OAR Box 1115 

Prepped by Ryan Dugan 

Document Number: 

85) ll-A-17 

Docket Number: 

A-84-22 

Printed 4/18/2008 10:52:09 AM 

-

Sheet 85 of 94 

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d * 

United States 

Environmental Protection 

Agency ' j 

(tf vrv^f 

EPA 500/4-83-011 

Research and 

Development 

TECHNICAL ASSISTANCE DOCUMENT: QUALITY ASSURANCE GUIDELINE 

FOR VISIBLE EMISSION TRAINING PROGRAMS 

Prepared for 

OFFICE OF AIR, RADIATION AND NOISE 

DIVISION OF STATIONARY SOURCE ENFORCEMENT 

TECHNICAL SUPPORT BRANCH 

Prepared by 

Environmental Monitoring Systems 

Laboratory 

Research Triangie Park NC 27711 
P.3 

' Project Summary 

QUALITY ASSURANCE GUIDELINE FOR. 

VISIBLE EMISSION TRAINING PROGRAMS 

Prepared by 

PEDCo Environmental, Inc. 

505 South Duke Street 

Durham, North Carolina 27701 

Contract No. 68-02-3431 

Project Officers 

Thomas J. Logan 

Quality Assurance Division 

Environmental Monitoring Systems Laboratory 

and 

Kirk E. Foster 

Division of Stationary Source Enforcement 

ENVIRONMENTAL MONITORING SYSTEMS LABORATORY 

OFFICE OF RESEARCH AND DEVELOPMENT 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NORTH CAROLINA 27711 
P.4 

ABSTRACT 

This document describes procedures and outlines technical guidance for 

assistance in establishing effective visible emission observer training programs. Smoke generator operating information is presented and appendices 

give examples of sample classroom training lectures as well as audit forms 

and statistical techniques used to access the quality of a training program. 

The adherence of visible emissions training programs to the materials in this 

document should result in improved and consistent levels of observer training. 

This documentation will aid enforcement programs in demonstrating that the 

observers were trained without biases and in a professional manner. 

SUMMARY 

EPA reference method 9 for visible emission observations requires that 

field inspectors and observers document their reading skills by periodic 

participation in a rigorous smoke training and certification program. It is 

therefore essential that visible emission (VE) observers continue to have the 

benefit of high quality training and testing. The document described in this 

summary isintended for individuals responsible for the general-conduct of 

VE training and certification program, and includes detailed information on 

recommended Quality Assurance (QA) procedures. 

The implementation of these procedures requires an understanding of the 

elements of an effective QA Program and its relationship to smoke training 

and certification. By definition, Quality Assurance is the total integrated 

program that assures reliability and credibility in opacity training and certification. It therfore should be structured into all aspects of the program 

including the initial planning and execution of the classroom training; the 
P.5 

acquisition, calibration, and operation of the smoke generator; the field 

training and certification;'and the reduction of data and maintenance of 

records. •* 

In concept and implementation, the QA program is a management tool or 

operational mechanism for assuring credible training and certification. To 

ensure success, this program must receive the commitment, support, and fallowup of management. 

DESCRIPTION OF QUALITY ASSURANCE PROGRAM 

The QA program consists of two distinct program operations, quality 

control (QC) procedures and auditing, that are complementary and mutually supportive. The program of QC procedures is operated integrally with the presentation of the smoke school, focusing on the operation of the smoke generator. 

This program provides the documented procedures which ensure routinely accurate 

and reliable training and certification including program planning; preparation, calibration, and operation of the generator; recordkeeping and documentation; and trainee control. 

The other important element of a QA program is auditing. A VE program 

audit is an external review of the program using structured evaluation forms. 

The audit is usually conducted by supervisory personnel to assure objectivity. 

Audits are designed to identify program weaknesses and deficiencies that must 

be addressed and corrected in order to maintain an effective and high quality 

opacity training and certification program. 

The Performance Audit is the structured and routine review of the various 

steps in the training and certification process. It generally consists of a 

number of specified checks to insure that proper and accurate procedural ac-
tivities have been completed. The Performance Audit is conducted by the 

Training Supervisor and/or designated staff, and is most applicable to fairly 

specific and routine procedures. Example formats for inspection and-operation 

of the smoke generator/transmissometer unit and the handling of certification 

test records are included in the report. In any audit situation, checklists 

should be devised for each specific activity. 

Records pertinent to the audit must be completed and maintained as part 

of the agency's official documentation file. The generator operating log, 

smoke school file, and other records are also components of the documentation 

and recordkeeping process. The importance of the Performance Audit as an 

integral part of the activity cannot be overemphasized as vital to training 

and certification efforts. This audit provides assurance that the requirements of Method 9 have been fulfilled and that a sound and high quality program has been provided. 

Complementary to the Performance Audit is the System Audit. The System 

Audit is conducted periodically, perhaps on an annual basis, through an onsite 

comprehensive review of the total smoke school program. This audit should be 

conducted to assess all aspects of the training activity and should identify 

problems that can be corrected. The System'.Audit preferably should be conducted by personnel outside the smoke school staff, i.e., Enforcement Program 

'Manager and/or EPA Regional Office personnel. Participation by the Enforcement Program Manager is preferable because opacity certification directly 

impacts and supports the day-to-day enforcement/compliance operation; more 

than 90 percent of particulate emissions compliance is determined and documented 

by opacity readings. Participation by enforcement management also provides a 

needed element of management involvement and concern. The smoke school is 

typically a service provided by the Technical Support Division. 
P.7 

A System Audit should have a positive impact on the training program and 

also should provide a mechartism.for management to gain needed program familiari 

zation. It can*also be used as a planning document to assist agencies in 

obtaining the support to update training materials and equipment. 

To assist in a systematic review, an itemized audit form should be used. 

An example is included in the report. The checklist approach assures thaj*-

all aspects of the program are evaluated and lends itself to the expedient 

preparation of an audit report. The form should be attached to a brief narra- • 

tive that summarizes the findings, conclusions, and recommendations. Post 

audit followup on the important recommendations is essential to assure that 

proper corrective actions have been taken. 
This report was prepared by Barbara E. Blagun, PEDCo Environmental, Inc., 

Durham, N.C. 27701. It was.based on work prepared by several contractors including Messrs. Norman Edminston, Robert Missen, .Thomas Rose, and Willie Lee. 

The complete report entitled, "Quality Assurance Guideline for Visible 

Emission Training Programs", (Order No. PB , cost:..$ , subject to 

change) will be available from: 

National Technical Information Service 

5285 Port Royal Road 

Springfield, VA 22161 

Telephone: 703-557-4650 

For information, contact: 

Thomas J. Logan 

Quality Assurance Division (MD-77) 

Environmental Monitoring Systems Laboratory 

U.S. Environmental Protection Agency 

Research Triangle Park, North Carolina 27711 
P.9 

RECOMMENDED QUALITY ASSURANCE TECHNIQUES 

AND PROCEDURES FOR VISIBLE EMISSION 

TRAINING PROGRAMS 

by 

PEDCo Environmental, Inc. 

505 South Duke Street 

Durham, North Carolina 27701 

Contract No. 68-02-3431 

Work Assignment No. 182 

PN 3529-47 

Project Officers 

Thomas J. Logan 

Quality Assurance Division 

Environmental Monitoring Systems Laboratory 

and 

Kirk E. Foster 

Division of Stationary Source Enforcement 

ENVIRONMENTAL MONITORING SYSTEMS LABORATORY 

OFFICE OF RESEARCH AND DEVELOPMENT 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NORTH CAROLINA 27711 

May 1982 
P.10 

DISCLAIMER 

This report has been reviewed by the Environmental Monitoring Systems 

Laboratory, U.S. Environmental Protection Agency, and approved for publication. Approval does not signify that the contents necessarily reflect the 

views and policies of the U.S. Environmental Protection Agency, nor does 

mention of trade names or commercial products constitute endorsement or recommendation for use. This report provides suggestions and guidelines for 

person's involved in observer certification and visible emission evaluation 

and is not a supplement to EPA Reference Method 9. Valid observations can 

still be made even though all recommendations herein are not completely 

followed. 

n 
P.11 

CONTENTS 

Figures 

Tables 

Acknowledgment 

1. 

2. 

3. 

4. 

5. 

6. 

Introduction 

Organization, Planning, and Training Announcements 

Organization 

Planning 

Training announcements 

Classroom Training 

Example lecture material 

Training Equipment 

Method 9 design and operating specifications 

Smoke generator 

Transmissometer 

Setup, operation, and shutdown procedures 

Storage and maintenance of the smoke generator 

Common problems, hazards, and corrective actions 

Certification Requirements 

Practice sessions 

Certification testing 

Grading and documentation procedures 

Quality Assurance - Techniques and Procedures 

Paje. 

v 

vii 

viii 

1 

2 

2 

2 

2 

4 

5 

7 

7 

8 

13 

32 

45 

47 

53 

•54 

57 

69 

77 

Quality assurance audits 

Quality assurance for classroom training 

Quality assurance for certification procedures 

Tracking program quality 

7. Visible Emissions Training Literature 

77 

79 

80 

80 

87 

m 
P.12 

CONTENTS (continued) 

Appendix A Sample lectures for VE training program 

Appendix B Performance audit and system audit 

Appendix C Analysis and example calculations of VE training 

program errors 

Page 

89 

122 

142 

iv 
P.13 

FIGURES 

Number Page 

1 Example Schematic Layout of a Simple Generator 9 

2 Smoke Generator Component List 10 

3 White Smoke Generating Equipment 12 

4 Black Smoke Generating Equipment 14 

5 Transmissometer 15 

6 Example Response Time Check Form 17 

7 Calibration Wand 18 

8 Calibration Error Check Form 20 

9 Neutral-Density Filter Form 21 

10 Smoke Generator Performance Evaluation Data Form 23 

11 Example Light Source 25 

12 Typical Photocell Schematic 25 

13 Examples of Acceptable and Unacceptable Smoke Stability 

Conditions 31 

14 Recommended Calibration Stamp 32 

15 Part and Supply Checklist 33' 

16 Example Generator Operation Procedure 35 

17 Electronic Panel of Smoke Generator Control Console 36 

18 Procedure for Practice Session 55 

19 Opacity Reading Training Form 56* 

20 Operator's Smoke Generator Checklist 59 

21 Sample Certification Test Form 62 

22 Example Completed Certification Test Form 64 
P.14 

FIGURES (continued) 

Number Page 

23 . Beaufort Scale of Wind Force 65 

24 Certification Run Identification Stamp 68 

25 Two Methods for Determining Average Deviation for 25 

Readings 71 

26 Certification Stamp 73 

27 Sample VE Program Roster 74 

28 Certification Letter 76 

29 List of Statistics Useful in Evaluating VE Training 

Schools 83 

30 Example Control Chart for Tracking Training School 

Performance 84 

31 Statistics Checklist Form 85 

vi 
P.15 

Number 

TABLES 

Page 

1 Transmissometer Design and Performance Specifications 8 

2 Properties of Candidate Fuels 48 

3 Common Smoke Generator Malfunctions 50 

4 Average Deviation Chart 70 

vn 
P.16 

ACKNOWLEDGMENT 

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

Division of Stationary Source Enforcement, and the Environmental Monitoring 

Systems Laboratory, Research Triangle Park, North Carolina, by PEDCo Environmental, Inc., Cincinnati, Ohio. It was based on technical work prepared by 

several contractors. Accordingly, appreciation for contributions is given to 

Mr. Norman Edmisten, formerly of Del Green Associates, Inc., Mr. Robert Missen, 

formerly of Pacific Environmental Services, and Messrs. Thomas Rose and Willie 

Lee of Eastern Technical Associates. 

The project was directed at PEDCo by Mr. Carl Nelson, and managed by 

Ms. Barbara Blagun. The principal editor, Ms. Barbara Blagun, would like to 

express her appreciation for the invaluable guidance and assistance provided 

by Dr. John Richards, formerly of PEDCo Environmental, and Messrs. Thomas 

Logan and Kirk Foster who served as project officers for the U.S. Environmental 

Protection Agency. 

vm 
P.17 

SECTION 1 

INTRODUCTION 

Visual observation of plume opacities is currently the most effective 

and economical method of determining compliance with opacity-based air pollution control regulations. It is one of the primary enforcement tools used in 

the United States to determine compliance with particulate emission regulations. The legality and credibility of this method have repeatedly been upheld in court. Recently, however, industry has begun to exercise their rights 

by challenging the techniques used to read plume opacity. Due to the role of 

visible emissions (VE) observations in compliance and enforcement of air 

pollution control laws, it is imperative that personnel conducting these observations make accurate and defensible readings. 

Field inspectors and observers are required to document their plume reading skills by periodic participation in a rigorous smoke training and certification program. It is therefore essential that VE observers continue to have 

the benefit of high-quality training and testing. Accordingly, EPA's Division of Stationary Source Enforcement (DSSE) and the Environmental Monitoring 

Systems Laboratory (EMSL) have furnished this document to individuals responsible for the general conduct of the VE training and certification program. 
P.18 

SECTION 2 

ORGANIZATION, PLANNING, AND TRAINING ANNOUNCEMENTS 

2.1 ORGANIZATION 

To ensure a coordinated and consistent program one agency training supervisor should have overall responsibility for the smoke training and certification program. This person will likely need the support of at least two 

other people, the smoke generator operator and the operator's assistant. The 

smoke generator operator will be responsible for the preparation, maintenance, 

calibration, and operation of the generator. His assistant will be responsible for documenting, reading, grading papers, and monitoring trainees. The 

roles of training supervisor and smoke generator operator could be combined 

if the classes are held only two or three times a year. 

2.2 PLANNING 

Planning the year's training and certification program is an essential 

aspect of any successful program. Although the number and frequency of 

training sessions ,will be partly determined by past experiences and demands, 

•the school should be scheduled at least twice each year to accommodate persons needing semiannual recertification. Certifying previous graduates 

while the smoke school is in operation is more efficient and less costly 

than scheduling a separate session. A summer/winter schedule is generally less 

desirable than a spring/fall schedule because of adverse weather conditions 

as well as the need to prepare inspectors for the heavy spring/summer source 

compliance activities. 

2.3 TRAINING ANNOUNCEMENTS 

Because VE training is an expensive program, it is important to provide 

a high-quality training program and to have the greatest number of students 
P.19 

possible. All local air pollution control agencies within the State or area 

should be sent in advance a copy of the training schedule, a brief discussion 

of course content, and a breakdown of the cost per trainee. In addition, 

industry, trade associations, and journals generally publish such information, 

as a service to their membership. Personnel at major industries and problem 

sources may be extended a special invitation. Public service notices may be 

submitted to several newspapers and should include a request for preregistration by interested individuals. Following these steps gives an indication 

of student load and establishes a point of contact for any followup notices. 
P.20 

SECTION 3 

CLASSROOM TRAINING 

Classroom training program is an essential part of any smoke reading 

certification program. This training, which is most effectively completed 

with an intensive 1- or 2-day classroom lecture/discussion session, is 

beneficial for the following reasons: 

1. It increases the visible emission observers' knowledge and confidence for the day-to-day field practice and application. 

2. It reduces training time required to achieve certification. 

3. It trains the smoke reader to properly record and present 

evidence that will withstand the rigors of litigation, and 

greatly strengthens an Agency's compliance and enforcement 

program. 

4. . It provides a forum for the periodic exchange of technical 

ideas and information. For example, periodic refresher 

courses provide field personnel with updated information 

and developments, and reinforce good practices and techniques. 

It can also point out poor techniques and questionable shortcuts that may have become incorporated into routine procedures 

and operations. 

Many States only require classroom training for initial certification. 

Because the fields of opacity reading technology, legal development, and 

court decisions develop and change rapidly, however, a full-day refresher 

course should be given at least once every 3 years as a criterion for certification renewal. Further, the training supervisor should attend one of the 

instructor seminars offered periodically by EPA because these serve as a forum 

for discussing and distributing new material, techniques, and training aids. 

To assure quality training and optimum student learning, lecturers should 

be selected with care. They should be experienced, knowledgeable, organized, 

and have good visual aids and current hand-out materials. 
P.21 

3.1 EXAMPLE LECTURE MATERIAL 

This section, along with Appendix A, provides only an overview of the 

classroom session. Separate EPA documents cited in Section 7 should be referred to for further, more detailed guidance concerning lecture materials. 

The set of lectures included in Appendix A provides samples of material that 

should be presented as part of the classroom lecture/discussion session. Although these example lectures are not intended to be a model for all schools 

to follow, the lectures do address most of the important topics covered in a 

visible emission training program. Thus, this material can be expanded to 

accommodate changes in the state-of-the-art and can be tailored to needs and 

regulations of a specific agency. 

The following describes a typical, six-lecture classroom training program: 

1. Lecture 1 - The student is introduced to the history, principles, 

and theory of opacity. 

2. Lecture 2 - The sources of visible emissions should be presented 

by experienced enforcement personnel or an engineer thoroughly 

familiar with source conditions and opacity reading procedures and 

problems. Note: The use of quality 35-mm slides illustrating 

common source and plume conditions is recommended during this 

particular lecture. 

3. Lecture 3 - The proper procedures for conducting field inspections 

are discussed. 

4. Lecture 4 - The influence and impact of meteorology on air quality 

are described. 

5. Lecture 5 - The legal aspects of visual emission and opacity 

measurement should be presented by an attorney familiar with the 

practices and problems of air pollution control enforcement. . . 

6. Lecture 6 - The actual testing procedures are discussed. This 

lecture relies upon the foundation built by the previous five 

lectures. 

Appendix A also includes two example quizzes.' A short quiz should be 

given at the conclusion of the classroom series to indicate the trainee's 

comprehension of the material presented in the lecture and to indicate whether 

the key points of the lectures have been sufficiently emphasized. If problems 

arise with specific questions, it indicates that the material has not been 

clearly presented. It may then be possible to clarify these points immediately 
P.22 

or at least to make the appropriate adjustments in subsequent sessions. This 

provides a QA check on training effectiveness. Two sample quizzes are presented in Appendix A. Note that the last few questions allow a brief critique 

of the course. These questions will alert the instructor to parts of the lecture that need improvement and thus allow the instructor to constantly improve 

his presentation. 
SECTION 4 

TRAINING EQUIPMENT 

In 1950, the first smoke generator was constructed and used for VE training by the Los Angeles County Air Pollution Control District. The VE training procedures were first outlined by EPA in the Federal Register on 

December 23, 1971. The most recent standards of performances and specifications for smoke generators were published in the Federal Register, Volume 39, 

No. 219 on November 12, 1974, as a part of "Method 9 - Visual Determination of 

the Opacity of Emissions from Stationary Sources" (Appendix 1). 

Most Federal, State, and local air pollution control agencies conduct 

VE training and certification courses at least every six months. This frequency is necessary to maintain opacity reading certification. 

This section presents performance specifications and operating procedures 

for smoke generators that, if followed under a QA program, will ensure nationwide uniformity and consistency with Method 9 criteria. An integrated QA 

program is particularly important, since VE enforcement procedures are frequently challenged in court and even more importantly, to assure that sources 

will correctly be observed in either compliance or violation. 

An integral part of this program involves the design and operation of 

the smoke generator in accordance with the requirements of Method 9'. In the 

following sections, the design and operation of the smoke generator and its 

associated transmissometer are explained, and procedures are given for assuring 

adequate performance. 

4.1 METHOD 9 DESIGN AND OPERATING SPECIFICATIONS 

Method 9, as published in the Federal Register, contains design and 

operating specifications for the smoke generator used in the training and 

certifying of observers. Method 9 was developed by EPA in support of NSPS 
P.24 

promulgations. Many states now make reference to Method 9 and even more are 

moving toward the common use of its operational and design requirements. 

4.1.1 Smoke Generator Specifications 

The procedures to follow in checking compliance with the design specifications are in Section 3.3.2 of Method 9. The specific items to be checked 

are listed in Table 1. The manufacturer should detennine the specifications 

of the light sources, photocell spectral response, angle of view, and angle 

of projection. The generator operator is responsible for checking the calibration error, zero and span drift, and response time. Each of these items 

will be discussed in detail. 

TABLE 1. TRANSMISSOMETER DESIGN AND PERFORMANCE SPECIFICATIONS 

Parameter 

Light source 

Photocell spectral response 

Angle of view 

Angle of projection 

Calibration error 

Zero and span drift 

Response time 

Performance 

Incandescent lamp operated at +5% of 

nominal rated voltage 

Photopic (daylight spectral response 

of the human eye) 

15 degrees maximum total angle 

15 degrees maximum total angle 

+3% opacity, maximum 

+_l% opacity,. 30 min 

5 s, maximum 

4.2 SMOKE GENERATOR 

The design and operation of the smoke generator have evolved since the 

mid-19601s. The basic components of a smoke generator include: 

1. Black and white smoke generating units 

2. Fan and stack 

3. Transmissometer system 

4. Control panel and strip chart recorder 

A schematic layout of an example commercial, smoke generator is shown in Figure 1, and a detailed component list is provided in Figure 2. The smoke generator can either be a stationary or mobile unit depending on the training 

8 
P.25 

(1 1 vay X V 

Comoonents 

1. vaporizer 

2. Mixing section 

3. Main blower 

'4. Stack section 

5. Combustion chamber 

1 

© 

fi 0 ' 

© = 

© 

o© 

© 

© ~~b 

©Ero 

© 

© 

> 

/ , 

8.0' 

J® 

1 ' 

6. Storage compartment 

7. Storage compartment 

0. Stack support 

9. Fenders 

10. Interconnect box to control panel 

11. Transmissometer system 

12. Remote control panel and strip chart recorder 

a. Strip chart recorder 

b. Digital readout 

c. Transmissometer control 

d. Fuel controls 

REMOTE 

CONTROL PANEL 

Figure 1. Example schematic layout of a simple generator. 
P.26 

TRAILER-MOUNTED COMPONENTS 

Trailer hitch 

Storage compartments 

Stack support for transporting 

White smoke vaporizer 

Black smoke combustion chamber 

Ambient air/smoke mixing chamber 

Induced draft (I.D.) fan 

Lower stack section 

Upper stack section 

Hinged support flange 

Transmissometer system (light 

source and photocell assembly) 

Stack fan 

Main electrical junction box 

Remote fuel line hookup 

Flexible fuel lines 

Electrical interconnect cables 

Solid sheet metal trailer bed 

Trailer axle and brake assembly 

Fuel storage tanks 

Hydraulic system for stack lift 

CONTROL CONSOLE 

Digital opacity meter 

Digital or strip chart 

opacity recorder 

Main power on/off switch 

I.D. fan control switch 

Stack fan control switch 

Fuel pump control switch 

Light source on/off switch 

Transmissometer span control 

Transmissometer zero control 

Fuel pump selector switch 

Power indicator light 

Toluene fuel control valve 

Fuel oil control valve 

Connects for fuel lines 

Amphenol connectors for 

electric supply and electronics 

Fuel pumps 

Bell or buzzer 

Speaker system to communicate 

with trainees 

Figure 2. Smoke generator component list. 

10 
P.27 

location. Most units are mounted on trailers, therefore they can be transported to training locations, thereby improving attendance and lowering travel 

expenditures. The unit should be stored indoors between training exercises 

in order to lessen weather deterioration and to improve security. 

Some negative trade-offs are associated with a mobile unit. It is subject to increased wear due to travel and usually requires additional refurbishment, calibration, and adjustment upon arrival at the training location. 

Due to these circumstances, the QA issue is of increased importance. 

The design and purpose of a smoke generator provide controlled black 

and white smoke plumes and a means of accurately measuring and recording 

plume opacity. A smoke generator must be able to generate smoke with an 

opacity range of 0 to 100 percent and have sufficient accuracy to allow the 

operator to control and stabilize the opacity of the smoke. Most generators 

have two basic equipment components: 1) the mechanism that actually produces 

and controls the smoke and is usually mounted on a trailer for portability 

and 2) the mechanism that monitors and records the various smoke opacities 

produced. The use of a separate console for housing the control and recording functions has proven highly desirable because it may be moved away from 

the generator. The console table also provides a working surface for making 

notes, reviewing records, etc. The console and trailer unit must have interconnecting lines for the fuels and electronics. 

4.2.1 Operating Principles 

The training, testing, and certification of smoke observers require the 

use of a device that can produce black and white smoke of any given opacity. 

