OAR Box 1115 

Prepped by Ryan Dugan 

Document Number: 

92) IV-A-3 

Docket Number: 

A-84-22 

Printed 4/18/2008 10:52:09 AM Sheet 92 of 94 

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MRItt 

A-84-22 

IV-A-3 

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Opacity Method Compliance Guide 

for Fugitive Sources 

Final Report 

For U.S. Environmental Protection Agency 

Attn: Karen Randolph 

EPA Contract No. 68-02-4463 

MRI Project No. 8913-K(43) 

November 27, 1991 

MIDWEST RESEARCH INSTITUTE 425 Volker Boulevard, Kansas City, MO 64110-2299 • (816) 753-7600 
P.3 

PREFACE 

This report was prepared for the U.S. Environmental Protection Agency 

(EPA) by Midwest Research Institute (MRI) under Assignment 43 of EPA Contract 

No. 68-02-4463. This assignment was conducted to identify currently used 

inspection procedures for fugitive sources. The task was issued on May 23, 1991, 

for completion by November 30, 1991. Ms. Karen Randolph of EPA's Stationary 

Source Compliance Division (SSCD) directed the work with the aid of Mr. Chris Oh. 

This report was prepared by Mr. Frank Pendleton. He was assisted by Ms. Karen 

Connery, Mr. DeWayne Coffman, and Mr. Gary Garman. 

Approved: 

MIDWEST RESEARCH INSTITUTE 

Charles F. Holt, Ph.D., Director 

Engineering and Environmental 

Technology Department 

November 27, 1991 

MRI-M\fl89.3-43 "| *| 
P.4 

CONTENTS 

Preface i i 

Acknowledgments iv 

Executive Summary ES-1 

1. Introduction 1 

2. Telephone Survey 3 

3. Literature Search 21 

4. Conclusions -' 27 

5. Recommendations 28 

6. References 29 

Appendices 

A. Method 9 A-1 

B. Method 22 B-1 

C. Method 1 C-1 

MRI-M\R8913-43 1 *| *| 
P.5 

ACKNOWLEDGMENTS 

The MRI project team would like to express our appreciation to Ms. Karen 

Randolph (EPA Work Assignment Manager) and Mr. Chris Oh of EPA's SSCD for 

their assistance and direction in this assignment. We would also like to 

acknowledge Mr. Kirk Foster of EPA's SSCD, Mr. Roy Huntley of the EPA's 

Emissions Measurement Branch (EMB), and Mr. John Summerhays of EPA 

Region V for their participation in the project review work group. Finally, we 

would like to express our thanks to everyone who provided input to the 

"Telephone Survey" of this effort. 

Mfll-MVfv8913-*3 T V 
P.6 

EXECUTIVE SUMMARY 

The U.S. Environmental Protection Agency (EPA) Stationary Source 

Compliance Divisipn (SSCD) has a need to provide guidance to States wishing to 

use opacity as an inspection and enforcement tool for nonprocess fugitive 

particulate emission sources. 

Some States already have promulgated opacity rules, which are used on 

various nonpoint particulate sources. It was noted that these rules utilize a variety 

of standards and methods to accomplish their objectives. 

To enhance the sharing of information between States interested in 

developing opacity rules for nontraditional sources, the SSCD requested that 

Midwest Research Institute (MRI) compile the experiences of various States in a 

report. This report thus presents practical information on the use of opacity as an 

inspection technique for nonprocess fugitive particulate sources. 

Telephone calls were made to regulators in 7 Regional offices, 10 States, 

and the District of Columbia. In addition, inspectors in nine States and three 

federal officials were contacted. A good cross-section, ranging from heavily 

urbanized to largely rural states, were included. Each was questioned about their 

views of the advantages and disadvantages of opacity as an inspection technique 

for their specific fugitive particulate sources. 

The following conclusions were derived from the telephone interviews: 

• Almost everyone contacted stated that opacity techniques provide an 

effective, inexpensive, and immediate means of inspecting particulate 

emission sources. 

• Although some stated that opacity techniques could be applied to 

almost any industrial source, techniques were most often used to 

inspect emissions from vehicular traffic, storage piles, and material 

handling. 

• Although most regulators acknowledged that opacity violations could 

be prosecuted on their own merit, they prefer accompanying 

emissions measurement, records, or work-practice violations prior to 

going to court. 

MHI-M\R8913-*3 ES-1 
P.7 

In addition, a number of refinements to generally accepted techniques for reading 

opacity from fugitive sources were identified during the telephone contacts. 

To supplement the telephone survey, a search was conducted of 

environmental literature for relevant information. The following is a summary of 

pertinent information obtained from these documents: 

• One study by regulators in the State of Tennessee argues convincingly 

that more attention should be devoted to the training of smoke 

readers, especially for those inspectors who will be required to 

measure opacity from nonprocess fugitive sources. 

• A number of studies emphasized the unique benefits (e.g., immediacy) 

and limitations (e.g., measurement error) of opacity measurement 

techniques. Future opacity rules must be written with these 

characteristics in mind. 

Information collected during this literature search suggests that agencies 

wishing to promulgate new opacity standards for fugitive sources should: 

• Set new standards sufficiently high to allow for the observational error 

associated with reading fugitive plumes. 

• Cite inspection methods addressing factors that influence readings 

from fugitive sources. These include the time interval between 

. readings, reader orientation with respect to the source and the sun, 

wind speed and direction, and the background upon which the plume 

is viewed. 

• Follow up any source violating opacity standards with investigation of 

records keeping, measurement, or work practice rules. 

Finally, it is suggested that the EPA consider the following recommendations 

to promote opacity as a viable inspection tool: 

• Develop a uniform set of field procedures and an accompanying 

quality assurance program for visible emissions training programs for 

fugitive plumes. The programs need to account for horizontal plumes 

that often originate below eye level, are located near interfering 

plumes, and must be read against noncontrasting backgrounds). 

• Further investigate the relationship between the opacity of a fugitive 

emission plume and the corresponding mass emission rate. Such 

study would improve the effectiveness of visual inspection techniques 

for enforcing mass concentration standards. 

MRI-M\H8913-13 ES-2 
P.8 

SECTION 1 

INTRODUCTION 

The U.S. Environmental Protection Agency (EPA) Stationary Source 

Compliance Division (SSCD) has a need to provide guidance to States wishing to 

use opacity as an inspection and enforcement tool for nonprocess fugitive 

particulate emission sources. 

Some States already have promulgated opacity rules for various nonpoint 

particulate sources. In each instance, these rules were tailored to address specific 

sources within the jurisdiction of the agency enforcing them. Because of the 

variety of concerns faced by different state agencies, a variety of methods and 

standards are found. 

To enhance the sharing of information between States interested in 

developing new opacity rules for nontraditional sources, the SSCD requested that 

Midwest Research Institute (MRI) study the experiences of states currently using 

these rules and compile this information into a report. 

To achieve these goals, MRI: 

• Contacted a cross section of the regulatory community for information 

on opacity standards for fugitive particulate emissions. 

• Searched commercial computer data bases for literature containing 

information on the use of opacity methods for inspecting nonpoint 

particulate emission sources. 

• Searched internal MRI files for reports describing the use of opacity 

techniques for nontraditional sources. 

• Compiled this information in the form of a detailed description of 

various methods, their successes and failures, and recommendations 

for future legislation. 

MRI-MvR8913->-3 
P.9 

The results of this activity are presented in the following sections. Section 2 

contains a summary of the telephone survey. Section 3 contains a summary of the 

literature search. Section 4 summarizes these results and lists conclusions. 

Section 5 lists recommendations, and Section 6 contains references. 

MRI-M\R8913-43 
P.10 

SECTION 2 

TELEPHONE INTERVIEWS 

The first task was to identify States with an interest in opacity-based 

regulatory approaches to monitor nonpoint sources of particulate emission. MRI 

began this task by contacting several federal officials to request the names and 

phone numbers of potential agency contacts. 

MRI contacted each state or region identified to learn of their operating 

experience with opacity standards. A broad cross-section of the regulatory 

community was included. These contacts included federal officials with particular 

interest in opacity methods, state and regional regulators, and inspectors. 

Representatives of each Region and the States, shaded ih Figure 1, were 

contacted. 

It was expected that these agency personnel could provide practical insight 

into the utility and reliability of various opacity rules for controlling fugitive 

emissions. Toward this end, each regulatory official was asked the following types 

of questions: 

1. What type of nonpoint particulate sources do you regulate with 

opacity methods? 

2. Could you describe the opacity field inspection procedure for each of 

these sources? 

3. What action is potentially triggered by a violation of an opacity limit? 

4. Could you provide a copy of your opacity procedures for all nonpoint 

particulate sources? 

5. What other techniques are used to monitor these sources? 

6. Could you specify any advantages or disadvantages of using opacity 

inspection methods over other techniques? 

MRI-M\fv8913-43 
Figure 1. States Participating In This Study 

Participating State 
P.12 

7. If you had the opportunity to write a new opacity inspection 

procedure, what would you do differently? 

8. Are you aware of any other States with opacity rules for nonpoint 

sources? Could you provide us with the names and telephone 

numbers of the people administering these programs? 

9. Could you provide the names and phone numbers of some of your 

inspectors that have field experience in these procedures? 

Calls were then made to the inspectors identified. These inspectors were 

questioned about the practical aspects of opacity compared to other inspection 

techniques. Inspectors were asked the following types of questions: 

1. Could you describe the opacity methods that you use to inspect 

nonpoint sources? 

2. How long have you been using opacity methods on nonpoint sources? 

3. What other methods or techniques are you using to inspect these 

sources? 

4. Are opacity methods an improvement over the methods you used 

previously? 

5. If you had the opportunity to make changes in your current opacity 

methods, what changes would you make? 

6. What would be contained in an ideal opacity inspection method for 

nonpoint particulate sources? 

Regulators in ail 7 Regional offices, 10 States, and the District of Columbia 

provided information on their experiences in the monitoring of nonprocess fugitive 

sources with opacity techniques. A summary of the inspection techniques used by 

these agencies is provided in Table 1. In addition, inspectors from nine States and 

three federal officials with specific interest in opacity methods also responded. 

Finally, five respondents indicated that they have very little knowledge of this 

topic, but each recommended other contacts. 

MRI-M\A8913-43 
P.13 

TABLE 1. SUMMARY OF INSPECTION TECHNIQUES USED BY VARIOUS STATES 

Region 

I 

II 

III 

IV 

V 

State 

Connecticut 

Maine 

New York 

West Virginia 

District of 

Columbia 

Kentucky 

Tennessee 

MR1-MVR8913-43 

Methods 

9 

9 

9 

9 

9 

9 

9 

9 

9 

9 

Opacity when 

violations occur 

Vanes for each 

state 

Exceeding 40% 

for more than 

5 min out of 1 h 

20% for 

process 

sources; 5% 

allowed for 

fugitive sources 

20% limit for 

fugitive 

emissions 

Varies for each 

state 

20% 

"No visible 

emissions" for 

fugitive sources 

20% for 

emissions 

outside property 

2-40%, 40% 

allowed for 

sources not 

subject to new 

regulation 

Varies for each 

state 

Comments 

Nuisance 

regulation used 

Used on 

continuous 

sources only 

No universal 

opacity limits 

have been set for 

fugitive sources 

Controlled by 

nuisance 

regulation 

Considering a 

new method 

Averaged 

Violation 

regulations 

depend on date 

of installation of 

source 

General action 

requirements 

Roads excluded 

Prefers to back 

opacity violation 

with measured 

violation 

6 

Potential 

remediation 

Enforced by 

records and 

emission limits 

Notice of 

violation 

Anything from a 

warning to a fine 

Case Report sent 

to enforcement 

division 

If opacity is an 

issue, there is 

usually another 

problem to deal 

with 

Notice of 

violation 

Citation, 

fines 

Onsite notice of 

violation, could 

lead to formal 

action (Frankfort) 

Trigger a source 

test, or increase 

monitoring 

Offender given 

chance to refute 

with test data 
P.M 

TABLE 1 (continued) 

Region 

VI 

VII 

VIII 

IX 

State 

Illinois 

Indiana 

Michigan 

Minnesota 

Ohio 

Texas 

South Dakota 

Methods 

9 

9 

9D 

9 

9, 22 

9 

9, 22 

9 

9 

9 

Opacity when 

violations occur 

30% stationary 

sources, 10% 

nonstationary 

sources 

0% paved 

roads, 8% or 

10% unpaved 

roads 

5% for a 3-min 

average out of 

1 hr 

Excessive and 

avoidable 

20% 6-min avg. 

30% for 

sources 

operating before 

1972; all others 

20% 

Varies for each 

state 

Varies for each 

state 

20% 

20% 

Comments 

8 min out of one 

60-min period, 

no more than 

three times a day 

Proposed limits 

For fugitive 

sources 

Method modified 

to determine if 

fugitive dust 

exists 

Method 22 used 

on storage piles 

and vehicle 

emissions 

Roads excluded 

A violation 

triggers an 

inspection for 

work practice 

violations 

No source 

specific 

provisions 

Not used on 

fugitive sources 

Not used on 

fugitive sources 

Potential 

remediation 

Fines 

Notice of 

violation 

Notice of 

violation 

Notice-of 

violation, fines 

Notice of 

violation 

Notice of 

violation, citation 

Fine 

Notice of 

violation, order 

for compliance 

Warning letter, 

notice of 

violation, fines 

Case Report sent 

to enforcement 

division 

MRI-MVR8913-43 
P.15 

TABLE 1 (continued) 

Region 

X 

State 

Alaska 

Idaho 

Washington 

Methods 

9, 22 

9, 22 

9 

Opacity when 

violations occur 

Exceeding 20% 

for 25 readings 

taken at 15-s 

intervals 

Exceeding 20% 

for more than 3 

min out of one 

60-min period 

20% for 3 min 

out of 1 h or 

5% for a 1-h 

average 

Comments 

Climate helps to 

control fugitive 

dust 

Method 9 used 

on all stationary 

sources 

Method 9 not 

used on fugitive 

sources; roads 

have a "no 

visible 

emissions" limit 

Potential 

remediation 

Notice of 

violation 

Warning letter, 

notice of violation 

Notice of 

violation 

MR]-M\R8913-43 8 
P.16 

The most important findings from the interviews are: 

• Opacity techniques provide an effective, inexpensive, and immediate 

means of inspecting particulate emission sources. 

• Most agencies rely on some variation of Method 9 of 49 CFR part 60 

of the Federal Register (Appendix A) for all of their opacity 

inspections, although a few use Method 22 (Appendix B) to inspect 

emissions from vehicular traffic and storage piles. 

• The most common sources monitored by opacity include vehicular 

traffic, storage piles, and material handling. 

• Many of the respondents recommended that fewer readings be taken 

over shorter intervals for vehicular emissions, and that readings be 

taken immediately following vehicle passes. 

• Although a few respondents consider anv visible emissions to be a 

violation, most agencies use a "trigger" value between 10% and 20% 

opacity for most sources. 

• Many regulators acknowledged that although they could prosecute an 

opacity violation on its own merit, most would prefer an 

accompanying measurement or work practice violation prior to going 

to court. 

Following are brief summaries of each interview: 

Stationary Source Compliance Division (SSCD) 

(Mr. Kirk Foster) 

Mr. Foster believes that opacity inspection techniques provide effective 

methods of monitoring particulate sources that should be considered by ail 

agencies. These techniques were originally applied primarily to process sources, 

but over time some of the fence-line and nuisance standards ran into problems. In 

response, some States began modifying Methods 9 and 22 to apply to sources 

such as storage piles and transfer points. Opacity methods worked well on these 

sources. Eventually the list was expanded to include sources like access roads, 

work yards, haul roads, and agricultural tilling. The State of Tennessee did some 

of the pioneering work in applying these methods to additional sources. Some of 

the most appropriate modifications that Mr. Foster is aware of for opacity 

inspection of nonprocess fugitive sources include: shortened interval between 

readings (i.e., 5 s), shorter averaging times, and citing violations for short-term 

averages of 10% to 15%. 

MR1-M\R8913-43 
P.17 

Although he would like to see more States litigating opacity violations on 

their merit, he concedes that a better case exists if the opacity violation is paired 

with a work-practice violation. He prefers that the other violation be based on 

record keeping. These methods are attractive because they are inexpensive, easy, 

generally accepted, versatile, and require very little formal training, equipment, or 

field preparation. Mr. Foster thinks that short-term averaging methods (e.g., 203 

A, B, and C) will be a very valuable opacity method for the future. However, he 

feels that States need to do a better job of sharing information, and that better 

training programs need to be instituted. 

