P.1 

OAR Box 1115 

Prepped by Ryan Dugan 

Document Number: 

81) ll-A-13 

Docket Number: 

A-84-22 

Printed 4/18/2008 10:52:08 AM Sheet 81 of 94 
P.2 

H-fY-pz JL-Pt~& 

Field Evaulation* of Opacity Reading Methods 

for 

Intermittent Plumes 

Contract No. 68-01-5110 

Task Order # 19 

Prepared by: 

DEL GREEN ASSOCIATES, INC. 

Environmental Technology Division 

1535 N. Pacific Highway 

Woodburn, Oregon 97071 

Prepared for: 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

Division of Stationary Source Enforcement 

Research Triangle Park, NC 27711 

TASK MANAGERS 

Kirk Foster 

Robert Ogg 

December 1931 
P.3 

TABLE OF CONTENTS 

page 

I. Summary 1 

II. Introduction 3 

III. Reading Methods 6 

A. Method 9 6 

B. Stopwatch Method 7 

C. Frequency Distribution Method 8 

D. Margin of Error 12 

IV. Field Study 14 

A. Experiment Design 14 

B. Equipment 19 

C. Observers 23 

D. Field Experiment 23 

E. Field Data 29 

F. Results 37 

Appendix A - Method 9 

Appendix B - Equipment Specifications 

Appendix C - Data Form Instructions 

Appendix D - Test Data 

Appendix E - Participants 

i I 
V 

P.4 

LIST OF TABLES 

page 

Table 1 Meteorological Conditions 30 30 

Table 2 Data Sets by Plume Color, Configuration, 38 38 

and Reading Method 

Table 3 Method 9 and Transmissometer Average Opacities, 

Black Smoke 

40 

Table 4 Method 9 and Transmissometer Average Opacities, 42 

White Smoke 

LIST OF FIGURES 

Figure 1 Coke Oven Form -- Charging Emissions 9 

Figure 2 Coke Oven Form -- Pushing Emissions 10 

Figure 3 Typical Plume -- Fast Rise 15 

Figure 4 Typical Plume -- Intermediate Rise 16 

Figure 5 Control Box 20 

Figure 6 Smoke Generator 21 

Figure 7 Certification Results 25 

Figure 8 Observer Locations 28 

Figure 9 Field Data Sheet 31 

Figure 10 Observed Mean Opacity v. Actual Mean Opacity, 44 

Black Smoke 

Figure 11 Observed Mean Opacity v. Actual Mean Opacity, 45 

White Smoke 

Figure 12 Standard Deviation of Observed Mean Opacity vs 46 

Actual Mean Opacity, Black Smoke 

Figure 13 Standard Deviation of Observed Mean Opacity vs 47 

Actual Mean Opacity, White Smoke 

111 
1 

LIST OF FIGURES (Cont.) 

Figure 14 Frequency of Difference Between Actual 

and Observed Mean Opacities, Black Smoke 

Figure 15 Frequency of Difference Between Actual 

and Observed Mean Opacities, White Smoke 

48 

49 

Figure 16 Frequency of Difference Between Actual 50 

and Observed Times of Excessive Emissions 

(Frequency Method), Black Smoke 

Figure 17 Frequency of Difference Between Actual 51 

and Observed Times of Excessive Emissions 

(Frequency Method), White Smoke 

Figure 18 Frequency of Difference Between Actual 52 

and Observed Times of Excessive Emissions 

(Stopwatch Method), Black Smoke 

Figure 19 Frequency of Difference Between Actual 53 

and Observed Times of Excessive Emissions 

(Stopwatch Method), White Smoke 

iv 
P.6 

• WT,Tn-*T**T"*»' 

ACKNOWLEDGEMENT 

Del Green Associates, Inc. (DGA) would like to express 

their appreciation for the assistance provided by Eastern 

Technical Associates in conducting the field work for this study. 

DGA wishes to acknowledge that the data summaries presented in 

this report are based on statistical evaluations conducted by 

the Research Triangle Institute for the Environmental Protection 

Agency. 
P.7 

I. SUMMARY. 

In 1974, EPA promulgated Method 9 to evaluate relatively continuous visual emissions for certain categories of new industrial sources. 

Though Method 9 is adequate for determining emissions of most sources, 

it may be ineffective for determining the compliance status of sources 

with short-term and intermittent excessive emissions. In addition, 

the data averaging technique of Method 9 is not compatible with numerous State aggregate-time regulations. Because of the Court's decision 

in Donner-Hanna Coke Corporation v. Costle regarding the use of 

a modified form of Method 9 to enforce such an aggregate-time regulation, EPA is now studying alternative methods for the determination 

of the opacity of highly variable and intermittent plumes. Field 

studies have been conducted to evaluate the general applicability of 

aggregate-time reading methods for intermittent plumes and the error 

associated with these methods. 

This report describes a field study conducted at Research Triangle 

Park, North Carolina, May 19-23, 1980, and summarizes the data collected. The purpose of the experiment was to evaluate two candidate 

aggregate-time reading methods: the frequency method and the stopwatch 

method. In the frequency method, readings are taken at 15-second 

intervals; during the data reduction, 15 seconds of excess emissions 

are accumulated for each observation equal to or exceeding 20% opacity. 

In the stopwatch method, time is accumulated directly on a stopwatch 

whenever the observed opacity is equal to or greater than 20%. 

During this field test, a smoke generator meeting the require-
P.8 

ments of Method 9 was used to produce a series of varying opacity 

plumes with "rapid" and "intermediate" opacity rise/fall speeds. 

Twelve participants observed a total of 1172 six-minute readings 

(about 100 readings/observer) during the four-day field trials. Both 

white and black plumes were evaluated. 

Data generated during this field study have been analyzed sta-

(2) tistically, and the results are presented in a separate report. 

This report provides a detailed discussion of the experiment and presents the data obtained (Appendix D). 
P.9 

II. INTRODUCTION 

The Environmental Protection Agency was required by the Clean Air 

Act of 1970 to establish standards of performance (emission limitations) for certain new industrial source categories. To supplement 

these standards, test methods for measuring various air pollutants were 

promulgated. Among these test methods was Method 9 (40 CFR 60, Vol. 

39, No. 219 of the Federal Register dated November 12, 1974), which is 

used for evaluating visible air emissions. Method 9 is very specific 

regarding the procedures and requirements for making opacity readings. 

Method 9 specifies that opacity readings are to be taken every 15 

seconds, and that 24 consecutive readings (covering six minutes) be 

averaged. Method 9 also includes requirements for certification of 

opacity readings, and has become the widely accepted standard for 

opacity training and certification. It is also extensively used in the 

documentation of source compliance, although the averaging times may 

vary. It is, however, recognized that Method 9 data documentation 

procedures are not applicable to all types of plume configurations 

(i.e., intermittent plumes). 

The 1974 preamble to Method 9 states that the averaging required 

under Method 9 may not be suitable for certain types of opacity emissions that are intermittent in nature. Highly variable emissions, such 

as those of coke oven batteries, are difficult to evaluate with an 

averaging method such as Method 9. At coke ovens, for example, substantial emissions with significant impact on ambient air quality can occur 

over a one- or two-minute period, with the cycle being repeated every 
P.10 

five to ten.minutes. A six-minute average, therefore, does not accurately represent the significance of the emission releases. 

Several reading method variations for coke oven type emissions 

have been adopted (both formally and informally) by various State and 

local agencies, mostly utilizing the accumulation on a stopwatch of 

total time exceeding the emission limit. EPA's Region II attempted to 

use one such reading method to document visible emissions from the 

Donner-Hanna coke ovens in New York State. In the subsequent court 

(2) 

case, Donner-Hanna Coke Corporation v. Costle , it was concluded that 

under 40 CFR 60, Section 51.12(c), EPA is required to use Method 9 in 

the absence of a specified reading method in the New York State Implementation Plan. Furthermore, the Court found that the agency's method 

of reading coke ovens strayed so far from Method 9 that a separate 

rulemaking procedure was required to address these intermittent plumes 

properly. 

A Federal Register modification of Method 9 to cover highly intermittent visible emission sources is needed. The purpose of the experiment described herein is to provide a data base for such modification 

or amendment of Method 9. Based on the data base generated, a methodology will be suggested and the appropriate method modification promulgated. 

In addition to Method 9 modification for evaluating highly variable visible emission sources, a modification is needed for the general 

application of the frequency distribution method employed by most State 

and local air control agencies. As a part of this effort, another 
P.11 

field experiment to evaluate continuous plumes was conducted in October 

|uen< 

(4) 

(3) 1980/ A third field experiment to evaluate the opacity frequency 

method on slowly changing plumes was conducted in January 1981. 

The entire project is to occur in three major phases. The first 

phase comprises the three field experiments, to be followed by statist-

(2) 

ical analyses of the data generated (Phase 2) , drafting of the technical support documents and methodologies, and preparation of the 

Federal Register package (Phase 3). This report covers only the actual 

field experiment for reading highly intermittent emissions. 
P.12 

III. READING METHODS 

At least three different opacity reading methods commonly are 

used. These methods are Reference Method 9, the stopwatch time accumulation method, and the frequency distribution method. The stopwatch and 

frequency distribution methods are the two candidates for reading 

highly intermittent emissions, and they were tested in this experiment. 

A. Reference Method 9 

This procedure for reading plumes was adopted as the standard 

visual emission evaluation procedure for sources subject to New Source 

Performance Standards. 

Method 9 requires the observer to be certified in accordance with 

test procedures contained in Paragraph 3 of the method procedures. 

Method 9 is included in this document as Appendix A. After certification, which includes theory and practical field experience, the 

observer must follow specific reading criteria whenever observations 

are taken. Considerable emphasis is placed on the physical relationship of the observer to the sun, plume, background, and source. After 

the physical requirements contained in the procedure are satisfied, the 

plume is read at 15-second intervals for six consecutive minutes. 

During the observation period, the plume is viewed only briefly at the 

15-second interval point. 

The NSPS regulations generally stipulate a maximum allowable 

visible (opacity) emissions level (no time limit specified). A typical 

regulation reads as follows: 
P.13 

"... no owner or operator subject to the provisions 

of this regulation shall cause to be discharged into 

the atmosphere any gases which exhibit greater than 

20% opacity." 

40 CFR 60, Section 60.11 (b) "Standards of Performance for New 

Stationary Sources", stipulates that Method 9 shall be used in determining NSPS opacity compliance. As previously mentioned, this method 

requires that opacity be determined as an average of 24 consecutive 

observations recorded at 15-second intervals to obtain a six-minute 

average opacity. In practice, an observer usually will take a minimum 

of ten minutes (40 readings) to establish compliance status; this procedure provides a reasonable level of caution in compliance determination and documentation. Because of the stipulated procedure for data 

reduction, Method 9 is commonly referred to as the "averaging" method. 

B. Stopwatch Method 

The stopwatch procedure has recently been applied by several air 

pollution control agencies as a better means to address intermittent or 

fugitive emission sources, especially those sources with short-term, 

high level emissions (i.e., coke ovens). Typically, these sources have 

very high particulate emissions represented by 60 to 100% opacity for 

brief periods (less than one minute) during charging and/or pushing 

operations. Therefore, it is difficult and frequently impossible to 

represent the high level of emissions being released using the averaging technique, even though the emissions are significant. 

The stopwatch method involves the use of two stopwatches. One 

watch is started at the time observations are initiated. The second 
P.14 

watch is started whenever the emissions exceed the allowable opacity 

level and stopped when the emissions drop below the allowable level. 

This procedure is repeated whenever the allowable opacity is exceeded. 

When the reading or observation period is completed, the observer 

stops the first watch and records both the total time of observation 

and the accumulated time of opacity violation recorded on the second 

stopwatch. The maximum opacity during each excursion period is noted 

and recorded. The total time recorded above the allowed opacity limit 

then is compared against the time allowed in the applicable regulation. 

Sample reading forms used for coke ovens are included as Figures 1 and 

2. 

The plume is studied during the entire observation period under 

this method. In Method 9 and the frequency distribution method, the 

observer-is cautioned not to study the plume but to make momentary 

observations every 15 seconds. Thus the stopwatch procedure differs 

significantly from the Method 9 and frequency distribution reading 

procedures in this respect. The observer still must maintain the 

proper physical relationship in reference to the sun, plume, and background. 

C. Frequency Distribution Method 

All State and local agencies have opacity regulations in their 

State Implementation Plan control strategies. Most of these regulations stipulate time exemptions; thus, opacity readings often are documented by the frequency distribution procedure. This procedure was 

derived over the years from agency experience in controlling smoke 
P.15 

Company 

Location _ 

Company Rep. 

Inspector 

Figure 1 

METHOD A 

CHARGING OBSERVATIONS 

Date 

Sky Condition 

Wind Speed _ 

Ambient Temp. 

