p.1 

OAR Box 1811 

Prepped by Keeia Richards 

Document Number: 

33) ll-A-14 

Docket Number: 

A-84-22 

Printed 10/30/2008 1:19:24 PM Sheet 33 of 82 
P.2 

At-r/K 3T-n\-f4-' is 

EVALUATION OF OPACITY FREQUENCY METHOD ON CONTINUOUS PLUMES 

Contract No. 68-01-5110 

Task Order # 26 

Prepared by: 

DEL GREEN ASSOCIATES, INC. 

1155 C Chess Drive, Suite A 

Foster City, CA 94404 

(415) 574-4737 

Prepared for: 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

Division of Stationary Source Enforcement 

'Research Triangle Park, NC 27711 

Task Manager 

Kirk Foster 

December 1981 
P.3 

ACKNOWLEDGMENT 

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

appreciation for the assistance provided by Eastern Technical 

Associates in conducting the field work for this study. DGA wishes 

to acknowledge that the data summaries presented in this report are 

based cn statistical evaluations conducted by the Research Triangle 

Institute for the Environmental Protection Agency. 

n 
TABLE OF CONTENTS 

P.4 

page 

1.0 Summary 

2.0 Introduction 

3.0 Background 

4.0 Study Design 

4.1 Selection of Opacity Patterns 

4.2 Smoke Source 

4.3 Selection of Observers 

4.4 Number of Opacity Observations 

4.5 Collection of Data 

4.6 Reduction of Data 

4.7 Quality Assurance Procedures 

5.0 Test Procedures 

5.1 Selection of Test Site 

5.2 Ambient Conditions 

5.3 Smoke Generator Operation 

5.4 Instruction of Observers 

5.5 Collection of Data 

6.0 Field Test Results 

6.1 Collected Data 

6.2 Discussion of Results 

1 

3 

4 

8 

8 

8 

10 

10 

11 

11 

11 

13 

13 

13 

13 

15 

15 

16 

16 

17 

Appendix A - Reference Method 9 (with Preamble) 

Appendix B - Sample Data Form; Transmissometer Log and Predetermined 

Plume Patterns 

Appendix C - Meteorological Data 

Appendix D - Data Summary 

Appendix E - Participants 
6.1 

6.2 

4.1 

5.1 

6.1 

6.2 

6.3 

6.4 

• 

6.5 

LIST OF TABLES 

Number of Observations Completed 

Method 9 and Transmissometer Opacity Averages 

LIST OF FIGURES 

Strip Chart Record for Typical Test Run 

Observer Location 

Observed Mean Opacity v. Actual Mean Opacity 

Standard Deviation of Observed Mean Opacity 

v. Actual Mean Opacity 

Frequency of Difference Between Actual and 

Observed Mean Opacities 

Frequency Distribution of the Differences of 

Actual and Observed Times of Excessive 

Emissions (Opacity ^20%) - White Smoke 

Frequency Distribution of the Differences of 

Actual and Observed Times of Excessive 

Emissions (Opacity >20%) - Black Smoke 

iv 

P.5 

* * 

page 

16 

18 

9 

14 

19 

20 

21 

22 

23 

* 
P.6 

% 

' » 

1.0 SUMMARY 

In order to establish the accuracy, precision, and general effectiveness 

of trained cbservers in determining source compliance with aggregate-time 

opacity regulations, EPA's Division of Stationary Source Enforcement authorized a series of data collection field studies. The studies were undertaken 

as part of a larger effort to support existing state aggregate-time regulations, included in many State Implementation Plans, as well as to support the 

development of an opacity reading method specifically for short-term intermittent plumes. This document reports the results of a field study conducted 

in Orlando, Florida cn October 18, 1980. 

In this study, observations of constant opacity plumes, designed to 

simulate steady-state sources, were taken to determine the amount of time the 

opacity exceeded a 20 percent standard. Test periods of unchanged opacity 

lasting six consecutive minutes were contained in each 12-minute test run. 

The position of the six-minute "flat" opacity test period within the 12-minute 

test run, as well as the opacity pattern outside the flat period, was varied 

to avoid revealing the nature of the test to the observers. The observations 

were taken using the "frequency" or "15-second" reading method, in which a 

visual opacity determination is made every 15 seconds (48 readings during the 

12-minute test run).* Using this method, each opacity reading greater than or 

equal to 20% opacity is assumed to represent excessive emissions for the 

entire 15-second period. Thus, each excessive reading is multiplied by 15 

(seconds) to determine the total time of excessive emissions. 

During this study, 20 readers certified according to Reference Method 9 

collected data for twenty 12-minute test runs. Eighteen of the runs sub-
P.7 

sequently proved to be valid, providing 2160 minutes of observation of constant opacity plumes. Both black and white smoke plumes were read, and 

mean opacity values ranged from 9 to 41 percent. The observed times of excess 

emissions were compared with the actual times measured from a transmissometer 

strip chart. 

The observed and actual opacities were used to calculate the mean opacity values according to Reference Method 9 procedures (40 CFR 60, Appendix 

A) and the aggregate time of excessive emissions using the frequency method. 

Since the opacities of the plumes were held constant, the actual times of 

excessive emissions (as measured by the transmissometer) generally were 

either 0 or 360 seconds, depending upon whether the plume was held below or 

above 20 percent opacity. The data analysis indicated that the readers generally were underestimating the opacity, particularly for black smoke. This 

resulted in an underestimation of the mean opacity, as well as the time of 

excessive emissions. In only three of the eighteen tests was the mean opacity 

overestimated by the observers. Errors in estimating the time of excessive 

emissions were distributed broadly for both smoke types, with black smoke 

errors having a definite negative bias. 

The data base developed through this field test has been statistically 

analyzed in a separate study' ' This report discusses the study design and 

summarizes the data obtained. 
P.8 

2.0 INTRODUCTION 

The use of direct visual observation for determining the level of air 

contaminant discharge has been a cornerstone of air pollution control for 

many years. Consequently, virtually all the states, as well as the federal 

government, have adopted regulations establishing visible emission limitations 

and procedures for determining compliance with those regulations. For the most 

part, reasonably accurate visual measurements of emissions have been accomplished by trained, certified observers. Re-certification of an observer's 

skill usually is required every six months. The utility of trained observers to both the industrial source and the enforcement agency has resulted in 

their continued use even though instrumental methods for determining opacity 

often demonstrate greater accuracy. 

