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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
ArfH«.«
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

-------
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

-------
     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

-------
     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

-------
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

-------
              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

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     • 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

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     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

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     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

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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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         LOCATION
         DATE	RUN #	TIME.

         1-25            26-50
         GENERATOR #_

         OPERATOR	
         VERIFIED BY
    a.  Calibration stamp (applied to strip chart following
                calibration procedures)
       QUALIFIED
       Graded by	
       Verified by	
b.  Certification stamp (applied to qualifying certification forms)


       Figure 3-7.  Calibration and Certification Stamps
                          3-12

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Zero and span transmlssometer and set chart speed to zero
               Distribute practice  forms
Generate 25,  50, and 75 percent opacities 1n white smoke
               Generate white smoke plumes
                   Read actual values
Generate 25, 50 and  75 percent opacities  1n black smoke
               Generate black smoke plumes
                    Read actual values
                No
                            Yes
                 Begin training session
       Figure 3-8.   Practice  Procedure
                         3-13

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     1.   Perform steps 1  to 6 given in Section 3.3.3 (i.e., set up
         the generator and perform the zero and span checks).
     2.   Set the chart speed (Figure 3-4,  no.  1)  to zero.
     3.   Distribute the practice forms (Figure 2-6).
     4.   Generate a 25 percent opacity white smoke plume.
     5.   Encourage the students to walk around and view this opa-
         city value at different angles to the sun.  Run this value
         for at least 10  minutes.
     6.   Generate a 50 percent opacity white smoke plume for at
         least 5 minutes.
     7.   Generate a 75 percent opacity white smoke plume for at
         least 5 minutes.
     8.   Generate a white smoke plume around the  25 percent opacity
         level and:
         a.  say "ready"  when the smoke is steady
         b.  wait at least one second
         c.  say "mark"
         The students estimate the opacity of the plume between the
         words "ready" and "mark," but record this observation on
         the form only when the instructor announces "mark."
     9.   On a duplicate practice form, record the transmissometer
         value for the same period.
    10.   Repeat steps 8 and 9 for values around 50 and 75 percent
         opacity.
    11.   Read the actual  values recorded from the transmissometer
         and have the students check their answers.
    12.   Repeat steps 8 to 11 with smaller shifts in opacity until
         the students become proficient at judging opacity in
         increments of 5 percent.
    13.   Shut down the white smoke generator.
    14.   Start up the black smoke generator.
    15.   Repeat steps 4 to 12 for black smoke plumes.
    16.   Shut down the black smoke generator.

3.5  TRAINING SESSIONS
     Training sessions are identical to test runs except that
students may compare answers and grade their own  papers to see
where they erred (the carbon copies are not turned in).  Figure 3-9
                               3-14

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          Warm up and calibrate
             smoke generator
           Distribute test forms
                    1
Generate 25, 50, and 75 percent opacities
                    1
      Zero  and  span transmissometer
          Give  25 white  readings
           Give  25  black  readings
  Check  zero  and  span  of  transmissometer
            Grade  test  records
Figure 3-9.  Training and Testing Procedure
                   3-15

-------
illustrates the following steps in the training session  (refer  also
to Appendix G):

     1.  Perform steps 1 and 2 given in Section 3.4  (i.e.,  set  up
         the generator, perform the zero and span checks).
     2.  Distribute the certification forms and have the candidates
         fill out the top (Figure 2-7).
     3.  Generate standard 25, 50, and 75 percent opacity white
         smoke plumes.
     4.  Turn off all valves.  Wait until no emissions are  visible
         and the transmissometer trace is flat.
     5.  Repeat steps 1 and 2 given in Section 3.4  (i.e., set up
         generator and perform zero and span checks).
     6.  Announce the start of the test and give the run number and
         time.
     7.  Open the oil valve and allow the smoke to  become steady
         within 1.5 percent opacity of a 5 percent  scale line
         (Figure 3-10a).
     8.  When the smoke has stabilized, say "number one" and press
         the record button on the generator console.
     9.  After one to two seconds, say "mark" jf this reading stay-
         ed within 1.5 percent opacity limits.  Then release the
         record button and number the reading.  If  unacceptable,
         say "scratch" and repeat the reading (Figure 3-10b).
         (Students do not mark their papers unless  the word "mark"
         is announced.)  Mark the unacceptable reading "void" on
         the chart and initial it (Figure 3-10c).
     10.  Repeat steps 7 to 9 for the remaining 24 white  smoke read-
         ings.  The opacity of these readings must  be selected  in a
         random order.
     11.  Shut  off the white smoke valve.
     12.  Check the zero and span transmissometer drift.  If the
         values are within 1 percent of 0 and 100,  go on to step
         13.   Otherwise, wait 15 seconds and repeat the  check.
     13.  Open  the black smoke valve and proceed with steps  7 to 10
         for readings 26 to 50.  The opacities must  again be
         selected at random.

     14.  Give  the correct readings.  Candidates should check their
         own papers so they can see where they erred.
                               3-16

-------
   a.  Acceptable readings for 40 percent opacity, I.e.,
       trace remained within 1.5 percent opacity of the
       5 percent scale value.
                                         5 J
   b.  Unacceptable readings for 40 percent opacity.


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   c.  Examples of how to mark valid and invalid readings.
Figure 3-10.  Acceptable and Unacceptable Smoke Readings
                          3-17

-------
3.6  TESTING PROCEDURES
     A valid test run consists of 25 white and 25 black smoke  plume
readings.  The candidate must demonstrate the ability to assign
opacity readings in 5 percent increments, meeting the following
criteria:
     • No one reading must be in error by more than 15 percent
       opacity
     • Average error must not exceed 7.5 percent for either white
       or black smoke
     Plumes within each set of 25 readings must be presented in
random order.  If the candidate fails to qualify, the complete run
of 50 readings must be repeated.  Certification is valid for 6
months, after which the qualification procedure must be repeated,
although the full lecture and training course need not be.
     Students must stay in the testing area with the sun at their
backs and at least 20 feet from the generator.  Smoke school
personnel will come into this area to collect test papers.  Remind
students that they will have to shift position to maintain optimum
viewing  conditions as the sun moves across the sky (i.e., as the
earth turns).
     Testing procedures follow the order shown in Figure 3-9 and
described in Section 3.5, using the certification form shown in
Figure 2-7.  These NCR (no carbon required) forms automatically
produce  a carbon copy as the observations are recorded.  The
crucial  difference between the training session described in
Section  3.5  and the testing procedure is that in the latter the
originals must be collected prior to announcing the correct
readings; the carbon copies are then checked by the students
themselves.
     Test runs must comply with the specifications given  in Method
9.  The  following points are particularly important:
                               3-18

-------
     • Allow a 30-minute warmup period for the smoke generator
     • Instruct students to follow field operation procedures in
       selecting their observation points (refer to Section
       c • D j
     • Instruct students to record their observations with ball-
       point pen (not pencil)
     • Instruct students not to compare observations among them-
       selves at any time during the test
     • Select the opacity of the emissions in a random order
     • Record each of the 50 readings on the strip chart recorder
       (for invalid readings, refer to Section 3.5 and Figure
       3.10)
     • Make three calibration error readings (one for each of the
       three filters) inbetween two of the certification runs (re-
       fer to Section 3.3.3)
     It should not be necessary to review the contents of the lec-
ture on testing procedures  (Section 2.8), since its purpose was to
prepare students so that they need not ask time-consuming questions
in the field.
     The grading procedures to be used by smoke school personnel
are presented in Section 4.0, which also discusses certification
letters and confidence limits procedures for those students who
qualify as visible emissions inspectors.  Passing papers should be
stamped "Qualified" and the grader should sign his name  (refer to
Figure 3-7b).
     Repeat the testing procedure as often as time permits so that
students have as many chances as possible to qualify during the,
training program.  A minimum of 10 test runs should be given.

3.7  GENERATOR SHUTDOWN
     Once the training session is over, the generator must be shut
down.  Figure 3-11 is a flow chart of the following major steps
involved in this procedure:
     1.  Repeat the calibration procedures (Section 3.3.3, steps
         3-14).
                               3-19

-------
            Turn  off  propane
       Turn  off all fuel valves
     Disconnect and  store fuel  Unes
       Vent  fuel tank pressure
          Disconnect PA system
      Store microphone and speaker
            Turn off  blower
          Turn off main power
         Disconnect and store
         electrical umbilical
             Fold  the  stack
Figure 3-11.   Generator  Shutdown  Procedure
                   3-20

-------
 2.   Turn off the propane tank valve at the tank (Figure 3-3,
     no.  9).
 3.   Turn off the kerosene and toluene valves at the back of
     the  console (Figure 3-3, nos. 1 and 2).
 4.   Disconnect the console inlet fuel lines from the console
     (the valves stay on the lines), and store them in the
     front storage compartment.
 5.   Disconnect the pressurization lines from the fuel tanks.
 6.   Vent the pressure from both fuel tanks by depressing the
     button on the pressure inlet.
 7.   Store the console inlet fuel lines in the front compart-
     ment, and close the compartment.
 8.   Disconnect the generator inlet fuel lines.
 9.   Attach the loose ends to the inlet console fittings, mak-
     ing a closed loop.
10.   Coil the attached lines in the base of the console.
11.   Turn off the propane torch in the vaporizer (Figure 3-3,
     no.  11)
12.   Turn off the toluene igniter in the burner (Figure 3-3,
     no.  14).
13.   Turn off the PA system (Figure 3-4, G)
14.   Unplug the speaker jacks (yellow).
15.   Wind the speaker wire around the base of the speaker and
     store it in the rear storage box.
16.   Disconnect the microphone from the cable and place  it in
     the accessory box  (blue).
17.   Disconnect the microphone cable from the console, and coil
     and store it in the rear storage box.
18.   Unscrew the microphone stand from the console and store  it
     in the rear storage box.
19.   Turn off the recorder (Figure 3-4, B).
20.   Turn off the transmissometer (Figure 3-4, E).
21.   Turn off the main blower (Figure 3-4, E).
22.   Turn off the main power (Figure 3-4, D).
23.   Unplug the generator.
24.   Disconnect the amphenol connector  (power) from  the  console.
25.   Disconnect the amphenol connector  at both ends  of the
     electrical umbilical.
                           3-21

-------
    26.   Store the electrical  cables in the rear storage box.
    27.   Turn the hydraulic valve so that it is horizontal.
    28.   Release the stack hold-down clamp.
    29.   Tip the stack.
    30.   Close the stack hold-down clamp and lock it with a bolt.
    31.   Put the back on the console and store it.
    32.   Store the fire extinguisher, torch, and torch igniter.
    33.   Break down the calibration staff and store it in the rear
         storage box.
    34.   Close the rear storage box.
    35.   Lock the front and rear storage boxes.

