..p.l. 

OAR Box 1115 

Prepped by Ryan Dugan 

Document Number: 

83) I I-A-15 

Docket Number: 

A-84-22 

Printed 4/18/2008 10:52:08 AM Sheet 83 of 94 
P.2 

fl~rv-*i I-A-/S 

EVALUATION OF OPACITY FREQUENCY METHOD 

ON SLOWLY CHANGING PLUMES 

Contract No. 68-01-5110 

Task Order # 34 

Prepared by: 

DEL GREEN ASSOCIATES, INC. 

1155 C Chess Drive, Suite A 

Foster City, CA 94404 

(415) 574-4737 

Prepared for: 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

Division of Stationary Source Enforcement 

Research Triangle Park, NC 27711 

TASK MANAGER 

Kirk Foster 

December 1981 
P.3 

ACKNOWLEDGMENT 

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. 

n 
P.4 

TABLE OF CONTENTS 

page 

1.0 Summary 1 

2.0 Introduction 2 

3.0 Background 3 

.4.0 Study Design

 7 

4.1 Method To Be Tested 7 

4.2 Smoke Source 7 

4.3 Selection of Observers 9 

4.4 Number of Opacity Observations 9 

4.5 Collection of Data 9 

4.6 Quality Assurance Procedures 9 

5.0 Test Procedure 11 

5.1 Selection of Test Site 11 

5.2 Ambient Conditions H 

5.3 Collection of Data 11 

6.0 Field Test Results 14 

6.1 Test Data Summary 14 

Appendix A - Reference Method 9 (with Preamble) 

Appendix B - Sample Data Form; Strip Chart Test Log and 

Predetermined Plume Patterns 

Appendix C - Meteorological Data 

Appendix D - Data Summary 

Appendix E - Participants 

m 
P.5 

LIST OF TABLES 

page 

6.1 Number of Observations Completed 17 

6.2 Method 9 and Transmissometer Opacity Averages 18 

LIST OF FIGURES 

4.1 Strip Chart Record of Typical Test Run 8 

5.1 Observer Location 12 

6.1 Observed Mean Opacity v. Actual Mean Opacity 15 

6.2 Standard Deviation of Observed Mean Opacity v. 16 

Actual Mean Opacity 

6.3 Frequency of Difference Between Actual and 20 

Observed Mean Opacities 

6.4 Frequency Distribution of the Differences of 21 

Actual and Observed Times of Excessive Emissions 

(Opacity _>20%) - White Smoke 

6.5 Frequency Distribution of the Differences of 22 

Actual and Observed Times of Excessive Emissions 

(0pacity.>20%) - Black Smoke 

iv 
P.6 

< * « fy 

1.0 SUMMARY. 

In order to ascertain the statistical accuracy of using the frequency 

(time-aggregate) method for determining source compliance with opacity regulations, the U.S. Environmental Protection Agency's Division of Stationary 

Source Enforcement conducted a field study in Jacksonville, Florida cn January 

15, 16, and 17, 1981. 

Data were collected by ten certified observers who read both black and 

white plumes from a smoke generator equipped with a transmissometer. In all, 

180 12-minute test runs were made. During six minutes of the 12-minute 

period, the plume opacity was increased or decreased very slowly over an 

opacity ranging between 20% and 60%. Readings were taken by EPA Reference 

Method 9 but the data were reduced using the time-aggregate method. In Method 

9, opacity readings are taken every 15 seconds. During data reduction by the 

time-aggregate method, it was assumed that 15 seconds of excess emissions 

occur for each reading greater than or equal to 20% opacity. The 15-second 

intervals of excess emissions were "aggregated" to determine the accumulated 

time of "observed" excess emissions for each test run. Similarly, the accumulated time of "actual" excess emissions as measured by the transmissometer was 

calculated. The data were also evaluated by the time averaging technique 

specified in Test Method 9. 

The data base developed through this field study will undergo s detailed 

statistical analysis which will be reported in a subsequent study. This 

report discusses the study design and provides a brief summary of the test 

data. 
P.7 

2.0 INTRODUCTION 

Technical support for visible emissions evaluation techniques was developed by the Environmental Protection Agency in 1974 and followed by the revision 

of EPA's Reference Method 9. Method 9 is based upon the averaging of 24 

consecutive visual observations of the opacity of an air effluent stream, 

taken at 15-second intervals to determine an average cpacity of the emissions. 

Because 24 observer readings are averaged over six minutes, high accuracy 

is achieved. __ 

However, several states use data reduction methods that vary from Method 

9 and generally pre-date the EPA 1974 revision of Method 9. One of these 

variations, referred to as the "frequency" or "15-second aggregate time" 

method, involves counting the number of 15-second readings above a certain 

opacity value and multiplying this figure by 15 (the number of seconds between 

readings) to determine the total time of emissions exceeding the specified 

opacity value. 

EPA recognized these variations in 1974 when the Method 9 revision was 

published and the Agency committed to the review of techniques other than 

six-minute averaging. This study is in response to that commitment. 
P.8 

3.0 BACKGROUND 

To investigate the accuracy and precision of Reference Method 9, the 

Environmental Protection Agency established a data base of visual observations 

that could be compared to actual in-stack opacity measurements obtained with a 

transmissometer. These measurements were made using a smoke generator, an acid 

plant, and a fossil fuel-fired steam generator as sources. The current Reference Method 9 (included as Appendix A) was revised to include data averaging 

based on these test data. 

Currently, Method 9 requires that 24 consecutive opacity observations be 

averaged to determine an opacity level. Because observations are taken eyery 

15 seconds, this results in a six-minute reading period. It was found, after 

comparison of reader observations to actual opacities, that averaging a series 

of opacity readings greatly improved the overall estimate of actual opacity. 

To ensure the accuracy of opacity observations, Method 9 stipulates the procedures and standards for observer training. Specifically, candidate 

observers must certify by demonstrating the ability to "read" opacity within 

15% of the true value for 50 individual readings, with an average deviation of 

less than ±7.5% opacity for 25 white and 25 black smoke readings. The actual 

field studies conducted in 1974 showed that for 99% of the test sets read by 

qualified observers, the average positive deviation of the observed opacity 

from the measured opacity was at or below 7.5% opacity. Thus, the overall 

error inherent in Method 9 is well defined. 

Prior to the revision of Method 9, most state air pollution regulatory 

agencies had adopted regulations referred to as "time-exemption", "timeexception", or "aggregate-time" regulations. A time-exemption regulation 
P.9 

generally requires a source to comply with a maximum opacity limit, usually 

20%, but also exempts the source from the limit for short periods. The exempted periods, typically two or three minutes per hour, allow the source shortterm malfunctions or batch emissions without triggering enforcement actions, 

yet require good source performance 95% of the time. Often, a maximum not-tobe-exceeded cpacity limit (e.g., 60% opacity) also is stipulated. Since the 

periods of excess emissions are aggregated over a one-hour period, compliance 

with the time exemption regulation generally has been found more difficult 

(2) than with the six-minute averages of Method 9-based regulations. 

Typically, enforcement of time-exemption regulations has been based upon 

uniformly spaced (usually 15-second intervals) visual opacity readings (as 

per Method 9) , with each nearly instantaneous reading assumed to represent the 

average opacity during the entire 15-second interval. Thus, each opacity 

reading above the standard causes an additional 15 seconds to be accumulated 

toward the time-exemption period. Consequently, under a three-minute exemption standard, 13 accurate observations of excessive emissions in a one-hour 

period would be considered to have exceeded the standard. This method often 

is called the "frequency" or "15-second aggregate-time" method. With the 

exception of the data analysis, this method conforms to the procedures of 

Reference Method 9. Although the accuracy of the 1974 revision of Method 9 

was well documented, the accuracy of the aggregate-time methods employed by 

(2) existing State time-exemption opacity regulations is not so supported. 

