APTD-1347
GUIDELINES FOR TECHNICAL SERVICES
OF A
STATE AIR POLLUTION CONTROL AGENCY
U. S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Programs
Stationary Source Pollution Control Programs
Research Triangle Park, North Carolina 27711
-------
APTD-1347
GUIDELINES FOR TECHNICAL SERVICES
OF A
STATE AIR POLLUTION CONTROL AGENCY
Prepared by
George A. Jutze, Project Manager
PEDCo-Environmental Specialists, Inc.
Suite 8 Atkinson Square
Cincinnati, Ohio 45246
Contract No. 68-02-0211
Neil Berg, EPA Project Officer
Prepared for
ENVIRONMENTAL PROTECTION AGENCY
Office of Air Programs
Stationary Source Pollution Control Programs
Research Triangle Park, North Carolina 27711
November 1972
-------
The APTD (Air Pollution Technical Data) series of reports is issued by
the Office of Air Programs, Environmental Protection Agency, to report
technical data of interest to a limited number of readers. Copies of
APTD reports are available free of charge to Federal employees, current
contractors and grantees, and non-profit organizations as supplies
permit from the Air Pollution Technical Information Center, Environ-
mental Protection Agency, Research Triangle Park, North Carolina 27711
or may be obtained, for a nominal cost, from the National Technical
Information Service, 5285 Port Royal Road, Springfield, Virginia 22151.
This report was furnished to the Environmental Protection Agency by
PEDCo-Environmental Specialists, Inc., Cincinnati, Ohio, in fulfill-
ment of Contract No. 68-02-0211. The contents of this report are
reproduced herein as received from the contractor. The opinions,
findings, and conclusions expressed are those of the author and not
necessarily those of the Environmental Protection Agency.
Office of Air Programs Publication No. APTD-1347
-------
ACKNOWLEDGMENT
Many individuals and organizations have been helpful in developing
these guidelines; for these contributions the project management extends
its sincere gratitude.
The contributions of Messrs. John Kinosian, Spencer Duckworth, and
K. Nishikawa of the California Air Resources Board; Messrs. Milton
Feldstein, Dario Levaggi, James Sandburg, and Waymon Siu of the Bay Area
Air Pollution Control District; Mr. William Munroe of the New Jersey
Department of Environmental Protection; Mr. Donald Pecsok of the St.
Louis County Division of Air Pollution Control; Mr. Harvey Shell of the
Missouri Air Conservation Commission; Dr. Harry Otto of the Delaware
Division of Environmental Control; Messrs. Charles Copley, Jr., and
William Hager of the St. Louis Division of Air Pollution Control;
Messrs. Richard Hatchard, J. Core, and J. Kowalczyk of the Columbia-
Willamette Air Pollution Authority; and a dedicated group of technical
specialists in EPA, Office of Air Programs were of particular
significance.
Mr. Neil J. Berg, Jr., Environmental Protection Agency, served as
project officer, and Mr. George A. Jutze, PEDCo-Environmental Specialists,
Inc., the project manager, assisted by Messrs. Lawrence A. Elfers and
Thomas C. Purcell.
iii
-------
TABLE OF CONTENTS
1.0 INTRODUCTION 1
1.1 Objective and Scope 1
1.2 Role of Technical Services 2
1.2.1 Role of the Director 2
1.2.2 Role of the Group 3
1.2.3 Operations 3
1.2.4 Data Handling and Analysis 6
1.3 Relationship-of Technical Services Group-to
Other Agency Elements 7
1.4 Functions of the Technical Services Group 7
1.4.1 Operations 7
1.4.2 Data Handling and Analysis 12
2.0 ORGANIZATION STRUCTURE 13
2.1 Health Department Structure 15
2.1.1 Technical Services Group Organization
Within the Health Department 18
2.2 Environmental-Protect!on-Type Agency Structure 20
2.2.1 Technical Service Organization Within the
Environmental-Protection-Type Agency 22
2.3 Separate Air Pollution Control Agency 24
2.3.1 Technical Service Functions Within the
Separate Agency 26
L
2.4 Evaluation of the Technical Service Operations
Within the Three Organization Structures 26
3.0 ANALYSIS OF TECHNICAL SERVICE OPERATIONS 29
3.1 Air Quality Monitoring 29
3.1.1 Primary Networks 31
3.1.2 Secondary Networks. 35
3.1.3 Tertiary Networks 36
-------
TABLE OF CONTENTS
Page
3.1.4 Network or Survey Protocols 39
3.1.5 Network Design Considerations 41
3.2 Surveillance Monitoring Required by Air
Quality Standards 43
3.3 Responsibilities in Support of Implementation Plans. ... 49
3.3.1 Source Emissions Testing 49
3.3.2 Emergency Episode Monitoring 52
3.3.3 Analyzing Special Samples 54
3.3.4 Defining Source Impact 56
3.4 Special Studies 57
3.4.1 Instrument Evaluation 57
3.4.2 Atmospheric Chemistry Studies 59
3.5 In-House Laboratory Considerations 60
4.0 LOCATION AND DIVISION OF TECHNICAL SERVICES
RESPONSIBILITIES 65
4.1 Overall State Program—Division of Responsibilities ... 65
4.2 State Technical Services—Division of Responsibility ... 66
4.2.1 Types of Technical Service Facilities 66
4.2.2 Location of the Technical Service Facilities ... 67
4.2.3 Allocation of Technical Functions 68
4.2.4 Number of Technical Services Facilities 70
4.3 Organizational Considerations 70
4.3.1 The Independent State Agency 70
4.3.2 The State and Local Agency Co-op 70
4.3.3 Intergovernmental Responsibilities 72
5.0 LEGAL CONSIDERATIONS 73
5.1 Requirements for Jurisdictional Samples 73
5.1.1 Definition 73
5.1.2 Regulatory Authority—General Considerations ... 73
5.1.3 Purpose of the Clean Air Act 75
5.1.4 Requirements Under the Clean Air Act 75
5.1.5 Jurisdictional Samples as a Basis for
Regulations—Program Criteria 75
VI
-------
TABLE OF CONTENTS
Page
5.2 Samples Used as Legal Evidence 78
5.2.1 Purpose of Samples 79
5.2.2 Rules of Evidence 79
5.2.3 Taking the Sample 80
5.2.4 Transporting and Handling the Sample 89
5.2.5 Analysis 91
5.2.6 Report on the Findings 91
6.0 MANAGEMENT OF THE TECHNICAL SERVICES GROUP 94
6.1 General System Management 95
6.1.1 Planning 96
6.1.2 Organizing 98
6.1.3 Staffing 101
6.1.4 Budgeting 102
6.1.5 Directing 104
6.1.6 Coordinating 105
6.1.7 Analysis 105
6.1.8 Reporting 107
6.2 Specific Systems Management 108
6.2.1 Resources: Personnel 109
6.2.2 Resources: Facilities 116
6.2.3 Specific Techniques for Technical
Services Group Management 120
7.0 DATA HANDLING 130
7.1 Data Flow 130
7.1.1 Local to State 131
7.1.2 State to Local Agency 133
7.1.3 State to Federal 134
7.1.4 Federal to State. 134
7.2 Records .' 135
7.2.1 Reporting Formats 135
7.2.2 Station Operator Logs 139
7.2.3 Summary Formats 139
7.3 Hardware Assistance 142
7.3.1 Current Practices 145
7.3.2 Advantages 148
vn
-------
TABLE OF CONTENTS
Page
7.3.3 Disadvantages 149
7.3.4 Recommended Utilization 150
8.0 LABORATORY QUALITY ASSURANCE PROGRAM 151
8.1 Introduction 151
8.2 Importance of Laboratory Quality Control 154
8.3 Proposed Laboratory Quality Assurance Program 157
8.3.1 Federal Agency Role in Quality Assurance 158
8.3.2 State Agency Role in Quality Assurance 160
8.3.3 Local Agency Role in Quality Assurance 163
8.3.4 Internal Laboratory Control of Analytical
Performance 163
8.3.5 Inter!aboratory Quality Control 189
9.0 CONTRACTING CONSIDERATIONS 200
9.1 Contract Areas 202
9.1.1 Sampling Program 205
9.1.2 Analysis Program 209
9.1.3 Data Handling Program 214
9.2 Contract Mechanisms 214
9.2.1 Types of Contracts 215
9.2.2 Contract Cost Arrangements 216
9.2.3 Contract Planning and Management 217
10.0 REFERENCES 222
Appendix A. Sampling Location Guidelines 231
Appendix B. Job Classifications 237
Appendix C. Summary of the NY/NJ Air Pollution
Abatement Activity Monitoring Program . , 271
Appendix D. Air Pollution Control Agency Manpower Model .... 277
Appendix E. Interagency Contracts for Technical
Services—A Checklist 283
vm
-------
List of Figures
Figure Page
1. Functional relationships of technical services
manager 4
2. Typical air pollution technical services 5
3. Administrative management services 8
4. Enforcement services 9
5. Engineering services 10
6. Typical State health department organizational structure . . 17
7. Organizational structure of typical environmental
protection agency 21
8. Typical organization structure of the separate air
pollution control agency 25
9. Laboratory services request form (an example) 61
10. Typical maintenance journal entry 86
11. Example of preprinted form for analysis and receipt
of source samples 90
12. Typical organization chart for technical services group. . . 99
13. Particulate sampling record 136
14. Raw sampling and laboratory data coding form 137
15. Card punch format for 24-hour data 138
16. Card punch format for continuous sampling data 140
17. Station operator's log 141
18. Cumulative frequency distributions of selected
pollutant concentrations 143
19. Monthly summary of hourly pollutant concentration data ... 144
20. Control chart for analysis of standard 175
21. Control chart 176
C-l. Location of air monitoring sites in the N.Y.-M.J.
Abatement Activity 275
-------
List of Tables
Table Page
1. Classification of Organization Structure of State
Air Pollution Control Agencies 14
2. Relative Degree of Effective Technical Operation
Within the Three Organization Structures 27
3. Components Used in Effects Sampling 38
4. Criteria for Classification of Air Quality Control
Regions 44
5. Recommended Number of Air Quality Monitoring Sites 45
6. Tabulation of In-House Laboratory Analysis Functions .... 63
7. Allocation of Technical Services Functions 69
8. Allocation of Responsibility for Technical Services
Functions Requiring Intergovernmental Cooperation 71
9. Use of Jurisdictional Samples and Amenability to
Challenge 80
10. Relation of Sampling Procedures to Evidence 81
11. Summary of Monitoring Network St. Louis Air Quality
Control Region Ill
12. Technical Services Personnel 114
13. Relative Annual Salaries and Within-Grade Salary Ranges. . . 115
14. Manpower-Labor Cost Requirements for Laboratory
Operations 128
15. Instruments Used in the Air Pollution Control Program. ... 178
16. Instrumental Quality Control 180
17. Ancillary Services Quality Control 182
18. Quality Control Requirement Based on Ski 11-Time-Use
Rating of Air Pollution Laboratory Operations 186
19. Typical Contractable Laboratory Program Functions 203
20. Measurement Methods for Special Air Pollutants 211
21. Typical Allocation of Responsibilities for Contracting
and Procurement in State Air Pollution Control Agencies. . . 220
A-l. Sampling Location Guidelines for Areas of Estimated
Maximum Pollutant Concentration 233
D-l. Basic Predictors and Manpower Factors for Manpower
Estimates 279
D-2. Summary of Man-Year Estimates for Example Agency 280
-------
GUIDELINES FOR TECHNICAL SERVICES OF
A STATE AIR POLLUTION CONTROL AGENCY
1.0 INTRODUCTION
1.1 Objective and Scope
The purpose of this document is to present guideline information
which will assist the user in detailing the needs and requirements
of a statewide air pollution control technical services system stressing
laboratory operations.
A number of State, regional, and local agencies, all operating
•^ •
or cooperating in the provision of services to support total agency
functions, were visited. Their individual situations and operational
programs were compiled into "case histories" which formed the data
base utilized in this effort. These data were then analyzed and the
subsequent evaluations used to assist in documenting a significant
number of elements or factors which will, in a given situation,
influence the organization of a statewide laboratory system.
In order for this document to be useful, the reader must acquire
a basic understanding of the responsibilities which any State agency
has to the governmental groups structured both above and below it:
A State agency must relate to both its regional and local agencies in
varying degrees of assistance and surveillance, as well as to the
i
Federal agency which oversees it, supplies guidance to it, and supple-
ments its funding. A local agency must recognize its relationship
with and responsibilities to the State and, at the same time, fulfill
its obligations to municipal government. Conversely, the Environmental
Protection Agency (EPA) is required to implement its grant programs,
-------
assure reasonable progress toward attainment of air quality standards,
and provide overall technical leadership without negating the influence
and authority of the State. Thus, the State program generally finds
itself "in the middle".
This document will attempt to provide administrators and those
faced with planning for new, modified, or expanded State technical
service groups, with guidelines for operating in the areas of organiza-
tion, management, program element definition, legal considerations,
technical functions, and quality control.
1.2 Role of Technical Services
1.2.1 Role of the Director
Before attempting to describe the role of the technical services
group, we should consider the position of the technical services group
manager (or chief, director, head, etc.). This person does exactly
as the title indicates: he manages or directs the activity; he does
not do all the work. Although he may take care of some of the detail,
his prime function is to see that it gets done. He may not make all
the decisions, but he sees to it that the required information and
services are available. His function and responsibilities may be
tabulated as follows:
(a) Planning the program and establishing overall project
schedules;
(b) Planning the group's budget and controlling the expenditure
of approved funds;
(c) Recruiting, selecting, and continuous training of staff;
(d) Selecting equipment, approach, methodologies, and outside
services when required;
-------
(e) Obtaining necessary commitments from both in-house and
outside elements;
(f) Organizing, staffing, controlling, and directing all projects
from initiation through completion of final report;
(g) Providing assistance and support to all other program
elements;
(h) Maintaining a dynamic communications system.
These functions are graphically displayed in Figure 1.
1.2.2 Role of the Group
*
The primary role of the technical services group including its
laboratory is to provide timely support services to all other program
elements.
Figure 2 presents the primary and secondary service areas
encompassed by typical air pollution technical services and lists the
major functions within each service area. However, considerable vari-
ability in the scope of these functions can exist. The following brief
discussion exhibits how this variability can influence the structure
of several technical service program areas.
1.2.3 Operations
An air quality surveillance program is composed of three distinct
but interrelated elements: sampling networks, laboratory support, and
data acquisition and analysis. Network designventaiIs such considera-
tions as the number and type of stations needed, their location,
frequency of sampling, duration of each sample, the type and effort
of analysis, and the like. The kind of network specified for a given
region will also determine the requirements for laboratory and data
-------
c
Vendors
/" \i—^£
iContractorsM!,1, •'.;,.'
consultants
INPUTS
1. Proposals, Reports
2. Plans, Evaluations
3. Support Services
4. Job Descriptions, Requests
5. Payment Authorizations
6. Specifications, Sources
1. Orders, Contracts
OUTPUTS
A. Decisions, Directions
B. Budget, Schedules
C. Problem Definition
D. People
E. Accounting, Checks
F. Expediting, Contracting
G. Equipment, Supplies, Services
Usual flow of
services
Inputs
Outputs
Figure 1. Functional relationships of technical services manager.
-------
Service areas
Primary
Secondary
Operations-
•Laboratory—
(Analytical)
Surveillance
-Instrumentation-
-Field Services
Data handling
and analysis -
•Data Processing-
Major functions
0 Source Sampling
Support & Analysis
0 Air Monitoring Support
_^_ Special Studies Support
0 Monitoring System Design
and Specification
0 Air Quality Data
Acquisition
0 Meteorological Data
Acquisition
0 Dispersion Modeling
0 Episode Criteria
^«. Monitoring
0 Instrument Design &
Specification
0 Instrument Calibration
0 Instrument Service &
Maintenance
0 Instrument Inventory
^M»
0 On-Site Source Testing
0 Monitoring Site
Preparation
0 General Field
_ Site Preparation
0 Data Reduction, Summari-
zation & Display
0 Computer Programs
(Surveillance, Emission
Inventory , etc . )
_^ Computer Operations
•Statistics-
Statistical Studies
Figure 2. Typical air pollution technical services,
-------
acquisition and analysis procedures. For example, with automatic
(continuous) instrumentation, the need for routine laboratory support
is greatly reduced but the amount of data transmission, validation,
and reduction is significantly increased.
Support of surveillance networks requires laboratory operations
ranging from very simple to highly complex. The requirements for
laboratory support, in terms of size and complexity, will be specified
by the pollutants of interest in the region, size of the networks,
and the degree of pollution. Generally, the laboratory must at least
be equipped for analysis of ambient samples for which Air Quality
Standards have been established, and should provide for calibration
of all collecting and measuring devices and preparation of reagents.
Some regions will require laboratory capability for analyses
of hazardous materials such as beryllium, mercury, and asbestos.
Analyses of fluorides and other more unique pollutants, such as
polycyclic organic matter, along with fuels and solvents must often
be provided.
1.2.4 Data Handling and Analysis
The development of data handling procedures is an essential
function of the total laboratory facility. The requirements for the
flow of data between cooperating agencies coupled with the reporting
requirements, defined in the Federal Register of August 14, 1971,
demand a defined data flow (1) between State and regional/local
agencies, and (2) between the Federal and State agencies. Following
the definition of data flow, formats for recording basic data and
-------
for routine and specialized reports plus reporting procedures must
be designed to provide pertinent information in a timely fashion.
1.3 Relationship of Technical Services Group to Other Agency Elements
In an air pollution control agency, the technical services group
provides across-the-board services to the other major program elements:
administrative, enforcement, and engineering. Figures 3, 4, and 5
graphically display the primary and secondary responsibilities and
functions usually assigned to each of these three agency elements.
In many of these functional areas, the technical services group
*
including its laboratory provides a significant amount of technical
support. These areas of related activity are designated on each table
by the symbol (T) . Detailed exploration of these interagency relation-
ships will be performed in the subsequent sections of this document.
1.4 Functions of the Technical Services Group
In order to establish an understanding of what is encompassed
by our general definitions of technical services, the functions given
in Figure 2 are described.
1.4.1 Operati ons
1.4.1.1 Analytical Laboratory. Its functions include receiving,
logging, preparation, and analysis of submitted samples. Samples can
include those collected in the ambient atmosphere and in source emission
tests; samples of liquid and solid fuels; samples of materials collected
by particulate and gaseous control devices; and samples of materials,
vegetation, and body fluids resulting from complaint investigations
or special studies. Analytical methods employed can range from simple
gravimetric/volumetric procedures to sophisticated physical/optical
-------
Responsibilities
Primary
Management
systems
Secondary
Agency I L]
Planninc
Systems
Development
Liaison-
Technical ( L
1— Informatio:
__ Budget
Administration —
Control
L— Personnel
Staff
development &
training
Manpower f L]
Major functions
E Policy
Program Planning
_T°~ Program Evaluation
LL. Control Strategies
Clntergovernment
Relations
Public Relations
Public Information
0 Technical Reports
^Technical Manuals
r°~Functional Requirement
!_!_ Organizational
Requirements
f°"procurement^)
-I ° Property
Lf_Financial Accounting
(By Functional Program)
r° Employment
-| ° Records
Ll.Payroll
"""Orientation and Training
(New Personnel)
0 Recruitment and Selection of
L— Procedures I LJ—
Legal
counsel
— Litigation r\—
_l,Job Description
""standard Operating
Procedures
0 Technical Manual and
Procedures
Legal Opinion &
Research
Prosecution, Court
r .. Procedures
Legal
L— Planning "
j ° New Legislation/ Drafts
-j ° New Legislation, Hearings
I° Variance Procedures,
Hearings
Figure 3. Administrative management services
-------
Re sponsibi1itie s
Primary
Area 1
Secondary
Patrol 1-
1
I
i
1
1
I
ZXt-oa M
irat.J.ux
1
1
1
I
1
|
Major functions
0 Violation Detection
and Enforcement
Action (Visible
Emissions, Odors,
Opening Burning)
0 Evidence Gathering I L]
for Prosecution
0 Prosecution Testimony f L]
0 Complaint Investigation fLl
0 Episode Control C'Lj
__ Enforcement ^"^
b__
0 Inspections
(Annual and Operational
Permit Renewal)
0 Emission Inventory
Updating
0 Specialized Industry
Control
Figure 4. Enforcement services.
-------
Responsibilities
Primary
Engineering
operations
Secondary
-Registration-
-Permit-
Emission
'Inventory"
Regulation _
Development
Major functions
0 Registration System
Development & Up-
dating
0 Boiler Registration
0 Incineration Regis-
tration
0 Industrial Process
Source Registration
°~ Permit System Develop-
ment & Updating
0 Process Application
Review (Permit Grant
or Denial)
0 New Construction -
Field Inspection
0 Inventory Development
& Maintenance fy
JLEmission Factors Study
«•«
0 Control Effectiveness
Determination & Re-
port ^^
0 Industry Episode Plan
Review
0 Control Regulation
Needs Determination
Figure 5. Engineering services.
10
-------
techniques requiring complex and expensive equipment. Also included
are: the calibration of all laboratory devices, standardization and
preparation of all sampling media, housekeeping, preparation and
updating of laboratory methods manuals, implementation of a quality
control program, and maintenance of chain of custody and integrity
of data to provide legal evidence in support of enforcement.
1.4.1.2 Surveillance. This function includes planning and
designing of all air quality monitoring networks and studies (both long-
and short-term), providing the sampling site operators and routine
•
maintenance services, and acquiring all raw air quality and meteoro-
logical data. This function may include competency in meteorological
modeling and provision of this expertise for control strategy evaluation
and episode control. This function also includes coordinating the
acquisition of data from intensified air quality monitoring during
air pollution episodes.
1.4.1.3 Instrumentation. This function includes the installation,
calibration, and specialized repair of all aerometric monitors. This
also provides evaluation of new or improved sensors (pollutant and
meteorological), as well as specifications for procurement. It also
services and maintains all equipment utilized in source testing and
special studies. This function is usually responsible for the shop
and storage areas and equipment, and maintains the hardware inventory.
It may provide equipment or device fabrication services.
1.4.1.4 Field Services. This function includes provision of
equipment operators and site preparation for emission source tests.
installation of services and shelter (when required) for air quality
monitoring equipment, and general field operation services.
11
-------
1.4.2 Data Handling and Analysis
1.4.2.1 Data Processing. This function includes the reduction of
all raw data to summary tabulations and graphic displays. This function
provides programming services for enforcement management systems, for
updating and analyzing data, and for control strategy evaluations and
forecasts. This function may also include the provision of computer
operations and services. Also included are the data storage and
retrieval responsibilities of the program.
1.4.2.2 Statistics. This function includes the provision of
expertise in the manipulation, analysis, and specialized evaluation
of data generated by both the program and outside sources.
12
-------
2.0 ORGANIZATION STRUCTURE
The organization structure of the air pollution control agency
employed at the State level must be examined in order to obtain an
optimum operation of the technical services group functions. There
exists among the 50 States a variety of agency organization structures.
These various structures can be grouped into three major categories:
(a) The air pollution control agency within the health department;
(b) The air pollution control agency as an independent agency;
(c) The air pollution control agency within, a total environmental
program: environmental protection agency.
Table 1 lists the existing State agencies with respect to these
categories. Approximately 50 percent of the State agencies fall under
the health department classification; approximately 30 percent can be
classified as an environmental-protect!on-type (EP-type) agency. Those
agencies with two or more environmental programs, such as air and water
together, are considered as EP-type agencies. The remaining State
agencies fall into the separate agency classification.
Organizational structure on the local level has a tendency to
become more diversified. Local agencies have been found within such
disciplines as building departments, sewer districts, recreation
commissions, and health and safety divisions, in addition to structures
similar to those above. Considerations within this chapter are addressed
to the State agency level but can be applied to all levels of air
pollution control agencies.
There are many similarities among these three structures. The
top echelon of authority is the Governor of the State. This position
13
-------
Table 1. CLASSIFICATION OF ORGANIZATION STRUCTURE OF STATE
AIR POLLUTION CONTROL AGENCIES
Air pollution
control agency
within
health department
Air pollution
control agency
within total
environmental agency
Independent
air pollution
control
agency
Alabama
Arizona
Colorado
Georgia
Hawaii
Idaho
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maryland
Massachusetts
Michigan
Montana
Nevada
North Dakota
Ohio
Oklahoma
Rhode Island
South Dakota
Tennessee
Texas
Utah
Wyoming
Alaska
California
Connecti cut
Delaware
Illinois
Mai ne
Mississippi
Nebraska
New Jersey
New Mexico
New York
North Carolina
Oregon
Pennsylvania
Vermont
Washington
Wisconsin
Arkansas
Florida
Minnesota
Missouri
New Hampshire
South Carolina
Virginia
West Virginia
will have no direct bearing on the technical services group functions.
The next common constituent will be a board or a commission, as the
case may be. As a result of the requirements under the Clean Air
Act of 1970, each State has adopted a board or commission to
promulgate regulations and provide a means for decisionmaking in
regard to program directives and policy. Many times this governing
body will have a direct effect on the technical services group functions.
As a result of the formulation and adoption of air pollution regulations,
14
-------
additional requirements are placed on the technical services group.
Normally input from this area is necessary prior to the formulation of
the regulation and after adoption there is the need for analytical
support of enforcement efforts which follow.
For these reasons a majority of the board members should be
technically qualified in the field of air pollution. Without such
a background the technical personnel will have difficulty in communi-
cating with the board on these matters; as a result, the effective-
ness of the program will be decreased.
The remaining organization entities are similar in purpose, but
have definite differences in their structures which result in assets
or liabilities to the individual program. Typical organizational
structures, representing these three primary classifications are
presented below and their impact on the laboratory functions are
considered.
2.1 Health Department Structure
Historically, many of the State agencies found outside the health
department today can trace their origin to the health department.
This is a result of the initial recognition of air pollution impact
on the population and its health effects. After a period of develop-
ment, many agencies within the health department began to meet
responsibilities which were considered outside the primary function
of the health department. These areas included such activities as
monitoring, enforcement, and engineering. Many of the agencies grew
in staff and facilities, and frequently the air pollution entity became
as large as or even larger than other sections within the
15
-------
health department. For these reasons, the agencies disassociated
themselves from the department. Nevertheless, a majority of the States'
air pollution control agencies still reside within the health department
structure.
A typical health department structure is presented in Figure 6.
As one can see, there are many activities within this structure which
are not related to and normally have little effect on the air program.
However, situations sometimes arise, particularly in newly formed
agencies, whereby the agency is dependent upon the technical services
of the health department. The ramifications of this situation are
discussed under Section 2.1.1.
The executive officer or the program director, as the case may be,
is normally next in the chain of organization structure, beneath the
Governor and the board. Often when the State air program is relatively
small, this position is filled by the health commissioner who is a
member of the medical profession. A person in this position needs the
ability to communicate on technical matters to the board as well as
provide technical direction to this subordinate staff. Larger, well-
established comprehensive programs normally find that this position
is best filled with a person qualified in the technical aspects of
environmental sciences in addition to having management capabilities.
The remaining structure of the organization is usually divided
into management, technical services, engineering, and enforcement
groups. For the purpose of this document, only the functions of the
technical services group will be considered.
16
-------
WATER POLLUTION
CONTROL BOARD
AIR POLLUTION
CONTROL BOARD
1 1
BUREAU OF
GENERAL SERVICES
BUREAU OF
PREVENTIVE
MEDICINE
1 1
DIVISION OP
ADMINISTRATION
DIVISION OF
LEGAL SERVICES
DIVISION OP
MEDICAL FACILITIES
DIVISION OF
VITAL STATISTICS
~" DIVISION OF
CHRONIC DISEASES
DIVISION OF
COMMUNICABLE
DISEASES
DIVISION OF
MATERNAL AND CHILD
HEALTH
DIVISION OF
DENTAL
HEALTH
1
1
j
-
GOVERNOR
DIRECTOR OF HEALTH
ASSISTANT
DIRECTOR
-
BUREAU OP
ENVIRONMENTAL
HEALTH
DIVISION OF
OCCUPATIONAL
HEALTH
DIVISION OF
SANITATION
DIVISION OF
ENGINEERING
1
AIR POLLUTION
UNIT
-
PUBLIC HEALTH
COUNCIL
MEDICARE
STAFF
1
BUREAU OF
LOCAL HEALTH
SERVICES
1
DIVISION OF
NURSING
DIVISION OF
PUBLIC HEALTH
EDUCATION
DIVISION OF
LOCAL SERVICES
-
BUREAU OF
PUBLIC HEALTH
LABORATORIES
1
DIVISION OF
PUBLIC HEALTH
LABORATORIES
REGIONAL
LABORATORIES
Figure 6. Typical State health department organizational structure.
-------
2.1.1 Technical Services Group Organization Within the Health
Department
Among the major areas of endeavor that can be found in technical
services programs are laboratory analysis, monitoring, and data handling.
Within the other activities of the health department, there exist similar
functions in two of these areas, the laboratory and data handling. The
cooperative use of personnel, facilities, and equipment in these areas
result in an economic advantage. For this reason the technical service
requirements of the air program are normally included with the other
technical service needs of the health department.
The manager of the technical services group must have a wide
technical background in such areas as biochemistry, bacteriology,
radiology, milk and food sanitation, air and water chemistry, and
competencies in the related fields of instrumentation and computer
sciences. Efficient supervision of such a varied technical services
group will require expert management capabilities and experience.
Five major disadvantages associated with this type of comprehensive
technical services group program with respect to the needs of the State
agency are as follows:
(a) Priority Requirements—Often the priority given to the
analysis of air pollution samples are secondary to that
of those of the health department.
(b) Level of Competencies—As a result of the diversity of the
analytical activities, a lower level of competency is sometimes
maintained in the air pollution area. This is especially true
in those cases where the air pollution control agency is in
its early stages of development.
18
-------
(c) Personnel Management—As a result of the many activities
carried out by the same group, additional supervision,
personnel scheduling, and work shifts are sometimes required
to meet the needs of the total department. Often this is a
source of personnel problems.
(d) Communications—Often communication problems arise as a
result of the varied interests and backgrounds of the personnel
within the department.
(e) Flexibility and Responsive ness—The analytical needs of the
air pollution control agency can be quite variable. The
rigid structure of the health department technical services
group normally does not respond well to those needs.
One working solution to these problems is to establish within the
health department technical services group a separate air pollution
control technical services section. This section would be under the
direction of one individual with a separate staff. This approach
is commonly employed in large, well-developed agencies within health
department structures. It eliminates many of the disadvantages
associated with comprehensive health department technical services,
but the economic advantage of the cooperative usage of facilities
and equipment remains. As an .'agency develops, so will the technical
service requirements. At some point in this development these require-
ments will be sufficient to support a limited staff of three to four
technical people. At this point the formation of this separate technical
service section to meet the agencies needs is advisable.
Advantages resulting from the technical services within the health
department organizational structure can be outlined as follows:
19
-------
(a) Availability of Additional Staff—The agency can call on the
large number of health department inspectors and field
personnel to support short-term or intermittent activities,
such as odor surveys, special effect studies, episode
surveillance, and the collection of intermittent air pollution
samples. These personnel are usually available but are not
trained or experienced. This aspect could become a problem
if the other more numerous agencies call upon the air agency
for temporary support.
(b) Medical Consultation—The excellent rapport with the medical
profession which exists within the health department becomes
advantageous during episodal periods and for long-range
health effect studies.
(c) Equipment and Facilities—The equipment and facilities found
within the health department laboratories are normally
directly adaptable to needs of the technical requirements
of the air pollution agency. Therefore, their cooperative
usage can be advantageous.
2.2 Environmental-Protection-Type Agency Structure
The environmental-protection-type agency structure initially appears
extremely complex. This "super" agency in reality is only a vehicle
for assembling and administering the total environmental program of
the State. Figure 7 depicts a typical statewide environmental
protection agency. Often each individual environmental activity within
this agency performs its designated function independently of each
other. As a result, many air pollution agencies within this structure
20
-------
GOVERNOR
ENVIRONMENTAL
BOARDS
1 1
DIRECTOR, EP-type
LEGAL COUNCIL AND
ADVISORY STAFF
DEPARTMENT OF AIR
RESOURCES
AIR QUALITY
DIVISION
MOTOR VEHICLE
DIVISION
DEPARTMENT OF
WATER RESOURCES
WATER QUALITY
DIVISION
STREAM AND LAKE
DIVISION
DEPARTMENT OF
SOLID WASTE
DEPARTMENT OF
CONSERVATION
GAS AND OIL
DIVISION
FORESTRY AND
GEOLOGY DIVISION
DEPARTMENT OF WILD
LIFE AND PARKS
1
PARKS DIVISION
GAME AND FISH
DIVISION
DEPARTMENT OF
INDUSTRIAL SAFETY
INCINERATOR
DIVISION
LAND FILL
DIVISION
NOISE .DIVISION
ACCIDENT CONTROL
DIVISION
Figure 7. Organizational structure of typical statewide environmental protection agency.
-------
can be considered as a separate agency. The majority of the well-
established, comprehensive state air pollution control programs fall
within this category.
2.2.1 Technical Service Organization Within the Environmental-
Protection-Type Agency
After the common elements of the board and program director, the
technical services group manager is the next element in the organization
structure. This position requires competency in the fields of environ-
mental engineering and chemistry, particularly analytical. Expertise
in biochemistry, bacteriology, radiology, and milk and food sanitation
is not required as it is when the position is within health department
structure. Normally, because this person does not have to be qualified
in fields irrelevant to air pollution, he will be better qualified
to perform the function of this position.
The activities of the technical services group under this structure
with regard to air pollution control activities, are the same as
described under the health department structure. Within the EP-type
structures existing today, two levels of activities are evident. In
the case of the well-established, comprehensive State agency, a high
degree of responsiveness and comprehensiveness can be found. These
State agencies, as stated before, appear to function independently of
other agencies within the EP-type structure.
There appear to be no inherent disadvantages as a result of the
EP-type structure with regard to these agencies. The advantages are
the same as those discussed in Section 2.3: Separate Air Pollution
Control Agency. The other level of technical service function, found
to exist with the remaining agencies with EP-type structures, is
22
-------
normally less responsive and comprehensive. These agencies for the most
part are in their formative stages. Within these agencies one can find
many interagency cooperative endeavors, the most common of which is the
function of laboratory and data handling. For example, air and water
laboratory service functions are commonly found combined. Also, State-
owned computer hardware is normally shared by all agencies. This combina-
tion of efforts is usually more compatible than the cooperative efforts
within the health department structure. The reason for the higher
degree of compatibility can be found in the common goals, requirements,
and related expertise of the cooperating agencies. Problems or dis-
advantages can occur as a result of these cooperative efforts. These
disadvantages are similar to those found within the health department
structure and are summarized as follows:
(a) Priority Requirements—Often the priority given to the
analysis of air pollution samples is secondary to that of
those of the other cooperating agencies.
(b) Level of Competencies—As a result of the diversity of the
analytical activities, a lower level of competency is
sometimes maintained in the air pollution area. This is
especially true in those cases where the Air Pollution
Control Agency is in its early stages of development
(c) Personnel Management—As a result of the many activities
carried out by the same group, additional supervision,
personnel scheduling, and work shifts are sometimes required
to meet the needs of all the cooperating agencies. Often
this is a source of personnel problems.
23
-------
The advantages of intercooperative endeavors within the EP-type
structure outweigh the disadvantages; therefore, these endeavors are
encouraged. The most prevalent advantages resulting from these
cooperative endeavors are:
(a) Equipment and Facilities—The joint use of technical service
equipment and facilities for the related agencies within the
EP-type agency is a definite economic advantage.
(b) Personnel Compatibility—As a result of the similarity in the
technical backgrounds of the EP-type agency personnel
involved in these joint endeavors, communications and
personnel compatibility among the staff are facilitated.
(c) Flexibility—The increased resources of both material
and personnel as a result of the cooperative endeavor
provides the EP-type agency with a higher degree of flexi-
bility and responsiveness during short periods of increased
responsibility.
2.3 Separate Air Pollution Control Agency
Structurally the separate State agency exists as an independent
State agency or as an independent entity of a larger State agency.
Separate air pollution control agencies are commonly found within
health department and EP-type agencies. Normally these agencies operate
completely independent of their sister or parent agencies. A typical
organizational structure of this agency is shown in Figure 8. The
board, manager and technical service positions can be considered
identical to those presented in Section 2.2.
24
-------
ro
ENGINEERING
GOVERNOR
BOARD
DIRECTOR
LEGAL COUNSEL
ENFORCEMENT
TECHNICAL SERVICES
ADMINISTRATION
Figure 8. Typical organization structure of the separate air pollution control agency.
-------
2.3.1 Technical Service Functions Within the Separate Agency
The degree of effectiveness with respect to such functions as the
laboratory, monitoring, and data handling will be directly proportional
to the resources of the agency. The only disadvantage with this
structure is realized in the case of the newly formed agency with
inadequate personnel and physical resources. Since these agencies
operate separately, the effect of cooperative ventures is not realized.
Program cost per amount of services received can be expected to be
higher in the case of the smaller agencies but for the larger agencies
the cost efficiency should be the same.
The advantages realized as a result of this type of organization
structure can be summarized as follows:
(a) Priority Requirements—The total efforts of this function
can be directed toward the needs of the agency.
(b) Level of Competency—As a result of the single field of
endeavor, the staff members tend to develop a higher degree
of expertise in their individual area.
(c) Personnel Management—Better personnel relations tend to
exist as a result of the well-defined program directives.
(d) Flexibility and Responsiveness—The needs of the agency can
be given the total attention of the technical services group;
as a result a high degree of flexibility and rapid response
to the changing requirement can be achieved.
2.4 Evaluation of the Technical Service Operations Within_ the Three
Organization Structures
As a result of personal interviews with several agencies, published
and unpublished State agency yearly progress reports, Federal grant
26
-------
Table 2. RELATIVE DEGREE OF EFFECTIVE TECHNICAL OPERATION
WITHIN THE THREE ORGANIZATION STRUCTURES
Requirements
Routine analyses
Special analyses
Research/development
Continuous
monitoring
Laboratory Q.C.
Episode monitoring
Calibration
Data evaluation
Field investiga-
tion and support
Support facilities
and equipment
Agency within
health dept.
G
F
F
F
G
G
F
G
* *
F , E
E
Agency within total EP-type
and independent agency
E
E
G
G
G
G
E
E
G
G
Degrees of effective operation are:
F - Fair
G Good
E - Excellent
*
Ability to respond with additional field personnel support excellent
but special analytical requirements resulting from this activity
would be fair.
application information, and Federal EPA reports evaluating State
and local agencies, a comparison of relative effectiveness of the
technical operations of the three organizational structures was made
and is presented in Table 2.
Two of the organizational structures, the independent and the
EP-type, resulted in the same advantages for the well-established
agency. However, it should be noted that for a newly formed agency, the
27
-------
ability to enter into cooperative ventures with sister agencies would
be a definite advantage; therefore, under this circumstance the EP-type
structure would be more desirable.
28
-------
3.0 ANALYSIS OF TECHNICAL SERVICE OPERATIONS
The air pollution technical services group operates much as the
typical "support services" type of organization. It has its routine and
regular activities, both within the laboratory proper and in the field.
It has the usual demands placed on it for immediate response to unfamiliar
situations, nonroutine investigations and analysis, and modification
or development of techniques and equipment. Of course, what makes this
technical services group with its facilities and resources unique are
the activities to which it is applied. This section is devoted to
a discussion of these categorical operations.
3.1 Air Quality Monitoring
Surveillance of air quality has become an increasingly important
function of an air pollution control agency, particularly at the State
level. Surveillance is usually the only program element for which
technical services takes primary, rather than support, responsibility.
Initially, the agency must determine the magnitude and scope of its
air pollution problem, i.e., the extent to which air quality standards
are being exceeded. These data may then be used to fit a simulation
model for the area or, as input to a relationship based on proportional
reduction or roll-back techniques, to develop an effective emission
control plan. Following the adoption of emission regulations, atmos-
pheric surveillance is required to evaluate the progress toward the
attainment of air quality goals. Additionally, for those areas having
possible periods of high air pollution (episodes), surveillance becomes
a vital part of the Emergency Action Plan.
The Clean Air Act of 1970 stresses the importance of air quality
surveillance as an integral part of the State's implementation plan.
29
-------
Specifically, Section 110(a) (2) (c) of the Act requires that,
"it (the implementation plan) includes provisions for
establishment and operation of appropriate devices,
methods, systems, and procedures necessary to (i) monitor,
compile, and analyze data on ambient air quality and
(ii) upon request, make such data available to the
Administration."
Recently, the Environmental Protection Agency has summarized the
objectives of air quality monitoring. Air quality surveillance within
a region must provide information to be used as a basis for the following
actions:
(a) To judge compliance and/or progress made toward meeting
ambient air quality standards.
(b) To activate emergency control procedures to prevent air
pollution episodes.
(c) To observe pollution trends throughout the region including
the nonurban areas. (Information on the nonurban areas
is needed to evaluate whether air quality in the cleaner
portions of a region is deteriorating significantly and
to gain knowledge about background levels.)
Cd) To provide a data base for application in evaluation of
effects; urban, land use, and transportation planning;
development of abatement strategies; and development and
validation of diffusion models.
Sampling site and equipment requirements are generally divided
into three categories, consistent with desired averaging times:
i
(a) Automatic—Pollutant concentrations measured with a
continuous analyzer and results recorded automatically;
30
-------
(b) Intermittent—Pollutant concentrations determined from
integrated hourly or daily samples on a fixed schedule;
(c) Static—Pollutant estimates or effects determined from
weekly or monthly exposure of qualitative measurement
devices or materials.
3.1.1 Primary Networks
Air quality surveillance networks that employ automatic equipment
to continually sample and analyze pollutant levels may be classified
*
as primary. Primary monitoring stations are generally located in areas
where pollutant concentrations are expected to be among the highest
in the area and in areas of highest population density. In addition,
these stations are designated as a part of the air pollution episode
warning system.
General guidelines applicable to sampling station location include
the following:
(a) Avoid locations that have restrictions to air flow in the
vicinity of the air inlet, such as adjacent buildings,
parapets, trees;
(b) Avoid sampling locations that are unduly influenced by
downwash from a minor local source or by reentrainment
L
of ground dust, such as a stack located on the roof of a
building where the air inlet is located or close to ground
level near an unpaved road;
(c) Avoid locations that are inaccessible with regard to adverse
weather conditions, subject to vandalism, or are otherwise
insecure.
31
-------
Specific sampling location guidelines, recently developed by EPA,
are found in Appendix A.
3.1.1.1 Operations. The technical services group must supply a
highly skilled technician who is responsible for the routine operation of
one or more primary sites. Typical qualifications and job descriptions
for such personnel are presented in Appendix B.
Provision for reagent preparation, spare parts, and instrument
calibration must also be considered. The magnitude of this requirement
will vary depending on the number of stations and their proximity to
each other and to a central support laboratory. In all cases, equipment
such as an analytical balance, colorimeter, calibration equipment,
and a source of pure water (distilled or deionized) will be required
to support the primary station. Much of this equipment could be
maintained at a central support laboratory and used as needed in the
field.
The Federal Continuous Air Monitoring Program, as well as agencies
such as the California Air Resources Board, the New Jersey Department
of Environmental Protection, the Los Angeles County and Bay Area Air
Pollution Control Districts, and the New York Department of Environ-
mental Conservation, have developed a series of internal information
memorandums covering operational protocols, spare parts requirements,
logistics, and the like that can serve as examples. Generally speaking,
all of these organizations have established technical information
offices which will supply data upon request or arrange your itinerary
should you wish to visit specific agency personnel.
o
3.1.1.2 Maintenance and Trouble Shooting. Continuous monitors,
like most electromechanical equipment, require general maintenance for
32
-------
prolonged satisfactory operation. With proper care and replacement of
expendable parts, extended and trouble-free operation can be obtained
with these devices. Manuals should cover the following areas:
(a) Routine Maintenance—Procedures for the care and cleaning
of the monitors on a regular schedule must be prepared.
Such activities insure that the station operator is pursuing
a continuous surveillance program relative to the operational
parameters of each monitoring system;
(b) Preventive Maintenance —General schedules for the replace-
ment of mechanical, electrical, chemical, and optical
components must be developed. The necessity of replacement
should be established through a predetermined set of
inspections and tests designed to give a warning to the
operator of prospective trouble.
The basic philosophy for operational manuals dealing with trouble-
shooting air monitors is to develop systematic and simplified proce-
dures for checking the operability and accuracy of the system.
2
A system of go/no-go checks should be developed to determine
the operability of the equipment. This simple series of checks is
designed to locate the problem area in one of three general categories:
electrical, mechanical, or chemical. A tabulation of the most commonly
occurring failures and remedies for these possible problems should be
presented.
Instructions must be provided for the logging of pertinent
operational data, e.g., zero drift, calibration checks, malfunctions,
and the like. Formats should be developed for recordkeeping. Data
33
-------
validation procedures should be established relative to the various
modes of data reduction (on-line computer, semiautomatic, manual)
currently utilized for continuous equipment output. Recommended data
reduction schemes that are based on the objectives and needs of the
State and cooperating agencies must be implemented.
3.1.1.3 Field Calibration and Validation of Data. The accuracy
and hence the usefulness of data from air monitoring programs are
dependent to a great extent upon the ability to calibrate the instrument
under actual operating conditions. For continuous automated measure-
ments, a dynamic calibration is required whereby the measuring instru-
ment is calibrated with a known quantity of gaseous pollutant while
the complete system is operational in the field. Under field conditions,
absolute calibrations are difficult and often impossible to achieve;
however, reliable quantitative analyses can be accomplished if equi-
valent calibrations are performed against an acceptable standard.
Since most present-day monitoring instrument systems are subject
to drift and variation in internal parameters, they cannot be expected
to maintain accurate calibration over long periods of time. Therefore,
it is necessary to check and standardize operating parameters on a
periodic basis; a direct, dynamic calibration utilizing the pollutant
species being monitored is desirable.
Dynamic calibration techniques have been described in a prior
guideline manual entitled "Field Operations Guide for Automatic Air
Monitoring Equipment". These as well as other published techniques
4-10
applicable for field calibration of air monitors should be
consulted.
34
-------
3.1.2 Secondary Networks
Air quality surveillance networks that employ equipment to provide
intermittent hourly or daily integrated samples, which are subsequently
analyzed in the laboratory to determine pollutant levels, may be
classified as secondary. Secondary monitoring stations are generally
located to coincide with population and emissions density. Their
objective is to define concentration levels that are representative
of any area of a region where air quality standards have the potential
*
to be exceeded.
Guidelines applicable to primary site location are applicable
to secondary as well.
3.1.2.1 Operations. The technical services group must supply a
trained technician who is responsible to the routine operation of at
least several secondary sites. Typical qualifications and job descrip-
tions for such personnel are presented in Appendix B.
As stated in Section 3.1.1.1, provision for expendable supplies
(filters, reagents, etc.), spare parts (motor brushes, pumps, bubblers,
etc.), and instrument calibration (flow meters, volt-ohm meters, etc.)
must be considered in light of the number of stations, their proximity
to each other, and the central support laboratory or satellite office.
Again, the agencies cited previously have developed standard operations
procedures which can be used for reference.
3.1.2.2 Maintenance and Calibration. The basic equipment utilized
at secondary sites consists of samplers for particulates and specific
gases. Procedures for maintenance and calibration of such devices
are supplied by the respective manufacturer. Also, maintenance,
35
-------
calibration, and general good practice guidelines are found in
"standard" or "reference" techniques which have been reported for
participates (suspended and soiling) ~ and gases. ' Of course,
the Federal Register of November 25, 1971, presents the reference
methods for the National Primary and Secondary Ambient Air Quality
18
Standards.
3.1.3 Tertiary Networks
Air quality surveillance networks that employ static equipment
or materials, which are subsequently analyzed in the laboratory to
estimate pollutant levels or effects, may be classified as tertiary.
Tertiary monitoring stations are generally located geographically,
either across the board on a grid basis to obtain areawide relative
measurements, or specifically clustered to determine point source
impact.