Emissions Measurement Branch 

(Mr. Roy Huntley) 

Mr. Huntley is currently developing opacity methods (203A, B, and C) for 

inspecting fugitive sources. He is aware of procedures used by many states for 

opacity inspection of fugitive sources. Although he is aware of some good opacity 

inspection techniques (i.e., the coke oven method), he believes that available 

methods are inadequate for many fugitive sources. For example, Method 9 is not 

compatible with the requirements of some states that industrial roads be free from 

visible emissions except during exemption periods (e.g., 3 min/h). Regulators in 

other states believe that for vehicular sources, opacity should be read at more 

frequent intervals (e.g., 5 s), but only immediately following a vehicle pass. To 

accommodate these needs, Mr. Huntley is working on Methods 203A, B, and C. 

Region I Regulator 

(Mr. Brian Hennessey) 

States in Region I usually use Method 9 for opacity measurement. Open 

sources of PM10 have been implicated in the only two PM10 nonattainment areas in 

this Region. Presque Isle, Maine, has a problem with reentrainment of snow/ice 

control materials, usually in the spring. New Haven, Connecticut, has a problem 

with emissions from industrial activities in open areas and nearby paved public 

roads in one part of the city. Although the Connecticut State Agency has not yet 

submitted a PM10 attainment plan, it appears that both Connecticut and Maine will 

prescribe control standards that will be enforced by work practice records (e.g., 

street cleaning, paving, roadway improvements), or emission limit surrogates that 

will be enforced by a measurement (e.g., surface silt loadings). Elsewhere in the 

region, nuisance or measurement regulations are used to inspect open sources of 

PM10. 

MRI-MVR8913-43 10 
P.18 

Connecticut Inspector 

(Mr. Bill Wihbey) 

Connecticut regulations define fugitive emissions as "fugitive dust or those 

emissions which could not reasonably pass through a stack, chimney, vent, or 

other functionally equivalent opening," and fugitive dust as "solid airborne 

particulate matter emitted from any source other than a stack." Opacity 

techniques are used only to inspect sources with stacks, continuous or not. 

Opacity is not used to inspect fugitive emission sources. Fugitive sources not 

inspected with opacity methods are qualitatively monitored visually or by Hi-Vol 

sampling. Method 9 techniques are used for visual emissions determination, as 

well as simple observation for stationary sources. 

Any reading greater than 40% opacity constitutes a violation, regardless of 

the time frame. More than 5 min of 20% to 40% opacity in a 60-min interval also 

constitutes a violation. Up to 20% is allowed indefinitely. Exceeding the 40% 

opacity limit results in a "Notice of Violation" followed by a grace period. It is also 

possible for a source to comply with the opacity limit while violating a process 

emission regulation. Most fugitive dust cases are inspected by visual 

determination; however, samples can be taken in the area in question. Mr. Wihbey 

believes the best way to inspect stack sources is to perform an actual stack test. 

Maine Inspector 

(Mr. John Chandler) 

Maine uses Method 9 to inspect asphalt and concrete batch plants and the 

storage piles and roads contained by these and other manufacturing sites. This 

method is not used for public roads, and no universal opacity limits have been set 

for fugitive sources (i.e., contaminated air not ducted through a stack, flu, 

chimney, or vent). However, in most cases, inspectors attempt to maintain 

fugitive sources to 0% opacity, and 5% is generally allowed. In addition, new 

sources are required to meet the provisions of a "Best Available Control 

Technology" (BACT) regulation. Maine also uses a "Best Practical Treatment" 

regulation for existing sources. A 20% opacity limit is enforced for process 

sources. Licensed sources exceeding opacity limitations could be assessed for 

anything from a "slap on the wrist" to a penalty, depending on the offense. 

Mr. Chandler does not foresee any changes regarding Maine's opacity 

regulation of fugitive sources. Presque Isle has a problem with reentrainment 

deicing agents on roadways, but opacity inspection techniques are not seen as a 

solution to this problem. Mr. Chandler believes that it would be difficult to regulate 

PMi0 emissions from this source with a method that does not differentiate between 

types of vehicles traveling on the road. He does see opacity as a possibility for 

inspecting diesel truck tailpipe emissions, but these are not considered fugitive 

emissions. 

MRI-MVR8913-43 11 
P.19 

New York Regulator 

(Mr. John Spencer) 

New York uses opacity methods to inspect conveyor operations at drop 

points. There is a 20% limit for these fugitive emissions. There is a 20% limit for 

stack operations as well. In each caase, a 6-min average taken per hour. Opacity 

measurements from boiler stacks are not averaged, and are allowed to reach 40% 

3 min/h. If these limits are not met, the first step in the legal process is taken, 

which is a case report. 

He sees opacity as a low-tech way to keep fugitive emissions down. The 

main objective is to control emissions that pose an obvious problem. For example, 

a road in a quarry that gives 100% opacity will have a watering requirement added 

to it. Nuisance regulation also has been used to control fugitive emissions from 

salting material piles at delivery points. As a result of public complaint, 

loading/unloading times were regulated, and piles were covered on windy days. 

Region III Inspector 

(Mr. Jim Gouvas) 

Region III uses variations of Method 9 to inspect fugitive sources in iron and 

steel facilities; however, different states use different averaging times on some 

sources. To deal with short-term emission sources (i.e., emissions from vehicular 

traffic), the Region is considering recommending a method that takes a reading 

every 5 s for 2 min. For other sources, Method 9 works in their Region, and no 

changes are foreseen. In general, if there is an opacity violation, there is a problem 

that needs to be corrected. However, enforcement issues are not a function of 

this department; therefore, he can not address "action taken." 

Region III Inspector/Regulator 

(Mr. Jim Topsale) 

Mr. Topsale has used Method 9 to inspect stationary dust sources. Each 

State in Region III has its own regulations regarding opacity. For example, 

Maryland enforces a "No Visible Emissions" law that only allows water vapor in 

uncombined form to be omitted from stationary dust sources. However, in 

Pennsylvania, an opacity violation occurs if 20% is exceeded by the average of 

readings from 3 min out of 1 h, and the source is at no time to exceed 40%. 

MRI-M\R8913-43 12 
P.20 

District of Columbia, Chief of Engineering Services 

(Mr. Don Wambsgans) 

The District of Columbia uses Method 9 to inspect stationary dust sources. 

Method 9 is not used to inspect fugitive dust sources; however, any visible 

emissions of fugitive dust may result in a review of "performance standards" and a 

citation may be issued. Opacity limits for a stationary source depend on the age of 

the source. For fuel burning equipment installed before January 1, 1977, opacity 

is not to exceed 10% unaveraged. When starting a source, opacity is not to 

exceed 40% for a total of 12 min out of a 24-h period. When shutting down a 

source, opacity is not to exceed 15% unaveraged, and is not to exceed 30% over 

any 3-min period. The opacity limit is 0% for fuel burning equipment installed after 

January 1, 1977. However, up to 40% opacity, unaveraged for 2 min/h, is 

allowed for start-up and shutdown of dust sources, providing that opacity does not 

exceed 40% for more than 12 min out of a 24-h period. 

West Virginia Compliance Manager/Inspector 

(Mr. Robert Weiser) 

West Virginia officially uses Method 9 for opacity inspections of all fugitive 

sources. For these sources, a violation would consist of an average opacity 

reading exceeding 20%. To accommodate these sources, Method 9 has been 

modified slightly. If an opacity violation is measured, a "Notice of Violation" is 

issued. If the offender does not come into compliance, the matter could end up in 

circuit court. Generally, these matters are taken care of with a clause that requires 

the use of "good engineering practice." Mr. Weiser thinks that the biggest 

problems with their opacity method are the lenient 20% limit and the difficulty of 

taking opacity readings in the midst of multiple sources. Rather than improving 

present opacity methods, he suggests rewriting the "best engineering..." clause. 

Kentucky Inspector 

(Mr. Philip Barnett) 

Kentucky uses Method 9 for all fugitive emissions subject to the federally 

approved fugitive emissions regulations (virtually any source) and for stack 

sources. There is a general limit of 20% for emissions outside of property. There 

are also general action requirements, or actions that must be taken regardless of 

opacity limit. The opacity limits for stack sources are 40% for older sources, 20% 

for most others, and a select few under Federal New Source Performance 

Standards that are less. He sees a slight problem with regards to this position 

when taking readings for fugitive sources, but he sees opacity as the best method 

at this time, and would make no changes. 

MRI-Mvfl.891 3-43 13 
P.21 

Region IV Inspector 

(Mr. Floyd Ledbetter) 

Tennessee uses Method 9 as well as an aggregate time count to enforce a 

zero opacity rule (specific classes are taken to read 0% opacity). Sources that are 

inspected by these techniques include power plants, rock quarries, asphalt and 

cement plants, incinerators, and combustion sources. Storage piles are also 

inspected when in the bounds of a facility that is being tested. Opacity limits are 

set between 2% and 40%, with 40% allowed for existing sources (i.e., sources 

not subject to new regulation). To exceed these limits would result in a violation, 

and" depending on the circumstances, could either trigger a source test, or increase 

monitoring to detect malfunctions. Mr. Ledbetter does not have a problem with 

the current methodology. The only improvement he would recommend would be 

the lowering of current limits. 

Former Region V Regulator 

(Mr. Jim Dewey) 

Region V uses opacity inspection techniques on a number of particulate 

sources including roadways, lots, storage piles, roof monitors, grain elevators, 

head houses, spout loading, and smoke stacks. These techniques have been used 

in some capacity since EPA began inspecting industrial sources. He believes that 

this is probably true for inspectors in every State, because opacity is more 

immediate (therefore a better assurance of compliance), faster, and less expensive 

than other techniques. He does prefer, however, to back an opacity violation with 

a measured violation prior to litigation. Otherwise, the offender has the option of 

providing test data that could refute the opacity violation. Mr. Dewey believes 

most agencies would agree. Although he is aware of some data that suggest a 

correlation between mass emissions and opacity measurements from fugitive 

sources, he believes that this area deserves further study. 

Illinois Regulator 

(Mr. Berkley Moore) 

Illinois uses Method 9 to inspect all fugitive field sources, boilers, and open 

dust sources. An opacity violation is currently a measured value exceeding 30% 

(up to 60% opacity is allowed for 8 min of each hour, three times each day). A 

measured violation results in a letter of violation, and could eventually lead to a 

fine. The state has proposed a State Implementation Plan (SIP) for attainment of 

PMi0

 tna t wi " require inspection of vehicular sources by modified Method 9 

techniques. Three readings will be taken at 5-s intervals from the time of a vehicle 

pass. For most other sources, the limit will drop from 30% to 20% with no 

exception periods. In addition, there will be a 10% opacity limit for 

MRI-M\fl8913-43 14 
P.22 

crushing/screening, and storage piles. A 5% limit will be set for sources of heavy 

metals. The test method for sources other than roads will be Method 9. Hearings 

regarding this proposed method are expected at the end of October. 

Illinois Inspector 

(Mr. Fred Smith) 

For the past 15 to 16 years, Illinois has used Method 9, as published, for a 

variety of sources. Prior to this, Ringleman numbers were used briefly. Mr. Smith 

believes that for noncontinuous sources, a time interval needs to be set that is 

much shorter than 6 min, especially for roadways (e.g., three 5-s readings). He 

also believes that a 1-min maximum out of 6 min would be a more useful method 

for stockpiles and transfer points. 

Indiana Regulator 

(Mr. Shri Harsha) 

Indiana uses Method 9 primarily to inspect stacks and power plants. 

However, they do use opacity to inspect other sources. If an opacity violation is 

noted, it typically triggers a check for a work-practice violation. For example, 

roads are often inspected for opacity violations. If opacity limits are exceeded, 

surface loading is measured. A work-practice violation would occur if more than 

50 lb/mile of dust was measured on a paved road, or less than a 90% control is 

discovered on an unpaved road. A new procedure has been proposed in which 

four instantaneous readings are taken and averaged. A 0% opacity limit will be set 

for vehicles traveling paved roads, and 8% for those on unpaved roads. 

Indiana Inspector 

(Mr. Ramesh Tejuja) 

Mr. Tejuja is aware that Region V is suggesting an opacity method for 

emissions from vehicular traffic. This method would require that three readings be 

taken, once every 5 s, immediately following a vehicle pass. EPA recommends 

that this procedure be repeated for four vehicle passes, and the readings averaged. 

This method suggests that for unpaved roads, a violation would consist of an 

average opacity of 10% or more. He is also aware of a study that suggested the 

best methoda^of characterizing a vehicular source is one instantaneous reading 

taken in the densest part of the plume. He believes that it would be difficult to 

write a procedure for noncontinuous sources like roads because other factors come 

into play, such as the type of vehicle, wind speed, vehicle speed, and so forth. A 

good method would try to enforce good work practices (efficiency) and use opacity 

as a mechanism to trigger additional control. Mr. Tejuja likes record keeping as an 

enforcement tool, because it allows inspectors to check every unpaved road in a 

large facility in a very short period of time. 

MRI-MVR8913-43 15 
P.23 

Michigan Regulator 

(Mr. Raj Sinha) 

Michigan uses State of Michigan Method 9D to inspect fugitive sources. 

This procedure consists of Method 9 as in 40 CFR, Part 60, with the following 

modifications: 

Data reduction provisions of Section 2.5 are based on 12 consecutive 

readings at 15-s intervals. For roadways and parking lots, the line of vision should 

be perpendicular to the direction of the plume and 4 ft above the surface of 

generation. The readings are taken momentarily at 15-s intervals looking at the 

densest point. Consecutive readings are stopped if a vehicle passes in the line of 

sight and resumed after the vehicle passes (this interval is excluded). Readings are 

also stopped for plume intermixing and resumed when interference is no longer 

apparent. For other fugitive sources, the point of observation must be chosen with 

the sun behind the observer, a clear view, at least 15 ft away from the source, and 

the line of sight perpendicular to the flow of dust and the longer axis of-emissions. 

Fugitive sources tested include paved and unpaved roads, storage piles, 

material-handling operations, dumping, and wind erosion of open areas. A 

violation consists of 5% for a 3-min average out of an hour. A violation of this 

limit results in a "Notice of Violation" and an investigation into possible workpractice violations. If a work-practice violation is discovered, a penalty follows. 

All fugitive sources have specific work practices that must be followed. Mr. Sinha 

does not see any shortcomings regarding this procedure; it works well, and 

violations have been written. 

Minnesota Regulator 

(Mr. Doug Wetzstein) 

Minnesota uses Method 9 to determine the extent of opacity from fugitive 

dust sources, but the length of readings is not specified. This opacity method is 

used on sources such as bulk storage transfer operations, grain unloading, sand 

and gravel operations, roads and stockpiles. The opacity method is used to 

determine if fugitive dust exists. If so, the source is evaluated for excessive and 

avoidable emissions. If an opacity violation occurs, a "Notice of Violation" is 

issued, with a request that the offender implement adequate control measures. If 

they do not comply, a negotiated stipulation agreement with a fine could result. 

The opacity method has been used extensively to enforce fugitive dust control 

regulation, and has met with few problems. 

MRI-M\R8913-43 16 
P.24 

Ohio Regulator 

(Mr. Tom Kalman) 

Ohio uses Method 9 to perform visible emission readings for stacks and 

process fugitive dust sources, and Method 22 to inspect roadways, parking areas, 

and storage piles. For stack sources, Ohio has a general opacity limitation of 20%, 

based on 1 h of 6-min averages; however, one 6-min time block is allowed to go 

up to 60%. For process fugitive emissions, Ohio has a general opacity limit of 

20% based on 3 min averaging. Open dust sources are allowed no visible 

emissions except during specified exemption periods. Paved roadways and parking 

areas are allowed 6 min of visible emissions each hour. Unpaved roadways, 

unpaved parking areas, and storage piles are allowed 13 min of visible emissions 

each hour. Selected process fugitive dust sources must meet specific opacity 

limits (e.g., iron and steel sources have a 20% limit for a 6 min average on four 

specified operations). 

An opacity violation for a source with a mass emission limit results in a 

stack test to determine compliance with the mass limit. If the source passes the 

mass emission test, then the source is issued an "Equivalent Visible Emission 

Limitation" (EVEL), which allows higher opacity readings. An opacity violation 

would trigger the enforcement process for sources without a mass emission limits. 

