V,
®sot
AIR POLLUTION CONTROL
IN PHILADELPHIA, PENNSYLVANIA
AN EVALUATION REPORT
WITH RECOMMENDATIONS
FOR PROGRAM IMPROVEMENTS
U. S. ENVIRONMENTAL PROTECTION AGENCY
Air Pollution Control Office
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AIR POLLUTION CONTROL
IN THE
CITY OF PHILADELPHIA
An Evaluation Report With
Recommendations for Program Improvements
Project Supervisor
Stenhpn R. Hassprtiiio
«. • ~ " "" "" O
Staff Participants and Specialists
Jay Avner (Administration & Data Handling)
J. Michael Joyce (Engineering 6c Enforcement)
Neil Berg (Technical Services)
William Polglase (Engineering)
ENVIRONMENTAL PROTECTION AGENCY
Air Pollution Control Office
Division of Applied Technology
February 1971
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CITY~OF PHILADELPHIA
Hr. Kenneth Johnson
Regional Air Pollution Control Director
National Air Pollution Control Administration
Public Health Service
U.S. Department Health, Education and Welfare
26 Federal Plaza (ipoley Scruare)
New York, N.Y. 10007
Dear Mr. Johnson:
Tn nrOftr^anc1 •'-t-h fUsrusRinn' In our mp.fctinf* at the
- • - - - • - -
Regional Office in Mew York City on January 15 and as
Affc.r.-,.-! ir. iir, Charles D. Yaffe's letter of last June,
i snould iiku lo formally request technical .nssx stance la
the form of an on-site review of the Philadelphia air
management program, as an additional aic in me definition
oi" the project undertakings v;hich will lead to develop-
ment of a maintenance level program to be considered for
appropriate Federal funding.
The recent conference in which Hr. Edward F. "Wilson
and I participated was very useful and constructive. I
am happy to know that funding under the present air pol-
lution improvement project grant will continue curing
the period when the Philadelphia air. management program,
with the consultation and advice of you and your staff,
will be further defined. V7e are most appreciative of
this type of assistance.
Incidentally, my fiscal officer informs-me that,
since the initiation of the first Federal air pollution
improvement grant to the Philadelphia program several, years
ago, there has never been a Federal fiscal audit of this
DEPARTMENT OF PUilUC HEAnii
Room 540, Municlpol S,,v;tcl B,M,
PhllodHphio, To. 19107
NORMAN R. INGPAHAM, M.D.
Commiisioner
VVAtTfR J. tCAR, M.D.
Deputy Comrajjsionei
February 3, 1970
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* Mr. .Kenneth.Johnson:
«• "-2 i-
2«r3-70
program. . It was . our under.standi.n3 that this would be
requested and, from the management standpoint, this'
voule certainly be-xiseful... I ".thought it inifhfbe
appropriate to bring . this up again at this time,
Thanlc you for your - continuing consultation, advice4
and financial support.
Sincerely yours,
^Ua/JZL{
Kprnau R, lnj?rch?-mr M.L\
i'UVJL e £r - -
cct 1-ir * Goodwin
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TABLE OF CONTENTS
PAGE
LIST OF TABLES . .... iii
LIST OF FIGURES. . iii
SECTION
1 Introduction. . 1
2 Summary... 2
3 Summary of Recommendations 4
4 Air Pollution Problems 4
5 Legal... '16
•5.1 Legal Authority 16
5.2 Legal Operations.. 18
6 Organization 24
6.1 Prior Study by USPRS 2b
6.2 Present Organization........... ^ . 24
6.3 AMR 28
7 Budget 30
»
8 Manpower 34
8.1 Staffing Requirements........... 34
8.2 Job Descriptions 38
8.3 Salaries... 40
8.4 Training 42
8.5 External Constraints 44
9 Communications 46
10 Program Planning and Evaluation... '48
11 Land Use Planning... 50
12 Public Information 51
13 Engineering 54
13.1 Emission Inventory. 54
13.2 Permit Approval 55
13.3 „ Industrial Improvement 57
14 Enforcement.. . 58
14.1 Compliance and Surveillance 58
14.2 Enforcement Section............... 60
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ii
PAGE '
15 Technical Services. 61
15.1 Air Monitoring 61
15.2 Laboratory 63
15v3 - Source -.Testing ,t 64
16 Meteorology ^
17 Data Handling ...» 69
17.1 Computer Capabilities.... 1 69
17.2 Data Utilization.. 70
Appendix A - Proposed Location of Station's in Expanded Air
Monitoring Network
Appendix B - APCO Guidelines for Numbers and Types of Air
Monitoring Stations
Appendix C - Calculation Parameters for APCO Manpower Pro-
jections
Appendix D - AMS Present Organization of Functions and
Personnel
Appendix E -
Appendix F - Staff Salaries in Air Pollution Control Agencies
Appendix G - Salaries: An Examination of Salary Levels for
Recent Graduates
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iii
LIST OF TABLES
TABLE NUMBER PAGE
4.1 EMISSIONS BY SOURCE CLASSIFICATION.,.. 15
5.1 COURT CASES 1968 + 1969...... 91
7.1 PHILADELPHIA FINANCIAL RESUME... 31
7.2 PERCENTAGE OF TOTAL PROGRAM BUDGET
RELATING TO ELEMENTS IN. THE APC ACTIVITY 32
7.3 ESTIMATED COST OF RECOMMENDATIONS.... ........ 33
8.1 PRESENT AND PROJECTED
MANPOWER NEEDS (AMS - PROJECTED) ... 35
8.2 PROJECTED MANPOWER NEEDS ( APCO - PROJECTED) 36
8.3 FISCAL YEAR 1970 MANPOWER SURVEY SHEET ....... 37
8.4 SALARY COMPARISON 41
.15.1 ORDER OF PUBLICATION: CRITERIA DOCUMENTS... 65
LIST OF FIGURES
FIGURE NUMBER . PAGE
6.1 CITY OF PHILADELPHIA - AMS ORGANIZATIONAL
CHART 26
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1. 'INTRODUCTION
On February 3, 1970, Dr. Norman R. Ingrahm, City of Philadelphia Health
Commissioner . in a letter to Mr. Kenneth Johnson, Air Pollution Control Office
(formerly NAPCA) , Region II Director., requested an objective evaluation
of Philadelphia's resources, laws', and all program activities for air pollution
control. This report has been prepared in response to that request. This study
is also timely since Air Management Serviceswithin the Department of Public
Health, plans to submit an application to 'APCO for maintenance program support
for FY 72 as authorized by the CleairAir Act as amended. With these factors in
mind, this report is designed to determine program weaknesses and to focus on
those program areas in need of strengthening and developing in order to qualify
for maintenance support. It must be understood that recommendations contained
in this report are presented as a means of reaching that goal. Certainly there
are alternate methods that can be used to reach program goals and, in all
probability, a few important problem areas were not detected or discussed.
There is no intent to stifle program initiative and imagination in such deci-
sions.
At the present time, several important program elements are being implemented
and are only discussed briefly in this report.
There arc many satisfactory, in fact excellent, program elements that are
not discussed within the report. The fact they are not dismissed by design
since the important objective of the report is to assist in the implementation
of a comprehensive effective air pollution control program designed to protect
the health and welfare of the citizens of the Philadelphia area.
Air Management Services (hereafter referred to as AMS) must operate within
a city government structure that imposes many constraints on a program and
makes it more difficult for the agency to achieve its goals. While these fac-
tors have been discussed in this report, "APCO realizes the difficulties of
altering long-standing systems. It is important, however, that these problems
and their effect on AMS be discussed and understood.
The Commonwealth of Pennsylvania, according to prescribed law, has certified
AMS as the exclusive agency in Philadelphia. This certification gives AMS com-
plete responsibility for control of all air pollution originating within the
City. This sole responsibility makes it all the more important for AMS to have
an effective program as it is logically the body tha,t can provide cleaner air
for the City of Philadelphia.
The Commonwealth of Pennsylvania also has an'active air pollution control
agency. This agency is responsible for control activities in the remaining
metropolitan area of Pennsylvania.
- The material for this report was obtained from information provided to
APCO'. in conjunction with the grants program,, the regional office in New York
City, and information gathered by a team of APCO investigators during, a visit
to Philadelphia, April 26-30, 1970. APCO' is indeed grateful for the cooperation
extended by the Air Management Service-;, the Health Department, and the
Philadelphia Planning Commission during the fact-finding effort and for the
review provided by the New York Regional Office.
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2. SUMMARY
In the past few years, virtually every metropolitan center in the east
coast of the United States has reached a critical point. They are faced with
massive demands for power and new materials on the one hand and rapid deterioration
of the urban environment on the other.
The City of Philadelphia offers a prime example of this paradox. Industrial
and population figures have increased, and corresponding power needs and
citizen demands for new materials have soared.
To combat this growing air menace, the City Council in October of 1969
adopted a new Air Management Code. This document provides the Air Management
Services with very strong enforcement powers and penalties. If progress toward
comprehensive program development and, more important, the improvement of air
quality is to be accomplished, it remains for AMS to assume the kind of
aggressive effort required for enforcement of the Air Management Code on a
scheduled system of priorities. These priorities should in turn reflect long
range air quality objectives.
This report has been prepared to guide AMS in developing an effective
organization geared to meet the challenge. The Federal Clean Air Act of 1967,
an amended, is quite explicit in placing the primary responsibility for air
pollution control at the. State and local levcis. lit Liii& Legcii'u, Lne ^ticite of
Pennsylvania and the Philadelphia program must develop definitive agreements on
responsibilities and authority; thus insuring complimentary rather than
duplicative programs, and further defining areas of responsibility.
It is hoped AMS will consider the points and recommendations of this report
and take immediate corrective action.
The program will be able to operate more effectively if: (1) legal
administrative procedures are improved upon; (2) better internal and external
communications are developed; (3) personnel conditions are improved; (4) specific
plans and procedures for abatement and prevention are developed in line with the
development of a comprehensive program, to effectively control all sources 5f
air pollution; (5) a comprehensive information activity is developed; (6) AMS
begins detailed planning for information systems to process, store, and utilize
all types of data.
To attempt to meet all objectives and carry out all recommendations at one
time is not sound for program balance or comprehensive program development.
Therefore, recommendations should be implemented in terms of priority based on
existing limited resources and desire by the agency to attain Federal maintenance
levels of support, implying an effective program. By no means are the
recommendations as stated the only solution for corrective action of a problem.
There may be many solutions to the problem. In the short time for the on-site
review, it could not be expected that all the agency's problems would be uncovered,
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although, it is felt that major program deficiencies were revealed. ¦ Further,
interpretation and definition of a problem by the AFCO reviewers may not in all
cases be complete. This study does not intend to lay blame on any individuals
or organizations but encourages as its objective that all program entities in
the city work together for the common goal of controlling air pollution in
Philadelphia.
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s were revealed. Further,
PCO reviewers; may not iri-a 11
sy blame on any individuals
it all program entities in
si ling air pollution in
SUMMARY OF RECOMMENDATIONS
inmendations presented herein can be classified into the
(1) legal, (2.) organization, (3) manpower,
) program planning and evaluation, (6) land use planning,
., (8) engineering, (9) enforcement, (10) technical
.logy, and (12) data handling.
jns relative to legal:
ENDATION l . Amend Section 3-103 (5) to increase
m fines to $1,000, at least for the first offense.
i
ENDATION 9 Reconstitute the Air Pollution Control
so that it is an objective and impartial representative of
tire community. Board Representatives having substantial
ial interests tend to disregard public interest and welfare.
ENDATION 3 Modify Item (2) of Section 3-302 by
ng "to establish areas where objectives are applicable"
t air quality goals for the entire city will be uniformly
cial. Reasonable time schedules for achieving the uniform
ives should be set in those parts of_the city rather than
ng less strict objectives at the sacrifice to air quality,
ition, such objectives must be consistent with the
ions of the Implementation Plan for the Philadelphia AQCR.
SNDATION 4 . Express emission limitations in this regu-
... in terms of pounds/hour or pounds/million Btu of heat in-
In addition, modify or replace the emission standard for
ting equipment, subsection (2), by a standard that varies with
size of the installation.
MMENDATION 5 Express the limitations on emission of
ur dioxide in Section IA (2), Non-Commercial Fuel, in terms
ounds/hour or pounds/million Btu of heat input. The comments
with reference to Regulation II, Section V, also apply here.
EMENDATION ft Specify standard test methods for testing
.incinerator designs for compliance with the regulation.
/
MMENDATION _7 . Develop' regulations for control of
ocarbons, carbon monoxide, and odors. Federal criteria
iments for hydrocarbons and carbon monoxide are currently
:lable, and should be utilized in developing regulations.
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RECOMMENDATION 8; . Work with the State to develop plans for
the State to control emissions from sources outside of Philadelphia
that contribute to air pollution within the City.
RECOMMENDATION "9:. . Obtain additiona 1 IcgaF support. The agency
needs an experienced attorney who is familiar with air pollution
problems. In addition, a close working relationship with the
-Counseling Division should be developed.
RECOMMENDATION 10 . Use the enforcement method through seeking
conviction and fines in Municipal Court only for minor and infre-
quent violations. This is because the procedure makes no provision
for long-term compliance with regulations or abatement of ait-
pollution.
Specific recommendations relative to organization:
RECOMMENDATION 11 . Allow the Assistant Commissioner more time
to work with organizations outside AMS, both inside and outside
City government. To accomplish this, three alternatives are
proposed.
1. Establish and fill the position of Deputy Assistant
Commissioner; he should be. responsive to the needs of AMS and
chosen by the Assistant Commissioner.
2. Delegate most responsibilities to the Division Director
and choose someone to act in the capacity of Assistant
Commissioner when he is out of the-office.
3. Hire a chief administrative assistant to coordinate all
o
staff functions as well as line functions and problems.
• However, at all times there should be sufficient access to the
Assistant Commissioner by the Division Directors to express
grievances.
RECOMMENDATION 12 . Update the Engineering Division's functional
description to include functional categories, staffing, goals,
objectives, and time schedules to meet program objectives.
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Specific recommendations relative to manpower:
RECOMMENDATION . Make a major erfort to fill existing
vacancies before planning and implementing further program
activities.
RECOMMENDATION 14 . Create the category of Air Pollution
Control Engineer. Persons having this classification would deal
specifically with air pollution, and would advance according to
• their proficiency in thdt field.
RECOMMENDATION .15 . Require that chemists be knowledgeable
primarily in air pollution aspects.
RECOMMENDATION 16 . Utilize Chemist III and IV positions.
Such positions, based on degree and experience, would help adjust
-chemists' salaries more in line-with those of other agency
personnel.
RECOMMENDATION 17 . Create a second step within each of the
technician positions. This will provide incentive and a cor-
responding pay increase for more qualified persons. In addition,
the position of lab helper should be eliminated and such duties-
assume a by rectYnitria-ns.
RECOMMENDATION -18 . Establish the position of Applied Scientist.
This could serve as a "catch-all" type of position and enable the
agency to obtain needed specialized scientific and technical
talent without having applicants wait for new positions to be
created.
o •
RECOMMENDATION ft . Create an Air Pollution Control Public
Information Specialist classification. This is discussed in more
detail in the Public Information Section of this report. This
position would enable the agency to reject public, information
applicants who did not have the necessary background in air pollution
control.
RECOMMENDATION 2D . Increase salaries for professional
personnel and have studies made to eliminate problems of the limited
pay step increase and the pay differential of professionals and
non-professionals.
RECOMMENDATION .2-1 . Adopt a formal training program in AMS
for orientation of new employees, training professional employees,
and training non-professional technical employees by disignating
someone as training officer with responsibility for'the criteria
analysis of training needs. (NOTE: This is one area where an
AMS task force would be extremely beneficial in studying the
problems and coining up .with recommendations based on program needs.)
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RECOMMENDATION 22 Review the 2-year training commitment to
reduce its severely restrictive influence for training personnel
in the dynamic air pollution control field.
REC0M11ENDATION 23 Develop better working relations and commun-
ications with the Health Department's personnel office and
Central Personnel.
RECOMMENDATION 24 Hire a personnel clerk to prepare and
follow up the necessary paperwork for creating job descriptions
and hiring people. This clerk should be able to relieve existing
AMS administrative staff of the burden of such work.
Specific recommendations relative to communications:
RECOMMENDATION ?5 . Develop and implement a uniform reporting
system.
RECOMMENDATION 26 i Hold frequent and regular staff meetings
within AMS.
RECOMMENDATION 27 'Work out a set of guidelines with the
State defining responsibilities in these areas. This is
necessary to aviod duplication of effort.
Specific recommendations relative to program planning and evaluation:
RECOMMENDATION 28 Develop formal procedures for quantifying
problems, examining alternatives, identifying resources, setting
priorities, and evaluation effectiveness.
RECOMMENDATION 29 Assign a trained and competent person the
responsibility of implementing the appropriate concepts of PPBS.
This, by necessity, includes proper attention to planning long and
short-term activities.
Specific recommendations relative to land-use planning:
RECOMMENDATION 30 . Develop environmental criteria for air
pollution as measures for providing effective land-use planning
and thereby prevent or minimize air pollution and its effects. All
responsibilities delegated to the APC Board should be carried out.
RECOMMENDATION 31 Develop formal procedures for cooperation
between AMS and the Planning Commission as a first step in
introducing environmental criteria into land-use planning. AMS
should have routine advisory powers and responsibilities on a
sign-off basis in the work of the Planning Commission involving
potential air pollution.
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Specific recommendations relative to public information:
RECOMMENDATION _32_ . . Clarify control over the public information
specialist position. Ideally, the position should be permanently
assigned to the Health Department and placed under the Assistant
Commissioner. However, if City policy makes this impossible, a
written agreement should be developed between .AMS and the City
Representative's office. The agreement should state the position's
responsibilities, term of assignment (recommended indefinite),
duties, and obligations. *
RECOMMENDATION 33 Develop a comprehensive public information
program. It is essential that the goals, objectives, strategies,
and procedures be planned before the program actually gets
underway.
RECOMMENDATION 34 Make the Assistant Commissioner for AMS
more visible to the public and allow him to take a larger role
in influencing community opinion through the public information
program. Creating and filling the position of Deputy Assistant
Commissioner discussed in the Administration Section of this
report should give the Assistant Commissioner more time to devote
to such activities.
RECOMMENDATION 35 . Have the public information specialist
receive extensive air pollution training. This should include
knowledge of local, State, and Federal regulations; air quality
criteria; and the state of the art in technology.
RECOMMENDATION 36~ Locate and utilize personnel and materials
outside AMS that can aid in developing a public information pro-
gram. A large amount of such help could be provided by APCO-arid
the State of Pennsylvania.
RECOMMENDATION 37 Involve the public information specialist
in the formulation of AMS policy. This will enable him to be
knowledgeable in his dealings with the public. Also, it will
lead to consideration of public opinion in developing policy.
RECOMMENDATION 3ft- Develop lines of communications and programs
between AMS and local universities and between the public
information specialist and voluntary agencies. The need for a
technical editor for reports and public information should be
considered.
Specific recommendations relative to engineering:
RECOMMENDATION 39 . Develop specific procedures to follow up
questionnaires and data requests not returned to the agency. This
would include personal contact, plant surveys, and stack testing.
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RECOMMENDATION "40 . Develop formalized and effective lines of
communication that allow for input from the other city agencies
regarding the nature of data requested and methods of data utiliza-
tion.
RECOMMENDATION __ 41 . Reassess data needs and develop data-
gathering forms that will request all needed information regardless
of^whether there is existing control equipment or not.
RECOMMENDATION -42 . Develop a data storage and retrieval system
that will properly assist the staff in emission inventory analysis
and reporting. This information system should be coordinated-with
other AMS systems as discussed, in the Data Handling Section of
this report.
RECOMMENDATION -43 « Familarize the entire staff in the operation
and use of the filing system, in order to increase the general
availability ..of this information.
RECOMMENDATION 44 . Develop systems and procedures to keep
emission figures constantly up to date. This is discussed further
in .the Enforcement Section of this report.
RECOMMENDATION ^.5 . Develop and publish a permit manual that
stipulates the type and amount of information required duu
processing procedures employed.
RECOMMENDATION 46 . Standardize the evaluation procedure for
reviewing plans.
RECOMMENDATION 47 Increase the number of qualified personnel
available for plan review.
RECOMMENDATION ^ . Require that all engineers in the Division
gain experience in evaluating plans and specifications. The
reviewing engineer, in conjunction with enforcement, should conduct
final inspection and make recommendations for approval or denial.
RECOMMENDATION 49 . Develop a specific schedule based on an
appropriate priority system for the submittal or improvement plans
that will include all the major sources in the City on a staged
basis.
Specific .recommendations relative to enforcement:
RECOMMENDATION 50 . Require that inspectors receive periodic
training in reading visible emissions on at least an annual
basis.
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RECOMMENDATION 51 . Acquire a communications system for the
exclusive use of the AMS.
RECOMMENDATION 52 Purchase additional appropriate simple
pollutant-detection equipment for all inspectors to use
routinely.
RECOMMENDATION _53 . Make arrangements for inspectors to
receive and investigate complaints expediently beyond the normal
working day.
RECOMMENDATION 54 . Assign specific objectives and priorities
for the control of particular pollutants. Having chosen the
desired pollutant levels, the agency's enforcement procedures
should be structured accordingly.- The AMS should, therefore, develop
a formal enforcement plan to achieve the levels, through a
systematic and scheduled control effort.
RECOMMENDATION _55 . Develop a manual for the administration of
the licensing system. (See -Appendix E ).
RECOMMENDATION 56 Make emission estimates part of plan
review and. licensing of existing equipment. This will serve as a
mean? to constantly update the emission inventory.
RECOMMENDATION 57, . Develop administrative procedures for
implementing air pollution warning, alert, and emergency procedures.
All persons affected by these plans should be notified in advance
of their responsibilities in emergency situations.
Specific recommendations relative to technical services:
M.
RECOMMENDATION .5.8 . To coordi nate efforts, develop program
goals, and improve communications, set up scheduled staff meetings
on a reasonable frequency to include heads of the Laboratory and
other divisions and the Assistant Commissioner for AMS. Refer to
Section on Communication.
RECOMMENDATION 59 . Recruit and assign additional manpower to
program functions as shown in the Technical Services portion of
Table 8-2. This table is a summary of estimated future manpower
needs for the agency.
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RECOMMENDATION 60 . Increase the number of intermittent sampling
stations consisting of high-volumes and 24-hour gas bubblers to
more closely correspond with APCO |:s., guidelines in accordance with
data needs.
RECOMMENDATION _<61 . Limit the telemetered continuous monitor-
ing network to the ten stations for which money has already been
committed. The proposed additional six stations should not be
considered or added at this time.
RECOMMENDATION _-62 • Re-design station locations to take into
account population and emission patterns. Statistical techniques
should be used to locate the stations.
RECOMMENDATION \6-3 . Perform additional analyses on some high-
volume filters. The more common ones are benzene solubles or
combustible carbon content, nitrates, chlorides, polynuclear
aeromatic hydrocarbons (carcinogens), and metals.
RECOMMENDATION ,64 . Write formal laboratory procedures so
that any competent chemist could duplicate the analysis. These
procedures should reflect the latest work by- APCO in the develop-
ment of standardized laboratory procedures.
RECOMMENDATION -65 . Recruit a chemist with experience or
provide training in the use of a gas chromatography to make use
of the existing laboratory equipment.
• .
RECOMMENDATION . Implement sampling and analysis procedures
to obtain background data on pollutants for which criteria
documents are forthcoming. Table 5.1 provides a listing of these pol- '
lutants.
RECOMMENDATION 67 . Establish source-testing teams whose prime
responsibility is to support information arid enforcement needs.
RECOMMENDATION 68 Initiate a program of scheduled source .
tests by industrial categories on a priority basis.
RECOMMENDATION 69 Develop written standard procedures for
conducting source tests.
RECOMMENDATION 70 . Purchase enough source-testing equipment to
allow duplicate samples to be obtained without intermittent cleaning
of equipment.
RECOMMENDATION 71 . Give consideration to reorganizing the
placement of this function and assigning source testing to the
Engineering rather than the Laboratory Division.
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Specific recommendations relative to meteorology:
RECOMMENDATION 72 . Investigate and evaluate the need versus
the cost for meteorological data as required by the- Air Quality
Display Model and hold data collection to a minimum,
RECOMMENDATION 73 . Bring a full-time meteorologist and one
or two technicians on board to implement the meteorological aspects
of the AMS.
RECOMMENDATION 74 Make some provisions for the Meteorology
Section to give meteorological advice on weekends or at night
during periods of high pollution potential.
RECOMMENDATION _75 . Start the modeling portion of the meteo-
rology program slowly and develop expertise in proven methodologies
before attempting more sophisticated, costly, and unproven methods
of air quality modeling.
Specific recommendations relative to data handling:
RECOMMENDATION • Begin detailed planning for information
systems to process, store, and utilize all types of data
immediately.
RECOMMENDATION 7'7 Assign one person within AMS with the
responsibility for.planning, coordinating, developing, and
implementing all AMS information systems. This should be his only
job, and other staff members should be assigned to him as
necessary.
RECOMMENDATION 7-8 Double the core memory capacity of the
computer. The additional core capacity is necessary to simultaneously
accommodate the two data systems. Magnetic-type-handling capability
should be added to the computer system.
RECOMMENDATION _79 Contract with IBM or another competent
computer programming firm to reprogram the computer's operating
system so it can simultaneously accept real-time data from both
the hospital and the air-monitoring systems. This could be
accomplished through the Health Department. Better computer access
as indicated should be a major effort of AMS in improving its
data-handling system.
RECOMMENDATION 80- Review air quality data needs carefully
with the goal of justifying storage of historical daily averages
only.
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RECOMMENDATION 81 Keep historical air quality data in machine-
readable form on either disc or magnetic tape. Historical data
should not be stored on cards. The amount of data involved would
make cards cumbersome, prone to loss or damage, and space con-
suming.
RECOMMENDATION 82 Begin detailed planning for the data-
analysis programs at once. In planning the data-analysis programs
and-..reports, careful study should be made to determine the needs
of cdata analysis. Often these will differ from what users say
they.'.would like. Only a "minimum amount of data should be printed.
RECOMMENDATION .8.3 Begin work on writing the specifications
and".-.actual programs for data analysis. The Water Department has
an .'IBM 1130 Computer that uses the same programming language
as <1:he 1800. This computer can be used to test programs until
the.-1800 is ready to begin processing air pollution data.
RECOMMENDATION 84 Add a computer programmer to the AMS
staff. During initial development of the air quality system, he
can-be assigned to writing some of the data-retrieval and data-
analysis programs. This will leave existing staff with more time
to ylan and coordinate the entire project. Later he would devote
much of his.time to writing programs for special data-analysis
studies. viAv^ilnbility of data for sudi studies was one of the
reasons for development of ~this system in the first place".
RECOMMENDATION 85 . Begin planning now for development of
information systems for emission inventory and permit and license
data.. This is necessary to facilitate storage and use of the. data
when it starts to be received in the near future.
RECOMMENDATION _8(x . Design a storage and retrieval system for
emission inventory data so that a complete emission inventory for
the. City can be calculated and periodically updated.
RECOMMENDATION 87 . Develop a filing system to coordinate.data
from:.
1. Complaints
2. Emission inventory
3. Enforcement actions
4. Permits and license
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4. AIR POLLUTION PROBLEMS
Air pollution in the City of Philadelphia is a result of heavy concentra-
tions' of people and industry within the City. About two. million people live in
an area, of 127. square miles. The density of automobiles is correspondingly
high-'
About 4,600 manufacturing establishments, over 300 of them with more than
100. employees, are located in Philadelphia. This is about 25 percent of the
number of manufacturing plants in the entire State of Pennsylvania. A large
portion of this manufacturing is heavy industry.
Sampling data reveal pollutant levels to be quite high. The annual mean
levels, for suspended particulates and sulfur dioxide during 1969 were 118
micrograms per cubic meter (u/m^) and 0.07 parts per million (ppm) respectively.
A detailed emission inventory is currently underway and is discussed
elsewhere in this report. Present data are based on a rapid survey emission
inventory performed in 1969 for the Philadelphia Air Quality Control Region
Consultation Report. Another emission inventory, also primarily a rapid survey,
was compiled by the City of Philadelphia in 1966. These results are summarized
in Table 4-1. .
1 f 1J v r>V ¦> Ho om i C c 1 Anc Qmninif S I)'1"* Mt 373 0^^ Anc por y ft Q v» ^
Electric Company's power plants contribute about 1/3 of this amount. Fuel
combustion from stationary sources and process emissions is the source of most
of the rest.
About 70,000 to 80,000 tons -of particulates is emitted annually. Most of
the total comes from industrial processes and stationary sources. An estimated
10 percent of the particulates (20 percent in the 1966 City study) comes from
Philadelphia Electric Company's power plants.
Carbon monoxide is the pollutant emitted in the largest quantity, some
800,000 to 900,000 tons per year. About 2/3 comes from motor vehicles. Much
of the remainder is from industrial processes, primarily refineries and chemical
plants.
Emissions of nitrogen oxides and organics (hydrocarbons) have also been
estimated. About 100,000 tons per year of nitrogen oxides is emitted, 1/3 from
motor vehicles and 1/3 from power plants. Of the estimated 200,000 tons per year
of organics, about 2/3 is emitted from motor vehicles and the rest from the
refineries and chemical plants.
Odors are also a singificant problem. The refineries, chemical plants, and
rendering plants are the major contributors.
