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Department of Justice
Legal Staff Seminar
on Stationary Source
Compliance Testing Methods
Seminar Program and
Reference Material List
US Environmental Protection Agency
Office of Air, Noise, and Radiation
Division of Stationary Source Enforcement
Washington DC 20460
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28045
DEPARTMENT OF JUSTICE LEGAL STAFF SEMINAR ON
STATIONARY SOURCE COMPLIANCE TESTING METHODS
Workshop Program and Reference Materials
Prepared by
PEDCo Environmental, Inc.
505 S. Duke St., Suite 503
Durham, North Carolina 27701
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF AIR, NOISE, AND RADIATION
DIVISION OF STATIONARY SOURCE ENFORCEMENT
WASHINGTON, D.C. 20460
August 1981
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CONTENTS
Page
SECTION A: PURPOSE AND SCOPE, AGENDA, AND LIST OF SPEAKERS
1. Purpose and Scope 3
2. Agenda 5
3. List of Speakers 9
SECTION B: LIST OF REFERENCE MATERIALS
1. Publication List of Method 5 Documents Included in the 13
Resource File Provided to the Department of Justice
2. Publication List of Method 9 Documents Included in the 17
Resource File Provided to the Department of Justice
V
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vi
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SECTION A:
PURPOSE AND SCOPE, AGENDA, AND LIST OF SPEAKERS
1
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2
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PURPOSE
State Implementation Plan Regulations and Federal Standards (NSPS
and NESHAPS) generally require stationary sources to demonstrate compli-
ance through source testing using prescribed methods and techniques. In
addition, visible emission standards play an important role in Federal
and State air pollution control programs for reducing particulate emis-
sion from stationary sources. Opacity limitations often provide the
only effective and practical method for determining whether emission
control equipment is continuously maintained and operated properly.
Standard test methods are essential for the establishment and
enforcement of emission limitations because different methods yield
different results. The Federal Reference Test Methods are designed to
provide consistent, predicable measurement values with sufficient accu-
racy and reliability for purposes of determining compliance. However,
the methods are quite complex and require qualified personnel for proper
application. Furthermore, each source industrial facility to be tested
frequently present unique field sampling problems which must be accoin-
modated within the flexibility of the methods. Thus, considerable
technical judgment must be exercised in the application of the methods
and interpretation of the emission test results.
Plume opacity readings are performed only by a qualified observer
following a prescribed procedure. The proper training and certification
of the visible emission observer is of prime importance inasmuch as the
observer’s testimony frequently constitutes the major evidence substan-
tiating the source’s violation of the opacity standard. Although the
validity of visible emission standards has been reaffirmed in courts
throughout the country as a reasonable and effective means of regulating
emissions, the outcome of the enforcement litigation generally hinges of
the visible emission observer’s training and the precision with which he
makes his readings. As with the application of any field measurement
technique, visual reading of plume opacity involves many judgmental
deci sions.
In using emission measurement methods in determining compliance
with emission standards and enforcing its violations of the applicable
regulations is imperative that all technical portions of the agency’s
enforcement case be correct and be presented in such a manner that the
layman can comprehend its validity. The high degree of technical com-
plexity involved with these case preparations generally requires that
1) the attorney have a general understanding of the compliance methods
used, 2) proper technical staff be available for technical assistance
and review, 3) proper technical documentation and references be ob-
tained, and 4) necessary technical experts be available during the case
presentation. This seminar is designed to provide the Justice Depart-
ment attorneys with information and reference materials to accomplish
these four technical requirements of the case preparation and presenta-
tion.
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SCOPE
The scope of the seminar includes a background of the methods,
brief overview of the methods, special problems with methods applica-
tion, alternative methods, precision and accuracy of the methods, stan-
dard sequence of events during a field compliance determination and
common augments used by the opposing counsel to discredit the field data
and methodology. Although the time allotted for each topic precludes
and indepth treatment, supplemental literature is provided which should
enable seminar attendees to broaden their knowledge in each area. Where
additional information is desired the attendee can also use the biblio-
graphies of the reference methods and opacity literature to find appro-
priate references.