3.1.3.1 Operations. The technical services group must supply a
semiskilled technician who is responsible for the routine operation of
many tertiary sites. Typical qualifications and job descriptions for
such personnel are presented in Appendix B.
3.1.3.2 Static Systems. Static or effects sampling systems
are designed to be used in estimating the nature and extent of air
pollution on a long-term basis. Individual components used are
selected because of their simplicity and relatively low cost of
preparation, operation, and analysis. In keeping with the concepts
of simplicity and low cost, the systems are designed as static testing
devices requiring no electricity. As a result, they can be easily
located in remote locations.
36
-------
19
In a recent report that evaluated the performance of regional
effects sampler networks, the following conclusions were reached:
(a) The effects sampler is capable of detecting the existence
of five major pollutants—sulfur oxides, particulates,
nitrogen oxides, hydrogen sulfide, and acid aerosols—and
one potential problem, oxidation potential. The conclusion
\
is based upon either direct correlation of sampler data with
air quality or emissions data, or on strong evidence of
source-receptor relationships.
(b) The effects sampler can be used to detect gross differences
in pollution levels. This conclusion was substantiated
either by the differences observed in the frequency distri-
bution of pollutants at various classes of stations or by
comparison of pollutant levels with emission levels, and by
correlations with air quality data.
(c) Components of the sampler can provide evidence of air
pollution effects. The most notable effects are related
to corrosion; however, damage to rubber and nylon was
noted.
(d) Evaluation shows that the eight components listed in
\
Table 3 provide valid data relative to the pollutant
or effect cited.
Effects networks have limitations:
(a) Exposure periods for the components vary from 7 days to 1
year, which makes it difficult to analyze the results;
(b) Air pollutants or their effects cannot be determined over
short time intervals;
37
-------
Table 3. COMPONENTS USED IN EFFECTS SAMPLING
Component Pollutant or effect
Sulfation plate Sulfur dioxide
Sticky paper Soiling potential, particulate
Dustfall Soiling potential, settleable particulate
Quarterly steel Corrosion
Fabric No. 3 Oxides of nitrogen
Silver plate Hydrogen sulfide
Rubber strip Oxidation potential
Monthly nylon Acid aerosol
(c) Data provided by some of the components are unreliable
in that they lack specific knowledge of the measured
pollutant(s);
(d) Detailed knowledge of replicate sampling errors for
the individual components is not available;
(e) The network does not permit a detailed assessment of
meteorological influences on the data;
(f) Since the methods are nonspecific, quantitative estimations
are not valid.
However, results from these types of static sampling networks
can often assist the administration by pointing out pollution problems
in areas where few data are available and by providing preliminary
information for future commitment of resources.
Most of the analyses of effects monitoring components can be
accomplished with routine laboratory equipment. If fabric fading
19
or reflectance measurements are desired, specialized optical meters
or contracted analytical services must be provided.
38
-------
3.1.4 Network or Survey Protocols
After the technical services group decides to establish an air
quality monitoring network, or even a relatively short-term aerometric
survey with a specific objective, it should draft a protocol that
outlines the general plan, delineates responsibilities, and sets
schedules and assignments. A typical protocol should cover the
following points:
(a) Introduction—This defines the scope and. objectives
of the effort, for example: "To assess the sources,
characteristics, concentrations, and intrastate movement
of air pollution that may affect health and welfare in
the metropolitan regions of the State, and to enhance
the development of an effective program for abatement
and control of air pollution throughout the State."
(b) Area—The boundary designations are especially necessary
in the specific survey effort that is often aimed at
assessing the impact of a single source.
(c) Measurement program—This defines the categorical
measurements to be accomplished and their sampling frequency.
Major items to be covered include:
(1) Air quality measurements,
(2) Effects of pollution,
(3) Meteorology,
(4) Calibration.
39
-------
(d) Participating agencies—This defines, when applicable,
the cooperating parties (Federal, State, local, private) and
should also include a listing of the personnel, equipment,
and any other resources committed to the effort by all of
the participants.
(e) Schedule—This presents the general schedule of operations,
including the conduct of on-site field operations as well as
the laboratory analyses program, reduction and summarization
of data, and reporting due-dates.
(f) Administrative operations—This establishes the intergovern-
mental relationships and responsibilities and should stipulate
the following:
(1) Each participant will provide salary, travel, per diem,
and administrative support for its personnel assigned
or detailed to the activity;
(2) Each participant will maintain and operate air sampling
equipment and provide supplies as necessary for equipment
that it devotes to the activity;
(3) The State program will establish field liaison with
operating elements of all participants and will provide
overall supervision.
(g) Exchange of data—This establishes the procedures and
responsibilities of data transmission and should stipulate
that all data obtained by the participants must be forwarded
to the State on a predetermined schedule, and,that the State
technical services group will tabulate and distribute data
summaries at appropriate intervals.
40
-------
3.1.5 Network Design Considerations
In designing an air quality surveillance program, the following
four criteria for locating sites must be considered:
(a) Monitoring stations must be pollution oriented;
(b) Monitoring stations must be population oriented;
(c) Monitoring stations must be source oriented;
(d) Monitoring stations must provide areawide representation
of air quality.
»
In order to select locations according to these criteria, it is
necessary to have detailed information on the location of sources of
emission, the geographical variability of ambient pollutant concen-
trations, meteorological conditions, and population density.
Therefore, the selection of the number, location, and type of
sampling stations within an AQCR is a complex problem without a purely
objective solution. The variability of sources and their intensity,
terrain, meteorological conditions, and demographic features requires
that each network be developed individually. The network chosen will
be the result of subjective judgments, based upon available evidence
and the experience of the decision team.
The sampling site selection process involves consideration of
economic, logistic, atmospheric, and pollutant reaction factors in
addition to the motivation for and the objective of the sampling
program. None of the factors stands alone; each is dependent in part
upon the others. However, the objective of the sampling program
must be clearly defined before the selection process can be initiated.
The initial definition of priorities may have to be reevaluated after
41
-------
consideration of the remaining factors before the final locations are
chosen.
The economic considerations are rather clearly defined. The amount
of money required for data gathering (instrumentation, installation,
maintenance, data retrieval system), data analysis (subjective or
objective), and data interpretation must be balanced against the
available monies (current and projected) and the cost-benefits of
additional or relocated sampling sites.
The logistical problems involve the means of obtaining, analyzing,
and interpreting the data. It must be determined whether the current
staff can manage the proposed system, or more or fewer persons are
required to accomplish the tasks. It is important to decide if the
information derived is necessary on a real-time basis or if several
weeks may elapse before it is needed.
The atmospheric problems pertain to definition of the spatial and
temporal variability of the pollutants and their transport. Local
effects upon the air trajectories by buildings, terrain, and heat
sources or sinks can produce local anomalies of excessive pollutant
concentration. Wind velocity, wind shear, and atmospheric stability
greatly influence the dispersal of pollutants.
Additionally, a sampling site or an array of sites for one
pollutant may be inappropriate for another pollutant species because
of the configuration of sources, local meteorology, or terrain.
Atmospheric chemical reactions such as the production of ozone in ttiie
presence of nitrogen oxides and hydrocarbons, and the time delay
between nitrogen oxides and hydrocarbons emissions and the peak ozone
42
-------
values may require either a sampling network for the precursors of
ozone and/or a different network for the actual ozone measurement.
Pollutants undergo changes in their composition between their emission
and their detection; therefore, the impact of that change upon the
measuring system should be considered.
While the interaction of the factors identified in the above
paragraphs is complex, the siting problem can be resolved. It requires
experience in the operation of air quality measurement systems, estimates
of air quality, field and theoretical studies of atmospheric diffusion,
consideration of atmospheric chemistry, and air pollution effects; this
combined expertise provides the input for determination of optimum
sampling site selection.
An application of the above-noted considerations in the design
of an air monitoring program is found in the New York-New Jersey Air
20 21
Pollution Abatement Activity. ' A detailed summary of this effort is
presented in Appendix C.
3.2 Surveillancejtonitoring Reqjm-ed by Air Quality Standards
Criteria for determining the number of monitoring sites required
for adequate surveillance in an Air Quality Control Region were
18
published in the Federal Register. by the Environmental Protection
Agency. The criteria are based on the priority (I, II, III) assigned
to a region (see Table 4).
The minimum requirements for the establishment of an air quality
monitoring system based on the priority classification of a region
are presented in Table 5. One or more monitoring sites are required
for each of the five pollutants in a Priority I region. For regions
43
-------
Table 4. CRITERIA FOR CLASSIFICATION OF AIR QUALITY CONTROL REGIONS
Concentrations in micrograms per cubic meter (ppm in parentheses)
Pollutant
Sulfur oxides
Annual arithmetic mean
24-hour maximum
3-hour maximum
Part icu late matter
Annual geometric mean
24-hour maximum
Carbon monoxide
8-hour maximum
1-hour maximum
Nitroqen dioxide
Annual arithmetic mean
Photochemical oxidants
1-hour maximum
I
> 100
(.04)
> 455
(.17)
> 95
> 325
> 14a
"(12)
>55a
"(48)
> no
•(.06)
> 195
'(.ID)
Priority
II
60-100
(.02-. 04)
260-455
(.10-17)
> 1300
(.50)
60-95
150-325
III
< 60
(.02)
< 260
(.10)
< 1300
(.50)
< 60
< 150
<14a
'(12)
< 553
(48)
< 110
(.06)
< 195
(.10)
a Concentration in milligrams per cubic meter.
classified as Priority II or III, the minimum requirements provide
for monitoring suspended particulates and sulfur dioxide with 24-hour
sampling every 6 days.
It must be kept in mind that these criteria establish minimum
requirements and do not necessarily limit the size and scope of a
network designed to monitor the progress toward the attainment of air
quality standards.
44
-------
Table 5. RECOMMENDED NUMBER OF AIR QUALITY MONITORING SITES
Regi onal
classifi-
cation
I
Pollutant
Suspended
parti cu-
lates
Sulfur
dioxide
f
Carbon
monoxi de
Photo-
chemi cal
oxidants
Nitrogen
di oxi de
Measurement
methodi
High volume
sampler
Tape sampler
Pararos an-
iline or ,j
equivalent
Nondispersive
infrared or
equivalent6
Gas phase
chemi lumin-
escence or
equivalent'
24-hour sam-
pling method
(Jacobs-Hoch-
heiser method)
Region
population
Less than 100,000
100,000-1,000,000
1,000,000-5,000,000
Above 5,000,000
—
Less than 100,000
100,000-1,000,000
1,000,000-5,000,000
Above 5,000,000
Less than 100,000
100,000-5,000,000
Above 5,000,000
Less than 100,000
100,000-5,000,000
Above 5,000,000
Less than 100,000
100,000-5,000,000
Above 5,000,000
Less than 100,000
100,000-1,000,000
Above 1,000,000
Minimum number of air
quality monitoring
sites3
4
4 + 0.6 per 100,000b
7.5 + 0.25 per 100,000b '
12 + 0.16 per 100,000b
One per 250,000b up to
8 sites
2
2.5 + 0.5 per 100,000b
6 + 0.15 per 100,000b
11 + 0.05 per 100,000b
1
1 + 0.15 per 100,000b
6 + 0.05 per 100,000b
1
1 + 0.15 per 100,000b
6 + 0.05 per 100,000b
1
1 + 0.15 per 100,000b
6 + 0.05 per 100,000b
3
4 + 0.6 per 100,000b
10
Minimum
frequency
of samolinq
One 24-hour
sample every
6 daysc
One sample
every 2 hours
One 24-hour
sample every
6 days (gas
bubbler)0
Continuous
Continuous
Continuous
One 24-hour
sample every
14 days (gas
bubbler)9
-------
Table 5 (continued). RECOMMENDED NUMBER OF AIR QUALITY MONITORING SITES
Regional
classifi-
cati on
II
III"
Pollutant
Suspended
particu-
lates
Sulfur
di oxl de
Suspended
parti cu-
lates
Sulfur
di oxi de
Measurement
method1
High volume
sampler
Tape sampler
Para ros aniline
High volume
sampler
Pararos aniline
Region
populati on
--
—
—
--
Minimum number of air
quality monitoring
sites4
3
1
3
1
1
1
Minimum
frequency
of sampling
One 24-hour
sample every
6 daysc
One sample
every 2 hours
One 24-hour
sample every
6 days (gas
bubbler)*
Continuous
One 24-hour
sample every
6 daysc
One 24-hour
sample every
6 days (gas
bubbler)c
a In interstate regions, the number of sites required should be prorated to each State on a population basis.
Total population of a region. When required number of samplers includes a fraction, round off to nearest whole number.
c Equivalent to 61 random samples per year.
Equivalent methods are (1) Gas Chromatographic Separation-Flame Photometric Detection (provided Teflon is used
throughout the instrument system in parts exposed to the air stream), (2) Flame Photometric Detection (provided
interfering sulfur compounds present in significant quantities are removed), (3) Coulometric Detection (provided
oxidizing and reducing interferences such as Og, NOg. and HgS are removed), and (4) the automated Pararosaniline
Procedure.
e Equivalent method is Gas Chromatographic Separation - Catalytic Conversion - Flame lonization Detection.
Equivalent methods are (1) Potassium Iodide Colorimetric Detection (provided a correction is made for SO? and N02),
(2)_UV Photometric Detection of Ozone (provided compensation is made for interfering substances), and (3) Chemilumin-
escence Methods differing from that of the reference method.
-------
Table 5 (continued).
RECOMMENDED NUMBER OF AIR QUALITY MONITORING SITES
FOOTNOTES (continued)
1
Equivalent to 26 random samples per year.
It is assumed that the Federal motor vehicle emission standards will achieve and maintain the national standards
for carbon monoxide, nitrogen dioxide, and photochemical oxidants; therefore, no monitoring sites are required
for these pollutants.
All measurement methods, except the Tape Sampler method, are described in the national primary and secondary
ambient air quality standards published in the Federal Register on April 30, 1971 (36 F.R. 8186). Other methods
together with those specified under footnotes (d), (e), and (f) will be considered equivalent if they meet the
following performance specifications:
Pollutants
Specification
Range
Minimum detectable
sensitivity
Rise time, 90%
Fall time, 90S
Zero drift
Span drift
Precision
Operation period
Noise
Interference
equivalent
Operating tempera-
ture fluctuation
Linearity
Sulfur dioxide
0-2620yg/m3
(0-1 ppm)
26 ug/m3
(0.01 ppm)
5 min.
5 min.
+ 1 :" per jday and
+_ 2% per 3 days
+ 1% per day and
+ 2% per 3 days
±2%
3 days
+ 0.5% (full
scale)
26 pg/m3
(0.01 ppm)
+ 5° C
2% (full scale)
Carbon monoxide
0-53 mg/m3
(0-50 ppm)
0.6 mg/m
(0.5 ppm)
5 min.
5 min.
+ }% per day and
+ 22 per 3 days
•^ li per day and
+_ "; per "< days
i4%
3 days
+ 0.5". (full
scale)
1 . 1 mg/m
(1 ppm)
+ 5° C
2% (full scale)
Photochemical
oxidant*
0-880 ug/m
(0-0.5 ppm)
20 g/m3
(0.01 ppm)
5 min.
5 min.
+ 1% per day and
+. 2% per 3 days
+ 1% per day and
i 2% per 3 days
^4%
3 days
+ 0.5% (full
scale)
20 yg/m
(0.01 ppm)
£5° C
2% (full scale)
Nitrogen dioxide
0-1880 wg/m3
(0-1 ppm)
1 9 v g/mj
(0.1 ppm)
5 min.
5 min.
+ 1% per day and
+_ 2% per 3 days
+ 1% per day and
+_ 2% per 3 days
+ 4%
3 days
+• 0.5% (full
scale)
19 pg/m3
(0.01 ppm)
+ 5° C
2% (full scale)
Hydrocarbons (CH^)
0-16 mg/m
(0-25 ppm)
0.16 mg/m,
(0.25 ppm)
5 min.
5 min.
+ 1% per day and
i 2% per 3 days
+ 1% per day and
i 2% per 3 days
+_4Z
3 days
+ 0.5% (full scale)
.32 mg/m
(0.5 ppm)
i 5° C
2% (full scale)
*Corrected for NO, & SO, .
^ ' I rnnt. innpd 1
-------
Table 5 (continued). RECOMMENDED NUMBER OF AIR QUALITY MONITORING SITES
FOOTNOTES (continued)
Corrected for N09 and S09.
** L '*•
These specifications are defined below:
Range; The minimum and maximum measurement limits.
Minimum detectable sensitivity; The smallest amount of input concentration which can be detected as
concentration approaches zero.
Rise time 90%; The interval between initial response time and time to 90% response after a step
increase in inlet concentration.
Fall time 90%; The interval between initial response time and time to 90% response after a step
decrease in the inlet concentration.
Zero drift; The change in instrument output over a stated time period of unadjusted continuous
operation, when the input concentration is zero.
CD Span drift; The change in instrument output over a stated period of unadjusted continuous operation,
when the input concentration is a stated upscale value.
Precision; The degree of agreement between repeated measurements of the same concentration (which
shall be the midpoint of the stated range) expressed as the average deviation of the single results
from the mean.
Operation period; The period of time over which the instrument can be expected to operate unattended
within specifications.
Noise; Spontaneous deviations from a mean output not caused by input concentration changes.
Interference equivalent: The portion of indicated concentration due to the total of the interferences
commonly found in ambient air.
Operating temperature fluctuation; The ambient temperature fluctuation over which stated specifications
will be met.
Linearity: The maximum deviation between an actual instrument reading and the reading predicted by
a straight line drawn between upper and lower calibration points.
-------
3.3 Responsibilities In Support of Implementation Plans
The technical services group must be responsive to the needs of
the administration and enforcement elements of the control program.
Laboratory and supporting field activities that best illustrate these
special investigative requests are:
(a) Source emissions testing;
(b) Emergency episode monitoring;
(c) Analysis of special samples;
*
(d) Measurement of defined point source impact on air quality.
Following is a general discussion of these work areas which
attempts to define the role of the technical services group. It must
be remembered that in all cases, these are "joint ventures" with the
general objectives and directions for the tasks coming from the
agency personnel charged with making the decision or defining the
problem with the input data supplied by the technical services group.
3.3.1 Source Emissions Testing
The primary function of source sampling is to obtain reliable
emission data. The exact duties assigned to the source sampling
unit in order to perform this function vary widely from agency to
agency depending on the potential work load, the emission regulations,
!
and the availability of other agency personnel when required. In
small organizations, in which source sampling may not be a full-time
activity, some personnel who are actually a part of another unit,
such as engineering, may be loaned to the technical services group
as the need arises. In this case, when sampling is required, personnel
will have to reschedule their other work, perform the test work and
analysis, then return to their routine duties.
49
-------
In contrast to this part-time activity, a large agency with many
requirements for source testing will need a full-time staff performing
tests. This staff will include chemists as well as technicians who
maintain the sampling equipment, perform calibrations, assist in stack
testing, and make routine calculations. These technicians support the
engineering staff who perform sampling site surveys, plan the test
procedures, set the schedule, supervise the actual tests, review
calculations, and prepare the final report. Generally, a senior
technician is assigned to the sampling group. This person should be
responsible for all routine laboratory analysis and serve as coordinator
between the laboratory and engineering groups.
22
A recent report prepared for EPA lists the specific duties of
the source emissions testing unit. Those duties asterisked(**) are
generally assigned to the technical services group.
(a) Technical Duties
(1)** Develop and update reliable source testing
procedures for particulate and gaseous emission;
(2)** Calibrate and maintain all equipment;
(3) Plan and conduct source tests as required;
(4)** Perform and check all test calculations;
(5)** Prepare analytical reports and summaries of
emission data;
(6) Review source tests conducted by private firms.
(b) Administrative Duties
(1)** Trai n pe rs onne1;
(2)** Procure equipment to conduct source tests;
50
-------
(3)** Maintain a file of all source tests data;
(4) Prepare annual reports and budget requirements;
(5) Make contacts with plant personnel;
(6) Schedule tests;
(7)** Coordinate source test activities with other
agency elements.
A wide variety of sampling trains are available for determining
particulate emissions. These trains have been described in the
literature, and each has its particular advantages and disadvantages
depending on the sampling conditions and the object of the test.
In all cases, however, the trains consist of a carefully sized
sampling nozzle or probe tip, a probe to convey the gases, a filter,
collector or solid/gas separating device, a pump, and a gas meter.
When hot gases (higher than about 150°F) are sampled, a condenser or
similar cooling device is also used to protect the pump and meter.
It is especially important that all components that contact the
sampling stream be carefully cleaned. Proper cleaning and lubrication
will also insure a leak-tight assembly. Any other suspected malfunctions
in the sampling train are also best diagnosed and fixed in the labora-
tory or shop. Frequent sources of mechanical problems include
defective pumps (usually broken or stuck vanes), dry gas meter
^
(erratic dial readings), timer or clock malfunctions, loose or broken
electrical wires, damaged nozzle or Pitot tube openings, and cracked
glass parts.
23
EPA has prepared a document dealing with specifics of mainte-
nance, calibration, and operations of source emissions testing.
51
-------
3.3.2 Emergency Episode Monitoring
The technical services group is invariably turned to for emergency
atmospheric monitoring. Two specific situations can occur: an
atmospheric stagnation-induced areawide episode, or an accident or
industrial spill. Both require an immediate response mechanism to
evaluate the magnitude of the problem and to provide information
on real-time levels of hazardous or toxic contaminants.
3.3.2.1 Episode Control. In the case of the meteorological
episode, preplanning and utilization of established equipment and
resources reduces much of the pressure on the technical services group
since a contingency plan will have been devised and the staff will
know their specific assignments and duties.
24
A recent EPA publication details all of the factors and agency
interrelationships involved in planning for episode avoidance,
establishment of an Emergency Operations Control Center (EOCC), and
standard operating procedures for all agency elements. The service
functions to be provided by the combined technical services staff are
summarized as follows:
(a) Provide continuous, valid data regarding air contaminants
with priorities given to those pollutant sampling instruments
that are necessary to provide criteria for the various
stages of the alert;
(b) Provide supplemental data needed to support information
and decisions during this period;
(c) Analyze and reduce raw data to meaningful information;
(d) Make such minor adjustments, calibration, and repairs to
instruments as necessary to provide continuous data;
52
-------
(e) Set up and maintain instruments as necessary at supplemental
monitoring stations;
(f) Provide sufficient sampling supplies and media in pre-
designated inventory quantities to support the intensified
level of air quality monitoring;
(g) Reduce, log, and post the air quality measurement data in
the EOCC. Provide interpretation of the measured values
relative to temporal and spatial factors and make recommenda-
tions relative to expanded or modified operations.
3.3.2.2 Accident Control. Accident control, by its very nature,
does not easily lend itself to specific planning. An unplanned and
unexpected release of volatile materials can become a localized
occupational health hazard as well as a significant air pollution
source. Rupture of reaction vessels and pipelines, collision of
truck and rail tankers, and spillage during transfer from container-
to-container represent potential sources for the major release of
toxicants and/or pollutants. In anticipation of such local pollution
situations, it is desirable to have a contingency plan for action.
At the present time, several States have established disaster
control programs and centers. In all other instances, the State and
v
regional police initially investigate and coordinate all efforts to
minimize the impact of accidents on the affected community.
Therefore, until such time as air pollution agencies formulate
and implement regulations requiring the immediate report and control
of accidental spills or emissions, the following procedure could
be established:
53
-------
(a) An emergency kit, consisting of various testing equipment--
primarily detector tubes, written reference source materials,
and safety equipment—is located at key police locations
throughout the State;
(b) In the event of an accident, the police notify the agency
and transport the kit to the scene;
(c) The agency dispatches the most suitable, available team of
investigators to the scene to conduct an investigation and
to make necessary judgments for control of the problem;
(d) The State agency would also provide the cooperating police
units with listings of responsible local air pollution
personnel who would be familiar with the test equipment
and who could provide initial•immediate assistance until
the State investigators arrive.
3.3.3 Analyzing Special Samples
3.3.3.1 Nuisance and Complaint. The public nuisance and complaint
is usually an urban problem. Complaints invariably increase with
industrialization, population, and rapid, unplanned growth patterns.
Complaint reaction to nuisance situations generally stems from the
emission of malodorous gases or vapors; deposition of and soiling
from fly ash, mineral dusts, and other miscellaneous particulate
matter; and stains on or erosion of materials resulting from impaction
of liquid particles, usually acidic or otherwise corrosive.
In certain nuisance situations, e.g., particulate deposition or
materials damage, the laboratory is employed to perform chemical or
physical (including microscopic) analysis of a sample taken by the
54
-------
enforcement inspector. Usually, these data are sufficient to allow
identification of the source category and the inspector can place
suspected emitters under surveillance.
It is difficult to list all of the possible sample categories that
the laboratory might be called upon to analyze. Generally, the labora-
tory of a comprehensive State program will have the necessary equipment
and staff experience to perform this particular type of "qualitative
analysis". Some typical samples brought in by inspectors would include:
(a) Parti oil ate matter deposited on private property, collected
from gutters, porches, siding, etc.;
(b) Materials such as curtains, drapes, screens, etc., that
have been soiled, stained, or corroded;
(c) Indigenous vegetation (flowers, leaves, etc.) that exhibit
symptoms of disease or pollutant damage.
Additionally, static sampling media are often used by enforcement
personnel to establish the source of a nuisance or complaint situation.
In these cases, the laboratory may be called on to:
(a) Chemically analyze particulate matter collected on impaction
plates (coated glass or metal slides);
(b) Physically identify particulates collected on impaction
\
plates, sticky paper, or cheesecloth;
(c) Chemically analyze impregnated media (sulfation or fluori-
dation rate, etc.) for reaction with gaseous pollutants.
All of the techniques utilized by the laboratory in these efforts
are found in standard chemical analysis texts, standard methods, or
referenced in specific sections of this document. However, one
55
-------
reference that should be noted in connection with particle identification
is the McCrone Atlas.25
3.3.3.2 Fuels. Often the laboratory is requested to perform
analysis of fossil fuels, e.g., coal or oil. This can be a major
analysis load in States that prescribe in specific regulations the
allowable amounts of sulfur and ash in fuels. Standard tools such
as the calorimeter and combustion trains are used and many reference
,.. . . ^ 26-28
methods exist.
In some special cases, mobile source fuels may be analyzed in the
State laboratories. However, this activity is usually associated with
automotive emissions testing programs which, except for the California
Air Resources Board, are only in the formative development or planning
stages.
3.3.4 Defining Source Impact
Monitoring the effect of a point source on ambient air may be
conducted for one or more purposes:
(a) To evaluate compliance with ambient air quality standards:
(1) Before and after monitoring may be specified for a
proposed plant in. order to obtain a permit to construct
and/or operate;
(2) Monitoring may be necessary to measure the pollutant
effects of an existing source upon the surrounding
community.
(b) To monitor an area of concern outside the region of maximum
concentration:
(1) Where a complaint has been substantiated;
56
-------
(2) Where a populated or otherwise important area warrants
monitoring to obtain concentration levels.
Specification of the quantity and location of sampling devices
for a long-range source investigation is difficult. Wind variables
will change greatly during the seasons so that the area of concern
may be downwind of the plant in summer, while in the colder months
the plume may reverse direction.
As a point source emits a pollutant into the atmosphere, it is
transported to another coordinate by the wind. Variances in wind
direction and speed can cause a parcel of air to have a history of
appreciable directional and velocity changes.
It is evident that a surveillance system totally surrounding the
point source is needed to insure protection against the varying plume
characteristics. The major portion of monitors is placed in the area
where the concentration is most likely to be the highest. This area
can be determined from the annual prevailing wind direction. A
smaller number of instruments completes the monitoring network.
3.4 Special Studies
Normally, the air pollution technical services group is concerned
with the program support activities that have been previously described.
However, in some State and regional agencies, specific studies
involving some research, development, and applied research have been
and will continue to be undertaken. Several examples, chosen to
illustrate these areas, are covered below.
3.4.1 Instrument Evaluation
Occasionally, the technical services group may be asked to perform
an investigation of one or more types of air quality monitors. This
57
-------
need will arise when instrument evaluation tests by the vendor have
been conducted on a limited scale and sufficient data are not available
to determine if a particular instrument or instrumental technique
meets the needs of the control agency for reliable and accurate
measurements. These data can be obtained only through comprehensive
instrument evaluation programs designed to obtain the required
performance data.
A general set of performance criteria can be specified that are
independent of the type of instrument being evaluated or the application
in which it is to be used. The following characteristics that describe
instrument performance criteria should be considered:
(a) Physical Characteristics—Portability, size, weight,
space requirements, auxiliary equipment, power requirements,
versatility, and hazards;
(b) Performance Specifications—Temperature effect, interferences,
interference equivalent, volumetric flow rate range, setup
time, warmup time, response time, lag time, rise time to
95%, total time to 95%, and sensitivity;
(c) Data Quality—Calibration requirements, stability, accuracy,
precision, zero drift, span drift, linearity, calibration
reproducibility, minimum detectable sensitivity, minimum
detectable change, and detection limit;
(d) Functional Capability—Fragility, durability, service-
ability, zero failure period, maintenance requirements,
operational period, and equipment cost.
The performance of an instrument must ultimately be determined
under actual field conditions for its complete evaluation. A partial
58
-------
evaluation can be performed in the laboratory, and the results may
provide the basis as well as the justification for field evaluation,
but a complete field test evaluates not only the instrument but the
performance of the operator and the facility as well. To determine
the effect of various combinations of pollutants in urban environments
on instrumental response, instrument evaluations should be conducted
in several geographical areas.
3.4.2 Atmospheric Chemistry Studies .
Photochemical reactivity of atmospheric constitutents has been
defined as the tendency of these materials to undergo a series of
chemical reactions under the influence of ultraviolet irradiation and
meteorological turbulence. The chemical reactions are initiated
principally by the photochemical dissociation of nitrogen dioxide by
solar energy below 4000 angstrom units.
This chemical activity or reactivity can be measured by various
types of human and animal response (eye irritation, plant damage,
breathing difficulty, visibility reduction) and by various techniques
associated with analytical and physical chemistry. Some of the more
common evaluations of this latter type are as follows:
(a) Determination of the rates of disappearance of various
t
hydrocarbons upon irradiation;
(b) Determination of the rate of photochemically induced
conversion of nitric oxide to nitrogen dioxide in the
presence of hydrocarbons; 9j-o<
(c) Determination of the rates of formation of selected
photo-oxidation products such as aldehydes, ketones, carbon
59
-------
monoxide, total oxidant, ozone peroxyacetylnitrates,
and peroxides.
3.5 In-House Laboratory Considerations
Currently, with very few exceptions, the analytical laboratory
is an element of the air pollution control program. Since the internal
chemical staff is often small (usually < 20), it can operate in an
informal manner. As a result there is usually no need for organiza-
tional subdivisions; each chemist and technician is familiar with
most of the laboratory procedures and only a few of the professionals
"specialize." Depending on the thrust of the air pollution control
program as well as its stage of development, the laboratory load of
nonroutine samples will vary. If the agency is seriously involved in
source emissions testing or has regulations demanding materials compliance
testing (fuels and solvents), the nonroutine sample analysis might well
utilize 70 to 80 percent of the available man-hours.
Requests for analytical services, an important item, should be
briefly developed at this point. It is recommended that samples
submitted for analysis be treated as follows:
(a) Laboratory Services Request Form (see Figure 9) is filled
out in detail; all data pertaining to the sample and the
type of analyses required are included on the form;
(b) The sample and request form is then inspected and either
accepted or rejected by the chief chemist; often the sample is
of insufficient size or is not representative enough for
analyses;
(c) The accepted sample is then logged into the laboratory record
book and processed for the analyses.
60
-------
Submitted by:
External Source:
AQAL Sample No:
Sample Description:
Solid D Liquid D Gas D
General Description:
Sample Description and Designation
EPA Division & Branch:
Date Received:
Submi ttal No:
Hygroscopic CH
Vol :
Sampling time
Air flow
Air volume
No3" n
So4 n
NH/ a
cr n
F- a
Analyses Desired
Inorganic Ions and Gases
Approximate
Concentration
Approximate
Concentration
N02 D
SO. D
Others:
Organic Compounds
Approximate
Concentration
Benzo(a)pyrene D
Benzanthrone LJ
Benzene Soluble LI
Organics
Others:
Figure 9. Laboratory services request form (an example),
61
-------
Other
Element
Be
Ti
V
Cr
Mn
Fe
Co
Ni
Cu
Mo
Cd
Sn
Sb
Pb
B
Mg
ATTENTION
3 Count D pH D
UV Spectrum D
Special Analyses Desired:
Conductivity D
IR Spectrum [J
Trace Metals and Nonmetals
AA
D
a
a
D
a
D
D
a
D
a
D
a
a
a
n
Method
Other Approx.
ES (specify) cone.
D
a
a
a
n
n
n
n
n
n
n
n
n
n
Element
Re
Ag
Ca
Zn
Al
As
Ba
Sr
Te
Zr
Sm
Tl
Pt
Bi
Hg
Se
AA
D
D
D
D
D
D
D
D
D
D
D
D
D All by ES
Method
Other Approx.
ES (specify) cone.
a
D
a
a
a
a
n
n
n
n
For all samples collected on solid absorbents or in solution
appropriate samples of the solid absorbent or collecting
solution must be supplied in order to determine correct
blank values.
Figure 9 (continued). Laboratory services request form (an example),
62
-------
Table 6. TABULATION OF IN-HOUSE LABORATORY ANALYSIS FUNCTIONS
Sample
Analysis usually performed Technique employed
Equipment utilized
CO
Ambient
Gases
Particulates
Effects
Source emissions
Gases
Particulates
Fuels
Stationary
source
Mobile source
S02, N02, oxidant, HgS;
Hydrocarbons & CO
Suspended, settleable;
Metals, i.e., Fe,Cu,Pb,etc. ;
Particle size (sticky paper
impaction)
j>ulfation rate;
Metal corrosion;
Color fading;
Material Deterioration
Nylon;
Rubber;
Silver
S02, S03, NOX, Cl;
Hydrocarbons
Total weight;
Particle size
Btu;
Sulfur;
Moisture ash;
Bromine number
Colorimetry;
Chromatography
Gravity;
Atomic adsorption;
Microscopy
Turbidimetry;
Gravimetry;
Colorimetry
Microscopy;
Microscopy;
Reflectometry
Colorimetry;
Chromatography
Gravimetry;
Microscopy or Air
Centrifugation
Calorimetry
Combustion train;
Gravimetry;
Colorimetry
Spectrophotometer;
Gas Chromatography
Analytical balance;
A.A. spectrophotometer;
Microscope
Spectrophotometer;
Analytical balance;
Color difference meter
Microscope;
Microscope;
Reflectance meter
Spectrophotometer;
Gas chromatograph
Analytical balance;
Microscope;
Bahco Micro-Particle
Classifier
Calorimeter;
Volumetric analysis;
Analytical balance;
Spectrophotometer
-------
It is vital that formal procedures for acceptance of samples be
established. When a laboratory workload reaches the level of
approximately 300 samples per month, a "sample clearinghouse"
approach would be useful.
In order to generally summarize the analytical service functions,
Table 6 has been developed. While it may not include all of the
specific sample categories nor detail alternate procedures or equip-
ment, it should provide a general feel for the scope of work and the
range of technology implemented in existing State or regional
laboratories.
64
-------
4.0 LOCATION AND DIVISION OF TECHNICAL SERVICES RESPONSIBILITIES
4.1 Overall State Program—Pi vision of Responsibilities
Each State program will carry out its technical service responsi-
bilities and laboratory functions as defined in its implementation plan.
In many cases, comprehensive municipal, county, and regional agencies
are already in existence dealing with the local air pollution control
problems. In other cases, local agencies either do not exist or are
concerned with only fragments of a minimum air pollution control program.
«
The major local air pollution control (APC) agencies will assist
and cooperate with the State APC agency in carrying out a large measure
of the statewide program. Each of these local agencies will be
responsible for the bulk of the management, enforcement, engineering,
and technical services within their own jurisdictions. The local
agencies will handle complaints, conduct scheduled inspections, patrol
in the field, make emission estimates, operate monitoring networks,
set local policy, and gather information necessary for legal actions.
These activities will differ in type and scope from agency to agency,
requiring varying levels of manpower and funding. Such activities
will be accomplished largely by independent action. Other APC program
functions require much closer intergovernmental cooperation, both
intrastate and interstate. Plans for the prevention of air pollution
emergency episodes are a prime example of an area requiring complete,
coordinated, and well-defined and understood interstate intergovernmental
cooperation.
The minimum EPA program criteria require that an agency have the
technical and administrative capability to perform at least the
65
-------
following functions: air quality monitoring, scheduled inspections,
complaint handling, operation of a field surveillance program, prepara-
tion for legal actions, and source identification and registration.
If the local agency cannot or will not meet these requirements, the
State agency must physically fill in the gaps in the areas of need.
This is accomplished by assisting in the development of a local agency
which at least meets the minimum requirements or by creating a State
satellite office to serve the jurisdiction.
4.2 State Technical Services—Division of Responsibility
There are presently no guidelines or scientific methodologies
which can be used to determine the ideal number, types, and locations
of technical services installations within the State APC agency.
Until such time as these tools become available, it is useful to
define several of the influencing parameters which, when given proper
consideration, are useful in determining allocation of functional
responsibilities.
4.2.1 Types of Technical Service Facilities
The needs of most State programs can be met with two types of
facilities: the central or primary facility and the satellite facility.
The primary facility would normally have the capabilities and resources
to support all technical services functions carried out within the
State program. The satellite facility is usually employed to support
the functions of field-related activities. The extent of equipment
and personnel located at the satellite facility will be proportional
to the activities which the facility serves. Often the satellite
facility will be located with other agency field activities such
66
-------
as engineering or enforcement. In many instances these satellite
facilities are extensions of a local agency, whereby the State provides,
under cooperative agreements, personnel and support for activities
beyond the local jurisdiction.
4.2.2 Location of the Technical Service Facilities
Several factors affecting the location of technical services common
to most State agencies are as follows:
4.2.2.1 Technical Service Requirements. > The heaviest demands for
technical services in relation to the geographical area of the State
will result from those areas of maximum population density.
Oftentimes, within a State, the number of these maximum population
areas will be less than five. As a guide, the population density will
exceed 1,000 persons per square mile, and the area will be greater
than 100 miles. In these areas the demand for technical services will
be sufficient to support a satellite facility.
The remaining technical services effort will be directed to the
large unpopulated areas of the State. These areas require limited
technical services: but due to the large size of such areas, as found
in many States, the effort becomes substantial.
4.2.2.2 Travel and Communications. Travel and communication costs
should be kept minimal. As a result, the agency will find it more
economical to support satellite facilities in remote areas. Normally,
the one-way distance from the furthest point of responsibility within
an area to the technical support facility should be less than a two-hour
automobile drive.
67
-------
4.2.2.3 Expenses—Facilities and Operational. The use of existing
State-owned facilities can be advantageous from an economic viewpoint.
The use of State-owned facilities within the jurisdiction of a competent
local agency can lead to an inefficient duplication of resources and
effort. It would be desirable in this instance for the State to support
and use the local agency's facility on a cooperative basis.
Operational costs are not greatly influenced by geographical loca-
tion, but the number of required facilities are. Therefore, every effort
should be made to develop cooperative agreements with existing local
agencies.
4.2.2.4 Public Relations Influence. The public relations factor
cannot be overlooked whenever issues such as this are involved. There
will exist pressures from the political element to locate facilities
in one geographical area in preference to another. Often this factor
can be used to the program's advantage, but care should be exercised
so that the selection of a geographical location is not based on these
factors alone.
4.2.3 Allocation of Technical Functions
As a result of the nature of the functions themselves, some are
best performed at a central location while others are more efficiently
carried out at field locations. The determining factor for the separa-
tion of these functions is based on the most efficient utilization of
resources with a minimum of effort duplication. The technical services
functions can be divided into two categories, i.e., those best suited
for performance at the central technical facility and those which can
best be performed at the field office or satellite facility (Table 7).
68
-------
Table 7. ALLOCATION OF TECHNICAL SERVICES FUNCTIONS
Technical services
function
Execution of function*
From
central facility
From
satellite facility
Analyses — ambient and
source samples
Source sampling
Air monitoring
Special studies
Data acquisition C
Instrument calibration
Instrument maintenance
Monitor site selection
Data reductions C
Computer program
Data summary
Statistical studies
Meteorological studies
A
A
A
A
A**
A
B
B
A**
A
A
A
A
B
A
A
B
A
A
A
A
A
C
B
C
C
Execution of the functions with respect to these two types
of facilities.
Telemetered data acquisition systems only.
Code:
A - Well Suited
B = Moderately Suited
C = 111 Suited
Centralized laboratory and data operations result in a considerable
savings in equipment and personnel. The other technical services
activities pertain primarily to operations performed in a field and,
therefore, lend themselves to operation from a satellite or field
facility.
69
-------
4.2.4 Number of Technical Services Facilities
The number of technical services facilities required to service
a statewide program will be dependent upon the area, population, and
presence of existing local agencies. In all States there is generally
a need for at least a central technical facility. Such a facility
could be operated by the State or by a local agency under contract to
that State.
4.3 Organizational Considerations
4.3.1 The Independent State Agency
Several State agencies operate independently, i.e., without the
existence of local agencies within their State. Normally, under these
circumstances, a larger number of satellite facilities will be required
to service the program.
The governing factor in this situation is the geographical size
of the State. New Jersey, for example, is a relatively small State and
is able to provide complete technical services from one central facility,
located in Trenton, without the need for satellite facilities. Larger
States, operating without local agencies, would require additional
satellite facilities to minimize travel and communications expense.
4.3.2 The State and Local Agency Co-op
A more common situation existing today is that of the State program
and several local programs working together toward a common goal as
established by the statewide implementation plan. Under this framework
much of the State's responsibility can be delegated to the larger local
agencies. These agencies can be considered a central or primary faw'lity,
and oftentimes they possess greater competence and experience than the
70
-------
Table 8. ALLOCATION OF RESPONSIBILITY FOR TECHNICAL SERVICES
FUNCTIONS REQUIRING INTERGOVERNMENTAL COOPERATION
Technical services functions
element
Laboratory Surveillance
State technical
services unit A A
State agency
central
laboratory C . ... C
State agency
regional primary
laboratory F F
State agency
satellite
laboratory P F
Local agency
primary
laboratory F F
Local agency
satellite
laboratory P F
Instrumentation
A
C
F
F
F
F
Field Data
services Statistics processing
A A A
C C C
F F F
F P P
F F F
F P P
Code:
A = Administrative responsibility
B = Coordinating responsibility
F = Full responsibility
P = Partial responsibility
-------
State program. The cooperative employ of these agencies by the State
can be one of the most valuable resources available to the State program.
In addition, the smaller local agencies can participate as satellite
facilities, providing supportive and field capabilities to the State
agency's central laboratory or to a neighboring primary facility operated
by a local agency.
4.3.3 Intergovernmental Responsibilities
As previously pointed out, a number of administrative options are
available depending upon the empirical nature of the State's organization.
State agencies having an in-house central laboratory capability
are responsible for overall administrative and technical coordination
of the statewide technical services activity. State agencies without
in-house central laboratory facilities will maintain administrative
control while establishing technical competency in regional State
laboratories and strong local agency laboratories. Each of these
designated "primary" laboratories will coordinate with other "primary"
laboratories and will provide direction and back-up capabilities to
State and local agency satellite operations, which need not or cannot
maintain complete technical services facilities.
Table 8 is presented as an example of State agency responsibility
for overall coordination and regional or local laboratory responsibility
for functional services.
72
-------
5.0 LEGAL CONSIDERATIONS
Ambient and source sampling provide the basic measurements for an
air quality management program. This chapter discusses the pitfalls
which may render test data useless from a legal standpoint. A broad
discussion of the legislative and other legal requirements is presented
to give the reader an overview of the importance of the sampling program
and the limitations inherent in a program which necessarily restricts
the use of private property. Procedures are suggested for maintenance
•
and calibration of equipment, data recordation, and analysis. This
procedure, if followed, will buttress the data as evidence in any
subsequent litigation and, more importantly, will reduce the possibility
of a successful court challenge.
5.1 Requirements for Jurisdictional Samples
5.1.1 Definition
The term "Jurisdictional samples" means those samples which, are
collected for use by a State or local air pollution control agency as
opposed to those taken by or for the owner or operator of an air
pollution emission source. While such samples will generally be ambient
or source samples extracted from the air or gas stream by means of
instruments or measuring devices, they may also include such items as
(
sweepings, leaves, animal bones, and the like which are descriptive
of conditions in a particular area. For the sake of clarity, Juris-
dictional samples will be classified herein as ambient, source, and
descriptive.
5.1.2 Regulatory Authority—General Considerations
The expertise required for a proper air quality management program
necessitates specialized administration. Unlike traffic laws, whereby
73
-------
the State legislature itself establishes speed limits and the like, the
authority to set air pollution limitations is delegated by the legislature
to an administrative body. This type of legislation is called "enabling
legislation" and the administrative body generally takes the form of a
health department, air pollution control board or commission, or a
multifaceted State environmental protection agency.
The powers of administrative agencies are generally limited by
the intent of the legislature as expressed in the enabling legislation.
Administrative agencies have no inherent powers; therefore, it is necessary
that the statute specifically provides that the agency is empowered to
adopt and enforce emission standards, conduct tests, and perform acts
incidental to the accomplishment of the agency's purpose. This adminis-
trative authority should be discussed in depth in the State's implemen-
tation plan and it is suggested that the reader refer to the appropriate
section of that document.
Establishment and enforcement of emission limitations are an
exercise of the Government's police power. Such regulation is a valid
restraint on the use of private property if the regulation is reasonable
and reasonably related to the public health, safety, or general welfare.
Thus, if it is established that a specified concentration of pollutant
in the ambient air is a threat to public health, safety, or welfare,
reasonable means may be taken to remove that threat. Valid emission
regulations must be based on sound ambient air quality data. There
must be a relationship between the regulation and the condition to
be corrected.
74
-------
5.1.3 Purpose of the Clean Air Act
Congress has found that increasing urbanization and industrial
development have resulted in complex air pollution problems affecting
public health and welfare. It was determined that, while the prevention
and control of air pollution at its source is the primary responsibility
of State and local governments, Federal leadership and assistance is
essential to development of the State and local programs. Thus the
Clean Air Act of 1970 was passed to protect and enhance the quality
of the Nation's air resources so as to promote the public health
and welfare and to provide assistance to State and local govern-
ments in developing air pollution prevention and control programs.
5.1.4 Requirements Under the Clean Air Act
The Clean Air Act accomplishes its purpose by requiring the States
to adopt and enforce emission limitations for stationary air pollution
sources as required to meet federally adopted ambient air quality
standards. To the extent that the Clean Air Act requires the States
to adopt necessary emission regulations therefore, it requires a program
for ambient air quality surveillance.
Whether specific sources are in compliance is generally determined
by source samples. It is therefore necessary that the State agency
have the authority and capability to conduct or have conducted source
tests.
5.1.5 Jurisdictional Samples as a Basis for Regulations—Program
Cri ten a
The imposition of emission regulations is an exercise of the State's
police power which is that degree of interference with the use of private
75
-------
property which is neither arbitrary nor oppressive, is equally applied,
and bears a real and substantial relationship to public health, safety,
morals, or welfare. This definition points out the importance of
solid ambient air quality data. This is particularly so in those areas
where very stringent limitations have been adopted.
The exercise by which the emission limitations are selected is
known as a "control strategy". The applicable control strategies are
shown in the implementation plans which the States are required to
submit to the Administrator of the Federal Environmental Protection
Agency. While mathematical estimates* of existing air quality based
on current emissions were, of necessity, used in some plans, the
acquisition of representative air quality is the ultimate proof that
air quality standards are being achieved. Therefore, emission limita-
tions based on faulty ambient data may be deemed an unreasonable
exercise of the Government's police powers. The cardinal rule in
designing and operating an ambient air monitoring network is to follow
accepted procedures with standardized techniques. It is possible that
current emission regulations may be insufficient to reach the specified
air quality levels. Only a properly designed monitoring network can
perform trend evaluation to determine the effectiveness of current
regulations.