-------
Pollutant '
Total
Tons/Year
Fuel Combustion
Stationary-Sources. %
Power
Plants, 7,
Process
Losses, 7,
Was te
Disposal, 7,
Mobile
Sources, %
Sulfur dioxide a
375,000
28
33
33
- '
5
Particulates 11
80,000
30
11
44
'4
10
Carbon Monoxide
830,000
2
-
33
1
64
Nitrogen oxides
110,000
30
30
11
1
27
„ . b
Orgamcs
200,000
3
26
6
64
a - Consultation Report
b - 1966 Philadelphia Emission Inventory
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-16-
5. LEGAL
5.1 Legal Authority
Philadelphia's Air Management Code, adopted on October 20, 1969, is a
modern up-to-date ordinance. It contains very strong enforcement powers and
penalties. The section on legislative findings is veil written and contains
strong language in policy regarding non-degradation of air quality. The defini-
tions of air pollution nuisance and the restrictions on open burning are also
good..
Section 3-103 Item (5) specifies penalities for violation of the Code or
Regulations. The maximum fine is $300. The State has recently amended its
lav/, to increase the maximum fine to $1,000.
RECOMMENDATION 1 Amend Section 3-103 (5) to increase
maximum fines to $1,000, at least for the first offense.
Section 3-301 Item (22) requires that the Health Commissioner, or his
designee, shall administratively hear appeals to orders of the Department. This
meeting should serve as an office conference or review. In practice, this means
that the Assistant Commissioner for AMS hears and decides on appeals from orders
issued by his organization with his approval. The recipient of the oi'der does
have an ultimate appeal to the License and Inspection Review Board, which is
independent from Air Management Services.
While such a perfunctory review procedure is not the best arrangement and
can lead to unnecessary delays; it has.some advantages. The administrative
hearing is useful because it operates similar to a show-cause hearing. The
recipient of the order is required to divulge his case and evidence at the hearing.
Having access to such information should assist AMS in prosecuting its own case
before the License and Inspection Review Board.
Section 3-302 of the Code defines the powers and duties of the Air Pollution
Control Board. While many of these duties are advisory in nature, the Board
does have considerable power in promulgating regulations both to control emissions
and adopt air quality standards. In practice, the Boaird has been asked to
approve regulations after they have been drafted rather than to actually write
the regulations. It is conceivable, however, that the Board could delay or not
approve regulations it did not find acceptable.
Hie composition of the Air Pollution Control board is spelled out in Section
3-902 of the City Charter. The Board consists of seven members, four of whom
must be representatives of specified industries. Because of its power in
adopting regulations, it is inappropriate that a majority of the Board be
comprised of industry representatives.
RECOMMENDATION 2 . Reconstitute the Air Pollution Control
Board so (hat it is an objective and impartial representative of
the entire community. Board Representatives having substantial
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-17-
financial interests tend to disregard public interest and
welfare.
Item (2) of Section 3-302 of the Code deals with the adoption of air
quality objectives. The paragraph allows different air quality levels in
different parts of the city.
RECOMMENDATION 3 Modify Item (2) of Section 3-302 by
deleting "to establish areas where objectives are applicable"
so that air quality goals for the entire city will be uniformly
beneficial. Reasonable time schedules for achieving the uniform
objectives should be set in those parts of the city rather than
allowing less strict objectives at the sacrifice to air quality.
In addition, such objectives must be consistent with the
provisions of the Implementation Plan for the Philadelphia AQCR.
Under provisions of Section 3-304 concerning inspections, AMS may allow
a private agency or industry to make its own inspections and determine its own
compliance.. AMS retains the right to make its own inspections. This provision
can.be useful,, but care must be taken to insure that it is properly administered.
Regulations I, XI, and lii dealing with General Provisions, Particulate's, cr.d
Sulfur Oxides became effective on April 29, 1970. A regulation governing
incinerators also exists. These regulations are adequate to control the pollutants
they concern.
Regulation II, Section V, governs emission of particulates from fuel-
burning equipment. The limitations are expressed in terms of pounds of particulate
per thousand pounds of stack gas. This approach is indirect and can contribute
to confusion in its application.
RECOMMENDATION 4 . Express emission limitations in:this regu-
lation in terms of pounds/hour or pounds/million Btu of heat in-
put. : In "addition, modify or replace the emission standard for
existing equipment, subsection (2), by a standard that varies with
the.size of the installation.
Regulation III.limits sulfur oxide emissions. The sulfur levels ultimately
allowed in fuels are the same as those allowed by New Jersey. Philadelphia's
time schedule for implementing these limitations is behind.that of New Jersey.
RECOMMENDATION 5 . Express the limitations on emission of
sulfur dioxide in Section XA (2), Non-Commercial Fuel, in terms
of pounds/hour or pounds/million Btu of heat input. The comments
made with reference to Regulation II, Section V, also apply here.
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The incinerator regulation is good. It includes design standards as well
as .'emission limitations. Testing procedures, however, have not been standardized.
RECOMMENDATION (•>' Specify standard test methods for testing
new .incinerator designs for compliance with the regulation.
Maintenance support requires that the agency have legal authority to control
emissions within its jurisdiction. This means all pollutants as well as all
sources. As mentioned in the discussion of Philadelphia's air pollution problems
elsewhere in this report, hydrocarbon, carbon monoxide, and odor emissions are
significant.
RECOMbffiNDATION 7 . Develop regulations for control of
hydrocarbons, carbon monoxide, and odors. Federal criteria
documents for hydrocarbons and carbon monoxide are currently
available, and should be utilized in developing regulations.
CFR 56.31 (2)(1) for maintenance requires that sources contributing to air
pollution within a jurisdiction be controlled even though they are located outside
Chat.: jurisdiction bt>f in the same state. In this case, such sources, if any exist,
must be adequately controlled by the State of Pennsylvania before Philadelphia
can receive maintenance support.
•
RECOMMENDATION 8 .Work with the State to develop plans for
the State to control emissions from sources outside of Philadelphia
that contribute to ^ir pollution within the City.
5.2 Legal Operations
Air Management Services and the Health Department have no legal staff. The
Law Department supplies necessary legal services to all other agencies of City
government. AMS works with the Counseling and Enforcement Divisions of the
Legal Department. The Counseling Division provides general legal advice to the
Enforcement Division, which prosecutes all air pollution violators.
Enforcement activities involving legal prosecution is one of the key areas
in carrying out AMS' program to obtain compliance with emission regulations. To
date, however, the agency has had inadequate legal service.
RECOMMENDATION 9 - , Obtain additional'legal support. The agency
needs an experienced attorney who is familiar with air pollution
problems. In addition, a close working relationship with the
Counseling Division should be developed.
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This experience can best be gained by having the individual work within the
program for a while. In addition to preparing and prosecuting cases, this
attorney should work with AMS staff to teach them proper procedures to testify in
court and maintain records.
There are two ways this recommendation could be achieved:
1. AMS could hire a lawyer as a member of its own staff.
2. The Law Department could assign an attorney exclusively to AMS.
The second alternative, having the Law Department assign an attorney to
AMS, seeins preferable for several reasons. There is a City policy prohibiting
operating programs from having their own attorneys. While a similar policy for
Public Information Personnel was waived for air pollution (Section 12 of this
report on Public Information), such an achievement would be difficult to repeat
and could cause resentment within other areas of the City government. Secondly,
the Law Department would probably be more agreeable to having one of their attorneys
assigned to AMS. Also, this alternative would not tend to isolate the attorney
from his professional group.
The Counseling Division of the Legal Department is responsible for providing
ffeneral, assistance with nnnl'r.io i-r . nrnrpdnvcs rponlHl'inns. and nl"tifr
' " " "* i i t ^ ........ ^ .
matters. This does not include aid in preparing legislation, however.
AMS has received only a limited amount of help from the Counseling Division,
largely because the Division is understaffed. One man has been assigned to the
entire Health Department, and he is only able to spend 1 to 2 hours per week on
air pollution control activities. Because of his workload, he is unable to work
actively with AMS during the development of legal documents. He sometimes
reviews them after the fact, which is far less effective.
AMS should have far more help from the Counseling Division in developing
enforcement procedures, writing contracts, extending regulations, and so forth.
The Counseling Division may need to expand its staff in order to provide such
help. This would also be helpful in providing backup support because, at present,
there is only one person within the Division who is at all knowledgeable about
air pollution. AMS should also work to brief the staff of the Counseling
Division on the health and technical aspects of air pollution control. One man
should be assigned full time from AMS to work with the Counseling and Enforcement
Divisions of the Law Department.
The Counseling Division is presently very concerned about the need to develop
expert testimony on the health effects of air pollution control. They feel it
is necessary to base cases on danger to health in order to establish precedents
for prosecution of future cases, . Miile.thiK approach may be useful, it differs
from the traditional ait pollution enforcement patterns and may tend to slow
down or limit the prosecution ot violators.
The Enforcement Division of the Legal Department is responsible for
prosecuting all violations of air pollution regulations. In the past, few cases
were prosecuted. Table 5-1 summarizes cases actually prosecuted during 1968
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-20-
and 1.S69. The number of prosecutions was small (222 in 196S and only 104 in
1969), and more than one-third were either dismissed or fined court costs only.
Cases that were prosecuted were handled poorly. This was most noticeable in the
case against George Sail Metals Co. This seems to have been largely the result
of prosecution personnel changes and inexperience ill air pollution control.
There appears to be a serious problem of cooperation between AMS and the
Enforcement Division. The AMS staff says that the Enforcement Division is
reluctant to prosecute, and that the legal staff is not eagerly pushing cases,
is unfamiliar with air pollution control, and is generally.less skilled than
legal counsel representing the defendents. They also say that the Enforcement
Division complains about the lack of good medical testimony and wants to base all
cases on the health hazard, issue. AMS should work with the Counceling Division
to move away from.proving probable health hazards as a primary requirement for
prosecution. Other lines of evidence, based on proving violation of the regulation,
merely by showing emission of pollutants, should be developed. Health damage is
difficult to prove and should be used only as supporting proof. The APOD. Air
Quality criteria should be used to help establish proof of health damage.
The point of view expressed by the Lav; Department is somewhat different.
A new Deputy City Solicitor has recently been appointed, and he seems sympathetic
toward AMS' problems. The Enforcement Division says ii: is willing and wants i:o
prosecute all air pollution cases, whether or not they involve health hazards~
but that AMS is not sending the cases to be prosecuted. One attorney, a half-
time employee, is currently assigned exclusively to air pollution control. The
Division says it will hire as much staff as is necessary to prosecute all .
air pollution cases..
This report does not attempt to reconcile these two points of view. It
appears that a communication problem exists, and it is important that it be
worked out. AMS should come to an understanding with the Law Department and
develop operating procedures for prosecution of cases. An aggressive enforcement
effort should be launched. All available legal assistance in the city, including
the District Attorney's office, should be utilized, and a formal plan of
cooperation should be developed.
As discussed above, one of AMS' problems is the City Attorney's lack of
knowledge about air pollution control. APCO has issued criteria documents for
various pollutants and other literature that would provide information to help
solve this problem.
AMS should be sure City Attorneys concerned with air pollution have APGO.
criteria documents and other publications and are aware of the information con-
tained in them. The attorneys should be kept up.to date as new documents are
issued. This should be one of-the responsibilities of an AMS man assigned to
liaison with the Legal Department.
The Code provides three methods of enforcement:
1. Convictions resulting in fines of up to $300 can be sought in
Municipal Court.
2. Administrative abatement orders can be issued.
3. Injunctions can be sought in courts of equity.
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Table 5-1
COURT CASES 1968 AND 1969.
1st
2nd
3rd
4th
V
Disposition
Year
. qtr....
qtr-..
qtr.
qtr.
Total
Costs only
1968
12
6
5
24
47
1969
0
0
0
0
0
§ 10 + costs
1968
0
0
0
0
0
1969
0
0
0
4
4
$ 25 + costs
1968
13
27
15
21
76
1969
0
0
1
6
7
$ 50 + costs
1968
13
.. 7
28
12
60
1969
0
0
15
2
17
$ 75 + costs
1968
0
0
0
0
0
1969
0
0
0
1
1
$ 100 + costs
1968
0
1
18
6
25
irt/cn
n
o
0
11
11
$ 300 H- costs
1968
0
0
0
0
0
1969
0
0
0
11'
11
Discharged
1968
0
0
0
0
0
1969
0
0
10
9
19
No service
1968
0
2
8
1
11
1969
0
0
. 4
1
5
Withdrawn
1968
3
0
0
0
3
1969
0
0
1
1
2
Total
1968
41
43
74
64
222
1969
0
0
31
73
104
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-22-
rrosccution in Municipal Court: and the seeking of injunctions require the services
of the City Law Department. The administrative order procedure does not; it was
created specifically so the Law Department would not be needed.
Occasional or minor violators can be prosecuted in Municipal Court. A
complaint, based on a violation observed by an inspector, is signed by the Director
of the Compliance and Enforcement Division, approved by the Assistant Commissioner
for Air Management Services, and sent to the Lav; Department for prosecution.
The judicial system in Philadelphia has not been provided with sufficient
information regarding air pollution control. As a result, prosecution has not
been too successful. In the past, small fines were levied if convictions were
obtained at all. Re.cently, however, this situation has improved, and some
significant fines have been levied.
RECOMMENDATION L~Q . Use the enforcement method through seeking
conviction and fines in Municipal Court only for minor and infre-
quent violations. This is because the procedure makes 110 provision
for long-term compliance with regulations or abatement of air
pollution.
Administrative abatement orders are a second method of enforcement. AMS
favors this approach because the Legal Department does not become involved.
The procedure is somewhat cumbersome, however.. The order is prepared by the
Director of the Division of Compliance and Enforcement, with approval of the
Assistant Commissioner for Air Management Services, and the Health Commissioner
is notified. A schedule for compliance with regulations is spelled out in the
order. As discussed in the review of the Code, the recipient can request an
administrative hearing for review of the order.
If the order or the compliance schedule is disregarded, steps may be taken
to revoke the offender's license for operating the polluting equipment. The
Di rector of the Division of Compliance dnd Enforcement notifies the Assistant
Commissioner of the non-compliance. The Assistant Commissioner in turn can re-
commend, to the Department of Licenses and Inspections that the license be re-
voked.
Any license revocation may be appealed to the Board of License and Inspection
Review. This is an independent agency specified by the City Charter. The
existence of this independent board to ultimately hear appeals from air pollution
abatement orders removes some of the previously mentioned objectives to having
the Assistant Commissioner first hear those appeals to his own orders.
As specified in the Charter, the Board of License and Inspection Review is
composed of between three and six members. The Board hears appeals to all types
¦>f license problems, not merely those for air pollution. As a result, the
-------
-23-
Board has no particular expertise' in air., pollution -control. Creation of a
separate Air Pollution review board would 'be desirable5 but would require amending
the City Charter. This would be difficult at best. While, the present procedure,
for appealing air pollution abatement orders has some disadvantages, it: appears
to be satisfactory.
These enforcement procedures have been worked out by AMS. However, they
are still in draft form and are, at present, untried.
If the Abatement Order procedure discussed above fails to achieve com-
pliance, another enforcement tool is available. This is to seek an injunction in
Common Pleas Court, This is undertaken by the Lav.' Department upon the request
of the Assistant Commissioner with the approval of the Health Commissioner.
Injunctions should be sought immediately against the major polluters instead of
trying to achieve compliance first with administrative abatement orders. A court
order carries greater respect than an administrative order. Furthermore, if
compliance is not achieved, the administrative order procedure leads, after much
delay, to the seeking of a court order anyway. .
A final point to be considered in discussing legal operations is State
certification. Pennsylvania State lav; grants exclusive jurisdiction to a local
air pollution control.agency only if that agency has been certified by the State.
Lack of certification means that the local agency auu the State would both have
concurrent jurisdiction over sources within the local jurisdiction.' Such an
arrangement can only lead to confusion. The Philadelphia agency has recently
been certified by. the State.
While the State has granted AMS exclusive jurisdiction in the City of
Philadelphia, this relationship is complicated by Federal legislation. The
Clean Air Act of 1.967 defines the Air Quality Control Region Concept and makes
the states ultimately responsible for air pollution control within Regions. The
State is required to prepare an Implementation Plan defining the means to be
used, to actually control air pollution. This plan may call for the local agency
to contribute significantly to the control effort, but the State is ultimately
held responsible for the results.
The. City, of Philadelphia is, of course, a part of the Philadelphia AQCR.
The State law. that grants control responsibility to AMS by means of certification
is inconsistent with the Clean Air Act. Because of this overlapping authority,
the State and AMS must have effective communications and a good working relation-
ship. During this study, it appeared that neither agency relied to any great
deal, on assistance from the.other or had information on what the other program
was doing, in Philadelphia. The Communication Section of this report recommends
more- effective, communications between the two agencies.
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6. ORGANIZATION
6.1 Prior Study by United States Public Health Service (USPHS)
In 'July,' 1967, a study was made by'James Williams of the USPHS entitled.
"Philadelphia Air Resource Management Program Suggested Organization." It
is appropriate to discuss that study at this time because many of the existing
program characteristics, and the., present, organizational structure of AMS were,
recommended by Williams.
Not all of Williams' recommendations have been carried out. However, a
, discussioa of those earlier recommendations can provide a benchmark from which to
begin the present study of the. organization, of AMS program. It is possible, to
review the progress made in the past 3 years and recommend further improvements
in .line with the purpose of this report discussed in the introductory section.
It was recommended that'the basic organization consist of a director and
three divisions. The program director was to become an Assistant Commissioner
with ability to influence City decision-making bodies. Further support to the
organization would be provided by a staff type group. Task forces were to be
created and assigned 'to study and reslove internal problems. The organizational
re-alignment has. been carried out., but the task force concept has not.
The"1967 report indicated that budget, fiscal, and other administrative
services centralized within the Health Department should be responsive to air
resource program goals and needs.- The. present, study has-found that this is not
always the. case.
The. program suggested by Williams was goal-oriented and management-directed.
At that time, the City of Philadelphia was instituting a Planning, Programming, and
Budgeting System. The PPB System was to provide the principal management tool
needed. . However, to use the.tool, management skills had to be developed in the
organization. Neither the system nor the skills have been developed by AMS.
Further utilization of educational institutions for research, training,
contracts, and special projects was recommended. The Air Pollution Control Board
was to be directed toward policy matters to ensure (a) establishment of air
quality goals, (b) enunciation of those goals, (c) program implementation, and
(d) provision of clear understanding and smooth implementation. Continual
examination to provide new initiative and action to reacfi program objectives was
also a recommended function.
6.2 Present Organization
In 1968, AMS was reconstituted as a separate organization, one of three
services within the Department of Public Health. AMS consists of three divisions
and.a staff support group, and is headed by an Assistant Commissioner. Additional
support for AMS is provided by the Office of Adminis t rat ion and Community Health
Services within the Health Department, the Law Department, and the City Repre.sen-
tative's office..
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-25-
It was evident: that the. Commissioner of Health strongly'supports AMS.
However, there is concern that the Assistant: Commissioner for AMS does not have
sufficient departmental responsibility and ability to influence City decision-
making bodies. Such power was recommended in the 1967 PHS report. The Health
Commissioner wants.to delegate more responsibility to AMS, and appears to be
working.. .in that. direction.
The. Assistant Commissioner for AMS has a huge job. In addition to working
with. City, decision-making bodies as discussed above, he is responsible for
numerous other functions, both inside and outside of AMS. Elsewhere in the
report it is recommended that he take a 'more active role in the public information
program.. Obviously,, all of this is too much for one man.
RECOMMENDATION 11 . Allow the Assistant Commissioner more time
to work with, organizations outside AMS, both inside and outside
City, government, To accomplish this, three alternatives are
proposed.
1. . Establish and fill the position of Deputy Assistant
Commissioner; he should be responsive to the needs of AMS and
chosen by the Assistant Commissioner.
2." . Delegate most responsibilities to the Division Director
and choose vsoaieiaijc.ujrc net. ir. the capacity of Assistant
Commissioner vhen he is out of the office.
3. .Hire a chief administrative assistant to coordinate all
staff functions as well as line functions and problems.
However, .at all times there should be sufficient access to the
Assistant Commissioner by the Division Directors to express
grievances.
The Assistant Commissioner's Staff support group includes specialized tech-
nical and administrative people whose specific responsibilities cover broad areas.
These include administration, project management, planning, information management,
training, and public information. The specific functions and the personnel assigned
to each for the staff support group and the three divisions of AMS are listed in
detail in Appendix D.
The three operating divisions are Engineering, Compliance and Enforcement,
and Laboratory. The Engineering Division is composed of two sections according
to the approved AMS organization chart, Figure 6-1.' The Division actually
operates on the basis of three sections. This discrepancy is unsatisfactory for
purposes of program planning and division of functional area of responsibility.
The three sections are Emission Inventory, Permit Approval, and Industrial
Improvement. The first two are combined on the organization chart. The functional
descriptions for the Division were outlined-in a 1.969 report. A similar descrip-
tion for the Compliance and Enforcement Division was written In 1970 and contained
considerably more detail.
-------
-26-
Figure 6-1
ORGANIZ AT IONAL C PiAIlT,
FOR CITY OF P)lT:LA])EI,PIiIA
DEPARTMENT OF PUBLIC HEALTH
AIR MANAGEMENT SERVICES
Figure 6*1. Oiganizationa! chart- for city of Philadelphia, Department of Public Heaiih, Air Management Services.
-------
- 27-
RECOMMENDATION ^ . Update the Engineering Division's functional
description to include functional categories, staffing, goals,
objectives, and time schedules to meet program objectives.
The Compliance and Enforcement Division is composed of two sections:
(1) Compliance and Surveillance and (2) Enforcement. The Compliance and
Surveillance Section, which supervises AMS' staff of inspectors, has divided the
city into three districts for field work purposes. The rest of the Health Depart-
ment uses a ten-district basis. As a result, AMS has staff located in only three
of the Health Department district offices.
The Laboratory Division has two sections: Analysis and Field Operations.
There was no program plan information available from the Division with defined
areas of responsibility for each section. This is a very unsatisfactory situation.
It has been recommended elsewhere in this report (see Technical Services) that
consideration be given to transferring the Laboratory Division's stack-testing
function to the Engineering Division.
The Office of Administration of the Health Department provides fiscal,
personnel, and analytical program support to AMS. In the fiscal area, the
Office of Administration audits, manages accounts, and administers the budget.
It appeared that Administration exerts too much control over budget affairs as
they affect program activities.
In the personnel area, the Office of Administration serves as a link between
AMS and Central Personnel. There have often been extensive delays in receiving
job descriptions, creating job classifications, and hiring people. This is
particularly true in non-professional areas. The Office of Administration has
been, at times, almost a line function over AMS setting its staffing priorities
rather than acting as a staff support group, which would.help push through
paperwork necessary for AMS to hire the people it wants. However, Central
Personnel has also been responsible for many of the delays in processing AMS'
personnel actions. These and other personnel problems are discussed in more de-
tail in the Manpower Section of this report.
The Office of Administration is also responsible for maintenance, duplicating,
and petty cash. These services have been generally unsatisfactory. AMS has
experienced serious delays having lights replaced, windows fixed, cleaning, and
other maintenance services. Delays of several days in duplication of documents
are common. As there is no petty cash fund, even small items must be ordered
through formal purchasing channels.
Environmental Health Services also provides some support to AMS. However,
the relationship is unclear. The organization chart dated 12/31/68 (see Figure
6-1) reveals a solid line direct relationship between AMS and EHS. An earlier
chart dated 9/6/67 showed a dotted line indirect relationship. The district
health offices, three of which are vised by AMS Compliance and Enforcement field
staff, arc; EHS facilities. With the exception of using office space in EHS
facilities and doing some radiological analysis and high-volume samples, AMS
scums to have little contact with EHS. This relationship should be clarified.
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6.3 AMS As A Separate Department:
It has been suggested that AMS would be more effective in its efforts to
control air pollution if it was reorganized as a separate Department of the City
government. In discussing this question with .various people, both advantages
and disadvantages of such a change were mentioned. Any decision would require
a comprehensive evaluation of cost and benefit factors, available resources,
and the public and private impact of the move. Such an evaluation is beyond the
scope of this study and, without it, the only reasonable approach is to merely
list the advantages and disadvantages of the change:
ADVANTAGES
1. There is considerable, prestige in being a separate department and being
able to negotiate at department level.
2. Air pollution control would be the sole activity of the new department.
It would not have to compete for priority with other programs within the
Health Department.
3. As Commissioner of Air Pollution Control, the head of AMS would have
full responsibility .fox all.•¦cc.atrol activities.
4. Air pollution can be treated as a legal and an engineering problem
and not be clouded by "health hazard" connotation.-
5. Air Pollution Contro.l could exert more control over personnel and fiscal
functions.
6. Positions can be upgraded as necessary to give, better salaries and pro-
motion potential. This would facilitate the acquisition of special disciplines
used in air pollution control programs.
7. The air pollution control program would have increased visibility cto
the public and could be more responsive to public opinion.
8. Many air pollution control activities are not common to other health-
related activities. Examples include, review of engineering plans, monitoring
of contaminants, source testing, inspection of technical processes, and code
enforcement by injunction or other legal means. A separate department would
allow AMS to set up its own programs and methodologies for its activities.
9. Air Pollution Control Agencies must be more enforcement-oriented than
Health Departments are by basic policy and philosophy.
DISADVANTAGES
1. The smaller department or organization would have less influence and re-
ceive less administrative support from the City bureaucracy.
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2. Results are frequently achieved within a City structure through a
system of trade offers. A new department v?ould have no stock of such
goodwill with which to bargain.
3. j Overhead operations in functional areas of personnel specialists and
fis:ca.l. officers can be overly burdensome to a small organization.
A. - There is an element of safety in budget support as part of a larger
Department, or organization available to AMS through the Health Department.
5. : The actual process of revising the City Charter and creating the new
agency could be quite time-consuming and may delay or disrupt abatement of
air pollution for. sometime.
Another trend in organizing, pollution control efforts is emerging around
the county. This is a creation of combined environmental control agencies with
responsibility for air, water, and land conservation. Such a possibility for
Philadelphia was not evaluated by this study for the same reasons thst no recom-
mendation was made about creating a separate air pollution control department.
-------
" -30-
7. BUDGET
Since 1965, the City of Philadelphia has received grant support: for its air
pollution control program. The agency is .now completing its second: 3-\year
improvement project. A summary.of AMS grant support is shown in Table 7-1.- . In.
6 years, the total project annual budget (Federal + non-Federal funds) has.,
grown from $142,000 to.almost $1 million. These figures do not include funds
that are not eligible for Federal matching. These "Program Exclusive of Project"
funds:add another $240,000 to .the agency's budget during the present fiscal
year;
Table 7-2 shows a breakdown of the budget by functional activity. The
allocation shows heavy emphasis on engineering and enforcement. Engineering
utilises 43 percent of the budget. . This percentage is high because air monitoring,
laboratory, and technical services have been included in this category. Enforce- •
ment consumes 38.percent of the budget while only 19 percent is devoted to
administration.
Future staffing and calculated budget needs were projected for AMS. This
estimate is discussed in the Manpower Section of this report. It was estimated
that a total of 125.5 people are needed by FY 1974. Table 8-2 projects the
progressive buildup of the staff:and the allocation of manpower to .various program
functions.
The effects of this.size.staff on the agency's budget are estimated in
Table 7-3. The total required budget for FY.1974 would be about $1.5 million.
AMS!. present budget (project grant for FY 71 plus program exclusive of project
funds) is about $1.25 million.. This is about what the projection forecasts will
be required by FY:1972. A budget expansion of about 20 percent will be required
by FY 1974 to reach the required manpower and activity levels projected by APCO.
-------
Table 7-1.
PHILADELPHIA FINANCIAL RESUME:
FEDERAL GRANT PROJECT FUNDS
Date
Type
Non-Federa L
Federal
Total
:
Remarks .
1/1/65-12/31/56
Imp. a
47,540
95,079
142,619
Expended
1/1/66-12/31/67
Imp. a
62,654
125,307
187,961
Expended
1/1/67-6/30/68
Imp. a
121,667
' 243,334
365,001
Expended
7/1/68-6/30/70
Imp. k
164,578
392,115
556,733
Expended
7/1/69-6/30/70
Imp. b
• 298,572
, 597,143
895,715
Budgeted
7/1/70-6/30/71
t b
Imp.
332,988
655,975 J
998,963
Budgeted
a - 42-month Improvement Grant 6/1/66-6/30/6S.
b - 36-month Improvement Grant 7/1/68-6/30/71.
-------
-32-
Table 7-2.
PERCENTAGE OF TOTAL PROGRAM
BUDGET RELATING TO ELEMENTS
IN THE AIR POLLUTION CONTROL ACTIVITY
Air pollution activities
Fiscal
year
1970
1971
I. General enforcement
xxxx
xxxx
1.
Complaint processing
2
2
2.
Inspection
20
18
3.
Prosecution
5
5
4.
Stack sampling
1
5
5.
Clerical
4
3
6.
Administration
6
3
7.
Other
38
36
CI. General engineering and analysis
xxxx
xxxx
1.
Plan review
2
3
2.
Permits
2
2
3.
Source survey or registration
4
2
4.
Emission inventory
4
3
5.
Code preparation
i
1
JL
6.
Public technical assistance
-
-
7.
Planning
1
1
8.
Air monitoring
-10
10
9.
Laboratory
10
9
10.
Data processing
4
9
11.
Meteorology
1
3
12.
Administration
3
2
13.
Clerical
1
1
14.
Other
43
46
CI. General administration
xxxx
xxxx
1.
Management and planning
8
6
2.
Local assistance
-
-
3.
Public information
3
3
4.
Accounting
1
1
5.
Clerical
4
4
6.
Training
1
2
7.
Legal
1
2
8.
Other
19
18
Total
100%
100%
-------
-33-
Table 7-3.
