Task Analysis of State and
Local Air Pollution Control Agencies and
Development of Staffing Guidelines
VOLUME
Detailed Task Data,and
Staffing Guidance t
ENGINEERING
SERVICES
UNITED STATES

ENVIRONMENTAL PROTECTION AGENCY

Manpower Development Staff   Office of Air Programs

Research Triangle Park, North Carolina 27711

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                 *t PRO^
United States
Environmental Protection Agency
Contract No. 68-02-0306
Applied Science
Associates,  Inc.
Task Analysis of State and   '
Local Air Pollution Control Agencies and
Development of Staffing Guidelines
VOLUME
Detailed Task Data, and
Staffing Guidance
ENGINEERING SERVICES
K. I. Rifkin, Senior Staff Scientist, ASA
R. L. Dueker, Staff Scientist, ASA
W. F. Digginsi Staff Scientist, ASA
F. C. Foss, Staff Scientist, ASA
                and
Michael  Senew, Project Officer, USEPA
Prepared for the
United States Environmental Protection Agency
Manpower Development Staff
Office of Air Programs
Research Triangle Park, North Carolina  27711
November 1972

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This Is not an offfetal policy and standards
document.  The opinions, findings, and conclusions
are those of the authors and not necessarily those
of the United States Environmental Protection Agency.
Every attempt has been made to represent the
present state of the art as well as subject areas
still under evaluation.  Any mention of products,
or organizatfons« does not constitute endorsement
by the United States Environmental Protection Agency.

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                             INTRODUCTION

One of the pressing problems in the air pollution control effort at
Federal, state, and local levels is planning manpower requirements and
developing manpower resources.  Questions are being asked such as, how
many people are needed, what kind of past experience and education should
they have, how should their jobs be structured, what do they need to know
to do their jobs, what special abilities do they need, and what kind of
training should they receive to do their jobs?  These questions are
becoming increasingly meaningful as the control effort broadens with the
creation of more and more local agencies and as existing agencies in-
crease the scope and depth of their programs.  Adequate answers are
required if progress is to continue toward the goal of clean air.
     In order to begin to answer questions relevant to manpower planning
and development, a data base describing the tasks to be performed by
control agency personnel and the skills and knowledge they must have to
perform those tasks effectively must be available.  Guidance concerning
the use of the data base in making staffing decisions must be prepared.
It is the purpose of this study to provide such a data base and the
appropriate guidance.

A.  Obj ectives
     The objectives of this project were the following:
          1.  To identify as great a proportion as possible of the
              population of tasks currently being performed by air
              pollution control agency personnel at the state and
              local levelithroughout the country.
          2.  To describe the identified tasks in terms of component
              behaviors and the skills and knowledge required to perform
              those behaviors.
          3.  To identify and describe categories of air pollution con-
              trol agency personnel who would perform the tasks mentioned
              above.
                                                  continued

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          4.  To structure and communicate the data which resulted
              from achieving the above objectives in a form which could
              be used by agency management in planning and developing
              manpower resources.
B.  General Project Overview
    The project was performed in two phases.   Phase I dealt with achieving
the first two project objectives, and resulted in the development of a
detailed data base describing the major tasks performed by agency personnel
in terms of the procedural components of the  tasks and the skills and
knowledge required to perform them.  Phase II dealt with achieving the
last two major objectives, and resulted in production of a guidance docu-
ment which integrates and structures data developed in Phase I and presents
it in a form designed to assist agency manpower developers.

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I THIS IS VOLUME B
Additional books  available are:

VOLUME A:  Guidance  and  Supporting  Information  for Staffing and Training
           Decisions in  an Air Pollution Control Agency - Introduction
           and Directions for Using These Guidelines

VOLUME C:  Guidance  and  Supporting  Information  for Staffing and Training
           Decisions in  an Air Pollution Control Agency - Field Enforcement

VOLUME D:  Guidance  and  Supporting  Information  for Staffing and Training
           Decisions in  an Air Pollution *Control Agency - Laboratory Support

VOLUME E:  Guidance  and  Supporting  Information  for Staffing and Training
           Decisions in  an Air Pollution Control Agency - Air Monitoring
           and Meteorological Support

VOLUME F:  Guidance  and  Supporting  Information  for Staffing and Training
           Decisions in  an Air Pollution Control Agency - Source Testing

VOLUME G:  Guidance  and  Supporting  Information  for Staffing and Training
           Decisions in  an Air Pollution Control Agency - Agency Management,
           Program Development,  and Public  Information Support


           AND
           TECHNICAL REPORT:
           Task Analysis of  State and Local
           Air Pollution Control Agencies,  and
           Development
           of Staffing Guidelines
           For  complete  sets, or individual  titles,  or the Technical
           Report please address your  request  to:

           United States Environmental Protection Agency
           Manpower Development Staff
           Research Triangle Park, N.  C.  27711

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                              ENGINEERING

     The task data and staffing information presented in this volume
cover a group of related tasks which are typically performed within
the engineering organization of a control agency.  The operations are
performed by the occupational categories of Engineer and Engineering
Technician.  The following tasks are included and are located within the
volume as indicated below:

         1.  Development and Production of an
             Emission Inventory                           Page B-3
         2.  Reception and Preliminary Screening
             of Plan Review/Permit System Appli-
             cations and Supporting Materials             Page B-26
         3.  Review of Plans and Application Forms
             in a Plan Review/Permit System               Page B-30
         4.  Engineering Inspection                       Page B-59
         5.  Design and Construction of an
             Episode Control System                       Page B-86
         6.  Review of Application for Tax Ex-
             emption on Air Pollution Control
             Equipment                                    Page B-110

     In addition to the above tasks, Table B-l (Page B-113) lists engineer-
ing tasks which have been identified but which have not yet been submitted
to detailed analysis.  Occupational categories have been suggested for each
task based upon current knowledge of the skills and knowledge required to
perform them effectively.  A brief rationale for each assignment is also
included in the table.
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                   Development and Production of an
                   	Emission Inventory	
Task Overview
The development and production of an emission inventory consists of a
complex, sequence of activities requiring many of the basic skills and
knowledge of an air pollution Engineer.  For the purposes of this study,
generation of an emission inventory will be described as a single task.
Many of the activities listed below could be treated as tasks in them-
selves and could be analyzed into more minute steps.  Such a molecular
breakdown was deemed to be inefficient with regard to identifying skill
and knowlege requirements.  However, such an analysis would be necessary
for the generation of detailed procedures and training.
Briefly, the objective of the emission inventory is to identify and sum-
marize the contribution of specific categories of sources to the total
of pollution for a given geographic area (whether it be a city, county,
state, or other subdivision).  The people involved in preparing this ,
inventory must define the population of sources to be surveyed, survey
them, summarize the data, and present it in a fashion which best meets
the objectives of the emission inventory.

Occupational Category:  Engineer  (Senior)

   Task Description
      1.  Identify and define the categories of emission sources to be
          included in the inventory.  Refine the categories to a level
          of detail such that the inventory staff can begin to identify
          their data requirements.  Include in the categories all relevant
          point and area sources subsumed under the following:
             a.  Fuel combustion
             b.  Process losses
             c.  Solid waste disposal (including agricultural burning)
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   d.  Transportation
   e.  Miscellaneous (e.g., forest fires, structural fires,
       and others)
For each source category identify the descriptive information *
categories about the source (either individual point sources
or area sources) required to estimate the quantity and type
of pollutant it is emitting over the unit time.
The required data about the source usually falls into the
following general categories:
   a.  The identify and location of the source.
   b.  The quantities,  identities, and composition of input
       materials (e.g., fuels, processing materials).
   c.  Information directly related to the process capability
       of the source (e.g., rated capacity in Ibs./hr. and
       burner capacity in BTU/hr. for incinerators, number
       and rated capacity of boilers, process weight for an
       industrial process).
   d.  Production or operating schedules.
   e.  Emission control data (e.g., identity and efficiency of
       control devices, stack description, and emission estimates)
   f.  Type of pollutant emitted.
Identify the specific questions from the above categories which
are relevant for each category of source to be covered.  Also,
    t
identify the manner in which the question should be answered
(i.e., level of detail, units, precision).  In lieu of detailed
knowledge of the source and its potential emissions, a variety
of resource materials can be used as a basis for identifying
the appropriate questions.  These materials fall into four
closely related groupings:
   a.  Materials currently being used by agencies with a
       complete or on-going emission inventory effort.
   b.  Emission factors handbooks.
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       c.  Descriptions of source processes, such as manufacturing
           of sulfuric acid or steel.
       d.  Descriptions of emission control methods and devices.
    It is important to note that the questions to be asked in the
    emission inventory data collection are frequently affected
    by other uses that are intended for the data, including:
       a.  Development of control strategies through modeling
           techniques.
       b.  Identification of sources operating without a required
           permit or otherwise not in compliance with regulations.
                                          X
3.  Develop an emission inventory data collection, verification,  and
    processing system.  In developing this system, include the fol-
    lowing activities:
       a.  Develop a data collection strategy and methodology.
           Decide what general approaches are going to be used to
           collect the raw data for the inventory and which ele-
           ments of the data will be collected with each method.
           The basic collection methods are direct contact  (e.g.,
           telephone conversation or on-site observation) or
           indirect (e.g., mailed data collection forms).  These
           two methods can be used in various combinations  (e.g.,
           initial data collection with mailed forms, followed
           up by a site visit).  The emphasis on one method or
           another depends upon factors such as:
              1)  Degree to which agency already knows the
                  industrial processes and the specific opera-
                  tions of the source (e.g., from their permit
                  system).
              2)  The manpower available to make site visits.
              3)  The quantity of sources within each relevant
                  category.
           After determining which data collection methods will be
           used, construct the data collection forms to be mailed
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    or used In the field.  These forms should convey the
    data collection questions, response requirements, and
    an adequate space for the responses.  Resource materials
    are available to support design of such forms and sur-
    veys.
b.  Identify the suppliers of raw data for the emission
    inventory:
       1)  For point sources, identify all the members of
           each category of sources.
       2)  For area sources, identify agencies or organiza-
           tions which can supply pertinent data (e.g., the
           gas companies and oil distributors can identify
           how much fuel was consumed by residential units
           during the period; airport management can identify
           the number of landings and takeoffs which occurred
           at that facility).
c.  Devise a method for verifying the raw data supplied
    during data collection.  Typically, this element of the
    survey is performed in some combination of the following
    approaches:
       1)  On-site observation of the source by Engineers
           who are knowledgeable of the process.  For a
           description of such an inspection and the as-
           sociated skills and knowledge, see Engineering
           Inspection (Page B-59 ) .
       2)  Telephone contacts to source management to
           verify questionable responses.
       3)  Review of the completed data collection forms in
           the office by Engineers who are knowledgeable
           of the process or who can use source data.
d.  Identify the methods to be used in processing the raw
    data to produce emission estimates.  The procedure most
    typically followed is to utilize published emission factors
    to determine emission levels for a given category of point

                     B-6

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       sources.  Other methods used when emission factors
       are unavailable or inadequate include:
          1)  Materials balance
          2)  Use of local source test findings
          3)  Industry loss estimates data
   e.  Develop a procedure for storage and retrieval of the
       raw data and emission estimates.  For any substantial
       amount of data (depending on the number of sources)
       such a system may require a computer.
Implement the data collection verification and processing
system.  Published emission factors provide the primary basis
for manipulating the raw data to,estimate emissions.  Docu-
mentation covering control device efficiencies are also available.
The major contingencies the Engineer may have to face are:
   a.  No published emission factors available.
   b.  Published control device efficiencies are inadequate
       because the device currently on the source is operating
       below optimum due to age or faulty maintenance.
   c.  Idiosyncratic characteristics of the source process
       call for special attention in applying published
       emission factors (e.g., the effluent is used down-
       stream in the process as a fuel rather than, as is
       typical, immediately vented via the stack).
Calculations required to make emission estimates are typically
performed using a desk calculator or slide rule.
                 i
Prepare the emission inventory data for publication.  This
activity involves elements including:
   a.  Identify the information to be communicated by the
       emission inventory report (e.g., current levels, trends).
   b.  Determine the presentation mode (e.g., tables, graphs,
       charts).
   c.  Define the requirements for and prepare narrative back-
       ground materials.
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Skill Requirements
   1.  Ability to communicate effectively,  orally and in writing,
       with technical personnel (e.g.,  computer operators,  graphic
       artists,  engineering assistants)  and respondents contributing
       to emission inventory data collection.
   2.  Ability to identify and describe  the air contaminants likely
       to be emitted by a unit of basic  equipment.   The description
       should be in terms such as:
          a.   Temperature, volume,  and velocity of the gas
              stream
          b.   Probable particle size  range  and  frequency dis-
              tribution
          c.   Odor
          d.   Chemical composition
          e.   Emission quantity per unit time or process weight
   3.  Ability to accurately apply  or adapt standardized or previously
       used emission inventory characteristics  in identifying and  de-
       scribing  the design characteristics  of a local emission inventory.
       The types of characteristics which will  have to be developed
       include:
          a.   Source categories to  be covered
          b.   Descriptive information to be collected about
              each source
          c.   Descriptive information about the source emissions
       This ability includes skill in discriminating where  and how
       standardized or previously used  inventory characteristics
       should be modified to reflect  local  conditions and information
       needs.
   4.  Ability to interpret regulations  relevant to development of
       an emission inventory.
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5.  Ability to design an Emission inventory data collection veri-
    fication and processing system.
6.  Ability to systematically and effectively solve problems or
    make decisions.  This general skill includes:
       a.  Ability to accurately define the problem in terms
           of objective, desirable outcome.
       b.  Ability to accurately and completely identify the
           elements of the situation which affect selection
           or development of a solution.
       c.  Ability to identify and describe potential solutions
           or approaches for developing solutions.
       d.  Ability to accurately define the relationships be-
           tween these elements and,the alternative solutions
           to the problem.  This includes  "trade-offs."
       e.  Ability to set realistic priorities.
       f.  Ability to estimate with a reasonable level of
           confidence the probabilities of successful solution
           for each alternative solution.
       g.  Ability to maximize positive payoff by selecting the
           most effective and least costly solution.
    Tasks requiring this ability often may have to be accomplished
    under a high degree of time stress and under public scrutiny.
7.  Ability to analyze the basic processes comprising an emission
    source and identify the operations which emit air contaminants
    which should be included or are required in an emission inventory.
8.  Ability to accurately describe or judge the characteristics
    of basic or control equipment required for estimating emissions
    as determined by on-site inspection.  The type of information
    collected and recorded can include:
       a.  Source operation
              1)  Number and type of source operations vented.
              2)  Rate or amount of raw materials used.
              3)  Rate or amount of finished product.
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          4)  Quantity, rate, physical state, and discarge
              point of waste materials.
          5)  Identity of unit operations (e.g., drying,
              melting, size reduction, material movement).
          6)  Description of process flow with points of
              pollutant discharge noted.  .»
          7)  Unit operating schedule.
   b.  Control devices
          1)  Type
          2)  Make and model
          3)  Design efficiency
          4)  Rated capacity
          5)  Installation date
          6)  Mechanical condition and maintenance
   c.  Stack
          1)  Location (within plant or geographic area)
          2)  Height
          3)  Materials
          4)  Type of construction (e.g., self-standing, roof,
              superstructure)
          5)  Availability of ports or openings
   d.  Discharge
          1)  Composition and physical characteristics (e.g.,
              size, shape).
          2)  Daily discharge period (normal and maximum).
          3)  Gas discharge rate and temperature.
          4)  Draft or exhaust type (e.g., forced, induced, natural).
                                                                  !
These data are used back in the office, along with the appropriate
emission factors, to calculate the quantity and type of emission.
                        B-10

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 9.  Ability to make and interpret a basic flow diagram which
     identifies and shows the relationship of the sub-processes
     which comprise an industrial process).
10.  Ability to interpret engineering drawings (e.g.,  plot plans,
     process flow diagrams) in order to plan for an inspection or
     locate and identify equipment in a facility.
11.  Ability to design data collection and data storage forms
     to be used in an emission inventory.
12.  Ability to develop data collection and processing procedures
     to be used in an emission inventory program.
13.  Ability to design "paper flow" systems to handle and store
     necessary documentation.  The system should be responsive to
     the quantity of materials to be handled and the agency's
     ability to utilize state-of-the-art techniques and equipment
     (e.g., microform, computers).
14.  Ability to interact with company management or use company
     records to secure operating information related to emis-
     sions (e.g., type of fuel used, amount consumed per unitg
     time, type and amount of process materials).
15.  Ability to locate, recognize, or describe air pollution con-
     trol devices as used in industrial or commercial facilities.
16.  Ability to assess the degree to which original control device
     efficiency ratings should be reduced or increased to accurately
     reflect its current condition and operating characteristics.
17.  Ability to locate, recognize, or describe the basic units
     of industrial process equipment which are capable of or are
     currently producing uncontrolled or inadequately controlled
     emissions.  Examples of such elements include:
        a.  Refining processes:
               1)  Pressure relief valves
               2)  Pump packing glands and valves
               3)  Vapor recovery systems
               4)  Flares
        b.  Cement plants:
               1)  Rotary drier
               2)  Storage bins
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               3)  Crushing and grinding equipment
               4)  Conveyors
               5)  Loading/unloading facilities
        c.  Metal melting:
               1)  Furnaces (e.g., cupolas,  induction,  reverberatory)
               2)  Casting equipment (centrifugal, die, sand casting)
               3)  Charging equipment
               4)  Sandblasting or cleaning  equipment
18.  Ability to recognize component operations of industrial or
     commercial processes which are being suboptimally  performed,
     thus resulting in or contributing to excessive emissions,
     for example:
        a.  Improper coking operation in a fuel burning process.
        b.  Unbalanced intake and draft air  ratio for cookers
            and driers in a rendering plant.
        c.  Improperly enclosed or ventilated loading,  unloading,
            or storage areas in a cement plant.
        d.  Sloppy housekeeping operations in a rendering plant.
        e.  Inadequate preventative maintenance program for air
            pollution control equipment.
        f.  Improper charge rate, fuel, or excess air in an in-
            cinerator.
19.  Ability to recognize problems for which mathematical models
     are appropriate and cost-effective means of solution.
20.  Ability to use nomographs, tables of data,  special slide rules,
     desk calculators, and other aids in performing required cal-
     culations or data determinations.
21.  Ability to use published emission factors to estimate emissions.
22.  Ability to use materials balance techniques to estimate emissions.
23.  Ability to estimate emission factors when no published factors
     are available.  These estimates will be based on source test

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     findings and engineering assumptions from consideration of
     situational factors including:
        a.  Escape effluent potential
        b.  Efficiency of burning
        c.  Amount of exhaust gas
        d.  Quantities of input materials
        e.  Temperature of operations
24.  Ability to identify and describe the general i.requirements
     for a source test required for a "permit to operate" or for
     acquisition of data for emission inventory.  The elements of
     the test to be specified include:
        a.  Equipment to be tested.
                                  e
        b.  General location of test points.
        c.  Constituents to be measured.
        d.  Operational conditions during which test is to be
            conducted.
25.  Ability to perform test procedures and operate test equipment
     on-site during an inspection.  The test procedures and equip-
     ment used may include:
        a.  Sensitized test papers.  These materials are used to
            test for the following contaminants:
               1)  Ammonia
               2)  Arsine
               3) , Hydrogen Sulfide
               4)  Phosgene
        b.   Squeeze Bulb Type Gas  Testers.  This device gives colorimetric
            reactions to the following contaminants:
               1)  Benzine
               2)  Toluene
               3)  Xylene
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               4)  Carbon Monoxide
               5)  Hydrogen Cyanide
               6)  Hydrogen Sulfide
               7)  Sulfur Dioxide
        c.  Tutweiler Apparatus.  This device uses gas/liquid titra-
            tions to determine the concentrations of the following
            contaminants in stack gases:
               1)  Hydrogen Sulfide
               2)  Sulfur Dioxide
               3)  Ammonia
               4)  Carbon Dioxide
        d.  Hilo Bromine Field Test Equipment
        e.  Midget Impinger and Gas Adsorption Cell
        f.  Halide Leak Detector
        g.  Explosimeters or Combustion Meters
        h.  Sling Psychrometer
        i.  Sword Pyrometer
26.  Ability to determine whether a control device is operating
     properly (e.g., reaching design efficiency) by visual inspec-
     tion of situational elements, including:
        a.  Extent and type of emissions
        b.  Operational sensors and monitoring equipment (e.g.,
            pressure gauges, rotameters)
        c.  Observable physical characteristics of the equipment
            (e.g., rust, corrosion)
27.  Ability to use agency files, source process data, and other
     methods to develop the appropriate background data to initiate
     an inspection of a stationary scmrce.
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  28.  Ability to prepare t>r supervise preparation of the narrative
       portions of an emission inventory report.

