Air Pollution Training Institute
United States MD 20 EPA-450/2-80-077
Environmental Protection Environmental Research Center March 1980
Agency Research Triangle Park NC 27711
Air
APTI
Course 444
Air Pollution
Field Enforcement
Instructor's Guide
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United States
Environmental Protection
Agency
Air Pollution Training Institute
MD 20
Environmental Research Center
Research Triangle Park NIC 27711
EPA 450/2-80-077
March 1980
Air
APTI
Course 444
Air Pollution
Field Enforcement
Instructor's Guide
Prepared By:
C. W. Gruber, PE
Cincinnati, Ohio 45213
With Legal Units By:
P. M. Giblin
Attorney at Law
Austin, Texas 78701
Under Contract No.
68-02-3014
EPA Project Officer
James O. Dealy
United States Environmental Protection Agency
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, NC 27711
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Notice
This is not an official policy and standards document. The opinions, findings, and
conclusions are those of the authors and not necessarily those of the Environmental
Protection Agency. Every attempt has been made to represent the present state of
the art as well as subject areas still under evaluation. Any mention of products or
organizations does not constitute endorsement by the United States Environmental
Protection Agency.
Availability of Copies of This Document
This document is issued by the Manpower and Technical Information Branch, Con
trol Programs Development Division, Office of Air Quality Planning and Standards,
USEPA. It was developed for use in training courses presented by the EPA Air Pollu-
tion Training Institute and others receiving contractual or grant support from the
Institute. Other organizations are welcome to use the document for training purposes.
Schools or governmental air pollution control agencies establishing training programs
may receive single copies of this document, free of charge, from the Air Pollution
Training Institute, USEPA, MD-20, Research Triangle Park, NC 27711. Others may
obtain copies, for a fee, from the National Technical Information Service, 5825 Port
Royal Road, Springfield, VA 22161.
il
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pnct*-
AIR POLLUTION TRAINING INSTITUTE
MANPOWER AND TECHNICAL INFORMATION BRANCH
CONTROL PROGRAMS DEVELOPMENT DIVISION
OFFICE OF AIR QUALITY PLANNING AND STANDARDS
The Air Pollution Training Institute (1) conducts training for personnel working on the develop-
ment and improvement of state, and local governmental, and EPA air pollution control programs,
as well as for personnel in industry and academic institutions; (2) provides consultation and other
training assistance to governmental agencies, educational institutions, industrial organizations, and
others engaged in air pollution training activities; and (3) promotes the development and improve-
ment of air pollution training programs in educational institutions and state, regional, and local
governmental air pollution control agencies. Much of the program is now conducted by an on-site
contractor, Northrop Services, Inc.
One of the principal mechanisms utilized to meet the Institute's goals is the intensive short term
technical training course. A full-time professional staff is responsible for the design, development,
and presentation of these courses. In addition the sendees of scientists, engineers, and specialists
from other EPA programs governmental agencies, industries, and universities are used to augment
and reinforce the Institute staff in the development and presentation of technical material.
Individual course objectives and desired learning outcomes are delineated to meet specific program
needs through training. Subject matter areas covered include air pollution source studies, atmos-
pheric dispersion, and air quality management. These courses are presented in the Institute's resi-
dent classrooms and laboratories and at various field locations.
/James A. Jahnlke
Technical Director
R. Alan Schueler
Program Manager
Northrop Services, Inc.
Northrop Services, Inc.
" Jean J: Schueneman
Chief, Manpower 9 Technical
Information Branch
iii
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FOKEWO RD
The Air Pollution Field ihforcement Course, No. Wi-, has been in the
curriculum of the Air Pollution Training Institute since its "beginning
in the late nineteen sixties. It has been given more than fifty time?;
with the agenda being altered to meet the changing needs of enforcement
created ty frequent enactment of new air pollution legislation at the
federal, state, and local government levels.
In 1977, the United States Environmental Protection Agency commissioned
Charles W. Giuber, P.E., Cincinnati, Ohio and Michael V. Mclntlre, J. D.,
Santa Monica, California to survey ten diverse control agencies to
determine the continuing need for training in field enforcement. The
survey concluded}
"The need is for a primary course for inexperienced
personnel, as well as a 'back to basics' refresher
course for experienced field enforcement officers."
In mid 1978, the Air Pollution Training Institute commissioned Charles
Gruber to carry out the survey recommendations by re-writing Course kbk
objectives and subject materials. Pamela M. Giblin, Attorney, Austin,
Texas, was selected to contribute the legal aspects.
Both authors drew upon their personal experiences of many years of
involvement in air pollution control administration and enforcement.
For more than eight years, both lectured in previous presentations of
Course Wj-.
The revised objectives and agenda, approved by the Air Pollution Training
Institute at the beginning of the work, have been constructed to teach
the broad principles which guide the Field Ehforcement Officer in the
conduct of his duties.
iv
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The Course covers three and one-half days, divided into;
First Day - The Field Enforcement Officer, His Job,
How He Prepares Himself, and How He Does It.
Second Day - The Legal Aspects of Enforcement.
Third Day - The Technical Aspects and Workshops.
Fourth Day - Continuation of Third Day subjects and summation.
Three separate books comprise the course resource materials
1. The Student Manual, written especially to parallel the
course sequence.
2. The Student Workbook containing the exercises.
3. The tnscructor's Manual for tha course facility.
The work was performed under the United States Environmental Protection
Agency, Contract No. 68-02-301^.
February 6, 1979
v
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Ackno wledgemen ts
A number of people contrite ted to this undertaking. My wife, Jean,
whose background in teaching enabled her to make many constructive
suggestions which improved the educational quality of the course
materials. James 0. Dealy, Project Officer, was constantly providing
related technical materials and promptly responded to questions.
Jean J. Schueneman, Chief of the Manpower and Technical Information
Branch, EPA, was most helpful "by his careful review of the course,
and Kirk Foster, Engineer, Division of Stationary Ehforcement, EPA,
contributed suggestions related to federal enforcement. James Hambright,
Director, Bureau of Air Quality and Noise Control, Commonwealth of
Pennsylvania, originally wrote the complaint handling case study. The
Instructional Development Staff of Northrop Services, Inc., the Air
Pollution Training Institute Contractor for EPA, produced the art work
and the slides which add substantially to the teaching efficiency of
the course materials. Eleanor Chappell skillfully transcribed the
manuscript to the finished product.
Charles W. Gruber, PE
Emeritus Associate Professor
Environmental Engineering
University of Cincinnati
February 6, 1979
vi
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TABLE OF CONTENTS
PAGE
PART I
Catalogue Description 1-1
Course Objectives 1-2
Terminal Objectives 1-4
Job Description, Field Enforcement Officer 1-6
Model Agenda 1-9
Agenda with notes 1-12
General Information I-l6
PART II
Course Opening 0-1
Lesson 1. - Overview of Air Quality Control 1-1
Lesson 2. - The Role of the Field Enforcement Officer 2-1
Lesson 3« - The Ehforcement Process 3-1
Lesson 4. - Off-Site Surveillance, Opacity, Documentation 4-1
Student Exercise No. 1 - Section I 4-14
Answer Sheet, Student Exercise No. 1, Section I (4-16)
Lesson 5* - On-Site Inspection of Sources 5-1
Student Exercise No. 1 - Section II 5-13
Answer Sheet, Student Exercise No. 1, Section II (5-1*0
Lesson 6. - Inspection of a Cement Plant 6-1
Answer Key, Lesson 6 6-6
Test No. 1 Answer Key 6-11
Lesson 7> - Basic Federal Legal Provisions, Constitutional 7-1
and The Clean Air Act
Lesson 8. - State and Local Laws and Administrative Procedures 8-1
Lesson 9« - Litigation Procedures 9-1
Lesson 10. - Court Room Procedures 10-1
Film, Role of the Witness
Lesson 11. - Mock Trial of Opacity and TSP Violation 11-1
Student Exercise
Answer Key, Lesson 11. Actual Trial Qiestions 11-5
Lesson 12. - Overview of the Federal EPA Ehforcement Program 12-1
Test No. 2 Answer Key (12-8)
vii
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Page 2 of 2
TABLE OF CONTENTS
PAGE
Lesson 13.
Lesson 14.
Lesson 15.
Lesson 16.
Lesson 17.
Lesson 18.
Lesson 19.
COURSE FINALE
Test No. 3
References
Appendix
Complaint Handling - Odor Complaint Case Study 13-1
Answer Key, Lesson 13 13-5
Odor Detection and Evaluation 14-1
Complaint Inspection of an Asphalt Plant 15-1
Answer Key, Lesson 15 15-7
Emission Control Hardware - Inspection Techniques 16-1
Inspection of Combustion Sources
Answer Key, Lesson 1?
Air Pollution Emergency and Alert Procedures
Sources of Technical Information
Further Training Opportunities
Answer Key
Tests and Answer Keys to be reproduced and
distributed to students at appropriate times.
17-1
17-12
18-1
19-1
19-4
(19-5)
20-1
viii
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CATALOGUE DESCRIPTION
W+
AIR POLLUTION FIELD ENFORCEMENT
3|- Day Lecture Course
PREREQUISITE: None
COURSE DESCRIPTION: This course is designed for the field enforcement
officer responsible for enforcement of air
pollution regulations who is relatively new in
the field, or who wishes to have a refresher
course. It provides an overview of the need for
control of pollutant emissions to the atmosphere.
The student is instructed in the procedures of
identifying an air pollution violation, gathering
evidence of the violation, and filing a citation.
Classroom demonstrations illustrate proper
handling of evidence for litigation and conduct
of a witness in the court room. Specific training
sessions are directed at recognizing control devices
and inspection points to assess failure, handling
odor complaints, and dealing Kith accident or
upset air pollution episodes.
MAJOR TOPICS: Overview of Air Quality Control
The Clean Air Act and Amendments
Common and Statuatory Law as Related to
Air Pollution Control
The Role of the Field Enforcement Officer
Types of Enforcement Systems and the
Enforcement Process
Inspection of Air Pollution Sources
Handling Public Complaints About Odors and
Other Situations
Hearing Boards and Courtroom Procedures,
Rules for Gathering Evidence, Role of an
Expert Witness
Case Studies
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COURSE NO. 444 GOAL OBJECTIVES
OVERALL GOAL
To maximize the effectiveness of the Field. Enforcement Officer
in the performance of those tasks which seek to bring sources
into compliance and to so maintain them.
The overall goal is broken down into five areas of expertise!
1. Personal Development.
2. Acquisition of skills in doing day to day tasks.
3. Recognition of violations and gathering proof thereof.
4. Ability to write effective reports and orders.
5. Ability to effectively present evidence before
administrative and judicial tribunals and to
defend such evidence under cross-examination.
1. Personal Development. To evolve a recognition of those
personal qualities which chaxacterize an effective FED and
how these qualities are developed. Stimulate desire and
enthusiasm for continuing self-training and for personal
development.
2. Acquisition of Skills. Teaching the many and varied skills
needed by the FED in performing his day to day field tasks
striving to bring sources into compliance and to so maintain
them. The agency programs for accomplishing and maintaining
compliance ares
* The external surveillance of sources.
* Responding to citizen complaint.
* Conducting internal source inspections.
* Performing field inspections for permits to
construct and permits to operate as may be
assigned to the FED.
* Reacting to emergency episodes.
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Recognition Of Violations And Gathering Proof. Prom the daily
field activity, certain violating situations will be observed.
The ability to recognize the elements of the violation and to
gather proof thereof will be taught. An understanding of the
constitutional and legal (Clean Air Act and Amendments and
State and Local laws and regulations) basis for action will
be generated. The interaction between local, state, and
federal agencies in enforcement will be discussed.
Writing Effective Reports and Abatement Orders. Writing of reports
to serve as the official record of the action taken ly the FED
will be taught. The form and content of effective orders will
be demonstrated.
Presentation of Evidence. Skill will be developed in presenting
evidence in a persuasive manner through lecture, practice, and
mock situations. Monitoring and enforcement of orders as an
essential part of effective action will be taught.
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TERMINAL OBJECTIVES
The student who successfully completes this course shall be
able tot
1. Identify the fundamental relationships which structure the
air pollution control programs at various levels of
government in the US.
2. Demonstrate an awareness of the personal qualities needed
by an FBD to successfully carry out his mission.
3. Define the skills needed by the FEB as he performs his day
to day tasks.
4. Differentiate between good and bad job performance in field
work.
5. Recognize from observation* conditions of violation as well
as compliance at sources under surveillance or Inspection.
6. Identify the factual information and related data necessary
to prove violations.
?. Identify the principles of effective reporting for a record
of the FED activity and actions.
8. State the principles of off-site surveillance.
9. Identify the various alternative measures available for
bringing sources Into compliance.
10. Construct evidential proof of conditions of non-compliance.
11. Identify the steps necessaxy to conduct on-6ite Investigations
of sources in response to observed violations, scheduled
inspections, delayed compliance orders, court orders»and
citizen complaints.
12. Differentiate between persuasive and Ineffective testimony
presented during mock direct testimony and cross-examination
of witnesses.
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13. Identify the Constitutional and legal "basis for all actions by
the FED in the process of bringing sources into compliance.
1^. Identify the sequence of actions to be taken try the U.S. EPA in
FCAA Section 113 enforcement actions.
15. Differentiate between role of federal, state and local control
agencies in the overall enforcement program.
16. Differentiate between common law and statutory law.
17. Differentiate between administrative and litigation procedures
as strategies for bringing sources into compliance.
18. Identify the major categories of control hardware from their
external appearance; list the major parameters of performance;
and identify a major cause of failure to perform effectively at
any point in time as compared to the permit conditions.
19. Identify the principles of combustion and list the important
inspection points of a coal or oil fired power plant.
The Terminal Objectives stated here will be restated in the beginning
of each chapter of this Manual. They will be expanded or revised,
as necessary, to fully state what you are expected to leain as you
progress through the course curriculum.
Definition of "Successfully Completes the Course". You will be
considered as successfully Completing the course if you are present
95 percent of class time, turn in all your assignments, and receive
an overall grade of no less than ?0% on all tests and assignments.
Active participation in class discussions and exercises may be
considered where test grades are marginal.
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FIELD ENFORCEMENT OFFICER
JOB DESCRIPTION
This section is included to acquaint you with the variety of tasks that may
be required of the Field Ehforcement Officer. Not all enforcement units are
structured alike. However, the tasks included here are those generally
assigned to the FED. They are developed from the author's experience and
ty reference to the EPA Technical Report, "Task Analysis of State and Local
Air Pollution Control Agencies and Development of Staffing Guidelines",
Volume C, Field Ehforcement, November, 19?2.
I. General Nature of the Work.
The FED functions in the field, having direct responsibility for securing
compliance with the rules and regulations pertaining to the operation,
maintenance, and inspection of air pollution source facilities. Initial
construction permit and scheduled re-inspections of large technically
complex source facilities as refineries, steel mills, petro chemical plants
and the like, are often assigned to specialized FED's sometimes called
engineering inspectors, but responsibility for on-going operational
compliance and complaint investigation nearly always is the responsibility
of the general district FED.
II. Tasks to be Performed.
A. Field Surveillance of an Assigned Area
Traditionally, the FED has been assigned an area or "district" for
the purpose of detecting.' violations of the visible emission
regulation, open burning restrictions, permit to construct and
operate requirements; excessive damage to vegetation and large
particle fallout; fugitive dust sources from construction or demolition
projects; or other sensory manifestations of some condition of non-
compliance with the rules and regulations. Upon detection, he conducts
the necessary investigation and records the facts to prove the
violation to the extent where it will allow his agency to take the
required enforcement action to bring the source into compliance. Most
observed violations require subsequent on-site inspection and
investigation.
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Field Ehforcement Officer
Job Description P2
B. Complaint Investigation.
Complaint investigation is universally assigned to the FED. The
objective is to satisfy the complainant's request for the abatement
of an alleged nuisance problem. The FED's role is to collect enough
information to determine if the complaint is valid and can be corrected
through the control functions of the agency. Most valid nuisance
complaint investigations require field surveillance within the area
of the complaint location and often require subsequent on-site
inspection and investigation.
C. On site Inspection and Investigation.
This task is defined as entering upon a source facility premises for
the purpose ofi
(a) Inspecting for compl&ince with an Issued document, such as a
permit to construct, to operate, or to register a new or
altered source;
(b) conducting a scheduled re-inspection as an annual inspection;
(c) determining compliance with a prescribed order of abatement;
(d) investigating the cause and responsibility of an observed
violation and to serve the necessary notices, orders as
required;
(e) completing the complaint investigation process;
(f) do such other things as are necessary to carry out the enforce-
ment responsibility of the FED.
Notei Often the large, highly complex technical sources, such as
refineries, steel mills, petro-chemical plants, utility stations are
assigned to specialty field enforcement officers, sometimes called
engineering inspectors. These specially trained FED's may be assigned
either to the Ehforcement or Ehgineerlng Division of the Agency.
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Field Enforcement Officer
Job Description P3
D. Preparation of Reports and Selection of the Compliance Action.
A vital task is the documentation of the field activity of the FED.
In the case of inspections for compliance, approval or non-
compliance forms are completed. For violation or complaint inves-
tigation, concise and complete reports are prepared. In many agencies
(tut not all agencies), upon completion of the record, the FED takes
or recommends the appropriate compliance action.
E. Serving as a witness in Court or at a Hearing.
Frequently the FED must appear in court or "before a hearing "body to
represent the Agency as an expert witness. They are required to
make their presentation clearly and to respond calmly to cross-
examination or criticism from opponents of the Agency's position.
1-8
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(model agenda)
U.S. ENVIRONMENTAL PROTECTION AGENCY
MANPOWER AND TECHNICAL INFORMATION BRANCH
AIR POLLUTION TRAINING INSTITUTE
#444 _ AIR POLLUTION FIELD ENFORCEMENT
(Date)
AGENDA
COURSE LOCATION: COURSE DIRECTOR
DAY & TIME SUBJECT SPEAKER
TUESDAY
8:30 Registration, Welcome, Course Objectives
9»00 Overview of Air Qaality Control
9s 30 Role of the Field Biforcement Officer
10sOO BREAK
10j15 The Ehforcement Process
10:45 Off-Site Surveillance of Sources with
Student Exercise No. 1, Section I
11: 30 LUNCH
12:30 Off-Site Surveillance of Sources with
Student Exercise No. 1, Cont'd.
1:15 On-Site Inspection of Sources with
Student Exercise No. 1, Section II
2:45 BREAK
3:00 Inspection of a Cement Plant
Film and Workbook
4:30 Assignment: Study for Test
Read "Trial of Opacity and TSP Violation"
See Student Workbook.
ADJOURN
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#444 - AP FIELD ENFORCEMENT
(Date)
Page 2
DAY & TIME
SUBJECT
SPEAKER
WEDNESDAY
8:30
9:00
9:30
10 s 00
10:15
11:00
12:00
12:30
Is 00
2i 30
3:00
3«15
4:30
Written Test on first day material.
Basic Federal Legal Provisions,
Constitutional and the Clean Air Act.
State and Local Laws and Administrative
Procedures.
BREAK
Litigation Procedures
Court Room Procedures.
Film "Role of the Witness".
Mock Trial of Opacity and TSP Violation.
Explain and organize.
LUNCH
Mock Trial continued -
Student Preparation
Conduct Mock Trial and Discussion.
BREAK
Overview of the Federal EPA Hhforcement Program
Stressing Interaction with State and Local
Enforcement Programs.
Assignment: Read and do Lesson 13 in Student
Workbook. Study for Test 2.
ADJOURN
1-10
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#444 - AP FIELD ENFORCEMENT
(Date)
Page 3
DAY & TIME SUBJECT SPEAKER
THURSDAY
8s 30 Legal Test
9:00 Complaint Handling Case Study.
Student discussion.
10s15 BREAK
10s 30 Odor Detection and Evaluation
lit 30 LUNCH
12s30 Complaint Inspection of an Asphalt Plant
Film and Workbook
2s00 Emission Control Hardware, Inspection
Techniques with Case Studies
4i30 Assignmenti Study for Test 3»
ADJOURN.
FRIDAY
8s 30 Inspection of Combustion Sources
Film and Workbook
10s00 BREAK
10115 Air Pollution Alert Procedures
10145 Sources of Technical Information
Recommendation for Further Study at
Appropriate EPA Training Courses
11:00 Course Summation
11:30 Final Test and Review
12 s 00 Course Critique
12:30 Course Closing
Certificates and two and one-half (2.5) Continuing Education Units (CHI's)
will be awarded to those students who attend a minimum of 95# of all scheduled
class sessions and who satisfactorily pass examinations based on studies and
assignments.
1-11
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AGENDA
WITH REFERENCE LESSON NUMBERS AND NOTES EUR
COURSE DIRECTORS AND INSTRUCTORS.
THE FED - HIS JOB - HOW HE DOES IT
DAY 1
Lesson
No.
Course
Opening
1
2
Beginning Length
Time Min.
4
5
8s 30
9:00
9» 30
10 s 00
10:15
10 s 45
11:30
12 s 30
1:15
2s 45
3:00
4:30
30
30
30
15
30
45
60
45
90
15
90
Subject
Registration, Welcome, Course Objectives,
Form Teams.
Overview of Air Quality Control
Role of the Field Ehforcement Officer
BREAK
The Ehforcement Process
Off-Site Surveillance of Sources with
Student Exercise No. 1, Section I.
Be sure to reach Student Exercise No. 1
before lunch. Explain exercise and make
assignments. Many will eat lunch together
and work during lunch hour.
LUNCH
Off-Site Surveillance of Sources with
Student Exercise No. 1, Cont'd.
On-Site Inspection of Sources with Student
Exercise No. 1, Part II.
BREAK
Inspection of a Cement Plant
Film and Discussion
Assignment: Study for Test; Rules of Test;
become familiar with Student Exercise,
Trial of Opacity and TSP Violations. See
Student Workbook.
Adjourn.
1-12
¦&
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DAY 2
Lesson Beginning Length
No. Time Min.
8:30 30
7 9:00 30
8 9:30 30
10t00 15
9 10:15 45
10 11:00 60
11 12j00 150
12:30
1:00
2:30
3:00 15
12 3:15 75
4:30
AGENDA
LEGAL ASPECTS
Subject
Written Test on first day material.
Basic Federal Legal Provisions,
Constitutional and the Clean Air Act.
State and Local Laws and Administrative
Procedures.
BREAK
Litigation Procedures
Court Room Procedures. Film and Discussion.
11:00 is a key time. Film session must begin
no later than 11:00 A.M. to allow time for
Mock Trial Exercise.
Student Exercise. Mock Trial of Opacity
and TSP Violation. Explain exercise,
organize teams, make assignments.
LUNCH
(Assign 30 minute lunch hour. Suggest students
eat lunch as a team and talk about case at
lunch.)
Student Exercise, continued.
Student Preparation.
Conduct Mock Trial and Discussion
(Begin trial earlier if students are prepared.)
BREAK
Overview of the Federal EPA Enforcement Program,
Stressing Interaction with State and Local
Enforcement Programs.
Read Lesson 13 - Odor Complaint Case Study
in Student Workbook.
Study for Legal Test.
Adjourn.
1-13
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COURSE 444
AGENDA
Day ?
Lesson
No.
13
14
15
16
TECHNICAL ASPECTS. WORK SHOPS.
Beginning Length
Time Min. Subject
8s30 30 Legal Test.
9s00 75 Complaint Handling, Odor Complaint
Case Study. Student discussion.
10$15 15 BREAK
10s30 60 Odor Detection and Evaluation.
11$ 30 60 LUNCH
12s30 90 Complaint Inspection of an Asphalt Plant,
Film and Workbook.
2t00 60 Emission Control Hardware, Inspection
Techniques.
3 s 00 15 BREAK
3s 15 75 Emission Control Hardware, Inspection
Techniques, Cont'd.
4s 30 Assignmentss Become familiar with
Inspection of Combustion Sources,
Student Manual; Study for Test No. 3»
Adjourn.
1-14
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OOURSE 444
AGENDA
WIND-UP
Day 4
Lesson Beginning Length
No. Time Min.
17 8:30 90
10:00 15
18 10 s 15 30
19 10:45 15
11:00 30
11:30 60
12:30
Subject
Inspection of Combustion Sources
Film and Workbook.
BREAK
Air Pollution Alert Procedures.
Sources of Technical Information.
Recommendation for Further Study at
Appropriate EPA Training Course.
Course Summation.
Final Test and Review.
Course Critique.
OOURSE CLOSING.
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GENERAL INFORMATION
SHJDENT PROFILE
The Catalogue Description of the Course states that the Course is intended
for those "relatively new in the field". Based on more than five years of
experience giving Course 444, the student "body will contain a fair number
of experienced FED's, as well as a mix of "backgrounds and occupations.
The following table characterizes more than 400 students who have been
enrolled in recent courses.
TABLE 1-1 - Demographic Characterization of Students
having taken Course 444.
(Total 400 students)
Employer
Federal EPA 14^
State Agency 48
Local Agency 35
Other 3
Educational Background
High School 26%
Bachelor 57
Master 15
PhD 2
0 ccupation
Administrator 4$
Chemist 4
Ehgineer 29
Fhys. Scientist 2
Sanitarian 15
Technician 18
Other (inspector) 28
Years Experience
0-1 years 2$%
2-4 39
5-7 22
8 -10 4
>10 6
A Class Profile Form has been prepared for use by Course Director for
current courses.
1-16
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CLASS PROFILE FORM
The course director may wish, for his own information, to work up the
class profile from the blue Trainee Registration Forms.
Make a photocopy for each course. The most used categories only are
included.
EMPLOYER CATEGORY
YEARS OF PROFESSIONAL
AIR POLLUTION EXPERIENCE
U.S. EPA 01
State 04
2-4
Local 05
5 - 7
Other
Other
OCCUPATIONAL CODE
EDUCATION
Admin i strato r
01
High School
(1)
Chemist
02
Bachelor
(2)
Ehgineer
03
(3)
Master
Sanitarian
08
Technician
10
Doctor
(k)
Inspector
11
Other
1-17
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PREPARATION OF CLASSROOM
Set up classroom. Preferred arrangement is a group of tables, one for
each three students, upon which are placed the student name cards.
Students should be mixed according to different agencies and differing
years of experience. During the work sessions, inexperienced students
will benefit from experienced ones and there will be maximum interchange
between the groups. Provide about 10% extra seating for late registrants.
Each day move students one row to the rear, bringing the last row to the
front.
Also will need:
Speaker"s table with lectern.
Projection Equipment - 2x2 slide projector, 16mm sound movie
projector, overhead transparency projector and screen.
Pointer for use by lecturer.
Good blackboard, chalk and eraser.
See Lesson 11 for "mock courtroom arrangement".
Distribute student manuals, course packets and other handout materials.
Check lighting, outlet plugs and needed extension cords, control of
window shades, switches, etc. See that projection equipment can be
operated and has spare projector bulbs. Know where to get help or spares
in case of equipment failure.
Check coat storage facilities.
If a library table is to be used, set this up with reference books.
Course Director should contact local representative of APC Agency or EPA
to determine if local person wishes to welcome the class and how long he
will take. Do not allow more than ten minutes, as more time would play
havoc with the Day I Agenda.
1-18
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m CONTENT OUTLINE /X\
Course: 444 \^l£/
Lft-Jfti Lecture Title: COURSE OPENING pro^0^
Pngn ~\ nf 3
NOTES
LESSON GOAL.
I
| To open the course, welcome the students, give them the course
f objectives and the necessary information about the conduct of
J the course and the training accommodations. This time is to
j uncover any problems about the personal needs of the students
i
i while attending the course and begin development of rapport.
! 7:45 A.M.
Course Director comes into classroom and checks all details
j which were to have been done the day preceding the course
| opening.
»
Put on boards
Welcome to EPA Course 444 A. P. Field Enforcement.
Please find your assigned place.
Begin filling out Registration Card. (Blue Card)
Initial Registration List at door.
Iron out registration problems, late registrants, substitutes,
no shows and seating.
8* 30 A.M.
Course Directori
"Welcome to Course 444, A. P. Field Enforcement."
i Introduces self: "I am , the Course Director,
j Writes name on board.
j Instructs students to complete registration cards and
j mailing list requests in blue folder.
| Pauses to give most of students time to complete this.
J Watches for late comers during this time.
I
1
1
t
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Page 2 of 3
CONTENT OUTLINE (CONT'D)
Announces: Where to eat.
Restroom locations.
How to receive or make phone calls.
Arrangements for coffee during "breaks.
Transportation to and from course location,
if special arrangements are needed.
Any hotel problems.
Introduces local representative, if there
is one.
Thanks local representative.
Adds "tie-in" remarks.
Asks for questions?
OOURSE OBJECTIVES:
To offer instruction to maximize (improve) the effectiveness of
the FED as he works to gain the objectives of his unit within
the agency: namely, securing compliance with regulations
pertaining to stationary sources.
Course is intended for those field personnel relatively new in
their jobs.
However, the Clean Air Act Amendments have introduced new
concepts which will be discussed.
We cannot present how you, individually, work within your
agency. Procedures may vary widely, but we will present
principles and practices applicable to a wide range of
situations.
Course is three and one-half days.
Day 1 - The FED, his job, how he performs it.
Day 2 - Test on Day 1. Legal aspects and case study.
Day 3 - Test on Legal. Technical aspect and workshop.
Day 4 - Wind-up - final test.
You will be expected to do evening work and study.
0-2
-------
OONTMT OUTLINE (OONT'D)
(introduce teaching staff here, or as each lecturer starts.)
Course will close at 12s30 on fourth day - commonly Friday,
till closing.
Students successfully completing the course will earns
A certificate of attendance.
Two and one-half Continuing Education Units.
Requirements for successfully completing courses
Attendance at 95% of classroom assembly time, turning
In all assignments.
Participation in classroom discussion.
Obtain a final grade of 70%.
Tests will be objectively graded and averaged. If the
numerical grade is below 70%, credit can be given for
work on daily assignments and for class participation.
Throughout the courses
Qaestions and discussions are encouraged.
If time permits and depending on class sizes
Students individually introduce themselves, or
If group is too large, introduce themselves to their
partners at their own tables.
By diow of handss
How many are FED's?
How many are local and state district?
How many are state headquarters?
How many are Federal?
How many are industry?
How many are others?
Collect registration cards and mailing lists.
Go on to Lesson 1.
-------
LESSON I
OVERVIEW OF
AIR POLLUTION CONTROL
-------
LESSON PLAN
TRAINING INBTITUTB
TOPIC: LESSON 1
OVERVIEW OF AIR QjJALITY CONTROL
COURSE: WJ-
LESSON TIME: 30 min.
PREPARED BY:C>W> Gru-ber DATE10/l/78
LESSON To determine how well the students understand the broad
GOAL. objectives and means of attainment of the air pollution
control effort in the USA as described in SI Course No. 422.
A model concept of ambient air quality will be presented.
LESSON At the end of this lesson the student should be able to:
OBJECTIVES.
1. Recite the ultimate goal of the Air Pollution Control
Agency and how progress toward the goal is measured.
2. Define ambient air quality.
3- Explain the fundamental relationships which create
ambient air quality.
4. Name the criteria pollutants.
5. Differentiate between primary and secondary National
Ambient Air Qiality Standards and between primary and
secondary pollutants.
6. Explain background pollution levels.
7. List two hazardous pollutants covered "fcyvNESHAPS.
¦J
8. Identify three meteorological parameters important in
air pollution control.
9. Identify the basic concept of air quality control in the
US.
10. Define atmospheric reaction products.
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Page 2 of 3
LESSON PLAN (CONT'D)
LESSON 1
STUDENT
PREREQJISITE
SKILLS.
One or more of the following: (a) Completion of SI 422, Air
Pollution Control Orientation Course; (b) equivalent college
training in air pollution control; or (c) job experience to
provide equivalent understanding of air pollution control
practice in the USA.
LEVEL OF
INSTRUCTION.
This lesson probes for the general level of knowledge in the
broad field of air quality control practice. It is not
intended to provide new knowledge but to orient the students
into a pattern of teaching vftiich depends heavily on class
discussion.
INTENDED
STUDENT
PROFESSIONAL
BACKGROUNDS.
High school graduation or better, but no specific technical
background is required. Some on-the-job experience is helpful.
More than four years of successful functioning as an FED may
over qualify the student and he will become bored. If such is
the case, stress the parts of the course which deal with legal
aspects and the updating of present practice to include the
recent amendments to the Federal Clean Air Act, and the oppor-
tunity to contribute to the instruction of the lesser
experience students.
SUPPORT
MATERIALS,
EQUIPMENT
LISTS.
35 mm Slides
35 mm Slide Projector and Screen
Blackboard
SPECIAL
INSTRUCTIONS.
This lesson is important in setting the tone for the course
and getting the students to respond and contribute.
The lesson format will "break the ice" in encouraging the
students to participate. It will give the instructor a feel
for the level of student knowledge of the air pollution
control program in the US.
1-2.
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Page 3 of 3
LESSON PLAN (CONT'D)
LESSON 1
The lesson will start as a verbal quiz with questions
flashed on the screen from slides. The conceptual AAQ Model
will be presented and then the discussion will return to the
question and answer format. The instructor, in most cases the
course moderator, will use a mix of volunteer and directed
responders.
SELECTED The course moderator and all instructors should be familiar
REFERENCES. with the content of SI kZZQ. All Area Training Centers will
have at least one copy of SI 422C, Air Pollution Control
Orientation Course, supplied ty the Air Pollution Training
Institute, Research Triangle Park, NC 27711. APTI, EPA, 1978
available from National Audio Visual Center, Ref. Sec/RL, GSA,
Washington DC 20409.
1-3.
-------
mi iww
fm
CONTENT OUTLINE
r '*1
"V
444
(TIME SCHEDULE)
< v r> -> 7 a y
^ c
£%
^7
OVERVIEW OF AIR POLLUTION CONTROL
I. INTRODUCTION
Page .. 1 :¦? .1
NOTES
Time
Of
Unit
Nin.
Ending
Min.
II. CJJ EST IONS TO DISCUSSION OF MDDEL
A. MDDEL
B. (JJESTIONS 8 through end
2
10
10
4
14
24
III. AIR (JJALITY CONTROL IN U.S.
IV CONCLUDING STATEMENT AND (£FESTIONS
26
30
1-4.
-------
CONTENT OUTLINE
444
,y.» o ''"l,
£%
r^teS£»-<
OVERVIEW OF AIR POLLUTION CONTROL
Pw l 6
HOTfS
INTRODUCTION
State the lesson goal and lesson format.