MATED COST OF RECOMMENDATIONS
CITY OF PHILADELPHIA
1
- i
FY 1970
6
FY 1971
FY 1972
FY 1973
j
196,000
49,000
1.500
276,000
69,000-
336,000
84,000
1. SOO
378,200
94,550
1 - 500
417^$0C|
*104^406
1 «?00
,
'323,400
323,400
'323,400
327,320
327,320
80,850
2,000
80,850
2,000
80,850
4.000
81,830
2.000
81,8*0t
7 GtiQ
159,600
%
172,900
199,500
239,400
269,990
39,900
S .000
43,225
i nnn
49,875
i nnn
59,850
i nnn
67,498
i noo
105,500
125,500
L :>i •
150,500
t. .
163,500
\ 1 9
178,000
26,375
31,375
in nnn
37,625
s nnn
40,875 .
s nnn
44,400
«; nnn
1,004,125
1,136,750
1,273,250
1,395,025
1,500,638
-------
-34-
8. MANPOWER
Manpower is the. most important resource of any organization. While AMS
has experienced considerable growth in the past 2 years, additional manpower is
still required to enable the ¦¦agency to do its job effectively- This section of
the report discusses the following facets of AMS1 manpower problems;
1. Staffing requirements
2. Job descriptions
3. Salaries
4. Training
5. External constraints
8.1 Staffing Requirements
Table 8-1 shows the present number of positions on the AMS staff and their
distribution by function. Table 8-3 shows a further breakdown of the functions
performed by each staff member during fiscal year 1970. The figures in Table 8-1
reflect a fairly well-balanced control effort. Of a total of 54 people, 32 peixent
are involved in management operations, 28 percent in enforcement, 17 percent in
engineering, and 23 percent in lsfc «n
-------
Table 8-1
PRESENT AMD PROJECTED MANPOWER NEEDS
CITY OF PHILADELPHIA
PREPARED BY AMS
1970
Fiscal Year
1971
1972
Management Operations
Policy, publications, strategy,
recruitment, etc.
. 4
5
7
Staff Training
0
0
1
Administrative & Clerical
13
19
Subtotal Management
•17
24
32
Enforcement Operations
Scheduled Inspections -
fuel and refuse
1
1
5
Scheduled Inspections -
„• 3. . _ j
jli to u:> u i- y
/
10
12
Complaints arid Field Patrol
Source Identification, and
Registration
7
8
8
Subtotal Enforcement
15
19
25
Engineering Operations
Permit System
1
1
1
Source Testing
h
1
1
Emission Estimates
1%
2
2
Engineering Reports, New
Regulations
7
12
18
Subtotal Engineering
9
16
22
Technical Operations
Air Quality Monitoring
3
5
7
Special Studies
1
3
6
Data Processing
I
3
5
Instrument Calibration
5
9
12
Lab. Operations
2
5
8
Subtotal Technical
12
25
38
Total Manpower
54
84
117
-------
-36-
Table 8-2
PROJECTED MANPOWER' NEEDS
CITY OF PHILADELPHIA - AS PREPARED BY DCAD, „APCO
] 1969a
1970
1971
1.972
1973
. 1974
Man-years/100,000 Population
4.2
4.3
4.9
5.5
6.0
6.3
Management Operations
Policy, P/R, Strategy,- Recruitment
4.0
6.0
8.0
9.0
10.0
11.9
Staff Training
0
1.0
3.0
5.0
6.0
6.5
Administrative, Clerical
17.0
15.0
18.0
20.0
22.0
22.0
Subtotal. Management3
21.0
22.0
29.0
34.0
38.0
40.4
Knforcement Operations
Scheduled Inspections - fuel and
refuse
2.0
2.0
3.0
3.0
4.0
4.0
Scheduled Inspections - industry
7.0
8.0
9.0
9.0
9.0
9.0
Complaint and Field Patrol
21.0
21.0
21.0
21.0
21.4
21.4
Sonrro -Pi nutlcn
Registration
3.0
2.0
1.0
0
0
0
Subtotal Enforcement3
33.0
33.0
34.0
34.0
34.4
34.4
Engineering Operations
Permit System
2.0
3.0
5.0
7.0
10.0
11.8
Source Testing
0.5
1.0
1.0
2.0
2.0
2.5
Emission Estimates
1.5
2.0
2.0
2.7
2.7
2.7
Reports, New Regulations
8.0
6.0
5.0
3.3
3.3
3.3
Subtotal Engineering
12.0
12.0
13.0
15.0
18.0
20.3
hnical Operations
Air Quality Monitoring
5.0
5.0
6". 0
7.0
8.0
9.0
Special Studies
1.0
2.0
2.0
3.0
3.3
3.3.
Data Processing
2.0
2.0
3.0 •
4.0
4.9
4.9
Instrument Calibration
5.0
6.1
6.1
6.1
6.1
8.0
Laboratory Operations
2.0
3.0
4.0
5.0
5.2
5.2
Subtotal Technical
15.0
18.1
21.1
25.1
27.5
30.4
Total Manpower, Philadelphia
81.0
85.1
91.1
107.1
117.9
125.5
fl - Budgeted (there are presently 27 vacancies).
-------
I
Tabl.-s 8-3 1
Fiscal Year 1970 Manpower Survey Sheet j
STAFF
1 Asst. Health
! Commissioner
Percent Assigned to
Program
c
lotal
shoul
wd ec
[ual
100'/
i of time
and eff
ort in
each fu
netion)
CJ
>
•r"!
4J
rj
U
AJ
to
•r^
c
£
<
1
c
•H
O)
c
r-
oc.
c
w
•U
e
£
S
c
o
o
d
JO
¦ tc
c
*ri
r—¦1
Q_
g
c5
00
CO
CO
>>
r-<
Co
C
a
•p"i
a
o
C£
C
•U
(—¦
O
o
a
<
a
>
•«-{
cd
CO
c
•r-(
g
c
"O s
C CD
03 -r-J
>
W
1 1 rv^
•rJ
e c
p
M
C
o
•i-i
CO
CO
•W
pi
W
tr
P
•r~i
f~*
s
r—{
P4
s
Ol
Ui
tc
c
t-i
P-,
c
o
•r>l
4-1
G
c;
~ CO
C
H
j-i
c
CJ
e
n
(D
>
o
a
u
V
i->
P
M
M
•r-{
u
o
•rl
rj
O
IS
•p-v
<
cc
p
*t-i
r—i
C-
e
CO
CO
o
cd
jj
CO
I
cd
O.
0)
Vi
O
*0
o
o
p
o
•f-i
•U
03
O E
•r-i J-l
T-I O
X>
3 n
Ph h-i
en
tc
r-
Vj
100
1 APC Eng.
100
X
70
5
5
5
1
10
5
2 PHE III
100
M
50
30
20
1 PRE II
100
xi
1
70
! i
30
o PHE I
100
x!
75
1 10
15
... ! J J... ^ ..
-------
-38-
One final area that needs clarification is that of instrument calibration.
The unusually high number in that category "reflects the manpower needed to servic
the ten-station telemetery network in addition to those required for routine
calibration of lab and technical equipment.
In addition to these general personnel recommendations, several specific
staffing recommendations have been made in discussions of various functional
activities throughout this report. These recommendations are summarized below:
1. Allow the Assistant Commissioner nibre time to work with organizations
outside AMS by one of the methods listed in the Organizational Section of
this report.
2. Have a full-time attorney assigned from the Law Department to AMS.
3. Assign one man the responsibility of working with the legal staff in
briefing lawyers, preparing cases, etc<.
4- Hire an assistant or clerk for personnel matters to relieve the admin-
istrative assistant and thus allow him more time for program planning.
5. Hire a chemist with experience in the use of the gas chromatograph.
6. Hire a full-time meteorolooist.
7. Assign one or two technicians to serve and maintain the automatic sampli
network.
8. Assign one person full-time to be in charge of data processing and
information systems and provide him with support in routine data handling
(key punch, etc.).
9. Secure full-time services of one man to serve as a training officer.
8.2 Job Description
AMS is limited in its choice of personnel to those positions for which a
job description and classification have been approved .by the Philadelphia Civil
Service Commission. Should specialized personnel be necessary, AMS must go
through the lengthy process of drafting, submitting, negotiating, and obtaining
approval for the proposed position. This process can take as long as eight
months, and qualified people often find other jobs in the meantime. The
Philadelphia Civil Service Commission is reluctant to create new classifications
or allow flexibility in using existing ones.
Job classifications are difficult since a precise description of the duties
for a hypothetical and probably unobtainable person is required. This is
particularly true for engineers where it is extremely difficult to satisfy
procedural requirements for any except a qualified environmental engineer. Such
a person is neither available or entirely suitable for AMS' needs.
-------
39-
.Engineering.personnel are currently classified as Public Health Engineers.
This designation enables the agency to draw -from a vide spectrum of engineering
disciplines including chemical, mechanical, civil, sanitary, and electrical
engineering. While this arrangement enables the agency to attract qualified
personnel, it may tend to be a disadvaxitage to these people when they seek
advancement. Despite the fact that they deal exclusively with problems of air
pollution, examinations for advancement between grades require a knowledge of
all facets of environmental engineering. •
RECOILMENDATION 14 . "Create the category of Air Pollution
Control Engineer, Persons having this classification would deal
specifically with air pollution, and would advance according to
their proficiency in that field.
Engineering position levels are assigned as follows:
Apprentice = Engineer I
Journeyman '= Engineer II
Deputy Division Director = Engineer III
Division Director - Engineer IV
This system of evaluating jobsTath.tr than people limits promotion potential.
Since, there are a "limited number of jobs at the III and IV level, a person could
be blocked at the top step of a II level even though he was qualified for a III
or a IV. The only way to achieve a higher classification is to fill a position
at that level.
. A similar situation is present in the series of chemist positions.
Applicants for Chemist I and II positions are required to have extensive knowledge
of fields not related to air pollution.
RECOMMENDATION 15 . Require that chemists be knowledgeable
primarily in air pollution aspects.
AMS currently uses only Chemist I and II positions. Both the qualifications
and salaries for these positiuns are low.
RECOMMENDATION 16 . Utilize Chemist III and IV positions.
Such positions, based on degree and experience, would help adjust
chemists' salaries more in line with those of other agency
personnel.
For less professional activities, the agency makes use of both an instrument.-
tation Technician and a Chemical Technician. The Civil Service System severely
limits career opportunities in these positions. They, provide for only one step,
and a technician reaches his maximum salary after 4 years. This situation can
stifle initiative, incentive, and lead to rapid turnover.
-------
-40-
RECOMMENDATION .. Create a second step within each ot the
technician positions. This will provide incentive and a cor-
responding pay increase for more qualified persons. In addition,
the position of lab helper should be. eliminated and such duties
. assumed by technicians.
Several other classifications would be helpful to AMS.
RECOMMENDATION 3-3 . -Establish the position of Applied Scientist.
This could serve as a "catch-all" type of position and enable the
agency to obtain needed specialized scientific and technical
talent without having applicants wait for new positions to be
created.
RECOMMENDATION , Create an Air Pollution Control Public
information Specialist classification. This is discussed in snore
detail in the Public Information Section of this report. This
position would enable the agency to reject public information
applicants who did not have the necessary background in air pollution
control.
Availability of applicants does not .seem to be a problem. Substantial
numbers of applications are being received for positions with salary levels
appropriate to the background or the 'applicants. Requirements fcfr non-degree
personnel are being met more easily than those for people with degrees, however.
In the past, th'rough advertising and at conventions AMS lias attracted applicants,
but external contraints have reduced their ability to hire the people. Certainly,
the 33 percent vacancy rate bears this out. The average vacancy period for an
engineer in AMS is 6 to 8 months.
Recruiting has been done by both AMS and the Administration Office in the
Health Department. Since AMS has no restraints on recruiting, it may be beneficial
for a man to be assigned from the AMS staff group to handle and coordinate re-
cruiting efforts.
8.3 Salaries
The rigidity and limitations of government salary schedules frequently
present difficulties in the recruitment and retention of qualified air pollution
control agency staff. This is further complicated by the fact that government
salaries have not risen as fast as those of private industry. Table 8-4 gives a
comparison between existing salary schedules of similar job functions for government
in Philadelphia, the Federal government, private industry, and medians for other
local and state air pollution control agencies. Supporting information is found
in Appendices P and G for 1966 and 1967 personnel salaries. However, professional
salaries since that time have risen 30 percent, or an average of 10 percent: per
year and are reflected in Table 8-4. Federal salaries reflect actual raise more:::-:
since 1966.
-------
Table 8-4 SALARY COMPARES
Philadelphia Civil Services
Pay'Ranges Applicable
to Air Management Services
Approximate
Approximate .
Federal Rating
Industrial Rating
7LS
GRADES
SALARY RANGE
SALARY
SALARY
^.inistrative Assistant
I
8,815
9,159
9,501
9,843
GRADES RANGE
GRADES . RANGE
II
10 .,883
11,320
11,756
12,189
9-12, 9,881-
. Ill
• 13,275
13,818
14,351
14,906.
18,449
Ininistrative Intern
-
-
9,205
9,535
ngineering Aide
I '
6,618
6,853
7,087
7,320
5-7 6,548-
II
7,385
7,654
7,923
8,190
10,528
ir Pollution Control
Engineers
-
16,604
17,267
17,931
ublic Health Engineer
I
-
9,798
10,152
II
• 10,833
11,320
11,756
12,189
9-13 9,881-
. 10,000-
III
13,275
13,818
14,361
14,906
21,791
I-7II 27,000
IV
15,942
16,604
17,267
17,391
'henist
" I
8,396
8,698
9,011
II
9,038
9,443
9,798
10,152
•9-12 9.881-
I-VT.' 9,500-
III
9,'713
10,095
10,477
10,963
18,449
20,000
Checical Technican
7,621
7,899 .
'8,178
8,459
7 8,089-
•
10,528
Air Pollution Control
* *
Inspector
9,088
9,443
9,798
10,152
Inspector Supervisor
10,883
11,320
11,756
12,180
C:
State
Agencies
(Median)
16.
-------
-42-
A summary of Table 8.4 reveals:
1. Top salaries for most positions are considerably less than salaries in
other governmental agencies and industry.
2. Salary ranges are limited to only four steps that can be attained in
4 years. With so few steps in a category, salary ranges are extremely
limited.
3. Salary ranges are attained by reviewing comparable agencies and situa-
tions, and using the middle pay scale. It is regrettable that
Philadelphia is not in a position to compete for the best personnel available.
Further, when this scale was established, salaries may have been attractive
at those starting levels. In fact they still are according to Table 8-4.
Philadelphia's raises over the past few years have been based on a common
numerical value for all positions, not on a percentage increase. The
results have created attractive salaries for new, unskilled employees, non-
professionals and professionals. The beginning salaries for clerks is $5,325,
while a Clerk IV can receive $9,257. A stenographer begins at $5,694, while
and engineer starts at only $4,100 more. A Chemist III can earn only $10,863,
only $1,600 more than the upper range of a Clerk IV. This differential will
continue to remain the same with numerical raises, although the percentage
difference will continue to diminish. Turnover will be low for non-professional
and increase in key program areas.
4. Regardless of training and experience that any one individual has, he
must begin at the first pay step of that grade. This seriously hampers the
recruitment of trained and qualified personnel.
5. Job descriptions are often set for "avenues of least pay." Critical
positions are frequently open to unqualified individuals as position
descriptions often omit degree or license requirements. Little regard is
given to professional requirements. Formerly, the chemist position did
not require a degree. In many cases, particularly in this essential APC
field and in the AMS program, experienced and qualified people are needed.
Restrictions in hiring the most qualified can only injure the program.
Descriptions for positions should be based on the agency's needs and on
program objectives.
RECOMMENDATION 20 . Increase salaries for professional personnel
and have studies made to eliminate problems of the limited pay
step increase and the pay differential of professionals and non-
professionals.
8.4 Manpower Training
Training within the AMS has been a particularly unique problem. The program
does not have a training officer, nor does it have a training program established
for new personnel in the air pollution control field. Only one AMS staff member
-------
-43-
has attended a APC'O training course given outside Philadelphia in the past
year. At .present, training is limited to iri-house activities such as having the
person work with several program components. Often this training program is
interrupted by other program.priorities needs as a crisis develops. For new
professional personnel, training requirements should range from 3 to 10 weeks
during the first 2 years of employment, depending upon an individual's background
in college or technical school, and his assigned role in the program.
Training requirements for middle-level technical personnel (2 to 5 years in
air pollution control) should range from 3 to 10 man-days per year of employment.
Smoke readers especially should receive scheduled refresher courses in plume
evaluation on at least an annual basis.
Upper-level technical personnel working in the field over 6 years should
receive at least one week per year of formal training to maintain competence.
Management, administrative, and supervisory personnel should receive from
3 to 10 man-days per year in areas of management, supervision, program planning,
and specialized technical areas.
AMS has no career development programs using rotational assignments and
formal training to advance personnel through the existing system of career ladders
to positions of increased responsibility.
Training has received, a rather.low priority in agency planning. Training
needs have not beeTi^e^ermi^ed-1 training program has not been planned,
nor do individuals receive s'u'iiic-iem: .orientation in Al-13 as well as air pollution
control. Agency resources available for training are minimal, although a library
is located at headquarters for staff use. The public information program should
develop visual aides, training materials, and programmed instructions as needed.
Assistance in these areas as well as in technical areas is available from State and
Federal officials.
One external AMS element severely handicapping the program's potential in
training is the following condition contained in an Administrative Board Ruling.
Instructions for Filling out a Request for
Philadelphia Personnel Manual
Education/Training Leave
(Form 73-S-122, Rev. 8/68)
If the cost to the City tor tuition, salary, travel and other related
expenses will be -$250.00 or more, the arrangement on the reverse side
of the Request for Education/Training Leave must be executed by the
employee. An employee requesting City aid of $250.00 or more must
agree to remain in City employ for at least two (2) years following
the termination of the training leave. .
-------
-44.-
This condition undoubtedly limits the number of employees requesting
training because of the obligation required ^by the City. Some employees have
refused to sign the condition for training, thereby causing their elimination
from highly desirable program training. The condition is unnecessarily severe for
short-term training. A 1-week course outside the city would undoubtedly exceed
the $250.00.
RECOMMENDATION '2:1 . Adopt a formal training program in AMS
for orientation of new employees, training professional employees,
and training non-profes-sional technical employees by disignating
someone as training officer with responsibility for the criteria
analysis of training needs. (NOTE: This is one area where an
AMS task force would be extremely beneficial in studying the
problems and coming up with recommendations based on program needs.)
RECOMMENDATION 22 . Review the 2-year training commitment to
,reduce its severely restrictive influence for training personnel,
in the dynamic air pollution' control field.
8.5 External Constraints
Many AMS manpower problems are at least partly a fault of factors external
to the agency, as already discussed. The Thilacielphia Civil Service system is
the worst- of these problems. The eye tern is, in general, unresponsive to new
functions such as air pollution control. The delays and inflexibility in
creating job descriptions, the low salary levels, and the lack of advancement
potential inherent in the system have been discussed in the appropriate sections
of this report.
Central Personnel has tried to prescribe the type of manpower needed by AMS
without receiving input from AMS. A recent example of this was a report indicating
that engineers were not needed within certain segments of AMS. This type of
program problem should be discussed with AMS and resolved by that agency.
The study team's review indicated that most engineering personnel are
almost exclusively involved in engineering functions. Supervisory engineers,
as well as those engineers assigiied to the Staff of the Assistant Commissioner,
are involved in program planning. In such areas as data processing, fewer engineer
types would be warranted, but the agency has been unable to fill these positions
with qualified personnel who are not engineers. The whole problem is a result
of insufficient staff and using existing personnel in understaffed areas. This
particular personnel report seems to indicate a lack of understanding of the AMS
program on the part of Central Personnel.
Personnel administration is one of the functions handled centrally by the
Health Department for all agencies within the Department, including AMS. This
function includes processing the paperwork to create job classifications, develop-
ing position descriptions, obtaining positions, actually hiring people,'and
dealing in general with Central Personnel. Because of AMS' great need for new
staff and new job descriptions, it is important that AMS administrative staff
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cooperate closely with the Health Department's personnel office. Some lack of
communication and understanding between the two was evident during this study,
RECOMMENDATION 3 . Develop better working relations and commun-
ications with;the Health Department's personnel office and Central
Personnel.
RECOMMENDATION 2~4 . Hire a personnel clerk to prepare and
follow up the necessary paperwork for creating job descriptions
and hiring people. This clerk should be able to relieve existing
AMS administrative staff of the burden of such work.
Residency rules create an additional difficulty in hiring people. Policy
requires that all city employees live within the city.
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9. COMMUNICATIONS
Communication, appears to be a problem at several levels. Difficulties
exist within the AMS organization, between AMS and other city government agencies,
and between AMS and the State of Pennsylvania.
Within AMS, both vertical and lateral communication seems to be a problem.
Communication between the Assistant Commissioner and his staff and both the
Compliance and Enforcement and the Engineering Division was generally fair.
Contact with the Laboratory Division, however, was extremely poor. Although an
important part of the total air pollution control effort, the laboratory seems
aloof from the rest of AMS. Reporting between the three divisions and the Assistant
Commissioner is not uniform or adequate. The staff seems to lack knowledge
about program goals and direction; therefore, they do not relate their, activities
to the goals and objectives of AMS. Although some program planning has been done,
it has not been effectively carried out. This is at least partly because of
poor communication.
RECOMMENDATION 25 Develop and implement a uniform reporting
system.
Lateral communication between the divisions also were not good. This
problem was not as evident between sections within the same division, however.
Staff meetings for exchange of information have been too infrequent.
RECOMMENDATION ^ t Hold frequent and regular staff.meetings
with AMS.
Proper communication in a large organization cannot be left to chance.
Formal information systems are important to ensure that necessary information is
available to the proper persons when needed. The details of such systems are
discussed in the Information Handling Section of this report.
Communication between AMS and other City government agencies was also
strained. This is particularly true of the Office of Administration within the
Health Department. This office provides AMS with such vital services as
personnel, financial management, and budgeting. Lack of good communication has
decreased the amount and quality of such services AMS recei-ves, and has handicapped
AMS in getting its own job done. AMS should work to establish better communications
and relations with the Health Department's Office of Administration.
An active enforcement policy requires close cooperation and communication
between AMS and the Legal Department. This relationship is discussed in more detail
in the Legal Section of this report. However, communication between the two-
departments needs to be improved. Communication to the general public has a].so
been ineffective. This situation is discussed in more detail in this report's
Public Information Section.
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Communication between AMS and the. State of PennsyIvania is limited. To date,
it "has mainly involved joint studies such as the emission inventory. The State
provides little input to AMS program planning. The State could provide useful,
assistance to AMS in areas such as training, inspection of exhaust control devices,
legislative assistance at the State level, specialized laboratory and engineering
support, and planning and implementation of control efforts throughout the
Philadelphia Air Quality Control. Region.
RECOMMENDATION 27 « Work out a set of guidelines with the
State defining responsibilities in these areas. This is
necessary to avoid duplication of effort.
TKX'si^problem cannot be solved by AMS alone, but requires a spirit of cooperation
byrbdth agencies.
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10. . PROGRAM PUNNING AND EVALUATION
The "City of Philadelphia, through the City Planning Commission, has
developed a Planning-Programming-Budgeting System (PPBS). The primary purpose
of this system is to obtain -the greatest possible effectiveness from the
available, resources while, also providing a means of program evaluation. This
program calls for identifying activities and problems, identifying capital and
operating expenditures, analyzing problems, setting long- and short-term
objectives, and developing a comprehensive program plan along with alternate,
methods of operation. At present, AMS'becomes involved only to the extent of
planning the capital budget for municipal incinerators.
AMS does not operate under a PPB System and has not developed an integrated
comprehensive package of objectives, plans, programs, budgets, performance
actions, evaluation reviews, and modifications. The agency also has not worked
out alternatives to reach program objectives or drawn up a list of program
pvioriti.es. Even the new Code, which is an implicit statement of goals and
objectives, was developed by a consultant with relatively little input from
AMS. AMS only recently, and after a formal request from A-PCO through the grants
program, developed a clear statement of program goals and objectives.
RECOMMENDATION 28 Develop formal procedures for quantifying
probl^Q . pvami ni.ng ves . identifying resources, setting
priorities, and evaluation effectiveness.
Lack, of staff has generally prevented AMS from doing formal planning.
The planning and evaluation that does take place is done at the division operating
level, but is not uniform or coordinated.
RECOMMENDATION .29 . Assign a trained and competent person the.
responsibility of implementing the appropriate concepts of PPBS.
This, by necessity, includes proper attention to planning long-
and short-term activities.
Operating memorandum No. 3 describes the only method currently utilized by
AMS to measure progress. The goals stated are: (1) reduction and abatement of air
pollution and (2) control of nuisances and air pollution hazards;. The first
goal is measured in "tons of pollution abated," as determined from the
Philadelphia emission inventory. The goal for FY '70 is 10 percent abatement of
air pollution. There are several reasons why this is a poor evaluation tool to
measure program effectiveness:
1 r The 10 percent: is a blanket figure applied to all pollutants. It does
not reflect the relative threat of various pollutants present in the airthe
severity of localized pollution problems, the specific sources, or the
availability of regulations and technology to control various sources. A
more meaningful approach would be to set different goals for each pollutant
in terms of air quality requirements. Elimination or reduction of certain
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localizcd problems should also be specific goals with long- and short-term
objectives.
2. All abatement actions are reported regardless of plant shutdowns .or
elimination of sources through urban renewal. Thin measures a decrease in
pollution as a result of external factors rather than program effectiveness.
Other changes in source emission brought about by plant expansions, plant
relocations, or process changes can produce situations wherein AMS takes
credit for results not due its actions.
3. There is no indication that new sources are computed and added to the
inventory to show pollution increases.
4. Using sampling data to indicate pollution decreases is inappropriate
because results may be affected by variations in weather, sampling and
analytical procedures, cyclic source operations, etc.
5. Effectiveness on a month-to-month basis cannot be fairly evaluated.
One plant controlled may bias results in any one month.
6. The 10 percent reduction, goal does not assist AMS in determining what
program elements are ineffective, and in what areas additional resources
are 'needed.
AMS' recent workable program discussed long-raiige planning and a 10-year
air management plan using something like Program Evaluation and Review
Technique (PERT) or Critical Path programming techniques. Howeve-r, personnel
shortages have prevented this.development. A man responsible for planning, as
recommended, should devote part of his time to long-range planning activities.
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11. LAND USE PLANNING
Section 3-302 of the Air Management Code gives the Air Pollution Control
Board power to set ambient air quality objectives. The Board may promulgate
regulations that, among other things, restrict uses of land and establish
zoning.
The City Planning Commissioner is responsible for subdivision control,
zoning, capital improvement budgeting, and urban renewal. In some of these areas,
the Planning Commission and the Air Pollution Control Board have overlapping
responsibilities. However, neither body has introduced any environmental criteria
into its planning activities.
RECOMMENDATION 30 . Develop environmental criteria for air
pollution as measures for providing effective land-use planning
and thereby prevent or minimize air pollution and its effects. All
responsibilities delegated to the. APC Board should be carried out.
It was quite apparent that little or no coordination exists between AMS and
the Planning Commission, even though both agencies have some similar responsibil-
ities.
RECOMMENDATION 31 Develop formal procedures for cooperation
between AMS and the Planning Commission as a first step in
introducing environmental criteria into land-use planning. AMS
should have routine advisory powers and responsibilities on a
sign-off basis in the work of the Planning Commission involving
potential air pollution.
Planning for the vacant land still left in Philadelphia is an important
preventive measure. All such vacant land has the potential of supporting an air
pollution source. Preventing such sources is a much easier way of limiting air
pollution than controlling them after they are built.
The Air Pollution Control Board has other significant responsibilities that
have been neglected. Long-range planning for air pollution control must
anticipate social and technological changes as well as the future growth potential
of Philadelphia and its regional influences. This includes studies of energy
utilization, transportation, waste products, and other materials that substantially
affect the air in Philadelphia. These factors should also be taken into account
in the development of air quality objectives.
A brief review of the overall regional planning concept revealed that there
is no air pollution component on the Delaware Regional Valley Planning Commission.
In light of the air quality control region concept, it may be highly desirable for
air pollution control agencies to be represented on this Commission.
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12. PUBLIC "INFORMATION
The goal of the public information program should be to provide a basis
for dialogue between AMS and the broadest possible spectrum of the public.
Functions of the program should include a transmission of facts, definition of
issues, and delineation of actions that AMS will take. Public involvement, in key
issues such as legislation, regulations, program budgets, and variance hearings
is essential. Only a well-informed public will make such involvement beneficial
to Al-iS.
The existing public information program includes:
1. A daily air pollution index.
2. Bi-monthly publications of progress.
3. Meetings with local groups.
4. Public hearings on regulations.
The existing public information program in Philadelphia can be evaluated
by determining the attitude of the general public. Recent public outcries con-
cerning air pollution control in the city indicate that there is a lack of
information available to the public. Review of the AMS program verifies that
the public information program has not been a dynamic, effective part of program
operations. papers nave been issued and talks have been given by AMS staff, but
this was not truly a ^public information program designed to effectively inform
the public.
The existence of an effective public information program is a necessary
part, of a comprehensive program operation that qualifies for maintenance support.
Over a year ago, Air Management Services issued Operating Memorandum No. 1, which
included the development of a public information program. However, a City
policy has required that all public information staff work within the City Repre-
sentative's office. This arrangement did not satisfy the needs of the AMS program,
and, finally in April, 1970, an agreement was assigned to the Health Commissioner
for Air Management purposes.
