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U.S. ENVIRONMENTAL PROTECTION AGENCY
a- - REGION IV AIR SURVEILLANCE BRANCH
UJ LL SURVEILLANCE & ANALYSIS DIVISION
ATHENS, GEORGIA 30601
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EPA-340/1-79-009
February 1979
Visible Emissions Program
Operational Manual
by
Victoria Scott
Pacific Environmental Services, Inc.
1930 14th Street
Santa Monica, California 90404
Contract No. 68-01-4140
Task No. 32
EPA Project Officer: John R. Busik
Task Manager: Tom Rose
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Region IV Air Surveillance Branch
Surveillance & Analysis Division
Athens, Georgia 30601
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TABLE OF CONTENTS
Section Page
1.0 INTRODUCTION 1-1
2.0 THE LECTURE COURSE 2-1
2.1 Introduction 2-1
2.2 Registration and Orientation 2-1
2.3 Lecture 1: Goals and Principles 2-5
2.3.1 History of the Method 2-5
2.3.2 Opacity * 2-6
2.3.3 Certification 2-7
2.3.4 Smoke Generators 2-8
2.3.5 Advantages and Disadvantages of Observer
Evaluation of Visible Emissions 2-9
2.3.6 Observer Position 2-11
2.3.7 Condensed Water Vapor Plumes 2-13
2.4 Lecture 2: Sources of Visible Emissions 2-13
2.4.1 Combustion Sources 2-14
2.4.2 Noncombustion Sources 2-14
2.4.3 Other Sources of Visible Emissions 2-15
2.5 Lecture 3: Field Operations 2-15
2.6 Lecture 4: Meteorology 2-18
2.7 Film: "Role of the Witness" 2-23
2.8 Lecture 5: Testing Procedures 2-23
2.9 Quiz 2-29
2.10 Lecture 6: Legal Aspects 2-29
2.10.1 Method 9 and Legal Precedent Case
Histories 2-29
2.10.2 Legal Rights of Inspection 2-29
2.10.3 Legal Restraints 2-32
2.10.4 Hold Harmless Agreements 2-32
2.10.5 Behavior During Inspections 2-32
2.10.6 Behavior in Court 2-33
References for Section 2.0 2-33
3.0 CERTIFICATION PROCEDURES 3-1
3.1 Generator Familiarization 3-1
3.2 Generator Operation 3-2
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TABLE OF CONTENTS (Continued)
Section Page
3.3 Generator Calibration 3-6
3.3.1 Zero and Span Drift 3-6
3.3.2 Calibration Error 3-8
3.3.3 Calibration Procedures 3-8
3.4 Practice Sessions 3-9
3.5 Training Sessions 3-14
3.6 Testing Procedures 3-18
3.7 Generator Shutdown 3-19
3.8 Maintenance Procedures 3-22
3.9 Recordkeeping 3-23
3.10 Recertification Procedures 3-24
References for Section 3.0 3-24
4.0 DATA REDUCTION 4-1
4.1 Grading the Certification Form 4-1
4.2 Certification Letters 4-3
4.3 Mean Deviation and Confidence Limits 4-6
References for Section 4.0 4-10
APPENDIX A. METHOD 9 A-l
APPENDIX B. CAMERA INSTRUCTIONS B-l
APPENDIX C. THE PSYCHROMETRIC CHART C-l
APPENDIX D. SMOKE GENERATOR SPECIFICATIONS, MODEL 3000-A .. D-l
APPENDIX E. OPERATOR'S MANUAL, MODEL 3000 SMOKE
GENERATOR E-l
APPENDIX F. SMOKE GENERATOR TESTING PROCEDURES F-l
1.0 Light Source F-l
2.0 Spectral Response F-l
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TABLE OF CONTENTS (Concluded)
Section Page
3.0 Angle of View of Smokeplume F-l
4.0 Zero and Span Drift F-3
5.0 Calibration Error F-3
6.0 Response Time F-3
APPENDIX G. QUALITY ASSURANCE TECHNIQUE FOR
CERTIFICATION TESTING 6-1
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LIST OF ILLUSTRATIONS
Figure Page
2-1 Sample Agenda for Visible Emissions Evaluation
Course 2-2
2-2 Sample Trainee Registration Record 2-3
2-3 Pencil Shadow Form 2-16
2-4 Sample Sketch of VE Observation 2-18
2-5 The Beaufort Scale of Wind-Speed Equivalents 2-22
2-6 Practice Form 2-24
2-7 Certification Form 2-25
2-8 Sample Quiz 2-30
3-1 Generator Setup Checklist 3-3
3-2 Generator Operation Procedure 3-4
3-3 Smoke Generator Schematic 3-5
3-4 Smoke Generator Console 3-7
3-5 Calibration Staff 3-10
3-6 Sample Calibration Form 3-11
3-7 Calibration and Certification Stamps 3-12
3-8 Practice Procedure 3-13
3-9 Training and Testing Procedure 3-15
3-10 Acceptable and Unacceptable Smoke Readings 3-17
3-11 Generator Shutdown Procedure 3-20
4-1 Grading Procedure 4-2
4-2 Sample VE Program Roster 4-4
4-3 Average Deviation Chart 4-5
C-l Relative Humidity Tables C-2
C-2 Sample Psychrometric Chart C-5
E-l Parts List E-16
E-2 Smoke Generator E-17
E-3 Transmissometer E-18
E-4 Control Console E-19
E-5 Console Rear Connector Panel E-20
E-6 Console Connector, Three Pin E-21
E-7 Console Connector, Nine Pin E-22
E-8 Main Junction Box, Trailer-Mounted Terminal Strip .... E-23
F-l Smoke Generator Performance Evaluation Data Sheet .... F-2
IV
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1.0 INTRODUCTION
This manual was prepared for use by the instructors and smoke
generator operators who conduct EPA Region IV visible emissions
(VE) training programs. It describes the specific smoke generators
owned by Region IV, but is otherwise generally applicable to
training programs throughout the nation. The instructor should
always emphasize the meteorological and other parameters pertinent
to the area where candidates will be evaluating smoke.
Section 2.0 is devoted to the lecture phase of the training
program. It outlines the general content of each suggested talk
and includes a sample agenda for the course. Both lectures and
agenda may be modified or expanded depending on the needs of the
class, since the program described in this manual is a minimal one.
The films and slide shows referred to in this section can be ob-
tained through the Air Surveillance Branch of Region IV EPA.
Section 3.0 discusses the procedures involved in conducting
the certification phase of the program. Generator setup, calibra-
tion, shutdown, and maintenance are included, as well as training
and testing procedures.
Section 4.0 deals with certification criteria and confidence
limits. The appendices include a copy of Method 9, "Visual Deter-
mination of the Opacity of Emissions from Stationary Sources," and
further details on smoke generator design, specifications, and
testing.
This manual is not intended to be a comprehensive source of
information presented in visible emissions lectures (student manu-
als and other references fill that need). Rather, it is a general
guideline for instructors, including both an outline of key issues
that should be addressed by the speakers and a step-by-step outline
for smoke generator operators in Region IV.
1-1
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2.0 THE LECTURE COURSE
2.1 INTRODUCTION
Figure 2-1 gives a suggested timetable for the three-day visi-
ble emissions evaluation course. Time allotments and order of pre-
sentation may be modified to accommodate guest speakers, but the
amount of material to be covered requires that a relatively strict
schedule be maintained. Less than three days does not provide suf-
ficient time for both a complete lecture course and the minimum 10
test runs to which students are entitled when attempting to qualify
as VE evaluators.
The purposes of the lecture course are:
• To provide a working knowledge of the principles behind the
method of evaluating emissions by the concept of opacity.
• To familiarize the student with the legal rights and re-
straints involved in reading visible emissions and in de-
fending his observations in court.
• To prepare the student for the certification training and
test phase of the program.
These goals are accomplished by a series of lectures, films,
and work sessions conducted on the first day of the visible emis-
sions program. A quiz is administered at the end of the first day
to determine the effectiveness of this lecture course.