The device must be able to achieve and hold opacities in 5 percent increments 

from 0 to 100 percent opacity. The desired testing opacity must be stabilized 

at +2 percent for a minimum of 5 seconds. After the plume is stabilized for 

2 or 3 seconds, the bell or buzzer is sounded for the trainee to make a reading. Another 2 to 3 seconds are allowed for the reading. Stability and control are essential and must be checked as part of the QA program. 

White smoke is produced by dispensing No. 2 fuel oil into the propaneheated vaporization chamber (Figure 3). After it vaporizes, the vapor is 

cooled until it condenses into a white aerosol cloud. The opacity of white 

smoke varies in proportion to the volume of oil vaporized and is regulated 

11 
P.28 

<P t 

6 

c 'tr 

7 

^ 1 

Components 

1. Transmissometer 

2. Vaporizer 

3. Exhaust manifold 

4. I.D. fan 

5. Fuel oil storage 

6. Pump 

7. Fuel oil control valve 

8. Dilution air damper 

Figure 3. White smoke generating equipment. 

12 
P.29 

by adjusting the flow of fuel oil with the fuel oil needle valve located on 

the fuel control panel. 

Black smoke is produced by the incomplete combustion of toluene in the 

double-wall combustion chamber (Figure 4). The opacity of the black smoke 

plume is regulated by adjusting the toluene fuel flow controlled by the toluene 

needle valve located on the console. 

Controlling smoke opacity is more of an art than a science because of the 

many parameters involved, such as fuel quality, temperature, and generator 

condition. Most operators soon learn their equipment characteristics and 

become very skilled in regulating plume opacities. This underscores the importance of conducting the smoke school with an experienced team. 

4.3 TRANSMISSOMETER 

The transmissometer is perhaps the most critical component of the smoke 

generator, the ^/ery heart of the system. Appendix 1 of Method 9 sets forth 

the specifications for smoke meters or transmissometers (Ref. 3.3.2). An 

acceptable smoke generator must be in full compliance with these design and ' 

operating specifications. The basic smoke generator transmissometer (Figure 5) 

includes a light source, a photopic photocell detector, and a readout device 

with a calibrated span of 0 to 100 percent opacity. The 1ight-to-photocell 

path is approximately 4 ft in length, but only 1 ft, the stack portion of its 

length, is exposed to smoke. The remaining 3 ft are continually flushed with 

ambient air from the small fans to prevent smoke buildup and soiling of the 

lamp or photocell. The transmissometer is located in the 3-in. diameter 

crossarms of the upper section of the 12-in. diameter stack. The following 

subsections discuss in detail individual components of the transmissometer 

and procedures for checking their performance. 

4.3.1 Calibration Procedures 

Before conducting the calibration sequences, the operator should refresh his memory by reviewing Method 9. The transmissometer is calibrated 

according to this method. 

Through field use, the term "calibration" has been expanded from its 

original meaning in Method 9. When a generator operator refers to "calibrating" the transmissometer, he usually means that a check has been made on 

13 
P.30 

CJ -£a-» 

Components 

1. Transmissometer 

2. Stack 

3. I.D. fan 

4. Combustion chamber 

5. Pump 

6. Toluene control valve 

7. Nozzle 

8. Dilution air damper 

9. Toluene storage 

Figure 4. Black smoke generating equipment. 

14 
P.31 

J 

b 

2 II 

'll 

5 

" 2 I I 2 

4 

34= 

b 

Components 

1. Light source 

2. Smoke stop 

3. Photocell 

4. Fan 

5. Stack 

Figure 5. Transmissometer. 

15 
P.32 

calibration error, zero and span drift, and response time of the system, in 

addition to simply establishing stable 0 to 100 percent readings. 

Method 9 specifies that generator transmissometers be calibrated eyery 

6 months or after any modifications or repair to the transmissometer or readout device. Experience has shown that it is strongly recommended that the 

calibration also be performed before and after each certification course. 

These calibration checks determine whether any significant drift or deviation has occurred during the certification training period. Since the calibration procedure has been refined to a fairly simple and expedient procedure, 

these additional checks are not too time consuming and add significantly to 

overall quality assurance. Keeping in mind the expanded definition of calibration, the following step-by-step procedure should be followed: 

1. Allow a 30-minute warmup time for the transmissometer and readout • 

device before starting calibration sequence. 

2. Make sure that the light source input voltage is within the +5 percent nominal rated voltage of the light bulb. This voltage cannot 

be varied for span purposes. 

3. Turn light source to OFF position and establish 100 percent span 

reference point on readout device. 

4. Turn light source to ON position and establish zero span reference point on readout device. 

5. Repeat steps 2 and 3 until the 0 and 100 percent span points 

are established as specified by Method 9. (Refer to Appendix 1 

of the Method.) 

6. Check for drift of either 0 or 100 percent span points. A maximum of 1 percent over 30 minutes is allowed. 

7. Check the response time of the transmissometer readout device 

with a stopwatch to ensure that it does not exceed 5 seconds. Response time is determined by switching the light to the OFF 

position and measuring the amount of time until the recorder 

reaches full scale. A total response time that is too lengthy 

can cause the transmissometer operator to misread the final value 

of the opacity reading. Record all response time checks on an 

appropriate form (Figure 6). 

8. Insert three neutral-density (ND) filters into the stack using 

the calibration wand (Figure 7) to intersect the light beam 

across the transmissometer cross arm. Take care to prevent 

erroneous readings from stray light. 

16 
RESPONSE TIME CHECK (Method 9, Section 3.3.2.7) 

P.33 

Checked by: Date: 

Time: 

Check 

1 

2 

3 

4 

5 

Response.time, 

sec 

Time: 

' Check 

1 

2 

3 

4 

5 

Response time, 

sec 

Figure 6. Example response time check form. 

17 
P.34 

POSITIONING 

NOTCHES 

u 

SPECTRAL 

RESPONSE 

FILTER 

OPEN 

20% 

50% 

75% 

SOLID 

Figure 7. Calibration wand. 

18 
P.35 

9. Take five random and nonconsecutive readings for each filter. 

10. Record the nominal values of the 20, 50, and 75 percent 

opacity ND filters on the appropriate transmissometer calibration form (Figure 8). Repeat this step four times, 

record all values, and graph the calibration error. 

11. If any reading exceeds the +3 percent calibration value for that 

specific filter, take corrective action before completing the 

certification test. Check the electrical and readout systems. 

12. Have the completed calibration error forms signed by the 

individual conducting these tests. 

13. File all signed documents (Figures 6 and 8) with the VE certification course records for the period in question. This provides the 

QA element in certifying observer skills necessary to support 

enforcement litigation. 

To ensure a properly calibrated transmissometer, and thus prevent possible 

legal challenges of calibration accuracy, it is strongly recommended that only 

glass metallic ND filters that are National Bureau of Standards (NBS)-traceable should be used. 

The two most common types of ND filters are composed of gelatin and glass 

metallic materials. Gelatin filters are fairly inexpensive but may deteriorate 

rapidly. They inherently have lower quality and greater variation than glass 

metallic filters. Gelatin ND filters frequently do not meet the Method .9 requirements of +2 percent accuracy'unless calibrated by the more sophisticated 

spectrophotometers that generally are not available. The glass metallic ND 

filters, as ordered from the manufacturer, have an NBS calibration curve 

accurate to +0.5 percent of their nominal rated values. Calibration curves 

must be provided with each filter to ensure the exact calibration is at 540' 

nm on the electromagnetic spectrum. This information should be recorded on 

the ND filter form shown in Figure 9. 

Due to the critical nature of the photocell alignment, no part of the 

transmissometer system should be removed from the stack assembly during calibration. A few degrees of misalignment can shift readings as much as 5 to 10 

percent. Inserting the ND filters into the center of the stack at the transmissometer crossarm eliminates any need for removing either the light source 

or photocell assembly in order to conduct the calibration. A calibration unit 

is now available from generator manufacturers or can specifically be built for 

19 
P.36 

CALIBRATION ERROR CHECK (Method 9, Section 3.3.2.5) 

Check performed by: Date: 

Time: 

Filter 

1 

2 

3 

Read 

i—i 

2 3 

inq 

4 5 

Average 

opacity, % 

Maximum 

error,% 

Average 

reading, % 

-s-si 

< 

Q. 

O 

CD 

ACTUAL OPACITY, % 

Figure 8. Calibration error check form. 

20 
P.37 

Filters calibrated by: 

Date calibrated: 

Were NBS-traceable filters used? yes no 

Filter 

1 

2 

3 

Nominal 

opacity, 

10 

20 

50 

75 

Measured 

opacity, 

% 

Figure 9. Neutral-density filter form. 

21 
P.38 

retrofit on older model smoke generators. Figure 7 illustrates a typical 

filter holder and calibration wand. 

4.3.2 Recording Instrument Span 

The next step in the calibration process is to set the span of the transr 

missometer readout device and to measure any drift. Since the transmissometer 

and recorder are a combination of electronic and mechanical devices, their 

resultant outputs will display some drift, which is defined as the amount of 

deviation in percent opacity per unit of time from a given setting. 

The following procedure may be followed on a transmissometer and recorder 

system to check zero and span" drift. 

1. Warm up the smoke generator/transmissometer system for at least 

30 minutes, but do not start generating smoke. This step is needed 

to allow the system to stabilize sufficiently before the span 

checks. 

2. Turn the light switch to the OFF position. 

3. Adjust the output readings (digital and chart recorder) to read 

100.percent on the chart scale. This adjustment will be on the 

readout device and will usually be labeled "zero adjustment." 

4. Turn the light switch to the ON position. 

5. Adjust the recorder to read 0 percent on the chart scale. This 

adjustment knob is located on the control panel of newer model 

generators. 

6. Repeat steps 2 through 5 until a stable response is obtained at 

0 and 100 percent on the recording instrument scale. 

7. Perform the calibration error test. 

8. Operate the generator for approximately 1 hour. Repeat steps 2 

through 5. The difference between the readings at the start 

and end of the hour indicates the resulting instrument drift. 

9. Record the difference in chart scale for the zero and span on 

the smoke generator performance data sheet (Figure 10). 

This total procedure, which is commonly referred to as a "zero and span" 

chsck, must be repeated before and after each test run. If the drift exceeds 

1 percent opacity after a typical 30-minutes test run, the instrument must be 

corrected to 0 and 100 percent of scale before testing is resumed. The drift 

readings should be recorded in order to develop a historical record of 

22 
P.39 

- rTTff'-Tij'--

Generator number: 

Operator: 

Generator Evaluation Data Form 

Manufacturer: 

Owner: 

Zero drift, % chart: 

Rise time, sec: 

Span drift, % chart: 

Fall time, sec: 

Light source lamp voltage, volts: 

Angle of view (9) calculation 

= 2 tan ~

l

 d/2L = (Note: 9 must not exceed 15°) 

where: 

Tested by: 

Verified by: 

L = mm 

d = mm 

20 percent 

% chart 

% chart 

% chart 

.% chart 

% chart 

Cal i br 

50 

•% 

10 

% 

% 

% 

*ation Error 

percent 

chart 

chart 

chart 

chart 

chart 

Date: 

Date: 

75 percent 

% chart 

% chart 

% chart 

% chart 

% chart 

Figure -10. Smoke generator performance evaluation data fo rm. 

23 
P.40 

instrument operation. As a QA measure, this operation log should be thoroughly 

reviewed at least every 6 months, and it should identify any instrument 

deterioration or failure so that preventive maintenance can be initiated. 

4.3.3 Light Source 

The smoke generator transmissometer light source in Figure 11 must emit 

light in a specified visible light spectrum range between 400 and 700 nm. 

Incandescent lamps are normally satisfactory if operated at +5 percent of 

their nominal rated voltage. If an incandescent lamp is operated at a different voltage, though, it will probably emit additional light outside the 

specified visible spectrum and thereby introduce significant calibration 

error. A typical light source voltage is determined by the manufacturer and 

is either listed on the bulb or is available in the manufacturer's catalog. 

The operating voltage should be measured with an accurate volt/ohmmeter at 

the base connection of the bulb and verified by the operator. Method 9 

requires that all lamps be operated within +5 percent of their nominal rated 

voltage. Therefore, a lamp rated at 12 V should be operated only between 

11.4 and 12.6 V. 

4.3.4 Photocell Spectral Response 

The most common photocell found in smoke generator transmissometer 

applications is the selenium photovoltaic-type shown in Figure 12. The 

photovoltaic series of photocells generate a voltage or current signal proportional to the intensity of light detected by the cell. This voltage is 

the signal received by the recording and readout components of the control 

console. 

The transmissometer photocell selected for generator applications must 

have a photopic response range of 400 to 700 nm as specified in the Federal • 

Register, Volume 39, No. 219, November 12, 1974. 

The photopic response is generally verified through a careful technical 

review of the data supplied by the specific generator manufacturer. This includes a check to ensure that a tungsten bulb is being used and that the photocell has the appropriate filters necessary to provide a photopic spectral 

response output. If the manufacturer's data are insufficient to make an 

accurate assessment, however, the transmissometer unit should be modified to 

ensure photopic spectral response. 

24 
P.41 

REFLECTOR 

AMPHENOL 

CONNECTOR 

END CAP 

ALIGNMENT 

SCREWS 

Figure 11. Example light source. 

25 
P.42 

ACTIVE 

CH.L AREA 

REX0VA8LE 

SUPPORT PLATI 

OUTPUT 

FRONT VIEW REAR VIEW 

s i 

r n r n n T 

J Li u u u U ci. 

A 

2 3 4 5 S 7 

1-FRONT CASE 

2-SUPPORT PLATE 

3-OPTICAl GLASS 

4-PKOTOPIC FILTEH 

5-OPTICAL GUSS 

6-SELENIUM ELEMENT 

7-INSULATOR 

3-SACX COVES 

EXPLODED VIEW 

•igure 12. Typical photocell schematic. 

26 
P.43 

4.3.5 Response Time 

The response time measures the time lapse required for the recorder to 

change its reading from 0 to 100 percent opacity on the recording instrument 

following an instantaneous light change in the transmissometer. This time 

interval should be measured by a stopwatch. Again, this determination should 

not be attempted until the instrument has been warmed up for at least 30 

minutes. The response time allowed by Method 9 is five seconds or less; an 

ideal response time is between 4 and 5 seconds. Shorter response times can 

cause the transmissometer readout to fluctuate constantly, making it very 

difficult to determine precise opacity readings. All response time checks 

should be recorded on an appropriate form as shown in Figure 6. 

The response time is determined by producing a series of five simulated 

0 to 100 percent opacity values by switching the light source on and off and 

observing the time required to move full scale. Note that the generator must 

not be producing smoke during these checks. The following steps are suggested 

for checking response time: 

1. Warm up the transmissometer/readout system for at least 30 minutes. 

2. Span the instrument as described in Subsection 4.3.2. 

3. Using a stopwatch, measure the time the recorder takes to move 

from 0 to 100 percent on the opacity readout device. 

4. Make sure that the recorder reads 0 percent with the light source 

on. 

5. Switch the light off and start the stopwatch. 

6. Stop the watch when the recorder reaches 100 percent opacity 

and record the lapse time. 

7. Make sure that the recorder stops and stabilizes at 100 percent 

opacity scale with the light off. 

8. Reset the stopwatch, switch light source on, and start the watch. 

Stop the watch when the recorder reaches 0 percent opacity scale, 

and record the lapse time. 

The transmissometer system response time adjustment is primarily a function of the adjustment of the chart recorder damping. It is recommended that 

either an electronic technician or the manufacturer make these modifications 

to the recorder. 

27 
P.44 

4.3.6 Angles of Projection and View 

The angles of projection and view refer to the projection of light from 

a light source and the view of this light by the photocell. Light from a given 

source is projected out in nearly all directions, resulting in highly variable 

light scattering conditions. The ideal system would have a narrow collimated ' 

beam light path. This optimum condition is approximated by limiting the angle 

of projection to a near-parallel travel band of light waves. Similarly, without shielding to restrict the angle of view, a photocell can respond to incoming light from nearly all angles to its flat face (approximately 180 degrees). Thus, by limiting the angles of projection and viewing to a maximum 

of 15 degrees, the light scattering errors are minimized over the approximately 

1-ft stack diameter. 

Limiting the angles of projection and view in a generator transmissometer 

serves to restrict the photocell's response to those light waves passing 

through the smoke plume approximately perpendicular to the long axis of the 

plume. This results in the most accurate measurement .of plume opacity. 

4.3.7 Estimation of Angle of View 

The construction geometry should be checked thoroughly to ensure that the 

total angle of view of the smoke plume, as seen by the photocell, does not 

exceed 15 degrees. 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 transmissometers, this is normally an orifice plate. Since 

correct angle of view usually is established by the manufacturer of the transmissometer, the manufacturer's specifications should be checked prior to performing the measurements and calculations illustrated in this subsection.' The 

total angle of view (V) should then be calculated by use of the following 

equation: 

V = 2 tan"1 |jwhere 

d = sum of photocell diameter and diameter of limiting aperture, mm 

L = distance from photocell to limiting aperture, mm 

28 
P.45 

4.3.8 Estimation of Angle of Projection 

As is the case with angle of view determination, the general construction 

geometry should be checked to ensure that the total angle of projection of 

the lamp on the smoke generator does not exceed 15 degrees. The total angle 

can be calculated by use of an equation similar to that for angle of view 

determination (subsection 4.3.7) except for a slight difference in the definition of the parameters. 

The total angle of projection (P) should be calculated by use of the 

following equation: 

P = 2 tan'1 ~ 

where 

d = sum of length of lamp filament and diameter of limiting 

aperture, mm 

L = distance from lamp to limiting aperture, mm 

The correct angle of projection is established by the manufacture of the 

transmissometer but should be rechecked by use of the equation in this subsection. Consistent units must be used in the calculations for both angle of 

view and angle of projection. 

4.3.9 Stability of Smoke 

Method 9 does not specify a time interval during which the generated smoke 

should remain stable or at a reasonably consistent value. A trained observer 

should observe the plume momentarily at 15-seconds intervals when making field 

observations, but trainees may need 2 or 3 seconds to make such determinations. 

The generator must therefore be capable of holding any set opacity value.to 

+2 percent for 5 seconds in order to minimize the possibility of incorrect 

observations. 

EPA Region IV, for example, has selected a 2-second observation period 

for the reader to make the opacity determination. The generator operator 

signals the beginning and the end of each observation period. Further, 

Region IV has stipulated two criteria for determining whether the opacity is 

adequately stable for making a certification reading. These criteria are: 

1. The average opacity, during the 2-second period is within +_1.5 percent of the intended opacity. 

29 
P.46 

2. The variation of the trace does not exceed 1.0 percent 

deviation of opacity from its average position at any 

time during the 2-second period. 

Figure 13 illustrates examples of acceptable and unacceptable smoke stability 

conditions as evaluated by the above criteria. 

4.3.10 Documentation and Logging for Quality Assurance 

The opacity reading record on field certification activities should be 

clearly recorded and maintained and is best provided by a continuous strip 

chart recording showing the actual transmissometer output tracings. This 

method provides full documentation of the spanning effort and adjustments 

during the training and certification exercise, and preserves the precise 

opacity reading conditions for quality assurance. The strip chart also facilitates the marking of each period and observation point for any future comparisons. 

As indicated in examples e and f of Figure 13, the generator readout indicates opacity conditions above and below the intended readings. At this point, 

the generator was producing a very stable plume and the control should have 

been adjusted slightly to the desired 40 percent opacity. The strip chart 

recording documents a great deal about the operation of the smoke generator 

and should be examined for acceptability in the QA review. 

All zero, span, mid-range linearity, and calibration filter readings 

should also be recorded on the strip chart or digital recorder in order to 

provide a permanent record that these tests were performed and that the Method 

9 criteria were achieved for each individual training school. The strip chart 

or digital recorder should allow the information required through the use of 

a recommended calibration stamp as shown in Figure 14. 

All of the performance verification procedures described in this section 

should therefore be documented in writing and dated. Some agencies prefer to 

use a form such as that shown in Figure 10 to record this information, although 

a bound logbook is highly recommended because it best assures a complete record of all events that concern the performance of the smoke generator, including records of repair and maintenance work, spectral response checks, calibration checks, response time checks, etc. These records are then added to the 

permanent files of the VE school. 

30 
OPACITY LEVELS ACCEPTABLE FOR CERTIFICATION 

1 

1 ~3C ~~" i 

_„TE... l

f 

^ 

! 

1 

•f 

II 

1. 

1 

^

J

l 

1 

3CT I H 

II 

A\ 

1 

-T1-^ „„3I.:. 

. _L 

1 ' 

Hp 1 

1 II 

1 

| 

| 

1 

Pri 

i I 

a. variation of <1.5% 

at 40% opacity 

b. variation of <1. 5% 

. above 40% opacity 

c. variation of <1.5% 

below 40% opacity 

OPACITY LEVELS UNACCEPTABLE FOR CERTIFICATION 

lll l 

1 T 

II 

1 

_LU- II I I 

II LiPi Mil ll 

i rmg 11111 PH 

mri i IIII I 

d. variations >1.5% 

at 40% opacity 

1 

1 ll -v\u 

II 

T 

i 

i 

IM 1 l 

MM! 

M M 

/ M 

T i 

Ml 

111 

PP, 

i I 

1 1 1 

lll l 

fM 

Mi l 

III II MU M 

INI 1 1 

\\\jm 1 

1 t 1 

Mil l 1 

1II 1 PM 

II 1 

e. constant opacity 

>1.5% above 

40% opacity 

f. constant opacity 

>1.5% below 40% opacity 

MARKING OPACITY READING PERIODS 

1 

3D 

1 

1 1J 

\A\ hf) 1 1 

I & h 1 

i i 1 

i i 

i 

Th 

1 

MM 

PH Ml 

1 1 

1 

II 

M l 

JIM II 

<fT 1 voi B i 

i 

i i 

* f W | PH 

i m . ! 111 

g. Valid readings h. Invalid readings 

Figure 13. Examples of acceptable and unacceptable 

smoke stabilit y conditions. 
P.48 

LOCATION 

DATE RUN TIME 

1-25 26-50 

GENERATOR 

OPERATOR 

VERIFIED BY 

Figure 14. Recommended calibration stamp. 

Proper entries and records can form the data base of an excellent QA 

program for the school. The records can be used for statistical studies to 

develop confidence intervals for the training sessions and the individual run 

forms can be used to develop confidence limits on individual readers. 

4.4 SETUP, OPERATION, AND SHUTDOWN PROCEDURES 

Operating an opacity training and certification program is an expensive 

but essential endeavor. It is therefore important to minimize the time and 

effort involved. This is best done by being prepared and thoroughly familiar 

with the activity. 

Since opacity training and certification are not a continuing daily operation, additional preparation is necessary. The smoke generator operator should 

remove the generator from storage before the training course and run through 

an operating sequence. This dry run usually identifies minor repair, preventive maintenance, and missing parts or inventory required for assuring high 

quality and efficient certification runs. Figure 15 provides a checklist of 

parts and supplies. The following step-by-step operating procedure can.be 

applied to smoke generators to prevent delays and breakdowns during field 

certification training sessions. The smoke generator operator should practice 

these steps until a high degree of proficiency is reached. (NOTE: An 

asterisk (*) indicates that the step must be performed as specified by Method 

9.) 

1. Assemble and inventory the spare parts and accessories by use of a 

checklist similar to that shown in Figure 15. 

32 
P.49 

GENERATOR CHECK 

Toluene (2 tanks) 

Kerosene (1 tank) 

Funnel 

Extension/power cord 

Ground fault interrupter 

Fuel interconnects (2) 

Electrical interconnect 

Propane torch 

Propane tank (full),.-

Striker 

Tip for vaporizer" 

Vaporizer 

Calibration filters 

Calibration staff 

Calibration stamp 

Digital voltmeter 

Flag and staff 

Control console 

Work table 

Chart paper 

Pen for recorder 

Loud speaker system 

Fire extinguisher 

Standard operating 

procedures manual 

SPARE PART CHECK 

Box fuses 15 A main 

Box fuses 10 A blower 

Box fuses 3 A fans 

Box fuses IH A light 

Box fuses 3/4 A amplifier 

Torch tip (white smoke) 

Torch tip igniter 

Tank "0" rings 

Valves 

Bulbs TS67 (12 V) (5) 

1 k linear pot 10 turn (1) 

Spare tire (mobile units) 

Hydraulic jack 

Disconnects (2) 

Duct tape 

Tool kit 

Lubricating equipment 

FIELD FILE CHECK 

China marking pens 

Filter calibration wand 

Calibration log 

Roster log 

Test forms 

Grading acetates 

Certification stamp 

Stamp pad 

Felt tip pens 

Extra ballpoint pens 

Clipboards 

Large rubber bands 

Figure 15. Part and supply checklist. 

