref. 9       Data

1947           15.7                               14.2
1948           19.6                               18.1
1949           15.5                               14.0
1950           16.3                               14.8
1951           16.5                               15.0
1952           17.0                               15.5
1953           15.2                               13.7
1954           14.7                               13.2
1955           13.9                               12.4
1956           13.9                               12.4
1957           12.1                 6.63          10.6           8.2
1958           11.5                10.04          10.0          11.6
195-9           11.8                10.80          10.3          12.4
1960           13.0                 8.80          11.5          10.4
1961           13.0                 5.94          11.5           7.5
1962           11.1                 8.88           9.6          10.4
1963           10.6                 9.44           9.1          11.0
1964           12.8                 7.28          11.3           8.8
1965           11.3                11.18           9.8          12.7
1966              -                 8.26             -           9.8
1967           	-                 7.38             -           8.9

Mean 1957-1965 11.9                8.8
 *Correction Factor (11.9-8.8)/2;  subtracted from tailpipe data, added to
 FY 71 data.

 "Excludes Denver Data and 1966/67 Los Angeles Data.
                                 21-68

-------
ro
h-

0\
vo
                                                                                                Table A-3


                                                                             CO Tailpipe Measurements from Uncontrolled Cars
Model
Year
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
Test

N
4
6
7
23
25
16
39
50
89
100
112
72
109
109
108
151
13
_
.
Los Angeles IK
Station Project16
Cone.,
%
3.68
3.55
4.36
3.22
3.78
4.40
3.95
4.26
3.44
3.63
3.54
3.46
3.06
2.75
3.43
3.23
3.19
.
-
1975 FTP,
g/ml
96.7
93.3
114.6
84.6
99.4
115.7
103.8
112.0
90.4
95.4
93.1
91.0
80.4
72.3
90.2
84.9
83.1
.
-
Reactivity

N
.
.
1
.
.
.
2
2
1
1
6
5
6
9
16
21
51
45
46
Cone. ,
X
.
.
6.62
.
.
.
3.49
2.86
2.27
1.55
3.75
2.23
2.87
3.98
2.92
2.64
2.47
3.30
2.89
Survey17
1975 FTP,
g/ml
.
.
173.0
.
.
.
91.5
75.0
59.4
40.6
98.1
58.4
75.1
104.0
76.4
69.1
64.6
86.3
75.6
1974 Car Survey31

N
—
2
5
8
13
9
12
13
26
22
15
11
17
16
19
.
.
.
.
Cone . ,
X
.
3.25
4.27
3.46
3.89
4.17
2.88
3.42
3.57
2.99
2.90
2.60
2.81
2.66
2.81
.
_
.
.
1975 FTP.
g/m1
m
85.4
112.3
91.0
102.3
109.6
75.7
89.9
93.9
78.6
76.2
68.4
73.9
69.9
73.9
_
_
.
.
20
Rose Bowl Survey

N
—
.
.
.
.
.
.
.
.
_
.
5
3
12
14
24
30
38
35
1970 FTP,
a/ml
m
_
.
.
.
.
.
.
•
_
.
88.15
33.56
52.71
71.38
49.57
75.51
70.13
69.97
1975 FTP,
a/Hi
.
.
-
.
-
-
.
-
.
.
.
100.8
38.4
60.2
81.6
56.7
86.3
80.2
80.0
Weighted
Average
M975 FTP,
g/ml
96.7
91.3
118.2
86.3
100.4
113.5
97.0
106.4
90.9
91.9
91.4
87.1
78.4
73.0
86.1
79.8
74.1
83.5
77.5
                                                                                  See Notes on Table A-l

-------
                              Table A-4

               CO Measurements from Uncontrolled Cars

                            Adjusted  Data

                     All data are 1975 FTP g/m1
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
   Mtd. Avg.
 Tailpipe Data
From Table A-3

      96.7
      91.3
     118.2
      86.
     100.
     113.5
      97.0
     106.
      90.
      91.
      91.
.3
.4
.4
.9
.9
.4
      87.1
      78.4
      73.0
      86.1
      79.8
      74.1
      83.5
      77.5
                                  FY 71
                                 CVS Data
                               From Ref. 9
81.4
78.2
                77.
                81,
                79.
                 78.0
                 96.
                 81.
                 87.
                 91.
                 93.
                               Data Corrected* to
                              Common 1957-1965 Mean
Tailpipe
Data
97.4
92.0
118.5
87.0
101.1
114.2
97.7
107.1
91.6
92.6
92.1
87.8
79.1
73.7
86.8
80.5
74.8
84.2
78.2
FY 71
Data**
_
-
_
_
-
-
-
-
-
-
80.8
77.5
77.6
81.0
79.1
77.3
95.8
81.1
87.3
                                                      90.4
                                                      93.0
Mean 1957-1965  81.2
                         82.5
^Correction Factor (82.5-81.2)/2 *  0.65; added to tailpipe data,
 subtracted from FY 71  data.

"Excludes Denver Data  and 1966/67  Los Angeles Data.
                                   21-70

-------
                             Table A-5

         NOx Tailpipe Measurements from Uncontrolled Cars

Los Angeles   ^                       17                         «-       Weighted
                                                  Rose Bowl Survey          Average
                                                   1970 FTP,   1970 FTP,   1975  FTP,
                                              _N      g/m1        g/m1         g/nrl

                                                                               3.40
                                                                               3.53
                                                                               2.83
                                                                               4.38
                                                                               4.18
                                                                               3.68
                                                                               4.13
                                                                               3.28
                                                                               4.60
                                                                               4.34
                                                                               4.41
                                               5      4.75        5.31         4.17
                                               3      5.31        5.94         4.79
                                              12      4.87        5.44         4.95
                                              14      3.91        4.37         4.04
                                              22      5.64        6.31         4.63
                                              30      4.49        5.02         4.93
                                              38      4.39        4.91         4.56
                                              35      4.29        4.80         4.85


                    See Notes on Table A-l
Test Station Project10
Model
Year
1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965

N
4
6
7
20
24
11
31
39
77
85
89
- 47
76
78
70
122
10
_
-
Cone . ,
ppm
802
831
738
1032
985
865
959
742
1079
1019
1045
947
1134
1194
'900
997
1033
-
-
1975 FTP,
g/m1
3.40
3.53
3.13
4.38
4.18
3.68
4.07
3.15
4.58
4.33
4.44
4.02
4.82
5.08
3.82
4.24
4.39
-
-
Reactivity Survey

N
—
-
1
-
-
.
2
2
1
1
6
5
6
9
16
21
51
45
46
Cone . ,
ppm
—
-
266
.
-
_
1774
2019
2270
1696
1413
1558
1327
1106
1665
1802
1754
1504
1722
1975 FTP,
g/ml
—
-
0.76
.
-
-
5.04
5.73
6.45
4.82
4.01
4.42
3.77
3.14
4.73
5.12
4.98
4.27
4.89

-------
                              Table A-6

                NOx Measurements from Uncontrolled Cars

                            Adjusted  Data

                      All  data are  1975 FTP g/m1
Model
Year

1947
1948
1949
1950
1951
1952
1953
1954
1955
1956
1957
1958
1959
1960
1961
1962
1963
1964
1965
1966
1967
   Htd. Avg.
 Tailpipe Data
From Table A-S

     3.40
     3.53
     2.83
     4.38
     4.18
     3.68
     4.13
     3.28
     4.60
     4.34
     4.41
     4.17
       79
       95
       04
       63
       93
       56
     4.85
   FY 71
  CVS Data
From Ref.  9
                                                 Data Corrected* 'to
                                                Common 1957-1965 Mean
Mean 1957-1965 4.59
   3.84
   3.62
   4.50
   3.94
   3.07
   3.33
   3.64
   3.67
   3.37
   3.57
   3.28

   3.66
Tailpipe
  Data

  2.94
  3.07
  2.37
  3.92
  3.72
  3.22
  3.67
  2.82
  4.14
  3.88
  3.95
  3.71
  4.33
  4.49
  3.58
  4.17
  4.47
  4.10
  4.39
 FYTI
Data**
 4.31
 4.09
 4.97
 4.41
 3.54
 3.80
 4.11
 4.14
 3.84
 4.04
 3.75
•Correction Factor (4.59-3.66)72 - .465; subtracted from tailpipe data.
 added to FY 71 data.

"Excludes Denver Data and 1966/67 Los Angeles Data.
                                  21-72

-------
                               Table A-7

     NOx Test-to-Test Conversions for Uncontrolled (pre 1968) Cars


General Motors Test Program Results

     Car          Number         1970 FTP    Average Equivalence Ratio
Manufacturer      of Cars          g/m1           1972 FTP/1970 FTP

GM                  15             4.06                 1.20
Ford                 5             3.98                 0.98
Chrysler             4             4.24                 0.97
AMC                  1             2.96                 1.08
Foreign              2             1.59                 0.93

     Mean                          3.86                 1.10
Overall average Equivalence Ratio should be weighted by car population.
Reference 31 provide car population weighting factors (for the early
1960's) of:

                              GM        .410
                              Ford      .281
                              Chrysler  .160
                              Other     .088
Applying these weighting factors to the above GM results  gives an over-
all equivalence ratio (1972 FTP/1970 FTP) of 1.082.   Correcting this
ratio to the 1975 FTP via the ratio of the 1975 to the 1974 standard
gives:    1.082 (3.1/3.0) =• 1.118  1975 FTP/1970 FTP
                                  21-73

-------
     The following written comments on this paper were received
from Marcia Williams, EPA, Office of Motor Source Air Pollution
Control, Ann Arbor, Michigan and are included for information.
This constitutes the only written response received to the papers
presented at  the workshop.
                               21-74

-------
       Comments on "Highway Motor Vehicle Emission Factors"
        paper by MVMA, presented at EPA Emission Inventory/
                   Factor Workshop (Sept, 1977)


The following comments are submitted after a careful review of the MVMA
paper entitled "Highway Motor Vehicle Emission Factors".  The MVMA paper
discussed the recently released draft version of the EPA Revised Emission
Factor Document.  That draft is currently undergoing changes to reflect
the recent 1977 Clean Air Act Amendments, some new data, and new information
on California standards.  The comments reflected here will pertain to
the draft document used by MVMA, not the revised version of that document.
MVMA has commented that the EPA document is still deficient on detailed
discussions regarding the experimental data base and computational
methods.  This information has been carefully compiled and will be
released in a separate document concurrently with the final Emission
Factor Document.

Introduction

1.   EPA has not concluded that CO emissions are being overestimated in
     the current test procedure as is implied in the MVMA paper.  EPA is
     currently performing a study to characterize the types of driving
     conditions which occur in CO hot spot areas.  These results will be
     compared with the driving patterns and test conditions (vehicle
     temperature, ambient conditions) which are currently reflected in
     the FTP.  If necessary, the FTP will be modified to ensure that
     emission reductions achieved over the test procedure will equate to
     emission reductions on the road in CO hot spots.  The study will
     also quantify the fraction of the CO problem which is due to local
     sources and that which is due to regional sources since typical
     local/regional driving conditions are not necessarily the same.

2.   The MVMA paper discusses the sensitivity of ambient air quality
     measurements to the location of ambient monitors.  The discrete
     nature of the monitoring system makes it impossible to properly
     quantify the air at every point.  Likewise, since the main CO
     standard of concern is an 8 hour average standard, one ideally
     wants to average the air quality levels that a person can be expected
     to be exposed to under typical worst case conditions.  Such conditions
     are likely to be those that affect policeman, airport porters, road
     work crews, etc.  These people are breathing air at curb level and
     at approximately 8 feet, not at 18 feet and at the building face.
     Thus, the CO levels measured in NYC may be more realistic of typical
    -worst case conditions that those measured elsewhere.  The MVMA
     statement that "It would be extremely unfortunate if transportation
     control plans were established from measurements based on the
     shortest distance between sampling probe and tailpipe without
     considering public health aspects" does not appear applicable to
     the NYC situation as implied in the paper.
                                  21-75

-------
3.   The MVMA paper assumes that since it is desirable to have a bench-
     mark emission rate, it is necessary to select a model year definition
     for the desired benchmark.  MVMA has chosen 1960 but has not specified
     the age or mileage of the vehicles at the time their emissions were
     computed.  If one infers that the emission levels are measured in
     1970, there is no reason for using these numbers as a benchmark.
     For baseline and percent reduction work, one wants to compare pre-
     controlled vehicles at a similar age to controlled vehicles.

     EPA has determined that the exhaust emissions of pre-controlled
     vehicles deteriorate with mileage.  The appropriate benchmark is
     considered to be the 50,000 mile point.  Since 50,000 miles is
     defined as the useful life, vehicles are expected to just meet
     exhaust emission standards at the 50K mileage point.  Thus, the 50K
     exhaust emission levels of pre-controlled vehicles (of all model
     years.) can be compared with later emission standards or 50K in-use
     emission levels to determine the appropriate emission reductions.
     If desired, the evaporative and crankcase emissions, which are not
     assumed to deteriorate with mileage, can be added to the exhaust
     emissions before reductions are compiled.

Uncontrolled Exhaust Emissions

4.   The  recent version of the Emission Factor Document contained data
     on approximately 1000 precontrolled vehicles, all of which were
     tested over the 1975 FTP.  Table I in  the MVMA paper contained only
     a fraction of the  total EPA data base.  EPA considers the use of
     the  MVMA concentration data base to be highly questionable.  The
     ability  to accurately convert concentration data to mass data is
     difficult if not impossible.   (The MVMA Appendix to the paper
     supports this fact.)  Both EPA and GARB have stated that since such
     conversions are extremely vehicle dependent, they should not be
     performed on in-use  emission factor data bases.

     The  incorrect use  of a single conversion factor over many model
     years and vehicle  mixes could account  for the downward trend in
     emissions shown in Figures 1, 2, and 3.  The other factor which
     could account for  an artificial downward trend is the testing of
     different model year vehicles at different mileage/age points. EPA
     FTP  data do not support a downward emission trend from 1957 to 1967
     although within each model year, a trend with mileage/age is apparent.

Uncontrolled  Evaporative  Emissions

5.   MVMA suggests  that the MIT method be used to convert from grams/test
     to  grams/mile.  The  EPA procedure  is based on  the most recent
     national average  trip  statistics while the origin of the MIT
     statistics  are unclear  (the  7.5 miles/trip figure is based  on over
     10  year  old data  from Los Angeles;  the basis for the 27 mile/day
      figure is not  known).
                                   21-76

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     The inclusion of running losses is not possible at this time due to
     the absence of a defendable procedure over which to measure the
     losses.  In order for vehicle operation to cause evaporative
     emissions in excess of those produced during the diurnal phase, the
     vehicle operation must result in a temperature rise of the fuel
     tank which is greater than that which occurs during the diurnal.
     At this time, the extent of these losses in real world operation
     have not been adequately quantified in order to include them in the
     evaporative emission factor.

Controlled Exhaust Emissions

6.   Post-1974 vehicles - The EPA regression equations for 1975 model
     year vehicles were performed by dividing all vehicles into two
     distinct groups:  within specification vehicles and out of specification
     vehicles.  Regressions were performed on each group and the results
     were weighted to get a final deterioration equation.   It is this
     difference in analysis methods that accounts for the difference in
     the MVMA and EPA linear regression estimates.  The correlation
     coefficients for the EPA data are higher than the MVMA values.
     Moreover, data from the recently completed FY75 Emission Factor
     Program support the earlier regression equations and linearity
     assumption.  The logarithmic model used by MVMA has been discredited
     for pre-1975 models as more data have been collected; GARB no
     longer uses the model.

     While an increase of CO normally is associated with a decrease in
     NOx for a given vehicle, the correlation is not excessively strong
     for newer model vehicles.  More importantly, as vehicles accumulate
     age, the types of maladjustments that cause high CO (and lower NOx)
     can be totally offset by concurrent maladjustments to the EGR
     system.

     EPA estimates of future model year emission levels are based on a
     technology evaluation model.  The model projects the percentage of
     vehicles that are properly tuned, maladjusted, and have emission
     control systems inoperable as a function of vehicle age.  Using
     manufacturer supplied data on the emission behavior of future
     control systems under various malfunction conditions, the composite
     emission rates as a function of mileage can be computed.  These
     regressions assume that some type of EPA regulation regarding
     limited vehicle parametric adjustability will be in effect by the
     1980 model year.

7.   1968-1974 Cars - The straight linear regression approach used by
     MVMA is not an optimal regression approach due to the large scatter
     in the data.  The EPA has applied a regression analysis using mean
     emissions and mean mileage inputs for each model year vehicle group
     in each test program.  The result of this type of analysis is to
                                  21-77

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     predict mean emissions of groups of vehicles (not individual vehicles)
     as a function of mileage/age.  The correlation coefficients for a
     linear model are excellent (greater than .8) for a range of data
     that goes from low mileage to approximately 80,000 miles.  The
     regression equations were used to predict the results in the most
     recent test program and predictions were correct within 10 percent.

Controlled Evaporative Emissions

8.   The EPA emission factor data are based on three separate EPA test
     programs.  All three programs gave similar results.  The possibility
     of gas tank cap leaks was carefully checked and EPA is convinced
     that significant leakage did not occur.

     Regarding the test data presented in Table 4 (referred to in the
     text as Table 5), the vehicles in the Exxon Study were fitted with
     new fuel tanks prior to the  test so that the vehicles would not be
     typical of in-use vehicles.

Truck  Exhaust Emission Factors

9.   Although the heavy-duty trucks are not subject to a chassis dynamometer
      (grams/mile) certification test, EPA has collected emission data
     from  these vehicles over chassis dynamometer transient tests and
     over  a real road route in Texas.

10.  Figure  11 is not clearly labeled but there  are believed  to be  two
     discrepancies in the MVMA comparisons; pre-controlled vehicles had
     much  higher mileages  at  time of test than 1972-73 models  (emission
     deterioration was not adjusted  for); 1972-73 trucks were  tested in
     a tuned  condition and pre-controlled trucks were tested  in an  as-
     received condition.
                                   21-78

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                      CONDENSED DISCUSSION
COMMENT:
FAGLEY:
I have one comment on your procedure you
recommend for evaporative loss emission
factors.  The intent that we (EPA) had in
putting that equation in there is that
area  specific data be used.  In other words
your origin-destination data for a number
of trips per day per vehicle and average
trip lengths - you put that into that
equation.  As I see what you are doing, you
are putting in a different set of default
values, and it was not our intent.  At least
in Supplement 5, that equation to recommend
default values was only to make it so that
people could put in  individual urban data.
The point we were trying to make in the
paper is that the numbers for evaporative
emissions come out of the test cycle.
That has a mileage associated with it.  You
know that might not be  appropriate to par-
ticular urban areas being addressed, but
that was the basis the actual measure of
                                21-79

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                       emissions.   So  they made the hot soak
                                                 «
                       emissions associate with 7.5 miles.   Not some
                       other value like ten or something elese.
COMMENT:               Again, I  think that you could use any default
                       value.  You chose one a little bit lower
                       than we did.  The difference is not very
                       significant.  I do think we should look into
                       running losses.  But that is just a personal
                       observation.
                                21-80

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       FTP Emission Factor Development:
       Correction for non-FTP Conditions
             Presented at the 1977
        Environmental Protection Agency
      Emission Inventory/Factor Workshop
Raleigh, North Carolina - September 13-15, 1977
                      By

                 Janet Becker
           Mathematical Statistician

                Marcia Williams
                     Chief

     U.S. Environmental Protection Agency
 Office of Mobile Source Air Pollution Control
     Emission Control Technology Division
   Characterization and Applications Branch
                      22-1

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I.   Introduction

The problem of estimating exhaust emission levels from in-use
light duty vehicles has been of interest for many years,
dating back to the early 1950's in California.  However, this
problem did not receive a federal mandate for action until the
passage of the Clean Air Act of 1963 and the Clean Air Act
Amendments of 1970, which called for a 90% reduction in HC and
CO from allowable 1970 levels, and for a 90% reduction in NOx
from average NOx emission levels actually measured from light
duty vehicles manufactured during model year 1971.  These
reductions were originally to be achieved by model year 1976,
but a series of one year extensions and the 1977 Clean Air Act
has revised final implementation dates until at least 1981.

The federal government has implemented programs designed to
ensure that properly maintained and used vehicles meet emission
standards in the field.  These programs include certification,
assembly line testing, and recall.  However, the states and/or
air quality control regions  (AQCRs) were given the basic
responsibility for preparing plans under which the progressively
more stringent national ambient air quality standards could be
achieved.  Of necessity, a part of any such plan includes a
statement regarding the impact of motor vehicle emissions on
air quality, and, if appropriate, methods for controlling the
exhaust emissions from in-use vehicles.

To help states and AQCRs in  the development of such plans and
to help estimate the deterioration of emissions in a real
world environment, the EPA instituted the Emission Factor
Program in FY 1971.

This program is designed to  estimate areawide urban emission
levels for in-use vehicles on a. nationwide basis.  Although
testing of other than light  duty vehicles has occurred in
recent years, the  emphasis of the program has been on estimating
passenger car emission levels.  Testing of vehicles occurs in
cities representing various  climatic and geographic conditions.
Light duty vehicles are currently tested according to the 1975
Federal Test Procedure  (FTP) as stipulated in the Federal
Register  .  Illustration 1 summarizes the conditions and
assumptions which  occur with the FTP.  The FTP driving cycle
 1  Federal Register, Vol.  137,  No.  211,  Nov.  15,  1972.
                                 22-2

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has been determined to be a reasonably representative urban
stop-and-go commute on the basis of data collected in Los
Angeles in the 1960's.  The ambient conditions are not inherent
in the driving cycle, but were established as part of the FTP
to ensure comparability of FTP test results.  The hot/cold
weighting factor used in the FTP is not inherent in the driving
cycle, but was determined to be representative of the percent
of hot start vs. cold start miles on the basis of data collected
in Los Angeles.

Thus, the estimates of exhaust emission levels derived from
the annual Emission Factor Programs are representative of
emission levels in areawide urban scenarios which conform to
the assumptions and conditions specified in Illustration 1.
These estimates are updated annually, and are published in AP-
42, Compilation of_ Air Pollution Emission Factors.  For scenarios
which do not conform to the FTP conditions and assumptions,
AP-42 estimates are more or less inappropriate, depending on
the extent of the nonconformity.  Therefore, in recent updates
to AP-42, starting with Supplement 5, so-called "correction
factors" have been provided and recommended for use in incorporating
scenario-specific considerations into emission estimates.  The
next supplement on mobile source emission factors was originally
scheduled for promulgation as AP-42, Supplement 8, and will
contain light duty vehicle correction factors for ambient
temperature, average speed, % hot start/% cold start operation,
humidity, a,iT conditioning, and extra vehicle loading.  This
supplement number is no longer firm;  however, the Supplement
8 designation will be used throughout this document.  This
paper will focus on the methodology used to correct FTP exhaust
emission estimates for ambient temperature, average speed, and
% hot start/% cold start operation (hot/cold).

II.  Data Bases

In order to correct for non-FTP conditions and assumptions, it
is necessary to have data taken under non-FTP conditions to
co.mpa.re with AP-42 numbers.  There were two data bases available
to EPA, representing FTP testing which occurred outside the FTP
ambient temperature range of 68 to 86°F.  One set of data was
provided by the study Ambient Temperature and Vehicle Emissions
CEPA 460/3-74-028, October 1974), in which FTP emission tests
were performed on 26 1967-1974, and 1975 prototype model year
non-California light duty cars at ambient temperatures of 20°
to 11Q°F,  Moat cars underwent four tests at ambient temperatures
of 20% 50% 75% and 100QF respectively.  The other set of data
                                22-3

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was provided by the Environmental Protection Service, Ottawa,
Ontario, and represents FTP emission tests on 12 1975 model
year light duty vehicles, 7 of which were designed to meet
which federal emission standards, and 5 of which were designed
to meet the more stringent California emission standards.
Multiple tests were performed on each vehicle at ambients of 0°
to 80°F.  For both data sets, the NOx emissions were normalized
to 25 grains of water/lb. of dry air, as stipulated by  the
FTP  .  Also, all cars were in a tuned-up condition immediately
prior to testing.  A description of each set of vehicles is
provided in Illustrations 2 and 3 respectively.  Illustration 4
summarizes some of the characteristics of these two fleets.

