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Data Reduction—"Time" Concept
The opacity readings recorded on Figure 4-8 should be summarized by completing
the items on the right hand side of Figure 4-9.
F. Source Inspection
After the visual observation has been made, whether from a location inside or out
side the plant operation, an inspection of the source that was evaluated, should be
made. To do this, the highest ranking official of the company, who is readily
available, should be contacted.
At all times during the inspection the inspector should maintain a business-like
relationship with company personnel. If requested by the company representative,
the inspector may give a brief discussion of the purposes of the opacity evaluation.
The inspector should noj under any circumstances indicate whether a violation
of the regulations was observed, and indeed at the time of the inspection a deter
mination of whether a violation was observed will not have been made, since the
information on Figures 4-8 or 4-9 has to be completed before such a determination
can be made.	'
During the inspection, information concerning the source should be obtained
from the company official. This information can be obtained by asking such ques-
tions as:
1.	Were the plant and the source of interest operating normally at the time the
evaluation was conducted?
2.	Are there any control devices associated with the source? Were they operating
properly?
3.	When were the source and its control device installed or modified?
Since an inspection report has to be written after the evaluation has been made,
the relevant information about the source should be collected and recorded in a
standard format. A data sheet similar to Figure 4-14 should be used to record this
information.
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Visible Emissions Evaluation Data Sheet
Observer:
Date:	
Company data
Company name:	
Company address:
Company contact:
Source data
Source identification: 	
Applicable regulation: 	
Operating rate: 	
Normal operating rate:	
Construction/modification date:
Control system data
Type: 	
Design efficiency:	
Installation date: 		
Comments:		
Figure 4-11. Inspection data sheet.
Telephone:
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Chapter 5
Onsite Inspection of Sources
ONSITE INSPECTION OF SOURCES
Goal
To teach good inspection methodology for inspection of the source premises, deci-
sion making, actions to be taken and documentation of the result thereof.
Objectives
At the end of this lesson, the student should be able to:
1.	State the definition of "on-site inspection."
2.	Define the purposes for which inspections are made.
3.	Differentiate between single and multi-purpose inspections.
4.	Explain preentry preparation.
5.	Explain the steps taken to gain entry.
6.	Describe the situation wherein a warrant may be necessary.
7.	Explain the proper procedure for conducting an interview.
8.	List the main points of source ownership identity.
9.	List the important points of inspection of the process or equipment.
10.	Identify the information to be supplied to the source.
11.	Write a notice of violation.
12.	Identify at least five essential points of an effective report.
13.	Identify the several ways of serving a notice of violation.
Selected Reading
Reference 4-APTD-1100 - Chapter 2 -IV, V, VI and VII. Chapter 4 IV, B 3,
4, 5.
Reference 9 —Communication for Justice Administration, Chapters 4, 6 and 7.
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ONSITE INSPECTION OF SOURCES
Introduction
The purpose of this chapter is to describe the principles of inspecting a source to
develop facts needed to determine compliance or noncompliance with a rule or
regulation. The method of obtaining information, making inspection of equip-
ment, gathering data and the decision making process (compliance or non-
compliance) is presented. The concluding actions and report writing are included.
Types of Inspections
An inspection of an air pollution emission source consists of entering a facility for
the purpose of obtaining information or collecting evidence.
A variety of inspections are conducted to gather evidence in relation to: an
observed offsite violation; followup of a previous inspection; a check on equipment
for construction permit, a cyclic operating permit, compliance plan status, or
obtaining source registration; complaint investigation; or providing owners and
operators with information on legal requirements.
Many inspections are conducted for a single purpose, such as checking to see
whether construction is continuing after a permit application has been denied.
Other inspections are comprehensive; that is, they are conducted to inspect and
gather information on all equipment and processes located within the facility.
The type of inspection relates to the reason for which the inspection is made.
The terminology is assigned for ease of communication.
A. Facility Inspection
The facility inspection is a comprehensive inspection made of all the equipment
and processes at one source premises. A source premises is one geographical loca-
tion such as Plant 1 or "Works," and may include one or more structures, or
operating areas. The emission points may be single or multiple, with multiple
sources numbering in the hundreds for large industrial complexes as refineries,
petro-chemical plants, steel mills, etc. A single complex source premises may be
subdivided into areas, each of which becomes a facility. Example: The open hearth
shop of a steel mill.
Facility inspections are sometimes referred to as "plant inspections," "source
inspections," "annual inspections," "inventory inspections," and "scheduled inspec-
tions." While terminology and procedures may vary among control agencies, all
inspections of this type are concerned with accounting for all possible souk es <>| ,tii
pollution located at a facility and with assessing the compliance 01 imiH ompli in< <•
with the rules and regulations of all elements of tlx' facility.
Under Facility Inspection will be included those limited purpose inspec t ions
which are programmed in advance, as
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1.	Construction Permit Inspection
The construction permit inspection is the site visit made periodically
throughout the construction period or at completion of construction to see
that the conditions of the issued permit are met. In complex facilities, con
struction permit inspections are often made by an agency air pollution
engineer. In such cases, the FEO should arrange to visit the site with the air
pollution engineer who granted the permit to construct some time during the
final stages of construction, to become familiar with the source facility,
especially the emission points, the potential emissions, control hardware and
the instrumentation to monitor the emissions.
For a new or modified facility, initial operating permits are required
separately or are included with the construction permit application. Prior to
granting the initial certificate of operation, a source emission test is usually
required at which the FEO, or the agency air pollution engineer, or both,
are present in the role of observer.
2.	Cyclic Source Inspections
The cyclic operating permits are required where the facility, following con-
struction, is granted a time limited operating permit. Periodically, an
inspection of the entire source premises or some designated facility within a
complex is required to ascertain compliance and qualifying for operating
permit renewal.
The Federal EPA enforcement program requires cyclic source inspections
by federal inspectors in company of state or local FEOs or to be made
independently. Present federal policy requires a federal inspection of 10 per
cent of the major sources within state or local jurisdiction.
3.	Compliance Plan Inspection
The compliance plan inspection applies to those sources which are operating
under an order that includes a schedule of milestones indicating progress to
ultimate correction of a violation condition. See Chapter 3, page 3-5 .
Inspection is limited to the particular process and site visits are made to
determine if the time schedule set down in the plan is being met.
B.	Violation Inspection
A violation inspection is made to gather facts related to an observed violation, as a
result of offsite surveillance program. The investigative process is usually limited to
the process associated with the violation recorded. However, it is extended to other
areas of the facility when other nonconforming conditions are uncovered.
C.	Complaint Inspections
Site visits are made to investigate citizen complaints. Specific regulations may be
involved if preentry observation shows violating conditions. Complaint handling is
treated more completely in Chapter 11.
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D. Inspections Relating to Emergencies
Emergencies are of two types: (1) local emergencies — incidents involving the
untoward release of contaminants that may be toxic or have the potential for other
undesirable health or environmental effects and (2) air pollution episodes in which
the buildup of contaminants in the atmosphere approaches or exceeds pre-
determined alert stages and which may necessitate the curtailment or shutdown of
source activities on a large scale. These conditions will require swift response on the
part of enforcement officers and performance of special inspections.
Response to emergency and alert situations is covered in Chapter 15.
Elements of the Inspection Process
A.	Preentry Observation
All programmed inspections (permit, cyclic, CPI, etc.) and complaint inspections
begin with an observation of the exterior of the source premises. Inspection for
observed violation will have been triggered by the event.
Chapter 4 deals with exterior surveillance and should be followed.
B.	Preparation for Entry
1.	Programmed Inspections
The FEO can prepare in advance for the site visit. There will usually be
available a complete inspection form which, in addition to having business
information entered, will have a stylized guide to the inspection process. For
complex industries, there is a trend to computerizing emission inventories
which could be readily extended to a preinspection document that can be
carried into the field by the FEO. Permits for construction should highlight
inspection points.
It is unreasonably poor practice to expect an FEO to conduct a complex
source facility inspection without thoroughly preparing him in advance for
the involved task, and providing him with the necessary inspection program
in forms and related documents,
2.	Inspections Following an Observed Violation
The preentry preparation is somewhat more difficult. Some FEOs will have
business and emission data in files carried with them into the field. An
extension of the inspector's source file is a set of records on microfiche with a
portable reader in the FEO's vehicle.
If source data is not "on-board," the FEO should contact his office by
two-way radio, if his vehicle is so equipped or by land phone if available, to
obtain business data and especially names and titles of people to be
contacted.
A brief assessment of the source manager's attitude and record of previous
violation would be helpful.
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Often the FEO, if he works within a district and the source is marginal
with respect to compliance, will be thoroughly familiar with the source and
contact people. This is particularly true in the smaller local agencies.
3.	Responding to a Complaint
The FEO can check the source files before leaving his headquarters, but if
he receives the complaint by two-way radio he should expect a "fill-in" on
the suspected source similar to the above.
4.	Organize the Inspection Plan
After developing all of the available preentry information, the FEO should
organize and plan for his entry to the premises:
•	The purpose for the inspection,
•	Who he wishes to see with alternates, if known,
•	What information he seeks,
•	The order of the investigative process.
C. Entry to the Premises
The procedure described here is the usual procedure for an unfamiliar or poorly
documented facility. Where the FEO is familiar with the source and certain of the
correctness of his data, some of the steps may be omitted.
1.	The usual procedure is to seek entry through the front gate or front door by
•	Identifying yourself and stating your business. Produce credentials
when requested or show them in advance.
•	Ask for the facility manager by name, if known; by title, if not known.
•	Abide by company visitor rules. While you are an "official", you are not
an employee and certain procedures may be specified to gain entry.
•	Most agencies advise or prohibit the FEO from signing any documents,
such as waivers or others, that are conditions for your presence on the
company premises. Discussion between your supervisor and plant official
is the best means of resolving any problems that might arise in this
matter.
2.	When entry is denied, and it may be in an unusual case, the FEO may:
•	Immediately change his posture. Become "rough". Example: "Your
position gives me no alternative but to proceed legally against your com-
pany and I will do it. Your attitude closes all other possible enforcement
routes."
•	Advise of possible action for "failing to grant entry". Section 114 of
Clean Air Act or appropriate local regulation.
•	Obtain a search warrant. (See Chapters 6 and 7.)
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D. Management Interview
Entering a plant, especially for the first time, will require a longer interview with
the manager or his representative than for repeat visits. Subsequent visits would be
of shorter duration and the manager may be bypassed where an environmental
contact is established by the FEO. The following are guidelines which should be
helpful to the novice FEO in developing a businesslike style as he pursues his
mission:
•	When ushered into the manager's office, identify yourself. If you are
introduced by a receptionist, listen to be sure you are properly identified
and correct any errors.
•	State your business in concise terms such as: "I wish to inspect the con-
struction site for the bag house, Permit No. A65." or, "I have observed a
12-minute visible emission effluent from the boiler house stack and wish to
investigate the cause."
•	Avoid excessive small talk. A simple but cordial "good-morning" is
preferable to discussing the weather or last Sunday's football game.
•	Don't be excessively accusing or berating. (No matter how mad or
aggravated you are at this particular source.)
•	Conserve time —your time and the manager's time.
•	Know what information you want from management and where you want
to go after management interview.
•	Give manager time to respond and listen. What he says is important to
recall. You learn nothing if you do all the talking.
•	Make notes as interview progresses. If you use a recording device, be sure
to reveal same and secure permission to record other voices.
•	If you wish to take photographs, secure permission, explaining the reason
for the photographs. If denied, forget about photographs and take com-
plete notes. Perhaps sketches, if they will aid and you have this ability.
1. The interview in the manager's office establishes the business data and what
you wish to do.
•	The present legal owner.
•	The type of business: subsidiary, partnership, individually owned, etc.
•	If a corporation, the corporate identity.
•	Correct addresses of source, and corporation headquarters, division
headquarters, etc.
•	The nature of the business.
•	Full name and title of the responsible facility manager. Make sure you
will be able to identify this person at a future time, if necessary.
•	Full name and title of person to conduct you to the site of interest.
•	The documents or plant records you wish to inspect, especially produc-
tion rates and materials involved.
•	The inspection plan you wish to follow.
Caution: If the FEO already has some of this information, be sure to verify
same since ownership and management change.
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E. Process and Equipment Inspection
The complexity of the facility and type of inspection being made determine the
time required. This part of inspection is often made with a source facility stall
environmental engineer who may or may not be familiar with the investigative
methods of the FEO. Where it is uncomplicated as in a small industrial boiler
house, the FEO may be on his own.
1. Process or Equipment Inspection
During process inspection the FEO will:
•	Obtain or confirm operational responsibility with names, titles, etc.
•	Check process and equipment involved, identifying same by name,
number or location.
•	Review equipment operating schedules or logs.
•	Inspect control equipment and determine specific abatement measures.
•	Status of compliance with permit regulations
Is permit posted?
Is operating permit outdated?
•	Inspect Instrumental Process Data — recorded or indicating.
•	Inspect continuous emission monitor data.
•	Be observant for signs of poor operating practice or maintenance.
F.	Operator Interview
Only for violation or perhaps complaint inspection is it necessary to interview the
operator. If there is no operator in attendance, ask to interview the process super-
visor or other responsible person who has personel knowledge of the process opera-
tion. Be sure full names and titles are obtained and recorded.
Where an operator is in attendance:
•	Obtain his complete'identity.
•	Does he normally operate?
•	Was he operating or in charge when the event occurred?
•	Was there a deviation from normal operating procedures?
•	If so, why?
•	Who instructed him to deviate?
•	Note —all this while you are seeking to place responsibility.
•	Who supervises the operator?
G.	Drawing Conclusions
After completing the inspection, it now becomes the FEO's responsibility to form a
judgment whether the source, equipment or process is in compliance or non-
compliance status. Some agencies do not specifically require this, but unless the
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FEO practices this process and forms solid convictions on his own, his whole inspec-
tion effort can be weak and inconclusive. In certain cases, he may be able to exer-
cise this judgment only after consulting with his superiors, the engineers or obtain-
ing the results of source tests. In the final analysis, he must know the
bottom line.'' compliance or violation.
1.	Noncompliance
Where noncompliance is the decision, the FEO should develop the following:
•	The specific permit condition in noncompliance.
•	The specific rule or regulation, by section number, which was violated.
•	Is the violation continuing?
•	The reason for noncompliance. While not germane to establishing the
existence of a violation, it is important to the investigation and the suc-
cessful prosecution of the case, should court action result.
•	Are there unauthorized process modifications (compared to valid
permits)?
2.	Breakdown
The cause of noncompliance is frequently blamed on breakdown, temporary
upset or bad materials. Where emergency conditions are given as a cause,
the FEO must determine:
•	Was there, in fact, a breakdown or emergency? Do not just accept the
word of the plant personnel. Probe the event. Look for signs to verify
the allegations. Look for spilled product, evidence of temporary repairs
or other irregularities. Check logs or recording instruments for upset
conditions.
•	Do the rules provide exception? Know what the regulations provide and
check the plant record.
•	Does the breakdown result from poor maintenance?
•	Are the breakdowns frequent, indicating poorly maintained or worn out
equipment?
•	Was prompt, aggressive, and effective action taken to correct the condi-
tion or minimize the emission during the upset period?
•	Does the company have a plan to prevent recurrence?
H. Providing Information
Jurisdictions vary widely in their policy of having the FEO provide directly to the
facility management, at the conclusion of an inspection, a statement of the condi-
tions found, i.e., compliance or noncompliance. The Federal EPA instructs field
officers to say as little as possible about the results of the inspection and in no case
state a condition of violation or compliance was observed. Many local and some
state agencies require FEOs to serve a notice of violation before leaving. The
majority follow the inbetween practice of having the FEO advise verbally of
findings and follow with a written notice after review of the FEO report.
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Giving Notice of Violation
For those agencies which issue a notice of violation at the inspection site, the key
elements are:
•	Identification of the violator, the name and address of the company and the
mailing address, if different.
•	Source ownership, whether it is a corporation or private ownership (partner-
ship or individual).
•	If a governmental entity, so state.
•	The name and title of the person in charge of the facility during the time of
the violation.
•	The date, time, location of the violation, and any other data necessary as
may be required by the special circumstance of the violation.
•	The name and position title of any other plant personnel (such as operator)
who may share responsibility for the violation.
•	Identify the statute violated by number.
•	The person to whom the notice is served along with his position in the
company.
Preparation of the Report
Most agencies provide report forms or inspection forms convenient for recording all
the necessary data and providing ample space for comments. In addition to filling
in the blanks, a narrative summary is nearly always required.
Immediately upon return to your car look over the data to see that you have
written down all the pertinent data. It is easier to go back immediately to verify
questionable notes or missing information than to try to complete your report by
phone or revisit the source at a later date. In such cases, be sure not to show
harassment of "lack of knowledge" or sloppy work.
Develop skill in report writing by
•	Being objective.
•	Include only what is important. (Aided by good note taking during
interview.)
•	Remember, you may need this report at some date in the future to recall
events for preparation of verbal testimony.
•	Do not include unnecessary information which may damage your case,
especially when you are uncertain about such material or such material is
subjective or based on personal bias.
Eleven Check Points
Knight and Stevenson (Reference 9) give the following eleven check points for a
clear and accurate report which favorably represents the writer's organization:
1. Provide accurate labels for each of the persons, places and things mentioned
in your report.
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2.	Use accurate time citations, providing a realistic time range where exact time
is not known.
3.	Try to keep your account of events within chronological order.
4.	Don't use jargon.
5.	Be careful to use appropriate quotation format.
6.	Watch out for misleading pronouns.
7.	Explain each occurrence within your report, no matter how obvious it may
seem to you.
8.	Remain in the third person, describing the actions of "reporting officer"
rather than telling what "I" did.
9.	Avoid all personal assumptions, and the unverified conclusions which proceed
from them.
10.	Describe rather than label; let readers draw their own conclusions.
11.	Include careful accounting of all required and proper "field" enforcement
procedures.
Conclusion
The first five units of the Student Manual deal with the FEO's job, his respon-
sibilities and how he carries out his mission in the field. His mission, simply stated,
is to bring into continuing compliance with the rules and regulations, all of the
sources assigned to him.
The FEO alone is not responsible for seeing that the AAQ standards are met;
this is the team effort of the entire agency, the planners, the technicians, the
engineers, and the director.
Most agencies hold that compliance by voluntary effort from the source, prodded
and perhaps goaded by the FEO, is the quickest and most inexpensive means of
getting results. However, most agencies are not so naive to hold that all sources will
comply by voluntary effort. They will all let the "nightstick of authority" show just
a little during negotiations and let their resolve be known to litigate for com-
pliance, if the voluntary effort fails.
In all of his field work, he should be mindful of the possibility that in the future
he may be called upon to verbally testify that which he perceived to be evidential
proof of noncompliance. His records and his ability to recall and communicate will
be a key in the success of the legal enforcement route.
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Chapter 6
Basic Federal Legal Provisions
U.S. Constitution and the Glean Air Act
BASIC FEDERAL PROVISIONS
U.S. CONSTITUTION AND THE CLEAN AIR ACT
Goal
To teach the Federal legal provisions applicable to Air Pollution Control law and
enforcement: (a) The principles of the Fourth, Fifth, and Fourteenth Amendments
of the U.S. Constitution and (b) Introduce the principles of the Clean Air Act as
amended.
Note: An overview of the Federal Enforcement Program will be given in
Chapter 10.
Objectives
At the end of this lesson, the student should be able to:
1.	Identify the Fourth Amendment as providing protection from unlawful search
and seizure, and the limitations for gaining entry to a source premises.
2.	Define right of entry and when a search warrant may be necessary.
3.	Identify the Fifth Amendment as providing protection against self-
incrimination, except for corporations.
4.	Identify the Fourteenth Amendment as establishing the principles of "due pro
cess" and "equal protection".
5.	Define the responsibility for enforcement of the Federal EPA, slates and local
governments as applied to (a) all sources except mobile, (b) mobile sources,
(c) emergencies.
6.	Identify the preconstruction control under the requirements of new source
review for NSPS, NESHAPS and PSD.
7.	State the responsiblity of the Federal EPA when states fail to enforce their SII'S
(Section 113).
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BASIC FEDERAL LEGAL PROVISIONS—THE U.S. CONSTITUTION