2.2 REGISTRATION AND ORIENTATION
Registration is usually conducted by the training officer, al-
though the course instructor may perform this task if necessary. A
brief welcoming address should be given, which is usually presented
by a higher level staff member. Registration and orientation,
which consist primarily of introductions, welcome, and completion
of trainee registration forms (Figure 2-2), involve the following
preliminaries:
2-1
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DAY ONE
8:30
9:00
10:00
10:10
11:20
12:00
1:00
2:00
2:10
2:55
3:10
4:10
DAY TWO
8:30
9:00
10:15
10:30
11:00
11:30
12:00
1:00
1:30
DAY THREE
8:30
9:30
9:45
10:15
10:45
12:15
1:15
Time
(minutes)
Registration and orientation 30
Lecture 1: Goals and principles
Break
Lecture 2: Sources of visible emissions
1. "The Three T's of Combustion" (film)
2. Combustion sources
3. None ombust ion sources
Lecture 3: Field operations
Lunch
Lecture 4: Meteorology
Break
"Role of the Witness" (film)
Break
Lecture 5: Testing procedures
Quiz, discussion, and closing
Generator familiarization and calibration
Practice sessions
Break
Training session
First test
Second test
Lunch
Third test
Continue testing (at least two tests per hour)
Lecture 6: Legal aspects
Break
Generator calibration
Training session
First three tests
Lunch
Continue testing (at least two tests per hour)
Final recal ibration
60
10
20
25
25
40
60
60
10
45
15
60
40
30
75
15
30
30
30
60
30
60
15
30
30
90
60
30
Figure 2-1. Sample Agenda for Visible Emissions Evaluation Course
2-2
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OJ
TRAINEE REGISTRATION RECORD - Technical Course
COURSE TITLE
COURSE NUMBER
{t-0
LAST NAME C«-«> CMwwP**} FIRST NAME C»«-»> INITIALC'O
Mr._Mrv_Min..
Position Title
Civil Service or PHS Commissioned Grade
Local Residence During Course
EMPLOYER
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7ln
EDUCATION (Check highest degree obtained) OO
Bachelor | \t Master |""]f Doctor [~|,
Years of College Training (Check correct box}C»)
None fJi 4 vears T 1, 7-8 y*8PJ T 1.
1 * ' Lv«JJ l«*J3
1-3 years [_], 5-6 years [ |, 9 or more [_Jt
PROFESSIONAL OR 1
OCCUPATIONAL CODE C«MO | . .0* Health Educator
U.S. CITIZEN C")
VIS DI NO O»
YEARS OF PROFESSIONAL EXPERIENCE C'«
0-1 year | |t
2-4 years [~[.
5-7 years f"], 11-15 years [_Jf
8- 10 years [~]4 16-20 years (~~1,
21 years or over [~|?
EMPLOYER CATEGORY (For U.S. and Foreign Trainees) G"-«)
GOVERNMENT
FEDERAL (NATIONAL)
EPA (U.S. only) Q >f
Dept. of Defense | ]M
Other Federal | | M
STATE Q] e4
LOCAI- Do,
09 Sanitarian
IM-.'IIT MOST APWOWATC coo§ 01 Administrator 05 Industrial Hyglenlst 09 Statistician
M.;««f«. ONE OIOIT IN EACH "
••OIVICUAI BO». 02 Chemist 06 Meteorologist 10 Technician
-.APCA-M (o^v,-) n-.t 03 Engineer 07 Physical Scientist 11 Othpr
FOR MC
Course
SEE BfVf
UNIVERSITY
Faculty IHJo*
Student [""] 07
INDUSTRY | 1 0.
CONSULTANT j | e,
OTHER [I],,
JDERATOR'S USE ONIr/
»SE SlOt FC1* COCE NUMSE*
Figure 2-2. Sample Trainee Registration Record
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1. Introduce yourself and welcome the class to the facility
and to the course.
2. State the purpose for and method of conducting the train-
ing course in evaluation of visible emissions.
a. The purpose is to train the student so that he or she
can qualify as a certified visible emissions evalua-
tor, i.e., can determine the opacities of both gray-
black and nonblack plumes within 7.5 percent of the
correct reading on the average, with no reading incor-
rect by more than 15 percent.
b. Half the time is devoted to lectures and half the time
to training and test runs using a smoke generator.
i. Lectures include instruction on the sources of
visible plumes, the effects of weather on these
plumes, the legal basis for visible emissions regu-
lations, and certification and field procedures.
ii. Training includes instruction in correctly identi-
fying plume opacities, training runs, and actual
test runs to establish or re-establish
certification.
3. Have each student introduce him or herself, giving a short
background as to where he is from, with whom he is affili-
ated, and so on.
4. Hand out registration materials and any other student ma-
terials not previously distributed, giving any necessary
instructions for filling out registration cards.
5. Point out the locations of restrooms, explain arrangements
for coffee during break periods, and so on.
6. Check that all students have adequate transportation for
the remainder of the session.
7- Suggest convenient restaurants or cafeterias for lunch and
mention local spots of interest and scenic attractions in
the area.
8. Give the names and affiliations of any guest speakers who
will be contributing to the course.
9. Collect the completed registration forms.
10. If time permits and such a show is available, present a
"sound-slide" introduction to the facility.
11. Have a secretary prepare a class roster to hand out to the
students at the end of the first day.
2-4
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2.3 LECTURE 1: GOALS AND PRINCIPLES
The purpose of this lecture is to introduce the student to the
history, principles, and practice of conducting visible emissions
evaluations. Visual aids include a 2 x 2 slide projector, screen,
and Visible Emissions Slide Show No. 1.
Begin by re-emphasizing the purpose of conducting the course,
expanding upon and clarifying the introductory remarks made during
orientation. Explain that certification is necessary to assure
accurate VE evaluations, and that it will be discussed in more
detail later in the day (refer to Sections 2.3.3 and 2.8). Then
start the slide talk, covering each of the following points.
2.3.1 HISTORY OF THE METHOD
The official standard for visible emissions evaluation proce-
dures is the current Method 9, "Visual Determination of the Opacity
of Emissions from Stationary Sources," published in the Federal
Register, Volume 39, No. 219, on November 12, 1974 (refer to Ap-
pendix A). All students should have a copy of this document for
study during the training course and for reference during future
field operations.
Explain that Method 9 is the standard method used and approved
by the U.S. Environmental Protection Agency to test for visible
emissions (slide No. 1). It is just as valid as stack testing
methods: in fact, its accuracy is much higher.
The entire visible emissions evaluation system is loosely
based on the principles devised by Maximillian Ringelmann around
the turn of the century in an attempt to measure air polluting
waste from coal-fired boilers (slide No. 2).
The Ringelmann Chart, a method by which the densities of
columns of smoke rising from stacks may be compared, was one of the
first tools used to measure emissions to the atmosphere (slide No.
2-5
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3). The chart consists of a scheme by which graduated shades of
gray that vary by five equal steps between white and black can be
accurately reproduced by means of a rectangular grid of black lines
of definite width and spacing on a white background.
In the 1950's, the term "equivalent opacity" was introduced
and the principle of visible emissions evaluation was extended to
other colors of smoke. The modern term is simply "opacity," which
is defined as the obscuring power of the plume.
The Federal government has discontinued the use of Ringelmann
numbers in Method 9 procedures and in Federal New Source Perform-
ance Standards (NSPS), basing the determination of the optical den-
sity of visible emissions from stationary sources solely on opacity
(refer to Section 2.3.2). Some state regulations have not made
this change, however, and so continue to operate under a dual sys-
tem in which the Ringelmann Chart is used in the evaluation of
black and gray emissions and equivalent opacity is used for all
other visible emissions.
Certified evaluators must be familiar with both systems of
measurement, but all smoke readings conducted by EPA personnel in
Region IV must be in percent opacity only.
Students should be told that the Ringelmann Chart is actually
unnecessary and that the training they are receiving will enable
them to evaluate the opacity of smoke plumes without such artifi-
cial aids.
2.3.2 OPACITY
The concept of "equivalent opacity" made possible the applica-
tion of the Ringelmann principle to white and other nonblack colors
of smoke. One of the first applications of this concept was in the
1945 air pollution control ordinances of the County of Los Angeles,
which specified that nonblack plumes be judged by the amount of
light that they obscure. The 1947 California Health and Safety
2-6
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Code was subsequently amended to limit visible emissions for a giv-
en period of time not only to Ringelmann No. 2 shade of gray, but
also to any opacity that obscures an observer's view to a degree
equal to or greater than Ringelmann No. 2.