III. Methodology of Correction Factor Development

The  general approach to developing correction factors in both
Supplement 5 and Supplement 8 has been to calculate multiplicative
factors which are applied to the AP-42 estimates of HC, CO,  and
NOx.  The final forms of the Supplement 5 and Supplement 8
correction factors are given in Illustration 5, and are viewed
as part of the basic emission factor  calculation.  In Supplement
5 three separate factors were used  to correct for  temperature,
average speed, and hot/cold operation, respectively.  Due  to
lack of data, the possibility of interaction among these three
factors was by and large disregarded.  In  the process of developing
Supplement 8  correction  factors it was decided  on  the basis  of
the  newly available  Canadian data  that interaction between
ambient temperature  and  hot/cold operation was  significant
enough  to warrant  the use  of a  single, more complex correction
factor  which  would  incorporate  the interdependence of  the
temperature and  hot/cold variants.   Future correction  factor
work will probably be  oriented  towards  the development  of  one
 correction  factor which incorporates the  interdependency among
 a.11 factors  affecting  exhaust  emission  levels.   Although joint
 data on average speed  and  hot/cold operation were  not  available,
 it was  felt  that the modeling  of  an interaction between these
 factors- was appropriate.   Certain assumptions,  which will  be
 discussed later,  had to  be made in order  to Incorporate this
 ititerdepeadency.   One correction factor,  the R1  correction
 fa,ctor, results in Supplement  8 and consists of temperature,
 hot/cold operation,  and average speed components.
 2  Federal Register. Vol. 28, No. 151, August 7, 1973.
                                 22-4

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The approach to calculating the R1 factor was to first develop
the temperature-hot/cold portion by finding an expression for
CF      which solves the following equation:
  t ,w,x
Equation Is    FTP^^ = (CF^^) (FTP75%


where     t =  ambient temperature (°F) ,

          w =  fraction of total miles driven which are driven
               in cold start operation (representative of
               emissions which occur on and shortly after
               start-up following a long engine-of f period) ,

          x =  fraction of total miles driven which are driven
               in hot start condition (representative of emissions
               which occur on and shortly after start-up following
               a short engine-of f period) ,

   FTP      =  emissions (gm/mi) as measured over the FTP
       >W)X    driving cycle at t°F, with a % hot start/% cold
               start operation ratio of x/w.

The situation where t is 75eF, w is .2058, and x is .2728
defines the FTP conditions and assumptions for ambient temperature
and hot/cold operation.  (Although the FTP requirement is only
that vehicles be tested in an ambient temperature range of  68-
86°F, 75" was taken as representative of the temperature range
used for FTP testing)..  As discussed previously, the FTP conditions
are reflected in AP-42 emission estimates.  The above Equation
1 is equivalent to Equation 2:
                         FTP
Equation 2:    CFtjW>x = FTP £i* .2058> .2728

The ambient temperature - hot/cold portion of the R' correction
factor is based on Equation 2.  Thus, in conjunction with this
formulation of correction factors an expression for FTP
was fundamental.                                       t,w,x

An equation for FTP,.     can be formulated as follows:
                   t,w,x

Equation 3:    FTP      = w(Bag 1)  + (1-w-x) (Bag 2)  + x(Bag 3)  ,
                  t,w,x           t                 t            t

where (Bag i)  = emissions (gm/mi) in Bag i, i=l,2,3, at
                 temperature t.
                               22-5

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The next step was to determine Bag 1,2, and 3 emissions as an
appropriate function of ambient temperature.

The data provided by the Environmental Protection Service on
1975 model year cars included extensive replicate testing on
each vehicle at ambient temperatures of approximately 0 to
80°F.  It was felt that these data would provide the best
estimate of the appropriate functional form for each bag's
gm/mi as a function of temperature, since each vehicle's data
represented a unit for analysis in and of itself.  Data on
vehicles which were designed to meet California emission
standards were analyzed separately from data on vehicles which
were designed to meet the federal emission standards.
                                           3
For each pollutant  (HC, CO, and NOx), bag 1 , bag 2, and bag 3
emissions  (gm/mi). were analyzed to determine the effect, if
any, of ambient temperature on emission levels.  Based on an
examination of scatter plots of emissions vs. temperature and
an examination of residuals from the linear and loglinear
regression models,  the loglinear model was selected.  The
regression model was as follows:

Equation 4:    ln(y) = a  + a- t,

where      In = natural logarithmic function,

           y = emissions  (gm/mi),

           t = ambient temperature  ("I?).

Due  to  the confounding effects of car-to-car variability which
arise when analyzing emission data on  several different vehicles,
it was  decided that covariance analysis could be useful in  the
determination of  an appropriate  slope  for  the regression line.
Large experimental  errors due, in this case, to car-to-car
variability would be encountered in a  regression analysis which
does not  stratify on vehicle, and would possibly result in  an
inaccurate regression  slope.  By stratifying on vehicle for the
    Bag 1 represents emissions which occur on and shortly after
    start-up, following a long engine-off period (cold start),
    bag 2 represents emissions which occur when a vehicle's
    engine and/or emission controls are in a warmed-up condition
    (stabilized), and bag 3 represents emissions which occur on
    and shortly after start-up, following a short engine-off
    period (hot start).
                                22-6

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analysis of covariance, smaller experimental errors result.
Thus, the relationship between emissions and temperature
becomes clearer.

Only bag 1 HC and bag 1 CO emission levels appeared to change
significantly with temperature.  The expressions for these bag's
emissions in terms of temperature, derived from the best-
estimate slope determined by the analysis of covariance and the
average of the individual vehicle regression intercepts, are
presented in Illustration 6.  It is emphasized that these
prediction equations reflect emission-temperature relationships
for 1975 model year vehicles in a tuned-up condition.  As a
check on the robustness of these equations, a visual comparison
of the observed average bag 1 HC and bag 1 CO emissions for the
4 1975 model year prototype cars tested in the EPA study Ambient
Temperature and Vehicle Emissions with the predicted values was
made.  The emissions predicted from the prediction equations
indicated reasonable predictability of bag 1 HC and bag 1 CO
emissions for these vehicles.  The observed and predicted
emissions are presented in Illustration 7.

Also on the basis of these visual comparisons, it was decided
that extrapolation of the prediction equations to 110°F was
reasonable.  The expressions presented in Illustration 6 are
therefore considered appropriate for temperatures in the range
0 to 11Q°F.  Although the expressions are based on data for
1975 model year cars, they are assumed applicable to 1975-79
cars, since technology over these years has not changed and
probably will not change substantially.

The only source of ambient temperature-emissions data on pre-
1975 model years cars available to EPA was the study Ambient
Temperature and Vehicle Emissions.  Since at most four FTP
tests were performed on a single vehicle, the reliability of a
functional form derived on the basis of these data alone was
considered poor.  The general functional form for the pre-1975
model year cars' temperature-emissions relationships were
therefore taken to be loglinear, this form having been determined
acceptable for 1975 model year cars.  Using this regression
model, an analysis of covariance was performed on all pre-1975
model year cars' data to determine expressions for bag emissions
(gm/mi) in terms of ambient temperature.  As was the case for
the 1975 model year data, only bag 1 HC and bag 1 CO emissions
appeared to be significantly affected by ambient temperature
for pre-1975 cars.  The expressions for bag 1 HC and bag 1 CO
emissions for pre-1975 model year cars are displayed in Illustra-
                               22-7

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tion 8.  (A separate analysis of pre-controlled cars' data
yielded relationships similar to those for 1968-74 model year
cars, so all pre-1975 data were combined).

Since states and Air Quality Control Regions are interested in
estimating the emission levels of in-use, as opposed to tuned-
up vehicles, the expressions for bag 1 HC and bag 1 CO emissions
which are given in Illustrations 6 and 8 were modified by
adding a constant equal to the difference between low mileage
0-0,000 miles) AP-42 bag 1 FTP emission levels, and bag 1
emission levels at 75° as predicted by the expressions for
tuned-up vehicles.  At this point in the development, the
temperature - hot/cold correction factors took the following
form:

     CF   ...
       preliminary

        w [exp  CaQ + a- t) + c] +  (1-w-x) (d) + x  (e)

         .2085 lexp  CaQ + 75 a^ + c] +  .5213 d +  .2728 e,

            c = difference between AP-42 low mileage bag 1
                emissions  Cgm/mi) and bag 1 emissions at 75° as
                predicted by the expressions for tuned-up
                vehicles,

            d = AP-42 low mileage bag 2 emissions  (gm/mi),

            e = AP-42 low mileage bag 3 emissions  (gm/mi),

            w = fraction of total miles driven which are driven
                in  cold start  condition,

            x = fraction of total miles driven which are driven
                in  hot  start condition.

For the above equation, FY72 and FY74 emission factor data  on
pre-1975 and 1975 model year cars, respectively, were used  to
calculate the percentages  of the FTP which were  in bags  1,  2,
and 3, respectively,  for precontrolled  cars,  for  1968-74 model
year cars,  and  for  1975 model  year cars.  These percentages
were applied  to the AP-42  low  mileage FTP levels  for each model
year group  to obtain  the values for  c,  d, and e.   The denominator
in the above  expression for CF preliminary  is a  low mileage
normalizing value,  equal  to the low mileage FTP  level under the
FTP assumptions.
                                22-8

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A review of these preliminary temperature - hot/cold correction
factors resulted in a decision that a mileage or age consideration
should be incorporated.  This decision was based on the fact
that these factors were extremely sensitive to the FTP levels
at 75° which were used as normalizing factors.  For example,
the preliminary correction factors described above, which were
based on low mileage normalizing factors, were often substantially
different from those which were based on 100,000 mile normalizing
factors.  The underlying assumption in applying a set of
correction factors which are normalized to a fixed mileage is
that the predicted steepness of the effect of low temperature
on emissions depends on mileage accumulation, as illustrated
below.  However, available data from the EPA study suggest that
the assumption of such a dependency is unwarranted.  Thus, the use
of correction factors which are normalized to a fixed mileage is
considered inappropriate.

             Prediction of HC Bag 1 Emissions (gm/mi)
              Fixed-mileage Normalized Temperature -
                    Hot/Cold Correction Factors
            1975 Model Year Federal Light Duty Vehicles
    1 Ht
                        I	I
           10  30  tO  50  frO  10
                                      All Cold Start Driving CFs*

                                      Normalized to  Normalized to
                                      10,000 miles   100,000 miles
20°
35°
50°
75°
5.64
4.10
3.03
1.89
2.67
2.14
1.76
1.36
* Curves A and C are based on
  the application of the 10,000
  mile normalized CFs to the
  100,000 mile AP-42 FTP (3.94)
  and to the 10,000 AP-42 HC FTP
  (1.38), respectively.  Curves
  B and D are based on the appli-
  cation of the 100,000 mile-
  normalized CFs to the FTP levels
  3.94 and 1.38, respectively.
                               22-9

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A consideration of vehicle age  (mileage) was incorporated into
the expression for the temperature - hot/cold correction
factors in the following way:

CF =
w[exp (aQ+ a-j^
.2058[exp (aQ
where
t) + c + A df-]
+75a- ) + c + A
+ (1-w-x) (d + A df
df^] + .5213(d+A df
„) + x(e + A df3)
2) + .2728(e + A df3)
     df. = deterioration  factor  (gm/mi/year)  in bag  j, j =  1,2,3,


       A =  (vehicle age-1) ,  in years;  A =  0  to 9.   (One year
            is  assumed  to  be  equivalent to 10,000 miles).

 The  above expression for  CF  is equivalent to  the following:
 CF  -

 w[exp(aQ+a1t)  + c + A df^  + (1-w-x) (d  + A df^  4- x(e + A dfj)
                          v + ^

 where

        v = low mileage AP-42 FTP emission factor at 75°,

        r = AP-42 FTP deterioration factor (gm/mi/yr) at 75°.

 With regard to the above expression,  for pre-1975s the assumption was
 made that, for a given pollutant, percent deterioration per
 year occurring in bag i (based on low mileage AP-42 emission
 factors, by bag), which is fairly constant for all bags at
 75°*, is constant for all temperatures.  (The percent deterioration
 in each bag is assumed to equal the overall percent deterioration,
 r/v).  For 1975-77 model year cars, the percent deterioration
 which occurs in bags 2 and 3 has been shown to differ from
 that in bag 1 for all pollutants.*  For HC and CO, percent
 deterioration is greater in bags 2 and  3 than in bag 1.  For
 NOx, deterioration is less in bags 2 and 3 than in bag 1.  The
 bag specific gm/mi/yr deterioration factors were obtained by
 multiplying the percent deterioration by the AP-42 low mileage
 bag 1, bag 2, and bag 3 emission levels.  The basic input
  July 20, 1976 internal EPA memo.
                                22-10

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values for the terms in the above expression for CF are given
in Illustration 9.

Incorporation of Speed Correction Factors;  So far the discussion
of ambient temperature, average speed, and hot/cold correction
factors has centered around considerations of temperature and
hot/cold operation. Separate consideration of the speed portion
was necessary due to the lack of data covering all three
factors at once.  Despite the lack of data, bag-specific speed
correction factors were incorporated into the correction
factors for temperature and hot/cold weighting as opposed to
being given as separate factors.  Although the available bag-
specific data on speed effects were insufficient for analysis
purposes, engineering judgment supports the assumption of a
hot/cold-speed interdependency.

Until further data on speed-temperature interdependencies
become available, speed and temperature effects on emissions
will be assumed to be independent.  This assumption will be
checked as data become available.  The result of incorporating
speed correction factors into the temperature - hot/cold
correction factors given above is more accurate predicted
emission levels, at the expense of quite complex correction
factor  calculations, if carried out by hand.  Due to this
complexity, EPA is currently in the process of computerizing
the calculation of these factors.  The derivation of the speed
correction factors and the final temperature, ambient temperature,
hot/cold correction factors is discussed below.

Derivation of Speed Correction Factors;  Speed correction
factors for warmed-up vehicle operation were developed using a
four stage process.  First, large quantities of second-by-
second speed-time data were collected, divided into acceleration,
deceleration, and steady state modes, and transcribed into
transition probability matrices.  A transition probability
matrix gives the probability that a vehicle moves to speed x
given that it is currently at speed y.  The data used to
develop the transition probability matrix were collected in
the 1970 Vehicle Operations Survey and the 1974 GM Chase Car
Survey, and covered 1957-1975 model year vehicles.

The second stage of the procedure generated second-by-second
speed-time cycles at average speeds between 5 and 60 mph.
Monte Carlo simulation techniques were applied to generate
cycles based on the transition probability matrix, and cycles
were screened so as to have the appropriate amount of idle
                               22-11

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time, acceleration time, deceleration time, cruise time, and
average speed, as determined from the observed average driving
cycle.  Multiple cycles were generated for each average speed
point.  All cycles were transient;  no steady state only
cycles were generated.

Each of the transient speed-time cycles was fed into the EPA
modal emission model  (EPA Report No. 460-3-74-065).  The modal
emission model is a mathematical regression model which predicts
warmed-up vehicle emissions in gm/mi over arbitrary transient
driving sequences from  speed-time data.  The model is based on
modal input data from approximately 2000 1957-1975 model year
vehicles.  For each model year vehicle, emission estimates
were obtained for each  of the generated speed-time sequences.

Plots were made of predicted emissions vs. average speed and
regressions were performed.  In all cases, the r  value was
above .95.  The regressions were then normalized to the average
speed of 19.6; that is, an average speed of 19.6 will give a
correction factor of  1.0.  Illustration 10 lists the model
year/city groupings for which speed correction factors for
warmed-up vehicle operation were formulated, and Illustration
11  lists the  formulas for the speed correction factors  (normalized
to  19.6 mph)  for stabilized and hot start driving conditions.
Illustration  12 provides the stabilized and hot start speed
correction factors in 5 mph increments.  All HC and CO regressions
are exponential fifth order polynomials.  All NOx regressions
are fourth order polynomials.  This work was performed under
an  EPA contract to Olson Laboratories.  More detailed information
on  the development of the speed correction factors can be
found in the  contract final report which should be available
by  late 1977.

These speed correction  factors for  stabilized and hot start
operation were used  to  derive bag-specific correction factors.
The need for  bag-specific correction  factors is based on  two
considerations.  First, the fact  that  the  cold and hot bags of
the FTP have  a different average  speed  from the stabilized bag
indicates a need  for  bag-specific  speed factors.  That  is, if
the percentage operation in each  of  the bags is altered,  the
average  speed will also be altered.   The  second reason  is more
complex.  The speed  correction factors  discussed up until now
were developed to predict changes  in  warmed-up vehicle  emissions.
It  is not reasonable, from an engineering  standpoint, to
expect  these  same emission changes  to occur during cold operation
because  of  the operation of the choke:  Pre-controlled vehicles
                               22-12

-------
were calibrated with rich air-fuel mixtures and as a result,
the difference in cold emissions and hot emissions at a given
average speed is not as great as for later model year vehicles
in which the air-fuel mixtures are leaner.  During cold
operation of controlled vehicles, the operation of the choke
can be expected to result in a situation where emissions are
relatively less sensitive to changes in average speed than to
changes due to choke operation.  Lacking conclusive data, the
emission dependency on speed during cold operation is assumed
to be similar for all model year vehicles and to be equal to
the dependency of pre-controlled vehicles during warmed-up
operation.

The calculations of the bag-specific speed correction factors
for a given pollutant were made according to the following
equations:

          Bag 1 speed correction factor = v_   /v0 0,
                                           2'S1  2»26

          Bag 2 speed correction factor = v    /v  .fi


          Bag 3 speed correction factor = v    /v  ~,
                                           & Q   O ft\
                                           B> **o  6» *•"»

where     s  = average speed in bag i, i=l,2,3
     v,    v - group-specific speed correction factor for
      ^'Si    warmed-up operation normalized to 19.6 mph
               Cg=2 designates pre-controlled low altitute
               vehicles).

Due to lack of data, a consideration of modal effects in a
cycle of interest, such as the cycle's percent time or percent
miles spent in acceleration, deceleration, and idle, or the
sequence of modes in the cycle has not been included in the
development of the speed correction factors.  Although EPA has
not investigated this question thoroughly, it appears that
for HC and CO as measured over various transient cycles, the
average speed difference accounts for the majority of the
effect on emission.  NOx emission seems to be influenced a
little more by the cycle than is HC or CO emission, although
speed still has the major impact.  It is expected that cycles
with higher percentages or rates of acceleration will have
higher NOx emissions for the same average speed.
                              22-13

-------
The bag-specific speed correction factors were incorporated
into the temperature-hot/cold factors, resulting in the general
formulas presented in Illustrations 13 to 15.

Applicability of Correction Factors;  The general correction
factors are applicable to ambient temperatures of 0-110°F,
speeds of 5 to 60 mph, and all combinations of hot/cold driving.
Also, the factors should only be applied to transient driving
situations.  To predict the emissions of a steady state driving
sequence such as constant 20 mph operation, the modal model
should be applied to the specific speed of interest and/or EPA
surveillance reports should be referenced.  The difference
between emissions as measured over steady state vs. transient
cycles is considerable at low average speeds  (greater than 20
percent) and becomes negligible at speeds of  around 45 mph.
                                22-14

-------
                            Illustration 1

                1975 Federal Test Procedure Conditions
                        for Light Duty Vehicles


1.   Ambient temperature = 68° - 86°F (An average temperature of 75°F
     is assumed to be representative of all tabled emission factor
     values).

2.   Ambient humidity = 75 grains

3.   Average speed for entire FTP driving cycle =19.6 mph, 18% idle
     operation.

     a.   Average speed for bags 1 and 3 (cold and hot start
          bags) = 26 mph

     b.   Average speed for bag 2 (stabilized bag) = 16 mph

4.   Average % cold start VMT operation = 20.58%

5.   Average % hot start VMT operation = 27.28%

6.   Average % stablilized VMT operation = 52.13%

7.   Air-conditioning does not pull large power load

8.   Car contains driver and fuel only, no passengers, luggage, etc.

9.   Car is not pulling a trailer
                                 22-15

-------
                                      Illustration  2
                       Environmental  Protection Agency  Study  Fleet
 Model Year
  Make & Model
                         2                  3
Engine Size  Transmission   Emission Control
     1967
     1967
     1967
     1969
     1969
     1969
     1969
     1970
     1970
     1971
     1971
     1971
     1971
     1971
     1972
     1973
     1973
     1973
     1974
     1974
     1974
     1974
Prototype 1975
Prototype 1975
Prototype 1975
Prototype 1975
Ford Galaxie           289
Chevrolet Impala       283
Plymouth Fury          318
Chevrolet Malibu       307
Ford Galaxie           302
AMC Ambassador         290
Mercury Montery        390
Oldsmobile Cutlass     350
Chrysler Newport       383
Ford Galaxie           351
Chevrolet Impala       350
Dodge Coronet          318
Buick Electra          455
Chevrolet Impala       400
Ford Torino-C          351
Volvo 142              121
Chevrolet Laguna       350
Ford LTD               351
Ford Torino-C          351
Plymouth Fury  III     360
Chevrolet Chevelle     350
Ford Torino            351-W
Ford Pinto             140
Plymouth Satellite     318
Ford LTD               400
Chevrolet Belair       350
                  A3
                  A2
                  A3
                  A2
                  A3
                  A3
                  A3
                  A3
                  A3
                  A3
                  A3
                  A3
                  A3
                  A3
                  A3
                  M4
                  A3
                  A3
                  A3
                  A3
                  A3
                  A3
                  A3
                  A3
                  A3
                  A3
PCV
PCV
PCV
EM, PCV
EM, PCV
EM, PCV
EM, PCV
EM, PCV
EM, PCV
EEC, EM, PCV
EEC, EM, PCV
EEC, EM, PCV
EEC, EM, PCV
EEC, EM, PCV
EEC, EM, PCV
EGR, EFI
EGR
EGR
EGR, MAI
EGR
EGR, MAI
EGR
EGR, MAI, Ox. Cat.
EGR, MAI, Ox. Cat.
EGR, MAI, Ox. Cat.
EGR, MAI, Ox. Cat.
  Ambient Temperature and Vehicle Emissions, EPA Report 460/3-74-028, October 1974.

