P.1 

OAR Box 1115 

Prepped by Ryan Dugan 

Document Number: 

86) I I-A-18 

Docket Number: 

A-84-22 

Printed 4/18/2008 10:52:09 AM Sheet 86 of 94 
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&$&*' B~ ^ 

United States 

Environmental Protection 

Agency 

Environmental Monitoring Systems 

Laboratory 

Research Triangle Park NC 27711 

Research and Development EPA-600/4-77-C27b Feb. 1984 

Quality Assurance 

Handbook for 

Air Pollution 

Measurement 

Systems: Volume III. 

Stationary Source 

Specific Methods 

Addition Section 3.12 
P.3 

April 1983 1 

x

e

,EPA 

United States 

Environmental Protection 

Agency 

Section 3.12.0 

Environmental Monitoring Systems 

Laboratory 

Research Triangle Park NC 27711 

Research and Development EPA-600/4-77-027b Feb. 1S84 

Section 3.12 

Method 9—Visible 

Determination of the 

Opacity of Emissions from 

Stationary Sources 

Outline 

Section 

Summary 

Method Highlights 

Method Description 

1. Certification and Training of 

Observers 

2. Procurement of Apparatus and 

Supplies 

3. Preobservation Operations 

4. On-Site Field Observations 

5. Postobservation Operations 

6. Calculations 

7. Auditing Procedures 

8. Reference Method 

9. References and Bibliography 

10. Data Forms 

Documentation 

3.12.0 

3.12.0 

3.12.1 

3.12.2 

3.12.3 

3.12.4 

3.12.5 

3.12.6 

3.12.7 

3.12.8 

3.12.9 

3.12.10 

Number 

of Pages 

2 

2 

5 

2 

2 

18 

2 

7 

2 

5 

1 

9 

Summary 

Many stationary sources discharge 

plume-shaped visible emissions into 

the atmosphere. Method 9 (EPA 

Reference Method) is used to 

determine the opacity of this plume by 

qualified observers. The method 

includes procedures for the training 

and certification of observers and 

procedures to be used by these 

observers in the field to determine 

plume opacity. This section of the 

Quality Assurance (QA) Handbook 

primarily concerns procedures used by 

the observers. Only Section 3.12.1 

reviews the training and certification 

procedures, which are described in 

Reference 1. 

The appearance of a plume as 

viewed by an observer depends upon 

a number of variables, some of which 

may be controllable and some of 

which may not be controllable in the 

field. Variables which can be 

controlled to an extent to which they 

no longer exert a significant influence 

upon plume appearance include: 

angle of the observer with respect to 

the plume; angle of the observer with 

respect to the sun; point of 

observation of attached and detached 

steam plumes and angle of the 

observer with respect to a plume 

emitted from a rectangular stack with 

a large length to width ratio. The 
P.4 

Section 3.12.0 April 1983 

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 tht 

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. Research studies 

of plume opacity 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 zero as the color and 

luminescence contrast decrease 

toward zero. As a result, significant 

negative bias and negative errors can 

be made when a plume is viewed 

under less contrasting conditions. A 

negative bias decreases rather than 

increases the possibility that a plant 

operator will be cited for a violation of 

opacity standards due to observer 

error. 

Method 9 is applicable for the 

determination of the opacity of 

emissions from stationary sources 

pursuant to-60.11(b). Studies have 

been undertaken to determine the 

magnitude of positive errors that 

qualified observers can make while 

reading plumes under contrasting 

conditions and using the procedures 

specified in Method 9. The results of 

these studies, which involve a total of 

769 sets of 25 readings each, are as 

follows: 

1. In the case of black plumes, 100 

percent of the sets were read 

with positive error of less than 

7.5 percent opacity; 99 percent 

were read with a positive error of 

less than 5 percent opacity. 

2. In the case of white plumes, 99 

percent of the sets were read 

with a positive error (higher 

values) of less than 7.5 percent 

opacity; 95 percent were read 

with a positive error of less than 

5 percent opacity. 

j The positive observational error 

(associated with an average of twenty-

/five readings is therefore established. 

/The accuracy of the method must be 

taken into account when determining 

possible violations of applicable 

• opacity standards. 

Note: Proper application of Method 

9 by control agency personnel in 

determining the compliance status of 

sources subject to opacity standards 

often involves a number of 

administrative and technical 

procedural steps not specifically 

addressed in the Federal Register 

method. Experience has shown these 

steps are necessary to lay a proper 

foundation for any subsequent 

enforcement action. To clearly 

delineate items that are EPA 

procedural policy and requirements of 

the Method 9 from additional quality 

assurance procedures, a wording 

scheme was developed. All of 

Sections 3.12.1, 3.12.2, 3.12.3, 

3.12.6, and 3.12.7 are suggested 

quality assurance procedures except 

where noted as EPA policy or Federal 

Register citings. Section 3.12.4 notes 

EPA requirements with directive 

statements using words such as shall, 

should, and must. QA procedures are 

noted either with suggestive 

statements using words such as 

recommended, suggested, and 

beneficial or by stating that the entire 

subsection is recommended. The use 

of these QA procedures should 

provide a more consistent program, 

improved observer effectiveness and 

efficiency, and improved data 

documentation. 

Method Highlights 

Section 3.12 primarily describes 

Method 9 procedures for the 

determination of plume opacity. 

Seaion 3.12.1 briefly reviews the 

quality assurance procedures to be 

used in the observer training and 

certification procedures described in 

detail in Reference 1. The remaining 

sections describe the field procedures. 

Section 3.12.10 provides blank data 

forms recommended for use by the 

observer and other personnel, as 

required. Partially completed forms, 

are included in Sections 3.12.1 

through 3.12.7 of the Method 

Description. Each form in Seaion 

3.12.10 has a subtitle (e.g.. Method 9, 

Figure 2.1) to allow easy reference to 

the corresponding completed form. 

The following paragraphs present a 

brief discussion of the contents of this 

section of the QA Handbook. 

1. Certification and Training of 

Observers The primary purpose of this 

section is to provide a brief summary 

of the certification and training 

procedures described in Reference 1. 

It includes a definition and a brief 

history of opacity, and it discusses 

observer training procedures and 

certification and recertification of 

observers. 

2. Procurement of Apparatus and 

Supplies Section 3.12.2 presents 

specifications criteria and design 

features to aid the procurement of 

useful equipment that would provide 

good quality visible emissions data. 

The following are some recommended 

equipment items not specifically 

required by Method 9: watch, 

compass, range finder, Abney level or 

clinometer, sling psychrometer, 

binoculars, camera, safety equipment, 

clipboard, and accessories. Table 2.1 

summarizes the quality assurance 

aspects of equipment procurement. 

3. Preobservation Operations 

Seaion 3.12.3 summarizes the 

preobservation activities: gathering 

facility information, providing prior 

notification, establishing protocol, and 

performing equipment checks. Table 

3.1 summarizes these procedures. 

4. On-Site Field Observations 

Section 3.12.4 contains detailed 

procedures for determining the visible 

emissions (VE). This section not only 

includes the recommended 

procedures for performing the 

perimeter survey, plant entry, and VE 

determination; it also contains a 

subseaion on special observation 

problems. This subsection explains 

how to take VE readings under less 

than ideal conditions (e.g., when the 

observer position is restriaed). The 

main feature of this section is the 

presentation of detailed instructions 

on how to complete the recommended 

VE data form, and examples of 

completed forms. 

5. Postobservation Operations 

Seaion 3.12.5 presents a brief 

discussion concerning the data 

reporting procedures, data summary, 

data validation, and equipment check. 

Section 3.12.6 contains a discussion 

of the calculations required for 

completing the data forms and 

reports. It also includes procedures for 

calculating the path length through 

the plume and for predicting steam 

plume formation by use of a 

psychrometric chart and pertinent 

measurements. 

6. Auditing Procedures Section 

3.12.7 recommends performance and 

system audits for use with field VE 

determinations. The two performance 
P.5 

April 1 983 Section 3.12.1 

1.0 Certification and Training of Observers 

The purpose of this section is to 

summarize the content of the QA 

manual for VE training programs.' 

Since the observer must be properly 

certified or a qualified VE reader in 

order to have his/her opacity reading 

accepted, it is important that he/she 

fully understand this phase of his/her 

training. 

1.1 Definition and Brief 

History of Opacity 

The VE evaluation system evolved 

from tne concept developed by 

Maximillian Ringelmann in the late 

1800's. in which a chart wit h 

calibrated black grids on a white 

background was used to measure 

black smoke emissions from coal-fired 

boilers. The Ringelmann Chart was 

adopted by the U.S. Bureau of Mines 

in the early 1900's and was used 

extensively in efforts to assess and 

control emissions. In the early 1950's, 

the Ringelmann concept was 

expanded to other colors of smoke by 

the introduction of the concept of 

"equivalent opacity." 

The Federal government has 

discontinued the use of Ringelmann 

numbers in EPA Method 9 procedures 

for New Source Performance 

Standards (NSPS). Current procedures 

are based solely on opacity. Although 

some State regulations still specify 

the use of the Ringelmann Chart to 

evaluate black and gray plumes, the 

general trend is toward reading all 

emissions in percent opacity. 

In practice, the evaluation of opacity 

by the human eye is a complex 

phenomenon and is not completely 

understood. However, it is wel l 

documented that visible emissions 

can be assessed accurately and with 

good reproducibility by properly 

trained/certified observers. 

The relationships between light 

transmittance, plume opacity, 

Ringlemann number, and optical 

density are presented in Table 1.1. A 

literal definition of plume opacity is 

the degree to which the transmission 

of light is reduced or the degree to 

which visibility of a background as 

viewed through the diameter of a 

plume is reduced. In terms of physical 

optics, opacity is dependent upon 

transmittance (l/l 0 ) through the 

plume, where l 0 is the incident light 

flux and I is the light flux leaving the 

plume along the same light path. 

Percent opacity is defined as follows: 

Percent opacity = (1-l/l 0 ) x 100. 

Many factors influence plume 

opacity readings: particle density, 

particle refractive index, particle size 

distribution, particle color, plume 

background, path length, distance and 

relative elevation to stack exit, sun 

angle, and lighting conditions. Particle 

size is particularly significant; 

particles decrease light transmission 

by both scattering and direct 

absorption. Thus, particles with 

diameters approximately equal to the 

wavelength of visible light (0.4 to 0.7 

pm) have the greatest scattering effect 

and cause the highest opacity. 

1.2 Training of Observer 

Field inspectors and observers are 

required to maintain their opacity 

evaluation skills by periodically 

participating in a rigorous VE 

certification program. Accordingly, 

EPA's Stationary Source Compliance 

Division (SSCD) and Environmental 

Monitoring Systems Laboratory 

(EMSL) have provided the QA training 

document' to individuals who conduct 

VE training and certification programs. 

This section summarizes the training 

program. 

1.2.1 Frequency of Training Sessions 

— Certification schools should be 

scheduled at least twice per year 

since Method 9 requires a semiannual 

recertification. It is highly 

recommended that training be an 

Table 1.1. 

Light Optical density 

transmission. % units 

Comparison of Light. Extinction Terms 

Plume 

opacity. % 

Ring9lmann 

number 

0 

20 

40 

60 

80 

100 

N/A" 

0.70 

0 40 

0.22 

0.10 

0.00 

100 

80 

60 

40 

20 

0 

5 

4 

3 

2 

1 

0 

*N/A = not applicable. 

integral part of the certification 

program. A spring/fal l schedule is 

preferable because of weather 

considerations. Certifying previous 

graduates while the smoke school is 

in session is more efficient and less 

costly than scheduling a separate 

session. 

1.2.2 Classroom Training — The 

training is accomplished most 

effectively by holding an intensive 1-

or 2-day classroom lecture/discussion 

session. Although this training is not 

required, it is highly recommended for 

the following reasons: 

1. Increases the VE observer's 

knowledge and confidence for the 

day-to-day field practice and 

application. 

2. Reduces training time required 

to achieve certification. 

3. Trains the smoke reader in the 

proper recording and 

presentation of data that wil l 

withstand the rigors of litigation 

and strengthens an agency's 

compliance and enforcement 

program. 

4. Provides a forum for the periodic 

exchange of technical ideas and 

information. 

Some states require classroom 

training for initial certification only. It 

is recommended, however, that 

observers attend the classroom 

training at 3-year intervals to review 

proper field observation techniques 

and method changes and to 

participate in the exchange of ideas 

and new information. 

1.2.3 Lecture Material — Example 

lecture material for a thorough 

training program is presented in 

Section 3.1 and Appendix A of 

Reference 1. A typical six-lecture 

classroom training program consists 

of the following: 

Lecture 1—Background, principles, 

and theory of opacity. 

Lecture 2—Sources of VE's. 

presented by someone 

thoroughly familiar with 

source conditions, 

related particle 

characteristics, and 

opacity reading 

procedures and 

problems. 

Lecture 3—Proper procedures for 

conducting field 

observations under a 

variety of conditions. 
P.6 

jS1 \^A 

Section 3.12.1 A. 

Lecture 4—Influence and impact of 

meteorology on plume 

, behavior. 

Lecture 5—Legal aspects of VE and 

opacity measurements. 

Lecture 6—Actual 

observation/testing 

procedures. 

1.2.4 Training Equipment — An 

integral part of the training program is 

the design and operation of the smoke 

f

r"aToTand its associated 

imissometer, as specified in 

tod 9 (reproduced in Seaion 

-8"_8tjcri a program is essential 

because proper observer certification 

^ cannot take place without the proper 

\V" equipment. Section 4 of Reference 1 

- s presents performance specification^ 

•"*' ^y and operating procedures for smoke 

fji,J* generators which, if followed under a 

\ good QAjPFagram, will ensure 

nationwtdVumformity and consistency 

with) Method 9/fcriteria. 

Tne^desj^rfand operation of the 

smoke generator has evolved 

significantly since the mid-1960s. 

The basic components of the smoke 

generator now include: 

1. Black and white smoke 

generating units, 

2. Fan and stack, 

3. Transmissometer system, and 

4. Control panel and strip chart 

recorder. 

Table 1.2 lists the design and 

performance specifications for the 

smoke generator. It must generate 

smoke with an opacity range of 0 to 

100 percent and be sufficiently 

accurate to allow the operator to 

control and stabilize the opacity of the 

smoke. It is recommended that the 

generator also achieve and hold 

opacities in 5 percent increments at 

±2 percent for a minimum of 5 s. 

White smoke is produced by 

dispensing, at regulated rates. No. 2 

fuel oil into the propane-heated 

vaporization chamber. The opacity 

varies in proportion to the volume of 

fuel oil vaporized and is regulated by 

adjusting the flow of fuel oil. 

Black smoke is produced by the 

incomplete combustion of toluene in 

comt 

J i u-T' 

cWApril198 

•JL fc 

X—Si Wotv / r-\ 

the double-wall combustion chamber. 

The toluene flowrate is also controlled 

by valves and flowmeters. 

1.2.5 Equipment Calibration 

Procedures/- Detailed calibration 

proceduraj^are included in a QA 

procedures manual for VE training 

programs.1 The generator transmissometers rm«s*t be calibrated every six 

months or after each repair. The 

National Bureau of Standards (NBS) 

traceable standards (optical filters) for 

linearity response are available from 

Quality Assurance Division, 

Environmental Monitoring Systems 

Laboratory, U.S. EPA, Research 

Triangle Park, North Carolina 27711. 

It is strongly recommended that the 

calibration be performed before and 

after each certification course to 

ascertain whether any significant drift 

or deviation has occurred during the 

training period. The "zero and span" 

check must be repeated before and 

after each test run. If the drift exceeds 

1 percent opacity after a typical 30-

min test run, the instrument must be 

corrected to 0 and 100 percent of 

scale before resuming the testing. 

All of the smoke generator 

performance verification procedures 

(e.g., repair and maintenance work, 

spectral response checks, calibration 

check, and response time checks) 

should be documented in writing and 

dated; a bound logbook is highly 

recommended. These records become 

part of the permanent files on the VE 

training program. 

1.2.6 Setup. Operating, and 

Shutdown Procedures — Detailed 

procedures and a parts list are given 

in Section 4.4 of Reference 1. 

1.2.7 Storage and Maintenance of 

the Smoke Generator — Proper 

storage and maintenance procedures 

are essential for smoke generators to 

increase their useful operating life 

and to provide reliability. 

1.2.8 Common Probtems. Hazards, 

and Corrective Actions — The 

generator has hot surfaces that can 

cause serious burns. It is 

Tabla 1.2. Smoke Generator Design and Performance Specifications 

Parameter Performance 

Light source 

Photocell spectral response 

Angle of view 

Angle of projection 

Calibration error 

Zero and span drift 

Response time 

Incandescent lamp operated at ±5% of 

nominal rated voltage 

Photopic (daylight spectral response 

of the human eye) 

15° maximum total angle 

15° maximum total angle 

±3% opacity, maximum 

±1% opacity. 30 min 

5 s, maximum 

we 

recommended that attendees be 

advised to stay away from the 

generator during training and test 

runs. It is also recommended that gas 

and fuel lines be correaly checked for 

leaks prior to each use of the 

generator to prevent fire and explosive 

hazards to the operator and nearby 

attendees. 

Occasional breakdowns or 

malfunctions of the generator usually 

occur at the most inopportune times. 

The problem must be diagnosed and 

repairs made expeditiously to provide 

the proper training and maintain the 

interest of the course attendees. 

Some common malfunctions are listed 

in Section 4 of the QA training 

manual.'. 

1.3 Certification of Observer 

This seaion summarizes the 

certification part of the training 

program. The fi*st part of the 

certification program is to acclimate 

the smoke readers. The following 

procedure is recommended. Both 

black and white plumes are produced 

at certain levels, and during this 

production, the opacity values are 

announced. After some standards 

exposure, four plumes are presented 

to the trainee for evaluation. The 

correct values of the four plumes are 

announced to provide the trainee with 

immediate feedback. The majority of 

the trainees should be ready to take 

the test after a few sets. Certification 

runs are made in blocks of 50 

readings (25 black smoke and 25 

white smoke). The trainees who 

successfully meet the criteria receive 

a letter of certification and a copy of 

their qualification form. The school 

retains the original of the qualification 

form for a minimum of three years, to 

be available for any legal proceedings 

that might occur. According to Method 

9, certification is valid for a period of 

only six months. Neither certification 

or recertification procedures require 

the observer to attend the lecture 

program; however, it is recommended 

that the observer attend the series 

during initial certification and 

thereafter every three years. It is also 

recommended that all persons unable 

to pass after 10 qualification runs, be 

provided additional training before 

allowing qualification runs to be 

made. 

Test forms vary greatly because of 

the specific needs and experiences of 

each agency. Figure 11 illustrates 

one suggested form. The form should 

be printed on two-copy paper, the 

original for the official file and the 

carbon copy for the trainee to grade 

after each certification run. The test 
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April 1983 

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Section 3.12.1 

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90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

35 

95 

Devia 

Error 

mn 

mn 

mn 

mn 

mn 

mn 

mn 

mn 

mn 

mn 

mn 

mn 

mn 

mn 

mn 

mn 

mn 

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mn 

mn 

mo 

mn 

mn 
' '

' W II l^«pf..*l l|-f"TT-

P.8 

April 1983 Sectio

n 3.12.1 

form must be filled in completely. 

Certification requires that both of the 

following criteria be satisfied: 

1. No reading may be in error by 

more than 15 percent opacity. 

2. The average [absolute] error 

must not exceed 7 5 percent for 

either set of 25 white or 25 black 

smoke readings. The certification 

runs may be repeated as often as 

necessary. However, it is recom-

mended that all persons who 

have not passed after ten certi-

fication runs be given addi-

tional training prior to conducting 

additional certification runs. 

The detailed testing and grading 

procedures required to ensure a valid 

test are outlined in Section 5 of the 

QA training manual.' The Agency 

should maintain a bound logbook, 

arranged by training session, for at 

least three years, as evidence that the 

observer has been certified as a 

qualified VE evaluator by a recognized 

smoke training and certification group. 

Each trainee who successfully meets 

the Method 9 criteria receives a letter 

of certification and a copy of his/her 

qualification form. This letter includes 

the date of expiration. 

2. The difference of the average 

value between observers should 

not exceed 10 percent. 

1.6 Smoke School 

Certification Quality 

A'Sisiaramce Program It is recommended that any 

gov,ernment< agency planning to 

devtetop a smoke school certification 

program obtain a copy of the 

"Recommended Quality Assurance 

TeiUvraiques and Procedures for Visible 

Errlssion Training Programs."' Table 

LS^contains an activity matrix for 

certification and training of observers. 

1.4 Recertification 

Method 9 requires an individual to 

be recertified every six months. 

1.5 In-the-Field Training 

After the observer's initial 

certification, it is recommended that a 

senior observer accompany the new 

observer on a field observation trip 

and that both individuals 

simultaneously record (using the 

same time piece) their opacity 

readings as a QA check (see Section 

3.12.7). A comparison of these 

readings will indicate any problems 

the new observer might have in 

conducting observations under field 

conditions. A significant discrepancy 

between the readings of the two 

observers, in individual or average 

values, indicates the need for further 

in-field training and continuance of 

the senior observer (not necessarily 

the same one) QA check. After 

satisfactory checks have been made 

on two consecutive field observations, 

the new observer can confidently 

conduct inspections without a senior 

observer. The suggested standard for 

a satisfactory check for 6-min 

(minimum) of consecutive readings is: 

1 No difference in individual 

readings should exceed 20 

percent. 
P.9 

• 

Section 3.12.1 5 April 1983 

Table 1.3. Activity Matrix for Certification and Training of Observers 

' Activity 

Classroom 

training of 

observer 

Smoke generator 

Setup, operating. 

and shutdown 

procedures 

Storage and 

maintenance 

Transmissometer 

Design and performance specifications 

Calibration 

Zero and span 

Certification of 

observer 

Recertification 

In-the-field training 

Acceptance 

limits 

Classroom training per Ref. 1 

(suggested) 

Should be able 

to generate 

smoke with an 

opacity range of 

0 to 100%: hold 

opacities ±2% 

for at least 5 s 

Adherence to 

procedures in 

Ref. 1 

As above 

Specifications in 

Table 1.2 

—3% opacity 

maximum 

Opacity drift 

<1% after a 

typical 30-min 

test run 

No reading must 

be in error by 

more than 15% 

and average 

absolute error 

must not exceed 

7.5% for either 

white or black 

smoke readings 

As above 

No reading in 

error by more 

than 20% difference and 

average absolute 

error should 

not exceed 

10% difference 

during the field 

observation 

Frequency and 

method of 

measurement 

Initially and 

every 3 years 

Before each 

certification test 

run: use method 

in Ref. 1 

Each test run 

As above 

Upon receipt. 

repair, and at 

6-mo intervals 

use method in 

Ref. 1 

Every 6 mo or 

after repair, 

before and after 

each certification course is 

recommended: 

use method in 

Ref. 1 

As above 

Take smoke 

reading test until 

a successful test 

has been completed 

Every 6 mo take 

a smoke reading 

test until a 

successful test 

has been 

completed 

Checks are made 

on the first two 

field observations subsequent to the 

initial certification: comparison 

is made between 

new certified 

observer and an 

experienced 

observer 

Action if 

requirements 

are not met 

Review training 

procedures per 

Ref. 1 

Adjust and make 

repeat check of 

operation 

Review procedures 

• 

As above 

Adjust and 

repeat specification check until 

specifications 

are met 

Adjust and 

recalibrate until 

acceptance 

limits are met 

Instruments 

must be corrected to 0 and 

100% before 

testing is 

resumed 

Retake test until 

successful completion 

As above 

Continue comparisons until 

acceptance 

limits are met 

during two field 

observations 

• 
P.10 

April 1983 Section 3.12.2 

2.0 Procurement of Apparatus and Supplies 

Method 9 does not specifically 

require any equipment or supplies. 