Opacity simply means the degree to which an image or back-
ground viewed through the plume is obscured. A good working defin-
ition of opacity is "the obscuring power of the plume expressed in
percent." (Thus reference to an opacity as "equivalent" to a given
Ringelmann number is no longer required or desirable.)
2.3.3 CERTIFICATION
The concept of opacity and the training through which evalua-
tors learn to apply it are presented in a series of smoke schools
that are held all over the country (slide No.4).
Qualifying trainees are certified for 6 months following the
date they successfully complete the lecture and test portions of
the visible emissions evaluation course. Recertification may be
obtained without repeating all of the classroom part of the course
(refer to Section 2.10).
To become certified, observers must read 25 white and 25 black
smoke plumes of varying opacities with a deviation of not more than
7.5 percent for each set of 25 readings and without erring by more
than 15 percent opacity on any single reading. Testing procedures
are explained in detail in Sections 2.8 and 3.6.
The standard of accuracy that students must demonstrate to
become certified is necessary to assure the quality of visible
emissions observations. Only currently certified evaluators can
perform field operations (Section 2.5) and act as expert witnesses
in court (Section 2.10).
2-7
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2.3.4 SMOKE GENERATORS
In order to train personnel to evaluate visible emissions, a
smoke generator that produces both black and white smoke and an
instrument that measures the transmission of light through this
smoke are necessary.
The instrument that measures light passing through the plume
is a transmissometer, which consists of a light source and photo-
cell combination; the percent transmission is indicated by a strip
chart recorder calibrated from 0 to 100 percent opacity. Calibra-
tion is accomplished by means of neutral-density filters. Further
details on the design, calibration, and operation of the smoke gen-
erator are included in the field portion of the course (refer to
Section 3.0).
Black smoke is generated by the incomplete combustion of tolu-
ene or other organic hydrocarbons in a specially designed^ insul-
ated combustion chamber (slide No. 5). Smoke density is varied by
adjusting the fuel injection rate. The smoke is pumped through a
fan and up the stack past the transmissometer, which reads the opa-
city of the smoke.
White smoke is generated by vaporizing kerosene or No. 2 fuel
oil on a heated plate or in a hot box (slide No. 6). Smoke density
is controlled by adjusting the fuel flow rate. The white smoke is
also pumped through a fan and past the transmissometer.
The opacity of the smoke depends upon several mechanisms
(slide No. 7):
» Reflection: the return of a ray of light after striking the
surface of the srnoke particles.
9 Refraction: the change of direction of a ray of light in
in passing from one medium (air) into another (smoke parti-
cles) in which its speed is different. This is similar to a
lens or prism effect.
2-8
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• Absorption: the reduction in energy in the form of electro-
magnetic radiation by a medium or by a reflecting surface.
Dark-colored smoke particles absorb the energy of the light,
thus preventing it from getting to the detector. (The
detector in this case is a phototopic photocell much like
that in a camera.)
2.3.5 ADVANTAGES AND DISADVANTAGES OF OBSERVER EVALUATION OF
VISIBLE EMISSIONS
Observer evaluation of visible emissions has numerous advan-
tages over stack testing. These include:
• Short training time (24 to 32 hours)
• No extensive technical background needed
• No expensive equipment required
• Many readings per observer per day
• Source testing not necessary in order to cite violators
• Questionable emissions easily located
• Cannot practically test many sources by any other method
One of the main reasons for using the visible emissions method
is its low cost (slide No. 8). Comparison of the cost of the mini-
mum equipment needed for the VE inspector versus that of a conven-
tional stack testing system reveals the truth of this statement: a
sun visor and a compass add up to around $8.35, whereas the samp-
ling procedures, tests, scaffolding, and so on required for Method
5 stack testing can very easily cost about $17,000. The amount of
time for the VE inspection is approximately 1 hour; the time for a
stack test is about 9 man-days.
Moreover, there are numerous facilities that cannot be prac-
tically tested by any method other than smoke reading. A battery
of coke ovens is one such source: a VE inspection would take about
2 days, but stack testing would require all year (slide No. 9).
There are, however, several criticisms of visible emissions
control regulations and the ability of evaluators to enforce them
2-9
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objectively. In addition to the variables mentioned in rela-
tion to viewer position (refer to Section 2.3.6), these criticisms
concern the difficulties of accurately evaluating smoke under the
following conditions:
• When the emissions are gaseous at stack temperature but
condense after plume expansion
• At night
• When condensed water vapor is present in the plume
• From within the building housing a point source
• When polluters circumvent regulations by adding more air to
the effluent or by building a new stack of smaller diameter
for emitting the same quantity of effluent
• When opacity is not well correlated with the amount of
material emitted
• In the presence of weather constraints such as raindrops,
inclement weather, and high winds that shear the plume
While these objections have a certain degree of validity,
they are mitigated by the following points:
« Opacity is not influenced by night time per se. The light
source should be behind the plume when making VE observa-
tions during hours of darkness. The light source can be the
moon, a star, a street light, or city lights. The densest
part of the plume should be between the observer and the
lighted object.
• Visible emissions evaluation programs teach inspectors how
to identify the presence of water vapor in plumes and how to
read such plumes so as to avoid looking through the "steam"
or condensed water vapor.
• Other methods of measuring emissions may be preferable with-
in the building housing a point source, but this does not
invalidate the method of observer evaluation.
o Circumvention can be detected by comparing current readings
with past VE records, which include the location and stack
diameter of all observed emission points.
• Opacity limits are enforceable independent of mass emission
limits and other standards. Studies such as those by Ensor
and Pilat have attempted to calculate smoke plume opacity
from particulate air pollutant properties (Reference 1), but
2-10
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this remains a complex and controversial issue. Refer also
to the EPA Response to Remand in Portland Cement Association
v. Ruckelshaus (Reference 2).
• Certified inspectors are aware of the influences of weather
constraints and do not attempt to make VE observations under
inappropriate conditions.
The validity of observer evaluation of visible emissions is
also attested to by the ability of students to learn to read smoke
(slide No. 10). Judging opacity is no different than judging
shades of color. The human eye is capable of selecting a very nar-
row range of the electromagnetic spectrum and identifying its fre-
quency of light. The VE training program consists of calibrating
this type of ability to a scale that distinguishes opacity in in-
crements of 5 percent. This is done by first teaching the student
to recognize 25, 50, and 75 percent opacity, and then giving read-
ings in between these standards.
2.3.6 OBSERVER POSITION
Opacity or smoke density observations may vary according to
the position of the sun, atmospheric lighting, background of the
plume, and size of particles in the plume (slide No. 11). This
variability can be minimized by reading plumes under the following
conditions:
• With the sun in the 140 degree sector to the observer's
back, and preferably in a 90 degree sector
• With the wind blowing at approximately right angles to the
observer's line of sight and from a point not less than two
stack heights and not more than 0.25 miles from the source
• Against a background that contrasts with the color of the
plume
• With the longer axis of rectangular outlets at approximately
right angles to the observer's line of sight
• Through the densest part of the plume and where the plume is
approximately the diameter of the stack
• With summertime readings avoiding the hours between 10:00
a.m. and 1:30 p.m. (when the sun is high in the sky)
2-11
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The major rule is to keep the sun directly over the observer's
back. This and the other guidelines are illustrated by the follow-
ing scenario:
• The deputy conies out to read smoke in the morning and what
does he see (slide No. 12)? Can he read smoke? Why not?
® He comes back after about 4 hours and the sun has moved
across the sky (slide No. 13). Now, should he look through
line A or line B? Obviously, he should look through line B.
« In fact, the only thing that would make it easier for the
deputy to read smoke would be to get a good background
(slide No. 14).
Emphasize once again that the correct line of vision is per-
pendicular to the long axis of the plume (slide no. 15). The best
viewing spot is one stack diameter above the stack exit, where the
plume is densest.
Encourage students to observe plumes using different back-
grounds and with the sun located at different angles in order to
demonstrate the effects that these parameters have on observed
opacity (slides No. 16 - 19).