  Transmission Code
  A2 - automatic 2-speed
  A3 - automatic 3-speed
  M4 - manual 4-speed

  Emission Control Code
  PCV      - positive crankcase ventilla.tion
  EM       - engine modifications
  EEC      - evaporative emission control
  EGR      - exhaust gas recirculation
  MAI      - manifold air injection
  Ox. Cat. - oxidizing catalytic converter
                                          22-16

-------
                                 Illustration 3

               Environmental Protection Service Fleet:  1975-1976

                              1975 Model Year Cars
Make & Model
Engine Size  Transmission   Emission Control'
Chevrolet Impala                350
Chevrolet Biscayne (Calif.)     350
Honda CIVIC  (Calif.)             90.8
Honda CIVIC  (Calif.)             90.8
Chevrolet Monza (Calif.)        140
Dodge Dart (Calif.)             318
Ford Maverick                   250
Ford Custom  500                 351
Dodge Dart                      225
Chevrolet Nova                  250
AMC Hornet                      258
Dodge S/W Monaco                440
                  A3
                  A3
                  M4
                  M4
                  A3
                  A3
                  A3
                  A3
                  A3
                  A3
                  A3
                  A3
EGR, Ox. Cat., MAI
EGR
CVCC^
CVCC
EGR, Ox. Cat., MAI
EGR, Ox. Cat., MAI
EGR, MAI
EGR, MAI
EGR
EGR, Ox. Cat.
EGR
EGR
  Transmission Code
  A3 - automatic 3-speed
  M4 - manual 4-speed
  Emission Control Code
  EGR - exhaust gas recirculation
  MAI - manifold air injection
  Ox. Cat. - oxidizing catalytic converter
  Compound Vortex Controlled Combustion - CVCC is a stratified charge
  system engine design which is used in place of auxiliary emission
  control devices.
                                     22-17

-------
                                  Illustration 4

                          Ambient Temperature Data Bases
      1.    Ambient Temperature and Vehicle Emissions (EPA 460/3-74-028,
           October 1974)

      2.    Environmental Protection Service, Ottawa, Ontario:  1975-76 Cold
           Weather Fleet.
                             Data Base Characteristics

                        No. Tests
                        per Vehicle                 Model Years     Ambient Tempera-
Source   No. Vehicles   (Range)       Total Tests   Represented     ture Range	

   1.       26            3-4           96          1967-1975        20 to 110°F

   2.       12           18-59         479          1975 Federal      0 to  80°F
                                                    and California
                                         22-18

-------
                            Illustration 5
         Basic Emission Factor Equation - Light Duty Vehicles
Supplement 5
                n
      npstwx    =_   CiPn  in
Supplement 8
                n
     Enpstwx =   l     ° ipn Min R'ipstwx Aip Lip Uipw Hip
        i  = model year
        n  = calendar year
        s  = speed
        t  = ambient temperature
        w  = fraction cold operation
        x  = fraction hot start operation
        p  = pollutant
     c, c" = emission factor in AP-42 tables
        M  = fraction of total mileage
        V  = average speed cf
        Z  = temperature cf
        R  = hot/cold cf
        R' = temperature, average speed, and hot/cold cf
        A  = air-conditioning cf
        L  = vehicle load cf
        U  = trailer towing cf
        H ^ = humidity cf


                                  22-19

-------
                            Illustration  6

Prediction of Bag 1 HC and Bag 1 CO Emissions from Ambient Temperature
          1975 Model Year Vehicles in a Tuned-up Condition

1975 Model Year     Bag 1 HC: y = exp (2.4339 - ,023591t)
Federal Cars:       Bag 1 CO: y = exp (5.5460 - .028945t)

1975 Model Year     Bag 1 HC: y = exp (1.9934 - .022269t)
California Cars:    Bag 1 CO: y = exp (4.2391 - .017522t),

where     y = emissions (gm/mi), exp = natural exponential function,
          t = ambient temperature (°F).  The equations are based
          on data for 12 1975 model year vehicles tested at ambient
          temperatures of 0° to 80°F.  A total of 479 tests were
          performed.
                                  22-20

-------
                            Illustration  7

              Observed* vs. Predicted** Emissions (gm/mi)
                   for Four 1975 Prototype Vehicles

                                                  Bag 1 HC
                                           Ambient Temperature (°F)

                                         20°      50°      75°      110°

Observed Level                           5.2      2.6       1.3     1.0
E.P.S. Federal Predicted Level           7.1      3.5       1.9      .85***
E.P.S. California Predicted Level        4.7      2.4       1.4      .63***
                                                  Bag 1 CO
                                          Ambient Temperature (°F)
                                         20°      50°       75°     110°

Observed Level                         126.3     67.5      17.0    10.1
E.P.S. Federal Predicted Level         143.6     60.3      29.2    10.6***
E.P.S. California Predicted Level       48.9     28.9      18.6    10.1***
  * Observed levels were taken from EPA study 460/3-74-028,  Ambient
    Temperature and Vehicle Emissions.

 ** Predictions were based on the results of covariance analyses per-
    formed on the Environmental Protection Service data on federal
    and California cars, respectively.

*** Extrapolated values.
                                    22-21

-------
                            Illustration  8

Prediction of Bag 1 HC and Bag 1 CO Emissions from Ambient Temperature
        Pre-1975 Model Year Vehicles in a Tuned-up Condition
               Bag 1 HC: y = exp  (2.9310 -  .014779t)

               Bag 1 CO: y = exp  (5.6548 -  .015965t),
where     y = emissions  (gm/mi), exp = natural exponential function,
          t = ambient  temperature  (°F).  Equations are based on data
          for 22 1967-74 model  year cars tested at ambient temperatures
          of 20° to 110°F  from  EPA study 460/3-74-028, October 1974.  A
          total of 83  tests were performed.
                                     22-22

-------
to
r
NJ
                                                          Illustration 9


                                        Numerical  Inputs  to  Correction Factor Expressions

Pre-1968
1968-74
1975 Federal
1975 Calif





HC
CO
NOx
HC
CO
NOx
HC
CO
NOx
HC
CO
NOx




al
-0.014779
-0.015965
0.
-0.014779
-0.015965
0.
-0.023591
-0.028945
0.
-0.022269
-0.017522
0.
The values



ao
2.9310
5.6548
0.
2.9310
5.6548
0.
2.4339
5.5460
0.
1.9934
4.2391
0.
for d^,



c e
.673 4.746
-14.74 42.84
2.876 4.25
-2.41 2.43
-33.89 25.26
4.44 5.92
0.623 1.11
11.29 15.855
2.26 2.989
-.032 .497
-0.20 4.12
2.05 2.88
d
5.685
57.57
2.768
2.61
35.9
3.77
1.053
21.167
1.887
.243
3.96
2.009
df2, and df, were calculated from
df1 - (rc/v)*(EXP(75
df2 = (rh/v)*d
df, = (rh/v)*e.
.*an+a )+c)
1 o


V
5.67
56.43
3.40
2.8
36.4
4.7
1.38
23.7
2.47
0.54
6.98
2.46
r
0.47
7.59
0.
0.64
6.79
0.
0.28
3.14
0.18
0.28
3.14
0.18
the following






re
0.47
7.59
0.
0.64
6.79
0.
.162
2.48
.2540
.178
2.645
.2563
formulas :



rn
0.47
7.59
0.
0.64
6.79
0.
.3532
3.50
.1524
.388
3.729
.1538





-------
Group Number

Group 1

Group 2


Group 3

Group 4

Group 5

Group 6

Group 7

Group 8

Group 9

Group 10

Group 11

Group 12

Group 13

Group 14

Group 15

Group 16

Group 17

Group 18
                Illustration 10

Group Definitions for Speed Correction Factors

                                   Group Definition

                                   Denver pre-controlled

                                   All low altitude  cities
                                   pre-controlled

                                   1966-1967  California

                                   1968 low altitude cities

                                   1969 low altitude cities

                                   1970 low altitude cities

                                   1971 low altitude cities

                                   1968 Denver

                                   1969 Denver

                                   1970 Denver

                                   1971 Denver

                                   1972 Denver

                                   1972 Los Angeles

                                   1972 low altitude cities

                                   1973-1974  Denver

                                   1973-1974  Los Angeles

                                   1973-1974  low altitude cities

                                   1975 low altitude cities
                                     22-24

-------
                                Illustration jtl

                       Speed Correction Factor Formulas
                              Normalized Equations

                  In HC  - AQ + A1 s + A2 s2 + Aj s3 + A/, s4 +


                  in CO  -A0+Al8 + A2B2 + A3a3+AA84 +
     NOx - A
                                a + A2.82 + A, s3 + A,
GROUP* i
HC*     0.22461E*01
C0=     0.1SJ98E*01
        0.24442E+01
               0.29097E*00
               0.25466E*00
               0.25011E*00
               0.158S9E-01
               0.15235E-01
               0.13829E-01
               0.47249E-03
               0.48740E-03
               0.28703E-03
               0.69408E-05
               0.75821E-05
               0.20758E-05
•0.39280E-07
•0.44951E-07
 0.0         '
1

Ul



GROUPS
HC=
CO*
NOX=

2
0.«!3103E*01
0.23399E*01
0.16863E01


. -0,28957E*00
-0.29698E*00
-0.11330E*00


0.15299E-01
0.16007E-01
0.65497E-02


-0.44669E-03
•-0.47740E-03
-0.13714E-03


0.64818E-05
0.70675E-05
0.10085E-05


-0.36346E-07
-0.40398E-07
0.0
GROUP= 3

COs
NOXa
0.21656E-+01
0»2A415E*01
0.il265E*01
0,26999E*OQ
0.29147E*00
0.3934QE-01
0.14422E-01
0.14295E-01
0.26864E-02
0.43364E-03
0.38785E-03
0.60802E-04
                                                                      0.65074E-05
                                                                      0.52978E-05
                                                                      0.47729E-06
 0.37810E-07
 0.28244E-07
 0*0

-------
ro
N»
ON
GROUP"
HCs
C0=
NOXs
QROUPa
HO
CO*
NOXs
GROUP*
HCs
CO*
NOX=
GROUP*
HCs
CO*
NOXs
GROUPS
HCs
co«
NOXs
GROUPs
HCs
CO*
NOXs
(Illustration
4
0.23973F*01
0.24655E+01
0.1226flf>01
5
0.240B7E*Ol
0.27780E+01
U.10174E+01
6
0,.22322E*01
0.27890E*01
0.98760E+00
7
0.22522F>01
0.27074E+Q1
0.11592E+01
8
0.20278E*01
0.18692E+01
0.18866E+01
9
0.21506E+01
0.18213E+01
0.15578E+01
11 cont'd)
-0.29998E*00
-0.30502E*00
-0.44498E-01
-0.30819E*00
-0.31913E*00
-0.11R96E-01
-0.28499E+00
-0,32711E*00
-0.19567E-01
• -0.28773E*00
-0.33131E*00
-0.44454E-01
-0.27305E+00
-0.27668E*00
-0.16129E*00
-0.28362E*00
-0.27205E*00
-0.11303E*00
*
0.16M5E-01
0.16050E-01
Ot262^8E-02
\
Otl6817E-01
0.15318E-01
0.91437E-03
0.1S383E-01
0.16294E-01
0.16964E-02
0.156R2E-01
0.17618E-01
0.29643E-02
0.1S358E-01
0.17233E-01
0.90499E-02
0.15384E-01.
0.17030E-01
0.67183E-02
-0.48749E-03
-0*47397E-03
-0.56715E-04
-O.S0684P-03
-0.42233fT-03
.-0.21574F-04
-0.45674F-03
-0.46757E-03
-0.40400E-04
-0.47318E-03
-0.53858E-03
-0.66899E-04
-0,46030E-03-
*.O.S58?8E-03 .
-0.18S61E-03
-0.44214E-03
-0.55202E-03
-0.14341E-03
0.72909E-05
0.69908E-05
0.43429E-06
0.75385E-05
0.5fl495E-05
0.1fl230E-06
0.67349E-05
0.67191E-05
0.32800E-06
0.70795E-05
0.81740E-05
0.52236E-06
0.67853E-05
0.87168E-05
0.13256E-05
0.62873E-05
0.86254E-05
0.10608E-05
-0
-0,
0
-0,
-0,
0,
-0,
-0,
0(
-0,
-0,
0.
-0,
-0,
0.
-0,
-0«
0.
                                                                                                0.41977E-07
                                                                                                0.39976E-07
                                                                                                0.43160E-07
                                                                                                0.31497E-07
                                                                                                0.38380E-07
                                                                                                0.37440E-07
                                                                                                 .0
                                                                                                0.40846E-07
                                                                                                0.47780E-07
                                                                                                0.38488E-07
                                                                                                0.51698E-07
            GROUP"10
            HCs     0,22302fT*01
            C0s     0.20342E*01
            NOXs    0,20452t-+01
•0.29365E+00
•0.29519E+00
•0.19401E+00
0.16236E-01
0.18635E-01
0.1l074ErOl
•0.48415E-03
•0.62161E-03
•0.23175E-03
0.71159E-05
0.99366E-05
0.16837E-05
                                                                                                0.34631E-07
                                                                                                 .51144E-07
                                                                                                 .0
•0.40286E-07
•0.59978E-07
 0.0

-------
                   (Illustration 11 cont'd)
10
N>

N>
GROUP* 11
HC= 0.21223?*01
C0= 0.20453f:*01
NOXs 0.101
FE= 0.35076E-01
GROUP«12
, HC= 0.21536E*01
C0= 0.23187E+01
NOX= 0.14482E*01
GROUP«13
HC= 0.20735E+01
C0= 0.25752fi*01
NOX= 0.24597E+00
GPOUPsl4
HC= 0.23495K*01
C0= 0.26B45E+01
NOX« 0,12817E*01
GROUP* 15
HC= 0.21134E*01
C0= 0.2154QE*01
NOXs 0.15345E*01
GROUP=16
HCs 0.21194E*01
CO* 0.25456E*01
NOX= 0.70481E*QO
6ROUP=17
HC« 0.2fi838F:*Ol
C0= 0.2S393E+01
NOXs 0.78384E*00
GROUP= 18
HO 0.23954fT*01
C0= 0.24875E*01
NOXa 0.94213E*00
-0.29107E*00
-0.31062E*00
-0.12186E*00
0.87843E-01
-0.28345E+00
-0.34115E*00
-0.12?64E+00
-0.28935E*00
-0.32889E*00
0.84195E-01
-0.30^96E*00
-0.33282E*00
-0.80487E-01
-0.28568E+00
-0.32912E*00
-0.12567E+00
-0.29863E*00
-0,36295E*00
0.38153E-01
-0,34463E+00
-0.36876E+00
0.32855E-03
-0.33578E*00
-0.39156E*00
-0.42324E-01
0.16909E-01.
0.20485E-01
0.70302E.-02
-0. 27727^-02
0.15695E-01
0.20945E-01
0.79502F--02
d,l73Q4E-01
0.18975E-01
-0.34Q84E-02
0.16842E-01
0.17628E-OI
0.53574E-02
0.16318E-01
0.210UE-01
0.78592E-02
0.18447E-01
0.23277E-01
-0.17391E-02
' *. ;
0.19542E-01
0.21078E-01
0.10603E-02
0.21161E-01
0.27072E-01
0.38625E-02
-0.52615E-03
-0.70853E-03
-0.14629E-03
0.47466E-04
-0.46976E-03
-0.66S89F.-03
-0.17108E-03
-0.55471E-03
-0.62826E-03
0.62988E-04
-0.50962E-03
-0.52412E-03
-0.11889E-03
-O.S0079E-03
-0.68906F-03
-0.16943E-03
• -0.61654E-03
-0.81504E-03
0.32614E-04
-0.62572E-03
-0.67644F-03
-0.31935E-04
-0.73155E-03
-0.97618E-03
-0.93985E-04
0.80271E-OS
0.11621E-04
0.10614E-05
,.-0.33220E-06
0.69383E-05
0.10223E-04
0.12578E-05
1
0.86420E-05
0.10092E-04
-0.41397E-06
0.75952E-05
0.77222E-05
0.90106E-06
0.75507E-05
0.10839E-04
0.12549E-05
0.99206E-05
0.13623E-04
-0.20385E-06
0.97844E-05
0.10627E-04
0.29039E-06
0.12072E-04
0.16527E-04
0.75388E-06
-0.47012E-07
-0.71569E-07
0.0
0.0
-0.39471E-07
-0.59827E-07
0.0
-0.51311E-07
-0.61273E-07
< 0.0
-0.43496E-07
-0.43702E-07
0.0
-0.43719E-07
-0.64712E-07
0.0
-0.60402E-07
-0.85591E-07
0.0
-0.58337E-07
-0.63641E-07
0.0
*
-0.74857E-07
-0.10432E-06
0*0

-------
                                                         Illustration 12

                                        Selected Speed Correction Factors - Warm Operation
N>
K>
00
GROUP

  1
  2
  3
  4
  5
  6
  7
  8
  9
 10
 11
 12
 13
 14
 15
 16
 17
 18
                                                         - Hydrocarbon
                                                         Average Speed
5.000
3.107
3.297
3.083
3.470
3.419
3.123
3.160
2.700
2.903
3.039
2.798
2.928
2.705
3.276
2.815
2.763
3.963
3.194
10.
1.679
1.749
1,708
1.808
1.773
1.695
1.709
1.548
1.600
1.649
1.571
1.623
1.548
1.726
1.582
1.575
1.931
1.708
000 15.
1.201
1.224
1.219
1.2*6
1.231
1.208
1.215
1.160
1.170
1.190
1.168
. 1.184
1.165.
1.216
1.172
l.lfll
1.285
1.228
000 20.
0.987
0.986
0.986
0.984
0.985
0.987
0.986
0.990
0.990
0.988
0.989
0.938
0.989
0.986
. 0.989
0.987
0.981
0.984
000 25.
0.858
0.844
0.841
0.821
0.834
0.853
0.845
0.85-9
0.891
0.867
0.877
0.871
0.871
0.844
0.876
0.848
0.784
0.803
000 30.
0,761
0.740
0.733
0.700
0.720
0.754
• 0.740
0.811
0.819
0.775
0.788
0.781
0.773
0.736
0.788
0.729
0.635
0.653
000 35.
0.684
0.659
0.650
0.606
0.630
0.677
0.658
0.748
0.762
0.702
0.716
0.709
0.694
0.650
0.717
0.635
0.523
0.540
000 40.
0.629
0.600
0.592
0.538
0.565
0.622
0.600
0.703
0.720
0.649
0.667
0.659
0.640
0.589
0.669
0.573
0.446
0.468
000 45.
0.597
0.565
0.556
0.497
0.526
0.591
0.567
0.681
0.699
0.619
0.644
0.632
0.616
0.554
0.646
0.543
0.401
0.432
000 50.
0.585
0.547
0.534
0.472
0.504
0.576
0.551
0.678
0.694
0.609
0.638
0.624
0.610
0.538
0.641
0.531
0.373
0.414
000 55.
0.571
0.530
0.503
' 0.445
0.479
0.557
0.529
0.672
0.691
0.596
0.617
0.612
0.589
0.519
0.628
0.497
0.337
0.373
000 60.000
0.516
0.482
0.429
0.381
0.414
0.495
0.460
0.616
0.649
0.538
0.525
0.553
0.493
0.456
0.553
0.383
0.258
0.260

-------
                (Illustration 12 -oont'd)
N>
VO
      GROUP

        1
        2
        3
        4
        5
        6
        7
        8
        9  *
      10
      11
      12
      13
      14
      15
      16
      17
      13
GROUP

 I
 2
 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
                                                Carbon Monoxide
                                                Average Speed
5.
2.389
• 3.319
3.656
3.621
.4.554
4.511
4.174
2.345
2.277
2.541
2.516
2.885
3.791
4.056
2.599
3.384
4.239
2.988
000 10.
1.463
1.751
1.856
1.844
2.120
2.103
2.003
1.418
1.395
• 1.488
1.474
1.540
1.916
1.950
1.459
1.744
1.980
1.580
000 15.
1.142
1.225
1.251
1.253
1.329
1.326
1.299
1.121
1.113
1.149
1.148
1.149
1.291
1.281
1.127
1.237
1.293
1.183
000 20.000 25.000
0.991
0.986
0.985
0.984
0.979
0.979
0.975
0,992
0.993
0,990
0.989
0.991
0.980
0.982
0.992
0.983
0.981
0.986
0.889
0.841
0.837
0.823
0.781
0.778
0.776
0.905
0.913
0.873 .
0.863
0.891- .
0.771
0.804
0.900
0.795
0.782
0.821
30.000
0.803
0,734
0.738
0.707
0.644
0.637
0.633
0.827-
0.841
0.770
0.746
O.S04
0.612
0.675
0.814
0.641
0.634 '
0.671
35.000 40.000 45.000 50.000 55.000 60.000
0.733
0.650
0.663
0.619
0.543
0.533
0.526
0.760
0.780
0.684
0.651
0.729
0.496
0.577
0,739
0.527
0.525
0.557
0.686
0.592
0.608
0.556
0.469
0.457
0.453
0.717
0.743
0.629
0.591
0.677
0.420
0.510
0.691
0.458
0,454
0.493
0.665
0.557
0.572
0.517
0.418
0.407
0.406
0.703
0.737
... 0.608
0.568
0.657
0.378
0.470
0.67S
0.427
0.415
0.475
0.663
•0.539
0.554
0.493
0.384
0.374
0.375
0.711
0.755
0.608
0.566
0.658
0.355
0.451
0.681
0.410
0.395
0.478
0.647
0.518
0.542
0,465
0.358
0.345
0.341
0.701
0.756
0.589
0.534
0.643
0.324
0.436
0.661
0.360
0.364
0.434
0.558
0.454
0.515
• 0.399
0.323
0.299
0.273
0.600
0.662
0.478
0.397
0.538
0.246
0.391
0.530
0.227
0.278
0.265
Nitric Oxide

5.
1.505
1.242
0.990
1.063
0.978
0.927
1.003
1.284
1.143
1,324
1.181
1.014
0.589
0.999
1.082
0.856
0.808
0.816

000 10.
1.060
1.031
0.946
0.992
0.970
0.924
0.949
1.006
0.966
0.997
0.981
0.860
0.806
0.903
0.907
0.943
0.864
0.819

000 15.
0.941
0.974
0.960
0.980
0.9B1
0.956
0,960
0,944
0.944
0.930
0.946
0.887
0.934
0.924
0.909
0.986
0.934
0.897

000 20.
1.010
1*004
1*004
1.002
1.002
1.004
1,004
1,008
1,007
1.010
1.007
1.012
1.004
1*008
,. 1*010
1.001
1.006
1.009
Average
Speed

000 25.000 30.000 35,
1.161
1.074
1.058
1.038
1.026
1.056
1.059
' 1.128
1.105
1.152
1.109
1.174
1.043
1.112
1.148
1.002
1.069
1.124
1.319
1.146
1,109
1.075 ,
1.049
1.102
1.110
1.255
1.200
1.297
1.214
1.330
1.070
J.208
1.280
1.000
1.121
1.222
1.440
1.203
.150
.105
.070
.141
,150
.359
1.275
1,410
1.300
1.454
1.097
1.282
1.382
1.002
1.161
1.294

000 40.
1.511
1.239
1.182
1.129
1.091
1.173
1.180
1.429
1.323
1,480
1.361
1.542
1.132
1.332
1.452
1.014
1.193
1.344

000 45.
1.551
1.26S
1.213
1.152
1.115
1.206
1.207
1.477
1.358
1.524
1.407
1.606
1.175
1.369
1.501
1.036
1.226
1.386

000 50.
1,608
1.306
1.258
1.189
1,151
1.250
1.250
1.531
1,406
1.582
1.462
1.678
1.221
1.421
1.564
1,067
1.274
1.446

000 55.
1.764
1.404
1.340
1.257
1.208
1.323
1.331
.. 1.641
1.511
1.721
1.570
1.B10
1.258
1.526
1.691
1.103
1.353
1.560

000 60.000
2.129
1.615
1.489
1.384
1.298
1.445
1.483
1.877
1.733
2.031
1*786
2.070
1.268
1.736
1.955
1.136
1.486
1.777