Therefore, this entire section includes 

quality assurance procedures that are 

recommended to assist the observer 

in documenting data. Nevertheless, 

this section provides specifications 

criteria or design features, as 

applicable, to aid in the selection of 

equipment that may be useful in 

collecting VE data. Procedures and 

limits for acceptance checks are also 

provided. During the procurement of 

equipment and supplies, it is 

suggested that a procurement log 

(Figure 2.1) be used to record the 

descriptive title of the equipment, the 

identification number (if applicable), 

and results of any acceptance checks. 

Table 2.1 at the end of this seaion 

contains a summary.of the quality 

assurance activities for procurement 

and acceptance of apparatus and 

supplies. 

2.1 Stopwatch 

A watch is used to time the 15-

second intervals between opacity 

readings. The watch should provide a 

continuous display of time to the 

nearest second. 

2.2 Compass 

A compass is useful for determining 

the direaion of the emission point 

from the spot where the VE observer 

stands and for determining the wind 

direction at the source. For accurate 

readings, the compass should be 

magnetic with resolution better than 

10°. It is suggested that the compass 

be jewel-mounted and liquid-filled to 

dampen the needle swing: map 

reading compasses are excellent for 

this purpose. 

2.3 Range Finder 

A range finder is used to measure 

the observer's distance from the 

emission point and should be capable 

of determining distances to 1000 

meters with an accuracy of ±10 

percent. The accuracy of the range 

finder should be checked upon receipt 

and periodically thereafter with 

targets at known distances of 

approximately 500 meters and 1000 

meters. 

Item description Quantity 

Purchase 

order 

number Vendor 

Date 

Ordered Received Cost Disposition Comments 

51of>ujakdr\ z 2.5076 Fisher 

Scientific 

S/'/BX *//?/< 'Z* *5Lty checkedready 

•to use,. 

Figure 2.1. Example of a procurement log. 
P.11 

Section 3.12.2 April 1983 

2.4 Abney Level or 

Clineometer 

An Abney level is a device for 

determining the vertical viewing angle. 

For visible emission observation 

purposes, it should measure within 5 

degrees: The accuracy should be 

tested by placing the level flat on a 

table that has been previously leveled 

with a referring level and checking it 

at a 45° angle by placing it on a 45° 

inclined plane constructed with the 

plane as the hypotenuse of a right 

triangle with equal base and height. 

2.5 Sling Psychrometer 

The sling psychrometer is used in 

cases where it is suspected that the 

atmospheric conditions will promote 

the formation of a steam plume (see 

Subsection 6.3). The psychrometer 

should consist of two thermometers, 

accurate to 1/2°C, mounted on a 

sturdy assembly whereby the 

thermometers may be swung rapidly 

in the air. One thermometer should be 

fitted with a wettable cotton wick tube 

on the bulb. Thermometer accuracy 

should be checked by placing the 

bulbs in a fresh ice water bath at 0°C. 

2.6 Binoculars 

It is recommended that the observer 

obtain binoculars preferably with a 

magnification of at least 8 x 50 or 10 

x 50. The binoculars should have 

color-corrected coated lenses and a 

rectilinear field of view. Color 

correction can be checked by viewing 

a black and white pattern such as a 

Ringelmann card at a distance greater 

than 50 ft; no color rings or bands 

should be evident, only black and 

white. The rectijinear field of view can 

be tested by viewing a brick wall at a 

distance greater than 50 ft. There 

should be no distortion of the brick 

pattern as the field of view is 

changed. The binoculars are helpful 

for identifying stacks, searching the 

area for emissions and aid in 

characterizing behavior and 

composition of plume. 

2.7 Camera and Accessories 

A camera is often used in VE 

observations to document the 

emissions before and after the actual 

opacity determination. A 35-mm 

camera with thrcjgh-the-lens light 

metering is recommended for this 

purpose. Useful accessories include a 

"macro" lens or a 250-mm to 350-

mm telephoto lens, and a 6-diopter 

closeup lens (for photographing 

logbook and evidence of particulate 

deposition). A photo logbook is 

necessary for proper documentation. 

and the observer should always be 

sure to purchase enough fresh color 

negative film (ASA 100 

recommended) for his/her purposes. 

2.8 Clipboard and 

Accessories 

For documenting the visible 

emission observation, the observer 

should have a 10 in. x 12 in. masonite 

or metal clipboard, several black ballpoint pens (medium point), a large 

rubber band, and a sufficient number 

of visible emission observation forms. 

2.9 Safety Equipment 

The following safety equipment, 

which should be approved by the 

Occupational Safety and Health 

Association (OSHA), is recommended 

for the VE observer: 

• Hard hat in high-visibility yellow 

or orange 

• Safety glasses, goggles, or eye 

shields 

• Ear protectors 

• Safety shoes (steel-toed for 

general industrial use). 

Specially insulated safety shoes are 

necessary in certain areas, such as 

the top of coke ovens. 

Table 2.1. Activity Matrix for Procurement of Recommended Equipment and 

Supplies 

Equipment Acceptance limits 

Frequency and 

method of 

measurement 

Action if 

requirements 

are not met 

Watch 

Compass 

Range finder 

Abney level 

Sling psychrometer 

Binoculars 

Camera 

Clipboard/ 

accessories/forms 

Safety equipment 

Continuous 

display 

Magnetic with 

10° resolution 

Accuracy of 

±10% over distances to 1000 m 

Accurate within 

±5° 

Each thermometer accurate 

to 1/2°C (1°F) 

Magnification of 

8x50orl0x50. 

color-corrected 

coated lenses 

and a rectilinear 

field of view 

35-mm camera 

with throughthe-lens light 

metering 

10 in. by 12 in. 

clipboard: black 

ball-point pens: 

VE observation 

forms 

Hardhat—yellow 

or orange, safety 

glasses and 

shoes, ear 

protectors 

Check upon 

receipt 

Check upon 

receipt 

Check upon 

receipt and 

quarterly with 

targets at known 

distances of 

about 500mand 

1000 m 

Check at 0° and 

45° 

Check thermometer accuracy 

with ice water 

bath at 0°C 

Check upon 

receipt by viewing selected 

objects 

Check quality of 

photos on 

receipt and after 

processing film 

Check supplies 

periodically 

Check supply of 

safety equipment periodically 

Return to 

supplier 

Return to 

supplier 

Adjust or 

return to 

supplier 

Same as above 

Repair or return 

to supplier 

Return to 

supplier 

Return to 

supplier for 

repair 

Replenish 

supplies 

Maintain equipment availability 
P.12 

April 1983 Section 3.12.3 

3.0 Preobservation Operations 

The following procedures are not 

required by Method 9 but are 

recommended in order to provide 

more consistent data collection and 

better data documentation and 

verification of representative plume 

viewing conditions. Not all procedures 

are needed for every observation. 

Before making on-site VE 

determinations, the observer should 

gather the necessary facility data, 

provide prior notifications when 

applicable, establish an observation 

protocol, and check for availability of 

supplies and properly maintained 

equipment. Table 3.1 at the end of 

this section summarizes the quality 

assurance activities for preobservation 

operations. 

3.1 Gather Facility 

Information 

The observer should be thoroughly 

familiar with the source facility, 

operation, emissions, and applicable 

regulations In preparation for the onsite visit, the observer should review 

the Agency's information (in the official 

source file) on the source in question. 

The observer should: 

1. Determine the pertinent people 

to be contacted. 

2. Become familiar with the 

processes and operations at the 

facility and identify those 

facilities to be observed. 

3. Review the permit conditions, 

requirements, and recent 

applications. 

4. Determine applicable emission 

regulations. 

5. Identify all operating air 

pollution control equipment, 

emission points, and types and 

quantities of emissions. 

6. Review history of previous 

inspections, source test results, 

and complaints. 

7. Check the file to become 

familiar with (or review) plant 

layout and possible observation 

sites. 

8. Determine normal production 

and operation rates. 

9. Identify unique problems and 

conditions that may be 

encountered (e.g., steam 

plume). 

10. Discuss with attorney if case 

development is expected. 

11. Obtain a copy of the facility 

map with labeled emission 

points, profile drawings, and 

photographs, if available. A 

facility map is very helpful 

during inspection and should be 

a required item for every 

Agency source file. The map 

makes it easier for the observer 

to identify point sources and 

activities, and it may be used to 

mark any emission points that 

have been added or modified. 

12. If an operating permit exists, 

obtain a copy because it may 

contain the VE limits for each 

point source and any special 

operating requirements. 

13. Determine the status of the 

source with respect to any 

variance or exemption from the 

Agency's rules and regulations. 

Observation may not berequired if 

the source has a variance or is 

exempt from the regulations. 

14. Review plant terminology. 

15. Use references such as facility 

maps and previous inspection 

reports to determine if the 

viewing position is restricted 

because of buildings or natural 

barriers. If the viewing position 

requires observations to be 

taken at a particular time of day 

(morning or evening) because 

of sun angle, consider this 

when planning the inspection. 

16. Determine the possibility of 

water vapor in the plume 

condensing (see Section 

3.12.6). This determination may 

prevent a wasted trip to the 

facility on days when a 

persistent water droplet plume 

is anticipated because of 

adverse ambient conditions. 

Note: If the observer is not familiar 

with the type of facility or operation, 

he/she should consult available 

reference material and inspection 

manuals on the source dategory. 

3.2 Prior Notification 

The usual procedure is to make the 

VE determination without prior 

notification unless the plant must be 

entered first to obtain a good view of 

the emission point of interest. 

However, this procedure is not always 

possible, especially in remote 

locations, when operations are 

intermittent, or when specific 

personnel must be present or 

contacted. Determining VE for 

compliance with State Implementation 

Plan (SIP) or NSPS opacity regulations 

requires on-site observations during 

conditions of typical or normal 

maximum operations. If the facility is 

notified of the time of this evaluation, 

some operating conditions may be 

altered. If this situation appears likely, 

it is EPA's policy not to give prior 

notification. EPA is obligated to notify 

State/local agencies of inspections 

and generally prefers to invite the 

applicable agency to participate. The 

observer should notify the affected 

facility and control agencie? as soon 

as practical following any official 

opacity readings. 

3.3 Establish Observation 

Protocol 

Based on information collected 

under Section 3.1 and any prior 

experience with the source, an 

observation protocol should be 

established. First, the observer 

should determine whether one, two, 

or more observers will be required. 

For example, two observers may be 

required to simultaneously make the 

VE determination and gather other 

on-site data (e.g., take photographs, 

draw a new modified facility map if 

one is not available from the plant or 

gather other needed plant information). 

In certain situations where the VE 

observations must be correlated to 

process operation, the second person 

will closely monitor the process 

activity and record the exact time of 

the operating modes of interest. Only 

one observer will make the VE 

determination unless an observer 

audit is being conducted. In this case., 

the designated observer is the one 

being audited. 

The applicability of Method 9 (and 

hence the method of observation) 

should be determined. If Method 9 is 

not applicable, see Section 3.12 4, 

Special Problems. 

A written checklist regarding an 

expected walk-through of the plant 

including questions to ask plant 

officials may be helpful. 

3.4 Perform Equipment 

Checks for On-Site Use 

Be sure that the necessary 

equipment and supplies are available 

for making the VE determination and 

documenting the results. All 

equipment should be visually checked 

for damage and satisfaaory operation 

before each VE determination field 

trip. 
Section 3.12.3 April 1983 

Table 3.1. Activity Matrix for Preobservation Operations 

Frequency and 

method of 

Activity measurement 

Gather facility 

information 

Make prior 

notification 

Establish protocol 

Perform equipment 

check 

Acceptance 

limits 

Action if 

requirements 

are not met 

Obtain necessary facility data, 

Subsec 3.1 

Make VE determination without prior notification except as 

stated in Subsec 

3.2: EPA should 

notify State/ 

local agencies 

and invite 

participation 

Prepare observation protocol. 

Subsec 3.3 

All equipment/ 

supplies available and in satisfactory working order 

Check for completeness of data 

Check the protocol for notification before 

each on-site visit 

and revise the 

protocol as 

necessary 

Check before 

on-site visit 

Same as above 

Obtain missing 

data before onsite visit, if 

possible 

Make required 

notifications 

Complete or 

prepare protocol 

as required 

Replace or 

adjust 

equipment 
P.14 

April 1983 Section 3.12.4 

4.0 On-Site Field Observations 

This section describes field 

observation procedures, including 

perimeter survey, plant entry, VE 

determination, and special observation 

problems. The latter subsection 

supplements the subsection on VE 

determination by providing some 

information on how to take VE 

readings when unfavorable field 

conditions prevent the use of the 

procedure described in Subsection 4.3 

(e.g., when the emissions are 

intermittent or the observer position is 

restricted). The QA activities are 

summarized in Table 4.2 at the end of 

this section. 

4.1 Perimeter Survey 

Before and after the VE 

determination, it is strongly 

recommended that the observer make 

a perimeter survey of the area 

surrounding (1) the point of 

observation and (2) the emission point 

on which the determination is being 

made. Such a survey also may be 

made during the VE determination, if 

warranted. 

A perimeter survey can be useful 

in determining the presence of other 

factors that could affea the opacity 

readings. For example, the 

representativeness of the VE readings 

for a given emission point could be 

questioned unless data is available to 

show that the observer excluded 

emissions related to material 

stockpiling, open burning, and 

ambient condensed water vapor in 

adjoining areas of the plant. It is vital 

that the observer be as aware as 

much as possible of extenuating 

conditions. The perimeter survey is 

made to document these conditions. 

Common sense should be used in 

determining the need and extent of 

the survey; in some cases (e.g., a 

single 350-foot stack) a perimeter 

survey is not vital. 

Perimeter surveys can be made 

from either outside or inside the plant 

properly, or both. This decision would 

depend on whether the VE 

observations are made from inside or 

outside of the plant, whether the 

observer actually gains entry tc the 

plant premises, and whether the plant 

is sufficiently visible from outside the 

premises to make a reasonable 

survey. It is suggested that during the 

survey the observer should note such 

factors as: 

1. Other stacks and emission points 

whose visible emissions might 

interfere with opacity readings. 

2. Fugitive emissions that result 

from product or waste storage 

piles and material handling and 

may interfere with observations. 

3. Fugitive emissions that result 

from unpaved road travel and 

may interfere with observations. 

4. Water vapor emissions from 

sludge or cooling ponds. 

5. Open burning. 

6. Any unusual activities on or 

around plant premises that could 

result in nonrepresentative 

emissions or interfere with 

opacity readings. 

If deemed useful by the observer, 

photographs may be taken to 

document extenuating conditions (see 

discussion of confidentiality and the 

use of cameras in Subseaion 4.2.7). 

4.2 Plant Entry 

The following discussion presents 

the recommended plant entry 

procedures. The VE readings 

themselves should not be affeaed by 

a change in these procedures. 

However, the usefulness of the 

readings in showing a possible 

violation of the applicable standards 

may be compromised by not following 

agency procedures for entering plants. 

Depending on the location of emission 

points at the plant and the availability 

of observation points in the area 

surrounding a facility, the VE observer 

may not have to gain entry to the 

plant premises prior to making VE 

observations. It may be preferable to 

gain access after taking readings to 

check on plant process control 

equipment operating conditions or to 

complete a perimeter survey. Figure 

4.1 is an example entry checklist that 

can be used to assist the observer in 

organizing the information that could 

be used at the time of plant entry. 

To maintain a good working 

relationship with plant officials and, 

most importantly, to comply with the 

Clean Air Aa and avoid any legal 

conflia with trespass laws or the 

company's right to privacy and due 

process of law under the U.S. 

Constitution, the observer must follow 

certain procedures in gaining entry to 

the plant's private premises. In most 

cases, consent to enter (or the 

absence of express denial to enter) is 

granted by the owner or company 

official. Figure 4.1 lists the pertinent 

section of the Clean Air Act on facility 

entry as well as information on 

confidentiality of process information. 

It is recommended that the inspector 

have a copy of this information 

available in case questions are raised 

by source representatives. 

4.2.1 Entry Point — It is 

recommended that the plant premises 

be entered through the main gate or 

through the entrance designated by 

the company officials in response to 

prior notification. The observer's 

arrival will usually occur during 

normal working hours unless 

conditions contributing to excess 

opacity levels are noted at certain 

times other than normal working 

hours. If only a guard is present at the 

entrance, it is desirable for the 

observer to present the appropriate 

credentials and to suggest that the 

guard's supervisor be contaaed for 

the name of a responsible company 

official. The observer would then ask 

to speak with this official, who may be 

the owner, operator, or agent in 

charge (including the environmental 

engineer). 

4.2.2 Credentials — After 

courteously introducing 

himself/herself to the company 

official, the observer should briefly 

describe the purpose of the visit and 

present the appropriate credentials 

confirming that he/she is a lawful 

representative of the agency. Such 

credentials will naturally differ 

depending upon the agency . ' 

represented, but it is recommended 

that they include at least the 

observer's photograph, signature, 

physical description (age, height, 

weight, color of hair and eyes), and 

the authority for plant entry. Agencies 

issue credentials in several forms, 

including letters, badges, ID cards, or 

folding wallets. 

4.2.3 Purpose of Visit — When first 

meeting with a company official, the 

observer needs to be prepared to state 

succinaly the purpose of the visit, 

including the reason for the VE 

determination. Space is provided in 

the recommended form (Figure 4.1) to 

specify the exact purpose of the visit, 

and the observer can refer to this 

when talking with the company 

official. 
P.15 

Section 3.12.4 April 1983 

Source name and address 

DM'HARP PORTCAlJD CEMOJT 

Z MILES £..oF /Tr. i OrV 

koc-KY HILLS, NJ OSf/io 

Observer JuDY A. 'btAlTTi 

Agency u s eJ>A 

Date of VE observation 

Previous company contact (if applicable) AoEzOKG^- C J\£~AR.S 

Title OWAi£ £ 

Purpose of visit £/f t AublT fN5P£^-T76sJ AfHD V£ OB^6Ji\//\T/0/J; RE-QfONrAC 

OFFICE /AJSP&CTS /o°7o OF JlAJOt sooRcces fN AJJZveAf YCAfe. 

Emission points at which VE observations to be conducted — 

Ol QaRINOeK. 3-05'007-O Z OZ CAAL.-F/££.0 KV-AJ 3-05-C&7'0=> 

QAL £>£Y££S **f A^D ^AL 3-06-007-0^ 

Authority for entry (see reverse side) 

Plant safety requirements 

Si Hardhat 

23 Safety glasses 

0 Side shields (on glasses) 

O Goggles 

D Hearing protection £Afi.WFFS l/J /MAfZJcHD AfiCAS j 

Specify PfiDViDa> &' PUyJT 

Sf Safety shoes (steel-toed) 

• Insulated shoes 

D Gloves 

• Coveralls 

Bf Dust mask suggested 

• Respirator(s) 

Specify 

D Other 

Specify 

Company official contacted (on this visit) Zrf~Aj\l L-EiT-f O. CjfcAY 

Title 

a.NVlR.0NM£N7*;£- EH<q(HE£& 

Figure 4.1. Visible emission observer's plant entry checklist. 
P.16 

April 1983 Section 3.12.4 

Authority for Plant Entry: Clean Air Act. Section 114 

(a)(2) the Administrator or his authorized representative upon presentation of his credentials • 

(A) shall have a right of entry to, upon or through any premises of such person or in which any records required to be 

maintained under paragraph (1) of this section are located, and 

(B) may at reasonable times have access to, and copy of any records, inspect any monitoring equipment or methods 

required under paragraph (1), and sample any emissions which such person is required to sample under 

paragraph (1). 

(b)(1) Each State may develop and submit to the Administrator a procedure for carrying out this section in such State. If the 

Administrator finds the State procedure is adequate, he may delegate to such State any authority he has to carry out this 

section. 

(2) Nothing in this subsection shall prohibit the Administrator from carrying out this section in a State. 

(c)Any records, reports or information obtained under subsection (a) shall be available to the public except that upon a showing 

satisfactory to the Administrator by any person that records, reports, or information, or particular part thereof, (other than 

emission data) to which the Administrator has access under this section if made public would divulge methods or processes 

entitled to protection as trade secrets of such person, the Administrator shall consider such record, report, or information or 

particular portion thereof confidential in accordance with the purposes of Section 1905 of Title 18 of the United States 

concerned with carrying out this Act or when relevant in any proceeding under this Act." 

Confidential Information: Clean Air Act, Section 114 (see above) 41 Federal Register 36902. September 1, 1976 

If you believe that any of the information required to be submitted pursuant to this request is entitled to be treated as 

confidential, you may assert a claim of business confidentiality, covering all or any part of the information, by placing on (or 

attaching to) the information a cover sheet, stamped or typed legend, or other suitable notice, employing language such as 

"trade secret," "proprietary," or "company confidential." Allegedly confidential portions of otherwise nonconfidential 

information should be clearly identified. If you desire confidential treatment only until the occurrence of a certain event: the 

notice should so state. Information so covered by a claim will be disclosed by EPA only to the extent, and through the procedures, 

set forth at 40 CFR, Part 2. Subpart B (41 Federal Register 36902. September 1. 1976.) 

If no confidentiality claim accompanies this information when it is received by EPA. it may be made available to the public by 

EPA without further notice to you. 

Figure 4.1. Reverse side of form. (Continued) 

The principal purpose for an 

observer's visit to a plant will probably 

fall into one of three categories: (1) a 

VE determination is being made 

pursuant to a neutral administrative 

scheme* to verify compliance with an 

applicable SIP or NSPS, (2) a VE 

determination is being made because 

some evidence of an opacity violation 

already exists, or (3) an unscheduled 

VE determination has just been made 

from an area off the plant property. 

The statement of purpose should state 

clearly what has prompted the visit. 

At this time, the observer also 

should provide the company official 

with a copy of the opacity readings 

and ask that person to sign an 

acknowledgment of receipt of any VE 

readings made previous to entry. In 

lieu of the above, the agency should 

provide a copy within a reasonable 

time. 

4.2.4 Visitor's Agreements, Release 

of Liability (Waivers) — The observer 

should not sign a visitor's agreement, 

release of liability (waiver), holdharmless agreement, or any other 

agreement that purports to release 

•Any routine of selecting sites for observation 

that is not directed toward any company. 

the company from tort liability. 

Signing this type of release form may 

waive the rights of the observer and 

his/her employer compensation in 

event of personal injury or damages; 

the precise effect of signing an 

advance release of liability for 

negligence depends upon the laws of 

the state in which it is signed. If the 

plant official denies entry for refusal 

to sign a release form, the observer 

should proceed as described in the 

section on entry refusal. 