As previously mentioned, a notable shortcoming cf Method 9 is its 

inability to quantify brief (intermittent) periods of high opacity emissions. 

For example, two or three minutes of 40% opacity emissions often would not 
P.10 

result in a violation of the 20% opacity standard when averaged ever a sixminute period, due to the mitigating effect of the other three or four minutes 

of relatively clean emissions. This pattern could repeat continuously, with 

the source still remaining in compliance based on Method 9. This deficiency 

did not appear critical when Method 9 was revised in 1974, and it was to be 

addressed in future EPA method development. 

The limitations of Method 9 in dealing with intermittent sources and the 

lack of a supporting data base for aggregate-time methods were highlighted by 

(3) the case of Donner-Hanna Coke Corporation v. Costle. EPA proposed to 

inspect the company's coke oven facilities in Buffalo, New York using an 

aggregate-time stopwatch technique described as a modification of Method 9. 

The "stopwatch" method, an alternative to the "frequency" method, requires an 

observer to measure with a stopwatch the accumulated time during which the 

opacity exceeds the standard. The observer starts the stopwatch when the 

opacity exceeds 20% (or some other standard) and stops it when the opacity 

drops below the standard. The technique was designed to determine compliance 

with New York's existing time exemption rule as adopted in the State Implementation Plan. The company claimed the stopwatch technique end its method of 

implementation to be inappropriate and refused entry to EPA. The Court found 

that the proposed EPA method was not promulgated properly and that Method 9, 

EPA's only other alternative, was inadequate for an intermittent source such 

as the coke even battery. Furthermore, Court investigation into the background of the proposed stopwatch technique showed a data base inadequate to 

support the accuracy of the method. 
P.11 

After the modified Method 9 failed to withstand Court scrutiny, EPA 

decided to develop, if feasible, an alternative method suitable for determining the compliance status of an intermittent source. As part of this effort, 

EPA conducted e series of field studies to collect observer data using aggregate-time techniques. Because initial data indicate that the rate of opacity 

change effects the error associated with aggregate-time readings significantly, the field data collection efforts were designed to obtain observer data 

from plumes with a variety of opacity change rates. This study, conducted in 

January 1981, concentrated cn plumes with periods of slowly changing (both 

increasing and decreasing) opacity. Other data collection and analysis 

efforts concentrated on plumes with fast, intermediate, and invariant 

opacity change rates. 
P.12 

4.0 STUDY DESIGN 

4.1 Method To Be Tested 

In an effort to assess the validity of the 15-second aggregate-time 

method for reading slowly changing plume opacities, a field study was designed 

by EPA. The resulting observed and measured cpacity data were analyzed to 

determine whether the aggregate-time method could adequately estimate the 

actual time of excess emissions for this type of emission. The data produced 

by the field study were to be available for analysis and technical support of 

a revision to Method 9 or development of a new alternative Reference Test 

Method. 

Because the field study was designed specifically to address the problem 

of slowly changing plumes, it was necessary to simulate those emission 

patterns. The smoke generator was used to emit plumes for 12 minutes. Submerged within this 12-minute period was a single six-minute period of yery 

slowly rising end falling opacity, with plume opacity graduating between 

20% and 60% opacity. Figure 4.1 presents the strip chart record for Test Run 

9, and is typical of the plume pattern used during this experiment. The 

transmissometer test log for the 18 runs, as well as the series of predetermined plume patterns to be followed during.testing,are presented in Appendix B. 

4.2 Smoke Source 

The Florida Department of Environmental Regulation's smoke generator was 

used in the study. The generator was set up with two strip charts. One 

strip chart system was used for the generator operator to plan and execute 

a pre-arranged program of plumes, and the other was used as a record of the 

test plume opacity. 
OOI 

^uaoae d 'A"q.pBd o 

08 09 0t? 02 

iii i I I 

1 1 1 1 J K\J 6 1 j ! 

j ! <-. 

. X7*rm?@& 

i 

'j* "• '" f i 

<E : > ! 

• i. l 

• \ — 

-~

 ;

- - • : "£ 

— f-* - ;-—;• • -j - - 7 -^v-^— • 

t 

-f • 1 

1 

1 

4 - •— 

, • 1 • ' ' • : 1 ; 1 1 

• '• 1 ;: • ! . i ' -T : • i i • 

.: 1 I ' • ' 

JA' 1 : ! 

d_ML_i_ -: - -

!l 

i i 

• 

o_ 

: i ;.i, : i. 

!•=!•!!! • 1 . 

i ''•' > 

i . • i • 

I ' ; : : • 

i *p-\ 

! i :<^~_i. 

j • • i :^* i i ! 

i !:. J-: 1-!;:' ! 

7 7.7-

'',: \ i : • 

I'i! : 

iiiiii ! 

77\\A 

i • !: : !;:•• • 1 ^AA^rrfilAA 

09 0-: ; 

I I 1 01 Oi 0C Or . ! ' : 

" T i ' . ; i •••-,--• • • ;- • | 

• ~ 

o^: 

I • 

1 • "rr^-f.-, 

1 ' ' ; 1 

J 'li!; : 

' | 

Or ! ;! ; |o'c|* ^ :! i i ; -CZ' ' 

09

 ; • 

-t-— -

!

 : ! ! • ; ; : i : ! 

AAA \ ! i' j i- i i . : 

: i 

! • !

 : ! '• 

\< •• . 

1 ; i . 

:!|j; -

• i 

: i 

i l 

TT 

;i 

! i 

| l = 5 

I i • • 

• 1 

.... :.... • _,. T —:... ~A— - ; ..ii — 

. :_i-: A .-' A' ' 

.71*

 : -r: , 

i 

. : i ' 

•; ' i 

: • i • . 

: . ! : • 

i • 

! • > 

nT; i i ! Ti:; 

:

; 

: | 

, ; ' 

> i : 

J ' : 

J' i J ! : 

• • • 1 

; • . i 

i;!! i 

i • i ' 1 

! ' ' ' ' 

i • ! ' i 

.•ii i 

. i • 

: • ! • j 

t ; ; • i 

; . 1 

;! ! I i:.; ! 

:!• • ! 

" • ' i 

i t 

| * 

..... 

"1 

i i* :• 

: S ;» 

1 ' •• ': 

'• '• i ! 

. . ! i ; ! 1 

->. ' 

| . 

' ' . ! i' O 

04 09 o'_ o* *5*?c a 

, . 0 : 3 . OE =" 

__ 

*£ Or 0 

TO 

, ' . ' ! 

1; : : !°^Hi 1 j ; : ! '0B. 

i , ; i 

i ' • : ' 

i ! ' 

i .:l.- l : 1 

• • 1 • ' • 

i i : • : . 

1 • : • • 

1 :!••! ; 

1. Mii H i 

. : i . . ; 

•. 1 : . ! : 

i : : ; : ! 

.'!: :| . :- hi ; I::-; ; 

IA-.]- . . :>••: 

i i • ; 

: • 

li; : . i ;- . :::= 

U l r '.• • • 

i . , 

: : 1 •• • 

M!!!-;:! 

!hil;;:i 

i » . : • 

! i :; i • 

:

 1 ; • 

'i' i 

.II I 

i! ; i !; i i 

*'/ 

' ' • i 

Au^ 

,

:

; i i 

!

 • ! ! 

jiU-J -

c*"

 ! 

