Document EyjbL3r32JmEyB7p5eGpDXL

MEMORANDUM -O: Mr. John N. Lehnert, Attorney Legal Department - MTO date S . :mber 15> 1967 subject: W. L. FAITH'S REPORT 1. Per your request, attached Is a copy of Mr. W. L. Faith's report. /^ . fLO /hmc Attachment S. Campanella Plant Manager C-fi-tQ 16-631 ASI-PR 0004248 ; COHiVLTINO CHEMICAL, ENGINEER W, L. FAITH 2540 Huntington Drive San Marino, calif. 91108 213-2S7.8303 March 30, 1967 p. j Mr. M.J. Guillory Mr. Mr. Air. Mr. C.E. McKay R.D. Anding J. J. Bergin Salvatore Campanella Mr. J.W. Kirk lane. Mr. R.F. Howe Mr. D.O. Howe Mr. J.W. Melancon Mr. J.R. Davis Mr. A. J. Knight Consolidated Chemical Industries Div., Stauffer Chemical Company Copolymer Rubber and Chemical Corp. Enjay Chemical Company Ethyl Corporation Industrial Chemical Division, Souxh Wor Allied Chemical Corporation Gulf States Utilities Company Humble Oil and Refining Company Ideal Cement Company Kaiser Aluminum and Chemical Company Plastics Division, Allied Chemical Cor Industrial Chemical Division, North Wo Allied Chemical Corporation Gentlemen: I am attaching to this letter to each of you, a copy of my report, ."Air Pollution in Eaton Rouge - March 1957." It was a pleasure to meet and talk with each of you, some for the first time. You are doing a good job in controlling air pollution in 3aton Rouge, but I must urge each of you to follow through with your plans to further reduce emissions. Such action will certainly fore stall Federal intervention. In the near future you will probably have to help the Louisana Air Control Commission get some operating funds and good leadership. When the Commission finally gets around to adopting rules and regulations, your own situation should stabilize. AIR POLLUTION IN BATON ROUGE - MARCH 1967 W. L. Faith Consulting chemical engineer, San Marino, Calif. During my visit to Baton Rouge. March 20-23, 1957, I evaluated the air monitoring data in the Kcm-Tcch reports for Nov-Dec 1966 and Jan. 1967, and discussed emissions with plant managers and technical representatives of the companies comprising the Associated Industries of Baton Rouge. Along with Messrs. P'Pool and Mayfield, I talked with Fred Brooks of Channel 2 concerning air pollution in Baton Rouge and elsewhere, and made a 5-minute TV tape for future showings. On Thursday, March 23, I met with the plant managers and gave them a verbal report of my findings and recommendations. This report is essentially a written.recapitulation of my verbal report. Evaluation of Kern-Tech Data Measurements made by the Kern-Tech organization were directed towa an assessment of atmospheric concentrations of particulate matter (fin particles), sulfur dioxide, and oxidant at 3 stations (designated as North, South, and East Analyzers). The period covered by the reported 'data is essentially December, 1965 and .January, 1967. Oxidant. Oxidant concentrations were measured only at the South Analyzer. The values reported were very high (maxima up to 999 micro grams per cubic meter, or 0.5 ppm, and daily averages not much lower on some days). Similar concentrations in Los Angelos would be accomp anied by intense eye irritation, extensive vegetation damage, and very low visibility. It is^donceivable that such values could be found in Baton Rouge particularly in the winter times when sun inten sity is low. It may well be that a small ozone source in the vicinity of the South Analyzer (an ozone generator or high tension sparking) may have confounded the results. Even a source of interfering N02 could also be the culprit. In any event, the high oxidant values in no way can reflect on the industrial complex. Atmospheric oxidant results almost entirely from the photochemical reaction between the major constituents of motor vehicle exhaust and thusAa measure of motor vehicle pollution.- ' S. Inasmuch as there have been' no reports of eye irritation, typical vegetation damage, and low visibility at low humidities, I do not believe a motor vehicle pollution problem exists in Baton Rouge. The excellent ventilation of the community during periods of intense sunshine-will probably'preclude the development of a motor vehicle pollution problem. Sulfur dioxide. Sulfur dioxide was measured continually during the 2-month period. A recapitulation of daily averages is shown below: ASI-PR 0004250 Range of daily average concentrations of S02 (microg/cu. m.) Month December January North 48-245 10-323 South 19-356 0-262 East 0-99 0-147 Measured daily average concentration of S02 by month December January 161 134 160 37 83 45 To convert the above values to parts per million, a more widely used unit for expressing the atmospheric concentration of S02, one should divide the value shown in micrograms per cubic meter by 2620. Thus the highest day for January at the South station showed a con centration of 262/2620, or 0.1 ppm. Detailed analyses of the data in the Kern-Tech report shows the worst condition found was from Dec. 7 through Dec. 12 when the daily averages at the South Analyzer were 0.11. 