Much of the material covered in this lesson is a review
of SI Course 422, Air Pollution Control Orientation.
Q. How many have been through SI 422?
II.
gJESTIONS AND DISCUSSIONS
1. Q. What is the ultimate objective (goal) of the
Air Pollution Control Programs in the US?
A. An outdoor air quality free from adverse effects on
health and welfare and prevention of significant
deterioration.
Q. What is health?
Q. What is welfare?
2. Q. How is progress toward this goal determined?
A. By measuring ambient air quality (AAQ).
3. Q. What is AAQ?
A. A pattern of the occurrences of levels of air
contaminants in the outdoor air.
Pattern implies variability.
4. Q. What determines AAQ?
A. AAQ results from the summation of all emissions
from sources, atmospheric reaction products,
background inflow, and re-intrainment of surface
contaminants, all transported, diffused or
accumulated, depending upon meteorological
parameters.
5. A conceptual AAQ model
E + A + B + C
Slide 1-1
Question
SM p. 1-2
Slide 1-2
Question
Slide 1-3
Question
No Slide
Lights on
Put model on
blackboard
AAQ
F
1-5.
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Page 2 of 6
CONTENT OUTLINE (CONT'D)
LESSON 1
Basic Slide. No pollutants. For clarity,
sources axe separated from receptors.
E is the sum of emissions from stacks and vents
plus the fugitive emissions from storage piles,
materials handling, construction and demolition,
building openings, etc. These are the identified
point and area sources of the AQCR.
The units are g .
e
A are the atmospheric reaction products -
Units are g .
9
B are the background pollutants, those which
flow in. The units are g .
9
C are the re-entrained surface contaminants, and
natural pollutants from within the AQCR.
The units are g .
G
F axe the meteorological influences, the dominant
ones being horizontal and vertical air flow in and
out of the AQCR.
As F values rise, AAQ values diminish, (AAQ
improves) so F is placed in the denominator of
the model. The units axe m3.
6
Repeat the AAQ model.
E+A+B+C
AAQ -
Slide 1-4
Slide 1-5
Slide 1-6
Slide 1-7
Slide 1-8
Slide 1-9
1-6.
-------
CONTENT OUTLINE (CON'D)
LESSON 1
Page 4 of 6
E Primary pollutants
A Influenced ty mixing layer and "try solar
radiation.
B Background influenced by pollution from
other AQCR.
C Influenced ty wetted surfaces or snow cover.
Sum up meteorological factors.
(a) wind flow
(b) Stability or turbulence
(c) Solar radiation (amount of sunshine)
(d) Other - rain, wet surfaces, snow cover
1-7
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Page 5 of 6
CONTENT OUTLINE (CONT'D)
LESSON 1
Now continue with question and answer format.
6. Q. How do we gauge if Ambient Air Quality is good
or bad?
A. By measuring and comparing levels with National
Ambient Air Quality Standards (NAAQS).
7. Q. Who established NAAQS?
A. Administrator of EPA, after criteria are
published and comments are received.
We call NAAQS "Criteria pollutants".
8. Q. Do the states use only NAAQS?
A. No. Some states have their own standards, author-
ized try their own state law. This is provided
for in the CAA if the state standards call for a
better quality than NAAQS.
9. Q. What are the criteria pollutants?
(Draw out and list on board.)
A. 00; SO2; NO2; HC non-methane; PhOx (O3);
Total Suspended Particulates, and Lead (P"b).
10. Q. Do we have a single set of NAAQS?
A. No - primary and secondary.
11. Q. What is difference between primary and
secondary NAAQS?
A. Primary standards protect health.
Secondazy standards protect welfare.
Slide 1-10
Question
Slide 1-11
Question
Slide 1-12
Question
Slide 1-13
Question
Slide 1-14
Question
Slide 1-15
Question
1-8
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Page 6 of 6
OONTENT OUTLINE (CONT'D)
LESSON 1
12. Q. Must the FED be able to justify the NAAQS values?
A. No - leave this up to medical profession, but he
should have basic understanding of impact.
13. Q. What are the "hazardous air pollutants" as
defined by the CAA? How are they controlled?
Name three.
A. Hazardous pollutants are those which may reasonably
be anticipated to result in an increase in mortality
or an increase in serious irreversible, or
incapacitating reversible^ illness. Controlled by
enforcing NESHAPS standards.
Asbestos, beryllium and mercury.
14. Q,. Are there other pollutants of concern?
A. Yes. States and local air pollution control
programs deal with many pollutants which axe not
federally regulated because they are of special
concern to the area.
Example: Fluorides in Florida; odor in Bay Area,
California.
Stop here on the Qiestion and Answer format.
III. AIR gjALITY CONTROL IN THE UNITED STATES
A two level programs
A - States and their political sub-divisions (call local).
B - The Federal Program
IV. CONCLUDING STATEMENT
The FED is involved in a program which is extremely complex;
politically, technically, socially and economically. The
following lesson will show that the FED plays a major role
in this perplexing interrelated effort.
Slide 1-16
Qui est ion
Slide I-I7
Question
Slide 1-18
Qli est ion
SM 1-5
1-9
-------
vyv let&si i
DO THE STATES Ifltl
ONLV ftWVAaj
DO Wt HAVf A StftGL r
«'»' HAASS'
mi*r Hrnt orrpinfnt
V PRIMARY ani
SECONDARY NAAQS •
WHAT ARf THI
HAZARDOUS AIH POltUTAN TS
AS DEFINED BY TMf CA/V ¦'
HOW ARE THEY CONTROLLED '
NAME THREE
TRfflf OrH*ft POLLUTANT
Of I QNQfRN * ' ; » J
-------
LESSON 2
ROLE OF THE
FIELD ENFORCEMENT OFFICER
-------
HF
I AIR POLLUTION I
|traimi>s>o WTITUT»|
I# ¦
LESSON PLAN
TOPIC: LESSON 2
THE BOLE OF THE FIELD ENFORCEMENT
OFFICER
course: 444
LESSON time: 30 min.
PREPARED BY:Ci w§ Qruber DATE ]_o/l/78
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Page 2 of 2
LESSON PLAN (CONT'D)
LESSON 2
INTENDED
STUDENT
PROFESSIONAL
BACKGROUNDS.
No specific technical 'background is required. Some
on-the-job experience is helpful. More than four years
of successful functioning as an FEO may "over qualify" the
student, except for updating his basic knowledge of enforce-
ment practices to the changing patterns of the Glean Air
Act Amendments.
SUPPORT 35 mm Slides
MATERIALS 35 roro Projector and Screen
ECJJIPMMT Blackboard
LISTS.
SPECIFIC The key point of this lesson is that the job of the FED is
INSTRUCTIONS, people and situation oriented. The success of each
enforcement action depends heavily on how well the FED does
his job.
This lesson points to Lesson 5« - On-Site Inspection.
The instructor should have some agency enforcement experience
or contact with an agency to fully comprehend the role of
the FED.
SELECTED The Student Manual, Chapter 2 and the instructor's experience
REFERENCES. with enforcement will provide the best background material.
Chapter 2 provides selected references.
-------
CONTENT OUTLINE /£
f*('0_^TA% I Page. 1 of ^
TTfflHSMJJIE
Course: ^ LESSON 2
Lectjre Title: the role of the field enforcement
O
V
NOTES
7>mm
I. INTRO EUGTION
| Time
; of
: Unit
Min.
Hiding
Min.
II. ROLE OF THE FED
III. SOOPE OF THE FIELD OPERATIONS PROGRAM
IV. FIELD ENFORCEMENT ACTIVITIES
V. CHARACTERISTICS OF THE FED JOB
VI. PERSONAL gJALITIES AND SKILLS
VII. ORIENTATION AND TRAINING
VIII. SUMMARY
5
10
5
13
23
28
30
2-3.
-------
CONTENT OUTLINE /2£\ "-ir'r
——————i ? NOTES
Course • Wj- LESSON 2 * ——-
V A I
Lecture Title: THE ROLE OP THE FIELD ENFORCEMENT*1^0 I
cmm r
I. INTRODUCTION. (Lesson Goal)
To describe the job characteristics of the FED, his
necessary personal qualities, and how he works to
become outstanding in the performance of his assigned
duties.
II. ROLE OF THE FED.
A. Importance of the FED to Success of Enforcement SM p.2-2
1. The FED is the contact person.
* He represents the Agency in the field.
* He deals with people face to face.
* He "is" the Agency, in the eyes of the
general public.
2. The "bottom line" of the enforcement action.
Ultimate success or failure depends heavily upon
how well the FID does his job.
III. SCOPE OF THE FIELD OPERATIONS PROGRAM. SM p. 2-2
A. Major External Determinants
1. The number and types of stationary sources that
require inspection.
2. The status of compliance with the regulations, j
compliance plans, consent orders, agreements, etc. i
B. Major Internal Determinants ¦
1. The complexity of rules and regulations to be
enforced.
2. Source registration support required.
3. Permit and Certification systems support required.
4. Frequency of required periodic reinspections.
5. Administrative and enforcement policies of the
Agency.
2-4.
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Page 2 of 6
CONTENT OUTLINE (CONT'D)
LESSON 2
IV. FIELD ENFORCEMENT ACTIVITIES.
* Field surveillance and complaint investigation.
* Source facility inspection.
* Report writing, composing orders, recommend or serve
notices of violation.
* Assist in developing a formal compliance plan.
* Serve as witness "before a hearing "board or court.
* Assist in stack tests or collecting samples.
* Carry out special field duties during air pollution
alerts and emergencies.
V. CHARACTERISTICS OF THE FED JOB
A. General
1. The FED's job is "both people and situation oriented.
B. Specific
The FED is:
1. Constantly meeting and dealing with people face to
face, frequently in an adversary situation.
2. Obtaining information.
3. Conducting investigations, seeking provable,
factual evidence.
b. Answering questions, solving problems.
5. Forming judgments.
6. Taking enforcement actions.
* Serving notices of violation, or
* Making recommendations for enforcement actions.
7- Preparing and preserving the record in written
reports.
8. Giving persuasive testimony.
An unusual person is required to handle such a variety
of duties with skill and diplomacy to attain the desired
results. (Compliance within shortest time and minimal
legal litigation.)
2-5.
SM p. 2-3
(board)
Q. What is FED
responsibility
for solving
problems?
Discuss
-------
Page 3 of 6
CONTENT OUTLINE (CONT'D)
LESSON 2
VI. PERSONAL QJALITIES AND SKILLS
A. Mature Personality
1. He is capable of dealing with the public in an
efficient, businesslike manner, often under
strained conditions. He is courteous but firm.
SM p. 2-3
2. He listens to caustic comment and criticism
without "blowing his cool".
B. Ability to Communicate
1. Verbal
* To the FED, words are the "tools of his
trade".
* Communicating is more than a matter of
people talking to each other. Be sure the
other party understands the full meaning
and import of what you say and what you want
him to do (if anything).
* Effective communications may well be the
lubricant that can prevent needless friction
between violator and enforcer.
* Avoid ordering or commanding. "Do this
because I say so."
2. Non-verbal communications
* How the FED acts, dresses, the level of
his calmness and self-assurance.
* Don't make it tough for yourself by going to
an interview with a "chip on your shoulder"
and showing it.
2-6.
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Page 4 of 6
CONTENT OUTLINE (OONT'D)
LESSON 2
G. Dress arid appearance
* General appearance must be neat and well groomed.
* One call may be into the president's office.
The next may be into a dirty, stinking plant.
* Heat and cold to contend with.
* Do not overdress.
* Have your own protective clothing available.
Your own hard hat,
Protective eye glasses,
Lightweight overshoes,
Shop coat, or clean oversized coveralls
to fit over your outer clothing.
Notes City of Philadelphia states*.
"Proper attire is required at all times on the job.
A tie is necessary always and a suit coat or
sports jacket must be worn. If the weather is
uncomfortably hot, the coat may be removed, but it
should be available, i.e., in the car so that it
can be worn if the situation should require it.
Exceptions to clothing requirements are made for
inspectors on night shifts or special (dirty)
details."
D. Investigative Skill
1. Ability to gather facts and organize them in a
concise manner requires the FEO to
Be observant.
Be Resourceful.
Sift meaningful from diversionary or
unimportant.
Seek facts without vehemence.
Develop skill in drawing out information
(which may be used against his adversary's
best interest).
Zf-7.
Reference (2)
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Page 5 of 6
CONTENT OUTLINE (CONT'D)
LESSON 2
E. Ability to Learn
1. Technical aspects of the field of air quality
management and source control technology.
Use each inspection as another learning process.
The doctors and lawyers practice—so should the
FED.
2. Develop a potential for legal enforcement.
Relate regulations, "by number, to corresponding
situations encountered in the field.
P. Function as a Member of a Team
Notwithstanding the central role of the FED in an
enforcement action, especially in the larger and more
complicated litigations, the FED must fully develop
rapport with the engineering and technical groups,
how his role supports them and vice versa.
VII. ORIENTATION AND TRAINING
How does ET-D attain proficienqy?
A. Orientation
SM p. 2-5
1. Mist learn air pollution law and rules and
regulations language and section numbers of
those he enforces.
Read them and understand them.
2. Learn administrative procedures.
2-8.
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i Page 6 of 6
CONTENT OUTLINE (CONT'D)
LESSON 2
B. Technical Training
1. Basic knowledge of combustion processes and
equipment operation.
2. Be able to identify equipment and processes and
the parameters which relate to emission potential.
3. Must develop a storehouse of operating character-
istics of the processes that abate air pollution
emissions.
4. Study and use reference texts, materials,
publications. Assemble your own reference
library.
G, Attain Expert Status
Mist attain expert status in opacity reading by
smoke schools and practice.
D. Continuing Education
* Available EPA self instructional courses.
* Specialized EPA training courses.
* Appropriate technical meetings.
* Specialized college courses.
* Seminars and conferences sponsored by the agency
for exchange of information.
* Selected reading of professional journals and
informational materials.
VIII.
SUMMARY.
*
*
*
The FED' s job is both people and situation oriente(.
Effective communications are a "must".
In the eyes of the general public, "he is
the agency".
SM p. 2-6
2-9-
-------
LESSON 3
THE ENFORCEMENT PROCESS
-------
LESSON PLAN
TOPIC: LESSON 3
THE ENFORCEMENT PROCESS
COURSE Wi
LESSON TIME: 30 mill.
PREPARED BY:C# w# Qruber DbJE' 10/l/?8
vS
£0
£
•c
w.
T>
UJ
CO
T
30
o
V f/
PROl^-
LESSON
GOAL.
To present an overview of the enforcement process "by which
sources are "brought into compliance and so maintained.
Emphasis will "be on the functioning of the FED within
the process.
LESSON
OBJECTIVES.
At the end of this lesson, the student should be able toi
1. State the mission of the enforcement operation of an
agency.
2. Identify three major enforcement systems.
3. State at least six ways how construction permits aid
enforcement.
Identify the Federal jurisdiction for new construction
permit review.
5• State the purpose of a "Policy of Enforcement".
6. State the three degrees of compliance.
7. State at least eight of the milestones included in a
Compliance Plan Schedule.
STUDENT
PREREQUISITE
SKILLS.
Completion of SI 422, Air Pollution Control Orientation
Course; equivalent college training in air pollution
control; or job experience to provide equivalent under-
standing of air pollution control practice in the USA.
3-1.
-------
Page 2 of 2
LESSON PLAN (CONT'D)
LESSON 3
LEVEL OF This lesson is descriptive in non-technical terms. It is
INSTRUCTION. intended to introduce the various processes available for
enforcement of the rules and regulations. In depth treatment
of each enforcement method will be given in other lessons.
INTENDED
STUDENT
PROFESSIONAL
BACKGROUNDS.
No specific technical background is required. Some on-the-job
experience is helpful. More than four years of successful
functioning as an FBD may over-qualify the student and he
will become bored. If such is the case, stress the parts of
the course which deal with legal aspects and the updating
of present practice to include the August, 1977 amendments
to the Clean Air Act, and the opportunity to contribute to
the instruction of the lesser experience students.
SUPPORT 35 nun Slides
MATERIALS 35 111111 Slide Project and Screen
EqjJIPMMT Blackboard
LISTS.
SPECIAL A most important point in this lecture is that in every
INSTRUCTIONS, observable or provable violation, alternative action routes
to secure compliance are available. Therefore, a decision
is necessary to select the appropriate route. Where an
agenqy has more than one FED, a rather clear enforcement
policy must be set down by the Ehforcement Chief so that
a near uniform response to violation among the several
FEDs will be achieved, in contrast to "tough and lenient"
FBOs operating within the same agency. No attempt is to
be made to say which enforcement policy is preferred, as
the choice truly rests with each agency.
SELECTED Student Manual Chapter 3-
REFEREN CES.
*
2=2-
-------
CONTENT OUTLINE
i
Course: W*
Lecture Title:
TIME SCHEDULE
LESSON 3
THE ENFORCEMENT PROCESS,
AN OVERVIEW
I. INTRODUCTION
II. MISSION OF ENFORCEMENT OPERATIONS
WJ
o
\
Page __i of L
NOTES
Time
of
Unit
Min.
2
1
Ending
Min.
2
3
III. ENFORCEMENT SYSTEMS
IV. PERMITS, CONSTRUCTION AND INITIAL OPERATION
V. CYCLIC OPERATING PERMITS
i VI. COMPLIANCE PLAN INSPECTION
VII. SURVEILLANCE AND COMPLAINT
VIII. DEGREES OF COMPLIANCE
IX. ENFORCEMENT ACTIONS
X. ENFORCEMENT POLICY
XI. SUMMARY
3
3
3
2
5
5
11
14
16
18
20
25
30
3-3.
-------
CONTENT OUTLINE «
Course: 444
Lecture Title:
LESSON 3
the ¦FwmHnmiiyjT PHnrrass
moi*
^e° sr^ Page L_ o/" 2_
J®) NOTES
I. INTRO DUCT ION
A. Lesson Goal I
I
Enforcement actions vary widely among agencies.
Policies selecting the enforcement strategy are as
individualistic as the agencies themselves. This
lesson presents the many and varied enforcement
mechanisms. It is hoped this lesson will widen the FEQ
perspective of enforcement even though he is not free
to choose, on his own beliefs, from the mechanisms
available. He is, or should be, directed "by the i
regulations and agency policy in such matters. i
SM p. 3-2
Q.
Do you agree?
II. MISSION OP THE ENFORCEMENT OPERATIONS
To carry out those field operational tasks designed to
bring all sources into compliance with the regulations at
the earliest possible time and to so maintain them.
I
III. ENFORCEMENT SYSTEMS
Control strategies are woven into four enforcement systems
for implementation. The F0O carries out the field
operations of one or all four enforcement systems:
i
* Permits to construct and initially operate t
Also Registration for sources with lesser emission
potential.
* Cyclic permits to operate.
(Scheduled periodic inspections)
* Compliance plan enforcement.
* Surveillance and complaint response.
IV. PERMITS TO CONSTRUCT AND INITIALLY OPERATE
A. Jurisdiction
Permit systems are administered by Local, State and
the Federal EPA for review.
SM p. 3_2
SM p. 3-2
3-4.
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Page 2 of 9
CONTENT OUTLINE (CONT'D)
LESSON 3
1. Local and State Permit Regulations
Usually all sources which have significant emission
potential are included.
a. In attainment areas for PSD, any source having a
potential emission greater than 250 TPY or 100 TPY
for 28 specific sources and (now for
particulates & SO2 only)
"b. In non-attainment areas, any source which has a
greater potential than 100 TPY.
B. Registration
Fbr sources not requiring federal permit, some agencies
use "registration" instead of "permits". Some, as in
Ohio, use state permits for all "but minor sources, less
than 25 T/year potential with "registration for said
minor sources.
Registration processing is similar to permit processing
except pre-construction review and approval is not
required^ "but it may occur in an advisory context.
C. The Permit and Registration Systems ald$ enforcement "byt
1. Providing for engineering review prior to construc-
tion. Changes can "be made with less cost than
after construction. (Not applicable to Registration.)
2. If the new source does not comply in all respect,
construction is prevented "before it starts.
3. Permit document can be required to highlight
parameters which are important to proper functioning
of control equipment.
4. Insuring that required emission monitors will be
installed.
5. The permit document can "be required to include an
operations and maintenance program.
2. Federal Preconstruction Requirement is generally a
reviewing process.
PSD
FGAA §165 (a) p82
§169 (1) p88
3-5.
-------
CONTENT OUTLINE (CONT'D)
LESSON 3
6. If inspection or tests show non-compliance, operation
permits are denied and source cannot legally operate
until it is in compliance.
7. Giving notice of change—adding new sources.
8. Keeps the emission inventory up to date.
9. Where FED does field inspection, it is a good
continuing training program; allows him to see
good equipment as it is being constructed.
CYCLIC OPERATING PERMITS
A. Purpose
To require a periodic re-evaluation of sources by
scheduling on-site reinspection, or other review process,
to determine compliance status with regulations and/or
conditions of the initial permit for the purpose of
granting or denying a permit to operate.
B. Aids Enforcement byi
1. Subjecting source to periodic review.
2. Where non-compliance is in evidence, denial of
operating permit adds "clout" to the overall enforce-
ment program by making operation of the source per se
a violation.
3. Provides a periodic updating of the original permit
documents such ass ownership change, process change,
materials change, etc., which would require a new
construction permit.
3-6.
-------
CONTENT OUTLINE (CONT'D)
LESSON 3
4. Providing for a systematic check of all emissions by
(a) Reviewing recorded emission data.
(b) Observing emission indicating devices.
(c) Checking for compliance with instrument
calibration procedures.
5. Updating the emission inventory.
6. Educating plant personnel on importance of and
requirements for air pollution control through
contact with FED.
VI. COMPLIANCE PLAN INSPECTION
A. Purpose
To inspect for progress the specific "milestones of a
Compliance Plan, Administrative Order or Court Order".
B. Compliance Plan Schedule
Every enforcement order should have a time table for
attaining compliance and a specified penalty for failure
to meet the scheduled milestone.
A compliance plan for the construction or reconstruction
of a major control facility would include the
following milestones, or some other appropriate items:
1. Engineering study, pilot studies and source testing
to generate process and emission data, and
cost estimates.
2. Approval of funds by management (Board of Directors).
3. Completion of final design, take bids and
select best proposal.
4. Secure approval of APC Agency. Secure construction
permit.
5• Place order for equipment.
6. Delivery of equipment.
Page 4 of 9
SM p. 3-5
Most Important
Step.
3-?.
-------
Page 5 of 9
CONTENT OUTLINE (CONT'D)
LESSON 3
7. Installation and "shakedown" runs.
8. Source test for compliance.
9. Secure operating permit.
10. Turn over to operating department.
(it now becomes the object of reinspection for
operating permit renewal and surveillance.)
The City of Philadelphia, Enforcement Procedures
Appendix 10 contains an example of a form for an
Emission Abatement Action, Compliance Schedule Summaiy.
See Figure 3«9«
C. Aids Enforcement by:
1. Time slippage can be spotted and action taken to
increase the tempo of the compliance program.
2. Save valuable time in generating legal complusion
if there is no action or gross deviation from
time schedule.
3« Penalties for non-compliance are visible to the
owner.
Example on
Page 3-9 SM
VII. SJRVEILLANCE AND COMPLAINT
A. Surveillance
1. Watching over an assigned district to spot
observable violations, generally from outside of
the source boundary.
2. Might include surprise (unscheduled) visits to
marginal sources for in-plant check of specified
processes, and around-the-clock observation in
special cases.
B. Citizen Complaint
Response to citizen complaint is a significant part of
the FIDO's job. A complaint can involve a specific
violation, such as visible emission or it can and often
does relate to nuisance.
Complaint management will be covered in Lesson 14.
SM p. 3-6
3-8.
-------
APPENDIX 10
AIR MANAGEMENT SERVICES
emission ABATEMENT
COMPLIANCE SCHEDULE SUMMARY
Pi™ Nana and Address:
Process, Operation or Activity related to compliance schedules
Name, Title and Address of Company official authorising Coa<-
pliance schedule:
*aw> Title and Address of Person completing lunuty:
Date of preparation of Summary:
A. Type of Abatement Activity to be Pndcrtaken. (Check one
or more categories below, as appropriate.Use separate
summary font for each process, operation or activity to
be covered by a compliance schedule).
VjJ /~7 Process/equipment change or modification
I _
vo / / Maintenance or operational change
n New control equipment installation
^7 Additional control equipment installation
/~7 Modification to existing control equipment or
apporten&ncee
n Installation of Instrumentation or automatic controls
/~7 Cessation of process, operation or activity
/~7 Other
B.
Description of Abatement Activity flea). (Give general
description of abatement activities as indicated in "A"
above).
C. . Compliance Schedule Profile. (Indicate projected completion
date adjacent to activities below which pertain to the com-
pliance schedule to be undertaken).
1. Engineering studies to be completed by:
2. Pilot Studies or tests to be completed by:
3. Appropriations requested by:
4. Appropriations approved by:
5. Permit application to be submitted by:
6. Purchase order to be issued by:
7. Control equipment to be delivered by:
8. Auxiliary equipment, instrumentation or controls to be
delivered by:
9. Control equipment installation completed by:
10. Process/equipment change or modification completed by:
11. Maintenance or operational changes to be instituted by:
12. Control equipment modification completed by:
13. Start-up or operation to commence by:
14. Cessation of process or operation by:
D. Effect of Contingencies on Completion of Compliance Schedule
(Indicate any known or contemplated contingencies which could
effect the time schedules as listed in "C" above).
hd
Signature 6 title of authorising company official:
CD
ON
O
•-b
vO
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CONTENT OUTLINE (CONT'D)
LESSON 3
VIII. DEGREES OF COMPLIANCE
All sources axe not always and positively in or out of
compliance now and forevermore. There are three degrees
of compliance
A. Continuing Compliance
The source is equipped and will operate continuously,
with great assurance, that it will be within the
regulations. Continuing compliance implies confidence
the source will operate day or night, day after day,
with little risk of violation. Requires minimal
surveillance - a good source.
B. Functional Compliance
A marginal source in compliance at time of observation
or inspection, tut little assurance of long term
compliance.
C. Non-Compliance
Violation conditions, supported try valid evidence
justifying enforcement action.
IX. ENFORCEMENT ACTIONS
A. Enforcement Actions Available
Each agency develops its own enforcement procedures and
policies.
1. Two extremes
a. A program based entirely on voluntary compliance
by source owners under specific order from the
control agency.
b. "File legal action first and talk later."
2. Most agencies operate somewhere in between, gearing
the enforcement action to fit:
a. The circumstances of the violation.
b. The agency resources, and
c. The specifics of the statutes.
d. The availability and effectiveness of legal
assistance, including the judicial processes
in the area.
Page 7 of 9
SM p. 3-8
I *
, Good Plant
; Marginal
1 Needs Work
I
i
\
j SM p. 3-8
3-10
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Page 8 of 9
OONTMT OUTLINE (CONT'D)
LESSON 3
X. ENFORCEMENT POLICY
A. What is It?
An established policy of the agenqy which directs the
FED in how he reacts to a violation.
B. Purpose
To have all FEDs of a jurisdiction acting uniformly in
like situations.
C. How is it communicated?
1. Written directives.
2. Word of mouth from supervisors.
3. Meetings of FEDs with supervisors.
4. Word of mouth from other FEOs.
5. By distribution of case summaries which show
proper selection of mode of attack.
D. Discussion
Qaeiy - How many have an established policy?
- How do you know how to react?
- How are policies communicated?
- Etc.
SM p. 3-9
3-11.
-------
Page 9 of 9
CONTENT OUTLINE (CONT'D)
LESSON 3
XI. SUMMARY
SM p. 3-9
A. All enforcement actions have a common objective to:
Secure a condition of continuing compliance of sources.
B. For emphasis close wlthi
From the very first contact, each contact, each record,
each notice, should be part of a carefully designed
case record which will assure successful prosecution
of a case in a court of law even though the policy of
the agency is co-option. When this is done, voluntary
compliance works best and if it fails, judicial
decisions in the courts will be favorable.
3-12.
-------
LESSON 4
OFF-SITE SURVEILLANCE
OPACITY, DXUMENTATION
-------
HB
I AJnpOU.UTION I
Itrainino iNSTmj-rml
i i11
LESSON PLAN
TOPIC:
LESSON 4
OFF-SITE SURVEILLANCE,
OPACITY, DOCUMENTATION
STUDENT EXERCISE NO. 1, SECTION I
COURSE: *+44
LESSON TIME: 90 mill. *
PREPARED BY:^ DATE : 10/l/?8
*Lecture - 30 rain*
Student Exercise No. 1, Sec. 1-60 min.
£
55
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LESSON The purpose of this lesson is to bring into focus that element
GOAL. of the enforcement program which seeks out violating condi-
tions ty surveillance of a district, surveillance prior to
making an on-site inspection, or surveillance of a limited
area "by simplified instruments or effects indicators. The
elements needed to establish a violation and how they
apply to opacity surveillance are included.
LESSON At the end of this lesson, the student should "be able toj
OBJECTIVES.
1. State at least five different violating conditions sought
out during surveillance.
2. Explain three different ways surveillance is exercised.
3. When testing an occurrence, state at least five questions
to be answered to prove a violation.
4. Identify the point of observation of a plume for visible
emission evaluation.
5. Differentiate between water vapor and particulate opacity.
6. Demonstrate how to properly document a visible emission
violation.
7. Explain the meaning of a "certified smoke reader".
8. Define "opacity".
9. Explain the Ringelmann chart method of determining smoke
density.
4-1.
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Page 2 of 3
LESSON PLAN ( CONT'D)
LESSON 4
10. Prom a set of opacity readings, determine compliance or
violation with a given set of regulations.
11. Identify some of the more simplified evaluation by effects,
such as:
* adhesive captures of nuisance particles
* use of high volume sampler
* effect on sampling materials
* damage to plants and materials.
STUDENT
PRERECJJISITE
SKILLS.
Attendance at preceding lectures of this course. Familiarity
with EPA Method 9» Visual Determination of the Opacity of
Emissions from Stationary Sources, is "beneficial. Attendance
at a Visible Emission Evaluation training school or some
field experience in reading plume opacity would be helpful.
LEVEL OF
INSTRUCTION.
This lesson begins to deal with the specifics of how the
FED does his job. It is still non-technical in character
tut presents the details of field operations. Practices
differ among agencies and students should learn from each
other as well as the lecture text, and then judge the
value of their own methods compared to others.
INTENDED
STUDENT
PROFESSIONAL
BACKGROUNDS.
No special professional background required.
SUPPORT
MATERIALS
EQUIPMENT
LISTS.
35 nun Slide Projector and Screen
35 mm Slides
Blackboard
SPECIAL The theme might be that the record and documentation of every
INSTRUCTIONS, observable violation must be created in such a manner as to
become the foundation for a case whether or not legal
prosecution follows.
Ihe instructor should have some experience in "reading"
the opacity of plumes in the field.
k-Z.
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Page 3 of 3
LESSON PLAN (CONT'D)
LESSON 4
SELECTED 1. EPA Standards of Performance for New Station Sources,
REFERENCES. Appendix A, Method 9* See Code of Federal Regulations,
40 part 60. Reference 8.
2. Air Pollution Effects Surveillance, Chapter 10, Vol. Ill,
Ed. 3 of Air Pollution, Stern Editor, C. W. Gruber and
G. Jutze, authors, Academic Press 1976. Reference 9»
3- ARB Enforcement Symposium, Sacramento, Calif. Sept. 14-16,
1977» Criminal Actions "by A. H. Segal, Director Enforcement,
South Coast Air Qjiality Management District. Reference 10.
4. EPA-450/3-78-005, Handbook "Diagnosing Vegetation Injury
Caused try Air Pollution" , Office Air Qiality Planning and
Standards, Research Triangle Park, NC, 1978. Reference 11.
5- Guide lines for Evaluation of Visible Emissions,
Certification, Field Procedures, Legal Aspects and
Background Material. EPA-3^0/1-75-007. April, 1975* Reference 12.
6. EPA SI Course #448 "Diagnosing Vegetation Injury caused
by Air Pollution". Reference 13.
7. EPA-450/3-78-105 and EPA-450/3-78-106 Instructor and
Student Manual, APTI Course #4391 "Visible Emissions
Evaluation". Reference 35.
4-3.
-------
CONTENT OUTLINE
^S ^SMK>
Course ¦ Wt (TIME solEn
Lecture Tine ¦ 0Hf-SITE amvEiLLmCB,
Lecture line. nPAPTTy mniimiTaTTnw
?
J
5
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* PROl*-
I. INTRODUCTION
II. SURVEILLANCE PRINCIPLES
III. DISTRICT SURVEILLANCE
IV. PRE-INSPECTION SURVEILLANCE
V. SURVEILLANCE BY INSTRUMENTS AND EFFECTS INDICATORS
VI. ENFORCEMENT OF VISIBLE EMISSIONS
VII. DOCUMENTATION OF A VISIBLE EMISSION VIOLATION
VIII. TYPES OF EVIDMCE
IX. TESTIFY TO OPACITY
X. ESTABLISHING THE PRIMA FACIA CASE_
XI. STUDENT EXERCISE No. 1 - SECTION I
Page 1 of
Time
of
Unit
Min.
58
25
28
30
32
90
4-4.
-------
Course.
Lecture Title
OFF-SITE SURVEILLANCE,
OPACITY, DOCUMENTATION
CONTENT OUTLINE /£"
trse : W* /-• Tm-m rtTTTMFTITT T ^ SB
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2
Page of 9_
NOTES
I. INTRODUCTION
State lesson goal.
IRM p. 4-1
II. SURVEILLANCE PRINCIPLES
Surveillance means to "watch over".
* An assigned district by patrolling.
* Prior to entering a source facility for inspection.
* A limited area with instruments and effects
indicators.
A. Purpose
To find ty sensory perception (see or smell) a manifes-
tation of a violation of the rules and regulations or
of a potential violation. At times, simplified
instruments of effects indicators are needed to prove
an ambient violation or assist in a complaint investiga-
tion.
B. Observable Manifestations of Violations
* Plumes of regulable opacity.
* Fugitive emissions from source operations such as
materials handling, quarrying, crushing, construc-
tion, demolition, etc.
* Large particle fallout.
* Evidence of plant damage.
* Obnoxious odors, especially if citizen complaint
has been received.
* New facility construction expansion or modifica-
tion for which a permit may not have been
obtained.