Background 

Battery/Oven 

Time of Charge: Start_ 

End 

Times. .%(seconds) 

Opacity 

Charge period 

Seal period 

Total 

Maximum opacity 

Comments: 

Indicate sun position, observation 

position, and wind direction: 

Mark dominant emission points 

«£*L^_____1__^_._?=-*1 

k M M )\^i 

w J7WJ U 

Battery/Oven 

Time of Charge: Start_ 

• End 

T1n-s2_ .%(seconds) 

Opacity 

Charge period 

Seal period 

Total 

Maximum opacity 

Comments: 

Indicate, sun position, observation 

position, and wind direction: 

Mark dominant emission points: 

&-£^_-i^_____rn 

KM M ; wi 

•tf «=3 

u aid 4A / 

ra 

tf1 

a 

Battery/Oven 

Time of Charge: Start. 

End 

Tlire 2 _ .%(seconds) 

Opaci ty 

Charge period 

Seal period 

Total 

Maximum opacity 

Comments 

Indicate sun position, observation 

position, and wind direction: 

Mark dominant emission points 

KM M )\^i 

?J7 v w n 
Figure 2 

P.16 

ENVIRONMENTAL PROTECTION AGENCY 

PUSHING OBSERVATIONS (METHOD D) Page of 

Company Name 

Sky Condition ___________________ _ 

Relativ e Humidity _______________ _ 

Type of Pollutio n Control Device (i f any?) 

Company Location 

Wind Speed 

Ambient Temperature 

3ATTERY/0VEN 

riME DOOR 

•tEMOVED (A*) 

TIME Z * 

BETWEEN (A&B) 

TIME OF' 

PUSH (B) 

TIME Z * 

BETWEEN (B&C) 

TIME OF 

QUENCH (D)* 

TIME z *• 

BETWEEN (C&D) 

MAXIMUM OPACITY 

BETWEEN (BSD) 

POSITION 

BACKGROUND 

COMMENT NUMBER 

COMMENTS:** 

* Indicat e applicabl e opacity 

** If pollution control device is utilize d indicat e any problems wich Che 

system. 

Indicat e sun (•?,*), vind direction (Hf>), 

observer ( 0 ), north (—>N), push side 

(PS), and coke 3ide (CS) 

A *• Door Removed 

B *• Star t of Push 

C - End of Push 

D .• Star t of Quench 

INSPECTOR (Print Name); 

(signacura): 

DATE: 

COMPANY REPRESENTATIVE: 

10 
P.17 

emissions from combustion sources. It was recognized that boilers* 

typically and unavoidably exceed "normal" emission levels frequently. 

These periods of high emissions generally are associated with boiler 

start-up, shutdown, and tube (soot) blowing. Operating experience and 

practices determine these higher emission periods to be in the few 

minutes per hour range. Air control agencies, therefore, negotiated 

and adopted time exemption regulations in accordance with the kinds, 

sizes, and types of boilers and fuels used within their jurisdictions. 

A typical opacity regulation involving time exemption reads as follows: 

"No person shall cause, suffer, allow or permit the 

emission of any air contaminant into the atmosphere 

from any air contaminant source for a period or periods 

aggregating more than three minutes in any 60-minute 

period equal or greater than 20% opacity". 

The opacity limits and period of time exemption vary in each 

state, but the concepts and approaches are similar. In application, 

the observer would make opacity readings in accordance with prescribed 

procedures, which are essentially the same as Reference Method 9. Such 

readings are made by momentarily glancing at the plume at 15-second 

intervals to read and record the plume opacity. Readings typically are 

made from 6 to 60 minutes. The number of readings in excess of the 

allowable opacity level would be counted to determine compliance or 

noncompliance. For example, in determining compliance with the cited 

regulation, readings are taken for six minutes at 15-second intervals, 

for a total of 24 observations: 

11 
P.18 

2 readings were 10% opacity 

4 readings were 15% opacity 

5 readings were 20% opacity 

9 readings were 25% opacity 

4 readings were 30% opacity 

This source is in violation of the example regulation with 18 readings 

or 4.5 minutes greater or equal to 20% opacity. 

D. Margin of Error 

There will be some margin of error inherent in any opacity reading method. The error associated with Method 9 (24 readings averaged) 

was established during field experiments in 1973 to be less than 7.5% 

opacity in 99% of the six-minute readings taken. Most State and local 

agencies make some recognition of this error factor and have established error margins for their opacity training and field reading/-

enforcement programs. This is generally reflected in the agency's 

informal policy of operation and is loosely based on experience in 

reading smoke plumes in the field and at smoke schools. Typical error 

margins cited in State enforcement programs for the frequency method 

(5) 

are as follows: 

1. Each 15-second reading must De 10% or more above the opacity 

limit; or 

2. For a three-minute time exemption, six minutes of excessive 

emissions must be recorded before a violation is declared; or 

3. For a three-minute time exemption, the readings must be at 

least 5% above the standard for at least four minutes. 

12 
P.19 

Using the frequency method and typical margins of errors utilized 

in the field, the example source (page 12) would not be in violation 

under criterion one above (only 1 minute at or above 30% opacity), 

under criterion two (only 4£ minutes at or above 20%), or under criterion three (only 3i minutes at or above 25%). 

13 
P.20 

IV. FIELD STUDY 

A. Experiment Design 

Two methods of reading highly variable and intermittent plumes 

were field tested. These methods are described and referred to as the 

stopwatch method and the frequency distribution method. 

The field study was designed to minimize the number of variables 

and to obtain an adequate data base for analysis. Only two distinct 

plume configurations were used. These basic plume configurations are 

characterized as fast rise and fall, and intermediate rise and fall. 

Figures 3 and 4 are strip charts of actual test runs and are typical 

examples of the two plume types. The rate of rise and fall refers to 

the rate of change of opacity as it passes through the 20% level. 

These plumes are characteristic of some source types of significant 

particulate emissions, where emissions are highly intermittent in 

nature. They are not indicative of more typical plumes encountered by 

control agencies. Both black and white plumes were read to determine 

the effect of dark and light smoke on reader accuracy. 

One of the most important highly intermittent sources currently 

encountered is the coke oven battery. Coke ovens present a difficult 

problem in a study such as this, in that most of their emissions do not 

come from stacks but rather are fugitive in nature. Field studies of 

coke ovens, therefore, cannot include a comparison of visual observations and transmissometer readings. Because of the lack of appropriate 

and readily available sources with transmissometers and the need to 

generate the necessary plumes as efficiently as possible, it was 

14 
"rm: I rr:i .1:1 0 o T .-

to 

0 

'ft 

s rv 

<v> 

ui 

Pi 

_ r« /*» U-t 

I 25 

Figure 3 

Fast Rise/Fall Plume 

Peak width 75 sec. 

Rate of rise = 

(60-10)% opacity 

1.5 seconds 

-------1 

""" T" ""."."iV~ 

-

1.5 Seconds 

1 Minute H 

15 
P.22 

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C D; 
decided to simulate these plumes with a smoke generator. The equipment 

used is discussed in more detail in the next section. 

Each run was six minutes in duration and contained one to three 

opacity peaks. Each peak generated was either a rapid or intermediate 

rate-of-rise peak. The rate of change of opacity was not varied within 

the run (i.e., there was no mixing of rapid rise and intermediate rateof-rise peaks). Each plume configuration was run separately, and there 

were 20 runs each for the black plumes and 30 runs each of the white 

plumes. The predetermined plume patterns to be followed during testing 

are presented in Appendix C along with the transmissometer test log. 

The rapid rise plume is defined as a plume that rises from less 

than 10% opacity to greater than 60% opacity, and then after some interval returns to less than 10% opacity. The plume was maintained at peak 

opacity for between 15 and 90 seconds, in 15-second increments. It 

required approximately 1.5 seconds to change the opacity of the plume 

from 10% to 60%, or about 35% opacity change per second. 

The intermediate rise plume can be described as changing from 

less than 10% opacity up to 50% opacity, maintaining that level for an 

interval, and then returning to 10% opacity. The plume remained at 50% 

opacity for 30-second intervals, up to a maximum duration of 90 seconds 

per peak. The change in opacity of the plume occurred in 10-12 

seconds. The rate of change was approximately 2-3% opacity per second. 

Actual transmissometer traces of representative plumes are shown in 

Figures 3 and 4. 

17 
P.24 

Although both plume configurations appeared "fast" to the 

observer, there was up to a full order of magnitude (factor of 10) 

difference in their rates of opacity change. Thus, one was designated 

a fast rate-of-rise plume and the other an intermediate rate-of-rise 

plume. The four plume configurations were black fast rise, black intermediate rise, white fast rise, and white intermediate rise. 

Prior to starting the field project, the data base requirements 

were reviewed to establish the minimum number of data points required 

for a statistically valid evaluation of each plume configuration. 

Using the population on a standard "T" chart, it was determined that 60 

data points would meet the minimum requirements. Data points in addition to the required minimum were obtained in all cases. White plumes 

were given additional consideration because there are many more sources 

with non-black plumes. Therefore, the number of white plume data 

points was increased by 50%. 

During each six-minute run, six of the observers used the stopwatch method, and six used the frequency distribution method. Thus, 

for each of the four major types of plumes, the following data points 

were to be obtained for each reading method: 

Plume Type Data Points Gathered Min. Data Pts. Stat. 

Required 

Black, intermediate 6 readers X 20 runs = 120 60 

Black, fast rise 6 readers X 20 runs = 120 60 

White, intermediate 6 readers X 30 runs = 180 60 

White, fast rise 6 readers X 30 runs = 180 60 

18 
P.25 

In addition.to these primary data points (i.e., one time value above 

20% opacity per six-minute reading), secondary data points were 

obtained for the frequency distribution method. That is, individual 

15-second readings could be compared with actual transmissometer readings for an additional 24 data points per six-minute run. 

B. Equipment 

In order to simulate a rapidly rising and falling plume, a standard smoke generator used for the training and certification of observers was modified to provide the required fast response. The overall 

requirements for the modified generator were as follows: 

1. Must be able to increase opacity from 0% to at least 40% 

in less than 10 seconds, and then drop to 10% opacity within 

15 seconds and to 0% opacity within 25 seconds. 

2. Must maintain opacity within the ranges of 40% and 80%, and 

25% and 40%, for up to 45 seconds. 

3. Must have a transmissometer that meets the minimum standards 

as set forth in Method 9 (see Appendix A) . 

A modified Environmental Industries Model 3000 Smoke Generator 

was used (see Figures 5 and 6 for diagrams and Appendix B for specifications). The major components of the system were as follows: 

Transmissometer 

1. photopic filtered selenium photocell 

2. incandescent 12 volt light source 

3. laboratory data control recorder 

4. TRW span control module 

19 
P.26 

Figure 5 

Control Consol i 

Components are identified 

in Appendix C 

(Control Console) 

20 

SMOKE GC*.: '".A:; I . 

*.'.ODE_. - 2:0 : 

EIWlROW-HMTAl . I*..-••_•:.7 = 

CARY. r.'ORTH CASO -.!:. ' 

DA7E: O-T '.v7S 
Figure 6 

Smoke Generator 

SMOKE GENERATOR 

MODEL -3000 

ENVIRONMENTAL INDUSTRIES 

CARY. NORTH CAROLINA 

DATE: OCT. 1979 

Components are identified in Appendix C 
P.28 

Fuel Delivery System 

1. four AC 12 volt fuel pumps 

2. Whitey metering fuel valves 

3. special fast delivery fuel panel 

4. dual fuel delivery lines 

Black Smoke Chamber 

1. modified for fast rise time and continuous high output opacity 

2. fuel - toluene 

White Smoke Generator 

1. modified for two input fuel lines (both utilizing diesel) 

2. propane-operated vaporizing chamber 

3. fuel - diesel 

Calibration filters 

1. Mel les Groit NBS traceable 

2. glass metallic construction 

3. maximum error less than 0.5% 

Fan 

1. 3/4 horsepower 12-inch blower 

2. stack diameter 12 inches 

3. free air flow 1510 CFM (30 fps) 

Quality Assurance 

Method 9 requirements were followed for calibrating the transmissometer, including the 30-minute warm-up before calibration. The 

day before the field trials (May 19), the following parameters were 

confirmed to be within specifications: 

22 
1. calibration error - ±3% opacity, maximum 

2. zero span drift - ±1% opacity, 30 minutes 

3. response time - _<5 seconds 

During the field trials, the transmissometer and recorder were 

electronically calibrated using a zero and span check between each 

six-minute run. These calibrations assured accurate chart data from 

the transmissometer. Midway through the series of runs, an audit was 

performed on the transmissometer using neutral density filters to assure 

reliable and accurate data. At the completion of the experiment, the 

smoke generator was recalibrated to check for any deterioration of 

operation. Neither the audit nor the final calibration indicated any 

equipment deterioration. 