While this agreement has given AMS the needed public information specialist
to develop a public information program, it has also caused some confusion. It
is not clear whether the public information specialist is only on temporary
assignment from the City Representative's office or whether the position is
permanent within the Health Department. If the public information specialist
has only been temporarily assigned to AMS, he could well become confused by orders
from both AMS and the City Representative's office, and divided loyalties could
result.
RECOMMENDATION 32 . Clarify control over the public information
specialist position. Ideally, the position should be permanently
assigned to the Health Department and placed under the Assistant
Commissioner. However, if City policy makes this impossible, a
written agreement should be developed between AMS and the City
Representative's office. The agreement should state the position's
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responsibilities, term of assignment (recommended indefinite),
duties, and obligations.
At the present time, a formal public education program does not exist.
Activities are being undertaken in piece-meal random fashion..
RECOMMENDATION ,33 . Develop a comprehensive public information
program. It is essential that the goals, objectives, strategies,
and procedures be. planned before the program actually gets under-
way.
RECOMMENDATION 34 . Make the Assistant Commissioner for AMS
more visible to the public and allow him to take a larger role
in influencing community opinion through the public information
program. Creating and filling the position of Deputy Assistant
Commissioner discussed in the Administration Section of this
report should give the Assistant Commissioner more time to devote
to such activities,
In order for AMS' public information program to be successful, the public
information specialist must be knowledgeable in both air pollution control and
public relations. While titles are generally not important to positions, in this
case it would be helpful to create a special title so personnel without
appropriate training in air pollution could be excluded. The title of "Air Pollut
Public Information Specialist" should be created for the person employed to do
public information work for AMS. This will enable the agency to exclude persons
who do not have suitable backgrounds in air pollution control.
The individual presently occupying the public information specialist
position has need for general training in the field of air pollution control.
RECOMMENDATION 35 Have the public information specialist
receive extensive air pollution training. This should include
knowledge of local, State, and Federal regulations; air quality
criteria; and the state of the art in technology.
RECOMMENDATION 36- . Locate and utilize personnel and materials
outside AMS that can aid in developing a public information pro-
gram. A large amount of such help, could be provided by APCO and
the .State of Pennsylvania.
The public information specialist should be continually aware of AMS
policy on all major matters and able to communicate directly with key citizens as
well as the mass public.
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RECOMMENDATIOK 37 . Involve the public information specialist
in the formulation of AMS policy. This will enable him to be
know led ge a b1e in his dealings with the public. Also, it will
lead to consideration of public: opinion in developing policy.
The need for a technical editor will continue to grow as the demands for public
hearings and implementation plans increase. Community participation by the
public information specialist is needed now in Philadelphia just to maintain
liaison with the many public organizations expressing interest in the air
pollution problem. Many of the people could provide valuable advice to the program
on a voluntary basis if there was an adequate mechanism, such as an advisory
council, established for their participation. There is obviously a great number of
non-technical people also -who would be willing to contribute time and talent to
assist AMS. However, to maintain the interest of such volunteers and to assure
them that their efforts are needed and appreciated, direct their efforts and ensure
that their comments are considered by the policy makers within the program. Such
programs are thus needed to ensure that information flows from the public to the
program policy makers as well as from the agency to the public.
RECOMMENDATION 38 . Develop lines of communications and programs
between AMS and local universities and between the public infor-.
mation specialist and voluntary agencies. The need for a technical
editor*for reports and public information should be considered.
At present, only 80 percent of the public information specialist's time is
spent on this prcJgram, Since this is a relatively new program area, and a weak
one, it may be advisable to assign an additional full-time person.
The public information program should further be responsible for organizing
technical training programs for AMS. Programs to be considered should be for the
AMS personnel, legislators, judicial people, boiler operators, and so forth.
This will require the information specialist to become aware of training and
educational needs throughout Philadelphia by coordination of AMS personnel and
researching public opinion. Programs of this nature would assist in furthering
the goals and objectives of.AMS.
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13. ENGINEERING
The first step toward any air pollution control effort must be to identify
the air pollution problems that exist, determine the. causes and effects, assess
the amount of emissions, investigate means of control, and evaluate control
efforts. This is fundamentally the mission of the engineering segment of the
program.
The engineering operation is established as a division-level activity as
are enforcement and laboratory services. The Engineering Division operates
autonomously as described in the portion of this report dealing with organization.
It is organized into three sections: emission inventory, permit approval, and
industrial improvement. Each of the sections is discussed separately with specific
recommendations addressed to each.
13.1 Emission Inventory
The emission inventory is a basic air pollution control activity. In
conjunction'with air quality data, it indicates the degree of emission control
needed to achieve air quality goals and helps to establish the priority schedule
for abatement action. It should, therefore, be a thoroughly planned, routine,
systematic activity.
The first attempt to establish a reasonable estimate of pollutant emissions
in Philadelphia was undertaken in 1958. Subsequent inventories were made during
the years 1965 through 1969 by the National Air Pollution Control Administration,
the Regional Conference of Elected Officials, and the City of Philadelphia.
Basically, five pollutant parameters were considered: oxides of sulfur, oxides
of nitrogen, organics, carbon monoxide, and particulates. The information re-
quired to calculate the emissions was obtained by the following methods: personal
contact and surveys, published data, special census data, and questionnaires
mailed to industrial and commercial locations in the City.
The latest inventory of industrial emissions is presently being conducted
by the City of Philadelphia in conjunction with the State of Pennsylvania. This
project is in the preliminary stages, with only the mailing phase completed. In
order that the operation be as informative and credible as possible, the agency
should develop and formalize procedures for follow-up, including plant surveys
and stack tests, while.also creating a system to constantly update emission
estimates.
RECOMMENDATION 39 • Develop specific procedures to follow up
questionnaires and data requests not returned to the agency. This
would include personal contact, plant surveys, and stack testing.
RECOMMENDATION 40 , Develop formalized and effective lines of
communication that allow for input from the other city agencies
regarding the nature of data requested and methods of data utiliza
t'ion.
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One of the uses of the emission inventory data will he in models to develop
control strategies. This is required as a par.t of the Air Quality Control
Region implementation plan. The present emission inventory forms will not supply
all the necessary information. Specific problems are:
1. The basic forms (process, boiler, and incinerator) do not request any
indication of associated control equipment.
2. Pi'ocess, boiler, and incinerator information forms do not include a
request for stack information. Tlii-s stack information is listed on the
collector and emission forms, but this form would probably not be completed
unless there is control equipment.
3. An estimate will have to be made by the agency regarding emission from
basic equipment. This information could be specifically requested.
RECOMMENDATION 41 . Reassess data needs and develop data-
gathering forms that will request all needed information regardless
of whether there is existing control equipment or not.
Data from an emission inventory should be available for use on a convenient
basis. Presently, all emission data are handled manually. The filing system is
cumbersome, and updating procedures have not been formalized.
: RECOMMENDATION 42 Develop a data storage, and retrieval system
that will properly assist the staff in emission inventor}' analysis
and reporting. This information system should be coordinated with
other AMS systems as discussed in the Data Handling Section of
this report.
RECOMMENDATION _ 43 . Familarize the entire staff in the operation
and use of the filing system, in order to increase the general
availability of this information.
RECOMMENDATION 44 Develop systems and procedures to keep
emission figures constantly up to date. This is discussed further
in the Enforcement Section of this report.
13.2 Permit Approval
A permit system provides a key mechanism for managing the control operation
because the agency must approve construction and operation of new or modified
sources of pollution. In this manner, the agency may prevent potential pollution
sources or require more stringent controls before a plant is built rather than face
the more difficult and expensive task of trying to control a source after it is
operating.
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The Air Management Code specifies that "no person shall build, erect, instal]
alter, or replace any article, machine, equipment device," which may be a source
of air pollution, "until an air management permit has been obtained for such
installation or construction."
AMS requires a potential polluter to have both a permit to construct new
equipment and a license to operate an existing source. The approval of con-
struction permits is an established activity, but the agency has only recently
begun to issue operating licenses, Both permits and licenses are administered by
the Compliance and Enforcement Division.
As part of the permit review procedure, the Engineering Division is called
upon by Compliance and Enforcement to review and approve the technical details
of plans submitted with the application. If Engineering decides the proposed
controls are adequate, the permits will be approved. If not, the application will
be returned with recommendations for improvement.
RECOMMENDATION 45 . Develop and publish a permit manual that
stipulates the type and amount of information required and
processing procedures employed.
RECOMMENDATION 4.6 . Standardize the evaluation procedure for-
reviewing plans.
Engineering's role in the process of granting operating licenses is much
less formal. The Division relies upon field inspections by enforcement personnel
to inform it about any new installations or alternations. Building permits are
another source of such information. Compliance and Enforcement may call upon
Engineering when necessary to review axiy such changes, recommended improvements,
and help decide whether or not to grant an operating license. With"the recent
implementation of the licensing system, the work load in-this area will undoubted
increase
RECOMMENDATION 47 Increase the number of qualified personnel
available for plan review.
In addition to serving as a valid control activity, the review of various
operations increases the knowledge and expertise of the-reviewing engineer.
RECOMMENDATION 48 Require that all engineers in the Division
gain experience in evaluating plans and specifications. The
reviewing engineer, in conjunction with enforcement, should conduc
final inspection and make recommendations for approval or denial.
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13.3 Industrial Iroprovemelit
The compliance procedures that are developed and implemented by the division
are most instrumental in determining the effectiveness of the agency in handling
pollution violations. To accomplish this end, the agency has established the
Improvement Program Section. Their task is essentially to conduct engineering
surveys of industrial operations, define the nature and extent of all air pol-
lution emission, and specify the degree of improvement required to meet acceptable
standards. Compliance schedules with target dates for the accomplishment of the
needed improvements are then developed vrlth the offenders.
To date, surveys of 15 major polluters in the city have been completed.
Acceptable compliance programs have been obtained from 4. The Code establishes
timetables and procedures to be followed for the submittal and formalization of
improvement programs.
RECOMMENDATION 49 . Develop a specific schedule based on. an
appropriate priority system for the. submittal of improvement plans
that will include all the major sources in the City 6n a staged
basis.
This section of the Engineering Division is also responsible for preparation
of special technical studies. These studies are "undertaken as necessary. One
example is development of control procedures for asbestos in both the construction
and demolition of buildings.
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14. ENFORCEMENT
The fundamental goal of any air pollution control agency is the abatement
of air pollution. Although the entire agency is involved in this activity, AMS
has given prime responsibility to the Compliance and Enforcement Division. The
Division is composed of the Compliance and Surveillance Section and the
Enforcement Section. Each section is discussed separately in this report and
specific recommendations are addressed to each.
14.1 Compliance and Surveillance Section
For field enforcement purposes, the division has sectioned the City along
previously established health department boundaries. Each inspector is
responsible for his designated area. These inspectors initially spend 3 days
at a Rutgers University-sponsored course to learn the basic elements of smoke
reading and the Ringelmann concept. There has been no provision for periodic
training or recertification of these inspectors. Such recertification would not
only keep the inspector informed of the latest concepts and practices, but also
would help him maintain expert qualifications in instances of legal action.
RECOMMENDATION ,50 . Require that inspectors receive periodic
training in reading visible emissions on at least an annual
basis.
Each inspector has at his disposal an automobile with a two-way radio.
Communications are handled through the City dispatcher. This system has proved
inoperable. The City dispatcher handles all city agencies with the. exception of
the police and fire departments. The system of referring complaints, sometimes of
a technical nature, from the main AMS office to the field inspector through the
dispatcher is cumbersome and inefficient.
RECOMMENDATION 51 Acquire a communications system for the
exclusive use of the AMS.
Air pollution detective and enforcement aids such as cameras, binoculars, and
hydrocarbon detection devices are not readily available to each inspector. The
agency has only four Polaroid earners for inspection use.
RECOMMENDATION 52 Purchase additional appropriate simple
pollutant-detection equipment for all inspectors to use
routinely.
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All complaints are received at the main AMS office. Questions are
answered directly or, if of a more technical nature, referred to a qualified
member of the staff. All complaints are recorded immediately. (Filing aspects
are treated in the Data Handling Section of this report). This system, except
for the communication difficulty mentioned above, appears to operate well. In
addition, there is some provision for off-hours complaint-handling and enforce-
ment, but this operation does not seem to be formalized.
RECOMMENDATION 53 Make arrangements for inspectors to
receive and investigate complaints expediently beyond the normal
working day.
14.2 Enforcement Section
Violations 'recorded in the field are processed by the Enforcement Section.
Three enforcement actions can result: Municipal Court, Order to Comply, and
Injunction Action. These procedures are discussed in the Legal Section of this
report.
Inasmuch as the initial step in the enforcement procedure is that of the
|nsnertor. reports of violations should be as extensive as possible. In this
regard, cooperation between the engineering and enforcement divisions should be
maintained. A stack-testing team should be available upon request to provide
necessary information on source emissions. Also, logging procedures should be
streamlined to allow for quick periodic evaluation of the violator's status.
In 1969, 844 violations were cited, and 11,895 investigations made. It has
been the agency's goal to eliminate 10 percent of the total pollutant load per
year. This goal seems unrealistic. Rather the enforcement process should work on
a scheduled source-by-source priority system.
RECOMMENDATION 54 Assign specific objectives and priorities
for the control of particular pollutants. Having chosen the
desired pollutant levels, the agency's enforcement procedures
should be structured accordingly. The'AMS should, therefore, develop
a formal enforcement plan to achieve the levels, through a
systematic and scheduled control effort.
A major new enforcement tool being developed by the agency is the system of
licensing. This operation calls for the annual review of each operating source,
and a subsequent renewal or refusal of the license based on the review. In order
that this activity be most effective, good operating procedures should be
developed.
RECOMMENDATION 55: . Develop a manual, for the administration of
the licensing system. (See Appendix E).
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RECOrJHKNDA'j'ION. 56 . Make emission estimates part of plan
review and licensing of existing equipment. This will serve as a
means to constantly update the emission inventory.
The' agency has initiated a program aimed at control of ''smokers" on
Philadelphia highways. This activity is carried on by the police department.
As yet, procedures for follow-up and penalities have not been formalized, and
actual abatement has been minimal. In order that this effort be effective, follow'
up procedures should be developed for the police to ensure compliance. In
addition, the city is now studying the possibility of equipping all city-owned
vehicles with air pollution control devices. This too, should be pursued and
actively encouraged by the AMS.
AMS presently has no provisions for dealing with air pollution emergencies..
As discussed in the Legal Section of this report, Regulation V, specifying the
requirements of ail" pollution emergency plans, has been drafted. However, no
administrative procedures for implementing ..this . regulation have been developed.
RECOMMENDATION y] . Develop administrative procedures for
implementing air pollution warning, alert, and emergency procedures.
All persons affected by these plans should bp notified ir. advance
of their responsibilities in emergency situations.
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15. TECHNICAL SERVICE?
The technical services area of the AMS program is, on paper, a part of.the
Laboratory Division. The functions included are air quality monitoring, labor-
atory operations, source testing, and instrument calibration.
"'"APCO, uses a slightly different breakdown of the program elements included
in technical services. These are air monitoring, special studies, data processing,
instrument calibration and maintenance, and laboratory operations. Source testing
is classified as a part of engineering operations. This breakdown is used in
the projections shown in the Manpower Section of this report.
The Laboratory Division is physically located approximately 10 miles from
the central office. The remote location is partly responsible for a breakdown
in communications between the laboratory and the central office.
RECOMMENDATION 58 . To coordinate efforts, develop program
goals, and improve communications, set up scheduled staff meetings
on a reasonable frequency to include heads of the Laboratory and
other divisions and the Assistant Commissioner for AMS. Refer tp
Section on Communication.
The physical building is 7888 square feet and includes an instrument shop,
Chemical laboratory, air monitoring room, and engineering shop. This facility
provides services' for the Environmental Health Division of Community Health
Services.
It has been difficult to obtain an estimate of manpower involved in technical
services area due to conflicting information received from various sections of
the agency and the fact that non-air pollution work is being done by laboratory
personnel. Depending on who is contacted, the number of people in the Laboratory
Division varies from 12 to 21, with no breakdown into the previously mentioned
functional elements. In any event, the APCO manpower model has shown a need for
30.4 man-years in the technical services area. This model is discussed in more
detail in the Manpower Section of this report.
RECOMMENDATION 59 . Recruit and assign additional manpower to
program functions as shown in the Technical Services portion of
Table 8-2. This table is a summary of estimated future manpower
needs for the agency.
15.1 Air Monitoring
The existing air monitoring in Philadelphia is primarily of a static nature,
i.e., samples yeild long-term integrated averages giving primarily annual infor-
mation. This static network is comprised of 4't stations, with dustfall buckets and
lead candles. Tlicse stations are located to provide uniform geographic coverage
of the area.
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This is supplemented by an intermediate station network consisting of
either three or four high-volume samplers, depending on whose description of
technical services one reads.
There is also a continuous station network of four stations with continuous
samplers for monitoring tota1 "oxidant, sulfur dioxide, carbon monoxide, total
hydrocarbons, nitrogen dioxide, and nitrogen oxide. AMS also used three, five, or
six paper tape samplers, depending again on the source of information.
AMS is proposing no addition to its static or intermediate monitoring net-
works. However, extensive changes have Been planned for the continuous network.
Data from the existing four stations will be telemetered to.a central processor.
This addition of six more continuous stations, also with telemetering, has been
approved. The proposed expanded air monitoring network is discussed in more
detail in Appendix A.
APCO has developed guidelines for determining the number of various types of
stations required as a function of the size, of the metropolitan area. The
• guidelines are included in Appendix B. They recommend that for every continuous
station there should be three to five intermittent stations, and for each inter-
mittent station, one to one and a half static stations.
AMS is already committed to a network of ten continuous stations, which,
according to the guidelines, is high for an area of Philadelphia's size. However,
with this numhpr already fixed., the sir -.jsTnitoring network should etlso have 30
intermittent and 45 static stations to be well balanced.
RECOMMENDATION 60 . Increase the number of intermittent sampling
stations consisting of high-volume samplers and 24-hour gas bubblers
to more closely correspond with APCO's. guidelines in accordance
with data needs.
Without these additional intermittent stations, AMS will be trying to go
directly from an essentially static to a fully automated monitoring network.
Lack of a well-developed intermediate network is not the most orderly and logical
way to develop an air monitoring network.
RECOMMENDATION .61 . Limit the telemetered continuous monitor-
ing network to the ten stations for which money has already been
committed. The proposed additional six stations should not be
considered or added at this time.
The selection of station sites is not easy to describe in a general way.
Station locations would be more meaningful if chosen on the basis o-f past air
quality data, isopieth maps from diffusion models, emission sensity, population
density, and geographic and meteorological parameters.
Uniformly placed stations are not necessarily the best way to achieve the- most
meaningful results. Statistical techniques are available that take physical factors
into account but still place stations randomly in order to achieve statistically
reliable results.
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-63-
RECCWHENDATION -.'62 . Re-design station locations to tatce uro
account population and emission'patterns. Statistical techniques
should be used to locate the station:;.
15.2 Laboratory
Under the present system, high-volume samplers are collected from three .or
four stations 7 days a week and analyzed in the laboratory. The analyses per-
formed are atomic absorption for total weight; trace metals including copper,
nickel, manganese, lead, and iron; and sulfate. Since the Air Management Laboratory
also provides services for the Environmental Health Division of Community Health
Services, one-half of the high-volume filters are used to make radiological
measurements.
This vise of one-half of every filter seems to be more than enough to
provide information on a background type of contaminant and could be reduced to
one-half filter per station once or twice per week. That would leave some portion
of the high-volume sampler available for futher air pollution related analysis.
RECOMMENDATION 63 . Perform additional analyses on some high-
volume filters. The more common ones are benzene solubles or
combustible .-carbon coRieuX-,- titrates , chlorides , polynuclear
aemmatic hydrocarbons-.(.carcinogens) , ' and metals .
A network of 44 dustfall buckets is analyzed each month. In one written
report it states there are two analyses performed on the dustfall samples:
total weight and the weight percent of free carbon in the sample. In discussing
this with the laboratory personnel, it was indicated that four analyses were being
done: dissolved solids, total solids, free carbon, and sulfate.
Analysis of gaseous air pollutants is minimal with only measurements of
sulfation by the lead candle technique and the gaseous monitoring of the four
continuous stations being done. No manual gas sampling with the NASN bubbler or
sequential sampler is being done. It was recommended earlier in the Air Monitoring
Section that such sampling be initiated.
We are unable at this time to make comment as to t.he technical suitability
of the chemical analysis procedures currently being used by the laboratory. A
request was made for these procedures at the time of the on-site evaluation and
several times since then by phone. The fact that they have not been forthcoming
can only mean that standard procedures for laboratory analyses are non-existent or
are so disorganized that they have not been able to be submitted to us as yet.
RECOMMENDATION _64; . Write formal laboratory procedures so
that any competent chemist could duplicate the analysis. These
procedures should reflect the latest work by APCO in the develop-
ment of standardized laboratory procedures.
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-6.4-
Other laboratory analyses consist of sulfur in fuel analysis and, in con-
junction with the Environmental Health Services Operations, radiological
measurements of air, water, and milk samples, analysis of urine for aminolevulinic
acid as being directly related to the lead exposure of the individual, lead in
paint samples and pollen slides.
The laboratory appears to have adequate facilities for most air pollution
analyses including atomic absorption, infrared, visible, and ultraviolet
spectrophotometry and gas chromatography. The gas chromatograph is not being
used currently since no one in the laboratory is an experienced operator.
RECOMMENDATION 65 . Recruit a chemist with experience or
provide training in the use of a gas chromatography to make use
of the existing laboratory equipment.
RECOMMENDATION "66 . Implement sampling and analysis procedures
to obtain background data on pollutants for which criteria
documents are forthcoming. Table 15.1 provides a listing of these
pollutants.
15.3 Source Testing
VJritten information indicates that there are five engineers assigned to stack-
testing activities. However, interviews with laboratory personnel indicated that
only one man is assigned primarily to stack testing and no team has been designated.
Staff must be borrowed from Engineering and Enforcement to run stack tests. No
source tests have been run recently due to lack of personnel assigned to this
activity.
RECOMMENDATION 67 Establish source-testing teams whose prime
responsibility is to support information and enforcement needs.
RECOMMENDATION "68 . Initiate a program of scheduled source
tests by industrial categories on a priority basis.
RECOMMENDATION W Develop written standard procedures for
conducting source tests.
RECOMMENDATION t Purchase enough source-testing equipment to
allow duplicate samples to be obtained without intermittent cleaning
of equipment.
Although source testing is visually a part of the engineering activities of an
air pollution control program, AMS has assigned it to the Laboratory Division.
Source tests are, however, generally requested by the Engineering and Enforcement
Divisions, as the information obtained is most useful and necessary in this
activity.
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-65-
Table 15.1
Tentative Order of Publication of Air Quality Criteria Documents
YEAR
-•-1969
'"-1970
1971
1972
1973
1974
1975
" Documents are available
""Schedule is firm
POLLUTANTS
Particulate matter and sulfur - oxides
Carbon monoxide, hydrocarbons, and photo-
chemical oxidants
Fluorides, lead, nitrogen oxides, and polynucleai
organics
Asbestos, beryllium, chlorine gas, hydrogen
cloride, and odors (including toxicologic and
corrosion aspects of hydrogen sulfide)
Arsenic, cadmium, copper, manganese, nickel,
vanadium and zinc
Kflrinm hovnn n Krnmi nm v- /-M ¦. -v-T- o 1 ;
- ) ------ ^ J } VV-J.VUA.UIU
Pesticides and radioactive substances
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-66-
RECOMMENDATION 7'1 . Give consideration to reorganizing the
placement of this, function and assigning source testing to the
Engineering rather than the Laboratory Division.
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-67-
16, METEOROLOGY
AMS is beginning to develop a meteorological component for the program.
Although meteorological activity is currently limited to part-time consulting
(1 day per week), plans are underway to create a full-time meteorologist
position and begin real-time modeling of the atmosphere.
Plans call for the meteorological parameters of wind speed, wind direction,
and temperature to be measured in the new remote telemetered air monitoring
stations. Such equipment would be added to the four existing stations, and
data from all ten stations would be telemetered every 5 minutes to a real time
computer. Also, a teletype would be rented for the reception of air pollution
forecasts from ESSA.
The data would be used for several purposes: application of APCO's Air
Quality Display Model - AQ'DM, trace back analyses for source location, investiga-
tions into simplified modeling procedures, and better determination of diffusion
parameters within the City of Philadelphia.
It is difficult to evaluate these generalized program goals in the absence
of specifics. However, APCO meteorologists have offered some comments. One
temperature measurement telemetered should be adequate for the stated purpose.
Temperature data is.necessary only for the calculation of effective stack height;
and this value is not overly sensitive to small variations in temperature. The
U.S. Weather Bureau Station could be used for this purpose. One U.S. City has
found that the expenses for tabulating (no analysis) meteorological data from
8 stations telemetered at 10-rninute intervals total $50,000. Philadelphia plans
presently to telemeter at least twice this amount of data. This would mean some
800 plus pieces of meteorological data alone would be transmitted daily to the .
computer from each site.
RECOMMENDATION 72 Investigate and evaluate the need versus
the cost for meteorological data as required by the Air Quality
Display Model and hold data collection to a minimum..
The recommendation for a full-time meteorologist" is appropriate. However,
to enable the meteorologist to spend most of his time on forcasting and the
analysis of meteorological data..'he should be supplemented by one or two technicians
to help handle the massive amounts of data that will be generated.
RECOMMENDATION ?3 Bring a full-time meteorologist and one
or two technicians on board to implement the meteorological aspects
of the AMS.
RECOMMENDATION 74 Make some provisions for the Meteorology
Section to give meteorological advice on weekends or at night
during periods of high pollution potential.
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-68-.
All projected -vises for meteorological data involve modeling. The area,
however, is quite complex and the problem should be approached carefully. The
AO DM is time-consuming and expensive to run, and should be used judiciously with
respect to the number of meteorological conditions and control strategies that
might be evaluated. The AQ1)H. is not particularly amenable to trace back
analysis as it is source oriented rather than receptor oriented. Neither
the employment of "simplified modeling procedures" or "better determination of
diffusion parameters within the city" has been defined. The latter may prove
to be quite expensive,if the diffusion parameters must be more exact than those
resulting from previous APCO• NQAA and university studies.
RECOMMENDATION 75 . Start the modeling portion of the meteo-
rology program slowly and develop expertise in proven methodologies
before attempting more sophisticated, costly, and unproven methods
of air quality modeling.
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17. DATA HANDLING
Air Management Services presently has only limited data-handling activity.
Air sampling data is recorded manually in notebooks at the laboratory; Brier
monthly summary reports are prepared manually. Because the data are. not in macliin
readable form, they are not frequently utilized for further analysis. Complaints
are processed manually and filed by source. As the work on the emission inventory
end license and permit systems are just beginning, no information system presently
exist to handle this data.
AMS needs formalized information systems. The IBM 1800 computer can be most
effectively used to process the large volumes of data collected by the air moni-
toring network. However, manual systems may prove effecient in satisfying most
other AMS information needs.
.RECOMMENDATION "?76 . Begin detailed planning for information
systems to process, store, and utilize all types of data
immediately.
RECOMMENDATION 7.7 . Assign one person within AMS with the
responsibility for planning, coordinating, developing, and
implementing all AMS information systems. This should be his only
inh ct s f f wpmKprs H apprl tr» him As nprpssarv
'• * ~ *" " •" " " - - • w ' • • '
17.1 Compu,ter Capabilities
An IBM 1800 Computer owned by the City Finance Department is available and
will be used as a part of the new air monitoring network. However, there are
several potential problems with this machine.
1. The computer must be shared with the Philadelphia General Hospital.
It is physically located at the hospital and AMS has no remote access.
2. The system can only read data entered on cards or discs. It has no
magnetic tape data-storage capability.
3. The computer at present has only 16,000 bits of core memory.
4. Both the hospital and the air monitoring systems operate in real time
with data being received and stored continuously. As presently program-
med, however, the computer cannot handle the two real-tirne systems
simultaneously.
The following-are recommendations for modifying the computer to make it.
more responsive to AMS's needs:
-------
RECOMMENDATION „7"8__... Double the core memory capacity of the
computer. The additional core capacity is necessary to simultaneously
accommodate the two data systems. Magnetic-type-handling capability
should be added to the computer system.
RECOMMENDATION 79 . Contract with IBM or another competent
computer programming firm to reprogram the computer's operating
system so it can simultaneously accept real-time data from both
the hospital and the air-monitoring systems. This could be
accomplished through the "Health Department. Better computer access
as indicated should be a'major effort of AMS in improving its
data-hand1ing s y s tem.
The computer system lacks a method for cheap storage of large volumes of
data in machine readable form. Magnetic tape is the easiest way to achieve this
capability. In order to have the system changed to accommodate tape, AMS will
have to work with the City Finance Department which owns the computer. Contact''
with the Finance Department should be made and work begun on this request and its
justification as soon as possible. This will ensure that the computer is ready
when the monitoring stations are installed.
Computer access is not very good at present. The computer is presently run
as a closed shop. Thau is, programs are left by the users, accumulated and run
in batches by the computer operating staff, and returned to the users. A good
deal of AMS staff time.could be wasted in taking programs to the hospital and
waiting for them*to be run or returning later to pick-them up. Even minor errors
will keep a program from running, and considerable time can be wasted while these
errors are corrected and the process is repeated. There are several possible
ways of improving computer access:
1. Acquire some type of a remote input device such as a teletype or a
¦remote card-reader printer. Details about suitable equipment and its
cost can be obtained from IBM or other hardware suppliers.