* Open fires Where prohibited.
* Change of ownership without new owner obtaining a
required certificate of operation.
SM p. 4-2
* Illegal fuel delivery where fuel use is regulated.
4-5-
-------
Page 2 of 9
CONTENT OUTLINE (CONT'D)
LESSON 4
III. DISTRICT SURVEILLANCE
Is carried out
A. By having the FED spend a part of his day on "patrol"
B. Exercising surveillance when in the field on other
assignments, going from job to job.
SM p. 4-2
IV. PRE-INSPECTION SURVEILLANCE
A. Prior to entering a facility for inspection.
B. How is surveillance accomplished?
By seeking out a vantage point or driving around the
facility. Do this safely. Do not drive and look
park and observe.
V. SURVEILLANCE BY INSTRUMENTS AND EFFECTS INDICATORS
A. Hi-volume sampler
Used to show compliance with or violation of Ambient Air
Quality Standard for suspended particulates. Locate
upwind and downwind to show source impact.
B. Ambient Adhesive Impactor
Used successfully to show nuisance particles larger
than 20 /u.
C. Effects Indicators
Show vegetation effect.
Indicator materials as lead-based paints
VI. ENFORCEMENT OF VISIBLE EMISSIONS
A. Opacity
* Define opacity as the degree to which transmitted
light is reduced.
Examples 4($ opacity reduces the light
transmitted through the plume by 40$.
SM p. 4-3
SM p. 4-4
Slide 4-1
Slide 4-2
Slide 4-3
Slide 4-4
Collecting paint
overspray
Slide 4-5
Slide 4-6
SM p. 4-4
4-6
-------
Page 3 of 9
CONTENT OUTLINE (CONT'D)
LJ.SSON 4
* Opacity regulation limits the discharge of very
small particles. It is not fundamentally related
to mass particulate concentration.
* Visible emission regulation is nearly universal.
* EPA Method 9 is most widely accepted reference j
method. -
* State and local regulations may contain both
opacity and Rlngelmann chart.
Question student FED's.
How many have opacity regulations which
specifically refer to Method 9?
How many have both Opacity and Ringelmann Number?
Challenge students to actually quote regulation
number or section number, time and other wording.
B. Structure of a Plume
Point outs
* Point of release
* Body of plume
* Point of dissipation
* Detached plume
* Residing wet plumes at point of dissipation
C. Rules for reading opacity
(Qiestion and answer format.)
1. What should be the observer's position?
* Sufficient distance to provide a clear view.
* The sun is oriented in the 140 degree sector
to his back.
* Line of vision is approximately perpendicular
to direction of plume.
4-7
Slide: 4-7
Figure: 4-2
Sm.p. 4-8
Fig. 4.1
SM p. 4-5
Slide 4-8, 4-9,4-lC
SM p. 4-5
Figures 4-3»
4-4 and 4-5
-------
4 of 9
Structure of a Plume
Point of
release
Aii\
Sm.p 4-6
Point of dissipation
clear area
Stack •
detached plume
Figure 4-1. General structure of continuous and detached plumes.
(Source: Weiiburd, Reference S)
4-8
-------
5 of 9
Figure 4-3. Light source ihould emanate from the rear of observer during daylight hours
(reflected light).
Sm.p 4-10
ft—-— 4
Figure 4-4. During darkness, the light source should emanate from behind the plume, opposite
the observer (transmitted light).
Mi
Figure 4-5. Readingi should be made at right angles to wind direction and from any distance
necessary to obtain a clear view of stack and background.
(Source: APTD-1100 Reference 4)
4-9
-------
CONTENT OUTLINE (CONT'D)
LESSON 4
* Should not include more than one plume at a time.
* Perpendicular to direction of wind and perpen-
dicular to the plume.
2. What is the importance of background?
Need contrast.
Bias due to variable "background.
Tests EPA indicate possibility of
(a) positive bias (reading denser than actual) is
greatest with greater contrast in background.
(b) negative bias (reading lighter than actual) is
greatest with non-contrasting background.
3. Does observer look continuously at plume?
No. He glances at plume and reads once in
15 second intervals.
4. How do you "read" wet plumes?
Where condensed water vapor dissipates, or where it
leaves the stack.
5- Where in the plume does he judge the opacity?
Just above the stack outlet where plume has highest
opacity. For wet plumes see Q4.
6. Why should observer's sight line be perpendicular
to plume?
Must look across the plume to get true opacity
D. Types of Opacity Regulations
1. Opacity averaged over a specified time period -
six minutes in the current Method 9»
2. Any time the opacity is in violation is totaled and
compared to the regulation limit after deducting
allowances or exceptions.
Page 6 of 9
SM 4-24
SM 4-18
4-10
-------
Page 7 of 9
CONTENT OUTLINE (CONT'D)
LESSON 4
VII . DOCUMENTATION OF THE VISIBLE EMISSION VIOLATION
Name of source and location.
Emission location, i.e., specific stack, building
or other concise identification.
Date
Time (Including beginning and end of observation)
Degree of opacity
Orientation of observer, sun and emission point
Estimate of distance, observer to emission point
Approximate wind direction
Estimate of wind speed
Temperature and humidity, especially if a wet plume
is involved.
Description of sky (color or presence of clouds)
Color of visible emissions
Background, if other than sky
Name and title of observer
Important: If physical conditions prevent making
the observation according to specified conditions,
notes should be made to justify the accuracy of the
reading and perhaps marginal opacities should not
be included in the time summary.
Note: Most agencies have a form for recording of
an opacity reading which includes the necessary
information.
Sketch.
SM p. 4-11
Pass up if
time is short.
SM 4-25
4-11.
-------
CONTENT OUTLINE (CONT'D)
LESSON 4
VIII. TYPES OF EVIDENCE
1. Testimonial
2. Demon strative
3. Presented "by Expert Witness
Testimonial
A direct statement of what he saw and all supporting
conditions relating the event to the regulation.
Reciting the Documentation of the Violation.
See Section X "below.
Demonstrative
Physical evidence to support testimonial.
Example: Samples of damaged vegetation, samples
of fuel, photographs.
Expert Witness testimony
Covered in Lesson 9«
Opacity testimony is given as an expert witness.
IX. TESTIFYING TO OPACITY •
* The FED is trained to read opacity try judgment
(eye-hailing).
* He is certified ty successfully completing a
"course" of opacity readings at a smoke school, or
* Is otherwise trained in reading opacity.
* The FED testifies at hearings or in court as an
expert witness.
* As an expert witness, he must "be qualified as
such before giving testimony.
It is absolutely essential when testimony on opacity is
to be given that the FED be able to describe in some
detail (especially under cross-examination) the
procedures by which he was qualified to make opacity
(or density) readings.
B.
Page 8 of 9
SM p. 4-14
^12
-------
Page 9 of 9
CONTENT OUTLINE (CONT'D)
LESSON 4
X. ESTABLISHING THE PRIMA FACIE CASE
Applicable to court prosecution in a criminal case
(misdemeanor penalties)
A. "Prima facie" - legally sufficient to establish a
case (violation) unless disproved.
B. Every element of the rule violated must be proven.
Example; If the opacity rule alleged to have been
violated states:
"a person shall not discharge into the atmosphere from
any single source .... any air contaminant" of any
particular quality or quantity for more than the
maximum permissible time specified, it must be
proven that-.
(l) a person (2) discharged (3) into the atmosphere
(4) from a single source (5) a contaminant (6) of the
quality prescribed (opacity or density), (?) for more
than the time specified.
If a single element is missing, the violation has not
been established and there is no case.
XI. STUDENT EXERCISE NO. 1
Lesson 4, Section I.
Henderson County Ohio Opacity Violation.
SM 4-11
SM 4-12
Explain Exercise
Go to Lesson Plan
IRM p. 4-15 and
Student Workbook
p. 1-2
itl3
-------
LESSON PLAN
TOPIC:
STUDENT EXERCISE NO. 1
CASE STUDY
HENDERSON COUNTY - OPACITY VIOLATION
AND INSPECTION
LESSON 4 - SECTION I
COU^SON 5 - SECTION II
LESSON TIME:
PREPARED BY'. DATE 1/19/79
C. W. Gruber
£
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EXERCISE
GOAL.
Practice in application of principles taught during the day.
EXERCISE
OBJECTIVES.
At the end of this exercise, the student should have demonstrated
his ability to:
1. Read and apply rules and regulations which are not familiar
to the student.
2. Objectively determine, from given data on a series of
opacity readings that a violation, in fact, has occurred
and relate such observation to the Rule or Regulation
violated.
3. Write a notice of violation of visible emission rule.
4. Write a pre-entry inspection strategy statement.
5. Identify errors in a poorly conducted, on-site inspection.
6. Identify all potential violations discovered during the
on-site inspection.
7. Write a report documenting the on-site inspection.
SUPPLY
MATERIAL
EQUIPMENT
LISTS.
Case Study and Student Response Forms in Student Workbook.
Answer Key.
Tables for working groups.
35 mm Slide projector and Screen.
SPECIAL
INSTRUCTIONS.
The Henderson County Incinerator case has many interesting
aspects related to multiple violations, new ownership, etc.
Best practice would be to assign groups of three (or four to
balance out the class), attempting to mix experienced and
Inexperienced students in the same group. Also try to have
different agencies represented in the same group.
-------
LESSON PLAN (CONT'D)
STUDENT EXERCISE NO. 1
INSTRUCTIONS. The Exercise has two sections:
Section I follows Lesson 4 and Section II follows
Lesson 5»
Because of the time limitations, carefully abide "try the
following instructions:
1. Work as a team of two or three to be assigned.
2. Read the case histoiy and do the work called for
in the case study.
Only one completed answer sheet is required for
each Team. All members should sign to record their
participation.
4. Following each Lesson (4 and 5)» forty (40) minutes
will "be allotted to complete the answer dieets.
5. After 40 minutes, the instructor will call for reports -
question try question - at random from the various Teams.
The spokesman will respond.
6. Each point will be discussed.
7. At the completion of Section I and Section II, an
answer sheet will be available to each student to
compare against the work of his team.
8. Collection of the reports for review "try the instructor
is optional. If collected, the Team Reports should be
returned the next day.
4-15
-------
STUDENT EXERCISE NO. 1
SECTION I (LESSON 4)
ANSWER SHEET
TEAM MEMBERS SIGN:
7 f
1. Completed Visible Emission Observation Form. Do not turn in.
2. Ehter oh the Notice of Violation Form that information which is valid
to this point in time.
*r
3. The rule violated was
Aggregate (length) of violation &> 'I'1*" minutes
4. The on-site inspection should produce the following information to
complete the do aimentat ion of this violation.
1.
S*)i.v/fSt- MfgnJ ckfe
2. Oi£/f
3. fpfifintjor Ola Aff.
*fL+e: fak&b.
U*s is e+emp+ed -fr,m +**
^ f mmoMs of d
-------
Source Name
Address
VISIBLE EMISSION OBSERVATION FORM
7
~~ 7?
Observer
Dace
Observation Point: 75 Lo~ cfl
0
15
30
45
0
15
30
4$
tun^au. r »
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HINGH MANM H SUAlf FOfl
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-------
LESSON 5
ON-SITE INSPECTION OF SOURCES
-------
LESSON PLAN
TOPIC:
LESSON 5
ON-SITE INSPECTION OF SOURCES
(including Student Exercise No. l)
, , , (Section II)
course W+
LESSON time 90 minutes*
PREPARED BY: q. W. Gruber DATE10/l/78
*Lecture - 30 min.
Exercise Section II - 60 min.
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-------
Page 2 of 2
OONTENT OUTLINE (CONT'D)
LESSON 5
STUDENT Attendance at preceding lectures of this course.
PREREQUISITE
SKILLS. Each student FED should have knowledge of the rules and
regulations relating to inspection of sources used by his
own agency.
LEVEL OF This lesson completes the specifics of the field inspection
INSTRUCTION. process. It is non-technical and relates to the usual
practices involving on-site inspection. Methods vary
among agencies, but as noted in Lesson 4, students should
learn from each other as well as from the lesson.
INTENDED Same as Lesson 1.
STUDENT
PROFESSIONAL
BACKGROUND.
SUPPORT 35 mm Slide Projector and Screen
MATERIALS, 35 mm Slides
ECJJIPMENT Blackboard
LISTS.
SPECIAL The instructor should be familiar with on-site inspection
INSTRUCTIONS. so he has a "feel" for this part of the FED job.
The lecture material must be carefully integrated with the
script of the case history to follow on Film - Lesson 6 -
Cement Plant Inspection. Note there is no
break after this lecture. The course agenda flows directly
to introduce and show the film.
SELECTED Student Manual Chapter 5-
REFERENCES.
5-2.
-------
CONTENT OUTLINE /S
——
o
Lecture Title: ON SITE INSPECTION OF SOURCES ^ pro^j
Course.
(TIME bUHMJULii;)
LESSON 5
Page 1_ nf 1
NOTES
\
Ui
O
*
Time
' of
i Unit
: Min.
Ending
Min.
I. INTRODUCTION
II. TYPES OF INSPECTIONS
III. ELEMENTS OF THE INSPECTION PROCESS
IV. GIVING NOTICE OF VIOLATION
V. PREPARATION OF THE REPORT
VI. STUDENT EXERCISE NO. 1 - PART II.
3
18
4
3
6o
5
23
27
30
90
5-3.
-------
CONTENT OUTLINE SS
'3E
Page 1 of 10
Course 444
Lecture Title: ON-SITE INSPECTION OF SOURCES
o
PfcO"^'
UJ
o
r
NOTES
I.
INTRODUCTION
State lesson goal.
A. Practices Vary Among Agencies.
Since many of the procedures for on-site inspection,
especially the serving of notices, varies between
agencies, this lesson will deal largely with principles
of source inspection and the documentation thereof.
B. Definition of On-site Inspection.
An on-site inspection consists of an entry on to the
premises of a source facility to obtain facts and
information necessary to establish compliance or
non-compliance of a specific process or the entire
facility with the applicable rules or regulations.
II.
TYPES OF INSPECTIONS
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 source facility or a sub-unit is inspected for the
purposes ofi
1. Construction Permit Inspection
A premises is entered for the purpose of seeing that
the conditions of an issued permit to construct or
operate are met.
2. Qycllc Source Inspection
An inspection made according to a time cycle to
qualify or disqualify a source for a renewal of an
operating permit or to maintain continuing
knowledge of source operation and emissions.
3. Compliance Plan Inspection
To determine the progress of a compliance plan, an
administrative order or a court order.
>4.
-------
I Page 2 of 10
CONTENT OUTLINE (CONT'D)
LESSON 5
B. Violation Inspection
The premises are entered following an observed violation
as a result of off-site surveillance.
G. Complaint Inspection
Similar to A "hut relates to a complaint situation.
D. Inspections related to Emergencies
Two events trigger this type of inspection, the process
upset emitting pollutants causing immediate danger, or
the general alert due to prolonged adverse meteorology.
The former comes on suddenly and requires instant
response, while the latter may generate a high number
of source inspections requiring long hours in the field.
Emergency Episode and Alert Inspections will be covered
in Lesson 22.
E. Inspections might be
1. Single Purpose
Entering the premises for a single purpose ast
* To investigate an observed emission violation.
* To check a certain step in a compliance plan.
2. Multl-Purpoae
Single purpose inspection might lead to multi-
purpose (a real "can of worms") inspection.
A violation inspection might reveal many other
conditions of non-compliance, such asi
Failure to obtain construction permit
New ownership
Expanded operation
Change in processes, equipment or raw materials
Change in fuels
Be prepared to extend from single purpose inspection
to comprehensive inspection should conditions warrant.
5-5.
-------
Page 3 of 10
CONTENT OUTLINE (OONT'D)
LESSON 5
III. ELEMENTS OF THE INSPECTION PROCESS
A. Pre-entry Observation of the Source Premises
All inspections "begin with a pre-entry observation of
the premises for signs of visible emissions or other
manifestations of non-compliance. (In the case of
visible emission violation, this will have been done.)
Refer to Lesson 4 which covered pre-entry observation
under the heading of Pre-inspection Surveillance.
B. Preparation for Entry
1. Review the source record by
a. Referring to the plant record files he carries
with him. (Many FBOs have data cards for
their sources in their cars.)
b. Checking the source file in the office before
leaving for the field.
c. Check source data by radio contact or land
phone.
d. Have possession of permit or compliance plan
inspection forms usually available.
SM p. 5-4
2. Organize your inspection plan.
Have your reasons for the inspection and your
intended procedure well organized in your head so
they can be communicated to each of the persons
you will contact.
* The purpose for the inspection.
* Who you wish to see with alternates, if your
first choice is not available.
* The order of your investigative process.
C. Entry to the Premises
The procedure described here is the usual procedure
for an unfamiliar or poorly documented facility. Where
the FED is familiar with the source and certain of the
correctness of his data, some of the steps may be
omitted.
5-6.
-------
Page 4 of 10
CONTENT OUTLINE (CONT'D)
LESSON 5
1. Normal Entry Procedure
(Such is usually the case.)
* Gain entry through front gate or front door
of the particular facility to be inspected.
* Identify yourself and state your "business.
Produce your credentials, if requested.
* Ask for the facility manager. If known "by
name or title, use this.
* Abide "ty company rules. You may have to wait,
"tut you can't "shoot" your way in.
2. When Entry is Denied
In unusual cases, entry may be denied. In this
case, the FED may
(a) Immediately change his posture. Become
"tough". Example: "Your position gives me
no alternative but to proceed legally
against your company and I will do it.
Your attitude closes all other possible
enforcement routes."
(b) Advise of possible action for "failing to
grant entry". Sec. 114 of Clean Air Act or
appropriate local regulation.
(c) Obtain a search warrant. (See Lessons 7 and 8.)
D. Management Interview, How to Conduct
* 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.
"I wish to inspect the construction 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.
SM p. 5-6
5-7.
-------
CONTENT OUTLINE (CONT'D)
LESSON 5
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; such will usually "be denied.
Re-explain to make sure the reason for pictures.
If still denied, forget about photographs and
take complete notes. Perhaps sketches, if they
will aid and you have this ability.
Management interview establishes business data,
such as:
To instructors: You may wish to do this section by
conference method or give one or two examples and
have students generate the rest.
* The present legal owner
* Type, corporation, subsidiary, partnership,
individually owned
* If a corporation, the corporate identity
* Correct addresses of source, corporation
headquarters, division headquarters, etc.
-* The nature of the business
* Full name and title of responsible facility
manager. Make sure you will be able to
identify this person at a future time, if
necessary.
5-8.
-------
Page 6 of 10
OONTENT OUTLINE (CONT'D)
LESSON 5
* Full name and title of person to conduct you to
the site of interest.
* The documents or plant records you wish to
inspect, especially production rates and
materials involved.
* The inspection plan you wish to follow.
Cautions If the FED already has some of this
information, "be sure to verify same as ownership
and management changes.
E. Process Equipment Inspection
The complexity of the facility and type of inspection
"being made determines time required. This part of
inspection is often made with a source facility staff
environmental engineer who may or may not "be familiar
with the investigative methods of the FED, where it is
uncomplicated as in a small industrial boiler house,
the FED may be on his own.
1. Process or Equipment Inspection
During process inspection the FED will
* Obtain or confirm operational responsibility
with names, titles, etc.
* Process and equipment involved, identifying
"try name, number or location.
* Equipment operating schedules - check logs.
* Control equipment and abatement measures or
source reduction plans.
* Status of compliance with permit regulations
+ Is permit posted?
+ Is operating permit outdated?
SM p. 5-7
Instrumental Process Data
indicating.
recorded or
5-9.
-------
Page 7 of 10
00NTMT OUTLINE (OONTD)
LESSON 5
* Continuous emission monitor data.
* Be observant for signs of poor operating
practice or maintenance. See Lesson 19.
P. 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
supervisor or other responsible person who has
personal knowledge of the process operation. 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
The FED must now draw a conclusion (form a judgment).
* The process is in compliance or in violation.
1. Non-compliance
Important to focus in on
* The specific permit condition in non-compliance.
SM p. 5-7
SM p. 5-7
5-10.
-------
Page 8 of 10
CONTENT OUTLINE (CONT'D)
LESSON 5
* The specific rule or regulation, "by section
number which was violated.
* Is the violation continuing?
* The reason for non-compliance. While not
germane to establishing the existence of a
violation, it is important to the investigation
and the successful prosecution of the case,
should court action result.
* Are there unauthorized process modifications
(compared to valid permits)?
2. Where breakdown or upset is claimed, 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?
* Was the equipment being pushed beyond its
capacity to cause breakdown?
* Are the breakdowns frequent, indicating
poorly maintained or worn out equipment?
* Was prompt, aggressive, and effective action
taken to correct the condition or minimize the
emission during the upset period?
* Does the company have a plan to prevent
recurrence?
H. Providing Information
Depends upon jurisdiction policy«
Federal EPA
Many Locals
In between
Say nothing.
Serve a violation notice.
Mail notice after review of
FED report.
SM p. 5-8
5-11.
-------
Page 9 of 10
CONTENT OUTLINE (CONT'D)
LESSON 5
IV. GIVING NOTICE OF VIOLATION
Purpose is to officially notify the violator that one
or more specific violations have, indeed, occurred.
Key elements of a violation notice (Review)
* Identification of the violator, the name and address
of the company and the mailing address, if different.
* Source ownership, whether it is1 a corporation or
private ownership (partnership or individual).
* If a governmental entity, so state.
* The name and title of the person in charge of the
facility during the time of tine 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.
A. Leaving the Premises
At completion of inspection, FID takes a brief and
friendly, if possible, farewell and leaves. Do not
hang around for small talk.
V. PREPARATION OF THE REPORT
Helpful forms are usually available.
SM p. 5-9
Depends upon
policy.
Some agencies sa
"give only the
facts"
Use a letter
notice.
SM p. 5-9
5-12.
-------
Page 10 of 10
CONTENT OUTLINE (CONT'D)
LESSON 5
Immediately upon return to car—look over data—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 try-
phone or re-visit later. In such cases, be sure not to
show harassment or "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 fox preparation of
verbal testimony.
* Use full names and titles.
* 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.
CLOSING
SM p. 5-10
Student Exercise No. 1, Section II
SEE IRM - LESSON 4, FUR INSTRUCTIONS.
STUDENT EXERCISE NO. 1. SECTION II
Student Workbook
p. 1-9 for
continuation of
Student Exercise
No. 1, Section II.
ANSWER SHEET FOR SECTION II FOLLOWS.
5-13.
-------
STUDENT EXERCISE NO. 1
SECTION II
LESSON 5
ANSWER SiEET
TEAM Jkk ujS% MEMBERS SIGN
3-26-79
1. List at least five important errors pertaining to different principles
of good on-site Inspection and Investigative practice.
1. When advised by secretary to see Mr. Peterson, he should have asked
"is he the person of highest authority on the premises?" If not,
who is, and ask to see that person.
2. He should have asked Mr. Peterson's full name and official title.
He may "be a company officer or comptroller.
3« As soon as Hartley Div., Compton Metals is mentioned, he should get
the corporate address of Compton Metals, as well as exact corporate
name, and determine relationship of Hartley Div. to Compton Metals -
an operating division or wholly owned subsidiary.
4. At the incinerator, as soon as Mr. Allen's name as plant manager was
mentioned, he should get Allen's full name and title and inquire if
he is on the premises now and see him before he leaves.
5. As soon as he notes Operating Permit is issued to Johnson Storage,
he should have advised of the violation of Rule 10a (Operating Without
a Valid Permit) since Rule iZ states "Permits are not transferable".
6. He should inquire about construction plans and advise of provisions
of Rule 10a.
7. The time the inspector left the premises was not stated.
8. No information was given regarding the regulations.
1-14
(5-1A)
-------
STUDENT EXERCISE NO. 1
LESSON 5
ANSWER SHEET (CONT'D)
List the number of potential violations and specify the Rule which
has been violated.
No. of
Rule Violations Description
iPu I £ 5"o l C p ac i fuf
Rule /o b I /Jo Qjtefntw* itrmf r wc.
I?ul£ jO^ 4- Z hard chrome bfchnc, -fanks
I bkuer^ <2* ha
/ -f-ant
Complete the notice of Violation Tom, front and back.
If so instructed, each Teas is to turn in one completed Answer Sheet,
signed by all members of the Team and one completed Notice of Violation
Form, front and back.
cm
-------
EXAMPLE OF A PBOPERLY EXECUTED NOTICE OF VIOLATION *
Henderson County Air Pollution Control
Henderson, Ohio
NOTICE OF VIOLATION. 9->s-->z
ftfefah (jt CorJ>~) nd rf/e -Dt f S618 i. #S/£t:A0rs St J*sT«l£>.
-------
EXAMPLE OF A PROPERLY WRITTEN REPORT *
WAS MANAGEMENT CONTACTED ^£S ) NO
0PK11AT0R
Name & Address
ne & Address
4 0 r)
HIS REMARKS
$0 IV . §£t-«~JUjL
c
NAME
7 777 A //7T ^/ce president o«4
r fitter TITLEplant- Sk7a»ei4er
HIS REMARKS^ Poj^fhAjy^ /d j/^-Ji <-J~(X? rnj
Untj, . Cj^Jh /Lt-—<Ujg
Jjutk fr4^£w#~/urh -j^fU ovu^ztdU^ . "MUJL
f 1 1 1
CORPORATE OFFICER
DRIVER'S LICENSE NO.
VACATION FROM ' TO
RFQUEST FOR COMPLAIN I* SIGNED DATE
1-16
*It is to be assumed Mr. Allen,Plant g:g:VcSi;3 Manager was present and was (5-17)
contacted "by Hubbard before he left the premises.
-------
LESSON 6
INSPECTION OF A CEMENT PLANT
-------
LESSON PLAN
TOPIC:
LESSON 6
^eD sr%
INSPECTION OF A CEMENT PLANT
COURSE 444
LESSON time: 90 min.
PREPARED BY:
FILM AND WORKBOOK
C. W. Gruber
date: 1/19/79
LESSON
GOAL.
LESSON
OBJECTIVES.
To demonstrate off-site and on-site inspection procedures
"try- depicting on film a permit status inspection of a
cement plant. The student's proficiency is tested fcy
completing inspection report forms to record conditions
shown in the film.
At the end of this lesson, the student should be able to:
1. List the elements included in a facility inspection.
2. Describe the basic process of manufacturing Portland
cement (dry process).
3. Use existing agency data to prepare for an inspection.
4. Properly obtain entry to a facility for the purpose of
conducting an inspection.
5. Interface effectively with plant management and
personnel so as to elicit their help and cooperation.
6. List inspection points for cement plants.
7. Examine the appropriate inspection points for permit
compliance.
6-1
-------
LESSON PLAN (CONT'D)
LESSON 6
STUDENT
PREREQUISITE
SKILLS
Attendance at previous lessons
LEVEL OF
INSTRUCTION
This lesson, with film, will demonstrate principles
covered in Lessons 4 and 5.
INTENDED
STUDENT
PROFESSIONAL
BACKGROUNDS.
Some job association with air pollution enforcement
or related interest.
SUPPORT
MATERIALS
EQUIPMENT
LISTS
SPECIAL
INSTRUCTIONS.
SELECTED
REFERENCES
16 mm sound movie projector and screen
Film Time: "Field Inspections: Dry-type
Cement Plants
Running Time: 14 minutes
Available from the Air Pollution Training Institute
Some of the material shown in the film is related
to the subject of Lesson 15, Emission Control Hard-
ware. It may be somewhat "cart before the horse"
instruction but it will serve to illustrate the
importance of the material to be taught in Lesson 15.
Special attention is called to comments on Chapter 4
in Lesson Content, Sec. III.
Instructors must preview film before showing it in
this Lesson.
"Air Pollution Inspection of Cement Plants and Asphalt
Batch Plants" Student Workbook,
Prepared for EPA by: National Loss Control Service
Corporation
Note: This manual is not used as a handout to the
students in this course but can be used by the
lecturer as a reference. Each Area Training
Center has been provided a copy. Part of the
material has been used for Exercise No. 2 in
the 444 course student workbook.
6-2
-------
HB CONTENT OUTLINE /XN
Course: 444
lljflf Lecture Title: inspection of a cement plant ^ proi^
Page. 1 nf 1
NOTES
LESSON 6
FILM
Time
Of
Unit Ending
Min. Min.
I. INTRO HJCTION
2 2
II. LESSON CONTENT
•
III. COMMENT ON WORKBOOK PRODUCED WITH FILM
3 5
IV. INSTRUCTION TO STUDENTS
25 30
V. QUESTIONS
5 35
VI. READINESS FOR FILM
5 40
VII. SHOWING THE FILM
20 60
VIII. POST FILM DISCUSSION
30 90
6^
-------
Course: W lesson 6
Lecture Title: inspection of a cement plant piI&ipbo^
INTRO IUCTION
State Lesson Goal.
See also Student
Workbook, p. 6-3.
II.
III.
LESSON ODNTENT
Centers on film showing a routine inspection of a
cement plant.
1. Students observe conditions as presented in film,
then fill out their own inspection report forms.
2. After completion of 1, students will compare their
work with correctly filled out forms.
3. Discussion with instructor on inspection practices.
COMMENT ON WORKBOOK PRODUCED WITH FILM.
The film and a Trainee Workbook were made so they could
be shown and studied independent of Course 444.
Because of the limited time available in this course,
this film and the Asphalt Plant Inspection Film
(Lesson 15) will be used to illustrate the principles
of field activity being taught in this course. The
film Workbook is not used in its entirety. The
inspection forms and certain documents, necessary
for inspection, are extracted and are found in the
Student Workbook of this course, beginning on page
6-2.
INSTRUCTIONS TO STUDENTS PRIOR TO SHOWING FILM.
(ORGANIZATION OF VARIOUS FORMS)
A. Have students lay out forms on the table in the
following order:
1. Data Gathering Form.
2. Cement Plant Inspection Sequence, Schematic
3. Pictorials of Various Instrument Readings.
4. Permit Forms.
5. Summary of Source Operation.
6-4
-------
Page 2 of 3
CONTENT OUTLINE (CONT'D)
LESSON 6
B. After laying out forms, go over the suggested
Inspection Points, item for item, referring to the
Schematic. Such a procedure will familiarize the
student with the process. Also point out the
instrument readings needed for the starred (*) items.
Review Permit Forms and Summary of Source Operation
to locate the data to "be covered by the inspection
so that actual inspection data can be compared to
Permit Data.
Note: The instructor must, in advance, become
familiar with the forms, especially the Permit Forms
to assist the student in finding the data without a
great loss of time.
V. QUESTIONS?
VI. READINESS FDR FILM
Have students ready to react and make their own inspec-
tion comments as the inspector in the film performs the
inspection on the screen.
VII. SHOWING THE FILM
When all students are ready and all questions disposed
of, the film showing is begun.
One stop point has been provided (just following the
control room inspection) for the students to record
observations.
Lights go on as the students may wish to record the
data from the instrument facsimile drawings in the
workbook.
The instructor must use his judgment in determining
the length of this stop interval by observing when the
students appear to be finished.
The above is the only stop called for on the screen.
There is no harm in stopping the film at other points,
if this seems warranted.
6zi
From Instructor's
Manual accompanying
the film.
-------
Page 3 of1 3
CONTENT OUTLINE (CONT'D)
LESSON 6
VIII. POST FILM DISCUSSION From Instructor's
Manual accompanying
After the students have had. a chance to record their the film.
final observations, the session should be wrapped up
with a discussion of the films and observations the
students made. Data gathering forms, complete with
observations as might be made "by an experienced
inspector, are provided at the end of this manual
to assist the instructor in leading this discussion
(See Answer Key). At the discretion of the
instructor, these forms may be referred to only try
the instructor, they may be used to create overhead.
transparencies for group viewing, or copies may be
made and distributed to the group as hand outs.
During this post-film discussion, interest should be •
centered on maximizing the simulation experience of
the film inspections. The instructor should be
careful to relate what is seen in the films to the
problems and practices generally applicable to the
FED's field activity.
See Answer Key that follows.
6-6
-------
ANSWER KEY
DATA GATHERING GUIDE
CEMENT PLANT*
(Kiln and Clinker Cooler only)
THE PLANT PERIMETER
"No emissions apparent."
CONTROL ROOM INSTRUMENT READINGS*
"Clinker cooler baghouse inlet temperature residing about
360 with one acceptable excursion to 430. Lowest reading,
270, well above dewpoint. Coal mill feed rate, 8650
lbs./hr., well below maximum. Kiln feed rate, 135t000
lbs./hr., well above permit limits. Operator maintains
this rate only until kiln fills."
FILM STOPS HERE
DELIVERY END OP KILN
"No leaks or emission apparent. Appears well maintained."
CLINKER COOLER ENCLOSURE
"No leaks or emissions apparent. Appears well maintained."
DUST RETURN SPOUT AND CONVEYOR
"No leaks or emissions apparent. Appears well maintained."
* Refer to the drawings at the end of this form.
£=Z
-------
CLINKER COOLER BAGTOUSE
"No leaks or emissions apparent. Well maintained except
for access door clasps. Some plugged and blinded bags
recently removed."
BAG CLEANING COMPRESSOR
"Operating at peak output. Well maintained."
CLINKER COOLER BAGIOUSE FAN AND MOTOR
"Motor as specified in permit. Well maintained."
CLINKER COOLER BAGHOUSE STACK
"No emissions apparent."
MULTI-CYCLONE PRE-HEATER
"No emissions apparent."
KILN BAGHOUSE ENCLOSURE AND STACK
"Visible emissions from stack, approximately 50% opacity."
Q. Should inspector have taken time and recorded an opacity violation?
Q. Should plant superintendent have been so notified?
6-8
-------
AREA BELOW KILN BAGHOUSE
"Excessive fugitive dust from numerous small leaks."
KILN BAOTOUSE MANOMETERS*
"Overall systems pressure 11" HoO. Cells 1, 2, 3» 5» 7» and 10
reading 8-10" HgO. Cell 4 on cleaning cycle read minus 8".
Cell 6 reading 0. Cell ? reading 4". Baghouse apparently overloaded
with high pressure overall and on operating cells, and cell 6 out."
KILN BAGHOUSE HOPPERS AND SCREW CONVEYOR
"Considerable fugitive dust from numerous small leaks.
Need for repair and maintenance apparent."
KILN BAGHOUSE DUST RETURN SYSTEM
"Considerable fugitive dust from numerous small leaks.
Need for repair and maintenance apparent."