Knowledge Requirements

   1.  Background knowledge of source processes complete enough to
       support identification of the elements of the process which
       are likely to emit contaminants to the atmosphere if not
       adequately controlled (e.g., in petroleum refining:   regenera-
       tion, combustion, compression, storage, and pumping).  Also,
       knowledge of the parameters of each of these process elements
       which affect the quantity and type of emissions possible.
       This type of knowledge is available to a useful extent in
       documents of the following types:
                                    e
          a.  Materials currently being used by agencies with a
              complete or on-going emission inventory effort.
          b.  Emission Factors handbooks (for example, References
              4, 17, 18, and 23).
          c.  Descriptions of source processes, such as manufactur-
              ing of sulfuric acid or steel (for example, References 2,
              3, 5, 6, 7, 11, 15, 16, 25, 26, 27, 28, and 36.
          d.  Descriptions of emission control methods and devices
              (for example, References 19, 20, and 21).
       Another source of this type of knowledge is work experience
       in the process area with emphasis on process design, opera-
       tion, or air pollution control.
   2.  Knowledge of (the relevant state-of-the-art in design of basic
       equipment for air pollution control (e.g., controlled air
       incinerators).
   3.  Knowledge of the jargon and terminology used by operators  or
       management of the basic or control equipment being inspected
       or reviewed.  This type of knowledge enables the inspector or
       reviewer to adequately describe his findings and to communi-
       cate with other knowledgeable individuals.  For relevant
       References, see Knowledge 9.

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A,  Knowledge of the specific practices and processes of the type
    of industry being inspected or reviewed which may contribute
    to air pollution, for example:
       a.  In a refinery, rattling and blowing coke from
           cracking tubes.
       b.  In metal melting, the air pollution effects of
           efforts to remove metal impurities during the melt
           process.
       c.  In a rendering plant, housekeeping problems which
           produce odor, such as fat accumulation inside hoods.
    For relevant References, see Knowledge 9.
5.  Knowledge of the sub-processes within the plant being inspected
    or reviewed which have the highest potential pollution effects.
    For example, in a refinery:
       a.  Fluid Catalytic Cracking
       b.  Isomerization
       c.  Crude Distillation
    For relevant References, see Knowledge 9.
6.  Knowledge of the operating principles of air pollution control
    equipment used at the facility to be included in the emission
    inventory.  The types of devices used can be-specialized
    according to the process they are controlling.  Examples of
    such specialized devices are:
       a.  Flares
       b.  Loading rack separators
       c.  Sulfur recovery plants
    Examples of less process-specific control devices include:
       a.  Baghouses
       b.  Scrubbers
       c.  Cyclone separators
       d.  Electrostatic precipitators
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    For relevant References, see Knowledge 9.
7.  Knowledge of the methods used to determine if pollution control
    devices are operating properly.  In addition to visual emission
    evaluation, the Engineer should know how to read and evaluate
    data relevant to pollution control from devices such as:
       a.  Chart recorders
       b.  Manometers
       c.  Pressure gauges
       d.  Rotameters
       e.  Flowmetexs
       f.  Ohmmeters
       g.  Voltmeters            e
    Also, the Engineer should know what physical characteristics of
    deterioration indicate that  the control device is operating
    below maximum capability.  These characteristics include:
       a.  Leaking or missing bags in a baghouse.
       b.  Corroded metal plates, baffles, and spray heads in
           a scrubber.
       c.  Heavily-coated grids  and plates in a precipitator.
    For relevant References, see Knowledge 9.
8.  Knowledge of the operating principles and uses of specific
    equipment within an industrial or commercial process  (e.g.,
    fractionating towers and bubble trays in a refinery).  For
    relevant References, see Knowledge 9.
9.  Knowledge of the chemical and physical properties of materials
    used in the process being inspected or reviewed which, have an
    effect on emissions and possible air pollution.  Basic resource
    information is available from publications of the following
    types:
       a.  Emission factors handbooks - see References in
           Knowledge Ib.

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        b.  Descriptions of source processes with emphasis
            on their pollution potential - see References
            in Knowledge lc.
        c.  Air pollution engineering guidelines - Reference 7.
        d.  Air pollution control technology - References 8,
            14, 19, 20, and 21.
        e.  Local recommended codes of practice - References 29,
            30, 31, 32, 33, 34, and 40.
10.  Knowledge of systematic approaches which are useful for prob-
     lem solving and planning of work activities (e.g., the ''systems"
     approach to design).
11.  Knowledge of agency regulations and enabling legislation,
     particularly those sections which provide a legal basis for
     conduct of the emission inventory.  This knowledge will be
     useful in coping with uncooperative or otherwise trouble-
     some respondents.
12.  Knowledge of the uses of data which can be collected as part
     of an emission inventory and which are required or useful for
     other areas of agency activity, such as enforcement, plan re-
     view, and regulation development.
13.  Knowledge of the resource documentation available which recom-
     mends or illustrates  the format and content of an emission
     inventory (e.g., References 1, 10, 22, and 23).
14.  Knowledge of the criteria for an effective and complete emis-
     sion inventory.
15.  Knowledge of representative data collection, verification, and
     processing systems that have been used or are currently being
     used in emission inventory projects.  Also, knowledge of each
     system's relative merits, weaknesses, and the reasons for these
     conditions.
16.  Knowledge of the basic procedures used in estimating source
     emissions from information describing the process, its pro-
     duction rates, production schedules, types of contaminants
                              B-18

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     emitted, or the emission control devices currently in service
     or proposed.  These procedures should include use of emission
     factors, materials balance, and source test findings.  For
     relevant References, see Knowledge Ib.
17.  Knowledge of materials balance procedures for estimating
     emissions.
18.  Knowledge of source testing procedures at a level of detail
     which enables the Engineer to establish the requirements for,
     participate in, and evaluate the findings of the tests.
     References  9, 12, 13, 35, 37, and 38 have been used in this
     area.
19.  Knowledge of the recommended methods for soliciting coopera-
     tion, assistance, and operating information from the operators
     or managers of units to be included in an emission inventory.
20.  Knowledge of the procedures for preparation of flow diagrams
     of industrial processes.
21.  Knowledge of the types of errors that are made by respondents
     in completing the emission inventory- data collection forms and
     the appropriate techniques for correcting these errors.  Typical
     types of errors include:
        a.  Data expressed in incorrect units
        b.  Omissions
        c.  Respondent thinks item does not apply to him when it
            does
        d.  Underestimates or overestimates of data, such as
            process weight, productivity
        e.  Inconsistencies between necessarily related items
             (e.g., quantity of input materials and exhaust volume)
     Some of the above errors can be corrected using resource documents
     (e.g., Reference 11) while others require direct contact with the
     operator of the source.
22.  Knowledge of the techniques for the design of data collection
     forms to be mailed to sources or used in the field by agency
     personnel (see Reference 24).
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  23.  Knowledge of "systems design'1 methods to be used in development
       of "paper flow" systems.
  24.  Knowledge of the suppliers of general information required for
       estimating the emissions of area sources (e.g., fuel suppliers,
       relevant census records) and point sources (e.g., industrial
       and trade associations).
  25.  Knowledge of the content of and use of specific data tables,
       graphs, nomographs, and specialized slide rules available to
       support design, calculations and evaluations of basic, control,
       or ventilation equipment (e.g., the Exhaust System Calculator
       and Fan Curve Calculator used at Los Angeles APCD and referred
       to in Reference 7,  pages 48 and 57).
  26.  Knowledge of the accepted techniques for planning and present-
       ing written or spoken communications, such as technical reports,
       public presentations, and formal correspondence.

References
   1.  Air Pollution Control District.   Profile of air pollution control.
        Los Angeles:   County of Los Angeles, 1971.
   2.  Air Pollution Sub-Committee.   Odor control manual for the render-
        ing industry.   Des Plaines,  Illinois:  National Renderers Associa-
        tion, January 1969.
   3,  Committee on Industrial Hygiene.  Steel mill ventilation.  New York:
        American Iron and Steel Institute, May 1965.
   4.  Control Agency Directors S-8 Committee.   Pacific northwest emission
        factors reference manual.   Air Pollution Control Association,
        Pacific Northwest International Section, April 1971.
   5.  Cooperative Study Project,  Manufacturing Chemists' Association
        and Public Health Service.  Atmospheric emissions from sulfuric
        acid manufacturing processes.  Durham, North Carolina:  U. S.
        Department of Health, Education, and Welfare; Public Health
        Service, Environmental Health Service, National Air Pollution
        Control Administration, 1965.  PHSP #999-AP-13.
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 6.   Cuffe, S. T., and Gerstle, R. W.  Emissions from coal-fired
      power plants:  a comprehensive summary.  Durham, North Carolina:
      U. S. Department of Health, Education, and Welfare;  Public
      Health Service, Consumer Protection and Environmental Health
      Service, National Air Pollution Control Administration, 1967.
      PHSP #999-AP-35.
 7.   Danielson, J. A. (Ed.)  Air pollution engineering manual.  Air
      Pollution Control District, County of Los Angeles.  Cincinnati,
      Ohio:  U. S. Department of Health, Education, and Welfare;
      Public Health Service, Bureau of Disease Prevention Environ-
      mental Control, National Center for Air Pollution Control, 1967.
 8.   Decker, L. D.  Odor control by incinerator.  Greenwich, Con-
      necticut:  UOP Air Correction Division, November 1965.  (Text
      of a talk given before a meeting of the Middle States Section
      of the Air Pollution Control Assn., Wilmington, Delaware,
      November 1965,)
 9.   Duffee, R. A.  Appraisal of odor-measurement techniques.  Journal
      of the Air Pollution Control Association, _7:472-474.  July 1968,
      Vol. 18.
10.   Environmental Protection Agency.  Requirements for Preparation,
      adoption, and submittal of implementation plans.  Appendices
      D, E, and F.  Federal Register, V. 36, No. 158, Saturday,
      August 14, 1971.
11.   Gulf Publishing Co.  Hydrocarbon Processing Handbook.  Houston,
      Texas:  Box 2608, 77001.
12.   Haaland, H. H. (Ed.)  Methods for determination of velocity,
      dust and mist content of gases.  Bulletin WP-50.  Seventh
      Edition.  Los Angeles:  Western Precipitation Division/Joy
      Manufacturing Company, 1968.
13.   Huey, N. A., Broering, L. C., Jutze, G. A., & Gruber, C. W.
      Objective odor pollution control investigations.  Journal of
      the Air Pollution Control Association, 6^:441-444.  December
      1960, Vol. 10.
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14.  Ingels, R. M.  The afterburner route to pollution control.
      Air Engineering, June 1964.
15.  Kreichelt, T. E., Kemnitz, D. A., and Cuffe, S. T.  Atmos-
      pheric emissions from the manufacture of portland cement.
      Cincinnati, Ohio:  U. S. Department of Health, Education,
      and Welfare; Public Health Service, Bureau of Disease Pre-
      vention and Environmental Control, 1967.  PHSP //999-AP-17.
16.  McGannon, H. E. (Ed.)  The making, shaping and treating of
      steel.  Eighth Edition.  United States Steel Corporation.
17.  McGraw, M. J., & Duprey, R. L.   Compilation of air pollutant
      emission factors.  Preliminary document.  Research Triangle
      Park,  North Carolina:  Environmental Protection Agency,
      April 1971.
18.  National Air Pollution Control Administration.  Air pollutant
      emission factors.  Washington, D. C.:   Department of Health,
      Education, and Welfare; Public Health Service, Environmental
      Health Service, April 1970.
19.  National Air Pollution Control Administration.  Control tech-
      niques for hydrocarbon and organic solvent emissions from
      stationary sources.  Washington, D. C.  U. S. Department of
      Health, Education,  and Welfare;  Public Health Service,
      Environmental Health Service,  March 1970.  No. AP-68.
20.  National Air Pollution Control Administration.  Control tech-
      niques for partjculate air pollutants.  Washington, D. C.:
      U. S.  Department of Health, Education, and Welfare; Public
      Health Service, Consumer Protection and Environmental Health
      Service, January 1969.
21.  National Air Pollution Control Administration.  Control tech-
      niques for sulfur oxide air pollutants.  Washington, D. C.:
      U. S.  Department of Health, Education, and Welfare; Public
      Health Service, Environmental Health Service, January 1969.
22.  National Air Pollution Control Administration.  Nationwide
      inventory of air pollutant emissions, 1968.  Raleigh,
      North Carolina:  U. S. Department of Health, Education,
                              B-22

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      and Welfare; Public Health Service, Environmental Health
      Service, August 1970.
23,  Ozolins, Guntis, & Smith, Raymond.  A rapid survey technique
      for estimating community air pollution emissions.  PHSP #999-
      AP-29, October 1966.
24.  Payne, S. L.  The art of asking questions.  Princeton, New
      Jersey:  Princeton University Press, 1951.
25.  Schueneman, J. J., High, M. D., & Bye, W. E.  Air pollution
      aspects of the iron and steel industry.  Cincinnati, Ohio:
      U. S. Department of Health, Education, and Welfare; Public
      Health Service, Division of Air Pollution, June 1963.
26«  Smith, W. S.  Atmospheric emissions from fuel oil combustion.
      An inventory guide.  Cincinnati, Ohio:  U. S. Department of
      Health, Education, and Welfare; Public Health Service, Division
      of Air Pollution, November 1962.  PHSP #999-AP-2.
27.  Swearingen, J. S., and Levin, H.  Hydrocarbon losses from the
      petroleum industry in L. A. County.  San Antonio, Texas:
      Southwest Research. Institute.
28.  Technical Advisory Board.  Code of recommended practices.  Asphalt
      mixing plants.  Chicago:  City of Chicago, Department of Environ-
      mental Control, April 1971.
29.  Technical Advisory Board.  Code of recommended practices.  Fuel
      burning equipment for heating, steam and hot water generation,
      absorption refrigeration.  Chicago:  City of Chicago, Department
      of Environmental Control, October 1968.
30.  Technical Advisory Board.  Code of recommended practices.- Grain
      handling and storage.  Chicago:  City of Chicago, Department of
      Environmental Control, April 1971.
31.  Technical Advisory Board.  Code of recommended practices.  Refuse
      burning equipment for domestic and non-domestic use.  Chicago:
      City of Chicago.  Department of Environmental Control, April
      1971.
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     32.  Technical Advisory Board.   Code of recommended practices.   Ren-
           dering processes.  Chicago:  City of Chicago, Department  of
           Environmental Control,  April 1971.
     33.  Technical Advisory Board.   Code of recommended practices.   Spray
           booths.  Chicago:  City of Chicago,  Department of Air Pollution
           Control, August 1968.
     34.  U.  S.  Department of Health, Education,  and Welfare.  Interim guide
           of good practice for incineration at federal facilities.  Raleigh,
           North Carolina:  Public Health Service,  Consumer Protection
           and Environmental Health Service, National Air Pollution  Control
           Administration, November 1969.  No.  AP-46.
     35.  U.  S.  Department of Health, Education,  and Welfare.  Specifica-
           tions for incinerator testing at federal facilities.  Durham,
           North Carolina:  Public Health Service,  Bureau of Disease
           Prevention and Environmental Control,  National Center for
           Air Pollution Control,  Abatement Program, October 1967.
     36.  U.  S.  Department of Health, Education,  and Welfare; Public
           Health Service, Division of Air Pollution.  Atmospheric
           emissions from petroleum refineries.  A guide for measure-
           ment  and control.  PHSP #763, 1960.
     37.  Ward,  F. R.  Odor measurement with the Scentometer.  Norfolk,
           Virginia:  Odor Control Subcommittee,  Industrial Standards
           Committee, National Renderers Association.
     38.  Wohlers, H. C.  Recommended procedures for measuring odorous
           contaminants in the field.  Journal of the Air Pollution
           Control Association, 9^:609-612.  September 1967, Vol. 17.

Special Staffing Guidance
The Engineer assigned to developing the emission inventory should have at
least five years' experience working in air pollution control engineering
areas, including:
   1.  Engineering inspections
   2.  Plan review, permit processing
   3.  Emission estimation
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The assignee should have detailed knowledge of the types of commercial,
industrial, and public pollution sources within the geographic area
to be covered by the inventory.
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                       Reception and Preliminary
                       Screening of Plan Review/
                      Permit System Applications
                       and Supporting Materials
Task Overview
Most agencies operating a permit system require applicants to submit com-
pleted forms and specific types of materials  (e.g., plans, specifications)
which will support evaluation of the planned  equipment.  In processing
these data, it is necessary to assure  that the preliminary materials sub-
mitted by the applicant are complete and accurate enough to support plan
review operations.  Also, someone must be available to describe and explain
the plan review function to applicants or potential applicants and to
answer their questions.

Occupational Category;  Engineering Technician

   Task Description
      1.  Receive application for permit to construct/install.  Receiving
          the application entails the  following activities:
             a.  Interpret the agency  regulations with regard to areas
                 such as who should apply, how to apply, what equipment
                 or equipment changes  require a permit, the conditions of
                 acceptability or denial, and the recourse in cases of
                 denial.
             b.  Administer and explain the fee system.
             c.  Distribute required application forms.
      2.  Review input data (i.e., forms, plans, drawings) to determine if
          they are complete and adequate for  the evaluation.  In the case
          of forms, see that all blanks are filled in as required.  Assure
          that the required plans and  drawings are provided and that the
          level of detail is appropriate.
      3.  Contact the applicant and request all missing input data required
          for the evaluation.
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    4.  When  application  file is complete and accurate enough to
       support  the initial elements of the plan review operation,
       route the materials to the appropriate engineering personnel
       for further processing.

Skill Requirements
   1.  Ability to interpret regulations regarding administration of
       the plan review/permit system including:
          a.   Discriminating which types  of equipment must apply
              and which are exempt.
          b.   Accurately applying emission standards, equipment
              design criteria,  and other  control regulations.
          c.   Establishing the appropriate fee for both simple and
              complex configurations of basic or control equipment.
   2.  Ability to answer applicant's questions and present information
       to them concerning the technical and administrative requirements
       of the plan review/permit system.
   3.  Ability to accurately and quickly  make calculations required
       to compute plan review/permit application fees.
   4.  Ability to make an initial determination of the completeness
       and adequacy of the application forms, plans, and drawings
       submitted by an applicant to plan  review/permit processing.
       This includes ability to identify  what additional data are
       required.

Knowledge Requirements
   1.  General knowledge of the goals and procedures of the plan
       review/permit system.
   2.  Knowledge of the general administrative and technical require-
       ments for initially processing applications and supporting material
       in a plan review system.  This would include knowledge of the types
       of equipment requiring a permit, requirements for supporting de-
       scriptive information, fees, and procedures and guidelines for
       communication with applicants.  The information to support this
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       knowledge is typically agency-specific and is provided to a
       limited extent in the agency's regulations.  References 1
       and 2 provide useful background information in this area.
   3.  Specific knowledge of the types of supporting information
       required to be submitted by a permit applicant to fully pro-
       cess a particular class of basic equipment, control equipment,
       or ventilation system.
   4.  Knowledge of the local regulations which directly or indirectly
       relate to administration of a plan review system.  Specifically,
       knowledge of all the prohibitions and controls provided for in
       the agency's regulations.  These typically include:
          a.  Limitations on visible emissions (opacity and density).
          b.  Limitations on the quantity of particulates, dusts and
                                 t
              fumes, specific gaseous compounds, combustion contami-
              nants, and organic compounds.
          c.  Rules specifying control requirements for petroleum
              products, storage tanks, and rendering equipment.
          d.  Specifications of sulfur content of fuels, photochemical
              reactivity, status of organic solvents.
          e.  Prohibitions on public nuisances, open burning, and single-
              chamber incinerators.
   5.  Knowledge of the procedures for routing completed files to
       plan review personnel for further processing.