2. Establish a carrier service between AMS offices and the computer. AMS
professional, personnel should not waste time carrying programs back and
forth to the computer.
3. Establish good relations with the computer personnel. They may be. able
to make minor corrections, re-tun or expedite programs, and do other small
favors that will reduce time lost by AMS staff.
17.2 Data Utilization
Air Management Services presently collects very few data and has no
systems to make use of it. This situation will change drastically when the
telemetered air sampling, network, emission inventory, and permit and license data
all begin to come in the near future.
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-71-
The most pressing; need is to begin work on a system to utilize the tele-
metered air quality data. The network will telemeter air sampling data every
minute to a central computer. Present plans call for the computer to receive
these, data, calculate hourly averages, check for alert criteria, and store the
hourly averages on a disc pack. This procedure will completely fill the
available space on the disc pack in about 40 days. Every 30 days the accumulated
data would be punched on cards for long-term storage and purged from the disc.
RECOMMENDATION _ 80 Review air quality data needs carefully
with the goal of justifying storage of historical daily averages
only.
Present, plans to store hourly averages resulted from requests from two
sources:
1. The APC'O" SARO.AI) system.
2. The State of Pennsylvania Division of Air Pollution Control. Data to be
sent to APCO for the SAROAD system could be punched out on cards and
mailed at short intervals. The State's data needs should be evaluated in ¦
detail. It is likely that hourly averages were requested because it was
mentioned that such data would be available. Every effort should be maHp
to get the State to agree that daily averages will be sufficient.
RECOMMENDATION _81 . Keep historical air quality data in machine-
readable form on either disc or magnetic tape. Historical data
should not be stored on cards. The amount of data involved would
make cards cumbersome, prone to loss or damage, and space con-
suming.
Some modification to the hardware system will be necessary to implement this
recommendation:
1. Disc - If disc is chosen for data storage, a second disc drive unit must
be added to the one already existing on the system. A disc data storage
pack mounted on the first drive unit would contain the programs and the
work area to accumulate totals and do all necessary analysis. Disc
packs containing only data would be mounted on the second drive unit. As
many disc packs as necessary can be used to store the total volume of data.
The cost of a second disc drive is about $8,000.
2. Tape - The least expensive way to store large amounts of data is on
magnetic tape. The necessary hardware can be added to the existing
system for about $30,000.
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-72-
The exact: cost and technical changes required for either of these approaches
will, depend on the exact configuration of the existing computer. An IBM represen-
tative should be consulted to obtain the necessary details and help decide which
approach would be more economical.
Implementation of this recommendation is particularly important if it appears,
after careful study, that it will be necessary to store hourly averages. The
mass of data required would make card storage unworkable.
Although some thinking has been done about data collection and storage,
no detailed.work has yet been done on any of the programming that will be necessary
to retrieve or analyze the air sampling data.
RECOMMENDATION >$2 » Begin detailed planning for the data-
analysis program at once.. In planning the data-analysis programs
and reports, careful study should be made to determine the' needs
of data analysis. Often these will differ from what users say
they would like. Only a minimum amount of data should be printed.
RECOMMENDATION 83 . Begin work on writing the specifications
and actual programs for data analysis. The Water Department has
an IBM 1130 Computer that uses the same programming language
as the 1800. This computer can be -used to test programs until
the 1800 is ready to begin processing air .pollution data.
RECOMMENDATION -84 . Add a computer programmer to the AMS
staff. During initial development of the air quality system, he
can be assigned to writing some of the data-retrieval and data-
analysis programs. This will leave existing staff with more time
to plan and coordinate the entire project. Later he would devote
much of his time to writing programs for special data-analysis
studies. Availability of data for such studies was one of the
reasons for development of .this system in the first place.
Very little work has been done on information systems for data other than
air quality. Each division has been free to develop whatever systems it feels
necessary. Some thought has been given to making these' systems compatible so
they can be incorporated into a total information system in the future. However,
no planning or development has been documented.
RECOMMENDATION 85 • Begin planning now for development of
information systems for emission inventory and permit and license
data. This is necessary to facilitate storage and use of the data
when it starts to be received in the near future.
The maintenance grant application requires, the agency to show actual '
reduction•in emissions "achieved each year. To satisfy this requirement, it will
be necessary to annually calculate a complete, emission inventory.
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-73-
RECOi-lMENDATION _f§6_ . Design a storage and retrieval system for
emission inventory data so that1 a complete emission inventory for
the City can be calculated and periodically updated.
The system for handling complaint data is efficient. Copies of all complaints
and the resulting action are filed by source. Monthly reports breaking down the
nature of the complaints are their resolution are produced from this data.
RECOMMENDATION "67 . Develop a filing system to coordinate data
from:
1. Complaints
2. Emission inventory
3. Enforcement actions
4. Permits and license
This will make most effective use of all data collected by the agency.
Planning for emission inventory and permit and license information systems re-
commended above should be directed toward this goal.
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APPENDIX A
Proposed Expanded Aerometric Monitoring Ketwork
The attached map illustrates the existing and proposed
locations of the Air Management Services Expanded Aerometric
Monitoring Network. Existing Continuous Air Monitoring Sta-
tions are represented as triangles and lettered A B C D,
'representing the CAMP Station, Air Management Services Labora-
tory, Temple University, and Mobile Lab, respectively.
Circle configurations represent planned Continuous Air
Monitoring Stations.and are numbered 1 through 12, v,T.ith the
exception of one location numbered "D"- reiyresentinc a Knbp.rin"?&A
transfer location for the Mobile T
Stations 1 through 6 represent the initial six locations
to be installed in accordance with the city perimeter configu-
ration alreadv decided unon.
Stations 7 through 10 were selected as the remaining
four sirabl^ locations for installation in fiscal 1970.
FinaLty,.^5.tjation%. 11 and 12 are shown to complete the. continu-
ous sarjp^i^Vr netv*%k.
j - • .-r:> ' .£?*•*
^a^sfji'ds on|phe ro3.p represent 14 static sampling lo-
catiG-ns';;«L<)^ geti^d oust and sulfate index measurements only.
Tliese' in^ci'^^emesfl^ >vdll^ be made at each location throughout the
I
en15^e.{^sanplingr^K^v/or^ thus at 30 stations.
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PROPOSED EAxJA]»rI)3» ASriOJCTKIC IJOJIITORIIKx HBll'V/OmC
GI2Y OP PH17jAD3LPHIA"—
-------
Expansion Schedule
Continuous Air Monitoring Locations
City of Philadelphia
¦A.-CAMP Station - 20th.& Race
B. Air -Management. Services Lab - Castor & Lycoming
Existing C. Temple University - Broad & Allegheny
D. Mobile Lab-- 10th & Pattison — future location
Food Distribution Center, Delav/are & Snyder
1. Delaware Ave. k Spring Garden St. - City incinerator
2. Roosevelt Park ~ opposite Naval'Base
3. Goorge Wolf School - 61st & Brunswick
Fiscal *1969 4« Add B. Anderson School - 60th &, Cobbs Creek Pky*
Vicinity 54th & City Line
6. German tov.'n Ave. & Gravers Lane (Pastorius Park)
7„ 'Roosevelt Blvd. - near Pennypack Circle (Baptist Home)
TQ-7H Richmond & Allegheny
J-V/u ^ vicinity Robin Hood Dell - Strawberry Mansion -• 33rd
& Cumberland
10. Vicinity V/issahickon & Walnut Lane
Fiscal 1971
11. -Solis-Cohen School - Bustleton & Tyson
12. Bar tram Park - near. 56th & Eastwick
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In order to get an indication of the requirements in terras of station
numbers for a State, Regional, or Municipal Network', we propose the following
scheme which is based on the, experience of NAPCA and would satisfy the objectives
for an average urban area:
Number.of Stations
Urban Category Population (1000's) Type I Type III
A 25 - 50 1
B 50-100 2-4
c 100 - 500 5 - 10 1
D 500 - 1000 11-17 1-3
E 1000 - 2000 18-25 3-5
F 2000 - 3000 26-30 4-6
Urban areas larger than 3 million would necessarily
have special guidelines
-------
At the present state-of-the-art there are several common samplers
available for use In establishing one or more of the. stations listed above..
How to establish a good mixture of the various types of samplers is again
based .somewhat on experience and the area being monitored.
Table I-gives a break-out by urban category and station type. This would
apply to an average urban area.
TABLE I ' ~
TYPE 1 TYPE III
Continu- Short
Urban
Category
r—J
O
f
•1-*
fr*
Gaa
Bubbler
OUS SO2
(or other)
Term Tape .
Sampler
Continuous
Monitors
A
1
1
0
0
0
B
3
2
1
1
0
C
8
4
1
1
0
D
.15
8
3
3
1
E
22
12
5
5
3
F
28
16
5
4
4
Type I - Stations which measure area-wide pollutants such as particulates
and SO2. Sample collectors for this type station would include such equipment
as Hi-Yol samplers, gas bubbler, a continuous pollutant monitor (e.g.. SO2) and
a short term continuous particulate monitor (e.g., short term paper sampler).
Type II - These stations would measure specific secondary pollutants that
might be a major pollutant for a given area (e.g. lbjS, F-, 11C1, Cl2> metals,
etc.) Sampling equipment for these pollutants would be selected for the specific
problem and could be an instrument depending on the state-of-the-art.
Type III - These stations would measure primary "automotive pollutants"
such as CO, N0X, Hydrocarbons, etc. This sampling equipment would probably
consist of continuous monitoring type, of equipment.
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Appendix b
AI R> I ©U $ L ITY SURVEILLANCE
INTRODUCTION. .
A i\ecessary.rportroiicof cthe Implementation :Plan.is to
dedfcgcnr'andr.establralica monitoring program:.in order to
detex:roin&:.ambientr.air.iguality within .the region. Over-
aliilairipoil-utioncsurveillance includes both• surveillance
of ce'misjsionsas arelllas La.ctua 1 air .quaXity .measurements.
© •
Thi'S:iout3:iner.isiconcerned.with the design and operation of
an aair Equality ^monitoring.-network which .is mecessary to
denianstrate-;thati:ambr.eirtr.air quality is progressing toward
con£orrarn.g~to,jocc>r ccontrrt.ui.ng to mee.t ambient -air :quality
standards-r.s.In Zaoraerrof cthe'." Air Quality .Control rRegions- a
varietyvofrmonitoringr.or"sampling networks' of varying
degrees-eof csophistication .'have been in-existence for a
number-oof cyears ;¦£ .Theseshave ranged from :static .sampling
dev:ices^ csuehcas-dustfall.buckets and sulfation candles,
to"-systems composed of: continuous air monitoring stations
with tdata "being:.continually telemetered to a central re-
ceiving point;...-Similarly, the degree of coverage ha'gr-
varied ifrdrn: networks-''.having a few stations, if any, to well
designed .multiple-station, .networks.
As;.a result '.of: the'.requirements of the Clean Air Act- as
amended and the subsequent regional control of pollution,
it will be necessary, to rethi.nl; and mod\fy as needed tne .
-------
established objectives, as well, as monitoring network
design. With the increasing availability and use of reliable
diffusion. models, the objectives of air quality monitoring
"networks, their design ana operation can and must be altered
to be responsive to this new approach and meet the demands
placed upon us by the Clean Air Act as amended. The
-availability of new and improved instruments, methodology,
and data handling procedures now permits a more accurate .
definition of ambient air quality than ever before. The
¦following are guidelines with respect to the objectives of
monitoring, the design of monitoring networks, types of
instruments, sampling frequency and data handling procedures,
VJhile these guidelines are currently aimed at monitoring for
-SO and total suspended particulates, the same principles
and practices apply to the determination of ambient air
quality for other pollutants.
--OBJECTIVES OF MONITORING
An air.monitoring network for an Mr Quality Control Region
must be designed and operated so theit it is responsive to
-the following 4 objectives?
Objective 1. The network must be capable of measuring and
documenting the region's progress toward meeting the-adoirted
ambient air quality standards.
It is necessary that the existing air quality within
an entire Region be known and that it can be compared
to the adopted air quality standards. Because of the
size of the regions and the extreme geographical
variability of air pollution levels, it is not economi-
-------
•cally feasible to design a sufficiently large network
to adequately characterize regional air quality levels.
'The practical approach is t,o provide a limited network
-supplemented by diffusion modeling for extrapolating
the data so that it.is possible to estimate or
predict existing concentrations of a pollutant
throughout a region. If the network/is properly
designed and operated, this information will permit
year-to-year comparisons on trends and in addition
provide feedback on adequacy of adopted control
strategy. It is important -to be able to depict the
changes in air quality as a result of changes in
emissions from different source types.:"
Objective 2. -..To.-.-•dptermine, the, ambient air quality in
nonurban areas of the region.
1 1 7\ 4 r\y 4- y /"O r-f ^ A\ v\ o /"• O *•>
•*- <¦— * I w ^ JL / iiXi. y> *.« v-<- X .4- c-V Uj. v j .1 v/ u .v *— O i * nxj-Ji
-areas that are not yet developed and where the pollu-
tion is minimal. It is an objective of the monitoring
program that the air quality in these areas also be
known. The measurement of air quality in nonurban areas •
which typically are in the periphery can provide infor-
mation on the extent to which sources outside the region
¦i
affect its air quality. In other words, this gives, us
information as to ambient air quality upwind as well as
downwind from an urban area.
Objective 3. To improve the reliability of diffusion models,
As demonstrated in the preparation of implementation
plans as well as the monitoring objectives, diffusion
-------
¦-modeling can be a very'important¦tool in the proper
management of regional air resources. Modeling can,
when properly supported, adequately characterize exist-
._.ing overall regional air quality. --More important
perhaps is the use of modeling in predicting future
levels of pollutants on both short-term and long-term
..bases, whether it be in industrial locations, residen~
tial areas, Center City, or nonurban areas. The
increased dependence upon modeling requires.continuing
availability of ambient air quality data for validation
.» purposes.
Objective 4. To provide air quality data during air pollution
episode s.
It is necessary to -provide air quality data rapidly
during air pollution.episodes. The primary requirement
is that the data be available as rapidly as possible
to permit taking action under the plan. If the episode
.plan involves forecasting, concurrent meteorological
data will also be needed. The U. S..Weather Bureau (ESS?0
can assist with necessary data for the description of
local meteorology.
CRITERIA FOR LOCATING MONITORING STATIONS
The placement or location of sampling stations within this
limited network must be such that ensuing data can be gain-
fully employed to meet the four objectives of monitoring.
With this .in mind, the following criteria are recommended.
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Criteria 1. Monitoring stations must be pollution oriented1.
It is most important that eireas most heavily polluted
be identified and monitored. It is in these•areas that
progress toward meeting ambient air quality standards is
most critical.. .
Criteria 2, Monitoring stations must be population oriented.
A portion of the network must be located according to
the population distribution. This is particularly
'important during times of air pollution alerts and
episodes. Such data is also frequently of administrative
use in demonstrating concern for the 'welfare or emotional
veil-being of the population.
Criteria 3. Sampling ststions twist be located to provide
area-wide rerrresentation of ambient air quality.
Data must be representative of the entire Air Quality
Control Region. Area-wide data is needed for validation .
of the model as well as to show- conformity to the
ambient air quality standards. This includes both
«
developed and undeveloped areas within the region.
In the nonurban areas increased consideration should
-be given to those areas where future land development
j
is anticipated.
Criteria 4. Monitoring stations must be source category and/or
source oriented.
The primary purpose of these stations is to provide
feedback relative to the effectiveness of the adopted
control strategies. For example, a control regulation
limiting the emissions from donestic use of heavy fuels ,
-------
would require that stations be 3_ocated whex*e the
resulting change best can be. appraised.
The air quality monitoring network should then be composed
of stations reflecting one or more of the above criteria.
4 *
It should contain stations that ajre situated primarily to
monitor the highest levels in the region, to measure popula-
tion exposure, to measure the pollution generated by specific
.classes of sources and to record the nonurban levels of
pollution. Also, in order to allow comparisons of present
and past air quality data and to permit inter-regional
comparisons, a "Center City" station should be located
adjacent to the HASH station. In many cases a given station
location will be capable in meeting more than one of the
listed criteria, i.e. a station located in a densely populated
area besides measuring population exposure will ailso monitor
the effectiveness of controls on emissions from domestic space
lieating if such is part of the overall control strategy.
GUIDELINES FOR DISTRIBUTION OF MONITORING STATIONS
In most Air Quality Control Regions it will.take- from 15 to
*
25 stations to furnish an adequate amount of air quality dcita.
In unusual circumstances additional stations may be needed, to
fulfill the above criteria. Based upon our experience~r-:i-n the
past, we recommend the following guidelines for the distribu-
tion of air quality stations within the region:
1. .Heavily polluted or "dirty" areas ~ in most cases
3 to 5 stations will suffice
2. Nonurban stations - 2 to 4, depending upon the
size of the hinterlands
-------
3„ Population oriented stations 3 to 7
4. Source oriented stations - 3 to 5
5c Comparison oriented (Center City) stations ~ 1
6» Remaining, or other necessary stations should be
placed where concentration gradient or gradation
--i"s"greatest as predicted'by'the diffusion model.
The development of network designs should be based on
all available air quality and emissions information. Most
notably this will include: (1) past air quality data
(2) isopleth maps from diffusion models (3) emission density
¦maps (4) population distribution maps (5) land development
maps.and (6) topographical and meteorological information.
MONITORING NETr"
The specifics of monitoring networks are briefly outlined.in
the next 6 sections. A very important part of network design
is the selection of averaging times, Sampling frequencies,
specific sampler location, as well as data handling.
1. Averaging Times
'The types of samples, whether continuous or intermittent#
depend upon the primary use of the data. To show com-
pliance with, or progress toward meeting the standards,
the sampling equipment•must be capable of producing data
consistent with the averaging times specified by the •
ambient air quality standards. For measuring the ex-
posure of population, as well as for emergency episodes,
continuous monitoring or data of relatively short
-------
•averaging times are required, in contrast# for
instance sampling at the nonurban stations can be
of a much longer duration.
More specifically, for particulate matter, the basic
sampling period is 24 hours, whereas for SO^r it can
range from continuous instruments up to 24-hour inte-
grated samples. Similarly, ambient standards for
particulate matter v/ill be in terms of 24-hour values
'(averages and maximums); the ambient standards for SO^
may be specified in terms of from 5-minute values to
yearly averages.
2* Sensors and. Methods
-The preferred methods.of: sampling and analysis are those
most commonly in use and for v;hich a large body of data
is available (see Criteria Documents)« When standard
methods become available in the near future, they should
"be used. The recommended sampling method-for suspended
particulates is the Hi-Vol sampler v.'hich collects total
suspended particulates on an 8" x 10" glass fiber filter
at the sampling rate of 50 to 55 cfm. For sulfur- dioxide,
.the NAPCA modification of the West-Gaeke method, the
flame photometric method, and the gas chromatographic'
method are all adequate, because they are relatively
specific and have been shovm to be comparable for.
continuous monitoring. For 24-hour integrated samplers
the modified. YJest-Gaeke procedure is preferred.
3 =
Sarooline; Preouency
Twenty-four hour integrated samples should be collected
at a frequency of eit least twice v/eckly in order to be
-------
•able to adequately predict the maximum conccntra- ^
tions* Days of the week. should be randomly selected
—SO- that- over a-period of -one year -each day would
be equally re£>resented.
4. Sampler locations
In the selection of sampling sites consideration should
be given to source locations in the immediate vicinity .
¦ and other parameters* that may unduly influence the results.
Sampling instruments or ports should be located from
10' to 20.' above the street and at'least 10* away from
-the nearest structure. This will result in more accurate
measurements by eliminating various interferences.
5. Regional distribution of types of samplers
To meet the previous listed monitoring objectives,
the following guidelines for sampler locations are
recommended:
a. In the heavily polluted spots, a Hi-Vol sampler,
-a continuous SO^ instrument, and an AISI sampler
should be located. (The AISI data is useful in air
pollution episode situations)
b. Honurban stations should contain as a minimum a
Bi-Vol sampler. In many cases, where it is anticipated
that land use will change or it is recognized that a
problem of SO^ may exist, 24-hour bubblers should be
utilized.
c. Inasmuch as possible, the population oriented
stations should contain a Hi-Vol and a sampler capable
of providing short-term averages for SO^. In populated
areas adjacent to major industrial zones, a continuous
SO^ sampler and an AISI tape sampler may ce needed.
-------
cL For source category oriented stations a Hi-Vol
. anQ Inibbler is usually sufficient... VThere ind5.vid.ual
~~J.ar.ge' sources predomiriate,, a continuous SO monitor
•-array - be -necessary.
e. The comparison oriratea,, ox Center Cityr station
ssliould contain as a minimum a 3li-Vol and a gas bubbler.
f. Por other stations, i.e. those to show gradation,
a Hi—Vol and "bnbbl.er is xisually .adequate.
6- Other types of toonitorinq
In addition to -the stationary monitoring sites,
it frequently may be feasible to operate mobile monitor-
ing stations„ Kbbi3.e stations "with continuous instru-
ments can l>e used •quite advantageously to map urban
areas over a. sji-ajri—time periods -"We also envision that
in the future large >iir 'Quality Control IRegions may
.Cinci. airborne monitoring expedients. "While we are not
jreccanroending this type of monitoring., we' certainly want
¦fco point out the fact that if does exist and may be
useful.
• JDMTi. 3?3^DCESSI"NG JvKD PKESEET^TIDN
Ik most important part of.the entire monitoring effort is the
validation, handling, and analysis of data. It is extremely
important that all data be analysed and be made available
quickly and in a standardised format. This means that
values are to be expressed in uniform units (metric system)
&nd in useful and systematic averaging periods.
To this end, 1MPCA has developed an aerometric data storage
and retrieval system
-------
.instituted and modified to fit the particular regional-:-, needs.
In addition, for the regions that already have their own .
-deita systems, it is relatively simple to convert their format
-into the SAROTtD format for entrance into the National Aero-
metric Data Bank„
The data system and presentation should he flexible and
responsive to meet a number of needs ranging from evaluation
of data with respect to the standards to providing inputs
for diffusion modeling,. The system should be capable of
producing data in terms of 5-minute, 15-minute, 1-hour, 8-hour,
"24-hour, monthly, and yearly averages. In addition, the
ability to extract the maximum concentration and develop
geometric means for each of these averaging times should be
included. The system should .also 'indicate the availability
of valid data.
-------
• niot'.vork design •
a. "• Da fin It ion of • a Stat ion
Inl.order : to- determiner.how well a network serves the
objectives.as:ontiifjad; it is necessary to define a
pollutant"' samplihgrstation in terms of the critex-ia
standards-^pollutantstmeasured and types of collectors
used ^ .
(1) The firstrcriteria of a station is that it
produce ::adequatetsamplcs so that data can be
analyzed:d,
(2}'2 ¦ The'..second:-.crit eria for a station is that it.
sample;juajor ^pollutants for which.standards are
available!,orcforcuse in producing v/ritten standards.
Wer.\hav.evdiv.idedctDiese into three types and are
defined '.as v. follows v.:
pollutants :srteh ~n;K; A-,?i-,*trr.\-. and £0- fv.'hcrc SO.
A - . J ; 'd " k;
:prpbleiTisr.'.exisliJii:) .Sample collectors: for this type
station~wouldiinclude such equipment as Hi-Vol
saffiplers/sgas^bubbler, a continuous .pollutant monitor
(e.g. SO^) and a short term continuous particulate
monitor.: :(e „.g. cohort: term tape sampler).
TypeII These stations wouId measure specific
secondafy::pollutants that might be a major pollutant
fof:a given: area .^e.g. H^S, F~, HC1, G.l , metals,
etc.). Sampling equipment for these pollutants would
be selected.for.the specific problem and could be
any:" instrument ^-depending on the si: a t p_-- o f. -1 h e - a r t.
TypeIThese stations v/ould measure primary
"atftomotive-.pollutants11 such as CO, NO , Hydrocarbons,
x
etc. .This sampling oquj.pm.ont v/ould probably consist
-------
of continuous monitoring type of equipment,
b„ Eiza of Hotwork
The number of stations required and the .selection of
the site is not an easy plan to describe in a general v/ayt
The planning would have to take into consideration many
criteirici such as^.l.) the population.of the area,
2.) the emission sources, and 3.) the meteorological
parameters and terrain, etc.
In order to get a figure for what would be required in
terms of station numbers for a State, Regional, or
Municipal Network, ve propose the following scheme which
is bJised on the experience of NAPCA and would satisfy
the objectives for an average urban area {See Figure 1).
^ Number of
i.UA'U o j '
Urban Category Population Type I Type III
A 25-50 1 ~
B
I
o
UO
100
2-4
— '
C
100 -
500
5 -.10
1
r>
500 -
1000
U - 17
1-3
E
1000 ~
2000
18 - 25
3-5
F
2000 -
3000
26 - '30
4-6
Urban areas larger than 3 million would
necessarily have special guidelines
c° Type of Network
At the present G'tate-of-the-art there are several common
samplers available for use in. establishing one or more
of the stations listed above. Bow to establish a good
mixture of the various typos of samplers is again hased
somewhat on experience and the area being-monitored.
-------
Table I gives a break-out by urban category and station type.
This would apply to an average urban area.
TABLE I
TYPE I . TYPE III
Continu- Short
Urban • Gas ous SO?. term tape Continuous
Category Hi-vol Bubbler (or other) Sampler Monitors
A 11 0 0 0
B 3 2 1 1 0
C 8 4 1 1 0
D 15 8 3 .3 1
E 22 12 5 5 3
F 28 16 5 5 4
d. Frequency of Sampling
Sampling frequency will depend on the particular objective and
applies only to the inteiMiiittent stations.
(1) To measure air quality, it is necessary to obtain a
sufficient number of samples over a representative number
of periods in order to draw valid statistical conclusions.
A minimum number would be 103 samples per year with the same
number of named days sampled per year. Increasing the
frequency by the same rule would obtain a better statistical mean.
(2) To measure air quality for standards comparison would
require a greater frequency of measurements and should be
confined to selected, small areas, (people oriented).
(3) To measure air quality for abatement action could require
daily measurements at or around selected sources. This would
be based on the judgment and experience of the air pollu-
tion agencies.
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k)•:twork o?ar;\t:i:pis;ar. reodirrmivvts
a. • If:'a network is. to produca valicl samp 1 es, it
requires good equipment, maintenance, and frequent
station:inspection. .This is particularly.true for
-1-argeynetv/orks- {greater- than 5 station)...Economically,
.a .central" maintenance-.chop. v.'itli appropriate . .instrument
sparesc-.and:".spare:;parts;.should be a partrof :• any ..large air
pollution/agency;; .Instruments requir6:*frequentncali~. •
bration'for air-flow and frequent inspection for any'
problems:, •_leaks/, etc» -that might invalidate .the..sample.
It lis if reqnently 1 impossible ' to dupl.icate.:a particular: .
samp.le;.~theref of e-good cper forming equipment-.is r.necessary
Personnel bperating:\thei n t erra.i11entr.samp 1 ers- must:ha've
¦ enough -training-to-:]jnbv7-:-v/heh equipment - is; not; function-
ing -proper ly
b.b .For": continuous/.operating: instruments, .^particularly' ;
v.vhcrcrda.ta/; is 'being- obtained continuously - ' it .".is" manda-:
'cov.yy *fch atalii of. e th c ;.sb cv c' -be., available .land. .iiiore. . At-
th&hpresent-state^of^ifheV-Grt :. in continuous'/monitoring..;
instrumentsspeciallyLtraincd operators /.-must .vber avail-!
abib.late.le astsa partrofcevery. day. .If D"nothing-else, c ..
«
a visit should.be made daily to check on the overall
performance : of. each .'individual instrument;. ;.. Frequent v.
calibration..and: zero checks' must be' made:"" And most
important, is: the ".¦•.type .of .'maintenance service reach:..'
instrument gets. Personnel servicing..these instruments
must be electronically oriented and should preferably
heme . some, knov/ledge of chemistry, since .quite . a few of.
th&;;pollutants .being;^measured today :;depcnd: on :chemical
reactors. If.they do not have' training in chemistry,
itiisr.necessary "that• .they-.understand the chemistry',- •
physics and engineering principles involved in each
measuring instrument.'
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c. PersonneJ. operating a network should include
several different entities and qualifications as.
follows:
...(1)._.N e t w o r k _ Super vi sor - Un ivers i ty tr a in ed
in a scientific profession. Should have .experience
in the Air Pollution field and be able to supervise
and train personnel,
(2) Xntermittent field operators ~ Should be
High School trained with on-the-job training in
instrument operation and maintenance. Must be able
to operate independently and in cooperation with
urban community dwellers.
—(3) Continuous station operators - Should have
University training in a scientific field and with
some background in chemistry. He should be job
trained in .instrument operation which, would include
changing individual consonants within a particular
instrument and in the calibration of same.
(4) Service personnel for continuous monitoring
equipment - They should be University trained in
electronics or be graduates of accredited electronic
trade schools. They should have thorough on-the-
job training .in maintenance and trouble-shooting of
all instruments and equipment used 'in the network.
(5) Service personnel, Intermittent -operating
equipment - Should have some shop experience, par-
ticularly in electrical and machine tools. Minimum
High School trained and on-the-job training in
servicing various network equipment-. '
(6) Support personnel ~ Would include shipping,
receiving, supply and administrative clerks. Prefer
ably High School trained.
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IABORATORV SUPPORT.;
Regu 1 x'cmoi\ts. /vccomplishing the objective of
lowering- the pollutant lend on the urban air 'mass
rnust be donc thr ough var ious abatcmen t. pr ooedi>res .
The gathering of facts to suppdrt those procedures
has to come from some type of analytical support.