KILN BAGHOUSE FAN AND MDTOR
"As specified in permit. Well maintained."
PLANT YARD
"Some evidence of recent emissions on vdiicles in yard."
~Refer to the chart at the end of this form,
6-2
-------
GENERAL DISCUSSION.
Inspector's Personal Qp.alities.
Q. Was he dressed professionally?
Q. Should he have had protective clothing, perhaps a jump suit
or coveralls?
Q. What was your reaction to the completeness of his equipment?
Clipboard
Drawings
Hard Hat
J^e Protectors
Dust Respirator
Camera
Q. Should he have had more communication with superintendent
"before leaving?
Q. Was he too formal? Too informal?
Q. Do you think he related well to the specifics of the regulations
during the inspection and before leaving?
Closing statement by instructor.
Do not collect student papers.
6-10
-------
LESSON PLAN
i*
TOPIC: TEST j AND REVIEW
ON DAY 1 LESSONS
COURSE:
lesson time: 30 mua. !/19/79
prepared by ^ ^ Giuter
sS
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LESSON
GOAL.
To test the students on how well they absorbed
Day 1 Lessons, 1 through 7.
LESSON
OBJECTIVES.
At the end of this lesson the student should "be able to:
1. Judge how well he absorbed the material covered in
Lessons 1 through 7 dealing with THE FED - HIS JOB -
HOW HE DOES IT.
SPECIAL
INSTRUCTIONS.
Allow 25 minutes for the test. Collect the papers and
immediately review the correct answers.
Instruct students to put answers on test sheet, as well
as the Answer Sheet so that they will retain their
answers and can grade their own work.
6-11
-------
/}&*)££
AIR POLLUTION FIELD ENFORCEMENT
COURSE #444
TEST NO. 1
33 questions - Time 25 minutes.
Circle the correct response for either True/False or Multiple Choice
questions. There is only one correct answer for each question. R>r
each wrong answer, three points will be deducted from 100 to give
the test grade.
Put your answers on the answer sheet, also your name, and tuna it
in when completed.
Papers will be collected 25 minutes after beginning of test.
1. Air Quality Control Programs in the U.S. are prescribed by
a. the Federal Clean Air Act alone
b. State legislative action only
© State legislative action and the Federal Clean Air Act
d. Local regulations alone
2. The scope of a field operation program depends upon
a. the number and types of stationary sources
b. the agency level, i.e., local, state, federal
c. the complexity of rules and regulations
© all of the above
3. Which of the following is least related to the field enforcement
process?
© ambient air quality monitoring
b. compliance plan inspection
c. requiring periodic re-inspection of sources
d. district surveillance
4. In proceeding from one inspection to another, it is not necessary
for the FED to exercise surveillance because he is specifically
assigned to source inspection. T
(6-12)
-------
5. The term opacity means the degree to which transmitted.
light is reduced. Qlj
6. Atmospheric particulates, larger than 20/u, can be sampled
with sticky paper. (Yj
7. Upon entering a plant for the first time, it is proper
procedure to obtain a search warrant in advance to insure
gaining entry. T
8. Before making an inspection for any purpose, it is
considered unnecessary to
a. consult the source file if available
b. form a plan before entering
© always phone ahead and make an appointment
d. obtain the name of the facility contact person,
if available
9. Tasks assigned to the FED roost always include
a. functioning as a working member of a source test team
0 investigating citizen complaints
c. operating the ambient air quality network
d. personally serving notices of violation
10. Which of the following are considered effective enforcement
actions?
a. filing a civil or criminal suits
b. notice of violation with orders to abate
c. revoking a permit to operate
^dJ all of the above
11. A source in "continuing" compliance requires minimal
surveillance. Qrj
12. Enforcement actions following an observed violation
are left entirely to the judgment of the FED. T
13. Protection against the adverse effects on public health
and welfare is the only goal of the Federal Qlean
Air Act. t
(6-13)
-------
14. Ambient Air Quality results only from the sum of emissions
from sources plus atmospheric reaction products. T
15. An enforcement policy guides the FED
a. in the types of equipment subject to the
permit regulations
b. in the percent opacity which constitutes
a violation
(c7) in the action he takes following an
observed violation
d. all of the above
16. Which of the following contaminants is not emitted directly
from sources?
(eu^ photochemical oxidants (O3)
b. particulates
c. hydrocarbons
d. carbon monoxide
17. The ultimate success or failure of the enforcement program
depends heavily upon
a. the manner of issuing a violation notice
(j^) how well the FED does his job
c. whether the air pollution control program is
state or local
d. all of the above
18. Which of the following does not apply to the FED's job conduct?
© an official vehicle must be used for field work
b. communication is more than people talking to each other
c. effective communications may prevent friction
d. dress and appearance are important
19. The FED does a better job if he develops a potential for s
legal enforcement. (t)
20. The most important part of a newly hired FED's orienta-
tion program, during his first week on the job, is to
obtain certification as an opacity observer. T
(6-14)
-------
21. Prior to making a periodic source inspection, it is good
practice to make an observation of the source exterior,
even though extra time is required. f T)
22. Which of the following is not an observable manifestation of
certain non-compliance during surveillance of a district?
<£> emission of excessive carbon monoxide
b. evidence of new construction for which no
permit has been obtained
c. plumes of readable opacity
d. none of the above
23. Assuming you are in a remote part of your territory and you
have no prior contact with a source facility, and you observe
a visible emission violation from what you assume to be power
house chimney, you should
a. go back to headquarters to see if there is a record
on the facility
b. go to the facility entrance and ask to see the
boiler operator
0 go to the facility and request to see the resident
manager
d. hope the guard at the gate does not request identifi-
cation
24. In making an opacity reading, the FED should look constantly
at the plume to detect changes that may occur during the
observation. T
25. Before deciding a condition is non-compliance, the FED
must relate the facts to the specifics of a rule or _
regulation. fn
26. A notice of violation must be delivered in person to the
highest ranking official present at a plant determined to
be in violation of a control regulation. T
27. Where breakdown is given as a cause of violation, it is
important to
a. probe the event for signs of the emergency
b. analyze the situation against the regulation
relating to emergencies
c. assess the frequency of breakdowns of a similar
nature from this source
all of the above
(6-15)
-------
28. An inspection report is always tetter if it is a
lengthy report.
©
29. At the initial plant inspection, you should obtain
a. the name of the secretary to the manager
b. the number of employees in the company
(c7) the present legal owner of the source
d. none of the above
30. Which of the following is unnecessary in documenting a
visible emission violation?
a. beginning and ending time of the observation
b. location of the source
c. position of the sun with respect to observer
and source
(jiT) the construction permit number and date
31. After learning the rules and regulations, administrative
procedures and policies, the FED is not concerned with
any further training. T Cl>
32. When inspecting a dry type Portland cement plant, it is
important to
record key instrument readings and relate them to permit data.
b. form judgements on fugitive dust emissions
c. form judgements on the adequacy of control equipment maintainence.
© all of the above
33* In a dry type Portland cement plant, a major problem is
the emission of
a. hydrocarbons
t. nitrogen oxides
<£) fugitive dusts
d. all of the above
(6-16)
-------
AIR POLLUTION FIELD 0TFORCEMENT
course mhh
TEST NO. 1
Kj:i(
/) biSu) €/C
2* £i Id
3.
4. True (False
6. False
12. True
False
False'
False,
Name
1. a "b (IT) d 18. (^a) "bed
c (^d) 19. (True) False
(ja) "bed 20. True (^False)
21. (True^) False
5. False 22. (T) bed
23. a b (cT) d
7. True (False) 24. True (fiaTse)
8. at @ d 25. (True) False
9. a (J) c d 26. True ^Fals^)
1°' a b c ® 27. a b c ©
11. (Se) False 28. True ^Fal^
29. a b © d
13. True (False") 30. a b c
l4' 11116 (Falsy 31. True (False'
a b (c) d 32. a b c ^d
16. (ja) bed 33. a b d
17. a © c d
TEST EVALUATION - Check one box each line. This test has been:
Too long CJ About right Q Too short CU
Too hard About rigjit ~ Too easy I I
(6-17)
-------
LESSON 7
BASIC FEDERAL LEGAL PROVISIONS
CONSTITUTIONAL AND THE CLEAN AIR ACT
-------
LESSON PLAN
i»
TOPIC:
LESSON 7
BASIC FEDERAL LEGAL PROVISIONS
CONSTITUTIONAL AND THE CLEAN AIR ACT
COURSE- ^
LESSON TIME: 30 mtn.
PREPARED BY
Pamela Giblin
DATE
1/19/79
$
5
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LESSON
GOAL.
To teach the federal legal provisions applicable to Air
Pollution Control law and enforcement thereof, namelys
(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.
Notet In depth discussion of the Federal Ehforcement
Program will be given in Lesson 17.
LESSON
OBJECTIVES.
At the end of this lesson, the student should be able tot
1. Identify the Fburth Amendment as providing protection
from unlawful search and seizure, and the limitations
for gaining entry to a source premises.
2. Identify the Fifth Amendment as providing protection
against self-incrimination, except for corporations.
3. Identify the Fourteenth Amendment as establishing the
principles of "due process" and "equal protection".
4. Define the responsibility for enforcement of the Federal
EPA, States and Local governments as applied to (a) all
sources except mobile, (b) mobile sources, (c) emergencies.
5. Identify the pre-construction control under the require-
ments of new source review for NSPS, NESHAPS and PSD.
6. State the responsibility of the Federal EPA when States
fail to enforce their SIPS. (Section 113)
7. Define "PSD" and "off-set" and vhere they apply.
8. Define LAER, BACT, NSPS, NESHAP and RACT.
7-1
-------
Page 2 of 2
LESSON PLAN (CONT'D)
LESSON 7
STUDENT Attendance at previous lessons of this Course. Reading
PREREQUISITE the text In advance is recommended.
SKILLS.
LEVEL OF This lesson begins the "legal aspect" series. (Lessons 8
INSTRUCTION. through 13.) The material deals with the basic federal
law (Constitution and Clean Air Act) provisions which
support and limit his field work. The instructor should
remember that the students have had no formal legal
training.
INTENDED No special professional background is required.
STUDENT
PROFESSIONAL
BACKGROUNDS.
SUPPORT
MATERIALS,
EQUIPMENT
LISTS.
35 nun Projector and Screen
Slides
Blackboard
SPECIAL
INSTHJCTIONS.
The instructor should be a practicing lawyer, preferably
from the staff of a state or local control agency. A
private attorney with environmental litigation experience
could be used.
Lessons 8 through 13 should be given try the same instructor
to provide continuity.
The instructor is encouraged to substitute his own case
histories for those examples in the test.
SELECTED
REFERENCES.
Student Text.
Federal Clean Air Act
7-2
-------
I.
CONTENT OUTLINE /£
TXMESQiiaXrLEr
Course: W "™ —* \^l^/
Lecture Title : BASIC FEDERAL LEGAL PROVISIONS % pro^
THE U. S. CONSTITUTION AND THE CLEAN AIH ACT
Page Jk of-L
NOTES
\
INTRODUCTION
Time
Of
Unit
Min.
Ending
Min.
II. CONSTITUTIONAL PROVISIONS
A. The Fourth Amendment
B. The Fifth Amendment
C. The Fourteenth Amendment
III. THE FEDERAL CLEAN AIR ACT
A. State Implementation Plans
B. Federal Enforcement
C. Permit Requirements
i 10
12
15
27
IV.
SUMMARY
30
7-3
-------
CONTENT OUTLINE
/rse: Wj-
Course: W+
Lecture Title: BASIC FEDERAL LEGAL PROVISIONS -^"RO^°
THE U. S. CONSTITUTION AND THE CLEAN AIR ACT
I. INTRO IUCTION
State the lesson goal.
The principal thrust of this lecture will be how federal
constitutional and statutory provisions interface with
state and local enforcement.
II. CONSTITUTIONAL PROVISIONS
A. The Fourth Amendment guarantees individual freedom
from unreasonable searches and seizures.
Inspection of air pollution sources and need for
reasonable procedures.
Advisability of obtaining search warrant when
entry denied.
B. The Fifth Amendment guarantees personal freedom
from self-incrimination.
Self-reported data and its use in enforcement
procedures.
C. Ihe Fourteenth Amendment guarantees due process of
law and equal protection for all citizens.
Reasonableness of regulations adopted by agency and
the role of hearings in insuring due process.
III. THE FEDERAL CLEAN AIR ACT
A. State Implementation Plans
B. Federal Ehforcement
1. Section 113
2. Section 303
3. National Enissions Standards for Hazardous Air
Pollutants (NESHAPS)
Page.
Of _JL.
NOTES
LESSON ?
SM p. 6-1 to 6-3
SM p. 6-3 to 6„6
FCAA Sec. 110
FCAA Sec. H3
FCAA Sec. 303
FCAA Sec. 112
-------
Page 2 of 2
CONTENT OUTLINE (CONT'D)
LESSON 7
C. Permit Requirements
Now much more detailed under 1977 Amendments to
Glean Air Act.
1. New Source Performance Standards (NSPS) FGAA Sec. Ill
Standards set for categories of sources.
Enforcement of NSPS may "be delegated to the states.
2. Prevention of Significant Deterioration (PSD) FCAA Part C
Protection of areas where the air is cleaner than
that prescribed "by the NAAQS requirements applicable
to "major emitting facilities".
Air quality sampling analysis must "be conducted.
Specified increments must not be exceeded.
Best available control technology (BACT) must be
applied.
Monitoring must be conducted.
3. Emission Offsets FGAA Part D
Protection of areas where an NAAQS is exceeded.
Applicable only to "major sources".
Requirement for lowest achievable emission rate
(LAER).
Compliance ty all existing sources owned or
controlled ty the owner or operator of the proposed
source in the same air quality control region.
Reasonable further progress (RFP) toward attain-
ment of NAAQS.
-------
LESSON 8
STATE AND LOCAL LAWS
AND ADMINISTRATIVE PROCEDURES
-------
LESSON PLAN
TOPIC:
LESSON 8
STATE & LOCAL LAWS AND
ADMINISTRATIVE PROCEDURES
(AM POU-UTION I
tminino iywriT\m»|
course: 444
LESSON TIME: 30 min
PREPARED BY:
UJ
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-------
LESSON PLAN (CONT'D)
LESSON 8
STUDENT
PREREQUISITE
SKILLS.
Attendance at previous lessons of this Course.
Reading text in advance is recommended.
LEVEL OF
INSTRUCTION.
Continuation of Legal Aspects Series
See Lesson
INTENDED
STUDENT
PROFESSIONAL
BACKGROUNDS.
No special professional background is required.
SUPPORT
MATERIALS,
EQUIPMENT
LISTS.
35 mm Slide Project and Screen
Slides
Blackboard
SPECIAL
INSTRUCTIONS.
Same as Lesson 8.
SELECTED
REFERENCES.
Student Text.
8-2
-------
BB CONTENT OUTLINE /X\
Course: Wj- \*dlk+g
IMLamm Lecture Title: STATE AND LOCAL LAWS AND % PR
Pngp 1 nf 1
NOTES
ADMINISTRATIVE PROCEDURES
Time Ending
Of Min.
Unit
Min.
I. INTRODUCTION
2 2
II. POLICE POWER
5 7
A. Constitutional "basis
B. Proper foundation'for valid regulations
III. OOMMDN LAW NUISANCE
5 12
A. Original theoxy ty which air pollution violations
were pursued in the courts.
B. Certain advantages in areas not suited to
emission limitations.
C. Problems associated with nuisance.
IV. THE STATUTORY APPROACH
5 17
A. Advantages.
V. ADJUDICATORY HEARINGS
13 30
A. Enforcement Proceedings
B. Permit Issuance
oA
-------
CONTENT OUTLINE /X
Course : W
Lecture Title:
STATE AND LOCAL LAWS AND
P
•C
i
O
\
Page L_ of fL
W) N0TES
PPO^'
ADMINISTRATIVE PBOCEDURES
I. INTRODUCTION
State the lesson goal.
The principal thrust of this lecture will "be how state
and local laws and administrative procedures originated
and the evolution of enforcement theories.
II. POLICE POWER
A. Constitutional "basis
B. Proper foundation for valid regulations
III. OOMMDN LAW NUISANCE
A. Original theory ty which air pollution violations
were pursued in the courts.
B. Certain advantages in areas not suited to emission
limitations.
C. Problems associated with nuisance!
1. Subjectivity
2. "Balancing of the equities"
3. General interference with the public
IRM 8-1
SM p. 7-2
' SM p. 7-2
p. 7-3
IV. THE STATUTORY APPROACH
A. Advantages:
1. Objectivity and predictability
2. Once violation has been shown, no need to prove harjn.
V. HEARINGS PRIOR TO REGULATION ADOPTION
Information gathering function of legislative hearings.
Adversary process not used.
SM p. 7.-3
8-I*
-------
I Page 2 of 2
CONTENT OUTLINE (CONT'D.)
LESSON 8
VI. ADJUDICATORY HEARINGS
A. Ehforcement Proceedings
"Show cause" hearings.
Hearings prior to entry of Section 112 compliance
orders.
SM p. 7-3 to
p. 7-4
B. Permit Issuance
Hearings useful in allocating air quality increment
under PSD.
Burden of proof on source to show that permit
requirements are met.
8-5
-------
LESSON 9
LITIGATION PROCEDURES
-------
LESSON PLAN
TOPIC:
LESSON 9
LITIGATION
PBOCEDURES
COURSE:
LESSON
time: 45 min
1
PREPARED BY:
DATE:
Pamela Giblin
12/15/78
S^,
£
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-------
Page 2 of 2
LESSON PLAN (CONT'D)
LESSON 9
STUDENT Attendance at previous lessons of this Course.
PREREQUISITE Reading text in advance is recommended.
SKILLS.
LEVEL OF Continuation of Legal Aspect Series, See Lessons 8 and 9.
INSTRUCTION.
INTENDED No special professional background is required.
STUDENT
PROFESSIONAL
BACKGROUNDS.
SPECIAL 35 mm Slide Projector and Screen
MATERIALS, 35 n® Slides
ECJJIPMENT Blackboard
LISTS.
SPECIAL This lesson becomes important when the FEO is faced with
INSTRUCTIONS. enforcement by litigation. It is even more important when
considering, in general, the relatively few enforcement
actions which terminate in litigation. Lesson 9 details the
administrative enforcement actions which are the choice of
most agencies before litigation is considered. But all
agencies must be prepared for strong action when administra-
tive procedures fail to bring about compliance on a case by
case basis or in general. For Federal EPA Ehforcement,
certain specific situations described in the Clean Air Act
mandate litigation. A well trained FED must be prepared
to cariy his share of the litigation process if and when
it is used.
9-2
-------
Course: 444
TIME SCHEDULE
Lecture Title: LITIGATION PROCEDURES
I. INTRO EUCTION
II. TYPES OF LITIGATION
A. Civil Actions
B. Criminal Actions
CONTENT OUTLINE
$
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NOTES
Time
Of
Unit
Min.
10
Biding
Min.
15
III. PRETRIAL DISCOVERY
A. Deposition
B. Interrogatories
IV. PRINCIPAL HJLES OF EVIDENCE
A. Hearsay Rule
B. Best Evidence Rule
C. Leading a Witness
D. Do's and Don'ts for Witnesses
V. HEARINGS PRIOR TO REGULATION ADOPTION
A. Information gathering function of legislative
hearings.
VI. ADJUDICATORY HEARINGS
A. Characteristics of adversary process
B. Enforcement proceedings
C. Compliance orders
D. Permit issuance
i 5
20
10
10
30
35
^5
9-3
-------
nn CONTENT OUTLINE ,"®\
LfiMjiil Course: w»
LIj&I Lecture Title: LITIGATION PROCEDURES % proi^
Paae. 1 of 2
NOTES
LESSON 9
I. INTROEUCTION
State the lesson goal.
The principal thrust of this lecture will he the basic
rules of evidence and procedures for trial, with
particular emphasis on the role of a witness.
II. TYPES OF LITIGATION
SM p. 8-2
A. Civil Actions
Generally seeking penalties of $50 to $1,000 per
violation.
Two types of injunction available — prohibitory
injunction whereby a facility is shut down and
mandatory injunction whereby a court orders a
source to take corrective measures within a given
time schedule and final compliance by a certain
date.
B. Criminal Actions
Possible problem areas: Judges stricter in requir-
ing that a control agency scrupulously observe
constitutional rights of defendant; burden of
proof is "beyond a reasonable doubt" rather than
"preponderance of the evidence" as in civil cases;
fines generally set so low that a violator could
simply pay a fine and continue to pollute.
III. PRETRIAL DISCOVERY
SM p. 8-3
A. Deposition
1. Fishing expedition to determine what a
witness knows.
2. Perpetuate the testimony of a witness.
3. "Impeach" a witness.
B. Interrogatories
Set of written questions to be answered ty a
prospective witness in lawsuit.
-------
Page 2 of 2
CONTENT OUTLINE (CONT'D)
LESSON 9
IV. PRINCIPAL RULES OF EVIDENCE
A. Hearsay Rule
Prohibition against testifying as to statements
which were made out of court.
Exceptions.
B. Best Evidence Rale
Evidence presented must be in best form for
proving facts in question.
C. Leading a Witness
Cannot ask questions which suggest answers.
D. Do's and Don'ts for Witnesses
Most crucial point is to prepare for testimony try-
consultation with counsel.
V. HEARINGS PRIOR TO REGULATION ADOPTION
A. Information gathering function of legislative
hearings.
VI. ADJUDICATORY HEARINGS
A. Characteristics of adversary process
B. Enforcement proceedings
C. Compliance orders
D. Permit issuance
SM p. 8-3 to
p. 8-4
2i5
-------
LESSON 10
COURTROOM PROCEDURES
-------
LESSON PLAN
I *
L
TOPIC:
LESSON 10
COURT BOOM PROCEDURES
FILM - HOLE OF THE WITNESS
im
60 min.
COURSE-
LESSON TIME:
PREPARED BY: * DATE:
Pamela Giblin 12/15/78
s^e0 sr"^,
£
5
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LESSON
GOAL.
LESSON
OBJECTIVE.
To show "Role of the Witness film, demonstrating court
room procedure. Discuss lessons from the film and prepare
for Case Study Exercise, "Trial of Opacity and TSP
Violations, Lesson 11.
At the end of this lesson, the student should be able tot
1. Distinguish between effective and ineffective court
demeanor by an FBO 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.
STUDENT
PREREQUISITE
SKILLS.
Attendance at Lessons 7 through 9.
LEVEL OF
INSTRUCTION
The film should generate discussion and solidification
of points presented in Lesson 11. The demonstration
will drive home the difficulties encountered when a
witness undergoes cross-examination.
10-1
-------
Page 2 of 2
LESSON PLAN (CONT'D)
LESSON 10
INTENDED
STUDENT
PROFESSIONAL
BACKGROUNDS.
No special professional background is required.
However, the student selected should he one of the
more experienced FED's and preferably has experience
testifying in court.
SPECIAL
MATERIALS,
EQUIPMENT
LISTS.
Chair for witness.
Table and chair for attorney.
Any notes the witness may widi to bring.
Film: "Role of the Witness" (running time 40 minutes)
SPECIAL
INSTRUCTIONS.
The film should be properly introduced. See Lesson Content
The film requires 40 minutes to show. See Agenda for
starter discussion points, but the instructor should
strive to get student comment.
After the film, have a brief discussion on court room
procedures.
After the discussion, begin preparation for mock trial
in Lesson 11.
10-2
-------
CONTENT OUTLINE /£*
Course: Wj-
Lecture Title:
COURT BOOM PROCEDURES
$
5
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*
INTRODUCE FILM:
Page ] nf l
THE ROLE OF THE WITNESS
The "basic function of the film "The Role of
the Witness" is to provide a graphic demon- i
stration 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 context of
particular testimony.
NOTES
One of the short-comings of the movie is that
it is fairly old and could he 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 prograjn
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 1A10 portrays the field
enforcement officer does an excellent job of
showing how effective a calm and unbiased
presentation can be.
10-3
-------
LESSON 11
CASE STUDY EXERCISE
TRIAL OF OPACITY AND TSP VIOLATIONS
SE STUDENT WORKBOOK
-------
LESSON PLAN
TOPIC: LESSON 11
STUDENT DEMONSTRATION
MOCK TRIAL
COURSE: W+
LESSON time: 150 min.
PREPARED BY
P. Giblin
C. W. Gruber
DATE:
1/19/79
S7^
£
55
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LESSON
GOAL.
LESSON
OBJECTIVES.
STUDENT
PREREQUISITE
SKILLS.
This lesson (exercise) is intended to provide a "background
against which the students may test their own ability to
develop a trial strategy, both prosecution and defense,
and to provide court room testimony.
At the end of this lesson, the student should be able to:
1. Differentiate between good and poor trial strategy.
2. Differentiate between testimony well given and poorly given.
Attendance at Lesson 10.
LEVEL OF
INSTRUCTION.
INTENDED
STUDENT
PROFESSIONAL
BACKGROUNDS.
This is a workshop exercise where students are asked to put
into practice the principles learned in Lessons 7 through 10.
No special professional background is required. Experience
as an FED is helpful.
SPECIAL Chair for witness
MATERIALS, Table and chair for each side, one for prosecution and
EQJIPMMT one for defense.
LISTS. Table and chair for "judge"
SPECIAL
INSTRUCTIONS.
See CONTENT OUTLINE.
SELECTED
REFERENCES.
Student Manual.
11-1
-------
CONTENT OUTLINE /X
Course: 444
Lecture Title:
TIME SCHEDULE
LESSON 11
I. INTRODUCTION
II. ORGANIZATION OF STUDENT GROUPS AND ROLES
III. CASE PREPARATION
IV. DEMONSTRATION
V. DISCUSSION BY CLASS
VI. CRITICJJE BY INSTRUCTOR
VII. SUMMATION
£
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41
NOTES
I t ime
of
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; 30
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125
140
145
150
11-2
-------
II.
III.
IV.
CONTENT OUTLINE
Course: 444.
Lecture Title:
LESSON 11
STUDENT DEMONSTRATION
I®
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i
INTRODUCTION.
Give Lesson Objective.
ORGANIZATION OF STUDENT GROUPS AND ROLES
Students will work in groups (teams) of 3 to 6 depending
upon the number of students in the class.
When the student total is 24 or less, 4 teams will "be
established. Two teams, T^y lot, will "be assigned to
opacity and two teams to the TSP case, after which, by lot
the teams will be assigned prosecution or defense.
If there are more than 2h students in the class, extra
teams will be formed as above and .just before the trial
begins, one of the duplicated teams, by lot, will be
chosen to go on with the trial and one will be an
observer. Thus, all teams must prepare for the mock
trial. The teams sire organized try the course moderator
to get a mix of students on each team. The moderator
will designate a team leader, selecting a more
experienced person for this assignment.
The teams are to organize as follows:
Prosecution
1 chief prosecutor
1 FED
1 chief of enforcement
Defense
1 defense attorney
1 technical adviser
1 assistant defense attorney
The other persons are assigned roles as desired by the
team leader.
CASE PREPARATION.
See Student Workbook.
DEMONSTRATION.
See Student Workbook.
Page-1_ of Z-
NOTES
Lesson Plan
WB 11-3
WB 11-4
WB 11-5
11-3.
-------
Page 2 of 2
CONTENT OUTLINE (CONT'D)
LESSON 11
V. DISTRIBUTION OF ACTUAL TRIAL QUESTIONS AND INJUNCTION.
After mock testimony is complete: distribute actual
trial questions, the Facsimile of Mandatory Injunction
and open for discussion.
VI. DISCUSSION BY CLASS.
VII. CRITIQjJE BY INSTRUCTOR.
WB 11-6
WB 11-6
VIII. SUMMATION.
11-4-
-------
LESSON 12
OVERVIEW OF THE FEDERAL EPA
ENFORCEMENT PROGRAM
-------
LESSON PLAN
TOPIC:
LESSON 12
OVERVIEW OF THE FEDERAL
EPA ENFORCEMENT PROGRAM
COURSE
LESSON TIME
PREPARED BY
Wj-
C.
75 min.
W. GruberDATE 11/25/78
nS
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£
-------
LESSON PLAN (CONT'D)
LESSON 12
STUDENT Attendance at previous lectures.
PREREQUISITE
SKILLS
LEVEL OF The lesson "broadly describes the Federal enforcement
INSTHU CTION program.
INTENDED No special professional background is required.
STUDENT
PROFESSIONAL
BACKGROUNDS
SUPPORT None, unless the instructor specifically request it.
MATERIALS
EQJIPM1NT
LISTS
SPECIAL The instructor should!
INSTRUCTIONS
Currently be involved with Federal enforcement,
either legally or technically, preferrably
in the EPA Region in which the course is given.
Use references to personal experiences and case
histories of enforcement actions.
Comment specifically on procedures used in the
EPA Region of the course with respect to State
notification of audit inspections.
Comment on citizen suits if he has personal
experience with the same.
Update any lecture material that is changed
ty EPA policy or by a change in the law or
regulations.
SELECTED The Clean Air Act, Sections 113 and 114 and Parts C and
REFERENCES
12-2
-------
CONTENT OUTLINE
(Sft) mi
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**£ ppn1^-
Page 1 of -
Course: W TIME scheeule
Lecture Title: LESSON 12
I. INTRODUCTION
II. INTERFACE WITH STATE AND LOCAL ENFORCEMENT
III. PROVISIONS OF THE CAA WHICH DIRECT FEDERAL ENFORCEMENT
IV. CLEAN AIR ACT ENFORCEMENT PROCEDURES
V. PROCESSING SECTION 113 ACTIONS
VI. PENALTIES
VII. AUDIT BY EPA OF STATE SOURCE INSPECTIONS
VIII. (JJESTIONS FROM STUDENTS RE: EPA, STATE AND LOCAL
ENFORCEMENT MATTERS. If no questions are forthcoming,
Speaker to give case histories.
IX. SUMMARIES
Time Biding
of Time
Unit
Min. Min.
' 5 5
t
i
j 2 10
!
*
| 10 20
25 ^5
5 50
5 55
15 70
5 75
12-3
-------
HF CONTENT OUTLINE /«\
Course: w* Lesson 12
U-JM Lecture Title * OVERVIEW OF THE FEDERAL EPA % PRQ^S
. trmjim tj ntnMTiwr program
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I. INTRODUCTION
State the lesson goal.
Lesson Plan
State that Principles of the GAA were presented
i
in Lesson ?.
The principal thrust of this lecture will be
How Federal enforcement works and how it interfaces
with State enforcement.
II. INTERFACE WITH STATE AND LOCAL ENFORCEMENT
SM p. 10-2
A. States and local governments have primary i
responsibility for prevention and control of j
air pollution at its source. |
Modification of "primary" try the CAA Amendments.
B. Fhforcement of SIP's arej
* unilaterally State;
* Federal EPA together with State;
* unilaterally Federal.
III. PROVISIONS OF THE CAA WHICH DIRECT FEDERAL ENFORCEMENT
SM p. 10-2
Section 113, Feferal Enforcement.
Section 114, Inspections, Montioring, and Entry.
Part C - Prevention of Significant Deterioration of
Air Quality.
Part D - Plan Requirements for Nonattainment Areas.
The main thrust of this lecture will be Section 113
procedures.
Parts C and D were covered in Lesson 7.
12-4
-------
Page 2 of 3
CONTENT OUTLINE (OON'D)
LESSON 12
IV. GLEAN AIR ACT ENFORCEMENT
A. Federal Enforcement Prior to the 1977 CAA Amendments.
B. Congressional Concerns with the 1970 Law.
C. Changes in Enforcement due to the 1977 Amendments.
* EPA enforcement discretion restricted.
* Existing consent decrees voided.
* Limitation on administrative orders.
Section 113 orders prior to 1977*
Delayed Compliance Orders
Special Section 113 orders
Shut downs
Innovative technology
Conversion to coal
V. PROCESSING SECTION 113 ACTIONS
Section 113 actions are triggered try:
Compliance status reports made by the States.
EPA field inspection reports.
Letter notice is sent.
Informal conference usually follows
After conference, order is sent.
Review process before EPA gets into court.
VI. PENALTIES
Criminal
Civil
Administrative
SM p. 10-3
Sec. 113 (d) (12)
Sec. 113 (a)
Sec. 113 (d)
Sec. 113 (d) (*0
Sec. 113 (d) (5)
SM p. 10-4
Cite case
histories
for
emphasis.
If available,
recite from an
actual order
issued.
SM p. 10-4
Cite a case
history.
SM p. 10-4
12-5
-------
-fage j uf 3
CONTENT OUTLINE (OONT'D)
LESSON 12
VII. AUDIT BY EPA OF STATE SOURCE INSPECTIONS
EPA makes a ten percent audit
Instructor, please comment on the procedure used try
your Region interfacing with the State source
inspection program, or
Present the EPA policy on audit inspections if it
differs from that stated in the Manual.
SH p. 10-6
VIII. EST JONS STUDENTS REi EPA, STATE AND LOCAL
ENFORCEMENT MATTERS.
If no questions are forthcoming, Speaker to give case
histories.
IX. SUMMARIES
12-6
-------
LESSON PLAN
TOPIC:
LEGAL TEST AND REVIEW
TEST II
time 30 min.
COURSE:
LESSON
PREPARED BY:
Pamela Giblin
DATE:
1/19/79
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LESSON
GOAL.
To test students on how well they absorbed legal
lessons, 8 through 12.
LESSON
OBJECTIVES.
At the end of this lesson, the student should be able to:
1. Judge his knowledge of legal aspects of the FED's job
by scoring his answer sheet as the instructor gives
the right answers and discusses the points of the test.
SPECIAL Test questions.
MATERIALS, Correct Answers.
EQJIPMENT Grading Key.
LISTS.
SPECIAL Allow 25 minutes for the test. Collect the papers and
INSTRUCTIONS, immediately review the correct answers.
Instruct students to put answers on test sheet, as well
as the Answer Sheet so that they will retain their
answers and can grade their own viork.
12-7
-------
AIR POLLUTION FIELD ENFORCEMENT
COURSE #444
TEST NO. 2
25 questions - Time 25 minutes.
Circle the correct response for either True/False or Multiple Choice
questions. There is only one correct answer for each question. For
each wrong answer, four points will be deducted from 100 to give
the test grade.
Put your answers on the answer dieet, also your name, and turn it
in when completed.
Papers will be collected 25 minutes after beginning of test.