33 
P.50 

2. Connect the mobile generator and move it to the area of operation. 

Be sure to select a trailer location that will provide trainees 

the optimum viewing conditions in respect to background, wind 

direction, and sun position. 

3. Chock trailer wheels and unhitch smoke generator from towing 

vehicle. Remove towing vehicle to avoid interference with 

trainee's view of the smoke stack plume. Adjust trailer dolly 

jack until front of trailer is slightly higher than the rear 

but level from side-to-side. 

4. Check for any damage or evidence of tampering with generator 

since the last operation. 

5. Check fluid level in hydraulic pump, remove the stack securing 

bracket, and partially raise the stack to resume operation. 

6. Lubricate main blower motor. This must be done prior to each 

certification school by injecting two drops of lubricating oil 

into each oil cup. 

7. Check both the toluene (black smoke) and fuel oil (white smoke) 

storage tanks to ensure an adequate supply of fuel for the entire certification course. The generator will burn 0.1 gal 

toluene or fuel oil per certification run; 10 gal of each fuel 

is adequate for most training and certification sequences. 

8. Place the generator's control module with detached console on a' 

table or stand approximately 10 ft from the generator trailer. The 

control console is normally operated on the left side of the trailer, 

facing away from the trainees. This position prevents trainees 

from viewing the transmissometer readout system during certification runs. If the control console is an integral part of the 

model generator being used, proceed with checking the operability 

of switches, lights, meters, etc. 

9. Make electrical connections by following steps 10 through 15. 

The electrical connection procedures that apply to the console ' 

model of generator are diagrammed in Figure 16. 

10. Connect one end of the 16-ft electrical interconnect cable to 

the main junction box at the rear of the smoke generator trailer, 

and the other end to the electrical control console. (The interconnect cable connectors are keyed and therefore cannot be connected incorrectly.) 

11. Attach the console AC power (117 VAC) cord to the read control 

panels (3 pin amphenol; refer to Figure 17). Do not plug into 

AC source at this time. 

12. Turn all switches on electrical control console to the OFF position. 

34 
P.51 

Connect the generator 

console fuel lines 

Connect the generator 

console electrical lines 

Connect the power line 

Turn on propane tank 

Light toluene igniter 

Connect speakers and 

microphone 

Light white smoke 

vaporizer torch 

Crank up stack 

Turn on main power 

Zero and span 

transmissometer 

Open toluene valve 

for black smoke 

Open oil valve 

for white smoke 

Figure 16. Example generator operation procedure. 

35 
P.52 

?

" n rj AJ • AC Input 

• Niln Output 

• Pnotocill Light Jourei 

• Put* Ltont Ssurct 

- Ololul Rttdaut 12V X (-) 

< - Olglul Kidout 12V CC (•) 

7 • Full Ptaps 12V OC (-) 

S - Full Pu=p« 12V OC (•) 

9 - Full Pops 12V 0C(« ) 

PANEL IDENTIFICATION 

'!» WIII£ COLOR VOLTAGE 

Rid 

Slide 

Grun 

117 V AC (•) 

117 V AC (•) 

E*rtn-Ground 

3-PIN CONSOLE CONNECTOR 

•!» I 

A 

I 

C 

0 

E 

F 

' 

H 

J 

SYSTEM 

Mara 

Stack F«nt 

**ln blowir 

Kiln Blowir 

S/ttta Ground 

Ham 

Full Pump 

Full Puap 

Full Puap 

viae COLOR 

u>t*n 

gii a 

Rid 

auct 

Grun 

81ui 

BUck 

euct 

' .SIui 

VOL USE 

12V OC (.) 

inv A: (.) 

I17V AC (.) 

U7V AC (.) 

Earth-Ground 

12V AC (.) 

i2v 3 : (.) 

12V CC (.) 

12V K (. ; 

9-PIN CONSOLE CONNECTOR 

Figure 17. Electronic panel of smoke generator control console. 

36 
13. Close both fuel control valves. This will generally be in the 

clockwise direction. 

14. -The control console normally requires an extension cord to reach 

the AC power source. The extension cord should be at least 3 

wire, 14 gauge, and weatherproof. Plug the control console into 

a 20 A, 117 VAC, 60 Hz electrical circuit. 

15. Set up and test the PA system by connecting the components 

(microphone, speakers, etc.) in their proper places. 

16. Identify and connect the fuel line. Two fuel line interconnect 

assemblies are included with the generator. The shorter set of 

fuel lines (10 ft) is connected.between the fuel control panel 

and the fuel shortage tanks. The longer fuel line assembly (16 

ft) is connected between the fuel control panel and the fuel input connectors on the rear of the trailer. 

17. Connect the fuel lines to the proper input and output connectors 

on the rear of the fuel control section of the control console. 

On newer generators, the ends of the fuel lines will be color 

coded. 

18. Open the vents on both fuel storage tanks to allow proper fuel 

flow through the fuel pumps and to the generator. 

19. Connect the long set of lines to the rear of the control console. 

Before connecting these lines to the connectors on the trailer, 

bleed each fuel line separately into a container by briefly 

turning on each fuel pump to ensure that most of the air bubbles 

have been removed from the lines. Clean fuel may be returned to 

its respective reservoir. 

20. Tighten all fuel line connectors to prevent leaks in the fuel 

delivery system. 

4.4.1 Smoke Generator Electrical Console Operation 

Verify that all electrical switches and fuel control valves are in the 

OFF position and then proceed with the following steps. 

1. Turn' main power switch to ON position. 

2. Turn on stack transmissometer fans. Check fans visually to 

ensure that they are operating. 

3. Turn the main blower on momentarily to ensure that it is 

operational. Then, turn off the main blower until you begin 

the actual smoke generation phase. 

37 
P.54 

4. Activate the transmissometer and readout system (digital meter 

or strip chart recorder, or both) by turning the electrical point 

switch to ON position. Allow the electronic components to warm up 

for at least 30 minutes prior to attempting the calibration phase. 

Unless the drive mechanism of the strip chart recorder is driving 

the pen to its extreme positions do not adjust the controls during 

this warmup period. Proceed with calibration of the transmissometer 

system. See Section 4.3.1 for additional details. 

*5. Establish 0 and 100 percent span adjustment of transmissometer. 

This procedure varies slightly depending on whether the readout 

system is a strip chart or digital recorder device. Refer to 

your generator's operating manual for detailed instructions on 

the specific readout system on your smoke generator. 

4.4.2 Recorder Transmissometer Readout System 

Although procedures will vary depending upon the manufacturer, the following steps can generally be followed. 

1. Turn light source to OFF position. 

2. Adjust transmissometer zero control to read 100 percent opacity 

on the chart scale. 

3. Watch recorder for a few minutes to check for significant instrument drift. 

4. .Turn light source to ON position. 

5. Adjust transmissometer. span control on the recorder to read 0 

percent opacity on the chart scale. Check for any significant 

drift or erratic changes in recorder setting. NOTE: The recorder 

readout may be in percent transmittance. This can be changed by 

reversing the recorder input leads. 

6. Repeat steps 1 through 5 several.times until the instrument 

stabilizes. 

4.4.3 Digital Transmissometer Readout System 

The following steps present a general procedure for span adjustment for 

digital transmissometer readout systems. 

1. Turn light source to OFF position. 

2. Adjust the control setting of the digital readout system to read 

100 on the digital meter. This number actually represents 0 light 

transmission across the stack transmissometer, or 100 percent 

opacity. 

38 
3. Turn light source to ON position. 

4. Adjust transmissometer zero control to read 0 on the digital 

panel meter. 

5.. Check for drift in both the 0 and 100 percent readout modes. 

Some drift is normal until the readout system has warmed up for 

about 30 minutes. 

6. Repeat steps 1 through 5 several times to document instrument stability. 

*4.4.4 ResDonse Time Test • » 4 I I ••• • ——- — . • ••• • 

Determine the response time by producing a series of five simulated 0 

and 100 percent opacity values and observing the time required for stabilization. Opacity values of 0 and 100 percent may be simulated by alternately 

switching the light source power off and on while the smoke generator is not 

producing a plume. The actual time can be determined by use of a stopwatch. 

Optimum response time should be between 4 and 5 seconds, but no greater than 

5 seconds. All response time checks should be recorded on a form similar to 

the one shown in Figure 8. 

*4.4.5 Transmissometer Calibration 

Step-by-step procedures for the calibration of VE generators should be 

followed in detail as outlined in Section 4.3 of this report. The calibration 

procedures outlined in Method 9 are essential to the proper operation of a 

smoke generator and should be thoroughly understood by the generator operator. 

4.4.6 Upper Stack Section Elevator 

The following steps should be followed to properly elevate the generator's 

upper stack section. 

1. Remove the stack cradle hold-down bracket. 

2. Close hydraulic bleed valve at front of hydraulic pump reservoir. 

3. Pump handle on hydraulic cylinder to raise stack. 

4. Place a "C" clamp on flanges between stack sections for additional 

stability. NOTE: Do not pump handle after stack reaches the upright position. The stack can be damaged if additional force is 

applied by the hydraulic cylinder. 

39 
P.56 

4.4.7 Procedures for Producing Black Smoke Plumes 

Prior to beginning this subsection, complete the procedures outlined in 

Subsections 4.4.1 through 4.4.4. The following steps outline the procedure 

for producing black smoke plumes. 

1. Be sure the stack transmissometer fans are operating properly. 

2. Turn on the main blower fan. 

3. Verify that the combustion chamber pilot light control valve and 

the white smoke generator gas control valve are turned off 

(clockwise). 

4. Open the main control valve on the 20-lb propane bottle; this is 

the fuel for the white smoke generating unit. 

5. Remove the heat register plate on the black smoke combustion 

chamber, move pilot control valve.to the open position, and use a 

small propane torch to ignite the pilot flame inside the combustion 

chamber. 

6. Replace the heat register cover plate. The adjustment arm for 

the register louvers should be located so that it cannot vibrate 

closed. 

7. Adjust register louvers for proper air flow. This will require 

trial- and error-adjustments until the best settings are achieved. 

8. Turn fuel pump electrical switch to toluene position as indicated 

on control panel. 

9. Open toluene fuel control valve slightly to allow fuel lines to 

fill with toluene. This can be observed by watching the toluene 

flow in the input line connected at the rear of the generator 

trailer. 

10. A small flame now should be evident inside the combustion chamber 

and the recorder should be indicating a low level smoke plume 

(less than 20 percent opacity). 

11. Check to be sure that the pilot light is burning. 

12. Check for possible fuel leaks at all connecting points in fuel 

lines and check for kinks or blockage in the fuel lines. 

13. Turn off pilot light and determine whether fuel cat; flow into the 

fuel tray mounted inside the combustion chamber. Before attempting 

this, make sure pilot light is off. Do not attempt to light the 

unit if more than 0.25 oz toluene is in the fuel tray. 

40 
P.57 

14. Allow sufficient time for removal of air from remote fuel lines. 

15. Repeat the preceding steps if the system appears to be functional. 

If the unit fails to function, review all steps and details carefully until the problem is found and eliminated. 

16. Allow the combustion chamber to warm up for a reasonable time before 

proceeding with 20 percent opacity. Allow a 10- to 20-minute warmup 

before starting the initial run. 

17. The desired black smoke opacity readings now can be set by adjusting the toluene fuel control valve. Stable readings can be achieved 

after a few minutes practice. Best results are achieved with slow 

but firm changes in the control knob setting. 

18. Readings of 80 percent opacity or higher should be held for only 

brief periods to protect the generator from excessive heat buildup. 

19. The pilot light should be left on between black smoke runs and until the generator is shut down for the day. 

20. Be sure that all toluene is burned out of the combustion chamber 

before proceeding to shut down the generator. 

4.4.8 Black Smoke Assembly Shutdown Procedures 

1. Turn fuel pump at control console to OFF position. 

2. Turn toluene fuel control valve to OFF position. 

3. Be sure all fuel is burned in the combustion chamber. This will 

be indicated by a few minutes of clear stack emissions. 

4. Turn off main valve on propane bottle if no other runs will be 

conducted with either black or white smoke. 

5. Cool the combustion chamber by running the main fan for at least 

10 minutes after fuel shutdown. 

4.4.9 Procedure for Producing White Smoke Plume 

Prior to generating the white smoke, be sure that all the toluene is 

burned out of the black smoke combustion chamber before proceeding. The 

main blower should be turned on and running, and the front of the smoke generator trailer should be slightly elevated to prevent any fuel oil spillage frcm 

pooling in the vaporizer cabinet. The following steps outline the procedure 

for producing white smoke plumes. 

41 
1. Make sure the vaporizer burner valve is in the closed or OFF position (fully clockwise). 

2. Open main valve on propane bottle. 

3; Open lid on vaporizer assembly cabinet. Check for any fuel oil 

or liquid in the cabinet chamber. 

4. Ignite the vaporizer burner flame with a small propane torch. 

5. Adjust the vaporizer burner valve until there is a smooth blue 

flame at the input to the fuel vaporization burner chamber. 

6. Allow the vaporization chamber to warm up for at least 5 minutes; 

a little longer time is needed in extremely cold weather. The 

intake throat of the vaporization chamber should appear slightly 

red before any No. 2 fuel oil is injected. 

7. Slightly open No. 2 fuel oil valve on console fuel control panel. 

A low opacity white smoke plume now will be indicated on the 

console recorder and it will be visible from the stack. 

8. If no white smoke is visible, shut off the fuel oil valve and check 

that the vaporizer burner is working. 

9. Slowly open the fuel oil control valve one more time. White smoke 

should be indicated and visible. 

10. If no smoke is produced, shut off the vaporizer burner and allow 

the unit to cool down. 

11. Check for blockage or leaks in fuel oil lines. 

12. Check to ensure that fuel oil will flow into vaporizing chamber. 

13. If all checks are positive and no excess oil is in the vaporizer, 

repeat the startup steps. If the unit still does not generate, 

shut the unit down and repeat each step until the problem is found 

and corrected. 

When the unit is ignited and operating, the white smoke vaporizer assembly 

should produce any desired opacity. Be sure to always guard against flooding 

of the fuel oil vaporization chamber. Do not open the fuel oil control valve 

beyond the initial point when 100 percent opacity is registered on the console 

opacity recorder. 

4.4.10 White Smoke Assembly Shutdown Procedure 

The following steps outline the proper shutdown procedure for the white 

smoke assembly. 

42 
P.59 

L Turn off the fuel pump at control console. 

2. Turn off fuel oil control valve. 

3. Allow all fuel to vaporize from the vaporization chamber. This 

will require only 2 or 3 minutes and will be indicated by a 0 percent opacity reading on the recorder. 

4. Turn off vaporization chamber propane torch. 

5. Turn off valve on propane bottle if no other runs are to be conducted with either white or black smoke or if the generator will 

be unattended over a lunch break, etc. 

6. Run main blower for 10 minutes to cool vaporizer heat chamber. 

7. At the completion of the certification runs, repeat the calibration 

procedures and record calibration data on the applicable forms. 

4.4.11 Generator Shutdown 

When the training session is over, the generator must be shutdown and 

secured for storage. The following steps outline the generator shutdown 

procedure. 

1. Ensure that both fuel control valves are completely off (turned 

clockwise). 

2. Be sure that all propane control valves are fully off (starting 

with the main bottle valve, the white smoke torch valve, and the 

toluene igniter valve). 

3. Disconnect fuel lines at trailer and insert ends into their 

respective fuel storage tanks. If proper connect procedures were 

followed, the blue connector should go into the toluene tank and 

the green connector should go into the kerosene or fuel- oil storage 

tank. 

4. Disconnect fuel supply lines (the short set) from fuel storage 

tanks and elevate them to avoid unnecessary spilling of fuel. 

Turn on the fuel pumps to drain the lines of fuel. 

5. Remove fuel lines from console disconnects. Elevate one end to 

fully ensure fuel drainage and cap the ends for storage. 

6. Cap the male connectors on console. 

7. Turn off the PA system. Disconnect the PA system components and 

store properly. 

43 
P.60 

8. Turn off all electrical control switches, starting with the induced 

draft fan (when the generator has cooled sufficiently), then the 

recorder power control switches, and finally the main power switch. 

9. Disconnect the generator from the AC power source. 

10. Remove the electrical system interconnects from the trailer junction 

box and the rear of the console control panel. Coil and store the 

cables in a dry and secure facility. 

4.4.12 Procedures for Lowering Upper Stack Section 

The following procedure should be followed to properly lower the upper 

stack section. 

1. Open cradle hold-down bracket. 

2. Partially open hydraulic bleed valve. 

3. Slowly tip the stack so it can work with the hydraulic system. 

4. The stack can be lowered by inserting a large screwdriver between 

upper and lower stack flange sections and applying leverage. 

5. Be careful not to let the stack get out of control and drop too 

suddenly. This can be controlled by careful adjustment of the 

bleeder valve. 

6. Close stack cradle and secure in place for.travel. Bleeder valve 

should be left open to prevent damage to stack caused by accidental 

activation of the pump; 

4.4.13 Transporting Smoke Generator 

The smoke generator is designed to be transported to various training 

sites to reduce student travel time and cost. The following items should be 

checked prior to transporting the generator. 

1. Bolt down stack in the cradle support. 

2. Protect fuel storage tanks by padding the inside portion of their 

storage compartments. 

3. Check trailer tail lights and turn signals for proper operation. 

4. Ensure that the tow vehicle is adequate and has the proper hitch 

assembly. 

5. Check tires for proper inflation and be sure that the lug nuts are 

secure. 

44 
P.61 

6. Be sure that the trailer and two vehicles have sufficient braking 

capabilities to ensure safe transport since the smoke generator 

is heavy. 

7. Transport the control console inside the towing vehicle—not on 

. the trailer. 

8. Upon arrival at. the designated training site, check the trailer 

and generator component system for possible damage, loose bolts, 

etc. 

4.5 STORAGE AND MAINTENANCE OF THE SMOKE GENERATOR 

Proper storage and maintenance procedures are essential for smoke generators since they not only increase the lifetime of the instrument but also 

provide better quality assurance. 

4.5.1 Storage of Smoke Generator 

The modern smoke generator is a complex and sensitive electronic instrument that requires care and protection in both handling and storage. The 

electronic console must be stored in either a heated facility or environment 

when not in actual operation, and must be covered with a plastic sheet when 

exposed to rainfall. The electrical interconnect cable can be stored in a 

generator storage compartment as long as it is reasonably dry. Although the 

basic smoke generator trailer unit can be stored outdoors, storing the unit 

in a warehouse or garage will increase its lifetime and result in lower maintenance requirements and operating costs. If the trailer is stored outdoors, 

the stack transmissometer section must be protected by a waterproof cover. 

A tarpaulin covering the entire generator may be used, but the covering must 

place no stress on the stack fans or the transmissometer electrical connection. Any unit stored in such a manner should be checked frequently to ensure the integrity of the protection. 

4.5.2 Maintenance Procedures 

Before and after each smoke school, the following routine maintenance 

procedures should be performed. 

1. Check all electrical cables to verify that there are no frayed 

parts, that all contact points are clean, that the connectors 

are not bent, and that the cables have good integrity. 

45 
P.62 

2. Check all fuel lines to ensure that they are unkinked; have no 

weathered or worn spots, splits, or leaks; and that the connectors 

are in good condition. Since ferrules can be easily lost inside 

the connectors, verify that these are present. 

3.. Use liquid soap or similar leak-check commercial products to check . 

the integrity of the fittings to the propane tank for leaks. 

4. Check the propane gas supply by weighing the cylinder. 

5. Assemble and check the PA system to ensure proper operation. The 

PA system should be stored with the console unit. 

6. Check that the small drain hole in the bottom of the stack is open 

so that water will not accumulate in the stack. 

7. Check the transmissometer calibration to ensure that the system 

has not aged or deteriorated and that the calibration curve is 

still good. 

8. Check the recorder pin assembly to ensure that it is operating 

correctly. This can be performed by turning on the transmissometer 

and turning the signal attenuator to the right and left to make sure 

that the recorder pin will travel up and down the scale. An alternate procedure is to turn the transmissometer on and off to ensure 

that the pin will drive back and forth smoothly from one side to 

the other. 

9. Inspect the fire box after it has cooled by inserting a mirror in 

the side. Make sure that the torch and deflector plate are in 

good condition and that the fire box has not been damaged in 

transit. 

10. Place a drop of oil on each of the bearing surfaces and in the oil 

drop slot on either side of the electric motor. 

11. Verify that all storage compartments contain the appropriate items 

and that these compartments are locked. 

12. Keep a bound logbook to record all events that bear on the performance 

of the smoke generator. Such events include records of all repair 

and maintenance work, spectral response checks, calibration checks, 

response time checks, dates of use, number of runs completed, best 

estimate of fuel consumption, and any other pertinent information. 

This book should be maintained by the generator operator and checked 

every six months by the training supervisor. Entries should be 

made whenever the generator is serviced, repaired, and/or operated. 

46 
4.6 COMMON PROBLEMS, HAZARDS, AND CORRECTIVE ACTIONS 

The proper operation and maintenance of a smoke generator requires personnel with a high degree of skill and instrument knowledge. The training 

supervisor is responsible for ensuring that a qualified person is present 

and that proper calibrations, checks, and safety procedures are followed. 

The generator should always be in top condition and ready to operate. 

To ensure optimum operation, the preliminary certification checks should be 

performed at least one day prior to the scheduled training and certification 

runs. For this preliminary run, the generator operator should review the 

applicable provisions of Method 9 and sections of this publication to ensure 

that all steps are performed. 

A number of problems can develop that may interfere with the proper opera- . 

tion of the smoke generator. Some of the' more common problems and solutions 

are discussed in this section. 

4.6.1 Fuels 

The use of improper fuels can cause several problems. The following 

fuel selection guidelines should be helpful in avoiding these problems. 

4.6.1.1 Black Smoke — 

Originally, most smoke generators produced black smoke by the incomplete 

combustion of fuel oil. In the late 1960's, many operators found better results using benzene as the fuel. While benzene was fairly successful, it is 

a highly toxic substance and hazardous when improperly used. In June 1977, 

EPA issued a memorandum which stated that an adverse health problem may be 

associated with the use of benzene and strongly suggested that other fuels 

be used instead. Possible alternatives include toluene, xylene, kerosene, 

and No. 2 fuel oil. Table 2 lists the various properties of these fuels. 

Although all of these fuels are suitable, toluene appears to be the most 

suitable fuel for producing black smoke. Care must always be used when handling 

any fuel since they are flammable. Possible adverse health effects are also 

associated with prolonged and unnecessary exposure to benzene, toluene, and 

xylene. 

47 
P.64 

TABLE 2. PROPERTIES OF CANDIDATE FUELS 

Fuel 

Benzene 

Toluene 

Xylene 

Kerosene 

No. 2 oil 

Composition 

C 6H 6 

C 7H 8 

C8H10 

Higher paraffins and 

naphthenes 

Paraffins, 

aromatics 

and napthenes 

Freezing 

point, 

°C 

55 

-95 

-25/+13 

«__ 

Boiling 

point, 

°C 

80 

111 

138-144 

79-227 

282 

Threshold 

limit 

value, 

ppm 

10 

100 

100 

a 

a 

Remarks 

Carcinogenic 

Requires increased accuracy 

in adjustment of 

fuel-to-air 

ratio compared 

with that required for 

benzene 

Burns too hot 

Gives brown smok 

Clogs valves 

threshold limit value will be greater than 100 ppm, although exact value 

depends on concentration of each specific compound. 