References
   1.  Lunche, R). G., Lemke, E. E., & Verssen, J. A.  Administration of
        a permit system.  Paper 68-112 presented at the 61st Annual
        Meeting of the Air Pollution Control Association.  Los Angeles:
        Los Angeles Air Pollution Control District, June 1968.
   2.  Lunche, R. G., Lemke, E. E., Weimer, R. L., Dorsey, J. R., &
        Verssen, J. A. (Ed.)  Administration of the permit system.
        Fourth Edition.  Los Angeles:  Air Pollution Control District,
        County of Los Angeles, January 1968.

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Special Staffing Guidance
The assignee for this task can be a junior level individual; however, his
training should emphasize effective response to applicants'  questions.

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                 Review of Plans and Application Forms
                    in a Plan Review/Permit System
Task Overview
The Engineer's task in reviewing plans and a permit application is to
determine whether the proposed equipment  (controlled or uncontrolled)
will be in compliance with local source emission standards or other
regulations designed to control ambient air quality.  Separate permits
are usually required to construct or install equipment and to operate
it.  The Engineer's judgments are based upon technical data supplied on
and with the permit application forms, as a result of on-site observations,
from resource documentation, and from direct contact with applicants, con-
tractors, or vendors.
Generally, the equipment submitted  for evaluation in plan review comprises
a system containing the following elements:
   • the basic equipment - a single unit  or a complex of equipment
     capable of emitting contaminants into the atmosphere.
   • an exhaust system typically containing a hood, ducts, and an
     exhaust fan.
   • an air pollution control device suggested as a means of bringing
     the basic equipment into compliance with relevant local regulations.
The objective of the review is to systematically evaluate the proposed
system or any of the elements within it with regard to effective pollution
control.
Plan review and permit systems vary in detail from agency to agency.  The
major differences between agencies  are in details such as the scope of
the program (i. e., the range of equipment covered), the content of ap-
plication forms, the specific administrative procedures followed, and
the scope and specificity of regulations.  However, the basic task of
reviewing the permit application materials presented below is indicative
of the skills and knowledge required to perform the operation within most
of the specific systems currently in use.
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Occupational Category:  Engineer
   Task Description
      1.  Briefly scan the input data (application forms,  specifications,
          plans)  and characterize the general review problem in terms of
          the following factors:
             a.   The type of basic equipment to be reviewed.
             b.   The probable air contaminants emitted by  the basic
                 equipment.
             c.   The specific regulations and requirements relevant to
                 the equipment.
             d.   The overall design of the exhaust system  and its impact
                 on the effectiveness of the pollution control device.
             e.   The type of control device proposed and its general
                 appropriateness to the basic equipment, emitted con-
                 taminants,  exhaust system, and relevant regulations.
      2.  Using  relevant design  criteria, emission factors,  and the
          descriptive data provided by the applicant, evaluate the
          adequacy of the proposed basic equipment.  Determine whether
          or not  an air pollution control device is required by comparing
          estimated emissions with the appropriate local regulations.
          In the  case of certain types of basic equipment  (e.g., incinera-
          tors, boilers) this step involves a detailed examination of the
          proposed equipment. For example, in evaluating  an incinerator
          design, application materials (in the form of specifications and
          drawings) typically include the following types  of information:
             a.   Make, model, type.
             b.   Configurational specifications (e.g., interior and
                 exterior dimensions, construction materials, chamber
                 design, and descriptions of the dampers,  sensors, burners,
                 and stack).
             c.   Intended use (e.g., type of waste, amounts to burned,
                 intended schedule of use).
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    To evaluate the adequacy of the incinerator, compare the infor-
    mation given in the above categories with the relevant local
    standards and requirements.  In addition, use the above data to
    derive (or verify, if already provided by the applicant) specific
    performance characteristics and compare them with requirements.
    The characteristics typically include:
       a.  Calculate heat release in primary chamber from volume
           of chamber and total BTU input to chamber.
                                          2
       b.  Determine whether the BTU/hr/ft  capacity is great
           enough that the gases in the primary and secondary
           chambers will reach criterion values.
       c.  Determine burning rate per square foot of grate area.
       d.  Compute velocity of combustion gases through selected
           cross-sectional areas assuming given levels of excess
           air.
       e.  Determine retention time.
       f.  Determine adequacy of barometric damper free area.
       g.  Determine adequacy of burning area in terms of hearth.
           size, hours per day burning, service requirements.
       h.  Predict emission characteristics  (e.g., smoke density,
           opacity, odor).
       i.  Calculate retention time.
3.  Evaluate the effectiveness of the process exhaust or ventilation
    system.  The objective of this system is to capture contaminants
    (e.g., dusts and fumes) at their source, move them to the pol-
    lution  control device, and then expel the cleansed gas stream
    into the atmosphere via the stack.  The ventilation system usually
    consists of the following elements:
       a.  The hood
       b.  The duct network
       c.  The exhaust fan
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To evaluate the ventilation system review each of the above
elements with regard to the source process and its associated
contaminants.
   a.  Use standardized ventilation design principles, procedures,
       and resource data to determine hood requirements, including:
          1)   Hood configuration (i.e.,  location, shape, size)
          2)   Hood construction materials (consider the need
              to resist high temperature or corrosive effluent)
          3)   Capture velocity
          4)   Face velocity
          5)   Slot velocity (if a slot hood is suggested)
          6)   Plenum velocity
          7)   Duct velocity
          8)   Transport velocity
       Compare findings with prescribed  hood design and determine
       whether differences are acceptable.
   b.  Use standardized ventilation design principles, procedures,
       and resource data to determine duct design characteristics,
       including:
          1)   Desired air volume.
          2)   Minimum duct velocity.
          3)   Duct network configuration (lengths, special
              fittings, elbows).
          4)   Pressure losses due to the components of the
              system including the pollution control devices
              (i.e., the system's static pressure).
          5)   Construction materials requirements.
       Compare findings to suggested design and evaluate adequacy
       of the differences.
   c.  Use standardized principles, procedures, and resource
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           data to specify the operating point of the ventilation
           system.  Consider factors such as:
              1)  Fan type (e.g., axial flow, centrifugal, air
                  inj ector).
              2)  Fan size, speed, horsepower requirements (use
                  Fan Rating Tables), and system operating charac-
                  teristic curves.
              3)  System operating volume and static pressure.
4.  Identify and describe the specific contaminants to be collected
    by the control device.  The description should be specific enough
    that the relative advantages and disadvantages of particular
    types of control devices can be determined and weighed.  Attend
    to descriptive dimensions including:
       a.  Temperature, volume, and velocity of the gas stream
       b.  Probable particle size range and frequency distribution
       c.  Odor
       d.  Chemical composition of the effluent
       e.  Emission quantity per unit time
5.  Decide whether or not the general type of control device(s)
    (e.g., baghouse, wet scrubber) selected by the applicant is
    well-suited to the characteristics of the contaminants de-
    scribed in the previous step.  If the applicant's choice is
    inferior to some other type of device, make note of the more
    desirable selection and the rationale for that judgment.  In
    making the judgment consider factors including:
       a.  Efficiency as a function of particle size and weight.
       b.  Possible physical or chemical attack by the contaminant
           on the device (including impairment of function due to
           moisture, poisoning of catalysts).
       c.  Possibility of transforming the pollution problem rather
           than solving it completely (e.g., creating a water pollu-
           tion problem as a result of treating an air contaminant,
           or creating an odor problem with the collection device).

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       d.  Only partially eliminating the pollution problem
           (e.g., cleaning the particulate element of the
           effluent without treating the odorous element).
6.  In the case where the suggested type of control device(s)
    is a type suited to the problem, identify the key parameters
    of the device's design which are relevant to its efficiency
    and effectiveness.  For example:
       a.  Afterburners
              1)  Type (thermal vs. catalytic).
              2)  Products of combustion.  That is, what will the
                  effluent of the afterburner be?  Will it be
                  odorous?
              3)  Retention time in combustion chamber.
              4)  Turbulence (thoroughness of mixing).
              5)  Temperature required to oxidize contaminant.
              6)  Catalyst/contaminant interaction.
              7)  Pressure drop.
              8)  Fuel requirements.
       b.  Baghouses
              1)  Air-to-cloth, ratio
              2)  Inlet temperature
              3)  Dew point temperature
              4)  Type of filtering media (particularly its
                  susceptibility to chemical attack)
              5)  Sensors to detect changes in pressure drop
              6)  Bag cleaning method and cleaning cycle
              7)  Construction characteristics (e.g., hopper
                  size)
              8)  Particle size frequency distribution
       c.  Adsorption equipment
              1)  Suggested adsorbent
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              2)  Saturation rate of the adsorbent
              3)  Retentivity of adsorbent
              4)  Regeneration characteristics of the adsorbent
              5)  Number of adsorbent beds
7.  Evaluate the suggested cleaning device on each of the key parame-
    ters identified in the preceding step.  This is done by a variety
    of methods, including:
       a.  In the case of some parameters (e.g., retention time
           in an afterburner), calculate the value required for
           acceptable efficiency and compare it with the value
           given for that parameter in the suggested device.  If
           the parameter value is not defined by the applicant,
           determine it by contacting the manufacturer, vendor,
           or contractor.
       b.  Directly compare the stated characteristic of the sug-
           gested device with accepted design criteria  (e.g.,
           air-to-cloth ratio in a baghouse, temperature in the
           combustion chamber of an afterburner).
       c.  Use historical data (e.g., results of source tests)
           to predict the suggested device's effectiveness.
8.  Where relevant (i.e., the issue is in doubt) estimate the level
    of emissions with the suggested control device installed.  Use
    process descriptive data filed by the applicant, documented
    efficiency data, and emission factors.  Compare the results
    with relevant local regulations.
9.  Identify any process or control device operating conditions
    which should be modified or maintained in order to sustain
    maximum control device effectiveness.  Such conditions include:
       a.  Minimum afterburner temperature.
       b.  Minimum water quantity per unit time within a given
           pressure range to be supplied to a scrubber.
       c.  Limit on the amount of fines (per unit time) used in.
           a drying process.

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10.  If the suggested control device is acceptable in terms of its
     design and effectiveness, grant a permit to construct.  Incor-
     porate any conditions deemed relevant to initial or continuing
     effectiveness of the device(s).
11.  If the suggested device is found to be unacceptable follow the
     procedure for permit denial.   This usually entails contacting
     the applicant, communicating the reasons for the denial, and
     informing him of the appeal procedure.
12.  If a permit denial is contested, prepare a presentation justi-
     fying the denial action and testify before the hearing body.
13.  In the case of an acceptable application, make a visual inspec-
     tion of the completed installation to assure that the equipment
     installed matches that for which the permit was granted.  Pre-
     pare any required reports of findings.  See Page B-59 for
     a complete description of the Engineering Inspection (used in
     Plan Review)  task and the associated skills and knowledge.
14.  Identify source test requirements, assist in tect administration,
     and evaluate  source test findings prior to granting a permit to
     operate the new equipment.
        a.   In determining source test requirements identify items
            such as:
               1)   Basic equipment and control equipment to be
                   tested.
               2)   Points to be tested (e.g., afterburner inlet
                   and outlet).
                   If possible, locate test ports on relevant draw-
                   ing.   Assure that ports are the proper size.
               3)   Constituents to be measured (e.g., total carbon
                   analysis).
               4)   Operational conditions during which test should
                   be conducted.  Tests should be run during 'periods
                   in the process in which emissions are the greatest
                   (e.g., during the oxygen blow on an electric fur-
                   nace) .

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               5)  Assure that "safe access" is provided.
        b.  In assisting the source test team:
               1)  Assure that the operation performed during the
                   test is specifically the one selected for obser-
                   vation (i.e., when emissions are expected to be
                   greatest).  This could include verifying operating
                   conditions such as charging rates, composition of
                   input materials, and level of dilution air used.
               2)  Evaluate visible emissions (opacity and density).
               3)  Suggest operational modifications which might
                   improve operation of basic equipment or control
                   equipment.  For example, in testing a smoking
                   incinerator,, adjustments to the charge rate,
                   fuel, and air might be suggested in order to
                   reduce emissions.  These adjustments could then
                   become "conditions'1 of operation required for
                   the permit.
        c.  In evaluating the source test findings, consider items
            such as the following:
               1)  Were the proper operating conditions, observed?
               2)  Is a materials balance indicated?
               3)  Were the parameters of control device design
                   and performance as expected (e.g., pressure
                   drop, retention time, filter velocity, efficiency)?
               4)  Is level of emission in compliance with relevant
               1   regulations?
               i
15.  If source test results show full compliance, grant a permit to
     operate the new equipment.  Incorporate all standard and special
     purpose conditions required to assure continued acceptable per-
     formance .
16.  In the case of a denial, follow the appropriate procedu.-e for
     informing the applicant of the situation and his recourse.
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  17.  Prepare a statement of the fees required.  Fees are typically
       calculated on the basis of energy,  power, or capacity associated
       with the equipment to which the permit applies.

Skill Requirements
   1.  Ability to answer applicant's questions and present information
       to them concerning the technical and administrative requirements
       of the plan review/permit system.
   2.  Ability to interpret regulations regarding administration of
       the plan review/permit system including:
          a.   Discriminating which types  of equipment must apply
              and which are exempt.
          b.   Accurately applying emission standards, equipment de-
              sign criteria, and other control regulations.
          c.   Establishing the appropriate fee for both simple and
              complex configurations of basic or control equipment.
   3.  Ability to accurately and quickly make calculations required
       to compute plan review/permit application fees.
   4.  Ability to interpret engineering drawings for detailed evalua-
       tion of basic equipment, ventilation systems, or control systems,
       The types of drawings reviewed include:
          a.   Assembly drawings (in plan and elevation)
          b.   Equipment location drawings
          c.   Plot plans
          d.   Process flow diagrams
   5.  Ability to briefly scan the plan review/permit process input
       data (application forms, drawings,  etc.)  and to initially char-
       acterize the general review problem in terms of the following
       factors:
          a.   The type of basic equipment to be reviewed.
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       b.  The probable air contaminants emitted by the basic
           equipment.
       c.  The specific regulations and requirements relevant to
           the equipment.
       d.  The overall design of the exhaust system and its impact
           on the effectiveness of the pollution control device.
       e.  The type of control device proposed and its general
           appropriateness to the basic equipment, emitted con-
           taminants,  exhaust system, and relevant regulations.
6.  Ability to recognize the component operations of industrial
    or commercial processes which are being suboptimally performed,
    thus resulting in or contributing to excessive emissions, for
    example:
                             t
       a.  Improper coking operation in a fuel burning process.
       b.  Unbalanced intake and draft air ratio for cookers
           and driers in a rendering plant.
       c.  Improperly enclosed or ventilated loading, unloading,
           or storage areas in a cement plant.
       d.  Sloppy housekeeping operations in a rendering plant.
       e.  Inadequate preventative maintenance program for air
           pollution control equipment.
       f.  Improper charge rate, fuel, or excess air in an inciner-
           ator.
7.  Ability to apply the appropriate standard engineering analyses,
    principles, and resource data to the evaluation of the proposed
    basic equipment, ventilation system, or control device using
    the agency's plan review/permit processing procedures.
8.  Ability to predict how the load requirements on a control
    device will change with time, so that designs can be selected
    which have the greatest productive longevity.  For example,
    predict how waste material likely to be consumed in a incinera-
    tor will change, such as an increase in plastics.
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 9.  In evaluating basic, control, or ventilation equipment, the
     ability to recognize trade-offs.  That is, the design of a
     piece of equipment may lack one desirable characteristic but
     be able to make up for it with another characteristic.  For
     example, if agglomeration is likely in a particular baghouse
     installation, shaking techniques and cycle may be judged
     adequate to counter the caking effect of the effluent.  Also,
     in an incinerator, if velocity through the flame port is too
     great (causing excessive turbulence), this can possibly be
     compensated for with increased downpass velocity.
10.  Ability to use published emission factors to estimate emissions.
11.  Ability to use materials balance techniques to estimate emissions,
12.  Ability to estimate emission factors when no published factors
     are available.  These estimates will be based on source test
     findings and engineering assumptions from consideration of
     situational factors such as:
        a.  Escape effluent potential
        b.  Efficiency of burning
        c.  Amount of exhaust gas
        d.  Quantities of input materials
        e.  Temperature of operations
13.  Ability to use nomographs, tables of data, special slide rules,
     desk calculators, and other aids in performing required calcu-
     lations or data determinations.
14.  Ability to identify and describe the air contaminants likely
     to be emitted by a unit of basic equipment.  The description
     should be in terms such as:
        a.  Temperature, volume, and velocity of the gas stream
        b.  Probable particle size range and frequency distribution
        c.  Odor
        d.  Chemical composition
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        e.  Emission quantity per unit time or process weight
15.  Ability to accurately judge whether or not the general type
     of control device(s) (e.g., baghouse, wet scrubber) selected
     by the applicant in a permit application is well-suited to
     the characteristics of the contaminants likely to go through
     it.  If the applicant's choice is inferior to some other type
     of device, the reviewer should be able to make note of the
     more desirable selection and the rationale for that judgment.
     In making the judgment consider factors including:
        a.  Efficiency as a function of particle size and weight.
        b.  Possible physical or chemical attack by the contami-
            nant on the device  (including impairment of function
            due to moisture, poisoning of catalysts).
        c.  Possibility of transforming the pollution problem
            rather than solving it completely  (e.g., creating a
            water pollution problem as a result of treating an
            air contaminant, or creating an odor problem with the
            collection device).
        d.  Only partially eliminating the pollution problem (e.g.,
            cleaning the particulate element of the effluent without
            treating the odorous element).
16.  Ability to estimate control equipment costs on an air volume
     basis.
17.  Ability to communicate effectively in writing, over the tele-
     phone, and in face-to-face contact with applicants, vendors,
     contractors, attorneys, and other individuals related to the
     activities of the plan review process.
18.  Ability to prepare and rehearse a presentation to be made before
     a court- hearing board, or other legal or quasi-legal body.
19.  Ability to present testimony effectively in court.  Effective
     testimony can be characterized as:
        a.  Confidently presented
        b.  Truthful
        c.  Brief
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        d.  Responsive to the questions asked
        e.  Responsive only to questions asked
        f.  Unbiased
        g.  Clearly and audibly spoken
        h.  Courteously presented
     This ability includes responding effectively under cross-
     examination.  Also includes skill in qualifying as a competent
     (therefore, valid) witness.  For example, in the case where
     the witness has made a smoke-reading, he will often have to
     establish himself as a competent smoke-reader (e.g., by de-
     scribing his smoke-reading training, or explaining the dif-
     ference between smoke density and opacity).
20.  Ability to reliably and accurately judge visible emissions from
     stationary sources in terms of density and opacity using accepted
     procedures.  The precision of these judgments should be adequate
     to serve as acceptable evidence in a court of law.
21.  Ability to recognize, describe, or judge the source of general
     categories of stains or deposits formed by settlement of air
     contaminants.  Such categories of stains or deposits include:
        a.  Acid stains (e.g., chromic acid, sulfuric acid, hydro-
            fluoric acid, and phosphoric acid)
        b.  Oil droplets
        c.  Faint deposits
        d.  Carbon spheres
22.  Ability to accurately observe, describe, or estimate environ-
     mental conditions current at the time of a smoke observation,
     including wind speed and direction, relative humidity, tempera-
     ture, and percent cloud cover.
23.  Ability to reliably and accurately detect or characterize odors
     such that illegal concentrations can be identified and related
     to the responsible source.  The terminology and procedure used
     to rate or describe odors vary from agency to agency and depend
     upon accepted legal requirements.