C. Observers 

Twelve observers were chosen to particpate in the field trials. 

All twelve were employed in the air pollution field, working in such 

areas as stack sampling, industrial source inspections, and conducting 

smoke schools. Employers at the time included EPA (2), State air 

pollution control agencies (.2), and private consulting firms (8). 

A wide spread of smoke reading experience levels was sought in 

choosing the participants. Two had no previous experience reading 

plumes. The most experienced reader was first certified twelve years 

previously. Most of the observers had one to six years of certified 

reading experience. 

D. Field Experiment 

The field study was conducted at the EPA Beaunit facility in 

23 
P.30 

___________________________i__________ ^ -_ , 

Research Triangle Park, North Carolina, May 19-23, 1980. A plume 

evaluation training course and experiment briefing was held May 19. 

The experimental field runs were conducted at the same facility. 

Prior to starting the field experiment, a refresher course on 

plume evaluation was conducted. The course reviewed all the basics 

normally taught at a plume evaluation training course. Special emphasis 

was placed on proper plume backgrounds, sun angles, distance to 

plumes, and eye fatigue. This was to assure that these critical elements were recognized and given proper consideration during the field 

studies. In addition, the readers were instructed in the operation 

of a stopwatch and how to read and record data. 

After the classroom training session, all observers participated 

in the standard smoke reading tests. Each observer was required to 

make 25 white and 25 black readings consecutively with no more than 

a 15% deviation on any one reading, while maintaining a 7.5% or less 

deviation for each set of 25 readings. The smoke generator met all 

requirements of the EPA Method 9 criteria. Charts were made during 

the course of the certification runs, which included the calibration 

checks. All observers were able to certify (see Figure 7 for certification results). 

The readers were assigned numbers and half of the readers were 

provided with stopwatches. Simultaneous readings were obtained during 

each run with six readers using the stopwatch and six readers using 

the frequency distribution method of reading. Each reader was required 

to read either by the stopwatch method or frequency method during each 

run. 

24 
P.31 

Figure 7 

Certification Results 

Observer 

11 

12 

13 

14 

15 

16 

22 

23 

24 

25 

26 

27 

Qualified 

on run # 

3 

2 

2 

1 

2 

2 

3 

2 

3 

1-

1 

4 

% Average Deviati 

White 

3.0 

4.6 

5.0 

7.0 

5.6 

6.6 

5.4 

7.0 

4.0 

4.6 

7.2 

7.0 

on - 25 readings 

Black 

3.6 

3.8 

3.4 

4.2 

6.0 

6.0 

3.0 

3.4 

7.4 

7.4 

6.0 

5.8 

25 
P.32 

Midway through each set of runs (after 10 or 15 six-minute runs), 

the stopwatches were given to the readers who had performed the frequency type readings. Thus, all readers performed approximately an 

equal number of stopwatch and frequency type runs. 

Approximately 30 runs were conducted each day of the experiment, 

with each run lasting six minutes. To assure interval uniformity, 

a tape recording was used as the master clock. When the tape was 

started, there was a warning bell and then a bell at 15-second intervals. Each bell was preceded by a three-second warning. Individuals 

reading by the frequency method were instructed to make their readings 

immediately at the bell (i.e., at fixed 15-second intervals). 

Readers utilizing the stopwatch method were instructed to start 

the stopwatch when the plume increased to 20% opacity and stop the 

stopwatch when the plume returned to less than 20% opacity, or at the 

end of the six-minute run if the plume was still above 20%. The stopwatches were silent electronic digital stopwatches able to accumulate 

time to accommodate cyclic plumes. Thus, there was no noise conditioning attributed to the watches, and the readers were not influenced 

by clicking stopwatches nearby. 

Between runs, a period of three to five minutes was provided 

to collect the data sheets and to calibrate the transmissometer. Also, 

this allowed a brief resting period for the participants. 

The readers were instructed to utilize proper sun angle and to 

read the plume cross section in accordance with Method 9 procedures. 

At the beginning of each run, the observers noted whether they were 

26 
P.33 

positioned in accordance with Method 9, checking the sun, background, 

and plume direction. As one additional safeguard, the smoke generator 

operators were instructed to watch the readers and alert anyone using 

an improper point of observation. In all cases, the sun was kept 

within a 140° sector behind the readers, with the plume at a right 

angle to the maximum extent possible. In the morning, the observers 

and the sun were in the positions designated A and 1, respectively, 

as shown on Figure 8. As the sun advanced through positions 2, 3, 

and 4, the observers moved through positions B, C, and D. 

The observers used a background of green trees while reading 

white smoke and blue sky while reading black smoke. The smoke generator 

was positioned to maximize use of the contrasting backgrounds while 

allowing the observers the greatest degree of freedom to maintain 

proper sun and plume angle. Figure 8 illustrates typical observer 

positioning in relationship to the plume. 

During the course of the experiment, the observers were constantly 

aware of the importance of the opacity experiment. Chairs and sun 

umbrellas were provided to make the readers as comfortable as possible 

so concentration could be focused on obtaining good, valid data. The 

readers maintained a professional approach to the project and abstained 

from discussing opacities during any observation period. Care also 

was taken to maintain privacy of each observer's readings as they were 

being taken. 

The meteorological conditions during the test days were excellent 

for plume evaluations except on May 20. Winds generally were light, 

27 
(^_/--• Background 

(trees) O 

N 

Generator 

D 

O O 

o 0 

o 

C 

o o 

o 

o 

B O 

oo 

o 

o 

o o 

\\l/ / i I ; 

Figure 8 

Observer Location 

28 

co 
P.35 

allowing substantial plume rise before folding over. This enabled 

the observers to concentrate on proper sun angle rather than wind 

direction, although wind direction was conscientiously considered. 

A summary of the daily meteorological conditions is provided in 

Table 1. 

Each observer recorded his or her readings on a field data sheet, 

shown in Figure 9. Basic instructions for completing the data sheet 

are included in Appendix C. Note that the form has a coded observer 

number and a code, indicating a valid or invalid run (i.e., proper 

sun angle), used to identify any observer biasing and to eliminate 

runs taken under improper conditions. The form provides spaces to 

identify test type and run number for the 15-second interval readings, 

as well as the accumulated time above 20% opacity. 

In'addition to the thorough observer orientation, a diligent 

effort was made to ensure that the smoke generator and recorder were 

accurate. This was done by using equipment meeting Method 9 specifications and by calibrating this equipment frequently. Zero and span 

checks of the transmissometer were performed on the unit after each 

run. All generator operating personnel had considerable training 

experience prior to this study, which proved invaluable in producing 

accurate and valid data. Photographs 1-10 are presented to provide 

additional insight into the conduct of the experiment. 

E. Field Data 

A total of 1172 six-minute data sets were obtained during the 

experiment (approximately 100 sets by each of the twelve observers). 

29 
TABLE 1 

Meteorological Conditions 

Date 

5/20 

5/20 

5/20 

5/21 

5/21 

5/21 

5/21 

5/22 

5/22 

5/22 

5/22 

5/23 

Time 

9:00 am 

10:15 am 

1:15 pm 

9:30 am 

11:15 am 

1 :45 pm 

3:30 pm 

8:45 am 

11:45 am 

1:00 pm 

3:00 pm 

8:45 am 

Sun1 

NA 

NA 

NA 

1 

2 

3 

4 

1 

2 

3 

2-3 

NA 

Temp 

wet 

bulb 

67 

68 

68 

63 

66 

67 

67 

65 

69 

70 

70 

71 

Temp 

dry 

bulk 

76 

74 

76 

71 

76 

78 

79 

73 

84 

87 

92 

7 4 

% 

Rela. 

hum. 

62 

74 

66 

68 

59 

59 

53 

65 

46 

42 

32 

86 

Obser 

post.* 

3 

3 

3 

A 

B 

B 

C-D 

A 

B 

C 

C-D 

A 

Wind 

vel . 

2-5 

2-4 

0-4 

3-7 

calm 

calm 

calm 

2-8 

2-7 

3-7 

3-7 

2-10 

Wind 

dir. 

WSW 

SW 

WSW 

S 

-

-

-

SE var. 

SW var. 

E 

E 

SE 

Cloud 

cover 

100 

100 

100 

0 

0 

30 

20 

-

0 

25 

-

100 

Comments 

)lery ligh t sprinkles 

Very 1ight sprinkles 

Light rain* 

Clear and sunny 

Clear and sunny 

Clear and sunny 

Clear and sunny 

Blue/white sky high clouds 

Blue sky 

Blue sky 

High overcast grey sky 

Overcast 

* Periods of heavy rain during runs 026,047,048,058, and 059. Light showers during runs 056,057,060, 

061 ,062,063, and 064. 

1

 Positions as noted in Figure 8. 

30 
P.37 

A 

Figure 9 

METHOD 9 FIELD TEST DATA FORM A 

TEST 

TYPE 

1 

TEST NUMBER 

2 3 4 

PARTICIPANT 

5 6 7 8 

49 50 

TIME 

57 58 59 

1 

READ 

9 

17 

INGS 

1 

10 

5 

18 

9 

25 26 

1 

33 

3 

34 

2 3 4 

11 

19 

2 

12 

6 

20 

10 

27 28 

1 

35 

4 

36 

_"• 

1 

41 

7 

42 

21 

1 

43 

8 

44 

22 

51 52 

HEST 

60 

13 14 

7 

21 22 

11 

29 30 

15 

37 38 

19 

45 46 

23 

53 54 

READING 

( 51 

15 16 

8 

23 24 

12 

31 32 

16 

39 40 

20 

47 48 

24 

5f> 36 

SIGNATURE 

31 
P.38 

m 

^ j 

A-____li 

P1|U.- - 7s 

. 

£^psl 

ig^riMiiiiljaijii 

Photograph 2 

Observer recertifying prior 

to starting the field study. 

Photograph 1 

Observer recertifying prior 

to starting the fiel d study. 
P.39 

Photographs 3 & 4 

Equipment calibration 

and adjustment to 

assure precision. 
P.40 

Photograph 5 

Equipment calibration 

and adjustment to 

assure precision. 

• 

Photograph 6 

View of readers 

observing the 

plume during 

the experiment. 

34 
P.41 

Photograph 7 

Observers viewing a 

white plume against 

a green tree background. 

Photograph 8 

Observers viewing a black 

plume against a blue sky 

background. 

35 
TF 

P.42 

Photograph 9 

Data point s being 

recorded. 

Photograph 10 

Field data sheets going 

through initia l review 

and being compiled. 
P.43 

A breakdown by plume color, configuration, and reading method is presented in Table 2. 

Tables 1 - 4 of Appendix D present a tabulation of the data by 

run and observer for each six-minute period. 

F. Results 

A complete statistical analysis of all test results was conducted 

on these data and is reported in a separate document prepared by 

(2) 

Research Triangle Institute. Nonetheless, some of the summary statistics are presented in this section in order to provide a basic idea 

of the results. The results presented here are generally restricted to 

frequency distributions for the measured differences in observed and 

actual opacity (percent), as well as the measured differences in 

observed and actual time of excessive emissions (seconds). 

Tables 3 and 4 summarize the average opacity values for observed 

(all observers) and actual (transmissometer) data for all test runs for 

black and white smoke, respectively. Figures 10 and 11 illustrate the 

regression of the observed values on the actual opacity values for the 

same data. The standard deviations of the observed Method 9 data for 

each run are tabulated in Tables 3 and 4 and are plotted against the 

actual mean opacities in Figures 12 and 13. Both color groups show a 

positive correlation between standard deviation and mean opacity. 

Figures 14 and 15 illustrate the distribution of errors for all 

observers in estimating the average percent opacity for a six-minute 

period as per Method 9 for black and white smoke, respectively. 

37 
P.44 

TABLE 2 

Data Sets 

by 

Plume Color, Configuration, and Reading Method 

Black Plume White Plume 

Stopwatch Method 

Rapid Rise 

Intermediate Rise 

Total 

120 

111 

231 

179 

168 

347 

Frequency Distribution Method 

Rapid Rise 

Intermediate Rise 

Total 

TOTAL 

120 

121 

241 

472 

180 

173 

353 

700 

38 
Figures 16 and 17 illustrate the distribution of errors for all 

observers in estimating excessive emissions by the frequency distribution method for black and white smoke, respectively. 

Similarily, Figures 18 and 19 illustrate the frequency distribution of errors for all observers in estimating the time of excessive 

emissions by the stopwatch method for black and white smoke, respectively. 