Illustrate what happens to a smoke plume when the wind is
blowing (slide No. 20). Also show how the plume can look very
thick if it is observed along the long axis instead of through it,
and discuss the effects of background (slides No. 21 - 23).
The smoke reading situation is somewhat akin to that of David
and Goliath (slide No. 24), in that the lowly smoke reader, equip-
ped only with his eyes and clipboard, must face the mighty giant of
industry. However, it is not so much the tool you use (slide No.
25), as how well you use it! The importance of correct observer
position cannot be overemphasized. Refer to Section 2.5, Figures
2-3 and 2-4.
2-12
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2.3.7 CONDENSED WATER VAPOR PLUMES
Condensed water vapor or "steam" plumes are a potential prob-
lem due to aesthetic considerations, visibility reduction, and the
possibility of their masking atmospheric contaminants. Condensed
water vapor is not a pollutant, however, so opacity observations
must be made either beyond or prior to the point where it is visi-
ble in the plume (refer to Appendix A, Sections 2.3.1 and 2.3.2).
The lecture on meteorology (refer to Section 2.6) gives details on
how steam plumes are formed, how to identify and evaluate them, and
how to predict their occurrence through use of a psychrometric
chart (refer also to Appendix C, Figure C-2).
The importance of correctly identifying condensed water vapor
plumes is illustrated by the following example (slide No. 26). Say
you have two plumes, plume No. 1 and plume No. 2. Which one is
dirtier? Without knowledge of what is contributing to those
plumes, it is impossible to make a judgment. Based on sheer opa-
city, plume No. 2 may appear dirtier. However, its white material
could be—and probably is-—condensed water vapor, in which case it
is not pollution. Thus plume No. 1 appears to be much cleaner, but
it is in fact all particulate and is probably the dirtier of the
two.
Condensed water vapor plumes can either be attached to or
detached from the stack exit (slide No. 27). Detached plumes occur
when the entrained water vapor is at too high a temperature and
condenses above the plume, or when sulfuric acid forms above the
plume. This is particularly prevalent where vanadium-containing
fuel oils, such as come from South America, are used in oil-fired
boilers.
2.4 LECTURE 2: SOURCES OF VISIBLE EMISSIONS
This lecture may be given either by an enforcement branch
staff member or by the training course instructor. Visual aids
2-13
-------
include a 16 mm movie projector, 2x2 slide projector, screen, the
film "The Three T's of Combustion," and slides illustrating combus-
tion and noncombustion sources of visible emissions.
Begin by discussing the importance of particle size to plume
visibility, the various types of visible air contaminants, and the
effects of particulate air pollutants. Then introduce the film
"The Three T's of Combustion," which is 20 minutes long and gives a
short introduction to the physics of combustion. Next, while show-
ing the appropriate slides, discuss the problems of and techniques
for accurately evaluating the different types of sources of visible
emissions. Special emphasis should be given to the topics discuss-
ed in the following subsections.
2.4.1 COMBUSTION SOURCES
Combustion sources of visible emissions are classified as fuel
combustion, transportation, and solid waste disposal, and include
fuel oil, natural gas and coal burning, incineration, agricultural
burning, and mobile sources. Stress the differences between com-
plete and incomplete combustion, black and nonblack smoke, types of
fuel, combustion equipment and methods, major emission points, and
other variables affecting visible emissions.
2.4.2 NONCOMBUSTION SOURCES
Industrial process losses, such as fumes, dusts, mists, gases,
and vapors, are classified as noncombustion sources of emissions.
Such emissions cannot truly be called "smoke" because this term
refers only to the visible effluent resulting from incomplete com-
bustion, which consists mostly of soot and fly ash. Operations
that emit noncombustion pollutants to the atmosphere include grind-
ing, melting, cooking, materials handling, and so on.
2-14
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Because a wide variety of industries produce visible process
emissions, this lecture should be tailored to the industries in the
area where the students will be evaluating smoke. Limit this part
of the lecture to a few examples of the problems and techniques
involved in identifying, evaluating, and controlling visible
emissions from noncombustion sources. Give particular attention to
ways of distinguishing between noncombustion emissions—particular-
ly condensed water vapor plumes—and smoke. This is most important
to the visible emissions evaluator because condensed water is not a
pollutant (refer to Sections 2.3.7 and 2.6).
2.4.3 OTHER SOURCES OF VISIBLE EMISSIONS
Emphasize the pertinence of fugitive emissions, types of
vents, and other factors that affect observer evaluation of sta-
tionary sources. During recertification, review any problems in
the area where observers are evaluating smoke (e.g., coke ovens;
refer to Section 2.10.1).
2.5 LECTURE 3: FIELD OPERATIONS
This section refers to the actual evaluation of visible emis-
sions by certified VE observers during field inspections. This
presentation should be made by an experienced inspector, if pos-
sible, or it can be made by the course instructor.
Begin by emphasizing the importance of doing preparatory re-
search prior to making actual field observations of a particular
plant. Such research should include information on process operat-
ing conditions, type and location of control equipment, probable
location of source emissions, possible observation sites, regula-
tions applicable to the source, presence of water vapor plumes, and
other pertinent data.
2-15
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Pass around the equipment that should always be taken along by
the inspector (e.g., inspection forms, field logs, a stopwatch, a
sling psychrometer, a compass, and a camera with a telephoto lens).
Other equipment may be necessary, depending on the type of source
and the observational conditions (such equipment might include
topographic maps, a hand-held anemometer, binoculars, a range-
finder, and a machete). It is also good practice to take along a
hard hat and safety boots; other safety equipment might include
safety goggles or a respirator.
Explain observer position (Section 2.3.6) in further detail,
including the use of a pencil shadow form (Figure 2-3). A line
drawn through the shadow of the pencil toward the sun must fall
within the triangular 140° sector when the pencil is placed upright
at the point that represents the observer's position in relation to
the plume.
North
Plume
ibserver
Figure 2-3. Pencil Shadow Form
2-16
-------
Illustrate the correct use of the pertinent observation form,
field log, and inspection data sheet, pointing out that observation
forms are source specific, i.e., different for different facili-
ties. In general, the following items should be performed by the
inspector in the field in conjunction with completing observation
forms and field logs. These items are necessary to meet Method 9
requirements and to improve documentation of the VE evaluation:
• Take readings every 15 seconds
• Take at least 24 readings (6 minutes)
• Divide the observations into sets of 24
• Obtain the average opacity for each set
• Record the average opacity for each set
• At the beginning and at the end of the observation, record
the following:
• Estimated distance to the emission point
• Direction of observer to the source
• Height of observation point
• Wind speed
• Wind direction
• Ambient temperature
• Wet bulb temperature
• Relative humidity
• Description of sky condition
• Plume background
• Distance plume is visible
• Indicate whether a steam plume is present. If there is a
steam plume, note whether it is attached or detached, where
the breakpoint occurred, and where the opacity readings were
made.
• Draw a sketch showing observer location in relation to the
emission point, the wind direction, and the location of the
sun. Use symbols, as indicated in Figure 2-4.
2-17
-------
• Record the operational data at the time of the evaluation
for the source being evaluated. Such data includes actual
operating rate, design operating rate, materials or fuels
being used, types of air pollution control equipment, and
so on.
Wherever possible, these items should be measured with the
appropriate instrumentation. The minimum amount of equipment
necessary consists of a sling psychrometer, an anemometer, a
compass, and a stopwatch.
If time permits, briefly illustrate the steps of photo docu-
mentation, using a single lens reflex camera or one with automatic
photocells. These steps are given in Appendix B. Conclude by em-
phasizing the importance of following up the visual observation
with an in-plant inspection.
North ^ 350 ft
Wind
SO K^i2
\
1
\
Observer $un
Figure 2-4. Sample Sketch of VE Observation
2.6 LECTURE 4: METEOROLOGY
This lecture is designed to introduce students to the basics
of air pollution meteorology, and may be presented either by a
guest speaker or by the course instructor. Visual aids may include
2-18
-------
slides, transparencies, or handouts illustrating major weather
influences on pollutants.
Give a brief synopsis of the air pollution cycle of release,
transport and dilution, and reception of air pollutants, pointing
out that diffusion and transport are the major weather influences
on pollutants after their release. Describe the structure of the
earth's atmosphere, including definitions of lapse rate (the rate
of decrease in temperature with increase in height) and inversion.
