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tion if he is to continue operating in the D.C. Compliance of course cannot be compulsory. A similar letter is sent to the Motor Vehicle Commissioner of the State in which the violator resides, setting forth the violation involved, for their consideration and action.

It would appear that one of the major difficulties in the area of enforcement is the lack of suitable test devices of sufficient accuracy and value to substantiate and support a charge of excessive smoke. Reference is made to the Ringelmann chart which at best merely provides a criterion only slightly better than a guess. Therefore the officer is virtually restricted to the most pronounced and irrefutable violations involving dense and sustained smoke emission.

In view of the District of Columbia's annual vehicle inspection requirement and follow-up inspections as required or requested by various police officers, it is felt that the bulk of the violations are attributable to vehicles from other jurisdictions, particularly those which are Diesel powered. From June of 1966 to the present date, enforcement action has been taken in 580 cases of defective mufflers and 289 cases of excessive smoke.

The Traffic regulations further stipulated in regard to excessive idling of motor vehicles as follows:

"Sec. 99.1

"No person operating or having control of a passenger vehicle having a seating capacity of eight persons or more shall permit the engine of such vehicle to operate more than three minutes while such vehicle is stationary and at a route terminal, except when the temperature in the District is reported by the United States Weather Bureau as below 35 degrees Fahrenheit."

Predominant violators appear to be sightseeing tour buses from other jurisdictions particularly in Capitol Hill area, Mall area and White House area. Surveillance and action has been initiated by this Department through the Capitol Police Department and the U.S. Park Police within their jurisdictional areas. No statistics of enforcement available.

Section 151.1 of the Traffic Regulations deals with requirements for vehicle air conditioning equipment, most pertinent of which is as follows:

"Such equipment shall be manufactured, installed and maintained with due regard for the safety of the occupants of the vehicle and the public and shall not contain any refrigerant which is toxic to persons or which is flammable."

Again in this instance, control rests with the Director of Motor vehicles through the manufacturer and enforcement would be minimal and post facto.

ADDENDUM (IF ASKED)

Various Police Regulations provide enforcement basis in matters and sources of pollutants relating only indirectly to air pollution control. partial listing: Deposits on streets and sewers.-Coal, dirt, mud, ashes, gravel, sawdust, shavings, hay, straw, offal, vegetable matter, garbage, trees, cinders, paper, refuse matter of any kind, dead animals, putrescible matter of any sort; kindling or setting fire any combustible on paved sidewalk or roadway-with provisions of exception to earth from excavations, building debris and coal on public space. Prohibits deposits on vacant lots; provides removal of debris be wetted down and from upper stories of building by tight chutes.

Garbage, ashes and other refuse.-Specifies containers, volume, covers required, separations of classes, transportation over public spaces, etc.

D.C. Code prohibits kindling of bonfires between sunset and sunrise. Weeds 4 or more inches to be cut.

Department has issued directives to the Force instructing constant and consistent enforcement of applicable regulations pertaining to excessive smoke and defective mufflers on vehicles. Requires Commanding Officers to submit annual reports to be compared with prior report and where indicated explanatory reports as follow up.

An effort was made to obtain statistical information regarding enforcement action taken by the various Precincts in Police Regulation violations of the following:

Open burning violations, bonfires, violations of burning permits, burning on paved public space.

Statistical section advised that due to the transition to computer data storage all of their records had been transferred to that Unit and that enforcement of applicable regulations was so minimal in number that they had been statistically lumped in the classification of "Other" violations. I was advised that Data processing might be able to supply the information since taping for the past fiscal year had been completed.

Data processing was contacted and they advised that it might be possible to obtain the information in 10 days or more since implementation of the system was incomplete, tapes for the computer on the subject matter would have to be searched for and due to the great number on hand would involve some time.

The Annual report for fiscal 1965 shows 6,783 arrests in the category of all other offenses-misdemeanors. However a tabulation of miscellaneous incidents investigated by the Department records 66 smoke complaints investigated; not conclusive but only pertinent statistic available.

All of the Precincts were personally canvassed by telephone regarding enforcement of the above regulations. Listed by precinct as follows:

No. 1: Investigated complaint re burning permit no enforcement due to full compliance with stipulations cautioned___.

Number

1

Investigated complaint of men burning wood in metal drum for
heat-fire ordered extinguished----

1

[blocks in formation]

No. 5: Arrest-burning rubbish at construction site without permit___ 20 to 25 arrests for attending bonfire----

No. 6

No. 7

No. 8: Burning leaves on public space_.