Two forms of opacity regulations are predominant in this country — the 

federally adopted New Source Performance Standard Reference Method 9 which 

requires the averaging of 24 consecutive discrete readings, and the aggregatetime method employed by many states which requires the aggregation of the time 

of excessive opacity. 

Though the precision and accuracy of Method 9 has been well defined, 

the aggregate-time method has not been similarly analyzed. Since the aggregate-time method is included in many approved State Implementation Plans, EPA 

has undertaken studies to determine the applicability of this method. A principal goal of these studies is to determine the error associated with the 

method and the factors that affect the error. This report presents the 

results of one such study. 
P.9 

3.0 BACKGROUND 

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

Environmental Protection Agency (EPA) established a data base of visual observations which could be compared to the actual in-stack measurements obtained 

with a transmissometer. These measurements were made using a fossil fuelfired steam generator, an acid plant, and a smoke generator as sources. 

Reference Method 9 (included as Appendix A) was revised to include data averag-

(2) ing based on these test data. 

Currently, Method 9 requires the averaging of 24 consecutive opacity 

observations to determine an opacity level. Since observations are made 

every 15 seconds, this results in the determination of a six-minute average 

opacity. It was found, after comparing reader observations to actual opacities, that averaging a series of opacity readings greatly improved the overall 

estimate of actual opacity. To insure the accuracy of opacity observations, 

Method 9 also stipulated the procedures and minimum standards for observer 

training. Specifically, candidate observers must certify by demonstrating the 

ability to "read" opacity within 15% of the true value for 50 individual 

readings, with an average deviation of less than ±7.5% opacity for 25 white 

smoke and 25 black smoke readings. The actual field studies conducted in 

1974 showed that for 99% of the test sets read by qualified observers, the 

average positive deviation of the observed opacity from the measured opacity 

was at or below 7.5%. Thus, the overall error inherent in Method 9 is well 

defined. 

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

agencies had adopted opacity regulations referred to as "time-exemption", 
P.10 

"time-exception" or "aggregate-time" regulations. A time-exemption regulation 

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

20%, but also exempts the source from that limi t for short periods. The 

exempted periods, typicall y two or three minutes per hour, allow the source 

short-term malfunctions or batch emissions without triggering enforcement 

actions, yet require good source performance 95% of the time. Often, a 

maximum not-to-be-exceeded (e.g. , 60% opacity) opacity limi t is stipulated 

also. Since the periods of excess emissions are aggregated over a one-hour 

period, compliance with the time-exemption regulation generally has been found 

more difficul t than with the six-minute averages of Method 9-based regulations^ 3 5 

Typically, enforcement of time-exemption regulations has been based 

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

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

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

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

toward the exemption period. Under a three-minute exemption standard, 13 

accurate observations of excessive emissions in a one-hour period would be 

considered to have exceeded the standard. This method is called the 

"frequency" or "15-second aggregate-time" method, and with the exception of 

data analysis, conforms to the procedures of Reference Method 9. Although the 

accuracy of the 1974 version of Method 9 was well documented, the accuracy of 

the aggregate-time methods employed by existing state time-exemption opacity 

(3) regulations is not so supported. 
P.11 

As previously mentioned, a notable shortcoming of Method 9 is its inability to quantify brief periods of high opacity emissions. For example, 

two or three minute's of 40% opacity emissions often would not result in a 

violation of the 20% opacity standard when averaged over a six-minute period, 

due to the mitigating effect of the other three or four minutes of relatively 

clean emissions. This pattern could repeat itself continuously but the 

source would remain in compliance based on Method 9. This deficiency did not 

appear critical when Method 9 was revised in 1974, and it was to be addressed 

in future EPA method development. 

The limitations of Method 9 in dealing with intermittent sources and 

the lack of a supporting data base for aggregate-time methods were high-

(4) lighted by the case of Donner-Hanna Coke Corporation v. Costle. EPA 

proposed to inspect the company's coke oven facilities in Buffalo, New York 

using an aggregate-time stopwatch technique described as a modification of 

Method 9. The "stopwatch" method, an alternative to the "frequency" method, 

requires an observer to measure with a stopwatch the accumulated time during 

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

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

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

compliance with New York's existing time exemption rule as adopted in the 

State Implementation Plan. The company claimed the stopwatch technique and 

its method of implementation to be inappropriate and refused entry to EPA. 

The court found that the proposed EPA method was not promulgated properly and 

that Method 9, EPA's only other alternative, was inadequate for an intermittent source such as the coke oven battery. Furthermore, court investiga-
P.12 

tion into the background of the proposed stopwatch technique showed a data 

base inadequate to support the accuracy of the method. 

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

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

EPA conducted a series of field studies to collect observer data using aggregate-time techniques. Because initial data indicated that the rate of opacity change affects the error associated with aggregate-time readings significantly, the field data collection efforts were designed to obtain observer 

data from plumes with a variety of opacity change rates. This study, conducted in October 1980, concentrated on plumes with periods of invariant opacity. Other data collection and analysis efforts concentrated on plumes with 

fast, intermediate, and slow opacity change rates. 
P.13 

4.0 STUDY DESIGN 

Previous opacity studies have found that aggregate-time methods are a 

reasonably accurate way to measure rapidly changing plumes. Such results are 

expected, because changes in time are small for large changes in opacity under 

these circumstances. However, questions remain concerning the accuracy of 

using aggregate-time methods to measure slowly changing plumes, because small 

errors in the judgment of opacity can result in significant errors in determining the time of excessive emissions. 

4.1 Selection of Opacity Patterns 

In order to explore possible limitations of aggregate-time methods, 

emission patterns containing periods of unchanging opacity were selected. 

Within each 12-minute test run, observers were shown six continuous minutes of 

unchanging opacity. The emission patterns varied in their opacity values, 

opacity rise and fall rates, and the position of the six-minute period within 

the run. This "randomizing" of opacity pattern elements was designed to 

prevent prejudgments by observers. Figure 4.1 is the strip chart record for 

Run 14; this run is typical of the plume patterns used during the experiment. 