* The diffusion model developed by Miller and Holzworth was used for <
area emissions while a modification of Turner's dispersion model was
used for large point sources. See EPA's Requirements for Preparation,
Adoption, and Submittal of Implementation Plans.29
76
-------
Proper instrumentation, methods, calibration, and maintenance are
all essential to a legally acceptable program. However, where the data
are to be used to establish emission regulations, a singularly important
design facet is instrument siting.
A common siting system is the area system whereby stations are
distributed uniformly throughout the area. This method will provide
a good indication of average ambient air quality. However, emission
regulations based on such data will not produce the desired air quality
•
in the so-called hot spots since the average will consist of both high
and low readings. Also there is no way to determine the actual existing
air quality in the hot-spots. In short, regulations based on data
obtained from an area-type monitoring system may be deemed inadequate.
Perhaps the most common siting system is the target system which
relies on data obtained solely from the hot-spots, the rationale being
that if the resultant regulations achieve the air quality standards in
the heavily polluted areas, all other areas will automatically meet the
ambient standards. One disadvantage of the target system is that it
results in an imposition of stricter emission limitations than is needed
for many processes in large areas of the region. This is disadvantageous
because the regulated sources may seek to have the regulations struck
i
down on the basis that the emission regulations are unrelated to the
achievement of the Federal ambient air quality standards and that such
regulations violate the constitutional mandate of equal protection.
While the current climate is favorable to stringent regulation, it may
be wise to avoid regulation which invites litigation.
A combination of the two siting systems appears to be the most
desirable approach to the problem from a legal point of view since it is
77
-------
the only known way to obtain a representative picture of the effect of
regulations and emission sources on air quality.
In summary, the following salient points should be remembered:
(a) Before property use is restricted, an evil must exist
(unacceptable air quality);
(b) The restriction must bear a substantial relationship to
the solution (limit pollutant emissions);
(c) The restriction must not be oppressive (avoid overkill);
(d) A well-designed, well-operated ambient air quality network
considers: siting, instrumentation, calibration, maintenance,
meteorology, and terrain.
5.2 Samples Used as Legal Evidence
Every test should be conducted as if it will ultimately be used
as evidence in court. The collection and analysis of jurisdictional
samples should become a routine matter to the State agency personnel
involved. However, it must be remembered that this routine procedure
is esoteric to the layman and, therefore, is subjected to greater scrutiny
whenever the agency has to rely on these results. It is imperative that
sampling and analysis be done under standard procedures and that each
step be well documented. In short, the report may ultimately be
subjected to the requirements of the Rules of Evidence.
In attacking the validity of the sampling results, the adverse
party will concentrate on four main items relative to taking the
sample: (a) the sampling procedure, (b) the recorded data and calcula-
tions, (c) the test equipment, and (d) the qualifications of the test
personnel.
78
-------
The State agency must keep in mind the possibility of adverse
inferences that may arise from the use of unorthodox or new procedures.
Therefore, deviations from the standard procedure must be kept to a
minimum and applied only where absolutely necessary to obtain an
accurate sample. Changes in methodology must be based on sound engineering
judgment and must be carefully documented. Standard procedures* which
should receive particular attention are:
(a) Location of sampling station,
(b) Number and size of sampling zones in the duct,
(c) Use of recommended sampling equipment,
(d) Careful determination of gas velocities,
(e) Maintenance of isokinetic sampling conditions,
(f) Proper handling of the collected sample and recording
of container and filter numbers.
5.2.1 Purpose of Samples
Most samples are taken for internal agency use rather than pursuant
to enforcement proceedings. While routine samples will rarely be used
as evidence of a violation, the possibility remains. Regardless of the
end use of the sample, care should be exercised to maintain its integrity
as a matter of sound policy. Table 9 illustrates the purposes for
which samples may be taken.
5.2.2 Rules of Evidence
Rules of evidence have been formulated to insure that whatever is
presented to the court is a bona fide representation of the item or
occurrence it purports to be. Source samples and ambient samples will
30
* In general, see New Source Performance Standards.
79
-------
Table 9. USE OF JURISDICTIONAL SAMPLES AND
AMENABILITY TO CHALLENGE
Type of Sample
Ambient
Ambient
Ambient
Source
Descriptive
Chances of
Purpose judicial challenge
Routine ambinet
surveillance
Routine source
surveillance
Establish and maintain
basis for regulation
Source surveillance
Source surveillance
Slight
Slight
Fair
Good
Good
rarely be used as direct evidence. The evidentiary matter will actually
consist of a report based on the samples since the samples, without
further analysis, convey nothing. The conversion of field samples to
material evidence is a four-step process: (a) taking the sample,
(b) transporting and handling the sample prior to analysis, (c) analyzing
the sample, and (d) reporting on the findings.
5.2.3 Taking the Sample
The sample must accurately represent the conditions at the time
and place from which it is taken. Particular attention must be paid to
the procedural steps outlined in Table 10.
5.2.3.1 Location. Where a sample is extracted from a gas stream
such as in source sampling, location of the test station must be in
accordance with good practice so as to obtain a representative sample.
When sampling for particulate matter and aerosol mists, the
primary criterion in selecting the test site is that the sample extracted
from this site be representative of the main gas stream. Relatively
80
-------
Table 10. RELATION OF SAMPLING PROCEDURES
TO EVIDENCE
Type of sample
Procedure
Evidentiary
element
Source
Location of test port
Test procedures
Equipment
Recording of data
Personnel
Marking of samples
Representative sample
Representative sample
Representative sample
Representative sample
Accuracy
•Identification
Ambient
Location of equipment
Test procedures
Equipment
Personnel
Marking of samples
Representative sample
Representative sample
Representative sample
Representative sample
Identification
Descriptive
Location from which
sample was taken
Marking of samples
Representative sample
Identification
little is known about the disposition of particulate within any specific
moving gas stream. Therefore, every effort should be made to obtain
a site in which the particulate-gas mixture is as homogeneous as
possible. Homogeneity is best achieved in straight vertical ducts.
Ideally, the gas flow should not be disturbed by any obstruction or
change in direction for approximately 7 to 8 hydraulic diameters*
upstream and 2 to 4 diameters downstream from a proposed test location.
In addition to flow considerations, accessibility to the site is
an important consideration. Safety, as well as clearance for the probe
and sampling apparatus, availability of electricity, weather exposure,
... ,. .. . Area of duct cross-section
Hydraulic diameter = Duct perimeter
81
-------
presence of toxic or explosive gases, etc., must all be considered in
selecting a site.
Because of these many considerations, compromises must be made in
test site selection although ideal flow conditions should be sought.
In some cases, a suitable test site may not be available without major
changes in the duct work. If these changes cannot be made, a meaningful
sample may not be practical, and only approximate emission results will
be obtained. While approximations made pursuant to good engineering
practices are generally admissible as evidence, reliance on them is
to be avoided where noncompliance with emission regulations is only
slight.
If the owner of the process to be tested is required to furnish
sampling ports, reliable data can be obtained. For example, the Bay
Area APCD requires the owner to provide test facilities (Regulation 2,
§ 3210). It behooves the owner to provide a proper site since, if the
site does not meet the requirements of good practice (as set forth in
Regulation 2, § 2036), the emissions will be calculated based on a
single measurement taken at the site provided. This reading is considered
to be the average for the entire cross-sectional area at the test site
(Regulation 2, § 2038).
Location of ambient sampling equipment is not amenable to objective
criteria because so many variables are involved. These variables include
terrain, meteorology, power source, permission of the owner of the
realty, elevation requirements, and purpose for which the sample is
taken.
As a general rule, ambient samples that are to be used for air
quality determination should be taken from representative locations.
82
-------
Avoid locations where fumigation effects are obvious. On the other
hand, the opposite is true where the purpose of the ambient sample
is source surveillance. This rule is also applicable to descriptive
samples such as dustfall jars, vegetation, and the like. Static monitors
are helpful in determining the overall system design and their use in
this regard should be documented.
5.2.3.2 Test Procedures. Both source and ambient samples should
be extracted according to recognized good practice. Adjustments to
*
compensate for sample decay, collector efficiency, and the like, should
be avoided as much as possible. Test periods should be long enough to
collect a sufficient quantity of pollutant. Be aware of the limitations
of certain sampling methods and calibration techniques. Above all,
use proper test procedures and attempt to use the best sampling method
available keeping the end use of the results in mind. One recent court
decision has held reliance solely on Ringelmann observations to be
31
insufficient evidence where more accurate tests could have been made.
There are two commonly used methods for source testing for
particulate matter—the dry train and the wet train. Many methods
exist for extracting gaseous source samples. All source sampling must
be done in accordance with the standards set forth in the control
\
regulations. Do not attempt to use samples taken with a wet train when
the regulations are written for a dry train, for example. If the air
pollution control regulations do not specify source sampling methods,
consult your agency's legal counsel. He should be apprised of the fact
that more than one source-test method often exists. When source sampling,
83
-------
o
o
particular attention should be paid to the following elements of field
procedure as applicable to the sampling method used:
Element Pollutant
0 Velocity traverse Solid
0 Isokinetic conditions Solid
0 Number of zones from which
sample is extracted Solid
0 Disassembly of train and
cleanup Solid
0 Check apparatus immediately
prior to use Solid, mist, gas
Reagent or water used in
train Solid, mist, gas
Record data at proper intervals Solid, mist, gas
0 Length of sampling time Solid, mist, gas
A very important procedural aspect of ambient sampling is that the
sample time should correspond with the existing or proposed ambient air
quality standards. Attention must also be directed to the reagent and
problems of sample decay in the case of some bubbler techniques. If,
for example, a sample is subject to decay, it should always be analyzed
within the proper time frame. For example, the sample should generally
be picked up promptly when only one sample is taken per week. Care
must also be taken to avoid the introduction of error due to vandalism
and the like. These items must be considered when the network is
designed.
5.2.3.3 Equipment. Use of proper procedures implies the use of
proper equipment. In addition, it is important that the equipment
be capable of extracting a representative sample. This means that the
equipment must be adequately maintained and calibrated to function
84
-------
23
properly. Maintenance schedules should be formulated and records kept.
Measuring devices should be calibrated frequently. Where reagents are
used, make certain that they are sufficiently fresh.
No hard and fast rule can be given for frequency of maintenance
and calibration since these depend on experience with the equipment
itself. When new sampling equipment is received, it should be calibrated
and maintenance procedures initiated in accordance with the manufacturer's
equipment manual. All these manuals should be properly filed. Adjust
*
the frequency of maintenance and calibration as your experience records
l
indicate.
To insure that each piece of equipment is adequately maintained and
calibrated, each should be uniquely numbered and records kept on that
basis. While a standardized maintenance checklist would be helpful and
provide an excellent record, it is not necessary for recordkeeping
purposes. A notebook in which the action taken is noted will suffice.
As a minimum the record should include:
(a) Date,
(b) Equipment number,
(c) Action taken,
(d) Observation,
(e) Name of person who performed the work.
See Figure 10 for a typical entry in a maintenance journal which records
the calibration of a dry gas meter used for a source test.
Reagent records should appear in the chemist's notebook, a routine
procedure for all laboratory work.
85
-------
DATE
EQUIP.
NO.
ACTION TAKEN
OBSERVATION
NAME
1-19-72
16
Calibrated against
spirometer; adjusted
dial linkage.
Recorded flow
was 3% high
Doe
Figure 10. Typical maintenance journal entry.
Bear in mind that the absence of consistent and timely maintenance
records will cast doubt on the accuracy of the test equipment. Failure
to produce these records upon request can result in an impeachment of
the test report or may even render the entire report inadmissible as
evidence. Where the results of source or ambient samples are the
basis for a conviction or an emission regulation, inadmissibility of
the test report would be disastrous.
Finally, the field personnel should record the equipment number
of each major piece of equipment in use so that the field reports and
maintenance-calibration reports dovetail.
In summary, observe the following:
(a) Use equipment numbers,
(b) Establish maintenance procedures,
(c) Maintain your equipment,
(4) Keep maintenance records.
5.2.3.4 Recording of Data. Manual recording of data is required
for source tests. Standardized forms should be utilized to insure that
the necessary information is obtained. These forms should be designed
to clearly identify the process tested, the date and time, location of
86
-------
test station, sampling personnel, and the person who recorded the data.
During the actual test period, the meter readings, temperature readings,
and other pertinent data should be recorded in the provided spaces
immediately upon observation. These data determine the accuracy of the
test and should not be erased or altered. Any errors should be crossed
out with a single line and the correct value recorded above the crossed-
out number.
Do not discard the original field records even if they become
soiled. These original records are the best evidence since mere copies
are not admissible as evidence. For neatness, the field data may be
transcribed or copied for incorporation in the final report but the
originals should be kept on file. Since these records may be subpoenaed,
it is important that all field notes are legible.
Ambient sampling field records generally consist of an automatic
recorder chart. Where such charts are incorporated in the equipment,
they should be identified with the equipment number, dated, and signed
after being removed from the instrument. Since these charts are original
documents, they should be filed for possible future use.
Simply stated, field records should be:
(a) Legible, (
(b) Identifiable,
(c) Accessible.
5.2.3.5 Personnel. Samples must be taken by qualified personnel.
Before operating continuous analyzers or source sampling, special
training or experience is required to insure the accuracy of the data
upon which the report is to be based. Also, it is necessary to have a
sufficient number of personnel to perform the test. Extensive training
87
-------
is not always required for routine ambient sampling, but the operator
should know how to operate the samplers and properly handle the filters,
reagent, and samples since he is subject to having his qualifications
challenged on the witness stand.
5.2.3.6 Marking of Samples. Care must be taken to properly mark
the sample for positive identification throughout the test and analysis
procedures. The Rules of Evidence require impeccable procedures for
identification of samples, the analysis of which is the basis for future
evidence. An admission by the laboratory analyst that he could not be
positive whether he analyzed sample No. 6 or sample No. 9, for example,
could destroy the validity of the entire report. Positive identification
must be provided for the filters and the containers used in any specific
monitoring activity.
Filters should be marked for positive identification. The ink on
the filter must be indelible and unaffected by the gases and temperatures
to which it will be subjected. Filters must be marked before determining
the tare weights. If another method of identification is desired by
the agency, it should be kept in mind that the means of identification
must be positive and must not impair the ability of the filter to
function.
Containers in which samples, reagents, and washings are held should
also be positively marked. Some agencies have found it desirable to
etch a permanent number in each glass container. However, temporary
marking, if positive, is adequate.
Both filter and container numbers must be recorded on the field
data form if the analysis is to be properly identified with the test.
88
-------
See Figure 11 for an example of how this requirement is met on a particu-
late matter source test form.
5.2.4 Transporting and Handling the Sample
Of primary importance in transporting the sample to the laboratory
is that precautions are made to eliminate the possibility of tampering,
accidental destruction, and/or physical and chemical action on the
sample.
To reduce the possibility of invalidating»the results, all components
of the sample must be carefully removed from the sampling train and
placed in sealed, nonreactive, numbered containers. The sample should
then be delivered to the laboratory for analysis. It is recommended
that this be done on the same day that the sample is taken. If this is
impractical, all samples should be placed in a carrying case (preferably
locked) in which they are protected from breakage, contamination, and
the possibility of loss.
To insure the integrity of the sample, the Rules of Evidence require
that a "chain of custody" be established. A good general rule to follow
in this respect is, "the fewer hands the better." Containers should not
be opened during chain of custody since this could lead to a presumption
of tampering. Each person who handles the sample must be able to
remember from whom he received it and to whom he delivered it. This
requirement is best satisfied by having each recipient sign a receipt
which accompanies the sample. In this way it is possible to refute any
possible charge of tampering with the sample by having each recipient
testify if necessary. Figure 11 shows how the chain of custody is pro-
vided on a standard preprinted form.
89
-------
vo
o
ANALYSIS-AND KECKIPT FORM FOR SAMPLES
('Phis fori.-i to accompany samples from field to lab)
Plant
WEIGHT OF PARTICULATE COLLECTED \Run No.
See Sec. 5.2.3.6
FIELD
CONTAINER
NO. ^
^
CONTENTS
Filter
Probe fi^v
Cvc^-pne
Washings
Impinger
Washings
Acetone
Washings
TOTAL FINAL
WEIGHT
(rag.)
TARE WEIGHT
(ing.)
Filter
Container
SSVN^ (see Sec. 5.2.4
^v
^See Sec. 5.2.3.6
WEIGHT
GAIN
(mg.)
-\ /
)
)
Location
\
Filter No.
Received from
by date
Received from
by date
Received from
by date
TOTAL WEIGHT OF PARTICOLATE COLLECTED, W = X 2.2 x 10~ = P<-iunr)s
x 15.4 x 10~3 = Grains
VOLUME OP MOISTUKE COLLECTED
Impingcrs
Silica Gel
Container
No.
FINAL
VOLUME
(ml.)
INITIAL
VOLUME OR
WEIGHT
ml.
- gm.
VOLUMETRIC
GAIN
(ml.)
Analyzer
Date analyzed
TOTAL VOLUME OF WATER COLLECTED, VT = ml . x 0.047 = scf
Figure 11. Example of preprinted form for analysis and receipt of source samples.
-------
5.2.5 Analysis
Source and ambient samples are transformed into useful information
or evidence by laboratory analysis or quantitative measurement. There
are four elements to consider:
(a) Equipment must be adequate to properly analyze,
(b) Personnel must be qualified to make analysis,
(c) Analytical procedures must be in accordance with
accepted good practice,
(d) Proper records must be kept.
The first three elements are similar to those discussed under Section
5.2.3 and further elaboration is not required. Proper records generally
consist of a laboratory notebook. Where practical, standard preprinted
forms should also be used. Do not discard these records since it is
possible that they will be required to substantiate the final report
in the future. Figure 11 shows a typical source test form which is used
both in the field and laboratory.
5.2.6 Report on the Findings
Descriptive samples are themselves material evidence. As previously
stated, however, source and ambient samples must be analyzed. The report
of the analysis is the material evidence. Just as the procedures and
data leading up to the final report are amenable to the Rules of Evidence,
so is the report itself amenable. Written documents, generally speaking,
are considered to be hearsay and, therefore, are not admissible as
evidence without a proper foundation. A proper foundation consists of
introducing the report by the principal author(s), who should personally
testify. Thus in the case of a source sample, the chief of the field
team and the laboratory analyst would both be required to lay the
91
-------
foundation for the introduction of the test report as evidence. However,
the foundation laying is greatly simplified, though still required, under
statutory exceptions to the Hearsay Rule found in the Official Reports
as Evidence Acts and Business Records as Evidence Acts which various
States have adopted.
The rationale of the Official Reports exception is the assumption
that a public officer performing a particular duty performs that duty
properly and is under no motive to distort the truth. Basically, the
Official Reports exception exists to avoid the necessity and expense of
calling as witnesses various persons who may have collaborated in making
the records.
To insure the benefit of these statutory exceptions to the Hearsay
Rule, all monitoring reports should be filed in a safe place by a
v
custodian who has responsibility for the files. Generally, although
the field notes and calculations need not be included in the summary
report, this material may be required at a future date to bolster the
acceptability and credibility of the report as evidence in an enforce-
ment proceeding. Therefore, the full report including all original
notes and calculation sheets should be kept in the file. Signed receipts
for all samples should also be filed with the test data.
Public records are also subject to the Best Evidence Rule which
basically states that the original of a document is the best evidence
and that a mere copy is not admissible as evidence. Microfilm, snap-out
carbon copies, and similar contemporary business methods of producing
copies are acceptable in many jurisdictions if the original is not
reasonably available, its unavailability is adequately explained, and
the copy was made in the ordinary course of business.
92
-------
In summary, the final report based on data obtained from source
or ambient samples need not include all the original calculations and
test data. However, the original forms and calculations should be kept
in the agency's files. It is necessary to keep the actual samples. The
original final report should also be filed. It is a good rule to file
all reports in the same place. Remember, reasonableness is the key to
keeping these reports and data. It is not necessary to keep these
documents under lock and key but, by the same token, it may someday be
necessary for the author of the report to testify that he knows where
the report has been kept since he wrote it.
93
-------
6.0 MANAGEMENT OF THE TECHNICAL SERVICES GROUP
As discussed in Section 1.3, the technical services group of an air
pollution control agency is related to the other three major functional
are as—management, enforcement, and engineering. Figure 1 presents
the primary and secondary services areas and major functions of the
typical technical services group. The relationships between the
services rendered by the technical services group and management,
engineering, and enforcement groups lie primarily in these listed major
functi ons.
For example, the technical services group can provide analytical
data and expert witness to an enforcement group engaged in the preparation
of prosecution testimony.
The technical services group must manage its own personnel; in
addition, it must provide information to the agency's management
(Office of the Director) in the various functional areas presented
in Figure 3.
The administrative group is concerned with the management require-
ments of the overall air pollution control agency, including the
technical services group. In order to carry out its function, the
administrative group reporting to the Agency Director must rely on
the input and assistance of the laboratory or technical services group
manager in the various areas of management functions: program planning,
budget, personnel, training, litigation, and public relations. Section
6.1 discusses the general requirements of a program management system as
it applies directly or is indirectly related with the air pollution
control agency's technical services functions. Section 6.2 and those
following, present the more specific areas of management which must be dealt
94
-------
with in planning, executing, and evaluating the performance of the
technical services group.
6.1 General System Management
The three major management functions of an organization involved in
technical services are (a) program planning, (b) execution of processes
concerned with achievement of identifiable program objectives, and
(c) program evaluation. Since these functions are highly interrelated
and thus interdependent, they comprise a total s'ystem.
Each of these functional areas can be subdivided into functional
areas of smaller breadth, each area having a multitude of interrelation-
ships with other subareas. The following categories and subcategories
are listed because they are generally applicable to technical programs
and will be subsequently discussed as they relate to the supply and
support of technical services functions to the air pollution control
agency:
(a) Program Planning:
(1) Identification of Objectives,
(2) Organization,
(3) Staff,
(4) Budget. !
(b) Program Execution:
(1) Direction,
(2) Coordination.
(.c) Program Evaluation:
(1) Analysis,
(2) Report.
In an operation, each of these categories is dependent on each of
the other categories. None can be considered static or merely "once
95
-------
a year" tasks. An event or effect causing a change in one subcategory
will probably generate changes or require adjustments in other
categories; these adjustments, in turn, may effect still other changes
in other categories. Thus, in actual practice, the entire management
system is dynamic and highly integrated. In any particular management
system, certain relationships between categories may be stronger than
others, but none is completely independent of the other.
Management of the technical services group must allow and provide
for the accomplishment of its operational functions while complying with
the structure and specific organization of the air pollution control
agency being served. The general objective of "management" is to
accomplish the required operational functions in an optimal manner
within the limits of available technology and within the constraints
imposed by statutes and regulations, budget, availability of personnel,
and organizational structure external to the technical services group.
These factors are illustrated in the following discussions of sub-
category management functions.
6.1.1 Planning
Planning requires the identification of specific objectives to be
achieved. Basic objectives for a technical services group may be
identified by determining what must be done to meet the requirements
imposed by State law or regulation, by approved State implementation
plans, and by its parent agency. Review of pertinent documents permits
listing of such requirements. When several means are available for
meeting these requirements, the practical alternatives may be listed
and judgments made regarding the combination of alternatives. In some
cases, quantitative procedures can be applied to the selection of an
96
-------
alternative; in others, a subjective judgment on the part of the group
manager must be made.
Identification of legal and other requirements permits the develop-
ment of objectives. Stated objectives, to be useful in program
management, must be quantitative. For example, "... to operate a
comprehensive air quality monitoring system in an efficient manner . . .,"
is not an adequate statement of objective. Such a statement may serve
as a general goal for a technical services group, but it will not serve
as a specific objective since it is nonspecific and is incapable of
quantification. Specific objectives pertinent to such an air monitoring
goal might be stated as follows:
"To maintain and operate an air quality monitoring system to
satisfy the laws and regulations of the State of ,
and the requirements of the Implementation Plan for (polfutants)
approved by the Administrator of the Federal Environmental
Protection Agency on (date).
"1. Operate a network of (number) high volume filter
samplers for suspended particulate matter as described
in the (identify) Implementation Plan, to yield valid
samples no less than percent of the time for the
network average and no less than percent of the
time for any one station.
"2. Operate a network of (number) (type) air samplers
for sulfur dioxide, etc. . . ."
Such specific objectives are ,of use to the technical services group
manager in a variety of ways, including his estimation of budget and
staffing needs, and as a base for use in evaluating accomplishments of
the group during and at the end of the period covered by the plan.
While basic objectives may be identified in an examination of
requirements, legal and otherwise, that are imposed on the group, other
objectives which are important to the long range functioning of the
group may not be made apparent by that examination. Obviously, such
objectives may relate specifically to matters such as data processing,
97
-------
public information, or staff training. Needs of these types will vary from
program to program and will no doubt lead to the identification of others.
6.1.2 Organizing
A variety of organizational classifications found among State
agencies is described in Chapter 2. The advantages and disadvantages
of locating technical services and laboratory functions either within
or external to the State agency are discussed in that chapter. Some
management factors pertinent to the matter of organization, wherever
the activity is located, will be examined here.
Development and revision of organizational structure is a management
function. Conventional formal organizational structures, such as those
ordinarily used for technical services functions, are pyramidal in nature
with responsibility and authority increasing with successively higher
positions. The span of control is a matter of considerable importance
in the organization of a technical services group. In a highly repetitive
and routine endeavor, one supervisor may perform satisfactorily with
10, 20, or even 100 direct subordinates. Such situations are seldom
if ever found in even the largest and most stable technical services
groups in air pollution control agencies. While a satisfactory span
of control for any given activity will vary somewhat with the organization
and with the qualifications and characteristics of the supervisor and
his subordinates, in highly technical activities it should generally be
small, on the order of five or fewer direct subordinates per supervisor.
Figure 12 presents the organizational elements and managerial
configuration for a typical technical services group. The concept of
line and staff positions in the organization will not be discussed here
in detail. However, in the conventional concept, line positions are
those through which operating authority flows, while staff positions
98
-------
TECHNICAL
COORDINATOR
TECHNICAL SERVICES GROUP
-Manager
-Deputy Manager
-Clerical Support
QUALITY CONTROL
OFFICER
METEOROLOGY
SECTION
MONITORING
SECTION
•Ambient Unit
•Source Test Unit
•In-line Test Unit
LABORATORY
SECTION
DATA ANALYSIS
SECTION
-Wet Chemical Unit
-Instrumental Unit
^Special Studies
Unit
Figure 12. Typical organization chart for
technical services group.
99
-------
are those of a functional advisory nature who report to, and assist, a
particular line manager. In this concept the operating responsibility
and authority reside in the line manager, not in members of his staff.
It is important for line managers of all levels to recognize, however,
that staff positions in reality often exercise a considerable degree
of authority in their functional areas. Many matters of budget, personnel,
facilities, technical information, quality control, and the like, which
are often handled in functional staff offices, have as great an impact
upon program operations as do decisions made in the line management
hierarchy.
The formal organizational structure for a function such as technical
services in an air pollution control agency is ordinarily designed to
accommodate a continuing long-range program. Such an organizational
structure may not be very appropriate for nonroutine projects which must
be undertaken periodically. Development of an ad hoc project group,
without altering the established organization, is appropriate in such
cases. The project manager may be drawn from any element of the organiza-
tion, and his coworkers from his and other elements; their participation
in project activities may be on a part- or full-time basis. Project
responsibility in the group need not necessarily be assigned in the order
of rank or position in the parent organization. Upon completion of a
project, the project group is inactivated and its members continue in
their assigned positions in the formal organization. It is important
that the line of reporting for individuals assigned in project groups be
clearly defined since they have two supervisors—the organization supervisor
and the project supervisor. Depending on such factors as project priority
and agency policy, a person so assigned to a project group might be directed
100
-------
to report first through his functional supervisor, then through the
project manager. However, this should be decided at a higher level of
management than either the person's immediate supervisor or his assigned
project manager.
6.1.3 Staffing
Year-by-year and long-range program plans should identify manpower
needs on a functional element basis. It is not necessary that all manpower
*
needs be satisfied by in-house staff. Use of extramural manpower resources
is discussed in Chapters 4 and 9.
The characteristics of job classification, and schedules for grades
and salaries, are often prescribed by the State, or perhaps by the parent
agency within which a group functions. The provision of technical services
within a State air pollution control agency involves some highly technical
activities. In some States, restrictions on grade and salary have hindered
the satisfactory staffing of such technical groups. Sought through proper
channels of appeal, means sometimes can be found to ease such restrictions
and facilitate recruitment. When restrictions are encountered, a thorough
effort to find the means for relief is in order. Competent staff is vital
to success of the program and to proper utilization of the resources
i
which are devoted to it.
A continuing program of staff training, both short courses on tech-
nical and administrative topics, and long-term professional training for
selected staff members, merits the attention of managers at all levels.
Long-term benefits in the form of increased quality and efficiency in
operations, staff retention, and recruitment of better job candidates,
accrue from a liberal and vigorous training program. Some training can
be conducted in-house within a State agency's on-the-job training program,
101
-------
in addition, training courses on specialized topics are available
at the Federal agency level.
6.1.4 Budgeting
Budgeting format and procedures for the technical services group of
an air pollution control agency are ordinarily dictated by State or local
agency requirements. The required procedure may or may not involve budget
development by line item on a function by function basis. Functions to
be used are those as determined in an activity plan as discussed in
subsection 6.1.1.
Typical line items that must be included in developing a group's
planning budget are salaries, personnel costs (insurance, retirement,
incentive compensation, etc.), facility costs (rent, utilities, etc.)>
equipment acquisition and maintenance, supplies and materials, travel,
communications, and contractual services. If the established budget
development procedure does not involve a listing which permits identifi-
cation of funds for these elements, serious consideration should be
given to construction of such a listing. It is a useful management tool,
both in budget development and in evaluation of progress in various
projects through the time interval covered by the plan.
Not all costs for all functions will appear in the budget of a
group if services are received from other elements of government and
the costs of these services are included in their budgets. Unreimbursed
services received from a State forestry service or agriculture department,
for example, or from a city or county government, represent a project
cost which does not appear in the air pollution control agency budget.
Such costs must be recognized and included in assessing total cost of a
102
-------
project and in judging relative costs of various alternative means for
achieving any particular program objective.
A common difficulty among governmental agencies involved in technical
programs such as air pollution control is inbalance in funds for personnel
services (salary and other related services) and other operating funds
(travel, communications, equipment, etc.). Line items to be included
in operating budgets may vary from agency to agency, and the operating
expenses will not be the same among all agencies. A new or expanding
activity, for example, may require more funds for equipment acquisition
than does an established activity. In general, however, experience has
shown that for technical programs whose budgets include the range of
line items listed above, funds committed to personnel services should
not exceed about 65 percent of the total budget. Programs can operate
successfully with personnel services greater than 65 percent of budget,
but it is suggested that managers carefully scrutinize programs showing
personnel services budgeted substantially higher than this level to
determine whether performance might be improved by adjustment of funds
distribution. As the ratio of personnel service expenditures increased,
more manpower is available, but this larger working group has fewer
resources with which to work. An increase in funds expended for per-
sonnel services from 65 to 80 percent of budget, for example, increases
manpower by less than one-fourth, but decreases to about one-half the
nonpersonnel services resources available per man. The lack of adequate
nonpersonnel service resources may seriously inhibit the operation of a
technical services group and prevent achievement of objectives which
could actually be reached with fewer people having better facilities
and greater flexibility for action.
103
-------
6.1.5 Directing
The management function of program direction is generally that of
motivating and controlling the activities of subordinates. It is of
particular importance in the technical services functions of air
pollution control agencies that operations be so conducted that they
are consistent with laws, standards, regulations, and policies applicable
to the jurisdiction within which the agencies operate. Some standardiza-
tion of technical procedures is ordinarily practiced, especially when
the results may be used in a regulatory or judicial action. The
establishment and documentation of procedures by means of operating
manuals, memorandums of instruction, and the like, is of value in this
regard. With established procedures and clear enunciation of agency
policies, the process of "management by exception" can be practiced.
In this process, decisions relative to day-by-day operations are made
at each level of supervision according to established practices and
policies of the agency. When a situation arises at any level of
supervision which is an exception to the established practice at that
level, the matter is taken to successively higher levels of management
until it is resolved.
6.1.5.1 Responsibility Succession. The technical services group
of an air pollution control agency may have specific responsibility
for action in regulatory or episode avoidance procedures. The laws or
regulations governing such responsibility, or the assignment of sudh
responsibility within the agency, may specify an officer of the group
as having responsibility and authority to act. Some designated person
must be available to act at all times, yet a single individual cannot
104
-------
be constantly accessible. Thus, a succession of responsibility should
be established and documented within the group. This document should
list, in order, each person to whom authority and responsibility are
delegated in absence of persons whose names appear earlier in the list.
In the development of this listing of persons in succession of responsi-
bility, it is well to seek advice of legal counsel to assure that all
persons listed meet any requirements imposed by law or regulation.
6.1.6 Coordinating
Technical service functions of an air pollution control agency by
their very nature, have a high degree of interaction with other functions
of the agency, and other elements of the State or community. Coordination
of the technical services functions as they relate to these extra-agency
elements is a management function. The coordination function in some
cases may be highly specific. For example, participation in the SAROAD
program of the Federal Environmental Protection Agency requires adherence
to agreed performance criteria regarding methodology, data format, and
the like which may influence major portions of the technical functions.
The conduct of joint projects and intergovernmental cooperation as
described in Chapter 4 imposes a coordination role upon project managers.
This is especially important'in interstate and multiagency activities.
A general agency policy, consistent with State laws and regulations,
regarding exchange of data, review of draft reports, assignment of
personnel, equipment, and facilities, is a useful guide for technical
services managers in their relations with extra-agency elements.
6.1.7 Analysis^
Evaluation of the effectiveness of a technical services group in an
air pollution control agency requires relating accomplishments in its
105
-------
various projects to stated program objectives. A summary evaluation
should be made each year for use in planning, programming, and budgeting
processes. Evaluations less comprehensive than the annual evaluation
should be undertaken at more frequent intervals, perhaps on a bimonthly
schedule, to permit assessment of progress toward meeting the year's
objectives. Special attention should be given to activities which
depart markedly from a reasonable time schedule, particularly those
which fall behind schedule. A senior person in the management group
or the technical coordinator, a staff position in the immediate office
of the technical services group manager, should have specific responsi-
bility for conducting the interim and annual evaluations, and for
coordinating input for them. He should provide interim summary reports
of progress to the technical services group manager.
The evaluation process is also the means by which various alter-
natives are weighed and by which choices are made for improvements in
program operations. Determination of the optimal mode of operation
requires evaluation of the relative efficiencies of performing various
subfunctions within the technical services group, by other agencies
or service elements, or by commercial contractors.
A systematic approach to efficient management is possible through
techniques of cost/benefit analyses, efficiency studies, staff selection
procedures, and facility arrangements evaluation. Trade-offs between
capital expenditures and operating costs must be evaluated, and current
and anticipated funding levels must be considered continually. Such
an approach presumes that the functions and subfunctions of the technical
services group are well defined.
106
-------
6.1.8 Reporting
The reporting function for a technical endeavor such as the technical
services group of an air pollution control agency takes several forms.
In-house operational reports such as data tabulations, project progress
reports, etc., are necessary for information exchange within the group
and with its parent agency. Reports relating in whole or in part to
technical services functions are necessary for exchange by the parent
agency with other governmental agencies such as»the Federal Environmental
Protection Agency, the State legislature, or regional and local air pollu-
tion control agencies. Reports of technical advances or new findings made
in the course of work should be made to the technical and scientific
community through the technical journals or through direct publication
by the agency. Finally, reports must be made to the public to fulfill
requirements imposed by legislation, on initiative of the agency, and
in response to inquiry.
Supervision of the reporting process by assuring the preparation of
required reports, identification of additional reporting needs, main-
taining high quality of reports, and the timely completion of reports,
is a management function whose importance can hardly be overstated.
A technical program excellent in. all other respects, but deficient in
reporting, may be ineffective in achieving its goals.
The public relations function is of some importance. This function
is the means through which the community is informed and educated
regarding existing and prospective air pollution problems, and is told
of the means and need for prompt, effective solutions. Professional
public relations services for the technical services group should be
sought in its parent agency or government department. In-house
107
-------
responsibility for technical information dissemination functions can be
delegated to a staff position such as that of the technical coordinator
or technical advisor to the technical services group manager.
6.2 Specific Systems Management
The following subsections are devoted to specific management
functions which are of direct concern to the technical services manager
and his administrative staff. As discussed in the preceding subsection
(6.1), a multitude of interrelationships exist among the various manage-
ment categories and subcategories; this is particularly due to the
recurrent nature of the planning-execution-evaluation management system.
Thus the technical services group manager must consider his resources,
both personnel and facilities, in both the planning and evaluation phases
of management. He must be concerned with existing operational efficien-
cies, logistical considerations, and cost/benefit relationships in the
execution and evaluation phases of management. Such specific responsi-
bilities are, of course, overall program responsibilities and as such
are part of the agency's management services functions. It must be
remembered, however, that the technical services group manager and
certain members of his staff are "management" personnel, serving as
extensions to the management services group by delegation of responsibility.
The information and management functions resulting from this responsi-
bility at the technical services function level serve as inputs to the
air pollution control agency's overall management system. It is
necessary, therefore, that the technical services group maintain a
continuing management function, keeping up-to-date records and staying
abreast of state-of-the-art planning-execution-evaluation techniques.
108
-------
6.2.1 Resources: Personnel
6.2.1.1 Number of Staff Required. Several techniques are available
for estimating the number of the several categories of people required
to provide the technical services necessary for an effective air pollution
control agency. None of these techniques provides a number that can be
accepted without question—the results of each must be adjusted on the
basis of the agency's experience, professional judgment, and special
characteristics of the State's pollution problems and agency's interests.
The latter factor is significant since it is reasonable to assume that
ambient air monitoring requirements are established by more-or-less
fixed characteristics of the industrial and commercial geography, and
the demography and the terrain of the State, but that the scope and
extent of special air quality investigations are determined primarily
by the interests of agency personnel.
Minimum requirements for a statewide air quality surveillance
29
system have been established by the Federal EPA, and are shown in
Section 3.2. Agency resource requirements are necessarily related to
the designated pollutant measurement method, the sampling frequency,
and the monitoring site number and type (continuous, intermittent,
!
or static).
Approaches for defining the manpower needed to staff a technical
services group are, of necessity, related to the staffing requirements
for the total air pollution control agency. Estimation of agency
manpower needs include the following methods:
(a) Extension of existing operation data,
(b) Utilization of empirical correlation (i.e, manpower models),
109
-------
(c) Professional judgment based on experience,
(d) Combinations of the above.
The first approach is limited to operating agencies and to the
functions conducted by their agencies. If an agency already has a
monitoring network and is expanding into a larger area with more stations
or is increasing the capabilities of the stations (e.g., bubblers to
continuous monitors, or two pollutants to five pollutants),it should not
be difficult to estimate additional or new manpower requirements.
It is sometimes beneficial to look at the manpower requirements
for an ongoing, effective air pollution control agency outside of one's
own jurisdiction. This outside agency could be a State or local air
pollution control program with operational characteristics and problems
similar to one's own. Table 11, for example, describes the monitoring
network and manpower estimates for operation and routine servicing for
a designated air quality control region. Such a manpower summary is
based on "rule of thumb'1 factors: 0.5 man-year per continuous station
or 0.6 man-year if the continuous station includes a meteorological
package; 0.1 man-year per intermittent sampler/station. Another useful
estimate is 0.1 man-year per sensor for the entire network exclusive
of static samplers.
When the professional judgment approach is taken, more fundamental
manpower estimates can be made using first-hand experience. For
example, to estimate manpower requirements for a monitoring network,
the station's location, accessibility, and types of monitoring equipment
are considered. Considerations include travel time, frequency of site
visits, and average station time based on routine operations as well
as maintenance requirements.
110
-------
Table 11. SUMMARY OF MONITORING NETWORK
ST. LOUIS AIR QUALITY CONTROL REGION (Ref. 32)
Number Estimated
Ultimate network of man-years for
stations operation
Missouri
Continuous operating station3 2C
Intermittent sampling station 7
Total
Illinois
Continuous operating station 1
Intermittent sampling station 6
Total
1.1
1.4
2.5
0.5
1.2
1.7
a Continuous operating station. Assume 0.5 man-year per station;
0.6 man-year per station when meteorological instruments also
present.
b Intermittent sampling station. Assume 0.1 man-year/sensor/station
when operated every 3rd day per year. However, they are operated
more frequently during emergency episode surveillance. Intermittent
sampling stations usually contain 2 sensors, namely S02 bubblers
and high volume samplers.
c Meteorological instruments at station located in high pollution
area.
If the air pollution control agency is new or is otherwise inacces-
sible to basic manpower data(from existing operations, it can make use
of an empirical approach such as the Air Pollution Control Agency Man-
power Model.33 The Manpower Model represents the collective experience
of several existing programs and is structured to provide an estimate
of manpower needs for each of the established agency functions, including
that involving technical services support. The model is based on four
readily available characteristics34'35 of the agency's jurisdiction (land
area, population, number of manufacturing establishments, and capital
111
-------
expenditures) and is built around four key agency functions: air
monitoring, scheduled inspections, field patrol and complaint handling,
and operation of the permit system. This model is presented in
Appendix D.
6.2.1.2 Level of Training and Experience. The training and
experience required of an individual filling a specific position within
an organization is directly related to the responsibility and authority
delegated to that individual as the incumbent. The discipline or field
in which one has been trained carries more importance in the professional
grades, particularly if the position is at the "working" or nonsupervisory
level.
In general, at the entry level of professional work, whether it be
as a chemist or one of the branches of engineering (e.g., mechanical,
environmental, sanitary, etc.), only appropriate education is required,
as represented by a bachelor's degree from a recognized institution, or
by a combination of some years of formal education, but no degree,
supplemented by experience in the field. Sometimes experience is
accepted on a one-to-one basis in lieu of formal education for no more
than two years. At the entrance level, the professional employee is not
assigned supervisory responsibility but, in fact, is subject to direct
supervision himself.
The entrance level requirements establish the base on which the
entire professional grade structure within an air pollution control
agency is developed. Advancement to higher grades (or entrance at a
higher grade level) is dependent upon satisfying the entrance level
requirement plus the accumulation of experience. Typical requirements
112
-------
for experience for several categories of chemists and engineers as well
as for technicians are given in Table 12. It should be pointed out,
however, that if the highest technical level of education is the master's
degree level, the technical depth of the group could (not necessarily
always) be low. The grade levels (GS ratings) are related to the duties
and responsibilities of the position itself. In-grade or step levels
within each grade (ten sublevels) are indicative of job performance.
Subpar performance may result in an in-grade demotion or no increase;
adequate performance results in annual or periodic step increases;
superior performance deserves multiple step increases. Appendix B
contains examples of job responsibilities or position descriptions for
various technical service grade levels.
6.2.1.3 Salary. In the rapidly expanding field of air pollution
control, the demand for trained personnel has resulted in a general
upgrading of salary levels. It is difficult to say whether this trend
will continue. Also, salaries for positions with identical descriptions
may differ from agency to agency as a result of the necessity to meet
the demands of the competitive labor market. A 1969 survey conducted
by the National Society of Professional Engineers indicated that the
New England and Middle Atlantic regions are areas of highest pay for
engineers. Relative salary levels for the South, West, Midwest,
Southwest, and Plains region were 92, 92, 89, 87, and 84 percent of
the New England and Middle Atlantic level, respectively. Salary surveys
for chemists appear annually in Chemical and Engineering News.
Rather than attempt to discuss and justify actual salaries, an
effort is made here to show the relationship between salaries for the
several grades mentioned in the preceding subsection (Table 12).
113
-------
Table 12. TECHNICAL SERVICES PERSONNEL LEVELS AND REQUIREMENTS
Labor
rating
1
2
3
4
5
6
7
8
Position
Assistant
AP tech.
AP tech.
Assistant
AP chemist/
junior
engineer
Expert AP
tech.
Supervisory
tech.
AP chemist/
engineer/
analyst
Senior
scientist/
engineer
Supervisory
professional
Minimum
Qualifications education
(minimum requirements) (or equivalent)
Semiskilled aide with
limited background
Experienced aide with
background technique
and some knowledge of
chemistry
Professional with
modest training
and experience
Proven experience in
highly specialized
area
Project management
ability plus firm
technical background
Wide experience in
air pollution chemistry,
engineering or systems
analysis, computer
programming
Experience in complex
and specialized areas
of analytical chemistry/
environmental engineering
Experienced at project
management level; firm
background in all
technical areas
HSG/AA
HSG/AA
BS
AA
AA
BS
BS/HS
BS/MS
Minimum
experience
(years)
__
0-2
0-2
2-4
4-6
2-4
4-6
4-6
Equivalent
grade level
GS 3 to 5
GS 4 to 6
GS 5 to 7
GS 7
GS 7
GS 7 to 9
GS 11 to 13
GS 12 to 14
Base salary
levels
5800-73009
6500-8200
7300-9000
9000-11700b
9000-1 1700b
9000-11000
13300-18700
15900-22000
a Iii-grade level; step one.
In-grade range.
HSG - High School Graduate
AA - Technical School Graduate
BS - Undergraduate Degree
MS - Graduate Degree
-------
Relative annual salaries, and the range of salary for each grade, are
shown in Table 13.
6-2.1.4 Training Programs. It is anticipated that formal training
programs will be required in several technical service areas. Often
training courses will be conducted by the State agency headquarters for
each of the cooperating laboratories, both local agency and satellite
State operations. In addition, reliance is placed on the training
programs conducted by the EPA to keep State agency personnel abreast
of approved techniques and procedures. Information and guidance obtained
at EPA training sessions are disseminated within the State agency through
on-the-job training and agency memorandums or directions.
On-the-job training offers the most practical method of increasing
the proficiency of technical services personnel. In addition, full
advantage should be taken of instruction offered by manufacturers for
Table 13. RELATIVE ANNUAL SALARIES
AND WITHIN-GRADE SALARY RANGES
Grade level
3
4
5
6
7
8
9
10
11
12
13
14
15
Base salary3
Step No. 1
., 5,800
6,500
7,300
8,200
9,000
10,000
11,000
12,100
13,300
15,900
18,700
22,000
25 ,600
Step No. 10
7,500
8,500
9,500
10,600
11,700
13,000
14,400
15,800
17,300
20,600
24,400
28,300
33,300
a Overhead rates associated with the base salary
must be included for budgeting.
115
-------
both the operation and maintenance of their specialized equipment or
instrumentation. Periodic meetings, for example, of air monitoring
program personnel to discuss problems encountered with instrument
operation and solutions to such problems can be a useful training device.
Similar sessions appropriately scaled are essential for the indoctrina-
tion of personnel when new instruments, procedures, or methods are
introduced.
6.2.2 Resources: Facilities
6.2.2.1 Space Requirements. The source sampling operation within
22
the technical services group requires both office and workshop space.
Shop space allocation is approximately 70 square feet of shop area per
man.
Office space is normally determined by administrative policy, and
space requirements are often considered on a basis of the number and
type of desks. A minimum of 50 square feet is required pe~ desk. Small
private offices require at least 80 square feet. Many organizations
figure their space requirements on the basis of the number of profes-
sionals employed. A common guide of 130 to 150 square feet of office
space per professional is used by organizations engaged in scientific
and technical activity. Space costs in leased office buildings are on
the order of $5 to $6 per square foot per year.
There is no single design for a remote air sampling station. The
design chosen depends on such factors as agency needs, climate, equipment
contained, neighborhood, and mobility. In cases where the station is
used without additional support laboratory facilities, extra space is
required. The need for mobility, of course, is a space limiting factor.
116
-------
In general, a self-sustaining remote air sampling station has the
2
following minimum space requirements:
Instrumentation and laboratory area 150 sq. ft.
Work area (desk and sink) 30
Compressed gas cylinder storage 15
Miscellaneous storage 10
Toilet facilities 15
Sampling equipment area 40 '
260 sq. ft.