-------
               (Illustration  12 cont'd)
K>
Ni
        CROUP

        1
        2
 6
 7
 8
 9
10
II
12
II
14
15
16
1"
18
        GROUP

         1
         2
         7
         8
         9
        10
        11
        1?
       15
       16
       .17
       IS
                                                              Hydrocarbon
                                                             Average Speed
6.000
2.662
2.816
2.663
2.951
2.901
,2.680
2.710
2.343
2.497
2.604
2.413
2.522
2. 343
2.788
2.430
2.389
3.309
2.717
11.000
.544
.601
.573 :
.650
. 620
..558
.571
.438
.477
.519
.457
.499 1
.440 1
.582 1
. 466 1
.464 1
.748 1
. 573 1
16.000 21. 000 "'26. 000" 31.000 36.000 41.000 46.000 51.000 56.000 61.000
1.146 0.957' 6.837. 0.744 0.671 0.621. 0.594 0.583 0.565 0.495
1.163 0.953 0.821 0.722 0.645 0.591 0.560 0.544 0.525 0.464
1.160 0.952 0.817 0.715 0.637 0.583 0.551 0.529 0.493 0.406
1.180 0.946 0.794 0.679 0.590 0.528 0.491 0.468 0.437 0.361
.168 0.950 0.809 0.700 0.615 0.555 0.520 i 0.500 0.471 0.793
.151 0.956 0.832 0.737 0.664 0.614 0.587' 0.5"3 O.f.50 O.H/4
.156 0.954 0.822 0.7£? 0.644 0.592 0.563 0.548 0.520 0.437
.116 0.967 0.872 0.797 0.737 0.697 0.680; 0.679 0.667 0.594
.123 0.966 0.875 0.807 0.752 0.714 0.697 0.694 0.687 0.631
.138 0.960 0.847 0.759 0.689 0.641 0.6161 0.607 0.589 0.51*
.122 0.964 0.858 0.772- 0.704 0.661 0.642' 0.636 0.606 O.H'f'l
.134 0.961 0.851 0.765 0.698 0.652 0.629 0.623 O.tOt 0.531
.121 0.963 0.850 0.756 0.681 0.633 0.614 0.609 0.578 O.HsO
.158 0.953 .0/821 0.717 0.636 0.580 0.550 0.535 0.511" 0.434
.125 0.963 0.857 0.772 0.705 0.662 0.644 0.640 0.620 0.526
.133 0.957 0.823 0.708 0.620 0.564 0.540 0.527 0.482 0.3H8
.209 0.936 0.751 0.610 0.505 0.435 0.395 0.368 0.325 0.3-75
.169 0.945 0.770 0.627 0.522 0.458 " 0.428 " O.'UQ O.J^ O.t**'
                                                           Carbon Monoxide
                                                            Average Speed
6.000 11.000 16.
2.105 1.373 1.104
2.829 .602 1.164
3.096
3.063
3.784
3.745
3.482
2.054 1
2.001 1
2.208
2.183
2.447
3. 196
3.383
2.228
2.848
3.500
.685 1.181
.678 1.184
.896 1.239
.882 1.237
.804 1.217
.333 1.088
.314 1.082
.392 1
.381 1
.425
.742
.759
.361
.601
.783. ... 1
"2.313 .465 1
. 110
.110
. 107
.215
.204
.092
.176
.214
.137
000 21.
0.968
0.952
0.949
0.946
0.932
0.932
0 . 929
0.973
0 . 975
0 . 965
0.963
0.969
0 . 933
0.940
0.972
0.942
0.935
0 . 952
000 26.
0.871
0.817
,0'.815
0.797
0. 750
0.746
0.744
0 . 889
0.898
0 . 852
.0.839
0 . 873
0.735
0.775
0.882
0.762
0.749
0.789
000 31.
0.787
0.715
0.721
0.687
0.622
0.613
0.609
0.812
0 . 827
0.751
0.725
0.788
0.585
0 . 653
0.797
0.615
0.609
"0.644
000 36.
0.721
0.637
0.650
0.604
0.526
0.515
0.509
0.749
0.770
0.670
0.636
0.716
0.477
0 . 562
0.727
0.510
0.508
0.540
000 41.
0.679
0.583
0.599
0.546
0.457
0.4H6
O.HHI
0.712
0.739
0 . 622
0.583
0.671
0.409
0.500
0.685
0.449
O.H44
0.486
000 46.
0.664
0.552
0.567
0.511
0 . H 1 0
0 . 399
0.399
0.704
0.739
0.607
0.567
0.656
0.373
0.465
Ci . 676
0.423
O.H10
0.475
000 51.000
0.663
0.536
0.551
0.488
0 . 3~9
0.369
0.370
0.712
0 . "58
0.608
0.564
0.658
0.351
0.449
0 . 682
0.405
0.391..
0.476
56.000
0.637
0.510
0.539
0.456
OT«s"T
«..•;•
0 . 338
0.331
0.691
0.748
0.577
0.517
0.632
0.313
0.431
0.646
0.341
0.352
0.411
61.000
0.?56
0.473
0.504
0 . 7~8
0.313
O.S85
0.253
0 . 563
0.624
0.440
0.355
0.501
0.223
0.375
0.486
0.193
0.253
0.221

-------
              (Illustration &  cont'd)
NJ
r
CO
GROUP

  1
  5
  •7
  4
  I?
  6
  7
  8
  9
10
II
15
13
14
15
16
17
18
                                                      Nitric Oxide
                                                      Average Speed
6.000 11.000 16.000
1.385 1.015 0.943
1.184- 1.010 0.975
0 . 975 0 . 945 0 . 967
1.043 0.986 0.983
0.975 0.971 0.985
0 .953 0 . 959 0 . 965
0 . 985 0 . 947 0 . 967
1.506 0.980 0.949
1.095 0.955 0.951
1 i 535 0 . 967 0 . 937
1 . 1 54 0 . 964 0 . 953
0.964 0.854 0.906
0.645 0.837 0.951
0.967 0.900 0.937
1.058 0.896 0.954
0 . 878 0 . 954 0 . 990
0.817 0.877 0.949
0.808 0.830 0.918.
51.000
.036
.017
.015
.009
.007
.014
.015
.059
.055
.036
.055
.043
.014
.058
.036
.001
.019
.033
•<
I/
l.l
.1
.1
1.1
1.1
.1
.
.
.
,
.
.
.
.
.0
.c
.1
••6.000
194
389
369
346
330
365
370
54
55
83
30
-07
49
33
75
01
81
45
. 31.000
1347
. 159
. 118
.081
.053
.111
. 119
.578
.517
.353
.533
.358
.075
.555
.303
.000
. 130 1
.538 1
36.000
.458
.511
.157
.110
.074
. 148
.157
.376
.586
.457
.314
.475
.103
.594
.399
.004
. 168
.306
41.000
.551
.544'
.187
.133
.095
.180'
.185
.440
.331
.490
.371
.556
. 140
.340
. 465
.017
. 199
.355
46.000
.559
.571
.550
.158
.151 ;
.513 ;
.514
.486 .
.365 1
>?77 |
• «P •' <^
.416
.618
. 1 84
.378 .
.511
.045
.534
.396
51.000
.658
.350
.571
. 199
. 160
. 565
.565
.546
.451
.601
.. 478
.698
. 559
.436
. 585
.074
. 587
.463
56.000 61.000
.816 5.539
.436 1 . 677
.364 1 . 530
.577 1.419
.553 1.351
.343 1 . 478
.354 1 . 555
.675 1.946
.544 1 . 798
.766 5.154
.605 1.849
.849 5.145
. 563 1 . 564
.557 1.797
.731 5.031
.110 1.141
.375 1.551
.594 1 . 838

-------
                                                                      Illustration  13
                                Light Duty Vehicle Hydrocarbon Correction Factors for Ambient Temperature and/or Average Speed
                                        and/or Z Hot  Start/Z Cold  Start Driving which differ from the FTP Assumptions*
Model Year
pre-1968

1968-74
[w(exp(2.9310-.014779t)  +  . 673+. 569A) (v.
       Correction Factor**
/.821) + x(4.75 +.393A)(v
                                                                                              /VB ,,) + (l-w-x)(5.69 +.471A)(vB 0 /VB .,)]/(5.67+.47A)
                      [w(exp(2.9310-.014779t) -  2.41 +.863A)(v,   /.821) + x(2.43 +.555A)(v    /v  ,,) + (l-w-x)(2.61 +.597A)(v    /VB -,)]/(2.8 +.64A)
                                                             *»»j_                         8t»3  8»*o                          8»»^  at*"
K>
1975 Federal      [w(exp(2.4339-.023591t) +  .623+.301A)(v2

1975 California   [w(exp(1.9934-.022269t) -  .032+.445A)(v2

*  FTP assumptions are outlined in Table I.I.
/.821) -f x(l.ll +.284A)(v,

         x( .497+.357A)(v
                                                                                           /va  ,,)
                                                                                  (l-w-x)(1.05 +.270A)(v

                                                                                           ,243+.175A)(v
                                                                 Jv
                                                                                                                                        )]/(!. 38+. 28A)

                                                                                                                                             .54+.28A)
   **
               v <• fraction of total miles which are driven in cold start condition,
               x • fraction of total miles which are driven in hot start condition,
               t - ambient temperature  (*F),
               A • vehicle age minus 1, in years,
               g • index for model year-city groups for which average speed data wsre available (g • 1, 2,... ,18),
              s. • average speed (miles per hour) in bag 1, 1 » 1,2,3,
       v( )^v( ) " ^)a8~8Peci^ic speed correction factor (.821 equals v. ,g)»
             exp - exponential function, base e.
        These 'correction factors are applicable to ambient temperatures of 0* to 110*F, vehicle ages of 1 to 10 years,  average vehicle
        speeds of 5 to 60 mph, and to all combinations of Z hot start/% cold start driving.  The incorporation of the appropriate v
        terms (calculated from Table 11.13) in the above equations would yield a correction factor for each of the 19 model year-clE^ groups
        for which data were analyzed.  Table II. 4 provides the method for combining the basic equations provided in the above table with
        the appropriate v    terms In order to perform calculations without the aid of a computer.

-------
                                                                        Illustration 14
Model Year
                              Light Duty Vehicle Carbon Monoxide Correction Factors for Ambient Temperature and/or Average Speed
                                        and/or Z Hot Start/Z Cold Start Driving which differ from the FTP Assumptions*

                                                                         Correction Factor**
to
u>
pre-1968         [w(exp(5.6548-.015965t) - 14.74+9.62A)(v2 fl /.817) 4- x (42.844-5.76A)(v  g /v  2fi) 4- (1-w-x)(57.57f7.74A)(v  g /v  16)J/(56.434-7.59A)


1968-74          [w(exp(5.6548-.015965t) - 33.89+9.77A)(v,   /.817) 4-x(25.2644.71A)(v    /v  ,,) 4- (l-w-x)(35.9 +6.70A)(v    /v  1R)]/(36.4 +6.79A)
                                                        ™f**i                         oft .1  o§ ™"                          &• ' A  o v •*»

1975 Federal     (w(exp(5.5460-.028945t) 4- 11.294-4.24A)(v2|8 /.817) 4- x(15.854-2.34A)(vgjB /vg>26) 4- (1-w-x)(21.174-3.13A)(vg g /v  16)]/(23.7 4-3.14A)


1975 California  [w(exp(4.2391-.017522t) -   .20«.99A)(v2jB /.817) 4- x( 4.124-2.20A)(vgj(j /vg>26) 4- (1-w-x)( 3.96«.12A)(v  g /v  lfi)]/( 6.984-3.14A)


*  FTP assumptions are outlined in Table Z.I.

**          w • fraction of total miles which are driven in cold start condition,

            x " fraction of total miles which are driven in hot start condition,

            t * ambient temperature (*F),

            A • vehicle age minus 1, in years,

            g « index for model year-city groups for which average speed data were available (g • 1, 2,...,18),

           s.  • average speed (miles per hour) in bag i, i - 1,2,3,

    v< »/v, .  • bag-specific speed correction factor (.817 equals v. .g)»

          exp  - exponential function, base e.

    These correction factors are applicable to ambient temperatures of 0* to 110*F, vehicle ages of 1 to 10 years, average vehicle
    speeds of 5 to 60 mph, and to all combinations of % hot start/Z cold start driving.  The incorporation of the appropriate v
    terms (calculated from Table 11.13) in the above equations would yield a correction factor for each of the 19 model year-cifyagroupa
    for which data were analyzed.  Table II.4 provides the method for combining the basic equations provided in the above table with
    the appropriate v    terms in order to perform calculations without the aid of a computer.

-------
_
r*
l
                                                                     Illustration  15

                                  Light Duty Vehicle Oxides of Nitrogen Correction Factors for Average Speed and/or
                                      . X Hot Start/Z Cold Start Driving which differ from the FTP Assumptions*
Model Year

pre-1968


1968-74


1975 Federal


1975 California
[v(3.26 •»• .335A)<2.01
                                                                                                              /v
                                                                                                              /v
                                                                                                .116A)(vB   /VB
                                                                                                        *' ft.  8

                                                                                                .126A)
                                                                                                                           )l/(2.47 + .ISA)
                                                                                                                          l)]/(2.46 + .18A)
         These correction factors are applicable to ambient temperatures of 0*  to 110*?, vehicle ages of 1  to 10 years, average vehicle
         speeds of 5 to 60 aph,  and to all combinations of Z hot start/% cold start driving.  The Incorporation of the appropriate v
         terms (calculated from Table 11.13)  in the above equations would yield a correction factor for each of the 19 model year-cify groups
         for which data were analysed.   Table II. 4 provides the method  for  combining  the basic equations provided in the above table with
         the appropriate vn a terms in order  to perform calculations without the aid  of a computer.
                          B»a

-------
                 LAND USE BASED EMISSIONS FACTORS
                      Presented at the 1977
                 Environmental  Protection Agency
               Emission Inventory/Factor Workshop
         Raleigh, North Carolina - September 13-15,  1977
                                By
Frank Benesh                        Thomas McCurdy
Environmental Planner               Community Planner
GCA/Technology Division             Land Use Planning Office
Bedford, Massachusetts              Strategies and Air Standards
                                      Division
                                    U.S. Environmental Protection
                                      Agency
                              23-1

-------
          ABSTRACT OF "LAND USE BASED EMISSION FACTORS"

     A set of land use based emission factors were developed for
five criteria pollutants and thirteen land use types.  The pollu-
tants are particulates, sulfur oxides, carbon monoxide,  total  hydro-
carbons, and nitrogen oxides; the land uses investigated were  five
classes of residential (detached single family, attached single
family, mobile homes, lowrise multifamily, and highrise  multifamily),
retail commercial, wholesale commercial, transient lodging, offices,
hospitals, cultural buildings, churches, and schools.  Units of the
emission factors for heating degree day or compressor operating
hour.  Non-residential emission factor units are given in pounds
of pollutant per square feet of floor area per heating or cooling
degree day.  Emission factors are also presented in SI units.

     Methods used to develop the emission factors are discussed in
the paper.  The factors are applied to one land use type to deter-
mine what project size (in terms of number of dwelling units)  would
be a "major source" under EPA's 1976 Interpretative Ruling on the
location of new sources within non-attainment areas.  This appli-
cation indicates that land use based emission factors are easy-to-
use.
                               23-2

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INTRODUCTION
     Any air resource management approach that includes evaluation
of community land use plans for their ambient air quality impacts
requires that estimates of emissions be devised for the time period
of analysis.  Normally this is a time consuming and laborious
process as evidenced by the amount of work that went into the
emission inventories discussed at this conference.  It is a process
well beyond the limited expertise and budget of most planning
agencies in this country.  Past EPA attempts to standardize and
simplify the procedure, such at its Volume 7 and 13 of the Air
Quality Maintenance Planning Analysis guidelines (1), are still
very complex and tedious.  (In fact, an effort is currently under-
way to determine if the procedure should be computerized or not
(2).)  If routine evaluation of land use plans for air quality
impacts is to become a reality, a method has to be devised to reduce
the complexity and labor involved — especially if urban planners
are the ones who will be doing the evaluation (3).
     The Land Use Planning Office of EPA's Strategies and Air
Standards Division has long been interested in developing easy-to-
use land use oriented emission factors.  The Office sponsored two
projects in 1972-1973 that developed and used land use based emission
factors: the "Air Pollution-Land Use Planning Project" with Argonne
National Laboratories (4) and the "Hackensack Meadowlands Air Pol-
                               23-3

-------
 lution  Study"  with  a  private  contractor  (5).*
 These two  efforts treated emissions  as a function  of  land area, viz:
                                     emissions	
                  emission factor  =  unit land  area
 Because space  heating,  process  emissions, and  the  like  occur  indoors
 and have no known consistent  relationship with land area per  se,
 the above  formulated  emission factor is  incomplete because another
 piece of information  is needed  to  use it -- density of  development
 (building  area per  lot  area).  To  avoid  this problem, land use
 based emission factors  based  on building area  were developed  as
 part of the "Growth Effects of  Major Land Use  Projects" (GEMLUP)
 effort  (9).  These  building area emission factors  are the subject
 of this paper.**
 RELATIONSHIP WITH  CONVENTIONAL  EMISSION  FACTORS
      Reference 4 has  shown the  lack  of ability of  land  use based
 emission factors to adequately  predict emissions of large industrial
 sources, i.e., point sources.  (It is also shown that other economic
 and planning indicators such  as employment and output are also
 *A critical review of land use emission factors developed in these
 projects is found in references 6-7.   An elaboration of Hackensack
 Meadow!and factors is found in reference 8.   How land use data  can
 be used to improve area source emission inventories is contained
 in reference 27.
**A land area emission factor can easily be derived from a building
 area factor by multiplying the latter by "floor area ratio," or FAR,
 which is a density measure with units of building floor area per
 unit lot area.  This ratio has been standardized for zoning purposes
 by the Federal Housing Administration, and is part of a larger  scheme
 to relate building areas with open space and parking.  See reference
 10 for additional information.
                               23-4

-------
incapable of predicting industrial point source emissions.  This is
due, in part, to the variability of emission rates within even fine
industrial categories such as four digit SIC codes).  Thus, large
industrial sources must be treated individually when using land
use based emission factors, as is the case when conventional  emission
factors are utilized in an emission inventory.
     Land use based emission factors can be expected to  handle
area source emissions adequately.  In the special  (and hypothet-
ical) case where the land use categories are identical to the
area source emission categories in a conventional  emission inventory,
an emission inventory prepared with land use based emission factors
will be exactly equivalent to a conventially prepared inventory.
In fact, one method of estimating locally specific land use based
emission factors is through a regression analysis  of a convention-
ally prepared inventory, such as was done by the California Air
Resource Board (30).  Depending on the data available in a specific
application, land use based emission factors may be able to provide
a more accurate emission inventory (both in terms  of aggregate
emissions and their spatial distribution) then the conventional
approach.  The classification scheme employed in the land use inven-
tory and the availability of accurate fuel  consumption data for the
region of interest are principal determinants of which approach will
be more accurate.  The utilization of land use based emission factors
would appear to be less time consuming in all instances.
                              23-5

-------
GEMLUP APPROACH TO DEVELOPING LAND USE BASED EMISSION FACTORS
     Land use based emission factors are usually disaggregated into
two components, an activity factor (i.e., fuel throughput, etc.,
per unit floor area), and the standard  emission factor (i.e.,
emissions per unit fuel).  For example, in the case of fuel oil
space heating consumption, this would be:
emissions (gr)        _  oil consump. (gals)   *  emissions (gr)
floor" area  ( 1 03 f tz )  ~  floor area  (TCP ft*)     oil consump, (gals)
Given this  approach, a complete set of land use based emission fact-
ors would consist of an n-dimensional array with specific values
given for a pollutant species, fuel or process type, building cate-
gory, and,  in some cases, energy requirements (e.g., region of the
country).
     Ignoring solvent evaporation, solid waste disposal, and other
miscellaneous emissions*, an energy  consumption related emission
factor  can  be generalized as follows:
emissions.-  ^ •,       Btu.            Btu_.              Btu.
         T »J»K  =  TI  . i               '                  '
                   uz
_              .  _        _ _ _^      . .. .
ftz * year         uftz * year     ftz * ht.d.d.     ftz * cl.d.d.;
                      1 _  ^          1           * emissions -i
                 heat content.     seasonal ef f i ciency   unit fuel^. k
*Emissions from these sources were not considered in the GEMLUP
project, because (1) there is limited information about their
characteristics, and (2) they may be expected to display a lot of
variation in per unit floor area emissions among parts of the
country.  However, the emission factor structure discussed above
is amenable to their inclusion.
                                23-6

-------
     Where:
            ht.d.d. = heating degree days per year
            cl.d.d. = cooling degree days per year
            and for a particular fuel type i, pollutant species j
                      and building category k.
     The fourth term in this equation, emissions per unit fuel,
is the  commonly used values determined directly from EPA's
Compilation  of Air Pollutant Emission Factors (11).  Hence, focus
of the GEMLUP project was on generating the first three terms
(i.e., the activity factor).
     The activity factor identifies fuel consumption per building
floor area given a number of heating and cooling degree days.  The
heat content of fuel in British thermal units is approximately
constant and is well known (12).  It does display some variation
for every fuel, especially for natural gas in different regions of
the country  (13).
     Efficiency values for building types and fuels are less well
known.  Efficiency can be defined in a variety of ways, and is used
to account for differences in the amount of energy consumed by a
building depending on the fuel type selected to provide that energy.
This is not  heating unit efficiency, which is measured at full load/
steady state operation.  Thus, it does not account for rapid on and
off cycling  associated with the typical oversized furnace.  Nor (in
the case of  gas furnaces) does it measure the pilot light fuel
                              23-7

-------
consumption when the furnace is off.
     The desired efficiency measure for GEMLUP purposes was the ratio
of heat loss from a structure to the energy input to the structure.
This is variously defined as efficiency of utilization or seasonal
efficiency.  However, even with this definition of efficiency, there
is some disagreement in the literature over what are appropriate
values to use.
     The term in brackets, the energy requirement per square foot
and per square foot degree day, represents building energy require-
ments.  It is divided into three components:
     1.  Process use of energy that is not related to climate, such
         as:
                    Lighting          Water heating equipment
                    Elevators         Cooking equipment
                    Refrigeration     Ventilation
     2   Energy requirements for space heating as a function of heat-
         ing degree days.
     3.  Energy requirements for air conditioning as a function of
         cooling degree days.
     The energy requirement factor, the efficiency of utilization,
and the standard emission factors are all estimates of the mean of
population values and can be expected to display a large variation.
In general, these factors are not precise indicators of energy
requirement, efficiency, or emissions of a single source.  They are
more valid when applied to a large  number of sources.  Sources of
variation  in the energy requirement and efficiency factors are
discussed  in the GEMLUP report  (9)  and will not be discussed here.
                               23-8

-------
     The critical element in the development of land use based emis-
sion factors is estimating energy requirements per square foot for
various building types; the rest of the information needed to develop
the factors is generally available.
     Much of the existing literature on energy consumption in build-
ings is not applicable to the development of energy requirement fact-
ors.  Most of it is devoted to predicting energy consumption of a
single structure.  The literature that was applicable to the GEMLUP
study fell into two classes:  (1) typical energy consumption data
for building categories based on engineering estimates, and (2)
average energy consumption information from a sample of structures
in a particular building category.   Both classes of literature
were used in GEMLUP analyses with slightly more emphasis given to
the latter category, particularly utility company surveys of customer
energy utilization.  Where conflicting data were presented, a compro-
mise value was chosen that seemed to represent an "average" situation.
     Not all of the data come from secondary sources.  Regression
analyses of office building energy usage were undertaken as part of
the GEMLUP project.  Input data for the analyses came from a Building
Owners and Managers Association annual survey of energy use (24).
The regressions yielded very low coefficients of determination, even
though various combinations of independent variables were used (9).
LAND USE BASED EMISSION FACTORS
     Land use based emission factors for uncontrolled single family
residences are presented in Table 1.  Similar factors for all other
                              23-9

-------
                                           TABLE 1

                  SINGLE FAMILY RESIDENTIAL LAND USE BASED EMISSION FACTORS
Pound of pollutant (or kilowatt-hours) per measure
PM SOV CO HC NOV • kWh Measure
X A
Space Heating
Electricity - - -
Gas 2.6 x IO"4 1.5 x IO"5 5.1 x IO"4
011 2.2 x IO"3 3.2 x 10"2S 1.1 x 10"3
A1r Conditioning
Central
Electricity - - -
N» Gas 1.8 x IO"4 1.1 x IO"5 3.5 x 10"4
,L Room
0 Electricity - - -
Process
Hot Water
Electricity -
Gas 3.0 x 10"1 1.8 x IO"2 6.0 x IO"1
011 2.5 3.7 x lO^S 1.2
Cooking
Electricity -
Gas 1.1 x IO"1 6.6 x IO"3 2.2 x 10"1
Miscellaneous - - -

3.8 dwelling
2.0 x IO"4 2.6 x TO"3 - dwelling
6.6 x IO"4 2.6 x 10"3 - dwelling


4.7 dwelling
1.4 x 10"4 1.8 x IO"3 - dwelling


unlfht.d.d.
unlfht.d.d.
unlfht.d.d.


uh1fop.hr.
un1fop.hr.