L •. • 1 

Iii-

^ ; i 

mmiL 

> f i i : i • 1 1 

' : : 1 

;^i j i I •• ; 

; | ja j i i . 

:

 !frii i 

iiiiii!! 

: : 1 ' ' V 

; jC: ii! i!H 

1 i -

• . ; 

!^i 

• '. : 

: 1 

' i i

 :, ii<: :

l 111 i' ! i: i! 

! j i j : 7 ; 

4 ^ i! j 

! | \Y \:: 

| yf j i i 

'if ii1' / Iiii 

1 : ! ' 

tlfltt 

! iil ! 

i !l!i 

A-tj 

i i iill 

1 i ill ! 

i; 'i i 

i i i i : 

^ ' ' 

1 ' [ 

, 

i • I 

Ml 

! l i 

i i ! 

i 11 

!M 

:

 • i 

1 1 « 

i • : 

I 11 

. i ; 

*"• /~~~Q* '• di. i | i j ] | : :oz:. 

r- V ^ 09 '!' : di. :' \[-... :oe: •' 

^ i ! i. j 

••:- : " ! -5"- : frr-i ITM1-

:: ; ; N 

• i 1 1 

Wtf ! ' ! 

! ' 1 

• | 

. 1

 : ' 

; i • ' • 

r 

• t 

f i 

i I 

: i 

TT' 

h 

. t 

i ! 

iji : 

i

: : 

; 1 i 

i l l ' 

!.'! ; 

1 ; 1 ! 

'. i i • 

i ' • i 

Q . 

i 

| 

' i 

i 1 

, ' " ' I ' ! • •• 

i 

6 ur 

^JBl|3 c 

i**f 9«in£ 

!

 i 

T r 

iw 

•a 

Jul**; 

m 

i — 

• • ' i • : 

. . ...j . 1 

.-. 

:C: ' 

\ i "WWJA-

'•• *^ l 

A s 

1 ' r 

-«G_Ti • i i

 :" ^ i 

' i: \.:J 

• l ' •; ? 

••!•! . • • 1 

1

 1 ' : i ' 1 

: : ; V 

"i-i . . !:• / 

: 1 • 

".71" 

- I """1 ' 

, ; : i~TiT 

ill : ! : 

1 . • . : 

.':';» : ! • 

:i!il = 

'iui ! 

. I I 

• ! 

! | 

• 1 •• : 1 • 

•iiiiii: ! ! 

h i

 : : 

•••(... . ; ; 

: 

. i * i 

: . 1 

: ! , 1 

1 ! • i 

I 

i ! ; ' • 

j

'

!:

l - i 1 il 

!:! . ! 

II 1 ! 

; ! 

i i 

' 1 I • i ; i , 

•" *i!!ii ii 

-i-j 

i 

i 

i t i 

j

1

 !! : ! 

! j 

:

:

 i 

• | . • 

:

 • j 

1' i; ; i 

! ' : ' i ! 

! !;l i 

i I!M 

1

 ih

! i : i i 1 i 

• ' i : : i 

i •• M: I 

: i : : • ; 

1 • | ' : 

' i ; 

' . ' • 

| ; | 

I'i ; 

i I • i 

!; i : 

• j ; ; 

• j : 

; : . 

..... i. . ,/-..i I:7.:.I.:J.; 1 :. 

0 

\ WVCL 

i • 

i 

i 

i .. . 

: : 1 : • : 

iWdili : l-m s 

; . ' | : i 

I . • : 

; i ' • : ' 

;: ;!!9*j.nui.w O'O 

• 

; 

: ; Wi Z L [ 

•

 :

 -i : : : 

: : ' : ! : i 

:

 ;_Lp !! t 

:•-_.-•: 'Wc 

! : i ill ! 

. ! ! J 1 1 | 

: :~? II i 

| • ' ' ' ! : [ 

! ;; i in"! 

! ' i 

1 

i ;: 

\f>\ 

un 

iii i E 

iii ; \ 

1 ! W(J M i i I 

' -dv '' •' i 

1

 : iP*: I | I 

i •': iii i 

:| i i | Mi 

•i

 !i> j i i 

i i

 : ' _ iii ! 

;! -ITtini 

i i "'J_UihV 

• ; i i 

:M!±-I 1 

il^Ur \M 

• h.fl l 1 

li.ili.Ji i 

•!

 : ;i]. j 

iiiiii. J *'< 

ilMlLJ 

'iiiiL J 

Iiiiii.. ) 

i!i,'L J K"l« 

ihiit j 

!'i:L J 

!'':: 1 ! 

. _J i W= 

^'i ! i 

.06; i i: 

i : ; i ; 

7\\\wt 

' I ;TT7 

"T* 1 . , 

1 : ; : i 

i • i ' M 

•

:

 |>irV<l 

; . : i i WV 

i • ujli l 

; : ill 1 

• i : Ml ! 

i-!i! iii i 

| • = : Mi4 

' ii AW 

:'••: : il l 

I

 ! i :l i 

•• 11 . 

i -\' Wtot 

! ! i ! : 

A-'.^ . 

i . op i 

MM 1 

'IS! ! 

M i l 

iii i 0 

iii ! ; 

ISii i g 

11 i 

1 1 1 

i ' ; 

i 11 

.j i i 

i i 

i l l 

Jt 

s 1 

! 4 

i S 

bi 1 

i i' " 

1! op 

i i 

i ; 

iii1 : 

1 ; 

j i . : 

l i : ' 

^J 

M • i 

\t:; ^ UJ 

i : sa^nuiw o 2 1 

j : j, -jf 

Ml 

c i ! 

'• 1 ' ! 

i i 

_L_i 

TTH M \M _ •!.. 

e i d 
P.14 

4.3 Selection of Observers 

In order to implement an opacity reading technique and the associated 

enforcement program, some baseline level of competency must be met by all 

observers (i.e., certification). However, in selecting individuals for experimental observations, it should be noted that the stringency and procedures 

of the competency test establish a lower, but not an upper, limit on the 

competency of the participants. Observers selected for this field test were 

all graduates of the Florida Visible Emission Program for Method 9 Certification conducted the previous week. As mentioned previously, Method 9 requires 

reading a series of plumes at 15-second intervals, and in this respect is 

identical to the frequency method planned for use in the field test. 

4.4 Number of Opacity Observations 

Due to the limited resources available for the study, the amount of 

data collected was more a function of the available time and manpower than 

specific study design considerations. However, to ensure the validity of 

the study, an adequate number of observations was taken to establish the 

accuracy of the frequency method when used to read slowly changing plumes. 

4.5 Collection of Data 

Procedures for data collection were designed largely to avoid biasing 

the results and to ensure compliance with Method 9 observation requirements. 

To expedite data collection and later use, a standardized form was designed 

for the observers. An example of the form is provided in Appendix B. 

4.6 Quality Assurance Procedures 

In order to ensure the success of the program and assure that the data 

are suitable for planning and enforcement purposes, the quality control and 
assurance procedures listed below were implemented. 

1. Smoke readers were all recent graduates of the Florida Department 

of Environmental Regulation smoke school, which meets Method 9 specifications. 

2. The smoke generator utilized in this study met all Method 9 specifications. It was calibrated carefully prior to conducting the test 

runs using NBS-traceable filters of known cpacities. In addition, 

zero and span checks were performed periodically to ensure minimum 

instrument drift. These instrument inspection and calibration procedures were performed in accordance with Method 9 requirements. 

3. Two strip chart recorders were utilized to maintain a permanent 

record cf smoke generator output. The strip charts were fully 

checked, with an audit performed cn the transcribed cpacity data. 