Point out the effects of temperature inversions on atmospheric
processes and hence on the dispersion of air pollutants.
Explain dry adiabatic lapse rate—the lapse rate of a parcel
of dry air as it moves upward in a hydrostatically stable environ-
ment and expands slowly to lower environmental pressure without
exchanging heat with its environment (it is also the rate of in-
crease in temperature for a descending parcel).
Next, discuss diffusion and vertical and horizontal transport
in some detail, as well as how climatic zones affect when and where
inversions occur (particularly in the area where students will be
evaluating smoke, if applicable). Also include other meteorologi-
cal parameters that affect plume shape and type, e.g., radiation,
fronts, pressure areas, water in the air, turbulence, eddies, and
so on.
Give a brief synopsis of the meteorological conditions that
interfere with or prohibit smoke reading. These include:
1. Rain: Rain not only creates a hazy background, but actu-
ally obscures the vision and may knock down part of the
plume.
2. Position of the sun: Although this is not specifically
meteorology, the position of the sun is very important.
If the sun is not at the observer's back, then the plume
can be enhanced in appearance due to the characteristic
called forward scatter.
2-19
-------
3. Wind: If the plume is being sheared off at the stack, the
observer will probably read the smoke as less opaque than
it actually is. Smoke should not be read under these
conditions.
4. Time of day: If it is dark, it is very hard to read
smoke.Although people have been certified in California
reading smoke after dark by the use of a light, it is very
impractical. Night vision scopes and other sorts of
devices have been tried, but smoke reading at night is
still a problem.
5. Clouds and haze: Clouds and haze also interfere with
smoke readings. A very strong gray cloud cover will tend
to make the observer underread the smoke due to the lack
of contrast between the particles of the smoke and the
background of the clouds. It is impossible to tell that
something is being obscured if it is the same color as the
obscuring body.
6. Cold temperatures and condensed water vapor plumes: Cold
temperatures can cause the condensation of water vapor in
the plume. This reduces the observer's ability to read
smoke accurately.
The four most important aspects of condensed water vapor (or
"steam") plumes are:
• How condensed water vapor plumes are formed
• How to identify condensed water vapor plumes
• How to read condensed water vapor piumes
• How to predict the occurrence of condensed water vapor
plumes through the use of a psychrometric chart (refer to
Appendix C, Figure C-2)
A sling psychrometer is a device that is operated by moisten-
ing the wick on one thermometer ("wet bulb") and swinging it around
in the air along with a dry bulb thermometer until a differential
temperature is evolved. Either the chart on the sling psychrometer
(if present) or the a relative humidity table such as the one shown
in Appendix C, Figure C-l can be used to determine the relative
humidity of the air. This number is plotted at one point on the
psychrometric chart. The water vapor percentage of the plume
2-20
-------
(derived from emissions information) is recorded at a second point.
If a line drawn through the two points enters the nongridded area
of the chart, then there is a good chance that a condensed water
vapor plume will form. This is the only method short of stack
testing that can predict the presence of condensed water. A sample
calculation using the psychrometric chart is contained in Appendix
C.
It is also important to note whether a given plume rises or is
dispersed, whether it stays compact, and so on. There are several
kinds of plumes:
1. Looping plume: This occurs on a superadiabatic day, i.e.,
a day on which the temperature cools as air rises in the
atmosphere. Due to the temperature of the plume and the
change in temperature of the earth, the plume varies and
loops.
2. Fanning plume: A fanning plume occurs when the lapse rate
is inverted, that is, when warm air is above the cold air.
In this case, the plume can travel for many hours in an
unaltered state.
3. Fumigation plume: This type of plume occurs when the
temperature inversion is breaking up and the sun warms the
earth, so that the air between the temperature inversion
and the earth becomes the same temperature as the plume.
When this happens, the plume mixes very strongly with the
air below the inversion and fumigates the area.
4. Coning plume: A coning plume occurs when the adiabatic
lapse rate is normal and extremely good mixing occurs
along with some wind. This type of plume gives maximum
dispersion.
5. Lofting plume: A lofting plume occurs when the smoke is
emitted above stagnation or above an inversion level.
Another point that ought to be emphasized in the meteorology
lecture is how to estimate cloud cover. This can be done with a
piece of blue cardboard and a sheet of white paper of equal size.
Illustrate 100 percent cloud cover, then tear the white page in
half, tear the half into smaller pieces, and illustrate 50 percent
2-21
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cloud cover. Next, take half the pieces away and illustrate 25
percent cloud cover. This shows that people tend to overestimate
cloud cover.
A final point that should be stressed is the use of a wind in-
strument to determine wind velocity. Both small rotameters and
hand-held anemometers are available. The Beaufort scale of
wind-speed equivalents may also be used (Figure 2-5).
General
Description
Characteristics
Limits of Velocity
33 feet (10 m)
above level ground
(MPH)
Calm
Light
Gentle
Moderate
Fresh
Strong
Gale
Whole
Gale
Hurricane
Smoke rises vertically
Direction of wind shown by smoke
drift but not by wind vine
Wind felt on face; leaves rustle;
ordinary vane moved by wind
Leaves and small twigs in con-
stant notion; wind extends light
flag
Raises dust and loose paper;
small branches are moved
Small trees 1n leaf begin to
sway; crested wavelets form
on inland waters
Large branches in notion;
whistling heard in telegraph
wires; umbrellas used with
difficulty
Whole trees 1n notion; Incon-
venience felt 1n walking
against wind
Breaks twigs off trees; gen-
erally impedes progress
Slight structural damage oc-
curs (chimney pot and slate
removed)
Trees uprooted; considerable
structural damage occurs
Rarely experienced; accompanied
by widespread damage
Under 1
1 to 3
4 to 7
6 to 12
13 to IB
19 to 24
25 to 31
32 to 38
39 to 46
47 to 54
55 to 63
64 to 75
Above 75
Figure 2-5. The Beaufort Scale of Wind-Speed Equivalents
2-22
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2.7 FILM: "ROLE OF THE WITNESS"
Show the film, "The Role of the Witness" (this requires a 16
mm projector and screen). This 45-minute film is a dramatization
of proper courtroom procedures when giving testimony as an expert
witness. Explain that the discussion of legal aspects of visible
emissions evaluation will take place on the morning of day three,
so that observers who are being recertified can hear the review of
current cases given by the speaker (refer to Section 2.10).
2.8 LECTURE 5: TESTING PROCEDURES
The testing procedure for obtaining certification is illus-
trated by Visible Emissions Slide Show No. 2, which should be shown
at the beginning of this lecture. Other visual aids include a 2 x
2 slide projector, overhead projector, screen, transparencies,
china marking pencils, and a practice and a test form (Figures 2-6
and 2-7) for each student. This lecture is crucial because if
students do not understand the proper procedures, they will use
valuable testing time to ask questions.
Distribute the practice forms (Figure 2-6) and explain that
they are used to introduce different opacities to the students.
Tell the class that the training sessions will consist of sets of
four readings, preferably of 25, 50, 75, and 100 percent opacities
(in random order) for the first few sets of four. After each set,
the instructor or generator operator will give the actual opacities
and have students grade their own papers.
Stress the fact that the students' ability to distinguish
these standard values accurately will build their confidence at the
outset, thus facilitating discrimination between smaller and
smaller increments of opacity. Explain that readings will continue
to be given four at a time until all students are reasonably
confident of their ability to read all four opacities correctly.
2-23
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ENVIRONMENTAL PROTECTION AGENCY
• SCION IV
SURVEILLANCE AND ANALTJIS DIVISION
ATHGN*, CCON6IA 13801
Vlalbl* Emission* Ev&luation
Practice Run Shact
KMDDIC ACTUAL OUTZSQICjg READIHC ACTO/O, DIFFERENCE
Figure 2-6. Practice Form
2-24
-------
NAME
COURSE LOCATION
DATE ~
SKY
IND
DISTANCE AND DIRECTION TO STACK
READING
NUMBER
1
•r~
3.
4
•»
6
7
R
9
10
11
J2
11
14
J5
16
17
1«
T»
?0
71
7?
71
74
.»