The transmissometer test log for the 20 runs, as well as the series of predetermined plume patterns to be followed during testing,are presented in 

Appendix B. 

4.2 Smoke Source 

The EPA's multi-transmissometer smoke generator was set up with two 

transmissometers and three readouts. The uppermost transmissometer, used as a 

backup and for quality assurance purposes, was connected to a standard smoke 

generator strip chart recorder. The primary system, in the next lower posi-
P.M 

End,Run 3fc 

(12 minutes) 

Start 

(0 minutes) 

30 40 50 

Percent Opacity 
P.15 

tion, was equipped with two readouts — a digital system for the generator 

operator, and a flat bed recorder to record permanently the actual opacity and 

observer cueing times. All strip charts were fully documented as to run type, 

chart speed, start and stop points, time, name of generator operator, etc. 

Opacity values were indicated to the nearest 1% opacity. 

4.3 Selection of Observers 

In order to implement an opacity reading technique, such as Method 9 

and the associated enforcement program, a baseline level of competency must be 

established through a training and certification program. However, is should 

be remembered that the requirements and procedures of the program tend to 

select a particular skill which may not be that valuable when using a different reading method. In other words, a competent Method 9 observer may not 

be optimally prepared for making observations using an alternative method. 

Fortunately, the required observation technique for the frequency method 

is essentially the same as that used in Method 9. 

The observers selected for this field test all were certified at a State 

of Florida Visible Emission Training Program conducted at the same site 

during the preceding week. The Florida school meet the requirements of 

Method 9. 

4.4 Number of Opacity Observations 

Since information regarding the biases and standard deviations of 

observers estimating the aggregate time of excess emissions on steady-state 

opacity plumes was not available during the planning of the experiment, selection of the appropriate sample size was somewhat subjective. Based upon 

review of the statistical characteristics of the noncontiguous opacity read10 
ings from EPA's RTI study17' and planned opacity patterns, a rough estimate 

was made of the required number of samples. 

4.5 Collection of Data 

Procedures for data collection were designed largely to avoid biasing 

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

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

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

4.6 Reduction of Data 

Time and opacity data from the transmissometer strip chart were summarized 

and put in a format similar to that of the observer data sheets. Keypunching 

was done directly from these data sheets. The time during which opacity 

exceeded 20% was determined from distances along the strip chart. These 

values then were compared to those calculated from the observer's 15-second 

readings. Time deviations were analyzed statistically by Research Triangle 

Institute and are discussed in Section 6.0 of this report. 

4.7 Quality Assurance Procedures 

Analyzing the observer's performance, thereby establishing the usefulness 

of a reading technique, requires that accurate determinations of observers' 

opacity reading and time estimates be made. Opacity and time reading deviations are defined as: 

D = Observed Value - Actual Value 

and are affected primarily by observer error, the subject of the study. 

However, it must be remembered that the "actual" opacity and time measured 

by the transmissometer also are subject to error. To minimize this error, 

the transmissometer was calibrated carefully using NBS-traceable filters 

11 
P.17 

0, V 

of known cpacity prior to conducting the runs. In addition, zero and span 

checks were performed periodically to ensure minimum instrument drift. These 

instrument inspection and calibration procedures met Method 9 requirements. 

A strip chart was used to maintain a permanent written record cf smoke 

generator output (maintenance of a strip chart record is needed to determine 

aggregate-time method error accurately). Subsequent analysis of the strip 

chart was fully checked, with a final audit check performed on transcribed 

opacity data. 

To ensure that the study results would estimate accurately the usefulness 

of the "frequency" method of visible emissions observations, and that the 

data would be of sufficient quality for planning and enforcement purposes, 

the following quality control and assurance procedures were implemented: 

1. Smoke readers were selected randomly from readers recently 

certified at a smoke school that meets all Method 9 requirements. 

2. The generator utilized in the study met all Method 9 specifications. 

3. A second transmissometer was utilized during the study for audit 

purposes. 

4. Confidence intervals, calculated for smoke generator operation, 

were compared with similar statistics from other generators. 

12 
P.18 

5.0 TEST PROCEDURE 

5.1 Selection of Test Site 

The study was conducted at Florida Technological University's Continuing 

Education Center, 7300 Lake Ellenor Drive in Orlando, Florida (Central Park 

area). This site provided suitable facilities for pretest orientation, smoke 

generator power hookup, a field test area with adequate background for reading both black and white smoke throughout the day, and acceptable weather. 

Method 9 positioning and observation procedures were followed throughout the 

day. Figure 5.1 is a schematic of the test location. 

5.2 Ambient Conditions 

At the beginning of the test day the sky was clear, with only a few scattered clouds. However, clouds built up during the day until cloud cover was 

about 60%. Heavy (dark) cloud buildup resulted in a highly variable background for black smoke in the late afternoon. Winds were calm in the morning 

and increased to 4 to 7 knots in the afternoon. Winds were from the southwest 

in the afternoon, resulting in a generally good sun/plume relationship. 

Visibility was good throughout the day and relative humidity varied between 50 

and 100 percent. 

Meteorological information from the Orlando airport reporting station is 

presented as Appendix C. 

5.3 Smoke Generator Operation 

The smoke generator and transmissometer, as previously noted, were 

calibrated according to Method 9 procedures using NBS-traceable, neutral 

density filters. After initial warm-up, the calibration and zero/span checks 

showed the transmissometer unit to be meeting Method 9 specifications. Zero/ 

13 
Smoke Generator 

O O 

o o 

\ 

o o 

o o 

Ai// 

12 Noon \ 

°o°° 

x \l/ / 

\ 

8 a.m. \ ' 

Figure 5.1 

Observer Location 

Building 
P.20 

span checks were conducted after each run as required by Method 9. The smoke 

generator operator adjusted the fuel flow to reproduce opacity patterns previously agreed upon by the experiment designers. 

Tape recorded instructions directed observers on completing the data 

sheets and provided cues at 15-second intervals for the observers to read and 

record the opacity. Simultaneous with each cue, the opacity trace was marked 

and the recording number identified for the run. 