The topics presented during the seminar will largely address the
technical and legal aspects of application of Reference Method 5 for
determination of particulate emissions from stationary sources and
Reference Method 9 for visual determination of plume opacity. However,
inasmuch as these methods are generally representative of the rationale
and principles underlying all reference methods the minimum requirements
for proper use of any reference methods for compliance testing purposes
will be amply illustrated. Comparison of EPA reference methods with
other types of test methods conveniently used in the testing community
will also be discussed.
4
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Department of Justice
Legal Staff Seminar
on Stationary Source Compliance Testing Methods
(With Emphasis on EPA Methods 5 and 9)
AGENDA
Location: Date:
Department of Justice September 22-23, 1981
Room 1257
10th and Pennsylvania Avenue
Iashington, 0. C. 20530
Date and Time Topic Speaker
September 22 (Tuesday)
SESSION I. OVERVIEW OF STATIONARY SOURCE COMPLIANCE TESTING
1:05 Welcome C. Green
Introduction and Purpose of Seminar K. Foster
1:30 Major Elements of a Compliance Test B. DeWees
Regulation/method applicability determination
Pretest agreement
Test implementation
Data validation and interpretation
1:45 Potential Technical Issues in Compliance Testing B. DeWees
Representative facility operations
Representative emission rate measurements
Agency use of the bias concept
2:00 Potential Policy Issues in Compliance Testing K. Foster
Purpose of the compliance test
Affect of averaging times and emissions varia-
bility
Uncertainty in measurements
Allowance for method error
5
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Agenda (continued)
Date and Time Topic Speaker
Tuesday (continued)
SESSION II. REVIEW OF MANUAL METHOD FOR DETERMINATION
OF PARTICULATE EMISSION FROM STATIONARY SOURCES
2:15 Description of Reference Method 5 and Support- B. DeWees
ing Methods 1, 2, 3, and 4
2:30 Historical Development of Method 5 and Affect B. DeWees
of Sampling Train Design on Test Results
2:45 BREAK
3:00 Major Applicability Issues Encountered in SIP K. Foster
Compliance Determination Using EPA Reference
Test Methods
Expanded use of Method S (4OCFR 52.12)
Pseudo particulates
Condensibles
3:15 Acceptability of Alternative Methods B. DeWees
Method modification
Bias concept
Special sampling problems
3:25 Minimum Quality Assurance Requirements B. DeWees
Method precision and accuracy determination
Quality control and chain-of—custody
Data validation
3:35 Facility Operation K. Foster
Production rate determination
Process/control equipment operating conditions
Data interpretation
3 45 Criteria for Reviewing Enforceability of a K. Foster
Compliance Test Method
4:00 Common Arguments by Opposing Counsel K. Foster
4:15 Group Discussion Panel
4:45 ADJOURN
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Agenda (continued)
Date and time Topic Speaker
September 23 (Wednesday)
SESSION III. REVIEW OF TRAINED OBSERVER METHOD FOR VISUAL
DETERMINATION OF PLUME OPACITY
9:00 Description of Reference Method 9 and Support- 1. Rose
ing Training and Certification Procedures
9:15 Historical Development of Method 9 and the Time T. Rose
Accumulation Technique
9:30 Current and Future Role of Opacity Standards K. Foster
in NSPS and SIP Enforcement
9:45 Scientific Basis for Plume Opacity Measurements T. Rose
Opacity principles K. Foster
Relationship between opacity and mass emission
Accuracy of Method 9 versus instrumental
methods
10:15 BREAK
10:45 Minimum Requirements for Proper Application of T. Rose
Method 9
Training and certification program
Documentation of field observation procedure
Special field observation problems
11:00 Review of Enforcement Checklist T. Rose
11:15 Common Arguments by Opposing Counsel K. Foster
11:30 Group Discussion on Session III Topics Panel
SESSION IV. REVIEW OF AGENCY EXPERTISE AVAILABLE AT
RESEARCH TRIANGLE PARK
11:45 Overview of EPA Programs Involved in Air Pollu- K. Foster
(optional tion Emission Measurement Method Development
1:00) and Other Groups Having Expertise in Air Pol-
lution Effects and Control Technology
12:00 Use of EPA Consultants and Contractors for Panel
(optional Expert Testimony
1:15)
12:25 CLOSE OF SEMINAR
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8
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LIST OF SPEAKERS
William (Bill) DeWees
Training Programs Director
PEDCo Environmental, Inc.
