United States
Environmental Protection
Agency
Environmental Monitoring Systems
Laboratory
Research Triangle Park NC 27711
Research and Development
EPA-600/S4-83-01 1 May 1983
Project Summary
Technical Assistance Document:
Quality Assurance Guideline for
Visible Emission Training
Programs
Barbara E. Blagun
This document describes procedures
and outlines technical guidance for
assistance in establishing effective
visible emission observer training pro-
grams. Smoke generator operating
information is presented and appen-
dices give examples of sample class-
room training lectures as well as audit
forms and statistical techniques used
to access the quality of a training pro-
gram. The adherence of visible emis-
sions training programs to the materials
in this document should result in im-
proved and consistent levels of ob-
server training. This documentation
will aid enforcement programs in dem-
onstrating that the observers were
trained without biases and in a pro-
fessional manner.
This Project Summary was developed
by EPA's Environmental Monitoring
Systems Laboratory, Research Triangle
Park, NC, to announce key findings of
the research project that is fully doc-
umented in a separate report of the
same title (see Project Report ordering
information at back).
Summary
EPA reference method 9 for visible
emission observations requires that field
inspectors and observers document their
reading skills by periodic participation in a
rigorous smoke training and certification
program. It is therefore essential that
visible emission (VE) observers continue
to have the benefit of high quality training
and testing. The document described in
this summary is intended for individuals
responsible for the general conduct of VE
training and certification program, and
includes detailed information on recom-
mended Quality Assurance (QA) procedures
The implementation of these procedures
requires an understanding of the elements
of an effective QA Program and its relation-
ship to smoke training and certification. By
definition. Quality Assurance is the total
integrated program that assures reliability
and credibility in opacity training and certifi-
cation. It therefore should be structured
into all aspects of the program including
the initial planning and execution of the
classroom training; the acquisition, cali-
bration, and operation of the smoke gen-
erator; the field training and certification;
and the reduction of data and maintenance
of records.
In concept and implementation, the QA
program is a management tool or opera-
tional mechanism for assuring credible
training and certification. To ensure suc-
cess, this program must receive the com-
mitment support and follow-up of man-
agement
Description of Quality
Assurance Program
The QA program consists of two distinct
program operations, quality control (QC)
procedures and auditing, that are com-
plementary and mutually supportive. The
program of QC procedures is operated
integrally with the presentation of the
smoke school, focusing on the operation
of the smoke generator. This program pro-
vides the documented procedures which
ensure routinely accurate and reliable train-
ing and certification including program
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planning; preparation, calibration, and
operation of the generator; recordkeeping
and documentation; and trainee control.
The other important element of a QA
program is auditing. A VE program audit is
an external review of the program using
structured evaluation forms. The audit is
usually conducted by supervisory person-
nel to assure objectivity. Audits are de-
signed to identify program weaknesses
and deficiencies that must be addressed
and corrected in order to maintain an
effective and high quality opacity training
and certification program.
The Performance Audit is the structured
and routine review of the various steps in
the training and certification process. It
generally consists of a number of specified
checks to insure that proper and accurate
procedural activities have been completed.
The Performance Audit is conducted by
the Training Supervisor and/or designated
staff, and is most applicable to fairly specific
and routine procedures. Example formats
for inspection and operation of the smoke
generator/transmissometer unit and the
handling of certification test records are
included in the report In any audit situation,
checklists should be devised for each
specific activity.
Records pertinent to the audit must be
completed and maintained as part of the
agency's official documentation file. The
generator operating log, smoke school file,
and other records are also components of
the documentation and recordkeeping pro-
cess. The importance of the Performance
Audit as an integral part of the activity
cannot be overemphasized as vital to train-
ing and certification efforts. This audit
provides assurance that the requirements
of Method 9 have been fulfilled and that a
sound and high quality program has been
provided.
Complementary to the Performance
Audit is the System Audit The System
Audit is conducted periodically, perhaps
on an annual basis, through an onsite
comprehensive review of the total smoke
school program. This audit should be
conducted to assess all aspects of the
training activity and should identify prob-
lems that can be corrected. The System
Audit preferably should be conducted by
personnel outside the smoke school staff,
i.e.. Enforcement Program Manager and/or
EPA Regional Office personnel. Participa-
tion by the Enforcement Program Manager
is preferable because opacity certification
directly impacts and supports the day-to-
day enforcement/compliance operation;
more than 90 percent of paniculate emis-
sions compliance is determined and doc-
umented by opacity readings. Participation
by enforcement management also provides
a needed element of management involve-
ment and concern. The smoke school is
typically a service provided by the Tech-
nical Support Division.
A System Audit should have a positive
impact on the training program and also
should provide a mechanism for man-
agement to gain needed program familiar-
ization. It can also be used as a planning
document to assist agencies in obtaining
the support to update training materials and
equipment
To assist in a systematic review, an
itemized audit form should be used. An
example is included in the report The
checklist approach assures that all aspects
of the program are evaluated and lends
itself to the expedient preparation of an
audit report The form should be attached
to a brief narrative that summarizes the
findings, conclusions, and recommends
tions. Post audit followup on the important
recommendations is essential to assure
that proper corrective actions have been
taken.
Barbara E. Blagun is with PEDCo Environmental, Inc., Durham, NC 27701.
Thomas J. Logan is the EPA Project Officer fsee below}.
The complete report, entitled "Technical Assistance Document: Quality Assurance
Guideline for Visible Emission Training Programs," {Order No. PB83-193 656;
Cost: $16.00, subject to change) will be available only from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Telephone: 703-487-4650
The EPA Project Officer can be contacted at:
Environmental Monitoring Systems Laboratory
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
Postage and
Fees Paid
Environmental
Protection
Agency
EPA 335
Official Business
Penalty for Private Use $300
5%
AGENCY
CHICAGO IL 60604
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