5.4 Instruction of Observers 

While smoke generator warm-up and calibration activities were conducted, 

instructions were given to the observers regarding the day's activities. 

They were instructed regarding use of the data collection forms, the anticipated schedule, and Method 9 procedures. Observers were not informed of 

the purpose of the data collection or the type of plumes to be encountered. 

5.5 Collection of Data 

Opacity observations were taken according to Method 9 procedures and 

the data entered in prepared bound notebooks. Information regarding test 

number, background, and sun position was recorded prior to each test and forms 

were signed by the readers at the completion of each run. After the tests 

were completed, field data notebooks were collected and observers were 

debriefed. 

Throughout the test, field activities were monitored by the testing 

staff to answer questions, ensure that proper positioning was maintained, and 

discourage collaborative observations. 

15 
P.21 

6.0 FIELD TEST RESULTS 

6.1 Collected Data 

Twenty test runs were conducted during the one-day testing session. 

Eighteen of these runs were valid; difficulties in following the prescribed 

opacity profiles for test runs 7 and 16 resulted in elimination of those data 

sets. Twenty-one observers were utilized in each test. Twenty of this group 

were certified readers and one was inexperienced. The results of the inexperienced, uncertified observer are not reported. 

During each test, 48 observations were taken by each reader. At least 

half of the readings were of a plume of constant opacity. Only the data taken 

during the six-minute constant plume period were statistically analyzed. A 

complete listing of these observations is included in Appendix D of this 

report. The number of opacity readings and six-minute test runs are shown in 

Table 6.1. 

TABLE 6.1 

Number of Observations Completed 

All observers, all test runs 

Certified observers, 

all test runs 

Certified observers, Total: 

valid test runs 

White: 

Black: 

Total No. of 

15-second 

opacity obs. 

20,160 

19,200 

17,280 

— 

__ 

No. of 15-

sec. opacity 

obs. at constant true 

opacity 

10,080 

9,200 

8,640 

--

__ 

No. of 6-min. 

time estimate 

observation 

periods 

420 

400 

360 

180 

180 

16 
P.22 

6.2 Discussion of Results 

Average opacity values are displayed in Table 6.2 for observed (all 

observers) and actual (transmissometer) data. Figure 6.1 illustrates the 

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

data. Though a linear relationship is clear for both black and white smokes, 

the slope of the regression line for white is closer to unity. 

The standard deviations of the observed Method 9 averages are displayed in Table 6.2 and plotted against actual mean opacities in Figure 6.2. In 

general, the standard deviations for the white smoke plumes are larger than 

those for black smoke. Both groups show a positive correlation between standard deviation and mean opacity. 

The negative bias of the black smoke data is illustrated further by 

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

Figure 6.3. Approximately 75% of the errors were negative. On the other 

hand, the white smoke data are nearly equally distributed about zero. 

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

smoke observations, as expected, show mostly negative estimation errors. 

Again, errors are more equally distributed about zero for white smoke. 

17 
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Figure 6.1 

Observed Mean Opacity 

Versus 

Actual Mean Opacity 

® — White 

A— Black 

• • 

•" •-

• ^ A 

20 30 40 

Actual Mean Opacity (%) 

50 

19 
P.25 

Figure 6.2 

Standard Deviation 

of 

Observed Mean Opacity versus Actual Mean Opacity 

10 _ 

8 . . 

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— Black 

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P.26 

Figure 6.3 

Frequency of Difference Between 

Actual and Observed Mean Opacities 

WHITE SMOKE 

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12 
100 _, 

80 

Figure 6.4 

Frequency Distributio n of the Differences 

of 

Actual and Observed Times of Excessive Emissions 

(Opacity >20%) 

WHITE SMOKE 

60 -

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240 300 360 

22 
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Figure 6.5 Frequency Distribution of the Differences 

of 

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

BLACK SMOKE 

60 

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P.29 

REFERENCES 

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

Triangle Institute, August 1981 (Draft). 

2. Evaluation and Collobrative Study of Method for Visual Determination 

of Opacity of Emissions from Stationary Sources, EPA 650/4-74-009, 

January 1975. 

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

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

October 1980 (Draft). 

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

N.Y. 

5. Field Evaulation of an Opacity Reading Method for Intermittent Plumes; 

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

6. Evaluation of Opacity Frequency Method on Slowly Changing Plumes; Del 

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

7. Examining the Properties of Qualified Observer Opacity Readings Averaged 

Over Intervals of Less Than Six Minutes; Research Triangle Institute, 

July 1976. 

24 
P.30 

APPENDIX A 

Reference Method 9 

(with Preamble) 

40 CFR 60 — Appendix A 
P.31 

Title 40—Protection of the Environment 

CHAPTER 1—ENVIRONMENTAL PROTECTION AGENCY 

**• 

Subchapter C—Air Programs 

(FRL 391-6) 

PART 60—STANDARDS OF PERFORMANCE FOR NEW STATIONARY 

SOURCES 

Opacity Provisions 

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

for the District of Columbia in 'Portland Cement Association 

v. Ruckelshaus,1 486 F.2d 375 (1973) remanded to EPA the 

standard of performance for Portland cement plants (40 

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

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

to reconsider among other things the use of the opacity 

standards. EPA has prepared a response to the remand. 

Copies of this response are available from the Emission 

Standards and Engineering Division, Environmental Protection 

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

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

evaluated a substantial amount of information which is 

summarized and referenced in the response. Copies of this 

information are available for inspection during normal office 

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

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

plant standards generally did not require revision but did 

not find that certain revisions are appropriate to the 

opacity provisions of the standards. The provisions 

promulgated herein include a revision of §60.11, Compliance 

with Standards and Maintenance Requirements, a revision to the 

opacity standard for Portland cement plants, and revisions 

to Reference Method 9. The bases for the revisions are 

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

They are summarized below. 