This process begins with the issuance of a "Notice of Violation," from the Field 

Office, to request a control plan and compliance schedule. If a satisfactory plan is 

submitted, the main office formalizes the plan and schedule and assigns any 

penalty according to the Ohio EPA Air Civil Control Policy. If an acceptable control 

plan is not received, the offender is referred to the Attorney General. 

Texas Inspector 

(Ms. Barbara Traham) 

Opacity is not a major issue in Texas. Only stationary sources (e.g., stacks, 

asphalt/concrete batch plants) are inspected by opacity methods. The State of 

Texas often considers it impossible to isolate a given emission source. They 

regulate fugitive sources with State provisions for property line emissions (based 

on Hi-Vol sampling) and nuisance regulations. For industry, visual emissions 

generally are not an alternative; however, if a facility is operating within their 

permit conditions, visual emissions do not occur. They regulate sources 

(companies) with one of three types of restrictions: grandfathered (those operating 

before 1972), standard exemption, and those operating under permit. There is a 

30% opacity limit for companies with grandfathered restrictions, whereas a 

permitted company would have to comply with lower limits (e.g., 20% for stack 

sources). The result of an opacity violation (depending on previous and/or other 

violations) could be a "Notice of Violation," possibly followed by a citation. 

MRI-M\R8813-43 17 
P.25 

Former Region VII Regulator 

(Mr. Dewayne Durst) 

Region VII uses Methods 9 and 22 to inspect a variety of sources. If a 

source inspection results in the violation of an opacity standard, this generally 

triggers further investigation. Mr. Durst believes that once visual emissions are 

apparent, a work practice violation can usually be found. He also believes that 

opacity is the easiest inspection technique to enforce, if it is backed up by a permit 

or contract. Prior to using the opacity methods, Region VII relied on ambient air 

sampling (Hi-Vol) and Ringleman numbers to inspect fugitive sources. He believes 

that inspector location and local air quality could have adversely biased some of 

their fugitive opacity data in the past. 

Compliance/Inspections Region VIII 

(Mr. Ron Rutherford) 

Region VIII uses Method 9 to inspect a variety of sources where opacity 

limits are imposed by regulation or permit. The Region does not use any sourcespecific variation of Method 9 (i.e., for paved/unpaved roads or storage piles). 

However, since the 6-min average is not appropriate for instantaneous intermittent 

source emissions, the Region is very interested in the new methods (203A, 203B 

and 203C) proposed for use in SIPs at 40 CFR Part 51, Appendix M, for such 

noncontinuous sources. Sources inspected by Method 9 techniques include 

asphalt plants, gravel pits, crushers, power plants, wood products manufacturing 

plants, open pit mines, and any other source for which opacity limits apply. If an 

opacity violation is documented by a Method 9 inspection, the Region takes the 

appropriate enforcement action, pursuant to the Clean Air Act. The Region looks 

forward to the new administrative penalty and Field Citation authorities tentatively 

scheduled for implementation in November 1991 and May 1993, respectively. 

Regional personnel believe that violations of visible emissions will constitute a 

significant portion of the new administrative orders and citations issued by the 

Region. Finally, the Region has had problems in applying the "no visible emission" 

requirements of the Asbestos NESHAP regulations and has provided comments to 

EPA for the development of a method for determining compliance with the 

asbestos NESHAP standard. 

South Dakota Regulator 

(Mr. Brian Gustafson) 

South Dakota does not use opacity to inspect fugitive sources. Method 9 is 

used for stack sources. A 20% limit is allowed for all sources except alfalfa 

pelletizing (30%) and those sources regulated by "New Source Performance 

Standards" (EPA Federal Regulation 40, Part 60), where allowances vary around 

10% from source to source. He realizes that these standards could be used to . 

MRI-M\fl8813-43 18 
P.26 

monitor fugitive emission sources. A first-time opacity offense results in a warning 

letter and request for plan and compliance. A "Notice of Violation" and fine are 

the result of a second violation. 

South Dakota, Chief Engineer for a Regulated Industry 

(Mr. Dennis Hengen) 

Contact was made with a private mining industry in South Dakota that does 

use opacity to restrict fugitive emissions. This facility uses Method 9 to determine 

the necessity to apply control methods. Mr. Hengen is aware that this is not the 

most accurate method to measure fugitive emissions, but it is an effective 

technique for triggering control methods. He is aware of a new method (TVEE 

Method 1) that is being used in Tennessee and Colorado for fugitive emissions. 

Region IX Inspector 

(Mr. Kingsley Adeduro) 

Region IX uses Method 9 for stack sources, but does not use opacity for 

fugitive sources. There is a 20% limit for stack sources, but specific limits are set 

by the different districts. The enforcement process consists of documentation of 

the case, and sending it to the enforcement division. Usually there is an evaluation 

of control equipment: whether it is needed, or if there is something wrong with it. 

Mr. Adeduro does not think opacity is a method that should be used for fugitive 

sources. 

Alaska Program Manager 

(Mr. Gary Guay) 

Alaska uses Methods 9, 22, and PM10 measurements to inspect stationary 

sources. Currently, Alaska has no procedure for determining opacity from fugitive 

sources. An opacity violation occurs when the average reading exceeds 20% for 

25 observations taken at 15-s intervals. After determining a violation has 

occurred, an inspector explains the violation to the company and suggests 

methods for bringing the source into compliance. A "Notice of Violation" may be 

sent to the company and fines may be accessed at the discretion of the regional 

administrator. Numerous violations may be documented before any legal action 

occurs. Mr. Guay believes that the climate in his state may reduce opacity. 

Idaho Manager 

(Mr. David Pisarski) 

Idaho uses Method 9 to inspect all stationary sources. Roads and other 

fugitive dust sources are governed by State Fugitive Emission Regulations. Method 

22 is occasionally used when a numerical determination of opacity is necessary. 

MRI-M\R8913-43 19 
P.27 

Currently, a violation occurs when opacity readings exceed 20% for 3 min out of a 

60-min period. Upon receiving a complaint, an inspector is dispatched to examine 

the source. If an opacity or other permit violation is observed, the inspector makes 

a judgement on how effectively the source is being controlled with existing 

technology. All violations, including opacity, result in a warning letter. After a 

response is received from the company, the source is reinspected. If the source 

still exceeds the opacity limit, a "Notice of Violation" may be sent, and the 

company may be assessed a fine. He believes the system would be better if 

methods were developed to use Continuous Emission Monitoring (CEM) and LIDAR 

(Laser radar) as enforcement tools and as the basis for legal action. 

Washington Inspector 

(Mr. Tom Husdon) 

The State of Washington does not normally use opacity to inspect fugitive 

emission sources (i.e., emissions that do not originate from a stack). Fugitive 

sources are assessed by a "Best Available Control Technology" (BACT) regulation 

with a "no visible emission" limit. This has never been tested in court. An offense 

of this rule could result in a "Notice of Violation." 

Method 9 is used to inspect stack sources. Industrial and residential sources 

must not "cause or allow the emission of any air contaminant from any source 

subject to Section 9.03(a) which is greater than 20% opacity for a period or 

periods aggregating more than 3 min in any 1 h. 

Mr. Husdon does not see opacity as a feasible regulatory method for most 

fugitive sources. The current methods are too stringent with regards to location 

and duration, and are time consuming. His version of a workable opacity method 

for fugitive sources would be a relaxed version of Method 9 with instantaneous 

readings instead of averaged readings over a period of time. 

MRI-MVR8913-43 20 
P.28 

SECTION 3 

LITERATURE SEARCH 

To supplement the telephone survey, MRI personnel conducted a search of 

environmental literature for relevant information. One objective of this search was 

to expand the list of potential regulatory contacts. In addition, research data were 

sought describing the use of opacity techniques on nonpoint particulate sources. 

Some very useful data were identified and reviewed in the literature search. 

The following is a summary of pertinent information contained in these documents: 

• More attention should be devoted to the training of smoke readers. 

This is especially important for inspectors who will be required to 

determine opacity from nonprocess fugitive sources. 

• Observational error is typically greater for observers reading opacity 

from fugitive sources than for those reading traditional stack sources. 

Therefore, it is recommended that visible emission standards consider 

this error in specifying opacity standards necessary to provide 

appropriate control. 

• Smoke readers measuring visible emissions from horizontal plumes 

originating below eye level and read against noncontrasting 

backgrounds tend to underestimate the opacity. This phenomenon 

was exaggerated for dense (i.e., greater than 40%) and for black 

smoke plumes. 

• Although several reports have demonstrated a positive correlation 

between fugitive particulate emissions and opacity, factors such as 

wind speed and direction and the background on which the plume is 

viewed influence this relationship. However, the only study of 

different sites demonstrated that good correlations between opacity 

and mass emissions are very site-specific (Reference 3). Development 

of a universally applicable opacity technique will require more field 

investigation. 

MRI-MVRB913-43 21 
The literature search consisted of four inquiries of files contained within the 

Dialog Information Services for abstracts of documents containing information 

relating opacity to PM10. Searched files included NTIS, Compdex Plus, Matadex, 

Dissertation Abstracts Online, Chemical Engineering Biotechnical Abstracts, 

Engineering Index, Environmental Bibliography, Enviroline, and Pollution Abstracts. 

Each search was conducted for documents containing various combinations of the 

key words: opacity, visible emissions, TSP, PM10, and particulate. Abstracts of the 

selected files were printed and reviewed for pertinent information. 

The first search was conducted for articles in the NTIS file containing the 

words: (opacity OR visible emissions) AND (TSP OR PM10 OR particulate) AND 

fugitive AND (correlate or relation). This search identified two documents; one of 

these was requested. 

The second search was of the NTIS file for articles containing the words: 

[(opacity or visible emission) and (TSP or PM10 or particulate) and (correlate or 

relation)] or (opacity or visible emission) and (TSP or PMi0 or particulate) and 

fugitive] NOT [(opacity or visible emission) and (TSP or PMi0 or particulate) and 

(correlate or relation)] and (opacity or visible emission) and (TSP or PMi0 or 

particulate) and fugitive]. This search identified 21 documents. None of these 

documents were requested. 

The third search was of the NTIS, Compendex Plus, Metadex, Dissertation 

Abstracts Online, Enviroline, Pollution Abstracts, Environmental Bibliography, 

Pascal, and Chem Engineering ci Biotechnical Abstracts files for articles containing 

the words: (opacity or visible emission) and (TSP or particulate or PM,o) and 

fugitive. This search identified 16 documents, 4 of which were requested. 

The final search was of NTIS for documents containing the words: opacity 

AND particle AND size. This search identified 25 documents. Two of these 

documents were requested. 

Of the six documents identified and ordered as a result of this search, five 

documents were received and reviewed in time for inclusion in this report. 

Following are brief summaries of each of the documents produced by this effort. 

1. CARB Revises Blasting Regulations1 

This document describes the revised abrasive blasting regulations enacted by 

the California Air Resources Board. This rule sets opacity limits for abrasive 

blasting inside and outside of buildings. Under the revised regulation, permissible 

abrasive blasting not conducted within a permanent building must not exceed a 

40% opacity limit. Blasting conducted within a permanent building must not 

exceed a 20% opacity limit. 

MRI-MVR8913-43 22 
2. The ASTM Dust Index. Its Uses, and Potential for Qualitv Control2 

This document proposes the use of the ASTM D547-41 "Index of Dustiness 

of Coal and Coke" technique to remotely measure the dust-generating potential of 

treated or untreated surfaces (e.g., coal piles). It suggests this technique for 

determining the performance of dust suppressants or to premeasure the dust 

potential of coal. 

The document contains little information that is pertinent to this study. It 

was identified by our search for its criticism of Method 9 on fugitive sources. It 

claims that Method 9 was developed for continuous sources and criticizes the use 

of Method 9 on sporadic sources (e.g., in a coal yard). It also cites the problems 

created by varying weather conditions on opacity measurements of nonstationary 

sources. 

3. Deveiooment of Measurement Methodology for Evaluating Fugitive 

Particulate Emissions3 

This document describes a study of the applicability of laser radar (LIDAR) 

for measuring the flux of particulate passing through a vertical plane downwind of 

a fugitive source. Testing was performed at three sites using four surrogate and 

one actual fugitive particulate source. In each test, attempts were made to 

correlate LIDAR back-scatter data with opacity and mass concentration data. 

These attempts were moderately successful. 

This study consisted of testing at sites near Camp Park, Woodland, and 

Cupertino, California. Surrogate particulate was generated as pneumatically 

dispersed silica powder (5 /ym in physical diameter), smoke from a smoke generator 

(i.e., used to train smoke readers), smoke pots, and smoke candles. The sum of 

airborne particulate released by a cement plant in Cupertino provided the actual 

particulate source for this study. 

The best correlations between LIDAR back-scattering and mass emissions 

appeared to occur in low density plumes created bycommercially available smoke 

candles. In higher density plumes, the LIDAR signal increased with particulate 

emission rates at less than a 1:1 correlation, as evaluated by a trained Method 9 . 

observer. Better relationships appeared to exist between downwind LIDAR backscatter and opacities. Although positive correlations were found, they tended to be 

much lower, for data taken at different wind speeds, different sites, or for different 

types of particulate. 

MRI-M\R8913-43 23 
P.31 

4. Fugitive Dust Reading Techniques From Roads and Parking Lots4 

This document describes the effort by the Tennessee Division of Air 

Pollution Control to develop and implement a fugitive dust-reading technique for 

roads and parking lots. This method is an adaptation of Method 9 and is 

designated Tennessee Visible Emission Evaluation (TVEE) Method T and is 

contained in Appendix C. This technique was developed to be the enforcement 

tool for reducing fugitive emissions from vehicles traveling on unpaved roads and 

parking lots. Tennessee State officials credit this method as a leading cause of 

Kingsport's reclassification to attainment status. 

TVEE Method 1 was developed to enforce a 90% reduction standard for 

emissions from vehicles traveling on unpaved roads and parking lots. A 10% 

opacity is assumed to correspond to a 90% emission reduction (an additional 10% 

was allowed to accommodate observational error). Therefore, a violation is not 

issued if less than 20% opacity is observed for 2 min. 

5. Hood Svstems Design for Capture of Process Fugitive Particulate Emissions5 

This document is a guide for the proper design and construction of capture 

hood systems for fugitive particulate emission sources. Proper design techniques 

are illustrated by case examples. This document contains little information that is 

pertinent to our study. It was identified by our search for a discussion of fugitive 

hood design to yield 0% source opacity. 

The following document was requested, but was not received in time for 

inclusion in this report. 

• Pendleton, D. R., 1977. "Evaluation of Source Compliance With 

Existing Particulate Standards Within NonAttainment Study Areas In 

Texas," Air Pollution Control Association, pp. 195-203. 

In addition to the computer literature search, files from past MRI projects 

were reviewed for additional documents relevant to this project. Following are 

brief summaries of each of the documents produced by this effort. 

1. Evaluation of Trained Visible Emission Observers for Fugitive Emission 

Opacity Measurements6 

This document describes a study of the biases, if any, introduced by 

certified Method 9 smoke readers measuring opacity close to ground level and 

viewed against non-sky backgrounds. A conventional smoke generator was 

modified to emit smoke plumes horizontally against a terrestrial background and 

below the eye level of the observers. 

MRI-M\R8913-43 24 
The study indicated that the panel of six smoke readers evaluated simulated 

white horizontal smoke plumes with accuracies similar to those from vertical stack 

plumes when opacity levels were around 15% to 20%. As opacity levels 

increased, however, the panel increasingly underestimated them; opacity was 

lower on average by about 8% at the 40% opacity level. 

Black horizontal smoke plumes were underestimated at all opacity levels. At 

15% opacity, the observers measured the opacity 5% low on average; at 40% 

opacity, the underestimation was 11 % on average. Overall, the observer panel's 

sensitivity to opacity changes was less for horizontal plumes than for conventional 

vertical stack-type plumes. The change in panel opacity measurement per change 

in transmissometer opacity measurement declined from near 1.00 for stack plumes 

to 0.62 and 0.77 for white and black fugitive plumes, respectively. 

2. Investigation of Relationship of Visible Emissions to TSP/PM^ Control 

Efficiency7 

This report describes a field study of the relationship between plume opacity 

and mass emissions from vehicular traffic on unpaved roads. Tests were 

conducted on an unpaved road in an integrated iron and steel plant. From this 

limited test scenario, the data suggest a relationship between plume opacity and 

particulate mass emissions, and between plume opacity and dust suppressant 

control efficiency. 