3.8  MAINTENANCE PROCEDURES
     At the end of each smoke school and prior to the beginning of
the next, the following routine maintenance procedures should be
performed:
     1.   All electrical cables should be checked to be sure that
         there are no frayed parts, that all contact points are
         clean, that the connectors are not bent, and that the
         cables have good integrity.
     2.   All fuel lines should be checked to ensure that they are
         unkinked, that there are no weathered spots, splits, or
         leaks, and that there is nothing wrong with the
         connectors.  It is very easy to lose the ferrules inside
         of connectors, so make sure that these are present.
     3.   The integrity of the fittings to the torch box with the
         white smoke vaporizer should be checked with snoop.
     4.   The propane gas cylinder that supplies the propane for the
         white smoke vaporizer and the pressure for the fuel system
         should be refilled.
     5.   The "0" rings on the fuel tanks should be checked to make
         sure that they have not become deformed due to the
         absorption of organics.
     6.   The PA system should be assembled  and checked out to
         ensure that all wires are still good, particularly the
         mike wires.
                               3-22

-------
     7.   There Is a small drain hole in the bottom of the stack.
         This should be checked to make sure that it is open and
         that the stack has not accumulated water prior to the
         school.

     8.   Calibration of the generator should be performed to ensure
         that the light bulb has not aged and that the calibration
         curve is still good.

     9.   Check the recorder pin assembly and ensure that the re-
         corder pin is operating correctly.  This can be performed
         by turning on the transmissometer and turning the signal
         attenuator to the right and left to make sure that the
         recorder pin will travel up and down the scale.  An alter-
         nate procedure would be to turn the transmissometer on and
         off to ensure that the pin will drive back and forth
         smoothly from one side to the other.  Time of travel from
         0 to 100 percent should be approximately 4.2 seconds but
         less than 5 seconds.
    10.  Safety inspection of the trailer should be performed
         whenever the trailer is to be moved:

         • Make sure that the trailer running lights and electric
           brake package are all functional.

         • Check that there are no loose parts in the stack hinge
           area; make sure that all of that is secure and solid.

    11.  After the fire box has cooled off, it should be inspected
         by  inserting an inspection mirror in the side and making
         sure that the torch and the deflector plate are good and
         that there has been no damage to the fire box in transit.

    12.  A drop of oil should be placed on each of the bearing
         surfaces and in the oil drop slot on either side of the
         electric motor at the beginning of each smoke school.
3.9  RECORDKEEPING

     A bound log book should  be  kept to  record  all  events  that  bear

on the performance of the smoke  generator.   Such events  include

records of all  repair and maintenance  work,  spectral  response

checks, calibration checks, response time checks, the  number of

observers attempting each test,  the number of observers  passing

each test, their names, addresses, and so on.   Appendix  F  includes

a form (Figure  F-l) for recording this information.
                               3-23

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3.10  RECERTIFICATION PROCEDURES

     Recertification procedures are identical to testing  proce-
dures.  Inspectors must be recertified every 6 months.  They  are

not required to repeat the entire lecture portion of the  course,

although a one-hour presentation on legal aspects and other speci-

fic topics of interest to visible emissions evaluators should  be

offered (refer to Section 2.10).
References for Section 3.0
1.  Wohlschlegel, P. and Wagoner, D.E. "Guidelines for Development
    of a Quality Assurance Program:  Volume IX - Visual Determina-
    tion of Opacity Emissions From Stationary Sources." EPA-650/4-
    74-005-i.  Research Triangle Institute, Research Triangle  Park,
    N.C.  27709.  Prepared for U.S. Environmental Protection Agen-
    cy, Office of Research and Development, Washington, D.C.
    20460, under Contract No. 68-02-1234, November 1975

2.  Rose, Thomas H.  Unpublished draft procedures for Region IV  VE
    Programs, 1978

3.  Lee, William S.  Personal communication
                               3-24

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                        4.0  DATA  REDUCTION


4.1  GRADING THE CERTIFICATION FORM

     Figure 2-7 is a  copy  of the certification  form.   If  another
form is used, it should include the  same  information  and  be design-
ed so that the average deviation for each run of  25 readings  can  be
entered on the form.  Both black and white smoke  deviations must  be
less that 7.5 percent and  no reading may  err by more  than 15  per-
cent to meet the Method 9  criteria.

     To grade the certification form,  follow the  procedures illus-
trated in Figure 4-1  and enumerated  in the following  steps:

     1.  At the end  of the test run, collect the  original  (top
         white) copy  of each student's certification  form (Figure
         2-7).  Place these  in the field  file in  the  first section.
     2.  Take a blank certification  form  and remove the carbon
         copy. Place  the test  form on a clipboard.
     3.  Write "master"  in the space for  the observer's name.   Fill
         in the run  number, date,  location, and time  the  test was
         begun.
     4.  Record the  actual values  on the  form as  they are read
         from the strip chart.  Have the  students grade their car-
         bon copies  as this  is done.
     5.  Place a grading acetate over the master, being careful  to
         align it correctly.
     6.  With a "china marking pencil," make a  diagonal slash from
         upper left  to lower right (\) over each  marked number  on
         the grading  master.   File the acetate  with the originals.
     7.  Turn the grading  master over and record  the  names of the
         students who think they have qualified.  These are the
         only papers  that  will be  graded.
     8.  Remove the  papers to  be graded from the  file. Select  one
         and align the acetate over  it.
     9.  Count from  the mark on the  acetate to  the mark on the
         student's paper.  Counting  to the left,  record a negative
         value (-); counting to the  right, record a  positive  one
         (+).  Each  5 percent  is counted  as one.  For example,

                 (3)     (2)      (1)
         30      35      40      45       50       Error =  -3

               Student                  Actual


                                4-1

-------
         Collect papers
         Prepare master
         Prepare acetate
         Grade answers
      Calculate deviations
     and record in log book
        Calculate  biases   ~~|
           and  record	
       Send certification
            letters
Figure 4-1.   Grading Procedure
              4-2

-------
    10.   Add all of the negative errors for the 25 white smoke
         readings and record "-10," or whatever the sum may be, on
         the line marked "White Deviation."

    11.   Add all of the positive errors and record on the same line
         used in step 10, e.g., "-10 +6."

    12.   Ignore the signs and add the two numbers, placing the ab-
         solute value in brackets on the same line used in steps 10
         and 11, e.g., "-10 +6 [16]."

    13.   If no single error has an absolute value of more than 3
         and the number in brackets is 37 or less, repeat steps 9
         to 12 for the 25 black smoke readings.

    14.   If no single error among the black smoke readings has an
         absolute value of more than 3 and the number in brackets
         is 37 or less, stamp the paper "Qualified" (refer to Fig-
         ure 3-7b).

    15.   Sign the line marked "Graded by," and have the supervisor
         verify the grade.

    16.   Enter the student's name, address, and qualifying run num-
         ber in the VE program roster, which is a bound log book
         (Figure 4-2).

    17.   Compute the deviation on the white readings by multiplying
         the number in brackets by 0.2 or by reference to Figure
         4-3, and record this value on the test paper and under
         "Deviation White"  in the roster.

    18.   Repeat step 17 for the black smoke readings.

    19.   Compute the bias on the white readings by combining the
         positive and negative percentages, first multiplying each
         positive and negative error by 5 percent (refer to step
         9).  Record this value under the "Bias White" column in
         the roster.

    20.   Repeat step 19 for the black smoke readings.

    21.   Inform the students who certified.

    22.   Follow up by sending a certification letter to each stu-
         dent who qualified.
4.2  CERTIFICATION LETTERS

     Wall certificates are  provided to all students who attend the

course.  Each passing test must be regraded by the instructor prior

to issuance of a letter stating that the observer  is a certified

visible emissions evaluator.  The letter should be mailed within

one month of the date on which the observer qualified.
                                4-3

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Grader: Sig Init.
SiE Init .
Sig Init.
Sig Init.

Instructor
Signature
Date

Figure 4-2.   Sample VE  Program  Roster
                 4-4

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Increment of
Error3
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Percent
Deviation
0.20
0.40
0.60
0.80
1.00
1.20
1.40
1.60
1.80
2.00
2.20
2.40
2.60
2.80
3.00
3.20
3.40
3.60
3.80
4.00
4.20
4.40
4.60
4.80
5.00
Increment of
Error
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
Percent
Deviation
5.20
5.40
5.60
5.80
6.00
6.20
6.40
6.60
6.80
7.00
7.20
7.40
7.60
7.80
8.00
8.20
8.40
8.60
8.80
9.00
9.20
9.40
9.60
9.80
10.00
a Each error of 5 percent opacity, either positive or negative,
  is counted as one increment.


               Figure 4-3.   Average Deviation Chart
                                4-5

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4.3  MEAN DEVIATION AND CONFIDENCE LIMITS
     If confidence limits are required for use in court or to
otherwise demonstrate the accuracy of a given visible emissions
evaluation, they should be calculated as follows.
     The objective of this calculation is to find the confidence
limits about the observer's mean deviation.  This mean deviation or
bias is the amount, on the average, the observer has differed from
the "true" opacity of the emission he has observed.  The confidence
limits tell us that in future tests, each consisting of 25 observa-
tions taken under the same conditions, the observer's mean devia-
tion is expected to be, 19 times out of 20, within the confidence
limits calculated from the data of the original test.
     In order to calculate the mean deviation we must find the dif-
ference between the "true value" and the evaluator's observed and
recorded opacity.  Finding the opacity value the observer recorded
is easy.   Finding the true value of the opacity is more demanding
because we must consider the introduction and the propagation of
errors.
     The starting place in the search for the "true value" is the
value recorded on the strip chart or other recording device of the
smoke generator.  In fact we can use this value as the "true value"
if we are  sure that any and all errors in this value are small;
small compared to the mean differences (deviation) between the
observer's recorded values and the "true value."
     Possible errors that could influence the value as recorded  on
the strip  chart are drift, calibration and random error.  Random
error might come from, for example, a large motor nearby turning  on
and lowering the voltage of the electrical supply, or the pen of
the chart  recorder mechanically sticking.  The operator of the
smoke generator must be alert to many possible interferences and
take steps to minimize these effects or to eliminate the  interfer-
ence if possible and keep this type of error small.