39 
P.46 

TABLE 3 

Method 9 

and 

• - Transmissometer Opacity Averages 

RUN 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

Black Smoke 

Mean Opacity, percent 

Observer 

11.8 

50.8 

41.7 

41.7 

25.9 

27.2 

13.4 

36.6 

5.4' 

20.8 

10.4 

15.7 

9.4 

26.3 

16.0 

33.3 

29.9 

11.3 

14.6 

20.7 

26.0 

33.0 

9.7 

18.6 

14.5 

18.0 

11.3 

9.9 

4.4 

Transmissometer 

11.3 

51.7 

44.8 

44.4 

29.1 

29.4 

16.7 

37.1 

7.3 

24.2 

10.1 

16.4 

6.4 

33.0 

16.0 

36.8 

29.8 

10.0 

14.1 

24.0 

29.1 

39.1 

10.2 

20.9 

15.8 

20.5 

13.0 

11.9 

6.0 

Standard Deviation 

Method 9 

1.37 

7.80 

9.00 

* 9.25 

7.32 

4.22 

1.40 

8.00 

1.20 

4.25 

2.20 

4.00 

2.51 

6.00 

4.00 

5.00 

3.31 

3.00 

3.34 

3.00 

2.31 

6.30 

2.00 

3.60 

1.40 

2.24 

1.90 

1.80 

1.74 

Runs 1-20, Fast rise plume; Runs 20-40, Intermediate rise pl 

40 

ume 
P.47 

RUN 

31 

32 

33 

34 

35 

36 

37 

38 

39 

40 

TABLE 3 (Cont. 

Mean Opacity, percent 

Observer 

28.6 

7.3 

26.4 

5.8 

21.4 

10.2 

7.1 

16.4 

4.7 

8.8 

Transmissometer 

30.7 

9.2 

26.7 

5.7 

21.6 

10.0 

10.8 

15.1 

6.3 

9.1 

Standard Deviation 

Method 9 

5.43 

1.55 

5.10 

0.78 

3.37 

1.09 

1.60 

2.72 

1.25 

1.66 

Runs 20-40,Intermediate rise Dlume 

41 
P.48 

TABLE 4 

Method 9 

and 

Transmissometer Opacity Averages 

White Smoke 

RUN 

41 

43 

44 

45 

46 

47 

48 

49 

50 

51 

52 

53 

54 

55 

56 

57 

58 

59 

60 

61 

62 

63 

64 

66 

69 

70 

71 

72 

Mean Opaci 

Observer 

23.2 

23.6 

19.6 

42.2 

6.7 

31.3 

41.0 

13.1 

6.8 

39.8 

26.3 

13.6 

24.1 

29.1 

41.1 

30.5 

37.8 

4.4 

23.0 

7.0 

13.9 

60.4 

35.0 

18.8 

20.9 

20.8 

10.7 

20.6 

ty, percent 

Transmissometer 

20.2 

22.5 

21.8 

41.5 

6.8 

25.8 

33.9 

11.9 

6.7 

34.5 

22.6 

11.2 

17.4 

27.0 

36.5 

23.0 

33.8 

5.6 

16.5 

6.3 

9.7 

50.9 

26.0 

26.9 

28.4 

26.8 

2.3 

25.0 

Standard Deviation 

Method 9 

3.42 

6.18 

4.07 

11.84 

0.92 

4.88 

8.83 

2.94 

1.59 

7.73 

2.83 

1.70 

3.31 

6.04 

6.52 

5.04 

6.22 

0.95 

3.24 

0.77 

2.63 

9.00 

3.67 

5.76 

8.53 

8.94 

2.46 

3.56 

Runs 41-70, Fast rise plume; Runs 71-100, Intermediate rise plume 

42 
TABLE 4 (Cont.) 

RUN 

73 

74 

76 

77 

78 

79 

80 

81 

82 

83 

84 

85 

86 

87 

88 

89 

90 

91 

92 

93 

94 

95 

96 

98 

99 

100 

142 

165 

175 

Mean Opacity, percent 

Observer 

20.1 

8.6 

23.8 

8.8 

14.8 

11.5 

23.9 

16.5 

5.8 

12.5 

8.1 

16.4 

21.2 

14.8 

31.2 

18.9 

16.3 

6.5 

12.4 

15.4 

30.2 

7.3 

16.4 

18.8 

22.3 

7.4 

38.6 

21.6 

24.0 

Transmissometer 

24.0 

8.6 

22.8 

9.5 

13.3 

11.9 

26.1 

17.5 

5.3 

10.0 

5.4 

13.4 

18.0 

10.2 

23.7 

14.2 

12.2 

7.5 

11.8 

15.9 

31.2 

6.3 

13.8 

21.7 

23.3 

9.3 

32.4 

29.5 

22.1 

Standard Deviation 

Method 9 

3.33 

2.10 

1.34 

0.82 

2 ..38 

1.86 

6.71 

3.43 

0.50 

3.13 

1.24 

4.15 

3.52 

3.61 

6.87 

2.58 

3.35 

0.36 

2.30 

1.61 

5.42 

2.01 

2.36 

3.23 

3.78 

1.96 

4.99 

6.84 

0.29 

Runs 71-100, and 175, Intermediate rise plume; 

Runs 142 and 165, Fast rise plume 

43 
P.50 

Opacit

y (%) Observe

d Mean 

50 

40 

30 

20 

10 

0 

Figure 10 

Observed Mean Opacity 

Versus 

Actual Mean Opacity 

Black Smoke 

® 

® 

® 

® s> ® 

• ®® 

®* 

®$ 

® 

® ® 

® 

is 

® ®* ® 

®® 

®®® 

®

9 

10 20 30 

Actual Mean Opacity {%) 

44 

®® 

® 

• ® 

40 

i 

4 

® 

50 
P.51 

60 J 

Figure 11 

Observed Mean Opacity 

Versus 

Actual Mean Opacity 

White Smoke 

® 

50-1 

40j 

<*« 

® 

® 

® ® 

® 

o 

ro 

Q. 

O 

c_ 

rO 

OJ 

-o 

> 

S _ 

cu 

in 

J_) 

o 

30] 

20| 

® 

® 

® 

® 

s _ ® 

® 

® 

® 

,® ® 

® 

® ® ® 

® 

® ® 

® 

®® 

lol ® 

® A ® 

® 

® 

® 

10 20 30 

Actual Mean Opacity (%) 

40 50 

45 
P.52 

Figure 12 

Standard Deviation 

of 

Observed Mean Opacity 

Versus 

Actual Mean Opacity 

Black Smoke 

12 

10 

® 

® 

c 

o 

•r-

+ J 

fO 

•r— 

> 

O 

T3 

s_ 

03 

c 

(O 

4-> 

® 

® 

® 

® 

® 

®® 

® 

® 

® 

_®< 

10 20 30 

Actual Mean Opacity {%) 

40 50 

46 
10 

8 

P.53 

Figure 13 

Standard Deviaiton 

of 

Observed Mean Opacity 

Versus 

Actual Mean Opacity 

White Smoke 

12 ® 

® 

® ® 

® 

ro 

> 

o 

-a 

sra 

-a 

c 

ro 

• ® # 

® 

® 

® ® 

® 

® 

® 

® 

® 

® ®a 

® 

Cf 

® i 

® 

® * ® 

® 

® 

10 

® 

® 

20 30 

Actual Mean Opacity {%) 

40 50 

47 
P.54 

120 

Figure 14 

Frequency of Differences 

Between 

Actual and Observed Mean Opacities 

Black Smoke 

100 

<L> 

O 

C 

CU 

s -

s _ 

-3 

o 

o 

o 

>> 

o 

_: 

QJ 

3 

a-

<u 

80 

60 

40 

20 

1 

•12 -8- 4 0 4 8 

Differences of Mean Opacities (%) (Observed - Actual) 

12 

48 
Figure 15 

Frequency of Differences 

Between 

Actual and Observed Mean Opacities 

White Smoke 

140 

120 

QJ 

U 

c 

OJ 

-. 

1 -

u 

OJ 

o 

> • > 

u 

c 

QJ 

3 

acu 

s_ 

100 

80 

60 

40 

20 

•15 -10 -5 0 5 10 

Differences of Mean Opacities (%) (Observed - Actual) 

15 

49 
160 

Figure 16 

Frequency Distribution of the Differences 

of 

Actual and Observed Times of Excessive Emissions (Opacity >_20%) 

(Frequency Method) 

Black Smoke 

OJ 

u 

c 

OJ 

_-

-3 

u 

o 

o 

CJ 

c 

QJ 

_3 

cr 

QJ 

s _ 

120 

80 

40 

•360 _270 -180 

Difference in Ti 

-90 0 90 180 270' 360 

me of Excessive Emissions (Observed - Actual), Seconds 

50 
200 

Figure 17 

Frequency Distribution of the Differences 

of 

Actual and Observed Times of Excessive Emissions (Opacity >20%) 

(Frequency Method) 

White Smoke 

cu 

o 

c 

QJ 

i~ 

l-

_3 

O 

O 

o 

OJ 

c 

OJ 

cr 

0) 

u 

160 

120 

80 

40 

.LL 

360 270 180 90 0 -90 -180 -270 -360 

Difference in Time of Excessive Emissions (Observed - Actual), Seconds 

51 
100 

Figure 18 

Frequency of Distribution of the Differences 

of 

Actual and Observed Times of Excessive Emission (Opacity >20%) 

(Stopwatch Method) 

Black Smoke 

80 

QJ 

CJ 

QJ 

t -

S-

- 3 

O 

O 

O 

4 -

O 

60 

u 

c 

OJ 

3 

cr 

QJ 

J -

40 

20 

-31-40 -21-30 -10-20 -1-10 0 1-10 11-20 21-30 

Difference in Time of Excessive Emissions (Observed - Actual), Seconds 

31-40 

52 
QJ 

O 

C 

QJ 

t -

S3 

U 

o 

o 

>> 

o 

c 

0) 

3 

cr 

QJ 

j -

160 { 

120 

80 

40 

Figure 19 

Frequency Distribution of the Differences 

of 

Actual and Observed Times of Excessive Emission (Opacity j>20%) 

(Stopwatch Method) 

White Smoke 

-41-50 -21-30 -1-10 1-10 21-30 41-50 61-70 

-31-40 -11-20 0 11-20 31-40 51-60 71-80 

Difference in Time of Excessive Emissions (Observed - Actual), Seconds 

53 
P.60 

REFERENCES 

1. Donner-Hanna Coke Corporation v. Costle, Civ No. 77-232, D.C. 

W.D., N.Y. 

2. Statistical Analysis of Three Smoke Generator Field Tests; Research 

Triangle Institute, August 1981 (Draft). 

3. Evaluation of Opacity Frequency Method on Continuous Plumes; Del 

Green Associates, Inc., December 1981 (Draft). 

4. Evaluation of Opacity Frequency Method on Slowly Changing Plumes; 

Del Green Associates, Inc., December 1981 (Draft). 

5. Telephone Survey of State and Local Air Control Agencies on Opacity 

Regulation and Enforcement Procedures; Del Green Associates, Inc., 

October 1980 (Draft). 

54 
P.61 

APPENDIX A 

Federal Register, Vol. 39, No. 219 

Reference Method 9 
P.62 

Title 4 0—Protection of the Environment 

CHAPTER 1—ENVIRONMENTAL PROTECTION AGENCY 

Subchapter C—Air Programs 

(FRL 391-6) 

PART 60—STANDARDS OF PERFORMANCE FOR NEW STATIONARY 

SOURCES 

Opacity Provisions 

"On June 29, 1973, the United States Court of Appeals 

for the District of Columbia in 'Portland Cement Association 

v. Ruckelshaus,' 486 F.2d 375 (1973) remanded to EPA the 

standard of performance for Portland cement plants (40 

CFR 60.60 et seq.) promulgated by EPA under section 111 of 

the Clean Air Act. In the remand, the Court directed EPA 

to reconsider among other things the use of the opacity 

standards. EPA has prepared a response to the remand. 

Copies of this response are available from the Emission 

Standards and Engineering Division, Environmental Protection 

Agency, Research Triangle Park, N. C. 27711, Attn: Mr. Don 

R. Goodwin. In developing.the response, EPA collected and 

evaluated a substantial amount of information which is 

summarized and referenced in the response. Copies of this 

information are available for inspection during normal office 

hours at EPA's Office of Public Affairs, 401 M Street SW. , 

Washington, D. C. EPA determined that the Portland cement 

plant standards generally did not require revision but did 

not find that certain revisions are appropriate to the 

opacity provisions of the standards. The provisions 

promulgated herein include a revision of §60.11, Compliance 

with Standards and Maintenance Requirements, a revision to the 

opacity standard for Portland cement plants, and revisions 

to Reference Method 9. The bases for the revisions are 

discussed in detail in the Agency's response to the remand. 

They are summarized below. 