The sampling equipment area must be an elevated surface, such as the
building roof or separate structure. The area must have sufficient
structural support and roofing material and must be accessible by
stairs or ladder. The overall cost of a remote shelter varies widely
throughout the country because of the changing labor situation. Mobile
facilities are more costly than conventional stationary sites. A good
estimate of shelter costs based on facilities for heating, cooling,
sink, toilet, elevated work platform, and electrical services would be
in the $30 to $40 per square foot range. A more reasonable alternative
would be the remodeling costs which would run about $10 to $15 per square
foot. If plumbing or electrical services were not readily available,
this cost would, of course, increase.
Laboratory space requirements vary depending on the number of
analysts, the equipment used (wet lab versus instrument lab), and the
need for storage of reagents, sample containers, and the like. Rules
of thumb allocations are 200 square feet of space per laboratory module;
150 to 250 square feet of space per analyst; and 10 running feet of bench
117
-------
space per analyst. Leased space costs for an analytical laboratory are
in the $10 to $20 per square foot per year range.
The laboratory contains sinks, hoods, laboratory benches and desks,
a water demineralizer or still, hoods, muffle furnaces, and facilities
for gas and water service. It is a laboratory in which the preparation
of reagents for the air monitoring stations, calibration of instruments,
and maintenance of equipment is done. Also, fuel oil and coal analysis
plus source testing and special sample analysis are accomplished. These
latter functions are usually performed in a separate module.
Another space in the laboratory, usually separate from the wet
bench areas, is the instrument shop and storage area. This space is
used for maintenance, repair, and routine cleaning of air monitoring
equipment and sampling gear. Usually 1,000 to 1,500 sq. ft. is a desirable
storage and shop area for large agencies.
Where required in State programs, motor vehicle testing occupies offices,
laboratories, storage rooms, and a large open work area. The laboratory
is used primarily for testing and calibrating the program's equipment
as well as providing for general research requirements. The large open
work area is used to test fleets of vehicles for motor vehicle emissions.
The open work area contains dynamometers, all the program's diagnostic
equipment, and automobile tune-up facilities.
6.2.2.2 Equipment Requirements. The major equipment items for a
source test program are the sampling trains, vehicles for equipment
22
transportation, and associated laboratory equipment. A new panel truck
or station wagon costs in the $4,000 to $5,000 range. A complete sampling
train costs $3,500. At least two complete trains are normally required.
118
-------
Associated laboratory equipment and miscellaneous hardware, which can
be shared by more than one team, costs about $2,000. Such equipment
includes an analytical balance, desiccator, Orsat apparatus, and
calibration devices (spirometer, mass flowmeters, or calibrated orifice).
Additional costs to be considered are equipment and vehicle maintenance
and depreciation costs.
A complete listing of automatic air monitoring equipment costs can
be found in Appendix A of reference 2. In addition, a recent journal
article described the current state of the art of air monitoring and
Q/T
related equipment costs. Common ambient air pollution monitoring
techniques were discussed in terms of sampling and analysis costs for
static, mechanized, and automatic equipment. In general, a Hi-Volume
sampler costs $300 to $400. A gas bubbler system costs $700 to $1000.
Laboratory-type recorders cost $1,000 to $1,500 each.
Capital laboratory equipment costs vary with the monitoring network,
source sampling program, and special studies undertaken. The samples
to be analyzed from these three sources may require only an analytical
balance for gravimetric suspended particulate determinations or a whole
array of instrumental hardware for such things as metal analysis
(atomic absorption and emission spectres copy), asbestos analysis
(electron microscopy), polynuclear hydrocarbons (thin layer chromatography
plus spectrophotofluorescence analysis), sulfur compounds (flame photom-
etry, coulometry), and gas analysis (gas chromatography, spectrophotometry)
Other pieces of equipment used in air pollution research or special
studies include mass spectrometers, X-ray fluorescence instruments, and
radioactivity counters. Equipment costs range from a simple colorimeter
at $2,000 to a mass spectrometer costing over $100,000. Atomic absorption
119
-------
instruments, gas chromatographs, spectrophotometers, and related
laboratory equipment are priced in the $5,000 to $15,000 range.
6.2.3 Specific Techniques for Technical Services Group Management
6.2.3.1 Cost/Benefit Analysis. There are several reasons why
the technical services group manager may wish to conduct a cost analysis.
It will be useful in planning next year's budget, especially if expanded
operations are foreseen; it will help in the evaluation of current
operations; and it will be a worthwhile tool in project execution, in
that in-house costs can be properly weighed against the employment of
the outside contractual mechanism. Not only cost but related benefit
must be considered. For example, a benefit of keeping an operation in-
house is that the investment in personnel training and equipment purchase
can be utilized in future related work requiring the same skill level
and/or the same piece of equipment. On the other hand, a benefit of
conducting a project or laboratory operation through an outside
contractor is that it can free the technical services group to work on
higher priority matters. There are many other benefits that can be
realized by either keeping a technical services function in-house or
contracting it out.
Comparative costs of performing certain defined categorical sub-
functions can be derived by comparing the estimated costs of performing
the tasks within the technical services group with the costs of using
facilities and personnel of other departments or agencies, or contracting
the job or service outside the government structure. In estimating costs
of performing the subfunction within the technical services group, the
volume of work to be done, the man-hours required, the equipment needed,
the space required, the time distribution of the work load needed, and
120
-------
the response priority that must be given the subfunction must all be
considered.
Another factor that must be considered is the importance of
foregone tasks, i.e., those tasks which could be done in-house if the
categorical subfunction under consideration were contracted out. For
example, an agency might not be able to perform microscopic analysis
of particulates without decreasing the manpower available for analysis
of gas bubblers. If the decision were made to perform the particulate
analysis at the sacrifice of less bubbler analysis, the bubbler analysis
would be the foregone task.
As discussed in Chapter 9, there are several important considera-
tions in determining whether or not a particular task or study would be
better conducted in-house or by contract. Two very critical factors
are task priority (how quickly the results must be ready) and task
compatibility (how the proposed work will affect the existing program).
In some cases, the priority and/or capability benefits of conducting a
project on contract far outweigh the increase in cost outlay. In other
situations, priority and compatibility are not the major considerations;
direct labor costs, equipment costs, and overhead costs become deter-
mining factors in evaluating in-house versus outside contractor
cost-benefit.
Economy of scale is an important factor in cost analysis. If,
for example, a task requires special equipment and a skilled operator,
costs per job will be high if the work volume is so low that the equip-
ment, operator, and work area (space) are idle a significant portion of
the day. While "convenience" and "independence" factors will carry some
weight in the management decisions, idle equipment, personnel, and space
121
-------
are difficult to justify, since they represent a portion of the overhead
costs to be assigned to the particular project, task, or laboratory
operation under consideration.
Detailed cost analysis can be applied at several levels: to the
overall technical services program, to the technical services program's
organizational subelements, to specific projects performed within the
program, or to individual laboratory and field operations. Basically,
the costs are broken down into the line items (and subitems) of direct
costs, overhead costs, and general and administrative costs (G&A). The
overhead and 6&A costs are often referred to as combined overhead costs
and average about 33-1/3 percent of direct costs for an air pollution
37
control agency.
Direct labor costs for individual laboratory operations can be
determined by defining the number of supervisory, professional, and
technician man-hours required per unit operation; the skill level for
each of these personnel categories; and the average hourly rates for
each skill level. Burdened rates for specific laboratory or field
operations must consider not only the agency's current overhead rate,
but the additional costs of idle personnel and equipment downtime
related specifically to that operation.
6.2.3.2 Efficiency Studies. Another beneficial management tool
is efficiency studies to help in the planning, execution, and performance
evaluation of the technical services program. Efficiency studies can
be used either to determine desirable equipment characteristics or to
fit the right man in the right job. Over-trained as well as under-
trained personnel can result in lower efficiency. It has been found
122
-------
that poorly educated persons do well in carrying out certain types of
routine operations; a more educated individual tends to think too much
about what he is doing instead of developing a routine procedure.
Many subfunctions of the technical services group involve tasks
that are amenable to automation. A number of factors enter into the
decision as to the most effective method—manual or automatic—of
accomplishing such tasks. One constraint in these efficiency studies
is that 11 of the alternative methods or procedures considered must be
acceptable under either Federal and State or local regulations. Further,
it is suggested that the appropriate city, county, or State attorney
who will be responsible for litigation of air pollution cases be
consulted to determine if results of the various alternative methods
are equally acceptable under the Rules of Evidence and by precedent.
Once the legal acceptability of the alternative methods has been
established, performance characteristics of the specific devices or
procedures being considered can be assessed. In particular, reproduci-
bility, resolution, sensitivity, and response time or time constant are
of concern. Also of importance is the reliability of the devices or
systems being considered, a factor which might be measured in terms of
the mean time between failures, and the percentage of observations lost
during some selected period as a result of failures, maintenance, or
waiting for replacement parts.
If performance characteristics of the alternative methods are
satisfactory and comparable, a comparative cost analysis can be made,
keeping in mind that the proposed methods may require increased tech-
nical skills and, consequently, additional employee training or
123
-------
replacement. The purchase of an automated spectrophotometer for a State
agency's central laboratory would not be difficult to justify; on the
other hand, small local agencies and State satellite laboratories can
often do better with a rather inexpensive colorimeter.
Work volume is a critical factor in analyzing the relative
efficiencies of manual and computer data processing. For small amounts
of data, charges for keypunch, verification, computer operator, and
computer time itself may generate relatively high costs per unit output.
When data quantities are small, it will ordinarily be found that a
clerk using a desk calculator can provide data processing service at a
lower unit cost than that for computer processing. A single ambient
continuous station or several intermediate stations can be handled
manually. An episode alert network or a group of three or more
continuous ambient stations normally require computer processing for
reasons of immediacy and cost, respectively.
Efficiency studies directed toward choices other than that between
automated and manual operations will also prove useful. An increase in
operating efficiency of a laboratory frequently can be achieved through
changes in work patterns of personnel or by simple physical rearrange-
ment of furniture, equipment, storage or supply facilities, etc. If
formalized, studies of such factors are classed as time and motion
studies; the basic concept is to make the facility "convenient" for
the workers.
Similarly, attention should be given to the activities of field
personnel; whether they have appropriate tools and materials for their
jobs; whether the vehicles being used are suited to their purposes;
124
-------
whether successive assignments are being undertaken in the most efficient
order; and whether the routes being followed are the most efficient, when
both time and distance are considered. Such activities merit investi-
gation; consultation with field personnel is essential in arriving at
the answers to these questions concerning efficiency and appropriateness.
6.2.3.3 Logistics. The logistics operations of a technical services
group include the acquisition, storage, and distribution of laboratory
and field supplies, spare parts and chemicals, and the packaging, trans-
portation, and storage of collected samples before and after analysis.
Initial quantities of supplies, spare parts, and chemicals must be
based on manufacturer's recommendations, the sampling plan (number of
stations, sampling interval, etc.), and shelf deterioration or reagent
stability. After a sufficient period of operating time has elapsed,
stock levels to be maintained can be derived from experience, if adequate
records have been kept. Records of consumption of supplies and reagents,
and requirements for repair should be kept for each instrument, rather
than just by station, for obvious reasons. Experience will soon indicate
whether the technical skills of the personnel permit the stocking of
instrument parts, or whether subassemblies, components, or modules are
required.
The sample-analysis schemes for atmospheric samples present varying
logistics problems. Samples that are taken in the field and simulta-
neously analyzed with an automatic instrument present no sample deteriora-
tion problem. Samples taken in the field that are analyzed manually in
the field present a relatively minor sample deterioration problem.
Gaseous samples that must be taken from the field to the laboratory for
125
-------
analysis can be transported "as is" in an evacuated flask or plastic
bag or can be absorbed in liquid or solid media, with or without chemical
reaction. In choosing the method for sample transport, one must consider
sample deterioration as well as media shelf life. Certain atmospheric
components store better in Pyrex; others in Mylar, Tedlar or other
plastic containers. " Whenever sample or reagent instability
is a definite problem, the use of portable instrumentation or a mobile
van with laboratory equipment can provide a short-term solution. For
longer periods, methods which can utilize automatic sampling-analysis
instrumentation are required.
6.2.3.4 Example Situations. The technical services group manager
will be confronted with numerous decisionmaking situations. If he is
the manager of a satellite laboratory in a strong-State, weak-local-
agency structure, he must assess the advantages and disadvantages of
analyzing sulfur dioxide bubbler samples in his own laboratory compared
with sending the samples to the State's central laboratory for analysis.
If he is the manager of a strong local agency laboratory, he must
determine the cost and efficiency of conducting manual colon'me trie
analyses for sulfur dioxide compared with using an automated analyzer.
If he is the manager of the State's headquarters laboratory, he must
determine whether to perform pesticide and fuel analyses in-house or
to use an outside contractor.
Cost analysis can be applied to each of these types of situations.
For example, each laboratory operation carried out in-house;has a cost
from three major factors: labor, equipment, and space. Labor costs
are related directly to manpower requirements, both man-hours and
personnel levels. Equipment costs depend on capital expenditures,
126
-------
depreciation rates, and the percentage of time that the equipment is
"sold" for the laboratory operation in question and for other laboratory
operations. Space costs, of course, are dependent on the personnel
and equipment requirements.
Table 14 is an example of a labor-factor cost analysis for three
distinct manual laboratory operations: colorimetric sulfur dioxide
»
analysis, fuel analysis, and pesticide analysis. In each case, the
manpower requirements are defined in terms of the manpower contribution
from supervisory, professional, and technician personnel, and in terms
of the skill level of these personnel. Unit operation costs are
calculated using the salary rate ranges listed in Table 12. in
addition, Table 14 presents the daily labor cost for each operation
based on an average daily work load. The equipment costs for sulfur
dioxide analysis will vary widely depending on the price of the colori-
meter or spectrophotometer and the extent of cost sharing with other
colorimetric laboratory operations such as methods for nitrogen dioxide,
oxidant, and hydrogen sulfide analysis.
Equipment cost for analyzing various fuels for their Btu content
I
is similar to the price of the bomb colorimeter. Although this equip-
ment can be used for determining heats of combustion, oxygen bomb
methods which include chemical analysis are available for determining
fuel content of sulfur, halogen, arsenic, boron, and many other elements.
Equipment costs for pesticide analysis is the price of the gas chroma-
tograph system. The gas chromatograph is a very versatile instrument
and can be used for analysis of several other pollutant species. An
increasing need for gas chromatographic analysis of reactive hydrocarbons
127
-------
Table 14. MANPOWER-LABOR COST REQUIREMENTS FOR LABORATORY OPERATIONS
ro
00
Laboratory
operation
S00 analysis
c.
(colorimetric)
Fuel analysis
(B.t.u.
cal crime try)
Reactive hydro-
carbon analysis
(gas chroma-
tography)
Skill level
Man-hours grades Cost per
unit
a h r UmT;
Sa PD Tc S P T operation
0.1 ~ 1.0 5 - 2 $3.47 to
$4.27
0.2 1.6 0.2 8 6 2 $9.08 to
$11.05
0.1 1.0 — 8 7 — $7.15 to
$9.89
No. of operations Labor cost
required per per
unit time
20/day
5/day
2/day
unit time
$69.40 to
$85.40/day
$45.40 to
$55.25/day
$14.30 to
$19.78/day
S = Supervisory
b P = Professional
c T = Technician
See Table 12 for skill level grade ratings; annual rates can be converted to hourly
rates by dividing by 2080 (hours per year).
-------
and oxidant materials would spread equipment costs over several
different laboratory operations.
Efficiency studies can also be used in meeting decisionmaking
situations. In setting up a statewide technical services function, an
efficiency study can be used to determine how best to locate, outfit,
and staff laboratory components in support of existing monitoring
networks, engineering functions, and enforcement functions. In
established technical services groups, efficiency analysis of
individual laboratory operations can provide for the maximum utili-
zation of equipment, space, and personnel. For example, an efficiency
study of the statewide program may indicate that the State would be
best served by a weak-State, strong-local-agency organizational
structure. The State agency headquarters would have minimum internal
laboratory capabilities but would coordinate and oversee all of the
State's satellite and local agency laboratory activities. An efficiency
study of an individual laboratory within the technical services program
would indicate the types of personnel and equipment needed, preferred
work patterns, recommended spatial arrangement of equipment, offices,
storage facilities, and laboratory bench areas.
129
-------
7.0 DATA HANDLING
Activities of the State air pollution control agency generate large
quantities of data. In addition for those States with comprehensive
local agencies, it is important that data collected by the local agencies
be made available to the State agency. Expanded program activities by
the State and local control agencies, especially in the area of air
quality monitoring, will greatly increase the quantity of data to be
handled. Since the technical services group has responsibility for the
collection and analysis of air quality data, it is important that the
development of data handling procedure be considered in the design of
the laboratory and its operating procedures. These procedures must
specify the flow of data within the technical services group as well as
between the technical services group and local agencies and between
the laboratory and the Federal Environmental Protection Agency.
In order to be responsive to the needs of management, the data
handling procedures must be flexible enough to satisfy a number of
requirements. First of all, provisions must be included for the very
rapid flow of data required by the emergency action p^an. Provisions
must also be made for the transmittal of data in a routine day-to-day
basis. Finally, the procedures must define the types and frequency of
preparation of routine and specialized statistical summaries.
7.1 Data Flow
The technical services group has the responsibility for the
collection, storage, and dissemination of data. Its relationship with
the Federal Environmental Protection Agency is one of providing data
which can be used for evaluating the progress toward the attainment
130
-------
and maintenance of national air quality standards. In addition, the
technical services group must provide data to EPA during periods of high
air pollution to demonstrate that the public is being protected from
imminent and substantial endangerment.
The relationship of technical services with local control agencies
is primarily supportive. In the case of a comprehensive local agency,
the technical services group may require a daily air quality status
report during normal conditions and hourly reports during air pollution
episodes. In addition, the local agency may be required to submit
detailed air quality data and data summaries on a monthly or quarterly
basis. Local control agencies with limited resources may assist the
State through the operation of monitoring stations. Under these condi-
tions the State technical services group provides analytical services
and reports its results to the local agency on a monthly or quarterly
basis. In areas with no local control agency, the State technical
services group is responsible for the field operations of the air
monitoring program.
7.1.1 Local to State
Data may be transported from the local agency (or satellite laboratory)
in a number of ways: (a) on da'ta record forms, (b) on punched cards or
magnetic tape, and (c) over the telephone by voice communication or a
telemetry system. The method of transmittal is dependent upon the type
of local agency (or satellite laboratory), the quantity of data involved,
and whether or not the data are essential to the emergency action plan.
7.1.1.1 Noncomprehensive Local Agency. An agency of this type
generally provides field operations support for the statewide air
131
-------
monitoring program. Typically, this support involved servicing air
monitoring equipment such as high volume samplers and 24-hour gas
bubblers. The field man sets out the sample media and records the
initial air flow. Following the termination of the sampling interval,
the air flow is again recorded. The field record and the sampling media
are forwarded to the State air pollution control agency.
Local agency personnel may also be responsible for the operation
of continuous monitoring stations. In this situation the operator is
generally required to submit a daily air quality status report by
telephone to the State agency. The contents of the status report
will be dictated by the data reporting requirements of the emergency
action plan. Upon activation of the emergency action procedures, the
field operator may be required to submit reports by telephone on an
hourly basis. At weekly intervals, the station operator sends strip
charts and the output from the data acquisition system to the State
laboratory for subsequent data processing.
7.1.1.2 Comprehensive Local Agency. A comprehensive local agency
typically has sufficient resources to operate its air monitoring program
including an analytical laboratory. Air quality data collected with
intermittent type sampling devices are submitted to the State agency
on a monthly or quarterly basis. Data of this type may be submitted
on data record forms, punched cards, or even magnetic tape.
Local agencies whose atmospheric surveillance activities include
continuous air monitoring devices may submit data to the State agency
in two ways: (a) hourly average pollutant concentration may be
visually scanned from strip charts and manually entered on data record
132
-------
forms or (b) hourly average concentration may be computer processed and
written on a magnetic tape. When computer services are available to
the local agency, the monthly, quarterly, and annual reports may be
also sent to the State agency.
Consistent with the emergency action plan adopted by the State,
the local agency will submit daily air quality status reports by
telephone. Hourly status reports may be required when the emergency
action procedures are invoked.
7.1.2 State to Local Agency
The State's technical services group operates in support of the
local control agencies. As such, the technical services group should
not duplicate any activities carried out at the local level. Therefore,
the flow of data from the State to the local agency must be sufficiently
flexible to fulfill the needs of these agencies.
7.1.2.1 Noncomprehensive Local Agencies. In situations where
the State's technical services group is responsible for the analysis
of intermittent air samples and the processing of continuous sampling
data, it is more important that air quality data be provided to the
local agency. The State should provide tabulations of the 24-hour
measurements made by the intermittent sampling devices and the hourly
averages computed from the data for the continuous analyzers. These
tabulations should be provided on either a monthly or quarterly basis.
In addition, statistical summaries should be provided to the local
agency on both a quarterly and an annual basis. The quarterly summaries
may be the same type of summary that is used by the State to submit
information to EPA.
133
-------
7.1.2.2 Comprehensive Local Agencies. For the most part, compre-
hensive local agencies will have sufficient need for prompt access to air
quality data that they will install and utilize the Air Quality Data
Handling System (AQDHS) to satisfy their immediate needs. This system is
currently being developed by EPA for State and local agencies. In so
doing these agencies will maintain their own data storage and retrieval
system. Agencies of this type will be most interested in statewide data
summaries and statistical analyses which only the State agency or techni-
cal services group will be in a position to prepare. Data of this type
provides the local agency the opportunity to compare its progress in
attaining air quality standards with that of other areas in the State.
7.1.3 State to Federal
The State is required to submit air quality data to EPA on a
quarterly basis commencing with the first full quarter after the approval
of the Implementation Plan. Submission of such data would be in one of
the following ways: (a) SAROAD form, (b) on punched cards in SAROAD
formats, or (c) on magnetic tape in SAROAD format. It can be expected
that the format of their data summaries will be published in the
Federal Register at an early date.
7.1.4 Federal to State
The State technical services group receives selected summaries of all
quality data which are submitted to the National Aerometric Data Bank.
Detailed data tabulations and statistical summaries of all data submitted
to the Data Bank by all State and local agencies throughout the country
are prepared annually by EPA. Copies of these publications are widely
distributed. Additional requests for selected data tabulations and
statistical summaries may be submitted to the National Aerometric Data
134
-------
Bank. The extent to which such requests can be fulfilled is dependent
upon resources available within EPA.
7.2 Records
7.2.1 Reporting Formats
The technical services group will find it necessary to develop a
variety of reporting formats to handle the data generated by the air
monitoring activities of the State and local agencies. While these for-
mats will differ somewhat from State to State, it may be practicable to
modify one or more of the following formats to meet the needs of a
particular technical services group.
7.2.1.1 Intermittent Sampling. A form is required to record
the field data, relative to the air sampling device, and the laboratory
data, both of which are necessary to compute the 24-hour pollutant
concentration. A typical form for use with 24-hour particulate samples
is shown in Figure 13.
When a computer-oriented storage and retrieval system is used, it
is necessary to prepare data for key punching. Since it is usually
sufficient to update master files containing 24-hour data on a monthly
basis, a form similar to that shown in Figure 14 or 15 is recommended.
A form of this type can be used for as many as 4 to 6 pollutants at
an individual station. Since the pollutant name is coded and entered
in the boxes entitled "Parameter Code" (Figure 15), the form can be
used for any 24-hour pollutant measurements. A form of this type
provides for updating master files on a monthly basis.
7.2.1.2 Continuous Sampling. If a continuous air monitoring
device is not equipped with a data acquisition system of some type,
135
-------
SAMPLE NO.
STATION NO.
DATE
TIME
FLOW RATE
START OF SAMPLING
FINISH OF SAMPLING
DATE
FILTER WEIGHT
ROOM TEMPERATURE
RELATIVE HUMIDITY
TOTAL VOLUME SAMPLED_
TOTAL WEIGHT GAINED__
DUST LOADING
CUBIC METERS
MILLIGRAMS
HGMS/M3
6AAPCD
WSrfm
10/8/70
STATION OPERATOR_
WEIGHING OPERATOR
Source: Bay Area Air Pollution Control District
Figure 13. Parti oil ate sampling record.
136
-------
Filter #
Raw Sampling and Lab Data
(Coding fora)
Time
Start | 1
Stop
Format Cnty City Site
£1 (2) (4) (6)
m 11 v I
Yr Mon By Hr Time Type Agency Time Run
(8) (10) (12) (14) (16) (17) (19) (20)
n m n rrm
n 111111 111
Flow
Start Stop
(24)
Pollutant Method Total Vol. Aliquot Sample Wt. DP
Blank 7. Filter
(28-52)
(53-77)
CD
No ]
(1)
(1)
(1)
(1)
m
Pollutant
C28)
f28)
C28)
C28)
f28)
M
lethod
Total Vol.
Aliquot Sample Wt
. DP
r
1
L
B
B
I
Blank
7.Filter
(28-52)
(53-77)
(28-52)
(53-77)
(28-52)
(53-77)
(28-52)
(53-77)
(28-52)
(53-77)
Remarks
Final Wt.
Tare Wt.
Sample Wt.
SOURCE: Columbia-Willamette air pollution authority.
Figure 14. Raw sampling and laboratory data coding form.
137
-------
ENVIRONMENTAL PROTECTION AGENCY
National Aerometric Data Bank
P.O. Box 12055
Research Triangle Park. N.C. 27711
24-HOUR OR GREATER SAMPLING INTERVAL
i Agency
Ctty Name
Sfte Address
Day
19 20
Q
n
0
0
0
0
0
0
0
1
1
1
1
1
1
1
1
1
1
2
2
2
2
2
2
2
2
2
2
3
3
1
2
3
4
5
6
7
8
9
0
1
2
3
4
S
6
7
8
9
0
1
2
3
4
5
6
7
8
9
0
1
Project
Name
PARAMETER
Code
1 1 1 1
23 2
3:10
Time Interval
Name
PARAMETER
Code
[
37
0
1 1 1
38 39 1.0 «.!
hod Units DP
amn
13 «,!. its >i6
<>7 >i8 <<9 SO
43210
State Area Site
1 1 1
1 1
Agency Project Tii
n m C
11 12 13 1
Name
PARAMETER
Code
r
51
56
1 1 1
52 S3 5". 55
a Units DP
mn
57 SB 59 60
61 62 63 6
-------
it is necessary to reduce pollutant concentration data from strip charts.
Data reduction may be completely manual, in which case a technician
visually scans hourly average concentrations and records them on a form
similar to that shown in Figure 16. With a form of this type, the
24 one-hour measurements are recorded on two lines. Since this type of
data reduction tends to be very tedious for the technician, it is
conducive to a high frequency of reading and recording errors.
*
The reduction of data from strip charts can be expedited through
the use of semi automated chart readers. With a chart reader the
technician still visually scans the hourly average concentration but
the resultant data is automatically punched onto cards. This eliminates
a separate key punch operation, increases the productivity of the
technician, and minimizes the error rate in transcribing data on the
record form.
7.2.2 Station Operator Logs
When automated data acquisition systems are used to record continuous
monitoring data on magnetic tape, it is necessary for the station
operator to maintain a daily performance log. An example of such a log
is shown in Figure 17. The operator records information about instru-
ment drift and equipment malfunctions. This information is subsequently
used by the computer to process and validate the continuous data.
7.2.3 Summary Formats
The kinds of air quality data summaries that are prepared should
be determined by the way in which the information is used by management
for program evaluation, planning, and decisionmaking. Examples of
formats in wide use are presented in this section.
139
-------
c/t
3>
ya
o
tst
?
LESS THAN 24-HOUR SAMPLING INTERVAL
i Agency
City Name
Site Address
ENVIRONMENTAL PROTECTION AGENCY
National Aerometrlc Data Bank
P. 0. Box 12055
Research Triangle Park
North Carolina 27711
State
Area
Site
Parameter observed
Method
i i i i i iirn
23 5 5 E 7 8 9 To
Agency (Project Time Year Month
-D m n m m
TT 12 13 1U IS 16 17 16
Parameter code Method Units DP
Time Interval of obs. Units of obs. I I I I I I I I I I I I [~\
23 2<0
Rdg 3
Ml >>< <43 <
-------
SEC 468
(REV 10-61)
RECORD OF OPERATOR'S LOG
STATION.
12345
DATE:
OPERATOR.
GAS
.to.
.LLJ
6 7
MO.
8
9
DA.
10
11
YR.
12J13
D*
14
ITEM
15
16
17
START
18
19
20
21
STOP
22
23
24J25
PURGE
2?
28J29
| '
30
COMMENTS
Day of W«.lc.
Source: Continuous Air Monitoring Program
OAP-EPA
Figure 17. Station operator's log.
-------
7.2.3.1 Cumulative Frequency Distributions. A summary format
which is used extensively to present air quality data is shown in
Figure 18. This method of data presentation is ideally suited for
24-hour and continuous monitoring data. Particularly with 24-hour air
quality surveillance in which samples are collected on a 6-day basis,
the cumulative frequency distribution is most useful. This technique
provides an estimate of the overall distribution of air quality for
the year.
7.2.3.2 Monthly Summary of Continuous Data. The hourly average
pollutant concentration data from a continuous monitoring device can
be summarized as shown in Figure 19. This method of presentation provides
a means of looking at pollutant concentration trends on individual days.
In addition, the table includes daily as well as monthly average
concentrations. Finally, the mean hourly concentration at the bottom
of the table shows the diurnal pattern.
7.3 Hardware Assistance
The large quantity of data resulting from air quality monitoring
activities makes the use of data handling hardware desirable from the
standpoints of both efficiency and cost. There are essentially two
types of hardware applicable to air quality data handling: (a) data
acquisition systems, and (b) computer-oriented data storage and retrieval
systems.
A data acquisition system provides an automated method of recording
the output from one or more pollutant sensors. The system may record
data in the field on paper or magnetic tapes. If the data are recorded
on magnetic tape, it is important that the tape format be compatible
with the computer to be used in processing the data. Through the use
142
-------
Table 1-7. FREQUENCY DISTRIBUTION OF CONCENTRATION OF GASEOUS ATMOSPHERIC POLLUTANTS
(5-mlnuU valuei, concentration in part* fur million)
City /pollutant
CHICAGO
CARBON M3NOXIDE
NITRIC OXIDE
ICTPOCd DIOXIDE
SULFUH DIOXIDE
KTOROCAK30N
TOTAL OXIDAOT
CAI2VN MDKOXIDE
Wir.-TC OXIDE
KITX/SEn DIOXIDE
SULFUH DIOXIDE
WDHOCASBOH
TOTAL CXTDAST
DENVER
CARBON KJNOXIDE
NITRIC OXIDE
NITKJCEI DIOXIDE
SULFUR EIOXiDE
HVDROCAEBOM
TOTAL OXKAOT
CAEBCN MDWIXrDE
HIT3IC OXIDE
SITSOO-:; DIOXIDE
SULFUR EIOXIDE
HTOROCASBOH
TOTAL OXI33AOT
ST. LOUIE
CAEBON MONOXIDE
KITKIC OXIDE
N7TEOGEI DIOXIDE
SULFCH DIOXIDE
HYDH3CAIIBON
TOTAL OKIZAJIT
WASHIIS-.W D.C.
CASKS MONOXIDE
KITSiC OXIDE
NITKMEN DIOXIDE
SULF'J?. 5IC.XIDE
HYDSGCA.'VOt:
TOTAL OXIDA1IT
Valid
data.
Frequency diBtrilrutlon, percent
£ Klnlnura 10
65
79
80
75
55
5V
3U
73
76
81
71
62
71
60
71
U8
ue
70
77
89
60
U2
86
66
81
90
89
U&
71
6U
7U
62
59
0
.00
.00
.00
.0
.00
0
.00
.00
.00
.5
.00
0
.00
.00
.00
.0
.00
0
.00
.00
.00
.0
.00
0
.00
.00
.00
.u
.00
0
.00
.00
.00
.0
.00
1
.01
.03
.01
1.9
.00
3
.00
.02
.00
1.7
.00
1
.00
.01
.00
1.7
.00'
3
.00
.02
.01
1.3
.00
2
.00
.01
.00
2.0
.00
1
.00
.02
.00
1.6
.00
30
3
.03
.OU
.<&
2.3
.01
U
.01
.02
.00
2.0
.01
3
.01
.02
.00
2.1
.01
6
.02
.03
.03
1.6
.01
.01
.02
.00
2.6
.01
Z
.01
.03
.00
1.8
.01
50
.06
.05
.08
2.7
.02
5
.03
.03
.01
2.2
.02
U
.02
.03
.01
2.5
.03
8
.03
.03
.05
1.9
.02
U
.02
.02
.01
3.1
.02
3
.01
.ou
.02
2.0
.02
70
7
.09
.05
.1U
3.2
.03
6
.06
.0>*
.02
2.6
.03
6
.OU
.OU
.02
3-1
.OU
10
.05
.OU
.08
2.3
.03
.0?
.03
.03
3.7
.03
U
.03
.05
.05
2.3
.03
90
13
.15
.07
.28
U.I
.05
9
.18
.05
.OU
U.O
.05
11
.10
.06
.03
U.U
.06
15
.12
.07
.19
3.3
.05
8
.08
.OU
.07
5.0
.OU
6
.08
.08
.10
3.0
.06
95
16
.18
.08
.36
U.7
.07
11
.27
.06
.06
5.1
.06
1U
.1U
.07
.OU
5.U
.07
18
.18
.08
.28
U.l
.06
10
.11
.05
.11
6.0
.05
8
.13
.09
.13
3.6
.06
9B
20
.23
.10
.ue
5.6
-09
15
.38
.07
.08
6.5
.08
19
''.09
.06
7.0
.09
22
.28
.10
.UO
5-1
.08
!o6
.18
8.0
.07
11
.23
.11
.17
.10
99
2U
.28
.11
.57
6.6
.10
31
.U6
.08
.10
7.U
.10
2U
.26
.11
.08
8.5
.11
25
.Ul
.12
.ue
5.9
.10
16
.20
.07
.23
.08
1U
.33
.12
.20
6.0
.12
Maximum
57
.66
.29
1.33
17.3
A7
U5
1.26
1.19
1.U9
18.1
.19 .
90
.68
.38
1.81
18.7
.U3
U9
1.68
.22
1.10
13.3
.31
U7
.uu
.20
1.33
17.1
.37
59
.76
.&.
.t7
18.6
.29
Arithmetic
mean
6.2
.071
,oua
.117
2.90
.023
5.6
.06U
.031
.017
2.58
.022
!036
.012
2.89
.029
8.5
.05U
.039
.080
2.1U
.022
U.6
.032
.023
.028
3.1>0
.023
3-3
.035
.036
2.23
.027
Table 1-8. FREQUENCY DISTRIBUTION OF SOILING INDEX
(2-hour meajurtments, conc*n«r
-------
! Ml MdNITOMNB HOCMM
tut Qu'My*• i-M. Ii>ou|e>Tf\ tv««"ni lit;' fty\uf Sown
U S OtpJilr-nU!H»'lk»Ji^>3n I
tcbtil A. l»lt StMMr [«|i»w«|C**rt«
HOURLY AVERAGES OF
GASEOUS POLLUTANT CONCENTRATIONS
CONCENTRATION IN PPM
POTASSIUM IODIDE ANALYSIS
PHILADELPHIA,PA.
TOTAL OXIDANT
JAN. 1968
DAT
or
MON1H
1
2
3
4
t
6*
7«
8
9
10
11
12
13V
15
16
17
18
19
20*
21«
22
23
24
25
26
27*
28*
29
30
31
VAX
ia i
.Oi
,oc
.04
.0!
.00
.0=
.01
.oe
,00
.oc
.03
.01
.03
.00
.03
.08
.03
.03
.02
.02
I02
.02
t
.01
.00
.10
.02
.01
.02
.0?
ZB,
.Id!
.02
,0
.04
.02
.OC
.0,
,01
.01
,00
• 0(
.03
.02
.02
.02
.oe
.02
.03
,01
,02
,02
.02
.01
.02
,o3
.01
'l
.02
.02
27
.01
... _
.Oi
.0
.02
.0!
.OC
.03
.01
.oc
.00
.00
.03
.02
.03
.01
.02
.03
...
.02
.02
:SJ
.03
.01
•02
.OC
.01
.02
.02
.0
28
.0:
.01
.0!
.02
.02
.01
.04
.OC
.0!
.01,
.on
.02
.02
.01,
.07.
.03;
"'I
.0?
.02!
.01
.03
.01
.01
.oz
.02
.02!
.02
.01
.0!
28
.04
a
.01
.01
.03
.02
.00
.03
.00
.00
.01
.00
.02
.02
.03
.01
.02
.03
..03
.02
.02
.02
.02
.03
.01
.00
.01
.02
.02
.02
.02
28
.03
M
.01
.02
.03
.02
.00
.03
.01
.OC
.01
• 0(
:d
.021
.OC
.Oi
.03
.02!
.03
.*02
.0
.02
!oc
.03
.02
.02
.Oi
28
.04
.02
.02
.OS
.01
.00
,03
-------
of telemetry, data may be recorded on tape at a central station or be
interfaced directly to a computer.
A computer-oriented data storage and retrieval system, such as the
AQDHS, provides a means of processing large quantities of data to obtain
tabulations, statistical analyses, or even graphical presentations of
data. The data storage and retrieval system utilizes magnetic tape or
disk storage devices for maintaining large data*files. These files
are extremely dynamic, since they are constantly being updated when new
data become available. Typically, these files are updated on a weekly
or monthly basis.
7.3.1 Current Practices
A wide range of hardware-assisted data handling systems are available
today. These systems range from those in which punched cards are used
to input data to a computer-oriented data storage and retrieval system,
to computer-controlled telemetry systems.
7.3.1.1 Punched Card Data Input. By far the most commonly used
hardware-assisted data handling system is based upon the use of punched
card input. In this system all data are initially recorded on data load
sheets from which punched ca'rds are prepared. The punched cards are
read by the computer and magnetic tape files are updated. The primary
functions of the computer are file maintenance and retrospective studies
of the data. This system is ideally suited to the preparation of
monthly, quarterly, and annual data tabulations and reports.
7.3.1.2 Field-Operated Data Acquisition Systems. Included in the
equipment specifications for the Continuous Air Monitoring Program (CAMP)
were punched paper-tape data-logging devices. Each pollutant sensor
145
-------
was interfaced with its own data logger. At 5-minute intervals the
instantaneous position of the pen on the strip chart recorder was
digitized and punched onto paper tape. Daily the station operator also
recorded pertinent information concerning the sensor and its operation
in an Operator's Log. At weekly intervals the strip charts, punched
paper tapes, and operator's logs were sent to the data processing center.
The punched paper tapes were processed by a computer, which corrected
for instrument drift and performed limited data validation. After
further data analysis the new information was added to the master files.
In addition to preparing listings of the 5-minute data, the computer
was used to prepare monthly and annual summaries and detailed statistical
analyses.
Systems of this type, which are currently being installed, now
record data on magnetic tape. In addition, these newer systems include
a programming device which permits the recording of data from a number
of sensors on a single magnetic tape. Even though these systems have
the capability of recording at a very fast rate, in some instances the
practice of recording at 3- to 5-minute intervals is maintained. From
a practical standpoint most control agencies are concerned with pollutant
concentrations averaged over an hour or more. In essence, the 3- to
5-minute measurements provide a means of integrating to obtain a
representative hourly average.
The practice of sending the magnetic tapes to the computer center
on a weekly basis is maintained by most agencies. Typically, the computer
center prepares listings of the 3- to 5-minute data for use in data
validation following which hourly concentrations are computed and stored
146
-------
on the master file. Data summaries are prepared monthly, quarterly,
and annually.
7.3.1.3 Telemetered Data Acquisition Systems. The next level of
sophistication in a data acquisition systems involves the use of telemetry
to transmit data from the monitoring station to a control station. At
predetermined intervals the command module at the control station selec-
tively polls the pollutant sensors at each station and records data on
tape (usually magnetic) at the control station. Typically, this system
includes a teletypewriter which provides a hard copy tabulation of the
data as they are received from the field stations. On a daily basis the
input tapes are processed by the computer. After validation, the data
are entered into the master files of the storage and retrieval system
from which all reports and analyses are prepared.
This type of system was first used by the City of Chicago for
transmitting data from its eight telemetered air monitoring stations.
7.3.1.4 Computer Controlled Data Acquisition System. The most
advanced data acquisition systems now in operation interface the pollutant
sensors at the field monitoring station via telemetry, directly to a
small dedicated computer at the State (or satellite) location. This
system operates in a real-time command and control mode and is ideally
suited to the rapid response required of an air pollution emergency
operations control center. Systems of this type tend to be very costly
and their justification is generally in terms of relatively high
frequencies of occurrence of air pollution episode conditions.
The command computer transmits a signal to a remote station,
activating a programmer which interrogates each pollutant sensor. After
completing the interrogation of all sensors, the computer receives an
147
-------
end-of-message signal which directs the computer to poll the next remote
station. Upon receipt of the data, the computer stores the data from
each sensor until the end of the hour. Each hour,the computer calculates
hourly averages for individual pollutants. These hourly averages are
printed through an online printer or teletypewriter and recorded on
magnetic tape. The magnetic tape is sent daily to the computer center
where the data are entered into the master files of the storage and
retrieval system.
The dedicated computer has the ability to compare incoming pollutant
concentrations with alert levels specified in the emergency action plan.
Whenever an alert level is in danger of being exceeded, the computer
will so indicate on the hard copy output.
7.3.2 Advantages
Most State air pollution control agencies will find it increasingly
more difficult to operate their air quality surveillance activities
without some type of hardware assistance. The type of hardware required
will depend upon the volume and types of data being collected. Almost
without exception, States will find it necessary to use computer-oriented
data storage and retrieval systems. Due to the volume of data generated
by continuous monitoring systems, it is advantageous to use data
acquisition systems to record data in a computer compatible form. The
extent to which a State can justify the use of telemetry systems and
online computers will depend a great deal upon its need for rapid
response during air pollution episodes.
The advantages of hardware assistance in the handling of air
quality data can be summarized as follows:
148
-------
(a) To provide an effective means of handling large quantities
of data,
(b) To relieve staff members from repetitive data manipulations
and to make them available for tasks that are more satisfying
and productive,
(c) To minimize the proliferation of errors that result in
repetitive tasks,
(d) To provide a means for rapid response during air pollution
episodes,
(e) To permit retrospective studies which otherwise would not
be performed without automated procedures.
7.3.3 Disadvantages
The use of data acquisition systems and computers introduces some
problems which cannot be overlooked. Some of the disadvantages of
these systems are:
(a) Capital outlay is required to purchase or lease and install
the equipment;
(b) Individuals with skills in electronics and computer science
must be available on the staff of the agency;
(c) Specialized computer programs must be designed and/or
implemented;
(d) Most control agencies must rely on a computer center that is
not under their own administration for data processing services
(it is very important for the control agency to negotiate a
fixed schedule for routine data processing services);
149
-------
(e) Automated data validation procedures must be developed to the
fullest extent possible because people tend to rely too much
upon the equipment and may tend to overlook bad data.
7.3.4 Recommended Utilization
All State air pollution control agencies should give serious consi-
deration to the use of a computer-oriented data storage and retrieval
system. Additionally, those States with the responsibility of handling
data from even a few continuous monitoring stations should investigate
the use of data acquisition systems.
The decision of whether or not to use telemetry and/or an online
computer should be based upon a cost-benefit type of analysis. There are
really two separate situations which must be considered. First of all,
the need to have immediate access to air quality data for the emergency
action plan must be evaluated. The additional cost of the system may
be quite small compared to the cost due to failure to react quickly in
averting an episode. Secondly, it is possible that the use of telemetry
may so reduce the cost of personnel required to attend the sampling
station as to warrant the additional cost of the system.
150
-------
8.0 LABORATORY QUALITY ASSURANCE PROGRAM
8.1 Introduction
Since air pollution control relies heavily on laboratory support, a
real need exists to maintain and document a high level of analytical
quality. In the laboratory the quality of the data produced depends on
three key considerations: (a) the methodology selected, (b) the reagents,
standards, and instruments used, and (c) the operational techniques
42
employed. High quality can be assured, even before the analytical
operations are undertaken. Quality assurance begins when the methodology
obtains a valid measure of the analytical parameter, when the laboratory
tools (reagents, instruments, standards) are of invariant quality, and
when the operational techniques insure exacting replication for the
entire analytical procedure.
The establishment of quality assurance programs and procedures
applicable to the air pollution control (ARC) laboratory requires a
concerted effort from each of the elements or levels that make up the
"national" ARC laboratory system, i.e., the Federal sector, such as the
National Environmental Research Centers (NERC) and the National Bureau
of Standards (NBS), professional associations, State ARC laboratories,
local ARC laboratories, and the private laboratory participating in the
ARC field. Each of these laboratory elements has a part in the develop-
ment and utilization of an acceptable laboratory quality assurance
program. The implementation of a quality assurance program is dependent
on the State and local laboratory managers.
A comprehensive quality assurance program strives to reach,
maintain, and assess an acceptable target level of reliability. The
151
-------
development of such a program for the air pollution control laboratory
includes several components: (a) uniformity of methodology—methods
development, methods standardization (reference methods, equivalent
methods); (b) internal laboratory quality control; and (c) interlabora-
tory testing—collaborative method evaluation studies and round-robin
performance evaluation studies. Laboratory accreditation procedures--
inspection, proficiency testing, and certification—are expected to
follow for an on-going quality assurance program.
Not all of these components are the purview of the State ARC
laboratory. Methods standardization belongs to EPA's Office of Research
and Monitoring and the NERC's, to the National Bureau of Standards, and
to certain professional associations and committees. Laboratory
accreditation, although presently nonexistent, may be implemented
through the EPA Regional Offices. The State APC laboratory will have
prime concern for internal laboratory quality control and for partici-
pation in interlaboratory quality performance studies.
A viable quality assurance program for the air pollution control
laboratory must be based on a framework for uniformity in methodology.
The development of sampling-analysis techniques and instrumental
applications in the air pollution field is continually progressing.
For the most part, standard methods are still under development through
the sponsorship of Government, interagency committees, professional
associations, and industry-sponsored organizations. Until the standard
methods are so designated, the prevailing methods of sampling and
analysis will probably be those for which a large amount of data is
already available.
152
-------
Several recent publications refer to the various types of existing
and proposed air pollutant reference methods and method
29 36 43-45
classifications. ' ' Recommended reference methods for the six
pollutants, for which primary and secondary standards have been
promulgated, have been designated by the Environmental Protection
43
Agency. Alternative methods may be used in place of certain reference
methods if deemed "equivalent" to the reference,,method. Guidelines for
the determination of the equivalence of candidate methods should be
determined by the NERC's.
Laboratory quality assurance begins with the basic daily and routine
operations in the laboratory. Quality control in analytical work
involves the many aspects of administration, personnel training, pro-
curement of materials and supplies, inspections and checks, and statis-
tical calculations. Quality control procedures are designed to remove
all unnecessary and controllable sources of variation in method or
46
technique. Thus, analytical procedures are defined in terms of proper
conditions or standard operating procedures. Statistical quality
control techniques can be used to detect the presence of assignable
causes of variation. In sampling and analysis work, basic quality
control techniques are calibration to assure accuracy, control samples
to determine calibration drift, replication to measure precision,
"spiking" to estimate accuracy, and the use of curve-fitting techniques
when indicated in the method write-up to provide verification of
precision and accuracy.
A laboratory quality assurance program may well include the
following areas: evaluation of the present state of the art in
153
-------
methodology; evaluation of equipment; evaluation of expected ranges of
normal analytical results; evaluation of methods; selection of methods;
setting up quality control charts; setting up appropriate procedures
and data sheets for the control of samples; and evaluation of the results
of the quality control measures.