505 South Duke Street, Suite 503
Durham, North Carolina 27701
Telephone: (919) 682-8347
Kirk Foster
Technical Coordinator
Technical Support Branch
Division of Stationary Source Enforcement (MD-7)
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Telephone: (919) 541-4571
Carol Lynn Green
Assistant Chief
Environmental Enforcement Section
Land and Natural Resources Division
U.S. Department of Justice
10th and Pennsylvania Avenue, Northwest
Washington, D. C. 20530
Telephone: (202) 633-5272
Tom Rose
President
Eastern Technical Associates
Raleigh, North Carolina 27658
Telephone: (919) 834-2970
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SECTION B:
REFERENCE MATERIALS FOR METHODS 5 AND 9
11
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12
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PUBLICATION LIST OF METHOD 5 DOCUMENTS INCLUDED IN THE
RESOURCE FILE PROVIDED TO THE ENVIRONMENTAL ENFORCEMENT SECTION,
LAND AND NATURAL RESOURCES DIVISION, US. DEPARTMENT OF JUSTICE,
WASHINGTON, D.C. (SEPTEMBER 23, 1981)
1. Environmental Protection Agency Performance Test Methods, EPA-340/1--78-O11,
August 1978. Compilation of EPA Reference Methods 1-8, published in
40 CFR 60, Appendix A.
2. Quality Assurance Handbook for Air Pollution Measurement Systems: Vol-
ume I — Principles, EPA—600/9-76-005. March 1976.
3. Quality Assurance Handbook for Air Pollution Measurement Systems: Vol-
ume II — Ambient Air Specific Methods, EPA-340/4-77-027a. May 1977.
4. Quality Assurance Handbook for Air Pollution Measurement Systems: Vol-
ume III - Stationary Source Specific Methods, EPA-600/4-77-027b. August
1977.
5. Collaborative Study of Particulate Emissions Measurements by EPA Methods
2, 3, and 5 Using Paired Particulate Sampling Trains (Municipal Incin-
erators ), EPA—600/4-76—014. March 1976.
6. Collaborative Study of Method for Determination of Particulate Matter
Emissions from Stationary Sources (Fossil Fuel-Fired Generators),
EPA—650/4-74-021. June 1974.
7. Collaborative Study of Method for the Determination of Particulate
Matter Emissions from Stationary Sources (Portland Cement Plants),
EPA—650/4-74-029. May 1974.
8. Guidelines for Development of a Quality Assurance Program: Volume I
Determination of Stack Gas Velocity and Volumetric Flow Rate (Type-S
Pitot Tube), EPA—650/4—74—005a. February 1974.
9. Collaborative Study of Method for Stack Gas Analysis and Determination
of Moisture Fraction with the Use of Method 5, EPA-650/4-74-026. June
1974.
10. The EPA Program for the Standardization of Stationary Source Emission
Test Methodology - A Review, EPA-600/4-76-O44. August 1976.
11. The Role of Quality Assurance in Collaborative Testing, Mitchell, W.
Paper Presented at ASQC/APCA Meeting, New Orleans. March 1979.
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12. How EPA Validates NSPS Methodology, Midget, R., Environmental Science and
Technology, Vol. II, No. 7, pp. 655—659. July 1977.
13. Comparative Testing of EPA Methods 5 and 17 at Nonmetallic Mineral Plants,
EPA—600/4-80-022. April 1980.
14. A Study of the Accuracy of the Type-S Pitot Tube, EPA-600/4-77-030.
June 1977.
15. Evaluation of Stationary Source Particulate Measurement Methods: Vol-
ume I — Portlant Cement Plants, EPA—650/2-75-OSla. June 1975.
16. Evaluation of Stationary Source Particulate Measurement Methods: Vol-
ume II — Oil Fired Steam Generators, EPA—600/2-77-026. February 1977.
17. Evaluation of Stationary Source Particulate Measurement Methods: Vol-
ume III — Gas Temperature Control During Method 5 Sampling, EPA-600/2-
79—115.