The revisions to §60.11 include the modification of 

paragraph (b) and the addition of paragraph (e). Paragraph 

(b) has been revised to indicate that while Reference Method 

9 remains the primary and accepted means for determining 

compliance with opacity standards in this part, EPA will 

accept as probative evidence in certain situations and 

under certain conditions the results of continuous monitoring 

by transmissometer to determine whether a violation has in 

fact occurred. The revision makes clear that even in such, 

situations the results of opacity readings by Method 9 remain 

presumptively valid and correct. 
The provisions in paragraph (e) provide a mechanism 

for an owner or operator to petition the Administrator 

to establish an opacity standard for an affected facility 

where such facility meets all applicable standards for 

which a performance test is conducted under §60.8 but fails 

to meet an applicable opacity standard. This provision 

is intended primarily to apply to cases where a source 

installs a very large diameter stack which causes the 

opacity of the emissions to be greater than if a stack of 

the diameter ordinarily used in the industry were installed. 

Although this situation is considered to be very unlikely 

to occur, this provisions will accommodate such a situation. 

The provision could also apply to other situations where 

for any reason an affected facility could fail to meet 

opacity standards while meeting mass emission standards, 

although no such situations are expected to occur. 

A revision to the opacity standard for Portland 

cement plants is promulgated herein. The revision changes 

the opacity limit for kilns from 10 percent to 20 percent. 

This revision is based on EPA's policy on opacity standards 

and the new emission data from Portland cement plants 

evaluated by EPA during its reconsideration. The preamble 

to the standards of performance which were promulgated on 

March 8, 1974 (39 FR 9308).sets forth EPA's policy on opacity 

standards: (1) Opacity limits are independent enforceable 

standards; (2) where opacity and mass/concentration standards 

are applicable to the same source, the mass/concentration 

standards are established at a level which will result in 

the design, installation, and operation of the best adequately 

demonstrated system of emission reduction (taking costs into 

account); and (3) the opacity standards are established at a 

level which will require proper operation and maintenance of 

such control systems. The new data indicate that increasing 

the opacity limits for kilns from 10 percent to 20 percent 

is justified, because such.a standard will still require the 

design, installation, and operation of the best adequately 

demonstrated system of emission reduction (taking costs into 

account) while eliminating or minimizing the situations where 

it will be necessary to promulgate a new opacity standard 

under §60.11(e). 

In evaluating the accuracy of results from qualified 

observers following the procedures of Reference Method 9, EPA 

determined that (some revisions to Reference Method 9 are 

consistently able to evaluation showed that, sic) observers 

trained and certified in accordance with the procedures 

prescribed under Reference Method 9 are consistently able to 

read opacity with errors not exceeding +7.5 percent based 

upon single sets of the average of 24 readings. The revisions 

to Reference Method 9 include the following: 
P.64 

1. An introductory section is added. This includes 

a discussion of the concept of visible emission reading 

and describes the effect of variable viewing conditions. 

Information is also presented concerning the accuracy of 

the method noting that the accuracy of the method must be 

taken into account when determining possible violations 

of applicable opacity standards. 

2. Provisions are added which specify that the 

determination of opacity requires averaging 2 4 readings 

taken at 15-second intervals. The purpose for taking 24 

readings is both to extend the averaging time over which 

the observations are made, and to take sufficient readings 

to insure acceptable accuracy. 

3. More specific criteria concerning observer position 

with respect to the sun are added. Specifically, the sun 

must be within a 140° sector to the observer's back. 

4. Criteria concerning an observer's position with 

respect to the plume are added. Specific guidance is also 

provided for reading emissions from rectangular emission 

points with large length to width ratios, and for reading 

emissions from multiple stacks. In each of these cases, 

emissions are to be read across the shortest path length. 

.5. Provisions are added to make clear that opacity 

of contaminated water or steam plumes is to be read at a 

point where water does not exist in condensed form. Two 

specific instructions are provided: One for the case where 

opacity can be observed prior to the formation of the 

condensed water plume, and one for the case where opacity 

is to be observed after the condensed water plume has 

dissipated. 

6. Specifications are added for the smoke generator 

used for qualification of observers so that State or local 

air pollution control agencies may provide observer qualification training consistent with EPA training. 

In developing this regulation we have taken into 

account the comments received in response to the September 

11, 1974 (39 FR 35852) notice of proposed rulemaking which 

proposed among other things certain minor changes to 

Reference Method 9. This regulation represents the rulemaking with respect to the revisions to Method 9. 

The determination of compliance with applicable opacity 

standards will be based on an average of 24 consecutive 

opacity readings taken at 15 second intervals. This 

approach is a satisfactory means of enforcing opacity standards 

in cases where the violation is a continuing one and time 

exceptions are not part of the applicable opacity standard. 
P.65 

However, the opacity standards for steam electric generators 

in 40 CFR 60.42 and fluid catalytic cracking unit catalyst 

regenerators in 40 CFR 60.102 and numerous opacity standards 

in State implementation plans specify various time exceptions. 

Many State and local air pollution control agencies use a 

different approach in enforcing opacity standards than the 

six-minute average period specified in this revision to 

Method 9. EPA recognizes that certain types of opacity 

violations that are intermittent in nature require a different 

approach in applying the opacity standards than this revision 

to Method 9. It is EPA's intent to propose an additional 

revision to Method 9 specifying an alternative method to 

enforce opacity standards. It is our intent that this method 

specify a minimum number of readings that must be taken, such 

as a minimum of ten readings above the standard in any one 

hour period prior to citing a violation. EPA is in the 

process of analyzing available data and determining the error 

involved in reading opacity in this manner and will propose 

this revision to Method 9 as soon as this analysis is completed. 

The Agency solicits comments and recommendations on the need 

for this additional revision to Method 9 and would welcome 

any suggestions particularly from air pollution control agencies 

on how we might make Method 9 more responsive to the needs of 

these agencies. 

These actions are effective on November 12, 1974. The 

Agency finds good cause exists for not publishing these 

actions as a notice of proposed rulemaking and for making 

them effective immediately upon publication for the following 

reasons: 

(1) Only minor amendments are being made to the opacity 

standards which were remanded. 

(2) The U. S. Court of Appeals for the District of 

Columbia instructed EPA to complete the remand proceeding 

with respect to the Portland cement plant standards by 

November 5, 1974. 

(3) Because opacity standards are the subject of other 

litigation, it is necessary to reach a final determination 

with respect to the basic issues involving opacity at this 

time in order to properly respond to this issue with respect 

to such other litigation. 

These regulations are issued under the authority of 

sections 111 and 114 of the Clean Air Act, as amended 

(42 U.S.C. 1857C-6 and 9) . 

Dated: November 1, 1974. 

John Quarles 

Acting Administrator." 
P.66 

METHOD 9 -- VISUAL DETERMINATION OF THE OPACITY OF 

EMISSIONS FROM STATIONARY SOURCES 

The current Method 9, published in the Federal Register, 

Volume 39, No. 219 on November 12, 1974 is reproduced below: 

"Many stationary sources discharge visible emissions into 

the atmosphere; these emissions are usually in the shape of a 

plume. This method involves the determination of plume opacity 

by qualified observers. The method includes procedures for the 

training and certification of observers, and procedures to be 

used in the field for determination of plume opacity. The 

appearance of a plume as viewed by an observer depends upon 

a number of variables, some of which may be controllable and 

some of which may not be controllable in the field. Variables 

which can be controlled to an extent to which they no longer 

exert a significant influence upon plume appearance include: 

Angle of the observer with respect to the plume; angle of the 

observer with respect to the sun; point of observation of 

attached and detached steam plume; and angle of the observer 

with respect to a plume emitted from a rectangular stack with 

a large length to width ratio. The method includes specific 

criteria applicable to these variables. 

Other variables which may not be controllable in the field 

are luminescence and color contrast between the plume and the 

background against which the plume is viewed. These variables 

exert an influence upon the appearance of a plume as viewed by 

an observer, and can affect the ability of the observer to 

accurately assign opacity values to the observed plume. Studies 

of the theory of plume opacity and field studies have demonstrated 

that a plume is most visible and presents the greatest apparent 

opacity when viewed against a contrasting background. It follows 

from this, and is confirmed by field trials, that the opacity of 

a plume, viewed under conditions where a contrasting background 

is present can be assigned with the greatest degree of accuracy. 

However, the potential for a positive error is also the greatest 

when a plume is viewed under such contrasting conditions. Under 

conditions presenting a less contrasting background, the 

apparent opacity of a plume is less and approaches zero as the 

color and luminescence contrast decrease toward zero. As a 

result, significant negative bias and negative errors can be 

made when a plume is viewed under less contrasting conditions. 

A negative bias decreases rather than increases the possibility 

that a plant operator will be cited for a violation of opacity 

standards due to observer error. 

Studies have been undertaken to determine the magnitude of 

positive errors which can be made by qualified observers while 

reading plumes under contrasting conditions and using the 

procedures set forth in this method. The results of these 

studies (field trails) which involve a total of 769 sets of 

25 readings each are as follows: 
P.67 

1) For black plumes (133 sets at a smoke generator), 

. 100 percent of the sets were r.ead with a positive 

error-'* of less than 7.5 percent opacity; 99 percent 

were read with a positive error of less than 5 

percent opacity. 

2) For white plumes (170 sets at a smoke generator, 

168 sets at a coal-fired power plant, 2 98 sets at 

a sulfuric acid plant), 99 percent of the sets were 

read with a positive error of less than 7.5 percent 

opacity; 95 percent were read with a positive error 

of less than 5 percent opacity. 

The positive observational error associated with an 

average of 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. PRINCIPLE AND APPLICABILITY 

1.1 PRINCIPLE 

The opacity of emissions from stationary sources is 

determined visually by a qualified observer. 

1.2 APPLICABILITY 

This method is applicable for .the determination of the 

opacity of emissions from stationary sources pursuant to 

§ 60.11 (b) and for qualifying observers for visually determining opacity of emissions. 

2. PROCEDURES 

The observer qualified in accordance with paragraph 3 of 

this method shall use the following procedures for visually 

determining the opacity of emissions. 

2.1 POSITION 

The qualified observer shall stand at a distance sufficient 

to provide a clear view of the emissions with the sun oriented 

in the 140° sector to his back. Consistent with maintaining the 

above requirement, the observer shall, as much as possible, make 

-'-For a set, positive error = average opacity determined by 

observers' 25 observations - average opacity determined from 

transmissometer's 25 recordings. 
P.68 

his observations from a position such that his line of vision is 

approximately perpendicular to the plume direction, -and when 

observing opacity of emissions from rectangular outlets (e.g. roof 

monitors, open baghouses, noncircular stacks), approximately perpendicular to the longer axis of the outlet. The 

observer's line of sight should not include more than one 

plume at a time when multiple stacks are involved, and 

in any case the observer should make his observations with 

his line of sight perpendicular to the longer axis of 

such a set of multiple stacks (e.g. stub stacks on baghouses) . 

2.2 FIELD RECORDS 

The observer shall record the name of the plant, 

emission location, type facility, observer's name and 

affiliation, and the date on a field data sheet (Figure 

9-1). The time, estimated distance to the emission 

location, approximate wind direction, estimated wind 

speed, description of the sky condition (presence and 

color of clouds), and plume background are recorded on 

a field data sheet at the time opacity readings are 

initiated and completed. 

2.3 -OBSERVATIONS 

Opacity observations shall be made at the point of 

greatest opacity in that portion of the plume where 

condensed water vapor is not present. The observer shall 

not look continuously at the plume, but instead shall 

observe the plume momentarily at 15-second intervals. 

2.3.1 ATTACHED STEAM PLUMES 

When condensed water vapor is present within the plume 

as it emerges from the emission outlet, opacity observations 

shall be made beyond the point in the plume at which 

condensed water vapor is no longer visible. The observer 

shall record the approximate distance from the emission 

outlet to the point in the plume at which the observations 

are made. 

2.3.2 DETACHED STEAM PLUME 

When water vapor in the plume condenses and becomes 

visible at a distinct distance from the emission outlet, 
P.69 

the opacity of emissions should be evaluated at the 

emission outlet prior to the condensation of water vapor 

and the formation of the steam plume. 

2.4 RECORDING OBSERVATIONS 

Opacity observations shall be recorded to the nearest 

5 percent at 15-second intervals on an observational record 

sheet. (See Figure 9-2 for an example). A minimum of 24 

observations shall be recorded. Each momentary observation 

recorded shall be deemed to represent the average opacity of 

emissions for a 15-second period. 

2.5 DATA REDUCTION 

Opacity shall be determined as an average of 24 consecutive observations recorded at 15-second intervals. Divide the 

observations recorded on the record sheet into sets of 2 4 

consecutive observations. A set is composed of any 2 4 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 requiring more than 2 4 

observations, calculate the average for all observations made 

during the specified time period. Record the average opacity 

on a record sheet. (See Figure 9-1 for an example). 