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24.  Ability to identify, recognize, or locate external character-
     istics of plants or installations where indications of pollution
     are most likely to be revaled  (e.g., stacks, vents, loading
     areas).
25.  Ability to determine if the operating conditions of an industrial
     or commercial process during a source test or inspection are
     representative of typical operations or are those likely to
     produce the greatest pollution potential.  This could include
     verifying operating conditions such as charging rates, compo-
     sition of input materials, and level of dilution air used.
26.  Ability to make and interpret a basic flow diagram which identi-
     fies and shows the relationship of the sub-processes which comprise
     an industrial process.
                             e
27.  Ability to determine whether a control device is operating
     properly (e.g., reaching design efficiency) by visual inspec-
     tion of situational elements,  including:
        a.  Extent and type of emissions
        b.  Operational sensors and monitoring equipment (e.g.,
            pressure gauges, rotameters)
        c.  Observable physical characteristics of the equipment
            (e.g., rust, corrosion)
28.  Ability to prepare inspection  or engineering field reports which
     are adequately detailed, complete, and cogent to be accepted as
     evidence in a court of law.
29.  Ability to accurately evaluate the source test findings to
     determirie whether or not to grant a permit to operate.  Items
     such as the following should be considered in this decision:
        a.  Were the proper operating conditions observed?
        b.  Was a materials balance indicated?
        c.  Were the parameters of  control device design and per-
            formance as expected (e.g., pressure drop, retention
            time, filter velocity, efficiency)?
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          d.  Was the level of emission in compliance with relevant
              regulations?
  30.  Ability to identify and describe the general requirements for
       a source test required for a "permit to operate," or to
       acquire data for emission inventory.  The elements of the
       test to be specified include:
          a.  Equipment to be tested.
          b.  General location of test points.
          c.  Constituents to be measured.
          d.  Operational conditions during which test is to be
              conducted.
  31.  Ability to communicate effectively with agency personnel in
       working on operational problems involving enforcement, engineer-
       ing, or technical activities of the agency.

Knowledge Requirements
   1.  General knowledge of the goals and procedures of the plan review/
       permit system.
   2.  Knowledge of the local regulations which directly or indirectly
       relate to administration of a plan review system.  Specifically,
       knowledge of all the prohibitions and controls provided for in
       the agency's regulations.  These typically include:
          a.  Limitations on visible emissions (opacity and density).
          b.  Limitations on the quantity of particulates, dusts
              and fumes, specific gaseous compounds, combustion con-
              taminants , and organic compounds.
          c.  Rules specifying control requirements for petroleum
              products, storage tanks, and rendering equipment.
          d.  Specifications of sulfur content of fuels, photochemical
              reactivity, status of organic solvents.
          e.  Prohibitions on public nuisances, open burning, and
              single-chamber incinerators.
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3.  Knowledge of the relevant state-of-the-art in design of basic
    equipment for air pollution control (e.g., controlled air
    incinerators).
4.  Detailed knowledge of air contaminants found in emissions of
    basic equipment typically submitted to plans review.  The
    Engineer should be able to identify and describe basic equip-
    ment emissions at a level of detail such that the information
    can be used to evaluate the proposed control equipment.  Resource
    materials providing useful support in this area include:
       a.  Emission factors handbooks - References 5, 19, 20, 28,
           and 30.
       b.  Descriptions of source processes with emphasis on their
           pollution potential - References 1, 3, 6, .7, 11, 15,
           18, 29, 31, 34, 35, and 43.
       c.  Air pollution engineering guidelines - Reference 3.
       d.  Recommended practices for design of basic equipment -
           References 17, 32, 35, 36, 37, 38, 39, 40, 41, 45,
           and 46.
       e.  A specialized taxonomy of basic equipment - Reference 16.
5.  Knowledge of the general types of control devices typically
    used and recommended for specific air contaminants.  That is,
    knowledge of the appropriate type of control device given the
    form, composition, temperature, dew point, etc., of the con-
    taminant.  References 9, 14, 21, 22, 23, 24, 25, 26, and 27.
    are used for this information.  Knowledge of the current state-
    of-the-art in this area is also required.
6.  Knowledge of the basic procedures used in estimating source
    emissions from information describing the process, its pro-
    duction rates, production schedules, types of contaminants
    emitted, or the emission control devices currently in service
    or proposed.  These procedures should include use of emission
    factors, materials balance, and source test findings. Refer-
    ences 5, 19, 20, 28, and 30 are relevant in this area.
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 7.  Knowledge of undesirable emission levels for contaminants not
     regulated by local regulations (e.g., documented health or
     nuisance effects).  These levels are typically established by
     agency policy with regard to "general air pollution" type
     prohibitions written into their regulations.
 8.  Knowledge of the local procedure and guidelines for deciding
     whether or not permits to install or operate basic or control
     equipment should be granted, based upon the outcome of the
     review or testing procedures.  This includes knowledge of rele-
     vant standards, criteria, priorities, and trade-off guidelines
     (e.g., use of conditional permits).
 9.  Knowledge of the chemical and physical properties of materials
     used in the process being inspected or reviewed which have an
     effect on emissions and possible air pollution.  For relevant
     References, see Knowledge 21.
10.  Knowledge of the jargon and terminology used by operators or
     management of the basic or control equipment being inspected or
     reviewed.  This type of knowledge enables the inspector or re-
     viewer to adequately describe his findings and to communicate
     with other knowledgeable individuals.  For relevant References,
     see Knowledge 21.
11.  Knowledge of materials balance procedures for estimating emissions.
12.  Knowledge of the types of adjustments which can be made to basic
     equipment or control device operation which can improve emissions
     control (e.g.,  flame adjustments on an incinerator).
13.  Knowledge of the content of and use of specific data tables, graphs,
     nomographs, and specialized slide rules available to support design
     calculations and evaluations of basic, control, or ventilation
     equipment (e.g., the Exhaust System Calculator and Fan Curve Cal-
     culator used at Los Angeles APCD and referred to in Reference 8i
     pages 48 and 57).
14.  Knowledge of the procedures for preparation of flow diagrams of
     industrial processes.
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15.  Knowledge of the standard principles, procedures, and resource
     data required to evaluate the effectiveness of the proposed
     ventilation system (i.e., hood, duct network, exhaust fan) to
     collect and transport the source emissions to the control equip-
     ment.  References 2, 3, and 4 provide useful support in this area.
16.  Detailed knowledge of the key parameters of control device design
     and operation which affect its efficiency and effectiveness (e.g.,
     retention time, turbulence, temperature and others in an afterbur-
     ner).  This includes knowledge of possible design shortcomings
     or faulty methods used in combining control devices into control
     systems (e.g., three wet scrubbers in series which use recycled
     water containing suspended particulate matter).  References 8,
     22, 23, and 24 are relevant to this knowledge.
17.  Knowledge of the specific practices and processes of the type of
     industry being inspected or reviewed which may contribute to air
     pollution, for example:
        a.  In a refinery, rattling and blowing coke from cracking
            tubes.
        b.  In metal melting, the air pollution effects of efforts
            to remove metal impurities during the melt process.
        c.  In a rendering plant, the housekeeping problems which
            produce odor, such as fat accumulations inside hoods.
     For relevant References, see Knowledge 21.
18.  Knowledge of the exterior characteristics of plants and facilities
     inspected and the location and configuration of the elements of
     the facility where air pollution problems would be evident  (e.g.,
     stacks, vents, storage areas).
19.  Knowledge of source testing procedures at a level of detail which
     enables the Engineer to establish the requirements for, partici-
     pate in, and evaluate the findings of the tests.  References 10,
     12, 13, 42, 44, and 47 have been used in this area.
20.  Knowledge of the methods used  for describing  and rating  the in-
     tensity of odors.
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21.   Knowledge of the methods used to determine if pollution control
     devices are operating properly.   In addition to visual emission
     evaluation, the industrial inspector should know how to read
     and evaluate data relevant to pollution control from devices
     such as:
        a.  Chart recorders
        b.  Manometers
        c.  Pressure gauges
        d.  Rotameters
        e.  Flowmeters
        f.  Ohmmeters
        g.  Voltmeters
     Also, the inspector should know  what physical characteristics
     of deterioration indicate that the control device is operating
     below maximum capability.  These characteristics include:
        a.  Leaking or missing bags in a baghouse.
        b.  Corroded metal plates,  baffles,  and spray heads in a
            scrubber.
        c.  Heavily-coated grids and  plates  in a precipitator.
     Basic resource information relevant to  the above knowledge
     areas is  available from publications of the following types:
        a.  Emission factors handbooks - References 5, 19, 20, 28,
            and 30.
        b.  Descriptions of source processes with emphasis on
            their pollution potential - References 1, 3, 6, 7,
            11, 15, 18, 29, 31, 34, 35, and  43.
        c.  Air pollution engineering guidelines - Reference 8.
        d.  Air pollution control technology - References 9, 14.,
            22, 23, and 24.
        e.  Local recommended codes of practice - References 36,
            37, 38, 39, 40, 41, and 45.
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22.  Knowledge of potential hazards and related safety regulations
     to be followed during inspection, including:
        a.  Fire hazards.
        b.  Restrictions against manipulating equipment without
            consent of the operator or management.
        c.  Requirements for protective personal equipment, including:
               1)  Rubber gloves
               2)  Respirator
               3)  Goggles
               4)  Hard hat
               5)  Gas mask
               6)  Safety flashlight
        d.  Check-in procedures.
        e.  Inspection precautions, including:
               1)  Location of water showers when working in areas
                   where acids or caustic solutions are being
                   handled.
               2)  Use of an assistant as a "safety."
               3)  Not walking on building or tank roofs without
                   appropriate supervision.
               4)  Not watching welding activities directly.
23.  Knowledge of the basic psychophysical and perceptual principles
     related to the human sense of smell.  This knowledge can include:
           I
        a.  Sensory adaptation effects.
        b.  Adaptation level effects.
        c.  Individual differences in awareness and emotional
            response to odors.
        d.  The concept of a sensory threshold as a statistical
            phenomenon which is affected by many external and
            internal variables (e.g., humidity and past experience).
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24.  Knowledge of the requirements for an accurate smoke-reading.
     These requirements include:
        a.  Read plume against background contrasting In
            color to the color of the smoke.
        b.  Light source (e.g., the sun) should be behind
            the observer during daytime.
        c.  Light source (e.g., spotlight) should be behind
            plume at night.
        d.  Wind direction should be from either right or left
            aide of the observer.

        e.  A clear view of the stack and background should be
            available.  In some agencies a maximum observer
            distance has been proposed.
        f.  Record smoke-readings on the proper data collection
            form and at the required time intervals.
        g.  Read residual plumes only, not "wet plumes."
        h.  Observe and record all required environmental
            conditions current at the time of the observation
            (e.g., wind speed, percent cloud cover, wind
            direction, temperature, relative humidity).
     Some relevant information is available in Reference 33.
25.  Knowledge of the procedure and format requirements for a
     presentation to an appeals body justifying a permit denial
     decision.
26.  Background knowledge of source processes complete enough
     to support identification of the elements of the process
     which are likely to emit contaminants to the atmosphere if
     not adequately controlled (e.g., in petroleum refining:
     regeneration, combustion, compression, storage, and pumping)
     Also, knowledge of the parameters of each of these process
     elements which affect the quantity and type of emissions
     possible.  This type of knowledge is available to a useful
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        extent in documents of the following types:
           a.  Emission factors handbooks (for example, Refer-
               ences 5, 19, 20, 28, and 30).
           b.  Descriptions of source processes, such as manu-
               facturing of sulfuric acid or steel (for example,
               References 1, 3, 6, 7, 8, 11, 15, 18, 29, 31, 34,
               35, and 43).
           c.  Descriptions of emission control methods and devices
               (for example, References 21, 22, 23, 24, 25, 26, and
               27).
        Another source of this type of knowledge is work experience
        in the process area with emphasis on process design, operation,
        or air pollution control.
References
    1.  Air Pollution Sub-Committee.  Odor control manual for the rendering
         industry.  Des Plaines, 111.:  National Renderers Assn., Jan. 1969.
    2.  Alden, J. L.  Design of industrial exhaust systems.  New York:
         The Industrial Press, November 1959.
    3.  Committee on Industrial Hygiene.  Steel mill ventilation.
         New York:  American Iron and Steel Institute, May 1965.
    4.  Committee on Industrial Ventilation.  Industrial ventilation.
         A manual of recommended practice.  Lansing, Michigan:  American
         Conference of Governmental Industrial Hygienists, 1970. (llth
         Edition.)
    5.  Control Agency Directors S-8 Committee.  Pacific northwest
         emission factors reference manual.  Air Pollution Control
         Association, Pacific Northwest International Section, April
         1971.
    6.  Cooperative Study Project, Manufacturing Chemists' Association
         and Public Health Service.  Atmospheric emissions from sulfuric
         acid manufacturing processes.  Durham, North Carolina:  U. S.
         Department of Health, Education, and Welfare; Public Health
         Service, Environmental Health Service, National Air Pollution
         Control Administration, 1965.  PHSP #999-AP-13.
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 7.  Cuffe, S. T., and Gerstle, R. W.  Emissions from coal-fired
      power plants:  a comprehensive summary.  Durham, North
      Carolina:  U. S. Department of Health, Education, and Welfare;
      Public Health Service, Consumer Protection and Environmental
      Health Service, National Air Pollution Control Administration,
      1967.  PHSP #999-AP-35.
 8.  Danielson, J. A. (Ed.)  Air pollution engineering manual.  Air
      Pollution Control District, County of Los Angeles.  Cincinnati,
      Ohio:  U. S. Department of Health, Education, and Welfare;
      Public Health Service, Bureau of Disease Prevention Environ-
      mental Control, National Center for Air Pollution Control,
      1967.
 9.  Decker, L. D.  Odor control by incinerator^  Greenwich, Con-
      necticut:  UOP Air Correction Division, November 1965.
      (Text of a talk given before a meeting of the Middle States
      Section of the Air Pollution Control Assn., Wilmington,
      Delaware, November 1965).
10.  Duffee, R. A.  Appraisal of odor-measurement techniques.
      Journal of the Air Pollution Control Associationt _7_:472-
      474.  July 1968, Vol. 18.
11.  Gulf Publishing Co.  Hydrocarbon processing handbook.  Houston,
      Texas:  Author, Box 2608, 77001.
12.  Haaland, H. H. (Ed.)  Methods for determination of velocity,
      dust and mist content of gases.  Bulletin WP-50.  Seventh
      Edition.  Los Angeles:  Western Precipitation Division/
      Joy Manufacturing Company, 1968.
13.  Huey, N. A., Broering, L. C., Jutze, G. A., & Gruber, C. W.
      Objective odor pollution control investigations.  Journal
      of the Air Pollution Control Association, 6^:441-444.
      December 1960, Vol. 10.
14.  Ingels, R. M.  The afterburner route to pollution control.  Air
      Engineering. June 1964, p. 39-42.
15.  Kreichelt, T. E., Kemnitz, D. A., and Cuffe, S. T.  Atmospheric
      emissions from the manufacture of Portland cement.  Cincinnati,
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      Ohio:  U. S.- Department of Health, Education, and Welfare;
      Public Health Service, Bureau of Disease Prevention and
      Environmental Control, 1967.  PHSP //999-AP-17.
16.  Loquercio, Peter, & Stanley, W. J.  Air pollution manual
      of coding...a coding system for the identification of basic
      equipment and control devices used in industrial processing.
      U. S. Department of Health, Education, and Welfare; Public
      Health Service Publication No. 1756, 1968.
17.  MacKnight, R. J., Williamson, J. E., Sableski, J. J., &
      Dealy, J. A.  Controlling the flue fed incinerator.  Paper
      59-4, presented at the 52nd Annual Meeting of the Air Pol-
      lution Control Association.  Los Angeles:  Los Angeles Air
      Pollution Control District, June 1959.
18.  McGannon, H. E.  (Ed.) ' The making, shaping and treating of
      steel.  Eighth Edition.  United States Steel Corporation.
19.  McGraw, M. J., & Duprey, R. L.  Compilation of air pollutant
      emission factors.  Preliminary document.  Research Triangle
      Park, North Carolina:  Environmental Protection Agency,
      April 1971.
20.  National Air Pollution Control Administration.  Air pollutant
      emission factors.  Washington, D. C.:  Department of Health,
      Education, and Welfare; Public Health Service, Environmental
      Health Service, April 1970.
21.  National Air Pollution Control Administration.  Control tech-
      niques for carbon monoxide emissions from stationary sources.
      Washington, D. C.:  U. S. Department of Health, Education,
      and Welfare; Public Health Service, March 1970.  No. AP-65.
22.  National Air Pollution Control Administration.  Control tech-
      niques for hydrocarbon and organic solvent emissions from
      stationary sources.  Washington, D. C.:  U. S. Department
      of Health, Education, and Welfare; Public Health Service,
      Environmental Health Service, March 1970.  No. AP-68.
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23.  National Air Pollution Control Administration.  Control tech-
      niques for particulate air pollutants.  Washington, D. C.:
      U. S. Department of Health, Education, and Welfare; Public
      Health Service, Consumer Protection and Environmental Health
      Service, January 1969.
24.  National Air Pollution Control Administration.  Control tech-
      niques for sulfur oxide air pollutants.  Washington, D. C.:
      U. S. Department of Health, Education, and Welfare; Public
      Health Service, Environmental Health Service, January 1969.
25.  National Asphalt Pavement Association.  Environmental pollu-
      tion control at hot-mix asphalt plants.  Information Series 27.
26.  New Jersey State Department of Health, Air Sanitation Program.
      A guide for evaluation of solid particle emissions from asphalt
      paving plants.  May 1966.
27.  New Jersey State Department of Health, Air Sanitation Program.
      A guide for the evaluation of solid particle emissions from
      ferrous foundry operations.  August 1966.
28.  Ozolins, Guntis, & Smith, Raymond.  A rapid survey technique
      for estimating community air pollution emissions.  PHSP #999-
      AP-29. October 1966.
29.  Schueneman, J. J., High, M. D., & Bye, W. E.  Air pollution
      aspects of the iron and steel industry.  Cincinnati, Ohio:
      U. S. Department of Health, Education, and Welfare; Public
      Health Service, Division of Air Pollution, June 1963.
30.  Sheehy, J. P., Achinger, W. C., & Simon, R. A.  Handbook of
      air pollution.  Durham, North Carolina:  U. S. Department
      of Health, Education, and Welfare; Public Health Service,
      Bureau of Disease Prevention and Environmental Control,
      National Center for Air Pollution Control.  PHSP //999-AP-44.
31.  Smith, W. S.   Atmospheric emissions from fuel oil combustion.
      An inventory guide.  Cincinnati, Ohio:  U. S. DepartmentofT .
      Health, Education, and Welfare; Public Health Service, Divi-
      sion of Air Pollution, November 1962.  PHSP //999-AP-2.
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32.  Standards and Engineering Information - re Boilers
                                              - Superheaters
                                              - Stokers
                                              - Pulverized Fuel Equipment
                                              - Air Preheaters
                                              - Economizers
      Available from the American Boiler Manufacturers Association,
      1180 Raymond Blvd., Newark, N. J.
33.  Sticksel, P. R., and Staff  (Ed.)  Student's manual for evaluation
      of visible emissions for state and local air pollution inspec-
      tors.  Columbus, Ohio:  BATTELLE Columbus Laboratories,
      August 1971.
34.  Swearingen, J. S., and Levin, H.  Hydrocarbon losses from the
                           t
      petroleum industry in L. A. County.  San Antonio, Texas:
      Southwest Research Institute.
35.  Technical Advisory Board.   Code of recommended practices.  Asphalt
      mixing plants.  Chicago:   City of Chicago, Department of Environ-
      mental Control, April 1971.
36.  Technical Advisory Board.   Code of recommended practices.  Fuel
      burning equipment for heating, steam and hot water generation,
      absorption refrigeration.  Chicago:  City of Chicago, Department
      of Environmental Control,  October 1968.
37.  Technical Advisory Board.   Code of recommended practices.  Grain
      handling and storage.  Chicago:  City of Chicago, Department of
      Environmental Control, April 1971.
38.  Technical Advisory Board.   Code of recommended practices.  Refuse
      burning equipment for domestic and non-domestic use.  Chicago:
      City of Chicago,  Department of Environmental Control, April
      1971.
39.  Technical Advisory Board.   Code of recommended practices.  Ren-
      dering processes.  Chicago:  City of Chicago, Department of
      Environmental Control, April 1971.
40.  Technical Advisory Board.   Code of recommended practices.  Spray
      booths.  Chicago:  City of Chicago, Department of Air Pollution
      Control, August 1968.
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      41.  U. S. Department of Health, Education, and Welfare.  Interim
            guide of good practice for incineration at federal facilities.
            Raleigh, North Carolina:  Public Health Service, Consumer
            Protection and Environmental Health Service, National Air
            Pollution Control Administration, November 1969.  AP-46.
      42.  U. S. Department of Health, Education, and Welfare.  Specifi-
            cations for incinerator testing at federal facilities.  Durham,
            North Carolina:  Public Health Service, Bureau of Disease
            Prevention and Environmental Control, National Center for
            Air Pollution Control, Abatement Program, October 1967.
      43.  U. S. Department of Health, Education, and Welfare; Public
            Health Service, Division of Air Pollution.  Atmospheric
            emissions from petroleum refineries.  A guide for measurement
            and control.  PHSP #763, 1960.
      44.  Ward, F. R.  Odor measurement with the Scentometer.  Norfolk,
            Virginia:  Odor Control Subcommittee, Industrial Standards
            Committee, National Renderers Association.
      45.  Williamson, J. E., and Hammond, W. F.  Interim guide to good
            practice for direct-fed multiple-chamber incinerators.
            Los Angeles:  L. A. County Air Pollution Control District,
            October 1966.
      46.  Williamson, J. E., MacKnight, R. J., & Chass, R. L.  Multiple-
            chamber incinerator design standards for Los Angeles County.
            Los Angeles:  Los Angeles County Air Pollution Control Dis-
            trict, October 1960.