Mass and visible emission measurements were taken of a dump truck 

traveling on an unpaved road in an integrated iron and steel facility. Consecutive 

segments of the road remained untreated or were treated with one of three dust 

suppressants. Dust suppressants included water, Asphotac , and Soil SementTM. 

Measurements made during the study suggest a relationship between 

opacity immediately following a vehicle and TSP for controlled unpaved road 

segments but not for the uncontrolled unpaved segments. In addition, a 

relationship was established between opacity and PM10 emissions for chemically 

treated roads. Finally, the data suggest a relationship between visible emissions 

and dust suppressant control efficiency. In summary, an opacity value of 15% 

represents about a 90% control of PM10 emissions or an emission factor of about 

0.61 Ib PM,0 per vehicle mile traveled for chemically treated unpaved roads. 

Opacity varied significantly with wind speed, however, but is not included in 

the relationship. Furthermore, no attempt was made to study the effect of road or 

vehicle characteristics on opacity. Finally, the study found that the standard error 

associated with reading opacity of a vehicle-generated plume was 7.5%. 

MRI-MVR8913-43 25 
P.33 

3. Qualitv Assurance Programs for Visible Emission Evaluations8 

This report documents the history of Tennessee's training programs for 

smoke readers and describes the quality assurance program that has evolved from 

this program. Based on the experience of their quality assurance program, 

Tennessee makes the following recommendations for smoke reader training 

programs: 

1. EPA should field audit every smoke school that certifies observers to 

ensure that the training school meets the federal requirements. If a 

field audit is impossible, a paper audit requiring a positive statement 

that the school meets the requirements should be instituted. 

2. EPA should publish a listing of all schools that it believes are qualified 

to certify readers under Method 9 criteria. Tennessee would suggest 

that this be accomplished at least every 2 years because of problems 

with older smoke machines. 

3. Tennessee supports the audit procedure concept for all observers, not 

just first-year readers. It believes that the remedial action to be 

followed for failure of the audit should be specified in the audit 

document. 

4. Tennessee supports the audit of data forms and calculations. It has 

found that even "experienced readers" can complete the reading 

forms incorrectly and thus invalidate the readings under Method 9 

requirements. 

5. Tennessee believes that the smoke school is the most vital part of any 

agency's training program and should be adequately supported. It 

suggests that all school operators be required to maintain certification 

at another school. 

6. Tennessee believes that the more credence that can be given to 

visible emissions, the easier it is to get compliance with visible 

emission standards. To date, experience has indicated that 

compliance with visible emission standards can be attained 

irrespective of mass emissions. 

MRI-MVR8913-43 26 
SECTION 4 

CONCLUSIONS 

The following conclusions were suggested by the telephone interviews 

conducted during this study: 

• Opacity techniques provide an effective, inexpensive, and immediate 

means of inspecting sources of fugitive particulate emissions. 

• Although opacity techniques could be applied to almost any industrial 

source, these techniques are frequently used to inspect emissions 

from vehicular traffic, storage piles, and material handling. 

• Many regulators acknowledged that they could prosecute opacity 

violations on their own merit, but most prefer accompanying 

measurement or work-practice violations prior to going to court. 

• Although most inspectors use standard inspection techniques, such as 

Methods 9 or 22, many have modified these techniques for many 

fugitive sources. 

In addition, the following conclusions were derived from the literature 

search: 

• More attention should be devoted to the training of smoke readers. 

This is especially true for inspectors who will be required to measure 

opacity from nonprocess fugitive sources. 

• Future opacity rules should be written to accommodate the unique 

benefits and limitations of opacity measurement techniques. 

From these conclusions, recommendtions can be made; these are contained 

in Section 5. 

MRI-MVR8913-43 27 
P.35 

SECTION 5 

RECOMMENDATIONS 

Information collected during this study suggests that agencies should 

consider the following points when contemplating opacity technique. 

• All new standards should be set sufficiently high to allow for the 

typical observational error associated with reading fugitive sources. 

• Factors such as the interval between readings, reader positioning, 

wind speed and direction, and the background on which the plume is 

viewed influence readings. These should all be addressed in training 

and in methods provided to inspectors for reading fugitive sources. 

• Opacity violations are much more enforceable as violations if they are 

accompanied by another violation. Therefore, in most instances, 

opacity violations should be used to trigger a search for accompanying 

measurement or work-practice violations. 

Finally, data collected during this study suggest that the EPA should take the 

following steps to promote the future use of opacity as a viable inspection tool: 

• Standardized national regulations and an accompanying quality 

assurance program should be installed for training programs of smoke 

readers. These programs should address fugitive plumes (i.e., 

horizontal plumes originating below eye level, located near interfering 

plumes and read against noncontrasting backgrounds). 

• Further investigation of the relationship between opacity and mass 

emissions is warranted. Currently these relationships are source 

specific. Testing would improve the effectiveness of visual inspection 

techniques for quantitative emission estimation. 

MRI-MVR8913-43 28 
SECTION 6 

REFERENCES 

1. Anon., "CARB Revises Blasting Regulations," Journal of Protective Coatings 

and Linings, March 1991, pp. 33-37. 

2. Kestner, M. 0., "The ASTM Dust Index—Its Uses and Potential for Quality 

Control," Journal of Coal Quality, April 1986. 

3. Uthe, E. E., et al., Development of Measurement Methodology for Evaluating 

Fugitive Particulate Emissions, EPA 600/2-81-070, Prepared for the Office of 

Research and Development, U.S. Environmental Protection Agency, 

Research Triangle Park, NC, 1981. 

4. Walton, J. W. and E. C. Koontz, Fugitive Dust Reading Technique From 

Roads and Parking Lots, Tennessee Division of Air Pollution Control, 

Nashville, TN. 

5. Kashdan, Edward R., Hood System Design for Capture of Fugitive Particulate 

Emissions, 1986. 

6. Rose, T. H., Evaluation of Trained Visible Emission Observers for Fugitive 

Emission Opacity Measurements, EPA 600/3-84-093, Prepared for the Office 

of Research and Development, U.S. Environmental Protection Agency, 

Research Triangle Park, NC, 1984. 

7. Unger, M., Investigation of Relationships of Visible Emissions to TSP/PMW 

Control Efficiency, EPA 600/2-81-070, Prepared for the Office of Research 

and Development, U.S. Environmental Protection Agency, Research Triangle 

Park, NC, 1981. 

8. Walton, J. W. and E. C. Koontz, "Quality Assurance Programs for Visible 

Emission Evaluations," Tennessee Division of Air Pollution Control, Nashville, 

TN,1985. 

MRI-M\R8913-43 29 
P.37 

APPENDIX A 

METHOD 9 

MRI-M\R8913-a3 A-1 
MXTHOD 9—VlSXJAt DmaJCIKATIOW Of TH2 

OPACITY or AMISSIONS FROM STATtotcui-r 

SotTRCZS 

[Method 9 corrected by 52 FR 34639. 

September U. 198?] 

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 

aethod includes procedures for the training 

and certification of observers, and procedures to be used tn 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 tiiey no longer exert a significant influence upon plume appearance include: 

Angle of the observer with respect to the 

plume: angie of the observer with respect to 

the sun: point oi observation of attached 

and detached steam plume: and angle of the 

ooserver with respect to a plume emitted 

!rom a rectangular stack with a large lenglh 

*o width ratio. The method includes specific 

critena 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 che ability of the observer to accurately assign opacity values to 

:he observed plume. Studies of the theory 

of plume opacity and field studies have 

demonstrated that a plume is most visible 

ana 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 

piume. viewed under conditions where a 

contrasting background is present can be assigned with che greatest degree of accuracy. 

However, the potential for a positive error is 

also che greatest when a plume is viewed 

unaer 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 

:oward :ero. As a result, significant negative 

tuas and r.egacive errors con be made wtien 

a plume is viewed under iess contrasting 

conditions. A negative bias decreases ratner 

'..-.ar. increases :.ie possibility •.nat a piant 

ocerator will be cued for a violation of opac-

:;••' itancaros aue co ooserver error. 

iitucies nave beer, unaertaxen co ieterT.:.-.e tne magnitude oi positive errors wnicn 

car. oe rnaae bv auaiifiea observers wniie 

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 T.S 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 ac a sulfuric acid plant). 99 

percent of the sets were read with a positive 

error of less than 7.3 percent opacity. 95 

percent were read with a positive error of 

less than 3 percent opacity. 

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. 

1. .Pnnespie and avpliccMiCv. 

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 che determination of the opacity of 

emissions from stationary sources pursuant 

to ! 60.11(b) and for qualifying observers for 

visually determining ooacity of emissions. 

2. Procedures. 

The observer qualified in accordance with 

Section 3 of (his method shall use :he 

following procedures (or -.Tsuaily determining the opacity of emissions: 

[2. amended by 55 FR -'-''.. November 

U. 1990! 

2.1 Position. The qualified observer shall 

stand at a distance sufficient to provide a 

clear view of che emissions with che sun oriented in the 140* sector to nis back. Consistent with maintaining tiie 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 *.o 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 axe involved. 

and in any case the observer should make 

his observations with ^is Une of sight perpendicular to the longer axis of such a sec 

of multiple stacks (e.g. stub stacks on baghouses). 

2J Field records. The observer shail 

record the name of che plant, emission !ocanon. type :'ic:iiiy. observer', .name ind affiliation, a sivsicn of the ooserver s position rsiative 

'.« tne jourc:. .nd me date on z rieid can sheet 1

 Fieure •"•; •. The ume. cjumatec distance 

'For a set. positive error » average ooacity determined by ooservers' -5 aoservations—average opacity determined from 

transmissometers 25 recordings. 
P.39 

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 

oa a field data sheet at the time opacity 

readinas are initiated and completed. 

[2.2. corrected bv 52 FR 3-1-539. September 14. 19ST] 

2J 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 snail observe the plume 

momentarily ac 15-second intervals. 

2J.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 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 wacer 

vapor in the plume condenses and becomes 

visible at a distinct distance from the emission outlet, the opacity of emissions should 

bs 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 S 

percent at 15-second intervals on an observational record sheet. (See Figure 9-2 for an 

example.) A *i'"'*i"in 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 a5-second intervals. 

Divide the observations recorded on the 

record sheet tnto 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 standard specifies an 

averaging time requirtng more than 24 observations, calculate the average for all observations made during tne specified time 

period. Record the average opacity on a 

record sheet- :See Figure 9-1 for an example.) 

3. Quaii/icalianj 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 3 percent increments co 23 different black 

plumes and 25 different wntte plumes, with 

an error not to exceed 13 percent opacity on 

any one reading and an average error not to 

exceed 7.3 percent opacity in each category. 

Candldaces sr.ai! be tested according :o tne 

procedures described :n Section j.; . 

Smoke zenertv.ors usee ru.-suar.: to Sec-

:

.:on 3.2 sr.i:: :e eduirtrtc .-wr. a ;rnoKt 

-neter which -r.eets -..ie .*5su:rtme**is ii 

Section 3.3. 

]3.l amended by 55 FR 47472. November 

14. 19901 

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 SO plumes—23 black plumes 

and 23 white plumes—generated by a smoke 

generator. Plumes within each set of 23 

black and 23 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 af SO readings, the score 

of the candidate is determined. If a candidate fails to qualify, the complete run of SO 

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 dunng 

which candidates are shown block and white 

plumes of known opacity. 

3J Smoke generator specifications. Any 

smoke generator used for the purposes of 

Section 3.2 shall be equipped with a 

smoke meter installed to measure opacity 

across the diameter of che smoke generator 

stack. The smoke meter output shall display 

inswvi.1*: opacity based upon a pathlength 

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 Section 3.3.1 prior 

to the conduct of each smoke reading test. 

At the completion of each test, the zero and 

span drift shall be checked and if the drift 

exceeds =1 percent opacity, che condition 

shall be corrected prior co conducting any 

subsequent test runs. The smoke meter 

shall be demonstrated, at che time of installation, to meet che specifications listed in 

Table 9-1. This demonstration shall be repeated following any subsequent repair or 

replacement of che photocell or associated 

electronic circuitry including tlie chart recorder or output meter, or every 6 months, 

whichever occurs first. 

(3.3 amended bv 55 FR -7472. November 

14. 1990] 

TABLE 9-1—SMOKE METE** DESIGN ANO 

PSS**O«MANCE SPECIFICATIONS 

Pcfanovcr So t ilmicow 

0. L-jnt sovco incs/vtjooccnt lorno oocrotco ot 

rsomzscs rnico v->ict)a. 

0. Soccn-cl rooooftco ot ' -***otoox (aovttam sscctra r » 

iinanocui. soonso of mo numefl 

Cfiuuun ; 

c. Anqto ot v-«c» 'V Tvajamum tota antpa. 

a Amjio ol oroiccfton ?5," fiojumuiTi total cngto. 

0. ("ass&nmoi' error =3 % ooccrry. monrnum. 

1. Zero ana seen 

arm— i X ogcary. "0 

iTVfaVilOfJ. 

3. .-loaasonoo amo 5 scconoa. 

(Tabie 9-1 amerced 

November ; -i. :990l 

FR -T3.3.1 Calibration. The smoke meter Is calibrated after allowing a minimum of 30 minutes warraup 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 o percent or 100 

percent, as appropriate. This calibration 

shall be repeated until stable 0 percent and 

100 percent readings 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 ire to be 

evaluated as follotTs: 

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 Spectral response of photocell. 

Verify from manufacturer's data chat the 

photocell has a photopic response: I.e.. the 

spectral sensitivity of the. cell shall closely 

approximate the standard spectral-luminosity curve for photopic vision which is referenced ln (b) of Table 9-1. 

3.3.2.3 Angle of view. Check construction 

geometry co ensure that the total angle of 

view of the smoke plume, as seen by the 

photocell, does not exceed 15'. The *'-: 

angle of view may be calculated froi.< -> -

tan~'d/2L. where Sato tal angle of 

do the sum of the photocell diameter-che 

diameter of the limiting aperture: and 

L=che distance .'rom the photocell to the 

limiting aperture. The limiting aperture is 

the point in che path between che photocell 

and the smoke plume where tne angle a: 

view is most restricted. In smoke generator 

smoke meters this is normally an o.-ifice 

plate. 

;3.3.2.3 corrected Sv 52 FR 3-639. Seo-

.ember I-i. 198": 52 rR 42061. November 

2. :*s-} 

m.3.2.4 Angle of projection. Check construction geometry to ensure that the total 

angle of projection of tne tamp on the 

smoke plume does not exceed 15". The total 

angle of projection may be calculated from: 

<J -< 2 tan" 'd/2I_ where »•» total angle of projection: d= the sum of the length of the 

lamp filament - the diameter of the limiting aperture: and Lo the distance from the 

lamp co the limiting aperture. 

3.3.2.3 Calibration error. Using neut.-aJdensity filters of Known opacity, cneck the 

error between ci-.e actual response and the 

theoretical linear response of the smoke 

meter. This check is accomplished by first 

calibrating che smoke meter according to 

3.2.1 and then inserting i series of •.-..-•? 

neutral-density filters of nominal opacity of 

20. 50. a.*id 73 percent in the smoke meter 

patnie.ngth. Filters calibrated -vitnir. =2 

percent snail be used. Care shouid be taxen 

wnen inserting trie filters to prevent stray 

'.ig.-.t from affecting the meter. Maxe a total 

Wr-nT^T w>^il|l« iilli.iili.il 
P.40 

of five nooconsecutlve readings for each 

filter. The manmnm error on any one reading shall be 3 percent opacity. 

3.3a-*Li5 Zero and span drift. Determine the 

zero and span drift by calibrating and operating the smoke generator In a normal 

manner over a' 1-hour period. The drift ls 

measured by checking the zero and span at 

the end of this period. 

3J.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. Bibliography. 

[4. revised by 55 FR 47472, November 14. 

19901 

1. Air Pollution Control Districte Rules 

and Regulations. Los Angeles County Air 

Pollution Control District, Regulation IV, 

Prohibitions. Rule 50. 

2. Weisbui-d. Meivin I, Field Operations 

and Enforcement Manual for Air. U-S. Environmental Protection Agency. Research Triangle Park. N.C.. .*PTD-U00. August 1972. 

pp. 4.1-4.36. 

3. Condon. E.U. and Odishaw. H- Handbook of Physics. McGraw-Hill Co, N.Y.. 

N.Y, 1938, Table 3.1. p. S-52. 