3. QUALIFICATIONS AND TESTING 

3.1 CERTIFICATION REQUIREMENTS 

To receive certification as a qualified observer, a candidate must be tested and demonstrate the ability to assign 

opacity readings in 5 percent increments to 25 different black 

plumes and 25 different white plumes, with an error not to 

exceed 15 percent opacity on any one reading and an average 

error not to exceed 7.5 percent opacity in each category. 

Candidates shall be tested according to the procedures described 

in paragraph 3.2. Smoke generators used pursuant to paragraph 

3.2 shall be equipped with a smoke meter which meets the 

requirements of paragraph 3.3. 

The certification shall be valid for a period of 6 months, 

at which time the qualification procedure must be repeated by 

any observer in order to retain certification. 
P.70 

3.2 CERTIFICATION PROCEDURE 

The certification test consists of showing the candidate 

a complete run of 50 plumes - 25 black plumes and 25 white 

plumes - generated by a smoke generator. Plumes within each 

set of 25 black and 25 white runs shall be presented in random 

order. The candidate assigns an opacity value to each plume 

and records his observation on a suitable form. At the 

completion of each run of 50 readings, the score of the 

candidate is determined. If a candidate fails to qualify, 

the complete run of 5 0 readings must be repeated in any 

retest. The smoke test may be administered as part of a 

smoke school or training program, and may be preceded by 

training or familiarization runs of the smoke generator 

during which candidates are shown black and white plumes of 

known opacity. 

3.3 SMOKE GENERATOR SPECIFICATIONS 

Any smoke generator used for the purpose of paragraph 

3.2 shall be equipped with a smoke meter installed to 

measure opacity across the diameter of the smoke generator 

stack. The smoke meter output shall display in-stack 

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 paragraph 3.3.1 prior 

to the conduct of each smoke reading test. At the 

completion of each test, the zero and span drift shall be 

checked and if the drift exceeds ± 1 percent, opacity, the 

condition shall be corrected prior to conducting any subsequent test runs. The smoke meter shall be demonstrated 

at the time of installation, to meet the specifications 

listed in Table 9-1. This demonstration shall be repeated 

following any subsequent repair or replacement of the 

photocell or associated electronic circuitry including the 

chart recorder or output meter, or every 6 months, whichever 

occurs first. 

TABLE 9-1 — SMOKE METER DESIGN AND 

PERFORMANCE SPECIFICATIONS 

Parameter Specification 

a. Light source Incandescent lamp operated at 

nominal rated voltage. 

b. Spectral response of Photopic (daylight spectral 

photocell response of the human eye -

reference 4.3). 
P.71 

c. Angle of view 

d. Angle of projection 

e. Calibration errorf. Zero and span drift 

g. Response time 

15° maximum total angle. 

15° maximum total angle. 

± 3% opacity, maximum 

± 1% opacity, 30 minutes 

< 5 seconds. 

3.3.1 CALIBRATION 

The smoke meter is calibrated after allowing a minimum of 

30 minutes warmup by alternately producing simulated opacity 

of 0 percent and 100 percent. When stable response at 0 percent 

or 100 percent is noted, the smoke meter is adjusted to produce 

an output of 0 percent or 100 percent as appropriate. This 

calibration shall be repeated until stable 0 percent and 100 

percent 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 are to be evaluated 

as follows: 

3.3.2.1 LIGHT SOURCE 

Verify from manufacturer's data and from voltage measurements 

made at the lamp, as installed, that the lamp is operated within 

± 5 percent of the nominal rated voltage. 

3.3.2.2 SPECTRAL RESPONSE OF PHOTOCELL 

Verify from manufacturer's data that 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 in (b) of Table 9-1. 

3.3.2.3 ANGLE OF VIEW 

Check construction geometry to ensure that the total angle 

of view of the smoke plume, as seen by the photocell, does not 
P.72 

exceed 15°. The total angle of view may be calculated from: 

5 = 2 -tan--1 d/2L, where $ = total angle of view; d = the 

sum of the photocell diameter + the diameter of the limiting 

aperture; and L = the distance from the photocell to the 

limiting aperture. The limiting aperture is the point in the 

path between the photocell and the smoke plume where the angle 

of view is most restricted. In smoke generator smoke meters 

this is normally an orifice plate. 

3.3.2.4 ANGLE OF PROJECTION 

Check construction geometry to ensure that the total angle 

of projection of the lamp on the smoke plume does not exceed 

15°. The total angle of projection may be calculated from: 

Q = 2 tan--*- d/2L, where Q = total angle of projection; 

d = the sum of the length of the lamp filament + the diameter 

of the limiting aperture; and L = the distance ^from the lamp 

to the limiting aperture. 

3.3.2.5 CALIBRATION ERROR 

Using neutral-density filters of known opacity, check 

the error between the actual response and the theoretical 

linear response of the smoke meter. This check is 

accomplished by first calibrating the smoke meter according to 3.3.1 and then inserting a series of three neutraldensity filters of nominal opacity of 20, 50, and 75 

percent in the smoke meter pathlength. Filters calibrated 

within ±2 percent shall be used. Care should be taken 

when inserting the filters to prevent stray light from 

affecting the meter. Make a total of five nonconsecutive 

readings for each filter. The maximum .error on any one 

reading shall be 3 percent opacity. 

3.3.2.6 ZERO AND SPAN DRIFT 

Determine the zero and span drift by calibrating and 

operating the smoke generator in a normal manner over a 

1-hour period. The drift is measured by checking the zero 

and span at the end of this period. 

3.3.2.7 RESPONSE TIME 

Determine the response time by producing the series 

of five simulated 0 percent and 100 percent opacity values 

and observing the time required to reach stable response. 
_P_73 

Opacity values of 0 percent and 100 percent may be simulated 

by alternately switching the power to the light source off 

and on while the smoke generator is not operating. 

4. REFERENCES 

4.1 Air Pollution Control District Rules and Regulations, 

Los Angeles County Air Pollution Control District, Regulation 

IV, Prohibitions," Rule 50. 

4.2 Weisburd, Melvin I., Field Operations and Enforcement 

Manual for Air, U.S. Environmental Protection Agency, 

Research Triangle Park, N. C. , APTD-1100, August 1972. 

pp. 4.1-4.36. 

4.3 Condon, E.U., and Odishaw, H., Handbook of Physics, 

McGraw-Hill Co., N.Y., N.Y. 1958, Table 3.1, p. 6-52." 
P.74 

APPENDIX 8 

Smoke Generator Specifications 
P.75 

SPECIFICATIONS 

Smoke Generator 

Model 3000-A 

1979 

GENERAL 

The generator shall be capable of producing constant black and white 

smoke plumes with an opacity range of 0 to 100%. The unit shall be 

mounted on a single or dual axle trailer to facilitate transportation. 

The smoke generator shall include the following major component systems 

1. Single or dual axle trailer 

2. Black smoke generator (toluene combustion chamber) 

3. White smoke generator {diesel fuel vaporizor) 

4. Stack assembly 

5. Transmissometer 

6. Fuel pump system. 

7. Dilution manifold 

8. Main blower assembly 

,9. Automatic benzene ignitor 

10. Operator's console 

11. Accessory and Maintenance Package 

12.. Storage compartment 

The unit shall meet the specifications as outlined in the Federal 

Register Volume Number 39, No. 177 - Dated November 12, 197^T 

SPECIFICATIONS 

A. Single or dual axle trailer 

The trailer shall be constructed to withstand a load capacity of 

•no less than 2,000 pounds. The trailer size shall be 6 ft. wide 

by 14 ft. long. All components of the smoke generator shall be 

mounted on a solid sheet metal bed attached to the trailer frame. 

The bed shall be constructed of 14 gauge cold rolled steel. Turn 

signals shall be included to meet all state and federal regulations 

concerning towed trailers in the 2,000 pound load range. The 

trailer shall be equipped with a 1-7/8 inch coupler and safety 

chains for towing. To ensure adequate trailer road stability, 

14.0" tires shall be used to support the trailer bed. 

8. Black smoke generator (toluene combustion chamber) 

Shall be constructed with double metal walls (15 gauge with a minimum of 2.0 inches of castable insulation between the walls. The 
P.76 

insulation material shall be rated at 2000 F or greater. Internal 

baffling and liner will be included in the combustion chamber to 

ensure proper benzene combustion to produce a plume opacity of 

0 - 100%. Baffling and liner will be constructed of No. 304 stainless steel. 

C. White smoke generator (diesel fuel vaporizor) 

White smoke shall be generated by injecting #2 fuel oil into a 

propane heated chamber. The fuel vaporization chamber will be 

constructed of stainless steel. The vaporization chamber will 

be mounted to the generator mixing chamber. The fuel vaporization 

assembly shall be capable of producing a white smoke plume from 

0 - 100% opacity. 

D. Stack assembly 

The stack shall be 12 inches in diameter with a minimum height 

of 16 feet in the raised position. The stack shall be constructed 

of 14 gauge cold rolled steel. The hydraulic cylinder utilized 

to raise the stack shall have a minimum load capacity of 2,500 

pounds. For travel purposes the stack shall be capable of being 

lowered to a maximum height of 8 feet or lower and the stack shall 

be held in position by a cradle supported from the trailer frame. 

The hydraulic cylinder shall have a minimum stroke of 18.0 inches 

and be at least 2.0 inches in diameter. 

E. Transmissometer 

The transmissometer shall be stack-mounted and will consist of 

a light source and a solid state photodetector. Both the light 

source and the photodetector shall be shock-mounted (spring-loaded) 

to prevent damage while in transit. The transmissometer shall 

be equipped with two positive pressure fans to prevent smoke interference with the light source and photodetector. Calibration of 

the transmissometer will be accomplished by the insertion of neutral 

density filters between the light source and photodetector. The 

neutral density filters will not be furnished by Environmental 

Industries. 

F. Fuel pump system 

Two direct current operated fuel pumps (AC type EP-1 or equivalent) 

shall be provided to supply fuel to the black smoke combustion 

chamber and the white smoke vaporization chamber. Two five gallon 

fuel tanks shall be included to furnish the fuel for the generator. 

Fuel flow shall be adjusted using two needle valves (Whitey No. 

B-IRS-4 or equivalent). . The removable fuel panel will be furnished 

with flexible fuel lines for fuel transfer to the smoke generator 

trailer. 
P.77 

G. Dilution manifold 

The generator shall be equipped with a dilution manifold between 

the black smoke combustion chamber and the main blower. The dilution chamber shall be constructed of 14 gauge cold rolled steel. 

The dilution chamber shall be at least 8.0 inches in diameter. 

H. Main blower assembly 

The unit shall be equipped with a 1430 cfm paddle wheel type blower 

to ensure proper air flow to the main stack. The blower assembly 

shall be located between the dilution chamber and the stack 

assembly. All components of the main blower shall be fabricated 

of 14 gauge cold rolled steel, except the blower blade and the 

motor housing. Power to the main blower shall be supplied by a 

3/4 HP,117 volt AC motor. Maximum RPM of the blower motor shall 

be 1725 RPM. 

I. Automatic toluene igniter 

The toluene combustion chamber shall be equipped with an automatic 

fuel igniter. The igniter shall be propane-operated and shall 

^include a trailer-mounted 20 lb. propane gas bottle. A propane 

regulation valve shall be inserted between the propane tank and 

the igniter head as an added safety factor. 

J. Operator's console 

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

1. Digital printer. 

The digital printer shall be included to accept the transmissometer output. The digital printer shall include all necessary 

input jacks for the transmissometer output and digital printer 

calibration. 

2. Operator's control panel 

The function of the operator's panel shall be to supply control 

voltages to all operating systems on the generator. Control 

switches shall be included to blower, main power, stack fans, 

2 DC fuel pumps, light source, and a 12 volt horn. The panel 

shall also include a variable 10-turn potentiometer for calibration of the transmissometer. Three isolated 12 volt DC 

power supplies shall be mounted behind the control panel to 

supply power to the fuel pumps, horn, and light source. The 

light source DC supply circuit shall also include a constant 

voltage transformer to prevent interference from AC-line voltage 
P.78 

fluctuations. All console electrical circuits shall be 

individually fused to prevent power overlads. A sixteen foot 

cable shall be supplied to interconnect the console and 

generator trailer. Amphenol mil spec connectors or equivalent 

shall be used on the control panel and the interconnect cable. 

The control panel shall not exceed 8.5" H X 19.0" W X 15.0" H. 

The control panel will include three isolated power supplies as 

fo11ows: 

a. Light source power supply 

1. Output voltage: 11.5 - 12.5 VDC 

2. Output current: 1.8 amps 

3. Input voltage range: 108 - 132 volts, or 216 - 264 volts 

4. Input frequency range: 50 - 400 Hz 

5. Regulation-line and load combined: ±0.1% 

6. Temperature coefficient: 0.0003 . 

7. Polarity: May be positive or negative 

8. Short circuit protection: automatic circuit protects the 

power continuously. Automatic return upon removal of short 

circuit. 