4.2.5 Section 114 — Section 114 of 

the Clean Air Act addresses both the 

authority for plant entry and the 

protection of trade secrets and 

confidential information. For the 

observer's reference, the applicable 

paragraphs are included on the 

reverse side of the entry checklist in 

Figure 4.1. 

4.2.6 Entry Refusal — In the event 

that an observer is refused entry by a 

plant official or that consent is 

withdrawn before the agreed-upon 

activities have been completed, the 

following procedural steps should be 

followed: 

1. Tactfully discuss the reason(s) for 

denial with the plant official; this 

is to insure that the denial 

has not been based on some sort 

of misunderstanding. Discussion 

might lead to resolution of the 

problem and the observer may be 

given consent to enter the 

premises. If resolution is beyond 

his/her authority,"the observer 

should withdraw from the 

premises and contact his/her 

supervisor to decide on a 

subsequent course of action. 

2. Note the facility name and exact 

address, the name and title of 

the plant officials approached, 

the authority of the person 

issuing the denial, the date and 

time of denial, the reason for 

denial, the appearance of the 

facility, and any reasonable 

suspicions as to why entry was 

refused. 

3. The observer should be very 

careful to avoid any situations 

that might be construed as 

threatening or inflammatory. 

Under no circumstances should 

the potential penalties of entry 

denial be cited. 

All evidence obtained prior to the 

withdrawal of consent is considered 

admissible in court. 
p.1i 

Section 3.12.4 April 1983 

When denied access only to certain 

parts of the plant, the observer should 

make note of the area(s) and the 

official's reason for denial. After 

completing normal activities to the 

extent possible and leaving the 

facility, the observer should contact 

his/her supervisor for further 

instructions. 

4.2.7 Confidentiality of Data — In 

conducting the VE investigation, the 

observer may occasionally obtain 

proprietary or confidential business 

data. It is essential that this 

information be handled properly. 

The subject of confidential business 

information known as "a trade secret" 

is addressed in Section 114 of the 

Clean Air Act (see Subsection 4.2.5) 

and in the Code of Federal 

Regulations (40 CFR 2; 41 Federal 

Register 36902, September 1, 1976, 

as amended). The Code of Federal 

Regulations (40 CFR 2, Subpart B, 

2.203) embodies a notice to be 

included in EPA information requests. 

This notice is paraphrased on the 

reverse side of the entry checklist 

(Figure 4.1) for the observer's and 

plant official's reference. The Code of 

Federal Regulations (40 CFR 2, 

Subpart 8, 2.211) also includes the 

penalties for wrongful disclosure of 

confidential information by Federal 

employees, in addition to the penalties 

set forth in the United States Code, 

Title 18, Section 1905. Employees of 

other agencies should check wit h 

agency attorneys to determine their 

exact personal liability. 

From the observer's standpoint, 

confidential information may be 

defined as information received under 

a request of confidentiality which may 

concern or relate to trade secrets. A 

trade secret is interpreted as an 

unpatented secret, commercially 

valuable plan, appliance, formula, or 

process used in production. This 

information can be in written form, in 

photographs, or in the observer's 

memory. Emissions data are not 

considered confidential information. 

Also the Agency reserves the right to 

determine if information submitted to 

it under an official request should be 

treated as confidential. 

A good rule of thumb for the 

observer to follow is to collect only 

that process and operational 

information and to take only those 

photographs that are pertinent to the 

purpose of the plant visit. The plant 

official should be advised that he 

must request confidential treatment of 

specific information provided (see 

paragraph on claims of confidentiality 

on reverse side of entry checklist) 

before it wil l be treated as confidential 

pending legal determination. The plant 

official should inform the observer of 

any sensitive areas of the facility or 

processes where proprietary or trade 

secret information is indicated. 

Photographs are often used to 

document visible emissions 

observations (see Subsection 4.3.4). 

Before taking photographs from inside 

the plant premises, the observer must 

have the consent of the plant official. 

Most of an observer's photographs 

will be of emission points only; 

presumably, these should not include 

confidential areas of the plant. If any 

opposition is encountered regarding 

the use of a camera on the plant 

premises, the observer should explain 

that the plant official should request 

confidential treatment of any 

photographs taken. The observer 

must properly document each 

photograph and handle those for 

which confidential treatment has been 

requested in the same manner as 

other confidential data. Photographic 

documentation of VE observations 

from an area of public access outside 

of the plant premises does not require 

approval from a plant official, provided 

the documentation is accomplished 

without the use of highly 

sophisticated equipment or 

techniques. For example, use of a 

high-power telephoto lens (over 100 

mm on a 35 mm camera) that yields 

extensive details (e.g., construction 

layout) might be construed as 

surreptitiously taking confidential 

business information. Thus, a good 

rule of thumb is to be sure that any 

pictures taken show only the details 

that could be seen with the naked eye 

from an area accessible to the public. 

When preparing to leave the plant, 

the observer should allow the plant 

official to examine the data collected 

and make claims of confidentiality. Al l 

potentially confidential information 

should be so marked, and while on 

the road, the observer should keep it 

in a locked briefcase or file container. 

It should be noted that emission data 

are not considered confidential. 

When the observer returns to the 

agency office, the potentially 

confidential information should be 

placed in a secure, lockabfe file 

cabinet designated especially for that 

purpose. The observer's agency 

should have an established secure 

filing system and procedures for 

safeguarding confidential documents. 

In all cases, the observer should make 

no disclosure of potentially 

confidential information until a 

company has had full opportunity to 

declare its intentions regarding the 

information and the Agency has ruled 

that the information is not legally 

confidential. 

4.2.8 Determination of Safety 

Requirements — The violation of a 

safety rule does not invalidate VE 

readings; however, the observer 

should always anticipate safety 

requirements by arriving at the plant 

with a hardhat, steel-toed safety 

shoes, safety glasses with side 

shields, and ear protectors. Safety 

equipment also should include any 

other equipment that is specified in 

the agency files and noted on the 

entry checklist form. 

Some companies require unusual 

safety equipment, such as specific 

respirators for a particular kind of 

toxic gas. In many cases, these 

companies will provide the observer 

with the necessary equipment. In any 

event, the observer must be aware of 

and adhere to all safety requirements 

before entering the plant. Information 

on plant alarms and availability of first 

aid and medical help may be needed. 

4.2.9 Observer Behavior — 

Observers must perform their duties 

in a professional, businesslike, and 

responsible manner. They should 

always consider the public relations 

liaison part qf their role by seeking to 

develop or improve a good working 

relationship with plant officials 

through use of diplomacy, tact, and if 

necessary, gentle persuasion in all 

dealings with plant personnel. 

Specifically, observers shouid be 

objective and impartial in conducting 

observations and interviews with 

plant officials. Al l information 

acquired during a plant visit is 

intended for official use only and 

should never be used for private gain. 

Observers must be careful never to 

speak of any person, agency, or 

facility in any manner that could be 

construed as derogatory. Lastly, 

observers should use discretion whe n 

asked to give a professional opinion 

on specific products or projects and 

should never make judgments or draw 

conclusions concerning a company's 

compliance with applicable 

regulations. Upon giving the data to 

the plant the observer can tell the 

source these are the data that were 

obtained and no judgment as to 

compliance can be made until all the 

data and the regulations are closely 

reviewed. 
P.18 

April 1983 Section 3.12.4 

4.3 Visible Emission 

Determination 

This subsection describes the 

preferred approach to VE 

determination. Because practical 

considerations do not always permit 

the observer to follow this procedure, 

however, special observation 

problems are discussed in Subsection 

4.4. 

4.3.1 Opacity Readings — The 

observer must be certified in 

accordance with Section 3.12.1, 

Subsection 1.3, and should use the 

following procedure for visually 

determining the opacity of emissions. 

Observer Position 

1. The observer must stand at a 

distance that provides a clear 

view of the emissions with the 

sun oriented in the 140° sector 

to his/her back. If the observer 

faces the emission/viewing point 

and places the point of a pencil 

on the sun location line such 

that the shadow crosses the 

observers position, the sun 

location (pencil) must be within 

the 140° sector of the line. 

During overcast weather 

conditions, the position of the 

sun is less important. 

2. Consistent with number 1 above, 

when possible, the observer 

should, make observations from 

a position in which the line of • 

vision is approximately 

perpendicular to the plume 

direction; when observing 

opacity of emissions from 

rectangular outlets (e.g., roof 

monitors, open baghouses, and 

noncircular stacks), the 

observer's position should be 

approximately perpendicular to 

the longer axis of the outlet. 

3. When multiple stacks are 

involved, the observer's line of 

sight should not include more 

than one plume at a time, and in 

any case, during observations, 

the observer's line of sight 

should be perpendicular to the 

longer axis of a set of multiple 

stacks (e.g., stub stacks on 

baghouses). 

4. The observer must stand at a 

distance that provides total 

perspective and a good view. 

5. In order to comply with the sun 

angle requirements (see item 1) 

it is recommended that the 

observer should try to avoid the 

noon hours (11:00 a.m. to 1:00 

p.m.) in the summertime (when 

the sun is almost overhead). This 

is more critical in the southern 

continental United States. The 

preferred reading distance is 

between 3 stack heights and 1 / 4 

mile from the base of the stack. 

6. The reading location should be 

safe for the observer. 

Opacity Observations 

1. Opacity observations must be 

made at the point of greatest 

opacity in that portion of the 

plume where condensed water 

vapor is not present. 

2. The observer must not look 

continuously at the plume (this 

causes eye fatigue), but should 

observe the plume momentarily 

at 15-s intervals. A 15-s beeper 

is recommended to aid in 

performing the VE readings. 

3. When steam plumes are 

attached, i.e., when condensed 

water vapor is present within the 

plume as it emerges from the 

emission outlet, the opacity must 

be evaluated beyond the point in 

the plume at which condensed 

water vapor is no longer visible. 

The observer must record the 

approximate distance from the 

emission outlet to the point in 

the plume at which the 

observations are made. 

4. When steam plumes are 

detached, i.e., 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 near the 

outlet, prior to the condensation 

of water vapor and the formation 

of the steam plume, unless the 

opacity is higher after 

dissipation. 

5. Readings must be made to the 

nearest 5 percent opacity. A 

minimum of 24 observations 

must be recorded. It is advisable 

to read the plume for a 

reasonable period in excess of 

the time stipulated ih the 

regulations (i.e., at least 10 

readings more than the minimum 

required). 

6. A clearly visible background of 

contrasting color is best for 

greatest reading accuracy. 

However, the probability of 

positive error (higher values) is 

greater under these conditions. 

Generally, the apparent piume 

opacity diminishes and tends to 

assume a negative bias as the 

background becomes less 

contrasting. 

7. It is recommended the observer 

wear the same correaive lenses 

that were worn for certification. 

If sunglasses were not worn 

during certification, the observer 

should remove them and allow 

time for the eyes to adjust to the 

daylight before making VE 

determinations. It is 

recommended that the observer 

not wear photo compensating 

sunglasses. 

8. The best viewing spot is usually 

within one stack diameter above 

the stack exit, where the plume 

is densest and the plume width 

is approximately equal to the 

stack's diameter. 

4.3.2 Field Data: The "Visible 

Emission Observation Form" — The 

1977 revision of EPA Method 9 

specifies the recording of certain 

information in the field documentation 

of a visible emission observation. The 

required information includes the 

name of the plant, the emission 

location, the type of facility, the 

observer's name and affiliation, the 

date, the time, the estimated distance 

to the emission location, the 

approximate wind direction, the 

estimated windspeed, a description of 

the sky conditions (presence and color 

of clouds), and the plume background. 

Experience gained from past 

enforcement litigation involving 

opacity readings as primary evidence 

of emission standards violations has 

demonstrated a need for additional 

documentation whe n making visual 

determinations of plume opacity. The 

Visible Emission Observation Form 

presented in Figure 4.2 is 

recommended. This form was 

developed after reviewing the opacity 

forms used in EPA Regional Offices 

and State and local air quality control 

agencies. The form includes not only 

the data required by Method 9, but 

also the information necessary for 

maximum legal acceptability. Valid 

data can be collected on any form; 

however, the recommended form may 

enhance observer efficiency and data 

documentation. A detailed description 

of the use of the recommended form 

is given in the following paragraphs. 

The Visible Emission Observation 

Form can be functionally divided into 

11 major sections, as shown in Figure 

4.3. Each section documents one or 

two aspects of the opacity 

determination. The form endeavors to 

cover ali the required and 

recommended areas of documentation 

in a typical opacity observation. A 

"comments " section is included for 

notation of any relevant information 

that is not listed on the form. 
P.19 

Section 3.12.4 April 1983 

VISIBLE EMISSION OBSERVA TION FORM 

SOURCE NAME 

ADDRESS 

It*. OCEAN WAD 

clAbfMfW- crrr 

PHONE 

STATE 

VA 

ZIP 

-Z3 H$l 

SOURCE ID NUMBER 

AJ&DS 4372.f 

PROCESS EQUIPMENT 

CONTROL E 

TX.""< , fftl-" 

QUIPMENT 

TATIC FH£C/f>lTATO/e. 

OPERA TING MODE 

3Ase.4-aAD 

OPERA TING MODE 

fiAPP(AC> 

DESCRIBE EMISSION POINT . „,_, 

3e'CCS7?kiC -25 /V«* 

HEIGHT ABOVE GROUND LEVEL 

START /OO ' STOP S 

DISTANCE FROM OBSERVER 

STARTa^Oa' STOP y ^ 

HEIGHT RELATIVE TO OBSERVER 

START /OO ' STOP ^ 

DIRECTION FROM OBSERVER 

STARTA/ffE. STOP yJ 

DESCRIBE EMISSIONS 

START tArr/'V *•""£• STOP S 

EMISSION COLOR 

STA$f*'/t»"Sf0P / 

WA TER DROPLETS PRESENT: 

NO vJ YESO 

PLUME TYPE: CONTINUOUSZT 

FUGITIVE 0 INTERMITTENT 0 

IF WA TER DROPLET PLUME: 

ATTACHED u DETACHED Q 

POINT IN THE PLUME A T WHICH OPACITY WAS DETERMINED 

START /O'AJtWSTjtCX EXIT STOP ^ 

DESCRIBE BACKGROUND 

START £"<•/ STOP CJ/ZECKI/J CLOOOS 

BACKGROUND COLOR 

START3UJe STOP^ZZr-H 

WIND SPEED 

START flT/HPH STOP ZOfiPM 

AMBIENT TEMP. 

START %5'F STOP I / 

SKY CONDITIONS P/^crui 

START ZMEA&. STOP Ccoo&f 

WIND DIRECTION 

START SbJ STOP .J 

WET BULB TEMP. 

5¥°F 

RH.percent 

Source Layout Sketch Drav 

tz 

POvJ*ft\ 

PLANT 

I I M 1 1 I I 1 I I 

v North Arrow 

' (J) 

{XjEmission Point 

7 • ^/*~* / \ r^w 

Sun-Q- Wind.*. V 

Plume and = ^Observers Position \ y 

Stack _.—"\ /~^--^ n.i/ r 

-/ ^-<J ^i/tn 

A ^~"~ *\ 

3 — ^ v / /-&;•»«*» . 

Sun Location Line AA7 

COMMENTS a-, , 

uses ^d, OIL. 

1 HA VE RECEIVED A COPY OF THESE OPACITY OBSERVA TIONS 

SIGNATURE toJutltCLafta- f. Qa^cJlTITLE <? DATE 

OBSERVATION DATE 

15 JULH12X. 

\SEC 

/Vf/A/X, 

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 

26 

27 

28 

29 

30 

0 

30 

5 5 

35 

30 

30 

35 

30 

35 

GO 

$o 

30 

3o 

15 

35 

30 

25 

35 

3D 

3 5 

30 

<?0 

¥C 

45 

-& 

3d 

30 

53 

¥ 0 

3 5 

35 

3 0 

35 

35 

60 

55 

35 

3 0 

30 

START TIME 

12>30 

45 

55 

30 

35 

3 5 

30 

3 5 

3 5 

55 

£0 

3Q 

30 

3 0 

AVERAGE OPACITY FOR ^ ^ 

HIGHES T PERIOD tfO 7© 

NM\. 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

51 

52 

53 

54 

55 

56 

57 

58 

59 

60 

0 

STOP TIME 

15 30 45 

i 

NUMBER OF READINGS ABOVE 

40 % WERE fl 

RANGE OF OPA CITY READINGS . •/Tfl / 

MINIMUM 3*59 b MAXIMUM *>V /O 

OBSERVER'S NAME (PRINT) 

ue. p/zofpfT OBSERVERS SIGNATURE DATE 

ORGANIZATION , _ ^ „^„ 0 « 3TXVC Atfl POUMTlOAl CD^vepL. (3C*e.& 

CERTIFIED BY A,,~-

EA&Tt&Jl&HMCM* ASSOC. 

VERIFIED BY 

ADA 

DATE/Vf*A>f/'?&-

DATE 

Figure 4.2. Visible emission observation form. 
P.2' >h 

April 198 3 Section 3.12. 4 

VISIBLE EMISSION OBSERVA TION FORM 

This form is designed to be used in conjunction with EPA Method 9, "Visual Determination of the Opacity of Emissions from Stationary 

Sources." Any deviations, unusual conditions, circumstances, difficulties, etc.. not dealt with elsewhere on the form should be fully noted 

in the section provided for comments. Following are brief descriptions of the type of information that needs to be entered on the form: for a 

more detailed discussion of each part of the form, refer to the "User's Guide to the Visible Emission Observation Form. " 

'Source Name • full company name, parent company or division 

intormation. if necessary. 

*Sky Conditions • indicate cloud cover by percentage or by 

description (clear, scattered, bioken, overcast, and color of clouds). 

'Address • street (not mailing) address or physical location 

of facility where VE observation is being made. 

Phone • self-explanatory. 

Source ID Number - number from NEDS, CDS. agency file. etc. 

'Process Equipment, Operating Mode • brief description of process 

equipment (include ID no.) and operating rate, % capacity utilization, 

and/or mode (e.g.. charging, tapping). 

'Control Equipment. Operating Mode • specify control device type(s) 

and % utilization, control efficiency. 

'Describe Emission Point • stack or emission point location, geometry, 

diameter, color: for identification purposes. 

'Height Above Ground Level - stack or emission point height, from 

files or engineering drawings. 

'Height Relative to Observer - indicate vertical position of observation 

point relative to stack top. 

'Distance From Observer • distance to stack ±10%: to determine, use 

rangefinder or map. 

'Direction From Observer • direction to stack: use compass or map: 

be accurate to eight points of compass. 

'Describe Emissions • include plume behavior and other physical 

characteristics (e.g.. looping, lacy, condensing, fumigating, secondary 

particle formation, distance plume visible, etc.). 

'Emission Color • gray, brown, white, red. black, etc. 

Plume Type: 

Continuous - opacity cycle >6 minutes 

Fugitive • no specifically designed outlet 

Intermittent • opacity cycle <6 minutes 

'' Water Droplets Present - determine by observation or use wet sling 

psychrometer: water droplet plumes are very white, opaque, and 

billowy in appearance, and usually dissipate rapidly. 

"If Water Droplet Plume: 

Attached • forms prior to exiting stack 

Detached - forms after exiting stack 

"Point in the Plume at Which Opacity was Determined • describe 

physical location in plume where readings were made (e.g., 4 in. above 

stack exit or 10 ft after dissipation of water plume). 

'Describe Background • object plume is read against, include 

atmospheric conditions (e.g.. hazy). 

'Background Color - blue, white, new leaf green, etc. 

'Windspeed • use Beaufort wind scale or hand-held anemometer; 

be accurate to ±5 mph. 

'Wind Direction - direction wind is from; use compass; be 

accurate to eight points. 

'Ambient Temperature • in °F or °C. 

"Wet Bulb Temperature -the wet bulb temperature from the 

sling psychrometer. 

"Relative Humidity • use sling psychrometer; use local U.S. 

Weather Bureau only if nearby. 

'Source Layout Sketch - include wind direction, associated 

stacks, roads, and other landmarks to fully identify location of 

emission point and observer position. 

Draw North Arrow - point line of sight in direction of emission 

point, place compass beside circle, and draw in arrow parallel 

to compass needle. 

Sun Location Line • point line of sight in direction of emission 

point, place pen upright on sun location line, and mark location 

of. sun when pen's shadow crosses the observers position. 

"Comments • factual implications, deviations, altercations, 

and/or problems not addressed elsewhere. 

Acknowledgment • signature, title, and date of company official 

acknowledging receipt of a copy of VE observation form. 

'Observation Date - date observations conducted. 

'Start Time. Stop Time • beginning and end times of observation 

period (e.g.. 1635 or 4:35 p.m.). 

'Data Set - percent opacity to nearest 5%: enter from left to right 

starting in left column. 

'Average Opacity for Highest Period - average of highest 24 

consecutive opacity readings. 

Number of Readings Above (Frequency Count) • count of total 

number of readings above a designated opacity. 

'Range of Opacity Readings: 

Minimum - lowest reading 

Maximum - highest reading 

'Observer's Name • print in full. 

Observer's Signature. Date • sign and date after performing final 

calculations. 

'Required by R&ference Method 9; other items 

suggested. 

""Required by Method 9 only when particular 

factor could affect the reading. 

'Organization - observer's employer. 

'Certifier. Date - name of "smoke school" certifying observer and 

date of most recent certification. 

Verifier, Date • signature of person responsible for verifying 

observer's calculations and date of verification. 

Figure 4.2. Reverse side of form. (Continued) 
P.21 

Section 3.12.4 April 1983 

VISIBLE EMISSION OBSERVA TION FORM 

SOURCE NAME 

ADDRESS 

^ ^ ^ 

CITY f A^YT £ ZIP 

PHONE ^S^dVURCE ID NUMBER 

PROCESS EQUIPMENT f U J 

CONTROL EQUIPMENT ^*—* 

OPERA TING MODE 

OPERA TING MODE 

DESCRIBE EMISSION POINT 

START ^m-S^OP 

HEIGHT ABOVE GROUND LfVffiHhGHT RELATIVE TO OBSERVER 

START STOP y^fSJART STOP 

DISTANCE FROM OBSERVEfT-^DIRECTION FROM OBSERVER 

START STOP | START STOP 

DESCRIBE EMISSIONS 

START STOP 

EMISSION COLOR f m±\jME TYPE CONTINUOUS D 

START STOP \ \^J3ITIVEO INTERMITTENT D 

WA TER DROPLETS PRESENrSm^tf WA TER DROPLET PLUME 

NOZ2 YE SO | ATTACHEDO DETACHEDO 

POINT IN THE PLUME A T WHICH OPACITY WAS DETERMINED 

START STOP 

DESCRIBE BACKGROUND 

START STOP 

. BACKGROUND COLOR >»*4^ Y CONDITIONS 

START STOP fr—s\RT ' STOP 

WIND SPEED I E 

START STOP ^"** 

AMBIENT TEMP 

START STOP 

mwJ.JD DIRECTION 

^TART STOP 

WET BULB TEMP RHjjercent 

Source Layout Sketch Draw North Arrow 

. o 

X Emission Point 

Cf) 

Sun-fy Wind^. V J 

Plume and =^Z*J*rvers Posi"

on 

^ ^ ^ 140° ^\ ^ 

Sun Location Line 

COMMENTS X0****. 