                                4-6

-------
     Drift of zero and span are checked both at the beginning  and
at the end of every test run.  If either  is found to exceed ±  1
percent opacity at the end of a smoke  run, the condition must  be
corrected.  The operator of the smoke  generator must keep this kind
of error small by replacement of the electrical circuits of the
unit if necessary.
     Calibration error is checked before  and after every run
series.  This is done by inserting a series of low, median, and
high neutral density filters that are  of  known opacity  and National
Bureau of Standards  (NBS) traceable.   The maximum error allowed as
measured between the pen of the chart  recorded and the  "known"
opacity of the filter should not exceed 3 percent opacity.  If the
limit is exceeded, then the operator of the smoke generator should
correct the problem before proceeding  with the work of  testing
visible emission evaluators.  He should check each filter before
use for any smudges on the filter or visible deterioration of  the
filter.  Here again the operator must  keep this kind of error
smal1.
     The mean deviation and confidence limits should be calcu-
lated from the data taken for each filter.  This  should be done as
fol1ows:
     1.  Determine the difference between the measured  value of the
         filter and the certified value for the filter:
         dj = Certified value - Measured  valuej
         d2 = Certified value - Measured  value2
         dN = Certified  value -  Measured valueN
         where  N  is  5  or greater.
                                 4-7

-------
     2.   Calculate  the mean  difference D and the standard deviation
         SD  as  follows:

              d:  +  d2  + .  .  .  + (dN)
          D  =	
                        N
              (dj  -  D)2  + (d2  - D)2  + .  .  .  + dn -  D)2
                               (N  - 1)
     3.   Calculate the confidence limits as follows

                                      t (SD)
          Low confidence limit =  D -
                                      t (SD)
          High confidence limit =  D +
         where "t"  is the Student t value for N data points or
         (N-l) degrees of freedom taken from standard statistical
         tables.

         The value  "zero" should be between the low confidence
         limit and  the high confidence limit.  In other words, the
         low confidence limit should be negative and the high
         confidence limit should be positive.  If this is not true,
         then the filter should be examined for deterioration or
         smudges  and the test repeated.

     4.   The calculations outlined in Steps 1 through 3 should be
         repeated for each filter used in the calibration check of
         the smoke  generator.

     The mean and confidence limits for each student can be calcu-
lated by a similar  procedure as follows:

     1.   Determine  the differences between the 25 white smoke
         determinations as follows:
                                4-8

-------
             Observer value^ - Chart value^

             Observer value2 - Chart value2
        d25 = Observer value25 - Chart value25


        The Chart  value  is taken to the nearest percent opacity.
    2.  Calculate  the mean difference"^ and the standard
        deviation  as follows:
                 i  +  do  +  .  . +
                                «c
                        25
                 (drDw)2 +

           w - N
(d2-Dw)2  +  .  .  . +  (d?,-Dw)2
       3.   Calculate the confidence limits  as  follows

                                          t(SDw)
         (Low confidence limit)w = Dw -
                                          t(SDw)
         (High confidence limit)w = Dw + .
     4.  Repeat Steps 1, 2, and 3 for the 25 black smoke determina-
         tions and calculate"ITB, SDB, and the confidence limits.

     The preceding calculation should be made for every student

observer's final passing test paper and the information should be

made available to the student.
                                4-9

-------
     There is another statistic that should be calculated for each
run (25 white and 25 black readings) of the smoke generator.  This
value is an indication not of the performance of the student
observer, but rather is an indication of how well the operator ran
the smoke generator.  This calculation is done in a similar manner
as the preceding calculation except Step 1, which is modified as
fol 1ows:
     1.  Determine the differences between 25 white smoke determi-
         nations as follows:

         di = Announced valuej - Chart valuej
         d£ = Announced value2 " Chart value2
         d?5 = Announced value,,,- - Chart

     The Announced Value is the value announced to the students for
the  purpose of grading their test papers and is in units that are
multiples of 5; for example, 10, 25, 65, etc.
     The remainder of the steps 2 through 4 are done as specified
in the  preceding calculation.  These values are retained in the
records of the "smoke school."
 References for Section 4.0

 1.   Spiegel,  Murray  R.  Schaum's Outline  of Theory  and  Problems  of
     Probability  of Statistics.  New  York:  McGraw-Hill  Book
     Company,  Schaum's Outline SEries,  1975, pp.  109-111,  194-195.
 2.   Rose, Thomas  H.  Personal communication.
 3.   Smith, Miles.  Personal  communication.
                                4-10

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                    APPENDIX A

METHOD 9 — VISUAL DETERMINATION OF THE OPACITY OF
            EMISSIONS FROM STATIONARY SOURCES

-------
                                APPENDIX A
              — VISUAL DETERMINATION Or THE 0?ACTTY OF EMISSIONS FROV,
                 STATIONARY SOURCES
      The current Method 9, published in the Federal Register, Volume
39, Ko. 219 on November 12, 1974 is reproduced below:
     "Many stationary sources discharge visible emissions Into the atmos-
phere; these missions are usually In the chape of a plume.  This method
involves the determination of plume opacity by qualified observers.   The
method includes procedures for the training and certification of obser-
vers, and procedures to be used in the field for determination of plume
opacity.  The appearance of a plume as viewed by an -observer depends upon
a number of variables, some of which nay be controllable and seme of
which may not be controllable in the field.  Variables which car. be
controlled to an extent to which they no longer exert a significant
influence upon plume appearance include:  Angle of the observer with re-
spect to the plume; angle of the observer with respect to the sun; point
of observation of attached and detached steam plume; and angle of the
observer with respect to a plume emitted from a rectangular stack with
a large length to width ratio.  The method includes specific criteria
applicable to these variables.
      Other variables which may not be controllable in the field are
luminescence and color contrast between the plume and the background
against which the plume is viewed.  These variables exert an influence
upon  the appearance of a plume as viewed by an observer, and can affect
the ability of the observer to accurately assign opacity values  to  the
observed plume.  Studies of the theory of plume opacity and field studies
have  demonstrated that a plume Is most visible and  presents the  greatest
apparent opacity when viewed against  a contrasting  background.   It
follows from this, and is  confirmed by field  trials,  that  the  opacity
of a  plume, viewed under conditions where a contrasting background  is
present can be assigned with the greatest degree of  accuracy.   However,  the
potential for a positive error is also the  greatest  when a plume is viewed
under such contrasting conditions.  Under  conditions presenting a  less
contrasting background, the apparent  opacity  of a plume  is less and
approaches sero as .the color and luminescence contrast  decrease toward
sero.  As a result, significant negative bias and negative errors  can be
«.»/*»  wv.»n • olumr is viewed under  less  contrasting  conditions.   A negative
                                  A-l

-------
bi>s decreases rather than increases Che possibility that  a  plant  opera-
tor will be cited for a violation of opacity standards due to observer
error.
      Studies have been undertaken to determine the magnitude--of positive
errors which can be made by qualified observers while reading plumes under
contrasting conditions and using the procedures set forth  in this method.
The results of these studies (field trials) which involve  a total of 769
Bets of 25 readings each are as follows:
      1)  For black plumes (133 sets at a smoke generator),100
          percent of the sets were read with a positive error1
          of less than 7.5 percent opacity; 99 percent were
          read with a positive error of less than 5 percent
          opacity.
      2)  For white plumes (170 sets at a smoke generator, 168
          sets at a coal-fired power plant, 298 sets at a  sul-
          furic acid plant), 99 percent of the sets were read
          with a positive error of less than 5 percent opacity.
      The positive observational error associated with an  average of
twenty-five readings is therefore established.  The accuracy of the method
•ust be taken into account when determining possible violations of appli-
cable opacity standards.

1.  PRINCIPLE AKD APPLICABILITY
1.1  PRINCIPLE
      The opacity of emissions from stationary sources is determined
visually by a qualified observer.

1.2  APPLICABILITY
      This method is applicable  for the determination of  the opacity  of
emissions from stationary sources pursuant  to § 60.1}  (b) and  for quali-
fying observers  for visually determining opacity of  emissions.

2.  PROCEDURES
      The observer qualified in  accordance  with paragraph 3  of this method
•hall use the following procedures  for visually determining  the opacity  of
emissions.
  For  a  set,  positive  error • average opacity determined by  observers'  25
 observations -  average opacity determined from transmissometcr's 25 recordings.
                                  A-2

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2.1  POSITION
      The qualified observer shall stand at s distance sufficient to pro-
vide a clear view of the emissions with the sun oriented In the 140°
sector to his back.  Consistent with maintaining the above requirement,
the observer shall, ss «uch as possible, Bake his observations fron a
position such that his line of vision is approxiaately perpendicular to
the plume direction, and when observing opacity of emissions froc rect-
angular outlets  (e.g. roof aonltors, open baghouses, noncircular stacks),
approximately perpendicular to the longer axis of the outlet.  The obser-
ver's line of sight should not Include store than one plume at a time when
Multiple stacks  sre involved, and in any case the observer should make his
observations with his line of sight perpendicular to the longer axis of
such a set of aultiple stacks (e.g. stub stacks on baghouses).

2.2  FIELD RECORDS
      The observer shall record  the name of the plant, emission location,
type facility, observer's name and affiliation, and the date on a field
data sheet  (Figure 9-1).  The tine, estimated distance to the emission
location, approximate wind direction, estimated wind speed, description of
the sky condition  (presence and  color of clouds), snd plume background are
recorded on a  field data sheet at  the tiae opacity readings are  initiated
and completed.

2.3  OBSERVATION'S
      Opacity  observations  shall be Bade at  the  point of  greatest opacity
in that portion  of  the  plume  where condensed  water vapor  is not  present.
The observer  shall  not  look continuously at  the  plume,  but  instead  shall
observe  the  plume momentarily at 15-second  intervals.

2.3.1  ATTACHED STEAM PtUMF-S
      When  condensed  water  vapor is present  within  the  plume  as  it
emerges  from the mission  outlet,  opacity  observations  shall  be  made be-
yond  the point In the plume at which  condensed water  vapor  is no longer
visible.  The  observer  shall  record  the approximate  distance  from the
emission outlet  to  the  point  In  the plume  at  which  the  observations are  sade.
                                    A-3

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-------
2.3.2  DETACHED -STEAK PLUME
      When water vapor in the plume condenses and becomes visible at a
distinct distance from the emission outlet, the opacity of emissions should
be evaluated at the emission outlet prior to the condensation of water
vapor end the formation of the steam plume.