9. Operating temperature: 0* C to 55" C 

10. Storage temperature: minus 20* C to plus 85" C 

b. Fuel pump power supply 

1. Output voltage: 12.0 - 14.0 VDC 

2. Output current: 3 amps 

3. Input voltage range: 110 - 120 VAC 

4. Input frequency: 60 Hz 

5. Filtered 

6. Operating temperature: 0* C to 55* C 

c. Horn power supply 

1. Output voltage: 12.0 to 14.0 VAC 

2. Output current: 8.0 amps 

3. Input voltage: 110 to 120 VAC 

4. Input frequency: 60 Hz 

5. Operating temperature: 0' C to 55* C 

3. Fuel control panel 

The fuel control panel shall be console-mounted to facilitate 

remote fuel adjustments to both the white and black smoke 

generators. The panel shall include two DC fuel pumps (AC 

EP-1 or equivalent) and two fuel control valves (Whitey No. 

B-IRS-4 or equivalent). Fuel line connectors shall be accesible 
P.79 

from the console rear and fuel line size shall not exceed 0.250 

inches in diameter. The console, shal 1 be designed to operate 

in any location up to 16 feet from the smoke generator trailer. 

The-entire operator's console shall be housed in a sheet metal 

cabinet. 

K. Storage compartments 

Two trailer-mounted storage compartments, 24" W X 26" L X 28" H, 

shall be furnished for accessory storage. The storage compartment 

covers shall be hinged and equipped with a locking clasp. The 

two compartments shall be fabricated from 14 gauge cold rolled 

steel. 

L. Accessories 

The following accessories shall be furnished with the Smoke 

Generator: 

1. Trailer spare tire 

2. Trailer dolly and leveling jack 

3. Two spare light source bulbs 

4. Parts list and instruction manual 

5. Towing vehicle wiring harness 

6. Folding table for operator's console 

7. Fire extinguisher, 5 lbs. dry chemical type 

8. One set neutral density filters 2 X 2 - Wratten Gelatin -

set includes 0.1 and 1.0 

M. Stipulations 

1. One-year warranty for parts and workmanship 

2. Three-year availability of parts 
P.80 

*•» -i* 'rM ;;-- di aervo - J a -T ft aer 

Single and Dual Pen Models SERIES 280 

^J^^^^^^^One^ r Two Channels 

Floating Input - r 

New Disposable Fiber Pen 

Two and Four Chart Speeds 

Modular — Solid State -•--"" 

Both of the recorders shown here are suitable for a wide variety of O.E.M. and systems applications. Highly versatile, they 

employ a true potentiometric null balance 

system of essentially infinite input impedance at nulL Full 10" calibrated chart !p_rovides optimum recording resolution." 

._i___3 

3 

•'3 

•';*3 

•.•-3 

•-•J 

The Model 2801 is a high-performance, low-

-.-.^e^^^^j^^*^--^-" 7::• _ •i-VV--"-"."-...,"_T'..?1. .";".." " cost, ruggedly-constructed recorder that is 

'^ji^^^^^^^^^^^-f- dA~!j^JJJAJS'^M^JJ^. adaptable to most needs where instrument 

:-••-.-'--•! ---*•-^''^^js^i^^.--^ ^ line" graphic form is're-

'7'. ' 7 quired. Fast and slow chart speeds andsim-' 

- plicity of operation make the Model 2801 

JJJ"useful in almost any area where reliable 

• 4f? curves can speed and enhance results.' 

/®?„:'.':..: • "Izf ^^ ; i '^ :-

: 

The Model 2802 provides, a' two-channel, 

cross-reference recording system, capable 

of plotting accurately. Any single, variable 

input signal, such as temperature, in direct_ 

time relationship to a second input, such as 

pressure. Each channeMs literally an independent 10" recorder offering full spans 

to 1 mv and is capable of handling data from 

any compatible instrument system. ~. 

•__,:,.-.*•-_; Jl . . . 
P.81 

MODELS 2B01 and 2302 SERVO GRAPHIC RECORDERS 

SPECIFICATIONS 

The basic Series 280 are highly sensitive instruments designed for standard 19" rack mounting and capable ol 

recording data from transducers, analytical and process 

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extend the versatility .of these dependable recorders. 

Circuitry is all silicon solid state contained on a single 

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FULL SCALE 

SPANS 

INPUT RESISTANCE 

INPUT ISOLATION 

LIMIT OF ERROR 

PEN RESPONSE 

DAMPING 

INKING SYSTEM (Model 

2S01) 

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2802) 

ZERO SET 

POWER 

CHART 

CHART SPEEDS 

ACCESSORIES (Model 

INCLUDED 2801) 

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PRICE 

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SERVICEABILITY 

Fixed Inputs 0 to 1, 2, 5, 10, 20, 

50. 100, 500 mv and 

0 to 1. 2, 5. and 10 volts. 

Multiple Spans 0-1 mv, 0-10 mv, 

1-100 mv, 0-1 V or 

0-10 mv. 0-100 mv, 

0-1 V, 0-10 V. 

Infinite at balance. Signal 

source resistance greater than 

25 K will degrade accuracy. 

100 volts maximum relative to 

chassis. 

40°F —100°F 

105 — 125v line _t'/-% from 

10 in/Sec 

Critically damped — No overshoot 

NEW disposable fiber tip cartridge pen. 

Remote capillary — NEW fiber 

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Pen may be referenced anywhere on chart. 

115/230V—50/60 Hz 15 watts. 

12 VDC also available. Any 

12 Volt lead/acid or NickelCadmium storage battery may 

be used, recommended operating range 11.0 to 140 Volts 

D.C. Current drain 200 to 260 

ma. 

10" calibrated x 100 

Single or Dual speeds. 

In./Hr. — 1, 2. 4, 6, 8, 12. 15, 

24, 30. 

In./Min. — 1, 2, 4, 6, 8, 12. 15. 

Four-speed combinations and 

multiple speed drives also 

available. 

1 Roll chart paper, #414003. 

1 Pen (Blue -412001). 

1 Fiber pen adapter. 

1 Roll chart paper. -414003. 

Vz oz. Bottle Ink 

(Red ="900043). 

Vz oz. Bottle Ink 

(Blue #900044). 

1 Hypo syringe. * 

See Price List 

» LONG LIFE RELIABILITY AND 

Model 280*2 — Each channel is an independent 10 inch 

recorder capable of plotting any variable input with 

respect to the other. 

10 mv Solid State 

Modular Servo Amplifier used in 

Series 280. 

OPTIONS and ACCESSORIES 

WRITING PLATEN =900045 

Model 2801 

PEN, Disposable fiber (Blue =412001) 

(Red =412002) (Black =412003) 

(Green =412004) 

Model 2802 

PEN,' Disposable fiber nib, =412006 

INK, VJ OZ. Bottle (Red =900043} 

•h oz. Bottle (Blue =900044) 

PAPER, 10" X TOO' =414003 

CHART MOTOR, Non-Std. or Extra 

"OEM & quantity discounts available 

— S15.00 

S 6.00" 

5 pack 

.75" 

each 

.65" 

each 

% 4.75* 

roll 

$20.00 

BASIC PRECISION RECORDER WITH OPTIONS TO FIT 

YOUR APPLICATIONS. ._*.._ 

For additional information, please contact your local sales otftce listed below, or the factory direcL 

LABORATORY DATA CONTROL,. INC. 

P.O Box 1023-1. Inierstale Industrial Park 

Riviera Beach. Florida "L3404 

Bulletin 707-* Printed in U.S.A 
P.82 

Appendix C 

Example Field Data Form 

and 

Transmissometer Log 
.P.83 

1 -

2 

BLACK FAST 

BLACK INTER 

WHITE FAST 

WHITE INTER 

3 4 

TEST # 

GENERATOR OP 

1 

2 

3 

4 

ERA 

5 6 

• 1. Run was valid. 

2. Run was not valid 

01 

o? 

03 

04 

OS 

Willie S. Lee 

David Savage 

Larry Sorrell 

•. 

SKY CONDITIONS 

1. Clear 

2. 25% cloud cover 

3. 50% cloud cover 

4. 75% cloud cover 

5. Overcast 

6. Ra i n 

1 24 

9 10 55 56 

Two digi t value for opacity in nearest 5% from 

00-95 use 99 as 100 frequency distribution 

method validation. 

TIME 

TS7 58 59 

57. TOTAL TIME IN MINUTES AT OR ABOVE 20% OPACITY. 

58-59. TIME IN ADDITIONAL SECONDS AT OR ABOVE 20% OPACITY 

60 61 

• 

62 

• 

53 

HIGHEST OPACITY 

PEAK # 

PEAK WIDTH 

C-l 
P.84 

A METHOD 9 STRIP CHART DATA FORM 

TEST 

TYPE TEST NUMBER 

* 

LU i 

i 

A. \J a cl 

2 3 4 

READINGS 

1 

9 10 

••• 

17 13 

9 

25 26 

13 ' 

33 34 

17 

41 42 

21 

49 50 

TIME 

o | 3 3> 

1 1 12 

6 

19 20 

10 

27 28 

14 

35 36 

18 

43 44 

22 

GENERATOR 

OPERATOR VALID RUN SKY 

'0 y 

5 6 

13 14 

7 

21 22 

11 

29 30 

15 

37 38 

19 

"45 tt 

23 

51 52 53 54" 

HIGHEST READING 

57 53 59 

o* 

66 

0 

( 51 

J 

b 

4 

15 16 

8 

| 

23 24 

12 

31 32 

16 

39 40 

20 

47 48 

24 

55 56 

62 63 

C-2. 
P.85 

Transmissometer Log 
c

C 

o 

< 

<1 x 

0 

M

0 

3 

I 

5' 3 

^_ x vi 

<0 <Q 

i  3  

4 o 

•

s 

^ 

N 

^

^ 

0 

§ 

5 -51 

\ ^ >^. ^ 

^ 

• ^ 1 

s s 

u 

u 

• o 

^ ^ V

^ 

o 

•sr 

OJ 

0 

N 

•0 

CJ OJ 

0 

Oi C\i w 

j I 

M w rt w \J 

^ * 

c_

3 

< 

< 

p 

j 

J) 

cd 

C

< 

O 

C

< 

d 

OH 

' C^ vrf c ^ 

CM 

1 v-- m m 

en cn cn 

0 0 

3 

H 

O •0 

Q 

ro m 

t n vO 

4 * * 

N *"_ 

rr 

0 

tr 

vO VO IT» CN 

• * 

^ en en en CN en en CN CN cn 

C

I 

N 

CO 

1—I 

I 

r-. 

1 

5 r

m 

H 

I 

1 

U_> 

it H 

i n 

!-

I 

H 

t 

v

r 

O 

1 

\ 0 

v

1 

o 

vO 

t-i 

I 

CN 

1—I 

I 

r-i 

I 

CM m i n vO CO i 0> | O CN m -n o 1 r*** CO ! a*-. 

CM 

i I 
RUN NO 

21 

22 

GENERATOR DATA I'OKM 

RUN TYPE 

2-16 

2-16 

NO. PEAKS PEAK WIDTH TIME 

LJl 

! : s<*~ 

OPERATOR 

OX 

6X 

* '" ' ' **" T 1~"/ 

CHART SPEED 

^ * ^Z/2 / , 

S-fi/'Q//?. 

COMMENTS 

A^_ _ 

- ^ 

23 

24 

2-18 ^:ao ftcl S'fij.flf'o- SLL 

2-8 ^ : rf OA. S-*//%//)• oAL 

25 2-12 <£:a.x oa. S.bl min. jA 

26 2-10 AISI, £2, ft. of /?)/'/)- QJL 

27 

28 

2-16 

2-6 

3'. 01/ iLL 

3:/3 

•A-6//>]//)• 

UAL S. of min. 

ok^ 

JlA 

29 

30 

31 

32 

2-6 

2-2 

2-18 

2-4 

A1AL ox 5.o//n in. 

Jc JJ1 OAX. 

3-Sl 

S-0 I min. 

&A .'i-o I min. 

lAJLl fil ULI mi/L 

J^ 

hA 

JA 

nA 

33 2-18 v.'/a OJL S-b /min. £& 

34 2-2 1:A oz ,5- 0 //!))•% oA 

35 

36 

37 

38 

39 

AO 

2-16 

2-4 

2-4 

2-10 

2-2 

2-4 

HAi oi S- o fgin. 

oX J5L±JJMA. 

ox 

±AA 

Jo jnifL 

D.A 

1 1 

-JLAL] 0.A 

oA 

L f 0 [MUL 

S- o //»/'/)• 

._i_li/2//A.._.. 
GENERATOR DATA FORM 

RUN NO. 