FIGURE *M 

XECORO or VISUM. orrnwiMT.on v ofAcrrr r*g af 

CCTMT 

10CAT.0I* 

TEST KU*ttER_ 

OATE 

TYPE f*CIl.ITT_ 

or-istx DEVICE 

HOURS Of 08SERVAT:C*._ 

OBSERVER 

OBSERVER CERTIFICATION DATE, 

08SERVER AFFILIATION 

POINT OF EMSS'.OMS 

HEIGHT Of OtSCHAAGE POINT 

aocx TW 

08SERVER IXATION 

31 stance ts 31 se*i»f**« 

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P.41 

FIGURE 9-2—OBSERVATION RECOR O 

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P.42 

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.•U.TIMATX MXTHOD 1—OaRXiuaMArioir or 

TH* OPACXTT or EMISSIONS FIOH STATIOHAJ-T Sotntcxs Rato-mr sr LOAM. 

This alternate method provides the quantitative determination of the opacity of an 

emissions olume remotely by a mobile lidar 

system (laser radar Light Detection and 

Ranging). The method includes procedures 

for the calibration of the lidar snd procedures to be used in the field for the lidar determination of plume opacity. The lidar is 

used to measure plume opacity during 

either day or nighttime hours because it 

contains its own pulsed light source or 

transmitter. The operation of the lidar Is 

not dependent upon ambient lighting conditions (light, dark, sunny or clouay). 

The lidar mechanism or technique Is applicable ta measuring plume opacity at numerous wavelengths of laser radiation. However, the performance evaluation and calibration test results given in support of this 

method apply only to a uaar that employs a 

ruby (red light) laser 'Reference 5.11. 

1.4°nncipt> and Applicability 

1.1 Principle. The opacity of visible emissions from stationary sources (stacits. roof 

vents, etc.) is measured remotely by a 

mobile lidar (laser radar). 

1.2 Applicability. This method Is applicable .'or the remote measurement of the 

onadty of vistbie emissions from stauonary 

sources dunng both nighttime and oayiignt 
P.43 

conditions, pursuant to 40 CTR 5 60.11(b). It 

la dsa applicable for the calibration end 

performance verification of the mobile lidor 

for the measurement of the opacity of emissions. A performance/ de3ign specification 

for a basic lidar system is also incorporated 

into this method. 

1.3 Definitions. 

AHmuth angle: The anfle in the horizontal plane that designates where the laser 

beam is pointed..It is measured from an arbitrary fixed reference line in that plane. 

Bacltscatter* The scattering of laser Light 

ln a direction opposite to that of the incident laser beam due co reflection (rom particulates along the beam's atmospheric path 

which may include a smoite plume. 

Backscatter signal: The general term for 

the lidar return signal which results from 

laser Ught being bacsscatiered by atmospheric and smoite plume particulates. 

Convergence distance: The distance from 

the lidar to the point of overlap of the Ud&r 

receiver's (ield-of-view and the laser beam. 

Elevation angle: The angle of inclination 

of the laser beam referenced to the horizontal plane. 

Par region: The region of the atmosphere's path along the lidar line-of-sight 

beyond or behind the plume being measured. 

Lidar Acronym for Light Detection and 

Ranging. 

Lidar range: The range or distance (rom 

the lidar to a point of interest along the 

Lidar llne-of-sight. 

Near region: The region of the atmospheric path along the lidar Une-of-sight between 

the lidar's convergence distance and the 

plume being measured. 

Opacity: One minus the optical transmittance of a smoite plume, screen target, etc. 

Plclt interval: The time or range intervals 

in the lidar backscatter signal whose minimum average amplitude is used to calculate 

opacity. Two piclt intervals are required, one 

in the near region and one in the (ar region. 

Plume: The plume being measured by 

lidar. 

Plume signal: The bacicscatter signal resulting 'rom the laser lignt pulse passing 

through a plume. 

l/R* correction: The correction made for 

the systematic decrease in lidar backscatter 

signal amplitude with range. 

Reference signal: The bacicscatter signal 

resulting .'rom the laser light pulse passing 

through ambient air. 

Sample interval: The time period between 

successive samples (or a digital signal or between successive measurements (or an 

analog siunai. 

Signal srike: An abrupt, momentary increase and decrease in signal amplitude. 

Source: The source being tested by lidar. 

Time reference: The time (t.) when the 

laser pulse emerges (rom the laser, used as 

the reference in all lidar time or range 

measurements. 

2. Procedures. 

The mooiie lidar calibrated in accoraance 

wttah Paragraph 3 of this method shall use 

the following procedures (or remotely measuring the opacity of stauonary source emissions 

11 Lidar Position. The lidar shall be positioned at a distance (rom the plume sufficient to provide an unobstructed view of the 

source emissions. The plume must be at a 

range of at least SO meters or three consecutive piclt intervals (whichever is greater) 

(rom the lidar's transmitter/receiver convergence distance along the llne-o(-sightThe maximum effective opacity measurement distance of the lidar is a function of 

local atmospheric conditions, laser beam diameter, and plume diameter. The test position of the lidar shall be selected so that the 

diameter of the laser beam at che measurement point within the plume shall be no 

larger than three-fourths the plume diameter. The beam diameter Is calculated by 

Equation (<YM1-1): 

D(lidOar)oA-v.l-U<0.73 D(Plume) (.-IM1-1) 

where: 

D<Plume)°diameter of the plume (cm). 

*=laser beam divergence measured in radians 

R=range (rom the lidar to the source (cm) 

D< Lidar)=diameter of the laser beam at 

range R (cm). 

Aodiameter of che laser beam or pulse 

where it leaves the laser. 

The lidar range. R. is obtained by aiming 

and firing che laser at the emissions source 

structure immediately below the outlet. The 

range value Is chen determined (rom the 

bacicscatter signal which consists of a signal 

spike (return from source structure) and the 

atmospheric backscatter signal (Reference 

5.11. This backscatter signal should be recorded. 

When there is more than one source of 

emissions in the immediate vicinity of the 

plume, che lidar shail be positioned so chat 

che laser beam passes through only a single 

plume, free from any interference of che 

other plumes for a minimum of SO meters or 

three consecutive pick intervals (whichever 

is greater) in each region before and beyond 

the plume along the llne-of-sighc (determined from the backscatter signals). The 

lidar shall initially be positioned so that its 

llne-of-sight is approximately perpendicular 

to the plume. 

When measuring the opacity of 'missions 

(rom rectangular outlets (e.g.. roof monitors, open baghouses. noncircular stacks, 

etc), the lidar shall be placed in - position 

so that its line-of-sight is approximately 

perpendicular co the longer (major) axis of 

the outlet. 

2.2 Lidar Operational Restrictions. The 

lidar receiver shail not be aimed within an 

angle of = IS* (cone angle) of che sun. 

This method shall not be used co make 

opacity measurements if thunderstorms, 

snowstorms, nail storms, hign wind, highambient dust levels, (og or other atmospheric conditions cause the-reference signals to 

consistently exceed the limits specified in 

Section 2.3. 

2.3 Reference Signai Requirements. 

Once placed in its proper position for opacity measurement, the laser is aimed and 

fired with the llne-of-.«'"*'it -iesr the outlet 

height and rotated horizontally to a position clear of che source structure and the 

associated plume. The backscatter signal obtained (rom this position is called the ambi> 

ent-air or reference signal. The lidar operator shall Inspect this signal (Section V of 

Reference S.1J to: (1) determine if the lidar 

line-of-sight is (ree (rom interference (rom 

other plumes and 'rom physical obstructions such as cables, power lines, et c (or a 

minimum of SO meters or three consecutive 

pick intervals (whichever is greater) in each 

region before and beyond che plume, and (3) 

obtain a qualitative measure of the homogeneity of the ambient air by noting any 

signal spikes. 

Should there be any signal spikes on* the 

reference signal within a minimum of SO 

meters or three consecutive pick intervals 

(whichever is greater) in each region before 

and beyond the plume, the laser shall be 

fired three more times and the operator 

shall inspect che reference signals on the 

display. If the spikets) remains, che azimuth 

angle shall be changed and the above procedures conducted again. If the spike(S) disappears in all three reference signals, che lidar 

line-of-sight is acceptable if there is shot-coshot consistency and there is no interference (rom other plumes. 

Shot-to-shot consistency of a series of reference signals over a penod of twenty seconds is venfled m either of two ways. (1) 

The lidar operator shall observe the reference signal amplitudes. Por shot-to-shot 

consistency the ratio of R. to R« (amplitudes of che near and (ar region pick intervals (Section 15.1)1 shall vary by not more 

than = S% between shots: or (2) the lidar 

operator shall accept any one of the reference signals and treat the other two as 

Slums signals: then the opacity (or eacr. of 

t.*ie subsequent reference signals is calculated (Equation AM1-2). Por shot-to-shoc consistency, the opacity values shall be -vithin 

zr 3% of 0% opacity and the associated 5, 

values less than or equal to 3% (full scale) 

'Section 2.61. 

If a set of reference signals fails Co meet 

tiie requirements o( this section, then all 

plume signals (Section 2.41 (rom the last set 

of acceptable reference signals to the failed 

set shall be discarded. 

2.3.1 Initial and Pinal Reference Signals. 

Three reference signals shall be ootatnec 

within a 90-second time penod pnor to ir.y 

data run. A final set of three reference signals shall be obtained within three (3) minutes after the completion of the same aata 

run. 

2.3.2 Temporal Criterion (or Additional 

Reference Signals. An additional set of reference signals snail be obtained during a 

data run i( there is a change in wind direction or olume dn(t of 30* or more from the 

direction that was prevalent ••••hen the iast 

set of reference signals was obtained. An acditionai set of reference signals shall also oe 

obtained if there is an increase :n value of 

Si. <near region stancard deviation. Equation AMl-Si or 3., far region stanaard deviation. Equation AMI-6) "hat is jreater •..-.an 

jm msaakmiBaBia m-Miinimiu-
6% (full scale) over the respective values 

calculated from the Immediately previous 

plume signal, and this increase in value remains for 30 seconds or longer .An additional 

set of reference signals shall also be obtained if there is a change in amplitude in 

either the near or che (ar region of the 

plume signal that is greater than 5% of the 

near signal amplitude and this change in 

amplitude remains (or 30 seconds or more. 

2.4 Plume Signal Requirements. Once 

properly aimed, the lidar is placed in operation with che nominal pulse or firing rate 

of six pulses/minute (1 pulse/10 seconds). 

The lidar operator shall observe the plume 

backscatter signals to determine the need 

for additional reference signals as required 

by Section 2.3.2. The plume signals are recorded (rom lidar start to stop and are 

called a data run. The length of a data run 

is determined by operator discretion. Shortterm stops of the lidar to record additional 

reference signals do not constitute the end 

of a data run if plume signals are resumed 

within 90 seconds after the reference signals 

have been recorded, and the total stop or interrupt time does not exceed 3 minutes. 

2.4.1 Non-hydrated Plumes. The laser 

shall be aimed at the region of che plume 

which displays che greatest opacity. The 

lidar operator must visually verify that the 

laser is aimed cieariy above the source exit 

structure. 

2.4-2 Hydrated Plumes. The lidar will be 

used to measure the opacity of hydrated or 

so-called steam plumes. As listed in che reference method, there are two types. i.e„ attached ana detached steam plumes. 

2.4.2.1 Attached Steam Plumes. When 

condensed water vapor is present within a 

plume, lidar opacity measurements shall be 

made at a point within the rariduai plume 

where the condensed water /apor is no 

longer visible. The laser snail be aimed into 

the most dense region i region of highest 

opacity) of the residual plume. 

During dayllgnt hours the lidar operator 

locates' the most dense portion of the residual plume visually. During nighttime hours a 

high-intensity spotlight, night vision scope. 

or low iignt level TV. etc.. can be used as an 

aid co locate the residual plume. If visual 

determination is ineffective, che Lidar may 

be used co locate the most dense region of 

che residual plume by repeatedly measuring 

opacity, alom the longitudinal axis or 

center of the plume (rom the emissions 

outlet to a point just beyond the steam 

plume. The lidar operator should also observe color differences and plume reflectivity to ensure chat the lidar is aimed completely within the residual plume. If the operator does not obtain a clear indication of 

the location of the residual plume, this 

method shall not be used. 

Once the region of highest opacity of the 

residual plume has been located, aiming adjustments shall be made to the laser line-ofsight to correct for the following: movement 

co the region of highest opacity out of the 

lidar line-of-sight (away (rom the laser 

beam) for more than IS seconds, expansion 

of che steam plume (air temperature lowers 

and/or relative humidity increases) so chat 

it just begins to encroach on the field-ofview of the lidar's optical telescope receiver, 

or a decrease in the size of the steam plume 

(air temperature higher and/or relative humidity decreases) so that regions within the 

residual plume whose opacity is higher than 

the one being monitored, are present. 

2.4.2.2 Detached Steam Plumes. When 

the water vapor in a hydrated plume condenses and becomes visible at a finite distance (rom the stack or source emissions 

outlet, the opacity of che emissions snail be 

measured ln the region of the plume clearly 

above the emissions outlet and below condensation of the water vapor. 

During daylight hours the lidar operators 

can visually determine If the steam plume is 

detached (rom the suet outlet. During 

nighttime hours a high-intensity spotlight, 

night vision scope, low light level TV. etc_ 

can be used as an aid in determining if the 

steam plume is detached. If visual determination is ineffective, the lidar may be used 

co determine if the steam plume is detached 

by repeatedly measuring plume opacity 

(rom the outlet to the steam plume along 

che plume's longitudinal axis or center line. 

The lidar operator should also observe color 

differences and plume reflectivity to detect 

a detached plume. If the operator does not 

obtain a clear indication of the location of 

the detached plume, this method shall not 

be used to make opacity measurements between the outlet and che detached plume. 

Once the determination of a detached 

steam plume has been confirmed, che laser 

shail be aimed into the region of highest 

opacity in the plume between the outlet and 

the formation of the steam plume. Aiming 

adjustments shall be made to the lidar's 

llne-of-sight within the plume to correct for 

changes in the location of the most dense 

region of the plume due to changes in wind 

direction and speed or if the detached steam 

plume moves closer to the source outlet encroaching on the most dense region of the 

plume. Lf the detached steam plume should 

move too close co che source outlet for che 

lidar to make interference-free opacity 

measurements, this method shall not be 

used. 

2J Field Records. In addition to che recording recommendations listed in other 

sections of this method the following 

records should be maintained. Each plume 

measured should be uniquely identified. 

The name of the facility, type of facility, 

emission source type, geographic location of 

the lidar with respect to the plume, and 

plume characteristics should be recorded. 

The date of the test, che Ume period that a 

source was monitored, che time (to che nearest second) of each opacity measurement, 

and the sample interval should also be recorded. The wind speed, wind direction, air 

temperature, relative humidity, visibility 

(measured at the lidar's position), and cloud 

cover should be recorded at the beginning 

and end of each time penod (or a given 

source. A small sketcn deoicting che location of che laser beam within che plume 

should be recorded. 

If a detached or attached steam plume is 

present at the emissions source, this fact 

should be recorded. Pigures AM1-I and 

AM1-II are examoles of logoook forms ti-.at 

may be used to record this type of data. 

Magnetic tape or paper tape may also be 

used to record data 
I III til 101. HIM HOI MHIIIIl IVHII UHl\ 

l.iiy II11 nl Niimbrr-

(Allll* I CONIIOl NUMIII l l Iit k lllililll l IIIK I Mil l lul l 

IHIIOI 

DMIll 

OAK 

ASSIfiMf B rioiici cm. sun 

ciilliu l u m l III I 

M M U UM. 4 0.MII0I. \fSIUK IUHI . \ 11 (IN (.uai) 

|Aili|i I CONTIIOl NUUMI ll lick l.i\ui-.\ nviti ult i lul | 

C0NII01 

NUMIII 

OAM 

ASSItMK rioiici •:m. iiAif 

Notl let Ink t.t>aboi* 

Figuro AMI-I Lidar Log Control Number Tabulation 
tattllll- •«• » H | I*. Ill * 

I Id til 101. 01 01*1 H I Ml»\» 

I ..„,,. I a-a.l.. . llH I I. . . 

IIIMH OMHtlll H > MITI N 

lllllal l »a|lllia It lul l III * •••tl* III*!- - llllllt l llaai . (l | | 

I . Il l ll.li ill . . 