2.4  RECORDIKG OBSERVATIONS
      Opacity observations shall be recorded to the nearest 5 percent at
15-second intervals on an observational record sheet.  (See Figure 9-2 for
an example).  A minimum of 24 observations shall be recorded.  Each
•omentary observation recorded shall be deemed to represent the average
opacity of emissions for a 15-second period.

2.5  DATA REDUCTION
      Opacity shall be determined  as an average of 24 consecutive observations
recorded at  15-aecond Intervale.   Divide  the observations recorded on the
record sheet into  aets of 24  consecutive  observations.  A set is composed
of any 24 consecutive observations.  Sets need not be consecutive in time
snd  in no case  shall two sets overlap.  For each aet of 24 observations,
calculate the average by sunning  the opacity of the  24 observations and
dividing this sum  by 24.  If  an applicable  standard  specifies an averaging
time requiring  more  than 24 observations, calculate  the average  for all
observations made  during the  specified  time period.  Record  the  average
opacity on a record  sheet.   (See  Figure 9-1 for sn example).

3.   QUALIFICATIONS AND TESTIKC
3.1  CERTiriCATIOK REQUIREHEKTS
      To receive certification  as a qualified  observer,  «  candidate must
be  tested snd  demonstrate  the ability  to  assign opacity  readings in 5
percent increments to  25 different black  plumes and  25 different vhitc
plumes, with an error  not  to  exceed 15  percent  opacity on  any  one reading
snd  sn sversge  error not  to exceed 7.5  percent  opacity in  each category.
Candidates  shall be  tested  according to the procedures described in para-
graph  3.2.   Smoke  generators  used pursuant to  paragraph  3.2  ahall be
equipped with  a smoke  meter which meets the requirements  of  paragraph  3.3.
                                    A-5

-------
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-------
      The certification shall be valid for • period of 6 months,  at which
tine the qualification procedure Bust b.e repeated by any observer in order
to retain certification.

3.2  CERTIFICATIOX PROCEDURE
      The certification test consists of shoving the candidate a complete
run of 50 plumes - 25 black plumes and 25 white plumes - generated by a
smoke generator.  Plumes within each set of 25 black and 25 white runs
shall be presented in random order.  The candidate assigns an opacity
value to each plume and records his observation on a suitable form.  At the
completion of each run of 50 readings, the score of the candidate is de-
tereined.  If a candidate fails to qualify, the complete run of 5C readings
•ust be repeated in any retest.  The smoke test nay be adr.inistered as part
cf a smoke school or training program, and may be preceded by training  or
familiarization runs of the smoke generator during which candidates are
shovn black and white plumes of known opacity.

3.3  SMOKE GENERATOR SPECIFICATIONS
      Any smoke generator used for the purpose of paragraph 3.2 shell be
equipped with a smoke meter installed to measure opacity across the dia-
meter of the smoke generator stack.  The smoke meter output shall display
In-stack opacity based  upon a pathlength equal to the stack exit diameter,
on  a full 0 to  100 percent chart recorder acale.  The smoke meter optical
design  and performance  shall meet  the specifications shown in Table 9-1.
The smoke meter shall be  calibrated  as prescribed in paragraph 3.3.1 prior
to  the  conduct  of each  smoke reading test.  At the  completion of each  test,
the zero and span drift  shall  be checked and  if  the drift exceeds 4 1  per-
cent opacity,  the  condition  shall  be corrected prior  to conducting  any  sub-
sequent test runs.   The smoke meter  shall be  demonstrated at  the  time  of
Installation,  to meet  the specifications  listed  in  Table 9-1.  This
demonstration  shall  be  repeated  following any subsequent repair  or replace-
ment of the photocell  or  associated  electronic circuitry including the
chart recorder  or  output  meter,  or every  6  months,  whichever  occurs first.
                                   A-7

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                   TABLE 9-1:  SMOKE METER DESIGN AND
                       PERFORMANCE SPECIFICATIONS
Parameter                                       Specification
a.  Light source	                Incandescent lamp operates at noainal
                                     rated voltage.
b.  Spectral response of photocell   Photopic (daylight spectral response
                                     of the human eye - reference 4.3).
c.  Angle of view—                 15° maximum total angle.
d.  Angle of projection              15  'maximum total angle.
e.  Calibration error-               + 3X opacity, aaximuc
f.  Zero and span drift              + IX opacity, 30 minutes.
g.  Response tine	                   5 seconds.
3.3.1  CALIBRATION
      The smoke meter is calibrated after allowing a minimum of 30 minutes
varmup by alternately producing simulated opacity of 0 percent and 100 per-
cent.  When stable response at 0 percent or 100 percent is noted, the
•moke meter is adjusted to produce an output of 0 percent or 100 percent as
appropriate.  This calibration shall be repeated until (table 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.

3.3.2  SMOKE METER EVALUATION
      The smoke meter design and performance are to. be evaluated as
follows:

3.3.2.1  LIGHT SOURCE
      Verify from manufacturer's data and from voltage measurements made
st  the lamp, as installed, that the lamp is operated within +  5 percent of
the nominal rated voltage.
                                  A-8

-------
3.3.2.2  SPECTRAL RESPONSE OF PHOTOCELL
      Verify from manufacturer's data that the photocell has a photopic
response; !.«., the spectral sensitivity of the cell shall closely
approximate the standard spectral-lutr.inosity curve for photopic vision
which is referenced in  (b) of Table 9-1.

3.3.2.3  AKCLE OF VIEW
      Check construction geometry to ensure that the total angle of view
of the smoke plume, as  seen by the photocell, does not exceed 15°.  The
total angle of view nay be calculated from:  0-2 tan"1 d/2L, where 6' total
angle of view; d«the sun of the photocell diameter + the diar.eter of the
Uniting aperture; and  L-the distance froir, the photocell to the lir.iting
aperture.  The limiting aperture is the point in the path between the
photocell and the smoke plume where the angle of view is most restricted.
In smoke generator smoke meters this is normally an orifice plate.

3.3.2.4  ANCLE OF PROJECTION
      Check construction geometry to ensure that the total angle of pro-
jection of the laep on  the smoke plume does not exceed 15 .  The total
angle of projection may be calculated from: 6*2 tan   d/2L, where  6' total
angle of projection; d-the sun of the length of the lamp filament + the
diameter of the limiting aperture; and L-the distance froir, the lamp to the
limiting aperture.

3.3.2.5  CALIBRATION ERROR
      Using neutral-density  filters of known opacity, check  the  error
between  the actual response  and  the theoretical linear response  of  the
•moke meter.  This check is  accomplished  by  first  calibrating  the  sr.okc
meter according to 3.3.1 and  then inserting  a  series of  three  neutral-
density  filters of nominal opacity of 20.  SO,  and  75 percent in  the  smoke
weter pathlength.  Filters calibrated within + 2 percent ahall be  used.
Cate should be taken when inserting the filters to prevent  stray light
from affecting the meter.  Make a total of five nonsonsecutive readings
for each filter.  The maximum error on any one reading ahall be  3  percent
opacity.
                                  A-9

-------
3.3.2.6  ZERO AND SPAK DRIFT
      Determine the zero and span drift by calibrating and operating the
moke generator in a normal manner over a 1-hour period.  The drift is
measured by checking the zero and span at the end of this period.

3.3.2.7  RESPONSE TIME
      Determine the response time by producing the series of five simulated
0 percent and 100 percent opacity values.and observing the time required to
reach stable response.  Opacity values of 0 percent and 100 percent may be
simulated by alternately switching the power to the light source off and on
while the smoke generator is not operating.

4.  REFERENCES
4.1  Air Pollution  Control District Rules and Regulations, Los Angeles
County Air Pollution Control District, Regulation IV, Prohibitions, Rule
50.

4.2  Weisburd, Melvin I., Field Operations and Enforcement Manual for Air,
U.S. Environmental  Protection Agency, Research Triangle Park, K.C., APTD-
1100, August 1972.  pp. 4.1-4.36.

4.3  Condon, E.U.,  and Odishaw, H., Handbook of Physics, McGraw-Hill Co.,
N.Y., N.Y. 1958, Table 3.1, p. 6-52."
                                   A-10

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    APPENDIX B





CAMERA INSTRUCTIONS

-------
                            APPENDIX B

                        CAMERA INSTRUCTIONS
                             (Minolta)


     Accurate photographs can be taken with a single lens camera or

one with automatic photocells by performing the following steps:

     1.  Check the ASA of the film (listed on the box) to ensure
         that it matches the ASA reading on the camera.  (On a Min-
         olta, the ASA number is located under the film speed
         dial.)

     2.  Set the film speed for  .01 second.

     3.  Point the camera at the subject, placing the subject in
         the center of the frame, and turn the focus ring until the
         picture appears sharp.

     4.  Note the "lollipop-shaped" line on the right side of the
         viewer and the needle that fluctuates when the camera is
         moved.  Turn the "F-stop" dial until the needle is square-
         ly in the center of the circle at the top of the "lollipop
         stick."  (This sets the Irish diaphragm or F-stop.)

     5.  Hold the camera steady and press the shutter.

If in the correct position to view opacity, this method ensures

clear, accurate photographs of the facility.

     To take telephoto pictures, perform the following  steps:

     • Locate the red button on the upper left side of  the camera
       face next to the lens, and slide it down.

     • Rotate the lens counterclockwise with the camera facing
       toward you; then remove the lens.

     • To insert the telephoto lens,  turn it clockwise  and then
       slide the red button up.

The remainder of the procedure consists of steps 1 to 5 given  above.
                                 B-l

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      APPENDIX C





THE PSYCHROMETRIC CHART

-------
                            APPENDIX C

                      THE PSYCHRQMETRIC CHART


     The following discussion and example are from Reference 1, pp.
5.3 to 5.7.

     A psychrometric chart is a graphical solution of various temp-

erature and humidity states of air and water vapor mixtures.  Each

point on the chart represents one unique combination of the follow-

ing atmospheric properties:

     1.  Dry bulb temperature, which is the actual temperature of
         the gas.

     2.  Wet bulb temperature, which is the temperature indicated
         by a thermometer that has its bulb covered with water and
         placed in a stream of moving air.

     3.  Relative humidity, which is the ratio of the partial pres-
         sure to the saturation vapor pressure of water, at the
         same temperature.  Either the chart on a sling psychro-
         meter or the one shown in Figure C-l can be used to deter-
         mine the relative humidity of the air.

     4.  Humidity ratio, which is the ratio of the mass of water
         vapor present  per unit mass of dry air.
     5.  Specific volume of dry air, which is the volume occupied
         by unit mass of dry air.