18. Evaluation of Stationary Source Particulate Measurement Methods: Vol-
ume IV — Basic Oxygen Furnaces, EPA-600/2-79-141. August 1979.
19. Evaluation of Stationary Source Particulate Measurement Methods: Vol-
ume V - Secondary Lead Smelters, EPA-600/2-79-116.
20. An Evaluation of the Current EPA Method 5 Filtration Temperature — Control
Procedure, Vollaro, R., (Unpublished Paper). U.S. Environmental Protec-
tion Agency, Research Triangle Park, North Carolina. 1977.
21. A Guideline for Evaluating Compliance Test Results (Isokinetic Sampling
Rate Criterion), Stack Sampling Technical Information. U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina. August 1977.
22. A Collection of Monographs and Papers, Stack Sampling Technical Informa-
tion: Volumes I — IV, EPA—450/2-78—042a, 042b, 042c, and 042d. October
1978.
23. Condensible Particulate and Its Impact on Particulate Measurements. Con-
tract No. 68—01-4148, Task Order No. 69. Prepared for the Division of
Stationary Source Enforcement, U.S. Environmental Protection Agency.
May 1980.
24. Selected Papers on Particulate Sampling in Cyclonic Flow. (A Compilation
of Six Papers on Cyclonic Flow Sampling Problems.) Prepared by the
Division of Stationary Source Enforcement, U.S. Environmental Protection
Agency. March 1980.
25. Observer’s Checklist Package for EPA Reference Test Methods, EPA—340/1—
80—009. June 1980.
26. Model Compliance Testing Protocol Manual, EPA—340/1—78-OL 1. September
1979.
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27. Observing Compliance Tests. Reference Material Prepared by the Division
of Stationary Source Enforcement, U.S. Environmental Protection Agency,
for Agency Staff Training. July 1979.
28. Source Sampling Introductory Manual. Reference Material Prepared by
the Division of Stationary Source Enforcement, U.S. Environmental Protec-
tion Agency, for Agency Staff Training. February 1978.
29. Source Sampling Technical Manual: Volume II. Reference Material Prepared
by the Division of Stationary Source Enforcement, U.S. Environmental Pro-
tection Agency, for Agency Staff Training. February 1978.
30. Source Sampling Administration Manual, Volume III. Reference Material
Prepared by the Division of Stationary Source Enforcement, U.S. Environ-
mental Protection Agency, for Agency Staff Training. November 1977.
31. Source Sampling Reference Manual: Part I - Supplemental Training Material.
Prepared by the Division of Stationary Source Enforcement, U.S. Environ-
mental Protection Agency, for Agency Training Staff. November 1977.
32. APTI Course 450 — Source Sampling for Particulate Pollutants: Student
Manual, EPA-450/2—79—O06. December 1979.
33. APTI Course 450 — Source Sampling for Particulate Pollutants: Student
Workbook, EPA—450/2—79—007. December 1979.
34. Administrative and Technical Aspects of Source Sampling for Particulates,
EPA—45O/3—74—047. August 1974.
35. Development, Observation, and Evaluation of Performance Tests at Asphalt
Plants, EPA—340/1-78—014.
36. Public Comment Summary: Revisions to Reference Methods 1—8 in Appendix A
of Standards of Performance for New Stationary Sources. Office of Air
Quality Planning and Standards, U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina. June 1977.
37. Determining Dust Concentrations in a Gas Stream - Power Test Code 27.
Published by the American Society of Mechanical Engineering, New York,
New York. April 1957.
38. Particulate Source Sampling at Steam Generators with Intermittent Soot
Blowing. Division of Stationary Source Enforcement, U.S. Environmental
Protection Agency. October 1978.
39. Draft Method 5A for Determination of Particulate and Condensible Organic
Matter. Prepared for Sinter Plant NSPS Under Development and Other
Source Categories with Condensible Organic Particulate Emissions. Emis-
sion Standards and Engineering Division, U.S. Environmental Protection
Agency. 1981.
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40. NAPA Environmental Inspection and Testing Manual. Information Series 65.
(Example of Industrial Testing Guide). January 1978.
41. Legal and Administrative Guideline and Policies for Method 5 Emission
Testing. Reference Material Prepared by the Division of Stationary
Source Enforcement, U.S. Environmental Protection Agency for the Depart-
ment of Justice Legal Staff Seminar on Stationary Source Compliance Test
Methods. September 22-23, 1981.