No. 9

No. 10

No. 11

No. 12

No. 13: Burning permit investigated-in compliance--

No. 14

Total

1

25

None

None

16

None

None

None

None

1

None

45

NOTE. These are merely estimates, no statistics maintained at Units for these categories.

Senator TYDINGS. Summarize your statement, Captain Thot.
Captain THоT. All right, sir.

The Metropolitan Police Department's function and involvement in the area of air pollution control is primarily that of enforcement. There are a number of statutory and regulatory provisions some of which are only remotely related to the overall problem of air pollution. The major portion of the enforcement effort is concerned with those regulations relating to motor vehicles such as mufflers which are required by the Director of Motor Vehicles, engine and exhaust systems to be equipped and operated to prevent escape of excessive fumes. We, too, are restricted to the Ringelmann chart No. 2 as a comparison medium and the second regulation prohibiting the use of smoke screen which is practically nonexistent and constitutes a felony.

Enforcement efforts are supplementary to the annual motor vehicle inspection program. The majority of local registered vehicles. are readily detected at inspection, minimizing the need for enforcement except in circumstances where excessive smoke emission occurs

due to mechanical deterioration of the vehicle subsequent to inspection.

There are several courses that we use to gain compliance with regulations. The enforcing officer is required to complete a form giving the owner's name, address, operator's name and address, permit number, tag number, the specific violation, and the case or ticket number. A copy of the form is transmitted to the Traffic Division for statistical compilation and another to the Director of Motor Vehicles for his action. Upon receipt of the form, the Director of Motor Vehicles orders the owner of record to report for inspection within 72 hours. Failure to comply within the specified time results in cancellation of vehicle registration.

In the case of nonlocally registered vehicles, the officer may order. the operator to the inspection station at once or, under terms of the violator compact between the District of Columbia, Maryland and Virginia, may issue a traffic violation notice to the vehicle owner or operator, although the compact agreement merely assures that violation notice will be honored and collateral will be posted. In these instances the officer also completes the required form and distribution is the same as in case of local violators. Upon receipt of this the Department of Motor Vehicles forwards a letter to the violator inviting him to submit his vehicle for inspection if he is to continue operating in the District of Columbia. Compliance is not compulsory. A similar letter is sent to the motor vehicle commissioner of the State in which the violator resides, setting forth the violation involved for their consideration and action.

It would appear that the major difficulty in the area of enforcement is a lack of suitable test devices of sufficient accuracy and value to substantiate and support a charge of excessive smoke. The officer is restricted to most pronounced and irrefutable violations involving dense smoke and sustained smoke emission.

Since 1966 to the present date, the Metropolitan Police Department has recorded 580 cases of defective mufflers and 289 cases of excessive smoke emission, and as an addition to my statement there were 1,277 cases of unsafe mechanical condition which are mentioned primarily because defective exhaust systems like the tailpipe being broken or perforated would enter into this category.

Subsequent further regulations, the excessive idling of motor vehicles relates to motor vehicles with a capacity of more than eight persons and prohibits the idling of the vehicle for more than 3 minutes while stationary at a route terminal unless the temperature is below 35 degrees.

Quite recently we had a surveillance of the Capitol area, the Mall area and the White House area involving sightseeing tour buses. Those jurisdictional areas are within the purview of the Metropolitan Police, the Capitol Police, and the U.S. Park Police, and we have coordinated and initiated action for enforcement, and we have no statistics available in that area.

The Department has issued directives instructing constant and consistent enforcement of applicable regulations pertaining to exces

sive smoke and defective mufflers on vehicles. This requires commanding officers to submit annual reports to be compared with prior reports and where indicated explanatory reports as a followup.

In relation to the other pollutant sources, open burning violations, bonfires, violations of burning permits, burning on paved public space during fiscal 1965 the Department responded to 66 incidents involving smoke complaints. Some type of action was taken in 45 of the incidents with the balance in compliance in terms of burning permits. One arrest for burning without a permit, 25 arrests for attending bonfires; 16 warnings were issued for burning leaves in public space, and three were warned to comply with the terms of the burning permit.

In the several months I have had occasion to make personal observation as far as excessive smoke emissions from vehicles en route from home to work and it seems to occur relatively infrequently, roughly averaging about two during a 3-hour period of duration on patrol activity.

This is the extent of my statement.

Senator TYDINGS. I think that is valuable information that we need to know. Thank you.

General MATHE. Mr. Chairman, again I would like to present the Director of Sanitary Engineering, Mr. Roy L. Orndorff, who was here last Tuesday.