If any two of these parameters are known, then the state point

on the psychrometric chart is defined.

     The psychrometric  chart for normal atmospheric pressure condi-

tions is shown in Figure C-2.  The curved line along the left side

of the chart represents the 100 percent relative humidity line, or

the saturation line.  Any state point to the left of this line, or

the path of any process crossing this line, will normally be accom-

panied by condensation  of the water vapor resulting in the forma-

tion of a steam plume.

     Toward the lower end of the ambient temperature range it takes

very little moisture to fully saturate the air, and thus the possi-
                                C-l

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                                Figure C-l.  Relative Humidity Tables  (Continued)

-------
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                                 Figure  C-l.    Relative Humidity  Tables  (Concluded)

-------
tn
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                                        Figure C-2.   Sample Psychrometric  Chart

-------
bility of the moisture in the plume condensing is very high, no
matter what the stack exit conditions may be.  The possibility of  a
steam plume being formed is smallest on hot, dry days.
     The psychrometric chart may be used to determine whether a
condensed water vapor plume is to be formed from a specific source
if the ambient weather conditions are known.
     Usually the information given (or estimated) consists of the
ambient temperature and relative humidity and the effluent gas
temperature and moisture content, the latter being defined as the
volume percentage of water vapor in the effluent gases.
     Knowing the moisture content (M.C.), a value for the humidity
ratio may be obtained from the following expression:
     ,,  •J-,    .-    4354 (M.C.)     grains
     Humidity ratio = —	~~            	—
                       1 - M.C.    Ib of dry air
which follows from the Ideal Gas Law and the definitions of
humidity ratio and moisture content.
     The initial state point is given by the effluent gas
temperature and the humidity ratio, and the final state point is
given by the ambient wet and dry bulb temperatures.
     Ambient
     Air temperature (dry bulb) = 70°F
     Wet bulb temperature       = 60°F
     Barometric pressure        = 29.92 inches Hg
     Effluent Gas (stack conditions)
     Exhaust temperature (dry bulb) = 160°F
     Moisture content               = 16.8%
     Substituting these values into the expression for the humidity
ratio gives:
                               C-6

-------
     Humidity ratio = 4354 fQ.168)
                       1 - 0.168
                    = 880    grains
                          Ib of dry air
     The state point of the ambient air is at the intersection of
the 70°F dry bulb temperature line and the 60°F wet bulb tempera-
ture line.  The effluent gas state point is at the intersection of
the 880 grains per pound of dry air line and the 160°F dry bulb
temperature line.
     Figure C-2 shows the two state points plotted on the psychro-
metric chart.  A line connecting these two state points crosses the
saturation curve at about 112°F and 84°F, indicating that a conden-
sed water vapor plume is a distinct possibility.  As the plume mix-
es with the ambient air, the water vapor in the plume will begin to
condense when the effluent temperature reaches 112°F and will begin
to revaporize when its temperature is further cooled to 84°F.
     However, stack gas is not a pure air water mixture, but gener-
ally contains gases such as S02 and $03, and fine particulates.
These substances can alter the dew point and affect the visibility
of the plume.
Reference for Appendix C
    Missen, R. and Stein, A.   "Guidelines  for  Evaluation of Visible
    Emissions:  Certification,  Field  Procedures,  Legal Aspects, and
    Background Material."   EPA-340/1-75-007-   Pacific Environmental
    Services, Inc., Santa Monica, Cal.  90404.  Prepared for U.S.
    Environmental Protection Agency,  Office  of Enforcement, Wash-
    ington, D.C. 20460,  under  Contract  No. 68-02-1390, April 1975,
    pp. 5.3-5.7
                                C-7

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           APPENDIX D





SMOKE GENERATOR SPECIFICATIONS,



          MODEL 3000-A

-------
                   SPECIFICATIONS

                   Smoke Generator

                     Model 3000-A

                        1975
GENERAL
The generator shall be capable of producing constant black and
white smoke plumes with an opacity range of 0 to 100%.  The
unit shall be mounted on a single axle trailer to facilitate
transportation.  The smoke generator shall include the following
major component systems:

          1.  Single axle trailer
          2.  Benzene combustion chamber
          3«  White smoke generator
          14.  Stack assembly
          5»  Transmissometer
          6.  Fuel pump system
          ?•  Dilution manifold
          8.  Main blower assembly
          9.  Automatic benzene ignition
         10.  Operator's console
         11.  Storage compartment
         12.  Accessories

The unit shall meet the specifications as outlined in the
Federal Register Volume Number 39, No. 177 - dated Wednesday,
September 11, 19?ij.

SPECIFICATIONS

A.  Single Axle Trailer

    The trailer shall be constructed to withstand a load capacity
    of no less than 2,000 pounds.  The trailer size shall be
    6 ft. wide by lij ft. long.  All components of the smoke
    generator shall be mounted on a solid sheet metal bed
    attached to the trailer frame.  The bed shall be constructed
    of ll{ guage cold rolled steel.  Turn signals shall be in-
    cluded to meet all state and federal regulations concerning
    towed trailers in the 2,000 pound load range.  The trailer
    shall be equipped with a 1 7/8 inch coupler and safety
    chains for towing.  To insure adequate trailer road stability,
    111" automotive-type tires shall be used to support the
    trailer bed.

B.  Benzene Combustion Chamber (Black Smoke)

    Shall be constructed with double metal walls (11; guage)
    with a minimum of 2.0 inches of castable insulation between
                          D-l

-------
    the walls.  The insulation material shall be rated at
    2000°F or greater.  Internal baffling and liner will be
    included in the combustion chamber to insure proper benzene
    combustion to produce a plume opacity of 0 - 100%.
    Baffling and liner will be constructed of No. 30ij stainless
    steel.

C.  Whi te Smoke Ge ne ra t or

    White smoke shall be generated by injecting #2 fuel oil
    into a propane heated coil.  The fuel vaporization chamber
    will be constructed from stainless steel.  The vaporization
    chamber and coil will be mounted to the generator mixing
    chamber.  The fuel vaporization assembly shall be capable
    of producing a white smoke plume from 0 to 100% opacity.

D.  Stack Assembly

    The stack shall be 12 inches in diameter with a minimum
    height of (16) feet in the raised position.  The stack
    shall be constructed of ll± guage cold rolled steel.  The
    hydraulic cylinder utilized to raise the stack shall have
    a minimum load capacity of 2500 pounds.  For travel pur-
    poses the stack shall be capable of being lowered to a
    maximum height of (8) feet or lower and the stack shall
    be held in position by a cradle supported from the trailer
    frame.  The hydraulic cylinder shall have a minimum stroke
    of 18.0 inches and be at least 2.0 inches in diameter.

E.  Transmissometer

    The transmissometer shall be stack mounted and will consist
    of a light source and a solid state photodetector.  Both
    the light source and the photodetector shall be shock
    mounted (spring loaded) to prevent damage while in transit.
    The transmissometer shall be equipped with two positive
    pressure fans to prevent smoke interference with the
    light source and photodetector.  Calibration of the trans-
    missoineter v/i 11 be accomplished by the insertion of neutral
    density filters between the light source and photodetector.
    The neutral density filters will not be furnished by
    Environmental Industries.

F.  Fuel Pump System

    Two direct current operated fuel pumps (AC type E^-l or
    equal) shall be provided to supply fuel to the black
    smoke combustion chamber and the white smoke vaporization
    chamber.  Two six gallon fuel tanks shall be included to
    furnish the fuel for the generator.  Fuel flow shall be
                          D-2

-------
    adjusted using two needle valves (Whitey No. B-iRS-l|) or
    equal.  The benzene fuel line shall be equipped with a
    (3) way drain valve to prevent freezing during extreme
    cold weather.  Color-coded fuel lines throughout:  black
    for benzene, white for fuel oil and quick disconnect
    fittings with double end shut off feature on all fuel lines.

G.  Dilution Manifold

    The generator shall be equipped with a dilution manifold
    between the black smoke combustion chamber and the main
    blower.  The dilution chamber shall be constructed of
    ll^ guage cold rolled steel.  A manually operated damper
    shall be included to control volume of ambient air allowed
    to pass through the main stack assembly.   The dilution
    chamber shall be at least 8.0 inches in diameter.

H.  Main Blower Assembly

    The unit shall be equipped with a 1).|30 cfm paddle wheel type
    blower to insure proper air flow to the main stack.   The
    blower assembly shall be located between the dilution chamber
  •  and the stack assembly.  All components of the main blower
    shall be fabricated of ll[ guage cold rolled steel, except
    the bloxver blade and the motor housing.  Power to the main
    blower shall be supplied by a (3/L|) HP 11? volt AC motor.
    Maximum RPM of the blower motor shall be 1?25 RPwi.

I.  Automatic Benzene Igniter

    The benzene combustion chamber shall be equipped with an
    automatic fuel igniter.  The igniter shall be propane
    operated and include a trailer mounted 20 Ib. propane
    gas bottle.  A propane regulation valve shall be inserted
    between the propane tank and the igniter head as an added
    safety factor.
    /
J.  Operator's Console

    A remote operator's console shall include the following
    components:

    1.  Digital Printer

        The digital printer will be included to accept the
        transmissometer output.  The digital printer shall
        include all necessary input jacks for the transmissometer
        output and digital printer calibration.