AND THE CLEAN AIR ACT
Introduction
This unit will be concerned with federal constitutional and statutory provisions
which affect air pollution enforcement.
Constitutional Provisions
There are several amendments to the U.S. Constitution which need to be con-
sidered by field enforcement officers in the discharge of their duties.
A.	The Fourth Amendment
This guarantees that citizens will be free from unreasonable searches and seizures.
The search and seizure problem can arise in an air pollution context in that most
air pollution control statutes have a provision allowing agency inspectors to enter a
facility at reasonable hours for the purpose of investigating suspected pollution
activities. Generally inspectors have not been required to obtain a search warrant
prior to conducting an investigation. Such a warrantless search has generally been
justified in view of the fact that air pollution laws are related to the protection of
public health. However, even where a warrant is not required, the key to the pro-
priety of such a search is "reasonableness." That is, the search has to be reasonably
related to air pollution control purposes and a certain amount of propriety has to
be exercised —i.e., conducted during reasonable hours with the investigators
showing proper identification to the owner or plant manager of the facility to be
inspected.
Very recently, a federal court has required inspectors for the Occupational Safety
and Health Administration (OSHA) to obtain warrants prior to entering a plant
property for inspection of OSHA regulations. To date, there has never been such a
requirement placed on air pollution inspections. Since the effects of an air pollu-
tion violation are felt directly by the public, the public's right to an investigation of
the source seems stronger than in a purely inplant situation.
In any event, the issue raised by administrative searches involves a weighing of
an individual's right to privacy against the need of a city, state, or federal program
to protect citizens from hazards to their health or welfare.
B.	The Fifth Amendment
This guarantees that a person cannot be required to give testimony against himself .
This arises in an air pollution context in that most air pollution control statutes
have a provision requiring sources to supply self-reporting data and emissions
inventories. Such data is extremely valuable in checking a source's compliance
status. There are several reasons why the Fifth Amendment has not posed a deter
rent to the use of self-reported data:
1. Fifth Amendment rights do not extend to corporations but only to
individuals;
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2. Most air pollution enforcement actions (at least at the state and federal
levels) are civil actions rather than criminal prosecutions and courts have
held that protection against self-incrimination applies only if a person is
faced with criminal sanctions.
C. The Fourteenth Amendment
This guarantees due process of law and equal protection for all citizens. Due pro
cess principals demand that a statute enacted under the police power be applied by
the enforcing agency in a reasonable manner and that the air pollution control
standard bear a reasonable relation to the interest that the standard is supposed to
protect (i.e., public health, the quality of air resources, etc.). One of the best ways
to ensure due process is to provide an opportunity for public hearing prior to the
adoption of regulations or prior to major agency action.
The equal protection clause of the Fourteenth Amendment forbids the enact-
ment of laws that establish arbitrary systems of classification or that permit
discrimination between persons of the same classification. Persons or subjects may
be classified for legislative purposes if such classifications are reasonable and bear a
rational relationship to the purpose of the regulation. For example, a hydrocarbon
control regulation may be directed at storage tanks of a certain size, while
excluding smaller tanks. This would not be unreasonable because the size of a storage
tank is related to the amount of evaporative loss and is therefore a valid considera-
tion in hydrocarbon regulation. However, a regulation would be arbitrary if it pro
vided that any hydrocarbon storage tank with an ecology flag painted on the side
would be exempt from regulation. Such a rule would not have any reasonable
bearing on air pollution control.
The Federal Clean Air Act (FCAA)
The fundamental precept of the Clean Air Act of 1967, as amended in 1970 and in
1977, is that the major responsiblity for control of air pollution from stationary
sources rests with state and local programs. Under the statutory framework of the
Act, EPA does not enter the enforcement picture unless the state or local programs
have failed to do the job prescribed in the Act. The control of air pollution from
new mobile sources has been given directly to EPA. Thus, EPA sets the standards
for new automobile engines, fuels or fuel additives, and aircraft emissions. The
reason for this is obvious. If every state had a different standard for these types of
mobile sources, there could be a substantial interference with interstate commerce.
A. State Implementation Plans (SIPs)
Under the Federal Clean Air Act the EPA is required, among other things, to
establish national ambient air quality standards (NAAQS) for the major air
pollutants. The 1970 amendments established dates for attaining the ambient stan
dards. For most areas the attainment date for each pollutant was June 30, 1975.
Congress realized that the standards were not attained in 1975 and amended the
Clean Air Act to allow nonattainment areas to continue the process of bringing
sources into compliance with the applicable plan or to modify the plan to achieve
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the standards. For nonattainment areas, Congress places restrictions on the growth
of sources (in the form of the Offset Policy discussed in Section B.3) and required
SIP revisions to be submitted which will demonstrate attainment on or before
June 30, 1982. For mobile source related problem areas they must demonstrate
attainment as expeditiously as practicable but no later than December 31, 1987.
However, Congress required specific steps to be taken. Those areas which attained
the standards prior to August 7, 1977, have to maintain those standards.
Section 110 of the Act required all states to submit an implementation plan laying
out the details of how the NAAQS were to be attained and maintained by the
statutory dates. These SIPs include emission limitations for stationary sources and
control strategies. The SIPs form an enforceable commitment on the part of the
states and the requirements of the SIPs can be enforced by EPA if the state and
local programs fail to enforce.
B.	Federal Enforcement
1.	Section 113 of the FCAA
This section provides that whenever the EPA Administrator finds that a
violation of a SIP requirement is occurring, he shall notify the person who is
violating the plan and the state in which the plan applies. If such violation
extends beyond the thirtieth day after notification, the Administrator may
issue an order requiring the violator to comply with the requirements of the
SIP or he may bring civil action in court for appropriate relief, including a
permanent or temporary injunction, and/or a civil penalty or not more than
S25.000 per day of violation.
2.	Section 303 of the FCAA
This provides that when a pollution source is presenting "imminent and
substantial endangerment to the health of persons", and the "appropriate
state or local authorities have not acted to abate such sources," the
Administrator may bring suit to immediately restrain the violation.
3.	National Emission Standards for Hazardous Air Pollutants (NESHAPS)
Section 112 of the FCAA requires the Administrator of EPA to establish
standards for air pollutants to which no ambient air quality standard is
applicable and which in the judgment of the Administrator may cause, or
contribute to "an increase in mortality or an increase in serious irreversible,
or incapacitating reversible, illness." A NESHAP standard applies to any
new or modified source. In addition, existing sources are required to comply
with a NESHAP standard within ninety days after its effective date.
C.	Permit Requirements
Under the Clean Air Act of 1970, states were required to have, as part of a SIP, a
permit system for preconstruction review of stationary sources. The 1970 Act dealt
with permits in virtually a single paragraph setting out a very broad requirement
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that states have a program for preventing the construction or modification of any
new source to which a standard of performance under Section III of the Act
applied at any location which the state determined would prevent the attainment
01 maintenance of an NAAQS.
In contrast, the 1977 Amendments set out a great amount of detail as to what
must be reviewed prior to the issuance of a permit. Basically, the following stan-
dards must be met:
1.	New Source Performance Standards (NSPS)
Section III of the Act requires the Administrator to publish a list of
categories of stationary sources which may contribute significantly to air
pollution which causes or contributes to the endangerment of public health
or welfare. He must then propose regulations establishing standards of per-
formance for new sources within each category. Enforcement of these stan-
dards can be delegated to the states.
2.	Prevention of Significant Deterioration (PSD)
The concept of preserving those areas of the country with air quality cleaner
than that, prescribed by the NAAQS gained attention as the result of a suit
brought by the Sierra Club against EPA (Sierra Club V. Ruckleshaus). A
Federal Court of Appeals agreed with the Sierra Club's position and ordered
EPA to revise all SIPs to prevent significant deterioration in clean air areas.
The U.S. Supreme Court split four to four in its review of the case, thereby
letting stand the Court of Appeals decision.
However, even after the PSD concept became clearly established as a
requirement of the Clean Air Act, there were many unanswered questions as
to how this policy was to be implemented. The very definition of "significant
deterioration" was far from clear. EPA attempted to shed light on the matter
by proposing regulations outlining how PSD was to be implemented through
state construction permit reviews. When Congress adopted amendments to
the Clean Air Act in 1977 it largely incorporated EPA's regulations into the
PSD sections of the Act (§§160-169). However, Congress made some changes,
particularly in the extensiveness of the preconstruction review which is now
required.
One of the most interesting changes in the concept of PSD is that it
originally applied only in areas that were "cleaner" than the NAAQS.
However, the regulations now extend the PSD preconstruction review to any
"major emitting facility" no matter where that facility will be located. The
rationale behind the expansion is that a source located in a nonattainment
area might affect the air quality in a clean area.
The basic PSD requirement as set out in Section 165 of the FCAA provides
that no major emitting facility (as defined in the Act) for which construction
is commenced after August 7, 1977, may be constructed unless:
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a.	A permit has been issued setting forth emission limitation;
b.	An air quality sampling analysis has been conducted;
c.	Certain specified increments are not exceeded;
d.	Best available control technology (BACT) is applied;
e.	The requirements for protection of pristine areas (class 1) have been met;
f.	There has been an analysis of any air quality impacts projected for the
area as a result of growth associated with the proposed facility; and
g.	Monitoring will be conducted to determine the effect of the facility's emis
sions on air quality.
3. Nonattainmen t A reas
The 1970 version of the FCAA did not include any provision concerning
nonattainment. It very optimistically set mid-1977 as the outermost date by
which the NAAQS were to be attained. When the attainment date passed,
many areas were found to be exceeding one or more of the NAAQS. Under
the 1970 Act, the only course of action available was to revise SIPs to ensure
attainment and maintenance of the standards. The states and EPA were
then faced with the question of what to do about growth in nonattainment
areas during the period in which the SIPs were being revised.
In an attempt to ease the problem, EPA developed regulations on emis-
sion "tradeoff' or "offset" (Interpretative Ruling of December 21, 1976).
Although there was no provision in the 1970 FCAA for such a concept, EPA
viewed it as a compromise alternative to a "no growth" policy. Congress
apparently agreed because the Clean Air Act Amendments of 1977
specifically adopted the requirements of EPA's Interpretative Ruling as an
interim policy, with the exception that the baseline to be used for determina-
tion of appropriate emission offsets was the applicable SIP in effect at the
time of application for a permit by a proposed major stationary source. For
purposes of the offset requirements, a "major" source is defined as one which
has a potential emission rate of 100 or more tons per year (1,000 for carbon
monoxide). Basically, EPA's Interpretative Ruling was to apply until a
revised SIP was adopted (these were to come into effect on July 1, 1979, but
most have been delayed). The SIP revision must include requirements for
the use of all reasonably available control technology (RACT). This essen-
tially involves a tightening of regulations on existing sources.
Both the Interpretative Ruling and the 1977 Amendments on Nonattain-
ment Area Plans (Part D of Title I) provide that major sources are subject to
an air quality analysis, and if the allowable emissions from the proposed
source would "exacerbate" a violation of an NAAQS, approval may be
granted only if all the following conditions are met:
a. Lowest Achievable Emission Rate (LAER)
In determining LAER, the reviewing authority must consider the most
stringent emission limitation contained in any SIP in the country and
the lowest emission which is achieved in practice for such type of
source. In no event can the specified emission rate be less restrictive
than the applicable NSPS.
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b.	Complete Compliance
All existing sources owned or controlled by the owner or operator of
the proposed source in the same air quality control region must be in
compliance with all applicable requirements under a SIP or must be
under an enforcement order issued pursuant to Section 113 of the
FCAA.
c.	Reasonable Further Progress (RFP)
Emission offsets from existing sources in the area (whether or not
under the same ownership) are required such that total emissions from
the existing and proposed sources are sufficiently less than the total
allowable emissions from the existing sources under the SIP so as to
represent "reasonable further progress" toward attainment of the
applicable NAAQS. RFP is essentially a two-part process in which a
schedule is first developed and then a yearly tracking exercise is per-
formed. The purpose of an RFP schedule is to verify that the emission
reductions obtained are being accomplished at the most reasonable
and efficient rate possible so that attainment by the prescribed time
can occur.
Many state revisions to SIPs will incorporate offset provisions almost
identical to the Interpretative Ruling, but the essential element will be
a system to demonstrate reasonable further progress (RFP) toward
attainment by the required dates of December 1, 1982 or 1987 (for CO
and O3, if the state can demonstrate the need for a delay).
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Chapter 7
State and Local Laws
and Administrative Procedures
STATE AND LOCAL LAWS AND ADMINISTRATIVE PROCEDURES
Goal
To present the source of authority for state and local control programs and the
various mechanisms for achieving enforcement, focusing on administrative pro-
cedures to secure compliance.
Objectives
At the end of this lesson, the student should be able to:
1.	State the source of authority for controlling air pollution within the state.
2.	Differentiate between common law and statutory law, including reference to
nuisance.
3.	State the various strategies for processing enforcement actions through the
agency and the courts.
4.	Explain that neither administrative nor court orders are self-enforcing.
5.	Define the process of enforcing orders.
6.	State that the nature of enforcement actions is that of "adversary" which is
not synonymous with "antagonistic".
7.	Explain why the FEO is the keystone of the enforcement process.
8.	Decide whether or not to sign a "Waiver of Liability" upon entry when
requested to do so by source.
9.	Explain the consequences of divulging proprietary process information or
confidential business records.
10. Explain how to determine if business records or process data is confidential.
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STATE AND LOCAL LAWS AND ADMINISTRATIVE PROCEDURES
Introduction
This unit deals with the legal basis for air pollution statutes and regulations and
basic administrative procedures.
Police Power
The police power forms the basis of state and local authority to control air pollu-
tion. Simply stated, the policy power is that power reserved to the states by the U.S.
Constitution whereby states can establish laws for the preservation of public order
and tranquility, the promotion of the public health, safety, and morals, and the
prevention, detection and punishment of crimes. As long as pollution control
legislation is founded on the need to protect the public health, not much question
can be raised about its constitutional validity. However, modern pollution control
statutes sometimes cover additional areas such as recreational and aesthetic
interests. It is probably safe to say that the strength of a statute's constitutionality
decreases as its coverage is extended beyond public health considerations.
Therefore, in drafting regulations, a control agency should always attempt to have
a reasonable and objective air quality basis for its rules.
Common Law Nuisance
Pollution was labeled a nuisance as early as 1611 when an English Court affirmed
the granting of an injunction and awarded damages to a plaintiff upon a showing
that defendant had erected "a hog stye so near the house of the plaintiff that the
air thereof was corrupted." As common law, it was not a personal environmental
right to breathe clean air, but rather a property right which was protected in a
nuisance action. The common law nuisance concept is evident in the fact that most
clean air statutes today define air pollution as: "the presence in the atmosphere of
air contaminants in such concentration and of such duration as are or may tend to
be injurious to the public health, welfare and the reasonable use and enjoyment of
property." A nuisance theory can be used effectively in areas where there is no air
pollution control standard (i.e., odor). In an odor case, the most effective evidence
is the testimony of live witnesses who can relate how odors from the source make
them ill, keep them awake at night, etc.
In planning a nuisance action, it is helpful for the complainants to keep some
sort of diary in order to be as specific as possible about the nuisance conditions.
For example, they should record the date, time, and wind direction (if possible)
when the odors are the most severe. They must be able to connect the nuisance
with the source as well as to show some adverse effect from the nuisance.
Notwithstanding its usefulness in areas not suited to emission limitations, there
are a number of problems associated with a nuisance case:
1. It is fairly subjective and it is therefore ill suited to guide engineering and
business decisions.
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2.	The court "balances the equities" and therefore looks at such things as who
was there first and how long a person waited before complaining of the
nuisance.
3.	The interference must generally be of a type which would affect a person of
ordinary sensibilities.
The Statutory Approach
Over the last fifty years there has been a trend toward dealing with certain
specialized areas of law by creating administrative agencies to "fill in the details" of
a broad statutory framework. This has been done very effectively in the area of air
pollution control. Legislators establish control agencies which in turn hire technical
personnel and develop expertise to enact rules and regulations in specific areas.
There are a number of advantages to this emission standard approach:
1.	There is more objectivity and predictability.
2.	When prosecuting for violation of an emission standard, no harm must be
proven because the legislature has, in effect, declared that any emission
exceeding the standard is unlawful.
Hearings Prior to Regulation Adoption
In adopting air pollution control standards, agencies not only rely on their own
technical personnel but also on input from regulated industries and the general
public. One of the most effective mechanisms for obtaining this information is
through public hearings. In fact, many federal and state statutes require a public
hearing prior to the adoption of a regulation or SIP revision [i.e., § 163(c)(1) of the
FCAA]. This type of hearing is referred to as legislative or fact-gathering and dif-
fers from adjudicatory hearings in that it is not an adversary proceeding and there
is generally no cross-examination of witnesses or use of the rules of evidence. The
function of this hearing is simply to inform the public of a proposed regulation and
to collect information and data on the proposal.
Adjudicatory Hearings
The Federal government and most states have an Administrator Procedure Act
which sets out certain requirements for contested case hearings. These hearings are
judicial in nature and, in fact, at the federal level the hearings examiners are
referred to as Administrative Law Judges.
The term "adversary" should not be confused with "antagonistic". The adversary
system simply ensures that the ultimate truth of the matter is reached by the full
presentation of all positions and arguments. At these hearings, the parties are
generally represented by counsel and the rules of evidence are followed. All
witnesses must be subject to cross-examination.
There are a number of areas in which these types of hearings can be very
effective:
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A.	Enforcement Proceedings
When an administrative agency feels that a company is in violation of the statute
or the rules but does not have quite enough information for court action, it can
benefit from conducting an adjudicatory hearing. These hearings are sometimes
called "show cause" hearings and the company or source in question is given notice
to appear to "show cause" why an enforcement action should not be initiated. At
the hearing, the agency can determine if there is justification for the source's non-
compliance status and if there is not, an enforcement order can be entered. This is
especially appropriate under Section 112 of the FCAA which provides for the
issuance of compliance orders. An administrative order can be extremely useful in
that it can set out a detailed timetable for compliance. However, if this
administrative order is violated, the control agency must go to court in order to
enforce it. Therefore, if a compliance schedule is going to extend over a long
period of time, it is generally preferable to have the schedule entered as a court
order which can be enforced through contempt of court procedures.
Whether enforcement is sought through administrative or court actions, it is
imperative to remember that the field enforcement officer is the most important
element in the enforcement process since he is the collector of evidence. All FEOs
should recognize that any sample they collect or any violation they observe may be
used as evidence in a hearing or in court.
B.	Permit Issuance
Adjudicatory hearings can also be used prior to the issuance of construction per-
mits. At these hearings, the applicant would have the burden of proof to
demonstrate that it will meet all of the applicable permit requirements. This will
be particularly necessary in areas where the air quality increment will be consumed
totally or in large part by a single source. The hearing format gives the staff of the
control agency and the general public an opportunity to fully examine all aspects
of permit issuance. The Federal Clean Air Act recognizes this in requiring a public
hearing prior to the issuance of a PSD construction permit under Section 165 of
the FCAA.
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Chapter 8
Litigation Procedures
LITIGATION PROCEDURES
Goal
To describe the important aspects of the legal enforcement processes and the
involvement of the FEO in such cases. Proper courtroom procedures are taught and
later demonstrated. See Chapter 9.
Objectives
At the end of this lesson, the student should be able to:
1.	Identify the various procedures used in assessing fines, penalties, injunctive
relief.
2.	Differentiate between civil and criminal action.
3.	Define pretrial discovery.
4.	Define the meaning of case strategy.
5.	Define "deposition".
6.	Define an "interrogatory" and tell when it comes into play.
7.	Identify the principal rules of evidence.
8.	Differentiate between the various kinds of evidence.
9.	Compare the effectiveness of direct testimony with the use of such visuals as
photographs, charts, maps, etc.
10.	Explain the basis for testifying as an "expert witness."
11.	State at least five "Do's" and "Don'ts" for a witness when giving testimony on
the witness stand.
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LITIGATION PROCEDURES
Introduction
This unit summarizes the basic rules of evidence and procedures for trial, with par-
ticular emphasis on the role of a witness.
Types of Litigation
Section 113 of the Federal Clean Air Act allows EPA to file civil or criminal actions
against persons who commit certain air pollution violations. Most state air control