The revisions to §60.11 include the modification of 

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

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

9 remains the primary and accepted means for determining 

compliance with opacity standards in this part, EPA will 

accept as probative evidence in certain situations and 

under certain conditions the results of continuous monitoring 

by transmissometer to determine whether a violation has in 

fact occurred. The revision makes clear that even in such 

situations the results of opacity readings by Method 9 remain 

presumptively valid and correct. 
P.32 

The provisions in paragraph (e) provide a mechanism 

for an owner or operator to petition the Administrator 

to establish an opacity standard for an affected facility 

where such facility meets all applicable standards for 

which a performance test is conducted under §60.8 but fails 

to meet an applicable opacity standard. This provision 

is intended primarily to apply to cases where a source 

installs a very large diameter stack which causes the 

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

the diameter ordinarily used in the industry were installed. 

Although this situation is considered to be very unlikely 

to occur, this provisions will accommodate such a situation. 

The provision could also apply to other situations where 

for any reason an affected facility could fail to meet 

opacity standards while meeting mass emission standards, 

although no such situations are expected to occur. 

A revision to the opacity standard for Portland 

cement plants is promulgated herein. The revision changes 

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

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

and the new emission data from Portland cement plants 

evaluated by EPA during its reconsideration. The preamble 

to the standards of performance which were promulgated on 

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

standards: (1) Opacity limits are independent enforceable 

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

are applicable to the same source, the mass/concentration 

standards are established at a level which will result in 

the design, installation, and operation of the best adequately 

demonstrated system of emission reduction (taking costs into 

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

level which will require proper operation and maintenance of 

such control systems. The new data indicate that increasing 

the opacity limits for kilns from 10 percent to 20 percent 

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

design, installation, and operation of the best adequately 

demonstrated system of emission reduction (taking costs into 

account) while eliminating or minimizing the situations where 

it will be necessary to promulgate a new opacity standard 

under §60.11(e). 

In evaluating the accuracy of results from qualified 

observers following the procedures of Reference Method 9, EPA 

determined that (some revisions to Reference Method 9 are 

consistently able to evaluation showed that, sic) observers 

trained and certified in accordance with the procedures 

prescribed under Reference Method 9 are consistently able to 

read opacity with errors not exceeding +7.5 percent based 

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

to Reference Method 9 include the following: 
P.33 

1. An introductory section is added. This includes 

a discussion of the concept of visible emission reading 

and describes the effect of variable viewing conditions. 

Information is also presented concerning the accuracy of 

the method noting that the accuracy of the method must be 

taken into account when determining possible violations 

of applicable opacity standards. 

2. Provisions are added which specify that the 

determination of opacity requires averaging 24 readings 

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

readings is both to extend the averaging time over which 

the observations are made, and to take sufficient readings 

to insure acceptable accuracy. 

3. More specific criteria concerning observer position 

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

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

4. Criteria concerning an observer's position with 

respect to the plume are added. Specific guidance is also 

provided for reading emissions from rectangular emission 

points with large length to width ratios, and for reading 

emissions from multiple stacks. In each of these cases, 

emissions are to be read across the shortest path length. 

5. Provisions are added to make clear that opacity 

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

point where water does not exist in condensed form. Two 

specific instructions are provided: One for the case where 

opacity can be observed prior to the formation of the 

condensed water plume, and one for the case where opacity 

is to be observed after the condensed water plume has 

dissipated. 

6. Specifications are added for the smoke generator 

used for qualification of observers so that State or local 

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

In developing this regulation we have taken into 

account the comments received in response to the September 

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

proposed among other things certain minor changes to 

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

The determination of compliance with applicable opacity 

standards will be based on an average of 24 consecutive 

opacity readings taken at 15 second intervals. This 

approach is a satisfactory means of enforcing opacity standards 

in cases where the violation is a continuing one and time 

exceptions are not part of the applicable opacity standard. 
P.34 

However, the opacity standards for steam electric generators 

in 40 CFR 60.42 and fluid catalytic cracking unit catalyst 

regenerators in 40 CFR 60.102 and numerous opacity standards 

in State implementation plans specify various time exceptions. 

Many State and local air pollution control agencies use a 

different approach in enforcing opacity standards than the 

six-minute average period specified in this revision to 

Method 9. EPA recognizes that certain types of opacity 

violations that are intermittent in nature require a different 

approach in applying the opacity standards than this revision 

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

revision to Method 9 specifying an alternative method to 

enforce opacity standards. It is our intent that this method 

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

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

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

process of analyzing available data and determining the error 

involved in reading opacity in this manner and will propose 

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

The Agency solicits comments and recommendations on the need 

for this additional revision to Method 9 and would welcome 

any suggestions particularly from air pollution control agencies 

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

these agencies. 

These actions are effective on November 12, 1974. The 

Agency finds good cause exists for not publishing these 

actions as a notice of proposed rulemaking and for making 

them effective immediately upon publication for the following 

reasons: 

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

standards which were remanded. 

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

Columbia instructed EPA to complete the remand proceeding 

with respect to the Portland cement plant standards by 

November 5, 1974. 

(3) Because opacity standards are the subject of other 

litigation, it is necessary to reach a final determination 

with respect to the basic issues involving opacity at this 

time in order to properly respond to this issue with respect 

to such other litigation. 

These regulations are issued under the authority of 

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

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

Dated: November 1, 1974. 

John Quarles 

Acting Administrator." 
METHOD 9 — VISUAL DETERMINATION OF THE OPACITY OF 

EMISSIONS FROM STATIONARY SOURCES 

The current Method 9, published in the Federal Register, 

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

llU^m . —±.~ J. A -.— -,*.., --.,,-.-,-- J J _ _,!_ _ _,_ _ ,,,' p^kl n Am- I e. e*-i A n r. it*(.>* 

P.35 

• 

-

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

plume. This method involves the determination of plume opacity 

by qualified observers. The method includes procedures for the 

training and certification of observers, and procedures to be 

used in the field for determination of plume opacity. The 

appearance of a plume as viewed by an observer depends upon 

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

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

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

exert a significant influence upon plume appearance include: 

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

observer with respect to the sun; point of observation of 

attached and detached steam plume; and angle of the observer 

with respect to a plume emitted from a rectangular stack with 

a large length to width ratio. The method includes specific 

criteria applicable to these variables. 