42. Emission Testing Concepts and Special Problems. Reference Material Pre-
pared by the Division of Stationary Source Enforcement, U.S. Environmental
Protection Agency for the Department of Justice Legal Staff Seminar on
Stationary Source Compliance Test Methods. September 22-23, 1981.
43. Guide to Audiovisual and Instructional Materials on Air Pollution.
Education and Training Committee, Air Pollution Control Association.
1981.
SELECTED PAPERS
1. The Number of Sampling Points Needed for Representative Source Sampling.
Knapp, K. Presented at the Fourth National Conference on Energy and
the Environment. October 4-7, 1976. Cincinnati, Ohio.
2. Determination of the Optimum Number of Traverse Points: An Analysis of
Method 1 Criteria. Contract No. 68-01-3172, Task Order No. 7). Division
of Stationary Source Enforcement, U.S. Environmental Protection Agency.
April 1977.
3. Reactive Plumes - Sampling and Opacity Concerns for Cement Kilns.
Chadbourne, J. and Brown, R. Presented at the 73rd Annual Meeting of
APCA, Montreal, Canada. June 22-27, 1980.
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PUBLICATION LIST OF METHOD 9 DOCUMENTS INCLUDED IN THE
RESOURCE FILE PROVIDED TO THE ENVIRONMENTAL ENFORCEMENT SECTION,
LAND AND NATURAL RESOURCES DIVISION, U.S. DEPARTMENT OF JUSTICE,
WASHINGTON, D.C. (SEPTEMBER 23, 1981)
1. Title 40, Protection of Environment, Part 60 — Standards of Performance
for New Stationary Sources, Appendix A, Federal Reference Method 9 -
Visual Determination of the Opacity of Emissions from Stationary Sources.
(39 FR 39872). November 12, 1974.
2. Guidelines for Evaluation of Visible Emissions: Certification, Field
Procedures, Legal Aspects, and Background Material, EPA—340/1-75-007.
April 1975.
3. EPA Visible Emission Inspection Procedures, S—24. Division of Stationary
Source Enforcement, U.S. Environmental Protection Agency. August 1975.
4. Evaluation and Collaborative Study of Method for Visual Determination of
Opacity of Emissions from Stationary Sources, EPA—65O/4—75—O09. January
1975.
5. Optical Properties and Visual Effects of Smoke—Stack Plumes. Conner, W.
and Hodkinson, J. U.S. Department of Health, Education, and Welfare,
Public Health Service Publication 999—AP—30. Revised May 1972.
6. Visible Emission Inspection and Observation Procedures (Draft). Division
of Stationary Source Enforcement, U.S. Environmental Protection Agency.
November 1980.
7. Examining the Properties of Qualified Observer Opacity Readings Averaged
Over Intervals of Less than Six Minutes. Contract No. 68—02-1325, Pro-
ject No. 893—66. Division of Stationary Source Enforcement, U.S. Environ-
mental Protection Agency. July 1976.
8. Visible Emissions Program Operation Manual. Region IV Surveillance and
Analysis Division, U.S. Environmental Protection Agency, Athens, Georgia.
EPA-34O/1—79—OO9. February 1979.
9. Quality Assurance Guideline for Visible Emission Training Programs (Draft).
Quality Assurance Division, U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina. August 1981.
10. EPA Responses to Reprimand Ordered by the U.S. Court of Appeals for the
District of Columbia in Portland Cement Association v. Ruckleshaus,
EPA—450/1—74—023. November 1974.
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11. Measurement of the Opacity and Mass Concentration of Particulate Emis-
sion by Transmissometry, EPA—650/2—74—128, November 1974.
12. APTI Course 439 Student Manual — Visible Emissions Evaluation,
EPA—450/3—78—1O6, September 1978.
13. Public Corr ent Summary — NSPS Opacity Provisions. Reference Material
Prepared by the Division of Stationary Source Enforcement, U.S. Environ-
mental Protection Agency, for Agency Staff Training. September 1978.