1. Which of the following is to be considered in determining
the legality of a regulation for the control of emissions?
a. the emission inventory
b. opacity standards
(c?) legislative authority to adopt
d. the Hearsay Rule
2. Which of the following is common to both administrative and
court proceedings?
© evidence presented must be relevant
b. a jury may be used to decide the facts
c. relaxing of strict rules of evidence
d. circumstantial evidence is preferable to direct
evidence
3. Which of the following relates directly to the
admissibility of evidence in a court trial or administrative hearing?
a. Hearsay rule
b. Relevancy
c. Best evidence rule
£dj) All of the above
12-8
-------
h. Which of the following is not good advice for a witness about
to testify in court?
a. think "before responding to a question
b. speak slowly and distinctly on the witness stand
c. Refuse to be ashamed or startled into giving an
answer you did not intend to give
© memorize your testimony so you will forget none
of the details
5- Which of the following is good advice for a witness about to
testify in court?
a. Read directly from your notes - you will be more
accurate
b. expand upon the facts to give interpretations of the
attorneys' questions
(Tj) Never hesitate to frankly admit that you do not
remember a certain physical fact
d. If you are testifying as an expert witness, do not
hesitate to give long and detailed accounts of your
accomplishments so as to impress the judge or jury.
6. Expert witnesses may rely on hearsay in forming opinions
within the area of their expertise. fly
7. Before a nonexpert witness can testify in a courtroom
proceeding, he must testify as to his education, background,
and training. T
8. The formal rules of evidence consider a photograph better
evidence of a given situation than the eye witness testimony
of an observer. T
9. If a witness gives testimony in a non-jury courtroom
proceeding which violates a rule of evidence, the judge
will refuse to consider the specific testimony in
deciding the case. CtI
10. Under the Federal Glean Air Act of 1967, as amended in 1970
and 1977. the Federal Government has primary responsibility for
the enforcement of emissions standards for existing
stationary sources. T
11. It is considered unethical for an air pollution control
officer to consult with his attorney before testifying
in a courtroom or administrative proceeding. T
12-9
-------
12. When an agency successfully obtains a court order that includes
a strict compliance schedule, everyone in the agency can relax
because now the violation, with certainty, will be abated. T
13. As a prosecuting (plaintiff) witness to an opacity violation
court case, your testimony is
a. immune from cross-examination
© given as direct testimony of the violation
c. valid because you are a field enforcement officer
d. valid only if you present a photograph of the emission
l*k The authority to control air pollution in a state or local agency
must be provided by the:
a. Governor
© State legislature
c. EPA
d. President
15. Under Prevention of Significant Deterioration (PSD), Federal review
of new construction permits for major sources is not required
a. in attainment areas touching a non-attainment area
b. in non-attainment areas
(cT) where sources have an emission potential of less than
100 tons per year in non-attainment areas
d. where the emission potential is 300 tons per year.
16. When prosecuting a violation of an emission standard, it is
also necessary to prove injury to public health, T
17. Founding air pollution control legislation on need to
protect public health is constitutionally valid. (T)
18. In a criminal action, the violation is proven by presenting
a preponderance of the evidence. T
19. A deposition serves as
(a?) a fishing expedition to try to determine what the
witness knows
b. a report by the FBD to his superior
c. a violation of large particulates falling on a
residence
d. a summation of the case try the defense attorney
12-10
-------
20. Good case preparation should discover the evidence either
side will present in court.
21. The 1977 Clean Air Act Amendments require enforcement
action to "be taken where there is a proven SIP violation.
22. A so-called Section 113 action begins with EPA
presenting to the violating source, a compliance order.
23* The filing of a suit in court immediately follows when
the EPA Washington legal staff approves the action.
Two constitutional amendments, the Fourth and the Fourteenth
provide the guarantees stated in questions 2h and 25. Circle
the amendment which applies to each guarantee.
2k. Guarantees due process of law and equal protection.
25* Guarantees freedom from unreasonable search and seizure.
12-11
-------
1.
2.
3-
4.
5.
6.
?.
8.
9.
10.
11.
a b
0 b
b
b
b
True
True
True
True
12. True
13-
($)
AIR POLLUTION FIELD ENIORCEMENT
COURSE #W±
TEST NO. 2
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-------
LESSON 13
COMPLAINT HANDLING
ODOR COMPLAINT CASE STUDY
-------
LESSON PLAN
i»
TOPIC'- LESSON 13
COMPLAINT HANDLING
ODOR COMPLAINT CASE STUDY
course: 444
lesson time- 75 min.
PREPARED BY:
C. W, Gruber
date:
1/20/79
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LESSON
GOAL.
To teach the principles of processing nuisance complaints
with emphasis on the field investigation process.
LESSON
OBJECTIVES.
At the end of this lesson, the student should he able tos
1. Differentiate between good and poor complaint
investigative procedures.
2. Document the procedure for investigation and case
development.
3. Design an odor surveillance plan for a suspected source.
4. Differentiate between a public and private nuisance.
5. Define the various steps in getting action from the
source management to abate the cause of the complaint.
STUDENT
PREREGJJISITE
SKILLS.
Attendance at previous lessons.
LEVEL OF
INSTRUCTION.
No formal lecture on Complaint Handling is given. A case
study from the files of an Air Pollution Control Agency is
used as a vdiicle for self study and class discussion to
develop the principles of good practice in complaint
investigation.
INTENDED
STUDENT
PROFESSIONAL
BACKGROUNDS.
No special background is required some experience in
handling complaints prior to entering the course is
helpful.
13-1
-------
LESSON PLAN (CONT'D)
LESSON 13
SUPPORT 35 mm Slide Projector and Screen
MATERIALS, 35 mm Slides
EQUIPMENT Blackboard
LISTS.
SPECIAL An odor complaint case study, developed from the files of
INSTRUCTIONS} a State Air Pollution Control Agency, is assigned to the
students for study at the conclusion of the previous day.
The Case Study is in the Student Workbook, identified as
Lesson 4, Odor Complaint Case Study.
The study contains a narrative of the actions of a rather
inexperienced FED, following his assignment to respond to
a citizen complaint of odor.
At the conclusion of the narrative, each student is requested to:
1. Critique the investigative actions of the FEO.
2. Develop his own approach to establishing a bona fide
air pollution case.
By reading the case history and reviewing the material on
Complaint Handling in the Student Manual, each student diould
prepare himself to enter into the class discussion, lead "by
the instructor during the first lecture period of Day 3 of
the Course.
The instructor uses the "Answer Key" to lead the discussion
and call for responses from the students.
At the conclusion of the discussion, the instructor sums up
Complaint Handling try using four slides showing:
1. Sources of Complaint
2. Receiving a complaint, information logged
3. Information sought on interviewing complainant
4. Four guidelines for the FED
The instructor should prepare himself thoroughly "by reviewing
the Student Manual, Chapter 13, on Complaint Handling as well
as Chapter 14, Odor Detection and Evaluation. It would be
most helpful if the instructor has actual Air Pollution Control
Agency experience in handling complaints.
SELECTED Student Manual Chapters 13 and 14.
REFERENCES. Also "Answer Key"
13-2
-------
CONTENT OUTLINE
Course: W
Lecture Title:
TIME SCHEDULE
LESSON 13
COMPLAINT HANDLING
\
A
Page L_ nf 1
NOTES
ODOR COMPLAINT CASE STUDY
Time
Of
;Unit
-------
i r
Course.
Lecture Title:
LESSON 13
COMPLAINT HANDLING
ODOR COMPLAINT CASE STUDY
CONTENT OUTLINE
35K,
\ PRU^C
O
z
Page__2 of 1.
NOTES
INTRODUCTION
State goals and method.
Note: When case is given out at the end of previous
day, give general instructions to students on format
of this period.
II. CASE SETTING
Brief summary of the case.
SWB
Lesson 13.
III. STUDENT INTERROGATION AND DISCUSSION
IV. gjESTIONS AND 0PM DISCUSSION OF STUDENT'S PROBLEMS
Call for any questions students have on Complaint
Handling.
Encourage students to give complaint case histories
of their own which illustrate proper complaint
handling procedures.
Answer Key
Jbllowing this
page.
VI.
SUMMARY
Use slides.
CLOSING
Announce availability of Answer Key, and actual case
disposition for pick up by those so desiring a copy.
Slides
| 1 through 4.
I
13-4
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LESSON 13
ANSWER KEY
ODOROUS GASEOUS EMISSIONS COMPLAINT HANDLING
Q. Assuming that Harry neither did nor saw anything more than that stated in
the case history, prepare a critique of his investigative technique. Indi-
cate ail errors and deficiencies in his technique.
CRITIQUE OF THE INVESTIGATION
As stated earlier, the field enforcement officer had little, if any, practi-
cal experience in the investigation of air pollution complaints. One of his
principal mistakes was his assumption that, because he could not detect any
inalodors, a problem did not exist. The following procedures would have been
good technique:
1. Harry should have noted the direction from the complainant's home to
the plant, any significant topographical features (or lack of them), and.
the prevailing wind direction.
2. The inspector failed to ask Mrs. Rust to characterize the odor and to
indicate when it was most prevalent, lie also neglected to ask whether or
not she had noticed the wind direction during the episode and failed to
record the names and addresses of the other complainants indicated by Mrs.
lUist. Several of these people should have been contacted and questioned
concerning the characteristics and prevalence of the odor episodes and
the wind direction during the episodes.
3. Upon arrival at the plant, Harry should have attempted to get down-
wind of the plant to determine whether or not there was an odor emanating
from the plant's operations.
4. He properly identified himself and was correct in accepting an inter-
view with the plant engineer when tlie plant manager was not available.
5. The interview with the plant engineer was carried out poorly. It
should have been specifically directed toward obtaining information about
the process operations as they affected the air pollution potential: the
operating and maintenance procedures, the operation of the air pollution
control equipment, and the review of records related to the preceding.
Some specific items which should-have been obtained are:
a. Types and quantities of paints used, including types and percent-
ages of solvents used in the paints.
13-5
-------
b. Oven temperatures.
c. Temperatures and volumes of the various effluent streams.
d. Operation and maintenance schedules, including times of day when
paint baking occurs and any unusual operating conditions such as
formulations that require higher baking temperatures or contain unusu-
ally-high percentages of solvents or particularly odorous solvents.
e. Control system data including information on temperatures of
inlet and outlet gases, volumetric throughput, and catalyst mainte-
nance schedules.
6. During the interview, the plant's operating permit should have been
reviewed and inquiries made to determine that the plant's equipment and
operation was actually the same as that covered in the permit.
7. After the interview, the plant inspection should have been utilized
to verify wherever possible the information given in the interview. The
inspection should have covered the following:
a. Inspection of the specific equipment used for each phase of the
production operation.
b. Inspection hooding, ducts, fans, drive belts, temperature record-
ers, and general level of maintenance.
c. Inspection of air pollution control equipment. Review of any
charts, recordings or maintenance schedules utilized in conjunction
with the control equipment.
d. An attempt should have been made to get onto the roof in the vi-
cinity of the stacks to ascertain whether any odor could be detected
in the exhaust gases.
8. After the plant inspection, Harry should have made a greater effort
to determine if the metal-plating plant mentioned by Mr. Erb could actu-
ally have been the malodor source. Merely driving by the plant is hardly
a proper investigative technique.. An investigation similar to that done
at the Alcoat Company should have been performed at the metal-coating com-
pany .
9. Prior to completing his report and recommendations, Harry should have
discussed the case with a more experienced investigator. It is likely
that the shortcomings of his investigation would have been pointed out to
hiin and a proper investigation rescheduled.
13-6
-------
Assuming that the investigation indicated that the Aicoat Company was indeed
the source of the odors, explain how you would go about. establishing a bona
fide air pollution case. Remember that thprc arc no specific odor control
regulations and that tlie burden of proof in establishing air pollution as
defined in the agency's ordinance rests with the agency. An odor problem of
this type is effectively a public nuisance and the manner of establishing the
existence of the problem would be similar to that used to establish the exist-
ence of a public nuisance.
COLLECTING DATA FOR ESTABLISHING THE CASE
Once Harry's superiors had determined that the complaints were increasing
rapidly in number and that they were coming from various locations throughout
Orangeland, they immediately consulted with him and advised him of the proce-
dures to be followed:
1. Obtain a complete description of the area surrounding the Aicoat
plant including the plant location, the location of the residents, dis-
tances and direction from plant to complainants, significant topographi-
cal features, and location and nature of any other sources in the immedi-
ate area which could be causing a problem.
2. Contact all of the complainants and determine, if possible, the char-
acter of the malodors: when they are most prevalent, their duration and
wind direction at time of occurrence, and any other pertinent data.
3. Request the citizens' assistance by establishing a citizens' odor
panel. (l;ive or six of the residents are to be asked to keep a log of
malodor episodes and record, to the best of their ability, the character
of the odor, the strength of the odor, the times of occurrence (noting
the duration), and the wind direction during the episode.)
4. Revisit the Orangeland area daily, at the hour of peak production,
if time is available, or on selected days with unfavorable meteorology,
until the existence of the malodors is conclusively established. Determine
if Alcoa is the source by proper odor survey procedures.
5. Revisit the Aicoat plant for the purpose of conducting a proper in-
spection and request the plant to routinely submit operating schedules to
the agency.
6. Obtain wind speed and direction data from a nearby airport weather
stat ion.
7. Ask the agency technical staff to review the plant data to evaluate
the odor potential of the various solvents used by the Aicoat Company,
and request%the engineering staff to investigate and evaluate the perform-
ance of the catalytic combustion units utilized by the company.
13-7
-------
ANALYSIS OF DATA AND ESTABLISHMENT OF CASE
As during the initial investigation, at the follow-up investigations Alcoat
repeatedly claimed that it had no odorous emission problems and that it was
conforming to all applicable air pollution control regulations. They again
implied that if there was a problem in the area it was caused either by some
other company or by malfunctioning of local sewage disposal systems.
In rebuttal to the company's position, the agency determined that:
1. The Alcoat Company is located less than one-half mile due west of
Orangeland. Any winds blowing from the northwest through the southwest
quadrant would blow across the plant and impinge upon some area of
Orangeland. Meteorological data accumulated over the past three years
indicates that during sixty-one (61) percent of the time, the wind blows
towards the development from the northwest through the southwest quadrant.
There are no significant topographical features that interfere with this
wind flow.
2. All complainants were contacted. They characterized the odor as a
solvent-type odor or as an eye and nose irritant. One complainant char-
acterized the odor as that of rotten cabbage. It was subsequently deter-
mined that this individual's neighbor had a seeping septic tank system
which was causing a localized odor problem.
In all, thirty families were contacted. Twenty-five of the families indi-
cated that the solvent odors were severe enough to require corrective
action. Fifteen of the complainants indicated that they would be willing
to testify in court.
3. Eight of the complainants were selected to monitor and log odor epi-
sodes in their area. These logs indicated that the odors are character-
istic of solvent odors, are very strong when detected, and are usually
present when the wind is blowing from the Alcoat plant toward their homes.
The location of the metal-plating plant is such that it would not have
been the source of the odors during the monitored episodes.
4. Harry and another inspector were assigned to visit the Orangeland
area at random times. Over a period of two weeks during which time they
conducted seventeen investigations, they confirmed the existence of sol-
vent odors and other irritation gases in the Orangeland area twelve times.
In nine out of the twelve verified episodes, the inspectors were able to
report tli^t the odors became stronger as they approached the Alcoat plant
and that they were not present upwind of the plant. The dates and times
of the observations were carefully recorded.
13-8
-------
5. A more thorough investigation was conducted at the Alcoat plant. It
was determined that the plant operates twenty-four hours a day and con-
sumes approximately one-hundred gallons of paint per hour per production
line. The paint composition normally is about 40% solvents (by volume).
These solvents include, but arc not limited to, amy1 alcohol, methyl
alcohol, methyl ethyl ketone, xylol and naptha. Phenolic resins arc
widely used in the paint formulations. The ovens operate at approximate-
ly 45001; and the volume of effluent is approximately 10,000 scfm per oven.
A trained observer, who visited the plant site, indicated that the odors
present were characteristic of solvent odors and partially oxidized and
polymerized organic solvents and resins. A review of the catalytic com-
bustion units showed that there was little, if any, temperature differen-
tial across the catalyst. Residual odors were noted near the exhaust of
the quenching operation.
6. A literature search on the solvents used revealed that the presence
of me thy 1 alcohol, amyl alcohol and methyl ethyl ketone in the air may
cause irritation of the membranes of the eye and respiratory organs.
The phenolic resins are normally stable at temperatures below 400°F.
When heated above 400°F in compounds, the resins will release formalde-
hyde .
DISPOSITION OF CASK
Upon completion of the investigation, Alcoat was advised of the agency's
findings and ordered to take corrective action. The company appealed the
order and the case was heard before a hearing examiner. After listening to
the testimony of ten complainants, and after hearing the comprehensive case
that the agency had prepared (based on the previous information), the hearing
examiner found for the agency. In his adjudication, he ordered the company
to comply with the agency's directive.
The company claimed that they were not causing air pollution: that there
were other sources of odor in the area, and that, in any event the ordinance
was unconstitutional as it failed to set forth adequate standards for the
determination of the existence of air pollution. In addition, they felt
that the definition of air pollution was vague and uncertain and not suscep-
13-9
-------
tible to acceptable standards of proof._ They were not satisfied with the
hearing examiner's adjudication and appealed to the county court.
The county court carefully reviewed the record of the case and the testimony
presented before the hearing examiner. The court found that "There is no
doubt that the evidence confirming the existence of an air pollution problem
is substantial. The testimony amply supports the hearing examiner's find-
ings." As a result of its determinations, the court dismissed the appeal and
ordered that the adjudication of the hearing examiner be sustained.
The agency won this odor case primarily by producing a preponderant weight of
evidence to verify the existence of an air pollution problem. Its careful
and thorough investigation was the keystone upon which th& entire case was
based. Since most odor problems are very subjective in nature, it is impor-
tant that the investigator accumulate a preponderence of evidence to tip the
scales in his direction. It is equally important thet the receptors or the
complainants be willing to support the agency's efforts and that they be used
to the best advantage.
13-10
-------
I t'/S M /%
Fwld E nlunwMrfit Hffitet Should
• EXCLAIM THt LAW
• DETERMINE It COMPLAINANT
WILL TESTIFY
• HAVE PERSON KEEP LOO
• NOT rROMlSt COUNT ACTION
-------
LESSON m
ODOR DETECTION AND EVALUATION
-------
LESSON PLAN
TOPIC:
LESSON 14
ODOR DETECTION AND EVALUATION
COURSE: 444
LESSON TIME: 60 min.
PREPARED BY: DATE: . .
G. W. Gruber 1/19/79
ST*.
£
-------
Page 2 of 2
LESSON PLAN (CONT'D)
LESSON 14
INTENDED
STUDENT
PROFESSIONAL
BACKGROUNDS.
No special "background is required; some experience in
handling complaints prior to entering the course is
helpful.
SUPPORT
MATERIALS
EQUIPMENT
LISTS
35 nun Slide Projector and Screen
35 Slides
Blackboard
SPECIAL
INSTRUCTIONS.
The lecturer should have some experience in handling
odor complaints.
*
The lecturer can well be the same person who gives
Complaint Handling.
SELECTED 1. Phelps, A. H.f in Air Pollution, Stern,Ed. 3 Vol. Ill,
REFERENCES. Chapter 8, Academic Press, NY, 19?6.
2. Development Odor Control Regulations, JAPCA, Jan. 1978.
3. Leonardis et al, Odor Threshold of 53 Odorant Chemicals,
JAPCA, 19 No. 2, Feb. 1969.
4. Leonardis - A Critical Review of Odor Control Regulations
JAPCA, 24, p. 456 - 468, 1974. '
14-2
-------
CONTENT OUTLINE
—
Page Jk nf 1
TIME SCHEDULE
LESSON Ik *+ ^
Lecture Title: odor detection and evaluation
Course: 444
\
\
UJ
O
x
NOTES
I. INTRODUCTION
II. GHARAGTERISTIGS OF ODOR PERCEPTION
Time
Of
1 Unit
I Min.
Eh ding
Min.
III. ODOR PARAMETERS
IV. ODOR IDENTIFICATION
V. ODOR MEASUREMENT
5
7
10
9
16
26
VI. INSTRUMENTATION
; 14
40
VII. FINDING THE ODOR SOURCE
VIII. INVESTIGATION AND ENFORCEMENT
IX. SUMMARY
I10
h
i
! 5
50
55
60
14-3
-------
HE3 CONTENT OUTLINE /X\
Course: 444 LESSON 14
Lecture Title: odor detection and evaluation pr0^
Page 1 nf ?
NOTES
I. INTRODUCTION
Odor causes strong (nearly violent on occasion)
public complaint.
I
Odor recognition citizen is instant. (Does not
need instruments to tell it is "bad. )
II. CHARACTERISTICS OF ODOR PERCEPTION
A. FED is concerned about odor so he can,
* Identify them as a cause of public
nuisance.
Slide 14-1
Sums up
SM p.12-2 &
12-3
* Identify the odorant.
* Trace the source.
* Collect evidence.
* Determine if a regulation has been
violated.
* Assess the effectiveness of control.
14-4
-------
Page 2 of 7
CONTENT OUTLINE (CONT'D)
LESSON 14
In estimating whether an odor problem exists, the following
are helpful:
* The olfactory sense becomes fatigued after continuous
perception of an odor.
* An odor is usually detected whenever there has been a
significant change in odor quality or intensity.
* Odors do not, in themselves, cause physical disease.
* A person's ability to perceive odors varies from
day to day.
* Compounds of different constitution may yield similar
odors, whereas compounds of veiy similar constitution
may yield different odors.
* An unfamiliar odor is more likely to cause complaints
than a familiar one.
* The perception level of odors decreases with increasing
humidity. However, high humidity often coincides with
poor ventilation which retards dispersion and increases
odor perception. Examples increase of odor complaints
at night.
*
*
Odor quality may change upon dilution.
Some persons can detect certain odor qualities "but
not others.
B. Definitions
Odor is "a sensation of smell perceived as a result of
olfactory stimulus."
Odorant is "the substance which causes an odor."
14-5
Slide:
SM p. 12-3
Slide 5 14-2
SM p. 12-3
-------
Page 3 of 7
lk-6
CONTENT OUTLINE (CONT'D)
LESSON 14
III. ODOR PARAMETERS
* Quality
* Intensity
* Acceptability
* Pervasiveness
A. Quality
Henning's Odor Classification
Spicy - as in cloves, cinnamon.
Flowery - as in jasmine.
Fruity - as in apples, vinegar.
Resinous - as in turpentine.
Foul - as in hydrogen sulfide,
or products of decay.
Burnt - as in scorched substances.
B. Intensity
Giving a numerical or verbal indication of strength a&
Rating Description
0 No detectable odor.
1 Odor barely detectable.
2 Odor distinct and definite.
3 Odor strong enough to cause
attempts at avoidance.
4 Odor overpowering, intolerable
for any appreciable time.
C. Acceptability
An odor may be acceptable or unacceptable depending
on its intensity and quality.
Odor Acceptability
Hedonic basis
D. Pervasiveness
The tendency to resist being dissipated by dilution.
A highly pervasive odor hangs around for a long time.
Slide:14-3
P- 12-4
Slide: 14-4
P- 12-5
Slide-: 14-5
SM p. 12-5
Slide: 14-6
Graphic
SM p. 12-6
Slide 14-7
-------
j Page 4 of 7
CONTENT OUTLINE (CONT'D)
LESSON 14
IV. ODOR IDENTIFICATION
For FED best is "smells like".
Table l4a-l Interpretation of Complaints
Complaint
Identification
*
Rotten eggs
h2s
*
Rotten cabbage
Mercaptan
*
Natural gas
Mercaptan
*
Dead fish
Di methylamine
*
Outhouse
Amines
*
Rotten odor
Rendering
«
Scorched popcorn
Grain drying by
direct flame
*
Coffee
Coffee Roasting
*
Bleach
Chlorine
*
Ammonia
Ammonia
*
Phenol
Phenol
Slide 14-8
SM p. 12-7
V .
ODOR MEASUREMENT
Most important to FED.
A. Thresholds cannot be anticipated from chemical
structure.
"Aside from sulfides, it is not possible to anticipate
the odor threshold of a material because of its
chemical structure."
Table 14a-2 0do rant Threshold Concentrations
Odor
Chemical
Threshold
Description
Acetone
100.0
Chemical
Aerolien
0.21
Burnt, Pungent
Trimethylamine
0.00021
Fishy
Ammonia
46.8
Bam-like
Benzene
4.68
Solvent
Hydrogen Sulfide
0.0004?
Rotten egg
Dimethylamine
0.5
Fishy
So all roads point to the human nose as the
"measuring instrument", aided by some form
of dilution mechanism.
14-7
Ref. 4
Slide 14-9
SH p 12-8
-------
Page 5 of 7
00NT BUT OUTLINE (CONT'D)
LESSON 14
B. Units of Intensity Measurement *
Dilution Factor
Odor Unit
1. Dilution Factor
The ratio of the diluted volume to the original sample.
2. Odor Unit - better for engineering.
"Odor Unit" is a defined term.
The amount of odor necessary to contaminate one cubic
foot of odor free air to the threshold, or barely-
perceptible, level. Note: A sample containing less
than one odor unit per cubic foot has no perceptible
odor for the average observer.
3. Method of determination -
Withdraw an odorous sample, dilute with odor free
air till the mix is at threshold, determine by a
single trained observer or a panel.
Odor strength is calculated ty«
Sample Volume * Odor free Volume
Sample Volume
Slide 14-10
SM p. 12-9
Slide 14-11
SM p. 12t9
Slide 14-12
SM p. 12-9
Odor Strength in
odor units per cu.
ft. by definition.
odor-
ous
5 ml
Sample
Example of Odor Unit
Odor
free
Mix
+
+
95 ml
Dilution Air
100
5
100 ml
Mix at threshold
or 20
5 £ ~ 95 lil =
Odor strength by definition is 20 odor units/cu. ft.
Slide 14-13
(Not in Text)
Shows a 1 cu. ft.
sample being diluted
One cubic foot
sample is not
practical
Slide 14-14
SM p. 12-9
* Note to Instructor Be careful not to consume too much time
with specifics of measurement. Try to get the concept of how
odor concentration, "by using "dilution factor" or "odor unit" is
done. It will be easier if the concept of a single "trained
observer" is used. To explain the panel method will consume too
much time. If any student wishes to pursue the panel method,
refer him/her to Reference 5.1 p. 93^ and Reference 19, both of
which are vezy good. Remember, there is a test question con-
cerning a sample containing less than one odor unit per cubic ft.
See Qiestion 10, Test 3«
14-8
-------
Page 6 of 7
&antitatlve 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 cu. ft.) and a volume flow of 10,000 acfm
has an
Emission Rate of
20 odor units ^ 10000 cu/ft.
cu/ft. min.
200,000 odor units
mill.
Note: By using the Emission Rate, an Odor Emission
Inventory can be constructed.
VI. INSTRUMENTATION
Examples of several more common methods.
A. Sampling for Later Evaluation (Sniffing).
1. Syringe or evacuated flask (small volume),
generally source only.
2. Teflon bags for use with power dilution train,
to hood or mask. (Large volume for source or
ambient.)
B. In-situ
1, Power dilution train - from source direct to power
dilution train and then to a face pieoe them to.
observer.
2. Scentometer - from ambient to observer through
Scentometer.
14-9
Slide 14-15
SM p. 12-10
Reference 1
Slide 14-16
SM p. 12-10
Slide 14-17
SM p. 12-14
Slide 14-18
Slides 14-19 &
14-20
Slides 14-20 &
14-21
-------
Page 7 of 7
OONTMT OUTLINE (CONT'D)
LESSON 14
VII. FINDING THE SOURCE OF ODOR
A. Characteristics of Transport from Source to Receptor
* Odor flows down wind 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 and low wind speeds.
* In favorable meteorology, odors travel long
distances.
* Odors axe dissipated by dilution, therefore may
change from source to receptor.
* Odors per se leave no residual effects.
B. Tracing the Odor Source (Insitu wind vector
measurement)
Release a helium filled balloon from the center of the
odor plume and track its flight. For night-time
observations, use bright yellow balloons and a six
cell flashlight.
1. Inflate balloon with helium, about 6 inches dia.
2. Release balloon.
3. Trace path by sighting with a hand held compass.
4. Record wind direction.
C. Locating source by triangulatlon.
Make multiple observations "by balloon release and
triangulate on a map.
The point where the wind vectors cross locates the
odor source. '
VIII. CONTROL PROCEDURE
(Generally this must be cut as there is insufficient time.)
IX. SUMMARY
Instructor prepares his own summary.
SM p. 12-13
Slides 14-22
through 14-24
SM p. .12-15
Slides 14-25
through 14-26
SM p. 12-15
Slides 14-27
through 14-32
14-10
-------
H SUt OUWft
vvy »^ ^
* HNUMON i»» IMI11
HNCIIVIO U A HIIUl 1
Of (K » AT TOHV tf IMI l| IMI
ouAnfv Acc«ftu«»irfv
MIMMIV l»IHVAJ»IWI NIKi
¦.ikoi»k». moicATxm o» r
OOOH •AM IT OCTfCTAKll
~MM M8TMCT ft Of F«MT« |
Ockx Acceptability
THf IINMMt) t<>
HI *1*1 Mim*i IMttl'AM I)
¦* Ull I'll.#.
riiLUTtON mvr——
RATIO OF OILUTfDVOlUMl TO
THE original SAMPLE
TMI AMOUNT OF ODOR NECESSARY
TOCONTAMINATI ONF I OBI' FOOT
OF ODOR FRfcF AIR TO TH» TMRfcSR
MOID Of PtRr fp I ion
,,<¦*,* . ao(>»v .
ixrt ¦>
>0 ODOR UNITS 10,000 CU'FT
<
CU.FT MIN
/fK) 000 ODOR UNITS
,>v J
• TRACIPATH
• «tC<>RD*lNOblNt(TION
• iNFiATI BALI(K)N
IIH" H
l|i )! !i
PKOCtSS CHANG!
»B8TmiT10N OF RAW MATERIALS
TENPFRATIRF AOIUSTHFIVT
PRESS!!RK ADJISTMENT
VOLUMR REDUCTION
¦AINTKKANCE
¦SUSEREEPINC
T'». V
t
•)
DILUTION AND DIM'KHSION
TAU. STACKS
INCREASING EMISSION VELOCITY
PUNT RELOCATION
• it point *mnt mi *ino
VIC TOHSCRO&& i OC ATI 8
1HF OOfiH SOUNt f
OX III AIIU*
1. CUUBKT10*
Nun calaljllr
fftialyiir
2 NON AIR OXIDATION
Ol(M
CWimIu# ImuH oiHUnis
Nrm«ncftRati
14-11
-------
LIQUID SCRUBBING
AB80RPTION
CONDENSATION
PARTICULATE REMOVAL
-------
LESSON 15
COMPLAINT INSPECTION OF AN
ASPHALT CONCRETE BATCHING PLANT
FILM AND WORKBOOK
-------
LESSON PLAN
TOPIC:
LESSON 15
COMPLAINT INSPECTION OF AN
ASPHALT PLANT
FILM AND WDRKBOOK
COURSE:
LESSON time: 90 min.
PREPARED BY: DATE
G. W. Gruber 1/19/79
£
55
srv
PROl^
\
Uj
0
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Page 2 of 2
LESSON PLAN (CONT'D)
LESSON 15
STUDENT
PREREQUISITE
SKILLS.
Attendance at previous lessons of this course.
LEVEL OF
INSTRUCTION.
This lesson with the film will demonstrate the principles
covered in Lessons 14, 4 and 5*
INTENDED
STUDENT
PROFESSIONAL
BACKGROUND.
Same as Lesson 1.
SUPPORT
MATERIALS,
EQJIPMENT
LISTS.
16 mm sound movie projector and screen.
Field Inspections: Asphalt Concrete
Batching Plants
SPECIAL Instructors must preview this film "before showing it
INSTRUCTIONS. in the classroom.
See Lesson Content Outline.
15-2
-------
HE! CONTENT OUTLINE /S\
„ , , , TIME SCHEDULE % ^\l/^ ®
Course: W*
ULjiU Lecture Title: qomplaint inspection op an ^ pro^
Page 1 of .J
NOTES
LESSON 15
ASPHALT PLANT
FILM AND TOKKBOOK
Time
Of
Unit Elding
Min. Min.
I. INTRODUCTION
2 2
II. LESSON CONTENT
3 . 5
III. INSTRUCTIONS TO STUDENTS
10 15
IV. IMMEDIATE PREPARATION 50R FILM
5 20
V. SHOWING THE FILM
40 60
VI. POST FILM DISCUSSION
30 90
2±2
-------
Course:
Lecture Title:
LESSON 15
COMPLAINT INSPECTION OF AN
CONTENT OUTLINE /£
$
I
w
PRO
Page.
of.
i
NOTES
ASPHALT PLANT
FILM AND WORKBOOK
I. INTROIUCTION
State the Lesson Goal.
II. LESSON CONTENT
Centers on a film showing two FED's responding to a
complaint of dust deposited on the car of a nearby-
resident.
A format similar to Lesson 6 - Inspection of A Cement
Plant will be followed.
1. Student views film as two inspectors respond to
a complaint received over their car radio.
2. As the conduct of the complaint response is viewed on
the film, each student makes notes on his own Data
Gathering Form found in the Student Workbook.
3. After completion of 2, students discuss their own
observation notes and compare their work with the
observations of experienced inspectors furnished to
the instructors.
After comparing notes, a general discussion of
complaint response and inspection practice follows.
III. INSTRUCTION TO STUDENTS
A. Have students lay out forms on the table in the
following orders
1. Data Gathering Fbrm
2. Asphalt Plant Inspection Sequence
Leave in Workbook:
3. Permit Forms
4. Parametric Evaluation Form
5. Summary of.Source Operation
6. Summary of Pitot Traverse Data
7. Summary of Particulate Sampling Data
8. Production Record for October, 197?.
B. Review with students!
1. Asphalt Plant Schematic
2. Sequence of Inspection
Do not go beyond this point as when the film is stoppel,
the students should look over the permits in a manner
similar to the inspectors' review in the plant
superintendent's office.
15-4
-------
Page 2 of 3
CONTENT OUTLINE (OONT'D)
LESSON 15
IV. IMMEDIATE PREPARATION SDR FILM
Have stiadents ready the Data Gathering Forms and remind
them to make entries as the FEO's on the film make their
inspection.