statutes allow only civil actions and most local ordinances are only enforceable
through criminal misdemeanor actions. Civil and criminal enforcement actions
serve different functions and have different advantages and disadvantages.
A.	Civil Actions
This type of action results in the levying of civil penalties and injunctive relief.
Statutes generally provide for penalties of $50 to $1,000 per violation and in some
cases as high as $25,000 per day. Even though this may seem a tremendous deter-
rent to polluters, there are situations where it could be cheaper for a violator to
pay these penalties rather than to comply. Therefore, one of the most effective air
pollution control remedies is an injunction whereby a court orders a source to fake
certain corrective steps within a given time schedule and to be in final compliance
by a certain date. If the source does not comply with the court order, it can be
held in contempt of court. A prohibitory injunction can be used to shut down a
facility. Such a drastic measure is seldom used and most control agencies prefer to
seek mandatory injunctions which set out a timetable for compliance.
B.	Criminal Actions
Most local government prosecutions in municipal court involve criminal misde-
meanor actions. These are not as well suited for the prosecution of ongoing con-
tinuous violations because the fines for misdemeanors are generally set so low that a
violator could simply pay a fine and continue to pollute. Furthermore, in the
criminal area, courts must be stricter in requiring that a control agency scrupulously
observe the constitutional rights of the defendant. In addition, in a criminal case
the control agency must prove the violations "beyond a reasonable doubt" rather
than simply by "a preponderance of the evidence" as in civil cases. Furthermore,
when a criminal action is brought against a corporation, the possibility of jailing a
lower echelon employee may not be a sufficiently stringent deterrent. Since most of
the litigation in which field enforcement officers will be involved is civil, the discus-
sion of litigation procedures will center on civil actions.
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Pretrial Discovery
The key to success in any kind of litigation is preparation. Contrary to some of the
popular television shows, there are rarely opportunities to drop "bombshells" in the
courtroom since under federal and state rules of procedure there is ample oppor-
tunity for both sides to "discover" the evidence which the other side will present in
court. In addition, under the federal Freedom of Information Act and state Open
Records Acts, control agency records are subject to full disclosure even without
discovery procedures.
A.	Deposition
A deposition involves the oral questioning of a witness who is under oath. The
testimony is not taken in open court but it is reduced to writing and can be used at
the time of trial. In general, any prospective witness can be deposed. Depositions
serve a number of functions:
1.	A general fishing expedition to try to determine what a witness knows or will
testify to;
2.	To perpetuate the testimony of a witness who will not be available at the
time of the trial;
3.	To later "impeach" a witness if his testimony at the time of trial is different
from his testimony in depositions.
B.	Interrogatories
Interrogatories are basically a set of written questions to be answered by a prospec-
tive witness in a lawsuit. While interrogatories are cheaper than depositions (i.e.,
no court reporter is needed; attorneys do not all have to gather for the asking of
questions), interrogatories do not provide the flexibility of a deposition. For exam-
ple, in a deposition, if a witness' answer opens up another area of information, the
questioner can immediately proceed to explore this. Also, when a person is respon-
ding to written questions, he has more time to "hedge" his response and give only
as much information as is absolutely required.
Principal Rules of Evidence
The rules of evidence form the ground rules by which a trial is conducted. They
determine whether certain testimony is admissible and they are designed to ensure
that a decision is based on proper facts.
A. Hearsay Rule
The hearsay rule prohibits testifying to statements made out of court due to the
fact that such statements were not made under oath, there has been no chance for
cross-examination, and there is no opportunity to observe the demeanor of the per-
son(s) making the statements. Exceptions to this rule include: declarations of a par-
ty to the suit if the declarations are against the party's interest, e.g., a plant owner
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states, "I know my factory is violating the regulations, but I'm not going to do
anything about it;" and business records if made during the regular course of
business at or near the time of the event in question (or reasonably soon thereafter)
and the person testifying has personal knowledge of how records are kept. Also,
expert witnesses can testify to hearsay within their area of expertise. For example, a
doctor can testify to his review of the literature in his field.
B.	Best Evidence Rule
Evidence presented must be in the best form for proving the facts in question. For
example, the letter itself is the best evidence of what was stated in a letter rather
than a witness' recollection of the contents of the letter.
C.	Leading a Witness
Counsel may not lead witnesses or ask questions which suggest the answers. This
prohibition does not apply to witnesses being cross-examined or to expert witnesses
at any time; it does however apply to ordinary witnesses during direct examination.
D.	Do's and Don'ts for Witnesses
1.	Listen attentively to each question.
2.	Think before responding (your attorney may use this opportunity to raise
valid objections).
3.	Speak slowly and distinctly on the witness stand.
4.	Answer questions directly.
5.	Avoid extended qualifications or explanations.
6.	Do not be long-winded.
7.	Do not interpret facts unless called upon to do so as an expert witness.
8.	Stick to the facts
9.	Be honest: do not stretch facts,
10.	Never guess at answering a question.
11.	Never hesitate to frankly admit that you don't remember certain physical
facts.
12.	Never memorize a story.
13.	Do not read directly from notes, although notes may be used to refresh your
memory.
14.	Beware of questions that seek to force a "yes" or "no" answer.
15.	Refuse to be ashamed or startled into giving an answer you didn't intend to
give.
16.	Never argue with opposing counsel.
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Chapter 9
Courtroom Procedures
COURTROOM PROCEDURES FILM: THE ROLE OF THE WITNESS
Goal
To show "Role of the Witness" film, demonstrating courtroom procedure. Discuss
lessons from the film and prepare for Case Study Exercise, "Trial of Opacity and
TSP Violations," Student Exercise No. 3.
Objectives
At the end of this lesson, the student should be able to:
1.	Distinguish between effective and ineffective court demeanor by an FEO as
he testifies,
2.	Differentiate between the kinds of testimony that can be given by the expert
witness,
3.	More effectively present testimony when called upon to do so,
4.	Identify effective use of photographs, maps and charts in giving testimony,
5.	React effectively to questioning under cross-examination by the defense
attorney,
6.	State the role of a judge in the case presented in the film.
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THE ROLE OF THE WITNESS
The basic function of the film "The Role of a Witness" is to provide a graphic
demonstration of courtroom procedures with particular emphasis on the testimony
of a field enforcement officer. Students have an opportunity to observe cross-
examination techniques and to see the applicability of rules of evidence in the con-
text of particular testimony.
One of the shortcomings of the movie is that it is fairly old and could be revised
to present a more current type of air pollution problem. Furthermore, the movie
portrays a private action rather than an enforcement action brought by a control
agency. In most cases where a field enforcement officer will be involved, the air
pollution control program is the plaintiff.
The basic benefit to be derived from the film is the portrayal of the professional
and impartial demeanor of the witness. To that extent, the actor who portrays the
field enforcement officer does an excellent job of showing how effective a calm and
unbiased presentation can be.
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Chapter 10
Overview of the Federal EPA
Enforcement Program
OVERVIEW OF THE FEDERAL EPA ENFORCEMENT PROGRAM
Goal
To present the Federal EPA Enforcement Program as directed by the Clean Air
Act and to show how this enforcement interacts with state and local air pollution
enforcement.
Objectives
At the end of this lesson, the student should be able to:
1.	Compare the enforcement responsibilities of the Federal EPA with that of
state and local agencies,
2.	Name the sections of the CAA which pertain to EPA enforcement respon-
sibilities,
3.	Explain how the EPA discretionary enforcement power was limited by the
1977 Amendments,
4.	Define two sources of information that trigger a Section 113 action,
5.	Name four conditions which must be met before a Delayed Compliance
Order can be issued,
6.	Explain the various steps required to process and review a Section 113
action,
7.	State which Federal Agency represents the EPA in litigation matters,
8.	Name the three types of penalties provided by the CAA,
9.	State the percent of sources audited by the Federal enforcement program.
Selected Reading
Reference 1, The Clean Air Act: Sections 113 and 114 and Parts C and D.
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OVERVIEW OF THE FEDERAL EPA ENFORCEMENT PROGRAM
Introduction
This unit will be concerned with the enforcement posture of the Federal EPA pro-
gram in carrying out the dictates of the Clean Air Act, with emphasis on the
changes brought about by the 1977 Amendments. The material is extracted from
notes prepared by R. P. Frye, Attorney-Advisor, Enforcement Division, EPA
Region III, (Reference 17) and from talks by other Federal speakers at recent
offerings of this course (Reference 18).
Interface with State and Local Enforcement
The CAA as written in 1970 and retained in the 1977 Amendments states that "the
prevention and control of air pollution at its source is the primary responsibility of
States and local governments."1 However, Congress in the 1977 Amendments, gave
to the Federal government rather specific directions op enforcement which seem to
modify somewhat the term "primary responsibility." For example, the states may
exercise discretion in choosing an enforcement route, whereas EPA is required to
initiate legal proceedings against any major source in violation of a State
Implementation Plan.
Fundamentally, EPA's present enforcement strategy is directed to the health
related provisions of the SIPs, that is, those which seek to attain the primary
NAAQS. The state regulations (i.e., secondary NAAQS) which deal with welfare
and nuisance are not presently subject to the Federal enforcement program, since
primary emphasis is and must be on enforcement in the substantial numbers of
areas of nonattainment of the primary NAAQS. Enforcement of the SIPs,
therefore, can be: (a) unilaterally state, (b) federal EPA together with state, or
(c) unilaterally federal.
Provisions of the CAA Which Pertain to Federal Enforcement
The provisions of the CAA which establish the Federal enforcement program are:
•	Section 113 which requires legal enforcement where major stationary sources
are in violation of a SIP
•	Section 114 which aids enforcement by providing access to records, requiring
continuous monitoring, data reporting, and right of entry.
•	Part C (Section 160 et seq.) which deals with prevention of significant
deterioration, establishing Federal requirements for preconstruction permits.
•	Part D (Section 171 et seq.) which requires SIP revisions in areas of
nonattainment.
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Since Chapter 6 of this manual discusses Part C and Part D and since Section
114 provides for enforcement aids, this chapter will be mainly concerned with
Section 113 procedures.
Clean Air Act Enforcement
A.	Enforcement Prior to the 1977 Amendments
1.	Basically, enforcement consisted of negotiations with violators and issuance
of administrative orders under Section 113 with extended schedules for com-
pliance.
2.	EPA could institute a civil action for an injunction against further violations
or could seek criminal penalties where it possessed appropriate evidence to
meet the burden of proof (i.e., "knowing" violation; proof beyond a
reasonable doubt).
B.	Congressional Concerns with the 1970 Law which Led to 1977 Amendments
1.	There was no public participation in the administrative enforcement process.
2.	There were no standards for EPA issuance of administrative orders under
Section 113.
3.	The desire of Congress to force technology development upon industry.
C.	Clean Air Act Amendments of 1977
The 1977 Amendments drastically changed the nature and scope of Federal
enforcement actions.
1.	The enforcement discretion was restricted and EPA is required to sue any
major stationary source in violation of a SIP more than thirty days after the
Administrator notifies the source of said violation.
A copy of the notice of violation is sent to the state involved to afford the
state an opportunity to take enforcement action within the thirty day period.
2.	All existing state and federal consent orders and decrees inconsistent with
Section 113(d) of the Act, and in existence at the time of the Amendments,
were voided by Section 113(d)(12).
3.	Availability of administrative orders for compliance is limited to:
a.	Section 113(a) orders, which prior to the 1977 Amendments were issued
with extended compliance schedules, may now be issued only to require
immediate compliance, which EPA has interpreted to mean compliance
within thirty days.
b.	Section 113(d) orders, "Delayed Compliance Orders," (DCO) may be
issued by a state, or by the administrator after he gives thirty days notice
to the state. A valid Section 113(d) order effectively insulates the holder
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from federal enforcement under the CAA and from citizen suits pursuant
to Section 304 of the Act. The following requirements, among others,
must be met:
•	Before a DCO may be issued, there must be notice to the public and
opportunity for public hearing.
•	Such DCO becomes a part of the applicable SIP.
•	The DCO, in addition to containing the final compliance deadline,
must require an interim compliance schedule containing increments
of progress,
•	The DCO requires emission monitoring and reporting by the source.
•	Final compliance date is not later than July 1, 1979 or three years
after the date for final compliance specified in the SIP (except Sec-
tion 113(d)(4) order which may allow a greater time for compliance).
c. Special types of Section 113 orders include:
•	Shut down orders with no interim schedule of compliance in which
case the source may operate until July 1, 1979 provided a bond is
posted equal to the cost of compliance and any economic benefit
which may accrue to the source owner by reason of failure to comply.
•	Innovative technology. Under Section 113(d)(4), is a source is deter-
mined to be utilizing innovative technology to conform with an emis-
sion limitation, it has five years after the effective date of the emis-
sion limitation to comply.
Innovative technology must be sure that it will result in a substan-
tial likelihood of achieving greater continuous emission reduction or
achieving equivalent reduction with lower energy cost than would
otherwise be achieved.
•	Conversion to coal from gas or oil. Section 113(d)(5) gives sources
converting to coal until December 31, 1980 to comply with the SIP.
Processing Section 113 Enforcement Actions18^
The procedural process of Section 113 notices begin when a violation at a major
source becomes evident to EPA. Regular reports on compliance status are made by
the slates to the EPA Regional offices. These reports are monitored and those
which show violation are singled out for action. EPA triggers Section 113 notices
from state reports or from the results of field inspections by their own personnel.
Notification of violation is sent to the source owner by letter or in legal docu-
ment form (used by Region IX).
The next step is usually an informal conference requested by the legal counsel
for the source owner (although EPA is not legally required to so confer). This step
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is not an adjudication or formal hearing but it has an air of formality as it is held
in a public building with a stenographer present. Totally informal conferences, as
over lunch, are detrimental and should be avoided.
The state agency is invited and is often represented by a senior enforcement
official or the FEO who supervises the source. EPA wants to know the state s posi-
tion with respect to the violation and utilizes the state reports and other documents
containing evidence supporting the conclusion that a violation exists.
From the conference, an order is produced that compliance be achieved by the
source within thirty days. The order says what the source owner must do within
thirty days and if it is not done, the source owner is in violation of the law. If a
suit is later instituted, it may be based on failing to comply with a lawful order of
EPA and violation of the SIP.
It does not always follow that the informal conference produces an EPA order. If
it becomes apparant that the state will take action, the Federal order may be
delayed or is not drawn.
For EPA to get into court:
•	A litigation report must be prepared. The report must contain a persuasive
statement of the facts and the law in support of litigation.
•	The report is reviewed by the EPA Washington legal staff.
•	A policy review is then given.
•	The report is then sent to the Department of Justice. If the Justice Depart-
ment staff approves, it goes to the Assistant Attorney General for signing.
•	If signed, the matter is sent to the U.S. Attorney General for action.
•	All the while the EPA and Justice Department are reviewing, the case could
be immediately stopped if the state takes effective action to prosecute the
violation. When this happens, the EPA action immediately stops, if EPA
determines that state action is adequate.
Penalties
A.	Criminal
For knowing violations, up to $25,000 per day of violation or up to one year
imprisonment or both.
B.	Civil
The statutory maximum civil penalty is $25,000 per source per day of violation
after August 7, 1977. This is a new provision with the 1977 Amendments.
C.	Section 120 Administrative Penalties
The administrator of EPA or the state may assess a noncompliance penalty against
a major source after July 1, 1979. The amount of the penalty can be no less than
the economic value which a delay in compliance beyond July 1, 1979 may have for
the source owner. Section 120 penalties are appealable to the U. S. Court of
Appeals.
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Audit by EPA of State Source Inspections
It is the general policy of EPA to make a ten percent audit of the state's source by
source inspection program. The methods differ between EPA regional offices. The
states may be advised in advance and actually make the inspection in company of
the EPA inspector. In some cases the EPA will conduct the source inspection
independently of the state which may give rise to controversy over differing inter-
pretations of the SIP. Where manpower is available, audit inspections should be
made in the company of state or local field enforcement personnel.
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Chapter 11
Complaint Handling:
Odor Complaint Case Study
COMPLAINT HANDLING
Goal
To teach the principles of processing nuisance complaints with emphasis on the
field investigation process.
Objectives
At the end of this lesson, the student should be able to:
1. Identify at least five sources of citizen complaint,
t. Identify the major information points necessary in receiving citizen nuisance
complaint,
3.	Document the procedure for investigation and case development of public
nuisance complaint,
4.	Define the various steps in getting action to abate the source of the com-
plaint from the responsible parties,
5.	Identify various means of evaluating complaint conditions by measurement of
effects,
6.	Differentiate between a public and private nuisance.
Selected Reading
Reference 9, Chapter 4, Interviewing.
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COMPLAINT HANDLING
Introduction
Responding to citizen complaint of air pollution nuisance is an important task of
the FEO. It often can be time consuming with great difficulties in legal prosecu-
tion, should such procedure be necessary to secure abatement of a public nuisance.
Public Nuisance, Legal Aspects
The inherent responsibility for enforcement against public nuisance starts with state
and local statutes. A typical regulation might read:
— No person shall discharge from any source whatsoever
such quantity of air contaminants or other material which
cause injury, detriment, nuisance or annoyance to any con-
siderable number of persons or to the public	"
The legislative intent is quite clear that no one should cause a public nuisance.
A "considerable number of persons" which defines the public nuisance in the
foregoing regulation has not been defined, and therefore is vague and causes pro-
blems of enforcement of the nuisance regulations. Some agencies have given as a
rule of thumb, "ten separate households" as defining "considerable number" and
then proceed with less if the situation is very bad, or requires more if the nuisance
is marginal.
An emission that affects only one person is a private nuisance and is not subject
to prosecution under the above quoted statute. However, the agency has a respon-
sibility to respond to all nuisance complaints, including those from a single com-
plainant, and should attempt to alleviate the nuisance situation. A single individual
who suffers a nuisance is free to take legal action, seeking damages or injunction,
against the suspected source. In such an action, the enforcement officer may be
called as a witness to testify to the extent or effect of the nuisance.
Causes of Nuisance Complaint
To assist the receiving operator, a list of typical situations which cause complaints
could be posted and referred to as a helpful guide. Complaints are triggered by
one or more of the following:
•	Offensive odors;
•	A specific violation, most probably opacity;
•	Large particle fallout, easily visible on porches, lawn furniture, and plants,
etc., but difficult to identify the source;
•	Fugitive dust from construction or demolition;
•	Plant or materials damage;
•	Fugitive dust from industrial source;
•	Episodal release affecting health;
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•	Open burning;
•	General conditions such as "The air is awful today, my eyes burn, throat is
sore, etc."
Receiving a Complaint
A complaint of nuisance is transmitted to the agency by telephone, by letter, by
personal visit, or by referral from a central reporting agency for all types of citizen
contacts.
Most serious complaints are phoned in to a receiving clerk of the agency who
should be trained and experienced in processing such calls. Often the caller is
irritated and emotional, rather than factual. Under such circumstances, the caller
should be allowed to talk himself out, and then questioned to get the facts the
operator needs for proper dispatching of the FEO.
An agency might prepare a form which includes the information needed from
the caller. A list of questions helpful to the operator would include:
•	What is your full name, address, and phone number?
•	What is the condition complained of?
•	Where do you think it is coming from?
•	Is it going on now?
•	When did it start?
•	Have there been other occurrences? Get specific dates and times.
•	Is anyone reported getting sick?
•	Are other people bothered?
•	Listen for other specific data related to the event.
The complaint form should include the date, time and name of person taking
the complaint and time of dispatch.
After the message log is completed, a complaint number is assigned, the time is
stamped on the log and a field enforcement officer is dispatched immediately to
the scene. Complaints are investigated as speedily as possible to ensure that the
reported source may be reached while the violation or nuisance is still in progress.
Complaint Investigation
If he works in a district, the FEO may already know much of the background of
the source. However, he should check the source file to obtain the recent history.
Upon arrival in the vicinity, the enforcement officer first observes the alleged
source to determine if a violation is involved. If a violation is observed, he
investigates, writes and serves a notice, if warranted. Then he visits the complai-
nant. However, if no violation is immediately apparent, the complainant is con-
tacted.
Some agencies will have the FEO first contact the complainant, then proceed to
the suspected source for investigation. Either this procedure or the above is
acceptable.
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A. Complainant Interview
The enforcement officer makes every effort possible to avoid obvious identification
of the complainant. He is particularly careful not to park his official vehicle too
close to the complainant's residence should the complainant and the source be near
each other. The identities of all complainants should be considered to be confiden-
tial and should not be disclosed to anyone who is not an employee of the enforce-
ment agency.
If the complainant is not at home the enforcement officer should leave a
message. If the complainant is at home, the enforcement officer identifies himself
by name and agency in a friendly manner, and proceeds with the interview.
The enforcement officer is friendly, but dispassionate. He generally employs a
"nondirective" interview technique in that he allows the complainant to get the
matter off his chest so that the facts of the situation can be calmly discussed. He