0
0
n
n
n
o
0
o
o
o
o
n
o
0
p
p
n
n
n
n
n
0
n
0
n
5 10 IS
5 10 15
5 10 15
5 10 15
S 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
70
26
20
20
20
20
20
20
20
20
20
20
20
20
20
20
70
20
20
70
20
70
20
70
70
25 30 35
25 36 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 36 35
40
•40'
40
40
40
40
4U
40
40
40
40
40
40
40
40
40
40
40
40
40
46
'40
40
40
TO
45 SO 55
45 50 55
45 SO 55
45 SO 55
45 SO 55
45 50 55
45 >0 «
45 56 55
45 SO 55
45 50 55
45 50 55
45 50 55
45 50 55
45 50 55
45 56 55
45 50 55
45 50 55
45 50 55
45 56 .'31
45 30 55
45 50 S5
45 50 55
45 50 Si>
45 50 55
45 50 55
60
66
(.0
60
60
60
tu
CO
6l)
bO
60
60
60
60
60
to
to
60
60
60
60
60
60
bO
60
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 7U 73
65 76 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70- 75
65 70 75
65 70 75
65 70 75
6S 70 75
65 76 75
65 76 75
65 76 75
65 76 75
65 70 75
65 76 75
65 76 75
65 76 75
80
no
80
RO
BO
80
bO
80
80
80
80
80
80
80
80
80
80
80
86
86
66
BO
SO
60
80
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 *3
85 90 95
85 90 93
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 9b 95
65 90 95
65 96 95
65 90 95
65 96 95
65 90 95
85 90 95
65 90 95
100
100
100
100
100
100
iuO
103
1UU
10U
100
10G
100
103
100'
100
100
160
loo
IOC"
16"
160
TOO
IOC-
loo"
ERROR
1
2
3
4
5
6
7
8
9
iO
11
12
13
14
15
lb
17
18
19
20
21
22
23
24
25
WHITE DEVIATION
2*
27
2S
29
30
31
32
33
34
35
36
37
36
39
4Q
41
42
«3
44
4«j
4ft
47
4fi
49
50
0
0
0
0
V
0
P
0
0
0
0
0
0
0
o
0
0
0
0
p
0
p
p
p
0
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5. 10 I?
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
5 10 15
1 10 15
S 10 15
S 10 15
S 10 15
S 10 15
20
20
20
20
20
29
20
20
2V
20
20
20
20
20
20
2Q
20
20
20
20
20
20
70
70
20
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
25 30 35
40
40
40
40
40
4°
40
40
40
40
40
40
40
40
40
40
40
40
40
40
40
4.0
40
40
4.0
45 50 55
45 50 55
45 50 55
45 SO 55
45 50 55
45 50 55
45 50 55
45 SO 55
45 50 55
45 50 55
45 50 55
45 50 55
45 50 55
45 50 55
45 50 55
45 50 55
45 50 55
45 50 55
45 50 55
45 50 55
45 50 55
4_5 50 55
45 SO 55
45 50 55
45 50 55
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
60
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
65 70 75
80
BO
80
80
80
RO
RO
80
RO
RO
80
80
80
80
80
80
80
80
80
80
RO
80
RO
RO
RO
85 90 95
SS 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
33 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
85 90 95
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
10:
100
100
100
100
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
4B
49
50
BLACK DEVIATION
Figure 2-7. Certification Form
2-25
-------
The number of readings per set will then be increased to eight, 12,
16, and so on, as time permits.
Give a brief list of the equipment needed during testing,
i.e., a clipboard, a large rubber band (to keep the test paper from
flapping in the wind), a small piece of cardboard (to keep one's
place on the form), ballpoint pens, a sun visor, appropriate
Clothing, and perhaps a folding chair, thermos of coffee, and so
on.
Also mention the use of sunglasses. If a candidate intends to
wear sunglasses while making visible emissions evaluations, he must
qualify wearing the same pair of glasses. Glasses that change
density with changing sunlight and red or blue sunglasses are not
acceptable. The best sunglasses for reading smoke are gray neutral
sunglasses or those in the green light range; the latter optimize
the visibility of smoke in the same way a transmissometer does.
Now distribute the certification forms (Figure 2-7), pointing
out the fact that the certification form is a "no carbon required"
(NCR) form that allows students to grade their own papers while
prohibiting cheating. Stress the necessity of using ballpoint pens
(not felt tip ones) on these forms.
Explain that in the actual test situation, the instructor will
hand out the certification forms and announce the run number. Each
set of 50 readings, 25 white and 25 black, is one test run. Stu-
dents then fill out the entire top part of the form, giving the
following information:
• Name
• Course location (including area, city, and state)
• Run number (provided by the instructor or generator operator)
e Time of day
0 Date
« Sky conditions (in percent of cloud cover)
2-26
-------
• Wind speed and direction
• Observer distance and direction to stack
Inform students that a compass board will be placed between the
testing area and the generator so they can determine the direction
the wind is coming from and their own direction to the stack.
Next, discuss the actual testing procedures, covering the
following topics:
• When to make readings
• How to mark the paper
• How to correct a reading
• How to grade a paper
The first thing the generator operator will say once the cer-
tification run begins is "number one." This indicates that the
smoke is steady as it comes out of the generator. When students
hear these words, they are to glance up at the plume and make a
judgment as to how Opaque it is by looking through the plume and
estimating the percentage of the background that is obscured.
Stress that students are not to write anything on their papers
until they hear the word "mark." At this time, they should make a
slash from the upper right to the lower left through the value that
most closely approximates the opacity they observed when the opera-
tor said "number one." This procedure will be repeated for the
remaining 24 white and 25 black readings (slide No. 1).
Occasionally, something will happen beyond the operator's con-
trol, e.g., the smoke shifts or a bubble occurs in the fire box so
that the smoke changes in opacity. When this occurs, instead of
saying the word "mark," the generator operator will say the word
"scratch." When students hear the word "scratch," they are not to
mark on their papers. Thus the generator operator validates the
steadiness of the smoke at the same time students are making their
readings (slide No. 2).
2-27
-------
If the student wishes to change a reading, he can do so by
circling the incorrect answer and making a new mark on the correct
answer (slide No. 3). More often than not, however, the first
impression is the best.
When the test run has been completed, students turn in the top
copy of their papers and grade their own carbons. Using a pen of a
different color, they mark down the answers given by the instructor
or generator operator by making slashes from the upper left to the
lower right through the correct values (slide No. 4). They then
add their "increments of error:" each error of 5 percent opacity,
either positive or negative, is counted as one increment.
In order to qualify, no one reading can be in error by more
than three increments, and the total error (without regard to sign)
must be 37 or less both for the 25 white and for the 25 black read-
ings (slide No. 5). If a student thinks he or she has qualified,
he turns in his carbon to the instructor, who matches it up with
the original test paper and grades the run according to the method
described in Section 4.1.
A student who thinks that he has qualified should nevertheless
take the next test because his paper will be graded during that
test. Thus if the student made a mistake in his grading, he will
not miss the next chance to qualify.
At the end of the slide talk, if time permits, have the stu-
dents fill out the certification forms as though a real certifica-
tion test were being conducted. Then give 50 readings, instructing
the class to record them as though they were doing so during a
test; follow this with the "correct" values, having the students
grade their own papers as they would during a test. Then show an
overhead transparency of a correctly graded sheet, emphasizing the
7.5 percent average deviation and 15 percent error limitation for
passing the test and thus qualifying for certification.
2-28
-------
Conclude by entertaining any questions, repeating the entire
exercise if necessary. This is more efficient than having to
answer questions individually in the field on day two.
2.9 QUIZ
Figure 2-8 is a sample quiz on the lecture part of the
course. This quiz or one similar to it should be given and graded
at the end of day one.
2.10 LECTURE 6: LEGAL ASPECTS
This lecture should be given on the morning of the third day,
so that observers who are becoming recertified can hear it. It
should be presented by a staff lawyer from the regional office,
although a legal support branch staff member may deliver it if
necessary.