\£) 

1 HAVE RECEIVED A COPY 0&*M^ f OPACITY OBSERVATIONS 

SIGNATURE f|_ l \ »'"" \J"L/ DATE 

OBSERVA TION DA TE 

*\sec 

MIN\ 

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 

26 

27 

28 

29 

30 

0 IS 30 i 

( 

START TIME 

**4?> T 

< - > 

A VERAGE OPACITY FOR 1 J 

HIGHEST PERIOD VTT * 

XSf C 

Af«VN 

fj 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

SO 

5* 

52 

53 

54 

55 

56 

57 

58 

S9 

.60 

0 

STOP TIME 

IS 30 45 

i 

1 

j/UMBER OF READINGS ABOVE 

/ % WERE 

RANGE OF OPACITY READINGS 

MINIMUM MAXIMUM 

OBSERVERS NAME (PRINT) 

OBSERVERS SIGNATURE DATE 

ORGANIZATION ( VC } 

CERTIFIED BY ^*^ ^ 

VERIFIED BY 

DATE 

DATE 

Figure 4.3. Functional sections of visible emission observation form. 
P.22 

April 1983 Section 3.12.4 

Each major section of the form is 

discussed in the following text. A 

short explanation of each section's 

purpose, a background explanation of 

each data element, a description of 

the type of information being sought, 

and in some cases, appropriate 

entries are included. These 

discussions are keyed to Figure 4.3 by 

corresponding capital letters, and it is 

clearly indicated whether information is 

required or recommended. 

A. SOURCE IDENTIFICATION. Provides 

information that uniquely identifies 

the source and permits the observer 

to locate or make contact with the 

source. 

Source name 

Address 

City State 

Phone 

Zip 

Source ID number 

Source Name (Required) - include the 

source's complete name. If necessary 

for complete identification of the 

facility, the parent company name, 

division, or subsidiary name should be 

included. 

Address (Required) - Indicate the 

street address of the source (not the 

mailing address or the home office 

address) so that the exact physical 

location of the source is known. If 

necessary, the mailing address or 

home office address may be listed 

elsewhere. 

City. State, Zip. Phone 

(Recommended) - Self-explanatory. 

Source ID Number (Recommended) -

This space is provided for the use of 

agency personnel and should be used 

to enter the number the agency uses 

to identify that particular source, such 

as the State file number. Compliance 

Data System number, or National 

Emission Data System number. 

B. PROCESS AND CONTROL DEVICE 

TYPE. Includes a several word 

descriptor of the process and control 

device, indication of current process 

operating capacity or mode, and 

operational status of control 

equipment. 

Process equipment 

Control equipment 

Operating mode 

Operating mode 

Process Equipment (Required) - Enter 

a description of the process 

equipment that emits the plume or 

emissions to be read. The description 

should be brief but should include as 

much information as possible, as 

indicated in the following examples: 

Coal-Fired Boiler 

#2 Oil-Fired Boiler 

Wood Waste Conical Incinerator 

Paint Spray Booth 

Primary Crusher 

Fiberglass Curing Oven 

Reverberatory Smelting Furnace 

Basic Oxygen Furnace 

Operating Mode (Recommended) -

Depending on the type of process 

equipment, this information may vary 

from a quantification of the current 

operating rate to a description of the 

portion of a batch-type process for 

which the emission opacity is being 

read. For example, entries could 

include "9 0 percent capacity" for a 

boiler or "8 5 percent production rate" 

for the shakeout area of a grey iron 

foundry. For a steel making furnace, 

entries would include the exact part of 

the process for which readings are 

being made, such as "charging" or 

"tapping." In some cases, the 

observer may have to obtain this 

information from a plant official. 

Control Equipment (Required) - Specify 

the type(s) of control equipment being 

used in the system after the process 

equipment m question (e.g., "hot-side 

electrostatic precipitator"). 

Operating Mode (Recommended) -

Indicate the degree to which the 

control equipment is being utilized at 

the time of the opacity observations 

(e.g., 75% capacity, full capacity, shut 

down, off line) and the operating 

mode (e.g., automatic). The observer 

wil l probably have to obtain this 

information from a plant official. 

C. EMISSION POINT IDENTIFICA TION. 

Contains information uniquely 

identifying the emission point and 

its spatial relationship with the 

observer's position. 

Describe emission point 

Start Stop 

Height above 

ground level 

Start Stop 

Distance from 

observer 

Start Stop 

Height relative 

to observer 

Start Stop 

Direction from 

observer 

Start Stop 

Describe Emission Point (Required) 

Include the identifying physical 

characteristics of the point of re'ease 

of emissjons from the source. The 

description must be specific enough 

so that the emission outlet can be 

distinguished from all others at the 

source. In subsequent enforcement 

proceedings, the observer must be 

certain of the origin of the emissions 

that were being read. 

Typical descriptions of the emission 

outlet include the color, geometry of 

the stack or other outlet, and the 

location in relation to other 

recognizable facility landmarks Any 

special identification codes the agency 

or source uses to identify a particular 

stack or outlet should be noted along 

with the source code used by the 

observer. The source of this 

information should be recorded (e.g.. 

plant layout map or engineering 

drawing). 

Height Above Ground Level (Required) 

- Indicate the height of the stack or 

other emission outlet from its 

foundation base. This information is 

usually available from agency files, 

engineering drawings, or computer 

printouts (such as NEDS printouts). 

The information also may be obtained 

by using a combination of a 

rangefinder and an Abney level or 

clineometer. The height may also be 

estimated. 

Height Relative to Observer (Required) 

- Indicate an estimate of the height of 

the stack outlet (or of any other type 

of emission outlet) above the position 

of the observer. This measurement 

indicates the observer's position in 

relation to the stack base (i.e., higher 

or lower than the base) and may later 

be used in slant angle calculations 

(see Section 3.12.6 and Subsection 

4.4.6) if such calculations become 

necessary. 

Distance From Observer (Required) -

Record the distance from the point of 

observation to the emission outlet. 

This measurement may be made by 

using a rangefinder. If necessary, a 

map also may be used to estimate the 

distance. 

It is important that this 

measurement be reasonably accurate 

if the observer is close to the stack 

(within 3 stack heights) because it is 

coupled with the outlet height relative 

to the observer to determine the slant 

angle at which the observations were 

made (see Figure 4.4). A precise 

determination of the slant angle may 

become important in calculating any 

positive bias inherent in the opacity 

readings. 

Direction From Observer (Required) -

Specify the direction of the emission 

point from the observer to the closest 
P.23 

Section 3.12. 4 10 April 198 3 

of the eight points of the compass 

(e.g., S, SE. NW, NE) or 45° . Use of a 

compass to make this determination 

in the following manner is suggested: 

hold the compass while facing the 

emission point; rotate the compass 

until the North compass point lies 

directly beneath the needle (which 

will be pointing towards magnetic 

North); then the point of the compass 

closest to the emission outlet wil l 

indicate the direction (Figure 4.5). A 

map (plant layout) also may be used to 

make this determination. 

Describe Emissions (Required) -

Include both the physical 

characteristics of the emissions not 

recorded elsewhere on the form and 

the behavior of the resultant plume. 

The description of the physical 

characteristics might include terms 

such as lacy, fluffy, and detached 

nonwater vapor condensibles. 

The terminology illustrated in Figure 

4.6 can be used to describe plume 

Stack 

Observer,' Slant 

s%45° Angle 

behavior. The behavior can be used to 

determine the atmospheric stability on 

the day of the opacity observations. 

Emission Color (Required) - Note the 

color of the emissions. The plume 

color can sometimes be useful in 

determining the composition of the 

emissions and wil l also serve to 

document the total contrast between 

the plume and its background as seen 

by the opacity observer during the 

observation period. 

Plume Type (Recommended) - Check 

"continuous" if the duration of the 

emissions being observed is greater 

than 6 minutes. Check "intermittent" 

if the opacity cycle is less than 6 

minutes. Check "fugitive" if the 

emissions have no specifically 

designated outlet. 

Water Droplets Present (May be 

required) - Check "yes " or "no " as 

appropriate. In some cases, the 

presence of condensed water vapor in 

the plume can be easily observed. 

L' • Observer Path Length 

L • Actual Path Length 

Height 

Relative to 

Observer 

I— —i 

Distance from observer 

Figure 4.4. Slant angle relationships. 

Observer 

Stack 

•o 

Compass 

Figure 4.5. Direction from observer is NE. 

D. EMISSIONS DESCRIPTION. Includes 

information that definitely 

establishes what was observed 

while making the visible emissions 

determination. 

Describe emissions 

Start 

Emission color 

Start Stop 

Stop 

Plume type: Continuous D 

Fugitive D Intermittent D 

Water droplets 

present 

No D YesD 

If water droplet plume 

Attached D 

Detached D 

Point in the plume at which opacity was 

determined 

Stan Stop 

Plumes containing condensed water 

vapor (or "steam plumes") are usually 

very white, billowy, and wispy at the 

point of dissipation, where the opacity 

decreases rapidly from a high value 

(usually 100%) to 0 percent if there is 

no residual opacity plume contributed 

by contaminate in the effluent. 

To document the presence or 

absence of condensed water vapor m 

the plume, the observer must address 

two points. First, is sufficient moisture 

present (condensed or uncondensed) 

in the plume initially? Second, if 

enough moisture is present, are the 

in-stack and ambient conditions such 

that it will condense either before 

exiting the stack or after exiting (when 

it meets wit h the ambient air)? The 

first question can be answered by 

examining the process type and'o r 

the treatment of the effluent gas after 

the process. Some common sources 

of moisture in the plume are: 

• Water produced by combustion 

of fuels, 

• Water from dryers. 

• Water introduced by wet 

scrubbers, 

• Water introduced for gas cooling 

prior to an electrostatic 

precipitator, or other control 

device, and 

• Water used to control the 

temperature of chemical 

reactions. 

If water is present in the plume, 

data from a sling psychrometer, which 

measures relative humidity, in 

combination with the moisture 

content and temperature of the 

effluent gas can be used to predict 

whether the formation of a steam 

plume is a possibility (see Section 

3.12.6). 

// Water Droplet Plume: (May be 

required) - Check "attached" if 

condensation of the moisture 

contained in the plume occurs within 

the stack and the steam plume is 

visible at the stack exit. Check 

"detached" if condensation occurs 

some distance downwind from the 

stack exit and the steam plume and 

the stack appear to be unconnected. 

Point in the Plume at Which Opacity 

was Determined (May be required) -

Describe as succinctly as possible the 

physical location in the plume where 

the observations wer e made. This 

description is especially important in 

the case where condensed water 

vapor and/or secondary plume is 

present. For example, were the 

readings made prior to formation of 

the steam plume? If the readings were 

made subsequent to dissipation (e.g., 

in the case of an attached steam 
P.24. 

April 1983 11 Section 3.12.4 

Fanning Fumigation 

Figure 4.6. Plume behavior descriptors. 

plume), then specify how far 

downwind of the dissipation point and 

how far downwind of the stack exit 

the reading was made. This 

information can be used to estimate 

the amount of dilution that occurred 

prior to the point of opacity readings. 

Descriptions such as 4 feet above 

outlet and 80 feet downstream from 

outlet, 10 feet after steam dissipation 

are appropriate. 

Figure 4.7 shows some examples of 

the correct location for making opacity 

readings in various steam plume and 

secondary plume situations. 

Describe Background (Required) -

Describe the background that the 

plume is obscuring and against which 

the opacity is being read. While 

describing the background, note any 

imperfections or conditions, such as 

texture, that might affect the, ease of 

making readings. Examples of 

background descriptions are roof of 

roof monitor, stand of pine trees, edge 

of jagged stony hillside, clear blue sky, 

stack scaffolding, and building 

obscured by haze. 

Background Color (Required) -

Accurately note the background color 

(e.g., new leaf green, conifer green, 

brick red, sky blue, and gray stone). 

E. OBSERVA TION CONDITIONS. 

Covers the background and ambient 

weather conditions that occur during 

the observation period and could 

affect observed opacity. 

Describe background 

Start Stop 

Background color 

Start Stop 

Windspeed 

Start Stop 

Ambient temp. 

Start Stop 

Sky conditions 

Start Stop 

Wind direction 

Stan Stop 

Wet bulb 

temp. 

Relative humidity 

Attached steam plume. 

Area of Steam 

Condensation 

Read Here 

Area of Steam 

Condensation 

Detached steam plume. In 

rare cases, it may be 

necessary to make readings 

at the point of steam dissipation if the plume is 

more opaque at that point. 

Read Here • 

(preferred) "Hy 

Or Here 

Point of Steam 

Dissipation 

Area of Steam i _ , „, -

Condensation SecondarV

P

'TJ. F°

rma"on 

(Acid Mist) 

Plume from a sulfuric acid 

plant with detacheo steam 

plume. Plume is clear at 

stack exit. Secondary acid 

mist is formed in area of 

steam condensation. 

\ Read Here 

Point of Steam 

Dissipation 

Figure 4.7. Location for reading opacity under various conditions. 
P.25 

Section 3.12.4 12 April 198 3 

Sky Conditions (Required) - Indicate 

the percent cloud cover of the sky. 

This information can be indicated by 

using straight percentages (e.g., 10% 

overcast. 100% overcast) or by 

description, as shown below. 

Term 

Clear 

Scattered 

Broken 

Overcast 

Amount of cloud cover 

<10% 

10% to 50% 

50% to 90% 

>90% 

Windspeed (Required) - Give the 

windspeed accurately to ±5 miles per 

hour. The windspeed can be 

determined using a hand-held 

anemometer (if available), or it can be 

estimated by using the Beaufort Scale 

of Windspeed Equivalents in Table 

4.1. 

Wind Direction (Required) - Indicate 

the direaion from which the wind is 

blowing. The direction should be 

estimated to eight points of the 

compass by observing which way the 

plume is blowing. If this type of 

estimation is not possible, the 

direction may be determined by 

observing a blowing flag or by noting 

the direction a few blades of grass or 

handfull of dust are blown when 

tossed into the air. Keep in mind that 

the wind direction at the observation 

point may be different from that at the 

emission point; the wind direaion at 

the emission point is the one of 

interest. 

Ambient Temperature (Required) - The 

outdoor temperature at the plant site 

is measured by a thermometer (in 

degrees Fahrenheit or centigrade) 

obtained from a local weather bureau 

or estimated. Be certain to note which 

temperature scale is used. This is 

done in conjunction with the wet 

bulb temperature and is only needed 

when there are indications of a 

condensing water droplet plume. 

Wet Bulb Temperature (May be 

required) - Record the wet bulb 

temperature from the sling 

psychrometer. This is to be done only 

when there are indications of a 

condensing water droplet plume. 

Relative Humidity (May be required) -

Enter the relative humidity measured 

by using a sling psychrometer in 

conjunaion with a psychrometric 

chart. This information can be used to 

determine if water vapor in the plume 

will condense to form a steam plume 

(see Section 3.12.6). If a sling 

psychrometer is not available, data 

from a nearby U.S. Weather Bureau 

can be substituted. 

Table 4.1. The Beaufort Scale of Windspeed Equivalents 

General 

description Specifications 

Limits of velocity 

33 ft (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 vanes 

Wind felt on face; leaves rustle: 

ordinary vane moved by wind 

Leaves and small twigs in constant 

motion; wind extends light flag 

Raises dust and loose paper; small 

branches are moved 

Small trees in leaf begin to sway: 

crested wavelets form on inland 

waters 

Large branches in motion: whistling 

heard in telegraph wires; umbrellas 

used with difficulty 

Whole trees in motion; inconvenience felt in walking against the 

wind 

Twigs broken off trees; progress 

generally impeded 

Slight structural damage occurs 

(chimney pots and slate removed) 

Trees uprooted; considerable 

structural damage occurs 

Rarely experienced; accompanied 

by widespread damage 

Under 1 

1 to 3 

4 to 7 

8 to 12 

13 to 18 

19 to 24 

25 to 31 

32 to 38 

39 to 46 

47 to 54 

55 to 63 

64 to 75 

Above 75 

OBSERVER POSITION AND SOURCE 

LA YOUT. Clearly identifies the 

observer's position in relation to the 

emission point, plant landmarks, 

topographic features, sun position. 

and wind direction. 

Source Layout Sketch Draw North Arrow 

o 

X Emission Point 

I Sun-fy Wind^. 

Plume and - ^Observers Pos.t.on 

Stack ^ 

140" 

Sun Location Line 

Source Layout Sketch (Required) -

This sketch should include as many 

landmarks as possible. At the very 

least, the sketch should locate the 

relative position of the observed outlet 

in such a way that it will not be 

confused with others at a later date, 

and clearly locate the position of the 

observer while making the VE 

readings. The exact landmarks will 

depend on the specific source, but 

they might include: 

• Other stacks 

• Hills 

• Roads 

• Fences 

• Buildings 

• Stockpiles 

• Rail heads 

• Tree lines 

• Background for readings 

To assist in subsequent analysis of 

the reading conditions, sketch in the 

plume (indicate the direction of wind 

travel). The wind direction also must 

be indicated in the previous section. 

Draw North Arrow (Recommended) -

To determine the direction of north, 

point the line of sight in the source 

layout sketch in the direction of the 

actual emission point, place the 

compass next to the circle and draw 

an arrow in the circle parallel to the 

compass needle. A map (plant layout) 

may also be used to determine 

direction north. 

Sun's Location (Recommended) - It is 

important to verify this parameter 

before making any opacity readings. 

The sun's location should be within 

the 140° sector indicated in the layout 

sketch; this confirms that the sun is 

within the 140° sector to the 

observer's back. 

To draw the sun's location, point the 

line of sight in the source layout 

sketch in the direction of the actual 

emission point, place a pen upright 

along the "sun location line" until the 
April 1983 13 Section 3.12.4 

shadow of the pen falls across the 

observer's position. Then draw the 

sun at the point where the pen 

touches the "sun location line " 

G. COMMENTS. Includes all 

implications, deviations, 

disagreement with plant personnel 

and/or problems of a factual nature 

that have bearing on the opacity 

observations and that cannot be or 

have not been addressed elsewhere 

on the form. 

Comments 

Comments (May be required) - Note 

all implications, deviations, 

disagreements with plant personnel, 

or problems of a factual nature that 

cannot be or have not been addressed 

elsewhere on the form. Examples of 

points to be included in this section 

are: 

• Changes in ambient conditions 

from the time of the start of 

readings. 

• Changes in plume color, 

behavior, or other characteristics. 

• Changes in observer position and 

reasons for the change; a new 

form should also be initiated in 

this case so that a new source 

layout sketch may be drawn. 

• Difficulties encountered in plant 

entry. 

• Conditions that might interfere 

with readings or cause thorn to 

be biased. 

• Drawing of unusual stack 

configuration (to show multiple 

stacks or stack in relation to roof 

line). 

• Suspected changes to the 

emissions or process during 

observation. 

• Unusual process conditions. 

• Additional source identification 

information. 

• Type of plant (if not specified 

• elsewhere). 

• Reasons for missed readings. 

• Other observers present. 

H COMPANY ACKNOWLEDGEMENT. 

Company acknowledgement of, but 

not necessarily agreement with, the 

opacity observations stated on the 

form. 

I have received a copy of these opacity 

observations 

Signature 

"1 

Title Date 

Signature (Recommended) - This 

space is provided for the signature of 

a plant official who acknowledges that 

he/she has received a copy of the 

observer's opacity-readings. His/her 

signature does not in any way 

indicate that he/she or the company 

concurs with those readings. 

Title (Recommended) - Include the 

acknowledging official's company title. 

Date (Recommended) - The company 

official should enter the date of 

acknowledgment. 

/. DA TA SET. Opacity readings for the 

observation period, organized by 

minute and second. This section 

also includes the actual date and 

start and stop times for the 

observation period. 

Average opacity 

for highest period 

Number of readings above 

% were 

Range of opacity readings 

Minimum Maximum 

Observation 

date 

A^£ 

1 

2 

29 

30 

0 15 30 

Stan time 

45 fa-^ 

31 1 

32 

59 

60 

0 

Stop time 

15 30 45 

Observation Date (Required) - Enter 

the date on which the opacity 

observations were made. 

Start Time, Stop Time (Required) -

Indicate the times at the beginning 

and the end of the actual observation 

period. The times may be expressed in 

12-hour or 24-hour time (i.e., 8:35 

a.m. or 0835); however, 24-hour time 

tends to be less confusing. 

Data Set (Required) - Spaces are 

provided for entering an opacity 

reading every 15 s.for up to a 1 -hour 

observation period. The readings 

should be in percent opacity and 

made to the nearest 5 percent. The 

readings are entered from left to right 

for each numbered minute, beginning 

at the upper left corner of the lefthand column, labeled row " M 1 " 

(minute 1) and column "s 0 " (0 

seconds). The next readings are 

entered consecutively in the spaces 

labeled M 1, s 15; M 1, s 30; M 1, s 

45; M 2, s 0, M 2, s 15, etc. 

If, for any reason, a reading is not 

made for a particular 15-second 

period, that space should be skipped 

and an explanation should be provided 

in the comments section. Also a dash 

(-) should be placed in the space 

which denotes that the space is not 

just an oversight. 

J. DATA REDUCTION. Basic analysis of 

the opacity readings to allow 

preliminary compliance appraisal in 

accordance with EPA Reference 

Method 9. 

A verage Opacity for the Highest 

Period (Required) - Enter the average 

of the sum of the highest 24 

consecutive readings (6-minute set). 

In other words, identify the 24 

consecutive readings that would sum 

to the greatest value and then divide 

this value by 24 to get the average 

opacity for that set of readings. Note: 

The average should not include a time 

lapse for which a valid reading could 

have been taken but was not (see . 

__S_ection 3.12.6). 

•Number of Readings Above .. % Were 

... (Recommended) - Indicate an 

optional frequency count of the 

opacity readings above a particular 

value. The value is chosen according 

to the opacity standard for the 

emission point and is generally the 

actual value of the standard. 

Method 9 does not specify the use 

of frequency counting to reduce data, 

but many States use it to determine 

compliance with their1 time exemption 

opacity standards. For example, a 

State regulation might specify that 

opacity of a specific type of emission 

source-is not to exceed 20 percent for 

more than 3 minutes in an hour. If 

more than 12 readings out of 240 

exceed 20 percent in an hour-long 

observation period, that State may 

consider that source out of 

compliance. For example, 

14 readings out of 240 readings (1 

hour) are above 20 percent opacity 

14 x 15 s per reading = 210 s 

= 3.5 minutes of readings above the 

standard. 

Range of Opacity Readings (Required) 

- Enter the highest and lowest opacity 

readings taken during the specified 

observation period. 

K. OBSERVER DA TA. Information 

required to validate the opacity data. 

Observer's name (print) 

Observer's signature 

Organization 

Certified by 

Verified by 

Date 

Date 

Date 
Section 3.12.4 14 April 1983 

Observer's Name (Required) - Print 

observer's entire name. 

Observer's Signature/Date 

(Recommended) - Self-explanatory. 

Organization (Required) - Provide the 

name of the agency or company that 

employs the observer. 

Certified By (Recommended) - Identify 

the agency, company, or other 

organization that conducted the 

"smoke school" or VE training and 

certification course where the 

observer obtained his/her most 

current certification. 

Date (Required) - Provide the date of 

the most current certification. 