Thus, a laboratory must be a part of any sample
collecting network to provide th*e physical and chemi-
cal data for documentation of the various pollutant
concentrations. Although the sophistication of this
type of support may vary in different regions of the
country, thex'e must be provided the basis equipment
and supr^lies to complete the premise for the reason
for the sampling retwork.
For netv;orks v:ith .:lesjE :±a^a'n 25 :statiant>, the laboratory
may consist of some work space, a semi~h\icroba;lanco,
a smaix ;ipec-cropnorovueter and necessary chemicals and
hardware for wet chemical microanalysis. Y?ith provision
for a special instrument for a unique pollutant source,
if necessary. Large programs within States should have
their own central laboratory for making large numbers
of routine determinations possible. This reduces the .
cost per determination to ei considerable degree by making
it feasible to operate automated systems. 7vlso the
central facility should have some capability for doing
limited research on applied and localized problems.
Some specialized instrumentation should be provided when
justified on the basis of the degree of the severity, of
the entity being measured, its effect on the population
and how prevalent the problem might become over the State
or Region. Since laboratories are support groups, they
should be a staff function.
-------
b* Personnel staffing. Small laboratories may be one-
man operations. If so, then a University trained person,
preferably .in chemistry, should bo that one person.
Large laboratory facilities should be supervised by a
*
University graduate in chemistry, preferably with
Graduate training. Re should be experienced not only
in v?et chemical techniques, but have extensive knowledge
arid experience in instrumentation, A degree chemist
v;ouid be recommended for each 10 technicians doing routine
v,'or)i.
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APPENDIX C
BASIC FUNCTIONAL DESCRIPTIONS. AND DEFINITIONS lJOR MANPOWER ESTIMATES
I«¦ Basic Definitions
For any specific air quality region a-.number of possibilities exist
relative, to functional activities performed and combinations of state
and local agencies existing or planned.
In addition, the region may be inter-state, compounding the variety
of state and local combinations. As a general rule, primary estimates
of manpower are made by considering one local agency for each intra-state
portion of an AQC Region. Appropriate distribution between state and
local agencies is made as a supplement to that estimate. The estimating
procedure (Model III) considers a comprehensive control program defined
to include the following functions:
.-A. Management Services
.B^. Technical Services
C. Enforcement.Services
T>> Engineering Services
2. Management Services
A. Policy, public relations, inter-governnental relations, and
development of cont-rol strategies and plans: These'functions include
the variety of special activities required of an agency director and
his immediate staff in order to conduct a meaningful and dynamic control
program. As an agency increases in size, specialists, such as system
analysts, public relations experts, and technical writers, are required.
1 ^ _
For small agencies the" work is considered a part of the work of maior
supervisors.
-------
B. Administrative ar>d clerical support: This function includes
budgeting, record keeping, filing," typing, and related owrk, as normally
required to operate an agency. All, cleric! staff of the agency are
included in this category for ease of tabulation.•
C. Legal counsel: In smaller agencies,, this function is handled
by lawyers not directly included on-the agency payroll, although portions
of the counsels's salary may be carried on budget statements. In larger
agenci.es, full-time counsels may be assigned to, or employed by, the
agency. The man-year commitment is so small, however, that man-year
estimates are not made in the model.
D. Staff training and evelopment: This function includes the
activities of training officers and supervisors in providing on-the-job
or fonnal group training. ;-.Time required for this function Increases
with-high rates of personnel turnover, cumbersome administrative practices,
improper job-entry requirements, and other similar factors. Civil service
rules and regulations can create unnecessary training pi-oblems and/or
limit the methods used to provide proper training.
3. Technical Services
A. Laboratory operations: This function includes all laboratory
support activities necessary to the conduct of source sampling, ambient
air monitoring, and special studies. In most larger agencies, it is
a part of direct operations. In some smaller agencies, the function
is conducted by a central laboratory in the local health department
or by a state agency.
B. Ope ration of monitoring network: This function relates to the
routine servicing and operation of air sampling and meteorological
instruments deployed in the field for continuous survei1 lance of air
-------
quality and diffusion characteristics. The data generated is used
as input to diffusion models for"prediction of future air quality
and the development of control, regulations", to determine the
effectiveness of agency operation in reducing and/or preventing air
pollution; to forecast episode conditions; and for public information
and education purposes.
C. Data processing: This function includes data reduction,
processing, and statistical treatment for air sampling, meteorology,
permit processing, emission calculations, and development of inspection
schedules. If automatic data processing equipment is used, the necessary
manpower vill generally be concentrated in one organizational unit.
Far estimating purposes, it is considered to be part of technical
services.
D. Special studies: This function includes a variety of special
studies conducted for purposes of locating sampling stations, determining
contribution of specific sources to ambient air pollution levels, and
determining need for new regulations. As such, it is an ongoing
activity of an agency, the extent of which is determined by administrative
decision and general capabilities of the technical services staff.
E. Instrument calibration and maintenance: This function
includes those duties that require specialized education, training,
or skills to ensure the proper operation of sampling, analytical,
and meteorological instruments operated by the agency.
A. Enforcement Services
A. Scheduled inspections for permit renewal: This function relates
to the activities required of an air pollution inspector to determine
whether all sources of pollution, operating under a permit are in
-------
¦ .compliance with the terms of that permit. „ The function includes, travel
time, inspection, and report preparation. For this function, an annual
inspect ion is considered a: program standard. Inspectors responsible for
specific sectors .as v?ell as specialized industrial inspectors would be
assigned to this function.
B. Complaint handling and field patrol". This function includes
the operation of a continuous field patrol to enforce regulations on
open burning, visible emissions, odors, etc. Patrol cars and radio
communication is assumed! the patrol officers are assumed to be available
tor immediate response to complaints.
C. Enforcement of episode prevention procedures: During periods
v.'hcn air pollution cpi&Cwes are occurring or may occur, all agency per-
« sonnel would be called upon to activate and enforce any procedures
that have been established for dealing with such situations. Engineering
personnel would concentrate on reducing industrial emissions; field
sampling personnel would increase their data-gathering.operations J
nnd patrol officers and inspectors would be in the field to insure
that emission reduction preocedures were being followed. Thus,
essentially all normal activities are intensified or preempted by
the emergency. Man-years for.this function are not considered in
the model.
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5. Engineering Services:
A. Source identification and registration: The purpose of this
function is to record poUution-produce,ing operations. A variety of
mechanisms and degrees of coverage are practiced at present. These fall
into three categories: • (1) Registration of combustion equipment, often
by an agency such as a building department, and general inventory of
industrial establishments with air pollution potential: (2) formal
registration of sources with the air pollution control agency, with or
without information relative to pollutant emission rates; and (3) primary
registration by a permit system, with follow-up by inspectors and patrol
officers as part of their routine duties. The last approach is used in
the model. For new agencies supplemental man-power should be assigned
this function for a period-of 2-3 years.
B. Calculation of emission estimates: This function relates to
the work done in estimating emission rates from various sources and source
categories to provide information on compliance with agencies rules and re-
gulations, program effectiveness, potential future problems within an
agency's area of jurisoiccxon, location of sampling stations, and need for
* c
new regulations. It is an engineering job requiring an initially high
expenditure of manpower. For new equipment, the job is associated with the
permit system. Estimates provided by the model are related to an on-going
activity; they should be increased for the initial years of a new agency.
C. Permit System: This function covers all the work involved in
reviewing plans for potential new sources of air pollution; estimating
.emissions by calculations; consultation with builder, owner and/or other
interested parties to effect changes, where necessary; making inspections
>
to insure that what is done conforms to the plans; and appearing before
-------
hearing hoards to substantiate findings, It is assumed that permits are
issued to prevent'pollution in a coniprehensive manner; and that the system
includes an authority to construct aiid a permit to operate.
D. Development of control regulations, preparation of technical
reports on control and review of industrial control plan for episodes:
Assignments in these areas are generally project-oriented or considered
part-time responsibilities of the engineering staff.
E, Source Testing: This function relates to the determination of
point source compliance with the agencies rules and regulations as well
as confirmation of calculation of emission estimates.
6. Manpower Estimates:
Man years for ^ach function are estimated by multiplying predictor
and manpower factors for each function, as indicated below.
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PREDICTORS AND MANPOWER FACTORS-MODEL III
Predictor Manpower Factor
X. Operation of Monitoring -Network,
2. Schedule Inspection-fuel use Original input required
(see separate sheet)
3. Schedule Inspection-industry
4. Complaints and field patrol
5. Permit system'
6. Policy, P/R Strategies, etc. MY 1,2,3,4,5 0.22
7. Staff training MY 1,2,3,4,5 0.12
8. Special field studies MY 1,2,3,4,5 0.06
9. Emission estimates MY 1,2,3,4,5 0.05
10. Eng. Repts; Tech. Aspects of
new legislation, etc. MY 1,2,3,4,5 0.05
11. Admin, and clerical support MY
12. Data processing MY
13.. Source Testing MY
14. Lab. operations MY
15. Instr. calibration and
maintenance MY
1,2,3,4,5 . See separate sheet
1,2,3,4,5 0.09
2,3,5 0.10
1,8,13 0.35
1,8 0.25
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1. Ope ration of: II o n i fc o r i n g N e t wo r k.
A. If monitoring network is known (actual or estimated) then
estimate man-years directly.
B« If monitoring netv.'ork is not known, but proposed number of
stations is available the following factors can be applied.
(1) 0.5 MY per CAMP station*.
(2) 0.1 MY per manual sensor in operation, neglecting static
devices (dustfall, Pb candles, etc.).
C. For unknown situations use:
1/3
Area A X (Number of manufacturinR establishments)
1,000 J 1,000 X 0.8
(
2. Schedules Inspections - Fuel use.
A. Basic predictor is number of boilers (residual oil and coal fired)
and incinerators (known or estimated). If this is known, then Man-Years .=
0.5 x Number of boilers and incinerators
1,000
* t
3.• Scheduled Inspections - Industry.
A. Obtain total number manufacturing establsihments from 1963 Census
of Manufactures or other reference:
(l) Manpower Factor = 2.0 MY/1,000 establishments.
B.. If number of boilers cannot be estimated for 2, above, then
use:
HF = 2.8 MY/1,000 establishments
for total My to inspect boilers, refuse, and industry.
C. All of above assume annual inspection; modify as needed for
other schedule.
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U . ' Complaint handling and Field Patrol.
The predictor used Model III "is Total. Population. Staff size is
1.00,000
increased for areas requiring extensive speace heating:
(1) Less than 3,000 degree days - use 0.3 MY/ 3.00,000
population.
(2) From 3001 to 4991 degree days - use 0.7 MY/100,000
(3) Over 5,000 degree days - use 1.0 MY/ 100,000 population.
5. Permit System
A. Predictor chosen relates to "Capital expenditures for new plants"
1963 Census of Manuracturers,
B. Estimated Man-Years provides sufficient manpower to maintain
an intensive system for variety of regulations and comprehensive
pollution prevention.
C. For agencies in growth,-'a time schedule is needed fee acquisition
of staff.
D. Manpower factor = 9.7 MY/$100,000,000
Capital Exp.
6 thru 10
A. Functions in this group are considered discretionary; that is
Agency Director can increase or decrease effort based on his preference
and/or judgement.
B. Manpower factors represent general allocations.
C. The predictor is the sum of the man-years for functions 1 thru 5.
This is basically the same as assuming some percent of total agency
man-years.
11. Admin i strati oj) and Clerical Support
A. The predictor is sum of man-years in functions 1 thru 5. The
estimated man-years include portions of supervisors time.
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B, For agencies doing v.lie bulk of their own budgeting, bookkeeping,
I
and other administrative chores, use man-power factor of 0.59 1TY/MY.
C. For agencies that receive administrative support from other
segments of apparent organization use man-power factor of 0.4 MY/MY.
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INPUT CHARACTERISTICS USED FOR
THE CITY OF PHILADELPHIA
1. Population -
2,040,000 (1960 data)
2. Area -
127 sq. miles
3. Manufacturing establishments -
4,618
4. Capital Expenditures -
$1.22 x 100,000
,000
PREDICTORS AND MANPOWER FACTORS
Predictor
Man-power
Factor
Man-
1. Operation of Monitoring Network
known.
9.0
2. Schedule Inspection - fuel use*"
L 2.8
4.614
13.0
3. Schedule Inspection - industryj
4. Complaints and Field patrol
1.0
20.4
11.8
54.2
6. Policy, P/R, Strategies, etc.
54.2
.22
11.9
7. Staff training
54.2
.12
6.5
8." Special field studies
54.2
.06
3.3
9. Emission estimates
54.2
.05
2.7
10. Eng. Reports, new legislation
54.2
.06
3.3
11. Administrative and clerical
54.2
.59
32.0
12. Data Processing
54.2
.09
4.9
13. Source testing
24.8
.10
2.5
14.. Lab operations
14.8
.35
5.2
15.. Instrument calibration
12.3
.25 .
3.1
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APPENDIX D
— ADMINISTRATIVE STAFF-SUPPORT
„ Admin 1 s I: r a t 1 ve
Functions - procurement, personnel matters, reporting, contracting, annual
budgeting.
Personnel - 5.0
Project Management
Functions - new projects, scheduling, ot,her projects, surveillance.
Personnel - 4.0
Planning - Short Range and Long Range
Functions - goal accomplishment, ongoing surveillance, establishing long
range goals 5-8 yrs., cost-effectiveness studies, priority setting, budget
preparation, evaluation.
Personnel - 1.0
Tnf Aymof-t' ManooomDnf"
Functions - management information, data management (automation and manage-
ment), form development.
Personnel - 1.0
Training Function
Functions - continuing training programs, long range personal development.
Personnel -o
Public Information
Functions - identify public needs, reporting program progress,
position papers development, press conferences, public participation,
disseminating information.
Personnel -.8
Air Quality Personnel - Technical Developments
Functions - study of new developments and agency requirements,
surveillance of technical progress, program review.
Personnel - «5
Other Support Elements - added from time to time as the need develops.
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ENGINEERING DIVISION
Ind us trial Improvement: Program
Functions - a. plant improvement progress
b. sending survey teams
c. identify each individual source
d. potential contribution to pollution load
e. actual contribution
f. recommendations for reduction
g. developing compliance plans
Personnel -3.0
Permit Approval
Functions - a, review aii plans
b. recommend.issuance of installation permit to Liscences
and Inspection
c. keep abreast of new control methods, and recommend
to appropriate sources
Personnel - 1.0
Emission Inventory
Functions - a. identify and catalogue all air pollution sources
Personnel - 1.5
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COMPLIANCE AND ENFORCEMENT, DIVISION
Compliance, and Survp.illance Section
Functions •- a. inspection of all assigned emission sources
b. 24-hour surveillance of city and investigate all
variations
c. answering and investigating all complaints
d. checking for compliance"with installation permits
e. monitoring of all improvement programs
f. inspections for annual liscensing
g. response to emergency and disaster situations
h. 20,000 pieces of equipment will be inspected on
an annual basis
i. within two years certification of 40,000 pieces of
equipment is expected
Personnel - 1 PHE III, 1 PRE II, 3 APC inspection supervisors, 18
APC inspectors (23 budgeted for), 2 clerk typist I, 1 clerk
steno I.
Enforcement Section
Functions - investigating and preparing"all violations requiring:
office conferences
municipal court action
orders
liscense and revocation
sealing of equipment
injunctive action
Development and direction of specific projects to implement new
programs for inciiieration upgrading of 1000 incinerators sulfur
in fuel requirements.
Personnel - 1 PHE III, 1 Enforcement Specialist, 1 lawyer (consultant),
•> at>r iiM'tAn/ii-riT-c 9 flfv!; i-vnists I. 1 clerk steno I.
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LABORATORY DIVISION
Analysis Section
Function - a. taking samples
b. laboratory tests
c. telemetry responsibilities
d. provide sampling data
e. provide reports
f. operation of all monitoring stations
Personnel -2.0
Field Operations Section
Function - pi~ovide source sampling teams, conduct source samples
Personnel - 1-0
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APPENDIX E
ADMINISTRATION OK "A PERMIT:'SYSTEM
Bjty
* <
Robert: G . .Lunch er\ g
Erie. .E.Xemke:;
Juliem -A. Ve.rs.se.nzr.
PaperE :6 8-1-1212
Presented at;±foen-2
Ai-tLrPaTIutiorr rCohtrral: Association
61£st: •ArinuaL- neeLang;.;
St:.z .PauL.IHILt.ori :Hot.el.,'. StVPaM^l Minnesota
June 26", 1968'
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Annual Meeting
Paper #68-112
ADMINISTRATION OF A PERMIT SYSTEM
By
Robert G. Lunche
Eric E. Lemke
Julien A.Verssen
ABSTRACT
In June 1947, the California Legislature enacted into law
a bill which authorized counties experiencing air pollution
to activate air pollution control districts. The law pro-
vided a district with the privilege aim necessary powers
for administering a tx^o-step permit system requiring first,
an authorization to construct prior to installation and sec-
ondly, a permit for operation. By October 1947, the Los
Angeles County Air Pollution Control District was activated
and rules and procedures~were adopted to ensure a satisfactory
operation of its air pollution control program. These rules
'established: types of equipment: tor which permits are required;
standards for granting applications; prohibitions tor emissions,
equipment and fuels; and procedures for appealing District de-
cisions or petitioning for variances before the Hearing Board.
Administration of the permit system is in the hands of profes-
sionally trained engineers. They are responsible for evaluating
applications for permits, making calculations necessary for de-
termining probability of equipment compliance with air pollution
laws, and making the decisions on the approval or denial of per-
mits. Consistency of treatment for all applicants is sought and
has resulted in standardized application forms, permit informa-
tion forms, instruction forms and processing techniques. Rather
tljam require a separate application and permit for each individ-
ual equipment item, a concept or "parmit units" is employed which
involves grouping equipment items operating as a functional unlL
into one application and one permit.
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Abstract
Page 2.
Annual Meeting
Paper #68-112
Administration of a permit system has been beneficial to Los
Angeles County. The permit system has proved to be one of the
most effective tools in reducing air pollution from stationary
pollution sources. It not only prevents operation of equipment
which emit air contaminants in excess of that allowed by law,
but prevents the installation or construction of such equipment.
This latter facet also conserves money:for the applicant because
he does not have to make expenditures for equipment until a fair
certainty exists that a permit to operate can be obtained. Thus,
the applicant is able to make needed changes on a drawing rather
than more expensive changes to the physical plant. Dependence
on unreliable voluntary cooperation is replaced by a more certain
system which places the same requirements on all applicants. . *
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ADMINISTRATION OF A PERMIT SYSTEM^
By
R.G.Lunche^, E.E.Lemke0^, J.A.Verssen^
INTRODUCTION
Following the initial appearances of photochemi-
cal smog in Los Angeles during World War II and its sub-
sequent increase in severity, an aroused public demanded
abatement action. The response was a bill drafted by the
County Counsel of Los Angeles and submitted to the Cali-
fornia Legislature. Descite strong opposition by certain
segments of industry, the bill was enacted into law in
June 1947. The purpose of the bill was to enable any
California county suffering from air pollution to estab-
lish an air pollution control district with the responsi-
bility for cleaning the air in that county. The first
California air pollution control district was activated
by and for Los Angeles County in October 1947.
a) Presented at the 61st Annual Meeting of the Air Pollu-
tion Control Association, St.Paul, Minnesota, June 1968.
b) Director of Engineering, Los"Angeles County APCD.
c) Principal Engineer, Los Angeles County APCD.
d) Air Pollution Engineer, Los Angeles County APCD.
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State Law
An. important feature of the new State Law was
the provision for administering a permit system. This
provision allows a district to require permits prior to
¦ li —— 11 ,J
building, altering, replacing, selling, renting, or using,
yith some exceptions, of all contaminant emitting equip-
ment. The State Law also delegated to a district the right
i "
'to:
1) require plans to show that the building will
be done, and approved equipment will be used,
so as"to eliminate or reduce contaminant emis-
sions;
2) rerquire the furnishing of such information,
analyses, plans or specifications as will
disclose the nature, extent, quantity or
degree of contaminants discharged;
3) suspend permits where requested information
is not furnished;
4) request the revocation of permits by the
Hearing Board;
5) require fees for the issuance of permits; and
6) enact rules and perform acts needed to reduce
air pollution and properly administer the
m ¦
district and the permit system.
To facilitate a district in putting a permit sys-
tem on a firm, enforceable basis, the State Law declared
-2-
-------
it a misdemeanor to fail to furnish requested information
for a permit, to submit a false statement in connection
with a permit, to build or operate without first obtain-
ing a permit, to build or operate with a suspended or
revoked permit, or to build or operate contrary to the
provisions of a permit
District Rules
The Los Angeles County Air Pollution Control
District opted for a permit system as one of the corner-
stones of its air pollution control program.• Rules and
procedures appropriate to that option, and in harmony
with the State Law, were adopted by the District and have
produced a permit system that is workable and effective
in reducing'air pollution. These rules and procedures
have been modified over the years as found necessary
through working experience.
Presently, these rules prescribe that an Authority
to Construct be obtained prior to construction, alteration
or replacement of any equipment capable of emitting or con-
trolling air contaminants. Also a Hermit to Operate must
be obtained prior to operation or use on a full-time or
permanent basis of any equipment capable of emitting or
controlling air contaminants. The procedure employed with
a Permit to Operate allows the equipment to be placed in
operation for "debugging" and demonstration purposes be-
fore the decision to grant or deny the Permit to Operate
-------
is made. Once granted, an Authority to Construct or Permit
to Operate is not transferable from one location to another,
from one person to another, or to other equipment.
Not all. equipment emitting air contaminants falls
within the purview of the permit system. Another rule
describes equipment exempted from the permit system by the
State Law, notably vehicles, or exempted by the District be-
v : :
cause the nature or amount of pollution from such equipment
does not justify its inclusion under the permit system.
However, this equipment must be operated in compliance with
emission standards.
To facilitate the, aim of consistent treatment,
applicants for Authorities to Construct and Permits to
Operate must fi£e applications with the necessary informa-
tion as prescribed by the District. Since plans to con-
struct or operate may be changed or discarded, Authorities
to Construct expire after 2 years and applications are can-
~
celed. In the case of an application for a Permit to Operate
existing equipment, as occurs during change of ownership,
the application is canceled after 2 years. The applicant
may reapply for the Authority to Construct or Permit to
Operate when plans to proceed are revived.
In certain installations, sampling and testing of
the effluent must be conducted. One of the adopted rules
requires that sampling and testing facilities be provided
. : "" — . : ^
and maintained as specified in the Authority to Construct
or Permit to Operate. When equipment is not shown to be
—4—
-------
capable of complying with the State Law or District Rules,
or when the equipment has not been constructed in accordance
with the approved Authority to Construct, the standards for
granting applications require that the applications be denied.
Instead of denying an application, the District may specify
conditions with an Authority to Construct or with a Permit
to Operate which will bring the equipment into compliance
with air pollution laws. These conditions may be revised
upon reapplication and demonstration of complying operation
under the revised conditions. When an Authority to Construct
or Permit to Operate has been denied, a new application for
the same equipment cannot be filed until the reasons given
lor ueuiGi iiciVb ween coricCi>cd> Failure tc supply requested
information can be used as a basis for denial action.
A series of rules, known as "prohibitions", provide
emission or performance standards, specify equipment or fuels
for various operations and prohibit certain operations. In-
cluded are (1) rules limiting and defining permissible dark-
ness and opacity for a visible emission plume, (2) rules
limiting discharge of particulates, dusts and fumes, sulfur
compounds, combustion contaminants and organic material from
solvent usage, (3) rules specifying acceptable controls for
petroleum products, storage tanks, oil-effluent water sepa-
rators, gasoline loading into tank trucks, tank cars and
service station tanks, and rendering cookers, (4) rules
specifying sulfur contents of fuels, degree of unsaturation
-------
of motor gasoline and photochemical reactivity status of
organic solvents, and (5) rules prohibiting public nuisances,
open fires and single chamber incinerators.
PERMIT SYSTEM
Operation of the permit system has contributed sig-
nificantly to the effectiveness of the District's air pollu-
tion; control program and the advancement of the "state of the
art11 of the control of dusts, fumes, smoke, gases and other
airi:contaminants from stationary sources. Before the permit
system could make this contribution, however, the framework
of State laws and District rules had to be implemented by
various administrative policies and procedures. These poli-
cies- and procedures ranged from interpretations of the laws
aiKkinstructions for their application, to mechanics of work
fLow, forms to be used, methods of processing permit appli-
cations, wording of permits and equipment to be included
onDione permit. The need for consistency and uniformity of
treatment for all applicants has always been recognized but
actual achievement of this goal did not come overnight.
Reinstatement of the fee system in 1957 focused
attention particularly on the practice of issuing permits
and.separating equipment into individual permit applications.
Thus was born the "permit unit" concept, which was reviewed
for. legality by the County Counsel's office and accepted by
industry because it brought consistency to the issuance of
-6-
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permits for similar equipment at different locations. Under-
lying the acceptance of the permit unit concept by the indus-
¦ ' ¦ 1 ¦¦ »!¦¦¦¦¦¦— ¦ ¦¦¦ " ¦ M ¦¦¦ ¦¦
trial community is the fact that they know that each appli-
cant must submit the same data and information, follow the
same procedures, use the same forms and comply with the same
rules and ordinance.
Permit Unit Concept
The basic principle for establishing the boundaries
of a permit unit is to include in a permit unit all equip-
ment items which operate together as a functional unit.
¦¦ — ¦¦ " ' "—' ¦
Amplification of this principle for various situations has
been made in a brochure entitled "Administration of the remit
System". This brochure also outlines procedures to be followed
in making applications, gives examples of various equipment
groupings which comprise permit units, includes an index for
equating different equipment groupings to the given examples,
and includes instructions and instruction forms for frequently
encountered permit units.
In Los Angeles County, "basic" emitting equipment and
the "ftir pollution control" equipment" are considered separate
% ¦
^permit units under the permit system. Thus, there is no nec-
essity to reprocess the basic equipment each time the control
equipment is altered or modified.
-7-
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Air Pollution Control Equipment
Air pollution control equipment is grouped in permit
units by the same principle applied to basic equipment. For
example, emissions from a gray iron cupola are passed in
series through ,an afterburner to burn combustibles, a spray
11— I I ¦¦ ¦¦ ¦¦ -¦1 — 1 l ¦¦¦—1 ¦¦ "¦¦¦¦¦ ¦ I ¦¦ ¦ ' ^ —'I ¦— I.I— .. ¦! ..I I I
chamber to coo1? the hot gases, and a cloth filter to remove
the aerosol emissions. -There is no need to issue separate
permits for the afterburner, the spray chamber, and the cloth
filter when all these units must be operated in unison to con-
trol the cupola. Therefore, one permit unit includes the col-
lection and exhaust system as well as the afterburner, water
cooler and baghouse.
Independent Equipment
The basis for forming a permit unit of one equipment
« ¦ i ¦ ' ii
item is the ability of that equipment item to constitute a
separate emission source or to operate independently from
other equipment within a plant. Examples of independent
equipment which can be separate permit units are boilers,
metal melting furnaces, galvanizing kettles, cookers, and
paint spray booths.
Series Equipment
Real problems of maintaining consistency arise with
processes employing a complex of equipment, operated in uni-
son, between the point of feed to the process and the final
storage. One need only examine the following typical flow
-8-
-------
sheet of "a rendering plant to visualize the various group-
ings of permits which would be possible and the problems
which would be encountered.
RENDERINC
Remaining consistent from one company to the next
is paramount in importance and examples used in the brochure
help in reaching that objective. The fundamental principle
which applies in the above case is to group such equipment
so as to encompass all the equipment employed from the point
—— ^
of initial charging or feed to the point or points where the
-9-
-------
material proceeds to a separate process or storage (i.e.,
classifying to storage, cooking to grinding, etc.).
Obviously, an alternative of issuing one permit per.
company could have been adopted, that is, a "door-to-door"
permit. This, however, would introduce the possibility that
considerable numbers of complying equipment in a plant could
be denied just because other equipment in the plant were in
violation of air. pollution laws. It's also equally obvious
that two companies would receive different treatment in the
event that one employed three process lines while the other
employed but one or two. Therefore, the permit unit concept
for operating groupings is that of a "common denominator".
Parallel Equipment
Normally, business enterprises add more productive
equipment as demand for their product grows. Therefore,
whether a company installs several furnaces or spray booths,
etc., immediately upon entering business or adds additional
units year-by-year, such "parallel" equipment is treated as
separate permit units.
Storage Equipment
Grouping storage equipment into permit units is per-
haps the most intricate permit unit concept, but, in general,
storage equipment is grouped with the source of material it
stores. Liquid storage is a major exception where each stor-
age tank is considered a separate permit unit. There are
-10-
-------
other exceptions which, although not as significant, are laid
down in detail in the brochure on "Administration of the
Permit System".
Permit Unit Examples
The various principles used in the grouping of equip-
ment into permit units have been adapted to approximately 50
groupings of the type of equipment more frequently encounter-
ed and of more significant air pollution potential. These
examples illustrating the permit unit concept indicate the
number of permit units involved, the general equipment in-
cluded, and the basis for fee assessments.
Specialized Instruction Furms
The type of information required by the engineers to
properly evaluate the air pollution potential or air pollu-
tion control potential of equipment is detailed in special-
ized instruction forms which are given to every firm or per-
son who must obtain permits. The District has prepared these
specialized instruction forms to apprise permit applicants
as to the type of information that will be demanded of them
or any other applicant applying for similar equipment. These
instruction forms cover various categories of equipment and
each form is detailed as to the information which must be
submitted concerning process description, operating sched-
ules, fuels and burners used, and flow diagrams. Each form
also describes how equipment catalogs may be substituted for
-11-
-------
drawings. Copies of application forms and several instruc-
tion forms are attached as examples of the types of informa-
tion required.