4.6.1.2 White Smoke — 

White smoke is made by vaporizing kerosene or No. 2 fuel oil. This 

usually is done by injecting the fuel oil either onto the hot exhaust-from 

a self-contained gasoline engine or onto a heated surface, causing the liquid 

droplets to vaporize and then condense into a thick white cloud. Both fuels 

appear to perform equally well. The No. 2 fuel oil tends to clog the valves 

and produces slightly less smoke per gallon of fuel than does kerosene. 

Variations in the volatility of some kerosenes result in their tendency to 

ignite or flash when the vaporizer overheats. The operator should be aware 

of this and be prepared to react accordingly if kerosene is to be burned. 

48 
P.65 

4.6.2 Overheating 

Overheating either the combustion chamber or the vaporizer can permanently 

distort the unit, resulting in unstable smoke production or reduced opacity 

capability. Overheating is easily avoided by properly fueling the vaporizer 

and limiting the durations of high opacities. Once a vaporizer is severely 

damaged, it must be replaced in order to achieve satisfactory service. 

4.6.3 Breakdowns 

The new model generators are designed and fabricated for durable field 

use and portability. Like all electromechanical devices, however, the generator will occasionally break down or malfunction. The problem must be diagnosed 

and repairs made expeditiously to maintain the proper training and interest of 

the attendees. The inventory of spare parts should be based on the more common 

needs and rnalfunctions. Experience over the years shows most failures to be 

in the areas listed in Table 3. 

4.6.4 Modifications to Improve Performance 

In recent years, the operation of the smoke generator has been improved 

with a number of important modifications in: 

o design of the black smoke combustion chamber 

o switch from the exhaust .manifold vaporizer to the hot 

plate vaporizer 

o photopic transmissometer system 

These improvements are adaptable to most basic generator units, if the frame 

and support assembly are sturdy and in good condition. Cost may be.optimized 

by simply replacing the troublesome component. Outlined are some modifications that can be made, however, to improve the operation of some of the 

older model generators. 

1. Place a baffle plate or refractory assembly in the air inlet opening 

of the combustion chamber to provide better air/fuel mixing conditions 

and to stabilize smoke production. Some experimentation may be 

needed to determine optimum location for the baffle. 

2. Reduce fuel line plugging significantly by-adding an inline fuel 

filter, which is standard equipment on the newer model generators. 

49 
P.66 

TABLE 3. COMMON SMOKE GENERATOR MALFUNCTIONS 

Malfunction Cause Problem 

Power failure Overloading the circuit 

to blow a fuse or trip 

the circuit breaker; 

this should not occur 

because the generator 

should not overload 

the standard 110 

VAC/15 A service 

Electrical connection 

has been broken or 

disconnected 

Locate service panel; 

check fuse or circuit, 

breaker; replace or reset as necessary; if 

power fails again, the 

circuit is being overloaded; locate and 

use another electrical 

service 

Reconnect and secure 

Loss of signal to 

the recorder 

Light source burned 

out or broken 

Loose wiring 

12 V power supply 

failure 

Replace bulb 

Locate and repair loose 

connections; this condition is frequently 

intermittent and may 

require some movement 

of wiring and tracing 

and insulation with a 

test of a continuity 

meter 

Connect to a 12 V DC 

battery until power 

supply pack is replaced 

Unstable smoke Wind influences, 

> 15 mph 

e.g. Check orientation of 

trailer in relation to 

wind direction; rotate 

trailer 30 to 60 degrees 

Poor air/fuel 

mixture 

Air flow into combustion chamber or deterioration of combustion chamber; wind 

direction may also be 

a problem 

Determine most probable 

cause by inspection and 

experimentation; if 

combustion chamber is 

deteriorated or warped 

by heat, replacement 

may be required; 

attempt to install a 

baffle at air inlet by 

placing a brick or metal 

baffle in entrance 

(continued,' 

50 
TABLE 3 (continued) 

P.67 

Malfunction 

Fuel flow problems 

or 1ine blockage 

Cause 

Dirty fuel filters 

Fuel pump failure 

Fuel line kinks or 

plugging 

Carbonization of 

burner tips 

Problem 

Replace or install fuel 

line filters 

Replace fuel pump; 

implement a temporary 

measure by switching 

the fuel lines to the 

operable pump; Note: 

Replacing fuel pump 

requires shutting off 

generator for 30 to 60 

minutes if possible, 

replace at lunch break 

or end of day 

Inspect fuel lines; if 

plugged, disconnect end 

and blow out debris 

Run a thin stiff wire 

through the orifice 

51 
P.68 

3. Minimize wind shear by increasing the main blower air flow since 

many of the older model generators have inadequate blower 

capacity. Wind shear is a common problem in areas that frequently experience wind speeds in excess of 12.mph. If the 

training session area has a prevailing wind direction, position 

the generator so that the wind does not blow directly into any 

openings in the smoke flow passages. If the wind shears off the 

plume at the top of the stack, a 90 degree elbow with laminar flow 

vanes may be used to allow the smoke to exit the stack parallel 

to the wind. This provides the trainees a better opportunity for 

certification by reducing the eddy effect. The elbow has been 

proven in field use, with some individuals reading successfully 

during winds exceeding 20 mph. 

4.6.5 Safety Requirements 

The normal safety requirements for trailer towing and handling apply 

to transporting the generator. Brakes, lights, etc. should be checked each 

time the trailer is moved. Wheel chocks must be used whenever the trailer 

is disconnected from a vehicle, and additional care must be exercised if the 

generator is located on an inclined surface. 

Since smoke generation fuels are flammable, proper and sensible 

storage and handling precautions must be followed. Possible health hazards 

of handling the fuels should be recognized and the equipment should be 

operated only in open ventilated areas. Proper explosion-proof fuel should 

be used and any fuel transfer operations should be conducted with care. A 

fully charged and functional fire extinguisher must always be readily 

available whenever the generator is operating. 

Because unit surfaces become hot while the generator is in operation, 

persons not involved and familiar with the equipment should remain at a 

safe distance. A pair of protective gloves should be available to handleany hot items, and operators should always wear safety glasses when working 

around the generator. Carelessness and shortcuts can result in serious 

injuries. 

Some internal components of the console have a 110-V electrical charge 

that poses a potential hazard especially during damp field conditions. A 

voltmeter connected to a grounding rod can be used to monitor electrical 

shorting conditions. 

52 
P.69 

SECTION 5 

CERTIFICATION REQUIREMENTS 

This section provides procedures for conducting the certification part 

of the training program. To ensure proper quality assurance, the certification must be attended by at least two people--one to operate the generator 

and the other to instruct the students, monitor student activity, ensure that 

the smoke is readable, answer student questions, grade records, etc. A third 

person is also recommended to assist with the above activities as well as to 

provide an additional element of quality assurance, especially for classes 

with 25 or more' trainees. 

Prior to firing up the generator, the instructor should identify the 

components, explain the operation of the generator to the trainees, and allow 

them to examine the equipment.- Safety requirements.should be discussed, and 

the trainees should be reminded to stay away from the generator during training and test runs. The instructor should also emphasize that the generator 

has hot surfaces that can cause serious burns and that there are numerous 

electrical cables and fuel lines which, if accidentally disconnected, could 

shut down the generator and delay the entire program. 

The first part of the certification test will.be a "test run." Both 

black and white smoke will be emitted, and the opacity announced in order to 

familiarize the trainees with the procedures and help "calibrate .the-eye" 

to the announced readings. 

After the initial test run, certification runs will be made in blocks of 

50 readings (25 black and 25 white). After the certification criteria have 

been achieved, the trainee must check that the form has been completed correctly and signed. It also is recommended that the trainee recheck the 

arithmetic on the form to avoid any errors in transcription or arithmetic 

that might preclude certification. Each form will then be checked by at 

least two other people to further assure that all criteria and requirements 

have been satisfied.. Those trainees who successfully meet the criteria will 

receive a letter of certification and a copy of the qualification form. 

53 
P.70 

The original qualification form is retained by the school for at least 3 

years for possible presentation in any future legal proceedings or challenge 

of certification. Note: Certification is valid for a period of only 6 months 

according to Method 9. 

Recertification procedures are identical to testing procedures, except • 

that the lecture series is usually omitted. Though presently not required, 

it is recommended that the trainee repeat the entire lecture portion of the 

school every third year to reemphasize techniques and to familiarize the 

trainee with new material and procedures. 

5.1 PRACTICE SESSIONS 

Prior to the actual certification runs, the trainee should be exposed 

to a series of practice readings over the full range of opacity levels in 

order to allow an adjustment or "eye calibration" period. Calibration with 

the standards is an important element of the 6-month recertification 

requirement of Method 9. Trainee calibration can be achieved in several 

ways, although experience has shown that one of the most effective methods 

is to focus on the 25, 50, and 75 percent opacity levels. 

The practice procedures consist of the following steps outlined in the 

flow chart diagrammed in Figure 18. 

1. Set up the generator and perform the zero and span checks. 

2. Set the chart speed to zero. 

3. Distribute practice test forms (Figure 19) and explain their use. 

The first blank on the form is for the trainee's observed opacity 

estimate, the second for the announced transmissometer readings, 

and the third for the difference in the two values. 

4. Generate a 25 percent opacity white smoke plume for about 3 minutes. 

5. Encourage the observers to walk around and view this opacity 

level at different angles to the sun. 

6. Repeat steps 4 and 5 for 50 and 75 percent opacity. Note: Standards of 20, 40, 60, and 80 percent opacity can also be used. 

7. Begin the practice certification when the smoke becomes steady; 

indicate the beginning of the reading with the word "Ready." 

54 
P.71 

Zero and span check transmissometer and set chart speed to zero 

Distribute practice forms 

Generate 25, 50, and 75 percent opacities in white smoke 

Generate four white smoke plumes 

Nc 

Read actual values 

D yA ,-. 

v i ui ILIeiiLy^ 

Yes 

Generate 25, 50, and 75 percent opacities in black smoke 

Generate four black smoke plumes 

Nt 

-

Fig ure -

Read actual values 

3 ^T.x.-

\riu i i 

18. 

ciencyx 

Yes 

End Practice Session 

Procedure for practi 

55 

ce session. 
cn 

Group 

Color: 

W B 

Group 

Color: 

W B 

Group 

Color: 

W B 

Group 

Color: 

Plume 

No. 

1 

2 

3 

4 

1 

2 

3 

4 

1 

2 

3 

4 

1 

JA 

3 

4 

Run No. 1 

Obs SG 

i 

Dev 

Run No. 2 

Obs SG 

i 

Dev 

Run No. 3 

Obs SG 

1 

Dev 

Run No. 4 

Obs SG 

I 

Dev 

'Obs stands for the observer's opacity reading, SG, the opacity from the smoke generator, and Dev, the 

difference between the tv/o. 

Figure 19. Opacity reading training form. J 
P.73 

i 

8. 

9. 

10. 

11. 

12. 

13. 

14. 

15. 

After the 

Wait at least 1 second and say "Mark" to indicate that the observer 

should record his observation, which he estimates at the moment 

"Mark" is announced. 

On a duplicate practice form, record the transmissometer value at 

the moment "Mark" is announced. 

Repeat steps 7 through 9 four times for values around the 

standards, e.g., 25, 50, and 75 percent opacity. 

After four different opacities are generated, read the actual 

values recorded for the transmissometer and have the trainees 

check their answers. Repeat steps' 7 through 11 with smaller 

shifts in opacity until the trainees become proficient at judging 

opacity in increments of 5 percent. 

Shutdown the white smoke generator. 

Start up the black smoke generator. 

Repeat steps 4 through 11 for black smoke plumes. 

Shutdown the black smoke generator. 

practice sessions, begin the actual certification testing. 

5.2 CERTIFICATION TESTING 

The 

have been 

of readin 

trainees should now be prepared for the certification runs. They 

exposed to the theory and background on opacity, proper techniques 

g, parameters of variables that influence accuracy of readings, 

legalities of sound documentation, and plume opacities simulated by the smoke 

generator 

5.2.1 Preparing for Certification 

The training supervisor and assistant must pay careful attention to the 

details of the certification operatives, and the staff must be able to state 

with certainty that all aspects of Method 9 have been fulfilled. This requires 

meticulous care of all records and information and stipulated QA checks of 

these procedures, thereby ensuring that any passing trainee is technically 

and legal ly certified. 

57 
P.74 

An important element of the QA program is a checklist that itemizes the 

important steps in the certification of opacity readers. This checklist fulfills two important QA needs: 

1. It assures that an orderly preparation and implementation 

procedure has been completed. 

2. It provides documentation and evidence in support of 

quality certification. 

Figure 20 presents an example format for the checklist, which should be 

marked off or initialed as appropriate after each item is completed. The 

training supervisor should check and sign the sheet at the end of the certification exercise. This form then becomes a part of the official file or 

record of the course. 

5.2.2 Test Forms and Recording Procedures 

Test forms vary greatly with the specific needs and experiences of each 

agency. A commonly used form that is both low in error and easy to grade is 

shown in Figure 21. The test form should be printed on two-copy paper so that 

the original can be turned in for the official file and the carbon copy can 

be graded by the trainee. Two test forms printed on regular bond paper with 

carbon paper between them is also satisfactory, although this arrangement 

is more cumbersome to use and subject to greater error and misunderstanding 

in reconciling the original with the carbon copy. In all cases, the agency 

should retain the original test page for the official file and certification 

record. 

The trainee is to circle one answer per line that is judged to be the 

generator opacity at the indicated signal for reading and may change any 

answer by simply Xing out the wrong answer and circling the new choice as 

indicated in the following example: 

20 25 ( ^ © 40 45 50 

It should be noted that the most common error with this form is placing 

the answer on the wrong line. Again, the procedure is to X the incorrect 

answer and circle the correct one. 

20 25 © 35 40 - 45 50 

20 *25 )$&f f&) 40 45 50 

58 
P.75 

Date: Agency: 

Operators: Location: 

Note: Initial each item as completed. Write NA (Not Applicable) where procedure does not apply. 

Generator Preparation 

Check for damage and vandalism 

Verify that a complete inventory of parts 

and supplies (refer to inventory list) 

exists 

Check inflation of tires 

Check operation of brakes, hitch, safety 

chain, etc. 

Lubricate fans and motors 

Check that stack is secure for traveling 

Perform preliminary check of console 

Adequate Fuel Supply 

Toluene 

Diesel or kerosene oil 

Propane 

Other (specify kind and use) 

Generator Setup 

Check background, sky, and wind conditions 

for best generator orientation 

Figure 20. Operator's smoke generator checklist. 

(continued) 

59 
P.76 

Figure 20 (continued) 

Check electrical service and availability 

(110 VAC/20 A, 3 wire grounded connection) 

Ensure that generator is leveled and wheels 

are chocked 

Connect fuel and electrical lines 

Check for fuel leaks (lines, connections, 

and tanks) 

Check fans for smooth, normal noise level operation 

Main or induced draft fan 

Transmissometer fans 

Be sure air volumes appear adequate 

Operation of Generator 

Be sure generator logbook is available 

Be sure that both fuel pumps are operable 

Check chart recorder operation and paper supply 

Check that all fuel valves are in full OFF position 

Check both combustion systems for operating 

condition 

Check operation of safety ignitors 

Turn on console for 30-minute electrical warmup 

Verify that all readout systems are working 

Transmissometer System Calibration 

Zero and span check 

Drift check 

Response time 

(continued) 

60 
P.77 

Figure 20 (continued) 

Light source voltage 

Calibration error (use NBS filters) 

Calibration record completed 

Generation of Smoke 

Raise and secure stack 

Run black smoke stability and range test 

Run white smoke stability and range test 

Check for excessive leaks and proper draft conditions 

Public Address System 

Check that Total Smoke System is calibrated and 

- operating properly for training and certification 

purposes 

Comments -- please list any problems or conditions 

encountered in the setup or startup of the smoke 

generator. 

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P.79 

The form should be completed with one answer per line and all the 

pertinent information provided (see Figure 22). All entries must be made in 

ink. The observer's name, affiliation, run number, course location, and date 

should be recorded; if sunglasses are used, the type and lense color should 

be noted. 

The windspeed should be estimated to within a 3 to 5 mph range. If an 

anemometer is not available, the Beaufort wind scale, Figure 23, may be used. 

Smoke school certification should not be attempted in winds above 25 mph 

which interfere with high quality, stable smoke simulation. A personal discomfort factor under these conditions tends to introduce an additional unacceptable error. 

The wind direction can be estimated to within eight points of the compass 

(N, NE, etc.) by observing which way a flag is blowing, or by observing the 

direction a few blades of grass are blown when thrown into the air. The north 

direction can be obtained by referring to a map. 

The sky condition should be filled in as: 

1. clear - less than 10 percent of the sky covered with clouds 

2. scattered - 10 to 50 percent of the sky covered 

3. broken - 50 to 90 percent of the sky covered 

4. overcast - more than 90 percent of the sky covered 

Certification can be achieved even under total overcast conditions provided the trainees have a contrasting background available. Readings should 

not be attempted during conditions of precipitation. 

The observer's orientation with respect to both the plume and the sun 

should also be indicated on the test.form. 

5.2.3 The Test 

The trainees should now be familiar with the testing procedures and ready 

to begin actual certification runs. The test forms should be distributed and 

the top portion filled in by the trainee for identification as described in 

Subsection 5.2.2. 

Method 9 stipulates that a valid test must have 25 white and 25 black 

smoke plume readings. The candidate must demonstrate the ability to assign 

opacity readings in 5 percent increments, within the following criteria: 

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P.81 

Beaufort Scale of Wind Force 

(Compiled by U.S. Weather Bureau, 1955) 

Beaufort 

number 

0 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 or 

more 

Mi 1 es 

per 

hour 

Less 

than 1 

1-3 

4-7 

8-12 

13-18 

19-24 

25-31 

32-38 

39-46 

47-54 

55-63 

64-72 

73 or 

more 

Knots 

Less 

than 1 

1-3 

4-6 

7-10 

11-16 

17-21 

22-27 

28-33 

34-40 

41-47 

48-55 

56-63 

54 or 

more 

Wind effects observed on land 

Calm; smoke rises vertically 

Direction of wind shown by smoke drift; 

but not by wind vanes 

Wind felt on face; leaves rustle; 

ordinary vane moved by wind 

Leaves and small twigs in constant 

motion; wind extends light flag 

Raises dust, loose paper; small 

branches are moved 

Small leaves in trees begin to sway; 

crested wavelets form on inland' 

waters 

Large branches in motion; whistling 

heard in telegraph wires; umbrellas 

used with difficulty 

Whole trees in motion; inconvenience 

felt walking against wind 

Breaks twigs off trees; generally 

impedes progress 

Slight structural damage occurs; 

(chimney pots, slates removed) 

Seldom experienced inland; trees 

uprooted; considerable structural 

damage occurs 

Very rarely experienced; accompanied 

by widespread damage 

^lery rarely experienced; accompanied 

by widespread damage 

Terms used 

in USWB 

forecasts 

Light 

Gentle 

Moderate 

Fresh 

Strong 

Gale 

Whole Gale 

Hurricane 

Figure 23. Beaufort Scale of Wind Force. 

65 
P.82 

1. No reading may be in error by more than 15 percent 

opacity. 

2. The average error must not exceed 7.5 percent for 

either set of 25 white or 25 black smoke readings. 

Failure to meet either of these criteria is considered to be an unacceptable' 

demonstration of reading accuracy, and the observer has failed that particular 

run of 50 readings. 

The runs can be repeated as many times as needed to meet the criteria 

for certification. A minimum of 10 runs should be made available during a 

given certification session. Generally, students pass certification in three 

or less runs and more than 95 percent pass within the 10 runs. The steps 

below are to be followed in the testing session: 

1. Set up the generator, allow warmup period, and perform the zero 

and span checks. 

2. Distribute the certification forms, and have the trainees fill 

out the top (Figure 22). 

3. Open the white smoke valve. 

4. Generate the first standard opacity smoke plume. 

5. Turn off all valves. Wait until emissions are not visible and 

the transmissometer trace is flat. 

6. Repeat zero and span checks. 

7. Announce the start of the test, give the run number and time. 

8. Start the strip chart recorder. 

9. Open the fuel valve and allow the smoke to stabilize within 1.5 

percent opacity of a 5 percent scale line (Figure 13). 

10. When the smoke has stabilized, say "Number one" and begin the 

trace on the strip chart. 

11. After 1 to 2 seconds, say "Mark" if this reading stayed within the 

1.5 percent opacity limits. Stop the recorder and number the 

reading. Restart the strip recorder. If unacceptable, say 

"Scratch" and repeat the recorder. Students do not mark their 

papers unless "Mark" is announced. Mark the unacceptable reading 

"Void" on the chart and initial. 

66 
P.83 

12. Repeat steps 8 through 10 for the remaining 24 white smoke 

readings. The opacity of these readings must be selected in a 

random order. 

13. Shut off the white smoke valve. 

14. Check the zero and span transmissometer drift. If the values are 

within 1 percent of 0 and 100, go on to step 15. Otherwise, wait 

15 seconds and repeat the check. 

15. Open the black smoke valve and proceed with steps 4 through 11 

for.readings 26 to 50. The opacities must again be selected at 

random. 

16. Collect the original or top sheet of the two-part form. After 

all trainee forms have been collected, give the correct readings. 

This allows the trainees to check their own reading so they can 

adjust and calibrate their readings as necessary. 

In general, people frequently tend to read either slightly higher or 

slightly lower than the actual value. If that is happening, the observer can 

make the mental adjustment and at that point can proceed refining and reinforcing his skill. It is suggested that the trainees continue their readings 

for all runs even though they may have certified in the first few runs. This 

additional practice serves to refine the newly developed skills. This is not 

as important during recertification tests, however, especially if the person 

is routinely engaged in making official opacity readings. 

5.2.4 Ensuring a Valid Certification Run 

The instructor must make sure that the trainees read the plume opacity 

at the same time the transmissometer records the opacity. Many schools rely 

on audible signals for informing the trainees when to read the plume. A 

major problem with this is that some trainees tend not to read instantaneously, 

as suggested, but rather give the plume a lingering stare. This is a common 

reason for failure to certify, since the transmissometer reading may have 

already started moving to- the next opacity reading. Readings must be made 

within a second of notification to mark. 

This potential problem can be corrected easily by using a public address 

system to cue the readers and by modifying the chart recorder so that the 

pen gives an instantaneous rather than a continuous trace. A rubber band 

should be wrapped around the tracing bar and anchored to a heavy paper clamp 

67 
P.84 

on top of the console. When the generator has sufficiently stabilized for the 

first reading, the operator should place a finger on the trace bar. While 

pressing down on the trace bar to allow the pen to contact the paper, he should 

simultaneously announce "Number one." The pen should trace for 2 to 3 seconds. 

The operator should then release the bar simultaneously and announce "Mark." 

The trainees should be instructed.to read between the two announcements of 

"Number one" and "Mark." This results in an exact trace of the transmissometer 

reading during the precise period the students are to read. Should the smoke 

destabilize and cause the opacity to jump greater than +2 percent, the instructor should void that number by announcing "Scratch" and indicate it on 

the chart record. 

The generator operator should circle and number each acceptable trace 

for full and accurate identification. He should indicate with an X any unacceptable trace, write VOID adjacent to it, and initial it to avoid any 

confusion on the validity of readings. The traces on the strip chart recorder 

discussed above are illustrated in Figure 13. The operator should clearly 

mark the strip chart at the beginning and end of each run and identify each 

run with the date, time, run number, and color of smoke. This is easily 

accomplished by use of a rubber stamp similar to the one illustrated in 

Figure 24. The operator should note and initial any event that could impact 

the validity of a run on the strip chart. In addition, any lengthy or detailed explanation should be noted in the bound logbook. 

METHOD 9 CERTIFICA' 

DATE 

RUN # 

TYPE 

CHART SPEED 

+ STOP TIME 

OPERATOR 

•ION RUN 

Figure 24. Certification run identification stamp. 

68 
P.85 

5.3 GRADING AND DOCUMENTATION PROCEDURES 

If a test form similar to the one shown in Figure 24 has been used, 

accurate grading is relatively simple with the aid of a grading key. The 

moderator can produce this key by marking the correct value for each reading 

with a china marking pencil on an acetate copy of the form. .The moderator 

should then place the acetate key over each form to be graded and identify the 

difference between the correct answers and the trainee's answers. With 

practice, an error exceeding 15 percent (three or more 5 percent increments) 

is quickly spotted. 