    2.  Operator's Control Panel

        The function of the operator's panel shall be to supply
        control voltages to all operating systems on the
        generator.  Control switches shall be included for main


                          D-3

-------
blower, main power, stack fans, 12) DC fuel pumps,
light source and a 12 volt horn.  The panel shall
also include a variable 10 turn potentiometer for
calibration of the transmissometer.  Three isolated
12 volt DC power supplies shall be mounted behind
the control panel to supply power to the fuel pumps,
horn and light source.  The light source DC supply
circuit shall also include a constant voltage trans-
former to prevent interference from AC-line voltage
fluctuations.  All console electrical circuits shall
be individually fused to prevent power overloads.
A 16 ft. cable shall be supplied to interconnect the
console and generator trailer.  Amphenol mil spec
connectors or equal shall be used on the control panel
and the interconnect cable.  The control panel shall
not exceed 8.5"H x 19.0"W x I^.O'H.
The control panel will
supplies as follows:
                       include three isolated power
                                                or
a.  Light Source Power Supply

    (1)  Output voltage:  11.5 - 12.5 VDC
    (2)  Uutput current:  1.8 amps
    13)  Input voltage range:  108 - 132 volt
         216 - 26li volts
    (ij)  Input frequency range:  50 - ijOO Hz
    (5)  Regulation-line and load combined:  * 0. 1%
    (6)  Temperature coefficient:  0.03% C
    (?)  Polarity:  May be used positive or negative
    (8)  Short circuit protection:  automatic circuit
         protects the power supply if the output is
         shorted continuously.  Automatic return upon
         removal of short circuit.
    19)  Operating temperature:  0°C to 55°c
   110)  Storage temperature:  minus 20°c to plus 85°c

b.  Fuel Pump Power Supply

    (1)  Output voltage:  12.0 - 114. 0 VDC
    (2)  Output current:  3 amps
    (3)  Input voltage range:  110 - 120 VAC
    (14)  input frequency:  60 Hz
    (5)  Filtered
    (6)  Operating temperature:  0°C to 55°c
c.  Horn Power Supply

    (1)  Output voltage:
    (2)  Output current:
    (3)  Input voltage:
    ([;)  Input frequency:  __ .,
    (5)  Operating temperature:
                          12.0 to lij.O VAC
                          8.0 amps
                         110 to 120 VAC
                           60 Hz
                                 0°C to 55°(
                   D-4

-------
    3.   Fuel Control Panel

        The fuel control panel shall be console mounted to
        facilitate remote fuel adjustments to both the white
        and black smoke generators*  The panel shall include
        two DC fuel pumps (AC EP-1 or equal) and two fuel
        control valves (Whitey No. B-IRS-lj or equal).  Fuel
        line connectors shall be accessible from the console
        rear and fuel line size shall not exceed .250 inches
        in diameter.  The console shall be designed to operate
        in any location up to 16 feet from the smoke generator
        trailer.  The entire operator's console shall be housed
        in a sheet metal cabinet.

K.  Storage Compartments

    Two trailer mounted storage compartments 2l|"W x 26HL x
    28"H shall be furnished for accessory storage. . The storage
    compartment covers shall be hinged and equipped with hasp
    for locking.  The two compartments shall be fabricated from
    114 guage cold rolled steel.

L.  Accessories

    The following accessories shall be furnished with the Smoke
    Generator:

    1*  Trailer spare tire
    2.  Trailer dolly and leveling  jack
    3.  (2) spare  light source bulbs
    [j.  Parts  list  and  instruction  manual
    5.  Towing vehicle wiring harness
    6.  Folding table for operator's console
    ?.  Fire extinguisher £  lb. dry chemical type
    8.  One set neutral density filters 2x2- Wratten Gelatin
        set includes  .1 to  1.0.

M.  Stipulations

    1.  One-year warranty for parts and workmanship.

    2.  Three-year  availability of  parts.
                          D-5

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                   MODEL 3000 SERIES

                    SMOKE GENERATOR

                       OPTIONS


Option #1

   Trailer Options

   (A)  The heavy duty trailer is recommended if the smoke
        generator is moved to various locations very frequently
        or over rough terrain.  Load capacity 2000 pounds.

   (B)  Electric Brakes

   (C)  Dual Axle Trailer - capacity ijOOO pounds with brakes.

Option #2

   Automatic Benzene Ignition System

   This option includes a propane ignition system to automatically
   .ignite the benzene fuel required to produce the black smoke
   plume.  This is a much needed safety feature not included
   on prior smoke generators.

Option #3

   Electrical (AC) Generator

   This option allows the smoke generator to be operated in
   areas where commercial AC power is not available.

Option #i]

   Remote Fuel Control Panel

   The standard Model 3000 has the fuel pumps and fuel control
   valves mounted on the generator trailer.   The remote fuel
   control option includes a console mounted panel equipped
   with fuel pumps and control valves.  This option permits
   the smoke generator operator the flexibility of moving the
   operator's console and fuel tanks inside a building while
   conducting a class if adverse weather conditions so dictate.

Option #5

   Cold Weather Package

   The cold weather package is recommended for customers who may
   be conducting visible emissions courses under extreme cold
   weather conditions.  The fact that benzene freezes at 37°f
   is the basic reason for the package.  The cold weather package
   includes an insulated fuel storage compartment and all benzene
   fuel lines are wrapped with heat tape and insulated to prevent
   freezing.
                            D-6

-------
Option #6

   Transmissometer Readout Systems
   (A)
   (B)
        Digital Readout/Printer - Option 6A includes a pane.l
        mounted digital voltmeter and an eleven column digital
        printer.  The transraissometer readout is printed directly
        on an IBM computer card by simply pressing a manual
        print switch.

        Recorder Readout - Option 6B includes a rack mounted 10
        inch strip chart recorder.  Specifications will be
        furnished on request.
                                                            on
Option

   Public Address System

   The PA system shall be portable and capable of operation
   120 volts AC or battery.  Unit will consist of amplifier,
   microphone, speaker cabinet and a 1^0 foot speaker extension
   cable.  The amplifier will be solid state with 1)0 watt output
   and external jacks for auxiliary equipment.

Option #8

   .One-Day Orientation and Maintenance Course

   Environmental Industries can also provide a one-day orientation
   course for training smoke generator operators.  The cost of
   the course can also be included in the cost of the generator
   if desired.  The course includes the basic requirements for
   a visible emissions course and the operation, calibration and
   maintenance of the Model 3000 Series Smoke Generators.  We
   feel that this service is a very important aspect of establish-
   ing a visible emissions course.

Option #9

   Accessory Package

   Includes the following:
                                       Bulbs & Fuses & Parts
                                       Vehicle Wiring Harness
                                       Fire Extinguisher
                                       Filter Holder 4 Calibrator
        Tire & Rim
        Manual & Schematics
        Table - Console
        Neutral Density  Filters

-Option #10

   White Smoke Generator

   The White Smoke Generator  is designed to  replace the air
   cooled engines presently employed on smoke  generators to
   produce the white smoke plume.  The White Smoke Generator
   is compact and does not have any moving parts to produce
   the noise associated with  air  cooled engines.
                           D-7

-------
References for Appendix D


1.  Lee, William S.  "Specifications, Smoke Generator Model
    3000-A."  Environmental Industries Air Monitoring Systems,
    Gary, N.C. 27511, 1975

2.  Lee, Uilliam S.  "Model 3000 Series Smoke Generator Options."
    Environmental Industries Air Monitoring Systems, Gary, N.C.
    27511, 1975
                                D-8

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         APPENDIX E





OPERATOR'S MANUAL. MODEL 3000



       SMOKE GENERATOR

-------
    OPERATOR'S MANUAL
       MODEL 3000
     SMOKE GENERATOR
           1976
 ENVIRONMENTAL INDUSTRIES
      P. O. Box 14^1
    Gary, N. C.
Telephone:  919 + 1467-1500

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                         TABLE OF CONTENTS
                                                         Page No.
Warranty                                                   E-4
Introduction                                               E-5
Operating Principles                                       E-6
Set-Up and Operating Procedures                            E-7
     Electrical Connections                                E-7
     Fuel Line Connections                                 E-8
     Operation of Generator Console                        E-9
     Elevate Stack                                         E-ll
     Procedure for Producing a Black
          Smoke Plume                                      E-ll
     Procedure for Producing a White
          Smoke Plume                                      E-13
     Shut-Down Check List                                  E-14
     Lowering Stack                                        E-15
Parts List                                                 E-16
Electrical Schematics                                      E-17
                                E-l

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                 WARRANTY


Environmental Industries warrants that all products are free
from defective workmanship or material for a period extending
one year from date of shipment.  This warranty shall be
applicable only if the products are used in accordance with
instructions and recommendations*

A defective product should be returned to Environmental
Industries, transportation prepaid.  The company will, at its
option, repair or replace the defective product and it will
be returned freight prepaid.

Environmental Industries shall not be liable for consequential
damages nor for labor, loss, or expenses directly or indirectly
arising from use of their products or equipment.
                          E-2

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                OPERATOR'S MANUAL

                   INTRODUCTION

     The training and testing of smoke observers requires
the use of a device for manufacturing black and non-black
smoke and for controlling the opacity of this smoke.  The
production of shades of black smoke can be accomplished by
various means of creating incomplete combustion.  The non-
black emissions can be produced by heating a distillate-
type oil so that it vaporizes into a gas and then cooling
it so that the vapor condenses into an aerosol cloud.  This
cloud is white and its opacity varies as the amount of oil
that is vaporized.  The control of the visual densities of
the smoke plumes is accomplished by measuring the densities
before the plume is emitted and altering the flow of com-
bustible material (black) or vaporizing liquid (white) until
the desired density is achieved.  There are no liquid flow
control settings which are calibrated to give specified
Ringelmann or equivalent opacity readings.  One obtains a
particular density by turning the fluid control valve until
the photo-electric cell system measuring the density indi-
cates on a dial or recorder that smoke of the desired density
is passing up the stack.
                          E-3

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               OPERATING PRINCIPLES
     The following describes the two methods  employed
to produce Black and White smoke with the Model  3000
Smoke Generator.
     White smoke Is produced by injecting #2  fuel  oil
into the propane heated vaporization chamber  located In
the generator mixing chamber.  The density of the  white
smoke aerosol cloud Is increased or decreased by adjusting
the needle valve (fuel oil) located on the front of the
console mounted fuel control panel.
     Black smoke is produced by the combustion of  benzene
or benzol in the double wall combustion chamber.  The
density of the black smoke plume Is determined by  increasing
or decreasing the Benzene fuel flow.  The benzene  fuel  flow
is determined by the needle valve (Benzene) located on  the
console mounted fuel control panel.
     The main blower mixing chamber may also  have  some
effect on the plume density.  By adjusting the damper con-
trol in the mixing chamber, the amount of the ambient air
entering the plume can be increased or decreased - thus
changing the density of plume read by the transmissometer.
     The transmissometer consists of a photocell and
regulated light source.  The transmissometer  is  located in
the ^ inch cross arms located on the 12 inch  stack.  Neutral
density filters are used to calibrate the transmissometer.
                          E-4

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         SET-UP AND OPERATING PROCEDURES
                    MODEL 3000