Verified By (Recommended) - The 

actual signature of someone who has 

verified the opacity readings and 

calculations, usually the observer's 

supervisor, or the individual who is 

responsible for his/her work. 

Date (Recommended) - Provide the 

date of verification. 

4.3.3 Facility Operating Data - It is 

strongly recommended that a VE 

inspection/observation conclude with 

a source inspection if opacity values 

are in excess of the standard. The 

observer would first follow the plant 

entry procedure in Subsection 4.1 and 

then follow the indicated procedure to 

obtain facility operating data. 

After the VE determination, it is 

recommended that the following 

source information be determined: 

1. Were the plant and the source of 

interest operating normally at the 

time of the VE evaluation? 

2. Are there any control devices 

associated with the source? 

3. Were the control devices 

operating properly? 

4. Have there been any recent 

changes in the operation of the 

process or control devices? 

5. Have any malfunctions or 

frequent upsets in the process or 

control devices been noted and 

reported (if required by the 

agency)? 

6. Is the plant operator aware of 

excessive visible emissions and 

have any corrective steps been 

taken to alleviate the problems? 

7. Are there any other sources of 

visible emissions in close 

proximity to the source in 

question that may interfere with 

reading the plume opacity or 

contribute to the appearance of 

the plume? 

4.3.4 Photographs - It is suggested 

that photographs be taken before and 

after the observation is made, not 

during the observation period. 

Conditions should be recorded as they 

existed at the time of the observation. 

The use of a 35-mm camera is 

recommended to ensure good 

photographs. 

Each photograph should be identified 

with the date and time, the source, 

and the position from which the 

photograph was taken. 

4.4 Special Observation Problems 

The VE observer constantly should 

be aware that his/her observations 

may be used as the basis of a 

violation action and subject to 

questioning as to the reliability of the 

observations. Therefore, he/she must 

also be aware that under some 

conditions or situations it may be 

difficult or impossible to conduct a 

technically defensible visible 

emissions observation. 

This section discusses some of the 

most prevalent difficult conditions or 

special problems associated with the 

visible emission observation. Each 

discussion is directed toward defining 

the problem, indicating how it might 

invalidate readings taken, and 

addressing possible solutions and/or 

ways to minimize the invalidating 

effects. 

Not all of these discussions offer a 

complete solution for a particular 

problem; thus, it is important for the 

individual observer to keep in mind 

the purpose of the visible emission 

observation when considering exactly 

what action to take when faced with a 

special problem. 

4.4.1 Positional Requirements -

Valid VE evaluations can be 

conducted only when the sun is 

properly positioned at the observer's 

back. Failure to adhere to this 

positioning can result in significant 

positive bias caused by forward light 

scatter in opacity readings. Because of 

this overriding constraint, some times 

and locations make it difficult for the 

observer to meet other opacity reading 

criteria, e.g., reading the narrow axis 

of a rectangular stack, reading a 

series of stacks across a short axis to 

prevent multiple plume effects, and 

obtaining a contrasting background. 

Plant topography also may generate 

constraints that restrict viewing 

positions to one or more locations. 

The observer will be aided in 

determining the best observation 

location by following the criteria listed 

below. 

1. Make sure that the emission 

point is north of the observation 

point. 

2. Obtain a clear view of the 

emission point with no 

interfering plumes. 

3. Be sure that rectangular stacks 

are read across the narrow axis 

and multiple stacks are read 

perpendicular to the line of 

stacks. 

4. Minimize the slant angle by 

moving a sufficient distance from 

the stack or to an elevated 

position (see Subsection 4.4.4). 

5. Find a contrasting background or 

a clear sky background. 

6. Finally, determine the best time 

of day for observations based on 

the daily sun tracks at that 

location. 

Collaborative studies of the 

performances of trained observers 

have indicated that, with the 

exception of the positive bias caused 

by having the improper sun angle, 

visible emission observation biases 

tend to be negative. Thus, if viewing 

conditions are not ideal and a 

negative bias (lower value) results, 

opacity readings may not provide the 

true measure of plume opacity 

required to correlate to mass 

emissions or control equipment 

efficiency. However, readings that 

indicate a violation can be regarded as 

the minimum opacity; therefore, 

documentation of the violation is 

valid. 

In situations where the observer 

must make plume opacity readings 

when all the criteria for correct 

viewing cannot be met, all 

extenuating circumstances must be . 

documented on the VE evaluation 

form. 

4.4.2 Multiple Sources/Multiple 

Stacks - An observer is sometimes 

compelled to evaluate a stack that 

discharges emissions from more than 

one source or to evaluate a single 

source that has more than one 

emission point. 

In the case where one stack serves 

more than one emission source, the 

observer may be able to isolate the 

emissions from one source as a result 

of intervals of operation, or by 

requesting the facility's cooperation in 

temporarily shutting down the other 

source(s). Otherwise, the observer 

should proceed with the VE 

observation and document the 

situation completely on the VE 

evaluation form. 

In the case of multiple emission 

points for a single source (e.g., in 

positive-pressure baghouses and 

multiple vents in roof monitors), 

Section 2.1 of Method 9 directs the 
April 1983 15 Section 3.12.4 

observer to read multiple stacks 

independently if it is possible to do so 

while meeting sun position 

requirements. If it is necessary to get 

an overall reading for the group of , 

stacks, the following set of formulas 

can be used to calculate this reading 

from the individual opacity values. 

T, xT; 

100 

1 -

1-

1 

X 

<(1 

0, 

100 

Oz 

100 

ON 

100 

... T N 

-Tr) 

= T, 

= T 2 

-TN 

= TT 

--OT 

where 

OT = % opacity of 1st plume 

02= % opacity of 2nd plume 

0 N = % opacity of nth plume 

Ti = Transmittance of 1st plume 

T 2 r Transmittance of 2nd plume 

TN= Transmittance of nth plume 

T T= Total transmittance 

O T = % total opacity 

4.4.3 High Winds - Occasionally the 

crosswind conditions are unfavorable 

during field observations of plume 

opacity. When the winds are strong 

enough to shear the emissions at the 

stack outlet, it is difficult for the 

observer to make an accurate and fair 

VE observation. Strong crosswinds 

can have several effects on the 

plume: 

1. The plume becomes essentially 

flattened and is no longer conical 

in shape thus the path length 

and apparent opacity increases. 

2. The plume is torn into fragments 

and becomes difficult to obtain a 

representative reading. 

3. The plume becomes diluted, and 

the apparent opacity is lowered. 

The observer can compensate 

somewhat for the effect of flattening 

by reading the plume downwind of 

the stack, after it has reformed into a 

cone. The dilution effect of high 

winds, which lowers the apparent 

opacity, presents more of a problem. 

Because of the negative bias 

introduced, the effectiveness of 

Method 9 as a control tool under 

these conditions is diminished. If a 

violation is still observed under these 

conditions, it should be considered 

valid. It is recommended that 

whenever feasible, VE observations be 

suspended until the wind-caused 

interferences have abated. 

4.4.4 Poor Lighting - Poor lighting 

conditions for VE observations usually 

involve one or more of the following: 

(1) a totally overcast sky, (2) early 

morning or late afternoon hours, or (3) 

nighttime. Each of these three lighting 

conditions has the same net effect on 

the plume; they differ slightly only in 

the cause of the poor illumination. 

When the amount of available 

sunlight is below a certain level, the 

contrast between a white plume and 

the background decreases. Therefore, 

readings are not recommended in 

either the early morning hours (at or 

approaching dawn) or late afternoon 

hours (at or approaching dusk). 

Nighttime viewing obviously 

represents the most severe of poor 

lighting conditions. Some agencies 

have attempted, with mixed results, to 

use night vision devices (light 

intensification scopes) for plume 

viewing and testing in the dark. 

Others have achieved better results by 

placing a light behind the emissions, 

which provides a very high contrast 

background. For this method, it is 

important to select a source of light of 

moderate strength that does not 

cause the iris of the eye to close. 

4.4.5 Poor Background - The color 

contrast between the plume and the 

background against which it is viewed 

can affect the appearance of the 

plume as viewed by an observer. Field 

studies have corroborated predictions 

of the plume opacity theory by 

demonstrating that a plume is most 

visible and has the greatest apparent 

opacity when viewed against a 

contrasting background. 

Consistent with these findings is 

the fact that with a high contrast 

background, the potential for positive 

observer bias is the greatest. 

However, field trials consisting of 769 

sets of 25 opacity readings each have 

shown that for more than 9 9 percent 

of the sets, the positive observer error 

was no greater than 7.5 percent 

opacity.2 

Also consistent with these findings 

is the fact that as the contrast 

between the plume and its 

background decreases, the apparent 

opacity decreases; this greatly 

increases the chance for a negative 

observer bias. Under these conditions, 

the likelihood lessens of a facility 

being cited for a violation of an 

opacity standard because of observer 

error. 

When faced wit h a situation where 

there is a choice of backgrounds, the 

observer should always choose the 

one providing the highest contrast 

with the plume because it will permit 

the most accurate opacity reading. 

However, if a situation arises where 

other constraints make it impossible 

to locate an observation point that 

provides a high contrast background, 

the observer may read against a less 

contrasting one with confidence that a 

documented violation should be 

legally defensible. 

4.4.6 Reduced Visibility -

Environmental factors at the time of 

observation also are of concern to 

the visible emissions observer. 

Environmental considerations include 

rain, snow, or other forms of 

precipitation, and photochemical smog 

buildup, fog, sea spray, high humidity 

levels, or any other cause of haze. 

These environmental factors create a 

visual obscuration that can increase 

the apparent opacity of the plume, but 

more commonly reduce the 

background contrast and thus 

decrease the apparent opacity. 

In recognition of the problems that 

could result from reduced visibility 

caused by environmental factors, the 

amended Method 9 (November 12, 

1974) states, in paragraph 2.1 of the 

Procedures Section: "The qualified 

observer shall stand at a distance 

sufficient to provide a clear view of 

the emissions ..." A "clear view" 

must be interpreted as a view free 

from obstacles or interferences. Most 

problems caused by reduced visibility 

can be alleviated simply by making 

the observations on another day. 

4.4.7 Tall Stacks/Slant Angle • 

When an observer's distance from the 

stack approaches 1/4 mile 

(approximately 1300 feet, or a little 

over four football fields), the ambient 

light scattering may begin to have an 

adverse effect on the contrast 

between the plume and the 

background. Also, if the sky is 

overcast or hazy on the day of 

observation, the farther the observer 

is from the emission point, the more 

the haze interferes with the view of 

the plume and hence, the less reliable 

the readings. 

On the other hand, the 

recommendation that the observer 

stand at least three stack heights from 

the stack being observed is intended 

to ensure that the width of the plume 

as it is viewed is approximately the 

same as it is at the stack outlet. As 

the observer gets closer to the stack 

and the viewing (slant) angle 
Section 3.12.4 16 April 1983 

increases, the observed path length 

also increases; this causes the 

observed opacity to increase because 

the observer is reading through more 

emissions. These relationships are 

shown in Figure 4.8. At an observer 

distance of three stack heights, which 

corresponds to a slant angle of 18° , 

the deviation of observed opacity from 

actual opacity decreases to 1 percent 

opacity, which is considered 

acceptable (see Section 3.12.6). 

The three-stack-heights relationship 

only occurs if the observer and the 

base of the stack are in the same 

horizontal plane. If the observer is on 

a higher plane than the base of the 

stack, then the minimum distance for 

proper viewing can be reduced to less 

than three stack heights; conversely, 

if the observer's plane is lower than 

that of the stack base, then the 

minimum suggested distance wil l be 

greater than three stack heights (see 

Figure 4.8). The real determining 

factor is the slant angle. To assure no 

more than a 1 percent opacity 

deviation of observed opacity from 

actual opacity, the observer must have 

a visual slant angle of 18° or less. 

4.4.8 Steam Plumes - Under certain 

conditions, water vapor present in an 

effluent gas stream wil l condense to 

form a visible water droplet or "steam " 

plume. Because the NSPS (specifically 

Method 9) and almost all SIP's 

exclude condensed, uncombined 

water vapor from opacity regulations, 

the VE observer must be careful that 

he/she does not knowingly read a 

plume at a point where condensed 

water vapor is present and record the 

value as representative of stack 

emissions. 

Knowledge'of the kind of process 

that generates the emissions being 

read and simple observation of the 

resultant plume almost always allows 

the observer to determine if a steam 

plume is present. Steam plumes are 

commonly associated with processes 

or control equipment that introduce 

water vapor into the gas stream. 

These sources include: 

• Fuel combustion, 

• Drying operations. 

^ - — 18° ^^27° /4S° 

Plume J-

_ 

D 

Slack 

h 

Y=2HY-H 

Y=3H 

Figure 4.8. Observer distance, observed path length relationships. 

• Wet scrubbers. 

• Water-induced gas cooling prior 

to an emissions control device, 

and 

• Water-induced chemical reaction 

cooling. 

Also, observation of steam plumes 

will reveal that they are usually very 

white, billowy, and have an abrupt 

point of dissipation. At the point of 

dissipation, the opacity generally 

decreases rapidly from a high value 

(usually 100%) to a low value. 

Depending on the moisture and 

temperature conditions in the stack 

and in the ambient air, steam plumes 

may be either "attached" or 

"detached." An attached steam plume 

forms within the stack and is visible 

at the exit; a detached steam plume 

forms downwind of the stack exit and 

does not appear to be connected to 

the stack. In cases when it is not clear 

whether a steam plume is present or 

when an observer would like to 

predict the formation of a steam 

plume, the stack gas conditions may 

be used in conjunction with the 

ambient relative humidity to make the 

prediction (see Section 3.12.6). 

When a steam plume is present, the 

particulate plume is read at a point 

where 1) no condensed water vapor 

exists, and 2) the opacity is the 

greatest. In the case of a detached 

steam plume, this point is usually at 

the stack exit, prior to the water vapor 

condensation; in the case of an 

attached steam plume, it is usually 

slightly downwind of the point of 

steam plume dissipation (for 

examples, see Figure 4.7). The observer 

should always carefully document the 

point chosen. 

4.4.9 Secondary Plume Formation -

Some effluent gas streams contain 

species that form visible mists or 

plumes by a physical and/or chemical 

reaction that occurs either at some 

point in the stack or after the 

emissions come in contact with the 

atmosphere. This situation is known 

as secondary plume formation. 

Examples of such secondary plume 

formation include: 

• A change in the physical state of 

a compound condensing from a 

gas into a liquid, such as 

vaporized hydrocarbon 

condensing into an aerosol or a 

solid. 

• A physiocochemical reaction 

between two or more gaseous (or 

in some cases, liquid) species in 

a plume, such as the 

condensation of ammonia, sulfur 

dioxide, and water vapor to form 
April 1983 17 Section 3.12.4 

particulate ammonium sulfite or 

the condensation of sulfur 

trioxide and water vapor to form 

sulfuric acid mist. 

• A physiocochemical reaction 

between species in a plume and 

species in the atmosphere, such 

as the formation of N2O3. 

Secondary plumes are sometimes 

found in the following processes (with 

these suspected secondary reactions): 

• Coal- and oil-firad cement kilns 

(SO3 + H20 - H2SO4 mist) 

or (NH3 + SO2 + H20 -

(NH„)2 S03] 

• Fossil-fuel-fired steam 

generators (S02 + H20 - H2SO4 

mist) 

• Sulfuric acid manufacturing (SO3 

+ H20 - H2S04 mist) 

• Plywood and particleboard wood 

heating (organic vapor — organic 

mist) 

• Glass manufacturing (inorganic 

vapor — organic aerosol). 

As in the case of steam plumes, 

secondary plumes can be attached or 

detached, depending on the specific 

condensation reaction and the 

ambient conditions. For example, a 

secondary plume will be attached if a 

reaction between plume species 

occurs in the stack and the stack 

temperature is sufficiently low to 

cause condensation of the reaction 

products to a visible liquid or solid 

phase. A detached secondary plume 

will be evident when the reaction 

does not occur until the gas stream 

comes in contact with the 

atmosphere. The degree of 

detachment depends on the ambient 

conditions, the degree of mixing 

between the effluent and the 

atmosphere, and the specific 

reaction(s) involved. 

Secondary plumes may occur with 

or without an accompanying steam 

plume, and it is important that the 

observer be able to distinguish 

between the two. Unlike steam 

plumes, secondary plumes are often 

persistent (they do not dissipate 

rapidly), are usually bluish white (due 

to the fine particles present), and are 

grainy rather than billowy. 

To read a secondary plume, the 

observer must locate the densest 

point of the plume where water vapor 

is not evident and make the readings 

at that point. This point may occur in 

several different areas, depending on 

the type of secondary plume. An 

attached secondary plume will usually 

be read at the stack exit if an attached 

steam plume is not present; if an 

attached steam plume /!s present, the 

secondary plume must be read at the 

point of steam dissipation. A detached 

secondary plume will usually be read 

slightly downwind of the area of 

formation, assuming there is no 

interfering condensed water vapor. 

Under some conditions, a secondary 

plume may not fully condense until 

some distance downstream of the 

point of formation; in this case, the 

observer simply looks for the densest 

area of the plume and makes the 

reading at that point. It is especially 

important in reading a secondary 

formation plume to describe fully the 

point at which the reading was taken 

and the exact appearance of the 

plume. (Refer to Figure 4.7 for one 

example of where to read a secondary 

plume.) 

4.4.10 Fugitive Emissions - Fugitive 

emissions are those emissions that do 

not emanate from a conventional 

smoke stack or vent. Examples of 

these nonconventional emissions 

include: 

• Dusty or unpaved roads 

• Stock or raw material piles under 

windy conditions or when moved 

by machinery 

• Conveyor belts, pneumatic lifts, 

clamshells, and draglines 

• Cutting, crushing, grinding, and 

sizing of minerals or other 

materials 

• Plowing, tilling, and bulldozing 

• Open incineration 

• Demolition activities 

• Roof monitors or building vents, 

especially in foundries, iron and 

steel facilities, and related 

industries. 

Because of the irregular shape of 

their emission point or area, 

conducting a conventional Method 9 

test on fugitive emissions may appear 

difficult; however, it usually involves 

only relatively minor adjustments. 

Commonly used procedures for 

observation of fugitive emissions are 

listed below: 

1. If possible, isolate the particular 

emission from other emissions 

by choosing an appropriate 

position for observation. 

2. Adhere to the lighting 

requirements of Method 9 by 

keeping the sun in the 140° 

sector to the observer's back. 

3. Also adhere to Method 9 in 

selecting a position with regard 

to wind direction and a 

contrasting background. 

4. Whenever possible, select the 

shortest path length through the 

plume. 

5. Before taking readings, view the 

emission for several minutes to 

determine its characteristics. 

Changes that may occur in the 

airborne particulate pattern over 

time are important to note and to 

consider in selecting a viewing 

point. 

6. Select the line of sight and the 

viewing point in the emissions so 

that, on the average, the densest 

part of the emissions will be 

observed. It is recommended that 

all subsequent readings in a data 

set be taken at the same relative 

position to the emission source. 

7. The configuration of the emission 

point or area may necessitate 

taking readings at a point 

downwind where the emissions 

have assumed a more 

conventional plume shape. 

8. If the plume cannot be viewed 

through a nearly perpendicular 

angle, corrections may be 

necessary. 

4.4.11 Intermittent Sources • Some 

sources release visible emissions 

intermittently rather than 

continuously; e.g., coke ovens, batch 

operations, single chamber 

incinerators, malfunctioning control 

equipment (in rapping, bag shaking, 

etc.), boilers during soot blowing, and 

process equipment during startup. 

Intermittent emissions may have a 

high opacity for a short time and a 

low or negligible opacity at other 

times. This high-low cycle may be 

repeated at fairly regular intervals. If a 

source is in violation (or in continuous 

compliance) of the applicable standard 

over the 6-minute averaging time 

required by Method 9, it does not 

pose a problem to the visible 

emissions observer. If the pollutantemitting operational cycle of a source 

is less than 6 minutes in duration, 

however, that source may be out of 

compliance only for a portion of each 

6-minute averaging period, which will 

make it difficult or impossible to 

document a violation if the data is to 

be reduced to a 6-minute average. 

If the source is not covered by a 

NSPS or a State Implementation Plan 

that specifies the explicit use of 

Method 9 or another specified 

modification to Method 9, another 

technique for reading intermittent 

emissions of less than a 6-minute 

duration is to use Method 9 

procedures but reduce the averaging 

time to about 3 minutes. This 

reduction will allow the observer to 

tally the number of 3-minute 

violations that occur. Analysis of 

many data sets has confirmed that 

using this method sacrifices little or 

no accuracy. 
P.31 

Section 3.12.4 18 April 1983 

In all cases where sources are not 

subject to NSPS or other federally 

promulgated standard, the existing 

State regulations and specified opacity 

observation methods (if any) must be 

used. Two other techniques that have 

been used to document intermittent 

emissions are the "stopwatch" 

technique (measuring the total 

accumulated time that the opacity 

exceeds the applicable standard) and 

the time-aggregate data reporting 

technique (taking readings every 15 

seconds, tallying the number of 

readings exceeding the standard, and 

multiplying this number by 15 seconds 

to determine the amount of time the 

source is out of compliance during the 

observation period). Many State 

agencies use these latter techniques, 

and have adopted their methods in 

their SIP rules and regulations. EPA 

currently has studies underway to 

evaluate the accuracy and reliability of 

these nonaveraging techniques. 

Table 4.2. Activity Matrix for Visible Emission Determination 

Activity 

Perimeter survey 

Plant entry 

VE Determination 

1. Position 

2. Observations 

3. Field data: VE 

observation form 

4. Facility operating 

data 

Special observation 

problems 

Acceptance 

limits 

Frequency and 

method of 

measurement 

Action if 

requirements 

are not met 

Completed perimeter survey 

Observer should 

follow protocol 

as suggested in 

Subsec 4.2 and 

adhere to confidentiality of 

data 

In accordance 

with Subsec 

4.3.1 

Taken in accordance with Subsec 4.3.1 

Completed data 

form 

Pertinent process data 

obtained 

N/A 

Prior to, following, and during 

(if warranted) 

the VE determination 

Entry prior to 

taking VE readings only if 

necessary; entry 

after VE readings 

to provide plant 

representative 

with data and/or 

to obtain necessary plant process data 

Take a position 

for observation 

as described in 

Subsec 4.3.1 

and document 

on data form 

Make VE determination as 

described in 

Subsec 4.3.1 

Complete data 

form as per instructions and 

examples in 

Subsec 4.3.2 

After VE observations, obtain 

facility data per 

Subsec 4.3.3 

Refer to Subsec 

4.4 when conditions do not permit VE observation under proper position, etc. 

N/A 

N/A 

Follow instructions under 

special problems 

(Subsec 4.4) 

when a proper 

position cannot 

be assumed 

As above 

Complete missing data (if 

possible) or give 

rationale for incomplete data 

Data must be 

obtained as soon 

as possible after 

VE observation 

N/A 

N/A - not applicable. 
P.32 

April 1983 Section 3.12.6 

5.0 Postobservation Operations 

Table 5 1 at the end of this section 

summarizes the quality assurance 

activities for postobservation 

operations. These activities include 

preparation of reports and data 

summaries and validation. 