I.iall.a il Ilk** 

II.ial llavl) 

ll'lll'l ' If lli' l • . 

tl.f- l 11 laHli l 

llll . ia(l.a.l>a * - *C|I | i | b| • • .|k*|| l | | 

Ita.i a l|*« aal all!.Ial 4»il|aallaa 

• la«a .laifiiailuli. Ital.i .iaaa- ii.aav |iaiaal all I 

••a l 1)1. 1 ll | I __ 

I I I laava.ialaia aaaii 

• aiaai.l. i | < | . a 

II.. . Il i a _ 

« Ri Ial lav ti tia l llia.llaa la|ia 

I ial . I' lalallaa aa*lil.| lf|<a . 

|.a IliltUili lt|ia aal ia | 

• « • 

. aa* __ _ 

' aal 

aa ll.l i llaaa . filalaal . v aala a al . | 

MUallit Mil l 

iiji / IIII * • iiiai 

OMIIIOI I IlaHllUII 

• limn ticriiiuii 

.•'i l 

.ni l 

IIIII imunti milium* 

• all rl llll cilituliM 

I 

(llililla t l»i<il | 

(allillll l •••(•If 

• lllila l •• Iiii 

liana unti l (lllnll l I I llilla i | I 

Uu lnl tiuKII •• llll* lull* 

I « til l 

trillio n iiiaimit; 

• 11*111 IIMIIUII: 

. Itll: 

. 1*11: 

Fiyur e AM1-I I Lida i Log O l Operation s 
P.47 

a) 

•a s 

(a) Reference Signal, 1/R Corrected 

C

° " l ""' 

(Far Region) 

**3 

a. 

Time or Range 

(b) Plume Signal. 1/Ra Corrected 

An 

-4-r* L* *• 

Plume Spike 

Time or Range 

(a) Reference signal, I/R -corrected. This reference signal is for 

plume signal (b). R , Rf are chosen to coincide with I , [,. 

(b) Plume signal, 1/R -corrected. The plume spike and the decrease 

in the backscatter signal amplitude in the far region are due to 

the opacity of the plume. I , I,' are chosen as indicated in 

Section 2.5. 

Figure AM1-III. Plots of Lidar Backscatter Signals 
P.48 

2.S Opacity Calculation and Data .Analyst*. Referring to the reference signal and 

plume signal in Figure AMI-in. the measured opacity (0«J in percent for each lidar 

measurement is calculated using Equation 

AM1-2. (O.-l-T^ T. is the plume trans* 

•Pittance.) 

0 p = (1QQS) 1 -

R

f

 ln 

(AMI-2) 

The average amplitudes for esuch of the 

pick Intervals. U. U R» R. shall be calculated by averaging the respective Individual 

amplitudes of the sample intervals from tne 

plume signal and the associated reference 

signal each corrected for 1/R*. The amplitude of I, shaU be calculated according to 

Equation (-AAI-3). 

. 1 

~ a 

rn 

I I 

.=1 m (AMI-3) 

where: 

I,-near-region pick interval signal amplitude, plume signal, 1/R* corrected. 

1V» far-region pick interval signal amplitude. 

plume signal. 1/R* corrected, 

R,-near-region pick interval signal amplitude, reference signal. 1/R' corrected. 

aad 

R,« far-region pick interval signal amplitude, reference signal. 1/R' corrected. 

The 1/R- correction to the plume and reference signal amplitudes is made by multiplying the amplitude for each successive 

sample interval from the time reference, by 

the square of the lidar time (or range) associated with that sample interval (Reference 

5.11. 

The first step ln selecting the pick intervals for Equation AMI-2 is to divide the 

plume signal amplitude by the reference 

signal amplitude at the same respective 

ranges to obtain a •normalized" signal. The 

pick intervals selected using this normalized 

signal are a minirrmri of IS a (100 nanoseconds) in length and consist of at least 5 

contiguous sample intervals. In addition, 

the following cntena. listed in order of Importance, govern pick interval selection. (1) 

The intervals shall be in a region of the normalized signal where the reference signal 

meets the requirements of Section -3 and is 

everywhere greater than zero. C2) The intervals (near and (ar) with the minimum average amplitude are chosen. (3) If acre than 

one Interval with the same minimum average amplitude is found, the interval closest 

to the plume is chosen. (4) The standard deviation. S„ for the calculated opacity shall 

be 8% or less. (S. is calculated by Equation 

AM1-T>. 

tf S. is greater than 8%. then the far pick 

interval shall be changed to :he next interval of minimal average amplitude. If S, is 

still greater than 3%. then this procedure is 

repeated for the far pick interval. This procedure may be repeated once again for the 

near pick interval, but if 5. remains greater 

than 3%. the plume signal shall be discarded. 

The reference signal pick intervals. R, and 

R. must be chosen over the same time interval as the plume signal pick Intervals. I, and 

I* respectively CFtgure AM1-HI1. Other 

methods of selecting pick intervals may be 

used If they give equivalent results. Fieldoriented examples of pick interval selection 

are available In Reference S.l. 

X

f " \ 4 Jfi ' Rn -

where: 

I«»the amplitude of the ith sample interval 

(sear-region). 

Z-sum of the individual amplitudes for the 

sample intervals. 

m« number of sample intervals in the pick 

interval, and 

I. a.average amplitude of the near-region 

pick interval. 

Similarly, the amplitudes for I,. R,. and Rt 

are calculated with the three expressions in 

Equation (.AMI-.). 

1 " 1 M 

m 1a l m f a- fi 

(AMI-4) 

The standard deviation. SM. of the set of Similarly, the standard deviations Sa., So. 

amplitudes for the near-region pick Interval, and S« are calculated wtth the three ezpresL., shall be calculated using Equation sions la Equation (AMI-<3). 

(AM1-S). 

'In 'If 

I < -fi * h >*" 

i=l (m-1) 

(AM1-5) 

SRn 

hi 

•[ 

3 

" ! < Rni -

 Rn >'] 

.1=1 (m-1) 

" m ( a. - Rf ) 2" 

2 -^ 

.1 = 1 (31-1) 

(AM1-6) 
P.49 

The standard deviation. S.. for each associated opacity value. 0 „ stitU be calculated »«-<-*g 

Equation (AMI-?.. 

R

f

 rn 

S

 2 S 2 S

 2 V 

(AM1-7) 

The calculated values of L. t. R. R» Sa.. 

Sw. St... S-» O. and S. should be recorded. 

Any plume signal with an S, greater than 

87. shaU be discarded. 

2.8.1 Azimuth Angle Correction. If the 

azimuth angle correction to opacity specified In this section is performed, then the 

elevation angle correction specified in Section 2.8.2 shall not be performed. When 

opacity is measured in the residual region of 

an attached steam plume, and the lidar lineof-sight is not perpendicular to the plume, it 

may be necessary to correct the opacity 

measured by the lidar to obtain the opacity 

that would be measured on a path perpendicular to the plume. The following method, 

or any other method which produces equivalent results, shall be used to determine the 

need for a correction, to calculate the correction, and to document the point within 

the plume at which the opacity was measured. 

Figure AMl-rV(b) shows the geometry of 

the opacity correction. L' ls the path 

through the plume along which the opacity 

measurement is made. P* is the path perpendicular to the plume at the same point. The 

angle < ls the angle between L' and the 

plume center line. The angle (ir/2-t). is the 

angle between the V and P*. The measured 

opacity. 0 „ measured along the path 1/ 

shall be corrected to obtain the corrected 

opacity, O.. for the path P\ using Equation 

(AMI -8). 

opc = (100%) [ I - (1 - 0.01 op) Cos (T-./2-S) 

= (100%0%)) 1[ 1 - ( 1 - o.oi op) Sin el (AMI-8) 

The correction in Equation (AM1-8) shall be performed If the inequality in Equation 

CAM1-9) ia true. 

Sin 

In (1.0 1 - 0 o ) 

In ( 1 - 0 p ) 

(AM1-9) 

Figure .*aMl-IV(a) shows the geometry 

used to cilrnlstr < and the position in the 

plume at which the lidar measurement is 

made. This analysis assumes that for a 

given lidar measurement, the range from 

the lidar to the plume, the elevation angle 

of the lidar from the horizontal plane, and 

the azimuth angle of the lidar from an arbitrary fixed reference in the horizontal plane 

can all be obtained directly. 
Projectio J n of P onto the yzplane. P " 

 P P Plume measurement position P (R , 4>', P ) 

Plume drift angle position 

Pa (Ra. +••«'. pa) 

l Itlar Position 

L idar Line-of-Sight. 

Position P 

(b)

 P 

N I / 

Projection of Pfl onto the xy-plane, P ' 

figure AMI - IV. Correction In Opacity for Drift of the 

Residual Region of an Attached Steam Plume. 
P.51 

R,» range from lidar to source* 

S, - elevation angle of R.* 

R,-range from lidar to plume at the opacity measurement point* 

$,melevation angle of R," 

R,-range from Udar to plume at some artitrary point. P. so the drift angle of the 

plume can be determined* 

£,« elevation angle of R,* 

a-angle between R. and R, 

R',-projection of R, tn the horizontal plane 

R",-projection of R, in the horizontal plane 

R*,- projection of R, in the horizontal plane 

*-•> angle between R", and RV 

a'.angle between R', and R',* 

R*S-distance from the source to the opacity measurement point projected In the 

horizontal plane 

IW-distance from opacity measurement 

point P, to the point In the plume P, 

V

s 1 (1 - Q ) C 0 S

 <*/2-

C

-* = 1 

P d V Sin c 

(AMI-8) 

The correction angle < shall be determined 

using Equation AM1-10. 

where:' 

a-Cos'1 (Costvt, Cos3, Cosa'+Slnfl. Slnfl.). 

and 

R»-(R,*+-R,'-2 R, R, Cosa)"' 

Rfi. the distance from the source to the 

opacity measurement point projected In the 

horizontal plane, shall be determined using 

Equation AMI-11. 

«, • («;- y - 2R'R'Cosi|r) 

s P 

(AMI-11) 

where 

R'.-R, Cos 3. and 

R'.-R, Costf.. 

Zn the special case where the plume centerline at the opacity measurement point ts 

horizontal, parallel to the ground. Equation 

AM1-12 may be used to determine < instead 

of Equation AMI-10. 

= Cos - i 11 P.

 2 RM2 

2 R pR

5 

(AMI-12) 

where: 

R-.«<R*\->R.*Sln-WM. 

II the angle < is such that « 30* or < > 150*. 

the azimuth angle correction shall not be 

performed and the associated opacity value 

shall be discarded. 

2.5-2 Elevation .Angle Correction. An individual lldar-measured opacity. 0„ shall be 

corrected for elevation angle if the laser ele-

•Obtained directly from 

values should be recorded. 

Udar. These. 
P.52 

T • • - -r*-:*-r*»*r3

 v 

vatlon or Inclination angle. 3. CPtgure A2dl- V*. is greater than or equal to the value calculated tn Equation AMI-13. 

S > Cos -» 

In (101 - OJ P 

In (100 - 0 ) (AMI-13) 

The measured opacity. 0„ along the Udar path la, ls adjusted to obtain the corrected opacity. O M for the actual plume (horizontal) path. P. by using Equation (AMl-14). 

(1 = (100%) [ l - (1 - 0.01 0J CoS3pl, (AMl-14) 

PC L p J 

where: The values for 2„ O. and 0 „ should be re5,-Udar elevation or Inclination angle. corded. 

O.—measured opacity along path L. and 

O--corrected opacity for the actual plume 

thickness P. 
Stack's Vertical Axis 

Horizontal Plane 

Lidar Lini_*-of-Si<|ht 

Keferenced to Level Ground 

(lloi -121111 tal IMane) 

Vertical Smoke Plume 

8 . Lidar Elevation or 

• Inclination Angle 

= Effective Plume Thickness 

= Actual Plume Thickness 

= LCosi* 

3 Opacity measured along path L 

= Opacity value corrected to the 

actual plume thickness, P 

Figure AMI-V. Elevation Angle Correction for Vertical Plumes. 
2.8.2 Determination of Actual Plume 

Opacity. Actual opacity of the plume shall 

be determined by Equation aAMl-13. 

0 • 0 - [2 S„ *> 5S]. 

pa pc o 

(AMI-IS) 

2.6.4 Calculation of Average Actual 

Plume Opacity. The average of the actual 

plume opacity. 0 _ shall be calculated as 

the average of the consecutive individual 

actual opacity values. O— by Equation 

AM1-16. 

_ 1 

pa 

n 

I 

lc***l 

<v* 

( AMI-16) 

where: 

(O-J.-the tth actual opacity value In an 

averaging interval containing n opacity 

values: it is a summing index. 

I-the sum of the individual actual opacity 

values, 

n-the number of individual actual opacity 

values contained in the averaging interval. 

O- - average actual opacity calculated over 

the averaging interval. 

3. Lidar Performance Verification. 

The lidar shall be subjected to two types 

of performance verifications that shall be 

peformed in the field. The annual calibration, conducted at least once a year, shall be 

used to directly verify operation and performance of the entire Udar system. The 

routine verification, conducted for each 

emission source measured, shall be used to 

Insure proper performance of the optical receiver and associated electronics. 

3.1 Annual CaUbration Procedures. 

Either a plume from a smoke generator or 

screen targets shall be used to conduct this 

calibration. 

If the screen target method is selected, 

five screens shall be fabricated by placing 

an opaque mesh matenal over a narrow 

frame (wood, metal extrusion, etc.). The 

screen shall have a surface area of at least 

one square meter. The screen material 

should be chosen for precise optical opacities of about 10. 20. 40. SO. and 80%. Opacity of etch, target shall be optically determined and should be recorded. If a smoite 

generator plume is selected, it shall meet 

the requirements of Section 3.3 of Reference Method 9. This calibration shall be 

performed in the field during calm (as practical) atmospheric conditions. The Udar 

shall be positioned In accordance with Section 2.1. 

The screen targets must be placed perpendicular to and coincident with the Udar lineof-sight at sufficient height above the 

ground (suggest about 30 ft) to avoid 

ground-level dust contamination. Reference 

signals shall be obtained just prior to conducting the calibration test. 

The Udar shall be aimed through the 

center of the plume within I stack diameter 

of the exit, or through the geometric center 

of the screen target selected. The Udar shall 

be set in operation for a 6-minute data run 

at a nominal pulse rate of I pulse every 10 

seconds. Each au&scatter return signal and 

each respective opacity value obtained from 

the smoite generator transmissometer. shall 

be obtained in temporal coincidence. The 

data shall be analyzed and reduced in accordance with Section 2-S of this method. 

This calibration shall be performed for 0% 

(clean air), and at least five other opacities 

(nominally 10. 20. 40. 60. and 80%). 

The avenge of the. Udar opacity values obtained during a S-rhinute calibration run 

shall be calculated and should be recorded. 

Also the average of the opacity values obtained from the smoke generator transmissometer for the same 6-minute run shall be 

calculated and should be recorded. 

Alternate calibration procedures that do 

not meet the above requirements but 

produce equivalent results may be used. 

3.2 Routine Verification Procedures. 

Either one of two techniques shall be used 

to conduct this verification. It shall be performed at least once every 4 hours for each 

emission source measured. The following 

parameters shall be directly verified. 

1) The opacity value of 07a plus a minimum of S (nominally 10. 20. 40. 60. and 30%) 

opacity values shall be verified through che 

PMT detector and data processing electronics. 

2) The zero-signal level (receiver signal 

with no optical signal from the source 

present) shall be inspected to insure that no 

spurious noise is present in the signal. With 

the entire Udar receiver and analog/digital 

electronics turned on and adjusted for 

normal operating performance, the following procedures shall be used for Techniques 

1 and 2. respectively. 

3.2.1 Procedure for Technique I. This 

test shall be performed with no ambient or 

stray light reaching the PMT detector. The 

narrow band .'liter < 694.3 nanometers peak) 

shall be removed from its position in front 

of the PMT detector. Neutral density fUters 

of nominal opacities of 10. 20. 40. 60. and 

80% shall be 'used. The recommended test 

configuration is depicted in Figure AM1-VT. 
P.55 

PMT Entrance 

Window Completely 

Covered 

Lidar Receiver 

Photcmultiplier 

Oetector 

(a) Zero-Signal Level Test 

! CW Laser or 

! Light-Emitting Oiode 

(Light Source) 1 ight' path M Lidar Receiver 

Photomultiplier | 

Detector ' 

(b) Clear-Air or Of: Opacity Test 

JA Laser or 

Light-Emitting Diode 

(Light Source) 

Neutral-density 

optical filte r 

light path 

Lidar Receiver 

Photcmultip! ier 

Detector 

(c) Optical Filter Test (simulated opacity values) 

'Tests shall be performed with no ambient or stray light reaching the 

detector. 

igure AMI-VI. Test Configuration for TechnicL.tr i 
P.56 

The zero-signal level shall be measured 

and should be recorded, as indicated in 

Figure AMl-VT(a). This simulated clear-air 

or 0% opacity value shail be tested in using 

the selected light source depicted in Figure 

AMl-VNb). 