Mechanics of Fork Flow
A Permit Application Receiving Unit has been especi-
ally established to assist persons required to submit permit
applications and receives all incoming plans, drawings, etc.
Here,applications are screened to determine if they are ac-
ceptable, or if they are possibly exempt under our exemption
rule. Also, assistance is given to potential applicants in
preparing their application forms, describing permit unit
boundaries and even in providing permit fee estimates.
Now, with the advent of the electronic data process-
ing system, the data presented with each application must be
organized into a standardized pattern. The information on
the application form is entered into the EDP system routinely
so that many different factors may later be retrieved, such
as: air contaminant measurements, costs to the community,
costs to various industries, types of remedial equipment
employed, and all the combinations of this information which
will serve as tools to provide intelligent direction of the
future air pollution control effort.
Each application is assigned a number chronologically
• •
upon receipt. This number is entered on a 3" x 5" card with
the applicant's name, address, permit unit (equipment) de-
scription, processing status, processing engineer, dates, etc
-12-
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These 3" x 5" cards are filed alphabetically by company
name arid can be used for quick answers to simple inquiries
about the application or its status. Complete information,
of course, is contained within each application due to the
policy of thorough documentation.
Personnel Requirements and Duties
The preceding policies are indeed important for ad-
ministering a permit system that is effective for reducing
air pollution but capable, dedicated personnel are equally
important. The District has found it essential to employ
professionally trained, graduate chemical and mechanical
i i i ¦¦
engineers who can apply the rules and procedures along with
good engineerlug principles. Thus* sincp each application
for an Authority to Construct and Permit to Operate is re-
viewed by an engineer, there can be confidence in the evalu-
ation as to whether the equipment involved will or does com-
ply with all applicable air pollution laws.
The evaluation is accomplished by a review of all
the plans and specifications for the equipment, and the pro-
cess chemistry, process flow and operation details. The
engineer calculates or estimates the types and quantities of
contaminants generated, emitted and collected by control de-
vices. The contaminant collection system is checked to insure
that it is designed and sizea properly to collect and trans-
fer the contaminants to a control device. A calculation of
-13-
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the control device efficiency also is a part of the evalu-
ation. Physical inspection of equipment operation and
sampling and analysis of emissions play an important part
in the engineer's evaluation.
Based upon his evaluation, an engineer will recom-
mend either approval or denial of the Authority to Construct
or Permit to Operate. If the engineer's recommendation passes
review of his supervisor without changes, the applicant re-
ceives either the Permit to Operate or a letter of denial.
In most cases the letter of denial is given after a conference
with the applicant, at which the District's action is discussed
and explained.
To expedite the processing of applications for Auth-
orities to Construct and Permits to Operate, the Engineering
Division has seven application processing units (each special-
izing in a different variety of equipment), two- source testing
units, anc engineering projects unit, and an application re-
ceiving unit for assisting applicants in the filing of appli-
•
cations. Los Angeles County, of course, has a large industrial
base so the number of technical persons required to staff the
program is necessarily larger than would be the case in smaller
communities. Counterparts to our organization in smaller in-
dustrial base communities could certainly be scaled down and
consolidated to meet the needs of their problem. Consistency
in processing applications for specific equipment is maintained
by the specialization of the processing units. Exchanges of
personnel between processing units widens consistency in pro—
-14-
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cessing applications for all equipment. Each unit consists
of a senior engineer, intermediate engineer and 4 to 6 air
pollution engineers so that the exchange of 1 or 2 men at a
time is not harmful. The exchange program also creates a
ready reserve of flexible, versatile engineers for each unit.
ADVANTAGES OF PERMIT SYSTEM
The permit system as administered under the rules of
the Los Angeles County Air Pollution Control District is an
example of preventive control of air pollution. As such it
has a number of important advantages not only to the citizens
of Los Angeles County but also to industry as well.
If the individual proposes to conduct activities like-
ly to create air pollution, he must first obtain a permit,
which is granted only after it is established that all required
safeguards are present. After a permit is issued, it remains
in effect only as long as its conditions are observed.
Advantages to Citizens
•
The citizens of Los Angeles County benefit because a
permit to operate is issued only when the emissions from the
equipment involved have been controlled.to the standards es-
tablished by law. Further, an Authority to Construct must be
obtained prior to construction, alteration, or replacement of
«• •
any equipment capable of emitting or controlling air contami-
-15-
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nants. This safeguard prevents the installation of equipment
which will not comply with air pollution laws and avoids the
need for long, drawn-out,legal procedures to bring existing,
violating equipment into compliance.
The permit system enables the District to fulfill its
obligations on the basis of information received from process-
ing applications, to inventory the amount of pollution in the
air, the sources of air pollution, the reduction that various
programs have achieved, and the effect that new programs will
have.
The permit system, coupled with a fee system,quite prop-
erly, shifts a portion of the cost of the air pollution control
program onto the operators of the equipment emitting the air
contaminants, rather than making the general county taxpayer
bear the entire burden.
Advantages to Industry
Requiring approval by the Air Pollution Control District
prior to construction has saved many companies the expense of
installing and subsequently replacing inadequate control equip-
ment. The District engineers are experts in the field of air
pollution and their experience has qualified them to recognize
errors or deficiencies in the design of control equipment. By
requiring a pre-construction application for a permit, our
• -
engineers can make recommendations which enable the applicant
to complete needed changes in the planning and blue-print stages
rather than to make higher-priced physical changes at a later
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date# District experience has shown that poorly designed or
improperly operated air pollution control equipment not only
does not achieve the degree of control required, but, may
actually increase air pollution problems. The permit system
has proved to be the most effective means to avoid such costly
mistakes.
Operating under the permit system, industry has com-
plete freedom of choice in the selection of basic equipment.
The selection of control equipment, however, is limited to
such equipment as has a reasonable chance of .successfully
eliminating, or reducing to acceptable levels, the air con-
taminants it is intended to control.
Some critics of the permit system claim that it stifles
initiative and the development of new processes. Nothing is
further from the truth. In staying at least one pace ahead
of the problem, the permit system of the District has produced
a great many air pollution control "firsts"during the past
twenty years. Far from discouraging inventiveness, the records
show that necessity to meet the standards guaranteed by the
permit system has fostered ingenuity within fundamentally sound
engineering principles.
There is a more recent and highly important use of the
permit system and its concept of consistent permit unit bound-
aries. The confirmation of equipment cost through which the
industrial community seeks to gain the tax credit or tax relief
provided by federal and state legislation for air pollution
-------
control installations can be achieved rapidly through the
permit records.
The engineer's evaluations and recommendations are
made solely upon the engineering merits of an installation.
As such they are not involved with any equities, or advantages,
or disadvantages to the residents of the District resulting
from requiring compliance or resulting from granting a variance.
The State law and the District's rules, however, provide the
applicant an opportunity to appeal the District's denial or
conditional approval of an authority to construct, permit to
operate or permit to sell or rent. Hearing Board, completely
separate from the District, composed of two lawyers and one
engineer is provided whose function is to hear evidence from
both the petitioner and the District. After considering the
evidence and the equities, the Hearing Board renders its de-
cision. It grants some variances to operate in violation of
District rules for limited periods of time. This is only done
when the petitioner proves to the Hearing Board's satisfaction
——— in. _ I- I III - .1 —¦ — - —— , , „| I.I . —^
that he is making diligent efforts to bring the operation into
compliance with all District rules. No variance can be granted
to continue a nuisance.
Emission Surveys
As mentioned earlier, the permit system provides a ready
Inventory source of equipment and air contaminants. The latest
inventory of all types of air contaminants from stationary sources
in Los Angeles County shows that we are preventing 5,5(60 tons
-18-
-------
per day of air contaminants from entering the atmosphere.
This means we have achieved control of slightly over 78 per
cent of all emissions from stationary sources by use of. the
permit system. See Table I. By comparison, the control of
moving sources in Los Angeles County, without a permit system,
prevents only 1,680 tons per day of air contaminants from en-
tering the atmosphere. Thus, the program for the control of
moving sources achieves less than 12 per cent control of all
emissions from such moving sources.
TABLE I.
*
INVENTORY OF AIR CONTAMINANTS FROM STATIONARY SOURCES
UNDER THE PERMIT SYSTEM IN LOS ANGELES COUNTY, JANUARY 1968
lONTAMINANT
TOTAL
POTENTIAL
TONS/DAY
CURRENTLY
BEING
EMITTED
TONS/DAY
PREVENTED
BY
CONTROLS
TONS/DAY
PER CENT
CONTROL
ACHIEVED
MAJOR REMAINING
STATIONARY
SOURCES
[ydro carbons &
•ther Org.Gases
2,100
760
1,340
63.8"
Petroleum Industry &
Organic Solvent Usag
^srosols
530
55
475
89.6
Fuel Combustion
Eitrogen Oxides
455
330
125
27.5
Fuel Combustion
larbon Monoxide
2,130
80
2,050
96.2
Petroleum Industry
iulfur Dioxide
1,845
275
1,570
85.0
Chemical Industry,
Fuel Combustion,
Petroleum Industry
TOTAL
7,060
1,500
5,560
78.7
-19-
-------
CONCLUSIONS
Through the administration of the permit system in
Los Angeles County, control measures have been applied to such
diverse sources and operations as coffee roasters, petroleum
*
iefixhneries, rock crushers, and hot asphalt plants. From the,
smelting of metals to the painting of manufactured goods, all
stationary industrial operations have been brought within the
scope of the permit system of the air pollution control program.
The following statistics, illustrating the consider-
able experience of the District with the administration of a
permit system, lend weight to the conclusion that a permit sys-
tem is workable, feasible and effective in reducing air pollu-
tion. The total number of permits issued by the Air Pollution
Control District of Los Angeles County since February 1, 1948
is 103,724«. This includes permits issued for new equipment,
altered equipment, change of location, and transfer of owner-
ship. The number of permits issued for new basic equipment
units now amounts to 71,229*, and these basic.equipment units
are valued at $1,157,261,300*. The number of permits issued
for hew control equipment units now amounts to 14,794* and these
control equipment units are valued at' $141,964,900*. During
^this same period of time 5,815* permits were denied to both
basic and control equipment units.
The following features of the administration of the
• •
permit system in Los Angeles County are worthy of emphasis:
*. Through February 29, 1968.
-20-
-------
!• The permit system prevents the installation,
alteration, replacement, or operation of equip-
ment which may emit air contaminants in excess
of that allowed by law or of equipment, which
may not eliminate, reduce or control the issu-
ance of air contaminants to the standards pre-
scribed by law. The permit system accomplishes
this by the application of engineering science
and does not involve policeman, prosecutors, or
courts.
2. The permit system incorporates a list of equip-
ment which is exempt from making application
for permit. Experience has shown this equipment
to contribute little to air pollution.
3. The permit system, with its pre-construction
review of applications by expert air pollution
engineers, saves the applicant money by prevent-
ing the installation of equipment which cannot
be operated if it does not comply with air pollu-
tion control laws.
4. The permit system, by means of the Hearing Board,
provides an inexpensive legal procedure for appeals
and for requests for variances.
_ . . »
-21-
-------
5. The permit system, with its provision for fees,
shifts some of the burden of an air pollution
control district onto those directly responsible
for creating the air pollution.
.6. The permit system has not stopped the expansion
of industry in Los Angeles County.
7. The administration of the permit system for the
past twenty years has provided the technical
know-how to control most air pollution emissions.
In fact, much of the hardware required to control
air contaminants can now be bought ready-made
off the shelf.
In conclusion, with the permit system, dependence on
*. '
voluntary efforts by air polluters to reduce their pollution
is eliminated. A voluntary control effort is rarely satisfac-v
tory in terms of control effectiveness or time required to
achieve control. In fact, it has been said that man has only
approximately 30 years to establish whether he can remain on
this planet or not and voluntary efforts are not likely to meet
fchattschedule.
Experience has shown that public statements by manage-
ment proclaiming their policy of controlling pollution from
their plants and complying with local air pollution laws are
not always put into practice by lower echelons of the company.
These lower echelons are concerned with showing a good profit
end loss record and are willing to sacrifice or postpone air
-22-
-------
pollution control expenditures for that purpose. More than
once these lower echelons have made attempts to disguise the
facts about an air pollution problem because of the money
situation. Recently, plant personnel, less pure than bhe
advertised product of their large corporation, were found
stuffing rags into a condenser to pass a permit inspection.
If this can happen at a corporation which maintains its own
permanent air pollution staff and actively participates in
the Air Pollution Control Association, even at this meeting,
the need for a thorough review as provided by a permit
system becomes evident.
(1) Lunche, R.G., Lemke, E.E., Weimer, R.L., Verssen, J.A.,
"Air Pollution Engineering in Los Angeles County",
MsrAngeles County Air Pollution Control District,
July 1966.
-23-
-------
appendix f
¦t
I '• . .•JOHN F, SKOKY
•V."
*V*« t ¦»»*• ^».t ,' v .. • ,•; ,* • • . ~ ,•
'• • •• ' • • . . V. . ''
in air pollution control agencies
Irvln Gartner
Research Associate, Center for Air Environment Studies, The Pennsylvania State University
Based on (lie author's nationwide survey of salaries in mi.-5
comparatively analyzes the results with pertinent occupations jr.
major national .salary surveys by the Bureau of Labor Statist
National Science Foundation, the; National Society of l'iufr.^i'::.:
Engineers, and College Placement Council. This baseline
tivc investigation indicates agency salaries are .significantly 1|,A*
than pa}' levels of the competition in today's labor market. 'IV*'
conditions are compounded by the disadvantage of compact iv>!:
fimnll organizational size will) consequent limitations on imie.i"1-"
Opportunities J or gnnvlh and recognition. Salary setting ref""-!:-' •
dations for jobs unique to government, and otlifrr j~<*.».-¦11j:-;: 1'
coping with the poor competitive .situation (for recruiting, rf*t1 ¦:¦
And motivating manpower) are presented.
Sftptombcc ' v6C V&!umo 10, l^o, 9
-------
;ta
r o
CAL
A RifTQ
i ft £ C3*
Govcniinciil i;u»k.s third in the following distribution 0;
lioti-agricultural payrolls: ' .
Arc slalT salaries for air pollution control agency positions
realistic itt today's competitive labor market ; i.e., can they l)c
expected to attract, retain, ami motivate the kinds ami quanti-
ties of employees needed to 'meet today's and tomorrow's
• control agency needs? If not, what arc the alternative possi-
bilities?
The questions arc examined in terms of prevailing rates of
pay for ten key occupations in .state and local air pollution
control agencies, the attraction of the better college graduates
to small organizations with limited growth and promotional
opiK>rlunities, and the related problem of inadequate supply
versus"demand for experienced personnel in a relatively new
field.
The-research data are based on the author's 1007 nation-
wade survey of regional, ."state, and loeai air pollution control
bOonriAc I ha «w«jt»n» iu tviv .ivi'jmvmj iiv »j 11 mm» ».
employees arc summarized and comparatively analyzed with
pertinent occupations in major national salary surveys. The
scope, of this paper precluded in-depth analyses by specific
levels of government, locale, mzc of population served, nature
of air pollution problem, political and economic variables,
organizational and division of work variables, manpower bio-
graphical and behavioral considerations, and a myriad of other
related variables.
Slate and Local Control Agency Employment in
National Perspective
The latest United .States Bureau of LaborStatisticsbulletin1
provides the following big picture perspective as of 19GG.
The United States as a wliote had almost 04 million employees
on non-agricultural payrolls of which almost 11 million were
government employees. Compared with majc." industrial
divisions of employment on non-agricultural payrolls, govern-
ment at nil levels employed 17 per cent, well on the way to
almost one out of every 5 such employees in the nation.
Manufacturing
Wholesale ami retail trade
Government
•Service and miscellaneous
Transportation and public utilities
Contract construction
Finance, insurance, and real estate
Mining '
Total
30.1
20.8
17.0
1-J.7
0.5
5.1
4.0
0.0
ioo ."o
The ever-increasing significance of governmental employ-
ment, and more particularly state ami loeai government
employment, is strikingly documented by the L". S. Bureau o;
Census data on public employees and payrolls from lOlG'ta
19G6.1
At the time of this nationwide study, there were approxi-
mately 3000 federal, state, and local air pollution control
agency filled positions, approximately two-thirds of whiea
were at the state, regional, and local levels. "Regional" U
intermittently referred to in the context of the Air Quality
Act of 1007. At (he time of the writing of this p.iprr tii(<
federal level was engaged in the battle, of the budget between
the-executive and legislative branches with the possibility ij
a 4 to 0 billion dollar cut in the President's requested ri.-r.u
19G3 budget, most of the cut to be taken reportedly t'roai
agencies not involved with the Vietnam War. The immediate
future could be quite unclear as to the quantity of addition::!
positions to be filled, because of the major financi:d import ..i
federal gra-nls-in-nid on state and local agencies as well a<
regional efforts called for in the 1907 Air Quality Aei: tiir
impact covers all levels of government from federal to Ior;ii.
At the earliest possibility, however, it is realistic to expect li-.p
iinanced ami subjected to tne tots oi tne competition n>:
talent: private industrial employers as well as federally
financed governmental, educational, ami research in-tiiuti'-ii-
' throughout the. country. A eur.-nry look at the Xatio:::ii
Center lor Air'Pollution Control'.-. itTpiest for -130 new
tions for the federal agency's Direct Oi>craiion> for tied yen;
19G0 provides some idea of the quality desired t'a> reflected :n
the GS levels) and some of the quantity to be recruited at ir.e
earliest possibility, proportionately for the following activi-
ties':
jRcsearch 161
Control Technology 77
Criteria and Standards 84
Abatement and Control
Motor Vehicle Control
Training
Total
Seventy of the above positions called for GS-14 and la
220
17
J1
439
Tabto I. Average Salaries: Nationwide Stud/ of State and Local Air Pollution Control Agencies, Mid-Year 1957
Occupational Group
Number
of Employees
Mean
Median
1st Quartile
I. Ctieniic.il Fru'.ineers
73
J11.351
$10,D
i 8,fA)
?. 1." c c! i .1 r i s c .i 1 Ln^ineerS
24
11.794
'11.255
9.550
3. Srimi.uy
20
. i2.r'0
12.COD
ID.505
4. Mi'jCcli.ifieous engineers
130
ii,r;6
11.50)
10.033
5. Inspectors
235
8/03 .
5'.120
6.624
S. instrument Technicians
83
7,523
8.532
5,903
7. Meteorologists
6
11.570
11.901
7.£90
8. Cliemi'.i',
94
9,761
9,<03
7.500
9. Si'initari.ins
70
7.379
7. COD
6,0 V)
10. ISiolof.i^ts
C
11.101
9,COO
8.193
Middle 50% Ranjc
3rd QuarMe
$53.?'.?
13.2:2
13.23'i
9.E2S
B.5S0
11,504
11.<12
B.Cii
)2.33i
^Crurfiol of tho Atf Po'lgltOA Coat.ol Ano*10*
-------
i,ilarics, |
nui! cxlviMrtl salary (minimum-maximum). ranges for surh
key positions in the Federal Govcrnmcntluc its follows (cxccu-
live levels .ire GS-1G, 17, and IS):
GS-H
CS-15
Present
$15,8-11 -20,503
18,401 -2.5,921
Authorized (and
still expected)
Increase, Julv 1,
19G8)* *
S1C.04G- "22,031
19,780-25,711
l.nftlfH'ei ^ IIILvmi; i
Engineers
By Specialization:"
Chemical Engineers
Sanitary Enpnecrs
Mechanical engineers
Miscellaneous engineers
Median
14,3?0
14, <-".3
.ie.no
Local, Stole, and Regional Control Agencies Salaries
in Comparison wilh the Competition
Are air pollution control agency salaries realistic in today's'
competitive labor market? Let us lake a look at the results of
the nationwide study of stale, local, and regional ngencie.s.
The comparative analyses are based on broad occupational
groups in the control agencies. This method insures promised
confidentiality of specific agency and individual employee
data. When the field has grown to Adequate statistical size
ond the position classification plans ami/or organizational
division of work have advanced in development, it may be
jKjssible and appropriate to use the key or benchmark job
Methodology in future salary studies.
One hundred and eighteen local and stale air pollution
control agencies wilh 1G0S budgeted positions provided
compilable responses to questionnaires mailed to all listed in
the 1067 Directory of G'oicnnnental Air Pollution Control
Agencies,* plus others discovered in an exploratory survey of
state and local health agencies concerning their future/current
plans relative to air pollution control. In addition, reference
was made to National Center.data on the status ci str.to
and local control agencies presented in Hearing* the
l-n-tcc' on Air ami ti'uurr iYmu--
lion of the Committee on Public Works5-in April and May
I9G7.
Tlic supply of talent might readily meet the demand of
unfilled positions in this comparatively small Held if it existed
in a vacuum; realistically, the national employment disirilui-
tion and demands (outlined earlier) must he taken into ac-
count. Our expanding economy, "rowing governmental
activities (civilian and military), and resulting "full employ-
ment" (economists- interpretation of unemployment under
four (per cent)) — nationally results in a highly competitive
situation. Perhaps the most competitive of all is the engineer-
ing profession. Numerically it. is the largest among siatc
one local control agencies. The 247 engineers in the author's
Study represents about 50% of the 10G7 .statistical universe.
Tables f and II almost speak for themselves. Central ten-
dency data for chemical, sanitary, mechanical, and miscellane-
ous engineers in slate and local control agencies are less than
the median .-alary figures provided by the .Society of Profes-
sional Lugincers recently released nationwide .survey* con-
ducted in J0G7. Control agency salaries were found to lag
behind the national market figures by $-000 to -55000 per
year; when converted to percentages the differentials are even
more striking. Control agency engineer's salaries ai>o lag
(although the differential is not so great) when compared with
City, state, and federal government central tendency data from
the Society for PrcilVs>ioual Knginecrs 1007 Survey.
following ihc engineers, the next largest state and local
COnliol agency occupational group is the inspectors. 'Jiii:i is
true not (.n'y for ||r-. writer's itudy i>i:L iialn>Mai'iy 1:1 terms of
total rxi.siuig position.1!. The 2.15 inspectors in Table 1 rcpre-
By employer:
Consulting Firms
Industry
Public Utilities
Educational Institutions
Non-Profit Research
Federal Government
City/County Government
Stato Govcrnm®««
By Degree:
Doctor's (Ph.D.)
• .Master's
All Society Members Reporting
JS.4G0
14,510
13.C10
16,K0
14,140
13.6C0
12,950
12.203
19,310
15,230
14,310
*Pos! APCA Conf. Koto:
July t, J'.iW.
Increases hnvo been nmdo on
Source: The National Society ot Professional Engineers, survey con-
ducted in 1S57 and released March 1S6S.
sent approximately 50% of the universe. Comparative
¦analyses of the salary data for air pollution control 'inspectors
are difficult. This is true for other occupational groups which
arc unique to government, i.e., have no comparable couatcr-
in ineit;sii> *'
midway in terms of central tendency data, with the except-':'
of the federal government salary ranges going "p »"
GS-9, potentially approaching comparability in grow th ai--'
promotion possibilities; however, G'S-.Vs starting salary ob-
viously-has not proved competitive with average l-'1" "
industry offers of SGG60 to our Associate Degree candidatci n
Klcctrical and KleelroniVs Technology at The JYnii^yb ;1": '
Stale. University.'
Six incteoii'ii)r;ists (about one third of all p.> ;i; w>n^ at i
fclaLc
for this
npproxiniitlcd ihc level found by
¦«x meteor^ (mc (;f ;i(i .
ic: tun! local Jcveis'laM year) provided indiv.du.-d pay -
1 able 1 their rentral tendency
hum cu tlic level louiul by the iS'uliouuf .Science .»*
Scplember I94f Volumt 1 ft. Mo. 9
-------
TAFF salaries.
:;n I /' il
lion in itsl:isl biennial nationwide survey in )006 (sec Table Y)
iv»cd on salaries of over GOOD meteorologists. The 10GS XSF
ttirvcy is now in llic data coHcction proofs-; in cooi>cr:ttion with
various national professional societies. '
Similar commentary applies to the salaries of the eight
biologists in the stutc-and local air pollution control study,
Willi a mean mmm ..-m...... .
li^nri'. I'liy.virians, i.e., M.I ).'.•> in llm stair and loral r health nitnu-y. Them
was an inadequate response front physicists, electronic d.ttn
processing specialists, and pnlilic inloim.ttiou S|ieria!i>t.s for
purposes of comparative salary interpretations. 1 tie 1-.'.^hest
average salary figure in this study was .¦>1-1,71)0 lor the nir.na;.;c-
inent-admini.-lrativc ;',roup based on nineteen respondents in
cither the director or deputy director position, i.e., number
one or number two portion in charge,o/ their re.-.;>rc;ive coa-
Irol agencies. .Such limited data preclude further eoinu',cut.
Solciries in Ihc Labor Markel for Inexperienced College
. Graduales-Io-Bc
With control jip-iicy development blossoming with the 1003,
19G"), and 1907 Clean Air and Air Quality Acts has conic the
related problem of inadequate supply versus demand for ex-
perienced personnel in a relatively nc-w ficid, at least relatively
new for the. majority of air pollution control agencies throu^h-
HI. Averape Salaries for Selected Occupations in Pn'vate Industry. United States except Alaska and Hawaii. June 19o7and Percent
Increase in Mean Salaries since February - Marcn »5co
Annual Salaries
Occupation and Class
Number
of
Employees
Mean
Median
*
Middle Range
First Third
Quarlilc Quartile
Percent
increase
in mean
Salaries
2.C97
5 7.550
$ 7.<23
S 6,555
$ 8.2:0
6.8
3.?C3
8,<32
8.400
7,783
9,048
7.6
S.579
9,719
•9.640
8.SOS
10.392
6.7
9.677
12.C44
11.820
10.6SO
13.330
5.2
r.m
14.405
14,340
12,900
15,755 -
4-3
ih./.vi
1**. 333
It « /w'M
«
4,/tV
1 - « 1 »
n,y/j
i-». t jr.
2\, vGO
<45
'24,676
24,000
• 21,060
27,<52
5-3
10.58-7
8.3SS
8.400
7,920
8.855 '
S.O '
23.273
9,078
9,000
8.496
9.540
6.9
77.570
10.330
10,224
9,528
11,043
5.6
105.705
12.<24
12.300
11.160
13.500
5.4
65.835
14,523
14.333
12,924
15,840
0.3
35,674
15.604
16,603
14,743
" 13.420
«.9
11.930
19.332
19,234
17,292
21,012
3.5
2,955
22.235
21,500
19,632
24,334
2.8
5.625
5.355
5,400
4.728
5,915
5.2
15.388
6,305
6,252
5,724
6.763
5.1
25.375
7,235
7.1S3
6.5S3
7.812
3.6
23.272
8,318
8,256
7,655
8.SS0
5.2
14.927
9.341
9.216
8.592
9.560
<-5
Chemists I
Chemists I)
Chemists III '
Chemists IV
Chemists V
CiiciuisiS Yii
Chemists VIII
Engineers I
Engineers II
Eiv,in*:ers 111
fr.gineers IV
Engineers V
Engineers VI
Engineers VII
Engineers Vlll
Fr.-!:">oring Technicians I
Engineering Technicians II
Engineering Technicians III
Engineering Technicians IV
Engineering Technicians V
ce: ,."*une National Survey of Professional. Administrative, Technical and Clerical Pay, U. S. Department of Labor, Bureau of Labor Statistics
•tin 1535, published January 1963.
Table IV. Selected Comparisons of Average Annual Industrial Salaries, June 1S67, v/ith Federal Salary Rates under the General scneauie
Occupation and Class
Average
annual
salaries
in private
industry
Salary rates for Federal Employees under the General Schedule
Grade
Per annum rates and steps
10
Engineering technicians I
Chemists I
Engineers I
Enpmeertn.-; technician V
Chemists Vlt
Engineers VIJ
Chc-miMs vill
E'n.-.mecrs yui
S 5.306
GS3 i } 4.4C&
S 4,615
$ 4.764"
i 4.913
$ 5.052
$ 5.211
5 5.360
S 5.550
$ 5.653
7,550
GS5
5.565
5,751
5,937
6.123
6.309
6.495
6.631
6. £67
7.053
8.3S3
GS5
9,341
GS9
8.054
8,323
8.592
8,861
9,130
9.399
9.653
9.937
10,205
20.110
GS14
15,541
16.369
16.637
17,425
17.953
18.431
19,009
19.537
20.055
13.332
GS14
23.303
24,676
G$15
13,404
19,017
19.630
20,243
20,856
21,469
22.C32
22.695
22.235
GS15
S 5.S07
30.^70
20.53J
,23,921
KfAdc* or lc*i;lv vl CCHjin occupation! linciuCin£ Cfi^inceu jnU iciciilnli).
|JSA APo.'JuIJaa Conf/ol /aiOvol'Ol
-------
lW onunlry. This brings us In anoiher part of the ques-
tion set forlh at ll«o oul.-et, namely, ;iir pollution control
Ktlaries in today's competitive labor market for attracting
nn«l motivating !Iution control chcmiea! engineering salaries at the state and
local levels are exceeded hy the average, oiler lo inexperienced
master's degree candidates.
• Uccenl offers to inexperienced caJidtdales 'iwaiWWs
degree in chemistry nvrraged SS7-1X per year as compared with
ri Prs' c.t'.~rMh' !v;uv ]\\ ;• p'>llvii:r>ti c>u'i"ol survey of
JfTiOO cr.d - ir.r;:::,:-. of i'j-IUS. Candidate-: for master's
decrees in chemistry have recent offers averaging Si0,320 per
year as compared with the median of $0403 almost $1000
above the highest salary among 50% and close to Si GOG below
the lop salary of 75%, i.e., the third quartiie.