5.1 Data Summary 

The opacity observations are 

recorded on data forms such as those 

shown in Figures 4.1 and 4.2. Figure 

5.1 is a summary data form for 

manual calculations. This form and 

the calculation procedures are 

discussed in detail in Section 3.12.6. 

It is recommended, however, that a 

computer be used when reducing 

large quantities of data and to avoid 

calculation errors. 

5.2 Reporting Procedures 

Recording opacity observation data 

on a three-part form is most 

convenient. One part can be given to 

the appropriate facility personnel 

immediately following the on-site field 

observation if this is the agency policy 

or procedure, one pan should be 

given to the Agency, and one part 

should be maintained in the 

observer's file. The data form should 

be completed on-site, and it should be 

signed by the observer, the facility 

representative (if applicable), and the 

Company Admiral PokJtr Pfd/lf Date / 5 Jt/fy Sf&Z 

Start time LHQ Emission point Off fArtd Qo'fer 

data validator. All corrections must be 

initialed. The file copy should be 

signed by the data validator. 

Inspection forms alone may not be 

adequate for documenting an 

enforceable violation and can be 

supplemented by a narrative report. It 

is recommended that a summary 

report be made containing the 

following information: 

1. Name and location of facility, 

date and time of inspection, 

name of inspeaor, and name of 

company official(s) contacted. 

2. Brief description of the specific 

process information gathered, 

. Location "*• Ocean AJ. Adm'"*! City, Vo.. 

Start 

no. • 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

II 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

Total 

opacity 

STS 

• W 

•Jto 

840 

ViO 

MS 

A ver age 

opacity 

3fc.8 

Sfc.I 

&(,.*> 

35* 

3 5 0 

3S.i 

26 : 

27 , 

28 

29 

30 

31 

32 

33 

34 

35 

36 

Maxi mum av 

Stan 

no. 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

51 

52 

53 

54 

55 

56 

57 

58 

59 

60 

61 

62 

63 

64 

65 

66 

67 

68 

69 

70 

71 

72 

erage . 

Total 

opacity 

Average 

opacity 

9.% % 

Stan 

no. 

73 

74 

75 

76 

77 

78 

79 

80 

81 

82 

83 

84 

85 

86 

87 

88 

89 

90 

91 

92 

93 

94 

95 

96 

97 

98 

99 

100 

101 

102 

103 

104 

105 

106 

107 

108 

Start 

Total 

opacity 

number 

A ver age 

opacity 

of six mi 

Start 

no. 

109 

110 

111 

112 

113 

114 

115. 

116 

117 

118 

119 

120 

121 

122 

123 

124 

125 

126 

127 

128 

129 

130 

131 

132 

133 

134 

135 

136 

137 

138 

139 

140 

141 

142 

143 

144 

nute a 

Total 

opacity 

verage . 

Average 

opacity 

1 . 

Start 

no. 

145 

146 

147 

148 

149 

150 

151 

152 

153 

154 

155 

156 

157 

158 

159 

160 

161 

162 

163 

164 

165 

166 

167 

168 

169 

170 

171 

172 

173 

174 

175 

176 

177 

178 

179 

180 

Total 

opacity 

Average 

opacity 

Stan 

no. 

181 

182 

183 

184 

185 

186 

187 

188 

Total 

opacity 

189 ! 

190 

191 

192 

193 

194 

195 

196 

197 

198 

199 

200 

201 

202 

203 

204 

205 

206 

207 

208 

209 

210 

211 

212 

213 

214 

215 

216 

A verage 

opacity 

i 

• 

Number ot nonoverlappina averages 

Calculated by Kg . Proffrf" 

in excess of standard «3 Listing stan number of these averages l.l*atVO,/7S 

DatelkjJ]/LtOVLRev,ewed bv If\. r?£i//£.U/£* Date IZJUtXISU 

Figure 5. 7 Visible emission summary data sheet. 
P.33 

Section 3.12.5 April 1983 

particularly any unusual 

occurrences. 

3. Description of the equipment that 

was inspected and its operating 

mode at the time of inspection. 

4. Notation of any excessive 

emissions seen and 

corresponding data from opacity 

continuous emissions monitor if 

available. 

5. Explanation of excessive 

emissions, if available, and 

corrective actions being taken. 

6. Summary of emission points not 

in compliance. 

7. Recommendations for followup 

action. 

One copy of the report, an updated 

plot plan, photographs, and other 

pertinent data should be placed in the 

Agency file. Whenever a violation is 

noted, it is EPA policy to notify the 

facility of the alleged violation and to 

permit them to review the evidence 

against them in a meaningful way. 

The importance of a good file cannot 

be overstated. This file represents the 

official Agency documentation of 

compliance history, the latest 

information on the source's operation 

and compliance status. The file also 

provides the means of communicating 

source conditions to other staff 

members. A thorough and accurate 

historical record on source inspections 

and opacity readings is essential to 

good operation and any necessary 

compliance/enforcement actions. 

5.3 Data Validation 

All opacity observation data 

obtained for compliance determination 

should be validated by senior staff 

assigned this responsibility. Data 

validation procedures are described in 

References 16 and 17. These data 

should be checked to the extent 

possible for their completeness, the 

correctness of source, the emission 

point and description, the background, 

and the process and control 

equipment in use. The calculation of 

the average opacities and highest 

average opacity also should be 

checked. All calculation checks should 

agree within acceptable roundoff 

errors. If possible, any questionable 

data should be reviewed with the 

observer. Ideally the data validation 

should occur as soon as possible after 

the observations are recorded so that 

questions may be resolved. Any other 

calculations made for the purpose of 

supporting the data (e.g., the effect of 

angle of observation on the observed 

opacity) should also be verified. Note: 

Any corrections in the data must be 

forwarded to all interested parties so 

that they may correct their records (a .. 

data form should have been given to 

them after the opacity observations 

were completed). 

5.4 Equipment Check 

A check of the equipment following 

the opacity observations helps to 

ensure the quality of the data. Any 

indication of equipment 

damage/malfunction should be 

recorded on an equipment log and 

noted for purposes of data validation. 

The malfunctioning equipment should 

be repaired, adjusted, or replaced so 

that the equipment will be available 

for subsequent on-site field 

observations. 

Table 5.1. Activity Matrix for Postobservation Operations 

Frequency and Action if 

Acceptance method of requirements 

Activity limits measurement are not met 

Data summary 

Repon ing procedures 

Data validation 

Equipment check 

Completed data 

form 

Completed report and data 

forms 

All checks 

should agree 

within acceptable roundoff 

error 

All equipment/ 

apparatus 

should be 

checked for satisfactory operation after each 

VE observation 

day 

See Subsec 

3.12.6 for instructions for 

calculations 

Use 3-part form 

as suggested in 

Subsec 5.2 

Make data validation check as 

soon as possible 

after VE observation 

Check equipment for 

damage/malfunctions 

Complete the 

data summary 

Complete the 

necessary data 

forms and reporting procedure 

Forward all 

corrections of 

the data/calculations to the 

interested 

parties 

Note on equipment log and 

repair, adjust or 

rep/ace the 

equipment 
£.34 

April 1983 Section 3.12.6 

Three types of calculations are 

described in this section: (1) the 

calculation of the average opacity for 

the specified time period (usually 6 

min. or 24 observations recorded at 

15-s intervals), (2) the calculation of 

the path length through the plume 

(seldom needed), and (3) the 

prediction of steam plume formation 

(seldom needed). In the first 

calculation, the 6-min running (or 

rolling) averages may be required. To 

minimize errors in the calculations, 

another individual should check all 

calculations for each VE 

determination for compliance. If a 

difference greater than a typical 

roundoff error is detected, the 

corrections should be made and 

initialed by the one making the 

correction. Table 6.3 at the end of this 

section summarizes the quality 

assurance activities for these 

calculations. 

6.1 Calculation of Average 

Opacity 

Figure 6.1 shows actual opacity 

data taken at one company 

(unspecified) for two 6-min periods. 

Note: Any corrections made by an 

observer must be initialed and the 

corrected value used in the 

computation of an average. The 

calculations can be checked by 

obtaining the row and column 

subtotals; the totals of these subtotals 

must be identical. 

Running 6-min averages are 

calculated from data on Figure 6.2 

and reported as described below. 

Running averages can include a timelapse break in opacity readings when 

caused by an element that makes taking 

a valid reading difficult (e.g., fugitive 

emissions, improper background, or 

process shutdown). Running averages 

should not contain time-lapse breaks 

in the readings as a result of the 

observer's desire not to take visible 

emission data for personnel reasons 

when conditions exist that would 

allow the observer to take valid 

opacity data (e.g., eye strain or no 

desire to continue readings). Figure 

6.3 is included to provide an easy 

reference between the VE reading 

time on Figure 6.1 and the start 

number on Figure 6.2. The start 

numbers are used to find the 

corresponding observation time for 

the beginning of the calculated six 

minute average. 

6.0 Calculations 

Determination of the running 

average is generally performed by 

computer or by a hand calculator. The 

main purpose of the calculations is to 

determine the number of 6-min 

periods in excess of the standard and 

the greatest value for any 6-min 

period. It is also suggested, but not 

required, that the opacity readings be 

plotted on a graph showing percent 

opacity versus time, with a straight 

line connecting each subsequent 

reading. 

6.1.1 Use of Computer for 

Calculations - It is highly 

recommended that a computer be 

used to calculate and plot data. 

Programming will vary with the 

language used by the particular 

computer, but the basic principle is as 

follows: 

Input: 

1. Enter all VE readings with their 

corresponding start number or 

identifying start time. 

Computation: 

1. The first average opacity reading 

is obtained by averaging the first 

24 opacity readings. 

2. Each succeeding running 

average is obtained from the 

previous one by adding the next 

observation reading and 

subtracting the first observation 

in the series and then dividing by 

24 (assuming 6-min running 

average). 

Printout 

1. The computer should print all VE 

readings with their 

corresponding number or time. 

This printing wiil ensure that all 

readings have been entered 

properly. 

2. The computer should search all 

averages and print the highest 

average opacity and its 

corresponding number or time 

interval. 

3. Starting at the first interval, the 

computer should search for all 

nonoverlapping 6-minute periods 

in excess of the standard. Each 

interval's average opacity value 

and corresponding number or 

time should be printed out. 

4. Finally the computer should plot 

VE readings versus time 

intervals. If the computer has a 

plotter, it should be used. If not, 

the values can be plotted without 

connecting lines. If desired, the 

computer can bracket intervals in 

excess of the standard. 

6.1.2 Use of Hand Calculator for 

Calculations - When a hand calculator 

is used, the calculation procedures 

are the same as those for the 

computer, except that they must be 

performed manually. All data should 

be recorded on the VE Summary Data 

Sheet (see Figure 6.2) if desired. To 

avoid calculating average opacify 

values that are less than the standard, 

the following procedure can be used. 

The total value for the 24 readings 

should be calculated first, and the 

total opacity should be entered at 

Start no. 1. 

Each succeeding total value can be 

obtained and recorded by adding the 

difference between the value dropped 

and the one added. These calculations 

can be performed easily without a 

calculator. If desired, the average 

opacity reading could then be 

calculated only for those totals that 

exceed the total allowable opacity 

limit (e.g., 20% x 24 = 480). Therefore, 

a total opacity of 480 or greater would 

be an exceedance of a 20 percent 

opacity standard. Method 9 does, 

however, require that the accuracy of 

the method be taken into account 

when determining possible violations 

of applicable opacity standard. 

It is suggested that when the 

opacity standard has been exceeded 

for any 24 consecutive readings, the 

data be hand-plotted with each VE 

reading versus its time interval. These 

plots fit best on graph paper scaled 10 

lines to the inch. Each 15-second 

reading can be plotted at 1/2 spacing, 

thereby allowing 20 readings per inch. 

If desired, intervals of opacity in 

excess of the standards can be 

marked on this plot. It is much easier 

to visualize a trend in opacity with 

time with such a graphical 

presentation than with tabulated 

numerical readings as shown in 

Figure 6.4. 

6.2 Calculation of Path 

Length Through the Plume 

The observer should be located so 

that only one plume diameter is being 

sighted through. In rare cases, the 

observer has no choice but to be 

relatively close to the stack so that the 

view is up through the plume rather 

than across it. In these cases, this 

extra width of plume should be 
P.35 

Section 3.12.6 April 1983 

SOURCE NAME 

AP/lfM L PDVER PLAhTT 

ADDRESS 

KX OCSLAlJ /fOAD 

CITY 

AD/MKM- cir^ 

PHONE , 

STATE 

VA 

ZIP , 

SOURCE ID NUMBER 

NZD5 ¥S7Zl 

PROCESS EQUIPMENT 

0l<- FIRED GOttZit. 

CONTROL EQUIPMENT 

eLL&TUDSTAnc pfeClPlTATDg. 

OPERA TING MODE 

£AS£z.OAZ> 

OPERA TING MODE 

RAfTlM 

DESCRIBE EMISSION POINT < , A/A 

START STOP l /""" 

HEIGHT ABOVE GROUND LEVEL 

START /O0 ' STOP lS~ 

DISTANCE FROM OBSERVER 

START tyCO' STOPS' 

HEIGHT RELATIVE TOOBSERVER 

START /Ot> ' STOP •/* * 

DIRECTION FROM OBSERVER 

START [ME- STOP ^ ^ 

DESCRIBE EMISSIONS „ lAje. 

START i*"7"* '""STOP ^ 

EMISSIONCOLOR^ 

START^/^gfbP ^ 

WATER DROPLETS PRESENT 

NO& YESO 

PLUME TYPE CONTINUOUS f / 

FUGITIVE'C INTERMITTENT G 

IF WA TER DROPLET PLUME. 

ATTACHEDC DETACHEDO 

POINT IN THE PLUME A T WHICH OPACITY WAS DETERMINED 

START f0'A2OVe.^i?OLG^T'STQp ^ 

DESCRIBE BACKGROUND 

START SKY STOP (j/BHOr<eM CL.OUPS 

BACKGROUND COLOR ajj^y 

START &LUE STOP^fa/Tt 

WIND SPEED 

START /6n-fih STOP 20mfl\ 

AMBIENT TEMP. 

START"Z^>°f STOP tJ 

SKY CONDITIONS fARTi-Y 

START GL£A& STOPCUWDY 

WIND DIRECTION , 

START <*5K/ STOP i/ 

WET BULB TEMP. RH.percent 

Source Layout Sketch Draw North Arrow 

AR7XACJCS f 

POWCK 

PLAfST 

&-s < 

T 

/ 

Plume and — JL, 

Stack ^*,0**K^ w ^**t ^ur 

2) 

It mission roint ^_^ 

/ASH 

[POfiD 

Observers Position 

)t>

 S * > ^ w 

Sun Location Line' 

^^a** * 

rtAC t 

COMMENTS ~M, 

\jSZAb T^, OIL 

1 HA VE RECEIVED A COPY OF THESE OPACITY OBSERVA TIONS 

SIGNATURE ilfTUUiouy^ ?? 0\OaV^jt 

TITLE " 

SHIFT MANAOl££-

OATE ^ „ 

OBSERVATION DATE 

\SEC 

MIN\ 

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 

26 

27 

28 

29 

30 

0 

3 0 

5 5 

3 5 

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3 5 

50 

3 5 

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5 0 

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3 0 

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3 5 

sd 

3 5 

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A VERA GE OPA CITY FOR / 

HIGHEST PERIOD ^O/O 

\S£ C 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

0 

ST OP TIME 

f3¥X 

15 

1 

50 

*' ! 

52 

53 

54 

55 

56 

57 

58 

59 

60 

j 

1 

30 45 

1 • 

1 

1 

1 

1 

, 

1 

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! 

1 

1 

1 

1 

i 1 

1 

NUMBER OF READINGS ABOVE 

Y(0 % WERE /f 

RANGE OF OPACITY READINGS _-> / /\d / 

MINIMUM QCPfO MAXIMUM faU /O 

OBSERVERS NAME (PRINT) 

(/£.. PeOFFITOBSERVER'S SIGN A TUBE DATE 

/s JUL* ex 

ORGANIZATION , A ^ - , _ _ 

CERTIFIED BY „*,„ * 

fASTER/VI 7TSCHA»CAi_ ASSOC. 

VERIFIED BY 

*PA 

DATk MAY HSZ 

DATE 

/ 5 AUO (HIFigure 6.1. Visible emission observation form. 
P.36 

April 1983 Section 3.12.6 

Visible Emission Summary Data Sheet 

Company 

Start time Emission point 

.Location //Z&7&}A/aD.; jOMipiL££fy 

Start 

no. 

1 

2 

3 

4 

5 

6 

7 

8 

Q 

to 

II 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23. 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

Total 

opacity 

685' 

A verage 

ooacity 

31 •£ 

3&rk 

3S.& 

&2-

Stan 

nn 

37 

3'8 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

51 

52 

53 

54 

55 

56 

57 

58 

59 

60 

61 

62 

63 

64 

65 

66 

67 

68 

69 

70 

71 

72 

Total 

ooacitv 

A verage 

opacity 

Start 

no. 

73 

74 

75 

76 

77 

78 

79 

80 

81 

82 

83 

84 

85 

86 

87 

88 

89 

90 

91 

92 

93 

94 

95 

96 

97 

98 

99 

100 

101 

102 

103 

104 

105 

106 

107 

108 

Total 

opacity 

A verage 

opacity 

Start 

no. 

109 

110 

111 

112 

113 

114 

115 

116 

117 

118 

119 

120 

121 

122 

123 

124 

125 

126 

127 

128 

129 

130 

131 

132 

133 

134 

135 

136 

137 

138 

139 

140 

141 

142 

113 

144 

Total 

opacity 

• 

• 

Average 

opacity 

Start 

no 

145 

146 

147 

148 

149 

150 

151 

152 

153 

154 

155 

156 

157 

158 

159 

160 

161 

162 

163 

164 

165 

166 

167 

168 

169 

170 

171 

172 

173 

174 

175 

176 

177 

178 

179 

180 

Total 

opacity 

Average 

opacity 

Start 

no. 

181 

182 

183 

184 

J 85 

186 

187 

188 

189 

190 

191 

192 

193 

194 

195 

196 

197 

\l98 

199 

200 

201 

202 

203 

204 

205 

206 

207 

208 

209 

210 

211 

212 

213 

214 

215 

216 

Total 

opact<, 

A verage 

opacity 

Maximum J>A£L . % Start number of >t six mi nute average / / . average 

Number of nonover/appingaverauesin excess of standard -2 Listing s'art numoer 

Calculated by . \Z-t7, PR6FF3T Date f&Jid&ASlReviewed by 

of these 

— Date 

averages '>'*•/ 

Figure 6.2. Visible emission summary data sheet. 

 
P.37 

Section 3.12.6 April 1983 

VISIBLE EMISSION OBSERVA TION FORM 

SOURCE NAME 

ADDRESS 

CITY 

PHONE 

STATE ZIP 

SOURCE ID NUMBER 

PROCESS EQUIPMENT 

CONTROL EQUIPMENT 

OPERA TING MODE 

OPERA TING MODE 

DESCRIBE EMISSION POINT 

START STOP 

HEIGHT ABOVE GROUND LEVEL 

START STOP 

DISTANCE FROM OBSERVER 

START STOP 

HEIGHT RELATIVE TO OBSERVER 

START STOP 

DIRECTION FROM OBSERVER 

START STOP 

DESCRIBE EMISSIONS 

START STOP 

EMISSION COLOR 

START STOP 

WA TER DROPLETS PRESENT 

NO "2 Vf SG 

PLUME TYPE CONTINUOUS D 

FUGITIVE D INTERMITTENT 0 

IF WA TER DROPLET PLUME: 

ATTACHEDC DETACHED a 

POINT IN THE PLUME A T WHICH OPACITY WAS DETERMINED 

START STOP 

DESCRIBE BACKGROUND 

1 START STOP 

1 BACKGROUND COLOR 

START STOP 

WIND SPEED 

START STOP 

AMBIENT TEMP. 

START STOP 

SKY CONDITIONS 

START STOP 

WIND DIRECTION 

START STOP 

WET BULB TEMP. RH.percent 

Source Layout Sketch Draw North Arrow 

o 

X 

Sun-r^t- Wind _>. 

Plume and ~ ^^X Observers Position 

^ 7 40° ' *^«^ ^ 

Sun Location Line 

COMMENTS 

1 HA VE RECEIVED A COPY OF THESE OPACITY OBSERVA TIONS 

SIGNA TURE 

TITLE DATE 

OBSERVATION DATE 

\SEC 

MllV\ 

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 

26 

27 

28 

29 

30 

0 

1 

5 

9 

13 

17 

21 

25 

29 

33 

37 

41 

45 

49 

53 

57 

61 

65 

69 

73 

77 

81 

85 

89 

93 

97 

101 

105 

109 

113 

117 

15 

2 

6 

10 

14 

18 

22 

26 

30 

34 

38 

42 

46 

50 

54 

58 

62 

66 

70 

74 

78 

82 

86 

90 

94 

93 

102 

106 

110 

114 

118 

AVERAGE OPACITY 

HIGHEST PERIOD 

RANGE OF OPACIT) 

MIN 

OBSERVER'S NAML 

OBSERVERS SIGN/ 

ORGANIZATION 

CERTIFIED BY 

VERIFIED BY 

30 

3 

7 

11 

15 

19 

23 

27 

31 

35 

39 

43 

47 

51 

55 

59 

63 

67 

71 

75 

79 

83 

87 

91 

95 

99 

103 

107 

111 

115 

,779 

FOR 

'REAL 

IMUM 

" (PRIN 

\TURE 

START TIME 

45 

4 

8 

12 

16 

20 

24 

28 

32 

36 

40 

44 

48 

52 

56 

60 

64 

68 

72 

76 

80 

84 

88 

92 

96 

100 

104 

108 

112 

116 

120 

)INGS 

Tl 

-

*\S£C 

Mlfhs 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

SO 

57 

52 

53 

54 

55 

56 

57 

58 

59 

60 

NUMB 

0 

121 

125 

129 

133 

137 

141 

145 

149 

153 

157 

161 

165 

169 

173 

177 

181 

185 

189 

193 

197 

201 

205 

209 

213 

217 

221 

225 

229 

233 

237 

ER OF 

9 

MAXI 

DATE 

DATt 

DATE 

STOP TIME 

15 

122 

126 

130 

134 

138 

142 

146 

150 

154 

158 

162 

166 

170 

174 

178 

182 

186 

190 

194 

198 

202 

206 

210 

214 

218 

222 

226 

230 

234 

238 

30 

123 

127 

131 

135 

139 

143 

147 

151 

155 

159 

163 

167 

171 

175 

179 

183 

187 

191 

195 

199 

203 

207 

211 

215 

219 

223 

227 

231 

235 

239 

READINGS > 

i WERE 

MUM 

45 

124 

128 

132 

136 

140 

144 

148 

152 

156 

160 

164 

168 

172 

176 

180 

184 

188 

192 

196 

200 

204 

208 

212 

216 

220 

224 

228 

232 

236 

240 

4B0VE 

Figure 6.3. Opacity data form with start numbers shown. 
P.38 

April 1983 Section 3 12.fi 

£ 

Time, minutes 

Figure 6.4. Plot opacity versus time. 

acknowledged and the individual data 

values may be adjusted 

mathematically in the final data report 

to show the increase in opacity 

reading due to the added path length. 