8.2 Importance of Laboratory Quality Control
As discussed in Chapters 1 and 3, the role of the technical services
function in a statewide air pollution control program emcompasses both
field and laboratory operations related to source surveillance, ambient
air quality data acquisition, episode criteria monitoring, and a variety
of special studies. The function of the technical services group is
to provide qualitative and quantitative data to be used at all levels
of decisionmaking. Consequently, the air sample procured must be
adequately representative of the pollutant source or atmosphere sampled.
In addition, the analysis of the sample, carried out in the field or
in the laboratory, by automatic instrumentation or by wet chemical means,
must provide data that accurately describe the characteristics or the
concentration of constituents in the sample. In many instances, an
incorrect result will lead to faulty interpretations that may be worse
than no result at all.
Far-reaching decisions will be made using air quality and emission
data as evidence. The laboratory data will be used to determine whether
or not standards are being met. If the results indicate a violation
of a standard, action is required on the part of the air pollution
control agency. With the current emphasis on legal action and social
pressures to abate pollution, the technical services group personnel
154
-------
should be made aware of their responsibility to provide results that
are a reliable description of the sample. In addition, the analyst
should know that his professional competence, the procedures used, and
the reported values may be used and challenged in court. To meet this
challenge, the laboratory data must be backed up by an adequate program
to document the proper control of all the factors that affect the final
result.
The economic implications alone in source testing are sufficient
reason for the exercise of extreme care in sampling and analysis.
Decisions on process changes, control device installation, and even the
construction of new facilities are often based on the results of
laboratory analyses.
Special projects and short-range development studies in air
pollution control must fall back on a firm base of laboratory data.
The value of the development effort will depend on the validity of the
laboratory results. The progress of the special study and the alterna-
tive experimental pathways are especially evaluated on the basis of
accumulated data; the final results and recommendations are presented
in numerical terms, i.e., data averages, standard deviations, and
confidence limits.
For such reasons as the foregoing, a formal program to assess and
document the reliability of the analytical data is essential. Although
chemists and technicians practice their own personal quality control,
they do so at varying levels and degrees of proficiency, depending on
such factors as professional integrity, background and training, and
understanding or awareness of the scope and importance of the work they
155
-------
are engaged in. Because of the routine nature of the normal workload
and under the pressures of periodic high priority "rush" projects,
analytical quality control is easy to neglect. Thus, in order to assure
validity and reliability in the final results, it is important to
require an established routine control program for eyery_ sampling
procedure and analytical test.
The quality control program in the laboratory has two major
functions: first, the program should be a management tool to monitor
the reliability of the results produced in real time; and second, the
program should control the analytical quality in order to meet the
requirements for reliability. This first function is the measurement
of the analytical performance of the laboratory. The second function
is the multitude of control measures required to maintain or improve
a given level of analytical performance. For example, the sampling,
processing, and analysis of standard or reference samples is a measure-
ment of analytical quality; the use of precision glassware, reagent
grade chemicals, and optimized instrumentation are control measures to
insure analytical quality.
Sampling procedures, operation of automatic and manual instrumenta-
tion, and classical analytical methods all utilize a standard protocol
or a rigid standard operating procedure (SOP). Likewise, the quality
control associated with each protocol should involve definite, required
steps to monitor and assure that the data and results are correct.
Quality control aspects vary with the type of sampling-analysis
scheme. For instance, in a gravimetric analysis, calibration of the
analytical balance with standard weights is an element of quality
156
-------
control. In a titration, frequent standardization of the titrant is an
element of quality control. When employing an instrumental method, the
check-out of instrument response and the calibration of the instrument
is likewise an element of quality control.
Ideally, a quality assurance program should consider and evaluate
all the variables that significantly influence the final analytical
result and should provide for the control of thes*e factors in order to
insure the best possible result. In the air pollution control labora-
tory, the laboratory quality assurance program should aim at the
fourfold objectives: (a) to assure the representative nature of the
sampled material, (b) to achieve a high level of reliability in the
analytical characteristics reported for the sample, (c) to provide
real-time management tools for the laboratory supervisor, and (d) to
produce quality control data to document the context of the sample data.
8.3 Proposed Laboratory Quality Assurance Program
Development and operation of an integrated statewide air pollution
control technical services system are the direct responsibilities of the
State air pollution control agency. State agencies will rely somewhat on
the EPA's Regional Offices and National Air Program Laboratories for
guidance and assistance. At the same time, the cooperating local air
pollution agencies, while serving their own county or municipal
jurisdictions, are essential parts or extensions of the State's technical
services function.
A laboratory quality assurance program within the statewide air
pollution control laboratory system is likewise the direct responsibility
of the State air pollution control agency. In addition, the Federal
157
-------
agency can and must provide guidance and technical assistance in this
area. The local agencies within the State program should be required
to meet a set of quality control standards in order to continue as
effective parts of the State laboratory system.
8.3.1 Federal Agency Role in Quality Assurance
EPA will continue to develop, evaluate, and publish air pollution
methodology via its own laboratories as well as in cooperation with
outside organizations. In its role as overseer and advisor to the State
laboratory programs, the following are areas in which the Federal agency
can provide valuable guidance and/or assistance to the statewide
laboratory quality assurance program.
8.3.1.1 Uniformity of Methodology
8.3.1.1.1 Method Development. With its comprehensive resources
and laboratory capabilities in the air pollution control area, the
Federal agency is the logical source of new analytical and sampling
methods. The need for new methods or method modification may be
dictated in part by the quality of the data generated in the measurement
of currently defined (by criteria) pollutants. Additional methods will
be required for the publication of criteria documents for new pollutants.
8.3.1.1.2 Method Evaluation. The Federal agency will continue to
determine the precision and accuracy of new methods through its collabora-
tive testing program. These tests represent the measurement of the best
multiple performance characteristics of the method under ideal conditions.
In many cases, the analysts participating in the method evaluation study
are highly trained specialists or experienced analytical chemists working
in research institutes, universities, and private consulting
158
-------
laboratories.47'49 it is expected, therefore, that as methods are
later adopted for use by the State programs, it may be necessary to
determine the precision and accuracy, not of the method, but of the
application of the method under routine operating conditions, using the
analysts and the laboratories that make up the State laboratory system.
In general, the NERC's will standardize the methods and determine
their optimal characteristics; the State laboratories should use the
meth'ods, document their quality control data, and attempt to reach
the same level of performance as attained by the NERC laboratories.
8.3.1.1.3 Method Publication. The Federal agency will participate
in and help to coordinate all the on-going method standardization
activities that are relevant to a statewide laboratory quality
assurance program. The reference methods will continue to be published
and guidelines for the determination of "equivalent" methods will be
made available to all State laboratory programs on a uniform basis.
8.3.1.2 Technical Assistance
8.3.1.2.1 Training. The Federal agency may develop a prototype
training course covering the various elements of a laboratory quality
assurance program. This course could be given to representatives of
selected State air pollution laboratories in order to refine and revise
the course content. Any acceptable training course would be made
available to all State air pollution agencies.
8.3.1.2.2 Regional Office Coordination. Each of the EPA Regional
Offices has staff members who are concerned with providing technical
assistance to State agencies in setting up and maintaining a laboratory
quality assurance program. This office, for example, could provide
159
-------
assistance to State agencies that are interested in entering into
interstate cooperative agreements in sharing the burden of various
laboratory quality assurance program elements.
8.3.2 State Agency Role in Quality Assurance
Chapter 3 describes each of the individual functional elements of a
statewide air pollution control technical services group: air quality,
monitoring, surveillance monitoring, emergency monitoring, and a variety
of support activities. The purpose of a laboratory quality assurance
program is to insure that quality control is an integral part of every
laboratory operation. The primary State agency objective in this regard
is to require uniform and routine acceptance of program elements by
State and local laboratories.
The role of the State agency in quality assurance is fivefold: to
survey and characterize the laboratory quality control practices of all
air pollution agencies within the State; to provide training in quality
control to all State and local agency laboratories; to conduct on-site
inspections of each agency's technical services facilities on both a
set, periodic basis as well as a random, unexpected basis; to set up
and operate a statewide laboratory proficiency testing system; and to
design and coordinate a statewide inter!aboratory collaborative testing
mechanism. To do its job well in inter!aboratory testing, the State
agency's central or coordinating laboratory must have good, internal
quality control performance.
8.3.2.1 Statewide Survey of Air Pollution Laboratories. Before
introducing a laboratory quality assurance program to each of the regional
and local agency laboratories, the State agency must first determine
160
-------
the status of the technical service or laboratory function in each
agency. A survey form could be developed to elicit the following
information from each agency laboratory: type of samples taken or
received; components and/or conditions measured; complete listing and
brief description of laboratory apparatus available; description of
sampling apparatus, sample containers, sample preservatives, sample
collection methods, and sample transfer and labeling procedures;
recordkeeping and data handling methods; descrip't'ion of the laboratory,
laboratory organization, and laboratory staff; and a description of
quality control measures taken and procedures used.
8.3.2.2 Quality Control Training. Just as the Federal agency
provides technical assistance and training opportunities to the State
agency, the State agency in turn must assist and train local agency
laboratory personnel in the elements of analytical and statistical
quality control. The development of a formal training course in quality
control given at the State level and made available to representatives
of the local agency laboratories could be based on the Federal labora-
tory quality assurance training program. On-the-job training could be
provided as part of the State's annual inspection of laboratories.
i
8.3.2.3 On-site Inspection. The State air pollution control
agency might conduct an inspection of every air pollution control
laboratory facility within the State at least annually and should
periodically spot check laboratory facilities on a random basis.
Although the inspection is aimed primarily at assessment of the
laboratory's quality control program, general information in such areas
as safety, personnel, housekeeping, and recordkeeping will also be
161
-------
acquired.
Inspection forms should be so designed that each checklist item
can be scored on a yes/no, met/not met/exceeds, or numerical rating
system. It is important to tie in the individual item scores with an
overall inspection rating system so that the inspection team has three
alternative recommendations: approval, denial, or reinspection required.
In this way, the inspection system could be used along with proficiency
testing for evaluation within an eventual Federal agency laboratory
accreditation system.
8.3.2.4 Proficiency Testing. Proficiency testing is a useful
tool in assessing the competency of laboratory staff and the adequacy
and quality of facilities, equipment, reagents, working conditions,
and procedures. Proficiency testing may be carried on during on-site
inspections (in the field and at the bench) or by submittal of "blind"
test samples (with known values) to the laboratory for routine
examination using regularly assigned personnel and procedures. On-site
proficiency testing of ambient sampling operations can be accomplished
by splitting the sample stream and conducting side-by-side sampling in
the field along with a reference sampling team. Subsequent "spiking"
of the sample stream would allow accuracy as well as precision
comparisons between the sampling teams. There are, however, inherent
problems with the spiking technique, e.g., the spiked ingredient may
sometimes react undetected with a constituent^) of the ambient air
sample.
A determination of proficiency in the analytical phases of the
laboratory operations can sometimes be distinguished from overall
162
-------
proficiency testing (i.e., sampling and analysis) by using aqueous
samples that simulate atmospheric samples collected in liquid media.
8.3.2.5 Collaborative Surveys. Collaborative survey of air
pollution measurement methods at the State and local agency or working
level gives the "real world" reliability of the method evaluated. The
State agency laboratory coordinates the interlaboratory collaborative
test program. The local agency laboratories are the so-called
cooperating or participating laboratories. Section 8.3.5 describes the
makeup and operation of a statewide interlaboratory quality control
system.
8.3.3 Local Agency Role in Quality Assurance
Local air pollution control agency laboratories are extensions of
the State's technical services function. The local agency laboratory
has two major responsibilities in quality assurance: to initiate and
maintain internal laboratory quality control and to participate in the
statewide interlaboratory quality control program. Once the local
agency undertakes the fulfillment of these responsibilities at a high
performance level, the other parts of the laboratory standardization
program will fall into place. The laboratory will pass inspections,
will use the recommended methods, and will maintain its accreditation
status.
8.3.4 Internal Laboratory Control of Analytical Performance
A laboratory quality assurance program is contingent on the overall
day-to-day operation of the laboratory itself. Does the laboratory use
reference methods or their equivalent? Does the laboratory have a
check system on its sampling procedures, e.g., maintenance/performance
163
-------
check lists, adequate supplies, etc.? Does the laboratory take adequate
measures to preserve sample integrity? Does the laboratory control and
assess its analytical processes—calibration, replication, and mathe-
matical evaluation of data? Does the laboratory have a way of monitor-
ing the performance of instrumentation? Is the laboratory committed to
the need for quality control—the need for making quality control an
inherent part of each laboratory function, the need for allocating funds
and manpower to a quality control "overhead" category on the order of
10 percent of its overall effort? This section stresses the importance
of each of these quality control areas for the air pollution control
laboratory.
Quality control begins with the collection of the sample and should
50 51
not end until the resultant data are reported. ' Sections 8.3.4.1,
8.3.4.2, and 8.3.4.3 will deal mainly with control of daily performance
in the laboratory itself; Section 8.3.4.4 will be devoted primarily to
the control of instrument performance, both sampling and analytical
instrumentation systems. Section 8.3.4.5 will discuss the more mundane
support service requirements of an air pollution control laboratory.
Section 8.3.4.6 will rate commonly used air sampling and analytical
operations by degree of complexity. The ski 11-time rating will indicate
the level of technical or professional personnel required as well as
the manpower requirements related to quality control.
8.3.4.1 Precision and Accuracy. Evaluation of daily performance
in the laboratory is essential to document the fact that valid data are
being produced and to permit real-time correction of troubles. The
quality assurance program requires routine surveillance of the
164
-------
reproducibility or precision and the correctness or accuracy of the
measurements.
Systematic (or determinate) errors affect the accuracy of the
method because they bias the results. Indeterminate error types affect
the precision of the method because they produce random fluctuations
in the data. For results to be accurate, the analysis used must give
values close to the true values. Precision is the degree of agreement
among results obtained by repeated measurements on a single sample
under a given set of conditions.
8.3.4.1.1 Determinate Error. A determinate error is one that
can be avoided or one for which corrections can be made after the
magnitude of the error is determined. Determinate errors may be either
constant or inconstant. Constant errors are of the same sign and
magnitude, and cause inaccurate results. A buret missing a graduation
is an example. Inconstant errors, such as the expansion and contraction
of volumetric glassware with temperature, are known errors which can be
corrected for but may vary in size and sign.
The sources of determinate errors are method, personal, and
instrumental errors. Method errors are inherent in the procedure and
are usually, but not always, very serious and the hardest to detect and
correct. A common method error is the presence of interfering substances
in the sample. To minimize or at least standardize these errors,
reference or equivalent methods are recommended. Personal errors are
attributable to individual mistakes that are made consistently by an
analyst, such as continual carelessness, lack of knowledge, or personal
bias. Examples are errors in calculations, use of bad reagents, and
165
-------
poor calibration of standards or instruments. Instrumental errors are
caused by an analytical instrument or by the effects of the environment
acting on the instrument. Incorrectly labeled volumetric glassware,
fluctuating environment temperatures, pickup or "stray" electrical
impulses by a spectrophotometer are examples.
The effects of a determinate error may be additive (i.e., the
error is constant regardless of the amount of analytically sought
constituent in the sample), proportional to the theoretical value, or
it may vary with a measurable parameter. Determinate errors can
usually be detected by using spiked samples or standard reference
materials and obtaining the quantitation of bias by measuring the
deviation from the known value. The detection of determinate errors in
unknown samples is accomplished by analyzing for the desired constituent
by two or more methods that are entirely different in principle,
although this may lead to different results from each method, none of
which may be correct. Determinate errors can be kept under control
if reference or equivalent methods are used intelligently.
Tact should be employed in dealing with personal error. The
importance of quality control should be stressed without making the
analyst feel that he is being monitored or policed. The quality control
program should aim at overall confidence in results; great care must be
used to avoid producing a "nonconfidence" attitude in a technician.
For method and instrumental error, blanks can be used to correct
for interferences for reagents, sample color, etc. Correction factors,
such as extraction recovery factors and chemical yield values in
gravimetric analysis, can also be used to eliminate determinate errors.
166
-------
Sample interferences can be overcome with the standard addition technique
by adding equal amounts of unknown sample to a series of standards and
determining the concentration of the unknown graphically from a plot of
the measured quantity versus the standard concentration. Another
approach is to prepare the standard so that its composition resembles
that of the sample as closely as possible although this is very
difficult for air pollutant samples. The objective of this standard
compensation approach is the same as that of the standard addition
approach, i.e., to compensate for the presence of interfering substances
in the unknown. A well-written analytical method will specify procedures
such as these to correct for instrument and method error.
8.3.4.1.2 Indeterminate Error. Even if all determinate errors are
eliminated, every replicate analysis will not give the same value. Such
variation in results is due to indeterminate error, also called random
error. Random error affects the precision or agreement among results
and is due to unassignable or chance causes. Since the causes of
random error are indeterminate, the statistical measures of precision
are used to quantify these errors. Three methods of reporting random
error are used: the determination of the range of replicate results,
the calculation of standard deviation on the same or different samples,
52-55
and the calculation of the coefficient of variation.
8.3.4.2 Analytical Variability. Statistical measures are needed
to express the variability to be expected from an analytical procedure.
An analytical procedure is considered reliable if the results are
accurate and precise. Several factors determine the reliability of the
procedure. When the results of a procedure do not deviate from the
167
-------
known value more than that explainable by the procedure's precision, the
procedure is considered accurate. Precision for a procedure involves
the variability of the procedure under well-controlled conditions.
There are various types of precision. Designation of the context in
which precision is used is absolutely necessary for meaningful interpre-
tation. When the conditions involve a single analyst's results, the
precision is termed repeatability. The precision of inter!aboratory
results is often referred to as reproducibility.
Considerable choice exists among the appropriate techniques for
measuring precision and accuracy of a method. The conditions under
which the laboratory procedure are expected to function will help
dictate the classes of variability to be included in an evaluation
(e.g., different analysts, instruments, reagents, and laboratories).
8.3.4.2.1 Evaluation of Precision. A reliable method will give
results that are predictable within consistent and acceptable limits.
These limits will define a band within which results can be expected to
fall with calculated probability. A simple way to display and summarize
the measures of performance is the control chart. The control chart
presents data graphically so that the acceptability of variability
developing with time can be seen at a glance.
For example, the analyst might complete a number of duplicate
determinations on a few typical samples. The expected standard
deviation might be used as a measure of acceptability of observed
precision. The control chart technique offers a simple and reliable
way of summarizing results to permit convenient and quick judgment of
on-going performance. The technique may also be routinely applied to
168
-------
control sample results in real time.
Many analytical procedures are deliberately designed to make use
57
of a linear calibration curve. The proper evaluation of precision
in such procedures includes an investigation of the components that
contribute to the overall error: replication error, scatter about the
calibration line, and the uncertainty of the calibration line itself.
Many laboratories use duplicate or replic.ate analyses as a routine
quality control procedure. The adoption of the procedure using statis-
tical quality control techniques provides a realistic measure of the
precision of the analytical procedure. In a typical program, analytical
determinations are made on all samples. About 10 percent of these
samples are selected randomly for resubmission as a "blind" replication.
By comparing the observed value with the calculated theoretical error,
it can be determined whether or not the analytical procedure is
operating in a state of control, i.e., that the observed values are
reproducible within a defined range.
8.3.4.2.2 Evaluation of Sensitivity. Analytical sensitivity is
concerned with two problems: the minimum change in true concentration
that can be detected, and the minimum detectable concentration. The
former problem is the concept of resolution which applies to instruments
[TO
as well as manual operations. In spectral methods, resolution is of
extreme importance when working with multicomponent mixtures.
Replication studies are necessary in determining resolution.
Often the analyst can choose a method with a working range that
will accomodate the concentration levels to be measured. At other times
he must stretch the ultimate capability of the method in order to detect
169
-------
lower and lower values. The National Bureau of Standards has defined a
minimum detectable activity (MDA) in terms of the normal variation of
the background. The MDA would be that amount of the substance that
is different from the blank by three times the standard deviation of
the blank. The standard deviation of the blank would have to be
evaluated by a series of replicate determinations of the blank value.
A linear calibration line can be fitted to a set of data by
application of the least squares method.57 The a^or y-intercept provides
a measure of the blank correction of the procedure. The determined
value of a_ and its standard deviation, calculated by the least squares
fitting process, provide another means of determining the lower limit of
detection or MDA of a procedure.
8.3.4.2.3 Evaluation of Accuracy. Another factor that can affect
a procedure or instrument is its linearity. Linearity is a measure of
the agreement between the best fit line and the true results. Linearity
is generally used as an instrumental performance specification but can
be also applied to a procedure. Therefore, linearity is defined as the
maximum deviation between an actual instrument reading and the reading
predicted by a straight line drawn between the upper and lower calibra-
tion points. Accuracy then is determined by the combined errors due to
the uncertainties of precision, resolution, and linearity. '
To evaluate and control long-term accuracy, the control chart
technique provides a very effective technique. The within-sets
variability (or range) provides a measure of precision. Any change,
either gradually or suddenly, in average value over a period of time
would indicate problems regarding accuracy.
170
-------
8.3.4.3 Evaluation of Analytical Performance. After valid
precision and accuracy data on the method and the analyst are made
available, systematic daily checks to insure that valid data are
consistently being generated should be initiated. For colorimetric
analysis, the original standard curve must be verified. (The
instrument's filter should be checked quarterly.) Next, at least two
standards (a high and a low) should be analyzed daily along with a
blank to determine that comparable conditions exist. If the data
indicate that the conditions are out of control, tha analyst must
troubleshoot the system to find and correct the problem. For gravimetric
analysis, the balance should be verified with standard weights prior to
weighing.
In order to document the reproducibility or precision of the method,
replicate samples are required. Frequency of replicate analyses is
dependent on the original precision of the method, the reliability of
the instrumentation involved, and the experience of the analyst. The
variance of the replicate analyses is calculated and compared with the
estimate of variance for the method. A statistical procedure for
determining the significance of the difference between the two variance
estimates is the f_ ratio test,1 If the value of £ exceeds a certain
value, the system is not under control and the analytical results are
subject to question.
One procedure for maintaining acceptable precision of analytical
results is to run a duplicate analysts on each, set of samples sent to
the laboratory. For each set of duplicate analyses, one computes the
variance from;
171
-------
2 _ (X, X,)2
where:
2
-------
large variance, the analyst would terminate routine analyses and
determine the source of error in the procedure.
Quality assurance requires documentation as to the extent to
which the method actually measures the content of the sample (i.e.,
accuracy of the method). Although it is by far preferable to have
obtained values that check with known or actual values, it should be
recognized that inaccuracy does not destroy the.value of data if the
degree and precision of the error is known and taken into account. In
order to account for background contamination and/or sample interfer-
ences, and as a matter of routine practice, spiked samples should be
used in addition to standards.
A convenient way of recording the obtained precision and accuracy
data is through the preparation of quality control charts. Plotting of
the data determines, in a systematic way, whether the laboratory analyses
are "in control" and whether trends of positive or negative bias are
developing.
When the analytical procedure is appropriate, a known standard is
routinely analyzed to insure the accuracy of the results. An acceptable
procedure is to run a standard prior to the actual analysis of each lot
of samples sent to the laboratory. In addition, if more than 10
individual analyses (i.e., duplicates on five samples) are made, 10 per-
cent of all the individual analyses are run on standards.
Using an estimate of the method variability (i.e., standard
deviation) obtained from the literature, or determined by repeated
duplicate analyses run in one's laboratory, control charts are prepared
(Fig. 20). Each time (t) the analyst runs a standard, the result is
173
-------
entered on the control chart. If the analytical procedure is in control,
the estimate of the standard should lie within ± 2a (standard deviation).
Furthermore, the results should be random and tend to fall above and
below the true value for the standard. (Fig. 20; left side). If an
individual analysis of the standard falls outside the 2o limits, the
analyst is required to repeat the analysis of the standard. Should
this second result also fall outside the 2o limits, the laboratory
supervisor must determine the cause of the discrepancy and make the
necessary corrections in procedure or technique.
The control chart also provides a means of detecting bias in the
results. Evidence of bias is obvious when the individual analyses of
the standard all tend to be above (or below) the true value, or begin
to show a definite trend in the amount of departure from the true value
of the standard (Fig. 20; right side). When this situation occurs, the
analyst is instructed to notify the laboratory supervisor even before
the 2o limit is exceeded. Again, routine sample analysis is not
continued until the source of bias has been identified and corrected.
A different view of a particular laboratory's performance can be
provided by participation in inter!aboratory studies. In these
cooperative programs, the study samples are treated as part of the
regular sample load. Such samples can be regarded as "blind" samples,
a very necessary requirement in the quality control of laboratory
results. By participating in inter!aboratory studies, the analyst is
able to compare his individual performance against the personnel from
other laboratories. It should be pointed out that these "round-robin"
studies are not the same type as those conducted as part of a methods
174
-------
+3o
+ 20
STANDARD
-10
-2o
-3a
TRUE
VALUE
TIME OF SUCCESSIVE ANALYSES
Figure 20. Control chart for analysis of standard.
development program to assess a particular method's capabilities (see
Section 8.3.5).
8.3.4.3.1 Control Chart Techniques. One of the most generally
used and easily applied qualify assurance techniques is the use of
quality control charts.56'61"64 As presented in Figs. 20 and 21, a
control chart is a graph with the vertical scale plotted in units of
time or sequence of results. The combined use of spiked samples and
control charts is an efficient means of keeping routine analyses in
control. The control limit is usually set at ± 2a (standard
deviations).56 Statistically, only 3 in 1000 tests on a spiked sample
fall outside this range.
175
-------
300
CO
LU
o:
CO
250
200
150
100
UPPER CONTROL LIMIT
LOWER CONTROL LIMIT
_* +•
456
SAMPLE NUMBER
10
Figure 21. Control chart-
The upper and lower control limits indicate when remedial action
is necessary by tagging the significance of variations between replicate
samples. The central line represents the average or the standard value
of the statistical measure being plotted. Data on both precision and
accuracy can be displayed on quality control charts to determine the
validity of data betng generated on a day-to-day basis.
Although the construction of the control chart can be begun as
soon as data are available, at least 10 sets of duplicate or spiked
176
-------
sample data from an in-control method are necessary for meaningful
evaluation. A method system is in control when the standard deviation
and recovery efficiency data from a given parameter are comparable to
those obtained under normal laboratory operation conditions by other
recognized, experienced laboratories.
There are several techniques available for constructing quality
control charts and plotting the subsequent data: Two popular
techniques are the Shewhart Technique ' and the Cu Sum
technique. In using either of the two techniques, precision control
charts are constructed from replicate sample analyses, whereas accuracy
control charts are constructed from recovery efficiencies using spiked
samples or standard samples.
8.3.4.4 Instrumental Quality Control. The modern air pollution
control program depends very much upon instrumentation, from the
automatic sampler to the computer. Analytical instrumentation is
continually developing, with manufacturers redesigning and improving
their products, and with increasing miniaturization, durability,
sensitivity, and automation. With the wide-ranging selection of avail-
able equipment on the market, the laboratory supervisor and his staff
have the difficult task of selecting the most appropriate instrumentation
for their needs. Price is only one consideration in purchasing
analytical equipment. Ease of operation and maintenance should also
be determining factors in the final selection of equipment. Table 15
lists the instruments used tn the field and on the bench for ambient
air pollution sampling and analysis. The list includes basic equipment
used in routine work as well as specialized instrumentation that might
177
-------
Table 15. INSTRUMENTS USED IN THE
AIR POLLUTION CONTROL PROGRAM
Manual Laboratory Equipment or Methodology
Analytical balance
pH meter (potentiometer)
Mi croscope
Oscilloscope
Voltmeter
Spectrophotometers
Visible
Ultraviolet
Infrared
Atomic absorption
Gas chromatography
Liquid chromatography (paper, thin layer)
Temperature measurement
Special methods
Carbon-hydrogen combustion analysis
Emission spectroscopy
Electron microscopy
Neutron activation
Specific ion electrodes
X-ray diffraction
Mass spectrometry
X-ray fluorescence
Fluorescence-phosphorescence
Automatic Laboratory Equipment
Colorimeters (e.g., Technicon Auto Analyzer R)
Continuous flame ionization detectors (FID)
Recorders
Calculators (programable)
Computer (desk top)
—continued
178
-------
Table 15 (continued). INSTRUMENTS USED IN THE
AIR POLLUTION CONTROL PROGRAM
Manual Air Monitoring Equipment
Hi-Vol sampler
Gas sampler (24-hour)
Spot tape sampler
Membrane filter sampler
Automatic Air Monitoring Equipment
Continuous soiling index (automatic tape)
Nephelometer
Mass monitor
S02 gas detectors
Colon" me trie
Coulometric
Flame photometric
Electrochemical
Conductimetric
N02-N0 detectors
Colorimetric
Coulometric
Electrochemical
Chemiluminescence
Oxidant detectors
Colorimetric
Coulometric
Chemiluminescence
UV absorption
Carbon monoxide detectors
Nondispersive infrared
UV mercury displacement
Gas chromatography
Hydrocarbon detectors
Flame ionization
Infrared
Gas chromatography
179
-------
be needed on occasion. Proper operation and maintenance of each of
these devices is a primary consideration in the production of satis-
factory data.
Table 16 is a tabulation of selected air pollution laboratory
instrumentation and the various parameters that affect their performance
and quality control, such as instrument design and instrumental weak-
nesses. A fundamental understanding of instrument design will assist
the analyst in the correct use of the equipment and, in some cases, will
aid in detecting instrumental failures.
Table 16. INSTRUMENTAL QUALITY CONTROL
Instrument type
Quality control parameter References
Analytical balance
Spectrophotometer
UV, IR, Visible
Turbidimeter
Atomic absorption
Gas chromatograph
Ion selective
electrodes
Calorimeter (Bomb)
Particle classifier
Particle mass
monitor
Microscope
Other laboratory
instruments
Automatic air
monitors
Source sampling
equi pment
Use and maintenance cali-
bration, performance
evaluation A, 65
Instrument specifications 66-68
Operation & maintenance 3,69
Design and operation 22,70
Theory & methodology 71-73
Theory & application 74,75
Theory & application 76
Theory & application 77
Theory & application 78
Theory & application 79
Operation & application 80-82
Theory & application 67,68
Calibration & maintenance A
Operation & maintenance 2,3
Procedures & errors 22,83,84
A - Use the instrument instruction manual.
180
-------
8.3.4.5 Ancillary Materials Quality Control. In order to produce
'high quality analytical data, the quality control program must minimize
or eliminate determinate errors. It is not sufficient to minimize
personal, operative, and instrumental errors by insuring that the
analyst is experienced, careful, and competent and that the equipment
is reliable and in optimal operating condition. The proper selection,
preparation, and storage of reagents, solvents, and gases and the quality
»
of the glassware, air. water, and electrical services have measurable
effect on the analytical results. Special considerations and precautions
that the analyst must take in certain cases will depend largely on the
individual requirements of the specific method used. In general,
however, the laboratory must set basic, routine requirements for the
purchase, preparation, purification, calibration, and standardization of
chemical reagents, solvents, compressed gases, and glassware. The
quality control considerations for the various ancillary laboratory
services are listed with references in Table 17.
8.3.4.6 Laboratory Operations Quality Control. Laboratory
procedures will vary in terms of frequency, man-hour requirements, and
degree of complexity. Certain operations are quite complex but
s
essentially "nonmanual," such as those that are condicted in the field
with completely automatic sampling, analysis, and data recording
equipment. Sampling operations vary widely in time requirements and
complexity. Some analyses require no pretreatment or preservation
scheme. Often such samples are measured in just a few minutes using
a routine instrumental method. Other sample determinations require
very extensive sample preparation prior to complex chemical or
181
-------
Table 17. ANCILLARY SERVICES QUALITY CONTROL
Ancillary services
Chemical reagents &
solvents
Gases
Glassware
Distilled water
Compressed air
Electrical services
Quality control parameter
Reagent quality
Primary standards
Preparation, standardization,
and storage
Errors
Purity
Cleaning
Calibration
Specifications
Purity
Preparation
Purification
Purification
Voltage regulation
Reference
85
86
87
88
89
88,90
90,91
92
93
94
94-96
89
97
instrumental examination.
In addition to these "hardware-type" laboratory operations, a
related group of "soft-ware" operations are part of any technical
services function. Such operations as sample logging, data logging,
data calculations, and statistical quality control techniques range from
the self-explanatory to the more time-consuming and more complicated
manipulations.
8.3.4.6.1 Analyst Training. In each air pollution control
laboratory, work assignments should be clearly defined both, in terms of
task descriptions and personnel job descriptions. The analyst should
undergo a training program including periodic refresher courses as well
as training in new areas so that he fully understands the assignments
and requirements of his present job before taking on new or added
182
-------
responsibilities.
Besides a planned curriculum of training courses, the novice
chemist and technician should receive on-the-job training in many of
the basic laboratory operations. Examples of basic operations
requiring periodic review with the laboratory personnel are:
(a) Recorder or other readout systems. Check to see whether the
individual knows the nominal range of the scale and the
*
principles of interpolation and extrapolation.
(b) Sample log. Emphasize a routine procedure and responsibility
assignments for recording and routing of samples entering the
laboratory.
(c) Sample handling. Discuss sample transfer (field to laboratory)
procedures, sample preservation techniques, sample stability
(thermal, photochemical, biological, etc.), and recommended
storage procedures. The analyst should also be completely
familiar with the procedure for transfer of the sample from
the sampling container to the analysis vessel (e.g., pipetted-
supernatant only, pipetted after mixing, filter, pour, agitate,
heat, cool, etc.).
i
(d) Volumetric Measurement. Instruction in the use of pipettes,
burets, volumetric flasks, and similar graduated glassware.
(e) Gravimetric measurement. Instruction in the proper use of the
analytical balance, including periodic standardization and
maintenance.
(f) Glassware and equipment maintenance. Glassware must be
cleaned and rinsed in accordance with requirements of the
183
-------
analysis. Laboratory personnel should be instructed in the
proper cleanliness techniques for both routine as well as
special analyses.
(g) Data handling. Instructions in mathematical procedures,
statistical methods, control chart techniques, and use of
desk top "programmable" calculators.
Quality control is based on a firm foundation of basic laboratory
techniques. Error due to the individual analyst as well as the labora-
tory as a whole can be minimized with the consistent practice of
approved, proven techniques. It is the duty of the laboratory super-
visor to initiate and to insure the continued use of approved techniques
by periodic review and evaluation of each analyst.
8.3.4.6.2 Quality Control Costs. The cost of data production in
the analytical laboratory is based largely upon three factors: the
pay scale of the analyst, overhead, and the number of data units produced
per unit of time. However, estimates of the number of measurements that
can be made per unit of time are difficult because of the variety of
factors involved. If the analyst is pushed to produce data at a rate
beyond his capabilities, unreliable results may be produced. On the
other hand, the analyst should be under some pressure to produce a
minimum number of measurements per unit of time lest the cost of data
production become prohibitive. In order to achieve the maximum number
of reliable measurements per unit cost, it is necessary to have
operational quality control. Thus, quality control is truly an overhead
cost. The level of quality control required should be based on the
operational complexity and frequency and the final usage of the data
184
-------
produced.
In the following table (Table 18), examples of sampling and
analytical operations required of an air pollution control laboratory
are described in terms of ski 11-time-equipment requirements.98 The
operations are rated in terms of level of personnel and skill required,
the overall degree of complexity, and the number or frequency of
operations that an analyst is expected to perform on a routine basis.
The utility of such a rating system is severalfold. One very important
consideration is its usage as a basic tool in determining the quality
control requirements of the multitude of air pollution laboratory
operations.
A laboratory's quality assurance program should be an integral
part of the overall laboratory function, not a separate, add-on segment.
Each analyst and technician should continually carry out the operations
and procedures designated to measure and improve laboratory performance.
The laboratory supervisor or quality control officer will use the
quality control data as a real-time management tool to improve laboratory
performance.
Quality control does contribute a cost to the laboratory operation.
It is estimated that an operating quality assurance program requires 5
to 10 percent of the available manpower for proper implementation.
Depending on the individual laboratory's operations, the allocation of
this 5 to 10 percent of technical manpower will be distributed in
various ways. For the air poll"tion control laboratory new to the
quality assurance field and for the air pollution control laboratory
interested in assessing its existing quality assurance program, the
185
-------
Table 18. QUALITY CONTROL REQUIREMENT BASED ON SKILL-TIME-USE RATING
OF AIR POLLUTION LABORATORY OPERATIONS
(Operations selected for illustrative purposes only)
Operation
I. Intermittent
A. Sampling
1. Parti oil ate
(Hi-Vol)
2. S02 (candle)
3. Gases (bubbler)
4. Gases (integrated
bag)
5. Metals (membrane
filter)
6. Fluoride (open
tubular column)
B. Analysis
1. Parti cul ate
(gravimetric)
2. S02 (gravimetric)
3. Gases (colori-
metric)
4. Gases (gas
chromotograph)
5. Metals (atomic
absorption)
6. Fluoride (specific
ion electrode)
II. Continuous
A. Parti cul ate
1. Tape
2. Mass monitor
B. S02
1. Col or i metric
2. Coulometric
C. Oxidant
1. Colorimetric
2. Chemiluminesence
D. CO
1. NDIR
2. UV
E. Hydrocarbon
1. FID
F. NOX
1. Colorimetric
2. Coulometric
G. H2S
1. Flame Photometric
2. Coulometric
3. Colorimetric
Complexity requirements
Freq.
(a)
4*
1
5
3*
3*
3*
5
1
5
3*
5*
3*
5
5
5
5
5
5
5
5
5
5
5
5
5
5
Man.
(b)
2
2
4
4
3
3
2
2
3
4
4
1
1
2
1
2
1
4
1
1
1
1
2
3
2
1
Instr.
(c)
1
1
2
2
1
3
2
2
3
4
4
2
2
4
1
5
1
5
1
2
2
1
5
4
5
1
Skill
(d)
4*
5*
3*
3*
3*
3*
3*
3*
3*
2*
2*
3*
3
3
2
3
2
3
3
3
2
2
3
2
3
2
Equip.
(e)
3
1
3
3
1
3
4
4
4
4
4
3
4
4
3
4
3
4
4
4
3
3
4
4
4
3
Data
Util.
(f)
1 to 4
1
1 to 4
2 to 4
1 to 5
1 to 5
1 to 4
1 to 2
1 to 4
1 to 4
1 to 4
1 to 4
1 to 5
1 to 5
1 to 5
1 to 5
1 to 5
1 to 5
1 to 5
1 to 5
1 to 5
1 to 5
1 to 5
1 to 5
1 to 5
1 to 5
(QCI)
(g)
15 to 19
11
18 to 22
17 to 19
12 to 17
16 to 21
17 to 20
13 to 15
19 to 23
18 to 22
20 to 24
13 to 17
16 to 20
19 to 23
13 to 17
20 to 24
13 to 17
22 to 26
15 to 19
16 to 20
14 to 18
/
13 to 17
20 to 24
-
19 to 23
20 to 24
13 to 17
*A particular laboratory may vary in the frequency and skill categories. A
more skilled analyst lessens the external quality control requirements.
186
-------
Table 18 (continued).
Code:
(a) Frequency
1 = Monthly
2 Biweekly
3 Weekly
4 Two to six times per week
5 Daily (or continuous)
(b) Manual complexity
1 Simple; quick
2 Simple; lengthy
3 Complex; quick
4 = Complex; lengthy
5 - Very difficult
(c) Instrumental complexity
1 Simple principle; minimum downtime
2 Simple principle; periodic downtime
3 - Complex principle; minimum downtime
4 Complex principle; periodic downtime
5 Complex principle; frequent downtime
(d) Skill required (the higher the skill level, the lower the quality
control cost)
1 Senior professional or expert specialist
2 Trained professional
3 Skilled technician
4 Semiskilled personnel (sanitarian)
5 Nontechnical personnel (fireman; policeman)
(e) Equipment required
1 Low cost (e.g., dustfall)
2 Low to moderate ( e.g., spot tape sampler)
3 Moderate (e.g., HiVol, gas sampler)
4 = Moderate to high (e.g., automatic type, continuous gas monitor)
5 High (e.g., mass spectrometer)
(f) Data utilization
1 Routine ambient network
2 Special studies
3 Source surveillance (enforcement)
4 Routine alert network
5 Episode alert network
(g) Quality Control Index (QCI) equals the i a_ through £
6 to 11 Minimum 12 to 17 Low
18 to 23 Medium 24 to 30 High
187
-------
method described below is an attempt to allocate costs and distribute
quality control effort among the various operations and procedures that
make up an air pollution control laboratory program.
The air pollution control laboratory should allocate a certain
percentage of available time and resources (man-hours) to the quality
assurance program. A technical services function that budgets 10 man-
years to its laboratory program might devote 1 man-year (or 10 percent
of available manpower) to quality control. This requirement will
decrease as better analysts and more reliable methods become available.
A tabulation such as illustrated in Table 18 could be used to obtain a
further breakdown of the quality control allocation by specific tasks
or laboratory operations. Each of the individual operations conducted
by the air pollution laboratory could be assigned a rating in several
different categories; e.g., frequency of the operation, complexity,
personnel skill required, and equipment requirements. The rating
system could also incorporate a parameter that considers the utilization
and/or immediacy of the data resulting from the operation. The quality
control index (QCI) could be represented as the summation of the scores
for each of the rating parameters. After each of the laboratory
operations has been assigned a quality control index, the amount of time
or manpower to be allocated to each of the individual operations can be
calculated by multiplying the total quality control manpower allocation
by the quality control index divided by the sum of the quality control
i ndexes :
Quality Control Man-Years (Operation #1) =
Total Quality y QC Indexl
Control M-Y A
188
-------
Quality Control M-Y (Operation #2) =
QC Index-
Total QC M-Y X — ^ . (8-4)
The quality control index for a particular laboratory operation
would vary from laboratory to laboratory; each of the rating parameters
should be developed and tailored for use by the individual laboratory.
Factors such as frequency of the operation, the skill level of the
personnel used for the operatton, and the end use for the data acquired
will vary significantly wtth each laboratory.
A laboratory, for example, that monitors only particulates might
have a quality control index (QCI) of 15 for particulate sampling and
a (QCI) of 20 for particulate analysis, while devoting 1 man-year of
effort to its monitoring activity. The 0.1 man-year for quality control
would be distributed as 15/35 or 43 percent for sampling and 20/35 or
57 percent for analysis.
8.3.5 Interlaboratory Quality Control
In addition to intralaboratory control, it is also desirable to
control the quality of interlaboratory analyses. More error (both
determinate and random) is expected when analyses are performed by
different people in different laboratories. Collaborative testing can
be conducted to evaluate and control interlaboratory error. The
careful design and preparation of the sample is the responsibility of
99
the coordinating or lead laboratory.
The results can be plotted on a control chart or ranked according
QQ
to the Youden method. Statistical methods can be used to evaluate
those laboratories that are out of control.
189
-------
8.3.5.1 Types of Inter!aboratory Studies. Collaborative testing
between groups of laboratories are conducted for at least three different
purposes: (1) selection of analytical methods, (2) evaluation of
analytical methods, and (3) evaluation of laboratory and analyst per-
formance. The first two purposes are part of methods standardization,
which determines the accuracy, precision, and bias of a method. The
third purpose is part of methods quality control, which determines how
well various laboratories are using the methods.
Methods standardization in the air pollution control field is the
responsibility of the Federal Environmental Protection Agency.
Collaborative testing of the various methods used in air pollution
control is an important part of the Federal EPA laboratory standardiza-
tion program. ' Inter!aboratory studies are necessary to obtain
the accuracy and precision of the selected methods used by the
participating laboratories. The evaluation of study results also permits
a judgment of the relative capabilities of these laboratories performing
the sampling and analysis schemes. '
8.3.5.2 Federal Collaborative Test Program. In defining an
interlaboratory method study, it may be well to explain what it is not.
It is not an evaluation of reagents, or of materials, or of different
test conditions. It is not an initial study of a method nor is it a
study to develop a method. An interlaboratory study, in fact, must come
after each of these tasks and often depends on their completion. An
interlaboratory study is a between-laboratory evaluation of the exact
physical, chemical, or biological method that yields a measurement of
desired properties. ~ ' An interlaboratory program is usually
190
-------
aimed primarily at one of three objectives: troubleshooting or
audit of the comparability of measurements, evaluation of a test method,
or extension of a measurement process from a primary laboratory to
other laboratories. Depending on the particular objective to be
emphasized in the round of tests, the approaches may be somewhat
different.
The Youden approach, for example, uses graphical analysis and
ranking score procedures that are designed to locate and identify
50 51
trouble sources. ' In addition, the Youden ruggedness test is a
procedure to check out and disclose significant influencing factors that
may change from laboratory to laboratory. The Youden emphasis is on
troubleshooting through experimental design.
Another approach offered by Mandel and Lashof aims to interpret an
established test method through a linear model. The analysis
segregates the overall variability into the replication component, the
scale or instrument calibration component, and the variability-between-
laboratories component. The emphasis of the Mandel-Lashof approach is
on the evaluation of the test method and on the quantitative estimation
of the effect of these three components.
8.3.5.2.1 General Requirements for a Method Study. Before the
State air pollution control program can be part of EPA interlaboratory
method studies, the participating laboratories must be "in control."
In most cases, this means that between-replicate deviation will be small
and uniform in all member laboratories.
Secondly, the method must be written out in detail and followed
explicitly.
191
-------
Thirdly, all laboratories and analysts must be so thoroughly
familiar with the method to be tested that any special reagents or
equipment required are recognized and made available. If, however,
all participating analysts are not acquainted with the method in
question, it is quite easy to-set up a simplified preliminary study to
accomplish this required familiarity.
Fourthly, the method to be evaluated should have been tested for
its ruggedness. The developer of the method or another qualified
analytical laboratory must determine whether or not the method will be
stable under routine analytical conditions, i.e., whether slight
variations in time, temperature, pH, reagent, sample volume, interfering
substances, etc. give rise to significant deviation effects.
8.3.5.2.2 Testing for Ruggedness. Variation among analysts and
among laboratories occurs readily due to differences in reagents used,
rate of heating employed, volumes dispensed, temperature reading errors,
and the like. After a particular method has been developed for
routine use, it is appropriate to deliberately introduce minor
deviations from the written procedure into the method and observe the
effect of these variations. If, for example, it is determined that a
method depends on seven key factors, it is possible to choose, from the
128 (or 27) different combinations of nominal and alternative values, a
subset of eight of these combinations to determine the effect of each
of the seven factors. If one or more of the factors are having an
adverse effect, their effect will be substantially larger than that due
to the sum of the other factor effects. It should be acknowledged that
errors resulting from ruggedness testing must be corrected or minimized
192
-------
before collaborative testing is begun.
8.3.5.2.3 Selection of Laboratories. To provide a statistically
valid evaluation, the participating laboratories should be representa-
tive of the ultimate users of the method. In a statewide air pollution
control program, the users of the method are the State and local agency
air pollution control laboratories. The coordinating agency could be
the EPA regional office, the State headquarters, or an interstate
cooperative. The reference or referee laboratory'would be the Federal
EPA NERC Center, the National Bureau of Standards laboratory, a
university or private institute's laboratory, or a private consulting
and testing laboratory. The reference laboratory selected must be
proved as competent in the use of the method being tested.
8.3.5.2.4 General Instructions for Methods Study. The inter-
laboratory quality control program should be a continuing element of the
air pollution control laboratory. It will change and fluctuate in level
of effort as existing methods are submitted to evaluation and new
methods are developed and compared with existing ones for sensitivity,
specificity, and reliability. As part of each method study, specific
directions should be prepared and made available to member laboratories
prior to study initiation. The .'following general instructions can be
used as a guide in these matters:
(a) Exact method writeups must be provided to each analyst. The
technical description of an analytical method is difficult
in that the language and organization must be complete, yet
unambiguous and easy to understand. Certain requirements in
a method may appear trivial. However, if they are not
193
-------
controlled, a methods study can become invalid and useless.
(b) The method must provide explicit directions for sampling,
sample preservation and storage, sample makeup and treatment,
time and other limitations, sequence of analyses, and so on.
(c) Advance notice of the methods study must be given so that
the participating laboratories can integrate the test into
their program and realistic deadlines can be established.