The moderator should count the number of increments of 5 percent error 

for both sets of 25 readings and compare the average deviation (D) for each 

run of 25 readings using the following equation: 

* (Sum of Positive Deviations) - (Sum of Negative Deviations) 

u " 25 

An alternate system is to total the number of increments of 5 percent error 

(both positive and negative)-and read the average deviation from the chart 

presented in Table 4. If a chart is unavailable, the total number of percent 

increments on 25 readings can be multiplied by 0.20 to get the average deviation. These two methods are illustrated in Figure 25. 

Several different grading methods are used. Some training supervisors 

prefer that all grading be done by the course moderators without trainee 

participation. Involving the trainees, however, enhances learning. The 

moderator collects the original sheet of the test form at the end of each 

run. The trainee retains the second copy for initial grading. After all 

original copies for a run have been collected, the transmissometer opacity 

values are announced. The trainees grade their copy of the run. The generator 

operator can prepare a master copy of the opacity readings as the values are 

announced to be used as the acetate grading key for the official grading. 

After the readings have been announced, the trainees are given a few 

minutes to check their paper and to recognize any needed adjustments in their 

reading skills. The training staff, however, must make the official determination of certification. 

In sessions involving a large number of students, another run may be 

started while one staff member continues grading. The graded forms must be 

69 
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P.87 

> • • '< ' y.-. • • " - V ;-T -T»""WI" ,f. .,"•'•"«" 

. Reading 

1 1 

'2 

3 

4 

5 

6. 

7 

8 

9 

10 

11 

12 

Deviation, 

+ .5 

0 

-10 

0 

- 5 

-10 

0 

0 

0 

-15 

0 

+ 5 

% Increment 

1 

0 

2 

0 

1 

2 

0 

0 

0 

3 

0 

1 

Method 1: 

s _ (Z pos read) - (E neq read) 

u 25 

30 + 75 

D =

 JU

2 5

 /5 = 4.2% 

TOTAL 105 

2 

2 

1 

0 

0 

0 

1 

0 

2 

0 

1 

1 

_1_ 

21 

Method 2: 

D = Number of 5% increments x 0.2 

D = 21 x 0.2 = 4.2%' 

Figure 25. Two methods for determining average deviation for 25 readings. 

71 
P.88 _ 

crosschecked for accuracy before a trainee is officially notified of certification. A copy is sent to the individual along with a letter of certification 

and preferably a wallet card stating the period of certification. Details of 

this technique are listed in the following step-by-step procedures. 

1. Complete an official run of 25 white and 25 black readings. 

2. Collect the original (top white) copy of each trainee's certification form (Figure 22). Place them in the field file and 

retain in the possession of a training staff member. 

3. Take a blank certification form, remove the carbon copy, and 

place the test form on a clipboard. 

4. Write "Master" in the space for the observer's name. Fill in the 

run number, date, location, and time of the test run. 

5. Correctly record the values on the form as they are read from the ' 

strip chart. Be sure to ensure accuracy. Make five random 

rechecks with the chart record. Allow the trainees to grade 

their (carbon) copy as this is done. 

6. Place a grading acetate over the master, watching alignment 

carefully. 

7. Using a marking pencil make a diagonal slash from upper left to 

lower right (\) over each marked number on the grading master. 

File the acetate with the originals. 

8. Turn the grading master over and record the names of the trainees 

who think they have qualified. Theirs are the first papers to be 

graded. 

9. Remove those papers from the file. Select one and align the 

acetate over it. 

10. Count from the mark on the acetate to the mark on the trainee's 

paper. Each 5 percent is counted as one. For example: 

(3) (2) (1) 

30 35 40 45 50 Error = 3 

Value Correct 

value 

11. Add all of the errors for the 25 white smoke readings and record 

the sum on the line marked "Deviation." 

12. If no single error is more than 3 and the total number is 37 or 

less, repeat steps 9 and 10 for the 25 black smoke readings. 

72 
13. If no single error among the black smoke readings is- more than 3 

and if the total number is 37 or less, stamp the paper "Qualified" (Figure 26). 

14. Sign the line labeled "Graded by," and have the supervisor verify 

the grade. 

15. Enter the trainee's name, address, and qualifying run number in 

the VE program roster in a bound logbook (Figure 27). 

16. Compute the average deviation for each color of smoke and record 

this value on the test form under "Deviation" in the roster. 

17. Inform the trainees who have qualified. 

18. Send a certification letter and wallet card to each trainee who 

qua!ified. 

QUALIFIED 

Graded fayl 

Verified by_ 

Figure 26. Certification stamp. 

5.3.1 Maintenance of Records 

The top sheet of the test form collected from each trainee at the end 

of each run is part of the documentation of an individual's certification as 

a qualified observer. A training staff member must collect these before 

announcing the correct values, and these forms must remain in staff custody 

thereafter. This control procedure prevents cheating or manipulation. 

A bound logbook should be maintained for recording all events that might 

affect the performance of the smoke generator. This logbook should include 

records of repairs, maintenance work, spectral response checks, calibration • 

checks, response time checks, etc. In another logbook, records should be 

kept of the number of attendees receiving training; the number of trainees 

certifying; and their name, address, scores and average deviation, dates of 

training, etc. The original of each individual's certifying run, the 

73 -
P.90 

Date: 

Generator #: 

Location: 

Comments: 

Name and Address 

Fe

e paid 

Training 

Recertifying Q

R Number 

Date Dev. White Dev. Black 

Bias White 

Bias Black 

Certification 

Grader: Signature_ 

Instructor: Signature_ 

Initial_ 

Date 

Date 

Figure 27. Sample VE program roster. 

74 
P.91 

checklist, the recorder strip charts, the VE program roster, and.any other 

pertinent information should be maintained in the agency's official file. 

This information may be needed for presentation at legal proceedings 

as evidence that the inspector or person in question has been certified as a 

qualified VE evaluator by a recognized smoke training and certification group. 

These files should be arranged by training session and maintained for 

at least 5 years to be available for use in any future legal proceedings that 

may occur. 

5.3.2 Certification Letters 

Within 2 weeks of the training session, each trainee who successfully 

meets the Method 9 criteria should be mailed a letter of certification or 

verification and a copy of their qualification form. An example letter is 

shown in Figure 28. 

Some agencies provide wall certificates and/or wallet cards to each 

successful participant. At least one of these should be provided and it 

should contain the following information: 

1. Participant's name 

2. State where accomplishment took place 

3. Date of certification 

4. Date of expiration or statement that certification expires 6 months 

from date of certification 

5. Location of course 

6. Signature of course moderator or other selected official 

Certificates should be numbered in sequence and a record maintained in order 

to account for each certificate. 

75 
P.92 

ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NORTH CAROLINA 27711 

August 12, 19 81 

Mr. John Doe 

U.S. EPA 

Research Triangle Park, North Carolina 27711 

Dear Mr. Doe: 

Please be advised that you successfully completed our recent 

Visible Emissions Evaluation course. Having attended the 

lectures (March 8, 1982) and participated in the smoke evaluation sessions, you met the following certification criteria: 

1. The average deviation for the sets of 25 black 

and 25 white smoke emissions was less than 7.5%. 

2. The deviation of each reading was 15% or less. 

This certification is valid until September 7, 19 82. 

Sincerely yours, 

John L. Forrest 

Physical Science Technician 

State Air Quality'Training 

Division . -

Figure 28. Certification letter. 

76 
P.93 

SECTION 6 

QUALITY ASSURANCE - TECHNIQUES AND PROCEDURES 

Several recent court decisions have favored industrial efforts to resist, 

question, and discredit the application of opacity readings in enforcement/ 

compliance documentation. Problems can be most readily avoided through a 

structured and consistently applied QA program that includes the elements 

stressed throughout the previous sections. Although this section will 

describe in concise detail a recommended program, it is not intended to represent the ultimate or ideal program. Each school should review its operations and needs, and then design an integrated QA program accordingly. 

A QA program, in concept and implementation, is a management tool or 

operational mechanism for assuring credible training and certification. To 

ensure success, this program must receive the commitment, support, and followup of management. This additional effort will help to readily identify smoke 

school weaknesses and shortcomings that must be resolved. If properly 

implemented, this program will provide the extra element of documentation and 

credibility that will withstand the investigation and scrutiny of special 

interest challenges. 

6.1 QUALITY ASSURANCE AUDITS 

The QA program consists of two distinct program operations that are complementary and mutually supportive. One program is operated integrally with 

the presentation of the smoke school and focuses on the operation of the 

smoke generator. This program provides the extra effort needed to assure 

routinely accurate and reliable training and certification. Such an effort 

includes the planning of the program; preparation, calibration, and operation 

of the generator; recordkeeping and documentation; and trainee control. This 

program has been suggested and emphasized throughout the previous sections. 

77 
P.94 

iipj.lipi • II P f ! 

Another important element of QA is auditing. A VE program audit is an 

external review of tke program by use of structured evaluation forms. The 

audit is usually conducted by supervisory personnel to assure objectivity. 

Audits are designed to identify program weaknesses and deficiencies that must 

be addressed and corrected in order to maintain an effective and high-quality 

opacity training and certification program. 

A performance audit is a structured and routine review of the various 

steps in the training and certification process. It generally consists of a 

number of specified checks to ensure that proper and accurate procedural activities have been completed. The performance audit is conducted by the 

training supervisor and/or designated staff, and is most applicable to fairly 

specific and routine procedures. Appendix B includes example formats for inspection and operation of the smoke generator/transmissometer unit and the 

handling of certification test records. Although not addressed in this manual, 

additional performance audit formats could be developed for other specific 

procedures important to overall program quality assurance. In this process, 

the staff would systematically review the content and operation of the program 

as outlined in this manual. In any audit situation, checklists should be devised for each specific activity. 

Records pertinent to the audit must be completed and maintained as part 

of the agency's official documentation file. The generator operating log, 

smoke school file, and other records are also components of the documentation 

and recordkeeping process. The importance of the performance audit as an 

integral part of the training activity cannot be overemphasized because it is 

vital to training and certification efforts. This audit provides assurance 

that the requirements of Method 9 have been fulfilled and that a sound and 

high-quality program has been provided. 

Complementary to the performance audit is the system audit. The system 

audit is conducted periodically, perhaps on an annual basis, through an onsite comprehensive review of the total smoke school program. This audit should 

be conducted to assess all aspects of the training activity and should readily 

identify problems and Weaknesses that should and can be corrected. The system 

audit preferably should be conducted by upper management such as the enforcement program manager and/or EPA Regional Office personnel. Participation by 

the enforcement program manager is preferable because opacity certification 

78 
P.95 

directly impacts and supports the day-to-day enforcement/compliance operation. 

This is particularly important since more than 90 percent of particulate 

emissions compliance is determined and documented by opacity readings. 

Participation by enforcement management also provides a needed element of 

management involvement and concern. The smoke school is typically a service 

provided by the Technical Support Division. It also demonstrates interest by 

the Enforcement Division in requiring the most credible operation possible. 

A system audit should have a positive impact. Management attention, concern, and opacity training and certification should increase with increased 

court challenges and litigation. The system audit provides a mechanism for 

management to gain needed program familiarization. It can also be used as a 

planning document to assist agencies in obtaining the support to update 

training materials and equipment. 

The system audit is a review of the entire training program and can be 

used to assist in a systematic check. An itemized audit form similar to the 

one included in Appendix B should be followed. The checklist approach assures 

that all aspects of the program ara evaluated. It also lends itself to the 

expedient preparation of an audit report. The form can be attached to a brief 

narrative that summarizes the findings, conclusions, and recommendations. It 

also provides the mechanism for followup on the important recommendations to 

assure that proper corrective measures have been taken. 

6.2 QUALITY ASSURANCE FOR CLASSROOM TRAINING 

Quality assurance activities for the classroom portion of a training and 

certification program ensure that adequate facilities are available and that 

the lectures adequately cover important subject matter. A portion of the 

example system audit checklist included in Appendix B addresses basic requirements of classroom training. In addition to the system audit, the classroom 

examination can be used to evaluate lecture content and delivery. Evaluation 

questions can also be used to assess the adequacy of the classroom facilities 

(see example quiz in Appendix A). 

79 
P.96 

6.3 QUALITY ASSURANCE FOR CERTIFICATION PROCEDURES 

Because field certification activities are time consuming and expensive, 

this part of the training process must be completed accurately and expeditiously. Field activities must also be well documented. Recordkeeping 

functions for certification are amenable to a performance audit and are 

addressed in Appendix B, whereas the general QA review of the field certification program can be effected through a system audit. 

Other factors that are important to the field certification program can 

be addressed as part of this system audit. These include the selection of an 

appropriate site, instructions to participants, operation of the generator, 

certification of generator outputs, and grading and documentation of reader 

results. Each of these components is addressed in the system audit checklist 

included in Appendix B. 

The system audit checklist also presents additional factors to be considered in planning and performing the overall certification testing. Overemphasis of one area of certification, such as the field test, may result in 

understaffing of classroom or QA efforts. In addressing the criteria necessary 

to produce certified readers, the system audit checklist provides a method 

of assuring that all components are adequately evaluated. 

6.4 TRACKING PROGRAM QUALITY 

A principal objective of a QA program for VE training is to.ensure that 

observers meet established performance standards. In addition, Reference 

Method 9 or other more stringent standards prescribe certain minimum levels 

of equipment quality and performance; therefore it is imperative that a 

mechanism exist to ensure compliance with these standards. Thus, a QA program 

must be able to track both qualitatively and quantitatively the overall program performance as well as the performance of individual program elements. 

6.4.1 Analysis of Opacity Error 

Some factors related to program performance are easily quantified because 

they can be directly measured, e.g., transmissometer accuracy and an observer's 

mean deviation. Other factors rely upon somewhat more subjective means for 

quantification, such as the use of examinations to determine the effectiveness 

80 
P.97 

of classroom training. In either case, the techniques used to make such quantification must maintain consistency since the performance tracking provided 

by a QA program relies upon comparable standards. 

To a great extent, overall program performance can be judged by the 

opacity reading abilities of the trainees. Since the reading ability is 

really the combined result of the observer's ability, his classroom training, and the accuracy of the smoke generation equipment, however, potential 

and measured errors associated with each factor must be estimated. Appendix 

C details the procedure for calculating the overall bias and variability due 

to equipment and operational procedures. The general procedure requires the 

summation of variances or errors associated with each step in determining an 

opacity value and comparing that value and its associated error with the value 

observed by the attendees. Accordingly, error values must be determined for:. 

1. Standard opacity (calibration) filters 

2. Transmissometer calibration 

3. Reporting of opacity value (rounding-off) 

The reported opacity value, which incorporates these errors, is then 

compared with the opacity values reported by the attendees. The bias and 

variance associated with differences in these two values describe the combined 

error of the attendee. 

The error analysis outlined in Appendix C establishes the basis for 

determining the adequacy of an important element in a VE training school, i.e... 

to what accuracy can certified trainees read opacity. Secondarily, but of 

equal importance, the analysis provides a method for evaluating equipment 

status and the effectiveness of other elements of the overall program. 

6.4.2 Evaluating Quality-Related Data 

Accurate recording and analysis of program information are fundamental 

to a good QA program. In particular, the ability to compare current data 

with data from historical or contemporary programs is useful in assessing 

the achievement and maintenance of program quality. Close tracking of 

quality-related statistics can identify problems in classroom training and 

field certification and possibly prevent the unnecessary failure of smoke 

school participants*. 

81 
P.98 

Several statistics important to evaluating the training program's performance have already been discussed. These include assessment of operational 

error, which is an accumulation of several errors caused by calibration filters, 

transmissometer calibration, and opacity value reporting. The error of the 

individual reader is the main criterion for certification. For an overall 

training program, however, statistics representing group performance are of 

greater value. In particular, average observer bias and variance provide 

insight into overall participant performance and can identify training and 

equipment biases. Although the percentage of trainees certified is indicative of opacity reading ability, it is also a reflection of the effectiveness 

of classroom training. Figure 29 lists key statistics that can be useful in 

evaluating training school performances. 

These statistics are of particular use for making comparisons with 

previous data or similar data from other VE training facilities. In this 

way, trends and significant deviations from a trend can be quickly 

observed. A useful tool for displaying quality control trends is the 

control chart. Values of significant parameters are plotted for succeeding 

periods of time or events, thus developing a trend line. Typically, lines 

indicating upper and lower acceptable values are also charted to clearly 

identify adverse trends. The major advantage of the control chart, or 

similar tracking systems, is that it.clearly illustrates changes in factors 

indicative of program quality. It can therefore serve as a warning to 

supervisors that procedures and equipment may need review or may signify to 

management that a system audit is needed. A typical control chart is shown 

in Figure 30. A basic QA program would include the tracking of the 

statistics calculated in Appendix C and those of Figure 29. 

Figure 31 lists some of these statistics in a checklist form suitable 

for auditing purposes. As may be noted, quality control criteria specified 

by Method 9 are included in the figures for ease of reference. Other 

criteria values in the figure represent those levels that reflect the 

experience of VE training schools with good QA programs. 

82 
P.99 

Date: Location: 

Instructors: 

Number of participants 

Average of participants' mean 

deviations 

Variance of participants' deviations 

Average of participants' variance or 

standard deviation 

Average of maximum positive and negative biases 

Percentage of participants that 

certified 

Percentage of participants that recertified 

Percentage of participants failing 

due to mean deviation >7.5%, due 

to single deviation >15% 

both 

Percentage of participants that 

passed the classroom examination 

Average examination score 

Average years experience of participants 

Percentage of participants within a 

given employment group (government, 

business, consultants, others) 

Smoke generator calibration error 

Opacity reporting error 

Figure 29. List*of statistics useful in evaluating VE training schools, 

83 
P. 100 

MEAN OF 

TRAINEE'S 

AVERAGE ° 

DEVIATIONS 

CLASS MEANS, 

1978 

UPPER CONTROL LIMIT FOR CLASS MEANS 

UPPER CONTROL LIMIT 

FOR ANNUAL MEANS 

ANNUAL MEANS 

LOWER CONTROL LIMIT FOR ANNUAL MEANS 

LOWER CONTROL LIMIT FOR CLASS MEANS 

1979 19E 

Figure 30. Example control chart for tracking training 

school performance. 

84 
P.1 

Statistics 

Calculated 

value 

Criteria 

value 

Acceptable 

_^es_ no Comments 

Calibration filter 

error 

Bias.X, 

SDj

 a l 

Total error 

(Xx +2SDJ) 

Transmissometer 

calibration error 

BiasJ, 

SD2

 a ' 

Total error 

(X2 +.2SD2) 

Opacity reporting 

error 

Bias.X, 

s o 3

a 3 

Total error 

(X3 +.2SD3) 

Overall SG/T error 

Bias X 

SD. ov 

ov 

Overall error 

(vX +2SD ) ov — ov' 

Student 

certification1. 

Percentage of 

students that 

certify 

Percentage of 

students that 

recertify 

2a «b 

1%L 

1.5% 

2.5% 

90% 

95% 

(continued) 

Figure 31. Statistics checklist form. 

85 
P.2 

Figure 31 (continued 

Statistics 

Percentage of 

students that fail 

due to: 

mean deviation >7.5% 

single deviation 

>15% 

Either mean deviation >7.5% or 

single deviation 

>15% 

Calculated 

value 

Criteria 

value 

2% 

8%-

10% 

Acceptable 

yes no Comments 

Specified in Reference Method 9. 

'Calculated pursuant to Reference Method 9, i.e., the absolute value of actual 

deviations is used to determine mean deviations. 

"Smoke generator/trainer. 

86 
P.3 

SECTION 7 

VISIBLE EMISSIONS TRAINING LITERATURE 

The following is a list of selected references pertaining to visible 

emissions determinations and training programs. 

Conner, W. D. Measurement of Opacity by Transmissometer and Smoke Readers, 

EPA Memorandum Report, 1974. 

Conner, W. D., and J. R. Hodkinson. Optical Properties and Visual Effects 

of Smoke Plumes. Environmental Protection Agency. Office of Air Programs, 

Edison Electric Institute and Public Health Service, 1967. 

Coons, J. D., et al. Development, Calibration, and Use of a Plume Evaluation 

Training Unit. JAPCA 15:199-203, May 1965. 

Crider, W. L., and J. A. Tash. Status Report: Study of Vision Obscuration 

by Nonblack Plumes. JAPCA 14:151-165, May 1964. 

Hamil, H. F., R. E. Thomas, and N. F. Swynnerton. Evaluation and Collaborative 

Study of Method for Visual Determination of Opacity of Emissions from 

Stationary Sources. EPA Contract.68-02-0626, U.S. Environmental Protection 

Agency, Research Triangle Park, N.C , January 1975. 

Malmberg, K. B. EPA Visible Emission Inspection Procedures. U.S. Environmental Protection Agency, Washington, D.C, August 1975. 

Osborne, M. C , and M. R. Midgett. Survey of Transmissometers Used, in 

Conducting Visible Emissions Training Courses. Environmental Monitoring 

and Support Laboratory, U.S. Environmental Protection Agency, March 1978. 

Ringelmann, M. Method of Estimating Smoke Produced by Undustrial Installations. Rev. Technique, 268, June 1898. 

U.S. Environmental Protection Agency. Office of Air Quality Planning and 

Standards, Emission Standards and Engineering Division, Evaluation of EPA 

Smoke School Results. October 9, 1974. 

Weir, A., Jr., D. G. Jones, and L. T. Paypay. Measurement of Particle Size 

and Other Factors Influencing Plume Opacity. Paper presented at the International Conference on Environmental Sensing and Assessment, Los Vegas, 

Nev., September 14-19, 1975. 

87 
P.4 1 

Wohlschlegel, P., and D. E. Wagoner. Visual Determination of Opacity Emissions from Stationary Sources. Guidelines for development of a quality 

assurance program, Vol. 9. EPA-650/4-74-005-i, U.S. Environmental Protection 

Agency, Washington, D.C, November 1975. 

Yocom, J.. E. Problems in Judging Plume Opacity: A Simple Device for Measuring Opacity of Wet Plumes. JAPCA 13:36, January 1963. 

88 
P.5 

APPENDIX A 

SAMPLE LECTURES FOR VE TRAINING PROGRAM 

LECTURE 1: HISTORY, THEORY, AND METHODS FOR EVALUATING VISIBLE EMISSIONS 

This first lecture is designed to introduce the student to the history, 

principles, and theory of opacity. The instructor should reemphasize the 

purpose of the course and expand upon and clarify the introductory remarks 

during the orientation. He should explain that certification is necessary to 

assure VE evaluations and that it will be discussed in more detail later in 

the day. The lecture should cover each of the following points. 

History of the Method 

The entire VE evaluation system is derived from a technical concept 

developed by Maximilian Ringelmann in the late 1800's to measure black smoke 

emissions from coal-fired boilers. The Ringelmann Chart, which was adopted 

by the U.S. Bureau of Mines in the early 1900's, has found extensive use in 

efforts to assess and control smoke emissions in this country. ' Since the 

early 1950's when the Ringelmann concept was expanded by the introduction of 

the term "equivalent opacity," the chart has become a very reliable and 

useful VE compliance/enforcement tool. 

The Federal Government has discontinued the use of Ringelmann numbers in 

Method 9 procedures for Standards of Performance for New Sources (NSPS).' The 

procedures are now based solely on opacity. Many states, however, still 

refer to the Ringelmann Chart to evaluate black and gray plumes in their 

regulations. The general trend, however, is to read all smoke as percent 

opacity. Certified evaluators must therefore be familiar with both systems. 

Opacity Theory 

As the use of the Ringelmann Chart for assessing smoke emissions increased, 

considerable curiosity developed as to the theory and scientific foundation 

for this effective tool. This curiosity grew with the transition to use of 

opacity readings as the basis for evaluating visible particulate emissions of 

89 
P.6 

both white and black smoke. In practice, the evaluation of opacity by the 

human eye is a very complex phenomenon, and for the most part the theory 

behind it is not completely understood. It is well documented, however, that 

visible particulate emissions can be measured with good accuracy and reproducibility by properly trained/certified observers. 

Previous study results indicate that plume opacity readings are influ- • 

enced by many factors such as: particle density and particle refractive 

index, particle size distribution, plume background, pathlength, distance and 

relative elevation to stack exit, time of day, and lighting conditions. 