4. To assist in the efficient collection of data, a specialized data 

form was developed. All of the data transcribed from the forms 

for keypunch entry were checked for accuracy. 

10 
P.16 

5.0 TEST PROCEDURE 

5.1 Selection of Test Site 

The test was conducted at the Florida Department of Environmental Regulation Offices on Bills Road in Jacksonville, Florida. This is an excellent 

site with good plume background all day. Figure 5.1 depicts the test location. 

5.2 Ambient Conditions 

At the beginning of the first test day, there were scattered clouds. The 

cloud cover began to dissipate before noon, and the afternoon period was clear 

and sunny. Winds were from the northwest at about 3-7 knots and visiblity was 

constant at 7 miles throughout the day. The temperature range for the day was 

41-69* F and the relative humidity varied between 31 and 83 percent. A trace 

of rain at dawn had no effect on the day's readings. 

The second test day began with light scattered clouds, which built up 

slightly throughout the morning and afternoon. Predawn fog dissipated by 

sunrise and visiblity remained 4-7 miles throughout the day. Winds were from 

the northwest at 3-5 knots until late morning and then picked up to 7-13 knots 

from the north-northwest until late afternoon. Temperature ranged from 35-

66" F and relative humidity from 27-88 percent. 

The third test day was exceptionally clear and sunny throughout, with 

visibility constant at 10 miles. Winds were from the north-northwest at 7-13 

knots. Temperature ranged from 27-40° F and the relative humidity varied 

between 24 and 50 percent. Meteorological information from the Jacksonville 

Airport reporting station is presented as Appendix C. 

5.3 Col lection of Data 

During the runs, the smoke generator operator varied the opacity to 

simulate a slowly changing plume. Three plume patterns were tested in both 

11 
Figure 5.1 

Observer Location 

ty 4r> 

O 

Smoke Generator 

Apartment 

Buildings 

/ r<^ 

/ O 

4 p.m. 

O O o o 

O .0 

o 

^J 

o \ 

o 

8 a .m. 

Septic 

12 
P.18 

black and white smoke. The plumes had a steady rise or fall of 20%, 40%, 

or 60% opacity over a six-minute period. These rise/fall patterns were submerged within a 12-minute period of varying opacity levels. 

At 15-second intervals, a horn was sounded to cue the observers to make 

an observation. Simultaneously, the opacity trace was marked and the reading 

number identified for the run. The readers recorded the observed cpacity 

on the provided form each time the horn sounded. 

13 
P.19 

6.0 FIELD TEST RESULTS 

6.1 Test Data Summary 

Ten readers participated in 18 tests over the three-day testing period, 

and each test comprised 48 readings. Thus, in all a total of 8640 separate 

observations were generated from this study. The number of opacity readings 

and six-minute test runs are shown in Table 6.1. Average opacity values are 

displayed in Table 6.2 for observed (all observers) and actual (transmissometer) data. A complete listing of these observations is included in 

Appendix D of this report. 

The field tests in this study were designed to show the observers ramplike increases (or decreases) in opacity over the six-minute reading period. 

These tests are characterized by large differences in opacity changes over the 

six-minute period (from -34% to +40% opacity), relatively low test-to-test 

variation in average opacity (19.7% - 42.1%), and moderate variation in 

opacity within tests i.e., the standard deviation of the 15-second opacity 

readings, (4.6% - 12.4%).( 6 ) 

Figure 6.1 illustrates the regression of the average observed values (per 

Method 9) to the actual (transmissometer) average cpacity values for the data 

obtained from this field study. A linear relationship is clear for both black 

and white smoke, and the slope of the regression line is approximately unity 

for both; however, the white smoke readings display a positive bias. The 

standard deviations of the observed Method 9 averages for all observers are 

displayed in Table 6.2 and are plotted against actual mean opacities in Figure 

6.2 In general, the standard deviations for the black smoke plumes are larger 

than those for white smoke. Although both groups show a positive correlation 

between standard deviation and mean opacity, the slope of the regression line 

is much higher for black smoke. 

14 
P.20 

TABLE 6.1 

Number of Observations Complated 

Total No. of 

15-second 

Opacity 

Observations 

No. of 6-Minute 

Observation 

Periods 

Al l observers, al l test runs 8,640 360 

15 
- ftr - •".•"••'WT--

P.21 

to 

Run 

IW 

2W 

3W 

4W 

5W 

6W 

7W 

8W 

9W 

10B 

IIB 

12B 

13B 

14B 

15B 

16B 

17B 

18B 

TABLE 6.2 «> 

Observed Method 9 

and 

Transmissometer Opacity Averages 

Mean Opacity, Percent 

Method 9 

27.3 

31.4 

33.0 

42.7 

36.3 

36.6 

40.2 

33.4 

45.2 

31.9 

24.8 

27.0 

42.8 

25.7 

26.6 

25.8 

31.3 

36.6 

Transmissometer 

19.8 

25.7 

25.3 

36.0 

30.5 

30.5 

30.0 

27.3 

37.9 

26.6 

25.1 

26.0 

42.1 

27.8 

31.4 

24.5 

27.5 

36.3 

Standard Deviation, Percent 

5.54 

4.16 

5.49 

5.65 

8.92 

6.49 

8.86 

5.10 

7.53 

12.97 

8.63 

10.37 

12.69 

8.37 

8.56 

6.73 

7.30 

5.76 

HA? 

16 
P.22 

FIGURE 6.1 - OBSERVED MEAN OPACITY 

VERSUS 

ACTUAL MEAN OPACITY 

40 -

• - White 

A - Black 

® 

© 

-J«-

a. 

o 

30 -

® ® 

€> 

® 

A 

20 -

CQ 

o 

10 -

10 

ACTUAL MEAN OPACITY ( % ) 

17 
FIGURE 6.2 - STANDARD DEVIATION OF 

OBSERVED MEAN OPACITY VERSUS 

ACTUAL MEAN OPACITY 

2 : 

0 

1 — ^ 

• — 

<1—. c 

> 

L_O J 

O 

o_ 

-_T 

< 1— 

l/> 

14 

13 

12 

11 

10 

9 

8 

7 

6 

5 

3 

2 

1 

» — White 

A — Black 

@ 

<& 

A 

A 

• $ 

<•> 

^ 

® 

€ & 

10 20 30 40 

" I 

50 

ACTUAL MEAN OPACITY ( % ) 

18 
P.24 

The positive bias of the white smoke readings is illustrated further by 

the frequency distibution of errors of mean opacity estimates as shown in 

Figure 6.3. Approximately 71% of the white smoke reading errors were 

positive, while the black smoke data are nearly equally distributed about zero. 

Figures 6.4 and 6.5 illustrate the distribution of the errors in estimating the time of excessive emissions by the aggregate-time method. The white 

smoke readings, as might be surmised, show only positive estimation errors, 

while errors are.distributed around zero for black smoke with only a slight 

positive bias. 

19 
FIGURE 6.3 - FREQUENCY OF DIFFERENCES BETWEEN 

ACTUAL AND OBSERVED MEAN OPACITIES 

o 

c__ 

on 

ZD 

o 

o 

o 

o 

Z3 

45 -

30 -

15 ~ 

BLACK SMOKE 

•20 -10 20 30 

DIFFERENCES OF MEAN OPACITIES (%) (OBSERVED - ACTUAL) 

c__ 

c__ 

ZD 

<_> 

<_} 

o 

>-

o 

2_ 

LU 

oUJ 

CH 

LL. 