One stop has "been provided - just after the inspectors
ask to see the permit file and the production records.
At this point, turn on lights - go over permit documents
and production records, making appropriate notes.
The instructor must use his judgment in determining the
length of this stop interval by observing when the
students appear to "be finished and the discussion of the
permit documents and production record is completed.
The above is the only stop called for on the screen.
There is no harm in stopping the film at other points if
this seems warranted.
V. POST FILM DISCUSSION
After the students have had a chance to record their final
observations, the session should be wrapped up with a
discussion of the films and observations the students made.
Data gathering forms, complete with observations as might
be made by an experienced inspector, are provided at the
end of this manual to assist the instructor in leading
this discussion (See Answer Key). At the discretion of
the instructor, these forms may be referred to only by the
instructor, they may be used to create overhead transpar-
encies for group viewing, or copies may be made and
distributed to the group as hand outs. During this post-
film discussion, interest should be centered on maximizing
the simulation experience of the film inspections. The
instructor should be careful to relate what is seen in
the films to the problems and practices generally applicable
to the FED's field activity.
See Answer Key that follows.
Following the Answer Key is some suggested discussion pointis
the instructor may use.
Following the questions is a completed "Inspection Data
Form for Asphalt Concrete Plants" which the students do
not have. This form may be used in any manner desired
by the instructor.
15-5
-------
page 3 of 3
GENERAL DISCUSSION
Complaint Handling Procedure
Q. Should FED's have proceeded to the complainant residence
"before entering the plant?
A. Many procedures of complaint handling would call for this.
By so doing, the FED's would have more knowledge of the
complainant conditions and would be in a "better position
to find the cause.
Q. What is possibility of fugitive dust being source of
complaint vs. stack plume?
Points: Note wet grounds and wet stock piles.
Was plume caused try water vapor?
Recent heavy rains.
Inspectors Personal ualities
Q. Were they professional?
Q. Did they relate conditions at the plant to the text of
regulations?
Q. Was their parting dialogue with the plant satisfactory?
General parting question
Q. How would you have handled this complaint?
15-6
-------
LESSON 15
ANSWER KEY
DATA GATHERING FORM
Asphalt Plant*
MTERING PLANT PREMISES
"Heavy emissions visible probably due to startup.
Considerable water vapor in plume."
(Q. What was your reaction? Discuss details of the plume appearance. Note
wet grounds and wet aggregate.)
INTERVIEWING PLANT MANAGER
"Plant Manager cooperative. Indicated heavy production in recent days."
REVIEWING DATA PROVIDED
"Permit file complete and up to date. Production record indicates production
at near capacity last several days. No unusual maintenance problems indicated."
FILM STOPS HERE
Go througi permit file and production record with class.
Q. How long would it have taken to do this in the superintendent's office.
Is it really productive?
THE PLANT YARD
"No fugitive dust problem evident."
Note - water all over the grounds. Recent rains?
~Refer to the chart at the end of this form.
15-7
-------
GENERAL PLANT SURVEY
"Some intermittent, light stack omission."
THE GOLD FEED CONVEYOR/BUCKET ELEVATOR TRANSFER POINT
"No fugitive dust problem evident."
Again, note wet surfaces.
THE ROTARY DRYER
"Some puff-back around delivery end collar."
THE HOT ELEVATOR
"Some dust leaks from poorly sealed ductwork joints."
THE MIXING TOWER
"Some dust leaks from poorly sealed seams and joints."
1£8
-------
THE UNDERSIDE OF THE BAGHOUSE
"One dust leak from screw conveyor."
THE BAGHOUSE EXTERIOR
"No leaks or emissions apparent. Well maintained except for one "broken
"bag cleaning air line."
Q. How good was dialogue between superintendent and FED's on departure?
THE INTERVIEW WITH THE COMPLAINANT
"Heavy dust fall-out evident on mairbox and automobile."
Q. Was this interview adequate?
ifc2
-------
LESSON 16
EMISSION GONTRDL HARDWARE
INSPECTION TECHNIQUE
-------
LESSON PLAN
TOPIC: LESSON 16
EMISSION CONTROL HARDWARE
INSPECTION TECHNICS
COURSE: 444
"IME
BY:
G. W. Gruber
lesson time 135 min. E. 1/19/79
PREPARED BY: Wte 1/x7/ Cf
LESSON
GOAL.
To familiarize the student with inspection of 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 inspection
points of control devices.
LESSON
OBJECTIVES.
At the end of this lesson, the student should be able tos
1. Name the six elements of the Source System.
2. Recognize various types of control hardware by the
outward appearance.
3. Identify the inspection points of the Source System
components.
h. Define one operating parameter which indicates the
effectiveness of separation for each type of control
equ ipment.
5. Recognize instrument indicators and physical signs
which indicate when control equipment is not
functioning effectively.
STUDENT Aix
PRERECJJISITE Attendance at previous sessions of this course•
SKILLS.
LEVEL OF This lesson provides an entering level description of the
INSTRUCTION. Source System including various types of control hardware,
their functional parameters, with emphasis on guides to
inspection methods to reveal deterioration in performance
from the newly installed equipment.
16-1
-------
Page 2 of 2
LESSON PLAN (CONT'D)
LESSON 16
intended
STUDENT
PROFESSIONAL
BACKGROUNDS.
An understanding of high school math would be helpful. An
engineering degree would be also helpful but not required.
Instructors must avoid use of Involved mathematical models
and language which cannot be understood try a high school
graduate or a student with an "arts" degree.
SPECIAL 35 mm Slide Projector and Screen
MATERIALS, 35 mm Slides
EQJIPMENT Blackboard
LISTS.
SPECIAL Instructor should have some familiarity with application and
INSTRUCTIONS, operation and maintenance of a wide range of control hardware.
An engineer from a control agency or a staff air pollution
control engineer from a complex industry should be a well
qualified speaker who could furnish a wealth of case histories
to illustrate his lecture. Students like and leam from
case histories.
SELECTED Text.
REFERENCES.
16-2
-------
1 M POM-l/TIC
|r*AIMIM(* IMST
3 CONTENT OUTLINE
Pjj Course: /ji/J/. TIME SCHEHJLE
¦¦ Lectwe Title: control hardware
i ££ %
USSJ
\ - ¦ 3
Vf ,v
^ PRCrtfc
Page 1 nf 1
NOTES
1
LESSON
16
Time Siding
of Min.
Unit
Min.
I.
INTRODUCTION
5
5 l
i
II.
ELEMENTS OF THE SYSTEM
5
i
10 !
f
III.
NOTES ON SYSTEM COMPONENTS
10
20 i
1
IV.
CLASSIFICATION OF AIR POLLUTION CONTROL DEVICES
5
r
25 ;
V.
GRAVITY SETTLING CHAMBERS AND DRY INERTIAL SEPARATORS s
5
30 |
e
1
VI.
CYCLONES
15
1
k5 |
VII.
FABRIC FILTERS
15
60
VIII.
ELECTROSTATIC PRECIPITATORS
15
75
I
IX.
WET COLLECTORS
15
90
X.
COMBUSTION
!
15
105
XI.
ABSORPTION |
10
115
1
XII
ADSORPTION
5
120
XIII.
CONDENSATION
5
125
I
! ix.
SUMMARY
10
135
16-3
-------
HP CONTENT OUTLINE ,'a\
ffTl CWs*: 444 LESS0N 16
LR—M* Lecture Title: CONTROL HARDWARE KR0^°
Pngp 1 nf 15
NOTES
I. INTRODUCTION
This lesson tells you what to look for during an
inspection to determine if the performance of the system
is "up to permit" conditions and what the signs of
deterioration (old age) are.
SM p. 13-1
The entire system is important, not just the control
hardware.
II. ELEMENTS OF THE SOURCE SYSTEM
SM p. 13-2
* System Entrance (point of contaminant generation)
* Transport (duct work)
* Air Mover (fan)
* Instrumentation (controls and monitors)
Slide 16-1
Fig. 13-1
SM p. 13-5
* Sub-systems (contaminant removal and feed
materials)
Slide 16-2
Fig. 13-2
SM p. 13-3
* Air Pollution Control Device
III. NOTES ON SYSTEM COMPONENTS
SM p. 13-4
A. System Bitrance
The system begins at the hoods or process vessel.
1. In open entrance systems (hoods)
Volume flow and temperature of gas is usually
steady (a "beneficial condition).
Look for spillage out of hoods or process
vessels indicating insufficient volume flow.
2. Closed entrance system (most often combustion de\
ices)
Volume flow and temperature fluctuate widely,
seriously affecting certain collectors.
B. Transport (Duct System)
Look fori (a) leaks in the duct work caused try
warping and cracking due to excessive temperature,
deterioration by corrosion, or just poor workmanship,
(b) possible blockage at elbows and dampers where
large particles may be separated due to too low
conveying velocity, (c) damper arms not working,
(d) buckling - cracking - no provision for expansion.
16-4
-------
Page 2 of 15
CONTENT OUTLINE (CONT'D)
LESSON 16
Air Mover (usually a fan)
A proper fan is as important to the system functioning
as the right collector. Too often, the fan as a source
of trouble is neglected.
Fan may "be positioned upstream or downstream of
control device.
Important parameters are fan speed and fan horsepower.
For a given fan wheel.
Fan Speed (rpm) - volume varies directly as the
rpm varies.
Fan horsepower varies with the cube of the volume,
therefore, as cube of rpm. Motor amperes indicate -
fan horsepower.
Look for
1. RPM and/or motor amperes and compare with permit
data. Too high, fan is overloaded; Too low, fan
probably not moving enough air.
Measuring fan rpm is difficult and impossible in
many cases. Measuring motor amperes usually can
be done. Some fan installations may have ampere
meters.
2. Signs of fan Imbalance - indicates loose blades or
dirt on blades.
3. Other signs of deterioration
* Excessive temperature coloring the metal
* Cracked casing
* Cracked duct connections
* Water leaking from fan housing in a wet system
D. Instrumentation
Varies with control devices.
Will be discussed with control device.
SM p. 13-4
SM p. 13-5
-------
Page 3 of 15
CONTENT OUTLINE (CONT'D)
LESSON 16
E. Sub-systems
1. Principally these would be
* Diy particulate removal disposal
* Diy Feed materials systems
* Sludge from wet systems
* Contaminated liquids from absorbers and
scrubbers for removal of gases
* Regeneration of adsorbing solids in adsorber.
* Catalyst regeneration
* Gas conditioning device, such as an
evaporative cooler, cold air bleed-in, or
heat exchanger
2. Inspection points
The most important inspections points are
(a) Systems for dry feed material and transfer of
collected dust from hopper to disposition
point.
* Transfer points without enclosures or
hoods and hoods not collecting
* Leaks through bucket elevator conveyor
housing
* Open conveyors
* Fugitive dust off storage piles
* Mechanical transfer by front end loaders
and backet cranes
* Roadway and driveway dust
* Inadequate control on pneumatic conveyors
* Failure of control devices on the conveyor
system
* Gravity transfer from hopper to open truck
SM p. 13-6
We went through
many of these
inspection points
in both cement
and asphalt plant
films.
16-6
-------
Page 4 of 15
CONTENT OUTLINE (CONT'D)
LESSON 16
(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) Disposal of collected contaminant.
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 non-contaminant
as in combustion or absorption
(d) Gas Conditioner
Look for: (a) evaporative coolers, vfaere
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.
SM p. 13-6
SM p. 13-6
16-7
-------
I
, Page 5 of 15
CONTENT OUTLINE (CONT'D)
LESSON 16
IV. CLASSIFICATION OF AIR POLLUTION CONTROL DEVICES
All control devices function to: (a) separate the con-
taminants from the gas stream within the collector and then
removes it without re-intrainment, either continuously or
intermittently, "by hopper batch, 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 service:
i.e., for particulates only; particulates and/or gases and
vapors; for gases only, and for vapors only.
A. Particulates (also known as dry collectors)
1. Gravity Settling Chambers
2. Inertial Separators
3. Centrifugal Separators (cyclones-multicyclones)
4. Fabric Filters (bag filter, baghouse)
5. Electrostatic Precipitator
B. Particulates and Gases and Vapors
1. Wet Collectors (scrubbers)
Absorption towers or packed towers not included
here - they cannot be used on particulates.
2. Combustion (afterturners, fume incinerators)
C. Gases
1# Absorption Towers
2. Adsorption
D. Vapors
1. Condensing
SM p. 13-7
V. GRAVITY SETTLING CHAMBERS AND INERTIAL SEPARATORS
Gravity settling chambers are unimportant as a control
device. Gravity separation is important in duct design
as plugging of duct work will take place with inadequate
conveying velocities.
Inertial separators, because of low separation efficiency on
all but large particles (max. 80% on 15 micron size) are seldom
used. An occasional installation of long standing may be
seen. Because of time constraints, no further discussion
will be given.
16-8
SM p. 13-7
Spend veiy
little time
here.
-------
CONTENT OUTLINE (CONT'D)
LESSON 16
VI. CENTRIIUGAL SEPARATOR (Qyclones-Multicyclones)
For solid or liquid particles.
Separating mechanism. Centrifugal force causes particles
to leave the gas vortex, and "be thrown to the cyclone
wall where it drops into the hopper.
A. Physical Appearance
1. Single
* High thruput - fat body, short in length,
low efficiency.
* High efficiency - small diameter body rather
narrow inlet duct and long body. Higher
efficiency than above unit.
2. Multiple-Qy clone
* Many cyclones in a rectangular casing.
Parameters Related to Efficiency
Pressure drop (Ap) across collector.
Very poor efficiency on sub-micron particles.
C. Inspection Points
>
1
1. Check pressure drop across collector (Ap). Too low, |
collection efficiency is reduced; too high excessive
re-intrainment. Ap varies greatly with volume flow.
Leakage through hopper bottom unloading valve, very
important. Back flow destroys the vortex.
2.
3.
Holes due to corrosion or wear.
2 above.
Result, same as
Hopper does not unload, when valve is opened.
5.
6.
7.
* When hopper fills, all collected particulates are
discharged out the stack.
Plugging inlet duct. Indicated by reduced volume
flow in duct system.
Condensation due to high humidity aggravates
4 and 5 above.
Interior parts deteriorated due to corrosion and
wear. Indication is failure to collect giant
particles. Look for fallout near outlet or
citizen complaint.
* Single cyclone - the outlet duct extension
corrodes away causing gas short circuiting.
* Multi-qyclone - individual tubes plug or
wear causing functional failure of the tube.
8. Visibility of outlet gases.
Page 6 of 15
SM p. 13-8
Slide 16-3
Fig. 13-3
SM p. 13-9
Slide 16-4
Fig. 13-4
SM p. 13-9
Slide 16-5
Fig. 13-5
SM p. 13-9
SM p. 13-8
16-9
-------
Page 7 of 15
OONTMT OUTLINE (CONT'D)
LESSON 16
D. Inspection Aids
* Pressure gage inlet and outlet ot gage.
* Instrumental indicator for full hopper. One type
available under trade name "Bindicator".
* "Poke-tubes" strategically located above hopper
discharge. These are generally two inch diameter
tubes, with removable cap, welded to the hopper.
* Inspection doors. Usually not used in single
cyclones because of disturbing cyclone contours,
tut very important in multi-cyclone units to
inspect interior cones and headers.
* Testing ports before and after cyclone. Usually
required in new installations.
* Opacity meter on outlet duct.
VII. FABRIC FILTER (also known as bag filter or baghouse) !
j
For diy particles only. j
;
A. Physical Appearance j
Most often a rectangular sheetmetal box, set on a hopper^
often insulated, ranging in size from the small 100 cfm j
units 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.
1. Separating Forces -
Building the cake
Impaction
Impingement
Electrostatic (natural)
Brownian movement (diffusion)
Aftercake
Direct sieving.
The interior arrangement varies widely, affecting desigri
and operation, tut externally they axe as described aboye.
Occasionally, a designer creates a bag filter with a
cylindrical exterior which may look very much like a
cyclone.
SM p. 13-10
Slide 16-6
Figurei3-6
SM p. 13-11
Small fabric filter
Slide 16-7
Fig. 13-7
SM p. 13-12.
Large volume
fabric filter
SM p. 13-10
16-10
-------
CONTENT OUTLINE (CONT'D)
LESSON 16
B. Operating Characteristics
* Air to cloth ratios, influenced greatly "by the cleaning
mechanism and the fineness of the dust.
* The cleaning mechanism.
Mechanical Shaking
Air Shaking (Reverse Air)
Bu"b"ble Cleaning
Pulse Jet
* The type of cloth, dictated try character of dust and
characteristics of gases to "be cleaned, especially
temperature.
* Effect of moisture.
* Temperature, methods of controlling.
Notes The baghouse is perhaps the only particulate collector
whose efficiency is not related to particle size. A "baghouse
does well on su"b-micron particles. In general, this is due
to the filter cake being the cleaning surface and the finer
the dust, the finer the filtration pores. A well designed
baghouse should operate with a clear stack.
Inspection Points
Table 5»13 Troubleshooting Checklist for Fabric Filters
1. Higgi differential pressure.
2. Seepage - visible discharge.
Causes:
Bags improperly Installed.
Loose bag clamps.
Tom bags - holes.
Improper sealing at tube sheet.
3. Insufficient suction on exhaust hood or system.
4. Dampers do not operate or fit ti^itly to the duct.
5. Visibility of outlet gases.
Inspection Aids
* Differential pressure gage, before and after baghouse,
C.
D.
*
*
and for each compartment.
Indicator lights to show cleaning cycles.
Indicating ammeter on fan motor.
Temperature, preferable recording, at inlet and
outlet where temperature is a factor.
Indicators to show damper positions (for larger
installations.
Testing ports.
Page 8 of 15
SM p. 13-10
Slide 16-8
Table 16-1
(Underlined values
only)
Slide 16~9a, b, c
Fig. 16-8
SM p. I3_i4
Slide13-10
Tabic 13-2
SM p. 13-15
(include only the
four cloths
underlined)
SM p. 13-21
16-11
-------
Page 9 of 15
CONTENT OUTLINE (CONT'D)
VIII. ELECTRO STATIC PRECIPITATORS
for dry solid or liquid particles.
A. Physical Appearance
Much like the "baghouse "but the ESP is distinguished
by the rapping mechanism and the transformer-rectifiei
sets usually mounted on top of the housing.
B. Operating Characteristics (Separating Mechanism)
1. Particles are charged "by gas ions created "by high
voltage electrical field.
In power plant ESP charge is usually negative.
2. Charged particles migrate to collecting plate
of positive potential and grounded.
3. Charges leak off collected particles.
k. Particles grow ty agglomeration on plates.
5. Plates sure rapped periodically to cause
agglomerated particles to drop into hopper, or are
•washed in an irrigated ESP.
6. Power supply to wires is
30 to 100 KVA and
20 to 100 MA
7. High voltage causes sparking from wires to plates.
8. Peak performance when voltage is high enough to
cause some sparking.
9. The sparking rate is sometimes used as an
indication of maximum efficiency.
10. Two-stage ESP
Operates much like a home electrostatic
air cleaner, voltage about 10 K.
SM p. 13-17
Slide 16-11
Fig, 13-10
SM p. 13-20
Slide 16-12 a,16-12t
Fig. 13-9
SM p. 13-16
Slide 16-13
Figure 13-11
SM p. 13-19
SM p. 13-17
Slide 16-14
Fig.
SM p.
13-12
13-20
16-12
-------
Page 10 of 15
CONTENT OUTLINE (CONT'D)
LESSON 16
G. Major Inspection Points
SM p. 13-21
* Increased, visibility of stack emission.
* Rectifier output in kilovolts and miliamps.
* Sparking rate in sparks per minute.
100 sparks per minute may tie considered a
reasonable value. Major variations should be
checked against permit data or manufacturer's
recommendation.
* Check maintenance logs.
* Check for process change such as: (a) raw
materials, change in sulfur or ash content of coal;
(b) chemical composition or; (c) rate of flow.
* General physical conditions to indicate quality
of maintenance.
D. Inspection Aids
Primarily the instrumentation to cany out the inspec-
tion points in C above as
* Opacity meter on outlet
* Voltmeter and ammeter on each of the electrical
subdivisions
* Spark rate indicator
* Rapping cycle indicators
* Sampling ports
* Maintenance logs
Fbr wet or dry particles. The almost endless variety of
wet collectors makes it difficult to include all types of
scrubbers in this course. However, several of the more
common types are shown.
Separating mechanism is impaction on liquid particle or
wetted target.
IX. WET COLLECTORS (SCRUBBERS)
SM p. 13-21
16-13
-------
Page 11 of 15
X.
CONTENT OUTLINE (CONT'D)
LESSON 16
A. Physical Appearance
See Figures 16-13 through 16-15,
B. Operating Characteristics
The parameters of great importance ares
(a) The pressure drop across the collector; (b) the L/G
ratio (gallons of scrubbering water/acfm of gas flow)
and; (c; the percent of liquid recirculation; (d) effi-
ciency of mist eliminator.
C. Inspection Points
Inspection points would be related to B above.
* Pressure drop across venturi throat.
* Gas volume in acfm.
* Liquid flow rate in gpm.
* Gas temperature inlet and outlet.
* Recirculation of scrubbing liquid in percent.
* Opacity of stack discharge.
D. Inspection Aids
* Instruments to indicate the above parameters.
* Visibility meter taking necessary precaution that
condensed water vapor does not add to opacity at
the meter location.
COMBUST ION
For gases and vapors.
Separating mechanism. The contaminant is chemically changed
by oxidation to non-pollutant compound.
SM p. 13-29
Slide 16-15
Figure 13-13
SM p.13-23
Slide 16-16
Figure 13-14
SM p. 13-24
Slide I6-I7
Figure 13-15
SM p. 13-25
SM p. 13-22
16-14
-------
Page 12 of 15
OONTENT OUTLINE (CONT'D)
LESSON 16
A. Physical Appearance
There are two types of combustion devices.
1. Direct or thermal units axe fumace-like in
appearance with either gas or oil burning apparatus
plainly visible.
2. Catalytic units have the appearance of a duct heater,
generally made of sheet metal, rather highly
instrumented.
SM p. 13^21
Slide 16-18
Figure 13-16
SM p. 13-26
Slide 16-19
Figure 13-17
SM p. 13-26
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.
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 500°
rise across the catalyst bed.
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.
SM p. 13-22
D. Inspection Aids
* Recording temperature instruments
* Opacity meter where visibility results from
inadequate thermal oxidation.
Note 1 Both units are usually highly instrumented
with controls for safety and fuel economy. These
can be of interest to the specialized FED.
-------
Page 13 of 15
CONTENT OUTLINE (CONT'D)
LESSON 16
ABSORPTION
For gases and vapors (particulates plug)
Separating mechanism is transfer of contaminants from
carrier gas stream "by dissolving them in an absorbing
solution.
A. Physical Appearance
A cylindrical vessel, generally with contaminated gas
stream entering at "bottom, leaving at top (counter-
current flow).
B. Operating Characteristics
Absorbers can "be
* Plate towers
* Spray towers
* Packed towers
C. Packed towers are most common.
Describe the packing.
D. Inspection Points
Inspection is rather difficult.
Major importance is design.
* L/G Ratio
Liquid Flow/Gas Flow.
* Temperature of Absorbent
(in some cases)
* If absorber is for odor control, sniff test near
discharge point.
E. Inspection Aids
Instrumentation for
Liquid flow, Gas flow and Absorbent temperature
(when important.
SM p. 13-27
Slide 16-20
Figure 13-18
SM p. 13-28
Slide 16-21
Figure 13-19
SM p. 13-28
16-16
-------
Page 14 of 15
CONTENT OUTLINE (CONT'D)
LESSON 16
XII. ADSORPTION
For gases only.
Separating Mechanism. Mass transfer of contaminant from
gas stream to surface of solid absorbent.
A. Physical Appearance
Usually a vessel for containing the adsorbing solid
arrangedj (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 axe often installed in parallel with
piping and controls for automatic cyclic operation from
adsorption to desorption modes.
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
efficiency. The only real measure of performance is an
emission test performed t>y a trained stack test team.
Dirty gases also containing particulates (especially
greagy particles) plug adsorber.
XIII. GONDMSING
For vapor recovery.
A. Physical Appearance
Condensers are
* Shell and tube, a cylindrical vessel, or
* Contact, a direct spray where discharge is
into a hot well.
SM p. 13-27
16-1?
Slide 13-22
Figure 13-20
SM p. 13-30
SM p. 13-29
Slide 16-23a
& 16-23b
-------
Page 15 of 15
1
CONTENT OUTLINE (OONT'D)
LESSON 16 I
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
measure of compliance would be a source test.
XIV. SUMMARY
The instructor constructs his own summary.
16-18
-------
TYPICAL
SINGLE
CYCLONE
COLLECTORS
muring C »cl« CUaning Cycl*
H»C 1RONIATK PRIIIP11ATOR
IMRICATIP
TUBUt Alt
¦LA*?
rUMMACI
PWtCim ATOR
VENTUftt scrubber
COMMON
TOWER
PACKING
MATERIALS
PACKED
TOWER
SHELL AND TUBE CONDENSER
16-19
-------
LESSON 17
INSPECTION OF COMBUSTION SOURCES
-------
LESSON PLAN
TOPIC: LESSON 1?
INSPECTION OF OOMHJSTION SOURCES
WORKBOOK AND FILM
COURSE W4-
lesson time^ 90 min.
PREPARED BY:
C. W. Gruber
DATE
1/19/79
sS
d sr4v
£
3
o
V
2E
PRCft^
4
UJ
O
LESSON
GOAL.
To teach the elements necessary for complete combustion as they
relate to an inspection to be carried out by an experienced FED.
LESSON
OBJECTIVES.
At the end of this lesson, the student should be able to:
1. Identify various important components of fuel turning
systems, especially coal or oil.
2. Enumerate the inspection points and observations which
should be made.
3. Explain the elements necessary for complete combustion.
Define air-fuel ratio.
5. Identify the instrumentation which relates to combustion
control.
6. Identify the instruments which relate to monitoring of
the combustion process and emissions therefrom.
otttHTOT
MPDwuTcnru Attendance at previous lessons of this course.
FnEREQJ I5IT£
SKILLS.
LEVEL OF Introductory lecture with visual aids specifically directed
INSTRUCTION, to coal and oil burning boilers in utility and large industrial
plants, to be followed by a film depicting the inspection of
three plantsi a pulverized coal fired utility boiler plant
(also describing a cyclone furnace); an industrial size boiler
fired by a spreader strokerj and a large plant burning residual
or distillate oils. Periodically during the film, the showing
is stopped and the students make entries on forms responding to
appropriate questions. After the film is completed, the student
answers are compared with the instructor's answers and
appropriate discussion is generated.
17-1
-------
iage 2 of 2
LESSON PLAN (CONT'D)
LESSON 1?
INTENDED
STUDENT
PROFESSIONAL
BACKGROUNDS.
An understanding of high school math would be helpful. An
engineering degree would be also helpful hit not required.
Instructors must avoid use of involved mathematical models
and language which cannot be understood by a high school
graduate or a student with an "arts" degree.
SPECIAL 35 nun Slide Projector and Screen
MATERIALS, 16 mm Sound Movie Projector, self threading
EQJIPMENT Blackboard
LISTS. Slides, 35 nun
Film - Inspection of Combustion Sources (running time 14 minutes)
Inspection of Combustion Sources, Trainees Workbook (ICS, T'W)
Inspection of Combustion Sources, Instructor's Manual (ICS, IRM)
SPECIAL The instructor should read the Instructor's Manual and
INSTRUCTIONS, preview the film in advance of the course. He should also
preview the Trainee's Workbook. Care must be taken to use
terminology similar to that found in the film and workbook.
Before starting each unit of the film, be sure students
have turned to the response forms in their workbook.
The student workbook includes an extensive study assignment
with questions. In this course, there is no time for the
reading as the previous evening was taken up with the
nuisance case study. Some of the questions from the text
might be extracted for verbally quizzing students at the
appropriate times.
An experienced instructor may disagree on some ol' the film
details. Use these points as discussion centers. Remember,
all agencies differ somewhat in procedure and selects what
is best for them. Be careful not to discredit the film just
because you disagree with a few details.
SELECTED 1. AP-40, Air Pollution Engineering Manual, US EPA, Office of
REFERENCES. Air Quality Planning and Standards Research Triangle Park
NC, 27711 - 1973* Out of print, tut many libraries have copies.
2. Inspection Manual for Enforcement of New Source Performance
Standards. Fossil-fuel-fired Steam Generators.
SPA 3^0/1-75-002, Feb. 1975-
3. APTD-1101 Field Operations and Enforcement Manual for
Air Pollution Control Volume II Control Technology and
General Source Inspection. US EPA 1972.
17-2
-------
CONTENT OUTLINE
^tosr^
& ^
Page 1_ of L
3JE
!» t
Course: m TIME SffiEWLK ^
Lecture Title: INSPECTION OP COMBUSTION SOURCES^ pro^
NOTES
FILM AND WORKBOOK
LESSON 1?
I. INTRODUCTION
THUS"
Of
Unit
Mln.
Ending
Min.
II. COMBUSTION GENERAL
III. ELEMENTS OF OOMBUSTION
IV. FUELS AND FUEL FIRING
V. FURNACE INTERIOR INSPECTION
VI. MONITORING THE COMBUSTION PROCESS
VII. NOTES ABOUT OPACITY
VIII. INTRODUCE FILM
IX. SHOW THE FILM
X. DISCUSSION OF THE FILM
XI. SUMMARY
! 3
j
i 8
i 5
2
5
5
5
30
20
5
5
13
18
20
25
30
35
65
85
90
17-3
-------
CONTENT OUTLINE ,'£*
Course: w*
Lecture Title:
O
\
LESSON 17
INSPECTION OF COMBUSTION SOURCE^
FILM AND WORKBOOK
W
L PRO"^
Page L_ of.
O
Z
NOTES
I. INTRODUCTION
Combustion sources axe in all jurisdictions.
Q. How many FEQs do not have a Combustion Source under
surveillance?
A.
The Workbook and Film.
This is constructed as a self-contained unit. It is
used here as a demonstration of basic inspection
procedures.
Workbook has four chapters.
Elements Necessary for Good Combustion
Operation of Equipment to be Inspected
Namely, two coal burning and one oil
burning plant, and the applied Air
Pollution Control equipment.
Inspection Points and Observations
Sources Being Inspected
Chapter 1.
Chapter 2.
Chapter 3-
Chapter U,
B.
The Film demonstrates the inspection practice and
uses three Data Collection Forms, one for each source,
on which student enters certain decisions which would
become part of an inspection report.
After each film unit, there is discussion of decisions
made.
Purpose of Combustion Lecture
When given as an independent course, the student would
self-study the Workbook. The lecture in part replaces
the self-study as a preparation for the film section.
It is the basics of combustion.
II. COMBUSTION GENERAL
Since many FEOs should have some knowledge of combustion,
a good format for this unit is question and answer.
Q. What are the combustible elements in all fuels?
A. Carbon, hydrogen and sulfur.
ICS, TW
Chapter 1.
17-4
-------
Page ? of h
CONTENT OUTLINE (CONT'D)
LESSON 17
Q. Are there both harmless and harmful products of the
combustion reaction? Name the products (emissions)
and the associated element.
A. Harmless
Harmful
OO2 from C
H20 from H
SO2 from S
CO from C
COMBUSTION REACTION
2C + 02 — 2C0
C + 02 — CO 2
2H2+ 02 — 2H20
S + 02 --- SO2
HEAT GENERATED
BTU/Kg fuel
14 207
32 228
136 868
8 882
Note that C to 0 to produce CO produces less than
one-half the heat of C to C02. Power plants work
hard to prevent CO for heat efficiency. They do a
pretty good job.
W,. What criteria pollutant emitted from Combustion Sources
is not in the above?
A. N0X
Q. Where does N0X (almost all NO) come from?
A. Reaction at high temperature of nitrogen and oxygen,
both from the combustion air.
Stop question and answer here and go to lecture.
III. ELEMENTS OF COMBUSTION
A. 3 Ts & plus of Combustion
Time, Temperature, Turbulence plus o^tygen
B. Theoretical Air
Theoretical Air -
The amount of air needed to supply the exact amount
of 02 for complete combustion — and no more.
ICS, TW p. 6
(Note: Text
omits time.)
17-5
-------
Page 3 of
CONTENT OUTLINE (CONT'D)
LESSON 17
C. Excess Air
Excess Air -
The air supplied to the furnace in excess of theoretical
air.
Q. What equipment uses an excess of air? Why?
A. (a) Stationary fossil-fuel-fired, combustion devices.
(b) To insure that all G goes to QOp for maximum
heat generation.
IV. FUELS AND FUEL FIRING ICS, TW Chapter 2
Give a general description of equipment to be inspected
in the film.
A. Traveling-grate Spreader Stoker with front ash discharge Figure 2.1
Point out primary air through plenum and secondary air
through over fire air jets for turbulence.
B. Spreader Stoker installation with gravity fly-ash return Figure 2.2
Added Comment.
Shows the stoker in a 2-drum boiler. Comment or.
relative position of IXist Collector, Economizer and
ID Fan, and the significance of volume of flue gases
related to exit gas temperatures.
C. Circular burners for firing pulverized coal. Figure 2.3
Point out primary and secondary air.
l?-6
-------
Page ^ of 't
CONTENT OUTLINE ( GONT' D)
LESSON I?
D. Cyclone Furnace
Figure 2.5
E. Circular register burner for oil burning
Figure 2.8
V. FURNACE INTERIOR INSPECTION
* Furnace grate and thickness of fuel bed for
Spreader Stoker
* Character of the clinker. Should be rather uniform
fused chunks? with an overall dimension about 5 inches
maximum. Large hard clinkers 12 to 2k inches which
must be broken up indicates excessive furnace
temperature.
* Flame characteristics, all three units.
* Furnace walls and ash tuild up on tubes.
* For oil burners flame impingement on opposite
furnace wall.
* Opening fire box doors. Do not open furnace doors
or inspection port covers. Always have boiler operator
or your guide do this.
VI. MONITORING THE COMBUSTION PROCESS*
A. Air-fuel ratio. An automatic control system keeps the
air flow in balance with the fuel being fed into the
furnace.
B. Steam-flow/air-flow recorder.
It is difficult to automatically measure the fuel flow
continuously and instantaneously.
Steam flow can be measured and since fuel flow varies
directly as steajn flow, steam flow is recorded on the
same chart with air flow using different color inks;
usually red for steam flow and green for air flow.