2.10.1 METHOD 9 AND LEGAL PRECEDENT CASE HISTORIES
The visible emissions regulations—Ringelmann numbers and
equivalent opacity—and their enforcement by certified observers
have been established for a number of years in various states and
their constitutionality has been supported by numerous appeals
cases. Summarize a few specific court cases, preferably both in
the region where the course is being given and nationwide (refer to
"Guidelines for Evaluation of Visible Emissions," EPA-340/1-75-007,
April 1975). Emphasize how these cases have affected the subjects
discussed in the following sections. Also discuss any currently
pending enforcement cases that involve VE observations and touch on
the highlights of Method 9.
2.10.2 LEGAL RIGHTS OF INSPECTION
Various courts in the country have found that visible emis-
sions may be evaluated from either inside or outside the plant
2-29
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NAME
Smoke School Quiz
1 point
Multiple Choice - 3 points each
1. A certificate is valid for:
A. 6 months B. 1 month
C. 1 year
2. The observer should stand:
A. Facing the sun B. With the sun on his back
3. The opacity scale is used for:
A. Black smoke B. White smoke C. Red smoke
E. A « B F. All of the above
C. With sun at his side
D. Blue smoke
4. A North wind blows from the:
A. South B. North
B. The smoke reading should be taken:
A. One stack diameter above
the top of the stack
C. At the widest part of the plane
6. The piune axis should be:
A. Along the reader's line of sight
C. West
D. East
B. At the top of the plume
D. At the narrowest part of the plume
B. At right angle to the reader's
line of sight
7. Smoke reading is an
A. Objective
B. Subjective
measurement.
8. White smoke emitted from the generator consists of:
A. Talcum powder
Matching - 1 point each
B. Oil soot
9. 201 opacity
10. 0% opacity
11. Water vapor
12. 501 opacity
13. Gaseous pollutants
14. Wind speed
15. 80% opacity
16. Light scattering
17. Photocell
18. Neutral density filter
19. 100% opacity
C. Oil Vapor
0. Steam
A. Transmissometer
B. Not measurable
C. 0 Ringelmann
D. 2-1/2 Ringelmann
E. Steam Ringelmann
F. 5 Ringelmann
G. 4 Ringelmann
H. Calibration
I. 1 Ringelmann
J. Beaufort scale
K. Opacity
Figure 2-8. Sample Quiz
2-30
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Short answer or listing - 8 points each
20. What Is opacity? 25 words or less
21. What are the advantages of the visual method of plume evaluation?
22. What are the limitations of visual plume evaluation?
23. Distinguish combustion versus process sources.
24. How can photographs be useful in smoke reading?
25. List typical sources of BLACK smoke.
26. List typical sources of WHITE smoke.
27. What is a sling psychrometer?
Figure 2-8. Sample Quiz (Concluded)
2-31
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property. Advance notices or entry warrants are not always neces-
sary, but the consent and cooperation of the owner is of course
advisable. Each agency should consult with its own counsel to
develop a policy of how and when entries will be made.
2.10.3 LEGAL RESTRAINTS
Different types of sources and different areas of the country
require different visible emissions restrictions. Certain opera-
tions may be exempt from the regulations, and exceptions may be
allowed for others (such as agricultural burning) during certain
periods of time. Discuss the specific variations applicable to the
location where the course is being held.
2.10.4 HOLD HARMLESS AGREEMENTS
Hold harmless agreements (also referred to as indemnity
agreements, waivers, and visitors' releases) are statements that
certain firms require inspectors to sign as a condition to entry
onto their industrial facilities. EPA employees cannot be denied
entry for refusal to sign such agreements and, in fact, should be
instructed not to sign them under any circumstances. For further
details, refer students to pages 12 - 15 and Attachment 3 (John
Quarle's 1972 memo) of the 1975 EPA Visible Emission Inspection
Procedures (Reference 3).
The situation may vary for state and local inspectors. If so,
tell students what the appropriate policy is or from whan they can
obtain this information.
2.10.5 BEHAVIOR DURING INSPECTIONS
Briefly discuss the importance of establishing and maintaining
courteous relations with plant owners and operators, of doing back-
ground research prior to making the actual field observations, and
2-32
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of completing all observation records and field logs at the time of
observation. Only by complying with the proper procedures can the
visible emissions inspector truly be an expert witness.
2.10.6 BEHAVIOR IN COURT
The film "Role of the Witness" (shown on day one; refer to
Section 2.7) elaborates on proper preparation for and behavior when
giving testimony as an expert witness. Familiarity both with
courtroom procedures and with all aspects of the law that deal with
the witness1 responsibilities is imperative, as is a calm but con-
fident demeanor.
References for Section 2.0
1. Ensor, D.S., and Pilat, M.J. "Calculation of Smoke Plume Opa-
city from Particulate Air Pollutant Properties." Journal of
the Air Pollution Control Association (APCA), Volume 21, No. 8,
August 1971, pp. 496-501
2. EPA Response to Remand in Portland Cement Association v.
Ruckelshaus, Appendix III, Part A: Opacity Standards, 1973
3. Malmberg, Kenneth B. EPA Visible Emission Inspection Proce-
dures. Division of Stationary Source Enforcement (DSSE), U.S.
Environmental Protection Agency, Washington, D.C. 20460, August
1975
4. Rose, Thomas H. Unpublished draft procedures for Region IV VE
Programs, 1978
5. Gerjuoy, Edward. "Common Legal Challenges to Agency Enforce-
ment Proceedings." Talk presented at the Region X Visible
Emissions Workshop, Seattle, Washington, October 11-13, 1978
2-33
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3.0 CERTIFICATION PROCEDURES
This section includes procedures for calibrating and operating
the smoke generator and for conducting the certification part of
the training program. For maximum efficiency, this part of the
course should be conducted by two persons—one to operate the
generator and the other to instruct the students, keep the
generator fueled, and ensure that the smoke is readable.
3.1 GENERATOR FAMILIARIZATION
Allow students to examine the smoke generator. At the same
time, give a brief explanation of its construction, including the
following points:
• White smoke production: White smoke is generated by vapor-
izing fuel oil in a heated chamber.
• Black smoke production: Black smoke is generated by burning
toluene or other organic hydrocarbons in a combustion
chamber.
• Cost of the generator: A generator that meets the specifi-
cations listed in Method 9 (Appendix A) costs about $15,000.
• Calibration: The smoke generator is routinely calibrated
according to the procedures specified by Method 9 (refer to
Section 3.3).
• Design and performance specifications: This smoke generator
meets the design and performance specifications listed in
Method 9.
• Strip charts: A strip chart record will be made of each
test run.
• Transmissometer: This device monitors the generator's smoke
output by means of a light source and a photocell.
Emphasize that for their own safety, students must stay away
from the smoke generator during training and test runs, because
once it is operating, (1) it has hot surfaces that can cause bad
burns, and (2) there are numerous electrical cables and fuel lines
3-1
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which, if accidentally disconnected, could shut down the generator
and delay the entire program for several hours.
3.2 GENERATOR OPERATION
Use the generator setup checklist (Figure 3-1) prior to
assembling the generator. Allow the students to observe the steps
involved (Figure 3-2); refer to Figure 3-3 for the locations of
the parts referred to by number below:
1. Connect the generator console fuel lines, which are stored
in the base of the control console (3). Connect them
first to the console input and then to their color-coded
connections on the generator.
2. Connect the generator console electrical lines, which are
stored in the rear storage compartment (not illustrated).
The two sets of electrical lines—a three-conductor and a
multiple-conductor—are combined in a single electrical
umbilical cord. Connect the umbilical first to the con-
sole and then to the generator.
3. Connect the power line (usually yellow) to the generator
and to a source of 15 amp 115 VAC power.
4. Turn on the propane tank (7) and adjust the pressure to 8
pounds with the regulator (9).
5. Light the toluene igniter (14) and the white smoke vapor-
izer torch (11) with a small propane torch.
6. Crank up the smoke stack by removing the stack strap and
pumping the hydraulic jack at the base of the stack.
7. Turn on the main power.
8. Connect the microphone to the "mike 1" input on the back
of the generator console.
9. Connect the speakers to the yellow jacks on the back of
the generator console.
10. Open the toluene valve for black smoke (2). To prevent
damaging the generator, do not keep the black smoke at 100
percent for more than 3 minutes.
11. Open the oil valve for white smoke (1). Do not open this
valve fully or too quickly or it will flood the vaporizer
with oil and start a fire. If this does happen, simply
shut off the valve, let the fire in the vaporizer burn
out, and then open the valve more slowly.
