[The material submitted by Mr. Dowd, referred to at p. 82 follows:]

We are appending a rather lengthy description of

the ambient air monitoring system prepared by our Environmental Engineering Division which may, if the Subcommittee wishes, be treated as an exhibit to my testimony. This system has a capital cost of $2.6 million which does not include any charge for use of the AEP microwave equipment which transmits the data over most of the distance to the computer. Annual operating costs are estimated from available data to be about $1.5 million. This is split between telephone charges, direct labor associated with the monitoring sites, professional analysis of the results, preparation of reports, heat and power for the site, etc. The overall cost, including operating expenses for five years is expected to be about $10 million.

The monitoring systems, even the earliest ones used

in 1954, operate 24 hours per day sampling the air once every minute. The present system can also report the current situation, a one hour, a three hour and a 24 hour average at any time, on demand.

With tall stacks we are able to utilize a portion of the natural assimalative capacity of the air. We endeavor to monitor to the outer edges of the area which might show some increase in SO2 concentrations above background. The area included in monitoring systems ranges from 80 square miles to somewhat more than 500.

Description of the American Electric Power System's Ambient
Air Quality Monitoring and Meteorological Facilities

I. General Background

The American Electric Power System has operated sulfur dioxide (SO2) and meteorological monitoring networks at several major plants for long periods of time. The first was at the site of the Clifty Creek station in the mid 1950's. A similar but somewhat more sophisticated network was operated at the Cardinal Plant over a four-year period beginning in 1966. The results of these two studies have been published. More recently, networks (see Figure 1 crosshatch networks) with improved monitoring equipment have been established at Muskingum River (1969), Amos (1970), Big Sandy (1970) and Kammer-Mitchell (1970) plants.

(1) (2)

The two main purposes of the early AEP air monitoring program were to verify the theoretical plume dispersion equations used to calculate the ground level concentrations resulting from pioneering application of tall stacks to power plants, and to maintain surveillance over ambient air quality in the vicinity of those power plants. Additional uses of data obtained from air quality monitoring have been: (1) to provide information which could be used in the design of new plants; (2) to test the benefits derived from the addition of air quality control equipment at older plants; (3) to verify the benefits derived from the construction of new tall stacks at older plants; and (4) to assess the effect of power plant operations on the environment.

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Recently, several developments have occurred which

have imposed new requirements for the AEP air quality

monitoring program. The impact of these developments have resulted in AEP's decision to revise and expand its present monitoring program to a total of 62 stations (Figure 1) as discussed in this report.

Events of particular significance are: (1) the promulgation by EPA of Federal standards for ambient air quality; (2) the development by states of air quality implementation plans, and (3) the use of S02 and particulate emission limitation programs to meet S02 and particulate ambient air quality standards at some power plants.

Also of particular significance is that, as part

of Federal standards for ambient air quality, EPA has approved methods for air monitoring which were published in the August 14, 1971 Federal Register. The continuous S02 monitors originally purchased and used at AEP power plants do not exactly conform to the new EPA-approved monitoring methodology. Expansions of the S02 and particulate matter monitoring system, completed on January 1, 1974, have been handled as follows: All new S02 monitors are of EPA-approved type, and at present monitoring networks, existing S02 monitors are operated in parallel (on a rotating basis) with a new EPA-approved type monitor until definite relationships between the two instruments can be established. The earlier dust-fall (settleable solids) studies have been replaced by daily

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monitoring of suspended particulate matter using EPA-approved high volume samplers. In addition, there are 200-foot meteorological towers, measuring wind direction and velocity and ambient air temperature at the 50 and 200-foot levels as well as the temperature differential between the 50 and 200foot tower levels.

With the exception of the total suspended matter,

all other parameters are being telemetered every minute to the contractor's (Environmental Research & Technology) central computer facility for data processing and reduction. This is a real-time system.

The optimum number and location of the monitoring stations for each network was determined on the basis of prior experience as well as on the basis of theoretical diffusion equation calculations. The equations used were basically those included in the A.S.M.E. Gaseous Diffusion Guide with some allowance for wind sheer. Depending on the size of plant, quantity of SO2 emitted, height of stacks, terrain, etc. the area monitored at each plant ranges from approximately 80 to over 500 square miles.

The heart of a real-time data collection network is the telemetry system which transmits the data from the field analyzer sites to a central location where the data are processed and used.

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