5.1x10 a.c. un1t°operat1ng
hour

1.4xlO+4 dwelling
2.4 x IO"1 3.0 - dwelling
7.5 x IO"1 3.0 - dwelling

3.5xlO+3 dwelling
8.8 x IO"2 1.1 dwelling
7.9xlO+3 dwelling


un1 fyear
unifyear
un1 fyear

unifyear
un1 fyear
uni fyear
Note:  A 1600 square foot dwelling unit Is  assumed.
       •S' represents the sulfur percentage of oil,  by weight.

-------
land uses investigated in the GEMLUP project are contained in Refer-
ence 9.  The factors are presented in units of pounds of pollutant
emitted per "measure" for oil and gas combustion.  For electricity
consumption, the factors are in terms of kilowatt-hours per "measure".
The measure, depending on the activity involved, may be square foot
of building floor area per heating degree day, dwelling unit per year,
air conditioner operating hour, etc.
     The quantity of secondary, i.e., offsite, emissions occuring
due to electricity consumption depends on the nature of the local
electric utility generating station.   In developing an estimate of
secondary emissions caused by a land  use type, the local utility
should be contacted to determine the  proper emission rate.   Default
values for these emissions have been  developed, however, and appear
as Table 2.  They come from data in references 11,25, and 26.
     None of the tables present process emissions for industrial
sources.  The estimation and use of land use based emission factors
for industry presents severe problems.  The variation in emissions
per square feet of industrial land area, and probably in industrial
building area also, is great (4,7). Therefore, GEMLUP industrial
emission factors only includes fuel combustion and treats these
emissions like area source emissions  in a typical emissions inven-
tory.  Process emissions have to be obtained separately and added
to fuel use emissions.
                              23-11

-------
                                             TABLE 2
                         TYPICAL EMISSION FACTORS FOR ELECTRIC UTILITIES
Pounds of
PM




N>
V
l-» :
K>




coal
oil
gas

5.
6.
1.

23 x
34 x
19 x

ID'3
io-4
ID"4
Kilograms of


coal
oil
gas


6.
7.
1.
PM

59 x
99 x
50 x


io-10
lo-11
ID'11
pollutant emissions
SO
x
1.53 x 10"2S
1.26 x 10"2S
7.13 x 10"6

4
2
2
pollutant emissions
sov
x
1.93 x 10"9S
1.59 x 10"9S
8.98 x 10"13


5
3
2
per kilowatt hour
CO HC

.03 x
.38 x
.02 x

ID'4
ID'4
ID'4
per joule
CO

.08 x
.00 x
.55 x


ID'11
io-11
ID'11

1.21 x
1.58 x
1.19 x
sold to
HC

1.52 x
1.99 x
1.50 x
sold to customer
NO..

io-4
io-4
ID'5
customer


io-11
ID'11
ID'12
X
2.21 x IO"2
8.32 x 10"3
8.32 x IO"3
(SI Units)
NOV
x
2.78 x 10"9
1.05 x IO"9
1.05 x IO"9
Note:  A 33.3% overall plant efficiency is assumed for coal fired plants [34].
       A 31.6% overall plant efficiency is assumed for oil and gas fired plants [34].
       A 10% transmission loss is assumed [35].
       'S' and 'A1 represent, respectively, the sulfur and ash percentage of fuel by weight.

-------
APPLICATION OF LAND USE BASED EMISSION FACTORS:  DETERMINING " MAJOR
SOURCES" IN NON-ATTAINMENT AREAS
     To illustrate how land use based emission factors can be used,
a "real-life" example will be presented.  On December 21, 1976
EPA issued "Requirements" (28) and an "Interpretative Ruling" (29)
on the location of new sources within non-attainment areas.   The
Ruling states that a major new source may Icoate in an area with
air quality problems only if stringent conditions can be met.  The
conditions are:  emissions are controlled to the "greatest degree
possible, "equivalent emission reductions will be obtained from
existing sources, and progress toward attaining air quality standards
will be achieved (41 FR_ 55525).   A preconstruction review process of
all sources emitting 100 tons of pollutant* .per year or more (1,000
tons for carbon monoxide) is mandated to implement the ruling.   If
these "major" sources do not meet the three conditions mentioned
above, a State is not allowed to issue a construction permit under
40 CFR 51.18 (41 FR 55525).
     In the other Federal Register notice, EPA proposes to lower
the "major source" definition down to 50 tons of pollutant* per year
(500 tons for carbon monoxide) (41 FR_ 55559).  In other words,
facilities emitting 50 tons of most criteria pollutants will be
required to undergo new source review and meet the stringent require-
ments.
*The pollutants of interest are particulate matter, sulfur oxides,
nitrogen oxides, and non-methane hydrocarbons.
                              23-13

-------
     For a private developer 6f land, a question immediately arises:
what size of project will trigger a new source review?  Phrased
another way,  what is the biggest shopping center (or apartment house,
etc.)  a developer can build without emitting 50 tons per year of
SOV or TSP?  Land use based emission factors can be used to answer
  A
these questions, and doing so constitutes the example to be shown in
the remainder of this paper.
     Basically, the answer is obtained by using Table 1 to solve the
following simple equation (or ones similar to it):
     sq ft  = 50 tons  •  sq ft  • ht.d.d.  •  yr.
                yr        tons               ht.d.d.
                           land use based     heating
                           emission factor    degree
                                             days.
Additional information needed, or needed to be assumed, to solve
the equation includes:  sulfur content of oil,  location of the new
source  (because of differences in heating/cooling degree days), air
conditioner operating hours, and so forth.
     Maps of heating and cooling degree days and air conditioner
compressor operation hours were consulted (9) to choose representa-
tive areas of  the country  for analysis.  A list of a sample of cities
appears  as Table 3.  Five  cities will be used for the analysis:
Atlanta, Bismarck, Boston, Miami, and San Francisco.
     The sulfur percentage of #2 fuel oil used for heating and the
coal and oil used in power plants has to be assumed in order to
                               23-14

-------
                                                    TABLE 3

                          LIST OF REPRESENTATIVE CITIES AND HEATING/COOLING PARAMETERS
ro
V
!-•
Ui
»
Cities Heating Degree Day
Albuquerque
Atlanta*
Bismarck*
Boston*
Chicago
Denver
Lincoln
Los Angeles
Miami*
Missoula
New Orleans
New York
Okla. City
Philadelphia
Portland
Raleigh
Reno
Salt Lake
San Antonia
San Diego
San Francisco*
Seattle
St. Louis
Washington
5000
3000
9000
6000
6500
6500
6000
2000
100
9000
1500
5500
3500
5000
7500
3000
6500
6000
1500
1500
3000
5800
4500
4500
Compressor Operating Hour Coolii
600
1600
300
400
600
200
1000
500
2500
100
2000
700
1700
850
300
1300
500
100
2500
500
100
100
1200
1000
1000
1400
 500
 500
 700
 500
1000
1000
4000
 500
2700
1000
2000
1000
 500
1500
 500
1000
3000
1000
 500
 500
1400
1000
           *Cities chosen for further analysis

-------
estimate sulfur oxide emissions.  The percentages used for the three
items listed in the previous sentence are 0.5%, 2.0%, and 1.0%,
respectively.
     Using the above assumptions and locations, emissions from land
uses can be derived for the eleven land use types listed earlier.
Presenting data for all these types would require a lot of space,
so only one example will be given.  It focuses on calculating SO
                                                                X
emissions for "single family residences" (1600 square feet in area)
having  three different energy supply combinations:  all gas, all
electric, and part oil and part electric.*  The results are presented
in Table 4.
     Both "Direct" and "Indirect" emissions are given in Table 1.
Direct emissions are those at the residence itself, while indirect
emissions are those at the power plant supplying electricity to the
house.  Indirect emissions are further divided into emissions from
oil  burning power plants (Oil) and coal burning power plants (Coal).
Indirect emission factors are found in Table 2.
     Multiplying emission factors times the appropriate "measure"
results in an estimate of total yearly SO  emissions.  For the five
                                         A
*An all gas residence uses natural or synthetic gas for space heat-
ing and cooling,  hot water, and cooking.  The last two uses are con-
sidered to be  "processes," resulting in process  emissions.  See the
emission factors  tables.   (All other process emissions are called
miscellaneous  emissions, and these are utility plant emissions ass-
ociated with the  residence's demand for electrical energy to run
appliances, lights, etc.)  An all electric house uses electrical
energy for space  heating and cooling, cooking, hot water, and pro-
cesses.  Emissions from an all electric residence are all indirect.
A part oil-part electric residence uses #2 fuel oil for space
heating and electricity for everything else.
                               23-16

-------
                                              TABLE 4

                            SOX EMISSIONS FROM SINGLE FAMILY RESIDENCES
                   (Pounds of Sulfur Oxide Emissions Per Dwelling Unit Per Measure)
                 All Gas
All Electric
Part Oil/Part Electric
Measure
Space Heating
Direct
Indirect:

Oil
Coal
.00002
—
—
.04788
.11628
.016
*• »
Heating Degree Day
Heating Degree Day
Heating Degree Day
Space Cooling
Direct
Indirect:
Process
Di rect
Indirect:

Oil
Coal

Oil
Coal
.00001
—
.41
99.54
241.74
__
,05922
.14382
—
320.04
777.24
—
.05922
.14382
«» w
320.04
777. 24
Compressor Operating Hours
Compressor Operating Hours
Compressor Operating Hours
Yea-r
Year
Year
Note:  Total Yearly Emissions = (Space Heating Emissions)(Heating Degree Day)  + (Space Cooling Emissions)x
                                (Compressor Operating Hours)  + (Process Emissions)(Year).

-------
cities previously chosen, estimated total direct yearly SOY emissions
                                                         f\


for a single family residence are presented in Table 5.  Also given



in the Table is the number of dwelling units needed before a 50 ton



new source review is triggered; the number should be doubled for a



100 ton new source review.



     If both direct and indirect emissions of a residence are con-



sidered, then the New Source Review triggering point reduces dramat-



ically, as shown in Table 6.  The seemingly anomolous results in the



Table, where SO  emissions for a single family residence are higher
               A


in warm areas than in (moderately) cold ones, is due to the very



high indirect emissions rates caused by operating air conditioner



compressors.  Because this rate is 2.5 times higher for coal fired



power plants than oil fired plants, a high number of compressor hours



(such as in Miami and Atlanta) causes some changes in emissions



ranking among areas depending on type of fuel burned in the plant.



     It should be reemphasized that the emission estimated are for



uncontrolled emissions.   Because most power plants control SO
                                                             /\


emissions  to some extent, the emission estimates and triggering



level of New Source Review have to be changed to reflect the amount



of  emissions control realized in an area.



SUMMARY &  CONCLUSIONS



     Land  use based emission factors were presented for single



family residences  (area  sources).  The factors were applied to a



problem associated with  EPA's evolving New Source Review policy,
                               23-18

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                             TABLE 5


   ESTIMATED DIRECT TOTAL YEARLY SOX EMISSIONS FOR A SINGLE FAMILY

           RESIDENCE IN FIVE CITIES AROUND THE COUNTRY
     City

Atlanta
  All Gas
  All Electric
  Part Oil, Electric

Bismarck
  All Gas
  All Electric
  Part Oil, Electric

Boston
  All Gas
  All Electric
  Part Oil, Electric

Miami
  All Gas
  All Electric
  Part Oil, Electric

San Francisco
  All Gas
  All Electric
  Part Oil, Electric
 SOX Emissions
(Pounds Year"1)
     0.49

    48.00


     0.59

   144.00


     0.53

    96.00


     0.44

     1.60


     0.47

    48.00
    Number of DUs
Needed Before a 50 Ton
NS Review is Triggered
     204,081
       N.A.
       2,083
     169,491
       N.A.
         694
     188,679
       N.A.
      62,500
     227,272
       N.A.
      62,500
     212,765
       N.A.
       2,083
N.A. = New Source review is not applicable (an infinite trigger).

DUs = Dwelling Units.
                               23-19

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                            TABLE 6

          ESTIMATED DIRECT AND INDIRECT TOTAL YEARLY SQy
       EMISSIONS FOR A SINGLE FAMILY RESIDENCE USING OIL HEAT
               IN FIVE CITIES AROUND THE COUNTRY
City
 SOX Emissions
(Pounds Year "1)
     Number of DUs
Needed Before a 50 Ton
NA Review is Required
Atlanta
  Oil PP
  Coal PP

Bismarck
  Oil PP
  Coal PP

Boston
  Oil PP
  Coal PP

Miami
  Oil PP
  Coal PP

San  Francisco
  Oil PP
  Coal PP
       462.79
     1,055.35
       439.73
       930.77
       469.69
     1,138.39
       373.96
       839.62
        216
         94
                                  207
                                  103
        227
        107
        212
         87
        267
        119
Note:  PP  stands  for power plant.
       DUs =  Dwelling  Units
       Total  Yearly Direct and  Indirect  Emissions =  Direct  Emissions
       + Indirect Emissions +  (Compressor  Operating  Hours)  (Indirect
       Space  Cooling Emission  Factor).
                                23-20

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and were found to be both tedious and easy to use in practice.
The tedium conies from the numerous steps involved in computing
emissions for a particular location for particular assumptions.
There may be a way to simplify the process some, but it is felt that
combining components or otherwise reducing the steps may result
in too large  an error in estimate.  The amount of labor involved
in using land use emission factors is still less than that needed
to develop a typical area source emission inventory.  Also, the units
and organization of the factors are familiar to urban planners,
which means that they probably will use the factors more readily
than, say, fuel use factors.
     While the factors have not been compared to other emissions
estimating procedures, the extensive use of disaggregated engineering
estimates and actual samples of energy consumption gives the authors
a lot of confidence in the factors.  However, it is recognized that
a validation of land use based emission factors is in order.
     The application of land use based emission factors to a new
source review illustrate their convenience and applicability with
project level data — especially with planned projects whose charac-
teristics are still vague.  They are also expected to be useful in
reviewing community or municipal scale plans and programs — situa-
tions where convential emission inventory techniques are .awkward
or impractical to use.
     The land use based emission factors presented in this paper have
                             23-21

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been applied successfully in the following situations.

     o To estimate the stationary source CO emissions in an indirect
       source air quality evaluation.

     o To estimate the sulfur oxide and particulate emissions from
       development in the corridor associated with a relocated major
       urban arterial highway.

     o To evaluate energy consumption associated with several alter-
       nate plans for a two city block urban renewal project.

     o To estimate residential emissions in an environmental impact
       statement for a residential development.
                                23-22

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                           REFERENCES

1.  Office of Air Quality Planning and Standards.  Guidelines for Air
    Quality Maintenance Planning and Analysis.  Research Triangle Park,
    North Carolina:  Environmental Protection Agency.   Volume 7:
    Projecting County Emissions (1975), EPA-450/4-74-008; Volume 13:
    Allocating Projected Emissions to Sub-County Areas (1974), EPA-450/
    4-74-014; "Accounting for New Source Performance Standards in
    Projecting and Allocating Emissions—Hypothetical  Example" (1975),
    a supplement to Volume 13; and Volume 13: Appendices A and B (1975);
    EPA-450/4-74-014a.

2.  Richard R. Cirillo and Michael J. Senew.  Development of Computer-
    ized Emmissions Projection and Allocation System—Phase I:  Prelim-
    inary Feasibility Study.   Research Triangle Park,  North Carolina:
    Environmental Protection  Agency, (EPA-450/3-77-001).

3.  Peter C. Cosier, IV.  "Land Use Based Emission Stretegies: Their
    Promise and Problems", Planning Comment (November  1976) 12:31-48.

4.  A. S. Kennedy, et al.  Air Pollution Land Use  Planning Project;
    Volume II:  Methods for Predicting Air Pollution Concentrations
    from Land Use.  Research  Triangle Park, North  Carolina:  Environ-
    mental Protection Agency, 1973. (EPA-450/3-74-028b)

5.  John C. Goodrich.  Hackensack Meadow!ands Air  Pollution Study-
    Emission Projection Methodology.  Research  Triangle  Park, North
    Carolina:  Environmental  Protection Agency, 1973.  (EPA-450/3-74-
    56b)

6.  Bill Swindaman.  "Notes on Land Use Based Emission Factors",
    Unpublished paper available at the Land Use Planning Office,
    Strategies and Air Standards Division, U.S. Environmental Pro-
    tection Agency, June 1972.

7.  Thomas E. Baldwin and Allen S. Kennedy.  "The  Feasibility of
    Predicting Point Source Emissions Using Industrial  Land Use
    Variables:  A Path Analysis", presented at  the 67th  Annual Meet-
    ing of the Air Pollution  Control Association,  1974.  (APCA paper
    #74-145)

8.  John C. Goodrich and Byron H. Willis.   "A Methodology for Deter-
    mining Emissions from Land Use Planning Data", presented at the
    65th Annual Meeting of the Air Pollution  Control Association,  1972.
   CAPCA paper #72-122)
                               23-23

-------
 9.   Frank Benesh.   Growth Effects of Major Land  Use Projects;  Volume
     II—Compilation of Land Use Based Emission Factors.   Research
     Triangle Park, North Carolina:  Environmental  Protection Agency,
     1976.  (EPA-450/3-76-012b)

10.   J. Ross McKeever (ed.).  The Community Builders Handbook.  Washing-
     ton, D.C.:  Urban Land Institute, 1968.

11.   Office of Air Quality Planning and Standards.   Compilation of Air
     Pollutant Emission Factors.  2nd Edition.  Research  Triangle Park,
     North Carolina:  U.S. Environmental  Protection Agency, April 1973,
     and supplements.  (AP-42)

12.   See, for example, the Keystone Coal  Industry Manual.  New  York:
     Mining Information Services of McGraw Hill,  1969.

13.   James Couillard.  Browns Directory of North  American Gas Companies,
     Duluth, Minnesota:  Harcourt Brach Jovanovich, 1973.

14.   Arthur D. Little, Inc.  Project Independence Blueprint:  Volume I.
     Washington, D.C.:  Federal  Energy Administration,  1974.

15.   Marketing Division.  Residential Appliance Gas Consumption, Phase
     4^  Lincoln, Nebraska:  Northern Natural  Gas Company, 1973.

16.   R. Anderson.  Residential Energy Consumption:   Single Family
     Housing Final Report.  Washington, D.C.:  U.S. Department  of
     Housing and Urban Development, 1973.

17.   American Gas Association.  Gas House Heating Survey  (Annual).
     Arlington, Virginia:  American Gas Association, various years.

18.   American Gas Association.  Info Data Sheet:  Use of  Gas by Resi-
     dential Appliances.   Arlington, Virginia:   American Gas Associ-
     ation, 1971.

19.   Hittman Associates.  Residential Energy Consumption—Multifamily
     Housing.  Washington, D.C.:  U.S. Department of Housing and Urban
     Development, 1974.

20.  Electric Heating Association.  EHA Case History. New York: Elec-
     tric Heating Association, various cases.

21.   Gordian Associates.  Environmental Impact of Electric vs.  Fossil
     Fuel Space Heating for the Welfare Island Development Project.
     New York:  New York State Urban Development  Corporati-on,  1972.
                               23-24

-------
22. H. Hansteen and J.  Kirkwama.   "The Fossil  Electric Ratio",  paper
    presented at the Annual  Meeting for the American Society of
    Mechanical Engineers,  1968.   (ASME paper #68-WA/PEM-3)

23. American Society of Heating,  Refrigerating,  and Air Conditioning
    Engineers.  ASHRAE  Heating.  Ventilating, and Air Conditioning
    Guide.  New York:  ASHRAE,  1958.

24. Building Owners and Managers  Association International.   1975
    Office Building Experience  Exchange Report for  the Calendar Year
    1974.  Chicago: BOMA,  1975.

25. National Coal  Association.  Steam Electric Plant Factors.   Wash-
    ington, D.C.:  NCA,  1973.

26. Edison Electric Institute.  Statistical  Yearbook of the  Electric
    Utility Industry, New  York:   EEI, 1972.

27. Kenneth A. Hagg, et al.   "Maintenance  Planning  in Massachusetts:
    Use of Land Cover Factors for Apportionment  and Projection  of
    Areas Source Emissions",  paper presented at  the 68th Annual  Meet-
    ing of the Air Pollution  Control  Association, 1975.  (APCA  paper
    #75-22.8).

28. 41 Federal Register 246:  55558 (December  21, 1976). The notice
    is entitled "Review of New Sources and Nodifications" and is part
    of 40 CFR 51.

29. 41 Federal Register 246;  55524 (December  21, 1976). The notice
    is entitled "Air Quality  Standards:  Interpretative Ruling"  and is
    related to 40  CFR 51.

30. Evaluation and Planning Division, California Air Resources
    Board.  The Land Use/Oxidant  Precursors  Emissions Study( DRAFT).
    Sacramento, CA.: A.R.B.,  1976.
                               23-25

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QUESTION:
MC CURDY:
CONDENSED DISCUSSION
 On these housing developments£ what new source
 review are you looking at  from a standpoint
 that a new housing development will bring in
 new cars and put out new hydrocarbons and
 whether they  should be subject to the new
 source review?
 That's an interesting question because under
 indirect source review you were supposed to
 have done that; but indirect source review
 as you probably know is dead for all types
 of land use except for highways and airports.
 This growth effects the major land use projects.
 It's specific aim was to develop a procedure
 where we can estimate the amount of secon-
 dary development caused by the construction
 and operation of major land use types.  The
 first two types  we looked at  were residential
 development and industrial parks.  You put in
 an industrial park and what happens to the
 urban structure around it?  What happens to
 VMT, etc.?  We have a simple predictive
 methodology which is based on multiple re-
                                        2
 gression again, and we are quite high r  's.
                               23-26

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                       2
I was appalled at the r 's that were mention-
ed  earlier.  Our's are .75 - .54.  At any
rate our office is looking Into that.  Right
now we have a project to do exactly the same
thing for sewage treatment plants.  If you
put in a sewage treatment plant, what is
going to happen next?  We are developing
easy to use procedures so that if you knew
what size treatment plant you had or what
size inceptor you had, we could estimate
the amount residential development induced
by and associated with this major project.
I don't think EPA is going to have a policy
saying that you have to do this for all
development types.
        23-27

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        EMISSION RATES FOR BIOGENIC NO
                                      A
             Presented at the 1977
        Environmental Protection Agency
      Emission Inventory/Factor Workshop
Raleigh, North Carolina - September 13-15, 1977
                      By

     Hilman C. Ratsch and David T. Tingey
          Terrestrial Ecology Branch
  Corvallis Environmental Research Laboratory
     U. S. Environmental Protection Agency
           Corvallis, Oregon  97330
                      24-1

-------
Abstract



     A literature  review of biogenic sources of NO  was conducted to
                                                   A


determine their  emission rates into the atmosphere.  NO  are some of
                                                        X


the products  of  microbial denitrification, chemical decomposition of



nitrites  and  the  oxidation  of  organic  nitrogen  compounds.   There



appears  to  be no  significant emission of NO   from either oceans or
                                             A


freshwaters.  Biogenic  emission  rates  for NO and N02 from soil range



from  0.015  to 0.02 kg  NO km-2 hr-1 and 0.01 to 0.2 kg N02 km-2 hr-1.



Submerged soils, sediments, marshes and swamps could be sources of NO



but emission  data  are not available.  There is no  significant evidence



of NO  emission from living vegetation.  During  decay, decomposition
      A


and ensiling  of  vegetation, NO  can be  formed.  Although the emission
                               a


rates are not known, they are probably not significant.