45 -

30 -

15 -

WHITE SMOKE 

18 2.4 

DIFFERENCES OF MEAN OPACITIES {%) (OBSERVED - ACTUAL) 

20 
60 

FIGURE 6.4 - FREQUENCY DISTRIBUTION OF THE DIFFERENCES OF ACTUAL 

AND OBSERVED TIMES 

OF EXCESSIVE EMISSIONS (OPACITY > 20%) 

WHITE SMOKE 

_e_ 

a_ 

_D 

3 

-L» 

r. 

_) 

Jj 

_D 

zr 

40 

20 

•360 

T-T-pr-| | | t ,• 

-300 -240 

I ' ' » | " 

•180 -120 

"I i |— i I I 

-60 

44 

60 120 180 

1 ' | ' ' ' | I I I | 

240 300 360 

DIFFERENCES IN TIME OF EXCESSIVE EMISSIONS (OBSERVED - ACTUAL), SECONDS 

21 

ro 
£_ 

_> 

J 

J 

3> 

40 -

FIGURE 6.5 - FREQUENCY DISTRIBUTION OF THE DIFFERENCES OF ACTUAL 

AND OBSERVED TIMES 

OF EXCESSIVE EMISSIONS (OPACITY > 20%) 

60 -

BLACK SMOKE 

Ll 

3 

~y 

Ll 

__ 

20 

- M • , I , i , , , r | i I i ; 1 I i |—J-4-t -

-360 -300 •240 •180 -120 •60 

uJ-Lu60 

!• "i— i i i i i i i i • 

120 180 240 300 360 

DIFFERENCES IN TIME OF EXCESSIVE EMISSIONS (OBSERVED - ACTUAL), SECONDS 

22 
P.28 

REFERENCES 

1. Evaluation and Collaborative Study of Method for Visual Determination 

of Opacity of Emissions from Stationary Sources, EPA 650/4-75-009, 

January 1975. 

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

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

October 1980 (Draft). 

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

N.Y., N.Y.. 

4. Field Evaluation of an Opacity Reading Method for Intermittent Plumes; 

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

5. Evaluation of Opacity Frequency Method on Continuous Plumes; Del Green 

Associates, Inc., December 1981 (Draft). 

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

Triangle Institute, August 1981 (Draft). 

23 
APPENDIX A 

Reference Method 9 

(with Preamble) 

40 CFR 60, Appendix A 

P.29 
P.30 

Titl e 40--Protectio n of th e Environmen t 

CHAPTER 1—-ENVIRONMENTAL PROTECTION AGENCY 

Subchapte r 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. 
P.31 

The provisions in paragraph (e) provide a mechanism 

for an pwner 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.32 

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. 
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. rt 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, 197 4 

John Quarles 

Acting Administrator. 
P.34 

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.35 

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

. 100 percent of the sets were read with a positive 

error1 of less than 7.5 percent opacity; 99 percent 

were read with a positive error of less than 5 

percent opacity. 

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

168 sets at a coal-fired power plant, 298 sets at 

a 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.36 

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, 
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 2 4 consecu-. 

tive" observations recorded at 15-second intervals. Divide the 

observations recorded on the record sheet into sets of 24 

consecutive observations. A set is composed of any 24 consecutive observations. Sets need not be consecutive in time and 

in no case shall two sets overlap. For each set of 24 observations, calculate the average by summing the opacity of the 24 

observations and dividing this sum by 24. If an applicable 

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.38 

3.2 CERTIFICATION PROCEDURE 

The certification test consists of showing the candidate 

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

plumes - generated by a smoke generator. Plumes within each 

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

order. The candidate assigns an opacity value to each plume 

and records his observation on a suitable form. At the 

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

candidate is determined. If a candidate fails to qualify, 

the complete run of 50 readings must be repeated in any 

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

smoke school or training program, and may be preceded by 

training or familiarization runs of the smoke generator 

during which candidates are shown black and white plumes of 

known opacity. 

3.3 SMOKE GENERATOR SPECIFICATIONS 

Any smoke generator used for the 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). 
c. Angle of view* 15° maximum total angle. 

d. Angle of projection 15° maximum total angle. 

e. Calibration error- + 3% opacity, maximum 

f. Zero and span drift ± 1% opacity, 30 minutes. 

g. Response time 5. 5 seconds. 

3.3.1 CALIBRATION 

The smoke meter is calibrated after a Plowing 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.40 

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

d = 2 .tan-1 d/2L, where 0 = 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-1 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 neutraldehsity 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.41 

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.42 

APPENDIX B 

• Sample Data Form 

- Smoke Generator Log 

Predetermined Plume Patterns 
P.43 

A 

TEST 

TYPE 

METHOD 9 FIELD TEST DATA FORM 

READINGS 

1 

9 10 

5 

17 18 

9 

25 26 

13 

33 34 

17 

41 42 

21 

49 50 

TIME 

TEST NUMBER 

2 3 4 

2 

11 12 

6 

19 20 

10 

27 28 

14 

35 36 

18 

43 44 

22 

PARTICIPANT 

5 6 

13 14 

7 

21 22 

11 

i 

29 30 

15 

*. 37 38 

19 

"45 T5" 

23 

51 52 5 3 54" 

HIGHEST READING 

< 

8 

4 

15 16 

8 

23 24 

12 

31 32 

16 

39 40 

20 

47 48 

24 

55 56 

57 58 59 60 61 

SIGNATURE 
-D-ATE r :& <*-n—<L6f—/L?_r/_ METHOD 9 FIELD STUDY II I 

GENERATOR DATA FOJIM A 

TEST 

II 

001 

002 

003 

004 

005 

00 6 

007 

008 

009 

01.0 

O U 

012 

013 

OH 

015 

016 

017 

010 

TEST 

TYPE 

1 

2 

0 

3 

1 

1 

3 

3 

2 

4 

5 

5 

6 

4 

4 

6 

6 

5 

• 

TIME PERIOD 

DESIGNATED 

OPACITY 

20% ris e 

30% fal l 

30% ris e 

40%: ris e 

20% fal l 

20% ris e 

'10% fal l 

4 0% ris e 

3 0% ris e 

20% ris e 

30% fal l 

30% ris e 

'10% ris e 

20% fal l 

20% ris e 

40% fal l 

4 0% ris e 

30% ris e 

GENERATOR 

OPERATOR 

o& 

o Z^ 

Od. 

OV 

OA 

QZ 

O ?^ 

6 L 

O 7 _ 

O Z 

o ^ 

o £ 

O 'L 

6 7, 

o Z. 

o t 

O 1^ 

o V 

£MA*3 

TIME 

•JftdG 

//: W 

it: oz 

ia: /£> 

tun 

H*\ 

/; Y& 

2 *, o ?> 

2; n 

?; 3 V 

?\ J-2 

/c?; o 9 

/t'.zy 

/o :so 

//: ov 

3: o3 

3\ /9 

J:* Y 

RECORDER 

CHART SPEED 

/ /H p<\- Mia*) 

/(•S j(>/.y />£_/_ 

/_J__ fit*} /fO-^) 

IJy ,dcf\ sttU-t/ 

/ 

/_*_._ -4*. ^JT-aA • 

1 *-HJ 'AMI A\IAA • 

/Ac*i f>±\ 'nul*\.i 

/ ^U -fZlr, <PiAj 

-*('i pet- *tn 

J t'l __»«•>- At\'r) 