Special Staffing Guidance
To get a complete picture of the Plan Review task and its associated skill
and knowledge requirements, combine the material presented above with that
presented under Engineering Inspection (Page fi-59).
Typically, control agencies maintain a staff of Engineers who work full-
time on plan review activities, and the degrees of freedom in assigning
an Engineer to process a specific application are limited.  However, in

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the case where specific assignments can be made to best take advantage
of personnel experience and skill level, the following variables should
be considered:
   1.  The judged difficulty or complexity of the basic or control
       equipment to be reviewed.  Examples of relatively uncomplicated
       basic equipment and control equipment include:
          a.  Buffing and grinding equipment
          b.  Degreasers
          c.  Dry cleaning equipment
          d.  Laundry tumblers
          e.  Oil quench tanks
          f.  Dry cleaning adsorbers
          g.  Spray booths
          h.  Settling chambers
       Examples of more difficult basic and control equipment include:
          a.  Grease solvent extraction units
          b.  Muffle furnaces
          c.  Open-hearth furnaces
          d.  Rendered products handling systems
          e.  Boilers used as an afterburner
          f.  Hot air baghouses
          g.  Vapor recovery units
                 i
      Under most conditions, senior level Engineers should be assigned to
      process applications concerning more difficult or complex equipment.
  2.  Unusual credibility requirements related to the application.  If
      the assignment is likely to be a controversial one, it may be
      advisable to assign the job to a senior level Engineer in order to help
      increase the strength and acceptability of the agency's position.
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                        Engineering Inspection

Task Overview
Frequently, agency personnel are called on to inspect complex and extensive
industrial, commercial, or public facilities.  These inspections are typically
performed as an adjunct to engineering or enforcement activities including:
   1.  Complaint investigation.
   2.  Enforcement of the permit system (e.g., to determine if a new
       installation fits the description given on the installation
       permit; to identify operating processes which have no permits).
        ^                        t
   3.  Data collection for an emission inventory.
   4.  Registration of equipment or processes as required by law (e.g.,
       processes emitting sulfur compounds) .
   5.  Investigation and documentation of violations (e.g., smoke density,
       open burning violation alert).
   6.  Inspection of progress in a compliance program (e.g., installation
       of control equipment or changes in processes to reduce emissions).
Engineering inspections contain many of the  task elements of the less
complicated Routine Inspection task covered in VolumeC •  Most of the
inspections, regardless of who does them and what equipment they cover,
have in common some general task requirements.  These requirements include:
   1.  Visual inspection of equipment and operations which can result
       in air pollution.
   2.  Interaction with personnel who operate orHmanage the equipment.
   3.  Attention to details of equipment design or operation which may
       be in violation of local regulations.
   4.  Collection and reporting of specific information about the equip-
       ment and processes.
   5.  Concern for public relations and ethical consideratHSras.
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Occupational Category;  Engineer

   Task Description
       1.  Identify the objectives of the inspection and perform all
           required pre-inspection activities.   These pre-inspection
           activities could include:
              a.   Secure and read the background data describing the
                  unit to be inspected.   The descriptive material may
                  be general or specific to the  exact plant,  equipment
                  to be inspected, or anticipated pollution problem.
                  In the case of large complex units, prepare or secure
                  and then review basic  flow diagrams, plot plans,  pro-
                  cess descriptions,  or  drawings before the actual
                  inspection.
                  Another area of background data to review would be
                  relevant files describing other agency activities
                  regarding the unit  to  be inspected.  For example,
                  files containing permit data,  prior violations, and
                  compliance program  details may contain useful infor-
                  mation.
              b.   If more than one inspector is  required, identify the
                  type and number of  required assistants and  make ar-
                  rangements for securing them.   Define the roles of
                  the assistants and  rehearse or brief them accordingly.
              c.   Identify the materials (e.g.,  data collection forms)
                  and equipment required for the inspection,  and secure
                  them In the appropriate numbers.
              d.   Identify the need for assistance from plant personnel.
                  Determine the types of people  (in terms of  knowledge,
                  experience, responsibility) and the numbers required.
       2.  On approaching  the inspection site,  carefully review  the scene.
           Generally,  locate and note items of  interest including:
              a.  Smoke  stacks
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       b.  Exhaust vents
       c.  Incinerators
       d.  Pollution control equipment
       e.  Materials loading and storage areas
       f.  Effluent water containers
       g.  Outdoor burning
       h.  Fugitive emissions
    Also, maintain awareness for localized air pollution conditions
    including:
       a.  Smoke
       b.  Odors
       c.  Settled dust
                            e
       d.  Stains due to emission of air contaminants
3.  Contact the highest ranking authority present at the plant.
    Inform him of the planned inspection and request permission to
    enter.  Also, describe and request the desired assistance from
    plant personnel.  It may be necessary to cite the relevant local
    regulations which define the inspector's duties and give him the
    right to perform them.  If permission to enter is not granted
    follow the appropriate procedure for refused entry.
4.  Locate the equipment to be inspected and make the required
    observations.  Typically, a data collection form is used to
    cue the inspector to specific characteristics of the equipment.
    Also, collect all required data related to operation of the
    equipment.  It may be necessary to secure information from
    equipment operators, management, or company records.
5.  Verify that the observed equipment fits the description of the
    equipment for which the permit to install was granted.  Identify
    and describe the equipment in terms of function, capacity, through-
    put, manufacturer, configurational characteristics, or serial
    number.
6.  Identify and describe all discrepancies between the observed
    equipment and that described in the installation permit material.
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    Determine the pollution control effects of the modifications
    to the accepted plan.  Discrepancies which adversely affect
    emmissions or violate local standards may result in denial to
    operate the equipment.
7.  Verify that the process observed is the one described in the
    permit application supporting data.  Verify characteristics
    of the process including:
       a.  Overall product  or function of the equipment
           in the process.   Include capacity, throughput,
           etc.
       b.  Sequential or parallel steps of the process and
           their functions  (e.g., storage, size reduction,
           drying, materials handling).
       c.  Type and quantity of materials used in the process.
       d.  Batch vs. continuous process.
       e.  Emission points  and acceptability of emissions
           (visible emissions, odors, stains).
8.  Prepare inspection findings and conclusions.  With regard
    to enforcement of the permit system, the inspector can
    report his findings in  two ways (depending upon local pro-
    cedures and regulations):
       a.  If the unit has  been constructed or is being operated
           in a manner not  consistent with relevant permits, file
           a notice of violation.
       b.  If the unit has  not received the appropriate permit,
           send a form to the source operator requesting that a
           permit application be completed.  This form can con-
           tain information including:
              1)  Firm name, address, telephone number.
              2)  Description of equipment requiring the permit
                  (make, model, general use of equipment, system,
                   or process).
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              3)  Deadline for application.
              4)  Description of emissions or odors.
              5)  Suspected or recorded violations.
              6)  Reason permit is required.
9.  Prepare any additional specialized reporting forms required.
    In addition to or in lieu of the above types of forms, the
    inspector may complete additional materials including:
       a.  Industry-specific inspection check sheets.  Such
           materials contain specific checkpoints to cover for
           a specific type of operation.  For example, a form
           for a foundry might contain checkpoints including:
              1)  Cupolas.
              2)  Charge materials (scrap metal, coke).
              3)  Control equipment (e.g., venturi type).
              4)  Pyro-vents.
              5)  Visible emissions at stack.
              6)  Operation of waste hoppers (e.g., operation
                  of wet rings, blow-off conditions).
              7)  Wind carry-off from storage piles.
              8)  Odor characteristics (quality, distress effects,
                  intensity).
       b.  Solvent usage survey (depending upon agency or regu-
           lations).  In the case of a solvent used prior to a
           heating operation, such a survey may require information
           including:
              1)  Description of articles processed in oven.
              2)  Type of process used for coating (e.g., spray
                  booth, dip tank).
              3)  Time between coating and oven process.
              4)  Oven process (baking, heat curing, heat polymerization).
              5)  Pollution control equipment.
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   10.  Prepare a general field report.  A general type of form is
        usually used to describe results of an inspection in addition
        to formal notices or other special forms.  The form can be used
        to describe suspected or near violations, follow-up inspection
        findings, and any other objectives not directly related to
        violations.  These forms are usually filled in with narrative
        statements describing the purpose and findings of the inspec-
        tion and any relevant statements made by the operator or manager
        of the process being inspected.

Skill Requirements
    1.  Ability to interpret regulations regarding administration of
        the plan review/permit system including:
           a.   Discriminating which types of equipment must apply
               and which are exempt.
           b.   Accurately applying emission standards, equipment
               design criteria, and other control regulations.
           c.   Establishing the appropriate fee for both simple
               and complex configurations of basic or control
               equipment.
    2.  Ability to answer applicant's questions and present information
        to them concerning the technical and administrative require-
        ments of the plan review/permit system.
    3.  Ability to use nomographs,  tables of data,  special slide rules,
        desk calculators, and other aids in performing required calcu-
        lations or data determinations.
    4.  Ability to reliably and accurately judge visible emissions from
        stationary sources in terms of density and opacity using accepted
        procedures.  The precision of these judgments should be adequate
        to serve as acceptable evidence in a court of law.
    5.  Ability to interpret engineering drawings for detailed evalua-
        tion of basic equipment, ventilation systems, or control systems.
        The types of drawings reviewed include:
           a.  Assembly drawings (in plan and elevation)

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        b.  Equipment location drawings
        c.  Plot plans
        d.  Process flow diagrams
 6.  Ability to determine if the operating conditions of an industrial
     or commercial process during a source test or inspection are
     representative of typical operations or are those likely to
     produce the greatest pollution potential.  This could include
     verifying operating conditions such as charging rates, compo-
     sition of input materials, and level of dilution air used.
 7.  Ability to visually recognize discrepancies between the
     accepted plans and the equipment  (basic or control) installed.
     Also, ability to determiner whether the discrepancies will have
     a positive, negative, or neutral  effect on pollution control.
 8.  Ability to identify and describe  the general requirements for
     a source test required for a "permit to operate," or for acqui-
     sition of data for an emission inventory.  The elements of the
     test to be specified include:
        a.  Equipment to be tested.
        b.  General location of test points.
        c.  Constituents to be measured.
        d.  Operational conditions during which test is to be
            conducted.
 9.  Ability to accurately observe, describe, or estimate environ-
     mental conditions current at the  time of a smoke observation,
     including wind speed and direction, relative humidity, tem-
     perature, and percent cloud cover.
10.  Ability to reliably and accurately detect or characterize
     odors such that illegal concentrations can be identified
     and related to the responsible source.  The terminology
     and procedure used to rate or describe odors vary from
     agency to agency and depend upon accepted legal requirements.
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11.  Ability to secure cooperation and assistance from the operator
     or manager of the source or plant being inspected.
12.  Ability to recognize the component operations of industrial
     or commercial processes which are being suboptimally performed,
     thus resulting in or contributing to excessive emissions, for
     example:
        a.  Improper coking operation in a fuel burning process.
        b.  Unbalanced intake and draft air ratio for cookers and
            driers in a rendering plant.
        c.  Improperly enclosed or ventilated loading, unloading,
            or storage areas in a cement plant.
        d.  Sloppy housekeeping operations in a rendering plant.
        e.  Inadequate preventative maintenance program for air
            pollution control equipment.
        f.  Improper charge rate, fuel, or excess air in an
            incinerator.
13.  During the inspection, ability to locate, recognize, or describe
     the basic units of industrial process equipment which are capable
     of or are currently producing uncontrolled or inadequately con-
     trolled emissions.  Examples of such elements include:
        a.  Refining processes:
               1)   Pressure relief valves
               2)   Pump packing glands and valves
               3)   Vapor recovery systems
               4)   Flares
        b.  Cement plants:
               1)   Rotary drier
               2)   Storage bins
               3)   Crushing and grinding equipment
               4)   Conveyors
               5)   Loading/unloading facilities
                             fi-66

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        c.  Metal melting:
               1)  Furnaces (e.g., cupolas, induction, reverberatory)
               2)  Casting equipment (centrifugal, die, sand casting)
               3)  Charging equipment
               4)  Sandblasting or cleaning equipment
14.  Ability to perform test procedures and operate test equipment
     on-site during an inspection.  The test procedures and equip-
     ment used may include:
        a.  Sensitized test papers.  These materials are used to test
            for the following contaminants:
               1)  Ammonia
               2)  Arsine
               3)  Hydrogen Sulfide
               4)  Phosgene
        b.  Squeeze Bulb Type Gas Testers.  This  device gives colorimetric
            reactions to the following contaminants;
               1)  Benzine
               2)  Toluene
               3)  Xylene
               4)  Carbon Monoxide
               5)  Hydrogen Cyanide
               6)  Hydrogen Sulfide
               7)  Sulfur Dioxide
        c.  Tutweiler Apparatus.  This device uses  gas/liquid
            titrations to determine the concentrations of the
            following contaminants In stack gases:
               1)  Hydrogen Sulfide
               2)  Sulfur Dioxide
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               3)  Ammonia
               4)  Carbon Dioxide
        d.  Hilo Bromine Field Test Equipment
        e.  Kldget Impinger and Gas Adsorption Cell
        f.  Halide Leak Detector
        g.  Explosimeters or Combustion Meters
        h.  Sling Psychrometer
        i.  Sword Pyrometer
15.  Ability to determine whether a control device is operating
     properly (e.g.,  reaching design efficiency) by visual inspec-
     tion of situational elements, including:
        a.  Extent and type of emissions
        b.  Operational sensors and monitoring equipment (e.g.,
            pressure gauges, rotameters)
        c.  Observable physical characteristics of the equipment
            (e.g., rust, corrosion)
16.  Ability to prepare inspection or engineering field reports
     which are adequately detailed, complete, and cogent to be
     accepted as evidence in a court of law.
17.  Ability to identify, recognize, or locate external character-
     istics of plants or installations where indications of pol-
     lution are most likely to be revealed (e.g., stacks, vents,
     loading areas).
18.  Ability to Interact with company management or use company
     records to secure operating information related to emissions
     (e.g., type of fuel used, amount consumed per unit time, type
     and amount of process materials).
19.  Ability to recognize, describe, or judge the source of general
     categories of stains or deposits formed by settlement of air
     contaminants.  Such categories of stains or deposits include:
        a.  Acid stains  (e.g., chromic acid, sulfuric acid, hydro-
            fluoric acid, and phosphoric acid)
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        b.  Oil droplets
        c.  Paint deposits
        d.  Carbon spheres
20.  Ability to take acceptable photographs of the physical
     evidence of air contamination.  Photographs should be
     'adequately focused, framed, and exposed.
21.  Ability to assess the degree to which original control device
     efficiency ratings should be reduced to accurately reflect its
     current condition and operating characteristics.
22.  Ability to use agency files, source process data, and other
     methods to develop the appropriate background data to initiate
     an inspection of a stationary source.
23.  Ability to interpret engineering drawings (e.g., plot plans,
     process flow diagrams) in order to plan for an inspection
     or locate and identify equipment in a facility.
24.  Ability to make and interpret a basic flow diagram which
     identifies and shows the relationship of the sub-processes
     which comprise an industrial process.
25.  Ability to locate, recognize, or describe air pollution control
     devices as used in industrial or commercial facilities.
26.  Ability to accurately describe or judge the characteristics
     of basic or control equipment required for estimating emissions
     as determined by on-site inspection.  The type of information
     collected and recorded can include:
                 i
        a.  Source operation
               1)  Number and type of source operations vented.
               2)  Rate or amount of raw materials used.
               3)  Rate or amount of finished product.
               4)  Quantity, rate, physical state, and discharge
                   point of waste materials.
               5)  Identity of unit operations (e.g., drying,
                   melting, size reduction, material movement).
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                  6)   Description of process flow with points of
                      pollutant discharge noted.
                  7)   Unit operating schedule.
           b.   Control devices
                  1)   Type
                  2)   Make and model
                  3)   Design efficiency
                  4)   Rated capacity
                  5)   Installation date
                  6)   Mechanical condition and  maintenance
           c.   Stack
                  1)   Location
                  2)   Height
                  3)   Materials
                  4)   Type of construction (e.g., self-standing, roof,
                      superstructure)
                  5)   Availability of ports or  openings
           d.   Discharge
                  1)   Composition and physical  characteristics (e.g.,
                      size, shape).
                  2)   Daily discharge period (normal and maximum).
                  3)   Gas discharge rate and temperature.
                  4)   Draft or exhaust type (e.g., forced, induced,
                      natural).
        These data are used back in the office, along with the appropriate
        emission factors, to calculate the quantity and type of emission.

Knowledge Requirements
    1.  General knowledge of the goals and procedures of the plan review/
        permit system.
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2.  Knowledge of the local regulations which directly or indirectly
    relate to administration of a plan review system.  Specifically,
    knowledge of all the prohibitions and controls provided for in
    the agency's regulations.  These typically include:
       a.  Limitations on visible emissions (opacity and density).
       b.  Limitations on the quantity of particulates, dusts
           and fumes, specific gaseous compounds, combustion contami-
           nants, and organic compounds.
       c.  Rules specifying control requirements for petroleum
           products, storage tanks, and rendering equipment.
       d.  Specifications of sulfur content of fuels, photochemical
           reactivity, status of organic solvents.
       e.  Prohibitions on public nuisances, open burning, and
           single-chamber incinerators.
3.  Knowledge of the relevant state-of-the-art in design of basic
    equipment for air pollution control (e.g., controlled air
    incinerators).
4.  Detailed knowledge of the key parameters of control device
    design and operation which affect its efficiency and effective-
    ness (e.g., retention time, turbulence, temperature and others
    in an afterburner).  This includes knowledge of possible design
    shortcomings or faulty methods used in combining control devices
    into control systems (e.g., three wet scrubbers in series
    which use recycled water containing suspended particulate matter).
    References relevant to this knowledge are 6, 20, 21, and 22.
               a--.
5.  Detailed knowledge of air contaminants found in emissions of
    basic equipment typically submitted to plan review.  The
    Engineer should be able to identify and describe basic equip-
    ment emissions at a level of detail such that the information
    can be used to evaluate the proposed control equipment.  Re-
    source materials used in this area include:
       a.  Emission factors handbooks - References 3, 18, 19,
           23.
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        b.  Descriptions of source processes with emphasis on
            their pollution potential - References 1, 2, 4, 5,
            10, 14, 17, 24, 25, 28, and 37.
        c.  Air pollution engineering guidelines - Reference 6.
        d.  Recommended practices for design of basic equipment -
            References 16,  26, 29,  30,  31,  32,  33,  34,  35,  39,  and
            40.
        e.  A specialized taxonomy of basic equipment - Reference
            15.
 6.  Knowledge of undesirable emission levels for contaminants
     not regulated by local regulations (e.g.,  documented health
     or nuisance effects).   These levels are typically established
     by agency policy with regard to "general air pollution" type
     prohibitions written into their regulations.
 7.  Knowledge of the types of adjustments  which can be made to
     basic equipment or control device operation which can improve
     emissions control (e.g., flame adjustments on an incinerator).
 8.  Knowledge of materials balance procedures for estimating emissions,
 9.  Knowledge of source testing procedures at a level of detail which
     enables the Engineer to establish the  requirements for, partici-
     pate in,  and evaluate the findings of  the teats.  References 8,
     11, 12, 36, 38 and 41  have been used in this area.
10.  Knowledge of the local procedure and guidelines for deciding
     whether or not permits to install or operate basic or control
     equipment should be granted, based upon the outcome of the
     review or testing procedures.   This includes knowledge of
     relevant standards, criteria,  priorities, and trade-off
     guidelines (e.g., use of conditional permits).
11.  Knowledge of the local procedures for performance of inspec-
     tions, obtaining entry, and dealing with refusal of entry.
12.  Knowledge of the data collection form and reports required
     for the specific inspection objective to be accomplished
     and the procedures for completing them.
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13.  Knowledge of the ethical considerations that impact on
     complaint handling and inspection.  These ethical con-
     siderations include:
        a.  Inspectors must not interfere with the acts or
            decisions of the control officer.
        b.  The law must be applied uniformly.
        c.  Recommendations for specific control equipment
            manufacturers are not permitted.
        d.  Information acquired about an operation or company
            is proprietary and must never be disclosed to
            competitors.
                                