should also appreciate the fact that a person who is angry may be honestly
motivated by a serious or chronic air pollution condition.
In permitting the complainant to speak his mind, it is best that the enforcement
officer not interrupt. It is particularly effective, however, that when facts appear
the officer repeats them aloud for verification and then writes them down.
After the complainant has expressed himself, the enforcement officer then pro-
ceeds on a line of questioning which will determine (1) the cause of the complaint
and (2) the nature and source of the air pollution problem cited in the complaint.
The line of questioning in this case is intended to complete and verify the data sup-
plied by the complainant.
The cause of the complaint may not always involve air pollution. Although most
complaints are justified, some will concern problems over which the agency has
little or no control and in which air pollution may play a minor role. These con-
cern backyard feuds, natural contaminants, resentment towards a nearby company
or low concentrations of contaminants which may affect illness or allergy in an
individual. Although the enforcement officer may have no legal powers in such
cases, he thoroughly investigates and attempts to correct all air pollution problems.
If such complaints are unsubstantiated, he establishes the cause of the complaint
and documents the fact that no violation has occurred by recording the operational
data of the equipment at the alleged source.
The information given by phone is checked and enlarged to include the following:
•	Name and location of source complained of,
•	Frequency of annoyance or occurrence of plume,
•	Time of day nuisance was first noticed,
•	Duration of nuisance at each occurrence,
•	Names and addresses of persons affected,
•	Location and extent of property damage, if any,
•	Description and frequency of any illness alleged to have resulted from the air
contaminants,
•	Description of odors or any other pollutants that may be involved,
•	Any other information the complainant may have that will relate the
nuisance to a specific piece of equipment.
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In an air pollution problem which appears to involve toxicity, the enforcement
officer records all observed or reported symptoms such as:
If the symptoms appear serious, a physician and the health authorities should be
contacted. The enforcement agency should be contacted. The enforcement agency
should also be immediately notified in order that an emergency vehicle may be
dispatched to the scene to measure the concentrations of any possible toxic
contaminant.
It should be noted that only a physician can make a diagnosis. The enforcement
officer records reported symptoms in his report. The enforcement officer can note
the name of the physician conducting the diagnosis and treatment. This informa-
tion is important if public nuisance action should be initiated.
While interviewing complainants, the enforcement officer does not promise legal
action nor does he commit himself or the control agency to any course of action.
He should, however, explain to the complainant the laws involved and the evidence
required to instigate legal proceedings. But he will also explain that he will first
attempt to seek cooperation on the part of those who may be responsible.
If odors, soiling or other property effects are involved, the enforcement officer
examines the citizen's property. The pattern of fallout of contaminants may
indicate the direction from which they came. If a malodor is detected at the com-
plainant's property, the wind direction can be determined for the purpose of
tracing the odor to its source.
As a rule, enforcement officers do not solicit opinions in a neighborhood
regarding the behavior of any plant, but confine themselves to those persons
volunteering complaints. It is usually citizens who do the canvassing and who
supply the information. The enforcement officer may then interview all com-
plainants involved. The canvassing of complainants is usually discouraged. The
enforcement officer does not sample nor act on opinion, but on sincerely motivated
complaints. The canvassing of the neighborhood can be construed in a court of law
as being prejudicial to the plant.
The enforcement officer, on the basis of his knowledge of air pollution, however,
evaluates the consistency, correspondence and intensity of remarks made by possi-
ble witnesses. He attempts to find some degree of unanimity regarding the objec-
tionability of the problem among those who might be equally affected. Diverse
opinions and inconsistencies are first signs that a public nuisance case may not be
easily developed.
B. Inspection of the Source
From the facts gathered so far, the enforcement officer may have a notion of the
specific or type of source responsible, especially if he has identified contaminants
nausea
vomiting
headache
eye irritation
fever
constriction of chest
eye tearing
soreness of throat
nasal discharge
turning blue
cough
difficulty of breathing, etc.
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and lias observed definite evidence of damage or detected odors on the complai-
nant's property. In other cases, he may know the identity of the contaminants, but
not the source of origin. In still other cases, the contaminants may be completely
unknown.
To establish a public nuisance, a source within a certain facility responsible for
the offending emission must be proved. In some cases, the equipment involved may
be obvious; in others, especially in a plant containing many pieces of equipment,
the source may be difficult to locate. In the latter instance, each piece of equip-
ment must be inspected in detail. Those which do not contribute to the problem
are eliminated from consideration.
Quite often the job is completed if the complaint or nuisance also involves a
violation of the rules and regulations through the emission of contaminants in
excess of that allowed, or through the operation of unpermitted equipment, or
through operation of equipment contrary to permit conditions. In these instances,
the action to be taken is indicated.
If, however, the nuisance is a result of quantities of air pollution which are
allowed by quantitative standards in the Rules and Regulations, a public nuisance
will have to be proven.
When the enforcement officer contacts the plant operator, he explains that he is
investigating a complaint, unless, in the individual instance it should be strategic
not to do so. The enforcement officer may also explain that he is trying to deter-
mine whether or not the complaint is justified. This gives management the oppor-
tunity to state its case, since it knows that the enforcement officer is not yet com-
mitted to any action. As with the complainant, he is also attentive and takes notes.
Then, on the basis of the information he acquires from the complainants, he asks
developmental questions and completes the story. He then inspects the equipment
and compares actual operating conditions, cycles and times of operation with the
times and frequencies of complaints.
Resolution of the Nuisance
Because the enforcement officer is an indifferent observer between two parties in
conflict, he has a natural tendency to act as mediator and will attempt to find that
solution to a problem which will satisfy both the complainant and the operator.
After the problem is identified and the specific source is isolated, means of
abatement may then be determined. If the problem was a single occurrence, it
probably was not anticipated, was perhaps caused by a breakdown, a fire, a power
shortage or some other situation equally unforseen. The chances of this same inci-
dent happening again are slim, preventative action unlikely, and corrective
measures unnecessary except to repair or compensate for damages. Where the
problem is operator error, then it becomes the company's responsibility to ensure
that personnel are adequately trained.
When the problem is continuing or recurrent, then it becomes critical to
eliminate the cause. Occasionally, an improved regular maintenance program will
abate the problem, either by reducing the likelihood of a breakdown or by preven-
ting a buildup of material causing fugitive dust or odor emissions.
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Sometimes the problem can be solved by altering the operation or process
somewhat, without actually altering the equipment. This may involve changes in
the processing rate or throughput, changes in operating conditions such as
temperature, or changes in material being processed. Relocation of the equipment
within the plant premises may also solve the problem. Ideally, when the equipment
is first put into operation, those operating conditions which could cause a public
nuisance should be anticipated. Restrictions or conditions can be imposed on the
operating permit limiting the operations to that which will not cause a nuisance.
The most common solution involves replacing the basic equipment with newer,
more air pollution efficient equipment or the installation of adequate control
equipment. After-burners, adsorbers and scrubbers have all been used successfully
to reduce odors; electrostatic precipitators, cyclones and scrubbers have been effec-
tive with particulate matter.
Enforcement
The most difficult type of air pollution case is the public nuisance. A public
nuisance frequently occurs when a number of persons are annoyed by a quantity of
contaminants which is otherwise allowed. The problem in cases of alleged public
nuisance is to determine whether a private dispute or a valid public dispute is
involved. If a private dispute is involved, then the citizen must initiate his own
legal action. A public nuisance, however, involving a "considerable number of per-
sons" or a reasonable cross-section of the immediate community affected is handled
as an enforcement action.
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Chapter 12
Odor Detection and Evaluation
ODOR DETECTION AND EVALUATION
Goal
To teach the principles of odor detection and evaluation.
Objectives
At the end of this lesson, the student should be able to:
1.	Define odor and odorant.
2.	Identify the characteristics of odor perception.
3.	State the four odor parameters.
4.	Name which parameter is used in odor regulations.
5.	Explain why odor measurement by instruments is difficult.
6.	Define "odor unit".
7.	Name three instruments which aid odor threshold measurement.
8.	Identify the characteristics of odor transport from source to receptor.
9.	Explain a means of tracing an odor source.
Selected Reading
References 22, 25 and 26
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ODOR DETECTION AND EVALUATION
Introduction
All air pollutant emissions of concern from the standpoint of field operations divide
into those which are perceptible to the human observer (e.g., enforcement officers,
complainants), and those which are imperceptible. Imperceptible contaminants
cannot be consciously perceived through the senses (seeing, hearing, smelling,
feeling, touching) at normal ambient concentrations and can include such con
taminants as carbon monoxide, hydrocarbons, and oxides of nitrogen. They arc-
primarily detected and measured through ambient air sampling and source sampl
ing and analysis.
The perceptible emissions are those, like dust, smoke, and fumes which can be
seen, or leaking gases which can be heard, or gases and vapors which can be
detected through the sense of smell. The field enforcement officer's stock-in-trade
are these forms of emissions. Indeed, he should be trained to be an expert in detec-
ting, describing, quantifying these emissions and in establishing their sources and
causes.
Evaluation of Odors
The problem in the evaluation of odors is essentially that there are no reliable
objective methods for field identification of specific compounds and conditions
causing the odors, or for quantifying the concentration of odorants in the ambient
environment. These aspects of odor evaluation must be treated as scientific in-
vestigations. Nevertheless, a trained enforcement officer should be sufficiently ex-
pert in odor evaluation so that:
1.	He can objectively evaluate the perception and his own level of odor sen-
sitivity in relation to complainants and the general population.
2.	He has thorough knowledge of the sources which produce odors and the
physical conditions that affect odor potentials.
3.	He can identify odors in the field.
4.	He has knowledge of the conditions which affect odor perception and of
scientific techniques used in odor evaluation.
Thus, to be an expert, the enforcement officer should have knowledge of both
the perceptual and the scientific aspects of odor investigation. These are treated in
this section.
Characteristics of Odors and Odorants
A major difficulty in dealing with odors as an air pollution problem arises from the
fact that an odor is not an air contaminant but is a property of air contaminants
which can only be detected or measured through its effects on the human
organism. Briefly, an odor is that property of a substance which affects the sense of
smell. A contaminant which has an odor is called an odorant.
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Odor Perception Varies with Individuals
The capacity in humans to perceive odors varies considerably among individuals,
and in one individual from time to time. Some persons ("anosmiacs") are very
insensitive to odors, while others may be acutely sensitive to odors unnoticed by
most people. This variability of individual sensitivity complicates the problem of
estimating the prevalence of an odor nuisance.
Legal Criteria
The air pollution inspector is primarily interested in establishing the existence of an
odor problem according to legal criteria: i.e., a problem which constitutes a
nuisance to a considerable number of persons over a continuing or significant
period of time. Both of these elements are important from a practical standpoint,
since there is little value in devoting substantial effort to the solution of a nonrecur-
rent problem or one not affecting an appreciable number of persons in the
community.
FEO Concerns
In such problems, the inspector is concerned with (1) identifying the odor,
(2) rating the odor's intensity, (3) identifying the odorant, (4) establishing the fre-
quency of the nuisance, (5) locating the "odor route," (6) locating the source of the
odorant, and (7) influencing some operational or engineering control over the
odorant.
A. Odor Perception
There are a few characteristics about odor perception which the enforcement
officer should be familiar with in. estimating whether an odor problem exists. These
are as follows:
1.	The olfactory sense becomes fatigued after continuous perception of
an odor.
2.	An odor is usually detected whenever there has been a significant change in
odor quality or intensity. A pleasant odor can become objectionable to one
who has become used to it under continuous exposure, when it increases in
intensity.
Odors do not. in themselves, cause physical disease. The odor of many toxic
materials (e.g.. chlorine, sulfur dioxide, hydrogen sulfide) may serve as a
warning agent, however. Odors, also, may bring on nausea and have an
adverse effect on asthmatics.
4.	A persons ability to perceive odors varies from day to day.
5.	Compounds of different constitution may yield similar odors, whereas com-
pounds of very similar constitution may yield different odors.
6.	An unfamiliar odor is more likely to cause complaints than a familiar one.
7.	The perception level of odors decreases with increasing humidity. High
humidity tends, however, to concentrate odors in a given locality.
8.	Odor quality may change upon dilution.
9.	Some persons can detect certain odor qualities but not others.
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B. Definitions
Odor is "a sensation of smell perceived as a result of olfactory stimulus".
Odorant is "the substance which causes odor".
Odor Parameters
In investigating odor complaints to establish the existence of a nuisance, the
enforcement officer should attempt to identify the odorant, describe the odor and
establish its objectionability, and provide some indication as to its severity. Nader19
in describing perceptual measurements of odors in the laboratory, defines the
following set of parameters pertinent to such an evaluation.
•	Quality
•	Intensity
•	Acceptability
•	Pervasiveness
Although developed primarily for experimental use, these parameters are also
useful for characterizing odors in the field. Skill in evaluating odors lies in the
ability to distinguish the separate characteristics of the odor, and in isolating the
smell from other senses (taste, feel, sight and hearing). Normally sensitive persons
can develop such skill through training.
A. Quality
The quality of an odor may be described either in terms of association with a
familiar odorant, such as coffee, onions, etc. (characteristic odors) or by associating
a familiar odor with an unfamiliar odorant. Aside from such direct descriptive
terms, the observer, in an attempt to be complete and accurate, may add modifiers
to his description to indicate shades or overtones of an odor. These may actually
include subjective reactions such as "fragrant," "foul" and "nauseating," or
characteristics of odor which may be associated with the sense of taste such as "bit
ter," "sweet," "sour," "burnt," or even partially with the sense of touch as far as
contaminants which are irritating are concerned, such as "pungent," "acrid,"
"acidic," and "stinging." As a matter of fact, a contaminant may sometimes affect
more than one sense. An irritant can be smelled, cause eye-irritation and be tasted.
Odor Recognition Training
Odor terminology is meaningless without actual exposure through odor training.
Therefore, the inspector should be exposed to samples of typical odorants found in
the local industry, so that he can be prepared to make quick and accurate iden-
tifications. There is no substitute for this kind of training. Verbal descriptions of
odors do not implant as vivid an imagery in the mind as do descriptions of visual
or auditory phenomena.
A few of the well-known odor classification systems are indicated here. They are
useful in training inspectors in making associations and analyzing the various com-
ponent sensations which odors may produce. For field purposes, one system is as
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good as another. The advantage of all systems is that they yield a useable odor
vocabulary, as shown in Table 12-1 and below.
Based on Six Types of Odor Classification
1.	Spicy: Conspicuous in cloves, cinnamon, nutmeg, etc.
2.	Klowery: Conspicuous in heliotrope, jasmine, etc.
3.	Fruity: Conspicuous in apple, orange oil, vinegar, etc.
4.	Resinous: Conspicuous in coniferous oils and turpentine.
5.	Foul: Conspicuous in hydrogen sulfide and products of decay.
6.	Burnt: Conspicuous in tarry and scorched substances.
Crocker-Henderson Classification
A Condensation of the Henning Arrangement
1.	Fragrant or sweet
2.	Acid or sour
3.	Burnt or empyreumatic
4.	Caprylic, goaty, or oenanthic
Table 12-1. Henning's odor classification.
B. Intensity
Intensity is described by some numerical or verbal indication of the strength of an
odor. Various intensity scales have been devised. The average observer or complai
nant can be expected to distinguish three levels of intensity, characterized as weak,
medium and strong. A useful rating system especially adapted for field work is as
follows:
Rating	Description
0	No detectable odor
1	Odor barely detectable.
2	Odor distinct and definite, any
unpleasant characteristics recognizeable
3	Odor strong enough to cause attempts
at avoidance
4	Odor overpowering, intolerable for any
appreciable time
This system depends on observation or reporting of behavior more than on sub
jective impressions of the complainant. The fact that a person desperately attempts
to avoid a strong and unpleasant odor is clear and verifiable indication of its inten-
sity. Reports of odor intensities of 2 or higher on this scale may be particularly
relevant in establishing the existence of a legal nuisance.
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For scientific purposes, on the other hand, an odor rating which does not depend
so heavily on the objectionable character of an odor is usually preferable. Such a
system, long used by expert evaluators, is the following:
Intensity	Expert Description
0	No odor
1	Very faint
2	Faint
3	Easily noticeable
4	Strong
5	Very strong
This system has the advantage of distinguishing the intensity parameter from tin-
acceptability parameter in a more definite manner.
C.	Acceptability
An odor may be either acceptable or unacceptable depending on its intensity and
quality. Thus odors normally considered as pleasant, such as flower fragrances and
perfumes, may become unacceptable only at very high concentrations (i.e., at very
high intensities on the scientific scale) whereas obnoxious odors may be unaccep-
table at much lower concentrations, where they are not clearly recognizeable.
D.	Pervasiveness
The parameter of pervasiveness refers to the tendency of an odor to resist being
dissipated by dilution of the air in which it occurs. Pervasiveness in this sense is
related to the nature of odorant and is not readily determined except by experi-
ment. Nevertheless, a highly pervasive odor is one which, in the field, will tend to
be detectable in sheltered areas over a longer period of time, and will therefore in
some incidents be easier to track than a less pervasive one.
Determinants of Odor Perception
Odor is a property of an odorant, but the report of a perceived odor is mediated
by the nervous system and the brain of an observer. Therefore differences in
reports of odor perceptions may be due partly to differences in the physical condi-
tions of exposure, and partly to differences in the physiological and psychological
status of the observer. In view of these considerations, the main parameters deter-
mining an odor report may be listed as
•	Identity of odorant (or odorants)
•	Concentration(s) of odorant(s)
•	Ambient conditions
•	Status of observer
The relevance of these parameters to problems of odor evaluation is discussed in
the following subsections.
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Identity of Odorant
The field enforcement officer should be trained to identify the odorants most often
responsible for complaints within his area. So trained, he can often identify the
cause of an odor problem by his own investigation in the field, even when the com
plainants are uncertain as to the nature or origin of the odor.
Complaint
Rotten eggs
Rotten cabbage
Natural gas
Dead fish
Outhouse
Rotten odor
Scorched popcorn
Coffee
Bleach
Ammonia
Phenol
Identification
hSs
Mercaptan
Mercaptan
Di-methylamine
Amines
Rendering
Grain drying by direct flame
Coffee roasting
Chlorine
Ammonia
Phenol
Table 12-2. Interpretation of odor complaints.
One difficulty that arises in the endeavor to associate particular odorants with
their odors is that the chemical identities of odorous industrial air contaminants are
not always known. Further, in some cases the odors are caused by mixtures of
odorants which may vary in their proportions under different conditions of produc-
tion; these variations can lead to changes in perceived odor quality, but usually
within some limited range which does not prevent recognition by a trained
observer.
Another complication in the recognition problem arises from the fact that odor
quality may change with dilution. In mixtures of odorants this may be due to a dif-
ference in pervasiveness of the individual compounds; however, single odorants
sometimes behave similarly.
Status of Observer
The principal parameters of observer status which are relevant to odor evaluation
may be listed as sensitivity, expertise, and physiological and psychological
conditioning.
1. Sensitivity
The sensitivity of observers for any given odor varies widely, and the relative-
sensitivities of two observers vary inconsistently for different odors. Further-
more, independent observers often disagree substantially regarding odor
quality, particularly when evaluating odors of mixed odorants. For these
reasons statistical evaluations using panels of observers are more likely to
provide reliable results than evaluations by individual observers.
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2.	Expertise and Training
As discussed above, expertise can be developed to a considerable extent by
study and training, although it is necessarily limited by the physiological son
sitivity of the would-be expert. With respect to quality, expertise consists in
the ability to recognize and discriminate between a number of odorants,
either singly or in mixtures. Relative to intensity, expertise permits reliable
discrimination between a large number of graded levels of intensity. Thus, a
trained person can detect a smaller percentage difference in concentration
levels of a given odorant than an untrained individual.
3.	Physiological and Psychological Condition
A problem of physiological origin, in the evaluation or tracking of odors, is
fatigue of the olfactory nerves, which tends to diminish the sensitivity of the
evaluator. The effect is especially noticeable after prolonged exposure to a
rather high intensity of odor, and may seriously complicate the conduct and
interpretation of odorant threshold determinations in the laboratory.
Colds and other infections of the nasopharyngal tract can cause serious, if
temporary, interference with the sense of smell and result in loss of sensitivity
to many odorants. For observers in an odor panel, a preparation of a stan
dard odor can be useful in checking on these variations in sensitivity from
day to day; at least when the condition is not too obvious to need
confirmation.
Measurement of Odor Intensity
A. Threshold Concentration
The threshold of odor in the ambient air is the main parameter determining the
intensity of the perceived odor, although ambient conditions and observer status
may cause appreciable variations in perceived intensity. Leonardos^: published
the threshold concentration in ppm by volume for fifty-two chemical compounds,
several of which are shown in Table 12-3.