At An -Oct- mA<i 

3 A *>{*• /Hi'rt 

Jl't SIC*. /tXlfa 

1 irx pe±- mt'A 

111. at I- M iri 

AL t'n >'*•*' ^' *l 

J. *4 yjiy\ _**_A^ 

COMMENTS 
P.45 

A 

PLUME CONFIGURATION 

METHOD 9 FIELD STUDY III 

JACKSONVILLE, FLORIDA 

TEST TYPE olol I TEST # 

0 

p 

A 

C 

I 

T 

y 

100 

io 

IS 

-H-H-f-fi-1-r: T - r 

:cn_r * 

s i ag±[ I ,-n ; 'Tfegf-ftilrtTfT^ 

-r-r 

SS-S 

affipM i 1 

§ 

-r-H-HH-H-i4HW-7 - H- mm±am i?gg rlr-^r 

-w TT.-*rr 

mrt-

-f-f-M-HrMINUTES 

10 11 12 
P.46 

PLUME CONFIGURATIO

A 

N 

METHOD 9 FIELD STUDY III 

JACKSONVILLE, FLORIDA 

© TEST TYPE InhlJl TEST 

100 

0 

P 

A 

C 

I 

T 

y 

r r -» - 0 

MINUTES 

 
P.47 

A 

PLUME CONFIGURATION 

METHOD 9 FIELD STUDY III 

JACKSONVILLE, FLORIDA 

\ol\ \o o L3 _. ^ 

100 

0 

p 

A 

C 

T 

y 

MINUTE S 
P.48 

PLUME CONFIGURATIO

A 

N 

METHOD 9 FIELD STUDY III 

JACKSONVILLE, FLORIDA 

3 TEST TYPE 0 AA± TEST 

100 

0 

p 

A 

C 

I 

T 

y 

MINUTES8 
P.49 

A 

PLUME CONFIGURATION 

METHOD 9 FIELD STUDY III 

JACKSONVILLE, FLORIDA 

TEST TYPE o 1 o l.C TEST 

0 

p 

A 

C 

I 

T 

y 

100 

20 

••J-I-.I; 

•hi -r-H-.-H , i '-'7-1 m= 

.1 '•••jJj. i 

T-P-' 

.ffi 

..... ,-r-r-r...... . i '•[•;••;••':'••>,:•':•''•;-;•_••• . 

OTX CTS r;. .j- L 

ill 1 \-\~Lt~ X U 

ffl Tri-) : 

x_q: 

::^y_l±j±i=r±14 

!-::{*:•+•'-'•*H- i .-r-f- — r 

k#m±tt rr T—r. 

i ; l ' 

ggpgjji 

:

FH-i-';:"!:' : :r 

±±± 

WW 

i ; I i I I. 

i i i i :4 -

.._A"LJ-AA 

• •••-,»^F-.-;-i-pPt—)• 

? r.l; ! T-f . , IMINUTES 

:o 
P.50 

A 

PLUME CONFIGURATION 

METHOD 9 FIELD STUDY II I 

JACKSONVILLE, FLORIDA 

fr^ T Tvp r O 0 b TEST „ 

0 

C 

T 

y 

100 

1 

.TTTT 

!.*}T 

L.I i I ) TT'-J-. 

; I .' ; • U-* -4-r-H-

_fi i iJA:lM^9^HBtB^AAiAAm 

>n JJ-

• l;- j ; I'. ffffi*im^k-«3^ 

20 

10 

r-iH-j-j-r-r- r 

£E sae nvi-.rr.FHMr-.v;.-L;:T 

'•'•".U-i1 

4-f 

H-H-t ' : I 1 TH 

III ! 

—'-*-

-H-

•

 :* - ~ .i.i-i -

• ••l-rn- i . ' i +*__+ 

•R-!-

ro: 

x_t L'.i i-l-. l.-T-O 

__•_____. ' i__ ••_•_ _ i ___L*______ ! i": i r 

-i-H-Hi . ••!•!• ! 

-£ 

t-t- i _• i FR PPH-i-H-4-1 ! i i l • - P 

4 - M L-.H i..'..J_i_i4_l__V_l__H_i_._f_ 

J t I * 1 I ' . I IjlTMI I • -J I I I 

I_:.J_:..,_i_i_-_i .-j i-j i t—i i J i l. ; ' • i.'-—__4.—...;.-r.. -

i .,.;,• .; :._.H-f-t|4-^44-Mq--pd^irf|.: j. . r"-.—-r—r-H'T-; i . i-i r, ! . : i !' i i 1—r~: :•(•:•• •••-r---- --T-i .' i < i . i ! i I I. ! i I . . • I i i -r-r-- •ri---r 

m 

s 

5EB5E" 

MJPTES 

10 11 12 
P.51 

A 

PLUME CONFIGURATION 

METHOD 9 FIELD STUDY III 

JACKSONVILLE, FLORIDA 

3 TEST TYPE 0\0\1 I TEST 

100 

0 

A 

C 

I 

T 

y 

I-!:/-'*!:!* H3#* # i j' I I i-J'-I 

1 I I I 

; i : i.,- r_***_:.-l\^.i..j. . - .i.l.i.•>•}-|-i•—:•.J-i-i. 

Hrt±;\J:.::;- :1 HJdio-_:irir__i_;-

M'INUTES8' 

10 1 I I ? 
P.52 

PLUME CONFIGURATIO

A 

N 

METHOD 9 FIELD STUDY III 

JACKSONVILLE, FLORIDA 

J T^ST TYPE o\o\x TEST 

100 

0 

P 

A 

C 

I 

T 

y 

MINUTES 
=2 

A 

PLUME CONFIGURATION 

METHOD 9 FIELD STUDY III 

JACKSONVILLE, FLORIDA 

TEST TYPE O 0 °\ 

A 

TES. 

100 

0 

A 

C 

I 

T 

y 

tAB^^^m 3SS frivr n-P-t-j 

-1-. • JH-r-> -

. ; i ' i I ,' i i I ; I I i i I I )• ! '• ;I : t-r 

ffH: 

•3^-pp: •••)*:^.^:r*: 

jj._.. . 

4 5 6 7 :8 

MINUTES 

10 11 12 
A 

PLUME CONFIGURATION 

METHOD 9 FIELD STUDY II I 

JACKSONVILLE, FLORIDA 

P.54 

f TEST TYPE Oil 0 TEST 

0 

P 

A 

C 

T 

y 

100 

20 

IO 

:.,'. ' rm.l. .-.i.-L-i.:-.hl..j*.— • -. . :.i-.|-.1-i-f..i.i^i.-l,-i..i-.-l-l.:i.--.l.:'l.-.l--.i-- .^- •••.'. -i.-Trr-: 

i.l.l.l:.i.:!.f:id:H"H;b);:^ 

—i—r—r —',i..r:i-I..M_j-**r 

i--:--lrr\,j)<Jt:-! i •'•!•;" ) I • i"^JqT! i -; " 7'-—' 

I •'. i . S ffi 

i£H-r± 

' • "IS-f-^*"* '1^11111 

-f-HM:!T 

• . 7TTT T 

•'-•-• -

:i±t 

r t r 

£3 

rtr 

? I)I H-4-I + 

j . • SS -f-H-f 

j i ) I i i " I i ' i-Hr- rr--r:- ;:U-y.r.i:zm3+t l 

SHE" 

MINUTES 

10 11 12 
.-. . -ry .- i-i~-''TT" 

A 

PLUME CONFIGURATION 

METHOD 9 FIELD STUDY III 

JACKSONVILLE, FLORIDA 

P.55 

-t6 TEST TYPE O I I TEST 

100 

0 

P 

c 

T 

y 

20 

10 

UUJ 11; i-^jn*};*.;|Tr.:r;-^*^ 

•WH I ; • n -

fe#^ . i i i i . r 

'•ni l 

' • • i i : i. 

rr 

-Hi\i:) i-v:-ffl7^ 

|:JJ.TTTI.-

-^r-t^^H-H HL^Hit±j-M; . p^ /-raro 

k-*^:ri±tf±jtrl iff l4Jdtt^L±i±tr±^S±& 

H-H-i-H1 2 3 4 5 6 7 :S g 

MINUTE S 

10 11 12 
PLUME CONFIGURATION 

METHOD 9 FIELD STUDY II I 

JACKSONVILLE, FLORIDA 

P.56 

; ^ i -•vc*' •0/2 -

. r < -. 