These adjusted opacity readings 

should be used in determining 

averages in excess of the standard. 

The calculation of observed path 

length is shown in Appendix A of 

Reference 1 and is included here for 

the observer's convenience. Figure 

6.5 shows how the slant angle varies 

with distance from an elevated 

source. As an observer moves closer 

to the base of the stack, the angle of 

sight and the path length through the 

plume both increase; this causes the 

observed opacity to increase even 

though the cross-plume opacity 

remains constant. This situation only 

applies when the opacity is read 

through a vertically rising plume and 

the observer is on the same plane as 

the base of the stack. 

The actual opacity may be 

calculated from the observed opacity, 

if the slant angle 8 is known, or from 

the known height of the stack and the 

distance from the observer to the base 

of the stack. 

Method 1 (when slant angle 8 is known) 

1 -( Qs ) = ToEquation 6-1 

100 

(1 -T&x 100 = Oe 

where 

00= observed opacity in % 

T0= observed transmittance 

F = cosine of 8 

Oc= corrected opacity in %. 

Method 2 (where distances are known) 

Y 

F = -/HJ + Y2 Equation 6-2 

1-( Op ) = T, 

100 

(1 -Tl)x 100 = Oc 

where 

00= observed opacity in % 

T0= observed transmittance 

F= cosine of 8 

Oe= corrected opacity in % 

H= height of stack 

Y= distance of observer from stack. 

Note: Since the correction is a 

power funaion, the correaion must 

be made on each opacity reading and 

the corrected values used for 

calculations, in lieu of the correction 

being conducted on the reduced 

(averaged) data. 

Table 6.1 presents the opacity 

corrected for slant angle or viewing 

angle 6 versus the full range of 

opacity readings. For angles less than 

approximately 18° the adjustment is 

relatively insignificant. 

6.3 Predicting Steam Plume 

Formation 

The psychrometric chart can be 

used in conjunaion with a simple 

Path Length through Plume 

Figure 6.5. Variation of observation angle and pathlength with distance from an elevated source. 
Section 3.12.6 April 1983 

Table 6.1. 

Measured 

opacity. 

% 

95 

90 

85 

80 

75 

70 

65 

60 

55 

50 

45 

40 

35 

30 

25 

20 

15 

10 

5 

0 

Opacity C 

0 

95 

90 

85 

80 

75 

70 

65 

60 

55 

50 

45 

40 

35 

30 

25 

20 

15 

10 

5 

0 

orrectior 

10 

95 

90 

85 

80 

75 

70 

64 

59 

55 

50 

45 

40 

35 

30 

25 

-20 

15 

10 

5 

0 

for Star 

Slant 

20 

94 

89 

83 

78 

73 

68 

63 

58 

53 

48 

43 

38 

33 

29 

24 

19 

14 

9 

4 

0 

n Angle 

angle 8. deqrees 

30 

93 

86 

81 

75 

70 

65 

60 

55 

50 

45 

40 

36 

31 

27 

22 

18 

13 

9 

4 

0 

40 

90 

83 

77 

71 

65 

60 

55 

50 

46 

41 

37 

32 

28 

24 

20 

16 

12 

8 

3 

0 

50' 

85 

77 

71 

65 

59 

54 

49 

45 

40 

36 

32 

28 

24 

21 

17 

13 

10 

7 

3 

0 

60 

78 

68 

62 

55 

50 

45 

41 

37 

33 

29 

26 

23 

19 

16 

13 

11 

8 

5 

3 

0 

equation to predict the formation of a 

visible water vapor (steam) plume. The 

psychrometric chart is a graphical 

representation of the solutions of 

various equations of the state of air 

and water vapor mixtures (see Figure 

6.6). Both the ambient and stack 

emission data points on the chart are 

referred to as their "state point" and 

represent one unique combination of 

the following five atmospheric 

properties. 

Dry bulb temperature - The actual 

ambient temperature; represented by 

the horizontal axis. 

Wet bulb temperature - The 

temperature indicated by a "wet bulb" 

thermometer ( a regular thermometer 

that has its bulb covered with a wet 

wick and exposed to a moving air 

stream); represented by the curved 

axis on the left side of the chart 

(saturation temperature). 

, Relative humidity - The ratio of the 

partial pressure of the water vapor to 

the vapor pressure of water at the 

same temperature; values are 

represented by the set of curved lines 

originating in the lower left portion of 

the chart. 

Absolute humidity (humidity ratio) -

The mass of water vapor per unit 

mass of air; expressed as grains per 

pound or pound per pound; 

represented by the vertical axes. 

Specific volume - The volume 

occupied by a unit mass of air, 

expressed as cubic feet per pound; 

represented by the diagonal lines 

running from lower right to upper, left. 

The relationships shown in the chart 

differ with changes in barometric 

pressure. The chart included in this 

section is for a barometric pressure of 

29.92 inches of mercury. Therefore, 

with use of wet bulb dry bulb 

technique, if the actual pressure is 

less than about 29.5 inches of 

mercury, the humidity ratio should be 

calculated from the equation and not 

the chart. 

Plotting the values for any two of 

the five atmospheric properties 

Table 6.2. Vapor Pressures of Water at Saturation 

Temp.. 

°F 

30 

40 

50 

60 

70 

80 

90 

too 

110 

120 

130 

0 

0.1647 

1 

0.1716 

2 

0.1803 

Water vapor pressure. 

3 4 5 

0.1878 0.1955 0.2035 

in. Hq 

6 

0.2118 

7 

0.2203 

8 9 

0.2292 0.2383 

0.2478 0.2576 0.2677 0.2783 0.2891 0.3004 0.3120 0.3240 0.3364 0.3493 

0.3626 

0.5218 

0.7392 

1.032 

1.422 

1.932 

2.596 

3.446 

4.525 

0.3764 

0.5407 

0.7648 

1.066 

1.467 

1.992 

2.672 

3.543 

4.647 

0.3906 0 4052 0.4203 0.4359 0.4520 0.4586 0.4858 0.5035 

0.5601 

0.7912 

1.102 

1.513 

2.052 

2.749 

3.642 

4.772 

0.5802 0.6009 0.6222 

0.8183 0.8462 0.8750 

1.138 1.175 1.213 

1.561 1.610 1.660 

2.114 2.178 2.243 

2.829 2.911 2.995 

3.744 3.848 3.954 

4.900 5.031 5.165 

0.6442 

0.9046 

1 253 

1.712 

2.310 

3.081 

4.063 

5.302 

0.6669 

0.9352 

1.293 

1.765 

2.379 

3.169 

4.174 

5.442 

0.6903 0.7144 

0.9666 0.9989 

1.335 1.378 

1.819 1.875 

2.449 2.521 

3.259 3.351 

4.289 4.406 

5.585 5.732 

determines the values for the 

remaining three properties. For 

example, by using a sling 

psychrometer to measure the wet and 

dry bulb temperatures, one can 

determine the relative humidity, the 

absolute humidity, and the specific 

volume of the air. 

To predia the occurrence of a 

visible steam plume, both the ambient 

air conditions and the stack gas 

conditions must be known or 

calculated and located on the 

psychrometric chart. If any portion of 

the line connecting the two points lies 

to the left of the 100 percent relative 

humidity line, it is an indication that 

the change of the exhaust gas from 

the stack state conditions to the 

ambient air state will be accompanied 

by the condensation of the water 

vapor present in the exhaust stream 

and a resultant visible steam plume. 

Obtaining the state point for the 

ambient air conditions is relatively . 

simple; as previously indicated, the 

wet and dry bulb temperatures, which 

will determine a unique state point, 

can be measured by using a sling 

psychrometer. Often the only data 

available for determining the state 

point of the stack gas are the dry bulb 

temperature of the exhaust gas 

stream and its moisture content.* 

However, a relationship exists 

between the moisture content and the 

humidity ratio (or absolute humidity), 

as shown in the following equation: 

MR=062(MC) 

1 - MC Equation 6-3 

where 

HR = humidity ratio, in pound of water 

vapor per pound of dry air 

MC =__%_ moisture content, expressed 

100 

as a decimal. 

The following sample problem 

demonstrates the use of this 

equation. 

Given; 

Ambient conditions 

Dry bulb temperature = 70°F 

Wet bulb temperature = 60°F 

Barometric pressure = 29.92 in. Hg 

Effluent gas conditions 

Dry bulb temperature = 160°F 

Moisture content =16 8% - 0.168 

100 

Find: 

Ambient relative humidity 

Exhaust gas humidity ratio 

Determine whether or not 

condensed water (steam plume) 

will form 

'These are usually obtained from plant records 

or are estimated from recent source test data. 
P.40 

April 1983 Section 3.12.6 

Solution: 

Plot ambient wet bulb and dry bulb 

temperatures (see Figure 6.5). 

Ambient relative humidity = 55%. 

Exhaust gas humidity ratio = HR 

HR=Q.62(MC ) 

1 - MC 

=0.62(0.168) 

1 -0.168 

= 0.125 lb/lb dry air 

Plot humidity ratio and stack dry bulb 

temperature (see Figure 6.6). Connect 

the ambient state point and stack gas 

state point with a straight line (see 

Figure 6.5). The line crosses the 100 

percent relative humidity line; thus, 

formation of a visible water vapor 

plume is probable. 

When the wet bulb/dry bulb 

technique is used and the barometric 

pressure is less than 29.5 in. Hg, it is 

suggested that Equation 6-5 be used 

to calculate the moisture content 

(MC). 

where 

VP = Vapor pressure of H2O using 

Equation 6-6 

Paos = Barometric pressure 

VP = SVP - (3.57x10"4) (P.bl) (Ta-T„) 

(1 +"•"», - 32) 

1571 Equation 6-6 

Table 6.3 Activity Matrix for Calculations 

where 

SVP = Saturated vapor pressure in in. 

Hg at wet bulb temperature 

(taken from Table 6.2) 

Ta = Temperature of dry bulb 

thermometer, °F 

T„ = Temperature of wet bulb 

thermometer, °F. 

Calculation 

Acceptance 

limits 

Frequency and 

method of 

measurement 

Action if 

requirements 

are not mst 

Average opacity 

MC=V ^ 

. aDs Equation 6-5 

Running average 

opacity 

Path length through 

the plume 

Predicting steam 

plume 

Data in Fig 6.1 

completed and 

checked to within roundoff error 

Data in Fig 6.2 

completed end 

checked 

No limits have 

been set 

No limits have 

been set 

For each compliance test, 

perform independent check 

of data form and 

calculations 

As above 

For each compliance test with 

the slant angle 

>18°, calculate 

using Eq. 6-1 

Use psychrometric chart and 

Equation 6-3 

Complete the 

data and initial 

any changes in 

calculations 

As above 

Perform calculations 

Perform calculations 

4L 60 80 100 120 140 160 180 200 220 240 260 280 300 320 

Dry Bulb Temperature. °F 

Figure 6.6. Psychrometric chart for problem solution. 

• - State Point lor Ambient Conditions. 

I I - State Point for Stack Gas Conditions. 
P.41 

April 1983 Section 3.12.7 

An audit is an independent 

assessment of data quality. 

Independence is achieved by using 

observers and data analysts other 

than the original observer/analyst. 

Routine QA checks for proper 

observer positioning and 

documentation are necessary to 

obtain good quality data. Table 7.1 at 

the end of this section summarizes 

the QA activities for auditing. 

Two performance audits are 

recommended for VE readings: 

1. Audit of observer by having an 

experienced observer make 

independent readings. 

2. Audit of data forms and 

calculations. 

In addition, it is recommended that a 

systems audit be conducted by an 

experienced observer at the same 

time the performance audit of visible 

emissions is conducted. The two 

performance audits are described in 

Subsection 7.1 and the systems audit 

is described in Subsection 7.2. 

7.1 Performance Audits 

Performance audits are quantitative 

evaluations of the quality of visible 

emission data. 

7.1.1 Performance A udrt of Visible 

Emissions - In this audit, an 

experienced observer goes with the 

observer being audited and both 

observers take the readings 

simulataneously (using the same time 

piece) and complete the data forms as 

independently as is practical. The 

audit is intended for observers in their 

first year and observers who have not 

made opacity observation in the field 

in over a year. The differences 

between the two readings serve as a 

measure of accuracy assuming the 

experienced observer reads the "true 

opacity." Because this assumption is 

not necessarily correct, the difference 

between the two readings is a 

combined measure of accuracy of 

both observers. For a minimum of six 

minutes (24 readings), the average of 

the absolute differences should be less 

than 10 percent, and no individual 

differences should exceed 20 percent. 

(The values of 10% and 20% 

suggested for the limits are the 

approximate results of combining the 

allowable errors of the two observers; 

e.g.,V(7.5)2 + (7.5r» = 10.6%, and 

V152 + 15' = 21.2%. This audit should 

be performed twice in a year for the 

7.0 Auditing Procedures 

first year of an observer and 

whenever conditions tend to warrant 

them thereafter. Calculate %A using 

Equation 7-1. 

%A = |VE (observer) - VE (auditor^ 

Equation 7-1 

where 

VE (observer) = average and individual VE 

reading(s) of the 

observer being 

audited 

VE (auditor)= average and 

individual VE 

reading(s) of the 

auditor. 

7.1.2 Performance A udit of Data 

Calculations - This audit is an 

independent check of all calculations 

performed for the summary VE report. 

Every calculation should be checked 

within round-off error. This audit 

should be conducted on at least 7 

percent of the annual numbers of VE 

summary reports. 

7.2 System Audit 

A system audit provides an on-site 

qualitative inspection and review of 

the total inspeaion. This audit 

includes a check of the "Record of 

Visual Determination of Opacity," 

Figure 9.1 of Section 3.12.8, and the 

top portion of the "Observation 

Table 7.1. Activity Matrix for Auditing Procedures 

Record," Figure 9.2 of Section 3.12.8. 

In addition, the auditor should assess 

the visible emission inspection 

technique used by the auditee. This 

portion of the system audit is best 

handled in conjunaion with the 

performance audit described in the 

previous Subseaion 7.1.1. Therefore, 

the frequency of the system audit 

should coincide with the frequency of 

the performance audits of visible 

emissions. Some observations to be 

made by the auditor are listed in 

Figure 7.1. 

Audit 

Acceptance 

limits 

Frequency and 

method of 

measurement 

Action if 

requirements 

are not met 

Performance audit 

of visible emissions 

Performance audit 

of data calculations 

System audit 

Individual observations within 

±20%: average 

(absolute) deviation within 

±10% 

Original and 

Lcheck calculations agree 

within round-off 

error 

Conduct observations as described in this 

section of 

the Handbook 

At least two 

times during the 

first year; simultaneous observation and 

data recording 

Seven percent 

of tests for 

compliance, perform independent check on 

all calculations 

At least two 

times during the 

first year; use 

audit checklist 

(Fig 7.1) 

Review observation techniques 

Check and correct all calculated results 

(averages) 

Explain to observer the deviations from recommended 

procedures: 

note the deviations on Fig 7.1 
P.42 

Section 3.12.7 April 1983 

Name of individual(s) audited 

Affiliation NetU Y^k SU-U rfqetctf 

Auditor name . .Affiliation 'Region j f £PA 

Date of audit _ 

M J* ers<s £-

<2-2S- 82 Auditor signature 7^ ^ &AA^U~ 

Yes No Comment Operation 

J 

1/ 

J 

S 

Jj 

JL 

J£ 

s 

1 / 

S 

jJ. 

/ 

y 

ccri-Piclentici/ly rehired 

j£ 

J//A_ 

j / 

7. Equipment satisfactory 

2. Data forms completed 

3. Post-notification (counesy obligation) performed 

4. Correct identification of point of emissions 

5. Plume associated with process generation point 

6. Credentials okay 

7. Observer acted in professional and couneous manner 

8. Proper observer position 

9. Opacity readings complete 

10. Ancillary measurements available 

11. Camera used to validate sightings/source identification 

12. Facility personnel given a copy of raw data 

13. Mutiple sources/plumes/outlets 

14. Lighting conditions satisfactory 

75. Background conditions (raining, etc.) satisfactory 

16. Slant angle recorded 

17. Fugitive emissions 

18- Time of day recorded 

19. Recertified within iast 6 months 

General comments: 

&*>*&', M of the. / ^ &*d''«3S «*'* /ess ~

t/l3/f *°7

* 

in Ooac/'ty ^ro/n tJf£ <S«^r^e. 

Figure '/. 1. Method 9 checklist for auditors. 
April 1983 Section 3.12.8 

Method 9—Visual 

Determination of the Opacity 

of Emissions from Stationary 

Sources 

Many stationary sources discharge 

visible emissions into the atmosphere; 

these emissions are usually in the 

shape of a plume. This method 

involves the determination of plume 

opacity by qualified observers. The 

method includes procedures for the 

training and certification of observers, 

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 

may be controllable and some of 

which may not be controllable in the 

field. Variables which can be 

controlled to an extent to which they 

no longer exert a significant influence 

upon plume appearance include: 

Angle of the observer with respea 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, viewad 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 

8.0 Reference Method8 

approaches zero as the color and 

luminescence contrast decrease 

toward zero. As a result, significant 

negative bias and negative errors can 

be made when a plume is viewed 

under less contrasting conditions. A 

negative bias decreases rather than 

increases the possibility that a plant 

operator 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 

sets 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 error' 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 sulfuric acid plant), 99 

percent of the sets were read 

with a positive error of less than 

7.5 percent opacity; 95 percent 

were read with a positive error 

of less than 5 percent opacity. 

The positive observational error 

associated with an average of twentyfive readings is therefore established. 

The accuracy of the method must be 

taken into account when determining 

possible violations of applicable 

opacity standards. 

1. Principle and 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 § 60.11(b) and for 

qualifying observers for visually 

determining opacity of emissions. 

'For a set. positive error - average opacity 

determined by observers' 25 observations — 

average opacity determined from 

transmissometer's 25 recordings. 

2. Procedures. 

The observer qualified in 

accordance with paragraph 3 of this 

method shall use the following 

procedures for visually determining 

the opacity of emissions: 

2.1 Position. The qualified observer 

shall stand at a distance sufficient to 

provide 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, as much as 

possible, make his observations from 

a position such that his line of vision 

is approximately perpendicular to the 

plume direction, and when observing 

opacity of emissions from rectangular 

outlets (e.g. roof monitors, open 

baghouses, noncircular stacks), 

approximately perpendicular to the 

longer axis of the outlet. The 

observer's line of sight should not 

include more than one plume at a 

time when multiple stacks are 

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 multiple 

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 time, estimated distance to 

the emission location, approximate 

wind direction, estimated wind speed, 

description of the sky condition 

(presence and color of clouds), and 

plume background are recorded on a 

field data sheet at the time opacity 

readings are initiated and completed. 

2.3 Observations. Opacity 

observations shall be made 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 plumes When 

condensed water vapor is present 

within the plume as it emerges from 

the emission outlet, opacity 

observations shall be made beyond the 

point in the plume at which 
P.44 

Section 3.12.8 April 1983 

Company 

Location 

Test Number. 

Date 

Type Facility _ 

Control Device 

Hours of Observation 

Observer 

Observer Certification Date 

Observer Affiliation 

Point of Emissions 

Height of Discharge Point 

Clock Time 

Observer Location 

Distance to Discharge 

Direction from Discharge 

Height of Observation Point 

Background Description 

Weather Conditions 

Wind Direction 

Wind Speed 

Ambient Temperature 

Sky Conditions (clear, 

overcast. % clouds, etc.) 

Plume Description 

Color 

Distance Visible 

Other Information 

Initial Final Summary of Average Opacity 

Set 

Number 

• 

Time 

Start—End 

Opacity 

Sum Average 

Readings ranged from. .to. . % opacity 

The source was/was not in compliance with 

at the time evaluation was made. 

Figure 9.1 Record of Visual Determination of Opacity 

Page. .ot. 

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 

made. 

2.3.2 Detached steam plume. When 

water vapor in the plume condenses 

and becomes visible at a distina 

distance from the emission outlet, the 

opacity of emissions should be 

evaluated at the emission outlet prior 

to the condensation of water vapor 

and the formation of the steam plume. 

2.4 Recording 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 

momentary 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-second intervals. Divide the 

observations recorded on the record 

sheet into sets of 24 consecutive 

observations. A set is composed of 

any 24 consecutive observations. Sets 

need not be consecutive in time and 

in no case shall two sets overlap. For 

each set of 24 observations, calculate 

the average by summing the opacity 

of the 24 observations and dividing 

this sum by 24. If an applicable 
P.45 

April 1983 Section 3.12.8 

Company 

Location 

Test Number 

Date 

Observer 

Type Facility 

Point of Emissions 

Hr. Min. 

0 

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 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

SO 

57 

52 

53 

54 

55 

56 

57 

58 

59 

Seconds 

0 IS 30 45 

Steam Plume 

(check if applicable) 

Attached Detached Comments 

Figure 9.2 Observation Record 

(FR Doc. 74-26150 Filed 11-11-74; 8:45 am) 

Page of 
P.46 

Section 3.12.8 April 1983 

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 an example.) 

3. Qualifications and testing. 

3.1 Certification requirements. To 

receive certification as a qualified 

observer, a candidate must be tested 

and demonstrate the ability to assign 

opacity readings in 5 percent 

increments to 25 different black 

plumes and 25 different white 

plumes, with an error not to exceed 

15 percent opacity on any one reading 

and an average error not to exceed 7.5 

percent opacity in each category. 

Candidates shall be tested according to 

the procedures described in paragraph 

3.2. Smoke generators used pursuant 

to paragraph 3.2 shall be equipped 

with a smoke meter which meets the 

requirements of paragraph 3.3. 

The certification shall be valid for a 

period of 6 months, at which time the 

qualification procedure must be 

repeated by any observer in order to 

retain certification. 

3.2 Certification procedure. 

The certification test consists of 

showing 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 

determined. If a candidate fails to 

qualify, the complete run of 50 

readings must be repeated in any 

retest. The smoke test may be 

administered as part of a smoke 

school or training program, and may 

be preceded by training or 

familiarization runs of the smoke 

generator during which candidates 

are shown black and white plumes of 

known opacity. 

3.3 Smoke generator 

specifications. 

Any smoke generator used for the 

purposes of paragraph 3.2 shall be 

equipped with a smoke meter 

installed to measure opacity across 

the diameter of the smoke generator 

stack. The smoke meter output shall 

display instack opacity based upon a 

path length equal to the stack exit 

diameter, on a full 0 to 100 percent 

chart recorder scale. 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 condua of each 

smoke reading test. At the 

completion of each test, the zero and 

span drift shall be checked and if the 

drift exceeds ±1 percent opacity, the 

conditions shall be corrected prior to 

conducting any subsequent 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 replacement of 

the photocell or associated elearonic 

circuitry including the chart recorder 

or output meter, or every 6 months, 

whichever occurs first. 

Table 9-1. Smoke Meter Design and 

Performance Specifications 

Parameter: Specification 

a. Light source Incandescent lamp 

operated at 

nominal rated 

voltage. 

b. Spectral Photopic (daylight 

response of spectral response of 

photocell. the human eye— 

reference 4.3). 

c. Angle of view 15° maximum total 

angle. 

d. Angle of projec- 15° maximum total 

tion angle. 

e. Calibration error ±3% opacity, maximum 

1. Zero and span ±1% opacity. 30 

drift. minutes. 

g. Response time <5 seconds. 