Other variables which may not be controllable in the field 

are luminescence and color contrast between the plume and the 

background against which the plume is viewed. These variables 

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

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

accurately assign opacity values to the observed plume. Studies 

of the theory of plume opacity and field studies have demonstrated 

that a plume is most visible and presents the greatest apparent 

opacity when viewed against a contrasting background. It follows 

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

a plume, viewed under conditions where a contrasting background 

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

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

when a plume is viewed under such contrasting conditions. Under 

conditions presenting a less contrasting background, the 

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

color and luminescence contrast decrease toward zero. As a 

result, significant negative bias and negative errors can be 

made when a plume is viewed under less contrasting conditions. 

A negative bias decreases rather than increases the possibility 

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

standards due to observer error. 

Studies have been undertaken to determine the magnitude of 

positive errors which can be made by qualified observers while 

reading plumes under contrasting conditions and using the 

procedures set forth in this method. The results of these 

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

25 readings each are as follows: 
P.36 

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

100 percent of the sets were read with a positive 

error* of less than 7.5 percent opacity; 99 percent 

were read with a positive error of less than 5 

percent opacity. 

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

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

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

read with a positive error of less than 7.5 percent 

opacity; 95 percent were read with a positive error 

of less than 5 percent opacity. 

The positive observational error associated with an 

average of twenty-five readings is therefore established. The 

accuracy of the method must be taken into account when determining possible violations of applicable opacity standards. 

1. PRINCIPLE AND APPLICABILITY 

1.1 PRINCIPLE 

The opacity of emissions from stationary sources is 

determined visually by a qualified observer. 

1.2 APPLICABILITY 

This method is applicable for .the determination of the 

opacity of emissions from stationary sources pursuant to 

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

2. PROCEDURES 

The observer qualified in accordance with paragraph 3 of 

this method shall use the following procedures for visually 

determining the opacity of emissions. 

2.1 POSITION 

The qualified observer shall stand at a distance sufficient 

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

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

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

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

observers' 25 observations - average opacity determined from 

transmissometer*s 25 recordings. 
P.37 

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

approximately perpendicular to the plume direction, and when 

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

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

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

plume at a time when multiple stacks are involved, and 

in any case the observer should make his observations with 

his line of sight perpendicular to the longer axis of 

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

2.2 FIELD RECORDS 

The observer shall record the name of the plant, 

emission location, type facility, observer's name and 

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

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

location, approximate wind direction, estimated wind 

speed, description of the sky condition (presence and 

color of clouds), and plume background are recorded on 

a field data sheet at the time opacity readings are 

initiated and completed. 

2.3 OBSERVATIONS 

Opacity observations shall be made at the point of 

greatest opacity in that portion of the plume where 

condensed water vapor is not present. The observer shall 

not look continuously at the plume, but instead shall 

observe the plume momentarily at 15-second intervals. 

2.3.1 ATTACHED STEAM PLUMES 

- When condensed water vapor is present within the plume 

as it emerges from the emission outlet, opacity observations 

shall be made beyond the point in the plume at which 

condensed water vapor is no longer visible. The observer 

shall record the approximate distance from the emission 

outlet to the point in the plume at which the observations 

are made. 

2.3.2 DETACHED STEAM PLUME 

When water vapor in the plume condenses and becomes 

visible at a distinct distance from the emission outlet, 
P.38 

the opacity of emissions should be evaluated at the 

emission outlet prior to the condensation of water vapor 

and the formation of the steam plume. 

2.4 RECORDING OBSERVATIONS 

Opacity observations shall be recorded to the nearest 

5 percent at 15-second intervals on an observational record 

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

observations shall be recorded. Each momentary observation 

recorded shall be deemed to represent the average opacity of 

emissions for a 15-second period. 

2.5 DATA REDUCTION 

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

observations recorded on the record sheet into sets of 24 

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

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

observations and dividing this sum by 24. If an applicable 

standard specifies an averaging time requiring more than 24 

observations, calculate the average for all observations made 

during the specified time period. Record the average opacity 

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

3. QUALIFICATIONS AND TESTING 

3.1 CERTIFICATION REQUIREMENTS 

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

opacity readings in 5 percent increments to 25 different black 

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

exceed 15 percent opacity on any one reading and an average 

error not to exceed 7.5 percent opacity in each category. 

Candidates shall be tested according to the procedures described 

in paragraph 3.2. Smoke generators used pursuant to paragraph 

3.2 shall be equipped with a smoke meter which meets the 

requirements of paragraph 3.3. 

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

at which time the qualification procedure must be repeated by 

any observer in order to retain certification. 
P.39 

3.2 CERTIFICATION PROCEDURE 

The certification test consists of showing the candidate 

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

plumes - generated by a smoke generator. Plumes within each 

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

order. The candidate assigns an opacity value to each plume 

and records his observation on a suitable form. At the 

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

candidate is determined. If a candidate fails to qualify, 

the complete run of 50 readings must be repeated in any 

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

smoke school or training program, and may be preceded by 

training or familiarization runs of the smoke generator 

during which candidates are shown black and white plumes of 

known opacity. 

3.3 SMOKE GENERATOR SPECIFICATIONS 

Any smoke generator used for the purpose of paragraph 

3.2 shall be equipped with a smoke meter installed to 

measure opacity across the diameter of the smoke generator 

stack. The smoke meter output shall display in-stack 

opacity based upon a pathlength equal to the stack exit 

diameter, on a full 0 to 100 percent chart recorder scale. 

The smoke meter optical design and performance shall meet 

the specifications shown in Table 9-1. The smoke meter 

shall be calibrated as prescribed in paragraph 3.3.1 prior 

to the conduct of each smoke reading test. At the 

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

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

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

at the time of installation, to meet the specifications 

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

following any subsequent repair or replacement of the 

photocell or associated electronic circuitry including the 

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

occurs first. 

TABLE 9-1 — SMOKE METER DESIGN AND 

PERFORMANCE SPECIFICATIONS 

Parameter Specification 

a. Light source Incandescent lamp operated at 

nominal rated voltage. 

b. Spectral response of Photopic (daylight spectral 

photocell response of the human eye -

reference 4.3). 
P.40 

c. Angle of view 

d. Angle of projection 

e. Calibration errorf. Zero and span drift 

g. Response time 

15° maximum total angle. 

15° maximum total angle. 