100 

0 

P 

A 

C 

I 

T 

y 

:

 ' ' - : - - - - - - - - • " - •• 

MINUTE S 
(o 

•1 

A 

PLUME CONFIGURATION 

METHOD 9 FIELD STUDY III 

JACKSONVILLE, FLORIDA 

TEST TYPE 0 I 3 TEST 

100 

0 

P 

A 

C 

I 

T 

y 

AJJj\±BiS^±r±ti 

!' i .'.' ; rr 

immisA 

MINUTES 

10 n 12 
A 

PLUME CONFIGURATION 

METHOD 9 FIELD STUDY III 

JACKSONVILLE, FLORIDA 

f TEST TYPE 

2 

I 3 TC'- p 

100 

0 

P 

A 

C 

T 

y 

AJp-^^±P^tnT^At-\ 

r • • ' • . i i i i . . . i . • i i i i • ' . i 

iJl'Aj"- :.J^:-;=.:;|: ^-/---r-i^-^f-f-f1 2 

MINUTES' 

10 11 12 
•-•p:--^":»p*-s?T: 

A 

PLUME CONFIGURATION 

METHOD 9 FIELD STUDY II I 

JACKSONVILLE, FLORIDA 

P.59 

f TEST TYPE 0 I S fPg T 

100 

0 

P 

c 

T 

y 

rat-mm 

J-iH -1-rr-R-JTfT11; : 

r-H— ) • i I ) • I '• •' . M l I •' I 

g-3r-ff:*p;^:r^^ 

' - .-•- T -—»-•• * .• . -••*••••• • T ' *•' ' ,* i ' • • • 'i"i—*—T—: — 

•H-H-f-r-. f-r-H-T-T-; 

-f-r-: T7---I 

fl^Tteff 

MINUTES 

10 ll - -> 
P.60 

A 

PLUME CONFIGURATION 

METHOD 9 FIELD STUDY II I 

JACKSONVILLE, FLORIDA 

U TEST TYPE 

• •.._.. _ I I . I. - !->»• 

0 I b TEST 

0 

C 

T 

y 

100 

40~' £> if 

. J . •. j I tl, * . M J 

-H-)—i--

30 H i 

B=nr LflJiHJ : 

20 -h-H-f*^ 

i 

^rifmtt 

^.Jr|:-|.-<:;l;.m:j^^ 

vf^ i • •Ti-*!.-.-

mmmm*^ 

r-r 

£&£ 

f/% 

:i„L.ijLi.TUi:^J.|;L..J/.i.:i>i..;J.: 4' : •• M.^'-j«f'- -f-f-'--•-?-•••(>-/-J---±r: 

"rrJirk 

ffi 

*T***r £ ^ ^ 

•n-rrt" 

r-r'••!' Ai J rJ-J-

±£ -r*ri

-|JJ---U? 

-f-H-l ••)•.' ; i ; t 

f+-Hr '• i i i • SI—J. 

• • ; * J:-f•• » • / 

H-H-f-r 

10 

^#s^ 

rrt t S 

« 

: l . i I I . I I I -f-r- 1 • I

i

 f

 i r

t S

v 

 •S I • • I fr- i l I i I I I I ' l •—*—.'— •-»—= 

±ri±H±fci±t*Hi-

: :"J-:-;.i-l-i-l il l J-TTViU..CT:-\S-i^.j—.^..J.71ZL^^^-i-,-\-+Z-i—L-i.. 

• • •-rt-f-i-l; H I ;.' i-ffF': •':; N-:-jA-A-!-,-?JAj-J:¥++:+-r--

. I •• — • ' — •••! • 

T T ; i i ! 

-T-4 

UW' ' t n 

A7rJ±$#±lA Th^T FttlAZ: 

'.!• ; 

i • i : i : i 

An±bWB±Hr': 

u-J-, :\ 'J 1 irj-J-1/1'; 'lAlZlliAi-Sj''\~T • !' H 

ii^W—w2B*L. 

MINUTES'8 ic 11 12 
#W:?-J.*''""**"W '"(""Vf VX.'^f^-'Y' 

A 

PLUME CONFIGURATION 

METHOD 9 FIELD STUDY II I 

JACKSONVILLE, FLORIDA 

P.61 

(c TEST TYPE Q\l 7 TEST 

0 

P 

A 

c 

I 

T 

y 

100 

1

 i ' V • '-• f [••'•• t-

|

'f-bH--i^l--/' ,-

l

- > t- -

i

-

l

'i-'--^"ii''»^r-prl''i-l>i-l-.! . '-!-••• •• 

. . i . ...••.••:••.•-.• ,..- r .--,.../.. | .i-upT.,-..!.-.,.;- •—-<•••• •Vi"-;-1- •>-•. - T-I-,;- il l I I- i 

20t£E±ki iiirfer 

10 

iij . i-i — 

-4—r 

4-t-

, , II- I i" 

l£.i:lJ\JAth\JA;.,JJAl&77\77-:7i7:+^j 

•r\-/\'\ i >.AJ-A-' A\-')J\-Air'AJ\J.h3^T 

±Jr: 

T T f 

•i i ; 

-r-;-

-n~ r rfe 

•i-+-

:n3= ! I J ~l ! I I I I I I I I ' I 

ArJs±\ 

I.:.!_: . 

!• '--i 

M ! i.l i I 

• • i 

r*rr: 

-!•<?; ^f4 ') • •' H 'I •' 7-1-:-J-J-J-1 i i t L^^-Li-a=rT 

•jA-hhhrrTiJJ- : I :-RT-l^-H-T-m^-r-f--^H-4-f-t--f-.'-

F - •••! -I '• i . 

I . 1 - I • I . I • •• • 

nrcr ! J J 

• i i i i I-J—• . 

H—11!:! — •• i 

"H* 

M'INUTES 8 10 12 
P.62 

A 

PLUME CONFIGURATION 

METHOD 9 FIELD STUDY III 

JACKSONVILLE, FLORIDA 

S TES* 0 1 % 

300 

0 

P 

A 

C 

I 

T 

y 

L^i.-j-i.i.^. i i i '_u.'-^-!_: ; ; i • ; i-l.; i •• t-1-i...-.j-i-^.J.,1 ,' i..-' .' • • ,- I l i-i ' .' 

•:••. • I • .- .-[-H-i,-

L

f-rn ; ; HTfTTi ; N-;-i-H-H-:-H-)^--p1-->-l-f-^-^-fj.-::;?;vj:!-r.i:t.:

 .r*-r+i~fp, : j :' ; ; -J^^H-i- •'•';t: j^I'J^nAitrsi^ 

jAWzi 

1 2 5 4 5 G 7 :S 9 10 11 

MINUTES 
APPENDIX C 

Meteorological Data 
P.64 

P.66 
npuieo U.i. DGPflDTCJGMT OP COeaGQCIZ 

MOAA 

C3AYIOC3AL OeATMEf t SERVICE 

SUQPACG oaaTwao oosaavATioas I - I [o -& ' 

==__—__ _ „ .^^^ ^ 

1TflTIO T, J T 

l o Ci 

AOO 

LST io O-T 

h,o. SUBTRACT 

<^^ci!2^0ruAiUii- ~^A 

h liiMMBBB-JBlli i lilll -- - ~-.*a*-MA*A*m~m mmt .I,.»V.„*l»^.i>lUtlUi.A, IJJIII . 1 J 
P.68 

•***.<->• *v oc t **-e *-»0 

SURFACf WCATHCH 06S£RVATK)MS 

1. 0«*A«**T»«-T O* CO«M»CC 

*t«OI»M a< C • -**-••-*•»•••• 'WSO. JACKSONVILLE. FLA 

JAN 1 7 1,981 rocowfjr LIT roast 

*O0 1Jj» i 5</« TRACT. 