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17.  Knowledge of the specific practices and processes of the.
     type of industry being inspected or reviewed which may con-
     tribute to air pollution, for example:
        a.  In a refinery, rattling and blowing coke from
            cracking tubes.
        b.  In metal melting, the air pollution effects of
            efforts to remove metal impurities during the
            melt process.
        c.  In a rendering plant, housekeeping problems
            which produce odor, such as fat accumulations
            inside hoods.
     For relevant References, see Knowledge 20.
18.  Knowledge of the operating principles and uses of specific
     equipment within an industrial or commercial process (e.g.,
     fractionating towers and bubble trays in a refinery).
     For relevant References, see Knowledge 20.
19.  Knowledge of the operating principles of air pollution control
     equipment used at the inspection site.  The types of devices
     used can be specialized according to the process they are
     controlling.  Examples of such specialized devices are:
        a.  Flares
        b.  Loading rack separators
        c.  Sulfur recovery plants
     Examples of less process-specific control devices include:
        a.  Baghouses
        b.  Scrubbers
        c.  Cyclone separators
        d.  Electrostatic precipitators
     For relevant References, see Knowledge 20.
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20.  Knowledge of the methods used to determine if pollution
     control devices are operating properly.  In addition to
     visual emission evaluation, the industrial inspector
     should know how to read and evaluate data relevant to
     pollution control from devices such as:
        a.  Chart recorders
        b.  Manometers
        c.  Pressure gauges
        d.  Rotameters
        e.  Flowmeters
        f.  Ohmmeters
      __                         .e
        g.  Voltmeters
     Also, the inspector should know what physical characteristics
     of deterioration indicate that the control device is operating
     below maximum capability.  These characteristics include:
        a.  Leaking or missing bags in a baghouse.
        b.  Corroded metal plates, baffles, and spray heads
            in a scrubber.
        c.  Heavily-coated grids and plates in a precipitator.
     Basic resource information relevant to the above knowledge
     areas is available from publications of the following types:
        a.  Emission factors handbooks - References 3, 18, 19,
            and 23.
                I
        b.  Descriptions of source processes with emphasis on
            their pollution potential - References 1, 2, 4, 5,
            10, 14, 17, 24, 25, 28, 29, and 37.
        c.  Air pollution engineering guidelines - Reference 6.
        d.  Air pollution control technology - References 7, 13,
            20, 21, and 22.
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        e.  Local recommended codes of practice - References 30,
            31, 32, 33, 34,  35, and 39.
21»  Knowledge of the potential hazards and related safety regula-
     tions to-be followed during inspections,  Including:
        a.  Fire hazards.
        b.  Restrictions against manipulating  equipment without
            consent of the operator or management.
        c.  Requirements for protective personal equipment,
            including:
               1)  Rubber gloves
               2)  Respirator
               3)  Goggles
               4)  Hard hat
               5)  Gas mask
               6)  Safety flashlight
        d.  Check-in procedures
        e.  Inspection precautions, including:
               1)  Location  of water showers when working in areas
                   where acids or caustic solutions are being
                   handled.
               2)  Use of an assistant as a "safety."
               3)  Not walking on building or  tank roofs  without
                   appropriate supervision.
               4)  Not watching welding activities directly.
22.  Knowledge of the techniques and under what conditions to use
     on-site test procedures and equipment during an inspection.
     Conditions for use of testing materials and equipment include;
        a.  In a refinery inspection:  use of  lead acetate paper
            to verify pH of  treated water effluent for stripping
            efficiency.
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        b.  In a refinery inspection:  use of the Bromine Field Test
            Equipment to determine if the Bromine number is below
            a locally required standard.
        c.  In a refinery inspection:  use of the Explosimeter to
            determine if any hydrocarbon vapor leaks are present.
        d.  In a rendering operation inspection:  use of the
            Sword Pyrometer to check afterburner temperature.
        e.  In an incinerator inspection:  use of a draft gauge
            to measure draft or use of a Pyrometer to measure
            chamber temperature.
23.  Knowledge of the requirements for an accurate smoke-reading.
     These requirements include:"
        a.  Read plume against background contrasting in color
            to the color of the smoke.
        b.  Light source (e.g., the sun) should be behind ob-
            server during daytime.
        c.  Light source (e.g., spotlight) should be behind plume
            at night.
        d.  Wind direction should be from either right or left
            side of the observer.
        e.  A clear view of the stack and background should be
            available.  In some agencies a maximum observer
            distance has been proposed.
        f.  Record smoke-readings on the proper data collection
            form and at the required time intervals.
        g.  Read residual plumes only, not "wet plumes."
        h.  Observe and record all required environmental conditions
            current at the time of the observation (e.g., wind
            speed, percent cloud cover, wind direction, temperature,
            relative humidity).
     Some relevant information is available in Reference 27.
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24.  Detailed knowledge of local regulations relevant to the
     objectives, duties, and rights of the inspector.  The inspec-
     tor must have full knowledge of the prohibitions, required
     conditions, and exemptions provided in the law.  The areas
     of the regulations the inspector needs to know include:
        a.  Smoke density and opacity standards.
        b.  Particulate and gaseous emission standards.
        c.  "Public nuisance" or general "air pollution by defi-
            nition" prohibitions.
        d.  Open burning controls.
        e.  Incinerator design requirements.
        f.  Storage,  loading, and unloading of gasoline and other
            petroleum products.
        g.  Provisions of the permit system.
        h.  Emergency control program requirements.
25.  Knowledge of pre-inspection duties and agency procedures for
     completing pre-inspection activities (e.g., securing assistance,
     checkout of test equipment).
26.  Knowledge of the types and appearance of property damage due
     to air contaminants.  Such damages include:
        a.  Acid stains
        b.  Discoloration of paint
        c.  Dust or fly ash deposits
        d.  Paint deposits
        e.  Vegetation damage
27.  Knowledge of the methods used for describing and rating the
     intensity of odors.
28.  Knowledge of the basic psychophysical and perceptual principles
     related to the human sense of smell.  This knowledge can include:
        a.  Sensory adaptation effects.
        b.  Adaptation level effects.
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        c.  Individual differences in awareness and emotional
            response to odors.
        d.  The concept of a sensory threshold as a statistical
            phenomenon which is affected by many external and
            internal variables  (e.g., humidity and past experience).
29.  Knowledge of the method for tracking odors in order to identify
     the likely source of the emission, including:
        a.  Analysis of wind patterns.
        b.  Area surveys.
        c.  Use of field test equipment (e.g., Scentometer).
30.  Knowledge of the procedure for preparing a notice of violation.
     This includes knowledge of the rules for recording information
     and all coding schemes used to designate data.  Also, know]edge
     of the appropriate wording for narrative portions of the notice.
31.  Knowledge of the procedure for serving violation notices and
     for keeping appropriate records of such, activities.
32.  Knowledge of local regulations at a level of detail to enable
     identification or verification of violations as formally re-
     ported by enforcement personnel.
33.  Knowledge of the types of data contained in agency enforcement
     files and their application to specific inspection, complaint
     handling, and other enforcement activities.
34.  Knowledge of the terminology and language used in agency files
     of past enforcement action.
35.  Knowledge of the basic procedures used in estimating source
     emissions from information describing the process, its produc-
     tion rates, production schedules, types of contaminants emitted,
     or the emission control devices currently in service or proposed.
     These procedures should include use of emission factors, materials
     balance, and source test findings.  References 3, 18, 19, and
     23 are relevant in this knowledge area.
36.  Knowledge of the exterior characteristics of plants and facili-
     ties inspected and the location and configuration of the elements

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        of the facility where air pollution problems would be
        evident (e.g., stacks, vents, storage areas).
   37.  Knowledge of the procedures for preparation of flow dia-
        grams of industrial processes.

References
    1.  Air Pollution Sub-Committee.  Odor control manual for the
         rendering industry.   Des Plaines, Illinois:  National Ren-
         derers Association,  January 1969.
    2.  Committee on Industrial Hygiene.   Steel mill ventilation.
         New York:  American  Iron and Steel Institute, May 1965.
    3.  Control Agency Directors S-8 Committee.  Pacific northwest
         emission factors reference manual.  Air Pollution Control
         Association, Pacific Northwest International Section,
         April 1971.
    4.  Cooperative Study Project, Manufacturing Chemists' Association
         and Public Health Service.  Atmospheric emissions from sul-
         furic acid manufacturing processes.   Durham, North Carolina:
         U. S. Department of  Health, Education, and Welfare; Public
         Health Service,  Environmental  Health Service, National Air
         Pollution Control Administration, 1965.  PHSP //999-AP-13.
    5.  Cuffe, S. T., and Gerstle, R. W.   Emissions from coal-fired
         power plants;  a comprehensive summary.  Durham, North
         Carolina:  U. S. Department of Health, Education, and
         Welfare; Public Health Service,  Consumer Protection and
         Environmental Health Service,  National Air Pollution
         Control Administration, 1967.   PHSP 0999-AP-35.
    6.  Danielson, J. A.  (Ed.)  Air pollution engineering manual.  Air
         Pollution Control District, County of Los Angeles.  Cincinnati,
         Ohio:  U. S. Department of Health, Education, and Welfare;
         Public Health Service, Bureau, of Disease Prevention Environ-
         mental Control,  National Center for Air Pollution Control,
         1967.
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 7.  Decker, L. D.  Odor control by incinerator.  Greenwich,
      Connecticut:  UOP Air Correction Division, November 1965.
      (Text of a talk given before a meeting of the Middle States
      Section of the Air Pollution Control Assn., Wilmington,
      Delaware, November 1965).
 8.  Duffee, R. A.  Appraisal of odor-measurement techniques.
      Journal of the Air Pollution Control Association, _7:472-
      474.  July 1968, Vol. 18.
 9.  Environmental Protection Agency, Air Pollution Control Office.
      Air pollution aspects of emission sources;  Municipal in-
      cineration-a bibliography with abstracts.  Research Triangle
      Park, North Carolina:  Author* May 1971.  No. AP-92.
10.  Gulf Publishing Co.  Hydrocarbon Processing Handbook.  Houston,
      Texas:  Author, Box 2608, 77001.
11.  Haaland, H. H. (Ed.)  Methods for determination of velocity,
      dust and mist content of gases.  Bulletin WP-50.  Seventh
      Edition.  Los Angeles:  Western Precipitation Division/
      Joy Manufacturing Company, 1968.
12.  Huey, N. A., Broering, L. C., Jutze, G. A., & Gruber, C. W.
      Objective odor pollution control investigations.  Journal
      of the Air Pollution Control Association, £: 441-444.
      December 1960, Vol. 10.
13.  Ingels, R. M.  The afterburner route to pollution control.
      Air Engineering, June 1964.
14.  Kreichelt, T. E., Kemnitz, D. A., and Cuffe, S. T.  Atmospheric
      emissions from the manufacture of Portland cement.  Cincinnati,
      Ohio:  U. S. Department of Health, Education, and Welfare;
      Public Health Service, Bureau of Disease Prevention and Environ-
      mental Control, 1967.  PHSP #999-AP-17.
15.  Loquercio, Peter, & Stanley, W. J.  Air pollution manual of coding
      ...a coding system for the identification of basic equipment
      and control devices used in industrial processing.  U. S.
      Department of Health, Education, and Welfare; Public Health
      Service Publication No. 1756, 1968.
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16.  MacKnight, R. J., Williamson, J.  E.,  Sableski,  J.  J.,  &
      Dealy, J. A.  Controlling the flue fed incinerator.
      Paper 59-4, presented at the 52nd Annual Meeting  of  the
      Air Pollution Control Association.  Los Angeles:
      Los Angeles Air Pollution Control District,  June  1959.
17.  McGannon, H. E. (Ed.)   The making, shaping and  treating
      of steel.  Eighth Edition.  United States Steel Corporation.
18.  McGraw, M. J., & Duprey,  R. L. Compilation of  air pollutant
      emission factors.  Preliminary document.  Research Triangle
      Park, North Carolina: Environmental Protection Agency,
      April 1971.
19.  National Air Pollution Control Administration.   Air pollutant
      emission factors.  Washington, D. C.:   Department of  Health,
      Education, and Welfare;  Public Health Service, Environmental
      Health Service, April 1970.
20.  National Air Pollution Control Administration.   Control tech-
      niques for hydrocarbon and organic solvent emissions  from
      stationary sources.  Washington, D.  C.:  U.  S. Department of
      Health, Education, and Welfare;  Public Health  Service,
      Environmental Health  Service, March 1970. No. AP-68.
21.  National Air Pollution Control Administration.   Control tech-
      niques for particulate air pollutants.  Washington, D. C.:
      U. S. Department of Health, Education, and Welfare; Public
      Health Service, Consumer Protection and Environmental Health
      Service, January 1969.
22.  National Air Pollution Control Administration.   Control tech-
      niques for sulfur oxide  air pollutants.  Washington,  D.  C.:
      U. S. Department of Health, Education, and Welfare; Public
      Health Service, Environmental Health Service,  January 1969.
23.  Ozolins, Guntls, & Smith, Raymond.  A rapid survey technique
      for estimating community air pollution emissions.  PHSP  I999r
      AP-29, October 1966.
24.  Schueneman, J. J., High,  M. D., & Bye, W. E.  Air pollution
      aspects of the iron and  steel industry.  Cincinnati,  Ohio:
      U. S. Department of Health, Education, and Welfare;  Public
      Health Service, Division of Air Pollution, June 1963.
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25.  Smith, W. S.  Atmospheric emissions from fuel oil combustion.
      An inventory guide.  Cincinnati, Ohio:  U. S. Department of
      Health, Education, and Welfare; Public Health Service, Division
      of Air Pollution, November 1962.  PHSP //999-AP-2.
26.  Standards and Engineering Information - re Boilers
                                              - Superheaters
                                              - Stokers
                                              - Pulverized Fuel Equipment
                                              - Air Preheaters
                                              - Economizers
      Available from the American Boiler Manufacturers Association,
      1180 Raymond Blvd., Newark, New Jersey.
27.  Sticksel, P. R., and Staff (Ed.)  Student's manual for evaluation
      of visible emissions for state and local air pollution inspectors.
      Columbus, Ohio:  BATTELLE Columbus Laboratories, August 1971.
28.  Swearingen, J. S., and Levin, H.  Hydrocarbon losses from the
      petroleum industry in L. A. County.  San Antonio, Texas:
      Southwest Research Institute.
29.  Technical Advisory Board.  Code of recommended practices.  Asphalt
      mixing plants.  Chicago:  City of Chicago, Department of Environ-
      mental Control, April 1971.
30.  Technical Advisory Board. Code of recommended practices.  Fuel
      burning equipment for heating, steam and hot water generation,
      absorption refrigeration.  Chicago:  City of Chicago, Department
      of Environmental Control, October 1968.
31.  Technical Advisory Board.  Code of recommended practices.  Grain
      handling and storage.  Chicago:  City of Chicago, Department of
      Environmental Control, April 1971.
32.  Technical Advisory Board.  Code of recommended practices.  Refuse
      burning equipment for domestic and non-domestic use.  Chicago:
      City of Chicago.  Department of Environmental Control, April 1971.
33.  Technical Advisory  Board.  Code of recommended practices.  Ren-
      dering processes.  Chicago;  City of Chicago. Department of Environ-
      mental Control, April 1971.
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34.  Technical Advisory Board.  Code of recommended practices.   Spray
      booths.  Chicago:  City of Chicago, Department of Air Pollution
      Control, August 1968.
35.  U. S. Department of Health, Education, and Welfare.  Interim guide
      of good practice for incineration at federal facilities.   Raleigh,
      North Carolina:  Public Health Service, Consumer Protection and
      Environmental Health Service,  National Air Pollution Control
      Administration, November 1969.  No. AP-46
36.  U. S. Department of Health, Education, and Welfare.  Specifica-
      tions for incinerator testing  at federal facilities.  Durham,
      North Carolina:  Public Health Service, Bureau of Disease
      Prevention and Environmental Control, National Center for Air
      Pollution Control, Abatement Program, October 1967.
37.  U. S. Department of Health, Education, and Welfare; Public Health
      Service, Division of Air Pollution.  Atmospheric emissions from
      petroleum refineries.  A guide for measurement and control.
      PHSP #763, 1960.
38.  Ward, F. R.  Odor measurement with the Scentometer.  Norfolk,
      Virginia:  Odor Control Subcommittee, Industrial Standards Com-
      mittee, National Renderers Association.
39.  Williamson, J. E., and Hammond, W. F.  Interim guide  to good
      practice for direct-fed multiple-chamber incinerators.
      Los Angeles:  L. A. County Air Pollution Control District,
      October 1966.
40.  Williamson, J. E., MacKnight, R. J., & Chass, R. L.  Multiple-
      chamber incinerator design standards for Los Angeles County.
      Los Angeles:  Los Angeles County Air Pollution Control District,
      October 1960.
41.  Wohlers, H. C.  Recommended procedures for measuring  odorous
      contaminants in the field.  Journal of the Air Pollution Con-
      trol Association. £: 609-612.  September 1967, Vol. 17.
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Special Staffing Guidance
The level of Engineer assigned to an inspection task depends upon factors
including:
   1.  The judged difficulty or complexity of the basic or control
       equipment to be inspected.  Examples of relatively uncomplicated
       basic equipment and control equipment include:
          a.  Buffing and grinding equipment
          b.  Degreasers
          c.  Dry cleaning equipment
          d.  Laundry tumblers
          e.  Oil quench tanks
          f.  Dry cleaning adsorbers
          g.  Spray booths
          h.  Settling chambers
       Examples of more difficult basic and control equipment include:
          a.  Grease solvent extraction units
          b.  Muffle furnaces
          c.  Open-hearth furnaces
          d.  Rendered products handling systems
          e.  Boilers used as an afterburner
          f.  Hot air baghouses
          g.  Vapor recovery units
       Under most conditions senior level Engineers should be assigned
       to inspect the more difficult or complex equipment.  In addition,
       the Engineer who initially processed the permit application for
       which the inspection is relevant is likely to have the best
       background to perform the required inspection.
   2.  Unusual credibility requirements related to the application.  If
       the assignment is likely to be a controversial one, it may be
       advisable to assign the job to a senior level Engineer in order
       to increase the credibility of the agency's position.
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                     Design and Construction of an
                        Episode Control System	
Task Overview
The task described below emphasizes the Engineer's efforts in designing
and developing the episode control system, rather than in operating it
during an episode.  Clearly,  the key to an effective system is a complete
and systematic plan for  the program.  The state-of-the-art in this area
is in its infancy relative to most of the other areas of agency activity.
Few agencies have developed comprehensive programs; however, many of  the
more advanced agencies are planning such a development for the near future.
Even in agencies where a program exists there has been relatively little
experience in operating  it (i.e., combating episode conditions).
The major difference between  state and local programs is the number and,
possibly, diversity of sources to be controlled.  At the state level  the
episode control system designer may deal with statewide organizations
of sources rather than on a one-to-one basis.  The following task is  repre-
sentative of the operations the designer would have to accomplish to  construct
a viable program at most agencies.