Threshold

Chemical
ppm by volume
Description
Acetone
100.0
Chemical
Acrolein
0.21
Burnt, pungent
Trimethylaminr
0.00021
Fishy
Ammonia
46.8
Barn-like
Benzene
4.68
Solvent
Hydrogen sulfide
0.00047
Rotten egg
Dimethylamine
0.5
Fishy
Table 12-3. Odorant threshold concentrations.,
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I'his data shows that the volume of odorant present to cause threshold levels
varies widely. For example, when ammonia and hydrogen sulfide samples are each
diluted with air and are of equal volumes, the volume of ammonia required would
be 100.000 times that of the volume of hydrogen sulfide to reach a concent ration
of ammonia that can be perceived.
B. Units of Intensity Measurement (Odor Concentration)
Since the concentration of an odorant to produce a threshold of odor varies widely,
the instrumental measurement of concentration is unlikely to produce any measure
of odor intensity above the threshold of perception.
A developing approach to odor intensity evaluation is to sample an odorous
atmosphere or effluent stream and dilute the sample with odor free air until a
threshold is determined by a panel of observers or a "trained observer". Thus, a
"dilution factor" can be quasi-objectively obtained. "Dilution factor" is the ratio of
the diluted volume to the original sample.
For the single "trained observer", threshold is the point at which the perception
of odor just begins. When a panel is used, threshold is determined by plotting, on
log-probability coordinates, the percentage of the panel indicating positive odor
responses vs. the "dilution factor" of the prepared samples presented to the
individual panel members. The resulting curve tends to follow a straight line and
the point where the plotted line crosses the 50% panel response ordinate is the
threshold concentration. The "dilution factor" at the threshold is the odor concen-
tration usually stated in terms of odor units per cubic foot (see page 934 of
Reference 7).
"Odor Unit" is defined as the amount of odor necessary to contaminate one cubic-
foot of odor free air to the threshold, or barely perceptible, level (see page 314 of
Reference 22).
C. Method of Determination
Any procedure which permits a sampling of the odorous air, diluting it with a
measured amount of odor-free air, and presenting the diluted mixture to a panel
of observers or a trained observer is satisfactory.
The calculations are quite simple.
Sample volume + odor free volume
	= odor strength
Sample volume
as odor units per cubic foot.
Example:
Odorous + Odor free = Mix
5ml + 95 ml = 100m/
Sample + Dilution air = Mix, presented to observer
5 pil + 95 pil _ 100
. ^	= —g— = 20, which is the dilution factor
12-9

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If a single trained observer judged the above "mix" to be at threshold, then the
original sample would have 20 odor units per cubic foot.
If a panel had been used, and the 50% response ordinate intersected the plotted
response line at a dilution factor of 20, then the original sample would have an
odor concentration of 20 odor units per cubic foot.
D. Quantitative Emission Rate
Odor emission can be calculated as an emission rate from odor concentration in
"Odor Units."
Example:
A source tested to have a concentration of 20 odor units (per cubic foot) and a
volume flow of 10,000 acfm has an
Emission Rate of
20 odor units 10000 cu/ft 200,000 odor units
	 X 	= 	;	
cu/ft	min	min
Note: By using the Emission Rate, an Odor Emission Inventory can be
constructed.
Instruments
A. Sampling for Later Evaluation
To confirm field estimates of odor intensity, or to determine odor removal efficiency
of control equipment, the investigator may collect samples of odorous gases of low
moisture content by means of a glass probe connected by a ball and socket joint
with clamp to a gas collection tube (e.g., a 250 ml MSA sample tube) as shown in
Figure 12-1. The odorous gas is drawn into the tube by a rubber squeeze bulb
evacuator. (Rubber or plastic tubing or other absorptive or heat sensitive materials
on the probe side of the sample tube should not be used.)
For gases with high moisture content, such as may be found in steam plumes,
precautions are required to prevent condensation of water vapor and possible
absorption of odorants in the liquid. This can be achieved by using a syringe and
hypodermic needle to aspirate a smaller sample into the sample tube, previously
filled with odor-free air. A system of this sort is also illustrated in Figure 12-1. (A
capillary probe may be used, to minimize error due to dead space in the probe.)
Sampling problems that must be dealt with include: (1) if sample is warm, con-
densation and cooling may result in the selective removal of odorants from the
vapor phase; (2) odorous material may be sorbed on the walls of containers and on
particulates in sample; (3) chemical changes after sampling may alter the odorant, etc.
A test kit convenient for field use consists of six 250 ml sample tubes, a hand
aspirator, and several probes of glass tubing with ball joints for attachment to the
sample tubes. A special capillary probe and syringe with hypodermic needle, for
sampling gases of high moisture content, may also be included.
12-10

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Method A
Ball & socket joint (with clamp)
Pyrex glass probe
MSA sample tube (250 ml)	Rubber squcivc bulb rvacuator
Method B
Capillary glass tube (2 mm O.D.)
Hypodermic needle (18 guage)
t
Cork	' Ball	MSA sample
tube (250 ml) Scrum	Medical syringe (10 ml)
stopper
stopper
joint
Figure 12-1. Schematic diagrams of odor sampling apparatus. Method "A" is used to collect
samples low in moisture content; Method "B," samples high in moisture content. The latter
method permits primary dilution of odor sample in the field, and minimizes condensation of
vapors on the inner surface of the sample tube.
B. Dilution Techniques
Dilution techniques are applicable both to the inspector in his field observations
and to the laboratory investigating team in providing for evaluation by odor
panels.
For field use, either in odor patrol or in investigation of an odor incident,
ambient air may be tested with the aid of a portable dilution device such as the
"sccntometer" (Figure 12-2). This device is actuated by inhalation by the operaioi,
thus dispensing with pumps and electrical power sources; holes which can be
opened or closed by the fingers permit precalibrated dilutions of the ambient air
stream with air which is simultaneously deodorized by an activated charcoal lilici.
A useful feature is that the observer can combat the effects of olfactory fatigue by
breathing only deodorized air for a period prior to an actual test.
12-11

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Various devices, mainly constructed on similar principles, have been used for
dilution of odorants for laboratory evaluation. However, the method of choice both
for simplicity and accuracy appears to be the syringe technique. The odorous gas is
displaced from the sample tube (for example, by mercury displacement) into a
large graduated syringe, in which it is diluted by addition of odor-free air. Further
dilutions are easily managed by the use of additional syringes, as illustrated in
Figure 12-3. The last dilution, usually 10 to 1, is performed by the panelist, who is
furnished with 10 ml of sample injected into his 100 ml syringe; he dilutes the sam-
ple to 100 ml with ambient air before sniffing it, and records a positive or negative
result as to detection of the odor.
For confirming the identity of suspected odorants, or for quantitative determina-
tion of concentrations of identified odorants, gas chromatography can be per-
formed, using samples no larger than those necessary for the organoleptic evalua
tion of odor.
Determining Sources Responsible for Odors
A.	Odor Patrol
The possibilities of instituting quick, effective action to control odors when com-
plaints arise depend, to a large extent, on the field officer's intimate knowledge of
the odor potentials of the various industrial and other sources within the
community. It is therefore necessary for him to become familiar with likely source
activities.
A simple odor patrol is probably the best indicator of existing or potential
nuisance from odorous discharges. This consists of a regular periodic patrol around
selected plants or in selected areas, documented by notes as to observed odors, with
time, location, and wind direction. Special patrols for complex industries such as
refineries and chemical plants may be assigned to personnel specially trained for
them, and cognizant of the particular activities which entail an odor potential. A
record of such odor patrols is also useful in indicating where odor control efforts
are most required.
B.	Field Investigations of Odor Incidents
In a routine inspection of an industrial plant, the normal air pollution configura-
tion is tracked from cause to effect —from the feed input of equipment to the
effects of the contaminant generated from the equipment on receptors and the
environment.
The tracing of an odor problem reported as a public nuisance is just the reverse
of this procedure. The investigation begins with the complainant and his environ-
ment and works back to the equipment responsible in the following steps:
12-12

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•	Interview of complainants to obtain as much factual information as to the
intensity, evidence and source of the contaminant.
•	Identification of the contaminant causing the nuisance.
•	Tracking the contaminant to its source or sources,
•	Inspection of the equipment at the source to determine plant's capacity to
emit the contaminant,
•	Collecting signed district attorney affidavits or other official forms from com-
plainants who desire to testify in court.
•	Serving notices of violation to the source or motivating plant management to
remedy the situation.
In an odor nuisance, the field officer must establish the existence of two areas:
the effect area, that is, the area over which the nuisance effect exists; and the
source area —that area which can be assumed by logical tracking techniques to
contain the specific source or sources of the nuisance contaminant. The determina-
tion of a source area is often a first step in isolating the exact source and cause of
the nuisance, especially in those cases where the specific source is difficult to
establish initially.
1.	Odor Transport
Odor Transport has several characteristics which should be recalled in field
investigations.
•	Odor flows downwind from source to receptor.
•	Transport from a vent or chimney is in a plume. (Similar to a visible
particulate plume.)
•	Meteorology is favorable for transport with little dilution in the night-
time. (Prevalence of nocturnal inversions.)
•	In unfavorable meteorology, odors travel long distances.
•	Odors are dissipated by dilution, therefore may change from source to
receptor.
•	Odors per se leave no residual effects.
2.	Determining Air Flow from Source
The basic problem in an odor nuisance is to establish the flow of air masses
from a source of air pollution to establish responsibility, or to determine
relative contributions to the problem from two or more sources. This pro
12-13

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Charcoal bed
Purified air
for dilution
Odor
Purified air
for dilution
Graduated series
of orifices
Odorous air
Figure 12-2. Schematic of scentometer. Odorous air passes through graduated orifices and is
mixed with air from the same source, which is purified by passing through charcoal beds. Dilu-
tion rates are fixed by the orifice selection. (Reference 22)
Mercury
reservoir.
Panel
member's
syringe
Sample
syringe
Dilution
syringe
"D"
(100 ml)
Sample
lube
(250
nil)
Figure 12-3. Equipment used for transferring and diluting odor samples. iSouru.-: Ai/ Pollution
(Reference 7)
12-14

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cedure is otherwise known as source tracking, and is especially applied when
the source of the nuisance is originally unknown. This basically involves
determination of wind direction and velocity for the purpose of triangulating
the source.
In source triangulation, only two vectors are required, i.e., wind directions
taken on separate occasions and locations at times of nuisance occurrence.
Wind direction is always ascertained from the direction in which it is blow-
ing. (A south wind blows from the south.) Wind direction can be determined
from flags, steam or smoke plumes, finger-wetting, or a small hand held
instrument available from most instrument companies.
The interview with the complainant should also attempt to establish the
wind direction at the time of contamination. The investigator should instruct
complainants and/or observers in recurring problems to maintain a record of
time, intensity and wind direction. If this is not possible, the investigator
should attempt to estimate the time the contamination is likely to occur, so
that he can logically schedule reinspections.
In complex cases involving heavily industrialized communities with many
possible sources, or where contamination or nuisance does not appear to be
localized according to wind direction, the inspector may plot a wind rose,
based on local meteorological data. A check with the enforcement agency
may disclose prevailing wind patterns and other pertinent
micrometeorological data for the area in question.
3.	Insitu Wind Vector Measurement
A conclusive determination of air flow movement may be made by making
in-situ wind vector measurements. Such observations can be made day or
night.
The procedure involves the release of a small balloon inflated to about six
inches diameter with helium from a portable tank carried at all times by the
FEO. The release takes place from a position approximately on the center
line of the odor plume, downwind from the source. The balloon is released
and its travel in the plume is traced by sighting with a hand held compass.
By using a bright yellow color for the balloon, the tracing can be made at
night with a six cell flashlight.
The wind vector is recorded and later plotted on the survey map. Odor
observations are made downwind and upwind and such data, odor present or
not present, is also plotted on the survey map. By repeating the tracing pro-
cess with different wind directions, the source can be located by triangula-
tions.
4.	Recording Odor Survey
In complex cases, the following tracking results are recorded on a map as
shown in Figure 12-4:
•	Location of complainants and distances from possible sources,
•	Plant source layout showing principal types of equipment which may be
involved,
12-15

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•	The number of complaints, and frequency of complaints as well as the
time of day,
•	Observations by inspectors at various points to fill in any gaps in data,
•	The tracked contaminant routes and vectors of triangulation,
•	Wind roses or other indications of wind direction.
Legend
Direction from which wind is blowing:
• Complainant's report
Inspector's report
Rendering odor
Light
Moderate
Heavy
Horse stable odors
Aluminum dross odors
5 mph
11:50 p.m
%
go Packaging
| s
12 Noon
Ace
Meat
Packing
3 mph 1:30 p.m, M-R
233 W. ^
4 mph
12:30
L-R
Smith Fertilizer
159 W
5 mph
6:15 a.m
Huck *
Rendering
B Street
3 mph A	* O
l:«p.m.X 6m<*h
5:30 p.m
NIL
M-R 2 mph
:50 p.m
M-R
Sec-
Alum
Plant
Corona Meat Prod
Captive Rendering
G5SS3
5 mph
6:00 p.m

A Street
Slaughterhouse
Horse
Stables
2 mph
H-R 2 p.m.
231 West
3 mph
1:50 p.m. ^
3 mph
fl 3:50 p.m
r M-R
M-R 233 W.
Arrow Highway
Blameless
Rendering
ft#
6 mph
5:00 p.m.
122 No.
H-R
124 No.
H-R
126 No
H-R
123 No
5:00-7:
Ace
Wrecking
Yard
5 mph
5:30 p.m.
City of Onyx
Figure 12-4. Odor survey. Although possibly malodorous industries are centered between Onyx
St. and End Road and along the Onyx Basic River, reports and observations indicate that the
Blameless Rendering Company is the primary source of the odors. This finding is verified by
the fact that complaints are reported in two time periods—from 11:00 a.m. to 5:00 p.m., from
residents north of Arrow Highway and west of Onyx Street, when the wind was from the
southeast, and from 5:00 to 7:00 p.m., from residents in the area around Oakwood Street, south
of Arrow Highway, when the wind was from the west. Inspection reports, operating data and
point observations verify the existence of a public nuisance at the Blameless Rendering Company.
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Relating Source Strength to Control Requirements
In correcting an odor problem, the contaminants responsible for an odor should be
controlled so that threshold levels are never reached in the outdoor atmosphere of
the community. Some industries incorrectly assume that they will have no odor pro
blems, because they consider their own discharges to be unobjectionable or even
pleasant. However, the presence of any odor which persists and is not normally
associated with the daily routine of living will be a source of annoyance to the
neighborhood. Complaint records show that this applies to such comparatively
acceptable odors as those of baking bread and roasting coffee; therefore, it is wise
to consider any odor as potentially objectionable.
The odor evaluations of source samples provide estimates of odor concentrations
in terms of odor units per cubic foot which can serve as guidelines in the develop
ment of control methods. Thus, if a stack effluent is normally diluted by a factor
of 1,000 before it arrives at a breathing level in the surrounding neighborhood, an
odor concentration of 1,000 odor units per standard cubic foot could be considered
to be on the verge of acceptability, while an odor concentration of 10,000 would
require at least 90% control.
This sort of guideline can be refined by calculating an odor emission rate in odor
units per minute. This is equal to the product of the odor concentration by the
volume rate of the stack exhaust, in standard cubic feet per minute (scfm). Table
12-4 illustrates some examples of typical results using this approach (as reported by
Benforado, et al.^6
An application of odor measurement in improving neighborhood odors would be
to survey all the operations in a plant and determine the odor emission rate from
each. Listing such emissions together with estimates of costs for control can help
management pick out the largest odor sources (rather than the largest stacks or
largest volume discharges) and concentrate effort initially on those which are likely
to provide the greatest improvement per dollar of expenditure.
Application
Exhaust
Flow
(scfm)
Average
Odor Strength
(odor units/scf)
Average
Emission Rate
j,odor units/min)
Remarks
Rubber processing
6900
50
350,00
Acceptable con
trolled by direct
flame fume
incinerator
Coffee roaster
3600
2000
7,200,000
Not acceptable
uncontrolled effluent
from roasters
Rendering plant
29,000
1500-25,000
55,000,000
730,000,000
Not acceptable
uncontrolled effluent
from dryer
Table 12-4. Miscellaneous tests: rendering plant; coffee roaster; rubber processing plant.
12-17

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Odor Control
The elimination of odors is the most important part of any odor problem. Air con
taminants responsible for an odor should be controlled so that threshold concentra-
tions are never reached in the outdoor atmosphere. This is accomplished by adop-
ting any one of a combination of control devices or techniques such as waste gas
incinerators, catalytic oxidation, and adsorption in activated carbon. Such
common-sense control methods as general sanitation, refrigeration of animal tissue,
improved maintenance and operational techniques should also be applied where
odors arise from plant housekeeping.
The abatement of odors is accomplished either by complete destruction of
odorants and prevention of odorant emissions, or neutralizing the malodorous
effects of contaminants. Odor prevention or odor destruction is generally preferable
since air pollution control in critical pollution areas seeks control of contaminants,
not the effects of contaminants. For this reason, the ideal odor control method is
perfect combustion. This is accomplished by an afterburner or waste gas
incinerator. To be effective, such devices must maintain complete combustion at
proper temperatures and exposure times, reducing all contaminants to odorless
water and carbon dioxide. Partial or incomplete combustion may result in a series
of reactive secondary products which may not only be malodorous, but eye-
irritating and corrosive as well.
Other methods of preventing the escape of odors to the atmosphere include
chemical scrubbing and charcoal filtering described in other sections of this
manual.
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Chapter 13
Emission Control Hardware
Inspection Technique
EMISSION CONTROL HARDWARE
Goal
To familiarize the student with the air pollution source system; the various classes
of emission control hardware; the physical appearance of control hardware;
operating parameters related to effective collection; and the potential for failure
along with indicators of such failure.
Objectives
At the end of this lesson, the student should be able to:
1.	Name the six elements of the source system,
2.	Recognize various types of control hardware by the outward appearance,
3.	Define one operating parameter which indicates the effectiveness of
separation for each type of control equipment,
4.	Recognize instrument indicators and physical signs which indicate when
control equipment is not functioning effectively.
Selected Reading
Reference 6, APTD-1101—Control Technology and General Source Inspection
Chapter 5.
EMISSION CONTROL HARDWARE
Introduction
A source of air pollution may also be defined as a source system. A source system,
then, is a variety of things, such as a motor vehicle, an airplane, commercial
process, an industrial process, or a combustion process such as a boiler or
incinerator.
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The source system begins with an area of contaminant generation and continues
through duct work and various components until the gas stream discharges through
.1 vent or stack to the outdoor air. Each element of the source system influences the
selection of the control process, the first cost and the operating cost of the control
equipment. Too often, in analyzing the needs of a non-conforming source, all
attention is paid to the control device only, neglecting potential savings by ignoring
an inadequate system.
Elements of the Source System
The functioning units of the system are:
•	System entrance (point of contaminant generation)
•	Transport (duct work)
•	Air mover (fan)
•	Instrumentation (controls and monitors)
•	Sub-systems (contaminant removal and feed materials)
•	Air pollution control devices
Figure 13-1 shows a combustion system where the combustion chamber of the
boiler is the system entrance. Control of the system entrance is by controlling the
firing devices, that is the fuel burner and the forced draft fan to satisfy the com-
bustion air requirements. From the outlet of the boiler, the gases with their con-
taminant load pass through a duct system in which controls regulate the flow. The
gases then progress usually to an air pollution control device, through an induced
draft fan and finally to a chimney. Monitoring is installed. In addition to the firing
subsystem, the ash handling may be a subsystem which also requires complete
control. The ash handling system would be typical of an industrial process
Figure 13-2 shows a typical industrial process in which the system entrance is a
series of hoods over operations which are a source of contamination. The conveying
gases, usually air with the pollutant load progresses through ducts, past control
dampers to a control device, then from the control device to the air mover, and
finally out to the atmosphere through a vent or stack. Operating control and
monitoring devices are needed. The contaminant removal arrangement is a sub-
system and must be reckoned with.
Figure 13-2 shows make-up air. Often huge quantities of conveying air are
necessary if the hood system is extensive. This air is discharged to the atmosphere
and must be "made up" into the working space. Often make-up air is forgotten
and the interior of the building is under a strong negative pressure.
The contaminant removal subsystem may require extensive treatment to condi-
tion the contaminant for its final resting place.
13-2