      The estimates of NO  emission rates from the above biogenic (soil)



sources were  computed for a global basis and then compared closely to



previously  estimated natural global emissions.  Also, the background



atmospheric  concentrations   of   NO  are  similar  to  those  levels



predicted from biogenic emission rates.
                                 24-2

-------
Introduction



     Several  authors  have Estimated  global biogenic  NO  emissions.
                                                         A-


Robinson and Robbins (1970) estimated global natural emissions of NO
                                                                    A


at 768 x 109 kg N02 which was approximately 15 times the anthropogenic



emissions  (53 x  109  kg N02).  McConnell  (1973) suggested  that the



natural  sources  of NO   were  4  times  the  anthropogenic  sources.
                       A


Galbally  (1975)  estimated  biogenic NO   emissions  for  the  northern
                                       A


hemisphere at  1  x 109 kg N02 yr-1 and the anthropogenic emissions at



0.5 x  lo9  kg N02 yr-1.  Estimates of biogenic  emissions  for NO  for
                                                                A


Ohio and surrounding states, ranged from 1.7 to 4.1 x 108 kg N02 yr-1



and the  anthropogenic  emissions  ranged  from 2.5 to 33.3 x 10s kg N02



yr-1  (RTI,  1974).   These  calculated  NO  emissions  were  based  on



atmospheric  concentrations  and   a  theoretical  balance  of  nitrogen



compounds.  At present there  is  no general agreement on the relative



contributions  of  the biogenic   and  anthropogenic  emissions.   Most



biogenic emission rates were derived from the amounts of NO   needed to
                                                          A


balance nitrogen cycles or were deduced theoretically.



     The  objectives of this literature review  were  to gather infor-



mation  on possible biogenic sources of  NO ,   to determine  biogenic
                                            A


emission rates and to  discuss the factors affecting NO  emissions.  The
                                                     A


nitrogen  cycle is discussed to suggest possible biogenic sources of
                                24-3

-------
nitrogen oxides.  The biogenic  sources  and emission rates of NO  are




divided  into   the   following  categories:   1)  water:   ocean  and




freshwaters; 2) soil; 3) flooded soil, sediments, swamp and marsh; and




4)  vegetation.   The biogenic  emission  rates  determined   from  the




literature were compared to other emission estimates and atmospheric




concentrations.
                                  24-4

-------
 Nitrogen Cycle




      Nitrogen is found in five major sinks in the biosphere:   primary




 rocks,  sedimentary rocks, the  deep-sea  sediment,  the  atmosphere,  and




 the soil-water pool.   Approximately 98%  of the earth's nitrogen is in




 primary and sedimentary rocks,  while the atmosphere contains about 2%;




 the deep-sea sediment  and soil-water pool  together contain less than a




 percent of  the global nitrogen (Burns and Hardy, 1975).




      In the  atmosphere,  N2  is  the major nitrogen constituent  while




 nitrogen oxides  (N20,  NO,  N02), NOs, N02,  NHg,  and NH4 are  present in




 the ppm range or less.   The soil-water pool can contain a large amount




 of dissolved N2.  N20, NO, and N02 can  also  occur in  soils for short




 time periods under specific environmental conditions.




      A  simplified nitrogen cycle showing  nitrogen transformations in




 the soil-water pool  and transfers between  the soil-water pool  and  the




.atmosphere  is shown in Figure 1. Nitrogen enters  the  soil-water pool




 through biological nitrogen  fixation,  industrial fixation, precipi-




 tation  and application of fertilizers.   Biological fixation reactions




 occur  either  in  free-living  organisms  (i.e.  Azotobacter)   or  in




 symbiotic  plant-microbial associations  (i.e. Rhizobium) .   Plants  and




 microorganisms utilize NH4, NOs, and N02 from the  soil-water pool  and
 nitrogen undergoes  a  multitude  of  chemical and  biological  trans-



 formations.
                                 24-5

-------
                             NH,
               Precipitation
                  (105)
Biological
Nitrogen
Fixation ,
 (135)  I Industrial
         Fixation
           (30)
                          NO;  NO;
                     Fertilizer*
                        (40)
       Soil Organic
       Material
                                                                N,
                                                        Outgasslng)
  Volatili-
   zation
   (130)
 N20

   NO

Denitrlfication
    (140)

 NO  N02

      NH,
                Combustion
                   (20)
                                      N02

                                  Nitrification
 Leaching
^ (15)
          Fig 1.     Terrestrial  nitrogen  cycle
                    transfer and transformations.
showing.  nitrogen
 Values  given are
                    metric  tons  (N)  x  106 yr-1  (Burns  and Hardy,
                    1975; Hardy and Havelka, 1975).
                                     24-6

-------
     In  nitrification (Figure  1), an  aerobic process,  ammonium is




oxidized to nitrate.
Oxidation  occurs  mainly  by the autotrophic  bacteria of  the Nitro-




bacteriacea.  The genus Nitrosomonas oxidizes ammonium to nitrite and




the  genus  Nitrobacter oxidizes  nitrite to  nitrate.  Other micro-




organisms , including certain bacteria , molds and fungi , are capable of




limited oxidation of nitrogen, but their contribution to nitrification




is  limited.   The  rapid  nitrification  of  ammonium  is  important




agriculturally, since  fertilizer  ammonium can be rapidly oxidized to




nitrate and then  lost  from the soil by denitrification,  leaching and




chemical decomposition  (Hauck,  1971).




     In denitrification  (Figure 1), an anaerobic  metabolic  process,




nitrate is reduced sequentially to NO, N20 or N£.




                     NOg -> N02 -»• NO -* N20, N2




The reduction is carried out by a diverse group of bacteria but the non




spore formers such as Pseudomonoas , Micrococcus,  and Achromobacter and




spore-forming species of Bacillus are the principal  denitrifiers.
                                 24-7

-------
Biogenic Sources of^ Nitrogen Oxides




Water




     Oceans—




     The  nitrogen cycle  in the oceans is  complex  in respect to the




large   geographical  translocations   of   nitrogen   and  in  species




composition   of   micro-   and   macro-organisms   (Dudgale,   1969).




Theoretical models  of nitrogen  circulation in oceans and mass balances




for marine nitrogen cycles  indicate that inorganic nitrogen is removed




or   lost  from  the   oceans  (Yoshinari,   1976;   Dugdale,   1969).




Denitrification is  a  significant factor in  loss  of  nitrogen from the




marine  environment, especially  in  oxygen-deficient  waters.  Goering




and  Cline  (1970)  determined that  denitrification  in  raw seawater




occurred  in  two  stages.  First,  nitrate was reduced to nitrite, and




second, the nitrite was further reduced, presumably to N£.  Nitrate15-N




added to  water  samples  from the oxygen-deficient layer in the tropical




Pacific  resulted  in the production  of  nitrite and N£- Denitrification




rates varied  from 7-150 |Jg  N/l/day  depending on sample depth (Goering,




1968).  Estimated denitrification losses in oxygen-deficient waters  of




the Black Sea (7  x 109 - 2 x 1011 g N yr-1)  and Cariaco Trench (1 x 1010




g  N  yr-1) were  not  significant compared  to   those in the eastern




tropical  North  Pacific  (1 x  1013 g N yr-1) (Goering et al., 1973).




      Patriquin  and  Knowles  (1974) examined shallow-water  marine  sedi-




ments  from several locations  for denitrifiers  and  found  that most  of




the  bacteria  that  reduced  nitrate  to  nitrite also  reduced  nitrite  to
                                 24-8

-------
gaseous nitrogen.  Bacterial isolates varied considerably in the rate



of  N£  production  and N£0  reduction,  and in  accumulation of ^0.



Barbaree  and  Payne   (1967)  demonstrated  that  N20  and very  small



quantities  of  NO  were present  transiently  in the  atmosphere over




reaction  mixtures  containing   cell-free   extracts  of  Pseudomonas



perfectomarinus cells.



     The above data support the conclusion that denitrification is an



active process in the oceans and that both N£ and ^0  are products but



there is no  evidence of NO  production in oceans.








     Freshwater—



     As in the oceans, denitrification in freshwaters  is a significant



factor in nitrogen loss.  The nitrogen cycle and the fate of nitrogen



in  freshwaters  has been  reviewed  recently  (Keeney,  1973;  Brezonik,




1973).



     In  lakes,  denitrification occurs mainly in the  oxygen depleted



hypolimnic  layers  where inorganic nitrogen levels are  at  a minimum



(Vollenweider, 1968).   Denitrification rates in Smith  Lake, Alaska, in



water  one  meter below  the  ice were  measured at  15  (Jg N/liter/day.



Molecular nitrogen appeared to be the only significant product and NO



and N20 were not detected (Goering and Dugdale,  1966).  Brezonik (1973)



concluded that  denitrification did  not appear to  be significant in




Florida lakes.  Of the 55  north central lakes sampled  in Florida, only



four  developed  anoxic conditions  at  the  bottom and  the  nitrate
                                 24-9

-------
concentrations  in  Florida lakes are typically  low.   Nitrogen is the




only product of denitrification released in significant quantity, and




seldom is NO or N20 detected (Payne, 1973).




     In  addition  to  denitrification,  there  is  the possibility  of




chemical  decomposition  of nitrite  to  produce  gaseous nitrogen prod-




ucts.   In  some  lakes,  concentrations of  polyphenolic  substances




(tannins,  lignins,  humic acid)  are high and pH  of  water is acidic.




Under these conditions the reaction of nitrous acid with organics could




be important as a source of nitrogen oxides  (Brezonik,  1973).








Soil




     The  soil is  an  open system  from which various nitrogen forms




volatilize  into the atmosphere.  As early as 1944, it was discovered




that nitrous oxide was one of  the constituents of soil air  (Kriegel,




1944).  Adel (1946, 1951) suggested that N20 was  produced in the soil




and  was the  source of  atmospheric N20. Arnold  (1954) confirmed N20




losses  from the soil  and  Wijler and Delwiche (1954) found that N20 was




the  major  initial  product   of   denitrification  under  some  soil




conditions,  but also  identified NO as an additional product.  More




recently,  in addition  to losses  from  denitrification, investigators




have found that NO and  N02 are  produced by chemical reactions in soil




involving HN02  and  nitrite.   (Reuss and  Smith,  1965;  Nelson and




Bremner,  1970; Bollag, etal., 1973).
                                 24-10

-------
     Denitrification—



     The  terra  "denitrification" implies the gaseous loss of nitrogen



 to  the  atmosphere,  usually as N2, N20 or NO, through some biological



 agency  and  it  is  the  subject of  two  recent reviews  (Payne,  1973;



 Delwiche  and Bryan,  1976).   In the absence of oxygen, microorganisms



 use  nitrate  or  its  reduction products as electron  acceptors  for the



 oxidation of some organic compound as an energy-yielding reaction.  The



 intermediates and  products of  denitrification  have been  studied ia



 cultures and in soil experiments, but the pathways are varied and not



 presently elucidated.  One possible pathway is as follows:



                      NOs -» N02 -» NO •» N20 •» N



     Many genera of bacteria are able to reduce nitrate to nitrite and



 of those a limited number are able to further reduce nitrite to N20 or



 N2.  Studies have determined that NO is a specific product of nitrite



 reduction; nitrous  oxide  (N20)  results  from NO reduction and is  the



 terminal denitrification product of several  bacterial  strains (Renner
                                                                    «


 and Becker, 1970; Payne, Riley and Cox, 1971).



     Factors Affecting Denitrification.  Denitrification is influenced



by factors such as soil oxygen concentration,  redox potential, pH, soil



 organic matter content  and  temperature.   In general,  conditions that



directly  or  indirectly  decrease the soil oxygen content or  increase



microbial activity  increase denitrification.  When  soil  oxygen  level



decreased from 8.5% to 1%,  N20 production increased, but as the oxygen



level  decreased  to  zero  the  N20  was reduced   to  N2  (Cady  and
                               24-11

-------
Bartholomew, 1961).  Although it was not measured, a similar response




would be  expected  for NO.  In a closed soil-plant system (Stefanson,




1972) N2 was the major component of denitrification but in the absence




of plants the main product was N20.  Over the temperature range of 15




to  35°C,  increasing  the  temperature  10°C  doubled  the  rate  of




denitrification  (Stanford et al., 1975).  Bailey (1976) reported that




as soil temperature increased the rate of N2 production increased and




NO  production decreased.  Denitrification  capacities of  17  surface




soils were significantly  correlated with total organic carbon content




and  very  highly  correlated  with  water-soluble  organic   carbon  or




mineralizable  carbon  (Burford and  Bremner,  1975).  Nitric oxide was




detected  in  the  atmosphere  of several soils  incubated at  20°C for 7




days, but the amount  represented  not more than 0.1% of the  nitrate




lost.  As the soil pH increased from 5 to above 7,  the ratio of N20 to
                             ••*.•



N2  decreased (Burford and Bremner,  1975); below pH 7.0, N20  was the




main product (Wijler and Delwiche, 1954).  The pH dependency of NO

                                                            Ju

production should be similar to N20.  In general, low  temperature, low




pH,  and  marginal  anaerobic  conditions  favor the production  of N20




relative to N2 (CAST,  1976).








     Chemodenitrification or Nonbiological Chemical Decomposition—




     In  addition  to  microbial  denitrification there  is  increasing




evidence  that  non  biological  reactions  produce nitrogen  gas  or




nitrogen  oxides  under some circumstances  (Delwiche and  Bryan, 1976;
                                24-12

-------
Porter, 1971).  Non biological loss of nitrogen may result from "side-

tracking"  during nitrification and  denitrification processes.  This

can  occur  when an intermediate in the process  (i.e. N02)  is produced

more  rapidly  than  it  can be  oxidized  or reduced  biologically and

undergoes  chemical decomposition (Lance, 1972).  There are several non

biological reactions that could  release NO into the  atmosphere.

     Nitrosation denotes the addition of the nitroso group (-N =  0) to

an organic molecule, and is brought about by HN02 and other compounds

to form an organic complex (0 = N = X).   The nitroso groups formed are

labile and  react further with the nitrosating  agent  to  form gaseous

products.

                      HN02  •* NO- + OH

                      NO-+R-»N = 0-R

                      N + 0 - R +"A -> NO +  A - R

Stevenson, et al. (1970) showed evidence that  NO, N20,  and N2 could be

produced  by  nitrosation   of  humic  and  fulvic  acids, lignins,  and
                                                              *
aromatic substances at pH 6.0 and 7.0 in the absence of oxygen.  Steen

and Stojanovic (1971) found that NO was  volatilized from a calcareous

soil when  high concentrations  of  urea were nitrified with concurrent

accumulation of  nitrite  and  assumed that nitrosation between nitrous

acid and organic  matter was the main pathway by which NO was formed.
                                                             i
     Wullstein and Gilmour (1964,  1966)  reported that nitrite reacted

with certain  reduced transition metals  in sterile,  moderately  acid

systems to yield  NO as a primary gaseous product.  In their proposed
                                24-13

-------
scheme, N02 and NO reacted with metallic ions to form complexes which



were either stable or  reactive.  The metals could also react directly



with N02 or NO without  forming complexes or intermediates to form NO or



N2.  They concluded  that copper and manganese ions  in  the soil were



primarily  responsible  in reacting  with  nitrite.   Nelson and Bremner



(1970)  found  that Cu+, Sn2+ and Fe2* were  the  only metallic cations



that promoted nitrite decomposition  and that soils normally do not



contain sufficient amounts of these cations under conditions suitable



for chemodenitrification to be significant in nitrite decomposition.



     Reuss  and Smith  (1965) showed  that  N2 and  N20 are  formed by



chemical decomposition of nitrite in soil and also showed that N©2 was



evolved when nitrite  was  added to acid soils.  Bremner  and Nelson



(1968)  found  that N2 and N02 and small amounts of N20 were formed when



nitrite was added to neutral"and acid soils.  They suggested that the



reactions between soil organic constituents and nitrite were respon-



sible for the formation of N2 and N20, while self-decomposition of HN02
                                                            *


was  responsible  for the formation of  NO and  N02-  In the steam-



sterilized  raw  humus   samples  incubated  with  nitrite,  NO  was  the



predominant  gaseous  reaction  product   (Nommick  and Thorin,  1971).



Nelson  and   Bremner   (1970)  found that  the  formation  of N02  by



decomposition of nitrite in pH 5.0 solution was not promoted by organic
                                                            )

and  inorganic soil constituents,  and concluded that most of the N02



evolved was  formed by self-decomposition of HN02-   The amount of N02



formed  was  inversely related to soil pH, but pH had little effect on
                                 24-14

-------
the amount of nitrite  converted to nitrate.  These findings led to the


conclusion  that  the  self-decomposition  reaction  of HN02  was best


represented by the equation:


                       2HN02 -> NO + N02 + H20


     Measurements of NO and N02 emissions from soil and biological and


non  biological   reactions  are  difficult  and  only  limited  data are


available  (Table 1).   Soil emission rates were determined by directly


trapping  liberated  gases  at the soil  surface.  Based on the limited


number of studies, NO  is produced at lower rates (0.004 to 0.02 kg NO


km-2 hr-1) than  N02 (0.01 to 0.2 kg N02 km-2 hr-1).  These rates are


temperature  dependent  and would  be  expected  to  increase  as  the


temperature increases (Bailey, 1976).




Flooded Soil,  Sediments, Swamp and Marsh


     Flooded  soil  or sediments  have characteristics  that  are unique


and separate them from  arable soil, such as the interruption of gaseous


exchange  between air  and soil  (Patrick  and dikkelsen,  1971).  The


restriction of oxygen diffusion  results in an oxidized layer of up to


one cm. in the  soil-water interface,  but below this layer the oxygen


content declines rapidly.  A second characteristic of flooded  soil is a
                                                                )

change .in microbial   forms  from  aerobic  to  facultative  anaerobic


organisms  to  anaerobic bacteria.  Retarded  metabolic processes  are


reflected  in  reduced  organic  matter  decomposition  and  a  lowered


nitrogen  requirement  for  decomposition.  In terms  of physiochemical
                                24-15

-------
changes, the pH  of flooded soils tends to  change  toward  neutrality,


redox potentials  are low  (-300  mv)  and there is an  increase  in the


amount of ions  in the soil solution (Ponnamperuma, 1972).


     In   submerged  soil,   inorganic   nitrogen  is   present   almost


exclusively  as  NH4  because  the  lack   of  oxygen  prevents   the


nitrification  of NH4 to N03.   However, the NOs formed in the  aerobic


layer  at  the  sediment-water  interface   diffuses  downward  to  the


anaerobic   layer  where   denitrification  occurs.   As  in   soils,


denitrification (biological and non-biological) is  the major source of


nitrogen  oxides  from flooded  soils,  sediments,  swamps  and marshes.

                        ^
Oxygen content, pH,  redox potential, temperature, nitrate content and


organic matter content of submerged soils are factors that affect the


amount and products of denitrification.


     Denitrification  as measured  by  nitrate  and nitrite  reduction


rates and Nj formation is significant in submerged soil and sediments


(Chen, Keeney, Konrad, Holding, Graetz, 1972; Chen, Keeney, Graetz and


Holding,  1972; Reddy and Patrick,  1975;  Engler and  Patrick,  1974;


Goering and Dugdale,  1966).  The disappearance of nitrate in sediments


and submerged  soils  is usually accompanied by the production of KT2 but


recently  several  workers have  shown other denitrification products.


Lake  sediments incubated  with nitrate and nitrite produced  N20 in


addition  to N2  (Macgregor and  Keeney, 1973; Chen,  Keeney^  Konrad,


Holding,  Graetz,  1972).  In the decomposition of  nitrite in  flooded


soils, N£ was  produced at all pH's but NO and ^0 were produced only at
                                 24-16

-------
pH 6.0 and below (Van Cleemput, et al. 1976).  The addition of a soil



sterilant (HgCl2) increased the rate of NO production.  The important



conclusions   from   this  study  were  that   under  acid  conditions



significant amounts of N2, ^0 and NO were formed.  The production of



NO under  acid conditions with and without a  sterilant suggested the



self-decomposition  of  nitrous acid similar to what  occurs in arable



soils.  However,  the  data are  not adequate to  calculate emission



factors.







Vegetation



     Plant leaves and roots can absorb both reduced or oxidized forms



of nitrogen from the environment and a relatively large concentration



of nitrogen compounds are found in plants.  However, there is no direct



evidence  that any  of this nitrogen is emitted into the atmosphere as



NO .  In  contrast  during  decomposition  NO   can be  emitted into the
  A                                        A


atmosphere but its significance  is not  known.  During the ensiling



process high  concentrations of nitrogen oxides can be  emitted.  In an



unventilated  silo or enclosure, NO and N0£ can reach hazardous levels



and such levels have accounted for several fatalities (Commins, et al.,



1971; Scaletti, et al.,  1960). In decomposition of  plant products only



a  small  fraction   of  total  nitrogen  losses  from  the   system  are



attributed to denitrification.  In an eastern mature hardwood forest,



an  estimated  3.6%  of   the   total  nitrogen  flux   was lost  through



denitrification  processes   (Mitchell,   et  al.,  1975).   Estimated
                                24-17

-------
denitrification  rates of  0.17, 1.61  and 0.08  kg  N ha-1  yr-1 were



measured for branches, logs and litter (H layer), respectively  (Todd,



et  al.,  1975).  It  is  conceivable that  under some conditions small



amounts  of nitrogen  oxides are emitted  during litter decomposition.



However, data on the  emission rates from decomposition are  lacking.







Estimates of Global NO Emission



     The  source of  NO   in the atmosphere  is both anthropogenic and
                      A


biogenic.  Estimates of anthropogenic  emissions of  NO   on a  global
                                                       A


basis  are in  good agreement as shown  in Table 2.   But the biogenic



emissions  are  varied and are much more difficult to  identify, measure,



or estimate.



     The biological  and chemical transformations of  nitrogen compounds



in  the  soil  appear to be the major source of NO .  The estimates of NO
                                               X                    A
 emission rates  from soil  (Table 1) range from 0.01 - 0.2 kg N k



 This  rate computed  on a global  scale  gives  an emission  from 3 to 58 x



 109   kg  N  yr-1 and  compares  closely to  the estimated  global NO
                                                                    A


 emissions by Galbally (1975) and Soderlund and Svensson (1976).



      The  background  concentrations  of   NO  and  N02  reported  by



 Rasmussen,  et  al.  (1975)  is about 0.3 -  2.5 |Jg m-3  and  2 - 2.5 M8 m~3>



 respectively.   Soderlund   and  Svensson   (1976)  reported  background



 concentrations  of NO  to  range  from 0.5  -  7.5 M8 ffl3 (as ^2) depending
                     A


 on geographical location.  If it is assumed that background NO  is in a
                                                             A


 steady state condition,  then NO  deposition must be balanced by NO
                                 A                                  A
                                 24-18

-------
emission.  The total wet and dry deposition of NO  for the terrestrial



system was estimated  at 32 to 83 x 109 kg N yr-1 and for the aquatic



system at  11 to 33 x lo9  kg N yr-1  (Soderlund  and Svensson,  1976).



Peterson (1977) estimated that NO  is removed by wet and dry deposition
                                A


processes at about 0.04 kg N km^hr-1.  This value is similar to soil



NO   emission   rates  given  in  Table   1.   Therefore,  background
  A


concentrations of NO   can  be explained in large part by biogenic NO
                    X                                              X


emissions.
                                24-19

-------
                Table 1.  Nitrogen Oxide Flux From Soil
Soil or
Medium
   N      Type N
Addition  Oxide
           kg/km2/hr.      Reference
           Emission Rate
low humic           NH4 N03
Ordinary Chernozem  urea
Chernozem
Podzol
NH4 N03
100 Kg.
N/ha
top soil from pine, none
oak, sod stand
(sandy loam)
          NO
NO
          N02
           .015-.02
.006
.004
               Getmanets, 1972
Borisova, et al.,
1972
Sod- Podzolic
NH4 N03   N02
Sod - Podzolic
medium  clay  loam
urea      N02
240 Kg/ha
           pine 0.125
           oak  0.07
           sod 0.11

           0.01-0.2

           comment: vari-
           ation during
           the growing
           season

           0.03-0.05
               Kim,  1973
              Makarov,  1969
*  emission rate  calculated  as N02
               Makarov and
               Ignatova,  1964
raw humus
in spruce
stand
(feather
moss)
raw humus
(sphagnum
moss)
KN03 *(NO+N02)
NH4 N03
Ca (N03)2
Al (N03)3

NH4 N03 *(NO+N02)
Ca (N03)2
Al (N03)3
.018
.029
.035
.104

.012
.018
.035
Mahendrappa ,
1974



Mahendrappa ,
1974


                                  24-20

-------
             Table 2.  Estimates of Global NO  Emission
                                             A

Sources of NO (109
A.
Anthropogenic
16
18
15
19

kg N yr-1)
Biogenic
234
* 72
20
8-25
3-58
References

Robinson and Robbins, 1970
McConnell, 1973
Galbally, 1975
Soderlund and Svensson, 1976
estimated from data in Table 1.