Of particular significance is particle size. Particles decrease light transmission by both scattering and direct obscurations. Particles in the diameter 

size range of visible light, 0.4 to 0.7 um, have the greatest light-scattering 

effect. 

By literal definition, opacity is the reduction in visibility of an 

object or background as viewed through the diameter of a plume; in terms of 

physical optics, opacity is dependent upon transmittance (I/T ) where I xo ° 

is incident light flux and I, the light flux leaving the plume. Percent 

opacity is therefore defined as: 

Opacity = (1 - I/. ) x 100 

o 

The relationships between light transmittance, plume opacity, and Ringelmann 

number are presented in Table A-l. 

TABLE A-l. COMPARISON OF LIGHT EXTINCTION TERMS 

Light transmission, 

% 

0 

20 

40 

60 

80 

100 

Plume opacity, 

% 

100 

80 

60 

40 

20 

0 

Ringelmann 

number 

5 

4 

3 

2 

1 

0 

90 
P.7 

Opacity Reading Methods 

Over the years, the procedures and guidelines for reading opacity have 

been refined and more rigidly defined. The three basic techniques currently 

used in reading visible emissions are: 

1) Time exemption (frequency distribution) 

2) Time averaging (Method 9) 

3) Stopwatch (time accumulation) 

Many states are using a combination of these procedures in opacity readings 

depending on the exact wording of the applicable emission regulation. The 

different techniques and provisions must be thoroughly understood, since 

legally sound opacity documentation must be consistent and in accordance with 

the applicable regulation. The three procedures are summarized below. 

Time Exemption --

Nearly all State Implementation Plan control strategies contain opacity 

regulations that are based on the time exemption procedure. This procedure, 

which historically was devised to control coal combustion sources, allows the 

source a stipulated number of minutes per hour to be in violation of the 

allowable emission level. The observer typically makes readings on 15-second 

intervals and reads for several minutes longer than the stipulated exemption 

period. The individual readings in excess of the allowable standard are then 

counted to determine the status of source compliance. 

Time Averaging --

Commonly referred to as EPA Method 9, this procedure was developed by ' 

EPA in support of NSPS and has been adopted widely by State and local air 

control agencies. This procedure also requires reading on 15-second intervals 

over a period of 6 minutes (24 consecutive readings). The sum of the readings 

is then mathematically averaged, and that value determines source compliance 

status. 

Stopwatch Procedure --

This procedure has recently been used by several air control agencies to 

more effectively address intermittent or highly variable emission levels, 

e.g., coke oven emissions. The observer uses two stopwatches. One watch is 

91 
P.8 

activated at the start of the observation period and stopped at the end. The 

second watch is activated in an accumulating time mode each time the emissions 

exceed the stipulated emission level and stopped each time the emissions fall 

below that level. The total accumulated time is then read and recorded from 

the second stopwatch over the total observation time of the first watch. 

Variables that Influence the Accuracy of Opacity Measurements 

The human eye is a unique instrument for making opacity readings due to 

its capability to discern very narrow color bands of the electromagnetic 

spectrum and thus identify light wave frequency. The purpose of the VE 

training and certification program is to refine or calibrate the human eye to 

a scale that distinguishes opacity in 5 percent increments. 

As previously mentioned, several factors influence the accuracy of 

opacity reading. The reader should understand these factors and take the 

necessary precautions to minimize errors. The standard observer form requires 

the observer to note and describe the conditions of reading that are needed 

to substantiate the validity of observations. This QA measure in the field 

reading and in the review of field reading by supervising personnel better 

assures sound documentation for enforcement purposes. 

Sun Angle — 

Small particles in the plume tend to scatter light in the forward direction at small angles with reference to the direction of the sun's rays. 

Thus, a plume would appear to be much more opaque if it is not viewed with 

the sun behind the observer. The most accurate readings are taken when the 

sun is within a 140 degree sector behind the observer. 

Wind Direction --

It is important that the plume be read through a plume diameter approximately the size of the stack exit. If the plume is blown toward or away from 

the observer, it is likely to be read through a longer pathlength than if 

readings are taken with the wind blowing perpendicular to the line of sight. 

The longer the pathlength through the plume, the greater the plume opacity 

with diameters of constant loading and particle size distribution. 

The error involved in observations made nonperpendicular to the plume is 

illustrated in the following example. Assume a plume rising from a rectangular 

92 
P.9 

stack with a width of approximately 2 ft has an opacity of 20 percent. 

Based on Beer's Law, the relationship between transmittance and pathlength is 

as' follows: 

I/, =e" b L 

0 

where b = the extinction coefficient of the plume; an intrinsi c 

property of. the plume due to particl e characteristic s 

L = pathlength 

For our example: 

opacity = (I - I/* ) x 100 = 20 percent 

o 

I/ z = 0.80 

o 

L = 2 f t 

Solving for b: 

Ln (0.8) = -b(2) 

-0.223 = -2b' 

0.112 = b 

On a 45 degree angle the actual pathlength (L 1), as presented in Figure A-l , 

would be as follows: 

The apparent opacity is obtained by use of the extinction coefficient previously calculated (0.112) and substituting b and L' into Beer's law. 

1/ = e-0.112 (2.84) 

o 

I, -0.318 

V

e 

Vj = 0.73 

o 

Thus, opacity = 1 - - p = 0.27 or 27% 

o 

93 
P.10 

Q 

Figure A-l. Top view of discharge. 

94 
P.11 

In this case, there was a 35 percent error between the two measurements. 

Proper positioning for plume observations is therefore influential to the 

accuracy of opacity measurements. 

Variable wind conditions can cause the plume to shift, putting the observer in a poor viewing location. The observer should change positions if 

possible, maintain the proper sun angle, and remain perpendicular to the 

plume travel. Such changes must be noted on the recording form. If a suitable 

position cannot be found, the observer should note the conditions and discontinue reading until viewing conditions improve. 

Effect of Observer Elevation Angle on Observed Opacity --

As the observer moves closer to the base of the stack, the angle of sight 

and the pathlength through the plume both increase, causing the observed 

opacity'to increase even though the cross-plume opacity remains constant. 

Table A-2 illustrates how observed opacity decreases with distance from the 

base of a stack emitting a plume of 20 percent opacity. Figure A-2 presents 

the variation of observed opacity with distance from any elevated source. 

The observed opacity is 27 percent, as evaluated from a distance of one stack 

height (H), drops to 22 percent from a distance of 2H, and to 21 percent from 

a distance of 3H. 

Observer 

distance 

(Y) 

H 

2H 

3H 

TABLE A-2. EFFECT OF ELEVATION ANGLE 

Observed 

elevation 

angle,0 

(e) 

45° 

27° 

18° 

Observed 

pathlength 

1.41 0 

1.21 D 

1.05 D 

Actual 

opacity, % 

20 

20 

20 

Observed 

opacity, % 

(°o» 

27.2 

22.2 

21.0 

Deviation, % 

+7.2 

+2.2 

+ 1.0 

95 
P.12 

PATHLENGTH THROUGH PLUME 

/ 

a* -t 

H h 

2H j-

•JU 

Figure A-2. Variation of pathlength through plume with distance 

from an elevated source. 

96 
P.13 

The observed pathlength (P ) is calculated as follows: 

„ D VH2 + Y2 

v

o ' Y 

where D = actual width of plume 

f = pathlength factor 

f-J-± 

T

 D 

T = 1 - 0 (decimal form) 

where T = transmittance 

0 = opacity 

Sample calculation: Y = 2H 

0Q = 1 - Tf 

p _ D V2Z + 1 _ D VET. . .?n 

f = If°=1.1 2 

T = 1 - 0.2 = 0.8 

Thus, 0Q = 1 - 0.81*

12

 = 22.2% 

The observer must be close enough to the emission point to have reasonable 

visual range. Earlier versions of Method 9 recommended that the observer 

stand a minimum of two stack heights but not further than 0.25 mile from the 

source. While this is no longer required, it does indicate approximately 

what distances between the source and the observer are considered optimum. 

Background --

Maximum accuracy is obtained when the plume is read against a contrasting background. The reader should choose the background of maximum color 

contrast with the plume, i.e., a green tree is considered best for a light 

colored plume and a blue sky for a black plume. Many observers, however, 

97 
P.14 

1 

prefer a contrasting object such as a tree or building to be included in the 

background for all plume readings. 

Viewing Point --

Method 9 procedures expressly require that the observation point be that 

of maximum opacity. This normally means as close to the point of emission as 

possible since the plume tends to dissipate with travel distance. Exceptions, 

though, must be made in situations when uncombined water or secondary particulate formation occurs. The observation must be made through a portion of 

the plume where uncombined water is not present since the water vapor can 

condense when exposed to cold ambient temperatures and form highly opaque 

plumes. Always indicate on the observation form where the viewing point is 

relative to the stack exit or source point. 

Time Interval between Readings — 

Staring continuously at a reasonably steady state plume while making 15-

second interval readings causes eye fatigue, which can result in reduced 

visual acuity. To prevent this, the observer should only glance at the plume 

momentarily and make the opacity determination at the regular 15-second intervals. Any deviation from this reading procedure must be noted and explained 

on the observation form. 

Atmospheric Haze --

Both natural or manmade atmospheric haze will generally reduce the 

contrast between the plume and its background, thereby reducing the opacity 

reading. Hazy conditions should not significantly affect the opacity reading 

if the visibility is at least 3 miles. 

Wind Speed and Atmospheric Stability --

A strong wind or unstable atmospheric conditions cause rapid dispersion 

of the plume, thus reducing opacity. As such interferences generally favor 

the source, this would not hinder official opacity readings. Accurate readings can be made under these conditions as long as the plume remains reasonably 

intact at the stack exit and as long as the opacity is read as close to the 

stack exit as possible. 

98 
P.15 

Night Viewing --

Questions sometimes have been raised about the feasibility of conducting 

visual opacity observations at night. Plumes can be read accurately at night 

if special training has been conducted and certain reading conditions exist. 

The opacity is judged by use of a light as a background target. A few agencies 

regularly conduct night observations, e.g., Los Angeles Air Quality Mangagement 

District. Procedures for certification and field observations under nighttime 

conditions, however, are not addressed in Method 9. 

LECTURE 2: SOURCES OF VISIBLE EMISSIONS 

This lecture should be given either by an experienced enforcement person 

or by an engineer thoroughly familiar with source conditions and opacity 

reading procedures and problems. The lecture should be illustrated by quality 

35-mm slides showing sources and plume conditions commonly seen in field 

operations. 

Opacity readings are generally made in the course of routine source 

inspections or after a casual observation of apparent visible emissions. 

Readings can be made either on or off the property of the alleged violator. 

Observations must, however,, be made in conformance with location and viewing 

conditions conducive to accurate readings, because any field readings and 

documentation may be used as evidence in a court of law. A source representative may request to be present during the reading period. If that is not 

possible or desirable, the source should be contacted immediately after the 

readings are taken to determine the operating conditions during the period of 

reading. The source may be in a legitimate condition of upset or malfunction, 

and thus any enforcement action would be unwarranted. The source should be 

provided the opportunity to explain or defend its operating condition during 

the period of alleged violation. 

The camera is very effective for illustrating the visual appearance of 

heavy visible emissions. It does not, however, replace accurate opacity observations and can only be used as secondary evidence in court. The inspector can testify that the photograph accurately represents the plume location 

and geometry that he observed. Care must be exercised in taking photographs 

so as not to divulge details of processes or operations designated confidential 

99 
P.16 

"1 

or as proprietary information by the source owner/operator. A telephoto lens 

should not be used; and if the inspector is on company property, prior permission is required to use a camera. 

The observer must also be cognizant of responsibilities and obligations . 

not to inadvertently divulge secret processes or operations in the course of 

day-to-day inspection or surveillance activities. A source employee might 

discuss a secret operation or process in order to explain excessive emissions 

or successful controls, but this privileged information must not be divulged 

to others. 

It is highly recommended that the observer make a perimeter survey prior 

to and following the observation to determine plant configuration and confirm 

that multiple plume interaction did not cause inaccurate opacity readings. 

This initial survey also identifies the most appropriate location with respect 

to Method 9. Numerous EPA publications and workshops are available on the 

techniques and procedures for conducting onsite inspection. 

Combustion Sources 

Combustion and incineration historically have been the major VE sources. 

These sources include fuel (primarily coal and oil) combustion for space 

heating and power generation, incineration for waste disposal or reclamation, 

mobile sources, and process furnaces or operations. 

The principles of combustion (time, temperature, turbulence, and oxygen) 

should be discussed along with combustion practices that have proven to be 

successful. Unique conditions and applications for reducing combustion emissions are continually reported by field personnel. An explanation should be 

presented detailing when emissions are most likely to occur and what can.be 

done to reduce them. 

Noncombustion Sources 

Industrial process losses, such as fumes, dusts, mists, gases, and vapors, 

are classified as noncombustion sources of emissions. Such emissions cannot 

truly be called "smoke" because this term refers only to the visible effluent 

resulting from combustion, and consists mostly of soot and fly ash. Operations that emit noncombustion pollutants include grinding, melting, cooking, 

materials handling, reaction processes, drying, and calcining. 

100 
P.17 

Because a wide variety of industries produce process visible emissions, 

this lecture should be tailored to the industrial activity where the majority 

of the attendees will be working. Limit this part of the lecture to a few 

examples of the problems and techniques involved in identifying, evaluating, 

and controlling visible emissions from noncombustion sources. 

Many VE sources do not fall into the above categories. Some sources such 

as area and fugitive emissions, may be associated with the source operation. 

Nonurban sources include demolition, road dust, farming, stockpiles, blasting, 

quarrying, roof monitors, and perhaps open burning. In urban problem areas, 

the remaining uncontrolled particulate is emitted from a slightly different 

set of major sources. Despite the tendency of many agencies not to rely on 

opacity observations in regulating these sources, the. emissions can be accurately read and effectively controlled by opacity regulations. The basic 

principles of opacity reading apply. The major differences are that opacity 

is usually read at or near ground level, and the pollutants are not emitted 

from a confined stack. The biggest problem in reading fugitive emissions is 

usually defining a single emission point and reading that plume. Some reasonable judgment in that regard will be necessary. Such judgments and conditions 

of observation must be thoroughly described on the emission form. The stopwatch technique may be preferable in reading some of these source conditions, 

especially if the plume is intermittent and highly variable. The stopwatch 

procedure, however, should be stipulated in the applicable regulation. 

Contaminated Water Aerosol Plumes 

Plumes containing condensed droplets of water have been variously described as "moist," "wet," "steam," "contaminated water aerosol," or'"condensed water vapor" plumes; however, they are usually referred to as "steam 

plumes." Although this term is not technically correct since steam is a gas, 

it has become the generally accepted description of a plume containing droplets of condensed water. In a "dry" plume, the temperature remains above the 

dewpoint and therefore the water remains in the gaseous state with no 

effect on opacity. As the plume cools and falls below the dewpoint, condensation occurs and water droplets are formed. At this point the visible 

"steam" occurs. These condensed droplets scatter light, generally causing 

•the plume to appear completely opaque. Because nearly all opacity regulations 

101 
P.18 

exempt "steam" or water droplets, care must be exercised to exclude the 

effect of "steam" in any official plume opacity readings. 

The moisture contained in the plume can condense within the stack itself. 

This plume is generally referred to as an "attached" plume unless the billowing white plume forms downwind of the stack, in which case it is referred to 

as a "detached" plume. In both cases, the contaminated water aerosol will 

usually revaporize eventually and then disappear. The formation and disappearance of "steam" are affected by relative temperature and ambient humidity. 

Because of the exemption provisions, it is important that the observer 

readily recognize and discern "steam" contamination. The presence of "steam" 

in the exit stack gases is determined by the billowy white appearance and the 

rather rapid dissipation of a dense plume. A dry plume generally does not 

have the billowy appearance, dissipates very slowly, and diffuses as it travels 

downwi nd. 

Contaminated water aerosol plumes can be expected from high water consumption processes, wet control systems (e.g., scrubbers and wet electrostatic precipitators), and cooling processes. Therefore, the inspector or observer must have some familiarity with the process and control system in 

order to expertly assess stack opacity conditions. 

Condensible and Secondary Plume Formations 

Both condensible and secondary plume formations are phenomenon of increasing significance and concern, particularly at industrial processes and 

combustion sources using high-sulfur fuels. Condensible plumes result from 

condensation of vaporized particulate as plume temperatures decrease. Secondary 

plumes occur as particulate is formed from reactions of species within the 

plume. At many sources that have applied high efficiency particulate and 

sulfur dioxide control systems, a high opacity plume persists. 

The major sources of these plumes are fossil fuel-fired power plants, 

coal-fired cement kilns, wood products drying operations, and Kraft pulp mill 

recovery furnaces. Secondary formation of condensation products results under 

certain atmospheric conditions. Under conditions of high humidity, fine 

sulfuric acid mist particles bind with water molecules from the atmosphere 

to form large light scattering particles. Such problems are particularly 

perplexing since industry has spent large sums of money to substantially 

102 
P.19 

reduce mass loadings but is still faced with serious opacity control problems. 

Another important formation occurs as a result of ambient cooling of the 

flue gas. Particles of this type (generally organics) are in the vapor state 

at stack gas temperatures and upon cooling in the ambient air, change to a 

liquid or solid state. These emissions are often further complicated by 

so-called steam plumes, and extreme care and keen observation are required 

to accurately document both condensible and secondary plume formations. 

The opacity must be read at some distance from the stack, and in this regard, 

the guidance in Method 9, Section 2.3 is: 

"Opacity observations shall be made at the point of 

greatest opacity in that portion of the plume where 

condensed water vapor is not present." 

Other Factors Affecting Plume Opacity 

Plume opacity can be significantly affected by a number of factors. The 

degree of influence of each factor varies widely from source to source. Some 

of the factors are presented in the following subsections. 

Control Hardware— 

The type and performance of particulate control systems can have a-significant impact on opacity. Most control devices are highly efficient in 

collecting large particulates (i.e., > 20 um), but collection efficiency 

generally drops with decreasing particle size. 

Growing evidence indicates that electrostatic precipitators (ESP's) and 

wet scrubbers have fractional efficiency curves of the type shown in Figure 

A-3. 

The particles in the 0.2- to 0.5-um range are particularly difficult to 

collect due to the limitations of basic physical mechanisms such as impaction 

and field dependent charging. Consequently, nonideal performance probably 

leads to the rapid increase in the quantity of 0.2- to 0.5-range emissions. 

This corresponds to the range that scatters visible light most effectively 

since the particle diameters are approximately equal to the wavelength of 

visible light. 

103 
P.20 

e 

V 

<J 

> 

U 

Z 

111 

u. 

u. 

z 

O 

rU 

LU 

O 

(J 

99.98 

99.9 

99.8 

99.5 

99 

98 

95 

90 

O 

60 

30i 

CO 

MEASUREMENT METHOD: 

^CASCADE IMPACTORS 

O OPTICAL PARTICLE COUNTERS 

• OIFFUSJONAL 

PRECIPITATOR CHARACTERISTICS: 

TEMPERATURE - 335°C 

SCA • 85 M2/(M3/sec) 

CURRENT DENSITY • 35 nA/CM2 

0.05 0.1 0.5 1.0 

PARTICLE DIAMETER, um 

5.0 10.0 

Figure A-3. Measured fractional efficiency of a hot-side ESP 

installed on a pulverized coal boiler. 

Familiarity should be gained with the various control devices and with 

the variations in system characteristics from source to source. Variations 

are generally observed and defined over a period of several plant inspections 

and opacity readings. Therefore, i t is important to document and meticulously 

record one's observations and review the source fil e and records prior to 

subsequent inspections and opacity readings. 

Process Operation --

Many processes have a cyclic operation (e.g., metallurgical furnace melts) 

Since visible emissions tend to be highly variable during the cycle, compliance documentation readings should be made during the period when highest 

opacity emissions are expected. Many source operations (e.g., aluminum 

plants) have primary and secondary collection systems—coll ection hoods 

connected to the primary system and roof monitors connected to the secondary 

system. The system configurations and the operating conditions during opacity 

readings should be observed and noted. 

104 
P.21 

Raw Materials --

The quality and content of raw materials can significantly influence 

particulate emissions. The source of influence can be as simple as the ash 

content of fuels or as complex as the chemistry of materials and resultant 

secondary reactions that might increase visible emissions. A well-designed 

control system may not be compatible with a significant raw material change. 

This could explain a sudden VE increase and subsequent compliance efforts. 

Circumvention --

Most agency regulations address circumvention efforts that are practiced 

to escape control requirements. Circumvention can be accomplished through 

multiple stacks, bypasses, diffusers, air dilution, etc. The inspector must 

be on guard against circumvention efforts or the alternation of operations to ' 

produce higher emissions at night or on overcast days, weekends, and holidays. 

Atmospheric Conditions --

Wind direction, wind speed, atmospheric stability, turbulence, relative 

humidity, and several other meteorological parameters influence the appearance of the plume. The wind direction affects the orientation of the observer 

and the plume. Plumes blown directly toward or away from'the observer generally result in readings through longer pathlengths through the plume than 

those observed when the wind blows perpendicular to the observer's line of 

sight. The longer the pathlength through the plume, the higher the apparent 

plume opacity. As is the case with unstable atmospheric conditions, stronger 

winds increase dilution and thus reduce opacity. 

Miscellaneous Factors --

Other factors that can influence opacity reading include background, sun 

angle, observer distance, and visual aids such as sunglasses. Therefore, it 

is important that these conditions and their respective influences be extensively 

documented before, during, and after the readings on the observation report. 

LECTURE 3: • FIELD OPERATIONS 

This section discusses the proper procedures for conducting field inspections. This presentation should be made by an experienced field inspector 

or engineer. 

105 
P.22 

Making technically sound opacity readings requires adequate preparation. 

In addition to being currently certified, the reader must know the source. 

This preparation requires review of the official source file to determine 

process operating conditions, type and location of control equipment, history, 

of any VE problems, possible observation sites, applicable regulations, presence of condensed water vapor plumes, pertinent operating data, and names of 

contact, etc. 

An opacity reader should have adequate supplies and equipment, including 

inspection forms, writing pad or surface, field logs, stopwatch, sling psychrometer, range finder, compass, binoculars, and camera. It is recommended 

that field personnel always be equipped with a hard hat, safety boots, safety 

goggles, and in some instances, coveralls and a respirator. Other equipment -

that may be necessary depending on the type of source and the observation 

conditions includes topographic maps' and a hand-held anemometer. In some 

instances, agency field personnel have conducted observations with little, if 

any, of this equipment, and data frequently have been recorded on a standard 

note pad, without the aid of even a watch. The field personnel must be 

adequately equipped and familiar with the use of all equipment. Fully acceptable 

readings, however, can be made pursuant to Method 9 with only a watch and proper 

forms. The remainder of the equipment simply makes the inspector's job more 

convenient, and does not necessarily render the observation more accurate. 

An agency-approved standard opacity form is essential to the quality 

assurance of an enforcement program. This form assures that all proper data 

will be obtained and recorded to document accurate readings and.it assures 

better consistency of technique and information reported by different readers. 

The consistency and adequacy of documentation should be reviewed and verified 

by the supervisor or legal personnel prior to initiating enforcement actions. 

The reading data must be reduced or summarized in accordance with applicable regulations. Thus, if an NSPS source is involved, at least 6 minutes of 

observation must be recorded to obtain an average of 24 individual consecutive readings. In some instances where more than one regulatory provision 

might apply, the readings could be reduced by frequency count, averaging, 

and/or time accumulation, with the more stringent provision taking precedent. 

The need for thorough and accurate field notes should be reemphasized. 

Any field observation is fresh and clear in one's mind, shortly after the 

106 
P.23 

reading; most enforcement actions, however, happen after a considerable lapse 

of time, perhaps years. Hurried or sketchy notes can jeopardize the quality 

and credibility of such enforcement actions. 

Agency staff should make a copy of the observations available to source 

personnel by leaving a carbon copy or by later mailing a copy from the office, 

depending on agency policy. This should be done with minimum delay and 

should.be officially noted in the record of action. Preferably, a representative of the source should sign the front of the observation form to acknowledge receipt. Under no circumstances, though, should the inspector attempt 

to summarize the results as a finding of noncompliance or compliance. This 

is a conclusion of law and the inspector's domain is limited to conclusions 

of fact. In addition, such action would preempt the inspector's supervisor 

and agency legal staff. 