14. Compilation of Opacity Standards: Standards of Performance for New
Stationary Sources. Reference Material Prepared by the Division of
Stationary Source Enforcement, U.S. Environmental Protection Agency,
for Agency Staff Training. September 1978.
lb. Survey of Opacity Standards: State Implementation Plan. Reference
Material Prepared by the Division of Stationary Source Enforcement, U.S.
Environmental Protection Agency, for Agency Staff Training. September
1978.
16. Plume Appearance vs. Plume Opacity. Reference Material Prepared by the
Division of Stationary Source Enforcement, U.S. Environmental Protection
Agency, for Agency Staff Training. September 1978.
17. Impact of Sulfuric Acid Emissions on Plume Opacity. Reference Material
Prepared by the Division of Stationary Source Enforcement, U.S. Environ-
mental Protection Agency, for Agency Staff Training. September 1978.
18. Selected Legal Briefs and Court Decisions on Opacity Standards. Reference
Material Prepared by the Division of Stationary Source Enforcement, U.S.
Environmental Protection Agency, for Agency Staff Training. September
1978.
19. Plume Opacity Observations vs. In—Stack Opacity Measurements. Reference
Material Prepared by the Division of Stationary Source Enforcement, U.S.
Environmental Protection Agency, for Agency Staff Training. September
1978.
20. Survey of Transmissometers Used in Conducting Visible Emission Training
Courses, EPA—600/4—78—023. May 1978.
21. State of North Carolina Visible Emission Evaluation Training Program.
North Carolina Department of Natural Resources, Raleigh, North Carolina.
(Example of State Training Manual.) 1979.
22. Feasibility of Emission Standards Based on Particle Size, EPA—600/5 -74-007.
March 1974.
23. The Opacity Witness. (Final Draft.) Paper by Kenneth Malmberg, Division
of Stationary Source Enforcement, U.S. Environmental Protection Agency.
December 1976.
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24. Review of Concurrent Mass Emissions and Opacity Measurements for Coal-
Burning Utility and Industrial Boilers, EPA-600/7-80—062. March 1980.
SELECTED PAPERS
1. Reactive Plumes - Sampling and Opacity Concerns for Cement Kilns,
Chadbourne, J. and R. Brown. Presented at the 73rd Annual APCA Meeting,
Montreal, Canada. June 22—27, 1980.
2. Correlation Between Light Attenuation and Particulate Concentration of
a Coal—Fired Power Plant Emission, Conner, W. and N. White. Atmospheric
Environment , Vol. 15, No. 6, pp. 939—944. 1981.
3. Smoke-Stack Plumes: Their Opacity and Visual Effects, Conner, W. Pre-
sented at the Symposium on Plumes and Visibility: Measurements and Model
Components, Grand Canyon. November 10—14, 1980. Sponsored by the U.S.
Environmental Protection Agency.
4. Modeling Smoke Plume Opacity from Particulate Control Equipment, Ensor, D.,
Cowen, S. and Sparks, L. Presented at the Third Symposium on the Transfer
and Utilization of Particulate Control Technology, Orlando, Florida.
March 9—12, 1981. Sponsored by the U.S. Environmental Protection Agency.
5. Tethered Balloon Plume Sampling of a Portland Cement Plant, Armstrong, U.
and Sparks, L. Presented at the Third Symposium on the Transfer and
Utilization of Particulate Control Technology, Orlando, Florida. March
9—12, 1981. Sponsored by the U.S. Environmental Protection Agency.
6. Survey of State and Local Air Control Agency Opacity Regulations and
Procedures. Contract No. 68—01—5110, Task Order No. 14. Division of
Stationary Source Enforcement, U.S. Environmental Protection Agency.
November 1980.
7. Legal and Administrative Guidelines and Policies for Visible Emissions.
Reference Material Prepared by the Division of Stationary Source Enforce-
ment, U.S. Environmental Protection Agency, for the Department of Justice
Legal Staff Seminar on Stationary Source Compliance Test Methods. Sep-
tember 22—23, 1981.
8. Visible Emissions Concepts and Special Problems. Reference Material
Prepared by the Division of Stationary Source Enforcement, U.S. Environ-
mental Protection Agency, for the Department of Justice Legal Staff
Seminar on Stationary Source Compliance Test Methods. September 22—23,
1981.
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