MT AMO CIlCIMC 

• Ilia d 

• NO 

otiraucnoa 

TO viilOw 

i t * 

LlVf L fit . 

t t l 

•taAMl UO UVMrfu m COMO OAT* # 

. /£ • ^ &£ 3/ ; <S^; ?/? _C2©*2 ,-££_ <u: 

(, ^TW* . J^-rOJ 2l?ti<r i^tjal'O S'xooc 6XW."> W.oiV^^gk - -/yog- ^r , ^IZJ T 

JCL 

IA 

2JL I 

£32jZ 

£44 £ 

* * ?**&« 

>VX 

tdS. 

to MW. &A ?&/,/&'. O— ScST tu4 14. 

JA *&.&&%&?• S25. ^1., >?/ 

Mt'frtHrr Wtet 7rx £1 

<L£»2s> 2&OI CC&Z2- gfllXLdM'Jl 4.'<^4j7c3l > CO-Q, r& 

S3-L in 

lA aa UL 

13. ZZrllLL 

sri/fl! afc 

a ^ Ax -. 

<£ 

£C ifl gag./fcyj/y.*ratt a 

•^fl-ScT " z£ . £1 s&r-tf 2-^sr?X 

Sf.r .&. ££<4 /t tf?/ i/3 ; S J Sl 

tenzo. -JA UAL mvsL IL X'tf •' 03j //•V /oo/ 37 . CL 

> ' 7210 1 1-tt.gf 6£<Or) ^<y^ 7 ^C3gZ j-OtP^ifl k3.1£.<£ V^-yp. rti*TLMJ PISJS <*S-XP £ i f o - .vrr A ^ G 

fc£5 CuK ZJ 

.ism/i. 

I S 

£2 

lfl. 

2AyAL£&l2l 

35| h *iZ f-ffyg/ 

-2^ 1 5 Zflt Z/. 35-.3 ^ f / o Agl 

2^ 

ia. 

a 

Cl/g, 

TX*- i£ u UL n 

fin 

ML 

2a ILL 

&MZ 

L olWl U&te 27/fi3 ctfc? /*, 

& i»«; 

^ 

GUO 

2Q 

42 

m. 

J3ZL,1. 4^£5 

3&" I %A& fe /BJC . 

, /o 

SSI 

<?52 

533 

22855 

^ r//te 

tO 34 

LL 

H 

IL 

lW& 

3t3t 

# > • 

&jfS_C2k f 

<*& 

^DA "guZD" 

L£ 

/o 

Z2. zi i QH 

& 

m 

QS. SA 

& 

WL. 

m 

P.70 

APPENDIX D 

Data Summary 
P.71 

• 

* 

TA3LE D-1 

Test Data 

White Smoke 

Observer 

T* 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

Time >.20% Opacity, Sec. 

Run 

1 2 3 4 5 

165 

270 

360 

255 

360 

360 

285 

345 

345 

360 

300 

225 

360 

360 

360 

360 

360 

255 

360 

255 

360 

360 

255 

360 

360 

330 

360 

360 

360 

360 

345 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

transmissometer 

Averaqe 

1 2 

20 

22 

31 

21 

36 

28 

22 

27 

25 

36 

25 

26 

32 

33 

37 

31 

33 

24 

32 

24 

34 

33 

Opacity, 

Run 

3 

25 

28 

31 

28 

34 

40 

32 

34 

26 

34 

44 

% . 

Percent 

4 5 

36 

38 

40 

38 

53 

48 

42 

41 

36 

41 

49 

30 

38 

32 

33 

57 

34 

27 

36 

26 

37 

44 
TABLE D-1 (Cont.) 

P.72 

Observer 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

Time 220% Opacity, Sec. 

Run 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

315 

360 

360 

360 

360 

360 

345 

360 

360 

360 

360 

255 

315 

300 

270 

315 

345 

330 

360 

300 

315 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

Average Opacity, Percent 

Run 

8 

30 

39 

32 

38 

39 

36 

31 

36 

26 

40 

50 

30 

46 

38 

38 

55 

39 

28 

36 

30 

37 

53 

27 

32 

28 

27 

41 

31 

32 

35 

29 

' 39 

40 

38 

46 

46 

39 

63 

40 

39 

42 

39 

47 

50 

* Transmissometer 
P.73 

TABLE D-2 

Test Data 

' 

Black Smoke 

Observer 

T* 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

Time 220% Opacity, Sec. 

Run 

10 11 12 13 14 

360 

30 

360 ' 

75 

360 

360 

360 

360 

360 

360 

360 

270 

90 

240 

180 

360 

330 

345 

270 

165 

225 

240 

285 

90 

225 

30 

360 

330 

345 

345 

300 

255 

315 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

195 

285 

210 

360 

360 

270 

345 

180 

255 

255 

* Transmi ssometer 

Average 

10 11 

27 

15 

28 

13 

57 

39 

37 

32 

28 

27 

41 

25 

14 

22 

22 

45 

27 

31 

23 

16 

22 

26 

Opacity, 

Run 

12 

26 

14 

22 

12 

50 

28 

32 

29 

24 

26 

32 

% • 

# 

Percent 

13 14 

42 

29 

39 

29 

71 

39 

49 

42 

33 

52 

46 

28 

17 

27 

16 

44 

29 

22 

26 

17 

27 

31 
TABLE D-2 (Cont.) 

Observer 

1 

2 

3 

4 

5 

6 

7 

8 

9 

'lO 

Time 2.20% Opacity, Sec, 

15 

360 

255 

300 

15 

360 

360 

360 

360 

330 

345 

360 

16 

255 

315 

315 

105 

300 

285 

270 

300 

255 

345 

315 

Run 

17 

210 

285 

360 

165 

360 

345 

360 

360 

285 

360 

360 

18 

345 

360 

360 

225 

360 

360 

360 

360 

360 

360 

360 

Average Opacity, Percent 

15 16 

Run 

17 

31 

19 

23 

.11 

42 

29 

27 

29 

23 

26 

36 

24 

35 

27 

14 

27 

21 

24 

26 

19 

29 

35 

28 

27 

34 

20 

42 

27 

31 

31 

26 

31 

44 

18 

36 

39 

35 

25 

43 

35 

40 

35 

38 

31 

45 

* Transmissometer 
P.75 

APPENDIX E 

Participants 
P.76 

Observer 

Martha Ann Allen 

Ed Balducci 

Thomas Barzyk 

Robert Dennis, Jr. 

Kathleen S. Gaston 

George H. Hawkins 

Daniel Jackson 

Judith Mai comb 

John J. Mello 

Donal C. Summerfield 

Affiliation 

City of Jacksonville 

City of Jacksonville 

City of Jacksonville 

Jacksonville Electric Authority 

City of Jacksonville 

City of Jacksonville 

Jacksonville Electric Authority 

City of Jacksonville 

Jacksonville Electric Authority 

City of Jacksonville