Scheduled deadlines for agreement to participate and for
completion of analyses and reporting must be closely adhered
to.
8.3.5.2.5 Providing Test Samples and Containers. A variety of
established and new techniques will be used to determine their role
and applicability in collaborative testing. Simulated solid, liquid,
and gaseous samples will be distributed by the coordinating laboratory
to each of the member laboratories to determine the reliability of
laboratory (or bench) sampling and analytical procedures. Simultaneous
sampling and analysis of various pollutants in the field at the same
location and time periods by representatives of each of the cooperating
laboratories will be necessary in certain method studies. Another
variation of an air pollution method study would include the simultaneous
sampling and analysis of replicates by each of the cooperating labora-
tories both in the field and, at another time, in the control laboratory.
In conducting a methods study in which the sample is either a solid
or a liquid (e.g., fuel or solvent analysis), the preparation of test
samples is not without problems. However, when the sample is gaseous,
vapor, or air-suspended particulate matter, the generation, sampling,
194
-------
and analysis of test or reference atmospheres for collaborative method
studies are still in the experimental stages. To this time, no satis-
factory particulate matter reference atmosphere has been developed.
Preparation of test samples that simulate the gaseous or particulate
pollutant, after it has been filtered out or trapped in a bubbler
solution, can be more easily accomplished. Collaborative tests based
on this type of sample evaluate only the analytical method; evaluation
of sampling methods depends on the provision of standard or reference
test atmospheres.
8.3.5.2.6 Liquid (or Solid) Reference Samples. The following
points relate to the preparation and containerization of liquid (or
solid) samples for fuel or solvent analysis or to air samples that have
collected in liquid {or solid) media:
(a) The sample should be carefully prepared so as to reflect the
composition and concentration level of the test species as it
normally occurs and yet to be within the workable portion of
the concentration range for the method.
(b) Since precision of almost all methods varies with concentration,
a comprehensive study includes several levels of concentration.
(c) Since accuracy of the Imethod is affected by interfering
substances, exactly known levels of selected constituents are
added to the samples or sampling media.
(d) In some cases, the coordinating laboratory will prepare the
samples as "concentrates," ready for final dilution and makeup
at each of the individual cooperating testing laboratories
(i.e., the local agency air pollution control laboratories).
195
-------
Advantages are the reduced space requirements and reduced
handling and transport costs. By using sealed glass ampoules,
preservation of concentrates is maximized by means of steam
sterilization. Chemical preservatives can be employed at
rather high levels in the concentrate and can be removed
later (as interferences) by dilution to the final sample
volume.
(e) An alternative to the "concentrate" method of sample prepara-
tion is to have the coordinating laboratory prepare and send
the dilute simulated samples to the local laboratories.
Such standard samples have the advantage that they reach the
analyst in the same fashion as does a routine unknown sample.
In addition, there is no dilution required so that this source
or error or variance is removed. The disadvantages are the
higher cost of sample transport, the logistics problems due
to storage of large quantities of such samples, the limited
choice of sample preservation methods, and the limitations
due to the size and composition of the sample container.
8.3.5.2.7 Provision of Test Atmospheres. A serious problem in
collaborative testing is the generation and/or selection of test
atmospheres. The ideal atmosphere is the real atmosphere with all its
interfering substances. Several kinds of approaches are currently
available to meet the requirements of interlaboratory method studies;
108
newer and different approaches may be required in some instances.
The selection of a particular sample generation procedure should receive
a considerable amount of preliminary evaluation by the coordinating
196
-------
laboratory in an attempt to define and compare the selective advantages
and disadvantages in each case. The approaches used may include the
following:
.(a) Permeation tubes. Calibrated standards can be sent to each
laboratory to be used in generating the test atmosphere. With
the recent availability of permeation tubes for sulfur dioxide,
certified by the National Bureau of Standards, the accuracy of
this method is further assured. NBS will provide similar
standards of certified composition for other pollutants in the
near future. These tubes must, however, be constantly
monitored to insure consistent permeation rates.
(b) Gas cylinders. Standard gas mixtures can be prepared in large
quantities and distributed to participants in individual
cylinders. For reactive contaminants that must be measured at
fractional-part-per-million levels, such as sulfur dioxide,
nitrogen dioxide, or ozone, this procedure cannot be used.
For nonreactive contaminants that are measured at parts-per-
million levels, such as carbon monoxide, this method has
been used when adequate precautions are taken in mixing and
49
calibration. Wall adsorption at low concentrations is a
major problem area.
(c) Bag sampler assembly. Duplicate ambient or simulated samples
of gaseous pollutants at typical atmospheric concentration
109
levels can be prepared in "bag-box" containers. The
containers are composed of Tedlar or Mylar bags enclosed in
corrugated boxes so designed t&at evacuation or pressurization
197
-------
of the box causes fining or emptying of the bag, respectively.
One of the replicates is sent to the central or referee
laboratory for analysis. The other is analyzed in the field
or within the facilities of the cooperating laboratories by
their analysts. An additional quality control measure would
include the simultaneous analysis of two replicate bag-box
samples both in the field and at the bench by the cooperating
local control laboratories.
(d) Other approaches used by the coordinating laboratory are to
use a mobile van completely equipped with the necessary
standards and calibration equipment to visit each member
laboratory on a periodic basis and to send representatives
from the coordinating laboratory to each of the participant
laboratories in order to prepare test atmospheres on a
simultaneous basis. This can be done by diluting pure gases
into a plastic bag with adequate control of volumes, tempera-
tures, and other operating conditions. If the same technique
is used for dilution of each participating laboratory, there
can be reasonable assurance that test atmospheres will be
very nearly identical throughout the group. However, suitable
precautions must be observed to avoid errors due to diffusion
of pollutant gases through the plastic, reaction on the surface
of the plastic material, or other experimental errors.
Sending a representative to each participating laboratory would
also impose serious restrictions on the scheduling of collabora-
tive tests by the participants. No single procedure will be
198
-------
satisfactory for all tests. Each method must be evaluated
before selecting the best test procedure for each collabora-
tive test series.
(e) Field tests. Instead of generating a test atmosphere, a
group of collaborators at a single location can sample a real
atmosphere if suitable concentration levels can be found to
test the method as desired. The primary, disadvantage here
is one of statistical validity. Ideally, a collaborative
test should indicate what each participant is capable of doing
in his own laboratory, not at some central location. The
results from this method more nearly indicate an internal
laboratory evaluation rather than an interlaboratory evaluation.
However, this method does distinguish the analytical differ-
ences between laboratory samples and "real" samples.
8.3.5.3 Interlaboratory Testing at the State Level. As described
throughout subsection 8.3.5.2, the statewide ARC program can participate
in the EPA collaborative testing program. Coordination of such Federal-
State laboratory method studies will take place through the EPA Regional
Offices, from whom more information can be obtained.
Some States may also choose to participate in an interlaboratory
quality control program that is not part of methods standardization.
Such a program would continually evaluate and rate the performance of
each of the cooperating State and local ARC laboratories. In certain
instances, the place of the central or coordinating agency would be
taken by the EPA Regional Office. In other cases, the Regional Office
may delegate this responsibility to the State agency or to a laboratory
serving a multistate area.
199
-------
9.0 CONTRACTING CONSIDERATIONS
The statewide air pollution control technical service group provides
technical services to the total State air pollution control program.
Since these services vary greatly in terms of frequency, manpower, and
equipment requirements, level of expertise needed, and immediacy of response
required, the technical service group may sometimes have to consider the
use of outside contractual assistance. The outside assistance may be from
another Government agency, from a university or research institute,
or from a private institutional or consulting laboratory.
The need for outside help for short-term projects occurs when
specialized equipment or personnel are required or when the increased
work load is beyond the capability of in-house resources. Examples of
this need are special studies such as a three-month sampling program
for a new pollutant, the use of a consultant meteorologist during
emergency episode conditions, and training of analysts and technicians
in a specialized technical service area.
The utilization of contractual assistance on longer term projects
is necessary when the special technical assistance, requiring nonroutine
techniques or equipment, is not available in-house. Analysis for metals
or pesticides, fuel and solvent analysis, material effects analysis,
and the analysis of odorous, nuisance, and hazardous materials are good
examples of tasks which could require outside contractual services.
The advantages of using outside contractors may include overall cost
savings and/or more immediate availability of results. In addition,
the outside laboratory adds a measure of objectivity to data and the
resultant recommendations that are used in enforcement activities.
200
-------
Disadvantages of using the contract mechanism may include the
restrictions of State procurement policies and procedures as well as
the need to devote time and manpower in keeping abreast with Federal
and State contractual guidelines and in monitoring the specific contract
for maximum acceptable performance.
To determine whether or not a particular task or study to be under-
taken by the State program should be done in-house or on contract, the
following considerations should be applied:
(a) Frequency. How often will the task be repeated?
(b) Level of Effort. How many technical operations are
conducted per unit time?
(c) Compatibility. How will the task affect the existing
program?
(d) Priority. How quickly must the results be ready?
(e) Resource Requirements. Personnel, equipment, other costs.
(f) In-house Capabilities. Current and expected.
(g) Contractor Availability. Location and key performers.
(h) Funding Availability. Current and expected.
The comparative cost between conducting a project In-house and
letting a contract can be a secondary consideration when the priority
is high and adequate funding is available. Other factors can make the
contract mechanism more suitable. The hiring of additional personnel
and/or the procurement of additional capital equipment are normally not
economically feasible for short-term, relatively infrequent tasks. In
other cases, an agency "freeze" on new hiring would postpone an in-
house project. Another consideration is the effect of a new project
on ongoing laboratory operations. Additional workload from a new
201
-------
project could adversely affect the normal output and quality control
of existing programs.
In considering cost alone, personnel additions must be looked at
in terms of the continuing program plan. Acquisition of new instrumenta-
tion and equipment involves the trade-offs between leasing or buying
compared with the costs of an outside contract. A general guideline in
this regard can be stated thusly: If the equipment acquisition costs
involved in conducting the services in-house are equivalent to the
contract cost over a 3-year period, the project should be conducted
in-house.
Table 19 lists laboratory functions that can be conducted in-house
as well as on a contract basis. The contract areas are elements of the
sampling program, of the analysis program, and of the data handling
program. In general, statewide laboratory programs can be categorized
into three major groups: existing programs with strong technical capa-
bilities, existing programs with lesser developed capabilities, and new
or imminent State programs. Table 19 rates each of the program elements
for both the central laboratory and the satellite laboratory components
of the State program as to the potential for outside contracting.
"Remote" (R) indicates that tasks are normally conducted in-house.
"Primary" (P) indicates that circumstances will very often warrant an
outside contract. "Secondary" (S) indicates that a contractual arrange-
ment will be utilized in some cases, depending largely on the requirements
of the individual laboratory.
9.1 Contract Areas
The laboratory program may require contractual services in three
areas: sampling and monitoring; analytical characterization of gaseous,
202
-------
TABLE 19. TYPICAL CONTRACTABLE LABORATORY PROGRAM FUNCTIONS
ro
o
CJ
Contract area
Strongly developed
State program
Weakly developed
State program
New
State program
Central Satellite Central Satellite Central Satellite
Laboratory Laboratory Laboratory Laboratory Laboratory Laboratory
Sampling program
Air quality
monitoring
Pollutant network R R S S F P
Effects network R R R R R R
Meteorology „._ R S P S P S
Calibration R S P P P P
Training R R S P P P
Surveillance
monitoring
Short-term ambient
Source emissions
testing
R
Emergency monitoring
Emergency episode S
Accidental spill P
Analysis program
Routine analysis R
Special analysis
Fuel S
Solvent S
Metals S
Pesticides S
Odor and nuisance R
Effects R
S
R
R
R
F
S
S
P
S
S
P
P
S
P
P
S
P
P
P
S
S
S
R
R
P
P
P
P
S
S
P
P
P
P
P
P
P
P
P
P
P
P
R
R
P
P
P
P
P
P
-------
Table 19(continued). TYPICAL CONTRACTABLE LABORATORY PROGRAM FUNCTIONS
ro
O
Strongly developed
State program
v^uii ur dot urea
Central
laboratory
Data handling program
Computer services
Programming S
Time sharing P
Modeling S
Statistical services R
Data acquisition
Storage and retrieval S
Satellite
laboratory
R
R
R
S
R
Weakly developed
State program
Central
1 aboratory
P
P
P
S
P
Satellite
laboratory
R
R
R
S
R
New
State program
Central
laboratory
P
P
P
P
P
Satellite
laboratory
R
R
R
S
R
Code:
R - remote contract potential.
S - secondary contract area.
P - primary contract area.
-------
liquid, and air samples; and both software and hardware support of the
data handling system. Since the technical services group gives technical
support services to each of other elements of the State agency, it
conducts routine activities on a regular or planned periodic basis. The
laboratory is also expected to respond to nonroutine sampling investi-
gations, special analytical studies, and other activities with which it
may have little or no familiarity.
9.1.1 Sampling Program
The laboratory sampling program includes the assessment of current
air quality, the determination of the degree of improvement required
and of the resultant control activities, and the provision of intelligence
before, during, and after emergency situations. Although the merits of
the air pollution laboratory are based in large measure on its in-house
sampling capabilities, there is a real need for contractual assistance
in this area with the ever-increasing demands for more data per pollutant
and for the measurement of more criteria pollutants.
9.1.1.1 Air Quality Monitoring. The current monitoring activities
are devoted in large extent to the measurement of the Set I pollutants
(particulate and sulfur dioxide) and, somewhat lesser, to the Set II
pollutants (carbon monoxide, hydrocarbons, oxidants, and nitrogen oxides).
A recent Federal report discusses the proposed emission standards for
three hazardous air pollutants (asbestos, beryllium, and mercury). The
resultant accelerated increase in monitoring activities for identified
pollutants will bring an additional utilization of the outside contractual
agreement.
9.1.1.1.1 Air Quality Network. Technical services tasks that may
be accomplished under contract could include the carrying out of a
205
-------
short-term aerometric survey, the development of a monitoring network
protocol document, and the selection of air monitoring network sampling
sites.
9.1.1.1.2 Meteorology. Most statewide air pollution control
agencies require the services of a full-time meteorologist; however,
infrequent instances necessitate the availability of multiple staff
meteorologists. A consulting firm which provides 24 hours-a-day
meteorology services could satisfy the need of most agencies. This
service could also be provided for very large metropolitan agencies
which need the equivalent service of two or more meteorologists, for
large agencies which need the services of a meteorologist on a less
than full-time basis, and for small agencies which need a one-time
service or service at irregular intervals.
The outside consultant or contractor meteorology firm should be
based locally and should be available to the agency on a 24-hour,
"on-call" basis. It is suggested that the contract or agreement be
written for a definite period of time (such as on an annual basis)
and that the projected manpower expenditure be specified in terms of
minimum and/or maximum number of service man-days. The types of service
rendered under a contract for meteorological assistance could include
the following tasks:
(a) Provide consultation and evaluation of urban climatology
and microclimatology to aid in determining the conditions
i
under which air pollutants in the particular community
atmosphere adversely affect health and property, and the
measures necessary to prevent these conditions.
206
-------
(b) Provide information relative to the relationship between
National Weather Service data and locally collected surface
meteorological data.
(c) Provide consultation and evaluation of episodic meteorological
conditions including adverse surface winds, inversions, and
lower atmosphere stagnations.
(d) Provide consultation on the selection and placement of sampling
and monitoring equipment for ambient as well as alert stations.
(e) Provide consultation and advice on the development of a simple
diffusion model for calculating point concentrations from
single and multiple sources and on the use of more sophisticated
models employing computers and telernetrie data.
9.1.1.1.3 Calibration. An outside contractor can be a very
effective agent for field calibration of continuous, automated
instrumentation. Periodic dynamic calibration techniques are most
effective when used in combination with reference methods. A regular
schedule for field calibration at all sampling sites can be set up and
carried out by the contractor laboratory team to insure the continued
validity of collected data and to permit examination of the possible
correlation of data from various sampling locations.
9.1.1.1.4 Training. An outside contractor can be used in
developing and carrying out an air pollution training program. The
contractor can provide on-the-job training to the technician involved
in sampling in the field and to the analyst in the laboratory. The
contractor can also prepare and conduct training courses on the various
topics related to the sampling, analysis, and data handling activities
of the technical services group. Course contents would often
207
-------
be multidisciplinary covering meteorology, chemistry, statistics,
electronics, and engineering.
9.1.1.2 Short-Term Ambient Sampling. Short-term ambient sampling
may be conducted to further assess the priority rating of the air
quality control region in question. Short-term projects are also used
to monitor a source's impact on the quality of the ambient air. A
private contractor can be used to evaluate the pollutant effect of an
existing source on the surrounding community or to conduct before-and-
after monitoring on a new facility (or on a new control device for an
existing facility).
9.1.1.3 Source Emission Testing. Source sampling is not a full-
time activity for the smaller air pollution agency. Since the duties
of a source sampling team vary widely, it is difficult for such an
activity to be completely self-sufficient. In addition, it is the
policy of some agencies to incorporate a level of objectivity into the
source testing program by arranging or recommending that compliance
testing be conducted by an outside testing team, under the direct
supervision of a representative of the cognizant agency.
State agencies will eventually setup and operate a vehicle testing
program. The New Jersey automotive inspection project is still in the
research phase to determine the effectiveness of engine tuneup and
vehicle repair for the reduction of exhaust emissions. The testing,
diagnosis, and tuneup or repair is conducted at State laboratories and
at private contractor service facilities. Full-scale implementation
of similar vehicle source testing programs may require licensing of
gasoline stations, car dealers, and maintenL.ice service centers to
Z08
-------
provide routine testing and repair. Random checking and comprehensive
testing of certified vehicles by the State agency will often require
assistance from private consulting laboratories.
9.1.1.4 Accidental Spills. Whenever vessel rupture or unplanned
spillage represents a significant imminent health hazard (in addition
to a local air pollution problem), it is necessary to involve the
services of an organization trained in the assessment of occupational
health and safety and industrial hygiene problems. This outside
organization may be another Government agency specializing in toxic
material treatment (such as the local or State equivalent of the Federal
National Institute for Occupational Safety and Health), or an agency
skilled in handling emergency situations (such as civil defense,
highway patrol, fire department), or a private consulting laboratory
possessing expertise in the handling and treatment of hazardous and
toxic materials.
9.1.2 Analysis Program
The laboratory analysis program includes the characterization
of routine ambient and source emission samples as well as special
studies requiring nonroutine techniques and equipment. Although the
use of an outside contractor is more common for the more specialized,
less common analytical measurements, relatively new agencies or small
agencies with limited resources may contract out the analytical work
to support its routine sampling program.
9.1.2.1 Routine Analysis. Smaller agencies cannot always afford
the automatic analytical instrumentation available for routine
characterization of air samples. Overall savings in time and cost
209
-------
could be achieved by channeling the analytical work from a group of
small satellite agencies to a centralized laboratory. This laboratory
could be the State's central laboratory, a neighboring metropolitan
agency's laboratory, or a private consulting laboratory. An added
benefit in the centralization of laboratory analyses is the facilitation
of analytical quality control and consequent ease of validation and
correlation of air quality data.
9.1.2.2 Special Analysis. The needs for special analytical
services in conjunction with air pollution control activities are
quite diversified. Samples submitted for characterization may be solid
fuel materials (coal, coke, wood, solid waste), liquid solvents and
cleaning compounds, or air-suspended particulates, gases, and vapors.
The analysis technique itself may involve physical, chemical, biological,
radiochemical, or physiological effects. The capabilities to analyze
for the increasing number of potentially detrimental or hazardous
pollutants are not readily available in-house to the State or local
agency. In the majority of cases, the agency laboratory would do
well to provide special analytical services in cooperation with an
outside agency or private contractor.
Table 20 lists selected air pollutants whose measurement is
related to concern for toxicity levels. In most cases, the instru-
mentation and expertise required for specific analysis are available
in a nearby universityks chemistry or environmental engineering
department, in a local private consulting laboratory specializing
in environmental analytical services, and in the laboratories of
Federal agencies engaged in environmental protection research and
monitoring projects.
210
-------
Table 20. MEASUREMENT METHODS FOR SPECIAL AIR POLLUTANTS
Pollutant
Principle sampling
technique
Analytical
method(s)
Aeroallergens
Anions
Arsenic
Asbestos
Bari urn
Beryllium
Cadmi urn
Chromium
Copper
Corrosive gases
Fine particles
Hydrocarbons:
Reactive
Polynuclear
Hydrogen sulfide
Lead
Manganese
Mercury
Nickel
Odor
Organic vapors
Pesticides
Polychlorinated
biphenyls (PCB)
Radioactive material
Selenium
Tin
Vanadium
Zinc
UD PA
High volume; Bubbler SIE; Colorimetry
High volume NA; Colorimetry
UD EM (UD)
Membrane filter ES
High volume ES; AA
High volume ES; AA
High volume ES; AA
High volume ES; AA
Bubbler UD '
Impactor OM; Gravimetry
UD GC
High volume; Bubbler LC; TLC; F
Bubbler; Tape FP; Coulometry; Colorimetry
High volume ES; AA; Colorimetry
High volume ES; AA
Gas bubbler AA; UV
High volume ES; AA
Grab samples Scentometer
Grab samples GC; MS
UD GC; Coulometry
UD GC; Coulometry
High volume; Bubbler Counters; &; y Scanners
UD AA; Colorometry
High volume ES; AA
High volume ES; AA
Membrane filter ES
Code:
AA - Atomic absorption
EM Electron microscopy I
ES - Emission spectroscopy
F - Fluorescence; phosphorescence
FP Flame photometry
GC Gas chromatography
IR - Infrared absorption
LC - Liquid chromatography
MS - Mass spectrometer
NA - Neutron activation
OM - Optical microscopy
PA - Protein analysis
SIE - Specific ion electrode
TLC - Thin layer chromatography
UD - Under development
UV - Ultraviolet absorption
211
-------
9.1.2.2.1 Fuel Analysis. Combustion calorimetry to determine Btu
content, sulfur content, ash content, and related parameters is a service
rendered by analytical and engineering testing laboratories listed in
the yellow pages of the telephone directories of most large metropolitan
areas. Elemental analysis is available from several analytical labora-
tories who advertize their services in most issues of technical journals
dealing with pollution control topics (Chemical and Engineering News,
Pollution Engineering, Environmental Science and Technology, Journal
of the Air Pollution Control Association).
9.1.2.2.2 Solvent Analysis. Process emissions from dry cleaning
and degreasing operations and various chemical syntheses cannot be
analyzed by routine methods. Gas chromatographic separation and infrared
spectroscopic analysis are required in most instances. Smaller agencies
can fill their periodic needs in this area by using an outside contractor.
9.1.2.2.3 Metal Analysis. Most analyses for metal air pollutants
require expensive instrumentation and an experienced analyst. Until air
quality criteria documents are prepared and routine monitoring is called
for. most agencies need not develop in-house capabilities in this area.
The outside contractor can fill the interim needs.
9.1.2.2.4 Pesticide Analysis. Pesticides are a concern to other
Government agencies concerned with pollution control and public health.
In circumstances where water pollution, industrial hygiene, or other
governmental agencies are conducting routine pesticide analysis, the
requirement for periodic laboratory services to the air pollution control
agency could be met by interagency agreement.
There are problems, however, with data interpretation related to
pesticide levels. Sampling for pesticides in the ambient air has not
212
-------
developed to the stage where sample representativeness is unquestioned.
In addition, pesticides are often rather unstable species, with decay
factors which vary under different conditions. Pesticide sample
integrity presentation is still a research area. In most cases, the
private consulting laboratory with capabilities to provide pesticide
analysis will conduct the gas chromatographic separation and electron
capture or microcoulometric detection only. The sampling operations,
data manipulation, and conclusions will be conducted in-house, using
state-of-the-art procedures obtained from the appropriate Federal
agencies doing pesticides method development.
9.1.2.2.5 Complaint and Nuisance Analysis. Complaints of malodorous
gases, corrosive vapors, staining and soiling materials, and dusts that
produce allergic reaction are often referred to the technical services
group of the air pollution agency. The desirable complaint handling
mechanism would involve the agency's enforcement activity with backup
technical support from the in-house laboratory program. In cases where
this backup expertise is not available internally, a contractual
arrangement with a private consultant is an effective alternative.
9.1.2.2.6 Effects Analysis.112'113 Effects analysis is limited
somewhat by the fact that component differences cannot be measured over
short time intervals. Corrosion rate, soiling potential, material
deterioration, color fading, etc., are determined over exposure periods
ranging from a week to a year. Many of the analyses can be handled using
ordinary laboratory equipment. In other cases, microscopic examination,
reflectance differential measurement, and other specialized techniques
are required. Contracted analytical services are employed when the
213
-------
routine effects analyses interfere with other projects and when the
specialized effects analysis tools are not available in-house.
9.1.3 Data Handling Program
Only the very large metropolitan and State agencies have complete
data handling support facilities. The coupling of telemetry systems
and computer technology has revolutionized the field of ambient air
monitoring. Station interrogation-data transmission techniques
have automated air pollution episode alert warning systems. Air quality
simulation and dispersion-diffusion modeling is a relatively new technique
in air pollution control, dependent upon the development of realistic
mathematical programs and the acquisition of valid air quality and
meteorological data and reliable emission inventory information. In
addition, there is a continual need for various statistical and computa-
tional services, data processing and data evaluation services, and data
storage and retrieval capabilities. In many cases, some of these data
handling requirements cannot be satisfied within the agency itself.
Interagency agreements and contracts with outside specialists are very
useful in filling the gaps in software and hardware, as well as
maintenance and service.
9.2 Contract Mechanisms
The air pollution control agency can enter into a contractual
arrangement for various technical services, for equipment maintenance
services, and for the leasing of hardware and computer-related software.
The contract may be with an individual consultant, a private consulting
firm, another Government agency, or a public utility such as the
telephone company (e.g., to provide telecommunication lines for
transmitting air monitoring data).
214
-------
9.2.1 Types of Contracts
A contract is any type of agreement or order for the procurement
of supplies and services. The contract may be either a fixed-price,
actual-cost, cost-pi us-a-fixed-fee, or incentive type. It may be a
contract providing for the issuance of job orders, task orders, or
task letters. It may be a formal contract document, a letter contract,
a letter of intent, a purchase order, or a supplemental agreement or
amendment to any of the foregoing types. Contracts may also be
»
classified by the method of solicitation and award: sole source,
advertised or open bid, or negotiated bid. A negotiated contract is
obtained by direct agreement with a contractor, without formal
advertising for bids, but after soliciting proposals from qualified
sources. Most negotiated contract requirements are for one of four
general areas: services, data, material or hardware, or a combination
of these three.
9.2.1.1 Service Contracts. This terminology is used to describe
contract requirements for certain types of professional, skilled, and
unskilled services to be performed over a definite time period. There
are usually no deliverable end items required under the contract.
The contracts are for janitorial, equipment, maintenance, clerical,
!
training, or similar type services.
9.2.1.2 Data Requirement Contracts. This is a type of contract
which calls for some type of data to be delivered as an end item. This
could be for research with a report as the end item, which is normally
the case on research contracts. Other types of contract requirements
which fall into this category are audio-visual aid production and
215
-------
reproduction, preparation of training manuals, and editing and publication
of authorized reference material.
9.2.1.3 Material or Hardware Contracts. This includes a variety
of requirements, from the standard catalog hardware items (normally
purchased by formal advertising) to specialized equipment being developed
for research and development purposes (normally handled by negotiations).
9.2.1.4 Combination Requirements. It is quite possible, particularly
for research and development procurement, for contracts to require services,
data, and hardware. It is important for the project officer to recognize
that he has combination requirements, so that in drafting the work state-
ment the required services, data, and hardware can be well defined and
separated for pricing and delivery purposes.
9.2.2 Contract Cost Arrangements
The type of contract cost arrangement should be compatible with
the technical requirements of the work. Generally, two basic types
of contract cost arrangements are the cost-reimbursement and fixed-price
types. A third type, the fixed-rate contract, is a combination of these
two basic types.
9.2.2.1 Cost-Reimbursement Contracts. There are five kinds of
cost reimbursements contracts which would normally be used by the air
pollution control agency:
(a) Cost (without fee),,
(b) Cost sharing,
(c) Cost-plus-fixed-fee (CPFF),
i
(d) Cost-plus-incentive-fee (CPIF),
(e) Cost-plus-award-fee (CPAF).
216
-------
The advantages and appropriate utilization of each of these type
contracts are well discussed in a recent EPA publication]18 For example
the cost contract is used principally in contracting with educational
and other nonprofit institutions.
9.2.2.2 Fixed-Price Contracts. Fixed-price contracts greatly
alleviate the administrative burden to the agency and contractor alike.
These contracts can be classified into five categories:
(a) Firm-fixed-price (FFP),
(b) Level-of-effort,
(c) Fixed-price with redetermination provisions,
(d) Fixed-price-incentive,
(e) Fixed-price-with-escalation.
I no
Each of these contract types is covered in a recent EPA publication.
9.2.2.3 Fixed Rate Contracts. This type of contract can be used
for services or items for which a fixed price or fixed rate can be
established for the labor or for the required items, but for which the
amount of labor or quantity of items cannot be determined at the time
of contract negotiation. Predetermined rates and/or prices are negotiated
in the form of a "basic ordering agreement" (BOA) between the agency and
the contractor. The agency will then request the services or items in
the form of a "call order" against this basic agreement.
9.2.3 Contract Planning and Management
After the laboratory supervisor or other responsible authority has
decided that the project requirement can be best handled by the contract
mechanism, there is need to decide if the situation calls for an
advertised contract or "invitation for bid" (IFB) or for a negotiated
217
-------
contract or "request for proposal" (RFP). The IFB approach is generally
acceptable when the tasks are clearly defined, when the costs are low,
and when the award can be easily made to the lowest responsive bidder
without need for technical evaluation.
The following subsections outline the duties and responsibilities
involved in designing, planning, soliciting, and monitoring a contract
in support of an air pollution agency's technical services function.
The detailed requirements of each element are fully described in
118
reference.
9.2.3.1 Presoil citation Planning and Determinations. A very
important part of the negotiated contract process is the presolicitation
phase. It is extremely important for the initiating project officer
(usually the laboratory supervisor) to contact and work with the agency's
cognizant contracting office immediately upon conception of a contract
requirement. The designated project officer should become closely
associated with the proposed contract program and should serve as the
technical contact for discussions with the agency's contracting officer
throughout the process. The following presolicitation elements require
frequent and open communication between the project officer and the
contracting officer:
(a) Advance procurement planning,
(b) Competitive versus noncompetitive procurements,
(c) The written request for negotiated contract,
(d) Obtaining sources,
(1) Research and development sources sought,
(2) Individual synopsis,
(3) Source files,
218
-------
(e) Preparation of the request for proposal (RFP),
(1) Scope of work preparation,
(2) Technical proposal requirement of the RFP,
(3) Business proposal requirements of the RFP,
(4) Inclusion of proposal evaluation criteria in RFP.
9.2.3.2 Solicitation, Evaluation, and Contract Award. In general,
during the solicitation and contractor/proposal evaluation period, all
»
written and oral communication between the agency and the prospective
contractors should be controlled by the contracting officer. The
agency's policies and procedures may be more or less formal than those
lip
prescribed by the Federal agency;"0 the basic elements are outlined
below:
(a) Solicitation,
(1) Relations and communications with prospective contractors,
(2) Safeguarding information received from prospective
contractors,
(3) Receipt and handling of proposals,
(b) Evaluation,
(1) Technical evaluation,
i
(2) Business evaluation,
(c) Negotiation and contract award,
(1) Prenegotiation conference,
(2) Negotiation and contractor selection,
(3) Contract preparation and coordination,
(4) Contract award.
219
-------
Table 21. TYPICAL ALLOCATION OF RESPONSIBILITIES FOR CONTRACTING AND
PROCUREMENT IN STATE AIR POLLUTION CONTROL AGENCIES118
Contract function
Responsibility designation
Project officer
Contracting officer
ro
INJ
o
Presoll citation
Advance planning
Submission of purchase request
Obtaining sources
Sole source determination
Request for proposal
Solicitation and evaluation
Discussions with contractor
Technical evaluation
Business evaluation
Selection of competitive range
Negotiations and award
Negotiations with contractors)
Selection of contractor
Contract preparation and award
Contract administration
Technical direction
Contract changes and extensions
Monitoring performance
Patents
Acceptance of final product
Payment of Vouchers
Property administration
Administrative close-out
Develops program plan
Decision to buy
Recommends & evaluates
sources
Prepares justification
Develops technical
aspects
Advisory to contracts
off1ce
Total responsibility
Advisory
Participant
Advisory
Scope of work and other
technical aspects
Within defined limits
Initiates to contracts
offi ce
Technical performance
Advisory to general
counsel
Varies with product
Advisory
Advises and recommends
Advises as to procurement
method
Establishes source 11st
Final decision
Responsible for RFP
contents and release
Responsible for all contacts
Total responsibility
Final decision
Responsible for conduct
Final decision
Total responsibility
Total responsibility
Cost performance
Coordinates requests
Varies with product
Reviews & certifies
Final decisions
Total responsibility
-------
9.2.3.3 Contract Management Responsibilities. The project officer
should insure that the contractor's progress is monitored and properly
controlled. If situations arise that would require contract modification
or termination, the problem or information should be promptly directed
to the attention of the agency's contracting office. The following outlines
the duties and responsibilities of the project officer:
(a) Evaluation and control of progress,
(1) Progress reporting,
(2) Progress reviews,
(b) Administration required by contract provisions,
(1) Prior approval items,
(2) Evaluation of inventions and data rights,
(3) Handling cost overruns,
(c) Contract modifications,
(1) Types of contract modifications,
(2) Modifications within the scope of the contract
versus new procurement,
(d) Contract completion.
Table 21 describes the elements of an outside contractual
arrangement (from advance planning to contract termination) in terms
of the primary and shared responsibilities within the contracting agency.
In essence, the project officer handles all technical aspects; the
contracting office is charged with all the administrative, fiscal,
and legal considerations.
221
-------
10.0 REFERENCES
1. "Guidelines: Air Quality Surveillance Networks." Office of Air
Programs Publication No. AP-98, EPA, Research Triangle Park, N.C.,
May 1971.
2. "Field Operations Guide for Automatic Air Monitoring Equipment."
Office of Air Programs Publication No. APTD-0736, EPA, Research
Triangle Park, N.C., November 1971.
3. Mueller, P. K. "Guide to Operation of Atmospheric Analyzers,"
Department of Public Health, Air and Industrial Hygiene Laboratory,
State of California, Berkeley, California, 1970.
4. Rodes, C. E., J. A. Bowen, and F. J. Burmann. "A Portable
Calibration Apparatus for Continuous Sulfur Dioxide Analyzers,"
Distributed in a Refresher Course entitled: "Selection and
Calibration of Continuous Sulfur Dioxide Analyzers." Presented
at 62nd Annual Meeting of the Air Pollution Control Association,
St. Louis, Mo. (June 1970).
5. O'Keeffe, A. E., and G. C. Ortman. "Primary Standards for Trace
Gas Analysis," Anal. Chem. Vol. 38, No. 760 (1966).
6. Scaringelli, F. P., S. A. Frey, and B. E. Saltzman. "Evaluation
of Teflon Permeation Tubes for Use with Sulfur Dioxide,"
J. Amer. Ind. Hygiene Assoc. Vol. 28, No. 260 (1967).
7. Scaringelli, F. P., A. E. O'Keeffe, E. Rosenberg, and J. P. Bell.
"Preparation of Known Concentrations of Gases and Vapors with
Permeation Devices Calibrated Gravimetrically," Anal. Chem.
Vol. 42, No. 871 (1970).
8. Chrisman, K. F., and K. E. Foster. "Calibration of Automatic
Analyzers in a Continuous Air Monitoring Program." Presented
at the Annual Meeting of the Air Pollution Control Association,
Detroit, Michigan (June 1963).
9. Nishikawa, K. "Portable Gas Dilution Apparatus for the Dynamic
Calibration of Atmospheric Analyzers." Presented at the Fifth
Conference on Methods in Air Pollution Studies, Los Angeles,
Calif. (January 1963).
10. Hodgeson, J. A., and B. E. Martin. "Laboratory Evaluation of
Alternate Chemiluminescent Approaches for the Detection of
Atmospheric Ozone," Presented ACS Meeting, Chicago (September
1970).
11. Jutze, G. A., and K. E. Foster. "Recommended Standard Method
for Atmospheric Sampling of Fine Particulate Matter by Filter
Media—High Volume Sampler." J. Air Pollution Control Assoc.
Vol. 17, No. 1 (January 1967).
222
-------
12. Robson, C. D. and K. E. Foster. "Evaluation of Air Sampling
Equipment." Presented at the Annual Meeting of the American
Industrial Hygiene Association, Detroit, Mich. (1961).
13. Henderson, J. A. "A Continuous Flow Recorder for the High
Volume Air Sampler." Manuscript submitted for publication,
Field Investigations Section, Abatement Branch, Division of
Air Pollution, EPA, Cincinnati, Ohio (1966).
14, Schumann, C. E., and C. W. Gruber. "A Recommended Method for
Soiling Index Surveys by Automatic Filter Paper Sampler,"
J. Air Pollution Control Assoc. Vol. 10, No. 6 (December
1960), pp. 436-40.
*
15. Am. Soc. Testing Materials, "Standard Method of Test for
Particulate Matter in the Atmosphere, Optical Density of
Filtered Deposit." ASTM Standards on Methods of Atmospheric
Sampling and Analysis, Philadelphia, Pa., October 1962, p. 94.
16. "Selected Methods for the Measurement of Air Pollutants."
U.S. Public Health Service Publication No. 999-AP-ll, 1965.
17. Ruch, W. E. "Quantitative Analysis of Gaseous Pollutants."
Published by Ann Arbor-Humphrey Science, Ann Arbor, Mich., 1970.
18. Federal Register. Vol. 36, No. 228 (November 25, 1971),
pp. 22384-97, 22403.
19. "Interstate Surveillance Project: Measurement of Air Pollut on
Using Static Monitors." Office of Air Programs Publication
No. APTD-0666, EPA, Research Triangle Park, N.C., May 1971.
20. Slater, H. H., 6. A. Jutze, and R. T. Walsh. "Design of an
Integrated Aerometric Emissions Project," Paper No. 68-43.
Presented at the 61st Annual Meeting of the APCA, St. Paul,
Minn., June 1968.
21. "Technical Report, New York-New Jersey Air Pollution Abatement
Activity," by the Division of Abatement, U.S. Public Health
Service, Cincinnati, Ohio, 1967.
22. "Administrative and Technical Aspects of Source Sampling for
Particulates," Office of Air Programs Publication No. APTD-0754,
EPA, Research Triangle Park, N.C., May 1971.
23. Rom, J. "Maintenance, Calibration, and Operation of Isokinetic
Source-Sampling Equipment," Office of Air Programs Publication No.
APTD-0576, EPA, Research Triangle Park, N.C., 1972.
24. Outze, G. A., et al., "Guide for Air Pollution Episode Avoidance,"
APCO Publication No. AP-76, June 1971.
223
-------
25. McCrone, W. C., R. G. Draftz, and J. 6. Delly. "The Particle
Atlas," Published by Ann Arbor Science Publishers, Inc.,
Ann Arbor, Mich., 1967.
26. Am. Soc. Testing Materials. "Standard Method of Test for Sulfur
in Petroleum Products and Lubricants by the Bomb Method,"
A.S.T.M. Designation D 129-58, Philadelphia, Pa., 1958.
27. Am. Soc. Testing Materials. "Standard Methods of Laboratory
Sampling and Analysis of Coal and Coke," A.S.T.M. Designation
D 271-58, Philadelphia, Pa., 1958.
28. Adam, J. "The Use of the Calorimetric Bomb for the Determination
of Carbon in Coal," J. Chem. Met. Mining Soc. of South Africa,
Vol. 39 (1938), pp. 69-70; also Chem. Abstracts. Vol. 33 (1939),
p. 9587.
29. "Requirements for Preparation, Adoption, and Submittal of
Implementation Plans," Federal Register, Vol. 36, No. 158
(August 14, 1971), pp.. 15486-506; see Section 420.17, p. 15492-3
and Appendix A, p. 15494.
30. "New Source Performance Standards," Federal Register, Vol. 36,
December 23, 1971, p. 24876 ff.
31. Western Alfalfa v. Air Pollution Variance Board, 3 ERC 1399,
Colorado District Court, Weld County, Civil Act 19974, 1971.
32. Walsh, 6. W. and D. J. Von Lehmden. "Resources for Air Quality
Control Regions," National Air Pollution Control Administration,
Durham, N. C., November 1969.
33. Walsh, G. W. and D. J. Von Lehmden. "Estimating Manpower Needs
of Air Pollution Control Agencies," Presented at 63rd Annual
Meeting Air Pollution Control Association, June 1970.
34. "Census of Manufactures (by State)," Bureau of the Census, U. S.
Department of Commerce, Washington, D. C., 1963.
35. "County and City Data Book," U.S. Department of Commerce,
Washington, D. C., 1967.
36. Hochheiser, S., F. J. Burmann, and G. B. Morgan. "Atmospheric
Surveillance—The Current State of Air Monitoring Technology,"
Environmental Science and Technology. Vol. 5, No. 8 (August 1971),
pp. 678-84.
37. Metropolitan Kansas City Air Quality Control Region, Program and
Financial Needs Report, Appendix F, March 1970.
224
-------
38. Altshuller, A. P., A. F. Wartburg, I. R. Cohen, and S. F. Sleva.
"Storage of Vapors and Gases in Plastic Bags," Intern. J. Air
and Water Pollution. Vol. 6, No. 75 (1962).
39. Wohler, H. C., H. Newstine, and D. Daunis. "Carbon Monoxide and
Sulfur Dioxide Adsorption on, and Desorption from Glass, Plastic
and Metal Tubings," J. Air Pollution Control Assoc. Vol. 17
(November 1967), pp. 753-56.
40. Byers, R. L. and 0. W. Davis. "Sulfur Dioxide Adsorption and
Desorption on Various Filter Media," J. Air Pollution Control
Assoc. Vol. 20 (April 1970), pp. 236-38.
41. Stevens, R. K. Private Communications pertaining to reactivity
of tubing materials for sampling low levels of various air pollutants.
Air Pollution Control Office, Durham, N. C., March 1971.
42. Mainline, A. "Quality Assurance for the Automated Laboratory,"
Presented at the Technicon International Congress, New York,
N.Y., November 1970.
43. Environmental Protection Agency, "National Ambient Air Quality
Standards," Federal Register. Vol. 36, No. 84 (April 30, 1971),
pp. 8186-201.
44. Stanley, T. W. "Method Classification and SAC Approval of High
Volume Particulate Method," Memorandum from Office of Measurement
Standardization, Environmental Protection Agency, August 3, 1971.
45. Methods of Air Sampling and Analysis, Manual of tentative methods
from the Intersociety Committee, American Public Health Assoc.,
Inc., Washington, D.C., 1972, 480 pp.
46. Kelly, W. D. "Statistical Method Evaluation and Quality Control
for the Laboratory," Section IV, "Quality Control," Training
Course Manual in Computational Analysis, Environmental Health
Facilities, Cincinnati, Ohio, March 1968.
47. McKee, H. C., R. E. Childers, and 0. Saenz. "Collaborative
Study of Reference Method for the Determination of Suspended
Particulates in the Atmosphere (High Volume Method)," Contract
CPA 70-40, Southwest Research Institute, San Antonio, Tex.,
Office of Measurement Standardization, NERC, Environmental
Protection Agency, June 1971.
48. McKee, H. C., R. E. Childers, and 0. Saenz. "Collaborative
Study of Reference Methods for Determination of Sulfur Dioxide
in the Atmosphere (Pararosaniline Method)," Contract CPA 70-40,
Southwest Research Institute, San Antonio, Tex., Office of
Measurement Standardization, NERC, Environmental Protection
Agency, September 1971.
225
-------
49. McKee, H. C., and R. E. Childers. "Collaborative Study of
Reference Method for the Measurement of Carbon Dioxide in the
Atmosphere (Non-dispersive Infrared Spectrescopy)," Contract
CPA 70-40, Southwest Research Institute, Office of Measurement
Standardization, NERC, Environmental Protection Agency, May 1972.
50. Youden, W. J. "Statistical Techniques for Collaborative Tests,"
Association of Official Analytical Chemists, Washington, D. C.,
1969.
51. Ku, H. H., Ed. Precision Measurement and Calibration, Publication
300, Vol. 1, National Bureau of Standards, U.S. Department of
Commerce, February 1969, p. 421.
52. Bennett, C. A. and N. L. Franklin. Statistical Analysis in
Chemistry and the Chemical Industry. New York: John Wiley and
Sons, 1954, p. 654.
53. Bauer, E. L. A Statistical Manual for Chemists. New York:
Academic Press, 1960.
54. Mickley, H. S., T. K. Sherwood, and C. E. Reed. Applied Mathematics
in Chemical Engineering. New York: McGraw-Hill Book Co., 1957,
p. 73.
55. Natrella, M. G. Experimental Statistics. National Bureau of
Standards Handbook No. 91, U.S. Department of Commerce, 1963.
56. Am. Soc. Testing Materials, Manual on Quality Control of Materials,
Special Technical Publication 15C, American Society for Testing
and Materials, Philadelphia, Pa., 1951.
57. Linnig, F. J. and J. Mandel. "Which Measure of Precision?",
Analytical Chemistry. Vol. 36, No. 13 (1964),pp. 25A-32A.
58. Deutisch, W. G. "Precision, Accuracy and Resolution," ISA Journal.
Vol. 12, No. 8 (1965), pp. 85-6.
59. National Bureau of Standards, Handbook No. 80, U.S. Department
of Commerce, 1961, p. 28.
60. Mandel, J. and F. J. Linnig. "Study of Accuracy in Chemical
Analysis Using Linear Calibration Curves." Analytical Chemistry.
Vol. 29, No. 5 (1957), pp. 743-9.
61. Shewhart, W. A. Economic Control of Quality of Manufactured
Product. Princeton, N.J.: D. Van Nostrand Co., 1931.
62. Grant, E. L. Statistical Quality Control, 3rd Edition, New York:
McGraw-Hill Book Co., 1964.
226
-------
63. Duncan, A. J. Quality Control and Industrial Statistics. 3rd
Edition, Chapter 18. Homewood, 111.: R. D. Irwin, Inc., 1965.
64. Griffin, D. F. "Systems Control by Cumulative Sum Method,"
American Journal Medical Technology. Vol. 34 (1968), p. 644.
65. American Society for Testing and Materials. Testing Single
Arm Balances. E 319-38, Part 30, 1968, pp. 1071-84.
66. Industrial Research, November 20, 1969.
67. Ewing, G. W. Instrumental Methods of Chemical Analysis. New York:
McGraw-Hill Book Co., 1954.
68. Willard, H., L. L. Merritt, and J. A. Dean. Instrumental Methods
of Analysis. New York: D. Van Nostrand Co., 1967.
69. American Laboratory, August 1969.
70. Black, A. P. and S. A. Hannah. "Measurement of Low Turbidity,"
Journal American Water Works Assoc. Vol. 57 (1965), p. 901.
71. Robinson, J. W., Ed. Atomic Absorption Spectrescopy. New York:
Marcel Dekker, Inc., 1966.
72. Slavin, W., Ed. Atomic Absorption Spectroscopy. New York:
Wiley-Interscience, Inc. , 1968.
73. Analytical Methods for Atomic Absorption Spectroscopy. Perkin-
Elmer Corp., Norwalk, Conn., March 1971.
74. Lynn, T. R. Guide to Stationary Phases for Gas Chromatography.
Hamden, Conn.: Analabs, Inc., 1968.
75. Heftman,, E., Ed. Chromatography. New York: Reinhold Publishing
Corp., 1963, pp. 753 (One of numerous textbooks and current
technical publications on gas chromatographic separation and
detection of air pollutants).
i
76. Rechnitz, G. A. "Ion Selective Electrodes," Chemical Engineering
News. June 12, 1967, p. 146.
77. Oxygen Bomb Calorimetry and Combustion Methods, Technical Manual
No. 130, Moline, 111.: Pan Instrument Co., 1966, p. 56.