0.12, 0.11, 0.11, 0.14, and 0.11 ppm for the six days respective ly. The foregoing values are less than those which would cause damage to indigent vegetation and also below those chosen by State of New York as ambient air goals for industrial areas (0.15 ppm per 24 hours not to be exceeded 99% of the time, i.e. 4 days a year). Ambient air quality standards set by the State of California are stated in a different time reference. The lowest value mentioned is 0,3 ppm for S hours which concentration is not believed to damage sensitive vegetation or to affect people. It should be noted that during the six-day period of interest at the South Analyzer, no daily average exceeded 0.07 ppm at the North Analyzer or 0.035 ppm at the East Analyzer. In my opinion, air pollution from sulfur dioxide emissions should give the public no concern in Baton Rouge. On the other hand, industry should be aware of the activities of the United States Public Health Service in this regard. A USPKS team studying air pollution "in the St. Louis Metropolitan Area recommended very sensitive ambient air goals in the area, and they were later adopted by the Missouri Air Pollution Commission. The USPKS report says: "These goals specify that the annual arithmetic mean concentra tion (of S02) should not exceed 0,02 ppm, and that the concentration of 0.1 ppm should not be exceeded-on more than 1 percent of the days in any consecutive 100-day period." Of course, the restrictions which will be most meaningful in Baton Rouge will be those eventually set by the Louisana Air Control Commission. During 1967,. the Texas Air Control Board expects to set ASl-pp 0004251 "T"! .WRSt-' standards for sulfur compounds. The values selected may well influence the Louisana Air Control Commission. Particulate matter. Dust and smoke in the Baton Rouge atmosphere was assessed b'y~KTem-Tech by three different methods'. 2-hour coefficient of haze (COII) values using an AISI tape sampler; dust stain index using the same equipment; and 24-hour suspended solids loadings using a high-volume sampler. Basically, the COM values and dust stain index measure the soiling capacity of atmospheric particulates; the nigh-vol "suspended particulates" are reported as the .weight df particulate matter in an air sample taken continuously over a 24-hr period. The weight is reported as micrograms per cubic meter. COH values, a measure of the "blackness" of atmospheric particulate matter may range from 0 to 10. A value below 1.0 represents a clean atmosphere; greater than 2.0 usually indicates undesirable levels of smoke or particulate matter; and 10 represents an atmosphere laden with heavy black smoke. Using the above values as criteria, Baton Rouge had satisfactory air quality. During the 74-day period (Nov. IS - Jan, 31) when COM values were determined, only about a dozen 2-hour periods showed COII values above 2.0 at any analyzer station. The daily average for all days at all analyzers averaged less than 0.5 COH, a highly satisfactory value. The only monthly concentrations above 0.5 were 0.9 at the North Analyzer during November (only 12 days of record), and 0.7 at the same analyzer during January. The dozen or so 2-hour periods above 2.0 probably reflected the presence near the ground of black smoke from a localized source, either a dump, a mal-operating flare, or other source of black particles. All of the high'values, all bur one at the North Analyzer, were obrained during periods of variable, low winds. The State of Colorado has adopted an air quality standard of 0.5 COH, when measured in rhe central business district of a city or community and averaged over a 3-month period. This is a highly restrictive standard, but I would suspect it is met in Baton Rouge. Ken-Tech also measured the dust stain index of the dark spots on the AISI and reported these along with COH values. DSI values appear to vary in a fashion similar to COH values but inasmuch as there is no experience in other communities with the method, no evaluation can be made of these .data. The most widely used measurement of air quality as reflected by atmospheric particulate matter is the 24-hr high-vol determination, reported in micrograms of particulates per cubic meter of air. HemTech made daily measurements' for suspended particulates at all three stations beginning Dec. 9, 1965. Ranges of values and averages for each of the two months were as follows: ASI-PR 0004252 Suspended Particulates in Micrograms per Cubic Me ter of Air l . . % North South East Dec. Range S.S-90 12-136 \ 3-75 Dec. Average 42. S 49.9 24.3 Jan. Range 23-136 10-129 9-5S J an j, Aver 65 62 29 Values over a longer period of time have been obtained at the Pub lie Health Bldg, at Florida and ISth. The values published by the United States Public Health Service, are: Years 1957 1960 1964 1965 No. of samples 24 ' 23 23 26 Avg. cone, (microg/cu, 170 125 J 86 93 m Thus it may be seen that over the years, suspended particulate loadings in Baton Rouge have been decreasing. The Kern-Tech data for Dec. 1966 and Jan. 1967 are even lower, but cover only a portion of the year. The data throw little light, of course, on the source of the part iculate matter in the air. Normally.'it comes from industrial dust sources, smoke from open burning, traffic on dusty highways and road shoulders, construction sites, aircraft take-offs, etc. In fact, the relatively high values found at ISth and Florida nay well reflect con struction work, such as street widening, at the time. To put the data in their proper context, I compared them with the air quality standards for suspended particulate matter recently adopted by the State of Texas. They are as follows: 1. Type A land use, residential and recreation - not to exceed 125 micrograms of suspended matter per cubic meter of air at least 90% of the time in any 30-day period. 