LECTURE 4: AIR POLLUTION METEOROLOGY 

Meteorology has a large influence on air quality. This impact can be 

from the microscale of building turbulence to the macroscale of pressure 

systems. Several meteorological parameters directly influence plume opacity 

(wind speed and direction, humidity, cloud- cover, atmospheric haze, etc.). 

The field inspector must be.aware of these factors and their potential impact 

on opacity readings. 

Although air pollution meteorology can be quite complex, especially the 

mechanics and mathematics that pertain to diffusion or dispersion modeling, 

the opacity reader should be familiar with meteorological concepts. This • 

lecture should be given by an air pollution meteorologist, a specialist who 

can present the material with a practical application. The lecture content 

should describe the basic plume behavior (Figure A-3) and its formation and 

associated meteorological conditions (Table A-3). 

Plume behavior and transport (vertical and horizontal) are largely a 

function of atmospheric stability and lapse rate and should be reasonably 

understood by the opacity observer. Of more direct influence in making 

quality opacity readings are relative humidity, wind speed, cloud cover, sky 

contrast, etc. Several techniques can be used to measure or estimate these 

conditions. * 

107 
P.24 

N 

\ 

STABLE (FANNINO) 

-^5 ^ ^ 

-fi^'iU* 

NEUTRAL BELOW, STABLE ABOVE (FUMtOATION) . 

Ja. 

UNSTABLE (LOOPING) 

TEMPERATURE -

STABLE BELOW, NEUTRAL ALOFT (LOFTINO) 

Figure A-3. Basic plume behavior. 

108 
TABLE A-3. PLUME BEHAVIOR AND RELATED WEATHER 

o 

U3 

Description of 

visible plume 

Fanning 

Narrow horizontal fan; 

little or no vertical 

spreading; if stack is 

high, resembles a meandering river, widening 

but not thickening as 

it moves along; may be 

seen miles downwind; if 

effluent is warm, plume 

rises slowly, then drifts 

horizontally 

Fumigation 

Fan or cone with well defined top and ragged or 

diffuse bottom 

Typical 

occurrence 

At night and in early morning, any season; usually associated with inversion 

layer(s); favored by light 

winds, clear skies, and snow 

cover 

During change from inversion 

to lapse condition; usually 

nocturnal inversion is 

broken up through warming of 

ground and surface layers by 

morning sun; breakup commonly begins near ground and 

works upward, less rapidly 

in winter than in summer; 

may also occur with sea 

breeze in late morning or 

early afternoon 

Meteorological 

conditions 

Inverted or isothermal 

lapse rate; very stable; light winds; very 

little turbulence 

Adiabatic or superadiabatic lapse rate 

at stack top and below; 

isothermal or inverted 

lapse rate above; 

lower layer, unstable 

or neutral, upper layer 

stable; winds light to 

moderate aloft, and 

light below; thermal 

turbulence in lower 

layer, little turbulence in upper layer 

Dispersion and 

ground contact 

Disperses slowly; concentration aloft high 

at relatively great 

distance downwind; 

small probability of 

ground contact, though 

increase in turbulence 

can result in ground 

contact; high ground 

level concentrations 

may occur if stack is 

short or if plume moves 

to more irregular terrain 

Large probability of 

ground contact in relatively high concentration, especially 

after plume has stagnated aloft 

(continued) 
TABLE A-3 (continued) 

Description of 

visibl e plume 

Looping 

Irregular loops and waves 

with, random sinuous movements; dissipates in 

patches and relativel y 

rapidly with distance 

Coning 

Roughly cone-shaped with 

horizontal axis ; dissi -

pates farther downwind 

>_, than looping plume 

i—• 

o 

Lofting 

Loops or cone with well 

defined bottom and poorly 

defined, diffuse top 

Typical 

occurrence 

During daytime with clear or 

partl y cloudy skies and in -

tense solar heating; not 

favored by layer-type cloudiness, snow cover or strong 

wi nds 

During windy conditions, day 

or night; layer-type cloudiness favored in day; may 

also occur briefl y in a 

gust during looping 

During change from lapse 

to Inversion condition; 

usually near sunset on fai r 

days; last s about an hour 

but may persis t through 

night 

Meteorological 

conditions 

Adiabatic or superadiabatic lapse rate ; 

unstable; ligh t winds 

with Intense thermal 

turbulence 

Lapse rate between dry 

adiabatic and isothermal; neutral or stable; 

moderate to strong 

winds; turbulence 

largel y mechanical 

rather than thermal 

Adiabatic lapse rate 

at stack top and above; 

inverted below stack; 

lower layer stable, 

upper layer neutral or 

unstable; moderate 

winds and considerable 

turbulence aloft ; very 

ligh t winds and littl e 

or no turbulence 1n 

layer below 

Dispersion and 

ground contact 

Disperses rapidl y with 

distance; large proba- , 

bl11ty of high concentra- , 

tions sporadically at 

ground relativel y close j 

to stack ' 

Disperses less rapidl y 

with distance than looping plus large probabili t y of ground contact 

some distance downwind; 

concentration less but 

persisting longer than 

that of looping 

Probabilit y of ground 

contact small unless 

inversion layer is shallow and stack i s short; 

concentration high with 

contact but contact 

usually prevented by 

stabilit y of inversion 

layer; considered best 

condition fo r dispersion 

since pollutant s are 

dispersed i n upper air 

with small probabilit y 

of ground contact 

s 
P.27 

Relative humidity is measured by a psychrometer, following a simple procedure. If this instrument is not available, an adequate reading can, in 

most instances, be obtained from airports, weather stations, or perhaps a 

local TV station. High humidity days (_> 70 percent) are usually associated 

with atmospheric turbidity that can interfere with accurate opacity readings. 

Wind direction is determined readily by the direction of plume travel in 

relation to the orientation of the compass. Wind speed can be measured by a 

small rotameter or hand-held anemometer. Area wind information can be obtained 

for the period in question from the local weather station. A reasonable 

estimate of wind speed can also be made by use of the Beaufort scale. Accurate 

determination of wind speed is not as important as other measurements. It is 

basically important to support that reasonable readings were, in fact, possible 

and that unusual turbulence and plume shearing or separations were not occurring. 

LECTURE 5: LEGAL ASPECTS 

This lecture should be presented by an attorney thoroughly familiar with 

the practice and problems of air pollution control enforcement as well as 

those recent court decisions that have affected the field of opacity reading. 

It is becoming increasingly important that all field opacity readings be 

conducted with the approach and attitude that the documentation must withstand the rigors of court scrutiny and interrogation. Because the evidence 

is only as strong as the weakest element, it is important that all aspects of 

the program (from classroom training and certification to field readings and 

documentation) be conducted within the requirements and structure of a good' 

quality assurance program. This requires the field observer to have thorough 

training and to be familiar with the legal requirements and conditions. 

As the frequency and amount of fines and penalties increase, industry is 

growing more concerned about the significance of a technically and legally 

sound opacity enforcement program. Opacity readings by field observers account for more than 90 percent of agency enforcement actions. In response, 

industry is spending a great deal of money to better understand the theory 

and practice of opacity reading. Industry has also initiated several 

precedent-setting legal actions to weaken this important tool. Therefore, an 

111 
P.28 

understanding of the legal requirements and cases is essential to avoid 

needless jeopardy in important enforcement actions. 

Applicable Regulatory Provisions 

Field readings made by the opacity observer will usually document compliance or noncompliance with several levels or layers of regulatory provisions. 

To help identify and promote the required understanding of the applicable 

provisions, the more common regulatory requirements are listed below: 

Clean Air Act, as Amended 1977 — 

Section 110 - State Implementation Plan Requirements 

Section 111 - New Source Performance Standards 

Section 112 - Emission Standard for Hazardous Air Pollutants 

Section 113 - Federal Enforcement Authority 

Section 114 - Inspection, Monitoring, and Entry 

Section 119 - Nonferrous Smelter Orders 

Section 120 - Noncompliance Penalty 

Section 160 - Prevention of Significant Deterioration 

Section 169 - Prevention of Significant Deterioration (Section A) 

Section 303 - Emergency Powers 

State Air Pollution Control Laws.and Regulations --

Nearly all states have opacity emission regulations that must be at 

least as stringent as those of the applicable Federal regulations. States 

are generally adopting Federal regulations (i.e., NSPS) but omissions and 

even inconsistencies may be discovered. Therefore, it should be remembered 

that several opacity emission regulations may apply to VE control for any 

pollutant source. 

Local Laws, Ordinances, and Regulations --

Familiarity should be gained with these regulations which, in some cases, 

are more stringent than State or Federal regulations. 

Important Legal Cases 

Opacity observations as a viable enforcement tool have been repeatedly 

upheld by several state courts as well as the U.S. Supreme Court. Significant 

112 
P.29 

court cases concerning opacity as a viable enforcement tool are reviewed in 

several references ,1isted below. Opacity standards have withstood the rigors 

of many serious challenges in the courts of this country. Recent rulings 

include: 

1. Air Pollution Variance Board of the State of Colorado v. Western 

Alfalfa Corporation, 419 U.S. 815, 94 S. Ct. 2114 (1974), at 

footnote 1. 

2. State of New Jersey v. Fry Roofing Co., Docket No. C-3682-72 (N. J. 

Superior Court, 1974, attached as Appendix A). 

3. St. v. Fry Roofing Co., 495 F. 2d 751, 4 ERC 1116 (Ore. Ct. of App. 

1972). 

4.. People v. Plywood Manufacturers, 291 P. 2d 587 (Sup. Ct. of Los 

Angeles, Ca. 1955). California enacted a statutory opacity require--

ment as early as 1947. Cal. Health and Safety Code 24242. 

5. Essex Chemical Corp. v. Rickelshaus, 158 U.S. App. D.C. 360, 486 P. 

2d 427 (1973). 

6. Portland Cement Association v. Rickelshaus, 486 F 2d 375, U.S. 

Court of Appeals, District Columbia Circuit (June 29, 1973). 

The following court cases established important legal precedents that 

are significant to the conduct of a sound enforcement program. 

The case of Air Pollution Variance Board (Colorado) v. Western Alfalfa 

Corporation, No. 7.3-690, U.S. Supreme Court, May 20, 1974, pointed, out the 

necessity of immediately notifying the source where opacity readings had 

documented a violation. The Court ruled that the source management must have 

opportunity to defend itself, and that it is unreasonable to expect the 

source representation to reconstruct in court the operating conditions on the 

day of the opacity observation several days or months later as an explanation of the observed excessive emissions. 

The case of Donner-Hanna Coke Corporation v. Administrator U.S. EPA, 

Civil Action No. 77-232, in the U.S. District Court for New York, January 1978 

pointed out the necessity of having clearly defined procedures in opacity 

documentation. The court ruled that EPA was remiss in not having documented 

the applicability and accuracy of the "stopwatch" reading method. 

113 
P.30 

Legal Procedures 

The inspection/enforcement staff must work closely with the legal staff. 

Before referring the case to the attorney, the field observer and supervisor 

should review the evidence and soundness of the opacity readings. The attorney 

should review the evidence again and thoroughly discuss any evidence of possible case weakness. Corrective actions (such as additional field readings) 

should be taken if possible. These tier level reviews provide a final layer 

of QA review to the enforcement action. 

The attorney and enforcement staff should again review the applicable 

regulatory provisions and be cognizant of any duplicate opacity regulations 

(i.e., State Implementation Plan, NSPS and_P_revention of Significant Deterioration provisions). The legal staff will probably decide if the case is to 

be prosecuted as a civil or criminal action. The inspector should have a 

reasonable understanding of each procedure and his/her role as an expert 

witness. The film "Role of the Witness" illustrates proper presentation and 

behavior in this role. 

Legal Restraints 

Different types of sources and different areas of the country require 

different VE restrictions. Certain operations may be exempt from the regulations, and exceptions may be a.llowed for others (such as agricultural 

burning) during certain periods of time. The specific variances applicable 

to the course location should be discussed. 

Authority to Enter Facilities 

Section 114 (a) 2 of the Clean Air Act duly authorizes the control, official to enter any facility to make inspections, take samples or readings, 

and gather information and records. Similar authorization is contained in 

the enabling authority of most or all states. This authority, however, is 

being subjected to frequent challenges. Any inspector denied entry should 

seek assistance from his/her supervisor and agency attorney to obtain a search 

warrant. 

Signing Waivers 

It is a fairly common practice for companies to request nonemployees or 

visitors to sign liability waivers as a condition of entry onto their industrial 

114 
P.31 

. facilities. EPA employees cannot be denied entry for refusal to sign such 

waivers, and are specifically instructed not to sign such statements. To 

sign such waiver statements could jeopardize the rights of the individual and 

his/her employer in cases of unforeseen injury or damage. 

Confidential Information 

In order to explain excessive emissions, the company may divulge or 

share confidential information. It is important to understand the liability 

associated with such information and the precautions that must be taken to 

protect it. Further decisions and guidance are presented in 40 CFR Part 2, • 

Public Information. 

LECTURE 6: TESTING PROCEDURES 

The preceeding classroom lectures have built the foundation for this 

lecture. The student should now be familiar with the theory, history, source 

conditions, meteorology, and reading techniques. The next step is to work 

with the smoke generator to "calibrate" the eyes and develop a proficiency 

and confidence for making field readings. 

The trainee must be fully informed and aware of the events and procedures 

in field training. The training supervisor or assistant will be in charge of 

this portion of the training. Most instructors have found 35-mm slides 

helpful in presenting the material and in displaying the generator equipment 

and components. High-quality slides can effectively simulate smoke in increments of 10 or 20 percent opacities. 

Practice forms may be distributed to the class, and practice recordings 

may be referenced to assure the skillful completion of the forms. Needed ' 

field equipment should be listed: clipboard, ballpoint pens, comfortable 

clothing, and folding chair. The class should be told that any trainee who 

intends to wear sunglasses in training and certification must wear the same 

type of glasses when making field opacity readings. Glasses that change 

intensity with changing sunlight and those with nonstandard colors are not 

recommended. The best sunglasses for opacity reading are those with gray 

and green tints. 

The trainees should be reminded of the time and location for the field 

testing and certification. 

115 
P.32 

Quiz 

A short quiz should be given at the conclusion of the classroom series 

for two reasons. First, the quiz will indicate the trainee's comprehension 

of the material offered in the lectures. The test need not pose an obstacle 

to the student, but simply indicate whether the student understands the key 

points of the lectures. Problems with specific questions would indicate 

that this particular material has not been clearly presented. It may be possible to clarify important points or at least make adjustments for subsequent 

sessions and provide a QA check on the training effectiveness. 

Second, the last few questions on the quiz would allow a brief critique 

of the course. These questions would alert the instructor to any parts of 

the lecture that need improvement. Both the quiz and critique will provide 

information to allow the instructor to continually improve the training 

program. Two sample quizzes are provided in Figures A-5 and A-6. 

116 
P.33 

NAME 

DATE 

LOCATION 

SMOKE SCHOOL QUIZ 

A certificate is valid for: 

A. 6 months B. 1 month C. 1 year 

The observer should stand, 

A. facing the sun B. with the sun at his back C. With the sun at 

The opacity scale is used for 

A. Black smoke B. White smoke C. 

E. A & B F. All of the above 

his side 

Red smoke D. Blue smoke 

A North wind blows from 

A. South B. North West D. East 

The smoke reading shall be taken with no allowance for deviation 

A. At the top of the stack B. At the top of the plume 

C. At the widest part of the plume D. At the narrowest portion 

E. At the densest portion of the plume 

Smoke reading is a/an 

A. Objective B. Subjective 

of the plume 

measurement. 

The following is not a part of white smoke generation equipment: 

A. Toluene B. Fuel pump C. Gasoline engine D. Blower 

The following is no_t a part of black smoke generation equipment: 

A. Gasoline engine B. Toluene C. Fuel pump D. Blower 

White smoke emitted from the generator consists of: 

A. Talcum powder B. Oil soot C. Oil vapor Steam 

(continued) 

Figure A-5. Sample Smoke School Quiz I, 

117 
P.34 

Figure A-5 (continued) 

Short answer or listing. 

10. Define opacity. 

11. What are the advantages of the visual method of plume evaluation? 

12. What are the limitations of visual plume evaluation? 

13. Sketch the proper relationships of (A) Smoke Reader, (B) Stack, (C) Wind 

direction (use plume), and (D) Sun's position (indicate North). 

14. What color light is most visible to human eyes? 

Why is this important? 

15. What are light obscuring mechanics? 

16. What is a hold harmless agreement? 

17. What should be added to this course? 

18. What should be removed? 

19. What should receive extra emphasis? 

118 
Nam e • • 

1 point 

SMOKE SCHOOL QUIZ 

Multiple Choice - 3 points each 

1. A certificate is valid for: 

A. 6 months B. 1 month C. 1 year 

2. The observer should stand: 

A. Facing the sun B. With the sun on his back C. With sun at •• 

•• his side 

3. The opacity scale is used for: 

A. Black smoke B. White smoke C. Red smoke D. Blue smoke 

E. A & B F. All of the above 

4. A North wind blows from the: 

A. South B. North C. West D. East 

5. The-smoke reading shall be taken: 

A. One stack diameter above the top of the stack 

B. At the top of the plume 

C. At the widest part of the plume 

D. At the narrowest part of the plume 

6. The plume axis should be: 

A. Along the reader's line of sight B. At right angle to the reader's 

line of sight 

7. Smoke reading is a/an measurement. 

A. Objective B. Subjective 

8. White smoke emitted from the generator consists of: 

A. Talcum powder B. Oil soot C. Oil vapor D. Steam 

Figure A-6. Example Smoke School Quiz II. 

(continued) 

119 
P.36 

Figure AMatching 

9. 

10. 

11. 

12. 

13. 

14. 

15. 

16. 

17. 

18. 

19. 

6 (continued) 

- 1 point each 

20% opacity 

0% opacity 

Water vapor 

50% opacity 

Gaseous pollutants 

Wind speed 

80% opacity 

Light scattering 

Photocell 

Neutral density filter 

100% opacity 

A. 

B. 

C. 

D. 

E. 

F. 

G. 

H. 

I. 

J. 

K. 

Transmissometer 

Not measurable 

0 Ringelmann 

2H Ringelmann 

Steam Ringelmann 

5 Ringelmann 

4 Ringelmann 

Calibration 

1 Ringelmann 

Beaufort scale 

Opacity 

Short answer or listing - 8 points each 

20. What is opacity (25 words or less)? 

21. What are the advantages of the visual method of plume evaluation? 

22. What are the limitations of visual plume evaluation? 

23. Distinguish combustion versus process sources. 

24. How can photographs be useful in smoke reading? 

25. List typical sources of BLACK smoke. 

120 
P.37 

Figure A-6 (continued) 

26. List typical sources of WHITE smoke. 

27. What is a sling psychrometer? 

28. What changes would you recommend to improve the lecture content? 

29. Were speakers adequately prepared? 

30. Were classroom facilities generally adequate? If not, what changes would 

you recommend? 

121 
P.38 

APPENDIX B 

PERFORMANCE AUDIT AND SYSTEM AUDIT 

This appendix provides an example grading and recordkeeping checklist 

for field certification test performance audits (Table B-l), a checklist for 

smoke generator performance audits (Table B-2), and an extensive information 

checklist for a smoke school training and certification system audit 

(Table B-3). These forms are designed to check and document QA for visible 

emissions training programs. 

122 
P.39 

TABLE B-l. GRADING AND RECORDKEEPING CHECKLIST FOR PERFORMANCE 

AUDIT OF FIELD CERTIFICATION TESTS ' 

Agency Date 

Operator 

Auditor 

Location 

Activity check 

Field Operations 

Certification forms (carbon/NRC 

paper) 

Field certification forms distributed individually to participants by field certification test supervisor 

Participants instructed to sign 

completed form before separating 

copies 

Participants instructed to submit original, completed, signed 

form to test supervisor 

Forms reviewed by supervisor for 

name, signature, illegible characters, completeness 

Completed forms checked against 

list of participants; discrepancies noted 

Both forms filed in a secure 

area 

Strip chart reviewed for correctness by test supervisor and 

smoke generator operator 

Operator certified that test 

completed in accordance with 

provisions of Method 9; 

noted on chart 

Adequate 

yes no Comments/corrective action 

(continued) 

123 
P.40 

TABLE B-l (continued) 

Activity check 

Chart with test forms and participant list secured by test 

supervisor 

Office Operations 

Master opacity sheet from strip 

chart audited for correctness 

Forms checked against participant list 

Certification forms graded; mean 

and maximum deviations noted 

against master opacity sheet; 

name, statistics, and pass/ 

no pass recorded on standardized grading form 

Opacity readers with mean deviation <_ 1.5% and no deviation 

> 15% passed by grader 

Grading of certification form, 

and pass/no pass status, reviewed by checker/auditor 

Test forms, grading form, 

class list, strip chart and 

master opacity chart forwarded to training coordinator; accuracy of grades 

and pass/no pass status 

certified 

Certificates to passing 

students issued by training 

coordinator in accordance 

with school requirements 

and 6-month certification 

period 

Test forms, grading forms, 

class list, strip chart, 

master opacity list, and 

list of certified readers 

filed in secure area by 

training coordinator 

Adequate 

yes no Comments/corrective action 

124 
P.41 

TABLE B-2. SMOKE GENERATOR FOR CHECKLIST PERFORMANCE AUDIT 

Agency Date 

Operator 

Auditor 

Location 

Activity check 

Pre-Setup Inspection 

General damage or damaged components checked 

Inventory of parts and supplies 

completed 

Fans and motors lubricated 

Console received preliminary 

check 

If transmissometer not inspected within last 6 months: 

Transmissometer disassembled 

and inspected 

Photocell detector inspected 

for alignment, damage, and 

proper electrical connection 

Phototopic response required 

by photocell 

Angles of projection and view 

£ 15 degrees 

Standard Fuels Used 

Toluene 

Diesel or fuel oil 

Propane 

Other (specify kind and use) 

Adequate 

yes no Comments/corrective action 

(continued) 

125 
P.42 

TABLE B-2 (continued) 

Activity check 

Generator Setup 

Background, sky, and wind conditions checked for best generator 

orientation 

Generator leveled and wheels 

chocked 

Separate control console set up 

Checks conducted for fuel leaks 

(lines, connections and tanks) 

Fans 

All fans checked for smooth, 

normal noise level 

Main or induced draft fan 

checked for normal operation 

and flow rate 

Transmissometer fans checked 

for normal operation 

Operation of the Generator 

Generator logbook available 

and used 

Both fuel pumps operable and 

not leaking 

Chart recorder paper supply 

adequate for proposed runs 

Chart recorder visible to 

operator or assistant 

Chart recorder equipped with 

event marker or otherwise 

easily marked by operator or 

assistant 

Adequate 

yes no Comments/corrective action 

* 

(continued) 

126 
P.43 

TABLE B-2 (continued) 

Activity check 

Console allowed to warm up for 

30 minutes before making opacity 

measurements 

All opacity readout systems 

operational, stable, and consistent 

Transmissometer System Calibration 

Initial zero and span drift 

check completed; repeated 

after each run 

Drift qreater than 1% corrected 

Response time checked prior to 

testing; 0 to 100% opacity 

swinq 

Response time 0 to 100%, <_ 5 

seconds 

Light source voltage checked 

prior to testing 

Voltaqe — 5% of nominal 

Calibration check 

Filters within +_ 2% of 

nominal value 

Five (nonconsecutive) 

checks for each filter 

completed 

Maximum error, 3% 

opacity 

Calibration record 

completed 

Adequate 

yes no Comments/corrective action 

(continued) 

127 
P.44 

TABLE B-2 (continued) 

Activity check 

Generation of Smoke 

Black smoke stability and 

range test complete 

Opacity range 0 to 100% for 

black smoke 

White smoke stability and range 

test complete 

Opacity range 0 to 100% for 

white smoke 

Public Address System 

Setup and operation checked 

Voice and cuing horn audible 

and clear throughout reader 

area 

Total smoke system calibrated 

and operating properly for 

training and certification 

purposes 

Adequate 

yes no Comments/corrective action 

Comments (please lis t any problems or conditions encountered in the setup or 

startup of the smoke generator): 

Auditor's signature 

Date 

128 
P.45 

•' •*» "-'n*1 1 ' !.w y »" • 

TABLE B-3. SMOKE SCHOOL TRAINING AND CERTIFICATION SYSTEM AUDIT 

I. General Information 

Agency 

Address 

Smoke School Personnel 

Training Supervisor 

Smoke Generator Operator_ 

Training Assistants 

Organization Schematic 

Date 

Phone_ 

Phone_ 

Phone_ 

Phone 

Schedule of Training/Certification (year 

Classroom , , 

Field opacity 

Average Number of Students Trained (year 

Agency Industry 

Other (specify) 

(continued) 

129 
P.46 

<* •-• m«-(orr-j?>rn* • 

.TABLE B-3 (continued) 

Activity check 

II. Classroom Traininq 

A. Registration and 

Orientation 

Forms and records 

Procedure 

B. Theory and Principles 

of Opacity Reading 

Visual aids 

Materials and Preparation 

Definition of opacity 

Opacity vs. transmissometer 

Contracts and background effect 

Particle size 

Chemical and physical 

properties 

Light scattering 

C. Sources of Visible 

Emissions 

Visual aids 

Material and Preparation 

Combustion sources 

Noncombustion sources 

Fugitive sources 

Adequate 

yes 

-

no 

• 

Comments/corrective actipn 

r 

(continued' 

130 
TABLE B-3 (continued) 

Activity check 

Plume characteristics 

Identifying water 

vapor 

Effect of control 

equipment 

D. Opacity Reading and Field 

Documentation 

Visual aids 

Materials and preparation 

Techniques of reading 

opacity 

Standardized forms and 

field log 

Important parameters 

Field equipment 

Regulations 

Source review 

Reading location 

Sun angle 

Number or time of 

readings 

Data reduction 

Contacting the source 

E. Meteorology 

Visual aids 

Adequate 

yes 

• 

no Comments/corrective action 

• 

> 

(continued) 

131 
P.48 

TABLE B-3 (continued) 

Activity check 

Materials and preparation 

Atmospheric stability 

Relative humidity 

Plume characteristics 

Wind speed and direction determinations 

Building and obstruction effects 

Cloud cover 

F. Legal Aspects 

Visual aids 

Material and preparation 

Leqal history 

Legal precedents 

Riqht of entry 

Hold harmless agreement 

Free and open field 

concepts 

Evidence and source 

information disclosure 

Freedom of information 

Case preparation 

Adequate 

yes no Comments/corrective action 

.' 