78. Microparticle Classifier. BAHCO, Operational Procedure Manual,
Detroit, Mich.: Harry W. Dietert Co.
79. Olin, J. G. and G. J. Sem "Air Quality Monitoring with Particle
Mass Monitor System," Technical Note No. 6, Thermo-Systerns, Inc.,
February 10, 1971.
227
-------
80. Chamot, E. M. and C. W. Mason. Handbook of Chemical Microscopy,
3rd Edition, New York: Wiley and Sons, 1960.
81. McCrone, W. C. and M. A. Salzenstein. "The Microscopic Identi-
fication of Atmospheric Particulates," Journal Air Pollution
Control Association. Vol. 12, No. 4, (1962), pp. 195-7.
82. Ferguson, J. S., R. T. Cope, and E. F. McFarren. Air Particulates
No. 1, Report of a Study Conducted by the Analytical Reference
Service, U.S. Department of Health, Education and Welfare,
Cincinnati, Ohio, 1965.
83. Hamcon, W. C. "Magnitude of Errors in Stack Sampling," Air
Repair. Vol. 4 (November 1954), pp. 159-64.
84. Shigehara, R. T., W. F. Todd, and W. S. Smith. "Significance
of Errors in Stack Sampling Measurements," Presented at Annual
Meeting of Air Pollution Control Association, St. Louis, Mo.,
June 1970.
85. Standard Reference Materials. National Bureau of Standards,
Special Publication No. 260, July 1969.
86. "Reagent Chemicals, American Chemical Society Specification,"
American Chemical Society, Washington, D. C.
87. Annual Book of ASTM Standards, Part 23, "Water; Atmospheric
Analysis, Method Designation," E 200-67, 1971, pp. 868-85.
88. Kolthoff, I. M. and E. B. Sandell. Textbook of Quantitative
Analysis, Chapter on "Errors in Quantitative Analysis," 3rd
Edition, New York: MacMillan Co., 1955.
89. Burke, J. J. Assoc. Official Analytical Chemists. Vol. 48
(1965), p. 1037.
90. Willare, H. H. and N. H. Furman. Elementary Quantitative Analysis:
Theory and Practice. New York: D. Van Nostrand Co., 1947.
91. Morgan, J. J. "Methods of Testing Volumetric Glassware,"
Proceedings of American Society of Testing and Materials, Vol. 41
(1941), p. 492.
92. Peffer, E. L. and G. C. Mulligan. "Testing of Glass Volumetric
Apparatus," National Bureau of Standards, Circular C434,
Washington, D.C., 1941.
93. Appelbaum, S. B. and G. J. Crits. "Producing High Purity
Water," Industrial Water Engineering, Sept./Oct., 1964.
94. Annual Book of ASTM Standards, Part 23, "Water, Atmospheric
Analysis, Method Designation," D 1193-70, pp. 196-97, 1971.
228
-------
95. Mi Hi pore Corporation, Bedford, Mass.
96. Continental Water Conditioning Corp., El Paso, Tex.
97. Sola Basic Industries, Elk Grove, 111.
98. Rittmiller, L. A., B. M. Zomkowski, and I. L. Wadehra.
"Comparison of Air and Water Pollution Instrumentation," Pollution
Engineering. Vol. 3, No. 6 (November-December 1971), pp. 28-28.
99. Youden, W. J. "The Collaborative Test," Journal Association
Official Analytical Chemists. Vol. 46 (January 1963), pp. 55-62.
100. McKee, H. C., R. E. Childers, and T. W. Stanley. "Collaborative
Testing of Methods to Measure Air Pollutants," Presented at
National Meeting of Air Pollution Control Assoc., June 1971.
101. McKee, H, C., R. E. Childers, T. W. Stanley, and J. H. Margeson.
"Collaborative Testing of Methods to Measure Air Pollutants,"
Submitted for publication, Journal Air Pollution Control Assoc.
102. Winter, J. A. and M. R. Midgett. "An Evaluation of Analytical
Methods for Water and Wastewater," Method Study No. 2, National
Analyses, Manual Methods, Analytical Quality Laboratory, Water
Quality Office, EPA, Cincinnati, Ohio, 1970.
103. McFarren, E. F. and R. J. Lishka. "The Use of Collaborative
Studies to Evaluate Water Analysis Instruments," Journal Water
Pollution Control Federation. Vol. 43, No. 1 (1971), pp. 67-72.
104. McFarren, E. F., R. J. Lishka, and J. H. Parker. "Criteria for
Judging Acceptability of Analytical Methods," Analytical Chemistry.
Vol. 42 (1970), pp. 358-65.
105. Mandel, J. and T. W. Lashof. The Inter!aboratory Evaluation of
Testing Methods. ASTM Bulletin No. 239, July 1959, pp. 53-60.
106. "Preliminary Study: Nutrient Analyses," Analytical Quality Control
Laboratory, Environmental Protection Agency, Cincinnati, Ohio,
September 1969.
107. Youden, W. J. "Experimental Design and ASTM Committees," Materials
Research and Standards. Vol. 1, No. 11 (1961), pp. 862-67.
108. Malin, M. H. "Project Threshold: Testing the Tests," Environmental
Science and Technology. Vol. 6, No. 1 (1972), pp. 23-2^
109. Jutze, G. A. and R. J. Lewis. "A Method for Checking Instrument
Performance at Remote Sampling Sites," Journal Air Pollution
Control Association. Vol. 15, No. 7 (1965), pp. 323-26.
229
-------
110. "Background Information - Proposed National Emission Standards for
Hazardous Air Pollutants: Asbestos, Beryllium, Mercury,"
Environmental Protection Agency, Office of Air Programs, Research
Triangle Park, North Carolina, December 1971.
111. Andreatch, A. J., J. C. Elston, and R. W. Lahey. "New Jersey Repair
Project: Tune-up at IDLE, Journal Air Pollution Control Association.
Vol. 21, No. 12 (1971), pp. 757-63.
112. Interstate Surveillance Project: Measurement of Air Pollution Using
Static Monitors, Environmental Protection Agency, Air Pollution
Control Office, Research Triangle Park, North Carolina, May 1971,
156 pp.
113. Jutze, G. A., R. L. Harris, and M. Georgevich. "The Interstate
Air Pollution Surveillance Program Effects Network," Journal Air
Pollution Control Association. Vol. 17, No. 5 (1971), pp. 291-93.
114. Larsen, R. I. "How Computers Aid Air Management," Journal Air
Pollution Control Association. Vol. 17, No. 7 (1967), pp. 439-45.
115. Stanley, W. J. "The Role of the Computer in Air Pollution Control,"
Journal Air Pnllutlon Control Association. Vol. 16 (1966),
pp. 100-1.
116, Brodovicz, B. A., V. H. Sussman, and G. B. Murdock. "Pennsylvania's
Computerized Air Monitoring System," Journal Air Pollution Control
Association. Vol. 19, No. 7 (1969), pp. 484-89.
117. Stanley, W. J., and A. N. Heller. "Air Resource Management in the
Chicago Metropolitan Area," Journal Air Pollution Control Association.
Vol. 16 (1966), pp. 536-40.
118. Carroll, T. E., H. M. Messner, and E. T. Rhodes. "Guide for Contract
Project Officers," Environmental Protection Agency, Contracts
Management Division, Washington, D.C., November 1971, 86 pp.
119. "1971-72 Pollution Control Directory," Environmental Science and
Technology. Vol. 5, No. 9 (1971), pp. 812-970.
230
-------
Appendix A
Sampling Location Guidelines
231
-------
Appendix A
Sampling Location Guidelines
This report establishes guidelines for installing air monitoring
instruments at particular sampling sites, especially those sites located
in areas of estimated maximum pollutant concentration. Such sites are
established for the purpose of determining compliance with national,
primary, ambient air quality standards that protect the public health.
The minimum number of air quality monitoring sites and the minimum
frequency of sampling necessary for monitoring compliance with national
standards are specified in published Federal rules and regulations.
General considerations governing the distribution of air quality moni-
toring sites within an air quality control region are described in an
2
EPA publication.
Specific guidelines for placing air monitoring instruments in
areas of estimated maximum pollutant concentration are given in Table
A-l. Guidelines are different for stations defining average 1-hour CO
concentrations and for stations defining average 8-hour CO concentra-
tions because people are not ordinarily exposed to CO concentrations
occurring over a period of 8 hours in a densely trafficked downtown
area. When only one sampling site is used to satisfy the minimum
surveillance requirement of the implementation plan, that site must
meet the guidelines for averaging over 8 hours. Distance from the
street is specified in the location guidelines for stations monitoring
for carbon monoxide because the street is the primary location of CO
emissions. For the same reason, height of the air inlet from the ground
is a more restrictive condition for monitoring for CO than for other
232
-------
Table A-l. SAMPLING LOCATION GUIDELINES FOR AREAS OF ESTIMATED MAXIMUM POLLUTANT CONCENTRATION
ro
co
oo
Pollutant
category
Primary
stationary
source
pollutant
Primary
mobile
source
pollutant
Secondary
pollutant
Pollutant
so2
N02 ,_
Parti culates
CO (1-hr
averaging
time)
CO (8-hr
averaging
time)
°x
A
NO,
L»
Station location
Determined from atmospheric diffusion
model, historical data, emission density
or other information; should be repre-
sentative of population exposure.
Same as above
Same as above.
Representing area containing dense, slow-
moving traffic, obstructions to air
flow (tall buildings), and pedestrian
population, such as a major downtown
traffic intersection (<20 ft from street
curb).
Representing area of high traffic density
in residential area, such as major
throughfare in center city or suburban
area (<50 ft from street curb).
Representing residential area downwind
of downtown area (5 to 15 mi les from
downtown and >300 ft from major traffic
arteries or parking areas).0
Representing residential area downwind of.
downtown area (<5 miles from downtown).
Height
from
ground,
ft
<50
»
<50
<50
<15
<15
<50
<50
Position of air
Vertical
clearance
above
supporting
structure, ft
>3
>3
>3
>3
>3
•
>3
>3
inlet
Horizontal
clearance
beyond
supporting
structure, ft
>5
>5
>3
>3
>3
>5
>5
Not applicable where air inlet is located above supporting structure.
Downwind of prevailing daytime wind direction during the oxidant season.
-------
pollutants. It is desirable whenever practical, however, to sample as
close as possible to the breathing zone; sampling height limitations
for all pollutants are specified accordingly.
There are no well-established meteorological dispersion models now
available to aid in selecting areas where secondary pollutants are
expected to reach maximum concentrations. Selection of the high concen-
tration areas described in Table A-l is based upon information available
on the reaction kinetics of atmospheric photochemical reactions in-
volving hydrocarbons, nitrogen oxides, and oxidants; upon atmospheric
data on diurnal variations in pollutant concentration; upon distribu-
tion of primary mobile sources of pollution; and upon meteorological
factors. A minimum distance from major traffic arteries and parking
areas is specified for oxidant monitoring sites because NO emissions
from motor vehicles consume atmospheric ozone. N02 is considered both
a primary stationary-source pollutant and a secondary pollutant.
Air-monitoring stations for this pollutant should be located according
to specific guidelines for NCL-monitoring stations. Differences in
horizontal and vertical clearance distances are based on the increased
probability of reaction between reactive gases and vertical surfaces.
Sampling sites in areas of estimated maximum pollutant concen-
tration should be chosen on the bases of actual aerometric and
meteorological data, urban and industrial growth and development
trends, and other pertinent information. Whenever feasible, a
preliminary aerometric survey should be conducted as an aid in selecting
sampling locations for maximum pollutant concentration.
234
-------
General guidelines applicable to sampling station location (in
addition to the specific guidelines listed in Table A-l) include the
following:
(a) Except for stations that sample 1-hour CO concentrations,
avoid locations where there are flow restrictions such
as buildings, parapets, or trees in the vicinity of the
air inlet.
(b) Avoid sampling locations that are undu>y influenced by
downwash or by ground dust, such as a roof-top air inlet
in proximity to a stack, or a ground-level inlet near an
unpaved road. In the latter case, either elevate the
sampler intake above the level of maximum ground turbulence
effect, or place the sampler intake away from the source
of ground dust.
(c) Avoid locations that are inaccessible in adverse weather
conditions, prone to vandalism, or otherwise insecure.
It may not be practical to select a sampling site that meets all
of the specific and general guidelines. In this case, it is especially
important to define the site selected so that the results from the site
can be compared with results obtained at other sampling stations that
meet these guidelines. Such a definition should include the critical
factors of elevation, vertical clearance, horizontal clearance,
distance from curb, distance from downtown, distance from major
traffic arteries or parking areas, restrictions to air flow in the
vicinity of samplers, nearby local sources of pollutants, and meteoro-
logical conditions. It is especially important that all samplers of a
given kind be located at the same elevation throughout the sampling area.
235
-------
REFERENCES
1. "Requirements for Preparation, Adoption, and Submittal of
Implementation Plans." U.S. Environmental Protection Agency,
Federal Register. Vol. 36, No. 158 (August 14, 1971),
Section 420.17.
2. Guidelines: Air Quality Surveillance Networks. U.S. Environ-
mental Protection Agency, Office of Air Programs Publication
No. AP-98, May 1971.
236
-------
Appendix B
Job Classifications
Materials contained in this Appendix were abstracted in total from the
EPA publication entitled "GUIDE CLASS SPECIFICATIONS FOR AIR POLLUTION
CONTROL POSITIONS IN STATE AND LOCAL PROGRAMS," July 1971.
237
-------
Appendix B
Job Classifications
B.O THE CLASSIFICATION PROCESS
B.I Using Position Specifications
The basic technique of position classification is the grouping together, in categories or classes, of
those positions which are sufficiently similar in duties and responsibilities so that they can be
treated alike for various administrative purposes. It provides standard titles and a common language
for personnel actions, budgeting, and program planning. The classification plan provides an objec-
tive foundation for a compensation plan designed to assure equal pay for equal work. It affords a
basis for the systematic recruitment, appointment, and promotion of personnel. Class specifications
serve as the basis for development of a practical and normally multi-part examination for assessment
of applicant attributes necessary for successful job performance and career development. The
validity of the examination depends upon the care with which the skills, knowledges, abilities, and
aptitudes sections of the specification are developed. They should reflect the level needed for
entrance into the job, since they determine the content of the tests used in the examination process.
Depending on the type of position and available manpower resources, work-sample, performance,
written or other types of tests may be used to assess the skills, knowledges, abilities and aptitudes
needed. Personal qualities necessary for success in the field normally are assessed through an oral
examination and evaluation of references. The education and experience requirement provides the
basis for a preliminary screening of candidates, admitting to the examination process only those
possessing the needed minimum qualifications. In addition, the education and experience require-
ment also provides a basis for the rating of the quality of the candidates' backgrounds where such a
rating is a weighted part of the examination process.
Class specifications help employees and supervisors to understand the duties and responsibilities in
job assignments. They are useful in the rating of employee performance and in the development of
staff training plans. The classification plan is a valuable tool for encouraging employees to plan a
career in the agency by pointing up the opportunities for broader responsibilities and the require-
ments for advancement.
B.2 Developing and Revising Classification Plans
The development or revision of the classification plan for State or local air pollution control
positions should involve the use of a number of resources and techniques in addition to guide
specifications. After policy decisions have been made about the organization of the program, jojb
descriptions should be prepared by the employees. Background information, including supervisor's
comments, program statements, organization charts, reorganization plans, and other materials
should be secured. The development of a workable classification scheme necessarily involves a
cooperative effort between the program officials and personnel specialists. The official specifica-
tions should conform to the established format used in the jurisdiction and should include all
238
-------
B.3 Guide Class Specifications for Air Pollution Control Positions
These specifications should be regarded as guide or illustrative materials to be used in the develop-
ment of class specifications in State and local air pollution control programs. They are not ready-
made substitutes for. the careful planning and technical work which must be carried out at the time
of installation or revision of a classification structure. Class specifications serve their proper purpose
as aids to improved administration when they accurately reflect the program, job content, and
organization which exist or have been planned and approved by responsible officials. The classifica-
tion process should follow, rather than precede, program and organizational decisions.
These specifications should not be interpreted as requiring adherence either to a particular classifica-
tion structure or to a single type of organization, nor do they represent Federal requirements. They
are offered for the assistance of State and local agencies in improving the classification of their jobs.
It is possible that some jurisdictions may be able to use the suggested guides without substantial
modification, but in many cases adaptation will be necessary. Guide specifications are not to be
construed as meaning that each agency should establish positions in all guide classes. No two
agencies are identical in their job arrangement: The number of classes necessarily will vary according
to the size of the program, the scope of its activities, and other factors. Official State and local
specifications should be developed by staff having a comprehensive knowledge of the air pollution
control program.
Those State and local programs which find, after investigation, that their needs are different from
those envisioned by this publication, can still use the guides as a resource for the needed classifica-
tion activity.
AIR POLLUTION CONTROL DIRECTOR
DEFINITION
Plans, organizes, and directs the professional, administrative, and technical activities of an air
pollution control program; coordinates the program with local. State, regional, Federal, and private
agencies and organizations concerned-with air pollution and related environmental activities; and
evaluates program and personnel effectiveness and initiates improvements.
EXAMPLES OF DUTIES
Plans, organizes, and directs the professional, administrative, and technical activities of the air
pollution control program.
Develops, recommends, interprets, and administers air pollution control statutes.
Coordinates a comprehensive air pollution control program with the programs of other govern-
mental organizations concerned with air pollution and related environmental activities at the local,
State, Federal and regional levels and of private agencies.
Evaluates air quality control regional plan effectiveness, develops recommendations for plan im-
provement, and participates in air quality control regional planning.
Evaluates the effectiveness of the air pollution control program and the effectiveness of program
personnel and initiates actions to maintain and improve effectiveness.
Insures that air pollution programs, policies, plans, and standards meet applicable laws and regula-
tions.
239
-------
features which program and personnel specialists in the jurisdiction are accustomed to utilizing.
While the merit system agency usually has the final authority for approval of the specifications, in
all cases both program and personnel specialists have vital roles to play in the process. They should
be cooperatively involved in the process at the earliest possible time.
The guide specifications can be most useful at two points in the development or revision of the
agency classification structure. After initial review of the job and program information, program
and personnel specialists can consult the guides as one possible approach to setting up a class series
— a sequence of related classes which covers all levels in the occupational area and is arranged in
order of difficulty and responsibility. Once the basic class structure is decided upon, the guide
specifications can be a resource in the preparation of the various sections of the specification and in
some instances may provide the actual language used. Caution must be exercised, however, to avoid
adopting language from the draft specifications which does not represent the facts concerning the
program as it is in the jurisdiction. Most specifications begin with a definition providing a clear,
concise statement of the major responsibilities of the positions in the class. In these guide specifica-
tions we have used "close supervision", "supervision", "general supervision", and "direction" to
show the differences in supervision received. "Close supervision" is defined as receiving detailed
instructions with constant review of work; "supervision" as receiving less detailed instructions,
except for complex duties, with periodic review of work; "general supervision" as receiving minimal
instructions with only results evaluated, and "direction" as receiving very broad guidelines with
only results evaluated. The definition should be followed by a sufficient number of examples of
work, starting with the more responsible, to cover the range of activities performed. Each example
normally is expressed in the same grammatical form.
The last major category in a specification, "minimum qualifications", should include requisites of
training, experience, knowledge, skills, abilities, and aptitudes that an employee needs for entrance
into the job. Such statements should not include kinds of experience, knowledge, or ability that
normally are acquired on the job after appointment. They should not be so narrow as to rule out
the recruitment of all except those with an ideal background. They should be reasonably clear from
the point of view of prospective applicants. They should be specific enough to be used in reviewing
applications of candidates. The establishment of minimum requirements calls for a realistic con-
sideration of the needs of the job and of manpower supply and oemand throughout the recruiting
area from which most candidates will be drawn. Improperly prepared minimum requirements un-
necessarily restrict employees promotability, limit employee reassignments and mobility, and cause
employees to seek opportunities elsewhere. In describing the levels of knowledges, a consistent
pattern should be followed and the number of levels held to a minimum. Three levels are generally
useful. In the guide class specifications presented in this monograph, we have used the terms
"thorough knowledge", "knowledge", and "some knowledge"
The administrators of State and local air pollution control programs will find that the time devoted
to a better classification plan is a worthwhile investment. Such a plan, reflecting program goals
position components, realistic statements of qualifications, will contribute to the achievement of
economical and effective program administration.
240
-------
Directs the development and implementation of a public relations program to educate public and
private organizations and individuals to improve air quality.
Represents the air pollution control program at conferences and meetings with public and private
officials and organizations.
Develops and presents reports and papers on air pollution control.
Directs the development of the program budget, presents and justifies the budget, and allocates
budgeted funds to program activities.
Coordinates and supervises the activities of a staff of professional, administrative, and technical
personnel to achieve maximum utilization of manpower, facilities, equipment and material.
Initiates, reviews, approves, and makes recommendations regarding requests for manpower, facili-
ties, equipment, and material.
Develops and administers a personnel program, including manpower planning and the recruitment,
orientation, and training of program personnel.
Directs the preparation of program reports and the maintenance of program records.
Performs related duties as required.
MINIMUM QUALIFICATIONS
Education and Experience:
Graduation from an accredited college or university and four years of progressively responsible
professional experience in air pollution control or a related environmental program which includes
at least one year of administrative or supervisory experience,
OR
A combination of education at an accredited college, university, or junior college and progressively
responsible professional experience in air pollution control or a related environmental program
which totals eight years and includes at least one year of administrative or supervisory experience,
OR
Eight years of progressivley responsible professional experience in air pollution control or a related
environmental program which includes at least one year of administrative or supervisory experience.
Substitution:
Successful graduate study in engineering, science, public health or administration, or a related
environmental field may be substituted for three of the required four years of progressively respon-
sible experience on a year-for-year basis.
No substitution is permitted for the one year of Administrative or supervisory experience.
Knowledges, Skills, and Abilities:
Thorough knowledge of administration, management, supervision, and training.
Thorough knowledge of the principles and practices essential to the identification, control, and
reduction of air pollution.
Thorough knowledge of information sources in air pollution control and related environmental
programs.
Knowledge of the laws, rules, and regulations applicable in the air pollution control program.
Knowledge of the major types of sources of air pollution.
Skill at analyzing complex documents and technical reports.
Skill at developing and presenting studies and reports orally and in writing.
Skill at establishing and maintaining positive and productive relationships with associates, public
and private officials, and the general public.
Ability to plan, organize, and direct the activities of a professional, administrative, and technical
staff.
241
-------
Ability to coordinate the air pollution control program with other air pollution control and related
environmental programs.
Ability to evaluate program and personnel effectiveness.
Ability to develop recommendations and to initiate program and personnel improvements.
Ability to represent the air pollution control program to public and private officials, the general
public, and to technical and professional organizations.
AIR POLLUTION CONTROL SUPERVISOR
DEFINITION
Under the direction of the Air Pollution Control Director, with broad technical latitude, is respon-
sible for planning a major segment of an air pollution control program; coordinating it with other
segments of the program; supervising a professional, administrative, and technical staff; and acting
for the Director as designated.
EXAMPLES OF DUTIES
Plans a major segment of an air pollution control program.
Supervises and coordinates as necessary with other segments of the program such functions as:
- Developing, conducting, and maintaining an emission and
source inventory;
- Operating and maintaining air monitoring, sampling, and
analyzing facilities and equipment;
- Reviewing and acting on requests for new and renewal
construction and operation permits;
- Investigating complaints;
- Inspecting facilities and equipment;
- Conducting surveys and special studies.
Develops emergency episode procedures; makes recommendations for invoking the procedures; and
may supervise the enforcement of the procedures for the agency.
Develops proposals for needed new standards, regulations, and laws.
Evaluates new local. State, regional, and Federal laws, regulations, and standards for program
implications and develops appropriate procedures to carry them out.
Appears at hearings on air pollution violations and presents pertinent data; appears at court actions
as an expert witness.
Develops and presents reports and studies on air pollution to management and at conferences and
meetings; reviews and evaluates staff reports and studies.
Develops and participates in a public relations program to improve air quality; may carry the
responsibility for the program for the agency.
Provides consultative services to public and private agencies and officials on the identification,
control, and reduction of air pollution.
Develops the budget for the program segment along with supportive data justifying requests for
manpower, facilities, equipment, and material.
Recruits and evaluates candidates for employment, evaluates employees, and makes recommen-
dations to the Director regarding all types of needed personnel actions.
Plans and implements training programs for program staff and for representatives of other public
agencies and private organizations interested in air pollution.
May supervise the organization and maintenance of a technical library resource.
Performs related duties as required.
242
-------
MINIMUM QUALIFICATIONS
Education and Experience:
Graduation from an accredited college or university and three years of progressively responsible
professional experience in air pollution control or a related environmental program
OR
Any combination of education at an accredited college, university, or junior college and progres-
sively responsible professional experience in air pollution control or a related environmental pro-
gram which totals seven years and includes at least three years of progressively responsible profes-
sional experience.
OR
Seven years or progressively responsible professional experience in air pollution control or a related
environmental program.
Substitution:
Successful graduate study in engineering, science, public health or administration, or a related
environmental field may be substituted for the progressively responsible professional experience on
a year-for-year basis.
Knowledges, Skills, and Abilities:
Thorough knowledge of the principles and practices essential to the identification, control, and
reduction of air pollution.
Thorough knowledge 6f information sources in air pollution control.
Knowledge of the laws, rules, and regulations applicable in the air pollution control program.
Knowledge of administration, supervision, and training.
Knowledge of the major types of sources of air pollution.
Knowledge of statistical principles and procedures as applied to air pollution programs.
Knowledge of the hazards of and the safeguards essential to a program which: utilizes electrical,
mechanical, and chemical equipment and hand and power tools; is performed in shops, laboratories,
field installations, and industrial and commercial facilities; and may be carried on under difficult
and dangerous conditions.
Skill at analyzing documents and technical reports.
Skill at developing and presenting studies and reports orally and in writing.
Skill at establishing and maintaining positive and productive relationships with associates, public
and private officials, and the general public.
Ability to organize and supervise the activities of professional, administrative, and technical staff.
Ability to coordinate the air pollution control program unit with other air pollution control pro-
gram units.
Ability to evaluate program unit and personnel effectiveness.
Ability to develop recommendations and to initiate unit program and personnel improvements.
Ability to represent the air pollution control program to public and private officials, the general
public, and to technical and professional organizations.
Ability to work under difficult and dangerous conditions including temperature extremes, heights,
and fumes where necessary.
243
-------
AIR POLLUTION CONTROL CHEMIST
Air Pollution Control Chemist positions often are included in broad chemist classes which may
cover all of a State or local government's chemist positions or those of several programs and
agencies. It is generally advantageous to keep to a minimum the number of classes established so
long as they adequately reflect for administrative purposes the functions performed in individual
positions. These guide class specifications were developed for use by those jurisdictions where a
determination is made to establish separate classes for Air Pollution Control Chemists, but the
duties described may be useful in preparing job descriptions for Air Pollution Control Chemists
where such positions are included in a broader class.
Another pattern of duties and minimum qualifications may be found in the joint Public Health
Service and Office of State Merit Systems publication "Guide Class Specifications for State Public
Health Laboratories", October 1969.
AIR POLLUTION CONTROL CHEMIST I
DEFINITION
Under close supervision, performs standardized chemical analyses of atmospheric contaminants;
assists in the development of analytical procedures and measurement techniques; learns to perform
more difficult analyses and to provide professional and' technical advice on the chemistry of air
pollution; may participate in special studies; may lead and assist in training program personnel.
EXAMPLES OF DUTIES
Performs standardized chemical laboratory and field analyses of atmospheric contaminants.
Assists higher-level staff to develop and standardize new chemical sampling and analyzing pro-
cedures.
Meets with public and private officials and assists higher-level staff in providing professional and
technical advice.
Gathers, organizes, and develops basic data and information for inclusion in technical reports and
studies.
Gathers and assists higher-level staff in the organization, correlation, and preparation of data and
exhibits for use in hearings or court cases.
Gathers, organizes, and participates in the evaluation of data and information on the effectiveness
and accuracy of air pollution control equipment and instruments and assists higher-level staff in the
development of recommendations for improvement.
Prepares for more important assignments by observation, study, on-the-job training, review of
reports, and participation in assignments of increasing difficulty and responsibility.
Operates, calibrates, repairs, and assists in the modification of field and laboratory equipment,
facilities, and instruments.
Learns to construct special purpose equipment and develop instrumentation by observing and
assisting higher-level staff.
244
-------
EXAMPLES OF DUTIES
May participate in special surveys and studies in the laboratory and in the field.
May appear in hearings or in court actions as a witness.
May participate in the training of program staff and representatives of other public agencies and
private organizations.
May lead lower-level employees.
May maintain a technical library resource.
Performs related duties as required.
MINIMUM QUALIFICATIONS
Education and Experience:
Graduation from an accredited college or university with a major either in chemistry or biochem-
istry, or a bachelor's degree in a biological science, physical science, or engineering which includes
the equivalent of a minor in chemistry,
OR
Any combination of education at an accredited college, university, or junior college and progres-
sively responsible technical or professional experience performing chemical examinations, tests, and
analyses which totals four years.
OR
Four years of progressively responsible technical or professional experience performing chemical
examinations, tests, and analyses.
Knowledges, Skills, and Abilities:
Knowledge of the basic principles and laboratory applications of chemistry and biochemistry.
Knowledge of information sources in chemistry and biochemistry.
Some knowledge of scientific methodology.
Some knowledge of current laboratory methods, equipment, facilities, and materials.
Some knowledge of the physical and chemical characteristics of air pollutants.
Some knowledge of the hazards of and the safeguards essential to a program which: utilizes elec-
trical, mechanical, and chemical equipment and hand and power tools; is performed in shops,
laboratories, field installations, and industrial and commercial facilities; and may be carried on
under difficult and dangerous conditions.
Some skill in the care and use of laboratory equipment.
Ability to make chemical and microscopic analyses of air samples.
Ability to make and record scientific observations accurately.
Ability to analyze and evaluate documents, technical reports, formulae, and data.
Ability to understand and follow complex oral and written instructions.
Ability to perform basic mathematical calculations.
Ability to develop and present studies and reports orally and in writing.
Ability to establish and maintain positive and productive relationships with associates and other
public and private individuals.
Ability to evaluate facility and equipment effectiveness.
Ability to understand and implement laws, rules and regulations.
Ability to perceive colors normally and to make olfactory distinctions.
Ability to observe safety precautions and practices.
245
-------
AIR POLLUTION CONTROL CHEMIST II
DEFINITION
Under general supervision, with technical latitude, performs professional chemical analyses of atmo-
spheric contaminants; develops analytical procedures and measurement techniques for laboratory
and field activities; provides professional and technical advice; plans and conducts special studies;
assists in planning the air pollution control program; leads and trains program personnel.
EXAMPLES OF DUTIES
Performs laboratory and field analyses of atmospheric contaminants utilizing wet and instrumental
chemical methodology.
Develops and standardizes new chemical sampling and analyzing procedures and modifies existing
procedures to meet program requirements.
Provides professional and technical advice to public and private officials on the chemistry of air
pollution identification, control, and reduction.
Performs special surveys and studies including chemical sampling and analyses in the laboratory and
in the field.
Prepares reports and studies for presentation to management and for publication.
Organizes and correlates chemical data and prepares exhibits and presentations for use in hearings
and court cases.
Appears in hearings and court cases as an expert witness; and explains and illustrates air pollution
data, equipment, instrumentation, and technical processes.
Compiles and evaluates data and information on the effectiveness and accuracy of air pollution
control equipment and instruments and develops recommendations for improvement.
Trains program personnel and representatives of other public agencies and private organizations.
Operates, calibrates, repairs, and modifies as necessary field and laboratory facilities, equipment,
and instruments used to chemically identify and analyze air pollutants.
Constructs special purpose equipment and develops instrumentation.
Leads, and may supervise, lower-level employees.
Initiates requests for, and makes recommendations regarding, new and additional manpower, facili-
ties, equipment, and material.
Provides basic data for the budget.
Performs related duties as required.
MINIMUM QUALIFICATIONS
Education and Experience:
Graduation from an accredited college or university with a major either in chemistry or biochem-
istry, or a bachelor's degree in a biological science, physical science, or engineering which includes
the equivalent of a minor in chemistry, and one year of progressively responsible professional
experience performing chemical examinations, tests, and analyses,
OR
Any combination of education at an accredited college, university, or junior college and progres-
sively responsible technical or professional experience performing chemical examinations, tests, and
analyses which totals five years and includes at least one year of professional experience,
246
-------
OR
Five years.of progressively responsible technical or professional experience performing chemical
examinations, tests, and analyses which includes at least one year of professional experience.
Substitution:
Successful completion of one year of full-time graduate study at an accredited college or university
in chemistry, a closely related science, or a closely related field or engineering may be substituted
for the professional experience.
Knowledges, Skills, and Abilities:
Thorough knowledge of the principles and laboratory applications of chemistry and biochemistry.
Thorough knowledge of information sources in chemistry and biochemistry.
Knowledge of scientific methodology.
Knowledge of current laboratory methods, equipment, facilities, and materials.
Knowledge of the physical and chemical characteristics of air pollutants.
Knowledge of the hazards of, and the safeguards essential to a program which: utilizes electrical, me-
chanical, and chemical equipment and hand and power tools; is performed in shops, laboratories,
field installations, and industrial and commercial facilities; and may be carried on under difficult
and dangerous conditions.
Some knowledge of research methods and instrumentation used in the study of air pollution.
Some knowledge of the laws, rules, and regulations applicable in the air pollution control program.
Skill at making chemical and microscopic analyses.
Skill in the care and use of laboratory equipment.
Skill at making and recording scientific observations accurately.
Skill at analyzing documents, technical reports, formulae, and data.
Skill at developing and presenting studies and reports orally and in writing.
Skill at establishing and maintaining positive and productive relationships with associates and other
public and private officials.
Skill at performing mathematical calculations.
Skill at observing safety precautions and practices.
Ability to evaluate facility and equipment effectiveness.
Ability to implement and to develop recommendations concerning laws, rules, and regulations.
Ability to represent the air pollution program to public and private officials and to the general
public.
Ability to interpret and implement complex oral and written instructions.
Ability to percefve colors normally and to make blfactory distinctions.
AIR POLLUTION CONTROL ENGINEER
Air Pollution Control Engineering positions often are included in broad engineering classes which
may cover all of a State or local government's engineering positions or those of several programs and
agencies. It is generally advantageous to keep to a minimum the number of classes established so
long as they adequately reflect for administrative purposes the functions performed in individual
positions. These guide class specifications were developed for use by those jurisdictions where a
determination is made to establish separate classes for Air Pollution Control Engineers, but the
duties described may be useful in preparing job descriptions for Air Pollution Control Engineers
where such positions are included in a broader class.
247
-------
Another pattern of duties and minimum qualifications may be found in the joint Public Health
Service and Office of State Merit Systems publication "Guide Class Specifications for Selected
Environmental Engineering Positions in State and Local Health Programs", March 1968.
AIR POLLUTION CONTROL ENGINEER I
DEFINITION
Under close supervision, makes beginning professional engineering analyses and evaluations of air
pollution sources, problems, and permit plans; makes basic emission inventory calculations and
assists in the development of emission reduction strategies; may assist in provision of professional
and technical advice; may participate in special studies; may lead and assist in training program
personnel; learns to perform more difficult engineering duties.
EXAMPLES OF DUTIES
Performs beginning professional engineering analyses and evaluations and assists higher-level staff in:
the review of plans and specifications for air pollution control devices, systems, and operations; the
examination and testing of air pollution control devices, systems, and operations, and the prepara-
tion of technical reports thereon.
Reviews, and assists higher-level staff in reviewing, plans and reports related to new construction
and changes in air pollution control facilities and equipment.
Compiles air pollution data and prepares charts and graphs for the interpretation of the data with
particular reference to the extent, nature, and source of atmospheric contaminants.
Drafts recommendations for the control or reduction of air pollution.
Meets with operators, managers, and owners of facilities which are actual or potential sources of air
pollution and assists higher-level staff in providing engineering advice and technical assistance.
Prepares for more important assignments by observation, study, on-the-job training, review of
EXAMPLES OF DUTIES
reports and participation in assignments of increasing difficulty and responsibility.
May, for training purposes, observe and assist more skilled staff in:
- Operating and making minor adjustments to air sampling equipment;
- Collecting samples of air pollutants;
- Patrolling assigned areas to observe and record smoke, fumes, and
other undesirable emissions into the atmosphere;
- Making facility and equipment inspections and carrying on
complaint investigations.
May participate in the training of program staff and representatives of other public agencies and
private organizations.
May participate in special surveys and studies in the office and in the field.
May appear at hearings or in court actions as a witness.
May lead lower-level employees.
May maintain a technical library resource.
Performs related duties as required.
248
-------
MINIMUM QUALIFICATIONS'1
Education and Experience:
Graduation from an accredited college or university /V..M ,, H,.,. iu;iii<>ririiig or a major in one of
the physical sciences and a minor or its equivalent in engineering,
OR
Any combination of education at an accredited college, university, or junior college and progres-
sively responsible technical or professional engineering experience in air pollution control or a
related environmental program which totals four years,
OR
Four years of progressively responsible technical or professional engineering experience in air pollu-
tion control or a related environmental program.
Knowledges, Skills, and Abilities:
Knowledge of engineering principles relating to air sanitation.
Knowledge of engineering mathematics and statistical techniques.
Knowledge of information sources in air pollution control engineering.
Some knowledge of combustion processes and of elementary thermodynamics.
Some knowledge of the methods used in determining the chemical and physical characteristics of air
pollutants.
Some knowledge of the hazards of and the safeguards essential to a program which: utilizes elec-
trical, mechanical, and chemical equipment and hand and power tools; is performed in shops,
laboratories, field installations, and industrial and commercial facilities; and may be carried on
under difficult and dangerous conditions.
Some skill in the care and use of instruments and equipment.
Ability to analyze and evaluate engineering plans, specifications, technical reports, blueprints, and
data.
Ability to understand and follow complex oral and written instructions.
Ability to perform basic mathematical calculations.
Knowledges, Skills, and Abilities:
Ability to develop and present technical studies and reports orally and in writing.
Ability to establish and maintain positive and productive relationships with associates and other
public and private individuals.
Ability to evaluate facility and equipment effectiveness.
Ability to understand and implement laws, rules, and regulations.
Ability to observe safety precautions and practices.
249
-------
AIR POLLUTION CONTROL ENGINEER II
DEFINITION
Under general supervision, with technical latitude, performs professional engineering work in an
office or in the field; makes analyses and evaluations of air pollution sources, problems, and permit
plans; calculates emission inventories and develops emission control and reduction strategies and
emergency episode plans; provides professional and technical advice; plans and conducts special
studies; assists in planning the air pollution control program; leads and trains program personnel.
EXAMPLES OF DUTIES
Analyzes and evaluates plans and specif ications of air pollution control devices, systems, and opera-
tions, and prepares engineering recommendations concerning acceptability or changes needed.
Reviews field reports and compliance schedules and provides engineering analyses for agency per-
sonnel and public and private officials
Calculates emission inventories and develops emission control and reduction strategies and emer-
gency episode plans.
Confers with public and private officials, engineering consultants and architects, and the general
public to provide engineering advice, technical assistance, and information relative to air pollution
control problems.
Reviews plans and specifications of proposed air pollution control facilities and equipment for
compliance with laws, rules, and regulations and recommends appropriate action.
Reviews zoning plans, air quality, meteorological and other relevant data and makes recommen-
dations for the location and control of industrial concerns, commercial organizations, and public
agencies and facilities with actual and potential air pollution problems.
Provides engineering assistance and technical advice to program staff engaged in air pollution surveil-
lance, inspection, and investigation.
Leads, and may supervise, program personnel.
Provides engineering advice and technical assistance to employees engaged in installing, operating,
calibrating, and maintaining air sampling instruments and equipment; initiates, evaluates, and makes
recommendations regarding requests for maintenance services; makes recommendations regarding
needs for new and additional instruments and equipment.
Trains program staff and representatives of other public agencies and private organizations in the
identification, control, and reduction of air pol.lutants.
Appears at hearings and in court actions as an expert; and explains and illustrates air pollution data,
equipment, instrumentation, and technical processes.
EXAMPLES OF DUTIES
Participates in special surveys and studies, prepares charts and graphs, and interprets data.
Analyzes data and makes recommendations as to air sampling site locations, facility types, and
necessary equipment and instrumentation. ,
Develops, adapts, adjusts, and modifies instruments and equipment used in obtaining and analyzing
air samples. '
Prepares reports and studies for presentation to management and for publication.
Provides basic data for the budget.
Performs related duties as required.
250
-------
MINIMUM QUALIFICATIONS1
Education and Experience:
Graduation from an accredited college or university with a major in engineering or a major in one of
the physical sciences and a minor or its equivalent in engineering, and one year of progressively
responsible professional engineering experience in air pollution control or a related environmental
program,
OR
Any combination of education at an accredited college, university, or junior college and progres-
sively responsible technical or professional engineering experience in air pollution control or a
related environmental program which totals five years and includes at least one year of professional
experience,
OR
Five years of progressively responsible technical or professional engineering experience in air pollu-
tion control or in a related environmental program which includes at least one year of professional
experience.
Substitution:
A master's degree from an accredited college or university in engineering, a closely related science,
or public or environmental health may be substituted for the professional experience.
Knowledges, Skills, and Abilities:
Thorough knowledge of engineering principles and practices of air quality conservation and of the
sources, character, and effect of air pollution.
Thorough knowledge of information sources in air pollution control engineering.
Knowledge of combustion principles in terms of the control of air pollutants.
Knowledge of the physical and chemical characteristics of air pollutants.
Knowledge of the hazards of and the safeguards essential to a program which: utilizes electrical,
mechanical, and chemical equipment and hand and power tools; is performed in shops, laboratories,
field installations, and industrial and commercial facilities; and may be carried on under difficult
and dangerous conditions.
Some knowledge of research and methods and instrumentation used in the study of air pollution.
Some knowledge of the laws, rules, and regulations applicable in the air pollution control program.
Some knowledge of the meteorological factors affecting the development and dispersal of air
pollutants.
Skill at analyzing engineering plans, specifications, technical reports, blueprints, and data.
Knowledgss, Skills, and Abilities:
Skill in the care and use of air sampling instruments and equipment.
Skill at developing and presenting technical studies and reports orally and in writing.
Skill at establishing and maintaining positive and productive relationships with associates and other
public and private officials.
Skill at performing mathematical calculations.
Skill at observing safety precautions and practices.
Ability to evaluate facility and equipment effectiveness.
Ability to implement and to develop recommendations concerning laws, rules, and regulations.
Ability to represent the air pollution program to public and private officials and to the general
public.
Ability to interpret and implement complex oral and written instructions.
251
-------
AIR POLLUTION CONTROL METEOROLOGIST I
DEFINITION
Under close supervision, performs beginning professional meteorological analyses and evaluations of
meteorological and air pollution data; assists in the relation of meteorological elements to air
pollution problems and preparation of periodic air quality forecasts; may assist in provision of
professional and technical advice; may participate in special studies; may lead and assist in the
training of program personnel; learns to perform more difficult meteorological duties.
EXAMPLES OF DUTIES
Collects from air monitoring stations and from local. State, and Federal sources meteorological data
such as wind velocity and direction, lapse rates, air pressure, temperature, and humidity, and data
concerning types and concentrations of air pollutants.
Operates, calibrates, and maintains specialized scientific equipment in meteorological (air moni-
toring) stations in an assigned area.
Correlates meteorological data with concentrations of air pollutants or the diffusion of contami-
nants in the atmosphere; and prepares charts and diagrams showing the relationships.
Assists higher-level staff in the preparation of meteorological reports, studies, and recommen-
dations.
Provides routine air pollution and forecast information to the public and to officials of public
agencies and private organizations in response to inquiries.
Prepares for more important assignments by observation, study, on-the-job training, review of
reports, and participation in assignments of increasing difficulty and responsibility.
May participate in special surveys and studies.
May appear at hearings or in court actions as a witness.
May participate in the training of program staff and representatives of other public agencies and
private organizations.
May lead lower-level employees.
May maintain a technical library resource.
Performs related duties as required.
MINIMUM QUALIFICATIONS
Education and Experience:
Graduation from an accredited college or university with a major in meteorology or a major in the
natural or physical sciences and a minor or its equivalent in meteorology or the atmospheric
sciences,
OR
Any combination of education at an accredited college, university, or junior college and progres-
sively responsible technical or professional meteorological experience which totals four years,
OR
Four years of progressively responsible technical or professional meteorological experience.
252
-------
Knowledges, Skills, and Abilities:
Knowledge of the fundamental physical and mathematical sciences underlying the science of mete-
orology.
Knowledge of meteorology with emphasis on the relationship of conditions of the atmosphere to air
pollution.
Some knowledge of scientific methodology.
Some knowledge of standard meteorological equipment and the method of applying it to meteo-
rological studies.
Some knowledge of statistical principles and procedures.
Some knowledge of the hazards of and the safeguards essential to a program which: utilizes elec-
trical, mechanical, and chemical equipment and hand and power tools; is performed in shops,
laboratories, field installations, and industrial and commercial facilities; and may be carried on
under difficult and dangerous conditions.
Some knowledge of information sources in meteorology.
Some skill in the care and use of meteorological equipment.
Ability to analyze and evaluate documents, technical reports, and data.
Ability to make and record scientific observations accurately.
Ability to operate and maintain a variety of meteorological measuring instruments.
Ability to develop and present studies and reports orally and in writing.
Ability to establish and maintain positive and productive relationships with associates and other
public and private individuals.
Ability to evaluate facility and equipment effectiveness.
Ability to perform mathematical calculations.
Ability to understand and implement laws, rules, and regulations.
Ability to interpret and implement complex oral and written instructions.
Ability to observe safety precautions and practices.
AIR POLLUTION CONTROL METEOROLOGIST II
DEFINITION
Under general supervision, with technical latitude, makes professional meteorological analyses and
evaluations of meteorological and air pollution data; relates meteorological elements to air pollution
problems in control models; prepares periodic air quality forecasts; recommends implementation
and termination of emergency episode- plans; provides professional and technical advice; plans and
conducts special studies; assists in planning the air pollution control program; leads and trains
program personnel.
EXAMPLES OF DUTIES
Plans and conducts meteorological studies using statistical design and air sampling technology.
Operates and supervises the operation of specialized scientific equipment in meteorological observa-
tion stations.
Calculates effects of different emission levels using inventories of emission sources, meteorological
and topographical data, and population.
Analyzes and evaluates climatological factors in making short-range detailed forecasts of expected
air pollution and in forecasting long-range seasonal and annual variations in air pollution measure-
ments.
253
-------
Advises air pollution control program staff regarding meteorological conditions affecting pollutant
measurement and air pollution surveillance.
Conducts and coordinates studies relating meteorological phenomena to the occurrence of airborne
wastes in order to devise new, and to refine existing, forecasting techniques regarding air quality
trends.
Participates in research projects related to air resource management and land use involving such
items as industrial zoning, trends in growth and concentration of industry and population, and
public reaction to air pollution standards.
Maintains records of levels of air pollution and meteorological data and advises program officials
when appropriate to declare an air pollution emergency episode.
Appears at hearings and in court actions as an expert; and explains and illustrates air pollution data,
equipment, instrumentation, and technical processes.
Performs special surveys and studies.
Analyzes data and makes recommendations as to air monitoring site locations, facility type, and
necessary equipment and instrumentation.
Develops, adapts, adjusts, and modifies instruments and equipment used in obtaining air samples.
Prepares reports and studies for presentation to management and for publication.
Leads, and may supervise, lower-level employees.
Provides basic data for the budget.
Performs related duties as required.
MINIMUM QUALIFICATIONS
Education and Experience:
Graduation from an accredited college or university with a major in meteorology or a major in the
natural or physical sciences and a minor or its equivalent in meteorology or the atmospheric
sciences, and one year of progressively responsible professional meteorological experience in air
pollution control or a related environmental program,
OR
Any combination of education at an accredited college, university, or junior college and progres-
sively responsible technical or professional meteorological experience which totals five years and
includes at least one year of professional experience in air pollution control or a related environ-
mental program,
OR
Five years of progressively responsible technical or professional meteorological experience which
includes at least one year of professional experience in air pollution control or a related environ-
mental program.