Senator TYDINGS. Delighted to have you back again, Mr. Orndorff. Mr. ORNDORFF. I would like to introduce my two colleagues who are with me, Mr. Norman Jackson, Deputy Director, and Mr. William Roeder, Chief of the Bureau.

Senator TYDINGS. Sorry to take up so much of your time, Mr. Orndorff and gentlemen. But we hope as a result of these hearings we will get moving in the field of air pollution.

Mr. ORNDORFF. I am sure it is all to the good. You realize, I am sure, that we are now leaving the enforcement and regulatory agencies and coming to service, the performance directly to the public.

I have a statement of some of the things we are doing in connection with our work and naturally, from the nature of these duties, there are many opportunities for us.

Senator TYDINGS. Let me ask you a question, Mr. Orndorff. How do you think that the field of air pollution should be handled administratively within the District? Do you think it is being handled properly now with the responsibilities spread out in four or five agencies?

Mr. ORNDORFF. Mr. Chairman, I would have to say that it certainly appears to be fragmented, as a lot of things are in the District government. But I don't think I would be the one to offer a design of a new system.

Senator TYDINGS. Excuse the question. Go ahead.

We will include your statement in its entirety.

Why do you not summarize it point by point, if you would. (The statement of Mr. Orndorff follows:)

STATEMENT OF ROY L. ORNDORFF, DIRECTOR OF SANITARY ENGINEERING,
MARCH 16, 1967

SOME AIR POLLUTION ABATEMENT ACTIONS BY DEPARTMENT OF SANITARY

ENGINEERING

The following paragraphs outline air pollution control or abatement activities which have been or are being undertaken in the Department of Sanitary Engineering.

1. Odors from Water Pollution Control Plant at Blue Plains

While odors from this plant have been under reasonably good control over the years, more recently the increased amounts of sewage reaching the plant and closer public contact by reason of the new Anacostia Freeway along the plant has indicated the need for a comprehensive odor control program. The problem is a very complex one on account of the variety of types and sources of odors, much can be accomplished by the relatively simple but expensive process of pre-chlorination of flow but there are known to be strong odor sources which are not affected by this treatment and, also, prechlorination may not be the most economical method of securing the same limited results.

Following air monitoring assistance during the past year by the Department of Public Health and the Federal Water Pollution Control Administration, the District has retained a consultant firm which specializes in such environmental problems to undertake a survey of the entire plant to pinpoint and evaluate all odor sources and to recommend corrective measures. These latter will be handled in two categories, the first being directed toward relief for the 1967 Summer season and entailing mostly revisions of operating routines, and the second encompassing construction and equipment modifications for permanent correction.

2. Refuse Transfer Station at New Jersey Avenue and K Street, S.E.

This station was constructed in 1948 as a facility for transfer of garbage and other noisome refuse from collection vehicles to (1) railroad cars for transport to the garbage rendering plant which was then in operation at Cherry Hill, Virginia, (2) the same cars destined to a small sanitary landfill also at Cherry Hill, (3) farmers' trucks for pig-feeding or (4) grinders for discharge to sewers of excess garbage.

In view of the great odor producing potential of this type of facility, the station was provided with an expensive ventilating system which exhausts the air through activated carbon and dust filters. This system has been highly successful. 3. Odors from Sewers

The odor potential of sewer systems is related to such factors as length of lines (time of transit), grades and velocities of flow, temperature of sewage and ventilation. These have been generally favorable to control in the District system in the past but more recently the connection to the system of long lines, which extend in Virginia as far as the Dulles International Airport and in Maryland to the Gaithersburg and Glenn Dale areas, has indicated the need for added attention to prevent air pollution by odor emissions. The approach has been to provide good ventilating with exhausts through special structures containing activated carbon filters where necessary. These were rather widely used on the Potomac Interceptor construction.

On one major sewer line which conveys Maryland flows from distant areas to the treatment plant, exhaust vents were provided as long steel tubes similar to street lighting standards and equipped with motor-driven forced draft systems where necessary.

Where odor problems are present in sewer systems, pumping station wet wells and screening stations are likely to be critical points. In recent years, it has been our practice to include activated carbon filtration for the exhaust air from such structures.

4. Up-system treatment in Sewer Systems

In the belief that some type of local treatment, such as chlorination, ozonation or oxygen diffusion, at strategic points in the collection and transmission lines, might be a practical method of controlling the septicity and, therefore, the odor producing potential, both in the system and, in part, at the Blue Plains plant, we filed an application last year with the Federal Water Pollution Control Admin

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