1.   Unhitch Smoke Generator from towing vehicle.  The dolly
    jack should be adjusted until the front of the trailer
    is slightly higher than the rear.
2.   Check for any damage to generator while in transit.
3.   Check levels of all fuels, lubricants and hydraulic
    fluid.
    a.  Lubricate main blower motor prior to each instruction
        period.  Two drops of 3 in One oil should be injected
        into each oil cup.
    b.  Check benzene and fuel oil levels in fuel storage
        compartment.
ij.   Electrical Connections
    a.  Connect the 16 ft* interconnect cable to the junction
        box at the rear of the Smoke Generator.
    b.  Connect the 16 ft. interconnect cable to the rear of
        the generator console.
       #The interconnect cable connectors are keyed and
        cannot be connected incorrectly.
    c.  Turn all switches on the generator console to the
        off position.  The fuel control valve should also
        be in the off position.
    d.  Attach the console power cord to the rear panel
        (3 pin amphenol).
                          E-5

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    e.  Plug the console power cord into a 115 VAC-60 Hz
        power source.  Maximum current required by the
        console will not exceed 15 amps.
5.  Fuel Line Connections
    a.  Locate the quick disconnect fuel line connectors
        under the main Junction box on the generator trailer
        and in the rear of the control console (bottom panel).
    b.  Fuel Line Identification
        Two fuel line interconnect assemblies are included
        with the Model 3000.  The shorter set of fuel lines
        is connected between the fuel storage tanks and the
        rear of the fuel control panel.  The longer fuel
        line assembly is connected between the fuel control
        panel and the quick disconnects mounted below the
        main electrical Junction box located on the rear or
        the generator.  Each fuel line assembly is made up
        of one white and one black fuel line.  The white
        fuel line is for benzene transfer and the black line
        is for fuel oil transfer.  All fuel lines are also
        identified by colored tape on each quick disconnect.
    c.  Fuel Line Connections
        1.  Close both fuel control valves prior to making
            fuel line connections.
        2.  Connect fuel lines to the rear of the fuel
            control panel as per matching color codes.
            IMPORTANT  Always connect the above lines to the
            fuel control panel prior to making trailer
            connections or fuel tank connections.
                          E-6

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        3.  Connect two fuel lines to the trailer mounted
            quick disconnects and complete the fuel line
            connections to both fuel storage tanks as per
            color coded tape markings.
        ij.  Vent fuel tanks - loosen filler cap.
7.  Operation of Generator Console
    a.  Main Control Panel  (Electrical)
        Note:  Insure that all electrical switches and fuel
        control valves are  in the off position before start-
        ing this procedure.
        1.  Main power switch should be turned to the (on)
            position.  The  amber power indicator light
            should now be on.
        2.  Stack fans to (on) position.
        3.  Main blower to  (on) position.
        1|.  Recorder to (on) position zero recorder - see
            Lab Data Control Operator's Instruction Manual
            for detailed instructions on recorder.
        5.  Turn light source to on position and adjust
            transmissometer output to read zero per cent
        =   on recorder scale.
    b.  Transmissoroeter Calibration
        Note:  Allow 30 minutes warm up tine for recorder
        and light source before attempting final calibration,
        1...-. Calibration
            The transmissometer is  calibrated after allowing
            a minimum of 30 minutes warm up by  alternately

                          E-7

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    producing simulated opacity of 0 percent and
    100%.   When stable response at 0 percent or
    100% is noted,  the transmissometer is adjusted
    to produce an output of 0 percent or 100%,  as
    appropriate.  This calibration shall be repeated
    until  stable 0 percent and-100% readings are
    produced without adjustments.   Simulated 0
    percent and 100% 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.
2.  Response Time
    Determine the response time by producing a  series
    of five simulated 0 percent and 100% opacity
    values and observing the time required to reach
    stable response.  Opacity values of 0 percent
    and 100% may be simulated by alternately switch-
    ing the power to the light source off and on
    while  the smoke generator is not operating.
Fuel Contro 1 Pane-1  - Lower_Pane1^
1.  Benzene i- The benzene control valve should  be
    left in the OFF position (clockwise) until  the
    procedure is followed in the section concerning
    Black  smoke plume production.
2.  Fuel Oil - Same as above except White smoke
    plume  production.
                 E-8

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8.  Elevate Stack
    a.  Remove nut from stack cradle.  Hold down bracket.*
    b.  Push top half of stack cradle over off the stack.
    c.  Close hydraulic bleed valve at front of hydraulic
        cylinder.  Turn to up and open vent at top of cylinder.
    d.  Pump handle on hydraulic cylinder to raise stack.
   *e.  Do not pump handle after stack reaches the upright
        position.  The stack can be damaged if additional
        force is applied by the hydraulic cylinder.
9.  Procedure for Producing a Black Smoke Plume
    Note:  Section 1 through 7 of this manual should be
    completed prior to executing this procedure.
    a.  Insure that stack fans and main blower are operating
        properly.
    b.  Check to insure that both the combustion chamber
        pilot light control valve and the White smoke generator
        gas control valve are in the OFF position - (clockwise).
    c.  Open the main control valve on the 20 Ib. propane
        bottle mounted in the front storage compartment.
    d.  Remove the heat register plate on the black smoke
        combustion chamber.  Open pilot valve.
    e.  Using a small propane torch light the pilot inside
        the combustion chamber.
    f.  Replace the heat register cover plate with adjustment
        arm on left.
    g.  Adjust louvers for proper air flow - Normally down.
    h.  Turn fuel pump electrical switch to benzene position
        as indicated on control panel.
                         E-9

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i.  Open benzene fuel control valve slightly to allow
    fuel lines to fill with benzene.  This can be
    determined by observing the benzene input line
    connected to the quick disconnect at the rear of
    the generator trailer.
j.  A small flame should now be evident inside the
    combustion chamber and the recorder should also
    be indicating a low level smoke plume less than
    20% opacity.
    CAUTION;  If a flame or plume is not evident close
    the benzene control valve and turn off benzene fuel
    pump.
    1.  Check for possible fuel leaks at all connecting
        points in fuel lines.
    2.  Check to insure that the pilot light is burning.
    3.  Turn OFF pilot light and determine if fuel is
        entering the fuel tray mounted inside the com-
        bustion chamber.  Before attempting this make
        sure pilot light is off.
k.  The combustion chamber should be given sufficient
    time to warm .up before proceeding with higher than
    a /2 Ringleman density reading.  10 to 15 minutes.
1.  The desired black smoke density reading can now be
    continued by adjusting the benzene fuel control valve.
m.  Number i| Ringleman or higher smoke densities should
    only be held for brief periods to prevent damage
    to the generator from excessive heat.

                     E-10

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     n.   The pilot light should be left on after  the completion
         of the Black smoke run.
10.   Procedure for Producing a White Smoke Plume
     CAUTION;  Insure that all the benzene is burned out  of
     the black smoke combustion chamber prior to  proceeding.
     The main blower should also be turned on prior to  proceeding.
     CAUTION;  Insure that the front of the smoke generator
     trailer is slightly higher than the rear of  the trailer.
     This will prevent the possibility of fuel spillage in
     the vaporizer cabinet area.
     a.   The vaporizer torch valve should be in the off
         position (clockwise).
     b.   Open main valve on propane storage bottle.
     c.   Open lid on vaporizer assembly cabinet.
     d.   Turn the main blower switch to the cm position.
         Adjust the vaporizer torch valve until a smooth
         blue flame exists at the input to the fuel vaporization
         chamber.
     e.   Light vaporizer torch with a small propane torch used
         to light the Black smoke igniter.
     f.   Allow vaporization chamber a minimum of  5 minutes
         warm-up time — longer if operating in extreme cold
         ambient conditions.  Vaporizer chamber should  appear
         slightly red prior to injecting No. 2 fuel oil.
     g.   Open No. 2 fuel oil valve on console fuel control
         panel slightly.  Allow enough time for fuel interconnect
         lines to fill with fuel.
                          E-ll

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     h.   If  the  above  steps  have been  followed,  a  low
         opacity White smoke plume will  now  be  indicated
         on  the  console recorder.
     i.   The White smoke vaporizer assembly  will not  produce
         any desired White smoke plume from  0%  to  100%  opacity,
         Caution:  To  prevent flooding of  the fuel  vaporization
         chamber, do not open fuel oil control  valve  beyond
         the 100% opacity level  indicated  on the console
         recorder.
11.   White Smoke Assembly Shut-Down  Procedure
     a.   Turn off fuel pump  at control console.
     b.   Turn off fuel oil control valve.
     c.   Allow all fuel to be burned from  the fuel  vaporization
         chamber.  This will be indicated  by a  0%  opacity
         reading on the recorder.
     d.   Turn off vaporization chamber propane  torch.
     e.   Turn off valve on propane bottle  if no other  runs
         are to  be conducted with either White  or  Black smoke.
12.   Shut-Down Check List
     a.   Insure  that both .fuel control valves are  completely
         turned  off.  .Clockwise direction.
     b.   Insure  that all propane  control valves are turned
         to  the  OFF position.
         1.   Main bottle valve first
         2.   White smoke torch valve
         3.   Benzene igniter valve
                         E-12

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     c.   Disconnect  fuel  lines  at  trailer  quick  disconnect
         and drop blue connector Into benzene  storage  tank.
         Also insert green connector into  filler neck  of
         kerosene storage tank.  The next  step should  be  to
         pump all fuel lines as free as  possible of  remaining
         fuel.  Open fuel line  control valves  completely  and
         allow both fuel  pumps  sufficient  time to clear lines.
         Remove fuel lines from console  quick  disconnects and
         insert caps on male connectors.
     d.   All electrical control switches can now be  turned
         to the (OFF) position.  The power control switches for
         the recorder should also be moved to  the (OFF) position.
     e.   The electrical system  interconnect cable should  now
         be removed from  both the trailer  main junction box
         and the rear of  the console control panel.
13.   Lowering Stack
     a.   Open cradle hold down  bracket.
     b.   Open hydraulic bleed valve slightly.
     c.   Insert large screwdriver in slow  between upper and
         lower stack sections.
     d.   Lift up on screwdriver to tilt  stack  slightly forward.
     e.   Adjust bleeder valve to control speed of stack descent.
     f.   Close stack cradle and tighten  hold down nut.
     g.   Bleeder valve should be left open to  prevent  accidental
         damage to stack.
 Note:   Additional information  on the operation  and  maintenance  of
 smoke  generators can be  obtained from EPA Instructors and
 Operators Manual on the  Evaluation of Visible Emissions. Contact
 Dennis  Holzschuh, NERC,  Research Triangle Park, N.  C..
                          E-13