41 

pyx " 

4 2 

A3 

A 4 

4 5 

A 6 

A7 

4 8 

49 

50 

51 

5'2 

53 

54 

55 

56 

57 

58 

59 

60 

RUN TYPE 

3-5 

3-J) 

3-1 1 

3-10 

3-6 

3-17 

3-7 

3-15 

3-16 

3-4 

3-2 

3-16 

3-14 

3-4 

3-14 

3-10 

3-12 

3-10 

3-16 

3-2 

3-9 

NO. PEAKS 

1 . 

2 

2 

1 

3 

2 

3 

3 

1 

1 

3 

3 

1 

3 

2 

2 

2 

3 

1 

2 

PEAK WIDTH 

5 

3 -

5 

4 

6 

5 

1 

3 

4 

4

 J

~~ 

2 

4 

2 

4 

2 

4 

6 

4 

4 

2 

3 

TIME 

<?:+! 

Jd :/& 

• *?:.-T? 

/o;sS 

I)-.*)-} 

i; •. i <? 

/I • *1 

/I .4 / 

n :SI 

rjj* 

J. 31 

I :H 

/ !5V 

A: o

L

i 

Al:il 

A.-o ^ 

„A\JJ 

JLTJA -

3:<U 

,^3 3 

3:1$ 

OPERATOR 

C.3L 

b9^ 

O &s 

bZ. 

6H 

6*L 

t>2. 

d^L 

071. 

A i 

0 3L 

oa 

OJ 

6 7L 

0 2 

f)3t 

03L 

OZ 

OZ. 

07L 

OfiTE -J^o/V* 

/ 

CHART SPEED 

Jf•& //»!/). 

S-0 '//?}/'/) • 

s.o/ mi/). 

SA / min. 

S-d 1min. 

J. 6 1 mi/). 

•S.6 1 /ni/). 

5-a i min. 

S.6 /mm. 

S-6 ) ft) j ft. 

S.d //?}//!• 

6-61 min. 

S-c> / mint 

5- 0 fm in. 

S.d l/nifta 

So f>nins.i) //min. 

S. 6 /n,ifi. 

S.6 /mint 

so //nift- i 

S. A / /riif). . 

COMMENTS 

._^L__ 

oK 

OJ 

bK p)\N 

otA Mi/v 

6/C RAIN 

dJ 

f)kA 

nJ 

OiC 

OK 

OJ 

OK 

6 A' f?/)iv 

fltC QftW 

ok /?.)•* 

AK £M 

OK Wirt 

ok PWAI 
nETHui,* 9 1-it.L.D ^IUD Y 

GENERATOR DATA FORM 

RUN NO. 

61 

62 

63 

64 

65 

66 

67 

68 

69 

70 

RUN TYPE 

3-2 

3-7 

3-18 

3-15 

3777" 

3-11 

3-15 

3-11 

3-5 

3-1 1 

3-11 

NO. PEAKS PEAK WIDTH 

S 

5 

TIME 

31S2, 

llLL 

laa. 

j ;<*o 

9'rfs 

to :A ? 

\b :37 

OPERATOR 

Oil. 

6 2. 

<U 

0^ 

6 X. 

AA, 

AL 

Od. 

b 2~ 

P/?TF J-ht/?** 

CHART SPEED 

S.6 J min. 

S.6 ]niiil:^ 

6.0 [MA 

S-6 /min 

5-6 / /*''/>• 

S. d / /A in. 

S. o j min. 

S-6/ />)//). 

S.6 j min. 

S-6 f win. 

r 

COMMENTS 

oir turn 

ot 

o'S 

OK 

.*.<•<•• c)m\,ff>f3pc. 

OX ' 

OK 
GENERATOR DATA FORM 

DftTE S/.2iJj.S„ 

RUN NO RUN TYPE 

71 

SS. 

21_ 

Slli 

i?i 

_76 _ 

7 7 

.SDL 

79 

80 

11. 

1

{

A 

AL 

JJ6_ 

_87_ 

88 

_89_ 

90 

4-8 

4-12 

4-16 

4-4 

T^/T 

4-16 

4-16 

4-4 

4-14 

4-14 

4-12 

4-10 

A-2 

4-8 

4-2 

4-6 

4-10 

4-4 

4-16 

4-14 

4-14 

NO. PEAKS 

3 

3 

PEAK WIDTH 

2 

>. 

TIME 

1LAL 

1AAL 

U__li 

11 '.S3 

JX .S3 

VOID 

I •' M. 

/•'I A 

JJ\ 

AAA 

XJA„ 

J.W 

JJJA 

SJA7L 

A: i A. 

ALtA 

Al£L 

J.J>A 

3.'AL 

JJ-M^ 

OPERATOR 

AJ. 

071. 

67L 

67k. 

712-

OJ... 

OX.-

0 7k. 

D-7 

o 71. 

AA 

A J. 

6 3... 

JL2_ 

JJA 

JiA 

dTL 

CHART SPEED 

S- 0 //>!//)• 

S- o / /nin. 

•-T- 6 /min. 

SJUUmJL 

JUun 

COMMENTS 

AL 

oK 

OK 

.^•4/J2U/L _ . 

JLA/JIILD^, . 

S.d I m/n. 

S.d/ min. 

S-61 //]jn. 

S-6 /min. 

S-6 //?}/'/). 

Soy win _ 

S.o //»//). 

S.6 )min. 

S*v l/n iflA-* JAMJL 

So /minS-6 

A 

SJ±AJUIL 

__k___J_Q__ 

M— 

JULoK 

oJ 

QJ 

'/>/ -

ok 

_/_£. 

ok 

_£_(___ 
GENERATOR DATA FORM 

RUN NO. 

91 

92 

93 

9A 

95 

96 

97 

93 

99 

100 

RUN TYPE 

4 - 8 

4 - 6 

4-10 

4-1 8 

4 - 2 

4-14 

4-1 8 

4-12 

4-12 

4 - 8 

NO. PEAKS 

2 

1 

2 

3 

1 

3 

3 

2 

2 

2 

PEAK WIDTH 

1 

3 

2 

3 

1 

1 

3 

3 

3 

1 

TIME 

S.3S 

3\<rf 

3:SJL 

*:/> / 

?;// 

r.ii 

4:47 

V:«3i-

<fM 

T.5I 

OPERATOR 

A^ 

6^t 

62, 

6& 

0<X 

bOL 

02-, 

6X 

OA^ 

bit. 

i 

CHART SPE;-.;) 

S-6 //nff). 

S-6 //»,/). 

S.d /mi/l 

/ 

S.d /min. 

S6 /mi/). 

S^ / /ni/)-

S * / mi/). 

S.t. //>iin 

S 6 l/n in. 

So //,,/n. 

/ > ' 

COMMENTS 

_ .aA. _ 

Oj 

• oK 

_AK 

_ oA . 

A J 

ok 

OK 

oK 

ok 

/ 
P.92 

Preplanned Patterns for Plume Type 
P.93 

ICO 

© 

•f Peaks 

£"= }S zee. 

T—)— P 

£ r-XVUTZS 3 

ICO 

© 

« Peaks / _ 

Peak '.'."idth -2-

£ z /5 = JO;ec. 

? -* • 

' ' ' I ' ' ' i 1 

• ' 

. . . 1 . 

> 

0 1 2 :-iT-:UT2S 3 

ICO— 

® 

;7 ?eaks_ 

- Peak va' Lth 3 

^ --: IS -

_ Ai.-C' 

60—1 

CJ < 

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o 

20-

i-
ICO 

eak Viith 4 cO 

¥ X ID *=(;^55C . ^ j 

o -J 

< ) 

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20 

2 .-___-•:« . ^ 3 

P.94 

© 

_-? o ea____s 

rea.-: .".ic-.-

<• x/-5"-7^"sec . 

100 -

# Peaks / 

© 

Peak »"idthjk__ &j _ 

4 x Ar = ?Osec . 

0 7 :-n:it7r__s 
P.95 

ICO 

LA ® 

rea:-: .;_.•_-.: 

/o sec . 

iVv'J 

© 

•y _-ea_:3 

Peak Vrid-.h « ^ £o 

20 — 

rccccccco 

ICO 

© 

. £ Peaks %S 

. Peak Vadih -3 60 -

3 x /vTWOeec . 
100 

P.96 

I**"! 7 

0 

= Peaks 

Peak Wicch ^i 

>* i 

r \ 

< 

o -

20 

2

 rtJ i j . i f u J. __ *D 

-• 4 

X:C<XXXAXXX:CVXXXAXAXXXXAXXAXXXXXX:O:XXX:C<XXAXAAAX::AX 

100 

i x . = v(i> 

= Peaks =>L 

Peak Width O 60 

X_*_Z£_=_£Lsec. 

< 

O -

20 

| ' ' ' I 

2 MINOTIS 3 

;xxxxxxxxxx;o;xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx: 

100 

S x . a 

£ Peaks <-2-

Peak Width <p 60 

Lj.<jS' = ?/) sec . 

20 

-

-

£-1 

CJ " 

< 

o 

2 MINUTES 3 
P.97 

100' 

13) 

= 

p 

p ea 

V 

ks 

wi ^» 

-7 

/SS 2 c 

6 0 ' _ _ r 

<"! 

O "! 

2 0. 

2 MINUTES 3 • 4 

XA:C<:C<-XX:'X'-XAXXAXAXXXXAXXX:<XX:O ^ 

100 

i x. = © 

= ? 

Pea 

•z 

k 

X 

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.il C 

<? 

—/ 

rn jL 

30se c 

60—j 

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o • 

20 

1 ' ' ' I 

2 MINUTES 3 

XXXXXXXXXXX:C-:XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXAXXXXXXXXXXXXXXXXXX 

100 

£*X. = 

= Peaks 3 

;-eax wict n h j 

6 0-

j x /o = ^Ssec. * 

H li 

C -j 

20 J 

— r I 

1 

i < i 

2 MINUTES 3 
io:= 

P.98 

. ""* • 

>. _ 

— 

< 

Ol 

.... 1 

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~— — 

j 

- , . — 

i 

j 

I 

I 

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v/7 \_ 

= 

p ^ 

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j 

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tk v 

7 -"" 

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5 = c 

f" 1 C v 1 

i 

; — • 

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X -

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— 

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1 

i 

1 

1 

i 

• 

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— 

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2 MINUTES 3 

XX^XXXXXXX<XJ{XXXXXXXXXXXXXXXXXXX 

100 

i X . = ® 

= Peaks 3 

Peak Width Cs 0 <r, j 

v /^ = <?0 sec. 

CJ -' 

< : 
P.99 

APPENDIX 0 

Data Summary 
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White Plume/Fast Rise 

Number of Seconds >20% Opacity 

Observer No. 

Run No. 

61 

62 

63 

64 

65 

Obse.rver to. 

66 

67 

68 

69 

70 

Observer No. 

142 

Observer fto. 

165 

22 

30 

45 

300 

150 

11 

120 

150 

75 

150 

150 

11 

150 

11 

165 

FREQUENCY 

23 

30 

45 

285 

135 

12 

135 

150 

75 

150 

150 

12 

150 

12 

165 

24 

30 

45 

300 

150 

13 

135 

150 

75 

150 

150 

13 

150 

13 

165 

METHOD 

25 

30 

.45 

285 

135 

14 

135 

150 

75 

150 

150 

14 

150 

24 

165 

26 

30 

45 

285 

135 

15 

135 

150 

75 

150 

165 

15 

150 

15 

165 

27 

30 

45 

300 

195 

16 

135 

150 

75 

150 

150 

16 

150 

16 

165 

11 

45 

34 

290 

149 

22 

139 

150 

76 

150 

154 

22 

154 

22 

163 

STOPWATCr 

12 

33 

34 

287 

155 

23 

140 

152 

75 

150 

154 

23 

159 

23 

165 

13 

32 

35 

287 

149 

24 

141 

153 

75 

149 

154 

24 

159 

14 

165 

METHOD 

14 

33 

34 

288 

155 

25 

140 

150 

75 

146 

153 

25 

162 

25 

162 

15 

33 

34 

295 

180 

26 

140 

152 

75 

148 

153 

26 

156 

26 

152 

16 

31 

36 

283 

149 

27 

138 

153 

76 

151 

158 

27 

155 

27 

164 

Transmissometer 

31 

33 

282-

147 

141 

141 

73 

153 

154 

154 

164 
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P.6 

APPENDIX E 

Participants 
P.7 

Visible Emission Observers 

NAME AFFILIATION 

Thomas Henderson GCA 

Mike Pleasant EPA 

Chip Duke EPA 

Barbara Burton DGA 

Paul Wi Unite DGA 

Carl Koontz TN DAPC 

Donald O'Gorman SC BAQC 

David Brande ETA 

Cecil Stackhouse TRW 

Gary Henry TRW 

Dave Gladding PES 

Greg Lathan PES