Occupational Category;   Engineer (Senior)

   Task Description
      1.  Define the limits of the agency's authority, responsibility, and
          Jurisdiction regarding an episode control system as established
          by the enabling legislation.
      2.  Identify the functional objectives of the episode control system.
          These objectives should be stated at a level of detail which per-
          mits design of the  methods and policies required to accomplish
          them.  The objectives should cover the following areas:
             a.  Curtailment  or elimination of source emissions
             b.  Monitoring of air quality and meteorological conditions
             c.  Enforcement  of curtailment activities
             d.  Communications
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3.  Identify the contaminants that the system will seek to control
    during periods of unusually high and potentially dangerous
    concentrations.  Choice of pollutants will depend upon factors
    such as:
       a.  Current emission levels as depicted in the emission
           inventory.
       b.  Estimated number of sources of the contaminant which will
           have to reduce emission.
       c.  Manpower and facilities available to commit to operation
           of the system.
       d.  Anticipated problems in securing required cooperation
           from individual or groups of sources.
4.  Prepare a detailed description of the manner in which the episode
    control system will operate.  Attend to the following aspects of
    the system:
       a.  Identify the stages of the episode in terms of the ambient
           air contaminant concentrations or meteorological conditions
           which define them (the episode stage criteria).
       b.  Describe the means by which the agency will sense the con-
           ditions which define an episode or stage of the episode.
           Indicate the role of the air monitoring system in the episode
           control effort.  Consider factors such as:
              1)  Reliability and validity of measurements.
              2)  The adequacy of the data acquisition and processing
                  subsystem.  For example, do current measurement units
                  and averaging times correspond with those used for
                  the episode control criteria?
              3)  The facilities that will be used to quickly transmit
                  monitoring system data to the agency.
           Also, indicate how critical meteorological conditions will
           be sensed.  Will National Weather Service regional pollution
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    advisories be used, or will more localized forecasts be
    prepared?  How will periodic weather forecasts be ac-
    quired and evaluated during an episode?  What measurements
    will be taken?  How will these periodic forecasts be
    interpreted in managing the episode control effort?
c.  Establish the general emission reduction objectives for
    each episode stage on a source-category basis.  These
    objectives should describe the general class of actions
    each type of source should take at each stage of the
    episode.  For example, the agency may require "substantial
    curtailment of operations" for refineries during the first
    stage of an episode.
d.  Describe the methods by which the specific emission re-
    duction activities needed to satisfy the general emission
    objectives will be determined for each source.  For example,
    the agency might request each source to fill out a form
    describing the specific actions they volunteer to take to
    satisfy the emission reduction objectives stated for each
    stage of the episode.  These voluntary actions could then
    be compared with actions the agency feels are required and
    possible.  Differences could then be settled through nego-
    tiation.
e.  Describe the methods that will be used to identify and counter
    socially or economically disruptive effects of specific control
    actions.  Particular attention will have to be paid to cur-
    tailment of vehicular traffic and refuse collection.
f.  Identify the major decisions that will have to be made to
    operate the system, who will make them, and the methods (i.e.,
    criteria, rules of thumb) which will be used.  For example,
    how will the sources who must curtail their emissions at a
    given point in the episode be determined?  Who will make
    the decision?
g.  Define the communication requirements of the episode control
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           system.  Consider factors such as:
              1)  How the agency will be informed of the onset of
                  episode conditions.
              2)  Who will have to be contacted (e.g.,  police, news
                  media,  sources, other governmental agencies) in the
                  event an episode occurs.
              3)  What information they need.
              4)  When in the episode they  should be contacted.
              5)  What media should be used (e.g., special telephone
                  line, two-way radio).
       h.   Describe the methods that will be used to enforce the specific
           reduction activities required of each source.  How will viola-
           tions be detected?  What personnel will be committed to the
           enforcement operation?  How will 24-hour enforcement be ac-
           complished during the episode?
       i.   Identify the need for formal,  written procedures and training
           programs.  For example, describe the information to be in-
           cluded in an episode control procedures manual.  What kind
           of training is needed?  Should drills be held periodically?
       j.   Devise a plan for evaluating the entire episode control
           system.  For example, short-term diffusion modeling could
           be used to evaluate the degree of ambient air quality im-
           provement resulting from implementation of the proposed
           emission reductions.
       k.   Identify the conditions under which the episode control
           effort will be officially terminated.
5.  Once the episode control system has been planned, identify the
    individual sources ef the selected contaminants.  Group the sources
    in terms of process or basic equipment similarities (e.g., re-
    fineries, bituminous concrete plants, municipal incinerators).
6.  Identify the type of control actions (either staged or immediate
    full effect) which could be employed to significantly reduce or
    eliminate emissions.   That is for each category of sources:
       a.   Identify the specific operations creating the

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           pollutants and the quantity emitted.
       b.  Identify and describe the status of all control devices
           currently in use on these operations:
              1)  How is it being maintained?
              2)  Is it being operated properly?
              3)  Is it suitable for emergency use?
              4)  Can it be bypassed?
           It may be decided to reduce or shut down processes with
           poor existing control before those processes which are
           already effectively controlled.
       c.  Identify methods of reducing pollutants (e.g., reduction in
           process activity, shutdown of the process, process modifi-
           cation such as a fuel change).
       d.  Identify the equipment which cannot be shut down because
           of danger of damaging the equipment or production of
           excessive emissions caused by shutdown.
       e.  Identify undesirable effects of shutdown including:
              1)  Damage to equipment (e.g., solidification of
                  melted material within furnaces)
              2)  Power for fire protection
       f.  Estimate response time for each of the control techniques.
7.  Select a program of control actions for each category of source
    which provides the greatest emission reduction at the lowest
    price to the industry and the people.  The program should be
    responsive to the emission reduction objectives established
    for the program.
8.  Solicit a control program from each source that details the
    control efforts they will voluntarily take to achieve the
    emission reduction objectives.  This is an optional step.  It
    is possible to simply present the source with the control program
    designed for it by the agency and convince them of its reasonable-
    ness.
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   9.  Secure a commitment from the source to adhere to its control
       program, if and when an episode occurs.  This may require some
       selling.
  10.  Construct the supporting elements of the episode control program
       including:
          a.  Communication arrangments and facilities.
          b.  Enforcement procedures and special contingency plans•
          c.  Administrative and decision-making procedures.
          d.  Training.
          e.  Adequate facilities and procedures for monitoring and
              transmitting air quality and meteorological conditions
              in a form which is directly useful to the episode control
              system.

Skill Requirements
   1.  Ability to recognize and incorporate into relevant planning the
       political and economic characteristics of the locality which
       will influence public and private acceptance of an episode
       control plan.
   2.  Ability to work on the operational and theoretical problems
       of an episode control system and communicate effectively with
       personnel in a variety of air pollution control technical
       disciplines, industry, news media, and citizen groups.
   3.  Ability to communicate effectively in written or spoken form
       with representatives of industry, citizen groups, or politicians
       in working on problems associated with development of an episode
       control system.
   4.  Ability to work with attorneys to interpret the relevant enabling
       legislation and local air pollution control regulations to define
       the agency's authority, responsibility, and Jurisdiction in
       episode control.
   5.  Ability to integrate knowledge of agency capabilities (legal
       and operational) and knowledge of the state-of-the-art in
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    episode control to identify and define the objectives of the
    system to be designed.
6.  Ability to systematically and effectively solve problems or
    make decisions.  This general skill includes:
       a.  Ability to accurately define the problem in terms
           of objective, desirable outcome.
       b.  Ability to accurately and completely identify the
           elements of the situation which affect selection
           or development of a solution.
       c.  Ability to identify and describe potential solutions
           or approaches for developing solutions.
          _                         ><•
       d.  Ability to accurately define the relationships between
           these elements and the alternative solutions to the
           problem.  This includes "trade-offs."
       e.  Ability to set realistic priorities.
       £.  Ability to estimate with a reasonable level of con-
           fidence the probabilities of successful solution for
           each alternative solution.
       g.  Ability to maximize positive payoff by selecting the
           most effective and least costly solution.
    This systematic approach is necessary to effectively integrate
    concern for the broad range of technical areas with the sensi-
    tive personal and social issues which must be considered for
    the ultimate solution.
                     i
    Tasks requiring this ability often may have to be accomplished
    under a high degree of time stress and under public scrutiny.
7.  Ability to identify the contaminants that a proposed episode
    control system should attempt to limit.
8.  Ability to design a working episode control system.  The system
    design should include:
       a.  The stages of the episode in terms of the ambient
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    air contaminant concentrations or meteorological
    conditions which define them (the episode stage
    criteria).
b.  The means by which the agency will sense the con-
    ditions which define an episode or stage of the
    episode.
c.  The general emission reduction objectives for each
    episode stage on a source-category basis.  These
    objectives should describe the general class of
    actions each type of source should take at each
    stage of the episode.
d.  The methods by which the specific emission reduction
    activities needed to satisfy the general emission
    objectives will be determined for each source.
e.  The methods that will be used to identify and counter
    socially or economically disruptive effects of specific
    control actions.  Particular attention will have to be
    paid to curtailment of vehicular traffic and refuse
    collection.
f.  The major decisions that will have to be made to
    operate the system, who will make them, and the
    methods (i.e., criteria, rules of thumb) which will
    be used.
g.  The communication requirements of the episode control
    system.
h.  The methods that will be used to enforce the specific
    reduction activities required of each source.
1.  The need for formal, written procedures and training
    program^
j.  A plan for evaluating the entire episode control system.
k.  The conditions under which the episode control effort
    will be officially terminated.
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 9.  Ability to analyze the basic processes comprising an emission
     source and identify those operations which can be shut down
     or reduced under episode conditions and those which cannot.
     For example, the ability to identify operations which can
     be postponed, such as:
        a.  Asphalt blowing
        b.  Chemical cleaning
        c.  Slag quenching
     Also, the ability to recognize operations which should not be
     shut down because shutdown would create excessive emissions
     or equipment damages.  Examples of operations that should be
     permitted to continue would incl'ude:
        a.  Condensers and coolers
        b.  Sulfur recovery systems
        c.  Facilities necessary for orderly startup
        d.  Power for fire protection
10.  Ability to make and interpret a basic flow diagram which identi-
     fies and shows the relationship of the sub-processes which comprise
     an industrial process.
11 •  Ability to predict how the load requirements on a control device
     will change with time, so that designs can be selected which have
     the greatest productive lengevity.  For example, predict how
     waste material likely to be consumed in an incinerator will change,
     such as an increase in plastics.
12.  Ability to assess the degree to which original control device
     efficiency ratings should be reduced to accurately reflect its
     current condition and operating characteristics.
13.  Ability to recognize the component operations of industrial or
     commercial processes which are being suboptimally performed,
     thus resulting in or contributing to excessive emissions, for
     example:
        a.  Improper coking operation in a fuel burning process.
                               B-94

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        b.  Unbalanced intake and draft air ratio for cookers
            and driers in a rendering plant.
        c.  Improperly enclosed or ventilated loading, unloading,
            or storage areas in a cement plant.
        d.  Sloppy housekeeping operations in a rendering plant.
        e.  Inadequate preventative maintenance program for
            air pollution control equipment.
        f.  Improper charge rate, fuel, or excess air in an
            incinerator.
14.  Ability to accurately estimate the time required for specific
     industries to shut down their processes or portions of their
     operation (without damage or excessive emissions).
15.  Ability to select an appropriate program of control actions
     for each type of source covered in an episode control system.
     The control actions should be responsive to the emission
     reduction objectives of the episode control system.
16.  Ability to carry out task description and task analysis pro-
     cedures as a precursor to personnel system developments
     including:
        a.  Training
        b.  Job specifications
        c.  Personnel selection criteria
        d.  Performance aid development
17.  Ability to prepare training objectives.  These objectives should
     adequately describe the behavior and knowledge to be acquired,
     the conditions under which these behaviors will be employed on
     the job, and the performance levels the trainee must achieve
     to demonstrate competence.
18.  Ability to design and administer the training required to
     prepare an episode control team.
19.  Ability to develop formal procedures to be followed by assigned
     agency personnel during emergency episodes.

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Knowledge Requirements
   1.  Knowledge of the portions of the enabling legislation which
       support development and operation of an episode control
       system.
   2.  Detailed knowledge of the capabilities (operations» methods,
       and facilities) of the functional areas of the agency that will
       participate in the design development and operation of the
       episode control program (e.g., emissions inventory, enforce-
       ment, air monitoring, meteorology).
   3.  Knowledge of industrial and commercial processes which comprise
       the major sources of pollution to support development of an
       episode control system:         <•
          a.  Identification of those processes which can be
              shut down without damage to the equipment or
              excessive emissions.
          b.  Solution of operational problems which may occur
              as a result of shutdowns, e.g., provision for storage
              of materials for the duration of shutdown*
          c.  Approximate shutdown time requirements for categories
              of industries and processes.
   4.  Knowledge of the state-of-the-art in development and evaluation
       of episode control systems.  References 6, 18, 19, 20, 21, 30,
       and 41 are relevant to this topic.
   5.  Knowledge of the "systems approach" to problem solving as a
       method for designing the episode control system.
   6.  Knowledge of the types of responses industry is likely to make
       to the imposition of a source curtailment plan, and the. kinds
       of counter-reactions which the agency can use to solicit their
       cooperation.
   7.  Knowledge of undesirable emission levels for contaminants not
       regulated by local regulations (e.g., documented health, or
       nuisance effects).  These levels are typically established
                               B-96

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     by agency policy with regard to "general air pollution1' type
     prohibitions written into their regulations.
 8.  Knowledge of the published or unpublished sources of information
     available in a variety of areas relevant to air pollution control
     and air quality standards.  Resources typically used in this
     task include:
        a.  The output of abstracting services (e.g., References
            10, 11, 13, 14, 16, 17, 42,  43, and 44).
        b.  Relevant literature reviews  (References 2, 12, 32, 33,
            34, 35, and 36).
        c.  Journal annual indices (Reference 25).
        d.  Proceedings of technical meetings (Reference 61).
        e.  Agency files and publications.
 9.  Knowledge of the suppliers of general information required for
     estimating the emissions of area sources (e.g., fuel suppliers,
     relevant census records) and point  sources (e.g., industrial
     and trade associations).
10.  Background knowledge of source processes complete enough to
     support identification of the elements of the process which
     are likely to emit contaminants to  the atmosphere if not ade-
     quately controlled (e.g., in petroleum refining:  regeneration,
     combustion, compression, storage, and pumping).  Also, knowledge
     of the parameters of each of these  process elements which affect
     the quantity and type of emissions  possible.  This type of
     knowledge is available to a useful  extent in documents of the
     following types:
        a.  Emission factors handbooks (for example, References 4,
            29, 31, and-45).
        b.  Descriptions of source processes, such as manufacturing
            of sulfuric acid or steel, (for example, References 1,
            3, 5, 7, 8, 23, 26, 28, 48,  49, 50, 51, and 60).
                                B-97

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        c.  Descriptions of emission control methods and devices
            (for example, References 38, 39, and 40).
     Another source of this type of knowledge is work experience
     in the process area with emphasis on process design, operation,
     or air pollution control.
11.  Knowledge of the basic procedures used in estimating source
     emissions from information describing the process, its pro-
     duction rates, production schedules, types of contaminants
     emitted, or the emission control devices currently in service
     or proposed.  These procedures should include use of emission
     factors, materials balance, and source test findings.  (Refer-
     ences 4, 29, 31, and 45.)
                                     *
12.  Knowledge of the types of adjustments which, can be made to
     basic equipment or control device operation which can improve
     emissions control (e.g., flame adjustments on an incinerator).
13.  Knowledge of the jargon and terminology used by operators or
     management of the basic or control equipment being inspected
     or reviewed.  This type of knowledge enables the inspector
     or reviewer to adequately describe his findings and to com-
     municate with other knowledgeable Individuals.  For relevant
     References, see Knowledge 17.
14.  Knowledge of the chemical and physical properties of materials
     used in the process bieng inspected or reviewed which, have
     an effect on emissions and possible air pollution.  For
     relevant References, see Knowledge 17.
15.  Knowledge of the>use and construction of the basic or control
     equipment being inspected or reviewed to estimate the effects
     and probability of failures which could have an effect on air
     pollution.  For relevant References, see Knowledge 17.
16.  Knowledge of the specific practices and processes of the type
     of Industry being inspected or reviewed which may contribute
     to air pollution, for example:
        a.  In a refinery, rattling and blowing coke from
            cracking tubes.
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        b.  In metal melting, the air pollution effects of efforts
            to remove metal impurities during the melt process.
        c.  In a rendering plant, housekeeping problems which pro-
            duce odor, such as fat accumulations inside hoods.
     For relevant References, see Knowledge 17.
17.  Knowledge of the sub-processes within the plant being inspected
     or reviewed which have the highest potential pollution effects.
     For example, in a refinery:
        a.  Fluid Catalytic Cracking
        b.  Isomerization
        c.  Crude Distillation
     Basic resource information relevant to the above knowledge areas
     is available from publications of the following types:
        a.  Emission factors handbooks - References 4, 29, 31, and
            45.
        b.  Descriptions of source processes with emphasis on their
            pollution potential - References 1, 3, 5, 7, 23, 26, 28,
            48,  49, 50, 51, and 60.
        c.  Air  pollution engineering guidelines - Reference 8.
        d.  Air  pollution control technology - References 9, 24, 38,
            39,  and 40.
        e.  Local recommended codes of practice - References 52, 53,
            54,  55, 56, 59, and 62.
18.  Knowledge of the uses, assumptions, and procedures of mathematical
     models of pollution diffusion.  For examples of resource materials
     in this area see References 15, 22, 27, 37, 46, 57, and 58.
19.  Knowledge of the services offered by meteorological forecasting
                                                                    i
     organizations available locally.  For example, knowledge of the
     following sources of meteorological support:
        a.  Environment Meteorological Support Units (of the National
            Oceanographic and Atmospheric Administration, NOAA).
                                 B-99

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        b.  Local NOAA services.
        c.  Meteorological consulting companies.
        d.  Services available from local Air Force and Army bases
            and commercial airports.
20.  Knowledge of the techniques for the design of data collection
     forms to be mailed to sources or used in the field by agency
     personnel (see Reference 47).
21.  Knowledge of basic statistical concepts and methodology used
     in mathematical modeling, such as:
        a.  Frequency distribution  (e.g., log normal)
        b.  Measures of central tendency and variability (e.g.,
            arithmetic mean, geometric"mean, geometric standard
            deviation)
        c.  Probability
        d.  Correlation
        e.  Regression equation
        f.  Statistical significance
22.  Knowledge of the procedures for preparation of flow diagrams
     of industrial processes.
23.  Knowledge of principles and procedures for identifying training
     requirements, preparing training objectives, and developing a
     program to achieve the objectives.
24.  Knowledge of the methods used in designing jobs and determining
     the types of individuals to fill the jobs.  In large agencies
     the individuals and teams of people working on episode control
     will have specific assignments.  These tasks will have to be
     designed and assigned so that the control system can accomplish
     its mission speedily.
25.  Knowledge of principles and procedures for organizing an opera-
     tional or task oriented group.
26.  Knowledge of principles and procedures for making work assign-
     ments.  The procedures used will vary depending upon the assign-
     ment policy of the agency.
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  27.  Knowledge of the techniques used in identifying the content
       requirements for and design of a procedures manual to be used
       by personnel involved in an episode control program.