3-2
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GENERATOR
FIELD FILE
SPARE PARTS
Toluene (2 tanks)
Kerosene (1 tank)
Funnel
Extension cord
Ground fault interrupter
Power cord
(2) Fuel Interconnects
Electrical interconnect
Propane torch
Propane (20 Ib)
Striker
Tip for vaporizer
Vaporizer
Calibration filters
Calibration staff
Calibration stamp
Digital voltmeter
Flag and staff
Control console
Table
Chart paper
Pen for recorder
Speaker
Microphone
Fire extinguisher
Tool box
SOP manual
China marking pens
Filter calibration log
Calibration log
Roster log
Test forms
Practice forms
Grading acetates
Certification stamp
Stamp pad
Felt tip pens
Extra ball point pens
Clipboards
Large rubber bands
Box fuses 15 amp main
Box fuses 10 amp blower
Box fuses 3 amp fans
Box fuses 1 1/2 amp light
Box fuses 3/4 amp amplifier
Box fuses 1/2 amp recorder
Torch tip (white smoke)
Torch tip igniter
Tank "0" rings
Valve
(5) Bulbs TS67 (12 volt)
(1) 1 K linear pot 10 turn
Spare tire 14 1/2 X
Hydraulic jack
(2) Disconnects
Chart paper (1 roll)
Recorder pens
Figure 3-1. Generator Setup Checklist
3-3
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Connect the generator
console fuel lines
Connect the generator
console electrical lines i
Connect the
power line
Turn on propane tank
Light toluene igniter
Light white smoke
vaporizer torch
Crank up stack
Turn on main power
Zero & span
transmissometer
Open toluene valve
for black smoke
Connect speakers
& microphone
Open oil valve
for white smoke
Figure 3-?. Generator Operation Procedure
3-4
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I
en
1. White smoke control 9.
2. Black smoke control 10.
3. Control console 11.
4. Fuel line shutoffs 12.
5. Toluene tank 13.
6. Fuel filters 14.
7. Propane tank 15.
8. Fuel oil tank
Propane regulator
Torch control valve
Vaporizer torch
White smoke vaporizer
Black smoke firebox
Toluene igniter
Connectors
Toluene lines
Fuel oil lines
---- High pressure propane lines
----- Low pressure propane lines
Figure 3-3. Smoke Generator Schematic
-------
A brief explanation of the smoke generator console (Figure 3-4)
may also be in order. Refer to Appendices D (Smoke Generator
Specifications) and E (Operator's Manual) for further information.
3.3 GENERATOR CALIBRATION
Calibration of smoke generators includes checking both zero
and span transmissometer drift and the accuracy of intermediate
opacity readings. The procedures involved are described in Sec-
tions 3.3.1 and 3.3.2, respectively, and are listed together in
Section 3.3.3 (refer also to Appendix F). Calibration error should
be checked prior to practice, training, and testing sessions to
save time during these portions of the program. Zero and span
drift must be checked at the beginning of each test run.
3.3.1 ZERO AND SPAN DRIFT
Method 9 (Appendix A) specifies that:
The smoke meter is calibrated after allowing a minimum of 30
minutes warmup by alternately producing simulated opacity of 0
percent and 100 percent. When stable response at 0 percent or
100 percent is noted, the smoke meter is adjusted to produce
an output of 0 percent or 100 percent as appropriate. This
calibration shall be repeated until stable 0 percent and 100
percent opacity values may be produced by alternately
switching the power to the light source on and off while the
smoke generator is not producing smoke.
This procedure is referred to as a "zero and span" check and
must be performed at the beginning and at the completion of each
test run (Reference 1).
If the zero or span drift exceeds ±1 percent opacity at the
end of a smoke reading run, the condition must be corrected prior
to any further test runs. In order to comply with Method 9, the
zero and span drift must also be checked following repair or re-
placement of the photocell, chart recorder, output meter, and so
on, or every 6 months, whichever occurs first.
3-6
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0 20 40 60
\\\\\
o o o o c
O c o
o o
O O
EL
\3
m
SWITCHES
A. Chart marker
B. Recorder
C. Main blower
D. Main
E. Tansmissometer source
F. Speaker
G. PA system
KNOBS
1. Chart speed
2. Recorder attenuation
3. Recorder span
4. Mike 1
5. Mike 2
6. Aux
7. Bass
8. Treble
9. Master
10. Transmissometer zero
11. Black smoke
12. White smoke
Figure 3-4. Smoke Generator Console
3-7
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3.3.2 CALIBRATION ERROR
The second calibration procedure that must be periodically
performed checks the error between the actual response of the
photocell and the theoretical linear response of the smoke meter.
Neutral-density filters that are of known opacity and National Bur-
eau of Standards (NBS) traceable should be used. They must be cal-
ibrated within ±2 percent.
The smoke meter must first be calibrated for 0 and 100 percent
opacity readings (refer to Section 3.3.1). A series of three neu-
tral-density filters with nominal opacities of 20, 50, and 75 per-
cent are then inserted into the smoke meter pathlength; care must
be taken to prevent stray light from affecting the meter. Method 9
specifies that five nonconsecutive readings are required for each
filter; the maximum error allowed on any one reading is 3 percent
opacity. If such an error occurs, troubleshooting procedures,
including checks for recorder and photocell malfunction, should
commence (Reference 1).
Also check the intensity of the light bulb with a digital
voltmeter to ensure that it is operated within ±5 percent of the
nominal rated voltage, as specified by Method 9 (refer to Appendix
F, Section 1.0).
3.3.3 CALIBRATION PROCEDURES
The zero and span drift and calibration error may be checked
separately or together, as in the following step-by-step procedure.
Refer to Figure 3-4 for the various switches and controls referred
to throughout.
1. Set up the generator's electrical system and raise the
smoke stack. Keep all switches turned off.
2. Turn on the recorder switch (B), with the chart advance
set to zero.
3. Turn on the transmissometer (E) and readjust the recorder
to zero percent with the zero control (10).
3-8
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4. Turn off the transmissometer (E) and adjust the recorder
to 100 percent using the span control (3).
5. Repeat steps 3 and 4 and adjust, if necessary.
6. Turn on the transmissometer (E).
7. Set chart speed (1) to 30 inches/hour.
8. Insert the "calibration staff" (Figure 3-5) into the stack
from the back of the generator and sequentially block the
light with each filter for one minute. If the generator
has only a needle meter rather than a strip chart, it is
necessary to record these readings manually.
9. Repeat step 8 four times (i.e., take five readings, in-
serting the filters in a random order, for each filter).
10. Withdraw the calibration staff.
11. Turn off the chart advance (1).
12. Record the strip chart values on the calibration form
(Figure 3-6) and plot the average of the five results for
each filter on the calibration log. Include location,
data, and calibrator's signature. The form shown in
Figure F-l of Appendix F may also be used.
13. Stamp the strip chart with the calibration stamp (Figure
3-7a), fill in the calibration information, and mark each
calibrated point.
14. If the error for any individual reading is more than 3
percent opacity from the calibrated filter opacity, re-
check the zero and span, reinsert the appropriate filter,
and repeat steps 2 to 14. If the discrepancy persists,
check for chart recorder and photocell malfunctions.
3.4 PRACTICE SESSIONS
Before test runs are conducted, students must be made familiar
with testing procedures and attain proficiency in evaluating visible
emissions. The usual procedure is to generate standard 25, 50, and
75 percent opacity plumes and then conduct several practice runs,
giving the actual values generated immediately after the students
have recorded their readings. This helps establish standards of
comparison and reinforces accurate judgments. Figure 3-8 is a flow
chart of the practice procedure, which consists of the following
steps:
3-9
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NOTCHES
r ^
o
o
SPECTRAL
RESPONSE
FILTER
OPEN
20%
50%
75%
SOLID
Figure 3-5. Calibration Staff
3-10
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CALIBRATED BY: Tom Rose
DATE: 3 July 1976
LOCATION: Athens. Georgia
too
90
80
•5 70f
60
""
20
10
10 20 30 40 50 60 70 80 90 100
MEASURED VALUE
CHART
0
100
20
50
75
0
100
20
50
75
0
too
zz
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