The light source either shall be a continuous wave (CW) laser with the beam mechanically chopped or a light emitting diode 

controUed with a pulse generator (rectangular pulse). (A laser beam may have to be attenuated so as not to saturate the PMT detector). This signal level shall be measured 

and should be recorded. The opacity value is 

calculated by taking two pick intervals [Section 2.61 about 1 microsecond apart in time 

and using Equation (AM1-2) setting the 

ratio R,/R<-1. This calculated value should 

be recorded. 

The simulated clear-air signal level is also 

employed.in the optical test using the neutral density filters. Using the test configuration in Figure AMl-VKc). each neutral density fUter shall be separately placed into the 

Ught path from the light source to the PMT 

detector. The signal level shall be measured 

and should be recorded. The opacity value 

for each fUter is calculated by taking the 

signal level for that respective filter (I,), dividing it by the 0% opacity signal level (I,) 

and performing the remainder of the calculation t>y Equation (AM1-2) with R./R.-1. 

The calculated opacity value for each fUter 

should be recorded. 

The neutral density fUters used for Teennique 1 shall be calibrated for a«ual opacity 

with accuracy of =2% or better. This calibration shall be done monthly whUe the filters are in use and the calibrated values 

should be recorded. 

3.2^ Procedure for Technique 2. An optical generator (built-in calibration mechanism) that contains a light-emitting diode 

(red light for a Udar containing a ruby 

laser) is used. By injecting an optical signal 

into the Udar receiver immediately ahead of 

the PMT detector, a backscatter signal is 

simulated. With the entire lidar receiver 

electronics turned on and adjusted for 

normal operating performance, the optical 

generator is turned on and the simulation 

signal (corrected for l/R*) is selected with 

no plume spike signal and with the opacity 

value equal to 0%. This simulated clear-air 

atmospheric return signal is displayed on 

the system's video display. The Udar opera-

. . . .„... _.k,^ .„,. «me idjustments max. 

•aay be necessary to maintain the system's 

normal operating range. 

The opacity values of 0% and the other 

five values are selected one at a time ln any 

order. The simulated return signal data 

should be recorded. The opacity value shall 

be calculated. This measurement/calculation shall be performed at least three times 

for each selected opacity value. While the 

order is not important, each of the opacity 

values from the optical generator shall be 

verified. The calibrated optical generator 

opacity value for each selection should be 

recorded. 

The optical generator used for Technique 

2 shall be calibrated for actual opacity with 

an accuracy of =1% ox better. This calibration shaU be done monthly whUe the generator is in use and calibrated value should be 

recorded. 

Alternate verification procedures that do 

not meet the above requirements but 

produce equivalent results may be used. 

3.3 Deviation. The permissible error for 

the annual calibration and routine vertfica. 

Uon are: "*"" 

3.3.1 Annual Calibration Deviation. 

3J.1.1 Smoke Generator. If the Udar. 

measured average opacity for each data run 

is not within =3% (fuU scale) of the respecUve smoke generator's average opacity over 

the range of 0% through 80%. then the Udar 

shaU be considered out of calibration. 

3.3.1.2 Screens. If the Udar-measured average opacity for each data run Is not 

within =3% (full scale) of the laboratory-determined opacity for each respective simulaUon screen target over the range of 0% 

through 80%. then the Udar shall be considered out of calibration. 

3.3.2 Routine VeriflcaUon Error. If *.he 

lidar-measured average opacity for tach 

neutral density fUter (Technique 1) or optical generator selection (Technique 2) is not 

within =3% (fuU scale) of the respective 

laboratory calibration value then the lidar 

shall be considered non-operational. 

4. ."er/ormance/Deintm Specification 

Sane Lidar Susiem. for 

4.1 Lidar Design Specification. The essential components of the basic Udar system 

are a pulsed laser (transmitter), optical receiver, detector, signal processor, recorder, 

and an aiming device that is used in aiming 

the lidar transmitter and receiver. Figure 

AMl-VTI shows a functional block diagram 

of a basic lidar system. 

Transmitted light Pulse 

aaasatter Return Signal ; 

'iflee 5iqnai 

?tyjr» AM I -'/ll functional Slock Oxigram af a Sasic lidar Syilem 
P.57 

4.2 Performance Evaluation Testa. The 

owner of a Udar system shall subject such a 

Udar system to the performance verification 

tests described in Section 3. prior to first use 

of this method. The annual calibration shaU 

be performed for three separate, complete 

runs and the results of each should be recorded. The requirements of Section 3.3.1 

must be fulfilled for each of the three runs. 

Once t»*ie conditions of the annual calibraUon are fulflUed the Udar shall be subjected 

to the routine verification for three separate complete runs. The requirements of 

Section 3.3.2 must be fulfilled for each of 

the three runs and the results should be recorded. The Administrator may request that 

the results of the performance evaluation 

be submitted for review. 

3. References. 

5.1 The Use of Lidar for Emissions 

Source Opacity Determination. TJ-S. Environmental Protection Agency. National Enforcement Investigations Center. Denver. 

CO. EPA-330/1-T9-O03-R. Arthur W. Dybdahl. current edition CiNTLS No. PB81-

2466621. 

5.2 Field Evaluation of MobUe Lidar for 

the Measurement of Smoke Plume Opacity. 

U.S. Environmental Protection Agency. National Enforcement Investigations Center. 

Denver. CO.' EPA/NEIC-TS-128. February. 

1976. 

5.3 Remote Measurement of Smoke 

Plume Transmittance Using Lidar. C. S. 

Cook. G. W. Bethke. W. D. Conner (EPA/ 

RTP). AppUed Optics 11. pg 1742. August 

1972. 

5.4 Lidar Studies of Stack Plumes in 

Rural and Urban Environments. EFA-550/ 

4-73-002. October 1973. 

5.5 American National Standard for the 

Safe Use of Lasers ANSI Z 136.1-178. S 

March 1976. 

5.6 U.S. Army Technical Manual TB 

MED 279. Control of Hazards :o Health 

from Laser Radiation. February 1969. 

5.7 Laser Institute of America Laser 

Safety Manual. 4th Edition. 

S.3 U.S. Department of Health. Education and Welfare. Regulations for the Administration and Enforcement of the Radiation Control for Health and Safety Act of 

1968. January 1976. 

S.9 Laser Safety Handbook. Alex Mallow, 

Leon Chabot. Van Nostrand Reinhold Co1978. 

UTT-HOO 10—Drrrxj.ccf AI-ION or CAUON Moworxor Euxssxotfs nau STATMKAaT Somen 

1. Principle and Applicability. 

1.1 Principle. An integrated or continuous 

gas sample Is extracted from a sampling pome 

and analyzed for carbon monoxide (CO) convent using a Loft-type aondlsperslve infrared analyzer (NI5n*., or equivalent. 

1.2 A.pplicadillty. Tils taetaod is ippllcable tor :ae decermlaattoa of carbon monoxide emissions from stationary sources only 

wnea specified by the tast procedures for 

determining compliance Trim new source 

performance standards. The taut procedure 

wul indicate whether a continuous or aa 

integrated sample Is to be used. 

2. Range and sensitivity, 

-X Range. 0 to 1.000 ppm. 

22 Sensitivity. Minimum detectable concentration ls 20 ppm for a 0 co 1.000 ppm 

span. 

3. interference-. Any substance having a 

strong absorption of infrared energy will 

Interfere to soma extent. For example, discrimination ratios for water (E.O) and carboa dioxide (CO,) are U percent S.O per 

7 ppm CO aad 10 percent CO. per 10 ppm 

CO, reapecttTgiy, for devices meaaunag in th* 

1.500 to 3.000 ppm range. Tor devices meaawiag ln the 0 to 100 ppm range, interference 

ratio* can be aa high as 3.3 percent H,0 per 

29 ppm CO and 10 percent CO, per SC ppm 

CO. The use of silica gel and ascattta crape 

will alienate the major Interference problems. Tht measured gaa volume must ba 

corrected if theae saps are- used. 

4. Precision and accuracy. 

. 4.1 Precision. The precision af moat N"DIB. 

analyzers is approximately —2 percent of 

spaa. 

4.2 Accuracy. The accuracy of moat NOQt 

analyzers ta approximately —5 percent ot 

(pan after calibration. 

3. Apparatus. 

3-1 Continuous sample (Figure L0—1). 

Su.1 Probe. Stainless steel or ihesthad 

Pyrexl glass, equipped with a flltatr to remove 

parnculate matter. 

50-2 Atr-eooUd condenser or equivalent. 

To remove aay exeesa moisture. 

SJ Integrated tample (Figure 10-2). 

3.2.1 Probe. Stainless steal or sheatbed 

Pyrex glass, equipped with a filter to remove 

-Martlculata matter. 

S22 AlT-coola-d condenser or equivalent. 

To remove any excess moisture. 

SJL2 Valve. Needle valve, or equivalent, to 

to adjust flow rata. 

S i t Pump. Leak-free diaphragm type, or 

equivalent, to transport gaa. 

5.2.5 Hate meter. Rotameter, or equivalent. 

to measure a low range from 0 to 1.0 liter 

per min. (0.033 cfm). 

5.2.6 Flexible bag. Tedlar. or v^uivalent. with i capacity of 60 to 90 liters (2 

to 3 ft'). Leak-test the bag in the laboratory before using by evacuating bag with a 

pump followed by a dry gas meter. When 

evacuation is complete, there should be no 

flow through the meter. 

aixocup cowaum 

numna 

'•aavaiavL m n •mmajr . 

5.2.7 Pitot tube. Type 3. or equivalent. attachad to the prone so that tha sampling 

rate can ba reguisud proportional to the 

itaask gaa velocity when velocity is varying 

with the time or a sample traverse ia conducted. 

SJ ainofysis (Figure 10-3). 

• Mention of tr-ule Tiami-a or specific producta doaa aot coastltuta endorsement by the 

Za« Uuameatal Protection Agency. 

5 J.l Carbon monoxids analyzer. Nondlspersire infrared spectrometer, or equivalent. 

This instrument should ba damo-oscrated. 

preferably by the maaufacrurer. to meet or 

exceed manufacturer's rpectficatloaa and 

thoae described la this method. 

3.3.2 Drying tube. To contain approxlmataly 200 g of silica gel. 

5.3 J Calibration gas. Refer to Section 

6.1. 

[5.3.3 amended bv 53 FR 41333, October 

21. 1988] 

5.3.4 /"titer. As recommeaded by KDQt 

maaufacturer. 

5 J J. CO. removal tube. To con uon aoproximataiy SOb % of ascarite. 

5.3.6 fee ujorer batfi. Por aacanta aad silica 

gel tubas. 

3.3.7 Valve. Needle valve, or equivalent, to 

adjust flow rata 

5.3.3 flare meter. Rotameter or equivalent 

to measure gas flow rate of 0 to 1.0 Star per 

mm. (0.03S cfm) through HDIR. 

3 J j Recorder ioptional). To provide per-

•*""» • record of NDI8 readings. 

S. Reagents. 

UU: UU 

R«rja)l4.t. ZmmmM mmmmm\t*m> 

6.1 ColibraCaon gases. KaoiTi concentration 

of CO la nitrogen IN,) for icstrumeas spaa, 

prepurtfied grade of X, for zero, sad rsro.aaldltloasd concentrations eorrespoadlag approximately to 60 percent sad 30 percent spaa. The 

span concentration snail not exceed 1.5 times 

tha applicable source performance standard. 

Tha calibration gases snail be cercflad by 

ti« maaufacturer to be 7itaia —i percent 

of tne specified concentration. 
P.58 

• J -Wiled gel. Indicating typ*. 6 to 16 mash, 

dried ac 178* C (347- T) tat 2 hotxra. 

.2 Jjcarite. Commercially available. 

7. Proeedure. 

7a Sdmj»«n«7. 

7a.1 Conrinwous sampling. Sat up tha 

equipment as shown ln l*1gur» 10-1

 T***v

lng 

sure all eoanecnoa* are leak free. Plan tha 

probe in tha stack at a sampling point aad 

purge the sampling Una. Connect tha aaalya« aad begin drawtag sample into the 

aaalyxar. Allow 5 mlautaa for tha systam 

to f •t"'1—*i taen racard tha aaalyzar readlag as required by th* tsart procedure. (Saw 

Seaion 7.2 and 8). CO. content of the gas 

may be deterrnined by using the Method 3 

integrated sample procedure, or by weighing the ascarite CO, removal tube ar.d 

computing CO- concentration from the 

gas volume sampled and the weight gain 

of ihe mbe. 

[7.1.1 amended by 53 FR 41333, October 

21. 1988] 

T.U Integrated sampling. Evacuate tha 

flexible bag. Set up the equipment aa shown 

in Figure 10-3 with tha bag disconnected. 

Place the probe in the stack aad purge tha 

sampling Una. Connect the bag, making sure 

that all connections ara leak free. Sample at 

a rata proportional to the stattk velocity. 

CO, coataat of tha gas may ba detenaiasd 

by using tha Method 3 lategratad sampl* 

procedures, or by weighing ihe ascarite 

CO. removal tube and computing CO, 

concentration from the gas volume sampled and the weight gain of the tube. 

[7.1.2 amended by 53 FR 41333. October 

21. 1988] 

12 CO atnoiysu. Aasemble th* apparatus aa 

shown ln Figure. 10-3. calibrate eh* taatrameat, and partotm other required operations 

as described in section 8. Purge analyzer 

with Ni prior to introduction of each sampl*. 

Direct th* sample stream through tha tnstrament for tb* test period, recording th* readings. Chack th* zero aad span agsdn artatr th* 

tsars to aaeur* that aay drift or mattuaetjon 

la detected. Record tha sampl* data on Tail* 

10-L 

[7.2 amended by 53 FR 41333, October 

21. 1988] 

-. Calibration, .Assemble th* apparatus according to Ptgur* 10-3. Oanarafly « iastrnm*nt require* a warm-up period baror* stability u obtained. Follow th* maa.xLtactax.r-* 

mstruetleaa for specific procedura. iUiow a 

auannum tins* or oa* bom- ror warm-up. 

Otmag this time chack th* sampj# coadiOonlag apparatus. Ls, Altar, condaaaer drylag tuba, aad CO, rtmoval tub*, to ensure 

shat each component la tt good op«r»crig 

caadiaoa. Zero aad caUbrat* th* lastnimaat 

acoordlng to th* maauracturer'a procedure* 

Uatiag. rasspeetivaiy. aicogan aad tha callbrauoagaaam. 

**•'-"** 10-L—r-tu. data 

LoeatiaUl. Comments: 

Test 

Data 

Operator. 

Clock Mm* Rotameter setting. Men per minute 

(cubic feet per msnutt) 

9. Calculation — Calatiata tha concentrsOon of carbon monoxide in the sock using aquaaon 10-t. 

Cco.^j, *» Cco^^Q. - ?co,) equation 10-1 

where: 

CCO.M.V,*" concentration ot* CO in stack, ppm by volume (dry basis). 

Cco.._.,_*"t!o*m-

f

'eaiTadon of CO xneaiured by NDIE .uulyter, ppm by volume (dry 'N-DIR basis). 

/co,*** volume (raction of COt In sample, Le., percent COi from Ortat analysis 

divided by 100. 

[9. amended by 55 FR 47472, November 

14, 1990] 

10. Alternative Procedures 

10.1 Interference Trap. The sample conditioning system described in Method' 

10A. sections 2.1.2 and 4.2. may be used 

as an alternative to the silica gei and 

ascarite craps. 

[New 10. added by 53 FR 41333. October 

21. 1988] 

11. Bibliography. 

[Former 10 redesignated as 11. by 53 FR 

41333. October 21. 1988: 11.1 — 11.6 as 

1. — 6. bv 55 FR 47472. November 14, 

1990] 

1. MeHnry. Frank. The Intmeca NDIR-CO 

Analyser. Preaaated at :ith Matbooa 

CoaXer-mc* oa Air Pollution. TTnivantty 

of auromia. Berkeley. Calif- April I, 

1970. 

Jscaca. M.S.. et si. Continuous Deteria_..i».ioa of Carson Monoxide aad Hydrocarbons la Air by a Modified laxrared Analyser. J. Air Pollunoa Control 

Association. $(3) : 110-114. August 1959. 