* natural sources estimated at 4 or more times the anthropogenic
  sources.
                               24-21

-------
                           REFERENCES

Adel, A.  1946.  A possible  source of atmospheric N20.  SCIENCE 103,
     280.

Adel, A.   1951.   Atmospheric nitrous  oxide and  the  nitrogen cycle.
     SCIENCE 113, 624-625.

Arnold, P. W.  1954.   Losses  of nitrous oxide from soil.  J. SOIL SCI.
     5, 116-128.

Bailey,   L.   D.    1976.    Effects   of  temperature  and   root  on
     denitrification in a soil.  CAN. J. SOIL SCI.  56, 79-87.

Barbaree, J. M. and Payne, W. J.  1967-  Products of denitrification by
     a marine bacterium as revealed by gas chromotography.  MAR. BIOL.
     1, 136-139.

Bollag, J. M., Drzymala, S. and Kardos,  L. T.  1973. Biological versus
     chemical nitrite decomposition in soil.  SOIL SCI.  116, 44-50.

Borisova, N. N., Burtseva, S. N., Rodionov, V. N. and Kirpaneva, 0. L.
     1972.  Determination of  nitrogen losses from soil in the form of
     different oxides  and ammonia under field  conditions.  SOV. SOIL
     SCI. (4), 540-546.

Bremner,  J.  M.  and  Nelson,   D. W.   1968.   Chemical decomposition of
     nitrite in soils.  9th TRANS. INT. CONGR. SOIL SCI. 2, 495-503.

Brezonik, P. L.  1973.  Nitrogen sources and cycling in natural waters.
     EPA-660/3-73-002  Ecological Research Series,  U. S. Environmental
     Protection Agency,  p. 7-19.

Burford,  J.  R.  and  Bremner,  J.  M.  1975.   Relationships between the
     denitrification capacities of  soils and total, water-soluble and
     readily decomposable soil organic  matter.  SOIL BIOL. BIOCHEM. 7,
     389-394.

Burns, R. C. and Hardy, R. W. F.  1975.  Nitrogen fixation in bacteria
     and higher plants.  Springer - Verlag, New York, 189 pp.
                                 24-22

-------
Cady, F.  B.  and  Bartholomew,  W. V.  1961.  Influence  of  low p(>2 on
     denitrification processes and products.  SOIL SCI. SOC. AM PROC.
     25, 362-365.

CAST, 1976.  Effect of increased nitrogen  fixation on stratospheric
     ozone.  Rep.  53.  Iowa:   Council  for  Agricultural Science  and
     Technology, 33 pp.

Chen, R. I.,  Keeney, D. R., Konrad,  J. G., Holding, A. J., and Graetz,
     D.  H.  1972.   Gas production in sediments of Lake Mendota, Wise.
     J.  ENVIRON. QUAL.  1(2), 155-158.

Chen, R.  L., Keeney,  D. R., Graetz, D.  A.  and Holding, A. J.  1972.
     Denitrification   and  nitrate   reduction  in   Wisconsin  lake
     sediments. J.  ENVIRON. QUAL. 1(2), 158-162.

Commins, B. T., Raveney, F. J. and Jesson, M W.  1971.  Toxic gases in
     tower silos.  ANN. OCCUP. HYG. 14, 275-283.

Delwiche, C. C. and Bryan, B. A.  1976.  Denitrification.  ANN. REV.
     MICROBIOL. 30,  241-262.

Dugdale,  R.  C.   1969.  The  nitrogen cycle in the sea.  BIOLOGY AND
     ECOLOGY OF NITROGEN. Conf.  Proc. University  of California, Davis,
     NAS, Washington,  D.  C.  p. 16-18.

Engler,   R.  M.  and  Patrick,  W.  H.   1974.   Nitrate  removal  from
     floodwater overlying flooded soils  and  sediments.  J. ENVIRON.
     QUAL. 3(4), 409-413.

Galbally,  I.  E.   1975.   Emission  of oxides  of  nitrogen  (NO )  and
     ammonia from the  earth's surface.  TELLUS  27, 67-70.        X

Getmanets, A. Y.  1972.  Loss of mineral fertilizer nitrogen from soil
     in gaseous form.  SOVIET SOIL SCI. 4, 172-175.

Goering,  J. J., Richards, F. A., Godispoti, L. A.  and Dugdale, R. C.
     1973.  Fixation and denitrification in the ocean.  In E. Ingerson
     (Ed.) Proc.  Intern. Symp.  Hydrogeochim.   Biogeochem.   Vol.  II.
     Clarke,  Co, Washington,  D. C. pp 12-27.

Goering,  J. J.  1968.  Denitrification in the oxygen minimum layer of
     the eastern tropical Pacific ocean.  DEEP  SEA RES. 15, 157-164.

Goering,  J. J.  and  Cline, J. D.  1970.  A note on denitrification in
     seawater.   LIMNOL OCEANOGR.  15, 306-309.
                               24-23

-------
Goering, J. J.  and Dudgale, V. A.  1966.  Estimates of  the  rates of
     denitrification in a subarctic lake.  LIMNOL.  OCEANOGR.  11, 113-
     117.

Hardy, R. W. F. and Havelka, V. P.  1975.  Nitrogen fixation research:
     a key to world food?  SCIENCE L88,  633-643.

Hauck,  R.  D.    1971.    Quantitative   estimates  of  nitrogen-cycle
     processes.   Nitrogen-15  in soil  plant  studies,   (Int.  Atomic
     Energy Agency, Vienna)pp. 65-80.

Keeney, D. R.  1973.  The  nitrogen cycle in sediment-water systems.  J.
     ENVIRON. QUAL. 2(1),  15-29.

Kim, C. M.  1973.   Influence of  vegetation types  on the intensity of
     ammonia and nitrogen dioxide liberation from the soil.  SOIL BIOL.
     BIOCHEM. 5, 163-166.

Kriegel,  M.  W.  1944.  Analysis  for hydrocarbons  in the presence of
     nitrous oxide.  GEOPHYSICS 9, 447-462.

Lance,  J.  C.   1972.  Nitrogen removal by soil mechanisms.   J. WAT.
     POLLUT. CONT. FED.  44,  1352-1361.

Mahendrappa, M.  K.  1974.  Volatilization of oxides of nitrogen from
     nitrate-treated Black  Spruce raw humus.  SOIL SCI.  SOC. AM. PROC.
     38, 522-524.

Makarov,  B. N.   1969.    Liberation  of  nitrogen  dioxide  from soil.
     SOVIET SOIL SCI. 1, 20-25.

Makarov, B. N.  and Ignatova, V.  P.  1964.  Losses of nitrogen from the
     soil in the gaseous form.  SOVIET SOIL SCI.  (4),  407-413.

McConnell,  J.  C.   1973.  Atmospheric  ammonia.   J. GEOPHYS.  RES. 75,
     7812-7821.

Macgregor,  A.  N.  and Keeney, D. R.   1973.  Denitrification in  lake
     sediments. ENVIRONMENTAL LETTERS 5(3), 175-181.

Mitchell,  J.  E., Waide,  J.  B. and  Todd, R. L.  1975.   A preliminary
     compartment model of  the nitrogen  cycle  in a deciduous forest
     ecosystem.  Mineral  Cycling in S.  E. Ecosystems.  ERDA symposium
     series CONF-740513. p.  41-57-

Nelson,  D.  W.  and Bremner, J.  M.  1970.  Role of soil minerals and
     metallic      cations    in     nitrite     decomposition     and
     chemodenitrification in soils. SOIL. BIOL. BIOCHEM. 2, 1-8.
                                24-24

-------
Nelson, D. W.  and Bremner, J. M.  1970.  Gaseous products of nitrite
     decomposition in soils.  SOIL BIOL. BIOCHEM. 2,  203-215.

Nommick, H.  and Thorin,  J.   1971.   Transformation  of  N-15 labelled
     nitrite  and  nitrate  in  forest  raw  humus  during  anaerobic
     incubation.  Nitrogen-15  in soil plant  studies,   (Int.  Atomic
     Energy Agency,  Vienna) pp 369-381.

Patrick, W. H. and Mikkelsen,  D. S.  1971.  Plant nutrient behaviour in
     flooded soil.  In Rinauer,  R. C.  (Ed.), Fertilizer technology and
     use, Second Edition.  SOIL  SCI.  SOC.  of AMER. Madison, Wise. 187-
     215.

Patriquin, D. G. and Knowles,  R.  1974.  Denitrifying bacteria in some
     shallow-water marine  sediments,  enumeration and gas production.
     CAN. J.  MICROBIOL. 20(7), 1037-1041.

Payne, W. J.   1973.      Reduction    of    nitrogenous    oxides    by
     microorganisms.  BACTERIOL. REV. 37, 409-452.

Payne, W. J., and Riley, P. S. and Cox, C. D.  1971.  Separate nitrite,
     nitric   oxide,   and  nitrous   oxide  reducing  fraction   from
     Pseudomonas perfectomarinus.  J. BACTERIOL. 106, 356-361.

Peterson, E. W.  1977.  Wet and  dry deposition:   A synopsis containing
     estimates of deposition  velocities  for some pollutant and trace
     gases in the atmosphere.  EPA.  CERL-037.  Corvallis Environmental
     Research Laboratory, Oregon.

Ponnamperuma, F.  M.  1972.   The chemistry of submerged soils.  ADVAN.
     AGRON. 24, 65-71.

Porter,  L.  K.   1971.   Techniques  for  the  measurement  of  soil
     nitrogenous  pollutants.   Int.   symposium on identification  and
     measurement of environmental pollutants, Ottawa, Ontario, Canada.
     pp. 84-91.

Rasmussen, K. H., Taheri, M. and Kabel, R. L.   1975.  Global emissions
     and natural processes for removal of gaseous pollutants.  WATER,
     AIR and SOIL POLLUTION 4, 33-64.

Reddy, K. R. and Patrick, W. H.  1975.  Effect  of alternate aerobic and
     anaerobic   conditions  on   redox  potential,  organic   matter
     decomposition  and  nitrogen loss  in  a  flooded  soil.  SOIL BIOL.
     BIOCHEM. 7,  87-94.
                                24-25

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Renner, E. D.  and Becker, G. E.  1970.  Production of nitric oxide and
     nitrous   oxide   during   denitrification  by   Corynebacterium
     nephridii.  J.  BACTERIOL.  101, 821-826.

Research  Triangle  Institute,   1974.   Natural  emissions  of  gaseous
     organic compounds and oxides of nitrogen in Ohio and surrounding
     states.  EPA Contract 68-02-1096, Task 12, 13.

Reuss, J. 0. and Smith, R. L.  1965.  Chemical reactions of nitrites in
     acid soils.  SOIL SCI. SOC. AM. PROC. 29,  267-270.

Robinson, E.  and Robbins,  R.   C.   1970.  Gaseous  nitrogen compound
     pollutants  from urban  and natural  sources.  J. AIR POLL. CONTROL
     ASSOC. 20, 303-306.

Scaletti, J. V.,  Gates,  C.  E.  Briggs, R.  A. and Schuman,  L. M.  1960.
     Nitrogen dioxide production from silage.  I. Field survey.  AGRON.
     J. 52, 369-372.

Stanford, G.,  Legg,  J.   D.,  Dziena, S.  and  Simpson,  E.  C.   1975.
     Denitrification and associated nitrogen transformations in soils.
     SOIL SCI. 120,  147-152.

Soderlund, R. and  Svensson, B.  H.   1976.  Nitrogen,  Phosphorus and
     Sulfur— Global Cycles.   SCOPE Report 7.  Ecol.  Bull.  (Stockholm)
     22,  23-73.

Stefanson, R. C.   1972.   Soil denitrification in  sealed soil-plant
     systems.  I. Effect of plants,  soil water content and soil organic
     matter content. PLANT and  SOIL 37, 113-127.

Steen, W. C. and Stojanovic, B. J.   1971.  Nitric oxide volatilization
     from a calcareous  soil and models  aqueous  solutions.  SOIL SCI.
     SOC. AM. PROD. 35, 277-282.

Stevenson,  F.  J. , Harrison, R. M.,  Wetselaar, R., and Leeper, R. A.
     1970.  Nitrosation of soil organic  matter.   III. Nature of gases
     produced  by reaction of  nitrite with lignins,  humic substances,
     and phenolic   constituents   under  neutral   and  slightly  acid
     conditions.  SOIL SCI.  SOC. AM. PROC. 34, 430-435.

Todd, R. L., Waide,  J. B. and Cornaby, B. W.     1975.   Significance of
     biological  nitrogen fixation and denitrification  in a deciduous
     forest ecosystem.   Mineral  Cycling in  S.  E. Ecosystems.  ERDA
     symposium series CONF-740513. p. 729-735.
                                24-26

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Van Cleemput, 0., Patrick, W. H. and Mcllhenny.    1976.        Nitrite
     decomposition  in  flooded  soil  under  different  pH  and  redox
     potential conditions.   SOIL SCI. SOC. AN. J. 40, 55-60.

Vollenweider,   R.   A.    1968.   Scientific   fundamentals   of   the
     eutrophication  of  lakes  and  flowing  waters,   with  particular
     reference   to   nitrogen   and   phosphorus   as   factors   in
     eutrophication, O.C.E.D. Report, DAS/CSI  68.27

Wijler,  J.   and  Delwiche,  C.  C.   1954.   Investigations  on  the
     denitrifying process in soil.  PLANT SOIL 5, 155-169.

Wullstein, L. J. and Gilmour, C. M.   1966.  Non-  enzymatic   formation
     of nitrogen gas.  NATURE 210, 1150-1151.

Wullstein, L. H. and Gil mour,  C. M.  1964. Non-enzymatic gaseous loss
     of nitrite from clay and soil systems. SOIL SCI. 97, 428-430.

Yoshinari, T.  1976.  Nitrous  oxide in the sea.  MARINE CHEM. 4,  189-
     202.
                                24-27

-------
                      CONDENSED DISCUSSION
QUESTION:              Which data did  you think was most accurate
                       of that in the table?
TINSEY:                Well I think our own 1s, but if you look
                       honestly at them I think in reality they are
                       all relatively suspect.
                              24-28

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PROCEDURES FOR CONDUCTING HYDROCARBON EMISSION INVENTORIES OF
 BIOGENIC SOURCES AND SOME RESULTS OF RECENT INVESTIGATIONS
                    Presented at the 1977
               Environmental  Protection Agency
             Emission Inventory/Factor Workshop
       Raleigh, North Carolina - September 13-15,  1977
                             By
                        Pat Zimmerman
             Assistant Environmental  Scientist
                 Washingtyn State University
               Air Pollution Research Section
                Pullman, Washington  99164
                           25-1

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Introduction
     All of us have enjoyed the smells of a thick pine forest or
a blossoming orange grove.  Few of us can forget majestic views
of distant blue mountains.
     Pollution from plants?  Not likely.  Plants manufacture
oxygen and we all know how important oxygen is.
     Rasmussen and Went were among the first to attempt to measure
vegetation emissions (Rasmussen and Went 1965, Rasmussen 1972).
Essentially all previous predictions of natural hydrocarbon
emission rates have either been made by Rasmussen or based upon
his early work.  That early work established that natural sources
can contribute hydrocarbons to ambient air and it postulated that
the amounts of emissions  may be quite large.  Smog chamber
studies showed that ozone could be generated when car exhaust was
irradiated by sunlight.   It was then found that a mixture of
"natural" hydrocarbons, NO  and sunlight could also produce ozone
                          X
(Ripperton et al. 1967).  During the same time period the technol-
ogy to accurately monitor ozone levels on a routine continuous
basis was developed.  As monitoring systems expanded, agencies
began reporting high ozone levels in rural areas well away from
local anthropogenic sources of ozone precursors.  Local, State
and Federal officials in  charge of maintaining specified oxidant
levels were faced with the monstrous task of designing comprehensive
and often very expensive  strategies to control the emission of
                                25-2

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oxidant precursors.  Detailed inventories of anthropogenic point
and area sources were conducted so that the most effective control
techniques could be employed. Yet the natural component - though
known to exist and known to have a potential for ozone development
was ignored.  No standardized technique for the evaluation of
natural sources existed.
     In 1976 the National Air Data Branch of the Environmental
Protection Agency funded the Washington State University Air
Pollution Research Section to develop a technique for the evalu-
ation of natural organic emissions.  Specifically the project
objectives were:
     1.  To Develop a standardized sampling and analytical
         methodology
     2.  To develop emission factors for a limited number of
         species
     3.  To develop standardized emission inventory techniques
     4.  To develop preliminary nationwide emission estimates
Sample Methodology
     A static/dynamic enclosure system was developed which satis-
fied the project objectives.  In addition the technique is rela-
tively simple, inexpensive and easily reproducible by other
laboratories.
     Basically, the method involves enclosing a portion of the
vegetation of interest in a Teflon bag, sucking most of the
                                25-3

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ambient air out of the bag and thus collapsing the bag around the
branch.  A "background" sample of the air from the collapsed bag
is then collected.  The bag is then quickly filled with a known
volume (60«, @ lOfc/min.) of air which is free of all hydrocarbons
and has a controlled level of C02-  After the bag is partially
inflated, an "emission rate" sample is collected while zero air
continues to flow into the enclosure at a rate slightly higher
than the sample rate (- ZVmin.).  The total enclosure time is
approximately 15 minutes.  The emission rate is equal to the
difference in the hydrocarbon content of the bag as measured in
the emission rate sample minus the hydrocarbon content of the bag
as measured in the background sample collected prior to inflation
with zero air.  This emission rate is then divided by some unit
of foliage measurement such as by leaf biomass.  The  result  is  a
raw emission  rate of the  units:   micrograms emission  per gram  leaf
biomass  per hour  (vg/g.hr).
     To  collect emission  samples  from  vegetation the  following
equipment  is  needed:
     1.  A portable source of pure air which  is hydrocarbon  free
         and  can  be regulated to  give  a  precise flow  rate.
     2.  A vegetation  enclosure which  does  not add to or take
         away from organic vegetation  emissions.
     3.  A method to collect  an  air  sample  from the enclosure  and
         to move  it to a  laboratory.
                                 25-4

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     4.  A temperature sensor to measure bag temperature and
         ambient air temperature.
The WSU sample train included an open-ended 110 x 150 cm Teflon
bag (capacity - 120£) as an enclosure.  A sample manifold (Fig.
1) provided flow control for the pure air entering the bag and
sample leaving the bag.  A metal bellows pump was used for the
transfer of samples from the enclosure into 5.5I electropolished
stainless steel cannisters.  Clean 1/8" (od) copper tubing or
1/8" od Teflon tubing was used for pure air and sample transfer
lines.  Figure 2 is a schematic drawing which illustrates the
experimental design.  The pure air was obtained by cryogenically
compressing air purified by an Aadco pure air generator into
empty medical oxygen cylinders.  Other sources of clean air such
as zero-grade air commercially available in high pressure cylinders,
could probably be used.  However, it would be important to conduct
a blank analysis of each cylinder to determine the COo concentration
and hydrocarbon species present. An indoor outdoor thermometer
was used to obtain the ambient air temperature and the enclosed
air temperature simultaneously.
     The emissions from the surface of soil/leaf litter can also be
sampled with this basic setup plus some additional equipment.  The
additional equipment consists of a sealing ring and a stainless-
steel  bag collar (Fig. 3).  The sealing ring is driven into the soil;
the bag collar is then placed in the center of the sealing ring.
                                25-5

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                         FIGURE 1
         PORTABLE  SAMPLE MANIFOLD
             0-AIROUT
     PRESSURE
      GAUGE
                                SAMPLE'   PRESSURE
REGULATOR
                                                  0-AIR IN
REGULATOR
   EVAC.
                     SAMPLE   0-AIR
                     FLOW     FLOW
                                             0-AIR OUT
                                              PRESSURE
                                               GAUGE
                                              NEEDLE VALVES
                         25-6

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                                              FIGURE 2
                      VEGETATION EMISSION  SAMPLE  COLLECTION  SYSTEM
ts»
                                                    PORTABLE SAMPLE MANIFOLD
                     -THERMOMETER
STAINLESS STEEL
 CANNISTER
                                                                        METAL
                                                                      BELLOWS PUMP

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                       FIGURE 3
  SOIL LEAF-LITTER  SAMPLING  SYSTEM
EVAC.
                        • COLLAPSIBLE
                        TEFLON BAG
                     [r
BAG COLLAR
SAMPLE
•ZERO AIR INLET

 MOIST SOIL SEAL
                           SEALING RING

          (2)J4"SWAGLOCK BULKHEAD
                                       SOIL
SHARP CUTTING
EDGE
         SEALING RING
           BAG COLLAR

 *all dimensions in centimeters
                         25-8

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Next moist dirt is used as a filler between the sealing ring and
the bag collar.  After the collar and ring are in place, the
Teflon bag is attached by means of a wide elastic strap to the
bag collar.  The sample collection procedure is then identical to
that for vegetation.
     Surface waters of bays, estuaries and marshes can be sampled
by the addition of a floatation ring to the bag collar.  The WSU
laboratory used two closed cell polyurethane filled water-ski
belts sewn together and strapped around the bag collar as a
floatation ring.
Analysis
     Most samples were returned to the laboratory for f.i.d. gas
chromatographic analysis within 24 hours.  Columns and conditions
are shown in Table 1. Three separate analysis were performed on
each sample.  One instrument was required to quantify methane,
ethane, ethylene, and acetylene.  Another instrument was equippped
to quantify ^ - Cg hydrocarbons.  A third instrument was committed
to the analysis of C^ - C^ hydrocarbons.
     The overlap in analysis served as a check on GC performance.
GC response was calibrated with respect to a standard concentration
of neo-hexane.
     In order to achieve sufficient GC response a sample concen-
tration step is required.  Prior to analysis, 500 ml of sample is
drawn through a 3.2 mm (1/8") o.d. stainless steel sample loop
                                25-9

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                                                        TABLE I

                                             Hydrocarbon Analysis Conditions
                 Compound
     Instrument
      Operating Conditions
ro

»—
o
                 Ethylene
                 Ethane
                 Acetylene
                 Methane

                 Light
                 Hydrocarbon
                    crce
P.E. 3920 Isothermal
         FID
P.E. 3920 Temp.  Prog.
         FID
                 Heavy Hydrocarbon
                 and Oxygenates
Column:  10' x 1/8" OD Porapak 0
Carrier:  He 80 psi, 7 ml/min
Hydrogen:  22 psig
Compressed Air:  50 psig
Column:  20' x 1/16" OD Durapak
         N-Octane
Carrier:  He 90 psig, 6 ml/min
Hydrogen:  40 psig
Compressed Air:  50 psig
Oven:  Initial Temp. -70°C
       final 65"C
     Delay time:  4 min.
     Program rate:  16°/min
Total Run Time:  40 min.

Column:  10' x 1/8" Durapak Low K,
         Carbowax 400
Carrier:  He 90 psig, 8 ml/min
Hydrogen:  40 psig
Compressed Air:  50 psig
Oven:  -20 to 100°C
     Delay Time:  2 min.
     Program Rate:  8°/min
Total Run Time:  20 min.

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                                    TABLE 1 (cont'd)

                             Hydrocarbon Analysis Conditions


Heavy           P.E. 3920 Temp. Prog.     4.  Column:  200' SCOTOV-101,
Hydrocarbon              FID GC                        10' x 1/16" OD
   C.-C1?                                              Durapak low-K, Carbowax
    ^  '                                                400 precolumn
                                              Carrier:  He 90 psig, 5 ml/min
                                              Hydroqen:  40 psig
                                              Compressed Air:  50 psig
                                              Oven:  0°C-100°C Temp. prog.
                                                   Delay Time:  6 min.
                                                   Program Rate:  6°/min
                                              Total Run Time:  60 min.