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Part Number
101
102
103
lOlj
105
106
107
106
109
110
111
112
113
1114
115
116
117
116
119
120
121
122
123
121,
125
126
Description
Trailer
Fuel Tanks
Third Wheel
Recorder » Model 2601
Stack Fans
Photocell
Light Source
Console Cabinet
Potentiometer
Cable Connectors
Fuel Pumps - 12 volt
Fuel Valves
Main Blower Fan
Uain Blower Motor
Vaporization Chamber
Propane Tank - 20 Ib.
Igniter Torch - Propane
Vaporization Torch /Ij063
Benzene Combustion Chamber
Quick Disconnects - Body
701
Flexible Tubing - Nylo-Seal
Fire Extinguisher - 5 Ib.
Hydraulic Cylinder
2.0 x 16.0 - 25001b.
Hydraulic Pump - Double
Action
Hydruallc Line - 146.0"
Control Panel (Elect.)
Manufacturer
E & 1
E & I
Jeffries
Lab Data Control
Dayton
E & 1
. E & 1
Bud
TRW
Amphenol
AC - EP1W
Whitey
Dayton
Dayton
E & I
Universal
Keen-Cutter
Exact Torch
E & I
Flo-Lok
imperial Eastman
Sentry
Livingston &
Haven
Livingston &
Haven
E & 1
£41
127
3000

Fuel Control  Panel
3000
E & 1
                 Figure  E-l.   Parts List
                            E-14

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                         E-17

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                            E-19

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                               E-20

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               Figure E-8.   Main Junction  Box, Trailer-Mounted
                                 Terminal Strip
                                       E-21

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References for Appendix E
1.  Lee, William S.  "Operator's Manual, Model 3000 Smoke Gener-
    ator."  Environmental  Industries Air Monitoring Systems, Gary,
    N.C. 27511, 1976
                               E-22

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            APPENDIX F





SMOKE GENERATOR TESTING PROCEDURES

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                            APPENDIX F

                SMOKE GENERATOR TESTING PROCEDURES
1.0  LIGHT SOURCE

     1.  Turn light source on.

     2.  Using a digital voltmeter, check the lamp voltage at the
         test points on the rear of the console.

     3.  Compare the voltage reading obtained with the
         manufacturer's recommended operating voltage.

     4.  If the voltage is not within  5 percent, corrective action
         is required.

     5.  Record operating voltage on the smoke generator
         performance data sheet (Figure F-l).

2.0  SPECTRAL RESPONSE

     Using the manufacturer's data, verify the photocell's photopic

response  (400-700 nanometers), or check it with Kodak band pass

filters.


3.0  ANGLE OF VIEW OF SMOKEPLUME

     1.  Remove the source and aperture apparatus from the
         transmissometer.
     2.  Set up the apparatus on  a  flat, horizontal  surface  making
         sure that the  distance between the  light source  and
         aperture  is the  same as  it  is  in the transmissometer.

     3.  Turn light source on.
     4.  Focus the light  on  a bare  surface  at a  known distance  from
         the aperture  (L) and record distance on the performance
         data sheet.
     5.  Measure the diameter of  the light  projected on  the  bare
         surface (d) and  record distance on  the  performance  data
          sheet.
     6.  Using the equation:
          6=2 tan'1   d
         calculate  the angle of view and record the distance on the
         performance  data  sheet.
                                    F-l

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ro
                            Generator Nunber_
                            Manufacturer
                                    Op*r«tor_
                                    Owner
                            Light source lamp voltage
                                                                       volts.
Angle of Vie* 0-2 tan-1 d/ZL
    I •	
    d •	
    0 -   ,
                            Zero drift
                                                                        * Chart
                            Span drift
                                                                        1 Chart
                                                                                         CalIbration Error
                                                                                           20%
                                                                                               % Chart
                                                                                                         50%
                                                                                                             I Chart
                                                                                                                       75%
                                                                                                                           1 Chart
% Chart
X Chart
» Chart
S Chart
X Chart
t Chart
t Chart
% Chart
I Chart
t Chart
% Chart
t Chart

                                                                                         Rtse time
                                                                                                                 Fall time
                                                                                         List any corrective action requ1red_
                                                                                         Tested by
                                                                                         Verified by_
                                                                                        Oate_
                                                                                        Date
                                     Figure F-l.   Smoke Generator  Performance  Evaluation  Data  Sheet

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4.0  ZERO AND SPAN DRIFT
     1.  Warm up the smoke generator for a minimum of 30 minutes.
     2.  Place light switch in the off position.
     3.  Adjust the recorder to read 100 percent chart scale.
     4.  Place the light in the on position.
     5.  Adjust the recorder to read 0 percent chart scale.
     6.  Repeat steps 2 to 5 until a stable response is obtained at
         100 and 0 percent recorder chart scale.
     7.  Perform the calibration error test.
     8.  At the end of the calibration error test, repeat steps 2
         to 5.
     9.  Record the difference in chart scale for the zero and span
         on the smoke generator performance data sheet.

5.0  CALIBRATION ERROR
     1.  After step 6 of the zero and span drift test, place  a 20
         percent opacity neutral-density filter in the light  path
         of the transmissometer.
     2.  Record the percent recorder chart scale response.
     3.  Repeat steps 1 and 2 for neutral, density filters of  50 and
         75 opacities.
     4.  Repeat steps 1 to 3 five times for each filter.
     5.  If any one reading is greater than 3 percent recorder
         chart scale from the stated value, corrective action is
         required.

6.0  RESPONSE TIME
     1.  After a  zero setting is  obtained,  introduce  a  span  into
         smoke generator.
     2.  Using a  stopwatch, measure  the time  the recorder  takes  to
         reach 100 percent chart  scale.
     3.  Record the rise time on  the  performance data sheet.
     4.  Place the smoke generator transmissometer  in the  zero
         position.
                                 F-3

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     5.   Using a stopwatch, measure the time the recorder takes to
         reach 0 percent chart scale.
     6.   Record the fall time on the performance data sheet.
     7-   If the response time for either test is more than 5
         seconds, corrective action is required.
References for Appendix F


1.  Rose, Thomas H.  Unpublished draft procedures for Region IV VE
    Programs, 1978
                                F-4

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                     APPENDIX G





QUALITY ASSURANCE TECHNIQUE FOR CERTIFICATION TESTING

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                            APPENDIX G
       QUALITY ASSURANCE TECHNIQUE FOR CERTIFICATION TESTING


     A strip chart recorder should be purchased and installed if
one is not already in operation.  The technique described below has
been developed by the VE training schools in Region IV and ensures
that valid emissions occur for every reading:

     1.  All zero, span, midrange linearity, and calibration filter
         readings are recorded on the strip chart, which then
         serves as a permanent record that these tests were per-
         formed and that the Method 9 criteria were achieved for
         each individual training school.
     2.  During each test, the chart is permitted to run continu-
         ously, but the pen is only activated during the short time
         intervals when observations are being made by the
         inspectors.
     3.  The observation period for each emission is about two sec-
         onds, and the beginning and the end of each observation
         period are signalled by the operator.  For example, read-
         ing number 7 would be announced "number 7 ... (2 second
         delay) ... mark!"  The observers therefore have two sec-
         onds to estimate the opacity of each reading, but more
         importantly, the instructor has two seconds to determine
         whether the emission is "valid."  If the readings is not
         valid, the instructor announces "number 7 ... (2 second
         delay) ... scratch!" and the observers do not make any
         record on their forms--readings are only recorded when the
         instructor announces "mark!"  The instructor can decide
         that the readings is invalid for any one of several
         reasons, for example:
         a.  A sudden shift in wind direction.
         b.  The plume becomes doubled over.
         c.  The opacity is not constant over the two-second obser-
             vation period.  Region IV has developed two criteria
             for determining whether the opacity is "constant"  (re-
             fer to Figure 3-10):
             i.  The average opacity during  the two seconds  is
                 within 1.5 percent opacity  of the announced
                 opacity.
                                 G-l

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             ii.  The variation of the trace does not exceed 1.0
                  percent opacity from its average position at any
                  time during the two seconds.
     A chart recorder of suitable quality costs a minimum of about
$1,000, but the subsequent improvements in certification procedures
compensate for this.  The ability of the instructor to declare
readings invalid ensures that observers only take readings under
optimum conditions.  They can thus qualify more quickly, which
means a net savings in labor costs to the agency conducting the
training program.  In addition, the values reported by the instruc-
tor can be validated if the accuracy of the smoke school is
questioned.
References for Appendix G
1.  Rose, Thomas H.  Unpublished draft procedures for Region IV VE
    Programs, 1978
                                G-2

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                                   TECHNICAL REPORT DATA
                            (f lease read Instructions on the reverse before completing)
 REPORT NO.
                             2.
                                                            3. RECIPIENT'S ACCESSION NO.
 TITLE AND SUBTITLE
 Visible  Emissions Program  Operations Manual
             5. REPORT DATE
              February 1979
                                                            6. PERFORMING ORGANIZATION CODE
 AUTHOR(S)

 Victoria  Scott
             8. PERFORMING ORGANIZATION REPORT NO.

              PES275
 .PERFORMING ORGANIZATION NAME AND ADDRESS
  Pacific  Environmental Services
  1930 14th  Street
  Santa Monica, CA  90404
             10. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.
              68-01-4140   Task No.  32
12. SPONSORING AGENCY NAME AND ADDRESS
  U.S.  Environmental Protection Agency
  Region  IV   Air Surveillance Branch
  Surveillance and Analysis  Division
  Athens.  Georgia  30601	
             13. TYPE OF REPORT AND PERIOD COVERED
               Final
             14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
  This  document contains a  set of guidelines  for use by officials who are
  responsible for conducting schools to train inspectors to evaluate the
  opacity of emissions from stationary sources.   The manual specifically
  addresses the requirements of EPA Method  9  (40CFR, Part 60,  Appendix A)
  as  revised on November 12, 1974.  For the lecture phase of the training
  course, suggestions are given for the content  of each of six lectures
  and a sample course agenda is presented.   Procedures are given for setup,
  calibration, shutdown and maintenance of  the smoke generator as well as
  directions for using the  generator in training and certification classes.
  Certification criteria and confidence limits are also discussed.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.lDENTIFIERS/OPEN ENDED TERMS
                           i1.  COSATI I icld Group
  Opacity
  Visible Emissions
  Method  9
  Transmissometers
  Smoke Generators
  Smoke Meters
 visible emissions
 training courses
18. DISTRIBUTION STATEMENT

  Release  Unlimited
19. SECURITY CLASS (This Keporri
 Unclassified
2.1. NO. OF PAGES
      75
                                               20. SECURITY CLASS (This page)
                                                Unclassified
                                                                          22. PRICE
EPA Form 2220-1 (R»v. 4-77)   PREVIOUS EDITION is OBSOLETE

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