+ 3% opacity, maximum 

± 1% opacity, 30 minutes. 

___ 5 seconds. 

3.3.1 CALIBRATION 

The smoke meter is calibrated after allowing a minimum of 

30 minutes warmup by alternately producing simulated opacity 

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

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

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

calibration shall be repeated until stable 0 percent and 100 

percent readings are produced without adjustment. Simulated 

0 percent and 100 percent opacity values may be produced by 

alternately switching the power to the light source on and off 

while the smoke generator is not producing smoke. 

3.3.2 SMOKE METER EVALUATION 

The smoke meter design and performance are to be evaluated 

as follows: 

3.3.2.1 LIGHT SOURCE 

Verify from manufacturer's data and from voltage measurements 

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

± 5 percent of the nominal rated voltage. 

3.3.2.2 SPECTRAL RESPONSE OF PHOTOCELL 

Verify from manufacturer's data that the photocell has a 

photopic response; i.e., the spectral sensitivity of the cell 

shall closely approximate the standard spectral-luminosity curve 

for photopic vision which is referenced in (b) of Table 9-1. 

3.3.2.3 ANGLE OF VIEW 

Check construction geometry to ensure that the total angle 

of view of the smoke plume, as seen by the photocell, does not 
P.41 

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

0 = 2 .tan"1 d/2L, where $ = total angle of view; d = the 

sum of the photocell diameter + the diameter of the limiting 

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

limiting aperture. The limiting aperture is the point in the 

path between the photocell and the smoke plume where the angle 

of view is most restricted. In smoke generator smoke meters 

this is normally an orifice plate. 

3.3.2.4 ANGLE OF PROJECTION 

Check construction geometry to ensure that the total angle 

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

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

Q=2 tan-1 d/2L, where Q = total angle of projection; 

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

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

to the limiting aperture. 

3.3.2.5 CALIBRATION ERROR 

Using neutral-density filters of known opacity, check 

the error between the actual response and the theoretical 

linear response of the smoke meter. This check is 

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

percent in the smoke meter pathlength. Filters calibrated 

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

when inserting the filters to prevent stray light from 

affecting the meter. Make a total of five nonconsecutive 

readings for each filter. The maximum error on any one 

reading shall be 3 percent opacity. 

3.3.2.6 ZERO AND SPAN DRIFT 

Determine the zero and span drift by calibrating and 

operating the smoke generator in a normal manner over a 

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

and span at the end of this period. 

3.3.2.7 RESPONSE TIME 

Determine the response time by producing the series 

of five simulated 0 percent and 100 percent opacity values 

and observing the time required to reach stable response. 
P.42 

Opacity values of 0 percent and 100 percent may be simulated 

by alternately switching the power to the light source off 

and on while the smoke generator is not operating. 

4. REFERENCES 

4.1 Air Pollution Control District Rules and Regulations, 

Los Angeles County Air Pollution Control District, Regulation 

IV, Prohibitions, Rule 50. 

4.2 Weisburd, Melvin I., Field Operations and Enforcement 

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

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

pp. 4.1-4.36. 

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

McGraw-Hill Co., N.Y., N.Y. 1958, Table 3.1, p. 6-52." 
P.43 

APPENDIX B 

• Sample Data Form 

• Transmissometer Log 

• Predetermined Plume Patterns 
P.44 

A METHOD 9 FIELD TEST DATA FORM A 

TEST 

TYPE TEST NUMBER PARTICIPANT 

• 

READINGS 

1 

9 10 

5 

17 18 

9 

25 26 

13 

33 34 

17 

41 42 

21 

49 50 

TIME 

2 3 4 

2 

11 12 

6 

19 20 

10 

27 28 

14 

35 36 

18 

43 44 

22 

51 52 

57 58 59 

5 6 

HEST 

40 

13 

21 

1 

29 

1 

37 

1 

45 

2 

53 

READ 

41 

3 

14 

7 

22 

1 

30 

5 

38 

9 

44 

3 

54 

ING 

p p 

15 16 

8 

23 24 

12 

31 32 

16 

39 40 

20 

47 48 

24 

55 56 

SIGNATURE 
P.45 

A METHOD 9 FIELD STUDY 

STRIP CHART DATA CODING FORM A 

• TEST TYPE 

White Smoke: (1) Flat Trace, (2) Varied with Flat 

Trace, or (3) Resolution 

Black Smoke: (4) Flat Trace, (5) Varied with Flat 

Trace, or (6) Resolution 

2 3 4 

TEST # 

5 6 

D 

GENERATOR OPERATOR: (01) Willie Lee, (02) David Savage, 

(03) David Brande/ (04) Judy Maples 

(1) Run was valid. (2) Run was not valid 

• SKY CONDITIONS: (1) Clear, (2) 25% Cloud Cover, (3) 50% Cloud 

Cover, (4) 75% Cloud Cover, (5) Overcast, 

(6) Rain 

/ TIME 

1 48 

9 10 103 104 

Two Digit value for opacity in nearest 5% 

from 00-95, use 99 as* 100 frequency districution 

method validation. 

Total time in SECONDS at flat trace- opacity level 

for "each run-from plume configuration curves. 

105 106 107 

108 109 

HIGHEST OPACITY OBSERVED 

LOWEST OPACITY OBSERVED 

110 111 

FLAT TRACE OPACIT" 

112 113 
DATE: 10/18/80 A METHOD 9 FIELD STUDY II 

GENERATOR DATA FORM 

it,* IJ *-- a 

TEST TEST 

TYPE 

FLAT 

TRACE 

OPACITY 

TIME PERIOD 

FLAT TRACE 

OPACITY 

GENERATOR 

OPERATOR TIME RECORDER 

CHART SPEED COMMENTS 

001 15 8 min . 15 se c 

(495 sec. ) oa 9U± h A^. 

1

 ifl ' Mt A 002 20 12 min . 

(720 sec. ) 

12 min. 

(720 sec. ) 

oz. ___n 

003 35 

8 min. 

(480 sec. ) 

OZ. (01 oc /.itr/tA\A 

004 15 

9 min.1 3 se c 

(540 sec. ) 

02- /0_ZL Jja/rtin 

005 40 

T min. 