References
   1.  Air Pollution Sub-Committee.  Odor control manual for the ren-
        dering industry.  Des Plaines,  Illinois:   National Renderers
        Association, January 1969.
   2.  California Air Resources Board.   Ambient air quality standards.
        January 1970.
   3.  Committee on Industrial Hygiene.   Steel mill ventilation.
        New York:  American Iron and Steel Institute,  May 1965.
   4.  Control Agency Directors S-8 Committee.  Pacific northwest
        emission factors reference manual.  Air Pollution Control
        Association, Pacific Northwest International Section, April
        1971.
   5.  Cooperative Study Project, Manufacturing Chemists' Association
        and Public Health Service.  Atmospheric emissions from sul-
        furic  acid manufacturing processes.  Durham, North Carolina:
        U. S.  Department of Health, Education, and Welfare;  Public
        Health Service, Environmental Health Service,  National Air
        Pollution Control Administration, 1965.  PHSP //999-AP-13.
   6.  Croke,  E. J., & Booras, S. G.  The design of an air pollution
        incident control plan.  Paper 69-99 presented during the
        June 1969 Annual Air Pollution Control Association Meeting
        in New York City.
   7.  Cuffe,  S. T., & Gerstle, R. W.  Emissions from coal-fired
        power plants;  a comprehensive summary*  Durham, N. C.:
        U. S.  Department of Health, Education, and Welfare; Public
        Health Service, Consumer Protection and Environmental Health
        Service, National Air Pollution Control Administration, 1967.
        PHSP 0999-AP-35.
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 8.  Danielson, J. A. (Ed.)  Air pollution engineering manual.
      Air Pollution Control District, County of Los Angeles.
      Cincinnati, Ohio:  U. S. Department of Health, Education,
      and Welfare; Public Health Service, Bureau of Disease Preven-
      tion Environmental Control, National Center for Air Pollution
      Control, 1967.
 9.  Decker, L. D.  Odor control by incinerator.  Greenwich,
      Connecticut:  UOP Air Correction Division, November 1965.
      (Text of a talk given before a meeting of the Middle States
      Section of the Air Pollution Control Assn., Wilmington,
      Delaware, November 1965.)
10.  Environmental Protection Agency>f Air Pollution Control Office.
      Air pollution aspects of emission sources;  Municipal inciner-
      ation-a bibliography with abstracts.  Research Triangle Park,
      North Carolina:  Author, May 1971.  No. AP-92.
11.  Environmental Protection Agency, Air Pollution Control Office.
      Air pollution aspects of emission sources;  Nitric acid
      manufacturing-a bibliography with abstracts.  Research Triangle
      Park, North Carolina:  Author, May 1971.  No. AP-93.
12,  Environmental Protection Agency, Air Pollution Control Office.
      Air quality criteria for nitrogen oxides.  Washington, D. C.:
      Author, January 1971.  No. AP-84.
13.  Environmental Protection Agency, Air Pollution Control Office.
      Photochemical oxidants and air pollution;  An annotated bibli-
      ography.  Part I.  Research Triangle Park, North Carolina:
      Author, March 1971.  No. AP-88.
14.  Environmental Protection Agency, Air Pollution Control Office.
      Photochemical oxidants and air pollution;  An annotated bibli-
      ography.  Part II.  Research Triangle Park, North Carolina:
      Author, March 1971.  No. AP-88.
15.  Environmental Protection Agency.  Air quality implementation
      planning program.  Vol. 1:  Operators manual.  Washington,
      D. C.:  National Air Pollution Control Administration,
      November 1970.
                                 B-102.

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16.  Environmental Protection Agency, Office of Air Programs.  Air
      pollution aspects of emission sources:  Cement manufacturing-
      a bibliography with abstracts.  Research Triangle Park, North
      Carolina:  Author, May 1971.  No. AP-95.
17.  Environmental Protection Agency, Office of Air Programs.  Air
      pollution aspects of emission sources:  Electric power production-
      a bibliography with abstracts.  Research Triangle Park, North
      Carolina:  Author, May 1971.  No. AP-96.
18.  Environmental Protection Agency.  Guide for air pollution epi-
      sode avoidance..   Research Triangle Park, North Carolina:
      Author, June 1971.
19.  Environmental Protection Agency.  Guide for control of air
      pollution episodes in medium-sized urban areas.  Research
      Triangle Park, North Carolina:  Author, June 1971.
20.  Environmental Protection Agency.  Guide for control of air
      pollution episodes in small urban areas.  Research Triangle
      Park, North Carolina:  Author, June 1971.
21.  Environmental Protection Agency.  Requirements for preparation,
      adoption, and submittal of implementation plans.  Appendices
      D,  E, and F.  Federal Register. V. 36, No. 158, Saturday,
      August 14, 1971.
22.  Gifford, F. A., Jr.  Uses of routine meteorological observa-
      tions for estimating atmospheric dispersion.  Nuclear Safety.
      .2:47-51, 1961.
23.  Gulf Publishing Co.  Hydrocarbon processing handbook.  Houston,
      Texas:  Author, Box 2608, 77001.
24.  Ingels, R. M.  The afterburner route to pollution control.
      Air Engineering,  June 1964, p. 39-42.
25.  Journal of the Air Pollution Control Association, Vol. 20,
      Number 1, January 1970, p. i-vl.  Author and title index
      for Volume 19 (January through. December 1969).
                              B-103

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26.  Kreichelt, T. E., Kemnitz, D. A., & Cuffe, S. T.  Atmospheric
      emissions from the manufacture of portland cement.  Cincinnati,
      Ohio:  U. S. Department of Health, Education, and Welfare;
      Public Health Service, Bureau of Disease Prevention and
      Environmental Control, 1967.  PHSP //999-AP-17.
27.  Martin, D. 0.  An urban diffusion model for estimating long
      term average values of air quality.  J.A.P.C.A.. 21;16-19,
      January 1971.
28.  McGannon, H. E. (Ed.)  The making, shaping and treating of
      steel.  Eighth Edition.  United States Steel Corporation.
29.  McGraw, M. J., & Duprey, R. L.  Compilation of air pollutant
      emission factors.  Preliminary document.  Research Triangle
      Park, North Carolina:  Environmental Protection Agency,
      April 1971.
30.  Nash, Leonard, Fansmith, S. J., & Huston, J. S.  Air pol-
      lution incident control guides - plans.  Philadelphia:
      The Franklin Institute Research Laboratories, December 1970.
31.  National Air Pollution Control Administration.  Air pollutant
      emission factors.  Washington, D. C.:  Department of Health,
      Education, and Welfare; Public Health Service, Environmental
      Health Service, April 1970.
32.  National Air Pollution Control Administration.  Air quality
      criteria for carbon monoxide.  Washington, D. C.i  U. S.
      Department of Health, Education, and Welfare; Public Health
      Service, Environmental Health Service, March 1970.  No. AP-6.2.
                      i
33.  National Air Pollution Control Administration.  Air quality
      criteria for hydrocarbons.  Washington, D. C.:  U. S. Depart-
      ment of Health, Education, and Welfare; Public Health Service,
      March 1970.  No. AP-64.
34.  National Air Pollution Control Administration.  Air quality
      criteria for particulate matter.  Washington, D. C.:  U. S.
      Department of Health, Education, and Welfare; Public Health
      Service, Consumer Protection and Environmental Health Service,
      January 1969.  No. AP-49.
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35.  National Air Pollution Control Administration.   Air quality
      criteria for photochemical oxidants.  Washington,  D.  C.:
      U. S. Department of Health,  Education, and Welfare; Public
      Health Service, Environmental Health Service,  March 1970.
      No. AP-63.
36.  National Air Pollution Control Administration.   Air quality
      criteria for sulfur oxides.   Washington,  D.  C.: U. S.  Depart-
      ment of Health, Education, and Welfare;  Public Health Service,
      Consumer Protection and Environmental Health Service, January
      1969.  No. AP-50.
37.  National Air Pollution Control Administration.   Air quality
      display model.   Washington,  D. C.:   U. S. Department of
      Health, Education,  and Welfare; Public Health  Service,
      November 1969.
38.  National Air Pollution Control Administration.   Control tech-
      niques for hydrocarbon and organic  solvent emissions from
      stationary sources.  Washington, D.  C.:   U.  S. Department
      of Health, Education, and Welfare;  Public Health Service,
      Environmental Health Service, March 1970.  No. AP-68.
39.  National Air Pollution Control Administration.   Control tech-
      niques for particulate air pollutants.  Washington, D.  C.:
      U. S. Department of Health,  Education, and Welfare; Public
      Health Service, Consumer Protection and Environmental Health
      Service, January 1969.
40.  National Air Pollution Control Administration.   Control tech-
      niques for sulfur oxide air pollutants.   Washington,  D. C.:
      U. S. Department of Health,  Education, and Welfare; Public
      Health Service, Environmental Health Service,  January 1969.
41.  National Air Pollution Control Administration.   Guide for air
      pollution episode avoidance.  Washington, D. C.:  Department
      of Health, Education, and Welfare; Public Health Service,
      Environmental Health Service, March 1970.
42.  National Air Pollution Control Administration.  Hydrocarbons
      and air pollution:  An annotated bibliography.  Part I.
      Raleigh, North Carolina:  U. S. Department of Health,

                               B-105

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      Education, and Welfare; Public Health Service, Environmental
      Health Service, October 1970.  No. AP-75.
43.  National Air Pollution Control Administration.  Hydrocarbons
      and air pollution:  An annotated bibliography.  Part II.
      Raleigh, North Carolina:  U. S. Department of Health, Education,
      and Welfare, Public Health Service, Environmental Health Service,
      October 1970.  No. AP-75.
44.  National Air Pollution Control Administration.  NAPCA abstract
      bulletin, Vol. 1, No. 9. Supplement 4.  Research Triangle Park,
      North Carolina:  U. S. Department of Health, Education, and
      Welfare; Public Health Service, Environmental Health Service.
45,  Ozolins, Guntis, & Smith, Raymond.  A rapid survey technique
      for estimating community air pollution emissions.  PHSP #999-
      AP-29, October 1966.
46.  Pasquill, F.  The estimation of the dispersion of windborne
      material.  The Meteorological Magazine, 90_:1063, 33-49, 1961.
47.  Payne, S. L.  The art of asking questions,  Princeton, N. J.:
      Princeton University Press, 1951.
48.  Schueneman, J. J., High, M. D., & Bye, W. E.  Air pollution
      aspects of the iron and steel industry.  Cincinnati, Ohio:
      U. S. Department of Health, Education, and Welfare; Public
      Health Service, Division of Air Pollution, June 1963.
49.  Smith, W. S.  Atmospheric emissions from fuel oil combustion.
      An inventory guide,  Cincinnati, Ohio:  U. S. Department of
      Health, Education, and Welfare; Public Health Service, Division
      of Mr Pollution, November 1962.  PHSP #999-AP-2.
50.  Swearingen, J. S., and Levin, H.  Hydrocarbon losses from the
      petroleum industry in L. A. county.  San Antonio, Texas:
      Southwest Research Institute.
51.  Technical Advisory Board.  Code of recommended practices.  Asphalt
      mixing plants.  Chicago:  City of Chicago, Department of Environ-
      mental Control, April 1971.
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52.  Technical Advisory Board.  Code of recommended practices.  Fuel
      burning equipment for heating, steam and hot water generation,
      absorption refrigeration.  Chicago:  City of Chicago, Department
      of Environmental Control, October 1968.
53.  Technical Advisory Board.  Code of recommended practices.  Grain
      handling and storage.  Chicago:  City of Chicago, Department of
      Environmental Control, April 1971.
54.  Technical Advisory Board.  Code of recommended practices.  Refuse
      burning equipment for domestic and non-domestic use.  Chicago:
      City of Chicago,  Department of Environmental Control, April
      1971.
55.  Technical Advisory Board.  Code of recommended practices.  Ren-
      dering processes.  Chicago:   City of Chicago, Department of
      Environmental Control, April 1971.
56.  Technical Advisory Board.  Code of recommended practices.  Spray
      booths.  Chicago:  City of Chicago, Department of Air Pollution
      Control, August 1968.
57.  Turner, D. B.   A diffusion model for an urban area.  J. of
      Applied Meteorology, _3:83-91, February 1964.
58.  Turner, D. B.   Workbook of atmospheric dispersion estimates.
      Cincinnati,  Ohio:  U. S. Department of Health, Education,
      and Welfare,  National Air Pollution Control Administration,
      PHSP #999-AP-26, 1967.
59.  U.  S. Department of Health, Education, and Welfare.  Interim
      guide of good practice for incineration at federal facilities.
      Raleigh, North Carolina:  Public Health Service, Consumer
      Protection and Environmental Health Service, National Air
      Pollution Control Administration, November 1969.  Publication
      No. AP-46.
60.  U.  S. Department of Health, Education, and Welfare; Public Health
      Service, Division of Air Pollution.  Atmospheric emissions from
      petroleum refineries.  A guide for measurement and control.
      PHSP #763, 1960.

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     61.  U. S. Department of Health, Education, and Welfare; Public
           Health Service, National Center for Air Pollution Control.
           Proceedings;  The third national conference on air pollution,
           Washington, D. C.. December 12-14. 1966.  PHSP #1649.
     62.  Williamson, J. E., & Hammond, W. F.  Interim guide to good
           practice for direct-fed multiple-chamber incinerators.
           Los Angeles:  L. A. County Air Pollution Control District,
           October 1966.

Special Staffing Guidance
1.  Development of an operational Episode Control Program is a task
    which should be assigned to a senior level Engineer.  The primary
    reasons include:                       ,
       a.  Requirements for credibility.  Industrial, commercial, and
           public pollution sources are likely to resist imposition
           of curtailment plans; and negotiations at a high level will
           not be unusual.  The individual who represents the agency
           should be "impressive" in terms of technical background and
           experience.
       b.  Requirements for considerable problem-solving ability involving
           both abstract  (e.g., socio-economic effects) and concrete con-
           cepts (e.g., selection of cost-effective source curtailment
           plans).  The individual developing the Episode Control System
           requires a broad background in industrial processes, air
           pollution control technology, air pollution effects  (on humans
           and plants), and control agency operations.  In addition, the
           assignee should be able to design personnel elements of the
           system including:  development of procedures, job assignments,
           and specialized training for the individuals who will operate
           the system routinely and in emergencies.
2.  One or more Engineering Technicians should be assigned to support the
    Engineer designing the system.  The Engineering Technicians could perform
    tasks including:
       a.  Structuring, analyzing, or filing of responses to questionnaires
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    mailed to sources requesting voluntary curtailment plans
    and other relevant information concerning processes which
    may have to be shut down in an emergency.
b.  Reviewing and analyzing emission inventory data to identify
    major sources of the contaminants to be controlled in
    emergencies.
c.  Initial screening of source curtailment plans to assure
    that the requested information is complete and acceptably
    accurate.
                           B-109

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                Review of Application for Tax Exemption1
                  on Air Pollution Control Equipment
Task Overview
In some localities, tax relief is offered to commercial or industrial
facilities which install air pollution control equipment (e.g., New Jersey).
In order to apply for such an exemption, the facility files an application
identifying and describing its process and control equipment.  Frequently,
these applications are filed in conjunction with an application for a per-
mit to install or construct the relevant equipment, and review of the
exemption application is performed after the permits to install and operate
the equipment have been granted.
The task of reviewing the application for tax exemption is primarily one
of checking it for accuracy and completeness.  The information areas to be
checked can include:
   1.  Identification of claimant.
   2.  Location of facility.
   3.  General description of operations conducted at site.
   4.  Description of process to which control equipment will be
       applicable.
   5.  Description of contaminant to be controlled and the anticipated
       degree of control.
   6.  Description of control equipment including its cost (upon which
       exemption will be calculated).

Occupational Category;  Engineering Technician (Senior) or
                        Engineer  (under special conditions described
                                  under Special Staffing Guidance)
1The task data reported here is incomplete; however, it is considered to
 be highly indicative of the actual task characteristics and skill and
 knowledge requirements.
                                   B-110

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Skill Requirements (Partial)
   1,  Ability to identify errors of omission and factual  errors  in
       reporting the information required by the application form.
       This primarily requires  checking  the  data described in the
       form with that recorded  in the appropriate permit processing
       file.
       One area of data presented in the form which may not be readily
       found in the permit file is the cost  of the equipment of concern.
   2.  Ability to use published guidelines to estimate the cost of  air
       pollution control equipment.
   3.  Ability to communicate with the claimant to secure  additional
       or corrected information as required.
   4.  Ability to determine whether or not the equipment described  in
       the application qualifies for tax exemption.   The following  are
       reasons for rejecting an application  in the State of New Jersey
       (Form AIR-25,  September  1967):
          a.   Not designed, constructed  and/or used for air pollution
              abatement or control.
          b.   A substantial part is  designed or constructed for
              purposes other than preventing air pollution.
              (Reapplication may be  made for that part which
              controls or abates pollution of the outdoor  air).
          c.   The prime function is  other than preventing  pollution
              of the outdoor air.
          d.   Does not comply with existing  State or  local Codes,
              Regulation or Ordinances.
          e.   The performance of the equipment as installed is not
              suitable and adequate for  the  primary purpose of pre-
              venting or abating air pollution.
          f.  Application incomplete or  incorrect.
                                B-lll

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   Knowledge Requirements (Partial)
      1.  Knowledge of the procedures and supporting materials (e.g.,
          cost estimation tables) used to check applications for com-
          pleteness and accuracy.
      2.  Knowledge of air pollution control technology and industrial
          processes at a level suitable for review of tax exemption
          application forms.
      3.  Knowledge of the procedures used to secure missing or cor-
          rected data from claimants.

Special Staffing Guidance
The task of reviewing tax exemption applications in conjunction with a
permit system could be proceduralized to the extent that it could be
accomplished by a senior level Engineering Technician.  The permit processing
operation can automatically make most of the demanding judgments required
to review the application and will provide most of the data needed to
describe the equipment of concern.  The need for a senior level assignee
primarily results from the possible need to communicate with claimants
to secure further information.
However, when tax exemption forms are to be reviewed without the equipment
of concern having been previously reviewed for permits, an Engineer will
be required to make judgments concerning its performance acceptability.
                                     B-ll?

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                               Table B-l

         Additional Engineering Tasks, Suggested Occupational
            Categories, and Rationale for Suggested Category
      Task Title
Review and evaluation of
Environmental Impact State-
ments
    Suggested
   Occupational
    Category
        Rationale
Engineer
Broad-based knowledge
required in engineering
processes with pollution
potential.  Significant
credibility requirement.
Develop and monitor pro-
gress on specific pollution
control programs
Engineer (Senior)
Broad-based knowledge
required in engineering
processes with pollution
potential.  Significant
credibility requirement.
Critical need to communi-
cate effectively with
management of source.
Prepare codes of  recom-
mended design practices  for
basic equipment with  air
pollution potential.
Engineer
Writing capability
required.  General en-
gineering skill and
knowledge required.
Evaluate  effectiveness  of
new  techniques  and equip-
ment in air  pollution
control
Engineer
General engineering skill
and'knowledge required.
 Conduct  detailed investi-
 gation and report on the
 air pollution potential
 of  major industrial,  com-
 mercial,  or public in-
 stallation.
Engineer (Senior)
Broad-based knowledge
required in engineering
processes with pollution
potential.  Significant
credibility requirement.
Critical need to communi-
cate effectively with
management of source.
                                     B-113

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                        Table B-l (continued)
In developing an emission
inventory:

  a.  compare submitted
      process and emis-
      sion data with
      relevant published
      figures (under
      supervision by an
      Engineer)

  b.  calculate emis-
      sion estimates
      using standard
      published factors
      (under close
      supervision of
      an Engineer)
Engineering Technician
Engineering Technician
Task capable of proce-
duralization.  Limited
technical knowledge re-
quired.  Limited public
credibility or communi-
cation required.  Few
decisions.

Task capable of proce-
duralization.  Limited
technical knowledge re-
quired.  Limited public
credibility or communi-
cation required.  Few
decisions.
In a plan review process,
routine screening of de-
signs for presence of
specific characteristics
or minimum objective
criteria (under super-
vision of an Engineer)
Engineering Technician
Task capable of proce-
duralization.  Limited
technical knowledge re-
quired.  Limited public
credibility or communi-
cation required.  Few
decisions.
In an episode control
program:

  a.  organization and
      filing of re-
      sponses from
      sources to in-
      dustrial question-
      naires
  b.  routine check of
      ambient air
      conditions to
      determine if ob-
      jective criteria
      have been exceeded
Engineering Technician
Engineering Technician
Task capable of proce-
duralization.  Limited
technical knowledge re-
quired.  Limited public
credibility or communi-
cation required.  Few
decisions.

Task capable of proce-
dural! zation.  Limited
technical knowledge re-
quired.  Limited public
credibility or communi-
cation required.  Few
decisions.
                                    B-114

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