MSA LIRA Intrared Css ind Liquid 

Analyzer lhstraenoa 3ook, Mine Saiety 

Appliances Co. Teeaaloal Products Olvision. PlttaOurgh. Pa. 

Moods 215a. 3I3A. ind 4I5A Ininred 

Analyzes-*. "•——•»" tostrameuta. Is c 

3*ckm«a lastr-aenoas 1835-a. Fullertoa. Calif. Octooer 1907. 

Continuous CO Monitonni Svstem. 

Model A5611. IntartaKA Corp. Princeton, 

UNOR Infrared Ou Aoslvters, Betiali 

Corp. aoacrferta. West Virginia. 
P.59 

APPENDIX B 

METHOD 22 

MRI-MvR8913-43 B-1 
P.60 

MiTHOD 22—VIS-.U, DETZailE* ATION OF FtfGrnvz EMISSIONS Faoat MAISRLU. 

Soiracss . .om SMOKS AMISSIONS FROM 

1. Introduction 

This method involves die visual determination of fugitive emissions. i.e.. emissions 

r.oc emitted directly from a procsss stack or 

due:. Fugitive emissions include emissions 

that <i) escape capture by process equipment e.xhaust hoeds: (2) are emitted during 

material transfer. (35 are emitted from 

buildings housing mater.al processing or 

handling equipment: and (-.) are emitted directly from process equipment. This method 

is used also to determine visible smoite emissions from flares used for combustion of 

waste process materials. 

This method determines the amount of 

time that any visible emissions occur during 

the observation period. Le.. the accumulated 

emission time. This method dees not require 

that the opacity of emi^ions be determined. 

Sines this procedure requires only the determination of •whether a visible emission 

occurs and does not require the determination of opacity levels, observer certification 

according to the procedures of Method 9 are 

not required. However, it is necessary that 

the observer is educated on the general procedures for determining the presence of viable emissions. As a •ninirrmm, -,ae observer 

must ce "rained and knowledgeable regarding the effects on the visibility of emi^ions 

caused by background contrast, ambient 

lighting, observer position relative to lighting, wind, and the presence of uncombined 

•water (condensing -water vapor). This training is *o be obtained from "written materials 

:'=und in References 7.1 and 7.2 or from the 

lecture portion of the Method 9 certification course. 

2. Applicability and Principle 

2.1 Applicability. This method applies to 

the determination of the frequency of fugitive emissions from stationary sources (located indoors or outdoors; when specified as 

the test method for determining compliance 

with new source performance standards. 

This method aiso is applicable for the determination of the frequency of visible 

smoke esiussions from flares. 

2.2 Principle. Fugitive emissions produced durmg material processing, handling. 

md Transfer operations or smoke emissions 

frcm flares are visually determined by aa 

observer without the aid of instruments. 

2. Definitions 

3.1 Emission Frequency. Percentage of 

time that eaLUSsions are visible during the 

observation period. 

3.2 Emision Time. Accumulated amount 

of time that emissions are visible during the 

observation period. 

3.3 Fugitive Eai^ons. Pollutant generated by an affected facility which is not collected by a capture system and is released to 

the atmosphere. 

3.4 Smoke Emissions. Pollutant generated by combustion in a flare and occurring 

Immediately downstream of the flame. 

Smoke occjirring within the flame, but not 

downstream of the flame, is not considered 

a smoke emission. 

3.5 Observation Period. Accumulated 

time period during which observations are 

conducted, not to be less than the period 

specified in the applicable regulation. 

4. Eauipment 

4.1 Stopwatches. Accumulative type with 

unit diviaons of at least 0.5 seconds: two required. 

4.2 Light Meter. Light meter capable of 

measuring illuminance in the 50- *.o 200-lu.t 

range: required for indoor observations 

only. 

5. Procedure 

5.1 Position. Survey the affected facility 

or building or structure housing the process 

to be observed and determine the locations 

of potential emisions. If the affected facility is located inside a building, determine an 

observation location that is consistent with 

the requirements of the applicable regulation (Le-. out3ide observation of emisions 

esc-iping the building/stricture or inside observation of emissions diirwtly emitted from 

the affected facility process unit). Then 

select a position that enables a clear 'new of 

the potential essisaon point(s) of the affected facility or of the building or structure 

housing the affected facility, as appropriate 

for the applicable .subpart. A position ac 

least 15 feet, but not more than 0.25 miles, 

from the emission source is recommended. 

For outdoor locations, select a position 

•where the sun is not directly in the observer's eyes. 

* 5.2 Field P.ecords. 

5.2.1 Outdoor Location. Record the following information on the field data sheet 

(Figure 22-1): company name, industry. 

process unit, observers name, observer's affiliation, and date. Record also the estimated wind speed, wind direction, and sky condition. Sketch the process unit oe.r.g observed and note the observer location relative to the source and the sun. Indicate :he 

• potential and actual emission points on tha 

sketch. 

5.11*2 Indoor Location. Record the following Information on the field data sheet 

(Figure 22-2): company name, industry. 

process unit, observers name, observers af-

"irwwm" 
P.61 

filiation, and date. Record as appropriate 

the type, location, and intensity of lighting 

on the data sheet. Sketch the process unit 

being obser/ed and note obser/er location 

relative to the source. Indicate the potential 

and actual fugitive emission points on the 

sketch. 

5.3 Indoor Lighting Requirements. For 

indoor locations, use a light meter to measure the level of illumination at a location as 

close to the emission source(s) as is feasible. 

An illumination of greater than 100 lux (10 

foot candles) is considered necessary for 

proper application of this method. 

5.4 Observations. Record the clock time . 

when obser/ations begin. Use one stopwatch 

to monitor the duration of the observation 

period: start this stopwatch when the observation period begins. If the observation 

period is divided into two or more segments 

by process shutdowns or observer rest 

breaks, stop the stopwatch when a break 

begins and restart it without resetting when 

the break ends. Stop the stopwatch at the 

end of the observation period. The accumulated time indicated by this stopwatch is the 

duration of the observation period. When 

the observation period is completed, record 

the clock time. 

During the observation period, continousiy watch the emi^ion source. Upon observing an emission (condensed water vapor is 

not considered an emission), start the 

second accumulative stopwatch: stop the 

watch when the emission stops. Continue 

this procedure for the entire obser/ation 

period. The accumulated elapsed time on 

this stopwatch is the total time emissions 

were visible during the obser/ation period. 

i.e., the eimssion time. 

5.4.1 Observation Period. Choose an observation period of sufficient length to meet 

the requirements for determining compliance with the emission regulation in the applicable subpart. When the length of the obserration period is specifically stated in the 

applicable subpart, it may not be necessary 

to observe the source for this entire period 

Lf the emission time required to indicate 

noncompliance (based on the specified observation period) is obser/ed in a shorter 

time period. In other words, if the regulation prohibits emissions for more than 6 

minutes' Ln any hour, then observations may 

(optional) be stopped after an emission time 

of o -ninutes is e.xceeded. Similarly, when 

the regulation is e.tpressed as an emission 

frequency and the regulation prohibits 

emissions for greater than 10 percent of the 

time in any hour, then observations may 

(optional) be terminated after 5 minutes of 

emissions are observed since 5 minutes is 10 

percent of an hour. In any case, the observation period snail not be less than S minutes 

in duration. In some cases, the process operation may be intermittent or cyclic In such 

cases, it may be convenient for the observation period to coincide with the length of 

the process cycle. 

5.4.2 Obser/er Rest 3reaks. Do not observe emi^ions continuously for a period of 

more than 15 to 20 minutes without taking 

a rest break. For sources requiring obser/ation periods of greater than 20 minutes, the 

obser/er shall take a break of not less than 

3 minutes and not .more than 10 minutes 

after ever/ 15 to 20 minutes of observation. 

If continuous observations are desired for 

extended time periods, two observers can alternate between making obser/ations and 

taking breaks. 

5.4.3 Visual Interference. Occasionally, 

fugitive emissions from sources other than 

the affected facility (e.g.. road dust) may 

prevent a clear view of the affected facility. 

This may particularly be a problem during 

periods of high wind. If che view of the potential e*aission points is obscured to such a 

degree that the obser/er questions che validity of continuing observations, then the 

observations are terminated, and the observer cieariy notes this fact on che data form. 

• 5.5 Recording Observations. Record the 

accumulated time of the observation period 

' on the data sheet as the observation period 

duration. Record che accumulated time 

emissions were obser/ed on the data sheet 

as the emission time. Record che clock time 

the observation period began and ended, as 

well as the clock time any observer breaks 

began and ended. 

S. CcUc-,latians 

If che applicable subpart requires that che 

emission rate be expressed as an e.mission 

frequency (in percent), determine this value 

as follows: Divide che accumulated emission 

time f-in seconds) by the du-racion of the observation period (in seconds) or by any minimum observation period required in che applicable subpart, if the acuta! observation 

period is less than the required per.od and 

multiply this quotient by LOO. 

7. References. 

7.1 Missan. Robert and Arnold Stein. 

Guidelines for Evaluation of "isibie Emisi sions Certification. Field Procedures. Legal 

.Aspects, and Background Material. ZFA. 

• Publication No. EF.*.-340/1-75-007. April 

1975 

7.2 WohiscfciegeL P. and D. E. Wagoner. 

Guideline for Development of a Quality Assurance Pre gram: Volume IU—Visual Determination of Opacity Emi^iotis From Stationary Sources. EPA Publication No. ZPA-

•350/4-74-005-1. November L975. 
P.62 

rTJGmV« OR SMQKZ £WIS*5ION INS?*C7.CN 

OUTDOOR LflCATICN 

Csmoany —__—_ _ 

Location -._______ _ 

Cjrnpany raortsantanv-a 

Cbaarvar 

Affiliation 

Oata __ _ 

Sky Csn^hiona 

f*****CTJ*t ation ._ 

Wind dtracaon 

Wind seaad — 

Incuaarv Procaaa unit 

Sltaten grocaar unit: indicata afiaarvar gcaitien raiaxiva is jcurca and sun; indicata gctantiai 

ttmiuicn gointa and/or actual atniaaion gcir.ts. 

OSSeSVATIONS 

3a*jin Cfcaarvaticn 

Cocx 

lima 

Observation 

paariod 

duration. 

min:3«c 

Xaz-(m..a\wd 

•inisxton 

lima, 

min.sac 

*..-.« cesarvaticn 
P.63 

Itjgitiv* .toisaior. Ins-pacnion Indoor Location Taclat 

•njcrnve aissioi INSPSCTICN 

DfXXTR LOCATICN 

Coapany 

..vScacicn 

Csacany **apre9a-»ncativ« 

CCaarvar ___ 

Affiliation 

Caca 

Industry Process unit 

Licrit typa (IluoirescBnt, incandeaacent, natural 

Li. ent location (cvwrha-wd, Sen ind coserwar, etc.) 

Illu«ira*nce (lux or Jootcandlea) 

Skats. process unit; indicata cOaervsr position relative co source; indicata pocencial 

mission points and/or actual amission poinca. 

v**BS£RVXnCNS 

•Jaqinninj observation 

accx tun* 

cesar/ation 

period 

duration. 

ram: sec 

Aaccuauiated 

oeissicn. 

tune. 

rain-sec 

Sind coaarvation 
P.64 

APPENDIX C 

METHOD 1 

MRI-M\H8913-43 C-1 
P.65 

33-39.3 

TENNESSEE VISIBLE E.M 155IONS EVALUATION 

METHOD I 

Visual Determination of Opacity of Emissions 

From Nontraditional Sources 

(Roads and Parking Areas) 

Tennessee Division of Air Pollution Control 

Source Sampling Section 

TERRA' Suiiding 

150 9th Avenue. Norm 

Nashville, Tennessee 37203 

May, 1981 

Approver By: 

On: 

Tennessee Air .

D

ollution 

Control Board 

A onl 29, 1982 

Amended: Seotemoer I J. 1982 
33-39.3 

TVEE Method I 

Section No. 2 

Revision No. 5 

Date April 26, 1982 

Page I of I Pages 

33-39.3 

Opacity of Emissions From Nontraditional Sources 

(Roads and Parking Areas) 

1. Principle and applicability 

1.1 Principle. The opacity of emissions from nontraditional sources 

(roads and parking areas) is determined visually by an observer 

qualified in accordance with criteria approved by the Tennessee Air 

Pollution Control Board ''on March 20, 1973). 

1.2 Applicability. This method is applicable for the determination of the 

opacity of emissions from nontraditional sources (roads and parking 

areas). 
TVEE Method ! 

Section No. 2 33-39. j 

Revision No. 5 

Date April 26. i 932 

Page 1 of I Pages 

33-39.3 

Opacity of Emissions From Nontraditional Sources 

(Roads and Parking Areas) 

Procedures. Tr.e observer qualified in accordance with the criteria set 

forth by the Tennessee Air Pollution Control Board shail 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 

I->Q0 sector to his back. Consistent with maintaining the above 

requirements, the observer shall, as much as possible make his 

observations from a position such that his line of vision is 

•approximately perpendicular to the olume and wind direction. The 

observer's line of sight should not include more Chan one olume at a 

time when multiple plumes are involved. 

2.2 Fieic records. The observer shall record the name of the plant, 

nontraditional source location, type (road or parking lot), method of 

control used, observer's name, certification date and affiliation, and 

the date on a field data sheet. The time, estimated distance to the 

nontraditional source location, approximate wind direction, estimated 

wind speed, description of the sky condition (presence and color of 

clouds), observer's position with respect to nontraditional source, and 

coior of plume and type of 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 using a contrasting 

background at a point that is perpendicular to the observer's line of 

vision and approximately four feet directly above the surface of the 

road or parking area from which the emissions are being generated. 

This initial reading shall commence immediately after a plume has 

been created from the surface involved. The observer shall not look 

continuously at the plume, but instead shall observe the plume 

momentarily at 15-second intervals. 

!.'•*• Recording observations. Opacity observations shall be recorded to 

the nearest 5 percent at '15-second intervals on an observational 

record sheet- A minimum.of S observations shall be recorded. Each 

momentary observation recorded shall be deemed to represent the 

average opacity of emissions for a 15-second period. A watch shall 

be used for determining 15 second intervals. 

2.5 Data reduction. Opacity shall be determined as an average of S 

consecutive observations recorded at 15-second intervals. Divide the 

observations recorded on a record sheet into sets of 8 consecutive 

observations. Sets need not be consecutive in time and in.no case 

shall two sets overlap. For each set of 8 observations, calculate the 

average by summing the opacity of the 3 observations, and dividing 

this sum by 3. Record the average opacity on a record sheet. 
P.68 

83-39.3 

TVEE Met.hod ' 

Sect'on No. 3 

Revision Vo. •* 

Date September 1( 

Page 1 of 1 Pages 

33-39.3 

! a 32 

Opacity of Emissions From Ncntraditicnai Sources 

CRoads and Parking Areas^ 

3.0 Prohibitions. Certain conditions can occir which prohibit the 

accurate visual determination by a qualified observer: 

3.1 Vehicles. Consecutive readings can be suspended for any 15 second 

period to compensate for a vehicle being in the line of sight. If this 

occurs the reading must be -narked "V" for vehicle. Readings will 

continue at the next 15 second period and be considered as long as 3.2 

is complied with. 

3.2 Intermixing of plumes. Readings must terminate if a vehicle passes 

through the area going in the opposite direction and creates a plume 

that is intermixed with t**** plume being read. A new set of readings 

must be started when the plume has settled and another plume has 

been generated. Intermixing of plumes from vehicles traveling in the 

same direction represents the road conditions and readings will 

continue in the prescribed manner. 

3.3 Representative reading. A reading encompassing an unusual 

condition (such as a broken bag of cement on the pavement) cannot 

be used to represent the entire surface condition involved. In such 

cases, another set of readings, encompassing the average surface 

condition, must be conducted. A reasonable amount of time will be 

allowed to correct an unusual condition. 
P.69 

TVEE Method ! 

Section .No. 4 

Revision No. 3 

Date April 26, 1982 

Page I of 1 Pages 

83-39.3 

83-39.3 

Opacity of Emissions From Nontraditional Sources 

(Roads and Parking Areas) 

•+.0 Observational Error 

->.l A positive observational error of 10.0 percent opacity shall be taken into 

account prior to issuing a Notice of Violation on nontraditional sources 

(roads and parking areas). This positive observational error of 10.0 

percent opacity includes the observers highest two minute average 

positive deviation (certification'* up to and not exceeding 10.0 percent.