ICS, TW p. 38
ICS, TW p. 40
~See also Ref. Chapter 4.
17-7
-------
CONTENT OUTLINE (CONT'D)
LESSON 17
When the control system is properly set, the two pens
parallel each other, either coinciding or separated
by about one inch. Setting the pens apart makes for
easier chart reading.
Steam-flow/air-flow pens calibrated to coincide and
Steam-flow/air-flow pens modified to show parallel
traces.
Note: Some charts are continuous strip charts.
In the film, the oil fired unit uses such a chart.
C. Excess Air Indication
1. CO2 Indicator or Recorder
OO2 concentration recorded continuously.
Notet Most often 00£ is checked manually with an
Orsat or equivalent instrument.
2. Oxygen Analyzer
The trend is to use % Oxygen in the flue gases to
Indicate excess air.
Oxygen analyzers are continuous recorders or grab
samples with Orsat.
D. Draft Indicators
An instrument panel board usually has a series of draft
indicators for points along the air and combustion
gas system.
1 age 5 of f-
Figure 3.3
Figure 3.4
ICS, TW p. 44
Figure 3.5
Figure 3.6
Several points along the way are important.
* Pressure drop across a multi-cyclone collector
will indicate its collection performance.
* Pressure over the fire indicates if furnace doors
can be opened. Some units run at above atmosphere
and gases will blow out inspection doors if opened.
17-8
-------
Page 6 of 6
CONTENT OUTLINE (CONT'D)
LESSON 1?
E. Opacity Recorders
Opacity Chart, 24 hr. (P 4l)
Opacity Chart, Continuous Horizontal
Strip Chart
F. On New Major Sources (Utility)
Continuous automatic monitoring systems for opacity,
SO2 and N0X axe being used.
G. Oil Bumera
Check oil preheat and atomization pressure gage for
each nozzle.
A sample of fuel oil may be taken for sulfur analysis.
VII. SIGNIFICANCE OF COMBUSTION MONITORS
A. Too much air indicated by high Og and low GO 2'
Efficiency is lost with too much excess air.
Manual gives values to compare.
Note: In some installations higher than usual
excess air may be needed to overcome opacity violation.
B. Sudden Steam Load Swings
Sudden large scale load swings make controlling
air-fuel ratio difficult. Greatest influences are
sudden load increase to boiler overload or drastic
reduction. Sustained low load (less than 60% of rating)
on Spreader produces smoke.
ICS, TW p. 39
Figure 3-1
Figure 3.2
ICM, TW p. 37
Summary of
1CM, TW
Chapter 3
C. Blowing flues
All coal and oil-fired boilers must be equipped with
soot blowers to remove deposited ash and carbon from
the boiler tubes. Soot blowing generally results in
opacity greater than allowed for short periods of time.
Usually three minutes In one hour aire exempted from
the opacity regulation to permit soot blowing.
17-9
-------
CONTENT OUTLINE (CONT'D)
LESSON 1?
D. Opacity
Plume opacity is a good Indication of the combustion
conditions.
Plume Characteristics and Operating Permits
i-age 7 r>f
ICM, TW p. 37
Table 3.1
VIII. INTRODUCE FILM
Film is in three parts, each part demonstrating a
different combustion system. The lecture covered many
points, but there are others demonstrated.
Part I Utility Boiler with Pulverized Fuel
and ESP. Cyclone furnace is
demonstrated.
Part II Spreader Stoker with Multi-Cyclone
Collector on industrial Power Plant.
Part III Oil Fired Utility Boiler with no Collector.
A. Demonstrates step by step Inspection Points.
Flume observation before entry
Fuel preparation
Furnace interior
Control panel instrumentation
Fans and duct work
Ash disposal system
Air Pollution Control devices
B. Explain reporting forms
Figure 1.* Examples cf the three to be used
while viewing the film.
C.
* Instructor's Manual p.4
After each part, the film will be stopped and student
answers will be compared with "text book" answers.
Discuss significance of answers.
D. Call for Qiestions.
ICM, TW
Chapter 4
17-10
-------
Page 8 of 8
CONTENT OUTLINE (CONT'D)
LESSON 17
IX. SHOW THE FILM
Be prepared to stop film where called for.
the film.
Twice during
Pulverized Coal
Spreader Stoker
Ore Burner
Reporting Form
Reporting Form
Reporting Form
X.
DISCUSS FILM
ICM, TW p. 55
ICM, TW p. 64
ICM, TW p. 73
A. Review each inspection report.
B. Call for questions. The instructor should have a series
of questions built around his own particular expertise.
The following are some examples of the type of questions
which will generate discussion.
1. How did you react to the personal appearance
of the FEO?
A. Observation - He was very neatly dressed, suit and
tie, and had his own hard hat.
2. What did you note about his vehicle?
A. He was driving a standard passenger car. Would an
"official" car have been an improvement?
3. What was your reaction to the interior firebox
inspection?
A. Observation - Try to get experienced FEO's to
express opinion. This is very difficult to do.
4. Should a plant be denied a Certificate of Operation
because it has CO2 too low or CO2 too high?
A. Definitely not. These are informative.
XX, SUMMARY
The instructor prepares his own summary.
17-11
ICM, IRM
Data Sheets
p. A-9
p. A-10
p. A-ll
-------
DATA COLLECTION FORM: PULVERIZED COAL BURNER
1. RECORD PERCENT OF OPACITY HERE: 30% *
CHECK ONE
RATE CONDITION OF:
SATISFACTORY
UNSATISFACTORY
2. STEAM FLOW
X
3. OPACITY CHART
X
4. COz CONCENTRATION
X
5. FLAME CONDITION
X
6. FURNACE WALLS
X
7. FANS AND DUCT WORK
X
8. ASH DISPOSAL
X
9. CONVEYOR SYSTEM
X
10. WINDBLOWN EMISSIONS
X
* Because the standard error of measurement is 15%,
correct answers may range from 15% to 45%.
17-12
-------
DATA COLLECTION FORM: SPREADER STOKER
1. RECORD PERCENT OF OPACITY HERE: 60% *
CHECK ONE
RATE CONDITION OF:
SATISFACTORY
UNSATISFACTORY
2. FLAME AND
X
FUEL BED
X
3. GRATES
X
4. FURNACE WALLS
X
5. FUEL DELIVERY AND
X
COAL SIZE
X
6. OPACITY CHART
X
7. STEAM-FLOW/AIR-FLOW
X
8. CYCLONE EXTERIOR
X
9. BOTTOM ASH
X
RATE CONDITIONS AFTER VIEWING FILM
10. CO* =10.5%
X
11. OXYGEN = 6.7%
X
12. PRESSURE DROP = 2 IN.
X
~Because the standard error of measurement is 15%,
correct answers may range from 45% to 75%.
17-13
-------
DATA COLLECTION FORM: OIL BURNING EQUIPMENT
1. RECORD PERCENT OF OPACITY HERE: 0% *
CHECK ONE
RATE CONDITION OF
SATISFACTORY
UNSATISFACTORY
2. OPACITY CHART
X
3. STEAM-FLOW/AIR-FLOW
X
4. FIREBOX INTERIOR
X
5. FORCED DRAFT FANS
X
AND DUCT WORK
X
RATE CONDITIONS AFTER VIEWING FILM
6. BOILER #1: 02=11%
X
7. BOILER #2: Oz = 7%
X
* Because the standard error of measurement is 15%,
correct answers may range from 0% to 15%.
17-14
-------
LESSON 18
EMERGENCY AND ALERT PROCEDURES
-------
LESSON PLAN
TOPIC:
LESSON 18
EMERGENCY AND ALERT PROCEDURES
COURSE: W+
LESSON TIME: 3O mill.
PREPARED BY:
DATE:
C. W. Gru"ber
1/19/79
LESSON
GOAL.
LESSON
OBJECTIVES.
STUDENT
PREREQUISITE
SKILLS.
LEVEL OF
INSTRUCTION.
INTENDED
STUDENT
PROFESSIONAL
BACKGROUND.
To describe the conditions 'which create emergency
situations and the FED response to such emergencies.
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 FED 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 FED during emergency episodes.
Same as previous lesson.
Introductory level to review in general the kinds of
emergencies in which the FED becomes involved.
Same as previous lesson.
18-1
-------
Page 2 of 2
LESSON PLAN (CONT'D)
LESSON 18
SUPPORT None.
MATERIALS,
EQUIPMENT
LISTS.
SPECIAL More stress should be placed on local emergencies than
INSTRUCTIONS, the general air pollution episode. However, it will be
recognized that JO minutes instruction for this subject
will permit only the broadest of treatment.
REFERENCES. Student Manual, Chapter lS
18-2
-------
CONTENT OUTLINE /£*
LESSON 18 v p'*
V r<^
Lecture Title: EMERGENCY AND ALERT PROCEDURES
Course: 444
\
%
Pngfi 1 of 4
NOTES
AIR POLLUTION EPISODES
I. INTRODUCTION SM p. 15-2
Emergencies axe
* Local Episodes
* Air Pollution Emergency Episodes, General.
II. LOCAL EMERGENCIES SM p. 15-2
Caused ~by process upset or failure such as
* Explosion or fire
* Safety valve lifting
* Sudden failure of control device with "by-pass
* Mechanical breakdown
* Radiation accidents
* Transportation accidents
III. GENERAL AIR POLLUTION EMERGENCY EPISODES SM p. 15-3
Triggered by
* Very unfavorable meteorology
* Build-up of pollutants toward "significant harm"
levels of contaminants in air.
All SIP must have plan which contains
* Episode criteria
* Surveillance system
* Emission Reduction Plan
* Communication System
* Legal Authority.
18-3
I
-------
CONTENT OUTLINE (CONT'D)
LESSON 18
Page 2 of 4
Significant harm levels are set try EPA (40 CFR 51.16 (a)) as
SM p. 15-3
S0£ - 2,620 ug/m^ (1,0 ppm), 2^-hr. avge.
Particulate - 1000 wg/m3 or 8 C0Hs, 24-hr. avge.
Product (TSP • S02> - cojf-(,,ppm3)> 24"hour *vge'
O3 - 1,200 pg/m3 or 0.6 ppm 1-hr. avge.
CO - 57.5 mg/m3 (50 ppm), 8-hr. avge.
86.3 mg/m3 (75 ppm), 4-hr. avge.
144 mg/m3 (125 ppm), 1-hr. avge.
NO2 - 3,750 yg/m3 (2.0 ppm), 1-hr. avge.
938 yg/m3 (0.5 ppm), Z4-hr. avge.
A. Episode Plan Bequlrements
The episode plan must contain t
* Episode criteria
* Surveillance system
* Emission reduction plan
* Communication system
* Legal authority
SM p. 15-3
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 18-1 shows the Air Pollution Episode Sequence
suggested "by kO CFR 51.16 and Appendix L.
SM p. 15-3
18-4
-------
CONTENT OUTLINE (CONT'D)
LESSON ;18
Page 3 of 4
FORECAST, ALERT, WARNING, EMERGENCY
SM p. 15-4
Forecast
Alert
Warning
Emergency
1
Pollutant
reaches
lit level
Pollutant
increases to
2nd level
Pollutant
increases
to 3rd level
Control
Agency
Condition
continue*
Air
Monitoring
Meteorological
Monitoring
Atmospheric
Stagnation
Advisory
3rd Alert
Dangerous health hazard
Major curtailment of all
activities in community
2nd Alert
Preliminary health hazard
Selective curtailment
of industrial activities
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
Figure 15-1. Emergency epbode, sequence procedure. "...To prevent ambient pollution concen-
trations from reaching levels which could cause tignificant harm to the health of persons..."
18-5
-------
CONTENT OUTLINE ( CONT'D)
LESSON 18
IV. RESPONSE IN EMERGENCIES
Must te out-of-the-ordinary.
Action ty FED at scene.
May call for technical help.
Interface with other emergency services, as
fire, police, civil defense.
Knowledge of sources in his district veiy helpful.
Also contacts with sources.
In General Emergency, FED enforces curtailment plans.
Must know what action he takes when sources fail to
cooperate.
V. SUMMARY
Training and planning are important.
Don't wait till the day arrives.
Especially know -
What he has to do.
What action he takes when people fail to comply.
Page 4 of 4
SM p. 15-3
SM p. 15-5
18-6
-------
LESSON 19
SOURCES OF TECHNICAL INFORMATION
FURTHER TRAINING OPPORTUNITIES
-------
LESSON PLAN
TOPIC: LESSON 19
SOURCES OF TECHNICAL INFORMATION
FURTHER TRAINING OPPORTUNITIES
COURSE; 444
LESSON TIME: 15 mill.
PREPARED BY:
C. W. Gruber
DATE
1/19/79
vS
£
5
V
sssz
^ PRCfi*-0
\
UJ
CD
T
LESSON
GOAL.
To give the students a listi (a) of technical documents
relating to enforcement and (b) of recommended EPA Training
Courses for further study.
LESSON
OBJECTIVES.
At the end of this lesson, the student should "be able toj
1. Select from the technical literature available, those
manuals which will be helpful for continued study.
2. Identify the various EPA training courses which would
be beneficial in advancing enforcement proficiency.
3. To create a desire for further study and training.
INTENDED
STUDENT
PROFESSIONAL
BACKGROUND.
Same as previous lesson.
SUPPORT
MATERIAL
EgjIPMENT
LISTS.
35 mm slide projector and screen
Blackboard
Handout to be placed in blue folder at course beginning.
EPA - NEED AIR POLLUTION INFORMATION?
EPA CHRONOLOGICAL SCHEDULE OF AIR POLLUTION TRAINING COURSES
SPECIFIC This is an interest building presentation.
INSTRUCTIONS.
SELECTED See above.
REFERENCES.
19-1
-------
CONTENT OUTLINE /S*
\mj
\
+?¦
Course. LESSON 19
Lecture Title: SOUBCES OF TECHNICAL INFORMATION^
FURTHER TRAINING OPPORTUNITIES
I. SOURCES OF TECHNICAL INFORMATION
* Displayed on library table during course.
* See list in Student Manual.
* Pick those applicable to your individual needs -
order them - read them.
* See pamphlet - "Need Air Pollution Information?"
Explains Library Service of EPA at Research Triangle
Park — Use it.
II. AIR POLLUTION TRAINING COURSES
* Mention catalog.
* Show "Sequence of Courses" for Field Inspection.
^13, ^15. ^82 are quite technical in control equipment application;
450 is source sampling for particulates and so on. See Figure 19-I
for a recommended sequence of Courses for Field Inspection.
Page .
of.
NOTES
SM p. B-l
SM p. B-2
Instructor should
have catalogue.
Supply of .
catalogues should
be available to
students.
Figure 19-1 Field In'pection Course Sequence
For individuals who are involved in field inspection and enforcement in a governmental agency.
1ir1
452 425
I
482 1
~i r ~i r. 1
4I5j 4_I4_j
427 , 413
II I
444
431
VE
422
Coda - Recommended Courses
= Highly Desirable Courses
VE s Visible 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
•Recommended for those who inspect continuous emission monitors.
A catalog of available training course is published annually ty
the APTI. Information on training programs can be obtained try
writings U.S. Environmental Protection Agenqy
Control Programs Development Division
Air Pollution Training Institute
MD 20 - Research Triangle Park, NC 27711.
19-2
-------
Page 2 of 2
CONTENT OUTLINE (CONT'D)
LESSON 19
Comments
* kjl can be taken following W+.
* ^52 - Is a good basic air quality management course.
* VE is a must.
* ^13 and 415 are quite technical for FED1s -
more for engineers.
* 425 - good for more legal aspects training.
* ^27 - combustion evaluation.
III. OTHER ADVANCED TRAINING
A. Advanced degree programs.
Plug EPA Traineeships as available when course is given.
B. Continuing Education Courses.
Colleges and Universities
C. Attendance at Technical Meetings.
D. Read Technical Journals, Reports, published Books.
IV. ASK FDR qJESTIONS OR COMMENTS.
SM p • B— 2
2a=i
-------
Course: W
Lecture Title:
FINALE
COURSE SUMMATION.
Each Course Moderator prepares his own course summation.
Note; The film, Lesson 17, Inspection of Combustion Sources
is a good basis for a Course Summation. In reviewing the
film, the Course Director should note the actions of the
FED and use these as the skeleton of his closing remarks.
FINAL TEST (TEST NO. 3)
Use same format as Tests 1 and 2.
After all tests are in, review tests, giving correct
answers and answer questions.
COURSE CRITIQUE.
Alternate plans are available.
Plan A. If there is plenty of time left, and students are
not "restless" to leave, hold critique until after Test
Review.
Plan B. If time is short or Course Director elects, as soon
as a student turns in a completed answer sheet for Test 3,
give the student a Critique Form. Hold the Test 3 Review
until all Critiques are in.
COURSE CLOSING.
Bid students farewell.
Hope they will do their job better for having attended this
course.
Engage in light talk.
When last student departs, Course Director indulges in a
huge sigh of relief and starts packing.
!
t
I
END IRM, COURSE Wt
19-4
-------
ANSWER KEY
AIR POLLUTION FIELD ENFORCEMENT
COURSE #444
TEST NO. 3
33 questions - Time 30 minutes.
Circle the correct response for either True/False or Multiple choice
questions. There is only one correct answer for each question. Jbr
each wrong answer, three points will "be deducted from 100 to give the
test grade.
Put your answers on the answer sheet, also your name, and turn it in
then completed.
Papers will be collected JO minutes after "beginning of test.
1. Canvassing of a neighborhood to obtain added complainants
should be done by the FED in response to a complaint from
one individual.
2. Mrs. Bradley Jones lives near the ABC Chemical Company. She
repeatedly calls and complains of odors. No other citizens
complain. Is the agency obligated to bring court action
against the ABC Company to abate a public nuisance?
3. Complaints can be caused ty
a. specific visible emission violation
b. fugitive dust from construction or industrial sources
c. a general bad atmospheric condition causing high
build up of contaminants
^d^ all of the above
4. Which of the following pieces of data is least likely to
be obtained in interviewing a complainant?
a. the frequency of the annoyance causing the complaint
b. the name and location of the suspected source of
the oomplaint
© the specific process within the source facility
causing the nuisance
d. time of the day the nuisance was first noted
T (j)
Yes VNo
19-5
-------
5. During an inspection in response to a complaint, the FED:
a. always identifies the complainant try name when
requested for such identification.
b. inspects only permit units
(c7) inspects first what might have caused the complaint and
then other processes if circumstances warrant
a. determines only who ownes the facility
6. The odor sensitivity of all persons is usually the same. T
7. Which of the following is the least valuable to the FID
in dealing with odor nuisance?
a. identifying the odor source
G> identifying the chemical composition of the odorant
c. rating the odor intensity
d. establishing the frequence of the odor nuisance
occurrence
8. Odors may be characterized by four parameters:
acceptability, pervasiveness, intensity and quality. (jr) F
9. Neighborhood complaint of natural gas in the air could
be caused by an industrial release of mercaptan. (r*) F
10. A sample of exhaust air containing less than one odor
units per cubic foot has no detectible odor. F
11. Which of the following does not characterize the transport
of odorous effluent from source to receptor?
a. odor flows downwind from source to receptor
b. in unfavorable meteorology, odors travel
long distances
c. odors are transported as in a plume
(d?) odors leave a residual so they can be traced
at a later time
12. In a source system, the air pollution control device is
the only important element. T (f)
13. The entrance to the source systems is a boiler, a
reaction vessel or a series of collection hoods. (r) f
14. Dust spilling from a collection hood indicates the
inflow of air has insufficient volume. OV F
19-6
-------
15. Which of the following is not a fan inspection point?
a. rpm
(?T) width of the fan blade
c. motor amperes
d. fan vibration
16. All air contaminants removed "by control equipment can be
disposed of ty landfilling, if properly covered. T
17. Which of the following type of collector is not well suited
to collect particulates?
absorption (packed) towers
b. scrubbers
c. centrifugal separators
d. fabric filters
(18. The mechanism for contaminant removal (operating characteristic)
.. is different in seven types of air pollution control devices.
These operating characteristics are listed and numbered one
23>) through seven as follows!
1. Separation try centrifugal force
2. Direct sieving of particles
3. Separation try electrical forces
4. Impaction on liquid droplets
5- Mass transfer to a solid surface
6. Chemical reaction (oxidation) of the contaminant
7. Changing the contaminant from a vapor to a liquid state
In the space provided, circle the number identifying the operating
characteristic of each of the following collectors!
Examples
electrostatic precipitator
1
2
6)
4
5
6
18.
fabric filter
1
©
3
4
5
6
19.
condenser
1
2
3
4
5
6
20.
cyclone
(D
2
3
4
5
6
21.
venturi scrubber
1
2
3
©
5
6
22.
adsorber
1
2
3
k
O
6
23.
thermal incinerator
(after-burner)
1
2
3
k
5
Q
19-7
-------
(24. Match the Inspection point to the control device. Circle the
correct inspection point.
28 ) Inspection point
1. pressure drop across the collector (A P)
2. electrical power (voltage and current) output
from the rectifier
3. outlet gas temperature 1
The same inspection point may apply to more than one collector.
2k. thermal incinerator 1 2
25. venturl scrubber © 2 3
26. electrostatic precipitator 1 3
27. cyclone separator © a 3
28. 4 catalytic incinerator 1 2
29. A steam flow-air flow meter indicates how the air flow changes
as the flow of fuel to the firing device changes. Q>
30. A high air-fuel ratio produces a high percentage of OO2 in
the combustion gases. X
31. In asphalt concrete batch plants, moisture is removed from
the aggregate in the:
a. hot elevator
(b^ rotary diyer
c. mixing tower
d. pugmill
32. The pressure drop (Ap) across a collector can be determined
by subtracting the reading on the inlet pressure gauge from ~
She reading on the,outlet pressure gauge when the fan is (TJ
own streaEi from the collector.
33- An FED should always "blow his cool" whenever a boiler
operator blows his flues. T
19-8
-------
AIR POLLUTION FIELD ENFORCEMENT
course 0m
TEST NO. 3
Name (ANSWER KEY)
1.
True
(False^)
18.
1
GL^
3 4
5
6
7
2.
Yes
c£)
19-
1
2
3 4
5
6
3.
a b
c (T)
20.
©
2
3 4
5
6
7
4.
a b
d
21.
1
2
3 <4)
5
6
7
5.
a b
© d
22.
1
2
3 4
CP
6
7
6.
True
(E^lse^
23-
1
2
3 ^
5
©
7
7.
a &
c d
24.
1
2
2
3
11.
a b
c (£)
28.
1
2
©
12.
True
(fSse)
29.
(JruJ)
False
13.
False
30.
True
1
14.
CErjjp
False
31.
a
c d
15-
a (£)
c d
32.
J
False
16.
True
(ffals^
33-
True
^alse)
1
17.
© *
c d
TEST EVALUATION - Check one box each line. This test has beenj
Too long ~ About rlgjit Q Too short ~
Too hard ~ About right ~ Too easy | [
19-9
-------
APPENDIX
-------
TESTS AND ANSWER SHEETS
This section contains Tests 1, 2 and 3 and the Answer Sheets
to be handed out to the students at the conclusion of the
various exercises.
Tests and Answer Sheets must "be reproduced in sufficient
quantities to give out one per student. Each set of test
papers and Answer Sheets should be stapled.
One copy of each Answer Key is found In the Instructor's Manual in
the appropriate chronological place.
A-l
-------
AIR POLLUTION FIELD ENFORCEMENT
COURSE #444
TEST NO. 1
33 questions - Time 25 minutes.
Circle the correct response for either True/False or Multiple Choice
questions. There is only one correct answer for each question. For
each wrong answer, three points will be deducted from 100 to give
the test grade.
Put your answers on the answer sheet, also your name, and turn it
in when completed.
Papers will "be collected 25 minutes after beginning of test.
1. Air Quality Control Programs in the U.S. are prescribed by
a. the Federal Clean Air Act alone
b. State legislative action only
c. State legislative action and the Federal Clean Air Act
d. Local regulations alone
2. The scope of a field operation program depends upon
a. the number and types of stationary sources
b. the agency level, i.e., local, state, federal
c. the complexity of rules and regulations
d. all of the above
3. Which of the following is least related to the field enforcement
process?
a. ambient air quality monitoring
b. compliance plan inspection
c. requiring periodic re-inspection of sources
d. district surveillance
4. In proceeding from one inspection to another, it is not necessary
for the FED to exercise surveillance because he is specifically
assigned to source inspection. T F
A-2
-------
5. The term opacity means the degree to 'which transmitted
light is reduced. T F
6. Atmospheric particulates, larger than 20/u, can "be sampled
with sticky paper. T
?. Upon entering a plant for the first time, it is proper
procedure to obtain a search warrant in advance to insure
gaining entry. T
8. Before making an inspection for any purpose, it is
considered unnecessary to
a. consult the source file if available
b. form a plan before entering
c. always phone ahead and make an appointment
d. obtain the name of the facility contact person,
if available
9. Tasks assigned to the FED most always include
a. functioning as a working member of a source test team
b. investigating citizen complaints
c. operating the ambient air quality network
d. personally serving notices of violation
10. Which of the following are considered effective enforcement
actions?
a. filing a civil or criminal suits
b. notice of violation with orders to abate
c. revoking a permit to operate
d. all of the above
11. A source in "continuing" compliance requires minimal
surveillance. T
12. Enforcement actions following an observed violation
are left entirely to the judgment of the FED. T
13. Protection against the adverse effects on public health
and welfare is the only goal of the Federal Glean
Air Act. t
A-3
-------
14. Ambient Air Quality results only from the sum of emissions
from sources plus atmospheric reaction products. T F
15. An enforcement policy guides the FED
a. in the types of equipment subject to the
permit regulations
b. in the percent opacity which constitutes
a violation
c. in the action he takes following an
observed violation
d. all of the above
16. Which of the following contaminants is not emitted directly
from sources?
a. photochemical oxidants (O3)
b. particulates
c. hydrocarbons
d. carbon monoxide
17. The ultimate success or failure of the enforcement program
depends heavily upon
a. the manner of issuing a violation notice
b. how well the FED does his job
c. whether the air pollution control program is
state or local
d. all of the above
18. Which of the following does not apply to the FBD's job conduct?
a. an official vehicle must be used for field work
b. communication is more than people talking to each other
c. effective communications may prevent friction
d. dress and appearance are important
19- The FED does a better job if he develops a potential for
legal enforcement. T F
20. The most important part of a newly hired FED's orienta-
tion program, during his first week on the job, is to
obtain certification as an opacity observer. T F
A-A
-------
21. Prior to making a periodic source inspection, it is good
practice to make an observation of the source exterior,
even though extra time is required. T F
22. Which of the following is not an observable manifestation of
certain non-compliance daring surveillance of a district?
a. emission of excessive carbon monoxide
b. evidence of new construction for which no
permit has been obtained
c. plumes of readable opacity
d. none of the above
23. Assuming you are in a remote part of your territory and you
have no prior contact with a source facility, and you observe
a visible emission violation from what you assume to be power
house chimney, you should
a. go back to headquarters to see if there is a record
on the facility
b. go to the facility entrance and ask to see the
boiler operator
c. go to the facility and request to see the resident
manager
d. hope the guard at the gate does not request identifi-
cation
2^. In making an opacity reading, the FED should look constantly
at the plume to detect changes that may occur during the
observation. T F
25. Before deciding a condition is non-compliance, the FED
must relate the facts to the specifics of a rule or
regulation. T F
26. A notice of violation must be delivered in person to the
highest ranking official present at a plant determined to
be in violation of a control regulation. T F
27. Where breakdown is given as a cause of violation, it is
important to
a. probe the event for signs of the emergency
b. analyze the situation against the regulation
relating to emergencies
c. assess the frequency of breakdowns of a similar
nature from this source
d. all of the above
A-5
-------
28. An inspection report is always "better if it is a
lengthy report. T
29. At the initial plant inspection, you should obtain
a. the name of the secretary to the manager
b. the number of employees in the company
c. the present legal owner of the source
d. none of the above
30. Which of the following is unnecessary in documenting a
visible emission violation?
a. beginning and ending time of the observation
b. location of the source
c. position of the sun with respect to observer
and source
d. the construction permit number and date
31. After learning the rules and regulations, administrative
procedures and policies, the FED is not concerned with
any further training. T F
32. When inspecting a dry type Portland cement plant, it is
important to
a. record key instrument readings and relate them to permit data.
b. form judgements on fugitive dust emissions
c. form judgements on the adequacy of control equipment maintain ence.
d. all of the above
33« In a dry type Portland cement plant, a major problem is
the emission of
a. hydrocarbons
1), nitrogen oxides
c. fugitive dusts
d. all of the above
A-6
-------
1.
2.
3-
k.
5-
6.
?.
8.
10.
11.
12.
13-
14.
15-
16.
17.
True
True
Tiue
True
True
True
True
True
AIR POLLUTION FIELD ENFORCEMENT
COURSE
TEST NO. 1
Name
False
False
False
False
False
False
False
False
18.
19• True
20.
21.
22.
23-
24.
25-
26.
27.
28.
29-
30.
31-
32.
33-
True
True
True
True
True
True
True
False
False
False
False
False
False
False
False
TEST EVALUATION - Check one box each line. This test has beent
Too long ~ About right CU Too short JZJ
Too hard £H . About right ~ Too easy Q
A-7
-------
AIR POLLUTION FIELD ENFORCEMENT
COURSE #444
TEST NO. 2
25 questions - Time 25 minutes.
Circle the correct response for either True/False or Multiple Choice
questions. There is only one correct answer for each question. For
each wrong answer, four points will be deducted from 100 to give
the test grade.
Put your answers on the answer sheet, also your name, and turn it
in when completed.
Papers will he collected 25 minutes after beginning of test.
1. Which of the following is to be considered in determining
the legality of a regulation for the control of emissions?
a. the emission inventory
b. opacity standards
c. legislative authority to adopt
d. the Hearsay Rule
2. Which of the following is common to both administrative and
court proceedings?
a. evidence presented must be relevant
b. a jury may be used to decide the facts
c. relaxing of strict rules of evidence
d. circumstantial evidence is preferable to direct
evidence
3. Which of the following relates directly to the
admissibility of evidence in a court trial or administrative hearing?
a. Hearsay rule
b. Relevancy
c. Best evidence rule
d. All of the above
A-8
-------
4. Which of the following is not good advice for a witness about
to testify in court?
a. think before responding to a question
b. speak slowly and distinctly on the witness stand
c. Refuse to he ashamed or startled into giving an
answer you did not intend to give
d. memorize your testimony so you will forget none
of the details
5. Which of the following is good advice for a witness about to
testify in court?
a. Read directly from your notes - you will be more
accurate
b. expand upon the facts to give interpretations of the
attorneys' questions
c. Never hesitate to frankly admit that you do not
remember a certain physical fact
d. If you are testifying as an expert witness, do not
hesitate to give long and detailed accounts of your
accomplishments so as to impress the judge or juiy.
6, Expert witnesses may rely on hearsay in forming opinions
within the area of their expertise.
7. Before a nonexpert witness can testify in a courtroom
proceeding, he must testify as to his education, background,
and training. T F
8. The formal rules of evidence consider a photograph better
evidence of a given situation than the eye witness testimony
of an observer. T F
9. If a witness gives testimony in a non-jury courtroom
proceeding which violates a rule of evidence, the judge
will refuse to consider the specific testimony in
deciding the case. T F
10. Under the Federal Clean Air Act of 1967, as amended in 1970
and 197?t the Federal Government has primary responsibility for
the enforcement of emissions standards for existing
stationary sources. T F
11. It is considered tan ethical for an air pollution control
officer to consult with his attorney before testifying
in a courtroom or administrative proceeding. T F
A-9
-------
12. When an agency successfully obtains a court order that Includes
a strict compliance schedule, everyone in the agency can relax
because now the violation, with certainty, will be abated. T F
13. As a prosecuting (plaintiff) witness to an opacity violation
court case, your testimony is
a. immune from cross-examination
b. given as direct testimony of the violation
c. valid because you axe a field enforcement officer
d. valid only if you present a photograph of the emission
14. The authority to control air pollution in a state or local agency
. be
provided ty the»
a.
Governor
b.
State legislature
c.
EPA
d.
President
15. Under Prevention of Significant Deterioration (PSD), Federal review
of new construction permits for major sources is not required
a. in attainment areas touching a non-attainment area
b. in non-attainment areas
c. where sources have an emission potential of less than
100 tons per year in non-attainment areas
d. where the emission potential is 300 tons per year.
16. When prosecuting a violation of an emission standard, it is
also necessary to prove injury to jublic health. T F
17. Founding air pollution control legislation on need to
protect public health is constitutionally valid. T F
18. In a criminal action, the violation is proven try presenting
a preponderance of the evidence. T F
19. A deposition serves as
a. a fishing expedition to try to determine what the
witness knows
b. a report try the FED to his superior
c. a violation of large particulates falling on a
residence
d. a summation of the case ty the defense attorney
A-10
-------
20.
Good case preparation should discover the evidence either
side will present in court. T P
21. The 1977 Clean Air Act Amendments require enforcement
action to be taken where there is a proven SIP violation. T F
22. A so-called Section 113 action begins with EPA
presenting to the violating source, a compliance order. T F
23- The filing of a suit in court immediately follows when
the EPA Washington legal staff approves the action. T F
Two constitutional amendments, the Fourth and the Fourteenth
provide the guarantees stated in questions 24 and 25• Circle
the amendment which applies to each guarantee.
24. Guarantees due process of law and equal protection. 4th 14th
25. Guarantees freedom from unreasonable search and seizure. 4th 14th
A-ll
-------
AIR POLLUTION FIELD ENPORCEMENT
COURSE #WJ-
TEST NO. 2
Name
1.
14.
2.
3-
4.
5.
6.
15-
16. True
True
False
1?.
18.
19-
True
True
False
False
False
?.
8.
9.
10.
11.
12.
True
True
True
True
True
True
False
False
False
False
False
False
20.
21.
22.
23.
True
True
True
True
24. 4th
25. 4th
False
False
False
False
14th
14th
13.
TEST EVALUATION - Check one tax each line. This test has beent
Too long ~ About right D Too short tU
Too hard About right Q Too easy ~
A-12
-------
AIR POLLUTION FIELD ENFORCEMENT
COURSE #444
TEST NO. 3
33 questions - Time 30 minutes.
Circle the correct response for either True/False or Multiple choice
questions. There is only one correct answer for each question. For
each wrong answer, three points will be deducted from 100 to give the
test grade.