                                          5.  Column:  30 m SE 30 Glass
                                                       Capillary Column
                                              Carrier:  He 90 psig, 1 ml/min
                                              Oven:  -30-80°C Temp. prog.
                                                   Delay Time:  8 min.
                                                   Program Rate:  4°/min
                                              Total Run Time:  50 min.

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attached to a six port sample valve.  The loop is filled with
60 - 80 mesh glass beads and immersed in liquid oxygen.  The
sample valve is then switched on stream with the GC column and
the loop is immersed in boiling water to flush the organics
trapped on the glass beads onto the head of the column.  Fig. 4 shows
the vacuum sampling system used to introduce known amounts of
sample into the sample loop.  This system consists of a chamber
of known internal volume which has been evacuated.  A vacuum
gauge is attached to the chamber and calibrated so that a specified
change in vacuum is equivalent to a specified sample volume.

Preparation of an Emission Inventory
     After a specific area and time period of interest have been
designated for an emission-study, program there are five major
steps in developing an emission inventory.
     1.  Identify the major vegetation types and predominate
         plant species.
     2.  Select the representative  species to be sampled.
     3.  Quantify the biomass for each species selected.
     4.  Conduct a field program to collect emission samples
         from each of the representative species.
     5.  Develop emission rate algorithums for seasonal and/or
         daily weather variables  (sunlight, temperature, moisture).
                                 25-12

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        FIGURE 4


VACUUM     SYSTEM
  for  sample injection
             OFF
                 SAMPLE
 FRONT   VIEW
                                 VACUUM SAMPLE
                                    INLET-
      BACK VIEW
           25-13

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     These five steps can be classified into two basic components
necessary for inventory development:  1) a set of emission factors
representative of the vegetative species and conditions (season,
temperature, etc.) for the area to be inventoried and 2) biomass
factors, which are a measure of the quantity of vegetation or
litter present in the area.  Inventorying vegetation is therefore
analogous to any other source category in that an appropriate
emission factor is multiplied by some source activity level in
order to estimate emissions.
     The samples collected by WSU in Pullman in the fall of 1976
were used to construct a sample emission inventory for the
continental U.S.  Figure 5 is a map of the major biotic regions
of the U.S.  Raw emission factors were then determined for each
biotic region by approximating the vegetative mix with the average
emission rates of similar vegetation sampled in the Pullman area.
The raw emission factors were then corrected for the effect of
temperature.  The temperature of the United States was approximated
by an average winter temperature of 7.5°C and an average summer
temperature of 23°C.  The corrected raw emission factors were
then multiplied by the respective summer and winter leaf biomass
estimates for each biome.  This resulted in an average summer
emission factor and  in an average winter emission factor.
Multiplying these emission factors by the number of hours of
summer and winter respectively and adding the products results  in
                                25-14

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                                                          Figure 5
MAJOR   BIOTIC  REGIONS    OF   THE  U.S.
                       :XvXvXvXxX;:
                       jx[:|xjxv:jx|xjx




                                25-15
                                         GKAMJI.AUD

                                         SCt l.KOr'IIYU. '.iCI

                                         TEMI'f-R/\TI: KA1N  t'ORCST

                                         DECIDUOUS I-OREST

                                         CONIFEROUS  FORCST

                                         DESI-IRT

                                         TUNDRA, ALPINi:  FIELDS
vZA

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an estimation of the average annual emission rate from natural
sources (Fig. 6).  As figure 6 illustrates, this total is equal
to aproximately four times the total emissions from anthropogenic
sources. This emission inventory will be updated this fall.
Recent sample programs conducted in Florida and North Carolina
indicate that the emission factor used for oaks may be five times
too small.   Early samples were collected in a dark stainless
steel enclosure.  The major emission from oaks is isoprene and
isoprene seems to be emitted almost exclusively in daylight
conditions.  Similarly samples of pines collected in Pullman had
emission rates approximately one third lower than those of measured
in North Carolina and Florida.  These emission rate differences
may partly be the result of species differences, but more likely
the differences are due to seasonal changes in emission rates  as
reflected by the basic metabolic rate of the respective vegetation.
Some raw emission rates for selected vegetation types sampled  in
Pullman, North Carolina and Florida are shown in Table 2.  Figure
7 illustrates a  preliminary emission inventory developed for the
Tampa,  St. Petersburg area.  This  inventory is also only an
approximation.   No area was subtracted for highways or developments
and no  provision for temperature or light relationships was
included.  Details of the inventory are explained in  EPA Periodic
letter  Report IIV, Interim Progress Report, prepared  for Air
Programs Branch  EPA Region IV, Contract -68-01-4432.  Approximately
                                25-16

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                                    Figure 6
               TOTAL YEARLY EMISSION RATE FOR THE CONTINENTAL U.S.
                              BASED ON LEAF BIOMASS
Summer Emissions:
Average Vegetation Emission Rate
     1.36 x 104T/hr x 708.7 hrs/mo x 5 mo =                      4.82 x 107T
Litter Emission Rate
     132 g/m2 hr x 1 x 106m2/km2 x 9.06 x 106 km2/U.S. = 1.2 x 103T/hr
     1.2 x 103T/hr x 708.7 hrs/mo x 5 mo =                       4.20 x 106T
                                           Total  Summer Emission 5.24 x 10 T
Winter Emissions:
Average Winter Emission Rate
     7.04 x 103T/hr x 708.7 hrs x 7 mo =                         3.49 x 107T
     Total Yearly Emission Rate for Vegetation and Leaf-Litter   8.73 x 10 T/yr
     Total Yearly Emission Rate from Anthropogenic Sources       2.12 x 10 T/yr
Natural Emissions as the Percent of the Total Emissions from All Sources
                    	8.73 x 107T/yr	= QQ%
                    2.12 x 10'T/yr + 8.73 x TO'T/yr

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                                                        TABLE 2

                         AVERAGE RAW  EMISSION RATES FOR SOME SELECTED SAMPLE TYPES  IN  FLORIDA
                                          NORTH CAROLINA AND WASHINGTON

                                                          Number         X" Raw  Emission
                               Sample Type               of Samples             Rate

                 Tampa, Florida  April  - May 1977

                      Selected Marine Samples                                       ?
                           Mud Flat                       8             119.8   yq/nyhr
                           Intertidal Samples             3             117.2   ya/nyhr
                           Decaying Vegetation           13             202.0   yg/nyhr
                           Marine Grass  -                20              93.5   yg/nyhr
N>                          All Marine Samples            89             143.0   yq/m'hr
Ul                                                                               'o
I*                     Pastures                           32             288.6   yg/m  "hr
00
                      Oaks
                           Laurel Oak                    10              11.2   yg/g'hr
                           Turkey Oak                     3              26.1   yg/g'hr
                           Water Oak                      3              27.2   ya/g'hr
                           Blue Jack  Oak                  6              16.5   ya/n'hr
                           All Species  of Oak (Day)      25              21.14  yg/q'hr
                           All Species  of Oak (Night)     3                1.20  yg/g'hr

                      Ci trus
                           Oranges                        8                3.1   yg/q'hr
                           Grapefruit                     3                2.8   yg/g'hr

                      Coni fers
                           Long Leaf  Pine                16                3.3   yg/Vhr
                           Slash Pine                     7                6.0   yg/n'hr
                           Sand Pine                      2                7.3   yg/g'hr
                           All Conifers                  26                5.1   yg/q-hr

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                                     TABLE 2  (cont'd)

      AVERAGE RAW EMISSION RATES FOR SOME SELECTED SAMPLE TYPES IN FLORIDA
                          NORTH CAROLINA AND WASHINGTON
Raleigh, North Carolina  June 1977

     Oaks                                3              26.10 yg/g-hr

     Conifers
          Shortleaf Pine                 2              16.3  yp/g-hr
          Loblolly                       2               4.85 yp/n'hr
          E.  Red Cedar                   2               1.14 yg/g'hr
          Virginia Pine                  1              13.60 yg/o-hr
          All Conifers                   7               8.4  yg/g-hr

Pullman, Washington  August - November 1976

     Conifers
          Ponderosa Pine                 6               2.96 yp/g-hr
          Mugo Pine                      2               1.78 yg/g-hr
          Douglas Fir                    6               0.86 yg/p-hr
          Juniper                        4               3.25 yg/n-hr
          Spruce                         3           .2.26 yg/g-hr
          All Conifers                  21               2.26 yg/g-hr
     Oak (Dark Chamber)                  2               4.40 yg/n-hr
     Pine Litter                         1             132.00 yq/m2-hr

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                                                    Figure 7
                                PRELIMINARY NATURAL HYDROCARBON EMISSION INVENTORY

                                        FOR THE TAMPA/ST.  PETERSBURG AREA
N>


Y
S3
o
Vegetation Type
Col umn
Tampa Bay
Intertidal
Marine Grass
Improved Pasture
Unimproved Pasture
Citrus
Mangrove
Palmetto
Pine
Shrubs
Leaf
Biomass
Factor
g/m2
1



498
156
240
760
240
X Raw
Emissions
Factor
yg/tj-hr
2



3.02
1.77
9.74
5.13
9.74
X Raw
Emissions
Rate
pq/m2 • hr
3
143
284
301
1,504
276
4,091
3,899
4,091
Percent
of area
covered
4
22
9
12
8
3
12
6
12
Est.
area
Km2
5
997
419
558
349
156
532
279
532
Total
Emission
Rate
(q)/hr
6
1.4X105
1.1X105
1.7X105
5.2X105
4.3X104
2.2X106
1.1X106
2.2X106

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                                                      Figure 7  (cont'd)

                                 PRELIMINARY NATURAL HYDROCARBON EMISSION INVENTORY
                                         FOR THE TAMPA/ST. PETERSBURG AREA


                  Oak-Hickory             498      14.87          7,405            8        349    2.6X106

                  Oak-Gum-Cypress         480      38.57         18,514            8        349    6.5X106
                                                                                          4,520    1.6X107q/hr

                                                           Total  Average Hourly Emission Rate  16T/hr

V                             Study Area natural  TNMHC Emission Rate:   16T/hr X 24hr/day       384T/day
to
!-•
                  Hillsborough County Anthropogenic Hydrocarbon Emission Rate                  132T/day

                  Pinellas  County Anthropogenic Hydrocarbon Emission Rate                       48T/day*

                   *No official  estimates were available for Pinellas  County.
                    This  figure is a guess based upon the Tampa Bay (AQCR 052)
                    NEDS  emission rate estimate of 539T/day.

                  Percentage of TNMHC Burden Attribritable to Natural  Sources:  384/180+384=68%

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330 additional samples have been collected since tabulation of
the preliminary Florida emission inventory.  Considerable time
has also been spent in better quantitation of the biomass in the
study area.  The final emission inventory will be available after
March 1978 and will be included in an EPA computer modeling
program which is intended to predict oxidant levels for the
Tampa/St. Petersburg area.
Conclusion
     Although all  preliminary emission estimates predict that
natural sources of hydrocarbons contribute significantly to the
atmospheric burden, the actual  concentration of natural hydrocarbons
in ambient air is dependent upon the dilution volume relative to
the hydrocarbon emission rate.
     Westberg and Holdren (1976) reported on an analysis of
monoterpenes from a rural forested site in northern Idaho by a
gas chromatograph linked directly to a Mass Spectrometer.  They
collected samples of ambient air as well as vegetation emission
samples using the Teflon bag enclosure technique described in
this paper.  The emission rates for the terpene compounds were
then used to calculate expected ambient air terpene concentrations
within the forest canopy.  Their calculations show that assuming
                                             2
an average terpene emission rate of 3120 yp/m -hr (obtained for a
coniferous forest of this region) and a typical canopy height of
20 meters, 3120 yg of terpene compounds are emitted into a volume
                                25-22

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unit 1  meter x 1  meter x 20 meters (20 m ) in one hour.  The time
(t) for the forest canopy to vertically exchange its volume can
be calculated utilizing the "random walk assumption" which states
that T 21 Z/2D, where Z is the mixing distance (20 m) and D is the
vertical diffusion coefficient in a forest canopy (assumed to be
10  cm /sec).  Using these values the time for vertical exchange
was calculated to be 200 seconds.  The expected ambient air
concentration within the canopy is then:
     The calculated value of 1.6 ppb agrees relatively well with
the ambient air values measured during the course of the Westberg-
Holdren study.  This calculation indicates that low levels of
natural hydrocarbons are expected in ambient air and that normal di-
lution processes can account for these low levels.  Thus, although an
annual U.S. emission rate of natural hydrocarbons which is four
times the total of all anthropogenic sources seems quite large,
the actual concentration of natural hydrocarbons in ambient air
is expected to be quite low.  These low levels can be attributed
to the diffuse nature of the source and natural dilution.
     Another approach which can be used to put natural hydrocarbon
emissions into perspective is to compare emission densities from
vegetation and from anthropogenic sources in urban areas.  Tom
Lahre, Engineer for the Air Management and Technology Branch of
                                25-23

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the Environmental Protection Agency has used this approach to
compare natural emission data generated by this study to data for
anthropogenic emissions gathered during the NEDS program (personal
communication).
     Mr. Lahre's comparison shows that for the St. Louis urban
and suburban areas (a radius of 22 miles from the center of the
city) vegetative emissions comprise only 6% of the total of all
emissions in the developed part of the city.  However the ratio
of the emission densities for Natural and Anthropogenic sources
reaches unity  if a radius of 68 miles from the center of the city
is used.  That is for the St. Louis area, assuming that the air
were evenly mixed within a 68 mile radius of the city, 50% of the
total hydrocarbon burden would be due to biogenic sources.
     From this information it appears that the total of natural
hydrocarbon emissions is large with respect to anthropogenic
emissions, however anthropogenic sources tend to be much more
concentrated and that physical dilution of natural hydrocarbon
emissions can  account for the low levels of natural hydrocarbons
observed in rural areas.
     Laboratory research has demonstrated that the natural emission
products are very reactive both in photochemical processes and
ozonolysis reactions. However it has also been reported that
laboratory ozonolysis experiments typically required from 10 to
30 ppb of carbon from the terpene compounds to produce 1 ppb of
                                25-24

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ozone.  In addition it has been predicted that many of the natural
hydrocarbons would react with ozone very quickly after entering
the atmosphere leaving only small quantities to exist long enough
to participate in photochemical processes (Westberg 1977).
     Though the information generated by the research is important
a few researchers do not feel that it is conclusive.  They point
out, for example that most previous estimates of the ozone producina
role of natural hydrocarbons are based upon a hydrocarbon mix of
terpenes.  They point out that our research has shown that in
many areas isoprene is by far the largest natural emission product.
Isoprene is very reactive photochemically and is not as likely to
produce aerosols as the heavier terpenes.  Also most bag irradiation
experiments in which large amounts of particulates were formed
were conducted at hydrocarbon levels much higher than those of
rural ambient air.  They believe that this would probably cause a
shift in reaction kinetics as well as in the end products produced.
     However a majority of previous research when coupled with
the biogenic emission rate data determined by WSU indicates that
biogenic emissions of natural hydrocarbons cannot in themselves
account for the existence of high ozone levels in rural areas.
Other mechanisms proposed to explain high ozone levels in rural
areas include the direct injection of stratospheric ozone into
the troposphere (Chatfield and Rasmussen, 1977), or the theory
that anthropogenic ozone precursors including NO  and man-made
                                                X
                                25-25

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hydrocarbons are transported downwind over long distances, reacting
to produce ozone.  The relative importance of these mechanisms has
not been determined.
     Although natural hydrocarbon emissions do not seem to be the
major cause of high rural ozone levels, it cannot be concluded that
these emissions do not play a significant role in the chemistry of
rural atmospheres.  Recently much of the scientific literature has
been focused upon the OH budget of the atmosphere.  OH radicals seem
to be very important in "scrubbing" trace gases such as S02, and
chlorofluorocarbons from rural air. OH radicals are postulated as the
reactive intermediates for many atmospheric reactions, including the
formation of ozone  (Wofsy 1976).  They therefore have an effect on
such far ranging problems as acid rain, stratospheric ozone depletion
and tropospheric ozone production.  The key to understanding these
problems is a thorough understanding of the OH budget.  One of the
basic inputs of OH  budget models is the hydrocarbon emission rate
(including methane) into the atmosphere (Crutzen and Fishman 1977).
     The interactions between stratospheric injection, downwind
transport, the production of natural hydrocarbons and the OH
budget are unknown.  As a result the occurrance of high ozone levels
in rural areas is not understood. Though many questions remain to
be answered, determining the magnitude and types of biogenfc
emissions is an  important step in understanding the air around
us.
                               25-26

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                             LITERATURE CITED

R. B. Chatfield and R. A. Rasmussen, "An Assessment of the
Continental Lower Tropospheric Ozone Budget," EPA Report No. 700-
lA-Jan., 1977.

R. J. Crutzen and J. Fishman, "Average Concentrations of OH in
the Northern Troposphere, and Budgets of CH,, CO and FL," NOAA,
Env. Res. Lab., Aeronomy Lab., Boulder, CO and NCAR, ATr Qual.
Div., Boulder, CO, 1977.

R. Rasmussen and F. W. Went, "Volatile Organic Material of Plant
Origin in the Atmosphere," Proc. Nat. Acad. Sci., 53:215 (1965).

R. Rasmussen, "What do the Hydrocarbons from Trees Contribute to
Air Pollution?" APCA Journal, 22, 537 (1972).

L. Ripperton, 0. White and H. Jeffries, "Gas Phase Ozone-Pinene
Reactions," Div. of Water, Air, and Waste Chemistry, 147th
National Meeting American Chemical Society, Chicago, IL, pp 54-56.
Sept. 1967.

H. Westberg, "The Issue of Natural Organic Emissions," prepared
for U.S. EPA Office of Res. and Dev., order No. DA-7-1290J,
1977.

H. Westberg and M. Holdren, Quarterly Technical Report for EPA
Grant No. 800670, J. Bufalini, Project OFficer, 1976.

S. C. Wofsy, "Interactions of CH, and CO in the Earth's Atmosphere,
Ann Rev. Earth and Planetary Sciences, 4, 1976, pp 441-469.
                                25-27

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                            Acknowlegements


     This work was supported by the Following EPA Contracts:

          Contract No.  68-02-2071    Title:   Testing of Hydrocarbon
               Emissions From Vegetation and Development of a
               Methodology for Estimating Emission Rates from
               Foliage  ion Any Geographical Area in the United
               States.

          Contract No.  Du-77-C063   Title:   Additional Testing of
               Organic  Emissions from Vegetation and Leaf Litter/
               Soil Surfaces.

          Contract No.  68-01-4432   Title:   Determination of
               Emission Rates of Hydrocarbons From Indigenous
               Species  of Vegetation in the Tampa/St. Petersburg
               Florida  Area.

          Don Sterns, Phil Sweany and Bob Watkins provided
          significant contributions toward the successful
          completion of the fieldwork.
                              Disclaimer

     The mention of specific brand names in this paper is solely

for reference use, and does not constitute an endorsement by

Washington State University or the Environmental Protection

Agency.
                                25-28

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QUESTION:
ZIMMERMAN:
CONDENSED DISCUSSION
 Could you estimate what percentage of total
 is isoprene?
 Isoprene has not been studied in bag studies.
 Isoprene is a very active ozone former and
 it doesn't tend to form particulates nearly
 as readily as the heavy organics.  Most bag
 studies were also done at high concentrations
 What that tends to do is favor the kinetics
 to produce  particulates etc.  I would
 say it depends on the forest.  In a north-
 west forest, the isoprene concentration is
 lower.  If you get back here where there are
 oak trees and other isoprene emiters, it
 would be higher.  For an oak tree it is 99%
 of the total emissions.  So, if you had all
 oak trees it would be 99%.  But it is prob-
 ably 60 or 70%, maybe as low as 50% in a
 mixed deciduous oak-hickory, etc. forest.
 Of course a lot of the oak-hickory areas that
 were shown on the map are actually loblolly
 pine now that the  original forests have been
 cut down and replanted.
                               25-29

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QUESTION:
ZIMMERMAN:
QUESTION:
ZIMMERMAN:
QUESTION:
ZIMMERMAN:
Will you report and try to break down the
emissions by compounds.
The report for Florida will.  This one won't
as it is a survey report.  We've got just
what I presented.  The one for Florida will
have the emissions quantified  by species for
each one by one grid area.  On an hourly
basis throughout the  day and throughout the
season the major emissions will be pointed out.
Could you measure emissions over a
diurnal cycle?
Yes, we did, day and night.  Every four to
six hours we would resample the live oak trees
and pine trees and so forth.
Did you get no emissions from the Teflon
sample bags?
It was pretty low because it was a short 15
minute enclosure time.  We did background
blanks.  As long as we turn the bags inside
out and let them  dry out good between
samples, background is low.  It would also
have been taken into account in our tests
because we collected a background sample
which would have included the bag emissions.
                               25-30

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QUESTION:
ZIMMERMAN:
QUESTION:
ZIMMERMAN:
QUESTION:
How did you investigate the possibility that
by surrounding the branch with a bag you
were changing its  natural emissions?
What we tried to  do was measure different
parameters such as the bag temperature.  We
found in the very worse  cases, if you put
the bag in the sun it would heat up maybe 7
or 8  degrees F.  We measured relative
humidity, etc.  That was the best we could do,
We  have also compared data with EPA people
that are doing flux estimates.
I went through some of their figures and
they came out pretty close.  Anyway, it
seems that at lower temperatures at least,
there  was a pretty good correlation.
Did you measure the COp or did you add COg to
the  bag?
Yes.  We added COp to the air that we put into
the bag.  We did measure it.  We put in 365
parts per million, which is equivalent to
ambient COp.
Did you check on the reduction of COp as the
reaction took place?
                               25-31

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ZIMMERMAN:
QUESTION:
ZIMMERMAN:
You mean did we measure it in the samples we
collected?  Yes, we did periodically.  We
didn't as a routine measure in Florida but
when we were developing the technique we
did.  It didn't change a large amount, like
10% maybe.  In the dark it would increase 10%.
You are talking about day and night sampling;
did you sample in direct sun light and
indirect sun light and were there any
differences?
We sampled in all different lights.  We
recorded the cloud cover and so forth in the
notes and we haven't gone through all the
data yet so I can't make any strong corre-
lations.  In other words, I  don't know
where the isoprene emission peaks out with
sunlight intensity.  We can get that infor-
mation from out data.  We will determine a
pattern when we refine our  data more and
more.
                               25-32

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                                    TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing}
1. REPORT NO.
  EPA-450/ 3-78-042 b_
4. TITLE AND SUBTITLE
 Emission  Inventory/Factor Workshop  Volume II
                                                             3. RECIPIENT'S ACCESSION NO.
              5. REPORT DATE

               Mav  1978
              6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
  Various
                                                             8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
  Air Pollution Training  Institute
  Air Management Technology  Branch
  Office of Air Quality Planning and Standards
  Research  Triangle Park, North Carolina  27711
                                                             10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
  Same
              13. TYPE OF REPORT AND PERIOD COVERED
                Final  Proceedings	
                                                             14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES


  Moderator:   James Southerland
16. ABSTRACT

       This  report in two volumes presents  the written form  and summarized discussions

  of  "presentations" made at  the Emission Inventory and Factor  Workshop in Raleigh, N.C.

  September  13-15, 1977.  A total of twenty-five "papers" on emission inventory and

  factor  experiences and other information  with emphasis on  organics (hydrocarbons)

  were presented.  Authors represented EPA, state air pollution control agencies and

  private industry.
17.
                                 KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS  C. COSATI Field/Group
  Emission inventory
  Emission factors
  Volatile organic compounds
  Oxides  of nitrogen
  Natural  organic emissions
  State  implementation  plans
18. DISTRIBUTION STATEMENT


   Unlimited
19. SECURITY CLASS (ThisReport)
   Unrestricted
                            21. NO. OF PAGES
414
20. SECURITY CLASS (Thispage)
   Unrestricted
                            22. PRICE
    Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSOLETE
                                             26-1

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