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Coal
system
Boiler
Unloadt-r
dustless
ra	
Ash system
Furnace
Secondary
combustion air
Conveying
air
Figure 13-1. Combustion source—system configuration.
V
fal
u
£
a
S
E
w
Operating
controls
Hoods
Monitor
Dampers
Control
device
T ransport
Hoods
Air mover
Contaminant
removal
Figure 13-2. Source system configuration—industrial process.
13-3

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SYSTEM COMPONENTS
A.	System Entrance
While the system entrance can be many things, a reaction vessel, a furnace, etc.,
this section will deal only with hood design of the typical industrial system.
The design objective is to effectively capture the contaminant being released
from the source with a minimum of volumetric air flow into the hood and a
minimum of pressure loss on entry. Optimization of both air flow and pressure loss
reduces fan horsepower and operating costs and the control device cost.
Inspection Points
1.	Visible dust or vapors spilling from around the hood face while the
system is operating is evidence of poor design or deficiency in volume flow
due to a number of causes, as undersized fan, poor duct design or failure of
dampers.
2.	The duct connection at the hood should be checked to see that the connec-
tion is in place.
B.	Transport (Duct System)
The duct system transports the gas (usually air) from the hood or the system
entrance throughout to the discharge point. The design objective is to select the
duct sizes to provide the minimum conveying velocities and then the fittings and
configurations to reduce friction and turbulence losses.
1. Inspection Points
The order of inspection is usually from the process, the point of contami-
nant generation or the hoods, to the control equipment. As the FEO walks,
he should look for:
•	Leaks in the duct work caused by warping, cracking, or buckling
due to excessive temperature, deterioration from corrosion, lack of
expansion joints or just poor workmanship;
•	Possible block at elbows, dampers or other fittings due to inertial separa-
tion of large particles;
•	Possible blockage due to settling of large particles in long straight runs
with low conveying velocities;
•	Damper arms disconnected or not working.
C.	The Air Mover (usually a fan)
The air mover can be a fan, a high hot chimney, or other form of exhauster which
creates movement of air within the system. Because a fan is used in a high percen-
tage of installations, discussion will be confined to the fan.
The purpose of the fan is to move the air through the duct system from the
system entrance to the discharge point. To do this, the fan must overcome the
friction loss in the duct system, the control devices, the entrance loss at the hoods
and have enough static pressure to accelerate the air from zero velocity to the
velocity in the duct and must be sized to the proper volume flow.
13-4

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A proper fan is as important to the functioning of the system as the right
collector. Too often the fan, as a source of trouble, is neglected.
The fan may be positioned upstream or downstream of the control device. A
downstream fan position creates a negative pressure at the control device, drawing
air in through cracks and openings, thereby minimizing leakage of the contaminant
into the working area. Inleakage may diminish the required capture velocity at the
source, allowing emissions into the work area. The reverse is true where the fan is
located upstream of the control device, creating a positive pressure at the control
device, permitting dust and other contaminants to escape into the work area
through cracks or holes in the casing or duct connections.
Important parameters are fan speed (rpm) and fan horsepower. For a given fan
wheel, change in air volume varies directly with the changes in rpm. Change in
horsepower varies as the cube of the volume of air handled and, therefore, with the
cube of changes in fan rpm.
Inspection Points
•	Check fan rpm and compare with permit data. If the fan speed is too high,
the motor may be overloaded. If it is too low, the air volume is below design
requirements.
Measuring rpm is often not possible, so measure motor amperes as an indica-
tion of motor horsepower. Often, the panel board has an indicating ammeter
for this purpose.
•	Listen or feel the fan casing for signs of imbalance due to loose blades or dirt
buildup on fan blades.
•	Check for signs of deterioration as: excessive temperature coloring the metal;
cracked casing; cracked or loose fitting duct connectors; or other signs of
failure.
D. Instrumentation
Operating controls are important to the functioning of the system, and do not
specifically relate to the air pollution control phase of the source system. Monitor-
ing on the other hand is important and more attention is being directed toward
monitoring. The Clean Air Act specifically requires monitoring devices for new
major sources. Lesson 18, Source Emission Evaluation includes discussion on
monitoring instruments.
Inspection Points for Operating Control
Look for obvious signs of failure or controls disconnected. The significance of
instruments related to the control device will be discussed with the various type of
control equipment.
RPMj
Qj _ RPMj
Q2 RPM2
3
13-5

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E. Subsystems
Subsystems are processes in themselves, needed to convey the contaminant to its
final disposal site or to feed materials into the process. Such process is often defi-
cient in preventing escape of contaminant, especially dusts and odors. Subsystems
include:
•	Dry particulate removal and disposal.
•	Dry feed materials systems.
•	Sludge from wet systems.
•	Contaminated liquids from absorbers and scrubbers.
•	Regeneration of adsorbing solids in an adsorber.
•	Catalyst regeneration.
•	Gas conditioning device, such as an evaporative cooler, cold air bleed-in, or
heat exchanger.
1.	Inspection Points
a.	Systems for dry feed material and disposal of dry collected dust
should be checked for the following:
•	Transfer points without enclosures or hoods not collecting,
•	Leaks through bucket elevator conveyor housing,
•	Dust from conveyors,
•	Fugitive dust off storage piles,
•	Mechanical transfer of dry dusty materials by front end loaders and
bucket cranes,
•	Roadway and driveway dust,
•	Inadequate dust control on pneumatic conveyors,
•	Failure of dust control devices on the conveyor system,
•	Dust from gravity unloading of hopper to open truck.
b.	Wet Systems
Wet systems are usually no problem unless the contaminant is smelly. An
odor problem may arise from settling ponds, holding tanks and trucks.
c.	Gas Conditioner
Look for: (a) evaporative coolers, where excessive water is being carried
over into collector; (b) bleed-in systems with dampers inoperative; (c) heat
exchangers with cracks or failures of metal components and (d) in all
systems, failure of controls and inadequate instrumentation.
2.	Disposal of Collected Contaminant
Question the ultimate disposal site or method. Four methods of final disposal
are available. Do not let the collected contaminant cause trouble. You are
never free of potential trouble until the separated contaminant is
•	properly land-filled
•	sold as a usable product
•	returned to the process
•	converted into a noncontaminant as in combustion or absorption.
13-6

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Classification of Air Pollution Control Devices
All control devices function to accomplish one of the following:
a.	Separate the contaminants from the gas stream within the collector and then
remove it without re-intrainment, either continuously or intermittently, to
the disposal system,
b.	Change the contaminant from offensive to inoffensive as in combustion or
scrubbing, or
c.	A combination of a. and b.
Control devices can be classified according to the contaminants to be removed: i.e.,
for particulates only; for particulates and/or gases and vapors; for gases only; or
for vapors only.
A.	Particulates (also known as dry collectors)
1.	Gravity settling chambers and inertial separators
2.	Centrifugal separators (cyclones-multicyclones)
3.	Fabric filters (bag filter, baghouse)
4.	Electrostatic precipitator (ESP)
B.	Particulates and Gases and Vapors
1.	Wet collectors (scrubbers)
2.	Combustion (afterburners, fume incinerators)
C.	Gases
1.	Absorption towers
2.	Adsorption
D.	Vapors
1. Condensing
Gravity Settling Chambers and Inertial Separators
Gravity separation and dry inertial collectors are unimportant as control devices
because they are ineffective in separating all but the giant particles. They are
seldom used separately, but may be seen occasionally as a preseparator ahead of a
more efficient collector. Gravity separation may occur in duct work to cause
plugging when inadequate conveying velocities are provided. Because of their
relative unimportance and limitation of time, no further discussion of these collec-
tors will be given.
13-7

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Centrifugal Separators (Cyclones, Multicyclones)
A device or structure without moving parts in which (by the configuration of the
structure) the velocity of an inlet gas stream is transformed into a confined vortex
from which centrifugal forces tend to drive the entrained particles to the wall of
the structure or body of the cyclone. See Figure 13-3. The separated particulates
fall by gravity along the wall of the cyclone body into a hopper from which they
are removed through a discharge valve.
A.	Physical Appearance
Cyclones can be used singly (Figure 13-4) or nested in a housing called
multicyclones (Figure 13-5).
Single cyclones are generally characterized as high efficiency or high throughput.
High efficiency cyclones have a narrow inlet opening to attain high inlet velocity,
long body length relative to body diameter and a small outlet diameter relative to
body diameter (C5, Figure 13-4). High throughput cyclones have larger inlet open-
ings and larger gas exits (C7, Figure 13-4).
Multicyclones, also called multiclones, or mechanical collectors (Figure 13-5)
have numerous small diameter cyclone tubes in parallel inside a housing. Each
tube is mounted into a header which separates the clean side from the dirty side of
the gas flow. Because of the close nesting of the multiple tubes (at times up to 200
in a single unit), inspection of the tubes for wear failure is difficult.
B.	Parameters Related to Efficiency
The pressure drop (Ap) across the collector is a strong indicator of separation effi-
ciency. The FEO should have access to the design Ap prior to inspection.
Cyclones are very sensitive to particle size with very poor efficiency on submicron
particles. Therefore, cyclones have difficulty in meeting opacity regulations where
submicron particles are present in quantity.
C.	Inspection Points
1.	Check pressure drop across collector. If Apis too low, the collection
efficiency is reduced. If Ap is too high, excessive re-intrainment may take
place. For a given cyclone, Ap varies as the square of the volume flow and
directly as the gas density.
2.	Leakage through hopper bottom unloading valve is very harmful. Back flow
destroys the vortex.
3.	Holes in cyclone body or hopper due to corrosion or wear. Result, same as
2., above.
4.	Hopper does not unload when valve is opened. When hopper fills, all
collected particulates are discharged out the stack.
5.	Plugging inlet duct. This condition is indicated by reduced volume flow in
duct system.
13-8

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\ \ t
Outer
vortex
Inner
vortex
Clean air
outlet
Inner
cylinder
(vortex)
finder
Cone
Dust outlet
Figure 13-3. Simple cyclone.
High efficiency High throughput
Figure 13-4. Typical single cyclone collectors.
Figure 13-5. Multicyclonc.
13-9

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6.	Condensation due to high humidity aggravates 4. and 5.
7.	Interior parts deteriorated due to corrosion and wear. Indication is failure to
collect giant particles. Look for fallout near outlet of collector or citizen
complaint.
•	Single cyclone - the outlet duct extension corrodes away causing gas
short circuiting.
•	Multicyclone — individual tubes plug or wear causing functional failure of
the tube.
8.	Visibility of outlet gases.
Fabric Filter (also known as bag filter or baghouse)
Filtration is the process of removing dusts and fumes by passing the gas stream
through a porous media. Such forces as impaction, impingement, diffusion, gravity
settling, electrostatic charge, and direct sieving (most important) are used to
separate the particulates from the gas stream.
A.	Physical Appearance
Most often a rectangular sheet metal box, set on a hopper, often insulated, ranging
in size from the small 100 cfm units (Figure 13-6) about the size of a refrigerator
packing box, to a very large unit handling 2,000,000 cfm which would fill one-half
of a football field (Similar to Figure 13-7).
The interior arrangement varies widely, accommodation design of the filter
media and operation, but externally they are as described above. Occasionally, a
designer creates a bag filter with a cylindrical exterior which may look very much
like a cyclone.
B.	Separating Forces
The fabric filter has a two stage separating mechanism: (a) the building of the
filter cake, and (b) the sieving through the cake. The fabric is used primarily to
support the cake.
1.	Building the cake results from impaction impingement, natural electrostatic
forces and Brownian movement.
2.	After the cake is established, the separating mechanism is direct sieving,
which is the most important mechanism, resulting in high removal efficiency
regardless of particle size. The finer the particles, the finer the cake (sieve)
becomes.
C.	Operating Characteristics
Fabric filters are usually rated by the ratio of gas (CFM) to the area of the filter
(square feet) which is the velocity of the gas through the filter cloth. This
parameter is called the air to cloth ratio or just filter ratio. A rule of thumb is a
ratio of 1.5 to 3.0 CFM per square foot of cloth for dust and 1 to 2 CFM per
square foot of cloth for fumes for a shaker type of cleaning. Pulse jet cleaning and
special designs may go to 10 CFM per square foot of cloth or higher (see Table
13-1).
13-10

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Clean air
outlet

/
Dirty air
inlet
Collection
hopper
Clean air
side
Filter bags
Cell plate
Figure 13-6. Typical simple fabric filter baghousc design.
13-11

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annnnnn

Figure 13-7. Typical pulse-jet baghouse with screw conveyor dust removal system
13 12

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Usual Air-Cloth Ratio

Usual Air-Cloth Ratio

(CFM/Sq. Ft.)

(CFM/Sq. Ft.)
Dust
Shaker
Pulse
Reverse Air
Dust
Shaker
Pulse
Reverse Air

Collector
J«
Collapse

Collector
J«
Collapse
Alumina
2.5-3.0
8-10
—
Leather dust
3.5-4.0
12-15

Asbestos
3.0-3.5
10-12
-
Lime
2.5-3.0
10-12
1.6-2.0
Bauxite
2.5-3.2
8-10
-
Limestone
2.7-3.3
8-10

Carbon black
1.5-2.0
5-6
1.1-1.5
Mica
2.7-3.3
9-11
1.8-2.0
Coal
2.5-3.0
8-10
-
Paint pigments
2.5-3.0
00
2.0-2.2
Cocoa, chocolate
2.8-3.2
12-15
-
Paper
3.5-4.0
10-12

•Clay
2.5-3.2
9-10
1.5-2.0
Plastics
2.5-3.0
7-9

•Cement
2.0-3.0
8-10
1.2-1.5
Quartz
2.8-3.2
9-11

Cosmetics
1.5-2.0
10-12
—
Rock dust
3.0-3.5
9-10

Enamel frit
2.5-3.0
9-10
1.5-20
Sand
2.5-3.0
10-12

Feeds, grain
3.5-5.0
14-15
-
Sawdust (wood)
3.5-4.0
12-15

Feldspar
2.2-2.8
9-10
-
Silica
2.3-2.8
7 9
1.2 1.5
Fertilizer
3.0-3.5
8-9
1.8-2.0
Slate
3.5-4.0
12-14

Flour
3.0-3.5
12-15
-
*Soap, detergents
2.0-2.5
5-6
1.2-1.5
Graphite
2.0-2.5
5-6
1.5-2.0
Spices
2.7-3.3
10-12

Gypsum
2.0-2.5
10-12
1.8-2.0
Starch
3.0-3.5
8-9

Iron ore
3.0-3.5
11-12
-
Sugar
2.0-2.5
7-10

•Iron oxide
2.5-3.0
7-8
1.5-2.0
Talc
2.5-3.0
10-12

Iron sulfate
2.0-2.5
6-8
1.5-2.0
Tobacco
3.5-4.0
13-15

Lead oxide
2.0-2.5
6-8
1.5-1.8
Zinc oxide
2.0-2.5
5-6
1.5-1.8
Note: Values tabulated are based on light to moderate loadings of granular dust having particle size and
shape characteristics typical of the specific material. Ratios will normally be less when dust loading is vi-iy
heavy, temperature is elevated, or particle size is smaller than commonly encountered.
Table 13-1. Typical air to cloth ratios.
13-13

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1.	The temperature and moisture content of the gases to be cleaned are impor-
tant factors in the operation of baghouses. "Wet" gases will cause blinding
(plugging) of the bags resulting in extremely high pressure drops which in
turn will reduce the effectiveness of the entire collection system by reducing
the volume of gases handled. The baghouse, therefore, should operate at a
temperature above the dewpoint of the incoming gas.
2.	Precooling equipment is a necessary part of most dust control systems using
baghouses, where gases are at elevated temperatures. Three cooling methods
are usually employed:
a.	Radiation and convection,
b.	Dilution air
c.	Spray cooling.
Radiation and convection cooling systems need large cooling surfaces
resulting in considerable space requirements. Spray cooling is not advised for
gases with high moisture content. Where dilution air is used, it is necessary
to increase the filter area to filter the cooling air. Where spray cooling can
be used, controls must be included to keep the temperature of the gases
50°F to 75 °F above the dewpoint.
3.	Bag cleaning techniques vary. Figure 13-8 describes the most common
cleaning mechanisms.
D. Inspection Points
A detailed list of all check points on a baghouse is beyond the scope of this course.
Three important causes of baghouse failure are given. For more complete analysis
of trouble shooting, see Table 5.13 of Reference 6.
1.	Condition: High differential pressure
Most installations are designed for differential pressure of 3 to 4 in. A
differential pressure of 1 in to 6 in can be considered normal.
High differential pressure is usually associated with failure of the bag
cleaning mechanism to properly function. The analysis of the cause is quite
complex and should be made by source owner.
2.	Condition: Visible emission from stack outlet
This condition is generally caused by some form of bag failure, torn bags or
loose seals, etc. Interior inspection must be made by the source owner to
find cause and correct.
3.	Condition: Insufficient suction on exhaust hood or system
Reduced volume flow is indicated. The cause could be at the fan, failure of
bag cleaning, leaking duct work or clogged ducts.
13-14

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Filtering
cycle
Cleaning
cycle
-j
¦ r • 'J
* «• »
!•»»»'»

Back
Clean
air
Shaking
Reverse air
Bubble
Bubble-jet/pressure-jet
Figure 13-8. Typical cleaning mechanisms
13-15

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Electrostatic Precipitators
Electrostatic precipitation is a process in which particulates (solid and liquid) are
removed from a gas stream by the action of electrostatic forces. As the gas passes
between a pair of collecting plates, a corona discharge from a wirelike electrode at
high voltage potential charges the particles and they move to electrically grounded
collecting plates of opposite potential. See Figure 13-9.
The discharge electrode may be placed inside a tubular collecting surface, the
configuration usually used in a wet precipitator, Figure 13-9.
A.	Physical Appearance
The ESP looks very much like a baghouse, i.e., a huge cube with hoppers beneath
except that the ESP is distinguished by the rapping mechanism and transformer-
rectifier sets mounted on top of the housing, Figure 13-10.
B.	Operating Characteristics
Electrostatic precipitators employ the principle of attraction of opposite charges.
The particles in the contaminated exhaust stream are charged in a high voltage
electric field and are then attracted to a grounded plate of the opposite charge
where they are collected and slowly lose their opposite charge. When the plate is
vibrated or rapped, the contaminants drop into a hopper.
There are two basic types of electrostatic precipitators. Single-stage precipitators
operating at high voltage, 30 to 100 KV peak voltage, and 2-stage, low-voltage
precipitators operating to 12 to 13 KV. The higher voltage precipitator is
commonly used in large installations such as coal-burning central power stations
and Portland cement plants. The low-voltage, 2-stage precipitators are used to
control mists and other particulates from smokehouses, asphalt paper (see Figure
13-12).
Direct current is used, being supplied by transformer-rectifier sets, each set sup-
plying a part of the ESP. Efficiency of collection is usually highest when the voltage
is highest. Peak performance is indicated by the beginning of the sparking from
wires to plate and the sparking rate is sometimes used as a control. Plates are
generally rapped by mechanisms mounted on top of the housing or, in some
designs, mounted on side of the plates. In large modern units, the wires may also
be rapped for cleaning.
13-16