Put your answers on the answer sheet, also your name, and turn it in
when completed.
Papers will be collected 30 minutes after beginning of test.
1. Canvassing of a neighborhood to obtain added complainants
should be done try the FED in response to a complaint from
one individual. T
2. Mrs. Bradley Jones lives near the ABC Chemical Company. She
repeatedly calls and complains of odors. No other citizens
complain. Is the agency obligated to bring court action
against the ABC Company to abate a public nuisance? Yes
3. Complaints can be caused tjy
a. specific visible emission violation
b. fugitive dust from construction or industrial sources
c. a general bad atmospheric condition causing high
build up of contaminants
d. all of the above
4. Which of the following pieces of data is least likely to
be obtained in interviewing a complainant?
a. the frequency of the annoyance causing the complaint
b. the name and location of the suspected source of
the complaint
c. the specific process within the source facility
causing the nuisance
d. time of the day the nuisance was first noted
A-13
-------
5. During an inspection in response to a complaint, the FED:
a. always identifies the complainant try- name when
requested for such identification.
b. inspects only permit units
c. inspects first what might have caused the complaint and
then other processes if circumstances warrant
a. determines only who ownes the facility
6. The odor sensitivity of all persons is usually the same. T F
7. Which of the following is the least valuable to the FED
in dealing with odor nuisance?
a. identifying the odor source
b. identifying the chemical composition of the odorant
c. rating the odor intensity
d. establishing the frequence of the odor nuisance
occurrence
8. Odors may be characterized ty four parameters:
acceptability, pervasiveness, intensity and quality. T F
9. Neighborhood complaint of natural gas in the air could
be caused "by an industrial release of mercaptan. T F
10. A sample of exhaust air containing less than one odor
units per cubic foot has no detectible odor. T F
11. Which of the following does not characterize the transport
of odorous effluent from source to receptor?
a. odor flows downwind from source to receptor
b. in unfavorable meteorology, odors travel
long distances
c. odors sure transported as in a plume
d. odors leave a residual so they can be traced
at a later time
12. In a source system, the air pollution control device is
the only important element. T F
13- The entrance to the source systems is a boiler, a
reaction vessel or a series of collection hoods. T F
14. Dust spilling from a collection hood indicates the
inflow of air has insufficient volume. T F
A-14
-------
15. Which of the following is not a fan inspection point?
a. rpm
Id. width of the fan blade
c. motor amperes
d. fan vibration
16. All air contaminants removed "try control equipment can "be
disposed of ty landfilling, if properly covered. T P
17. Which of the following type of collector is not well suited
to collect particulates?
a. absorption (packed) towers
b. scrubbers
c. centrifugal separators
d. fabric filters
(l8. The mechanism for contaminant removal (operating characteristic)
.. is different in seven types of air pollution control devices.
^ These operating characteristics are listed and numbered one
23.) through seven as foliowsi
1. Separation tiy centrifugal force
2. Direct sieving of particles
3. Separation tiy electrical forces
4. Impaction on liquid droplets
5* Mass transfer to a solid surface
6. Chemical reaction (oxidation) of the contaminant
7. Changing the contaminant from a vapor to a liquid state
In the space provided, circle the number identifying the operating
characteristic of each of the following collectors!
Examplet electrostatic precipitator
18. fabric filter
19. condenser
20. cyclone
21. venturi scrubber
22. adsorber
23. thermal incinerator
(after-burner)
A-15
2
©
4
5
6
7
2
3
4
5
6
7
2
3
4
5
6
7
2
3
4
5
6
7
2
3
4
5
6
7
2
3
4
5
6
7
2
3
4
5
6
7
-------
(24. Match the inspection point to the control device. Circle the
correct inspection point.
28 ) Inspection point
1. pressure drop across the collector (A P)
2. electrical power (voltage and current) output
from the rectifier
3. outlet gas temperature
The same inspection point may apply to more than one collector.
24.
thermal incinerator
1
2 3
25.
venturi scrubber
1
2 3
26.
electrostatic precipitator
1
2 3
27.
cyclone separator
1
2 3
28.
catalytic incinerator
1
2 3
29. A steam flow-air flow meter indicates how the air flow changes
as the flow of fuel to the firing device changes. T F
30. A high air-fuel ratio produces a high percentage of 00 2 in
the com"bustion gases. T p
31. In asphalt concrete batch plants, moisture is removed from
the aggregate in the:
a. hot elevator
t>. rotary diyer
c. mixing tower
d. pugmill
32. The pressure drop (Ap) across a collector can "be determined
by subtracting the reading on the inlet pressure gauge from
the reading on the outlet pressure gauge when the fan is T p
down stream from the collector.
33* •An FED should always "blow his cool" whenever a boiler
operator blows his flues. T p
A-16
-------
AIR POLLUTION FIELD ENFORCEMENT
COURSE #444
TEST NO. 3
Name
1.
True
False
CO
1—1
l
2
3
4
5
6
7
2.
Yes
No
19.
l
2
3
4
5
6
7
3-
a
b
c
d
20.
1
2
3
4
5
6
7
4.
a
b
c
d
21.
1
2
3
4
5
6
7
5.
a
b
c
d
22.
1
2
3
4
5
6
7
6.
True
False
23.
1
2
3
4
5
6
7
7.
a
b
c
d
24.
l
2
3
8.
True
False
25.
1
2
3
9-
True
False
26.
1
2
3
•
o
H
True
False
27.
1
2
3
11.
a
b
c
d
28.
1
2
3
12.
True
False
29.
Tiuf
False
13.
True
False
30.
True
False
14.
True
False
31.
a
b
c d
15-
a
b
c
d
32.
True
False
16.
True
False
33.
True
False
17.
a
b
c
d
TEST EVALUATION - Check one box each line. This test has beeni
Too long O About right Q Too short Q
Too hard ~ About right £Zf Too easy | [
A-17
-------
STUDENT EXERCISE NO. 1
SECTION I (LESSON 4)
ANSWER SHEET
team A members signs
1. Completed Visible Emission Observation Form. Do not turn in.
2. Ehter on the Notice of Violation Form that information vdiich is valid
to this point in time.
*-
3. The rule violated was
Aggregate (length) of violation to minutes
k. The on-site inspection should produce the following information to
complete the documentation of this violation.
1. Hfg/lJ cUfe
2.
Gaoi0 nfifi ^4 fer/nrf a/«
3-
-/or oU hr.
f /Jiitf: J fate 5&h. On ll 2 'b to'" " ^
AU% or le.*$ IS etemp+ed J"** ^fo/
OS, '/*'
Vy A-18
-------
Source Name
Address
Observation Point: 75 fit U> » £fl
0
15
30
45
0
15 1 30
45
JU. r d
0
30|
( — * /
Stack: Distance From A? ^ H«iaht !2j
1
31
Wind: Speed bh Direction ^
2
32
Sky Condition: (c fassu^ej))
3
33
Color of Emission: J?/a g/C-
4
34
Ambient Temp: Dry Bulb C&&) °F (ctSSurtGD)
5
35
•
Wet Bulb "°F
Relative Humidity:
6
36
7
37
Observation began Ended & 21$
a
38
sssi: >
Q
39
Certification Date: 2- /7S)
10
40
11
41
1?
42
l*s-Ci^q 7tf Ai#rt,
13
43
rJ.
14
44
15
£T
45
ll!r
i/v
l/v
55
26
•h
'/>
r>
56
27
0
0
£>
57
28
38
29
59
fey
VISIBLE EMISSION OBSERVATION FORM
Observer \AJ-/t*Ji_
Date
7/^flP
A-19
-------
ANSWER KEY 4-1-79
e#«r
i»a«t
iMoir
Henderson County Air Pollution Control
Henderson, Ohio
NOTICE OF VIOLATION .7-/s-7f
sisrr
AOOIICM
flC PMMISti AT
TMITAtLtNaCONTRACTdf"
"w*r
"wtv
YOU ARE HEREBY NOTIFIED THAT PURSUANT TO SECTION
B> ie So on THE HEALTH AND SAFETY CODE OF THE
STATE OF OHIO A MISDEMEANOR HAS BEEN COM.
MITTED THROUGH tub c/k,. &oj a->r c*«'hn,IMiik
an oba.c*rhl Jh *C&£>5> ctor
By.
BnforeamAit
Bodgo
i=r:o.W-t
d$su m e.d
A-20
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AfJwsz K&y
STUDENT EXERCISE NO. 1
SECTION II
LESSON 5
ANSWER SHEET
LM flHMjUbfZ r\&1 MEMBERS SI©
3-26-79
List at least five important errors pertaining to different principles
of good on-site Inspection and investigative practice.
1. When advised "by secretary to see Mr. Peterson, he should have asked
• "is he the person of highest authority on the premises?" If not,
who is, and ask to see that person.
2. He should have asked Mr. Peterson's full name and official title.
He may "be a company officer or comptroller.
3> As soon as Hartley Div., Compton Metals is mentioned, he should get
the corporate address of Compton Metals, as well as exact corporate
name, and determine relationship of Hartley Div. to Compton Metals -
an operating division or wholly owned subsidiary.
4. At the Incinerator, as soon as Mr. Allen's name as plant manager was
mentioned, he should get Allen's full name and title and inquire if
he is on the premises now and see him before he leaves.
5« As soon as he notes Operating Permit is issued to Johnson Storage,
he should have advised of the violation of Rule 10a (Operating Without
a Valid Permit) since Rule 12 states "Permits are not transferable".
6. He should inquire about construction plans and advise of provisions
of Rule 10a.
7. The time the inspector left the premises was not stated.
8. No information was given regarding the regulations.
A-21
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STUDENT EXERCISE NO. 1
LESSON 5
ANSWER SHEET (QONT'D)
List the number of potential violations and specify the Rule which
has been violated.
No. of
Rale Violations Description
Pule 5o ( & pact hi
Rule Jo b I /Jo obeyahn* iermif *jor WC,
l?ule to
6* 4- % hard chrorhe o/&hn4 "hints
/ blower d e*hau$f
I d tortus., y $ -fant
Complete the notice of Violation Ibzm, front and back.
If so instructed, each Team is to turn in one completed Answer Sheet,
signed "by all members of the Team and one completed Notice of Violation
Fbra, front and back.
A-22
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EXAMPLE OF A PROPERLY EXECUTED NOTICE OP VIOLATION *
CO*?
z
r««r
maiv
Henderson County Air Pollution Control
Henderson, Ohio
NOTICE OF VIOLATION, w?
£*•*.") mrf/e* V".
¦Am4 1 ' . / ' ""
i-3\q £r/e Srt £Aic*ya Tn, _ 6>3t<4o
QSIQ &f~ £2 h. tO/£ c/)gr£ It /¦ieridfrSa* £>,
• NC rUHIKI AT "" ' ' ""
rUMiia at
TtMTAlUftQ C0MTMC10*"
to
W
YOU ARE HEREBY NOTIFIED THAT PURSUANT TO SECTION
OF THE HEALTH AND SAFETY CODE OF THE
STATE OF OHIO A MISDEMEANOR HAS BEEN COM*
MITTED THROUGH tub
POINT Of OlSMVATIONs
WtATHIRi
WHO
N
1
i w
ARRIVALS {J
VtSIIU (MISSIONS OBSttVIO
OfPARTURIi JJ
tf AIT
•TOP
ma.
R. Ma.
oiua
V.AS iOURCI KMITTIN6
VISIILi DISCHAR6I AT
»
CNO Of OISIRVATION?
YU U NO ~
• .
N. M«. Oft
OPACITY
mujon £*,0l
Of IN. MM
•
Sliced
TOTAL
WIN.
titi g i/,c c -fires - Phni Sop h
D«t« el Strvic«,7'/i"-7 K By
Sector———
-WVX3>^ •
Dlrvctor of Enforcement
B«dg» Ne.
EI
*This is Information added to Violation Notice after on-site inspection. This data
with that filled in after observation (Lesson 4) completes the notice. It is- -
assumed that Mr. Allen, Plant Manager, was present and waa. contacted "by Hubbard
"before he left the premises. A-23
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EXAMPLE OF A PROPERLY WRITTEN REPORT *
,W T&* '
WAS MANAGEMENT CONTACTED OES)
OnillATOR
Nume & Atldresa o ^ 10
*
"32
PTTS'Se n
Ills REMAKKS
NAME
UiAGEMENT CONTACTED ^YES ) NO
/ / r -A//* "/CjC president a„}0 r> /• s*7 4 * A (Zs>t&OK.<^
S^LsvydJ /j
~Ce
QX
Xtcj c06 (sKA^Ld/uv TUlUjL
* j A*s&hutiU^eJ ^/c'^j2^7nC^.
JRIVER'S LICENSE NO.
VACATION FROM
TO
REQUEST FOR COMPLAIN; SIGNED
DATE
~It is to be assumed Mr. Allen,Plant E:ff:V<£^ Manager was present and was
contacted try Hubbard before he left the premises.
A-24
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ANSWER KEY
LESSON 11
SECTION IV - ACTUAL TRIAL QUESTIONS
The following questions are extracts from the courtroom record of the actual
trial of a large smelting corporation for opacity and suspended particulate
matter violations. Part A presents questions which were asked of the field
enforcement officer testifying by his own agency's attorney. Part B
consists of questions asked during the cross examination of the same officer
by the defense counsel.
PART A - QUESTIONS ASKED OF THE
FIELD ENFORCEMENT OFFICER BY HIS OWN AGENCY'S COUNSEL
1. Please state your name and address.
2. What is your position of employment?
3. How long have you been employed in your present capacity?
4. What are your duties as a field enforcement officer?
5. Please describe your educational background, your training and
qualifications as a field enforcement officer.
6. Please state whether or not your have ever investigated the
Columbia Smelting Company? Where is it located?
7. When did you investigate the plant?
8. What was the purpose of your visit?
9. What tests did you conduct? Who accompanied you?
10. What is suspended particulate matter? How do you test for it?
11. How long have you been taking high volume air samples?
12. What is the correct procedure for taking high volume air samples?
13. (Exhibit a high volume air sampler or photograph thereof.)
How does a high volume air sampler work?
14. What is the purpose of the up-wind sampler?
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15
16
17
18
19
20
21
22
23
24
25
26
27
Would you describe the physical characteristics of the plant and
its boundaries with respect to other geographical features of
the area, including residential or other land use-type areas.
(Have him draw a map of the plant and surrounding area.)
Please describe in detail how you and your partner conducted the
high volume air sample on January 15, 1972.
Describe ^hat you did with sample after you completed the test.
How is a sampler tested for accuracy? Do you know whether or
not the samplers used to test Columbia Smelting Company were
accurately calibrated? Describe how and when said samplers were
checked for accuracy.
Do you know whether or not the samplers were functioning
correctly and accurately on January 15, 1972? (If someone else
calibrated the samplers you may need to have him testify as to
their accuracy. If someone other than the investigator did the
weighing of the samples, you will need to have him testify as to
the manner and accuracy of the weighing.)
Describe how you weighed the samples. How accurate is your
balance? Do you know whether or not your balance was operating
accurately? How did you check?
What was the weight of the sample paper before the test? What
was the weight of the sample after the test? How long were the
samplers run? What volupne of air passed through the samplers?
What is the up wind u/M5? The downwind?
What is the net ug/lt3of suspended particulate coming from the
plant?
What is the source of said emissions?
State whether or not the source is in excess of the allowable
limits provided in Rule 105.2 of the State Air Control Board
Regulations. How much?
Describe your training and experience with respect to conducting
opacity tests?
How accurate must you be to qualify to make visual opacity
readings?
Describe fully how you made the opacity reading? Where were you
located with respect to the stack that was read?
A-2 6
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28. State whether or not the source was in excess of the allowable
opacity limit provided in Rule 103 of the State Air Control
Board Regulations?
PART B - QUESTIONS ASKED IN CROSS-EXAMINATION
OF THE FIELD ENFORCEMENT OFFICEk BY THE DEFENSE COUNSEL
The following questions were part of the cross-examination of the investi-
gator by the defense counsel. They are based on those actually asked in the
case this exercise is taken from, and therfore they are phrased in the same
probing style a good defense attorney would use. You, as a field enforce-
ment officer, should be able to answer them in a calm and direct way.
Remember that the opposing counsel can ask an adverse witness (in this
case, the investigator) leading questions.
1. When you are conducting a suspended particulate matter test, is
it possible to get an amount sufficient to constitute a violation
in just a few minutes?
2. Even though the test might still be run for several hours?
3. It appears from your report that you set up and started the
downwind sampler a full 20 minutes before the upwind sampler.
Is that correct?
4. Did you and your partner leave the downwind sampler while you
started the upwind?
5. (If they did:) You left it unguarded? Unprotected?
6. Isn't it possible that someone could have come by when you were
setting up the upwind and dumped dirt or some other substance in
the sampler?
7. Can you state, of your own personal knowledge, that it wasn't
tampered with during that time?
8. You stated that the purpose of the upwind is to measure the
suspended particulate matter level upwind of the plant so that
you can determine the amount leaving the plant premises which the
plant is responsible for. Is that correct?
9. Isn't it possible that during this twenty minutes you could have
collected a high amount of suspended particulate matter from
A-27
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upwind of the plant in the downwind sampler thereby showing a
violation, without the upwind sampler showing it?
10. You can't always see suspended particulate matter, can you? It's
possible, isn't it?
11. You can't then state of your own personal knowledge that it
didn't happen, can you?
12. Now, the downwind sampler was next to the road on the shoulder,
right ?
13. The road has gravel shoulders, doesn't it?
14. Anytime a car or truck passed, it would stir up the dust and
whip it around?
15. It could get in the sampler, couldn't it? A road is a windy
place usually anyway, isn't it?
16. The dust could get in the machine and affect the sample, couldn't
it?
17. It appears from your map or drawing that the two samplers were
not placed due upwind and downwind in relation to the plant.
Is that correct?
18. Why not?
19. Can you see the downwind site from the upwind site or vice-versa?
20. How would you know they were due upwind or downwind in relation
to the plant? Don't you bother to use a compass to line them up
correctly?
21. The wind was variable and shifting directions, wasn't it?
22. Everytime you had a shift in wind to out of the southeast it
could also bring a high level of particulate matter from some
other source into the downwind sampler, couldn't it? without the
upwind sampler ever detecting it, isn't that correct?
23. At any rate, if the wind shifted from out of the southwest to the
southeast, the upwind sample couldn't accurately show what amount
was actually upwind of the plant?
24. In fact, the downwind wouldn't even show what was coining off the
plant, would it? It'could be picking up some dther source? a
higher level source?
A-28
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25. Where did you set the generator that runs the sampler? Could
exhaust from the generator have been caught in the downwind
sampler?
26. Was the generator calibrated? If it wasn't functioning properly,
couldn't it mess up the sample?
27. Where did you put the sample paper in the machine? Where did you
take it out of the machine?
28. Do you smoke? Were you smoking when you were handling the
sample paper?
29. Do you ever sue farmers for violating Regulation 105.2?
30. Wouldn't a farmer, when he is plowing or cultivating his field,
be in violation of Regulation 105.2?
31. There is no provision in the regulations exempting him, is there?
Or do you know the regulations that well?
32. Why don't you sue farmers and put them out of business? Why
don't you require them to install pollution abatement equipment
on their tractors?
33. Couldn't suspended particulate matter from a farmer's plow do
just as much harm as any suspended particulate matter from
Columbia Smelting Co.?
34. Isn't Columbia Smelting just as important to the economy and
security of this country as the farmer?
35. Can you say of your own personal knowledge that this suspended
particulate sample is accurate?
3
36. Who arrived at the 100 ug/m as the maximum allowable suspended
particulate matter level? How?
37. Has anyone in your agency done any independent study as to health
effects, or did you just borrow the standard from someone else?
38. Have you, yourself ever done any in-depth research as to health
effects?
39. You can't state of your own personal knowledge whether or not the
regulation is reasonably related to health, can you?
40. You can't state whether or not the regulation is reasonable, can
you?
A-29
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41. Who thought up the 30% figure for opacity?
42. Has anyone done any research or study as to the health effects
of 30% opacity?
43. Did your agency just borrow that figure from another state or
from EPA?
44. Did someone just think it up?
45. If it is based upon aesthetics, isn't that very subjective?
46. "Grayish white" smoke looks like clouds, doesn't it? Is there
anything unaesthetic about clouds?
47. In fact bright red or yellow smoke might be aesthetically
pleasing, couldn't it? Like a sunset?
48. Was this smoke impairing the visibility of motorists on the road?
49. Was this smoke impairing visibility anwhere in the community?
50. In making the opacity readings, where were you reading the plume
in relation to the stack?
51. It doesn't say in Rule 103 where you read the plume, does it? It
is vague, isn't it?
52. Shouldn't you read the plume at the property line of the plant?
After all, that's the closest place it could bother anyone, isn't
it?
53. Can you really read the percent opacity by just looking at it?
Accurately? Wouldn't the color of the smoke affect your
estimate?
54. Bright red smoke wouldn't distract you? The shade and color
don't make any difference?
55. You don't think a bias or prejudice against the company you were
testing might unconsciously affect your reading?
56. At any rate, the accuracy of the reading is based entirely on the
credibility of the investigator, isn't that correct? You would
just have to take his word that the company was in violation,
right?
57. Have you had any arguments or disputes with the plant manager?
58. What were you using as a background, the sky?
59. You stated in your report that this was a cloudy day?
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60. Wouldn't grayish white smoke blend in with a cloudy background?
61. What does your training manual say about reading white smoke
against a cloudy background?
62. A cloudy background could give you a much higher reading - even
100%, couldn't it?
63. Isn't it possible that a cloud could have gotten in the way while
you were concentrating on the plume, and you just didn't see it?
64. After all you were looking into the sun, weren't you?
65. It appears, based on your map, that you would be northeast of the
plant looking southeast in making your readings, isn't that
correct?
66. In relation to the map at about 2:00 P.M., wouldn't the sun be
in the southwest? So you would have to have been looking into or
in the direction of the sun, correct?
67. What does your training manual say about taking readings with
respect to the sun? Why?
68. Based on the wind direction shown on the map, you were not at a
right angle with the plume when you made your readings, correct?
69. What does the manual say about where you should be in relation
to which way the plume is drifting? Why?
70. In fact, the plume was coming toward you, wasn't it? You were
looking into the plume?
71. Did you take any other readings within sixty minutes of this
reading? (If he did not: ) Then you can't say that the plant was
in excess of the limit during sixty consecutive minutes of your
first reading, can you?
72. Can you say, of your own personal knowledge, that the visible
emissions did not occur ''during the cleaning of a firebox or the
building of a new fire, sootblowing, equipment changes, ash
removal and rapping of precipitators"?
73. Doesn't Rule 103.1 permit emissions in excess of the limits for a
period of five minutes in any sixty consecutive minutes, or six
hours in any ten day period during the cleaning of a firebox or
the building of a new fire, sootblowing, equipment changes, ash
removal and rapping of precipitators?
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LESSON 13
ANSWER KEY
ODOROUS GASEOUS EMISSIONS COMPLAINT HANDLING
Q. Assuming that Harry neither did nor saw anything more than that stated in
the case history, prepare a critique of his investigative technique. Indi-
cate all errors and deficiencies in his technique.
CRITIQUE OF THE INVESTIGATION
As stated earlier, the field enforcement officer had little, if any, practi-
cal experience in the investigation of air pollution complaints. One of his
principal mistakes was his assumption that, because he could not detect any
malodors, a problem did not exist. The following procedures would have been
good technique:
1. Harry should have noted the direction from the complainant's home to
the plant, any significant topographical features (or lack of them), and^
the prevailing wind direction.
2. The inspector failed to ask Mrs. Rust to characterize the odor and to
indicate when it was most prevalent, lie also neglected to ask whether or
not she had noticed the wind direction during the episode and failed to
record the names and addresses of the other complainants indicated by Mrs.
Rust. Several of these people should have been contacted and questioned
concerning the characteristics and prevalence of the odor episodes and
the wind direction during the episodes.
3. Upon arrival at the plant, Harry should have attempted to get down-
wind of the plant to determine whether or not there was an odor emanating
from the plant's operations.
4. He properly identified himself and was correct in accepting an inter-
view with the plant engineer when the plant manager was not available.
5. The interview with the plant engineer was carried out poorly. It
should have been specifically directed toward obtaining information about
the process operations as they affected the air pollution potential: the
operating and maintenance procedures, the operation of the air pollution
control equipment, and the review of records related to the preceding.
Some specific items which should-have been obtained are:
a. ' Types and quantities of paints used, including types and percent-
ages of solvents used in the paints.
A-32
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b. Oven temperatures.
c. Temperatures and volumes of the various effluent streams.
d. Operation and maintenance schedules, including times of day when
paint baking occurs and an/ unusual operating conditions such as
formulations that require higher baking temperatures or contain unusu-
ally high percentages of solvents or particularly odorous solvents.
e. Control system data including information on temperatures of
inlet and outlet gases, volumetric throughput, and catalyst mainte-
nance schedules.
6. During the interview, the plant's operating permit should have been
reviewed and inquiries made to determine that the plant's equipment and
operation was actually the same as that covered in the permit.
7. After the interview, the plant inspection should have been utilizod
to verify wherever possible the information given in the interview. The
inspection should have covered the following:
a. Inspection of the specific equipment used for each phase of the
production operation.
b. Inspection hooding, ducts, fans, drive belts, temperature record-
ers, and general level of maintenance.
c. Inspection of air pollution control equipment. Review of any
charts, recordings or maintenance schedules utilized in conjunction
with the control equipment.
d. An attempt should have been made to get onto the roof in the vi-
cinity of the stacks to ascertain whether any odor could be detected
in the exhaust gases.
8. After the plant inspection, Harry should have made a greater effort
to determine if the metal-plating plant mentioned by Mr. Erb could actu-
ally have been the malodor source. Merely driving by the plant is hardly
a proper investigative technique.. An investigation similar to that done
at the Alcoat Company should have been performed at the metal-coating com-
pany.
9. Prior to completing his report and recommendations, Harry should have
discussed the case with a more experienced investigator. It is likely
that the shortcomings of his investigation would have been pointed out to
him and a proper investigation rescheduled.
A-33
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Assuming that the investigation indicated that the Alcoat Company was indeed
the source of the odors, explain how you would go about ostabl i shing a bona
fide air pollution case. Remember that thprc arc no specific odor control
regulations and that the burden of proof in establishing air pollution as
defined in the agency's ordinance rests with the agency. An odor problem of
this type is effectively a public nuisance and the manner of establishing the
existence of the problem would be similar to that used to establish the exist-
ence of a public nuisance.
COLLECTING DATA FOR ESTABLISHING THE CASE
Once Harry's superiors had determined that the complaints were increasing
rapidly in number and that they were coming from various locations throughout
Orangeland, they immediately consulted with him and advised him of the proce-
dures to be followed:
1. Obtain a complete description of the area surrounding the Alcoat
plant including the plant location, the location of the residents, dis-
tances and direction from plant to complainants, significant topographi-
cal features, and location and nature of any other sources in the immedi-
ate area which could be causing a problem.
2. Contact all of the complainants and determine, if possible, the char-
acter of the malodors: when they aire most prevalent, their duration and
wind direction at time of occurrence, and any other pertinent data.
3. Request the citizens' assistance by establishing a citizens' odor
panel. (Five or six of the residents are to be asked to keep a log of
malodor episodes and record, to the best of their ability, the character
of the odor, the strength of the odor, the times of occurrence (noting
the duration), and the wind direction during the episode.)
4. Revisit the Orangeland area as frequently as possible until the exist-
ence of the malodors is conclusively established. Determine whether the
odors could be related to the Alcoat plant by backtracking them when they
are detected in Orangeland.
5. Revisit the Alcoat plant for the purpose of conducting a proper in-
spection and request the plant to routinely submit operating schedules to
the agency.
6. Obtain wind speed and direction data from a nearby airport weather
station.
7. Ask the agency technical staff to review the plant data to evaluate
the odor potential of the various solvents used by tho Alcoat Company,
and request the engineering staff to investigate and evaluate the perform-
ance ot" the catalytic combustion units utilized by the company.
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ANALYSIS OF DATA ANO ESTABLISHMENT OF CASE
As during the initial investigation} at the follow-up investigations Alcoat
repeatedly claimed that it had no odorous emission problems and that it was
conforming to all applicable air pollution control regulations. The/ again
implied that if there was a problem in the area it was caused either by some
other company or by malfunctioning of local sewage disposal systems.
In rebuttal to the company's position, the agency determined that:
1. The Alcoat Company is located less than one-half mile due west of
Orangeland. Any winds blowing from the northwest through the southwest
quadrant would blow across the plant and impinge upon some area of
Orangeland. Meteorological data accumulated over the past three years
indicates that during sixty>one (61) percent of the time, the wind blows
towards the development from the northwest through the southwest quadrant.
There are no significant topographical features that interfere with this
wind flow.
2. All complainants were contacted. They characterized the odor as a
solvent-type odor or as an eye and nose irritant. One complainant char-
acterized the odor as that of rotten cabbage. It was subsequently deter-
mined that this individual's neighbor had a seeping septic tank system
which was causing a localized odor problem.
In all, thirty families were contacted. Twenty-five of the families indi-
cated that the solvent odors were severe enough to require corrective
action. Fifteen of the complainants indicated that they would be willing
to testify in court.
3. Eight of the complainants were selected to monitor and log odor epi-
sodes in their area. These logs indicated that the odors are character-
istic of solvent odors, are very strong when detected, and are usually
present when the wind is blowing from the Alcoat plant toward their hones.
The location of the metal-plating plant is such that it would not have
been the source of the odors during the monitored episodes.
4. Harry and another inspector were assigned to visit the Orangeland
area at random times. Over a period of two weeks during which time they
conducted seventeen investigations, they confirmed the existence of sol-
vent odors and other irritation gases in the Orangeland area twelve times. .
In nine out of the twelve verified episodes, the inspectors were able to
report thqt the odors became stronger as they approached the Alcoat plant
and that they were not present upwind of the plant. The dates and times
of the observations were carefully recorded.
A-35
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5. A more thorough investigation was conducted at the Alcoat plant. It
was determined that the plant operatos twenty-four hours a day and con-
sumes approximate!/ one-hundred gallons of paint por hour per production
line. Die paint composition normally is about 40% solvents (by volume).
These solvent* include, but aro not limited to, amy1 alcohol, methyl
alcohol, methyl ethyl ketone, xylol and napthu. Phenolic resins arc
widely used in the paint formulations. The ovens operate at approximate-
ly 450°F and the volume of effluent is approximately 10,000 sct'm per ovon.
A trained observer, who visited the plant site, indicated that the odors
present were characteristic of solvent odors and partially oxidized and
polymerized organic solvents and resins. A review of the catalytic com-
bustion units showed that there was little, if any, temperature differen-
tial across the catalyst. Residual odors were noted near the exhaust of
the quenching operation.
6. A literature search on.the solvents used revealed that the presence
of methyl alcohol, amyl alcohol and mothyl ethyl ketone in the air may
cause irritation of the membranes of the eye and respiratory organs.
The phenolic resins are normally stable at temperatures below 400°F.
When heated above 400°F in compounds, the resins will release formalde-
hyde .
DISPOSITION OF CASE
*
Upon completion of the investigation, Alcoat was advised of the agency's
findings and ordered to take corrective action. The company appealed the
order and the case was heard before a hearing examiner. After listening to
the testimony of ten complainants, and after hearing the comprehensive case
that the agency had prepared (based on the previous information), the hearing
examiner found for the agency. In his adjudication, jie ordered the company
to comply with the agency's directive.
The company claimed that they were not causing air pollution: that there
were othur sources of odor in the area, and that, in any event the ordinance
was unconstitutional as it failed to sut forth adequate standards for the
determination of the existence of air pollution. In addition, they felt
%
tlt.it the definition of air pollution was vague and uncertain and not suscep-
A-36
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tible to acceptable standards of proof.t They were not satisfied with the
hearing examiner's adjudication and appealed to the county court.
The county court carefully reviewed the record of the case and the testimony
presented before the hearing examiner. The court found that "There is no
doubt that the evidence confirming the existence of an air pollution problem
is substantial. The testimony amply supports the hearing examiner's find-
ings." As a result of its determinations, the court dismissed the appeal and
ordered that the adjudication of the hearing examiner be sustained.
The agency won this odor case primarily by producing a preponderant weight of
evidence to verify the existence of an air pollution problem. Its careful
and thorough investigation was the keystone upon which the entire case was
based. Since most odor problems are very subjective in nature, it is impor-
tant that the investigator accumulate a preponderance of evidence to tip the
scales in his direction. It is equally important that the receptors or the
complainants be willing to support the agency's efforts and that they be used
to the best advantage.
A-37
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1. REPORT NO. 2.
EPA 450/2-80-077
3. RECIPIENT'S ACCESSI ON» NO.
4. TITLE AND SUBTITLE
APTI Course 444
Air Pollution Field Enforcement
Instructor's Guide
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.
R18A2.C
11. CONTRACT/GRANT NO.
68-02-3014
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
Manpower and Technical Information Branch
Air Pollution Training Institute
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
Instructor's Guide
14. SPONSORING AGENCY CODE
EPA-0ANR-0AQPS
15. SUPPLEMENTARY NOTES
EPA Project Officer for this manual is J. 0. Dealy, EPA-ERC, MD-17, RTP, NC 27711,
TECHNICAL REPORT DATA *
(Please read Instructions on the reverse before completing)
The Instructor's Guide for the Air Pollution Training Institute
Course 444 "Air Pollution Field Enforcement" contains complete
information for conducting a 3h day training course. The Guide
contains course objectives, course agenda, information about past
students, examinations and answer keys and 19 lesson plans with
keys to visual aids. The training course is designed for field
inspectors responsible for enforcement of air pollution regu-
lations. It covers identification of air pollution violations;
gathering evidence for violation abatement; conduct as a witness;
handling public complaints about air pollution; compliance testing;
and other related subjects.
The Instructor's Guide is used in conjunction with a Student
Manual (EPA 450/2-80-075) and a Student Workbook (EPA 450/2-80-076),
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
Education
Manuals
Air Pollution
b. I DENTIFIERS/OPEN ENDED TERMS
Training course
Instructor's guide
COSATI Field/Group
13 B
5 I
68 A
a. distribution statement Unlimited
Available from National Technical Infor-
mation Service, 5285 Port Royal Rd.,
Snri'ngf ield . VA 22161
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
283
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
A-38
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