3.3.1 Calibration. 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 

rpadings are produced without 

adjustment. Simulated 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 at the lamp, as 

installed, that the lamp is operated 

within ±5 percent of the nominal 

rated voltage. 

3.3.2.2 Spearal response of 

photocell. Verify from manufacturer's 

data that the photocell has a photopic 

response; i.e., the spearal sensitivity 

of the cell shall closely approximate 

the standard spectral-luminosity curve 

for photopic vision which is 

referenced in (b) of Table 9-1. 

3.3.2.3 Angle 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 may be calculated from: 8-2 

tan"1 d/2L, where 8 = total angle of 

view; d = the sum of the photocell 

diameter •*• the diameter of the limiting 

aperture; and L = the distance from 

the photocell to the limiting aperture. 

The limiting aperture is the point in 

the path between the photocell and 

the smoke plume where the angle of 

view is most restriaed. In smoke 

generator smoke meters this is 

normally an orifice plate. 

3.3.2.4 Angle of projection. Check 

construction geometry to ensure that 

the total angle of projection of the 

lamp on the smoke plume does not 

exceed 15°. The total angle of 

projeaion may be calculated from: 8 -

2 tan"1 d/2L, where 8 = total angle of 

projeaion; d = the sum of the length 

of the lamp filament + the diameter of 

the limiting aperture; and L = the 

distance from 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 smoke meter. 

This check is accomplished by first 

calibrating the smoke meter according 

to 3.3.1 and then inserting a series of 

three neutral-density filters of 

nominal opacity of 20. 50, and 75 

percent in the smoke meter 

pathlength. Filters calibrated within 

±2 percent shall be used. Care should 

be taken when inserting the filters to 

prevent stray light from affecting the 

meter. Make a total of five 

nonconsecutive readings for each 

filter. The maximum error on any one 

reading shall be 3 percent opacity. 

3.3.2.6 Zero and span drift. 

Determine the zero and span drift by 

calibrating and operating the smoke 
P.47 

April 1983 Sectio

n 3.12.8 

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 L. Field 

Operations and Enforcement Manual 

for Air, U.S. Environmental Protection 

Agency, Research Triangle Park, N.C, 

APTD-1100, August 1972, pp. 4.1-

4:36. 

4.3 Condon. E.U., and Odishaw, H., 

Handbook of Physics. McGraw-Hill 

Co., NY., NY., 1958. Table 3.1, p. 6-

52. 
P.48 

April 1983 Section 3.12.9 

9.0 References and Bibliography 

8. 

10. 

11 

Technical Assistance Document: 

Quality Assurance Guideline for 

Visible Emission Training 

Programs, EPA-600/S4-83-011. 

Federal Register, Volume 39. 

No. 219. November 12, 1974. 

Method 9 - Visual 

Determination of the Opacity of 

Emissions from Stationary 

Sources (Appendix A). 

Conner. W.D. Measurement of 

Opacity by Transmissometer and 

Smoke Readers. EPA 

Memorandum Report. 1974. 

Conner, W.D., and J.R. 

Hodkinson. Optical Properties 

and Visual Effects of Smoke 

Plumes. U.S. Environmental 

Protection Agency. Office of Air 

Programs, Edison Electric 

Institute, and Public Health 

Service. 1967. AP-30. 

Coons, J.D., et al. Development, 

Calibration, and use of a Plume 

Evaluation Training Unit. JAPCA 

15: 199-203, May 1965. 

Crider, W.L.. and J.A. Tash. 

Status Report: Study of Vision 

Obscuration by Nonblack 

Plumes. JAPCA 14:161-165, 

May 1964. 

U.S. Environmental Protection 

Agency. Evaluation of EPA 

Smoke School Results. Emission 

Standards and Engineering 

Division, Office of Air Guality 

Planning and Standards. October 

9, 1974. 

Evaluation and Collaborative 

Study of Method for Visual 

Determination of Opacity of 

Emissions from Stationary 

Sources. EPA-650/4-75-009. 

Malmberg, K.B. EPA Visible 

Emission Inspection Procedures. 

U.S. Environmental Protection 

Agency, Washington. D.C. 

August 1975. 

Osborne, M.C, and MR . 

Midgett. Survey of 

Transmissometer Used in 

Conducting Visible Emissions 

Training Courses. Environmental 

Monitoring and Support 

Laboratory, U.S. Environmental 

Protection Agency. March 1978. 

Ringelmann, M. Method of 

Estimating Smoke Produced by 

Industrial Installations. Rev. 

Technique. 268, June 1898. 

12. Weir, A., Jr., D.G. Jones, and 

L.T. Paypay. Measurement of 

Particle Size and Other Factors 

Influencing Plume Opacity. 

Paper presented at the 

International Conference on 

Environmental Sensing and 

Assessment. Las Vegas, Nevada, 

September 14-19, 1975. 

13. U.S. Environmental Protection 

Agency. APTI Course 439 

Visible Emissions Evaluation. 

Student Manual. EPA-450/3-

78-106, 1978. 

14. U.S. Environmental Protection 

Agency. APTI Course 439 

Visible Emissions Evaluation. 

Instructor Manual. EPA-450/3-

78-105, 1978. 

15. U.S. Environmental Protection 

Agency. Guidelines for 

Evaluation of Visible Emissions. 

EPA-340/1-75-007, 1975. 

16. U.S. Environmental Protection 

Agency. Screening Procedures 

for Ambient Air Quality Data. 

EPA-450/2-78-037. July 1978. 

17. Validation of Air Monitoring 

Data. EPA-600/4-80-030, June 

1980. 
P.49 

April 1983 1 Section 3.12.10 

Blank data forms are provided on 

the following pages for the 

convenience of the QA Handbook 

user. No documentation is given on 

these forms because it would detract 

from their usefulness. Also, the titles 

are placed at the top of the figures, as 

is customary for a data form. These 

forms are not required format, but are 

intended as guides for the 

development of an organizations' own 

program. To relate the form to the 

text, a form number is also indicated 

in the lower right-hand corner (e.g.. 

Form M9-1.1 , which implies that the 

form is Figure 1.1. in Section 3.12.1 

of the Method 9 Handbook). Any 

future revisions of this form can be 

documented by adding A, B, C (e.g., 

1.1 A, 1.1B). The data forms included 

in this section are listed below. 

Form Title 

1.2 Sample Certification Test Form 

2.1 Procurement Log 

4.1 Visible Emission Observer's 

Plant Entry Checklist 

4.1 Visible Emission Observer's 

Plant Entry Checklist (Reverse 

Side) 

4.2 Visible Emission Observation 

Form 

4.2 Visible Emission Observation 

Form (Reverse Side) 

5.1 Visible Emission Summary Data 

Sheet 

6.2 Visible Emission Summary Data 

Sheet (same as Figure. 5.1) 

7.1 Method 9 Checklist for Auditors 

10.0 Data Forms 
Section 3.12.10 

Sample Certification Test Form 

April 1983 

P.50 

Al filiation 

Course loc. 

Date 

Reading 

number 

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 

ot.nn 

nd direction to stack 

0 5 10 15 

0 5 10 15 

0 5 10 15 

0 5 10 IS 

0 5 10 15 

0 5 10 15 

0 5 10 15 

0 5 10 15 

0 5 10 15 

0 5 10 15 

0 5 10 15 

0 5 10 15 

0 5 10 15 

0 5 10 15 

0 5 10 15 

0 5 10 IS 

0 5 10 15 

0 5 10 15 

0 5 10 15 

0 5 10 15 

0 5 10 15 

0 5 10 15 

0 5 10 75 

0 5 10 15 

0 5 10 15 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

Ni 

SI 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

ime 

<Y 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

Sunglasses 

SO 55 60 

50 55 60 

50 55 60 

50 55 60 

50 55 60 

50 55 60 

50 55 60 

SO 55 60 

50 55 60 

50 55 60 

50 55 60 

50 55 60 

50 55 60 

50 55 60 

50 55 60 

50 55 60 

SO 55 60 

SO 55 60 

50 55 60 

50 55 60 

50 55 60 

SO 55 60 

50 55 60 

50 55 60 

50 55 60 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

R 

V 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

un Number 

Vind 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

75 80 

85 

85 

85 

85 

85 

85 

85 

85 

85 

85 

85 

85 

as 

as 

85 

85 

85 

85 

85 

85 

85 

85 

85 

85 

85 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

Devia 

Error 

im 

ion 

too 

too 

100 

700 

700 

inn inn 

mn 

inn 

100 

i nn 

inn 

mn 

mn 

mn 

mn 

mn 

mn 

WO 

mn 

mn 

mn 

mn 

linn 

Reading 

number 

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 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

5 

5 

5 

5 

5 

5 

5 

5 

5 

5 

5 

5 

5 

5 

5 

5 

5 

5 

5 

5 

5 

5 

5 

5 

5 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

10 

15 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

15 

15 

15 

15 

15 

15 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

20 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

25 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

30 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

35 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

40 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

45 

50 

50 

50 

50 

50 

50 

50 

50 

50 

50 

50 

50 

50 

50 

50 

SO 

SO 

SO 

50 

50 

50 

50 

50 

50 

50 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

55 

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 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

65 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

70 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

75 

80 

80 

80 

80 

80 

80 

80 

80 

80 

ao 

80 

80 

80 

ao 

80 

80 

80 

80 

80 

80 

ao 

80 

80 

80 

80 

85 

85 

85 

85 

85 

85 

85 

85 

85 

85 

85 

85 

85 

85 

85 

85 

85 

85 

85 

85 

35 

85 

as 

85 

85 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

90 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

95 

Devia 

Error 

mn 

mn 

mn 

mn 

mn 

mn 

mn 

100 

mn 

mn 

tpn 

mn 

mn 

mn 

ton 

mn 

mn 

100 

700 

mn 

mn 

mn 

mn 

100 

too 

tmn 

Quality Assurance Handbook M9-1.2 
P.51 

April 1983 Section 3.12.10 

Procurement Log 

Item description Quantity 

Purchase 

order 

number Vendor 

Date 

Ordered Received Cost Disposition Comments 

Quality Assurance Handbook M9-2.1 
P.52 

|li n •ill) II II !!> • "»'» . 

Section 3.12.10 April 1983 

Visible Emission Observer's Plant Entry Checklist 

Source name and address Observer 

Agency 

Date of VE observation 

Previous company contact (if applicable) 

Title 

Purpose of visit 

Emission points at which VE observations to be conducted 

Authority for entry (see reverse side) 

Plant safety requirements 

D Hardhat 

D Safety glasses 

D Side shields (on glasses) 

tJ Goggles 

D Hearing protection 

Specify 

• Safety shoes (steel-toed) 

D Insulated shoes 

D Gloves 

D Coveralls 

D Dust mask suggested 

Q Respirator(s) 

Specify 

• Other 

D Specify 

Company official contacted (on this visit) 

Title 

Quality Assurance Handbook M9-4.1 
P.53 

April 1983 6 Section 3.12.10 

Visible Emission Observer's Plant Checklist (Continued) 

Authority for Plant Entry: Clean Air Act. Section 114 

(a)(2) the Administrator or his authorized representative upon presentation of his credentials • 

(A) shall have a right of entry to. upon or through any premises of such person or in which any records required to be 

maintained under paragraph (1) of this section are located, and 

(B) may at reasonable times have access to. and copy of any records, inspect any monitoring equipment or methods 

required under paragraph (1), and sample any emissions which such person is required to sample under 

paragraph (1). 

(b)(1) Each State may develop and submit to the Administrator a procedure for carrying out this section in such State If the 

Administrator finds the State procedure is adequate, he may delegate to such State any authority he has to carry out this 

section. 

(2) Nothing in this subsection shall prohibit the Administrator from carrying out this section in a State. 

(c)Any records, reports or information obtained under subsection (a) shall be available to the public except that upon a showing 

satisfactory to the Administrator by any person that records, reports, or information, or particular part thereof, (other than 

emission data) to which the Administrator has access under this section if made public would divulge methods or processes 

entitled to protection as trade secrets of such person, the Administrator shall consider such record, report, or information or 

particular portion thereof confidential in accordance with the purposes qf Section 1905 of Title 18 of the United States 

concerned with carrying out this Act or when relevant in any proceeding under this Act." 

Confidential Information: Clean Air Act. Section 114 (see above) 41 Federal Register 36902. September 1. 1976 

If you believe that any of the information required to be submitted pursuant to this request is entitled to be treated as 

confidential, you may assert a claim of business confidentiality, covering all or any part of the information, by placing on (or 

attaching to) the information a cover sheet, stamped or typed legend, or other suitable notice, employing language such as 

"trade secret," "proprietary." or "company confidential." Allegedly confidential portions of otherwise nonconfidential 

information should be clearly identified. If you desire confidential treatment only until the occurrence of a certain event; the 

notice should so state. Information so covered by a claim will be disclosed by EPA only to the extent, and through the procedures, 

set forth at 40 CFR. Part 2. Subpart B (41 Federal Register 36902. September 1, 1976.) 

If no confidentiality claim accompanies.this information when it is received by EPA. it may be made available to the public by 

EPA without further notice to you. 

Quality Assurance Handbook M9-4.1 
P.54 

Section 3.12.10 April 1983 

Visible Emission Observa 

SOURCE NAME 

ADDRESS 

CITY 

PHONE 

STATE ZIP 

SOURCE ID NUMBER 

PROCESS EQUIPMENT 

CONTROL EQUIPMENT 

OPERA TING MODE 

OPERA TING MODE 

DESCRIBE EMISSION POINT 

START STOP 

HEIGHT ABOVE GROUND LEVEL 

START STOP 

DISTANCE FROM OBSERVER 

START STOP 

HEIGHT RELATIVE TO OBSERVER 

START STOP 

DIRECTION FROM OBSERVER 

START STOP 

DESCRIBE EMISSIONS 

START STOP 

EMISSION COLOR 

START STOP 

WATER DROPLETS PRESENT 

NO C YESO 

PLUME TYPE CONTINUOUS 0 

FUGITIVE 0 INTERMITTENT C 

IF WA TER DROPLET PLUME 

ATTACHED^, DETACHED C 

J POINT IN THE PLUME A T WHICH OPACITY WAS DETERMINED 

| START STOP 

DESCRIBE BACKGROUND 

START STOP 

BACKGROUND COLOR 

START STOP 

WIND SPEED 

START STOP 

AMBIENT TEMP 

START STOP 

SKY CONDITIONS 

START STOP 

WIND DIRECTION 

START STOP 

WET BULB TEMP RH. per cent 

Source Layout Sketch Draw North Arrow 

o 

Sun-fy Wind .j . 

Plume and ~ 

Stack ^^-^***7 

Observers Position 

^^.-^^ 14U" "> . 

Sun Location Line 

COMMENTS 

1 HA VE RECEIVED A COPY OF THESE OPACITY OBSERVA TIONS 

SIGNA TURE 

TITLE DATE 

ion Form 

OBSERVATION OATE 

\SEC 

MIN\ 

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 

26 

27 

28 

29 

30 

0 75 30 

| 

! 

i 

i 

i i 

j 

j 

| 

| 

START TIME 

45 

A VERAGE OPACITY FOR 

HIGHEST PERIOD 

*^EC 

Mlti\ 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

42 

0 

. 

50 

51 

52 

53 

54 

55 

56 

57 

58 

59 

60 

STOP TIME 

15 30 

; 

45 

I 

| 

I 

I 

I 

NUMBER OF READINGS ABOVE 

% WERE 

RANGE OF OPACITY READINGS 

MINIMUM MAXIMUM 

OBSERVERS NAME /PRINT) 

OBSERVERS SIGNA TURE DATE 

ORGANIZA TION 

CERTIFIED BY 

VERIFIED BY 

DATE 

DATE 

Quality Assurance Handbook M9-4.2 
P.55 

April 1983 Section 3.12.10 

Visible Emission Observation Form 

This form is designed to be used in conjunction with EPA Method 9. "Visual Determination of the Opacity of Emissions from Stationary 

Sources." Any deviations, unusual conditions, circumstances, difficulties, etc.. not dealt with elsewhere on the form should be fully noted 

in the section provided for comments. Following are brief descriptions of the type of information that -needs to be entered on the form; for a 

more detailed discussion of each part of the form, refer to the "User's Guide to the Visible Emission Observation Form." 

'Source Name - full company name, parent company or division 

information, if necessary. 

'Sky Conditions • indicate cloud cover by percentage or by 

description (clear, scattered, broken, overcast, and coior of clouds). 

'Address • street (not mailing) address or physical location 

of facility where VE observation is being made. 

Phone • self-explanatory. 

Source ID Number • number from NEDS. CDS. agency file. etc. 

'Process Equipment. Operating Mode • brief description of process 

equipment (include ID no.) and operating rate. % capacity utilization, 

and/or mode (e.g.. charging, tapping). 

'Control Equipment. Operating Mode • specify control device type(s) 

and % utilization, control efficiency. 

'Describe Emission Point • stack or emission point location, geometry, 

diameter, color; for identification purposes. 

'Height Above Ground Level • stack or emission point height, from 

files or engineering drawings. 

'Height Relative to Observer • indicate vertical position of observation 

point relative to stack top. 

'Distance From Observer - distance to stack ±10%: to determine, use 

rangefinder or map. 

'Direction From Observer • direction to stack; use compass or map; 

be accurate to eight points of compass. 

'Describe Emissions • include plume behavior and other physical 

characteristics (e.g.. looping, lacy, condensing, fumigating, secondary 

particle formation, distance plume visible, etc.). 

'Emission Color • gray, brown, white, red. black, etc. 

Plume Type: 

Continuous • opacity cycle >6 minutes 

Fugitive • no specifically designed outlet 

Intermittent - opacity cycle <6 minutes 

" ' Water Droplets Present • determine by observation or use wet sling 

psychrometer; water droplet plumes are very white, opaque, and 

billowy in appearance, and usually dissipate rapidly. 

"If Water Droplet Plume: 

Attached - forms prior to exiting stack 

Detached - forms after exiting stack 

"Point in the Plume at Which Opacity was Determined • describe 

physical location in plume where readings were made (e.g., 4 in. above 

stack exit or 10 ft after dissipation of water plume). 

'Describe Background • object plume is read against, include 

atmospheric conditions (eg., hazy). 

'Background Color • blue, white, new leaf green, etc. 

'Windspeed • use Beaufort wind scale or hand-held anomometer; 

be accurate to ±5 mph. 

' Wind Direction • direction wind is from: use compass; be 

accurate to eight points. 

'Ambient Temperature • in °F or °C. 

"Wet Bulb Temperature • the wet bulb temperature from the 

sling psychrometer. 

"Relative Humidity • use sling psychrometer; use local U.S. 

Weather Bureau only if nearby. 

'Source Layout Sketch • include wind direction, associated 

stacks, roads, and other landmarks to fully identify location pf 

emission point and observer position. 

Draw North Arrow - point line of sight in direction of emission 

point, place compass beside circle, and draw in arrow parallel 

to compass needle. 

Sun Location Line - point line of sight in direction of emission 

point, place pen upright on sun location line, and mark location 

ot sun when pen's shadow crosses the observers position. 

"Comments - factual implications, deviations, altercations, 

and/or problems not addressed elsewhere. 

Acknowledgment • signature, title, and date of company official 

acknowledging receipt of a copy of VE observation form. 

'Observation Date • date observations conducted. 

'Start Time, Stop Time - beginning and end times of observation 

period (e.g.. 1635 or 4:35 p.m.). 

'Data Set - percent opacity to nearest 5%: enter from left to right 

starting in left column. 

'Average Opacity for Highest Period • average of highest 24 

consecutive opacity readingsNumber of Readings Above (Frequency Count) count of total 

number of readings above a designated opacity. 

'Range of Opacity Readings: 

Minimum - lowest reading 

Maximum • highest reading 

'Observer's Name • print in fullObserver's Signature, Date • sign and date after performing final 

calculations. 

•Required by Reference Method 9, other items 

suggested. 

"Required by Method 9 only when particular 

'actor could affect the reading. 

'Organization • observer's employer. 

'Certifier, Date - name of "smoke school" certifying observer and 

date of most recent certification. 

Verifier, Date - signature of person responsible for verifying 

observer's calculations and date of verification. 

Quality Assurance Handbook M.9-4.2 
P.56 

Section 3.12.10 April 1983 

Visible Emission Summary Data Sheet 

Company . 

Start time 

.Date . Location 

Emission point 

Start 

no. 

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 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

36 

Total 

opacity 

Average 

opacity 

Start 

no. 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

51 

52 

53 

54 

55 

56 

57 

58 

59 

60 

61 

62 

63 

64 

65 

66 

67 

68 

69 

70 

71 

72 

Total 

opacity 

Average 

opacity 

Start 

no 

73 

74 

75 

76 

77 

78 

79 

80 

81 

82 

83 

84 

85 

86 

87 

88 

89 

90 

91 

92 

93 

94 

95 

96 

97 

98 

99 

100 

101 

102 

103 

104 

105 

106 

107 

108 

Total 

opacity 

Average 

opacity 

Start 

no 

109 

110 

111 

112 

113 

114 

115 

116 

117 

118 

119 

120 

121 

122 

123 

124 

125 

126 

127 

128 

129 

130 

131 

132 

133 

134 

135 

136 

137 

138 

139 

140 

141 

142 

143 

144 

Total 

opacity 

• 

Average 

opacity 

Start 

no 

145 

146 

147 

148 

149 

150 

151 

152 

153 

154 

155 

156 

157 

158 

159 

160 

161 

162 

163 

164 

165 

166 

167 

168 

169 

170 

171 

172 

173 

174 

175 

176 

177 

178 

179 

180 

Total 

opacity 

Average 

opacity 

Start 

no 

181 

182 

183 

184 

J85 

186 

187 

188 

189 

190 

191 

192 

193 

194 

195 

196 

197 

198 

199 

200 

201 

202 

203 

204 

205 

206 

207 

208 

209 

210 

211 

212 

213 

214 

215 

216 

Total A verage 

opacity opacity 

Maximum average 

Number of nonoverlapping averages 

Calculated by _ 

. % Start number of six minute average . 

in excess ot standard 

Date . 

Listing start number of 

-Reviewed by 

these 

Date 

averages _ 

Quality Assurance Handbook M9-5.1 

and M9-6.2 
P.57 

April 1983 Section 3.12.10 

Method 9 Checklist for Auditors 

Name of individual(s) audited 

Affiliation 

Auditor name . 

Date of audit _ 

.Affiliation 

.Auditor signature 

Yes I No Comment Operation 

1. Equipment satisfactory 

2. Data forms completed 

3. Post-notification (courtesy obligation) performed 

4. Correct identification of point of emissions 

5. Plume associated with process generation point 

6. Credentials okay 

7. Observer acted in professional and courteous manner 

8. Proper observer position 

9. Opacity readings complete 

10. Ancillary measurements available 

11. Camera used to validate sightings/source identification 

12. Facility personnel given a copy of raw data 

13. Mutip/e sources/plumes/outlets 

14. Lighting conditions satisfactory 

15. Background conditions (raining, etc.) satisfactory 

16. Slant angle recorded 

17. Fugitive emissions 

18. Time of day recorded 

19. Recertified within last 6 months 

General comments: 

Quality Assurance Handbook M9-7.1