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Charging field
High-voltage
discharge
electrode ( - )
Charged (- )
particles
Collecting
baffle
Grounded (+)
collecting surface
Discharge
electrode
tension weight
Flat surface-type electrostatic precipitator
Discharge
electrode
Cnarged
particles
Grounded
collecting
surface

Grounded
collecting
surface
Gas flow
High voltage
discharge
electrode
Tubular surface-type electrostatic precipitator
Figure 13-9. Electrostatic precipitators.
13-17

-------
Rappers
Collection
electrode
Discharge electrode
Figure 13-10. Electrostatic precipitator.
13-18

-------
(>as inlet
Gas outlet
High-voltage system
support insulator
Water sprays
Discharge electrodes
Tubular collecting
surfaces
Weight!
Figure 13-11. Irrigated tubular blast furnace precipitator.
13 19

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Baffle
(to distribute
air uniformly)
£



Collector cell
(to collect particles)

Ionizer
(to charge particles)
Figure 13-12. Components of standard two-stage precipitator, Wcstinghouxr IAcrit ic
Corporation, Hyde Park, Boston, Massachusetts.
i:i 20

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C. Major Inspection Points
The FEO should confine his inspection to several major indicators. Visibility of the
outlet gases is perhaps the most telltale inspection point, particularly where visi-
bility has increased from previous inspections. There are innumerable conditions
which could result in increased visibility, due to fall-off in fine particle collection
efficiency, some of which could be checked as:
•	Rectifier output voltage (usually kilovolts) and current (usually in
milliamperes). Check against design conditions.
•	Sparking rate in sparks per minute. Sparking rate indicates maximum voltage
being utilized. Sparking rate meters are not common, but they may be found
on newer installations.
•	Maintenance logs to determine adequacy of interior inspection, particularly for
broken discharge wires.
•	Check for change in process or materials, such as ash characteristics of fuels.
When deviations are noted, the FEO should avoid comment on the consequences
of such deviation and especially specific recommendations. Many interdependent
conditions affect ESP performance.
Wet Collectors (Scrubbers)
This section will deal with wet collectors, whose separation mechanism is impaction
of the particulates on liquid droplets or wetted targets. The almost endless variety
of wet collectors makes it difficult to include all types and varieties in this course.
Three types of scrubbers have been selected for discussion in this unit, namely
centrifugal spray, venturi and flooded bed scrubber.
A.	Physical Appearance
Centrifugal spray scrubber is shown in Figure 13-18; venturi scrubber is shown in
Figure 13-15; and a flooded bed scrubber is shown in Figure 13-14.
B.	Inspection Points
In addition to observing the color, opacity and carryover after the dissipation of
water vapor from the scrubber, the enforcement officer must be aware of its
operating characteristics and physical characteristics. Inspection points include;
1.	Record the Af) and check against design.
2.	Recording the water pressure to the scrubber to compare it with the design
pressure. Lower than design Ap indicates a lowering of collection efficiency.
3.	Noting impairment in efficiency due to freezing.
4.	Check the maintenance schedule for cleaning and replacing nozzles.
f>. Noting the operation of fans and pumps. Check for excessively worn drive
belts.
13-21

-------
6.	Noting if the bypass system has been opened and the duration ol the time of
bypass.
7.	Recording temperature and pressure of gases entering llit- scrubber to check
against design parameters.
8.	A check for structural wear from corrosion.
Combustion (Afterburner. Fume Incinerator)
(For gases and vapors.)
Combustion is the rapid oxidation of contaminant gases, vapors, and particulates
to odorless, colorless and innocuous waste gases generally not considered to be con
taminants. Principally applied to control organic compound emissions, the end
products would be C02 and water vapor.
A.	Physical Appearance
There are two types of combustion devices.
1.	Direct or thermal units which are furnace-like in appearance with either
gas or oil burning apparatus plainly visible (Figure 13-16).
2.	Catalytic units have the appearance of a duct heater, generally made of
sheet metal, rather higher instrumented (Figure 13-17).
B.	Parameters Relating to Efficiency
In both thermal and catalytic units, the parameter indicating efficiency is the
outlet temperature which is dictated by the characteristics of the contaminant to be
oxidized. It is assumed that good mixing and proper retention time are designed
into the unit. In thermal units, the minimum outlet temperature is considered to
be 1200° F with certain substances requiring considerably higher temperatures.
Catalytic units are generally designed for a bed inlet temperature of 800T000°F.
Permits should always state the temperature parameters for reference during
inspections.
C.	Inspection Points
Principally, the outlet temperature for thermal units or temperature rise for
catalytic units.
Outlet visibility or odor emission should be checked.
13-22

-------
Clean gas
out
Core buster
disk
Spray
manifold
Damper
Water
out
Figure 13-13. Centrifugal spr;iy soiiIiIh
13-23

-------
&¦
$
°0 o S 0° °0
0 O O O O
Mist eliminator
Scrubber liquid
Floating bed
T
Feed gas
To drain
Figure 13-14. Floating-ball (fluid-bed) packed scrubber.
13-24

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Figure 13-15. Venturi scrubber.
13-25

-------
Gas burner
piping
Refractory lined
steel shell
Burner ports , Refractory ring baffle

Inlet for contaminated
airstream
Burner
block
Figure 13-16. Direct-fired afterburner with tangential entries for both the fuel and
contaminated gases.
Discharge to atmosphere
Return to oven
Catalyst
Perforated plate
Figure 13-17. Catalytic afterburner utilizing direct heat recovery.
13-26

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Absorption
(For gases and vapors.)
Absorption is the process of removing contaminants from a gas stream by causing
them to dissolve in a liquid. Both gaseous and vapor contaminants may be
separated by absorption methods. The effectiveness of the method for a particular
contaminant depends upon the use of a liquid which is a specific solvent for that
contaminant.
Absorption equipment can be either plate (bubble), spray, or packed towers,
each type being designed to provide thorough contact between the gas and liquid
phases. The rate of removal is largely dependent upon the amount of surface
exposed. The necessary contact can be accomplished by dispersing gas in the liquid
as the gas passes through the tower. In a packed tower (Figure 13-18), both gas
and liquid phases are continuous.
A.	Packed Towers
A packed tower is filled with small solid objects designed to expose a large surface
area, which is kept wet by a continuous flow of the absorbent, over the packing as
shown in Figure 13-19.
Usually the flow through a packed column is countercurrent, with the liquid
introduced at the top to trickle down through the packing, while gas is introduced
at the bottom to pass upward through the packing. This results in high efficiency,
since, as the solute concentration in the gas stream decreases as it rises through the
tower, there is constantly fresher solvent available at the top (gas outlet) of the
tower for contact.
B.	Inspection Points
Once a tower has been designed, the operating parameter that can be changed is
the liquid flow rate and variability of the gases to be cleaned. In air pollution con
trol applications, the packed tower is often used to remove odorous substances, so
the carryover of odor is a good indicator and should be noted.
Other check points might be a change in the liquid/gas ratio, the temperature of
the liquid and the plugging of the tower by particulates or other substances, caus
ing excessive pressure drop and consequently reduced gas flow.
Adsorption
(For gases only.)
Adsorption is a process hv which there is a mass transfer of ihe < ontaminaiit hom .»
gas stream onto the surface of a highly porous solid, railed an adsoi bent. In the
general case, an adsorption prorrss is usually followed by a i egrnri at ion pi<><< v,, in
which the activity of the adsorbent is restored by driving the .ulsoi l>.n< <11- <<>u
taminant) out ol the bed. with or without recovery <>l the ailsoil>ai<
13 27

-------
Mist eliminator
Scrubber liquid
Clean
Packing
To drain or recovery
Figure 1.3-18. Packed tower.

Berl saddle
Raschig ring
Pall ring
Intalox saddle
Tellerette
Figure 13-19. Common tower packing materials.
13-28

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Activated charcoal is the adsorbent most suitable for removing organic vapors, as
it affords practical control for all vapors of compounds having boiling temperatures
above the temperature of melting ice. Even more volatile contaminants can be
effectively adsorbed if the temperature of the adsorbent is lowered.
A.	Physical Appearance
Usually a vessel for containing the adsorbing solid arranged: (a) in a cannister,
(b) in a thin bed such as a filter, or (c) in a thick bed placed in a closed cylindrical
vessel.
Thick bed units are often installed in parallel with piping and controls for
automatic cyclic operation from adsorption to desorption modes, schematically in
Figure 13-20.
B.	Inspection of Adsorbers
An adsorber is a complex process and no definitive parameters, which can be
instrumented, are available for surveillance. Since adsorbers are often used in odor
control, inspection might be the observation of odor carryover from the stack. In
many cases, economic recovery of solvents spurs the operator to maintaining effi-
ciency. The only real measure of performance is an emission test performed by a
trained stack test team.
Condensing
(For vapor recovery.)
Condensation is the process of removing a vaporous material from a gas stream by
cooling it, thereby converting it into a liquid phase. In some instances, control of
volatile contaminants can be satisfactorily achieved entirely by condensation.
However, most applications require additional control methods. In such cases, the
use of a condenser as part of the control system, or vapor recovery system, can con
fer such benefits as reducing the load on a more expensive control device.
A. Physical Appearance
Condensers are (See Figure 13-21):
•	Surface condenser such as shell and tube, a cylindrical vessel, or
•	Contact or barometric condensers where a direct spray contacts the gases wltit li
then discharge into a hot well.
Besides collecting condensable contaminants, condensers may materially reduce
the volume of the contaminated gas streams. To a degree, contact condensers are
also scrubbers. Probably their most common application is as auxiliary units in
systems containing afterburners, absorbers, baghouses, or other control devices.
13-29

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Adsorbers on stream
Adsorber
Regenerating
Solvent Laden
Air
_A


K
Condenser
Steam
Clean air
exhaust
Figure 13-20. Typical Adsorber.
13-30

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B. Inspection of Condensers
Condensers are used to abate odors or recover solvents from high temperature
exhausts from drying processes.
An important parameter is the temperature and flow rate of the condensing
liquid.
Instrumentation would permit monitoring of such temperature and flow rates.
As in adsorption, a good surveillance technique is to monitor the odor from the
stack. The only quantitative measure of compliance would be a source test.
13-31

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Vapor inlet
Tubes
Non-condensaic outlet
Baffles
Condensate outlet
Shell and tube condenser
Gas inlet
Gas outlet
/ *t 1 i
IIHllltfHIllllI itlllltlHIHI I III IIlill11 III	
Water
Spray type contact condenser
13-21. Condensers.
13-32

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Chapter 14
Inspection of Combustion Sources
INSPECTION OF COMBUSTION SOURCES FILM AND WORKBOOK
Goal
To teach the principles of combustion as they relate to an inspection to be carried
out by an experienced FEO.
Objectives
At the end of this lesson, the student should be able to:
1.	Identify various important components of fuel burning systems, especially
coal or oil,
2.	Enumerate the inspection points and observations which should be made,
3.	Explain the elements necessary for complete combustion,
4.	Define air-fuel ratio,
5.	Identify the instrumentation which relates to combustion control,
6.	Identify the instruments which relate to monitoring of the combustion pro-
cess and emissions therefrom.
Selected Reading
Reference 6, APTD-1101 — Volume II. Chapter 7. Sections I and II.
Reference 31, Enforcement Manual for NSPS. Fossil-Fuel Fired Steam Generators.
Reference 7, Air Pollution Engineering Manual. Chapter 8. Combustion
Equipment.
14-1

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INSPECTION OF COMBUSTION SOURCES FILM AND WORKBOOK
General
This lesson uses a specially written short program for study of combustion and then
presents a film demonstrating the inspection by an FEO of three fossil-fuel fired
steam generators:
Part 1	Utility Boiler with Pulverized Fuel and ESP. A cyc lone furnac e is
demonstrated.
Part II	Industrial Boiler Fired by a Spreader Stoker, Equipped with a
Multi-Cyclone Collector.
Part III Oil Fired Utility Boiler with no Collector.
Special Student Manual
A special manual for the students titled, "Inspection of Combustion Sources" and
included in exercise 6 of your workbook contains two components: first, a general
discussion of combustion and combustion equipment called the Workbook, and
second, the film with an introduction and data forms to be filled out while viewing
each part. An Instructor's Manual is supplied to the instructor containing the data
forms as completed by the inspector in the film.
Student Workbook
The beginning parts of exercise 6 in the workbook are intended to be a self study
manual on combustion practices. Because of the length of time that would be
required to read and study the material, it cannot be used in this manner for this
course. In its place, a thirty minute presentation of the principles of combustion,
based on the workbook will be given by the instructor.
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Chapter 15
Emergency and Alert Procedures
EMERGENCY AND ALERT PROCEDURES
AIR POLLUTION EPISODES
Goal
To describe the conditions which create emergency situations and the FEO response
to such emergencies.
Objectives
At the end of this lesson, the student should be able to:
1.	Differentiate between local emergencies and air pollution emergency
episodes,
2.	Explain the involvement of the FEO in local emergencies,
3.	Give three examples of possible causes of local emergencies,
4.	Name four stages of the episode plan structure,
5.	Explain the type of inspections required of the FEO during emergency
episodes.
15-1

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EMERGENCY AND ALERT PROCEDURES
AIR POLLUTION EPISODES
Introduction
Emergenc ies are of two types: (a) local emergencies, that is incidents involving the
untoward release of contaminants that may be toxic or have the potential for other
undesirable health or environmental effects; and (b) air pollution episodes in which
the buildup of contaminants in the atmosphere approaches or exceeds pre-
determined levels and may necessitate the curtailment or shutdown of source
activities on a large scale. These conditions require swift response on the part of
enforcement officers and performance of special inspections.
Local Emergencies
Local emergencies may be observed during field patrol, may occur as a result of
citizen complaints or result from reported breakdowns of equipment. Frequently,
other governmental units such as fire and police will report emergency conditions
and request assistance.
Examples of these emergencies include emergency dumping of ammonia from
commercial refrigeration systems; explosions from a chlorine manufacturing plant;
safety valves lifting; sudden failure of central device; refinery breakdowns and fires;
the spread of noxious or malodorous gases; or radiation accidents.
Special emergency field sampling equipment that may be needed during local
emergencies include explosimeters, geiger counters, test papers, tutweiler
apparatus, midget impingers, gas absorption cells, halide leak detectors, sling
psychrometers, and so on.
Description of the foregoing equipment and other on-the-spot testing can be
found in the Field Operation and Enforcement Manual, Vol. I, (Reference 4,
Chapter 4, Section VI, F.) The effective use of this equipment would generally be
assigned to a technical services group, but in an emergency the FEO may be
required to take samples. Interpretation of results of measurement is open to ques-
tion and depends on the training of the sampling group.
The field enforcement officer's knowledge of the sources and the properties of
the toxic gases that may be involved would be helpful. He should know whether
potential hazards to life or health exist within the sources he is assigned for supervi-
sion. The benefit of a doubt should be given to the possibility of a hazard and
appropriate assistance should be sought from health, fire or police authorities.
A full report of any incident should be made including any possible determina-
tion as to whether it was due to accidental or to deliberate causes. Industries which
have a potential for posing hazards to health under accidental or abnormal condi-
tions should be required to install and continuously maintain source monitors or
otherwise provide for preventative measures.
15-2

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Air Pollution Emergency Episodes
The State Implementation Plans must include episode contingency plans which, at
a minimum, provide for preventing ambient pollutant concentrations from
reaching levels which could cause significant harm to health of persons within the
affected area.
Significant harm levels are set by EPA (40 CFR 51.16 (a)) as
S02- 2,620 jx/m3 (1.0 ppm), 24-hr. average
Particulate - 1000 ftg/m3 or 8 COHs, 24-hr. average
490* 103(/ig/m3)2)
Product (TSP»S02) - . _	> 24-hour average
1.5 COHs»ppm J
O3- 1,200 /xg/m3 or 0.6 ppm 1-hr. average
CO - 57.5 mg/m3 (50 ppm), 8-hr. average
86.3 mg/m3 (75 ppm), 4-hr. average
114 mg/m3 (125 ppm), 1-hr. average
N02- 3,750 ng/m$ (2.0 ppm), 1-hr. average
938 ng/m3 (0.5 ppm), 24-hr. average
A.	Episode Plan Requirements
The episode plan must contain:
•	Episode criteria
•	Surveillance system
•	Emission reduction plan
•	Communication system
•	Legal authority
B.	Episode Structure
A four-stage episode structure is generally adopted to meet the plan requirements.
The stages, in order, are Forecast, Alert, Warning, Emergency.
Figure 15-1 shows the Air Pollution Episode Sequence suggested by 40 CFR
51.16 and Appendix L.
Response in Emergencies
Air pollution episodes, general or local, require out of the ordinary response by the
entire agency and in particular by the FEO. In the local episode the FEO will
usually be first at the scene especially if radio communication is available. Often,
other units as fire, police or civil defense will also be there. The FEO surveys needs
for technical help and calls for same or acts on his own knowledge depending upon
the seriousness of the situation.
In the general air pollution emergency, more time is available because of the
staged procedure. The FEO will have little responsibility for initiating any part of
the plan but will function according to a preassigned set of tasks. The main thrust
15-3

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of the FEO would be to monitor the effectiveness of curtailment orders and act to
bring sources into compliance with general orders or with the source bv source
emergency curtailment plan.
A most important part of the FEO training in preparation for his field assign
merit during an emergency is to establish a firm understanding of the enforcement
policies when noncompliance and/or noncooperation is observed during the
emergency. The agency cannot wait until the day of the emergency to decide on
such enforcement policy.
In all curtailment plans, it is worthy to note that some sources may requite many
hours to shut down. Such time requirements must he provided for in the source
curtailment plan.
FORECAST, ALERT, WARNING, EMERGENCY
Forecast
Alert
Warning
Emergency
1
Condition
continues
Condition
continues
Condition
continues
Meteorological
Monitoring


Atmc
Stag
Ad
spheric
nation
risory
Control
Agency
I
Forecast
Meteorology Conditions
Only
Agency prepare for
potential episode
Advise major sources
1st Alert
safe, but preventive
action required
Public announcement
Fuel switching
Curtail incineration
^burning
2nd Alert
Preliminary health hazard
Selective curtailment
of industrial activities
3rd Alert
Dangerous health hazard
Major curtailment of all
activities in community
Air
Monitoring
Pollutant
reaches
1st level
Pollutant
increases to
2nd level
Pollutant
increases
to 3rd level
Figure 15-1. Emergency episode, sequence procedure. "...To prevent ambient pollution concen
trations from reaching levels which could cause significant harm to the health of persons..."
15-4

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Summary
In summary, the FEO should prepare for emergency situations by learning, in
advance, what he is expected to do, the curtailment requirements, source by
source, and how he reacts to the nonconformist.
15-5