Since the cducalior.nl requirements for the beginning sani-
tarian differ considerably throughout the country, but in many
instances require a bachelor's degree not restricted to any
'particular discipline, it seems conservatively appropriate to
compare the average salary recently being offered lo bachelor's
degree candidates in tiie humanities and social sciences (the
lowest paying of the various educational fields reported).
These young graduates have recently been offered an average
of $73t>S per year as compared to a median of $7000, and a
mean of S7379 and a third quartiie of SSOSG reported bv .sani-
tarians in state and local air pollution control assignments..
Jn other words the inexperienced decree candidates arc being
offered by industry (a) higher starting salaries than over 50%
of the woiking sanitarians salaries reported. (6) approximately
$700 less than the highest salary among 75% of ail sanitarians
KUrveyed, and (c) approximately the same, salary as the. rvvcr-
Hgc idl saiiilari.-iii-> arc receiving l«»r the entire gamut of re-
>.poiisilii!il n's includingsupervisory nssigmuenls.
*i*«» cotifluili' iJiis bleak outlook for air pollution control
recruiting: rnid retention of college graduates, one further com-
parison of the average oilers to master's decree candidates in
business administration, industrial management, or commerce
w pertinent i;i li;-ht of the need for administrative talent
throughout the country. i'"or those receiving the master's
decree i;;icr receiving a hon-tccniiical i;::iiei;:.'i.cuate degree,
tbc :iver.-i;;c annual salary offered is Si0,050; for tno.-e receiv-
ing tlie master'n degree ni u-r a technical undergraduate dei'.ree,
the nvcr;«j;c offer i i $iO,J:CO ;ier year. .Sinco we don'i have u
COinpariible occupational Kr^uj' in tho air poliulion control
Mtnly ilireet eoit>p.in--ous ai'e urn cniireiy ajipropnaie. Ilovv-
ever, it is lalher ilisconeerliic: to look at the 'salaries''repot ini
by ll-.o 10 directors and deputy directors of air polhiliott i-!) and third (piarlile.of Sio
/tie |iresenled to efiuelude. this section but not. with any claim
of slalislieal worth in li^htof the. very limiteilsamplo.
Occupations Unique fo Government
As noted above air pollution rouirol inspectors and sani-
tarians are oerupalional groups wliicit have in r(iii\iac,r. llic
jnohlem of bein^ unique lo the. public service, i.e., with no
comparable counterparts in nongovernmental or;;ani:.atina.s..
Such occupations have been a lon;;-time problem for -nvent-
mcntal salary setting. Much of the concern relates to the
prevalent method for (and particularly the Ie;;i>l.-itivp imple-
mentation of) setting salaries for ail jobs in government. Tlic
preferred nietliodnloiiy 1ms been and continues to be tiic u>c
of prevailing community rale surveys. This approach is well
illustrated by the United Stales Bureau of Labor Statistic.,'
Notional Survey of Adnrinislmlivc, Technical, and Ckricnl Pc.y
referred to throughout this article; in this instance, the. federal
government's "community" is the nation of competing private
industrial employers.
'I'llis nationwide i-oinmunily of competition is a rcalMic one
for slate and local levels of Kovernment competing for scarce
manpower resources which cannot be readily recruited in the
immediate "community" of the region, state, or locality. The'
prevailing rate approach to salary setting has cnntributcii
much to realistic, competitive levels of compensation for those
jurisdictions which have been able to have.their findings iaip'is-
lueuled by annual (in some cases scmi-aununi)' .¦nijusfnieuU
based on comparative analyses of prevailing community pay
data for key or benchmark jobs.
This policy has the disadvantage of merely "eatchinj; v;p
AVjt)^ 'he |K,f * t! *' HipM'w iiu'fi* ri * «-
of months (many times extending to years) "after the fact -
of .surveying, compiling, and analytically applying prrvaiia;;;
pay rates,'incorporating resulting pay adjustment reroa'.nicr.ii-
ations in executive budgetary recpiests, reviewing the.;e by t;-.c
legislative body with the purse string power under con-.pciiP.'^
prcsssurc of all. other monetary demands at budget scuias
time (annually in some jurisdictions; biannuaiiy in others).
Table V. Median Annual Salaries of Full-Time Emotoyccf CiviliJa
Scientists, for Selected fields and Highest Degree, iS66
Three Selected Median
Scientific and Technical Number (orlctal
fields and fiighest of of a"
Oegrees Scientists Employers
AH fields
Chemistry
Ph.D.
Professional Medical
Master's
Bachelor's
Less than Onchelor'S
Moleorulo^y
Ph.D.
Professional Medical
Master's
. Bachelor's
less than fiachclor's
Giolofieo! Sciences
f')>.0.
Piofossiorial Medical
M.'liter's
Uaciielor's
Lc-si than D.ichc'or's
2<2.7C3
65.917
6,28)
29,633
j4.c:o
)5,W
J1.K0
lo.r-c-o
jn.r.M
11
JV.C-J0
SoufCc: N.-itionnl Itrc.istrf" ol r.c'oniitic 1 n,^(, .
f4.>tiOna| V.cic mco V/.» i In" (I. **
A/ncnC-an oitoitco /.^nnpo^Cf,
t«pl«n.ber k?46 10, Ho. 9.
-------
The above complications are further involved for those
particular occupations which have no counterpart in private
industry.4 This has resulted in :t long standing practice of
sonic public jurisdictions more or less "looking in the mirror,"
i.e., surveying salaries of similar occupations in other govern-
mental jurisdictions. An example would be the surveying of
'sanitarians pay rates in other public health agencies. It has
been observed that this method has "the equally hazardous
possible effects of either .1 stalemate or an unwarranted escala-
tion of rates for all resulting from the actions of a few."" In
'response to the request 10 "find a better way." the late Louis
Kroeger ami his associates applied their rich and varied back-
grounds to produce a report- requested by fellow professionals
with the following pertinent conciiisiousand recommendations
considered worthy of extensive quotation here:
ll't/inif thai to an extent the problem iscrentcd by require-
ments of law tint agencies should pay. the prevailing rale,
»• t i:a • V- »4* Ci'
lho< ptTuliar to public set vice.
uv rcconiiiint-l that thc.-c laws he amended to require only
that prevailing pay practices be "taken into account" in
SCttir.K public salaries. -
JIV/in-/ thai part of the diliieuily in interpreting and using
any salary data whie-h may be gathered i> thai in common
practice 1 lie data are now gathered about all employees, re-
gard'-e« of longt b of service or otlicr considerations.
lit Tccommcit'l that .-alary data be gathered only for the
hirh;; rate, siine tliis is the single point ut which salaries arc a
means o:" competing in the job market.
ll'f fir,-! that some of the problem is caused by the wide-
spread n-c of five-step pay plans, applying the same salary
jnciea,eiits to positions of all kinds wit hum regard to inherent
^differencesin their nature.
UlJ't tccommcii'l serious consideration of .1 concept first
ftjtfcd in Hartford, Conneciirut, which recognizes more
effectively the diiTering natures of positions by. providing
Varying increments nf salary increase at varying limes;
and Klii.-ii provides separ.-ueiy for treatment of nrrmat
growth on the job, .seniority and exceptional service.
H'efind that present practices make no distinction in trcat-
Tncut between non-administrative and administrative posi-
tions aIihoii;;h there are considerable differences in liic com-
petitive conditions thai apply to tiie-e two broad categories.
U'< rcromincii'l two completely dillerenl. methods, as be-
tween the non-administrative ami the administrative,
for (tctcrmiuuig the salaries of chisscs peculiar to the public
icrvirc.
For the iion-adinini.->lralive classes, ice recommend that
salaries beset for classes peculiar to public service in relation
to itiftnm.il ion about, hiring rates for tdl of the occupations
In the private labor market to which individuals of compara-
ble training and interests .might be attracted. Tins can
Cst;iM'.-lt ihi- public; .service in j\ truly eompulilive position,
v.'ill nuke puliln: salaries more directly responsive to enrreut
econanni: 1 oniiuurns, and wiii oveieome the taints we hud ill
the pi e.-cnt .system..
I" or //.Iministrative cla-v^es, ice rcro/umc/id that, ns ft j'.roup,
thev 1* M-i in fair relation to 10I other job.i and thai then,
Vtihiu the ^loop, 1:>1 i 1.-1-1 > 1.11 lias-ivs be lela'.ed to each otner
In.iuily nn the basii of 1 c,-|iou.Mbiiil v, taking. into iiceoiinl tho
f-cvcrul r.ipLcls oi responsibility a-> outlined in ihi.-) report."
Cnunlrr-argumrnls are presented concerning the iievi 1<>
' the last, recommendation above. It is contended that salary
Ktliveysbased oil "onlv the. hiring rate" are poindiallv hazard-
ous attil ltighly volatile if not misleading over relatively short
jicriiids of time ns the job market changes. Consider private
industries1 comparatively large amount of discretion, i!e\ibi!-
ity, itiid speed in making hiring rati: adjustments during
individual negotiations. It is entirely- possible (hat public
Jurisdictions could very well he misled by hiring, rates alone,
except for certain entrance level positions stieh as those which
nre filled by college graduates without experience.
The only other reservation concerns the overly restrictive
recommendation for setting salaries for administrative classes
Oil the one basis of fair internal relationships. Add to this the
•counter wisdom of comparing private industrial prevailing
salaries for administrative positions. The aforementioned
annual Bureau of Labor .Statistics nationwide study has pro-
vided the factual bases for applying the so-called "compar-
ability principle"— another term for the prevailing commu-
nity rates policy; rcsultingsalary adjustment recommendations
have produced increasingly more attractive pay levels, both at
the entrance hiring rates as well as throughput the rate ranges.
The. federal government still has a long way to go to catch up
withits competition at the executive levels but certainly the
noled progress could not have been so realized without the aid
of the "comparability principle."
The key distinction to keep in mind is comparability with
private industrial rates of pay; when such comparability
cannot- be established, comparability with other governmental
jurisdiction rates can result in an unrealistic ii" not vicious
•circle. The recommendations above are therefore worthy of
positive support, with the additional recommendation that
there be flexible hiring rates and related adjustments autho-
rWorl fltiri»wr •- V.7C YJY.ri !««"
VvTiiiiir'Ji Ifii IttC tiCiii 11 \ VI itl ! ii\.'.'\i' j i 1 • I >* iiii.'j
proven most helpful to major governmental employers, in-
cluding the federal level.
Findings and Observations
. The following briefly summarizes the statistical and related
contents presented above:
1. Air pollution control agency employees constitute a minis-
cute part of the total private as wcil as governmental cm-,
plovmcnt market in the United States.
2. Government employment as a whole, and particularly the
state and local levels, has been growing rapidly during the
past 20 years, and is now approaching a ratio of one out of
every five non-agricultural employees.
3. Within the governmental labor market, state and local air
pollution control agencies are also growing but typically
arc disadvantaged by reason of small size of organization
and comparative potential for employee growth and recog-
nition. .
4. With the four to six billion cut in federal funds, immediate
future development of plans under the Air Quality Act of
19G7 may be seriously handicapped by lack 01 funds lor
needed personnel in control agencies at the federal, state,
and local levels.
5. Comparisons of central tendency 10G7 salary data for state
and local air pollution controlagency employees with HI>S,
NSF, and NiSl'lO surveys indicate state and local salaries
below the competition in the labor market.
G. Further comparisons with the lOuT - OS College Placement
Council survey of salary offers to incxpcra-nccd i.e
candidates lor bachelor's and master's degrees resulted in a
. very discouraging picture lor state and local com 10I agency
recruiting of competent college graduates; this condition i>
compounded by the aforementioned disadvantages" of
limited orguni/.iUionid size.
-------
» ,— _
' ji, icfoiiuitendatioiis outlined above, emphasizing {«)
'^Jiliril .-ipplicat i'»n 'I"' prevailing rates policy along the
(if iIn* Ihirifonl I'l.'ni, (h) realistic flexibility in lining
rates I'i'tgovernmental annual and biannual salary
«-c(ling Iu-rifuls. :iikI (r) avoidance of the >(c-ril(* surveys
limitril only to comparisons of other governmental salaries.
Whnl can 1m (lone about (he blo:ik comparative salary
t?ltinli*"'!!? ' '1C obvious, simple answer is lo increase salaries
In clearly competitive levels by moans summarized in item 7
nbove. However, the answer is not so .simple when I lit* fads
of state and local control agency status arc reviewed. Typi-
cally, ^vn-h agencies arc small subdivisions of health depart-
ment* with many manpower shortage specialties in-long est.il>-
lishcd subdivisions competing fur tho budgetary dollars. In
Inrn, the health department as a whole usually must compete
with other departments for needed shares of (lie entire jnris-
dictionM budget. This picture is partially modified by ear-
marked federal grants-in-aid provisions. Salary adjustments
nrc typically late if not last- on the agenda of budgetary deei-
fion-making. meaning that the remaining funds from anti-
cipated revenues, et oL. may be inadequate to meet all needed
increase* in salaries along with increased numbers of positions.
Whnl linpj>ciis? The salary surveys presented above indicate
fonie cumulative results.
Wli.il else lias been happening relative to such results?
Public service employees have been joining unions, have
begun collective bargaining. ami (below the federal level) have
"begun striking in increasing numbers in recent years. The
future impact of such organized employee efforts is to some
extent foretold by what happened earlier in private industry.
Salaries for the.organized can be expected to heroine increas-
ingly eomj>eutive. w i;ii beneficial side effects to some of the
unorganized including adniinis'rative and executive salary
V**rl*. O'lvv ji....• i.jij.. v.*f*r!!:v fif l.-ut :irc
V-., , } v st,:..
mv •"» «'j-N ««4 ii, iv.. (
How cm air pollution control agencies expect to interest
(initially recruit) needed talent*.-md then maintain the interest
on a career basis, in li^ht of the limitations outlined above?
Can a national "treasury'' of information on trained and ex-
perienced manpower be established, maintained, and utilized?
Can such talent become part of an intergovernmental career
system to cope with high priority control needs and at the
same time provide tor the growth and recognition offered
employees in larger organizations? Can intergovernmental
mobility he fostered by intergovernmental retirement systems
or alternative plau> with the same effect of not penalizing the
experienced public servant for moving into new job challenges?
Clin career development plans in the public service 'oe estal>-
lisJied comparable to those found in such holding corporations
as Standard of Jersey? When will Congress pass needed,
related legislation such as the Intergovernmental Personnel
Act sponsored for some years by Senator Muskic, and the
Intergovernmental Manpower Act formulated under the
leadership oi U. 8. Civil Service Commission Chairman .John.
Mary? .
•¦ViiMver.s to these questions, and a myriad of related ones, are
liasic regardless of what a particular salary study may or may
Hot indicate.
"i he nuihijr'b .xdary study of state and local air pollution
¦ control agencies i* :t ha~<-iinc study; it requires refinement, and
coordination with lii.- i-Vderal I9li7 baseline itudv in which
there w:i> very little dup!icatioii of data. The situation calls
for follu\vt;;i attention as ou'hucd in tlie Air ljuahty Act ot
.1007. liu- siuiuld Iic a sophi-iiraled as well a.i coiiipsvhcu-
iivc report —which realistically f.u.vs up to the problem —
riot mere numbers -employed and paid in government, in-
dustry, research, and related atva.i— but an niialy.M.i in depth
•donj; the lines presented in another paper on the lovcia Oi
) P6(j Volvme ) 0, No. 9
zeroes in pragmatically on comparative-progress'in dili'crii,"
air pollution communities/areas, conversely on what ate the
problem areas, ami what are the "manpower" eaiiscs. 1"f-,(»-
power" is placed in quotes because this refers (o the en; ire
spectrum of human clenwnts*-- - (a) internal: within the A l'C
agency, within the government agency above the A l'C agruev
including executive elected and appointed ollieials; and (o)
external:- the legislative body, the judiciary, cotutmiuitv
power structure, news media, and related "manpower" varia-
bles.
Application of the Pl'HS approach to intergovernmental
decision-making in pollution control is called for at the earliest
possibility— to have positive effect in determining intci!i.;cat
alternatives in program, budget, and implementation via
manpower, equipment, facilities, and incentive systems tor
polluters lo speed up control at the sources of pollution. The
10G7 Air Quality Act sets the stage, for creative federalism,
i.e., spelling out the roles of federal and state levels, with
rather tight timetables for states to establish regional
dards and implement- them. Hold, direct actions may well
allocate our citizens money (taxes coliected) and radically
increased supplemental funds from fines tor violations on die
basis of results achieved, i.e., not primarily on the basis of
repeated extensions of budget and grant "pitches," but upon
reduction of pollution at the sources, with obvious conse-
quences for control agencies and polluters. Scarce, highly
paid professionals are not needed to measure pollution at ;!:e
sources; so-called paraprofcs.Monals and subproiessiuaals
requiring comparatively limited education, training, and
financial expenditures, can help fill the manpower gap."reduce
poverty as well as pollution through the strategy of cross-
eommitmcnt involving the interaction of two (or more) pro-
grams with different- but--mutually helpful goals.
* t ' . . . . * . . -
MChi'WWtCMVjriitunt
The research for ihi.s paper was snppiMu-u in (i;u i,I¦>" a ti.iu! frorr.
the National Center, for Air. Pulltition Control, USi'US/lUAV,
Grant No. Al'UOuW. ...
References
1. U. S. Bureau of Labor Statistics, "Employment and Earn-
ings for States ami Areas HKV.l-GG," Bulletin No. 1370—1,
p. XVI, Washington, 1J. C. (ISiG7).
2. U. S. Bureau of the Census, "Chart Book on Goveriimcnj.il
Finances anil Employment: 19G7," GF No. 1">, J>. 3-,
Washington, J). C. U'Jii").
3. National Center for Air Pollution Control, U.S.iMl-^-
Fiscal Year lDG'J budget reipie.-l, p. 'Jt, Washington, J). C.
(10ti.S).
4. "IJHJ7 Directory: Governmental Air Pn'iulmii Amende*.
Air Pollution Control As*<><-tatiini and National tenter lor
Air Pullutimi Coulrol, l-.S.P.Il.S., Pittsburgh (I'.'m )¦
3. I'. S. Conmcss, Senate, Subciniimutee "I the
on rublie Wotks, "Healings, S. 7St> ami Ilelatcil •^':'.iurl'
l'crlairiing to the Pieveniiiin and Comml ui Air I'.i.nimm.
lltllli Coni'iess, 1st Sc.s-iim, pp. 11 lit) - l'-'N-S, W a~!nn^i»ri,
l).C.(ltHM). ' . . ,
6. Natioicil Sn:iety of Pntfcs-Moiia! KngtiU'Oi'J ic"f¦-",ri-•
Kngincers* Income mul SalarvSurvev - 1 ,.Hi7,* \\ »«hi"gi"«i.
1). C. fl'.it'.S). ' '
7. U.S. Bureau .if l.al.or Stalisti.s. "j'.ltw Ni.Ii<•;.at >¦'rv»v •-
Professional A'linitii-tralivc, Teelinical, and t iciical •>>,
Bullet in ,\o. I.'iV'i, \\ a^hni'^iMii, I). (.
8. Nntiuiial Science l'«/umlai ton. '"National WcgMcr ot .*¦. .cn-
tific and Technirnl Personnel." Wasiiine'oii I'. C ¦ it'.M'l. t
9. l'laocmeut Service ft-npuiiii-lied herniate), I he l-ca»s>»-
Vauia Jit a*e h'nivcrsity, I'nivt-i-ii y Pai-'ic. I'a- n'.'0N l.
JO. ("olli-i.c i'iaceme.lil t'oua.-;!. "("•¦ia ee I'laecie.enl t-oviaii . •»
nrv Snivcv," Kcji^.i t No. 'J, 1'.>¦ t Inei.em, i'a. t I'h.s i.
ji. Ki'oiv.er, j., i:,,,.;,. I-:., \Vi:i:..n.-, I-:.
11. J*.., "i'l I'.in,: J ijJm Iniaji!*; to ( .i/vi-i m ti'.-a I ( iv.
Jicporl No. 0 K), l'nblie. JVisonncl A^oc-'ln'o,
fl'Jiit). •
J2. Jtii'l.. 3 - -i. „r,
i:t. i'lthln; I,aw 'jO-l-tX. «i0th Con^tc:;.\ S. 7S0 t-Nov. _M, 1»" /•
-------
'I IIC iMC.xican K1JV'L"i miii'iii .s loiig-.staiKI-
ing policy to promote "Mexicani/.n-
tion" of foreigti-owntrcl companies op-
crntinj; within 1"ts borders has won a
success with the sale by General
Electric of 10',j. of its Mexican subsidi-
ary to Mexican nationals. General
Electric dc Mexico, the country's hij;-
jjest manufacturer of electrical prod-
ucts, had been one of the major
Mexican firms still wholly owned by a
foreign parent. Last year it earned
$2.7 million on sales of 3-10 million.
GK's yielding to government sugges-
tions to Mexicani/.e, after prolonged
tnll;s, may put increased pressure on
Other large wholly owned subsidiaries
of foreign companies, such as General
Motors and Ford, to do likewise.
GE's stock offering, restricted to
'Mexican nationals and foreigners who
fire permanent residents, was an ini-
tial success. The -i.J6.000 shares sold
to Mexican investors at the equivalent
of ?550 a share were oversubscribed
' and quickly rose in price on the Mex-
ico Gily slock exchange.
The Mexicanization of Mexican in-
dustry is a complex issue of interwoven
Jaws,- official decrees, and unofficial
arm twisting. Major sectors of the
economy, among them the petroleum
industry, the production of basic pet-
rochemicals and most fertilizers, elec-
tric power, and railroads am run solely
hv
general, though, Me.xicanizalion is not
a matter of nationalization but rather
of participation of private Mexican in- ¦
vestors in partnership with foreign
Capital.
Even where there is no legal re-
quirement for Mc.xicanization, govern-
ment policy encourages it. And gov-
ernment officials can apply many sub-
tic pressures to bring it about. Finns
that Mcxicanize may, for example,
find themselves less hindered by offi-
cial red tape. Tax concessions, im-
port licenses, and tariff protection all
may be easier to obtain.
The Mexican affiliates of several
U.S. chemical companies have been
Mexicanizcd for many years. Cela-
nese lias long owned less than half of
its two large Mexican enterprises. Dn
Pont has a wholly owned subsidiary
that makes explosives, paints, and ag-
ricultural chemicals, but most of its
expansion south of the border in the
[last 10 years lias been through four
foint ventures" in which its interest is
40% or less. Union Carbide Mexi-
L'aua, in which the U.S. parent's stake
now is CO'/.., sold Mock lo the Mexican
Hibhc in J 'J00. i\cvei tin-less. nianv
argc Mexican piuducci.s of chemical's
continue to be wholly owned aims of
heir U.S. parents.
Graduates''-salary climb continues^apace
Number c>f offers
J 907-00
1967-CQ
Averse offeis.
190G 07
Bachclor's-dcgrec candidate
Chemical cn^inceriiif;
Chemistry
s
3228
493
$ 790
729
$ 733
689
% 6£?
6U
Master's-dcgree candidates
Chemical enginceiing
Chemistry
613
90
919
• 864
858
814
£09
760
Doctoral-degree candidates
Chemical engineering
Chemistry
461
588
1247
1180
1175
1118'
1102
1063
Source: College Placement Council
RECRUITING:
Salaries Up, Offers Down
Viewed as not quite enough by the
196S graduate, lar too much by his
less recently graduated coworker, com-
petitive by his employer, and likely lo
drop drastically to an Army private's
pay of $102.30 by liis local draft
board's action—starting -salaries /or this
year's graduates continued the familiar
upward pattern. Hut fewer oilers
wprc mnfif mid salaries were >>>¦> no'
rp.nr." «ii |>iy<--'i'S
That's the starling salary picture
that emerges from the Coliege Place-
ment Council's salary survey of the col-
lege recruiting season just completed.
The Bethlehem, Pa., council calls
this an erratic recruiting year. In Jan-
uary, for example, the number of offers
to technical students was down 26%
from last year. By March this loss had
been recouped and a slight increase
took place. Bui activity then leveled
off to a year-end total that was lAVo
below last June's.
Overall, the volume of offers
dropped 2Vc at the bachelor's degree
level *iom last year. Even more se-
rious was the decline in offers, to ad-
vanced degree graduates. The num-
ber of offers this year to those graduat-
ing with master's degrees dropped
IS.9% while oilers-to those with doc-
toral degrees fell 12.-J /'<¦•.
A major factor behind the decline
in offers", the CPC study points- out, is
reduced activity by the aerospace in-
dustry. Aerospace registered a drop
of 23.7/Ji this year over last dcspile J lie
fact that it .made more oilers (til'J.7)
than any olh'-r employer gioup in die
study, which is li.t.seii on in;<>imaliou
on male graduates at 12V universities
tuiil colleges front coast lr> coast. Tlie-
chemicab, drugs, and allied products
group was third with 352G ofie:s, be-
hind electronics and instruments with
43S0.
The chemicals-drugs group, }x-
ever, offered the top average staging
salary of S7G7 per month to l)acli'..,or,s
degree graduates. Among all types of
employer, the bachelor-level .cheszirai
engineers and chemists fared r.v.i.cr
well when compared with graduates
in other areas. The chemical cr.ci-
neers topped the CPC salary list for
the tltirrl tlvni'nlo w.nr \.'il!\ r>
iniro ill oi cm
June. Bachelor-level chemists received
offers of starting salaries that wciekvs
than those made to engineers, but
. high among the sciences with r.>"v:--:e
offers of $729 per month, an inc:i-ase
of 5.8% over last year. This consists
with an increase of 1c.'c for the prcrr;!-
. ing year. A similar drop oecui.ren in
the dollar average of oilers to technical
students; it rose G.5r/e this year, cc.n-
pared with a 7.3'o gain in the previ-
ous season.
GRANTS:
H.R. 875 a Key First Step
The funds authorized in Jl.ll. Si-'i [,:r
institutional grants are a chop in n---
btickel compared to the needs o' f"'*
leges and' universities, Or. 11
Brooks told Hep. Ktnilio l)add.i::as.
Subcommittee on Science, )\esc.ne!i.
and Development. However, he
tinned, the proposals" in the hill ;»«' -111
important /irsl step that should he
taken if the pressing financial poio-
leins of the schools in science e.:--'"
linn nnd scientific jese.utii aie !i
solved.
Dr. Brooks, .dean of c.-ninneeMn;'.
Harvard and chainoau ot 11 " N'ati;:-1
Academy of Sciences' coniuntU'v on
JULY 15, <:tu<
-------
I -Clwfrticch, dfjQh Cind
Solory, $/mo.
fARTING- SALARIES for I3.S. oraduates. See text (below) for explanation
years. For Uie class of 1072-1973, we prognosticate a
a'-arliny ¦ salary- for master's decree chemical engineers
of SUH'O/mo., and for Ph.D. Ch.E.'s of §l,G00/mo.
Cover SlD.OOO/yr.).
As wc said at the start of this article, maybe \vc nil
to t:o hack to college and start over.
The bar graphs on this page may bring us back to fl
c of actuality. These are starting salaries for 1903
Y'-'-iic.-i! en;-inevrin;: ii.S. degree graduates, broker.
I"°"n the industry segments that they entered, com-
] -Med wiili tjio data for last year. Each bar represents
|'a the hvcrr.^o salary oh'cr, calculated on the entire
range of offers (not merely the middle SO% shown).
In 19GS, average oft'ers for the fields shown ranged
from $755/mo. (research and consulting organiza-
tions) to ?S0 i/mo. (petroleum) ; this is a spread of
almost ?50/mo.
Last year, the range was smaller,$70S/mo. (metals)
to $7-53/mo. (petroleum).
If you rend the article, "How Do You Stand in Your
Salary Progress?" in the last i.vuie of Cm'.MlCAl,
KhKiUNC, you may recall that the technique b l>."K"d
on published starting salaries. Now you have yorne new
numbers lo plug into author. 'Olden'a ¦ formulas. Wo
wish you good luck.
' Auu
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_ Match '"26, 1971
Mr Pollution Control Office
P. 0. Box 12900
Philadelphia, Pa. 19108
Morraan R. Ingrahaw, M. D.
Consiissioner
Philadelphia Bepartaent of Public Health
Room 540, Municipal Services Building
Philadelphia, Pennsylvania 19107
Dear Dr. Ingraha®; .
As a result of the eoanasnts you made on the draft copy of the report
evaluation for the.Kiiladeiphia prograsy ".We ti«v« revised tha report to
reflect saMiy; of your recommendations. However, based upon the review
of the observation tea© that was sent to your agency, and circumstances
at that ti©e> other Issues and recoraaendations rewain in tact. We
realize that your program lias already made aigaiflcant achievesents
since thaAPCO conducted'that review. We welcome this progress and
realiza that your program is headed in the proper direction to implement
some of the other racosneadations that were'made.
Although .this report says 'Draft Copy" on the eovar* xc win serve as
tha final report that trill be issued from this office. We look forward
to continuing oar work' with your agency, for any assistance or resource
that are needed by the program or farther clarification of this report,
please do not hesitate to contact sne. W® recosmend that this report *
serves as a docataant to be used by your ageacy and as a guide for future
program improvements.
U 4> UVV X V-J.JF jrvuiat
ORIGINAL SIGNED BY
Sincerely yours.
S. R. Wassersug
Stephen £U VJessersug
Regional Mr Pollution
Control Director
Enclosure' As stated
cc: Mr. Edward F. Wilson
Asst. Health Cosmissioaer
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