Substitution:
Successful graduate study in engineering, science, public health, or a related environmental fioin
may be substituted for the professional experience.
Knowledges, Skills, and Abilities:
Thorough knowledge of meteorology with emphasis on the relationship of conditio
atmosphere to air pollution.
Thorough knowledge of surface and upper air analysis techniques, precipitation forec. xinci-
ples, and their application to air pollution control.
Thorough knowledge of information sources in meteorology.
Knowledge of standard meteorological equipment and the methods of applying it to meteorological
studies.
254
-------
Knowledge of air pollution control measures and procedures.
Knowledge of the hazards of and the safeguards essential to a program which: utilizes electrical
mechanical, and chemical equipment and hand and power tools; is performed in shops, laboratories,
field installations, and industrial and commercial facilities, and may be carried on under difficult
and dangerous conditions.
Knowledge of scientific methodology.
Some knowledge of the laws, rules, and regulations applicable in the air pollution control program.
Some knowledge of electronic data processing techniques.
Skill in the care and use of meteorological equipment.
Skill at analyzing documents, technical reports, and data.
Skill at making and recording scientific observations accurately.
Skill at developing and presenting studies and reports orally and in writing.
Skill at establishing and maintaining positive and productive relationships with associates and other
public and private officials.
Skill at performing mathematical calculations.
Skill at observing safety precautions and practices.
Ability to evaluate facility and equipment effectiveness.
Ability to implement and to develop recommendations concerning laws, rules and regulations.
Ability to represent the air pollution program to public and private officials and to the general
public.
Ability to interpret and implement complex oral and written instructions.
AIR POLLUTION CONTROL SPECIALIST I
DEFINITION
Under close supervision, makes beginning professional-level analyses and evaluations of air pollution
sources, problems, and permit plans; assists in complex surveillance, inspections, and investigations;
assists in the development of recommendations and in the conduct of negotiations for improvement
or modification of air pollutant conditions, initiation of enforcement actions, and provision of
professional and technical advice; may participate in special studies, may lead and assist in the
training of program personnel; learns to perform more difficult professional-level duties.
EXAMPLES OF DUTIES
Gathers and organizes information and data on air pollution sources and emissions and on the
effectiveness of program facilities, equipment, instrumentation, and technical processes; and assists
higher-level staff in analyzing and evaluating the information and data and in developing recommen-
dations for improving the air pollution control program.
Assists higher-level staff performing complex surveillance, inspections, and investigations.
Assists higher-level staff in evaluating requests for new and renewal operation and construction
permits by checking public records, reviewing plans and drawings, inspecting facilities and equip-
ment, and making reports and developing recommendations.
Reinspects public and private facilities and equipment to determine if air pollution operation and
construction permit requirements are being met.
Gathers and organizes for presentation basic data on violations of air pollution laws, rules, and
regulations and participates with higher-level staff in evaluating and developing recommendations
related to the violations.
Meets with public and private officials and assists higher-level staff in conducting negotiations and
providing professional and technical advice.
Discusses air pollution control with operators, managers, and owners of facilities which are actual or
potential sources of air pollution and seeks to secure voluntary compliance with air pollution laws,
rules, and regulations.
255
-------
Prepares for more responsible assignments by observation, study, on-the-job training, review of
reports, and participation in assignments of increasing difficulty.
May participate in special surveys and studies.
May appear at hearings or in court actions as a witness.
May participate in the training or program staff and representatives of other public agencies and
private organizations.
May lead lower-level employees.
May maintain a technical library resource.
Performs related duties as required.
MINIMUM QUALIFICATIONS
Education and Experience:
Graduation from an accredited college or university with a minor or its equivalent in engineering,
chemistry, or the physical or biological sciences,
OR
Any combination of education at an accredited college, university, or junior college and progres-
sively responsible technical or professional experience in air pollution control or a related environ-
mental program which totals four years,
OR
Four years of progressively responsible technical or professional experience in air pollution control
or a related environmental program.
Knowledges, Skills, and Abilities:
Some knowledge of the major types of sources of air pollution.
Some knowledge of basic statistical principles and procedures as applied in air pollution control
programs.
Some knowledge of information sources in air pollution control.
Some knowledge of the hazards of and the safeguards essential to a program which: utilizes elec-
trical, mechanical, and chemical equipment and hand and power tools; is performed in shops,
laboratories, field installations, and industrial and commercial facilities; and may be carried on
under difficult and dangerous conditions.
Some skill in the care and use of instruments.
Ability to analyze and evaluate documents, technical reports, and data.
Ability to develop and present studies and reports.
Ability to establish arid maintain positive and productive relationships with fellow workers, supe-
riors, and other public and private individuals.
Ability to evaluate facilfty and equipment effectiveness.
Ability to perform basic mathematical calculations.
Ability to understand and implement laws, rules, and regulations.
Ability to understand and follow complex oral and written instructions.
Ability to work under difficult and dangerous conditions including temperature extremes, heights,
and fumes.
Ability to observe safety precautions and practices.
256
-------
AIR POLLUTION CONTROL SPECIALIST II
DEFINITION
Under general supervision, with technical latitude, functions as a professional-level program repre-
sentative; conducts complex inspections and investigations of reported violations; analyzes and
evaluates air pollution sources, problems, and permit plans; develops recommendations and nego-
tiates improvements or corrective actions; initiates enforcement actions; provides professional and
technical advice; plans and conducts special studies; assists in planning the air pollution control
program; leads and trains program personnel.
EXAMPLES OF DUTIES
Represents the air pollution control program in discussions and meetings with public and private
officials involving the identification, control, and reduction of air pollutants.
Negotiates with operators, managers, and owners of facilities which are actual or potential sources
of air pollution to secure voluntary correction or improvement of the pollutant condition; provides
technical advice and makes recommendations regarding facilities, equipment, and processes; and
issues warnings of possible legal action.
Performs complex or difficult field surveillance, facility and equipment inspection and reinspection,
and complaint investigation.
Analyzes and evaluates new or amended laws, rules, and regulations; data on air pollution sources
and emissions; and the effectiveness of program facilities, equipment, instrumentation, and tech-
nical processes and develops recommendations for improving the air pollution control program.
Analyzes and evaluates requests for new and renewal permits for the construction and operation of
pollutant-emitting facilities and equipment and makes recommendations regarding action on the
requests.
Gathers, correlates, and evaluates data on violations of air pollution laws, rules, and regulations and
provides program management with recommendations on the initiation of legal action.
Implements emergency episode procedures.
Provides technical assistance to employees engaged in installing, operating, calibrating, and per-
forming field maintenance on air sampling instruments and equipment; initiates, evaluates, and
makes recommendations regarding requests for maintenance services; makes recommendations
regarding needs for new and additional instruments and equipment.
Trains program staff and representatives of other public agencies and private organizations in the
identification, control, and reduction of air pollutants.
Appears at hearings and in court actions as an expert; and explains and illustrates air pollution data,
equipment, instrumentation, and technical processes.
Performs special surveys and studies.
Analyzes data and makes recommendations as to air sampling site locations, facility type, and
necessary equipment and instrumentation.
Prepares reports and studies for presentation to management and for publication.
Leads, and may supervise, lower-level employees.
Provides basic data for the budget.
Performs related duties as required.
257
-------
MINIMUM QUALIFICATIONS
Education and Experience:
Graduation from an accredited college or university with a minor or its equivalent in engineering,
chemistry, or the physical or biological sciences, and one year of progressively responsible profes-
sional experience in air pollution control or a related environmental program,
OR
Any combination of education at an accredited college, university, or junior college and progres-
sively responsible technical or professional experience in air pollution control or a related environ-
mental program which totals five years and includes at least one year of professional experience,
OR
Five years of progressively responsible technical or professional experience in air pollution control
or a related environmental program which includes at least one year of professional experience.
Substitution:
Successful graduate study in engineering, science, public health or administration, or a related
environmental field may be substituted for the professional experience.
Knowledges, Skills, and Abilities:
Knowledge of the principles and practices essential to the identification, control and reduction of
air pollution.
Knowledge of the hazards of and the safeguards essential to a program which utilizes electrical,
chemical, and mechanical equipment and hand and power tools; is performed in shops, laboratories,
field installations, and industrial and commercial facilities; and may be carried on under difficult
and dangerous conditions.
Knowledge of information sources in air pollution control.
Knowledge of the major types of sources of air pollution.
Some knowledge of the laws, rules, and regulations applicable in the air pollution control program.
Some knowledge of statistical principles and procedures as applied in air pollution programs.
Skill at analyzing documents, technical reports, and data.
Skill at developing and presenting studies and reports orally and in writing.
Skill at establishing and maintaining positive relations with associates and other public and private
individuals.
Skill at performing basic mathematical calculations.
Skill at observing safety precautions and practices.
Ability to evaluate facility and equipment effectiveness.
Ability to develop recommendations concerning and to implement laws, rules, and regulations.
Ability to represent the air pollution control program to public and private officials and the general
public.
Ability to work under difficult and dangerous conditions including temperature extremes, heights,
and fumes.
Ability to interpret and implement complex oral and written instructions.
258
-------
AIR POLLUTION CONTROL INSPECTOR I (TRAINEE)
DEFINITION
Under close supervision, following detailed directions, performs routine field surveillance, facility
and equipment inspection, and complaint investigation and learns to perform more responsible tasks
by observing and assisting higher-level staff and participating in training.
EXAMPLES OF DUTIES
Performs routine field surveillance, noting air pollution sources and reporting locations, and ob-
serves and assists higher-level staff on complex field surveillance. ,
Performs routine facility and equipment inspection, reports findings, and observes and assists
higher-level staff on complex inspection.
Performs initial complaint investigation of a routine nature, reporting on situational observations
and on the statements of complainants and other involved parties, and observes and assists higher-
level staff on complex complaint investigation.
Maintains daily records and logs and makes oral and written reports on activities.
Operates vehicles used in field work.
Prepares for higher-level tasks by reading journals, articles, and releases on air pollution control and
through participating in training.
Performs related duties as required.
MINIMUM QUALIFICATIONS
Education and Experience:
Graduation from high school or the possession of a certificate of high school graduation equiva-
lency,
OR
Three years experience in air pollution control or a related environmental program.
Knowledges, Skills, and Abilities:
Some knowledge of basic chemical, electrical, and mechanical principles.
Ability to understand air pollution control rules and regulations.
Ability to discuss air pollution control problems with fellow workers, superiors, and other public
and private individuals.
Ability to maintain positive and productive relationships with associates and other public and
private individuals.
Ability to perform arithmetic computations.
Ability to understand and carry out verbal and written directions.
Ability to understand and apply safety precautions.
Ability to work under difficult and dangerous conditions including temperature extremes, heights,
and fumes.
Ability to maintain technical and administrative records.
Ability to operate vehicles used for field work.
259
-------
AIR POLLUTION CONTROL INSPECTOR II
DEFINITION
Under supervision, following general technical directions, performs field surveillance, facility and
equipment inspection, and complaint investigation; may assist professional staff conducting special
studies; and may lead and assist in the training of lower-level staff.
EXAMPLES OF DUTIES
Performs field surveillance of air pollution and documents the sources, quantity, and density of the
air pollution.
Performs facility and equipment inspection, noting level of operational effectiveness of air pollution
control devices, recording observations and data, and reporting on inspection findings; may make
recommendations for corrective actions.
Investigates complaints through observing air pollution conditions, interviewing complainants and
owners and operators of allegedly-polluting equipment and facilities, and inspecting equipment and
facility operations.
Develops detailed reports on complaint investigations together with recommendations as to cor-
rective actions needed.
Prepares oral and written reports of activities.
Provides assistance to, and may make work assignments to and lead, lower-level employees.
Operates, and performs the daily maintenance on, vehicles used for field work.
Maintains an effective relationship with representatives of public and private agencies and organiza-
tions.
Maintains and improves personal level of technical competence through reading and training.
May attend air pollution control hearings to present data and may be called as a witness in court
cases.
May work independently on specialized assignments.
May assist professional staff in conducting special studies.
May assist in the training of lower-level employees.
Performs related duties as required.
MINIMUM QUALIFICATIONS
Education and Experience:
Graduation from an accredited junior college
OR
Graduation from high school or the possession of a certificate of high school graduation equivalency
and at least one year of progressively responsible experience in air pollution control or a related
environmental program assisting in field surveillance, facility and equipment inspection, and com-
plaint investigation,
OR
Four years of progressively responsible experience in air pollution control or a relatea environ-
mental program which includes at least one year assisting in field surveillance, facility, and equip-
ment inspection, and complaint investigation.
260
-------
Knowledges, Skills, and Abilities:
Some knowledge of the principles of operation of air sampling instruments and equipment.
Some knowledge of technical terminology in air pollution and related environmental fields.
Some knowledge of the hazards of and the safeguards essential to using electrical, mechanical, and
chemical equipment and hand and power tools.
Skill at performing arithmetic computations.
Ability to operate air sampling instruments and equipment.
Ability to understand and interpret air pollution control laws, rules, and regulations.
Ability to discuss air pollution control problems with fellow workers, superiors, and other public
and private individuals.
Ability to maintain positive and productive relationships with associates and other public and
private individuals.
Ability to maintain technical and administrative records.
Ability to work under difficult and dangerous conditions including temperature extremes, heights,
and fumes.
Ability to operate vehicles used for field work.
Ability to learn to:
- Work independently on specialized assignments;
- Evaluate technical processes and procedures and to develop
recommendations for improvement;
- Communicate orally effectively;
- Assist higher-level staff engaged in training activities.
AIR POLLUTION CONTROL INSPECTOR III
DEFINITION
Under general supervision, with technical latitude, performs field surveillance, facility and equip-
ment inspection, and complaint investigation; assists professional staff conducting special studies;
and leads and trains lower-level staff.
EXAMPLES OF DUTIES
Performs field surveillance, facility and equipment inspection, and complaint investigation.
Works independently on specialized assignments.
Develops and presents recommendations as to new or different air pollution control processes and
procedures.
Maintains files on daily activities including records of surveillances, investigations, and inspections.
Develops and presents oral and written reports together with recommendations.
Leads, and may supervise, lower-level employees.
Attends air pollution control hearings, presents evidence and data, and testifies as a witness in court
cases.
Assists in the training of lower-level employees and other personnel.
Assists professional staff conducting special studies.
Maintains and promotes effective personal relationships with public and private officials, agencies,
and organizations.
Discusses air pollution — its causes, impact, and control — with public and private officials, agencies,
and organizations in the course of field activities.
Operates, is responsible for the daily maintenance of, and initiates requests for repair and main-
tenance of vehicles used for field work.
May make recommendations regarding new and additional equipment.
Performs related duties as required.
261
-------
MINIMUM QUALIFICATIONS
Education and Experience:
Graduation from an accredited junior college and one year of progressively responsible experience
in air pollution control or a related environmental program performing field surveillance, facility
and equipment inspection, and complaint investigation,
OR
Graduation from high school or the possession of a certificate of high school graduation equivalency
and at least two years of progressively responsible experience in air pollution control or a related
environmental program performing field surveillance, facility and equipment inspection, and com-
plaint investigation,
OR
Five years of progressively responsible'experience in air pollution control or a related environmental
program which includes at least two years performing field surveillance, facility and equipment
inspection, and complaint investigation.
Knowledges, Skills, and Abilities:
Knowledge of the principles of operation of air sampling instruments and equipment.
Knowledge of technical terminology in air pollution and related environmental fields.
Knowledge of the hazards of and the safeguards essential to using electrical, mechanical, and
chemical equipment and hand and power tools.
Knowledge of air pollution control laws, rules, and regulations which affect field surveillance,
facility and equipment inspection, and complaint investigation.
Some knowledge of administrative principles and practices.
Some knowledge of training principles.
Some knowledge of basic principles of leadership and supervision.
Skill at performing surveillance, inspection, and investigation activities.
Skill at operating air sampling instruments and equipment.
Skill in maintaining positive and productive relationships with associates and other public and
private individuals.
Skill at performing arithmetic computations.
Skill at communicating orally.
Ability to evaluate technical processes and procedures and to develop recommendations for im-
provement.
Ability to analyze documents, reports, and plans.
Ability to discuss air pollution control problems with fellow workers, superiors, and other public
and private individuals.
Ability to present evidence and data and to testify as a witness in court cases.
Ability to work independently on specialized assignments.
Ability to assist higher-level staff engaged in training activities.
Ability to work under difficult and dangerous conditions including temperature extremes, heights,
and fumes.
Ability to maintain technical and administrative records.
Ability to operate vehicles used for field work.
262
-------
AIR POLLUTION CONTROL TECHNICIAN I (TRAINEE)
DEFINITION
Under close supervision, following detailed directions, performs routine technical tasks in the labor-
atory, field, and shop; assists higher-level staff installing, operating, calibrating, modifying, main-
taining, and repairing a variety of equipment and instruments used in the air pollution control
program; and participates in training.
EXAMPLES OF DUTIES
Performs routine technical tasks in support of higher-level staff in the laboratory, field, and shop.
Observes and assists higher-level staff in laboratory, field, and shop:
- Installing, operating, calibrating, modifying, maintaining, ,
and repairing air sampling, meteorological, and laboratory
equipment and instruments;
- Measuring, testing, and analyzing air pollutants;
- Stack sampling;
- Source and emission inventorying;
- Recording, tabulating, charting, and graphing data;
- Fabricating field shelters for equipment;
- Keeping files and records on activities;
- Operating and maintaining field vehicles.
Drives, loads, and unloads vehicles used in field work.
Performs related duties as required.
Prepares for higher-level technical tasks by reading journals, articles, and releases on air pollution
control and through participation in technical training.
MINIMUM QUALIFICATIONS
Education and Experience:
Graduation from high school or the possession of a certificate of high school graduation equiva-
lency,
OR
Three years of experience in air pollution control or a related environmental program.
AIR POLLUTION CONTROL TECHNICIAN I (TRAINEE)
Knowledges, Skills, and Abilities:
Some knowledge of basic chemical, electrical, and mechanical principles.
Some knowledge of the kinds and uses of hand and power tools.
Ability to operate and perform routine field maintenance of air sampling equipment and instru-
ments.
Ability to discuss technical problems with fellow workers, superiors, and other public and private
individuals.
Ability to maintain positive and productive relationships with associates and other public and
private individuals.
263
-------
Ability to perform arithmetic computations.
Ability to understand air pollution control laws, rules, and regulations.
Ability to understand and carry out verbal and written directions.
Ability to maintain technical and administrative records.
Ability to work under difficult and dangerous conditions including temperature extremes,
heights, and fumes.
Ability to understand and apply safety precautions.
Ability to operate vehicles used for field work.
AIR POLLUTION CONTROL TECHNICIAN II
DEFINITION
Under supervision, following general directions, installs, operates, calibrates, modifies, maintains,
and repairs a variety of equipment and instruments used in the air pollution control program; and
may lead and assist professional staff conducting special studies; and may lead and assist in the
training of lower-level staff.
EXAMPLES OF DUTIES
Installs, operates, calibrates, modifies, maintains, and repairs air sampling equipment.
Conducts stack sampling activities and gathers data for source and emission inventories.
Performs routine tests and measurements including standardized analyses of air pollutants.
Records, tabulates, charts and graphs data obtained from air sampling equipment, meteorological
instruments, and laboratory analyses.
Assists higher-level staff designing or modifying instruments and equipment.
Fabricates field shelters and facilities and assists in the placement of air sampling and meteorological
instruments and equipment.
Assists higher-level staff reviewing and evaluating engineering proposals and drawings for new and
modified industrial processes and facilities as actual or potential sources of air pollution.
Assists higher-level staff conducting the more complex tests, measurements, and analyses.
Prepares oral and written reports of activities.
Provides technical assistance to, and may make work assignments to and lead, lower-level em-
ployees.
Operates, and is responsible for the daily maintenance on, vehicles used for field work.
Maintains an effective relationship with representatives of public and private agencies and organiza-
tions.
Maintains and improves personal level of technical competence through reading and training.
May work independently on specialized assignments.
EXAMPLES OF DUTIES
May assist professional staff conducting special studies.
May attend air pollution control hearings to present data and may be called as a witness in court
cases.
May assist in the training of lower-level employees.
Performs related duties as required.
264
-------
MINIMUM QUALIFICATIONS
Education and Experience:
Graduation from an accredited junior college with at least 12 semester hours in engineering, chem-
istry, or the physical or biological sciences,
OR
Graduation from high school or the possession of a certificate of high school graduation equivalency
and at least one year of progressively responsible experience in air pollution control or a related
environmental or other program assisting in the installation, operation, calibration, modification,
maintenance, and repair of equipment and instruments, '
OR
Four years of progressively responsible experience in air pollution control or a related environ-
mental or other program which includes at least one year assisting in the installation, operation,
calibration, modification, maintenance, and repair of equipment and instruments.
Knowledges, Skills, and Abilities:
Knowledge of technical terminology in air pollution and related environmental fields.
Knowledge of basic chemical, electrical, and mechanical principles.
Knowledge of the kinds and uses of hand and power tools.
Some knowledge of the basic technical practices and standized procedures utilized in stack sampling
and source and emission inventorying.
Some knowledge of the principles of operation and repair of air sampling instruments and equip-
ment.
Skill at performing arithmetic computations.
Some knowledge of the hazards of and the safeguards essential to using chemical, electrical, and
mechanical equipment and hand and power tools.
Ability to operate and repair air sampling instruments and equipment.
Ability to discuss technical problems with fellow workers, superiors, and other public and private
individuals.
Ability to maintain positive and productive relationships with associates and other public and
private individuals.
Ability to understand and interpret air pollution(control laws, rules, and regulations.
Ability to work under difficult and dangerous conditions including temperature extremes, heights,
and fumes.
Ability to maintain technical and administrative records.
Ability to operate vehicles used for field work.
Ability to I earn to:
- Work independently on specialized assignments;
- Evaluate technical processes and procedures and to make
recommendations for improvement;
- Assist higher-level staff engaged in training activities.
265
-------
AIR POLLUTION CONTROL TECHNICIAN III
DEFINITION
Under general supervision, with technical latitude, performs a broad range of technical duties of
varying complexity in laboratory, shop, and field; assists professional staff conducting special
studies; and leads and trains lower-level staff.
EXAMPLES OF DUTIES
Performs complex installations, operations, calibration, maintenance, and repair of air sampling
equipment.
Performs stack sampling and the gathering of data for source and emission inventories.
Performs complex tests, measurements, and analyses of air pollutants using standardized proce-
dures.
Fabricates field shelters and facilities for air sampling equipment.
Sites and places air sampling and meteorological instruments and equipment as directed.
Assists in the review of engineering proposals and drawings for new or modified industrial processes
and facilities and may develop recommendations.
Works independently on specialized assignments.
Leads, and may supervise, lower-level employees.
Prepares oral and written reports of activities and makes recommendations.
Assists in the training of lower-level employees and other personnel.
Assists professional staff conducting special studies.
Attends air pollution control hearings, presents evidence and data, and testifies as a witness in court
cases.
Maintains and promotes effective personal relationships with associates and other public and private
individuals.
Operates, is responsible for the daily maintenance of, and initiates requests for repair and main-
tenance of vehicles, instruments, and equipment.
Performs related duties as required.
MINIMUM QUALIFICATIONS
Education and Experience:
Graduation from an accredited junior college with at least 12 semester hours in engineering, chem-
istry, or the physical or biological sciences and at least one year of progressively responsible
experience in air pollution control or a related environmental or other program installing, operating,
calibrating, modifying, maintaining, and repairing equipment and instruments,
OR
Graduation from high school or the possession of a certificate of high school graduation equivalency
and at least two years of progressively responsible experience in air pollution control or a related
environmental or other program installing, operating, calibrating, modifying, maintaining, and re-
pairing equipment and instruments,
OR
Five years of progressively responsible experience in air pollution control or a related environmental
or other program which includes at least two years installing, operating, calibratiang, modifying,
maintaining, and repairing equipment and instruments.
266
-------
Knowledges, Skills, and Abilities:
Knowledge of technical terminology used in air pollution and related environmental fields.
Knowledge of basic chemical, electrical, and mechanical principles.
Knowledge of the air pollution control laws, rules, and regulations which affect stack sampling and
source and emission inventorying.
Knowledge of the kinds and uses of hand and power tools.
Knowledge of the basic technical practices and standardized procedures utilized in stack sampling
and source and emission inventorying.
Knowledge of the principles of operation and repair of air sampling instruments and equipment.
Knowledge of the hazards of and the safeguards essential to using chemical, electrical, and me-
chanical equipment and hand and power tools.
Some knowledge of administrative principles and practices.
Some knowledge of training principles.
Some knowledge of basic principles of leadership and supervision.
Skill at stack sampling and gathering data for source and emission inventorying.
Skill at performing arithmetic computations.
Skill at working with hand and power tools.
Skill at operating and repairing air sampling instruments and equipment.
Ability to evaluate technical processes and procedures and to develop recommendations for im-
provement.
Ability to analyze documents, reports, and plans.
Ability to discuss technical problems with fellow workers, superiors, and other public and private
individuals.
Ability to maintain positive and productive relationships with associates and other public and
private individuals.
Ability to present evidence and data and to testify as a witness in court cases.
Ability to work independently on specialized assignments.
Ability to assist higher-level staff engaged in training activities.
Ability to work under difficult and dangerous conditions including temperature extremes, heights,
and fumes.
Ability to maintain technical and administrative records.
Ability to operate vehicles used for field work.
AIR POLLUTION CONTROL AIDE 1
DEFINITION
Under close supervision, following detailed instructions, serves as a helper to a higher-level employee
and learns to perform routine tasks.
EXAMPLES OF DUTIES
Observes and helps a higher-level employee working on a task such as:
- Analyzing air pollutants;
- Calibrating air sampling equipment;
- Keeping daily records;
- Maintaining vehicles.
Loads, unloads, and moves equipment, instruments, and supplies.
Unpacks and stores equipment, instruments, and supplies.
Collects, cleans, and distributes laboratory glassware.
Keeps working areas neat and clean.
Through training, observation of higher-level employees, and practice, develops a basic knowledge
and understanding of procedures for the tasks to which assigned.
Learns safe praci'oes.
Performs related duties as required.
267
-------
MINIMUM QUALIFICATIONS
Education and Experience:
None
Knowledges, Skills, and Abilities:
Ability to help higher-level employees performing various laboratory, shop, and office tasks.
Ability to learn to perform routine and repetitive tasks.
Ability to learn to use basic hand and power tools.
Ability to work cooperatively and productively with fellow workers.
Ability to follow safety precautions.
Ability to understand and follow simple written and oral directions.
Ability to read and write at the eighth grade level.
Ability to perform addition and subtraction.
Ability to communicate orally.
AIR POLLUTION CONTROL AIDE II
DEFINITION
Under close supervision, performs routine tasks as a helper to higher-level employees and learns to
perform more difficult tasks requiring some technical knowledge and skill.
EXAMPLES OF DUTIES
Observes and helps higher-level employees performing a variety of air pollution control duties in
laboratory, shop, field, and office, such as:
- Surveillance, inspection, and complaint investigation;
Testing and analyzing air pollutants;
-Stack sampling;
- Source and emission inventorying;
- Installing, operating, and maintaining air sampling equipment;
- Operating and maintaining field vehicles;
- Keeping files and records on activities.
Loads, unloads, and moves equipment, instruments, and supplies.
Records receipt of, unpacks, and stores equipment, instruments, and supplies.
Decontaminates and sterilizes laboratory glassware.
Maintains working areas in a safe, neat, and clean condition.
Through training, observation of higher-level employees, and practice, develops a basic technical
knowledge, understanding of practices and procedures, and some skill in performing the routine
types of duties to which assigned.
Learns safe practices and safety principles.
Performs related duties as required.
MINIMUM QUALIFICATIONS
Education and Experience:
One year of experience in air pollution control or a related environmental program.
268
-------
Knowledges, Skills, and Abilities:
Ability to perform routine and repetitive tasks as assigned.
Ability to learn to assist professional, administrative, and technical staff as needed.
Ability to acquire a basic technical vocabulary and understanding of basic technical practices and
procedures.
Ability to learn to use hand and power tools.
Ability to develop skill in performing assigned tasks.
Ability to work cooperatively and productively with fellow workers.
Ability lo learn and apply safely precautions.
Ability to understand and follow simple written and oral directions.
Ability to read and write at the eighth grade level.
Ability to perform addition and subtraction.
Ability to communicate orally and in writing.
269
-------
Appendix C
Summary of the NY/NJ
Air Pollution Abatement
Activity Monitoring Program
271
-------
Appendix C
Summary of the NY/NJ Air Pollution
Abatement Activity Monitoring Program
The objectives of the New York-New Jersey project were to demonstrate
the geographical distribution of sulfur dioxide and carbon monoxide, to
document interstate transport of pollutants, to compare observed concen-
trations with levels having an impact on health and welfare, and to
delineate probable sources. Principal phases of the project were the
air-quality-meteorological network and the emissions inventory.
The emissions inventory estimated emissions from a few large sources
and from a host of small sources. Sources were characterized as fossil -
fuel combustion for power generation and space heating, vehicles, refuse
disposal by open burning or incineration, and industrial processes. The
emissions were located and source types described as points or areas.
They were summarized by political divisions, census tracts, and grids.
The agreements among the agencies, unilaterial actions already
taken by the agencies, and the Federal procedures to gather manpower
and to procure equipment placed restraints upon the network design.
The more significant factors were:
(a) An abatement conference would be convened in late 1966,
(b) The initial actions would concern carbon monoxide and sulfur
compounds,
(c) New York had several sampling sites in operation,
(d) New Jersey had already negotiated for most of its sites,
(e) Sampling equipment to be used by the Federal personnel would
not be available before April, and some not before June 1966.
272
-------
From these factors, additional and necessary considerations became
apparent:
(f) The time schedule confined the sampling to the summer months;
(g) Industrial activities were the predominant sulfur dioxide
sources in summei—sulfur dioxide emissions from residential
space heating being at a minimum;
(h) Most sulfur dioxide would be emitted from stationary sources
whose locations were fixed and generally known; most carbon
monoxide would be emitted from automobiles, a mobile source;
(i) Interstate transport of emissions could be demonstrated and
its rate ascertained more readily, if the sampling network
were:
(1) Oriented so as to be consistent with the prevailing
direction of air flow during the summer;
(2) Oriented with respect to the sulfur dioxide sources
whose locations were known; and
(3) Designed to be compatible with existing sampling
locations.
An analysis of wind directions at the four New York area weather-
observing sites of the U.S. Weather Bureau indicated that summertime
air flow was from the southwest more than one-third of the time with no
other direction being more frequent.
From a map of the 17-county metropolitan area, an estimate of the
major centers of sulfur dioxide emissions, and the locations of existing
sampling stations, it was apparent that the axis of a sampling network
could be placed parallel to the prevailing summertime air flow, through
273
-------
several established sampling sites, and through the area where most of
the sulfur dioxide was emitted.
For convenience in analyzing data when winds were not precisely
parallel to the axis of the network, radials with their origin near
Raritan Bay were constructed 22-1/2° from the axis. Additional
sampling stations were placed on the radials. Preferred locations were
at the intersections of radials and minor axes constructed normal to the
primary axis and through established sampling stations.
The resultant aerometric surveillance network is described in the
following text extracted from Air Quality Monitoring Protocol for the
New York-New Jersey Air Pollution Abatement Activity:
"Air Quality Monitoring Network
"The United States Public Health Service proposed a design
of air quality monitoring equipment to study interstate
pollutants between New York and New Jersey. The design
consists of an inner portion (or core network) ringed by
two concentric arcs of lead peroxide sulfation candles.
[Figure C-l shows geographical location.]
"Air Monitoring Stations
"The core network will be oriented on a 45°-225° axis through
a monitoring station in Bayonne, New Jersey. This axis also
passes through the monitoring stations in Central Park on
Manhattan Island, and near the centers of gravity of the two
largest industrial pollution regions in the study area,
i.e., the north-eastern New Jersey (Arthur Kill) and East
River regions of New York. Assuming the areas of major
industrial pollution are located along the East River and
west of Arthur Kill, the sampling station in Bayonne is
approximately midway between the two. The distance from
Bayonne to Central Park is considered a unit distance.
Two additional stations will be located on the axis, one
at three unit distances 'downwind' from Bayonne (New Roche!le,
N. Y.), and another 'upwind1 three unit distances from Bayonne
(Raritan Depot, N. J.). Automatic stations will be placed
on either side of the axis, located insofar as practicable,
to form with stations on the axis, three Tines perpendicular
to the axis. The stations west of the axis from north to
south are Fair Ridge, Neward, and Roselle. East of the
274
-------
tfffffflff
Pollution tomoled
S02. CO. NOX, HC. Ox
S02. CO, NOX, HC. Ox. Aldehydei
SOj,CO.NOx,HC (occo.lonolly olhen)
S02 (C02)
S02. CO
S02
S02 (Lead peroxide candle)
Wind data
New J«r»ey Oept. of Health
New York State Air Pollution Control Board
New York City Oept. of Air Pollution Control
New Rochelle Oept. af Public Health
New York University
U. S. Public Health Service
O ALBERT EIKSTEIIIHOSP.imi
H UNIVERSITY HC
FAIRVIEI PHS-
CEHTRAL PAR
USWB U. S. Weather Bureau (tor weather data
only)
lOTClUSIB
IK
OJERSET CITT KTU
KEWM.«J
I
«EtAlH AIRPORT IBfB-j-
ROSELLE P
ARCS Ol
LEAD PEROXIDE
ANCORA CONTROL STATION
APPROX. 80 &M. ON BEARING
2\0f FROM BAYONNE STATIC
Figure C-l. Location of air monitoring sites
in the N.Y.-N.J. Abatement Activity.
275
-------
axis are 121st Street Lab., Fort Hamilton, and Willowbrook. A
station at Ancora, N. J., would serve as a control background
station. Five additional New York University stations will
provide sulfur dioxide data. They are Passaic, Albert Einstein,
Jersey City, Prospect Park, and JFK Airport. This deployment
provides a reasonably wide sector coverage when air flow is
from southwest and northeast quadrants, and provides data on
variations in concentrations with distance when winds are from
southeast and northwest quadrants.
"Lead Peroxide Sulfation Candles
"Two arcs of lead peroxide sulfation candles will ring this
core network and will be centered on the Bayonne station.
The inner arc will have a radius of 15 miles and will have
lead candles stationed every 7-1/2° or about 2 miles. The
outer arc will have a radius of 30 miles and will have its
candles located every 15° or about 8 miles. In addition,
each station in the core network will have a lead candle to
provide correlation information between continuous automative
analyzers, sequential samplers, and candle sampling. A
total of 70 candles will be utilized; 54 in the two arcs and
16 at the air monitoring stations."
276
-------
Appendix D
Air Pollution Control Agency Manpower Model
277
-------
Appendix D
Air Pollution Control Agency Manpower Model
The APCA Manpower Model has 14 sets of basic predictors and manpower
factors to be used in estimating the manpower needs for 14 designated
agency functions (see Table D-l). Several of these functions directly
involve the technical services group: operation of the monitoring
network, special studies, data processing, source testing, instrument
calibration and maintenance, and analytical laboratory operations.
Other functions are indirectly related such as staff training, agency
policy, public relations, administration, and clerical support. The
number of man-years required for a given function is the product of
the basic predictor times the particular manpower factor. For example,
the basic predictor for operation of the monitoring network is the
number of monitors required, based on Federal Register specifications.
The manpower factor is 0.1 man-year per unit predictor. The basic
predictor for operation of the laboratory is equivalent to the sum of
the manpower required for ambient monitoring, source testing, and
special studies. The laboratory manpower factor is 0.35 man-year per
unit predictor. The manpower required to conduct special studies is
equivalent to the manpower needed for the four key agency functions
times 0.06; the manpower required for source testing is equivalent
to the sum of the manpower needs for scheduled inspections and permit-
system operation times 0.10.
To demonstrate the use of the model, the manpower requirements
will be determined below for a region with the following characteristics:
278
-------
Table D-l. BASIC PREDICTORS AND MANPOWER FACTORS FOR MANPOWER ESTIMATES
Functi on
Predi ctor
Manpower
factor
ro
»vl
10
1. Operation of monitoring
network
2. Scheduled inspections
3. Complaints and field patrol
4. Operation of permit system
5. Policy, public relations,etc.
6. Staff training
7. Special field studies
8. Emission estimates
9. Special engineering
activities
10. Administrative and clerical
support
11. Data processing
12. Source testing
13. Instrument calibration and
maintenance
14. Laboratory operations
No. of instruments (from
Federal Register
No. of manufacturing
establishments
1000
Population
100,000
Capital expenditures
for new plants
100,000,000
MY 1,2,3,4
MY 1,2,3,4
MY 1,2,3,4
MY 1,2,3,4
MY 1,2,3,4
MY 1,2,3,4
MY 1,2,3,4
MY 2,4
MY 1,7
MY 1,7,12
0.1 MY/unit predictor
2,8 MY/unit predictor
0.7 MY/unit predictor
9.7 MY/unit predictor
0.22
0.12
0.06
0.-05
0.06
0.50
0.09
0.10
0,25
0.35
Code: MY - Man-year.
-------
Table D-2. SUMMARY OF MAN-YEAR ESTIMATES FOR EXAMPLE AGENCY
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
Functi on
Operation of monitoring
network
Schedule inspections
Complaints and field patrol
Operation of permit system
Subtotal
Policy, public relations, etc.
Staff training
Special field studies
Emission estimates
Special engineering
activities
Administrative and clerical
support
Data processing
Source testing
Instrument calibration
and maintenance
Laboratory operations
Total
Predi
74.
7.
24.
2.
68.
68.
68.
68.
68.
68.
68.
43.
11.
15.
ctor
15
43
46
3
3
3
3
3
3
3
8
5
9
Manpower
factor
0.
2.
0.
9.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
1
8
7
7
22
12
06
05
06
50
09
10
25
35
Calculated
man-years
7
20
17
23
(68
15
8
4
3
4
34
6
4
2
5
156
.4
.0
.1
.8
•3)
.0
.2
.1
.4
.1
.1
.1
.4
.9
.6
.2
280
-------
(a) Number of monitors: 74;
(b) Population: 24.43 x 105;
(c) Number of manufacturing establishments: 7.15 x 10 ;
(d) Capital expenditures: $2.46 x 10 .
Direct application of the predictors listed above and the
predictors and manpower factors listed in Table D-l results in a total
estimated staff of 156.2 man-years as detailed in Table D-2. When
t
compared to the population served, this estimated calls for a staff
of 6.3 man-years/I00,000 population.
281
-------
Appendix E
Interagency Contracts for
Technical Services—A Checklist
283
-------
Appendix E
Interagency Contracts for
Technical Services—A Checklist
E.I Introduction
Types of agreements can range from a simple agreement to provide
technical services for five or six specific hi-vols to a complex arrange-
ment whereby a complete program including day-to-day monitoring, episode
monitoring, data handling, and input and source testing is contemplated.
This checklist, coupled with the text in the body of this report, will
provide the reader with sufficient information to insure that the agency's
attorney can draw up a workable agreement. The agency will benefit if
its attorney is knowledgable of the workings of an air pollution control
agency.
Since agency personnel often work out preliminary agreements prior
to involving an attorney, this checklist also covers facets of contract-
ing common to all agreements. This enables preliminary agreements to
be made in a manner that enables the parties to know where they stand.
For this reason, two checklists are provided—one "legal" and one
"technical."
E.2 Legal Checklist
(a) Authority to Contract. Since a technical services contract
involves governmental entities, it is important to verify that
both parties are authorized by the State constitution,
statutes, and/or local ordinances to enter into the contract.
Note that there is a difference between providing a service
and receiving a service. It is not uncommon for a governmental
284
-------
agency to have the authority to contract to receive services
but lack authority to provide services.
(b) Consideration. An agreement is not binding unless there is
consideration. Both parties must be obligated to give some-
thing. If the agreement merely provides that one agency is
to provide services to another without any kind of recompense,
there is no binding contract.
i
(c) Term of Contract. The agreement must be specific as to its
term. Is it to run from year to year? Is it to be auto-
matically renewable? Is its term indefinite as to termination?
The agencies' contract-making authority may also limit the
term of the agreement.
(d) Termination. Do the parties want a provision for orderly
unilateral termination? What happens to the equipment upon
termination? If unilateral termination is desirable, how
much notice should be given?
E.3 Technical Checklist
(a) Operations (Refer to Chapter 3.0). Are the services to cover
ambient monitoring? Source testing? For what pollutants?
i
Does it matter which sampling and analytical methods are used?
If so, specify method. (See also Chapter 8.0 in this regard.)
Who supplies the equipment? If both parties are to supply
equipment, list the equipment. Who maintains the equipment?
Who insures the equipment? How many tests are to be made
during a specific time period?
(b) Partition and Location (Refer to Chapter 4.0). Where are the
285
-------
laboratory facilities to be located? May they be moved at
the discretion of only one party? Is work to be shared? If
so, how? Is one party to pay the other for the services?
Who pays rent and utilities?
(c) Legal Considerations (Refer to Chapter 5.0). Is the testing
agency to furnish enforcement support? If so, specify that
proper methods shall be used to insure usefulness of a sample
as evidence. Testing agency should supply the report and
expert testimony to support tests if required. How is the
agency to be paid for this service?
(d) Management (Refer to Chapter 6.0). To render services, an
agency must have adequate manpower. Personnel must be
qualified. (See also Chapter 5.0 in this regard.) What are
test priorities, if any? Will recipient agency have voice in
determining priorities? Are tests to be made only upon
issuance of work order? May the laboratory subcontract work
to private firms? Such subcontracts may void contract if the
recipient agency lacks authority to contract with private
firms directly. (See also Chapter 9.0 in this regard.)
(e) Data Handling (Refer to Chapter 7.0). Are test results to be
used in a computer program? In what format? Is one party to
provide hardware for the other? Will technical services
include episode monitoring? How often is data to be reported?
286
-------
INDEX
Page Numbers^
A - Abatement Program 272
Accident Control 53, 209
Advancement in Grade 112
Air Quality Monitoring 29, 205
Air Quality Network 31, 205, 206
Air Quality Standards 43
Analysis Program 209
Analyst Training 182
Analytical Sensitivity 169
Analytical Variability 167
Ancillary Materials Quality Control 181
A.P.C.A. Manpower Model 111, 112, 278
Authority 73, 75
Automatic Sampling 126
B Bag Sampler Assembly 197
Basic Objectives 97
Basic Training 183
Budgeting: 102
Line Items 102
Operating Funds 103
Personnel Services 103
Ratio 103
Unreimbursed 102
C - Calibration 34, 207
Capability Benefits 121
Chemical Reactivity of Pollutants 59
Chemists Salary 114, 115
Collaborative Field Test 199
Collaborative Testing 163
Competent Staff 101
Complaint and Nuisance Analysis 213
Complaints 54
Contract Areas 202
Contract Checklist 284
Contract Mechanisms 214
Contract Planning and Management 217 to 221
Coordinating 105
Cost/Benefit Analysis 106, 120
D - Data Acquisition 142 to 148
Data Continuous Sampling 135, 136
Data Display 139
Data Flow 13° to 135
287
-------
INDEX (Continued)
Page Numbers
D - Data Handling Program 214
Data Input: 145
Magnetic Tape 145
Punched Cards 145
Telemetered 147
Data Intermittent Sampling 135
Data Records 135 to 142
Data Requirements 130
Definition of Inter-Laboratory 189
Determinate Error 165
Direct Labor Costs 122
E Education 112
Effects Analysis 213
Effects Network 213
Efficiency Studies 122-125, 129
Emergency Monitoring 52
Enabling Legislation 74
E.P.A. Standardization Training 159
Episode Authority 104
Episode Control 52
Equivalent Method 159
Evaluation of Laboratory Accuracy 170
Evaluation of Laboratory Daily Performance 171
Evaluation of Laboratory Precision 168
Expenses Operational 68
Expenses - Travel 67
F F-Ratio Test 171, 172
Field Personnel 124
Fuel Analysis 212
Fuels 56
6 - Gas Bubbler Cost 119
Gas Cylinders 197
Geographical: 65
Agencies 65
Program Criteria 65, 66
H - Health Laboratory 15
I Indeterminate Error 167
Imminent Health Hazard 209
Instructions for Methods Study 191, 193
288
-------
J
L
INDEX (Continued)
Instrument Evaluation
Instrument Quality Control
Interlaboratory Quality Control
Job Classifications
Jurisdictional Sample
Laboratory Control Chart
Laboratory:
Director (manager, chief, head)
Functions
Operations
Responsibilities
M -
On-Site Inspection
Proficiency Testing
Quality Assurance
Quality Control
Services
Soft-Ware
Standardization
Laboratory
Laboratory
Laboratory
Laboratory
Laboratory
Laboratory
Laboratory
Legal Acceptability
Legal Evidence
Legal Records
Liquid or Solid Samples
Local Laboratory Role
Logistics
Maintenance
Management Personnel
Mandel and Lashov Approach
Manpower (Model)
Manpower Factors
Metal Analysis
Meteorology
Method Evaluation
Development
Publication
Validation
Calibration
Method
Method
Method
Mobile
Van
Monitoring:
Air Quality
Networks Primary
Operation
Monitoring Expanded
Motor Vehicle Laboratory
Page Numbers
57
177
189
238
73, 75
173 to 177
2
2
7
3, 29
49, 65
161
162
151
151.
60
182
151
123
77
84
195
163
126
35
108
191
109.
110.
212
206
158
158
159
146
198
29
29
31
32
110
118
161
to 93
278
111
151
289
-------
INDEX (Continued)
Page Numbers
N - NBS 151
NERC 151
Networks Secondary 35
Networks Tertiary 36
Nuisances 54
0 - Organization: 20
E.P.A. (State) 20
Health Department 15
Separate Agency 24
Organizational Structure 98, 99
ORM 152
P - Permeation Tubes 197
Personnel Requirements 32, 109
Pesticide Analysis 212
Pollution Methodology 158
Position Descriptions 238
Precision and Accuracy 164
Priority Benefits 121
Program Analysis 105, 106
Proficiency 115
Program Evaluation 95
Program Execution 95
Program Planning 95, 96
Project Manager 100, 101
Protocol 39
Proposed Laboratory Quality Assurance Program 157
Purpose of Interlaboratory Tests 189
Q Quality Control Costs 184
Quality Control Function 151 to 157
Quality Control Importance 154
Quality Control Man Year 185
Quality Control Requirements 153
R - Reference Method 158
Regional Offices 159, 199
Reporting 107, 108
Routine Analysis 209
Ruggedness Testing 192
S - Salary 113
Sampling 31, 232
Sample - Legal 78
290
-------
INDEX (Continued)
Page Numbers
S - Sampling Legal Requirements 79, 80
Sampling Program 205
Sampling Station Space 117
Sampling Train Cost 118, 119
Service Facilities: 67
Communications 67
Expenses 68
Location 67
Political 68
Primary 66
Satellite 66
Technical 67
Travel 67
Short Term Ambient 208
Site Location 41, 232
Skill-Time Rating 164
Solvent Analysis 212
Source Emission Testing 49, 208
Space Guide 116, 117
Space Requirements 116, 117, 118
Specific Objectives 97
Specific Technical Service 108
Special Analysis 210
Standardization Training 159
Standard Method 152, 159
Stated Objectives 97
State Laboratory Standardization 160
Statewide Laboratory Survey 160
Sub-Par Performance 113
T - Technical Facilities ' 66
Technical Facility Location 67
Technical Functions 68, 69
Test Atmospheres 196
Toxicity Levels 210
Training 207
Training and Experience 112
Training Program 115
Types of Contracts 215 to 217
U - Uniformity of Methodology 158
V - Variance 172
Y - Youden Approach 189, 191
•tt O. S. GOVERNMENT PRINTING OFFICE! 1B72 746768/4129
291
------- |