(continued) 

132 
P.49 

TABLE B-3 (continued) 

Activity check 

Requirements of certification 

Expert witness 

G. Preparing for Testing 

and Certification 

Visual aids 

Materials and preparation 

Requirements for certification 

Review techniques for 

readinq opacity 

Forms 

Calibrating the eye 

When to read 

Use of glasses or 

other aids 

H. Closing 

Course review 

Quiz 

Discussion 

I. Refresher Courses 

Requirements 

Frequency 

Adequate 

yes no Comments/corrective artinn 

(continued) 

133 
P.50 

< 

. TABLE B-3 (continued) 

Activity check 

J. Presentation and Preparation 

Background speeches 

Speaker experience 

Material organization 

Preprinted notes and 

illustrations 

Visual aids 

K. Facilities and Training 

Equipment 

Classroom 

a. Size and suitability 

b. Comfort and convenience 

Visual aid equipment 

Chalkboard, easel, 

etc. 

III. Field Traininq and Certification 

A. Site Selection 

Smoke generator power 

supply 

Suitable backgrounds 

for readinq smoke 

Sufficient area for 

expected number of 

readers 

(continued) 

Adequate 

yes no 

134 

! Comments/corrective action 

t 

i 

i 

i 

•1 

-
P.51 

TABLE B-3 (continued) 

Activity check 

Reader and generator 

properly oriented 

with sun 

B. Smoke Generator 

General condition and 

operability 

Operating manual 

Transmissometer system3 

Angle of projection 

(15° max) 

Angle of view (15° 

max) 

Photopic response 

Incandescent light 

source 

Nominal rated 

voltaqe (- 5%) 

Calibration filters (+ 2%) 

Calibration error 

(+ 3%) 

Ease of calibration 

Zero and span 

drift (+ 1%) 

Response time (max 

5 sec) 

Transmissometer fans 

Controls (operating 

and identified) 

Readout devices 

(specify type) 

Adequate 

yes no Comments/corrective action 

(continued) 

135 
P.52 

1 

TABLE B-3 (continued) 

Activity check 

Control Panel 

Operating condition 

Operability 

Controls identified 

Electrical/fuel 

connections 

Main Fan 

Capacity (cfm) 

Air flow control 

Stack 

Diameter (12" minimum) 

General condition 

Raising/lowering 

mechanism 

Black Smoke Generation 

Fuel supply and type 

Stability of plume 

opacity 

Capable of generating 0 to 100% 

opacity 

Color of smoke over 

opacity range 

Safety cf operation 

(continued) 

Adequate 

yes no 

136 

Comments/corrective action 
P.53 

TABLE B-3 (continued) 

IV. 

Activity check 

White Smoke Generation 

Fuel supply and type 

Stability of plume 

opacity 

Capable of generating 0 to 100% 

opacity 

Safety of operation 

General 

Spare parts inventory 

Maintenance tools 

Maintenance log 

Operations procedural manual 

Operator protected 

during inclement 

weather 

Public Address System 

Audible in reader 

area 

Bell or buzzer for 

cuing 

Operation of Smoke Generator 

Operators familiar with 

the operation of the 

equipment 

Generator service and 

maintenance conducted 

Adequate 

yes no Comments/corrective action 

• 

-

. 

(continued) 

137 
P.54 

TABLE B-3 (continued) 

Activity check 

Generator checked for 

operation prior to day 

of training and certification 

Warmup before operation 

prior to day of training and certification 

Calibration requirements completed 

Data and information 

properly recorded and 

maintained 

Students provided 

reasonable training 

at selected opacity 

levels 

V. Certification Testing 

A. Meeting Method 9 

Requirements 

3oth 25 white and 25 

black readings on one 

sheet 

V.o more than 7.5% average 

opacity deviation accepted on either the 

white run of 25 or the 

black run of 25 

No error exceeding 15% 

ooacity allowed 

Points of test given in 

random order 

Applicants required to 

certify from the correct 

viewinq anqle 

Adequate 

yes no ' Comments/corrective action 

(continued) 

138 
P.55 

TABLE B-3 (continued) 

Activity check 

Applicants properly instructed before testinq 

Adequate communication 

between tester and 

teacher 

Standards provided prior 

to tests 

Backqround provided 

Smoke held at one value 

long enough for evaluation 

Weather conditions considered 

Elbow used during windy 

periods 

B. Testing Forms 

Carbon or NCR 

Name 

Location 

Date 

Run and color identification 

Distance from stack 

Sun/stack reader orientation 

Time of day 

Cloud cover 

Wind sDeed 

Wind direction 

Adequate 

yes no Comments/corrective action 

(continued) 

139 
P.56 

i 

TABLE B-3 (continued) 

Activity check 

Sunglasses (type) 

Corrections noted 

Student signature 

Graded by 

Validated by 

C. Issuance of Cards and/or 

Certification 

Dated properly 

Accountable forms 

VI. Qua!ity Assurance 

A. Records Control (Retained for 5 yrs by 

agency) 

i ! 

Student lists 

Transmissometer calibration data 

Transmissometer opacity 

data 

Student test forms 

Issued certificates 

B. Auditing Functions 

Traceability of calibration standards 

Calibration of generator transmissometer 

Auditing of generator 

transmissometer data 

(continued) 

Adequate 

yes no 

140 

Comments/corrective action 

« 
" m> nut i P i'pp' i 

P.57 

TABLE B-3 (continued) 

Activity check 

Verification and control 

of dociJiintatjon 

Auditing of griding system 

Performance audits conducted 

C. Maintenance of Control 

Statistics 

Standards 

Transmissometer response 

Reported opacity 

Applicants final test 

score 

Percent certification 

Other 

Calculated according to -

accepted statistical 

methods 

D. General Information 

(specify numbers) 

Number of schools per 

year 

Number of persons per 

school 

Number of recffrtifiers 

Percentage of new applicants certifying 

Percentage of recertifies certifying 

Adequate 

yes no Comments/corrective action 

The transmissometer system consists of the 1 

readout instruments. The system must meet a 

Method 9 specifications. 

141 

ight source, photocell, fans, and 

ppiicable 40 CFR 60, Appendix A, 
P.58 

APPENDIX C 

ANALYSIS AND EXAMPLE CALCULATIONS OF VE TRAINING 

PROGRAM ERRORS 

Several elements of the VE training program performance can be estimated, within statistical limits, through error analysis of individual program activities. These error estimates may be combined to produce an aggregate error estimate. The probability limits resulting from this error estimate serve as a quantitative measure of program effectiveness and should be 

included as part of its documentation. Individual errors associated with 

the standardized calibration filters, the transmissometer as compared with 

these standardized filters, and the announced opacity as read from the transmissometer are determined along with their respective standard deviations (SD). 

Combined precision and accuracy can then be estimated for' the transmissometer 

and smoke generator operator as well as the total precision and accuracy for 

the VE training program including trainee precision. The following sections 

provide example calculations and an error analysis for a VE training program. 

The descriptions of the statistics are not included since they are available 

in several standard statistical textbooks. 

Filter Qua!ity Error 

In order to determine the precision and accuracy of the transmissometer, 

the error associated with the standardized filters used to calibrate the transmissometer must be determined. The following assumption should be used to 

calculate filter quality error directly from the specifications of the standardized calibration filters. 

1. Each NBS-traceable filter used to calibrate the transmissometer 

is accurate within +0.5 percent opacity of its nominal value. 

2. The area within 3 SD of the mean of a standard normal curve is 

99.73 percent of the total area or approximately the total area. 

142 
P.59 

3. Therefore, under the assumption of normal distribution of 

errors, the calibration filter standard error (SD,) will be 

less than one-third of the nominal error or 

S D X < ^ 

SDX < 0.17% . 

The standard deviation of error associated with the calibration 

filters is therefore less than 0.17 percent opacity. 

Linearity - Calibration Error 

To determine how accurately the transmissometer compares with the standardized filters, the standard deviation (SD~) of the transmissometer must be 

obtained by use of the following procedure. Note: At least 10 data points 

from each filter must be used. 

1. Use the data obtained from filter readings taken during the VE program certification runs. Fifteen filter readings must be taken at 

the beginning of the training course, and 15 additional readings 

must be taken at the end. Record these data points on a form 

similar to that illustrated in Figure C-l. 

2. Determine the difference (d.) between each of the 30 values reported 

by the transmissometer and the actual opacities of the corresponding 

filters as shown in Figure C-l. 

3. Sum the differences obtained in step 2 and determine the mean (5L) 

and the standard deviation (SDo) of the 30 differences, where d, is 

the first difference, dp is the second, and so on. 

d, + d0 + d, + ... + d,n Ed. 

v2 30 

S D2 **• 

(Ed^) - (Zd.)2/n h 

n - 1 

Operational Error 

The following procedure should be used to determine the standard deviation 

(SD3) of the reporting error from the transmissometer, the difference between 

143 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

INITIAL 

Measured 

17.5 

17.5 

17.5 

17.5 

17.0 

49.0 

49.5 

49.5 

51 

49.5. 

76 

74 

74.5 

74 

74 

FILTER READINGS3 

Actual 

13 

18 

18 

18 

18 

50 

50 

50 

50 

• 50 

74 

74 -

74 

74 

74 

di 

-.5 

-.5 

-.5 

-.5 

-1 

-1 

-.5 

-.5 

+ 1 

-.5 

+2 

0 

+ .5 

0 

0 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

FINAL 

Measured 

17 

20 

17.5 

19 

18 

50 

49.5 

51 

49 

50 

75 

74.5 

74 

73.5 

74 

FILTER READINGS 

Actual 

18 

18 

18 

18 

18 

50 

50 

50 

50 

50 

74 

74 

74 

74 

74 

a 

V 

-1 

+2 

-.5 

+1 

0 

- 0 

-.5 

+ 1 

-1 

0 

+ 1 

+ .5 

0 

-.5 

0 

Measured denotes values read by the transmissometer; actual denotes filte r 

values; d. denotes the difference (Measured - Actual 

n = 30 

Zid.J = 19 

SD. 

Ed.2 - (ld.) 2/n 

n - 1 

19 - (0V30) 

29 = 0.80% 

Figure C-L, Linearity - calibration error 

data and calculations. 

144 
P.61 

1. 

the actual opacity value as recorded on the transmissometer strip chart and 

the opacity as announced to the nearest 5 percent value by the generator 

operator. 

Randomly select one certification run from the school's fiel d 

training program. Note: Avoid selecting the firs t run--it usually 

wil l have the highest error, since the generator operator is unfamiliar with the generator's operation at this point. On a form 

similar to the one illustrated in Figure C-2, record the actual 

transmissometer readings for each of the 25 white smoke readings, 

the 25 readings as announced by the generator operator, and the 

caJj^ilaJ^d__d_rfference (d.) foreach of the readings. 

Sum the differences obtained in step 1 and calculate the mean (5L) 

ind standard deviation (SD,) of the 25 readings, where d, is the 

first difference, d« is the second, etc.: 

SDdl

 + d2 + d3 + . . . + 

25 

Ed. 2 - (Ed.) 2/n h 

d

25 . 

Ed. 

25 

n - 1 

3. Repeat steps 1 and 2 for the 25 black smoke readings. Refer to 

Figure C-2 and the strip chart record trace illustrated in Figure C-3. 

Probability Limits 

The following procedure is used to calculate the 95 percent probability 

limits (PL) for the actual readings. This calculation establishes a reasonable 

estimate of the combined transmissometer and generator operator error in reporting individual smoke readings (see Figure C-4). Figures C-l and C-2 show the 

standard errors computed from the previous discussions of filter quality, 

linearity-calibration error, and operational error. The following steps 

outline the procedure for determining these probability limits. 

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' 

Figure C-3. Example of a strip chart recorder 

trace showing recorded opacity value. 

147 
P.64 

For White Smoke: 

x4 = x2 + x3 

0.1 = 

SD4 -

1.00 = 

0 + 0.1 

'(SD^2 + (SD2)

2 + (SD3)2 

(0.17)2 + (0.81)2 + (0.72); 

H 

h 

PL4 = X4 + .2 (SD4) or 

PL4 =0.1+ 2 (1.10) or 

0.1 + 2.20 = 2.3 

0.1 - 2.20 = -2.1 

X4 = 

0.08 = 

SD, = 

For Black Smoke: 

x2 + x3 

0.08 + 

0.08 -

'4 

1.08 = 

P L4 = 

P L4 = 

2.16 = 

2.16 = 

0 + 0.08 

(SD^2 + (SD2)

2 + (SD3)2' 

(0.17)2 + (0.81)2 + (0.69)2 

X"4 + 2 (SD4) or 

0.08 + 2 (1.08) or 

2.2 

-2.1 

Therefore, 95% of the time it is expected that: 

1. An individual white smoke reading will not exceed the true value by more 

than 2.3% opacity. 

2. An individual white smoke reading will not be less than 2.1% opacity 

below the true value. 

3., An individual black smoke reading will not exceed the true value by more 

than 2.2% opacity. 

4. An individual black smoke reading will not be less than 2.1% opacity 

below the true value. 

Calculated by 

Calculations Audited by 

Date 

Date 

Figure C-4. Example calculations and reporting of probability limits 

for individual smoke readings. 

148 
P.65 

1. Determine the mean error (Xj for white smoke. 

x4 = x2 + x3 

where XM = mean of the 30 differences (d.) from initial and 

final calibration error checks using NBS traceable 

filters 

X~ = mean of the differences (d.) from one certification 

run for 25 smoke readings for the operational error 

2. Determine the cumulative standard deviation (SDM for white smoke. 

SD4 = ^(SD^ 2 + (SD2 )

2 + (SD3 )2 

where SD, = standard deviation of error of the standardized 

calibration filters, i.e., 0.17 

SD2 = standard deviation of the 30 differences (d.) from 

initial and final calibration error checks using NBS 

traceable filters 

SD3 = standard deviation of the 25 differences (d.) from 

one certification run for smoke readings for the operational error 

3. Using the results from Steps 1 and 2, compute the 95 percent probability 

limits for individual white smoke readings. 

PL4 = X4 + 2(SD4) 

This results in a 95 percent probability that: 

o An individual smoke reading will not exceed the true 

value by more than % opacity. 

o An individual smoke reading will not be less than % 

opacity. 

4. Repeat Steps 1, 2, and 3 for black smoke. Be sure to clearly mark 

whether the calculations are for white or black smoke. Sign and 

date the calculation form. It is recommended that the calculations 

be audited and that the auditor also sign and date the form as shown 

in Figure C-4. 

149 
P.66 

Aggregate Data Analysis 

Even though the section on probability limits provides statistical calculations for.generator operator's biases along with other sources of error, 

additional calculations are still required to derive a "total" cumulative error 

for the VE training program. The standard deviation (SDr) of the difference between the actual opacity values and those recorded by the trainees measures the 

precision of the individual trainees. 

Figure C-5 illustrates a qualifying test form. The procedures for calculating the mean (RM) and standard deviation (SD5) for white smoke follow. , 

Example calculations are illustrated in Figure C-6. 

1. For each of the 25 white smoke readings on the qualifying test 

form record the opacity announced by the generator operator to 

the nearest 5 percent, the reported opacity from the trainee's 

test form, and the difference (d.) between the announced and the 

trainee's values. 

2. Sum all the differences obtained in step 1 and calculate the mean 

(X,-) and the standard deviation (SD5) of the 25 differences, 

where d, is the first difference, d? is the second, etc. 

id, 

*5

 = 

SD5 = 

d1 +d 2 + d3 + .. . 

25 

(Ed. 2) - (Sd.) 2/n 

L n - 1 

+ d25 

h 

3. Repeat steps 1 and 2 for the 25 black smoke readings. Again, 

be sure to indicate which set of calculations is for white smoke 

and which is for black. 

The following calculations establish a 95 percent confidence interval (CI) 

for the "true average" opacity based on 25 readings each of both white and black 

smoke by an individual. 

1. Combine the three means for white smoke {IJ to calculate the mean 

error. See Figures C-6 and C-7. 

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P.69 

For White Smoke: 

Xg = (x"2) + (x3) + (T5) 

3.1 = 0 + 0.1 + 3.0 

SD6 = 

5.87 = 

(SDX)

2

 + (SD2)

2

 + (SD3)

2

 + (SD5)

2

_ 

(.17)2 + (.81)2 + (.722)2 + (5.77) 2]

2 

f 

For Black Smoke: 

„. -TJJA or XL®. 6 6~VE VI? 

6

 "" V25 

3.72 = 

x6 = (x2 ) + (x3 ) + (x5 ) 

2.48 = 0 + 0.08 + 2.4 

"(SD^2 + (SD2)

2

 + (SD3)

2

 + 

'(.17)2 + (.81)2 + (.69)2 + 

(SDs)

Z

f 

0.57) 2] 

3.1 + 2.35 = 5.5 

3.1 - 2.35 = 0.8 6 5 "V25" V25 

CI, = 2.48 + 2 ^

3,73 ^ 5

 "V25 

2.48 + 1.49 = 4.0 

2.48 - 1.49 = 1.0 

Therefore, 95% of the time i t is expected that: 

White Smoke 

1. (Qualified Individual's Name) wil l not report an average of 25 white smoke 

readings in excess of 5.5% opacity above the true opacity. 

2. (Qualified Individual's Name) wil l not report an average of 25.white smoke 

readings below 0.8% opacity above the true opacity. 

Black Smoke 

1. (Qualified Individual's Name) wil l not report an average of 25 black smoke 

readings in excess of 4.0% opacity above the true opacity. 

2. (Qualified Individual's Name) wil l not report an average of 25 black smoke 

readings below 1.0% opacity above the true opacity. 

Calculated by 

Calculations Checked by 

Date 

Date 

Figure C-7. Example calculations for determining the bias and confidence 

intervals for a true average opacity reading by an individual observer. 

153 
P.70 

h - h + X3

 + X5 

where X2 = mean of the 30 differences (d.) from initial and 

final calibration error checks using NBS traceble 

filters 

>L = mean of the 25 differences (d.) from one certification 

run for white smoke readings for the operational error 

Xr = mean of the 25 differences (d.) from the trainee's 

test form for white smoke readings 

2. Combine the four standard deviations for white smoke to obtain 

the "total 

Figure C-7 

the "total" cumulative standard deviation (SDg) as illustrated in 

SD6 = \'(SD1)

2 + (SD2 )2 + (SD3 )2 + (SD5 )2 

where SD, = standard deviation of error in standardized calibration 

filters 

SD2 = standard deviation of the 30 differences (d.) from 

initial and final calibration error checks using NBS 

traceable filters 

SD3 = standard deviation of the 25 differences (d.) from 

one certification run for white smoke readings for the 

operational error 

SDr = standard deviation of the 25 differences (d.) for white 

smoke readings recorded on the trainee test form and the 

master sheet for the operator's announced transmissometer 

readings 

3. Compute an approximate 95 percent confidence interval for "true average' 

opacity based on white smoke readings. 

CI6 = X6 ±

 2SD 6 

•AT 

where CI, = 95 percent confidence interval for white smoke 

X, = average of three means for the error for white smoke 

154 
P.71 

SDg = pooled or combined average of four standard deviations 

for white smoke 

/a = square root of the number of white smoke readings 

4. Using the results computed from Step 3, record the 95 percent confidence interval on a form similar to the one illustrated in Figure C-7. 

5. Repeat steps 1 through 4 for the black smoke readings. Be sure 

to clearly indicate whether the calculations are for white 

or black smoke. 

6. Sign and date the calculation form. It is recommended that the 

calculations be audited and that the auditor also sign and 

date the form. 

155 
P.72 

TECHNICAL REPORT DATA 

(Please read Instructions on the reverse before completing) 

1. REPORT NO. 3. RECIPIENT'S ACCESSION NO. 

4. TITLE.ANO SUBTITLE 

TECHNICAL ASSISTANCE DOCUMENT: Quality Assurance 

Guideline for Visible Emission Training Programs 

5. REPORT OATE 

6. PERFORMING ORGANIZATION COOE 

7. AUTHOR'S) 8. PERFORMING ORGANIZATION REPORT NO. 

Barbara E. Blagun 

9. PERFORMING ORGANIZATION NAME ANO ADDRESS 

PEDCo Environmental Inc. 

505 South Duke Street 

Durham, North Carolina 27701 

10. PROGRAM ELEMENT NO. 

11. CONTRACT/GRANT NO. 

68-02-3431 

12. SPONSORING AGENCY NAME AND ADDRESS 

Environmental Monitoring Systems Laboratory 

Office of Research and Development 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 27711 

13. TYPE OF REPORT AND PERIOD COVERED 

Fina l 

14. SPONSORING AGENCY COOE 

EPA 600/08 

15. SUPPLEMENTARY NOTES 

To be published as an. ORD Project Report 

16. ABSTRACT 

This document describes procedures and outlines technical guidance for assistance in 

establishing effective visible emission observer training programs. Smoke generator 

operating information is presented and appendices gives examples of sample classroom 

training lectures as well as audit forms and statistical techniques used to access 

the quality of a training program. The adherence of visible emissions training 

programs to the materials in this document should result in improved and consistent 

levels of observer training1. This documentation will aid enforcement programs in 

demonstrating that the observers were trained without biases and in a professional 

manner. 

17. KEY WOROS ANO DOCUMENT ANALYSIS 

DESCRIPTORS b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Fieid/Group 

18. DISTRIBUTION STATEMENT 

RELEASE TO PUBLIC 

19. SECURITY CLASS (Tiiis Report! 

UNCLASSIFIED 

21. NO. OF PAGES 

20. SECURITY CLASS (This page) 

UNCLASSIFIED 

22. PRICE 

EPA Form 2220-1 (R«». 4-77) PREVIOU S EDITIO N I J OBSOLET E