2. Type B land use, commercial and business - same as above except 150 micrograms per cubic meter. 3. Type C land use, industrial - same as 1 except 175 etc. 4. Type D land use, open spaces - same as 1 except 200, etc. Thus it may be seen that Baton Rouge values are wbll within the Texas limits. The State of Colorado has adopted an ambient air quality star, dare ASI-PR 0004253 for suspended particulates of 120 micrograms per cubic meter. The standard is based on the average of samples collected at least once every third day over a 3-month period in the central business district of the community. The air in Baton Rouge meets this standard. Meeting with Fred Brooks of X3RZ (Channel 2) During my stay in Baton Rouge, I met with Mr. Fred Brooks, a newsman from Channel 2, along with Messrs. P'Pool and Mayfield. * Mr. Brooks appeared to be interested mainly in the facts con cerning the Eaton Rouge atmosphere, the nature of air pollution problem in general, and specifically the importance of the various plumes he saw when flying over or riding by the industrial areas, or when view ing it from the State Capitol. As a result of a 2-hr interview, he asked me questions which were recorded on TV tape. My answers were essentially as follows: Air pollution is worst during periods ox stag nant air, or inadequate ventilation, which in Eaton Rouge is usually the fall months. During such periods atmospheric pollution from smoke and dust build up to give Baton Rouge a mild to moderate visibility problem. Aiding visibility reduction is fog formation which is also most prevalent during the same period of the year. On the other hand, Baton Rouge has much better ventilation than many industrial cities, so the potential for an air pollution problem is minimized. The only important air pollution effect noticed was visibility. Concen trations of pollutants measured by Kern-Tech show they are far below 1 levels that would effect health or cause property damage, e.g. to paint or vegetation. There appears to be r.o motor vehicle pollution problem in Baton Rouge, but there are probably visibility and nui sance problems related to open burning in dumps, trash piles, sugar cane field burning, and even burning of leaves. A properly-designed municipal incinerator or cut-and-fill disposal site would alleviate problems caused by open burning. Reviews with plant managers I talked with most of the plant managers or their representatives concerning their plans for further reducing air pollutant emissions. Generally, X found all plants to have plans (1) to reduce dust plumes, and (2) to reduce emissions from disposal of solid waste and flared gases. Some progress had been made since my visit in November. 1965. More remains to be done and the various companies know which plumes are most amenable to control. Plans should be converted to action. The industry should also make a concerted effort to solve the solid combustible waste problem. When trash is being burned, the effluent is quite noticeable and draws attention to the industrial complex. In fact, it is what people see and smell that activates them to an "awareness"of pollution. The three things that were most noticeable to me were reduced ASI-PR 0004254 visibility at the street level caused by low-level dust pluses, occasional odors as I rode past some parts of the industrail complex, and lung irritation_from an acid plume looping to ground level. * If we could get rid '.of these the industry would have a good story to tell based on favorable ventilation in the Baton Rouge area, low values of pollutants in the atmosphere as measured by Xem-Tech lack of any health and property damage effects, and a bare minimum of visibility and odor problems. Future monitoring ' - The present monitoring system being operated' by Kern-Tech aonears to be adequate. The three-month period selected should more nearly conform with the periods of low air movement. Daily measurements fc~ S03, suspended particulates (nigh-volume sampler), and COH values are the minimum i,nat should be none. X suspect DSI values are not ex pensive to obtain inasmuch as the same tape is used for COH analyses Ihei efore, inasmuch as Dbl values over a period of years are avail able, it m.iy be worthwhile to continue them for another year. Ob viously measurements oi wina velocity and direction should be con tinued. t.ie need for oxidant values is doubtful . and I would dis continue them. The minimum pro gram outlined above should certainly be continued Nowhere else, to my knowledge, has an industrial complex had the foresight to gat!-- atmospheric data over a 10-year period as has been done in Baton Rouge. Perhaps industry should talk about it a little bXi V San Marino, Calif. March 30, 1SS7 ASI-PR 0004255 CONSULTINw CHEMICJl. E.SCI.NEEH W. L. FAITH 2540 Huntington Drive San Marino, calik. 3U0S 213.5a7.s30 March 31, 1967 / Industrial Chemical Division, Allied Chemical Corp. P.0. Box 2330 Baton Rouge, Louisana South Worlcs Attention: Mr, Salvatore Campanella INVOICE BCR SERVICES For professional services in connection v/ith air pollution study in Baton Rouge (March, 1SS7) 5 i/2 days at $250 per day times one-eleventh Relevant expenses times one-eleventh Air fare $277.20 Hotel and meals 5S. 93 Local transportation _______6.55 $342.63 Total $125.00 31.15 $156.15 %/> r ASI-PR 0004256