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A. REFERENCES
1.	The Federal Clean Air Act.
2.	11.S. Government. Code of Federal Regulations, Title 40, parts 50 to 59. U.S. Government
Printing Office, Washington, DC; 1978.
3.	U.S. Government. Code of Federal Regulations, Title 40, parts 60 to 99. U.S. Government
Printing Office, Washington, DC; 1978.
4.	U.S. EPA, Office of Air Programs. Field Operations and Enforcement Manual for Air
Pollution Control, Volume I: Organization and Basic Procedures, APTD-1100, Research
Triangle Park, NC; 1972.
5.	U.S. EPA, Office of Air Quality Planning and Standards. Guidelines for Public Reporting of
Daily Air Quality— Pollutant Standard Index (PSl), EPA 450/2-76-013. Research Triangle
Park, NC; 1976
6.	U.S. EPA Office of Air Programs. Field Operations and Enforcement Manual for Air Pollu-
tion Control, Volume II: Control Technology and General Source Inspection, APTD-1101.
Research Triangle Park, NC; 1972.
7.	Danielson, J.A. Air Pollution Engineering Manual, 999-AP-40, Second Edition. EPA
OAQPS; May 197S.
8.	Air Pollution Training Institute. EPA Course SI 422—Air Pollution Control Orientation
Course. Research Triangle Park, NC; 1979.
9.	Knight, H. and Stevenson, W. Communication for Justice Administration, Theory and Skills.
Cincinnati, OH: Anderson Publishing Co.; 1976.
10.	U.S. EPA. Inspection Manual for Enforcement of New Source Performance Standards,
Portland Cement Plants, EPA 340/1-75-001; 1975.
11.	U.S. EPA. EPA Standards of Performance for New Stationary Sources, Appendix A,
Method 9. Code of Federal Regulations, 40 part 60.
12.	Gruber, C.W., and Jutze, G. Air Pollution Effects Surveillance, Chapter 10, Volume III,
Ed. 3 of Air Pollution, A.C. Stern, Ed., New York: Academic Press; 1976.
13.	Segal, A.H. Criminal Actions, ARB Enforcement Symposium, Sacramento, CA: Sept. 14-16,
1977.
14.	U.S. EPA, Office of Air Quality Planning and Standards. Diagnosing Vegetation Injury
Caused by Air Pollution, EPA-450/3-78-005 handbook. Research Triangle Park, NC;
1978.
15.	U.S. EPA. Guidelines for Evaluation of Visible Emissions, Certification, Field Procedures,
Legal Aspects and Background Material, EPA-S40/1-75-007; April 1975.
16.	EPA Air Pollution Training Institute. Course SI 448 Diagnosing Vegetation Injury Caused by
Air Pollution, Research Triangle Park, NC; 1979.
17.	Frye. R.P., Notes for Ovenriew of the Federal EPA in the Enforcement Program with
Emphasis on the Interface with State Enforcement, EPA Course 444, Pittsburgh, PA; July
1978.
18.	Gruber, C.W. Notes from talks on the Federal Clean Air Act, given by the following:
(a)	Foster, K., Engineer, Division of Stationary Source Enforcement Course 444. Research
Triangle Park, NC; Oct. 1978 and Jan. 1978.
(b)	Walker, M.S., Senior Attorney/Hearing Officer, Enforcement Division, EPA Region
IX, Course 444, Honolulu; August 1978.
(c)	Sanderson, M. General Attorney, Enforcement Division, EPA Region VII, Course 444,
St. Louis; May 1978.
(d)	Phillips, C. Chief, General Enforcement Section, EPA Region VIII, Course 444.
Denver; Feb. 1978.
19.	Nader, J.S. Current Techniques of Odor Measurement, Chemical-Toxicological Conference.
A.M.A. Archives of Industrial Health. Volume 17, No. 5; May 1978.
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20.	Crocker, h.C. and Henderson, C.F. Analysts and Classification of Odors, American Perfumer
and Essential Oil Review 22:325; 1927,
21.	McCord, C.P., and Witherridge, W.N. Odors Physiology and Control. New York; McGraw-
Hill Book Co., Inc., 1949.
22.	Phelps, A.H., "Odors," in Air Pollution, Volume III, Edition 3 A C. Stern (ciI.). New York
City: Academic Press; 1976.
23.	Turk, A. Selection and Training ofJudges for Sensory Evaluation of the Intensity and
Character of Diesel Exhaust Odors. DHEW, PHS, Pub. No. 999-AP-32; 1967.
24.	Prince, R.G.H., and Ince, J.H. The Measurement of Intensity of Odor. J. Appl. Chem. H:
314-321; 1958.
25.	Leonardos, G., Kendall, D. and Barnard, N. Odor Threshold Determinations of 53 Odorant
Chemicals. J. Air Pollution Control Association. Volume 19, No. 2; February 1969.
26.	Benforado, D.M., Rotella, W.J., and Horton, D.L. Development of Odor
Control Equipment. J. Air Pollution Control Association. Volume 19, No. 2; February
1969.
27.	Gruber, C.W.,Jutze, G.A., Huey, N.A., Odor Determination Techniques for Air Pollution
Control. J. Air Pollution Control Association 10:327-330; 1960.
28.	Feldstein, M., Story, T.E., and Mangat, T.S. The Control of Odor by Emission Limitations,
APCA Paper 77-38.4 APnA Pittsburgh, PA; 1977.
29.	Prokov, W.H., et al. Developing Odor Control Regulations, Guidelines and Considerations. J. Air
Pollution Control Association. Volume 28, No.1., January 1978.
30.	U.S. EPA. Inspection Manual for Enforcement of New Source Performance Standards,
Asphalt Concrete Plants; 340/1-76-003. 1976.
31.	U.S. EPA. Inspection Manual for Enforcement of New Source Performance Standards, Fossil
Fuel Steam Generators, 340/1 -78-002; 1975.
32.	U.S. EPA. Industrial Guide for Air Pollution Control, EPA Handbook; June 1978.
33.	Air Pollution Training Institute. Continuous Monitoring for Source Emissions. EPA Training
Course 474; April 1977.
34.	Air Pollution Training Institute. Source Sampling for Particulate Pollutants, Student
Manual. EPA Course 450.
35.	U.S. EPA. Resource Manual for Implementing the NSPS Continuous Monitoring
Regulations, Manual 3—Procedures for Agency Evaluation of Continuous Monitor Data
and Excess Emission Reports, 340/1-78-0050; 1978.
36.	Steiner, J. and Jaye, F. Draft of Inspector's Manual for Continuous Monitoring Systems
(Acurex Corp. /Aerotherm Div.). Contract 68-01-3158, Task 8; (August 1976).
37.	Air Pollution Training Institute. Trainee's Manual, Field Enforcement in Air Pollution Con-
trol. U.S. EPA; 1975. Unpublished.
38.	Air Pollution Training Institute. Instructor's Manual and Student Manual, APTI Course No.
439, "Visible Emissions Evaluation," EPA-450/3-78-105 and EPA-450/3-78-106, Research
Triangle Park, NC.
39.	Kudlich, R., Ringelmann Smoke Chart, Bureau of Mines Information Circular No. 7718, No.
8333, revised. Dept of the Interior, May 1967.
A 2

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B. SOURCES OF TECHNICAL INFORMATION AND FURTHER
TRAINING OPPORTUNITIES
Sources of Technical Information
Many of the manuals should be available in the libraries of the individual agencies.
However, where manuals would be helpful to the FEO, it is suggested he obtain a
copy for his personal use.
Many publications can be obtained without cost by writing on agency letterhead
to EPA Library Services.
A list of publications is shown in Appendix C.
Library Services
The Library Service Office at EPA, Research Triangle Park, North Carolina fur
nishes documents and literature searches for eligible groups and even personalized
reference service.
For more information about library services, or to obtain single copies of EPA,
A.P. documents write or call:
Library Services, MD-35
Environmental Protection Agency
Research Triangle Park, NC 27711
Commercial Phone 919-541-2777
FTS Phone	629-2777
Training Courses
At the end of this course, it is evident that many of the FEO's activities were
"introduced." The FEO should now consider the courses which are deeper in the
individual areas which go to make up the whole job. For example, Course 425 goes
deeper into legal aspects; 431 begins to probe control technology; 413, 415, 482 are
quite technical in control equipment application; 450 is source sampling for par-
ticulates, and so on. See Figure B-l for a recommended sequence of Courses for
Field Inspection.
A catalog ol available training courses is published annually by the AP I I.
Information on training programs can be obtained by writing:
U.S. Environmental Protection Agency
Control Programs Development Division
Air Pollution Training Institute
MD 20
Research Triangle Park, NC 27711.
B-l

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422
—r	1
r ± i r ~L
L4- _J l_t!!
nr ni— ~i
482
. 427 , 413
I	II	I
444
431
VE
Code
—	— Recommended courses
—	= Highly desirable courses
VE = Visable Emission Evaluation
In addition to the courses shown above, the following courses are suggested for further job
enrichment, based upon an individual's job and interests:
SI 406 435 SI 448 450 463 468 483
Figure B-l. Field Inspection Course Sequence
(For individuals who are involved in field inspection and enforcement in a governmental agency.)
Other Advanced Training
Those FEOs with bachelor's degrees should seriously consider advanced university
training by entering master's degree programs either on a fulltime or parttime
basis. Many universities arrange their classes in evenings and on weekends to
accommodate those who are employed.
Look for scholarships or grants to fund advanced study. In 1979, llit* U.S. I-.I'A
has scholarships available and many agencies will pay tuition lor surli adv,m< 
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C . LIST OF SELECTED PUBLICATIONS
OF INTEREST IN ENFORCEMENT1
Background Information on Industrial Processes
EPA Reports:
1.	Air Pollution Engineering Manual, AP-40, second edition. John Danielson,
cd., US EPA, Research Triangle Park, NC; May 1973.
2.	Compilation of Air Pollution Factors, parts A and B with Supplement 1-5,
AP-42. US EPA-MDAD/OAQPS, Research Triangle Park, NC.
3.	Field Operations and Enforcement Manual for Air Pollution Control: Vol. I;
Organization and Basic Procedures (APTD-1100), Vol. II;
Control Technology and General Source Inspection (APTD-1101), Vol. Ill;
Inspection Procedures for Specific Industries (APTD-1102).
US EPA, Research Triangle Park, NC; August 1972.
4.	Field Surveillance and Enforcement Guide for Primary Metallurgical Industries,
EPA-450/3-73-002. US EPA, Research Triangle Park, NC; December 1973.
5.	Controlled and Uncontrolled Emision Rates and Applicable Limitations for
Eighty Processes. EPA Contract 68-02-1382 Task Order #12, US EPA, Research Triangle
Park, NC; September 1976.
6.	Technical Guide for Review and Evaluation of Compliance Schedules for Air
Pollution Sources, EPA 340/1-73-OOla. US EPA-DSSE, Washington, DC; July 1973.
(A revised and updated guide is being printed.)
7.	Industrial Process Profiles for Environmental Use: Chapter 3—Petroleum Refining Industry,
EPA 600/2-77-023, Chapter 24—The Iron and Steel Industry, EPA 600/2 17 023x. US
EPA 1ERL/ORD, Research Triangle Park, NC; 1977. (Chapters 1-30 covering 30 in-
dustrial categories are being prepared.)
8.	Field Surveillance and Enforcement Guide: Wood Pulping Industry, 450/3-75-027. US EPA,
Research Triangle Park, NC; March 1975.
9.	Field Surveillance and Enforcement Guide: Petroleum Refineries, 450/3-75-042. US EPA,
Research Triangle Park, NC; July 1974.
10.	Background Information for Proposed New Source Performance Standards.
(Technical information reports describing the basic process equipment and operation are
published for each source category for which Federal emission standards are promulgated)
US EPA, ESED/OAQPS, Research Triangle Park, NC
11.	Inspection Manuals for Enforcement of New Source Performance Standards:
Fossil-Fuel-Fired Steam Generators, EPA 340/175-002;
Portland Cement Plants, EPA 340/1-75-001;
Municipal Incinerators, EPA .340/1 75-004;
Asphalt Concrete Plants, F.PA H40/1 7<> 003.
Secondary Lead Smellers F.PA 310/I 77 001;
Basic Oxygen Process Furnaces, EPA 340/1 77 00/;
Secondary Brass 9 Bronze Ingot Production, l\l'A 340/1 77 00'.;
Petroleum Refineries (being printed);
Storage Vessels for Petroleum Liquids (being printed);
Nitric Acid Plants (being prepared);
Sulfuric Acid Plants (being prepared);
Phosphate Fertilizer Plants (being prepared). US KPA DSSE, Washing.,,.. IX.
* Source: Kirk & Foster, U.S. EPA, Division of Stationary Source Enforcement, I <>78.
CM
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Text Books:
1.	Stern, Arthur C., cd. Air Pollution, New York: Academic Press; 1977 (especially Vol. III).
2.	Kirk and Othmer, ed. Encyclopedia of Chemical Technology, Interscience Publishers; 1970.
3.	McGraw-Hill Encyclopedia of Science and Technology, McGraw-Hill; 1971.
4.	Bond and Straub, ed. Handbook of Environmental Control, CRC Press; 1972
(especially Vol. I).
5.	Lund, Herbert, ed. Industrial Pollution Control Handbook, McGraw-Hill; 1971.
6 Shreve, Norris. Chemical Process Industries, McGraw-Hill; 1967.
Miscellaneous Reports on Industrial Processes Displayed at Region IV Workshop:
1.	Source Assessment: Class Container Manufacturing Plants, EPA-600/2-76-269. US EPA,
Research Triangle Park, NC; October 1976.
2.	Guidelines for Industrial Boiler Performance Improvement, EPA-600/8-77-003a. US EPA,
Research Triangle Park, NC; January 1977.
General Information on Enforcement Program Operation
1.	Field Operations and Enforcement Manual for Air Pollution Controls: Vol. I-Organization
and Basic Procedures, APTD-1100. US EPA, Research Triangle Park, NC; August 1972.
2.	Guidelines for Technical Services of a State Air Pollution Control Agency, APTD-1347.
US EPA, Research Triangle Park, NC; November 1972.
3.	Guide to Engineering Permit Processing, APTD-1164. US EPA, Research Triangle Park, NC;
July 1972.
4.	Enforcement Management System Users Guide, APTD-1237. US EPA, Research Triangle
Park, NC; September 1972.
5.	Analysis of Final State Implementation Plans—Rules and Regulations, APTD-1334. US EPA,
Research Triangle Park, NC; July 1972.
Sources of Current Industrial Process/Control and Stack Sampling Information
1.	U.S. EPA Cumulative Bibliography, parts 1 and 2, PB 26S-920; December 1976.
2.	Computerized Literature Search Systems. (There are several commercial computerized
literature search systems. They are used through terminals located in many places.
Employees of governmental air pollution control agencies, nonprofit citizens environmental
groups and a few others can request searches using these services through the EPA library,
MD-35, Research Triangle Park, NC 2771 1.
Those seeking further information and other parties should contact the .search service
vendors listed below:
Lockheed Retrieval System (Dialog)
Dept. 208, Building 201
3251 Hanover Street
Palo Alto, California 94304
(800) 277-1960
System Development Corporation
2500 Colorado Avenue
Santa Monica, California 90406
(800) 421-7229
Bibliographic Research Service
Corporation Park, Building 702
Scotia, New York 12302
(518) 374-5011
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3.	Environmental Pollution & Control, (weekly government abstracts). Weekly newsletter con-
taining technical report summaries, $40/year, available from National Technical Informa-
tion Service (NTIS), 5285 Port Royal Road, Springfield, Va. 22161.
4.	Stack Sampling News, (monthly), publication for Source Testing Information, $30/yr.,
available from Technomic Publishing Co., 265 W. State St., Westport, Conn. 06880.
5.	Source Evaluation Society, Newsletter (quarterly), $10/yr. Current Editor, Roger Shigerhara,
ESED (MD-19), US EPA, Research Triangle Park, NC 27711.
General Background Information on Source Testing Methods and Procedures
1.	Brenchly, D. L., and Turley, C. D. Industrial Source Sampling, Ann Arbor Science
Publishers, Inc., P. O. Box 1425, Ann Arbor, Michigan 48106.
2.	Rossano, A. T., and Cooper, H. D. Source Testing for Air Pollution Control, Environmental
Science Services, Wilton, Conn.; 1971.
3.	Administrative and Technical Aspects of Source Sampling for Particulates, EPA
450/3-74-047. US EPA-OAQPS, Research Triangle Park, NC; August 1974.
Miscellaneous Reports and Manuals Displayed at Region IV Workshop
1.	Symposium on Fugitive Emissions Measurement and Control, EPA 600/2-76-246. US EPA-
IERL/ORD, Research Triangle Park, NC; September 1976.
2.	Technical Manual for the Measurement of Fugitive Emissions: Quasi-Stack Sampling
Method, US EPA 600/2 76 089c. US EPA-IERL/ORD, Research Triangle Park, NC; May
1976.
3.	Technical Manual for Measurement of Fugitive Emissions: Upwind/Downwind Sampling
Method, US EPA 600/2-76-089a. US EPA-IERL/ORD, Research Triangle Park, NC;
April 1976.
4.	Technical Manual for Measurement of Fugitive Emissions: Roof Monitor Sampling Method,
EPA 600/2-76-0896. US EPA IERL/ORD, Research Triangle Park, NC; May 1976.
5.	Particulate Sampling Strategies for Large Power Plants including Non-uniform Flow. EPA
Contract No. 68-02-1244, US EPA-ESRL/ORD, Research Triangle Park, NC.
6.	Collaborative Study of Particulate Emission Measurements by EPA Methods 2, 3, and 5 using
Pair Particulate Sampling Trains (Municipal Incinerators), EPA 600/4-76-014. US EPA-
EMSL/ORD, Research Triangle Park, NC; March 1976.
7.	Guidelines for Development of a Quality Assurance Program: Vol. IV-Determination of Par-
ticulate Emissions from Stationary Sources, EPA 650/4-74-005d. US EPA-EMSL/ORD,
Research Triangle Park, NC; August 1974.
8.	Evaluation of Stationary Source Particulate Measurement Methods Vol I Portland Cement
Plants, EPA 6*0/2-71 -OUa. US EPA ESRl./ORl), Research Triitngle Park, NO; June
1 !)7.r>.
51. Particulate Sizing Techniques for Control Device Eitilualioii. I\l'.l	It 102 US l\l'A
IERL/ORD, Research Triangle Park, NC; October li>71.
10.	Cascade Impactor Calibration Guidelines, EPA 600/2-76-118. US EPA-1KR1./OR1),
Research Triangle Park, NC; April 1976.
11.	Magnitude of SO2, NO, CO2, and O2 Stratification in Power Plant Ducts, EPA
600/2-75-053. US EPA-ESRL/ORD, Research Triangle Park, NC; July 1975.
12.	The Effects of Nozzle Design and Sampling Techniques on Aerosol Measurements, EPA
650/2-74-070. US EPA-ESRL/ORD, Research Triangle Park. NC; July 1974.
13.	HP-65 Programmable Pocket Calculator Applied to Air Pollution Measurement Studies: Sta-
tionary Sources, EPA 600/8-76-002. US EPA-IERL/ORD, Research Triangle Park, NC;
October 1976.
14.	Stack Sampling Nomographs for Fteld Estimations, available from Entropy Environmen-
talists, Inc. P. O. Box 12291, Research Triangle Park, NC, 27709
C-3
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State Compliance Sampling Manuals (Examples)
1.	Compliance Sampling Manual, Revised 1975. Texas Air Control Board, 8520 Shoal Creek
Boulevard, Austin, Texas 78758.
2.	Source Sampling Manual, Amended August 1975. Tennessee Department of Public Health,
Division of Air Pollution Control, Cordell Hull Bldg., Nashville, Tenn. 37219.
3.	Source Sampling Manual, January 1976. Oregon Department of Environmental Quality, Air
Quality Control Division, 1234 S.W. Morrison Street, Portland, OR, 97205.
4.	Compliance Sampling Manual. Iowa Department of Environmental Quality, Air Quality
Management Division, 3920 Delaware, Des Moines, IA, 50316.
C-4
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 2.
EPA 450/2-80-075
3. RECIPIENT'S ACCESSION»NO.
4. TITLE AND SUBTITLE
APTI Course 444
Air Pollution Field Enforcement
Student Manual
5. REPORT DATE
March 1980
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
C. W. Gruber, P. M. Giblin
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
B18A2C
11. CONTRACT/GRANT NO.
68-02-3014
12. SPONSORING AGENCV NAME AND AOORESS
U.S. Environmental Protection Agency
Manpower and Technical Information Branch
Air Pollution Training Institute
Research Trianele Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
Student Manual
14. SPONSORING AGENCY CODE
EPA-0ANR-0AQP S
15. SUPPLEMENTARY NOTES
EPA Project Officer for this manual is J. 0. Dealy, EPA-ERC, MD-17, RTP, NC 27711.
16. ABSTRACT
This is a student manual to be used in the air pollution training course
444 entitled "Air Pollution Field Enforcement". It is essentially a
textbook for the 3*5 day course for governmental air pollution control
agency personnel responsible for enforcement of air pollution regulations.
Topics covered include the role of the field enforcement officer) the
enforcement process; surveillance techniques; handling odor complaints;
inspection techniques; emission control equipment; legal procedures; and
enforcement programs.
The Student Manual is to be used £n conjunction with the Instructor's
Guide (EPA 450/2-80-077) and Student Workbook (EPA 450/2-80-076).
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Education
Books
Manuals
Air Pollution —
Training course
Student Manual
13 B
5 I
68 A
18. DISTRIBUTION STATEMENT Unlimited
Available from National Technical
Information Service, 5285 Port Royal
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
162
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
epa Form 2220-1 (..73) Road> Springfield, VA 22161
C-5
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