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.
B-2
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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.
B-4
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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
B-5
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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.
B-7
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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.
B-8
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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.
B-9
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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
B-ll
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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
B-12
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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
B-13
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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.
B-15
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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
B-16
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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).
B-19
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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.
B-21
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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.
B.-23
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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
B-24
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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.
B-25
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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.
B-2'6
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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
B-27
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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.
-------
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.
B-30
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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).
B-31
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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
B-32
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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
B-33
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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).
B-34
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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
B-35
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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.
B-36
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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) .
B-37
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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.
B-38
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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.
B-39
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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.
B-40
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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
B-41
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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
B-42
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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.
B-43
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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)?
B-44
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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.
B-46
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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.
B-48
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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
B-51
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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,
B-53
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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.
B-54
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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
-------
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
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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.
-------
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
-------
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
6-91
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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.
B-98
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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).
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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).
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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,
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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