(420 sec. ) 

OZ /0'39 U*/MAA Ze*o 4 t>jA* Ck-ch <de.J)j JL&<~ 

006 25 i2L2, fmz. iQ. M/H 

007 

008 10 

*See Comments Shee t O 2. 

8 min.3 0 se c 

(510 sec. ) 

//ISO 

o a 

lu /lr» 

8 min . 

(480 sec. ) 

//:H I.U/M.* t_^p^5^M Ck**h *t—iij&*«•** % 

009 

010 

30 

20 *See Comments Shee t 

o I 

O L. 

H\c>i 

n\£* 

AA./M,A 

(Uj >AA* 

011 

012 

40 12 min. 

(720 sec. ) 

30 7 min. 

(420 sec. ) 

o a J11AL /Au/ HlA 

7 min . 30 sec 

(450 sec. ) 

& £ lil_9_ /r-ti Vi<« 

^^/> n Cke-rfj A,«* +< (L*n 

013 35 OJL. 11'if IM /MA* 

014 

015 

15 8 min . 15 sec 

(495 sec. ) 

20 12 min. 

(720 sec. ) 

cdL a;o° 

llKt I IAI.-V 

& z. l \ it A*/* <-* / n4.*.i Z<*#4 5^ c£j> J<J^L^A< 

016 

* See Comments Shee t 0 z. _z__% % -^ft/Miit 

017 25 8 min . 30 sec 

(510 sec. ) O 2 3! OS (XMJN^ 

018 

019 

020 

20 12 min . 

(720 sec. ) «tt ^ 

25 7 min . 

(420 sec. ) 

i

 x.7.t /Ai /**;* 

10 12 min. 

<2-L 2\36 

/Ct 7 ?'. ft/ 

1^4. ____i_4L 

/« / x 

/ . . . / . 14 . 
METHOD 9 FIELD STUDY II *4k 

GENERATOR DATA FORM 

COMMENTS 

NOTE: Record Test # prior to writing comments 1 

Test fl 007 - 2 min. (120 sec.) at 25 

Test # 010 -

Test # 016 • 

1 

1 

1 

1 

1 

1 

- 6 

1 

- 2 

1 

1 

1 

1 

1 

1 

m m . 

min. 

min. 

min. 

min. 

min. 

min. 

min. 

min. 

min. 

min. 

min. 

min. 

min. 

min. 

(60 sec.) at 30 

30 sec. (90 sec.) at 

30 sec. (90 sec.) at 

30 sec. (90 sec.) at 

(60 sec.) at 20 

15 sec. (75 sec.) at 

40 

35 

25 

15 

30 sec. (390 sec.) at 20 

30 sec. (90 sec.) at 

(120 sec.) at 25 

(60 sec.) at 30 

30 sec. (90 sec.) at 

30 sec. (90 sec.) at 

30 sec. (90 sec.) at 

(60 sec.) at 20 

15 sec. (75 sec.) at 

20 

• 

40 

35 

25 

15 

-' 
• 1 

1 

s 

" \ 

{ 

+

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cr 

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P.51 

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Meteorological Data 
P.69 

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APPENDIX D 

Data Summary 
P.72 

t -tt 1 

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---- - • — • • - • — - • - — • • - • — 

TABLE D-l 

Test Data 

White Smoke 

Observer 

T* 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

• 

11 

12 

13 

14 

15 

16 

17 

18 

19 

2 0 

Time 2:20% Opacity, Sec. 

Run 

1 2 3 4 5 

0 

255 ,-

-0-

-0-

15 

-0-

30 

285 

-0-

45 

210 

240 

150 

330 

360 

30 

30 

150 

-0-

270 

225 

240 

225 

-0-

45 

135 

90 

60 

330 

90 

60 

360 

255 

240 

360 

360 

-0-

120 

45 

-0-

360 

135 

360 

360 

-0-

345 

360 

360 

360 

360 

345 

330 

360 

360 

360 

360 

360 

360 

300 

285 

360 

360 

360 

-0-

-0-

-0-

-0-

-0-

-0-

-0-

150 

-0-

-0-

75 

-0-

150 

345 

360 

-0-

-0-

-0-

-0-

30 

-0-

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

"ransmissometer 

Averaqe Opacity, 

Run 

1 2 3 

16 

20 

6 

8 

14 

10 

14 

19 

7 

14 

18 

24 

17 

20 

23 

14 

13 

16 

11 

19 

19 

20 

19 

8 

13 

17 

15 

15 

24 

15 

15 

32 

20 

19 

25 

24 

15 

15 

13 

10 

22 

17 

33 

30 

14 

23 

35 

38 

22 

36 

29 

21 

41 

36 

44 

38 

40 

20 

20 

20 

25 

31 

25 

% * *t* 

Percent 

4 5 

14 

8 

6 

8 

10 

11 

11 

17 

12 

13 

15 

14 

17 

20 

23 

10 

11 

9 

9 

15 

9 

38 

35 

30 

30 

37 

39 

34 

37 

37 

35 

50 

36 

46 

40 

44 

25 

25 

30 

44 

38 

37 

V 
TABLE D-l 

Test Data 

White Smoke 

P.73 

Observer 

T* 

1 

2 

3 

4 

5 

6 

'7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

Time ^20% Opacity, Sec. 

6 8 

360 

300 

• -0-

-0-

135 

255 

75 

360 

210 

180 

360 

150 

360 

360 

360 

360 

90 

360 

360 

360 

135 

-0-

-0-

-0-

-0-

15 

-0-

-0-

210 

30 

-0-

120 

-0-

240 

90 

360 

-0-

-0-

-0-

-0-

150 

-0-

Run 

9 10 

360 

225 

360 

270 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

360 

270 

285 

360 

360 

345 

90 

75 

360 

165 

225 

150 

225 

360 

300 

240 

330 

300 

360 

360 

360 

345 

90 

150 

315 

360 

195 

Averaqe 

6 8 

23 

21 

10 

8 

17 

20 

16 

23 

19 

17 

40 

17 

27 

20 

28 

20 

15 

21 

26 

26 

17 

9 

7 

12 

7 

14 

10 

13 

18 

14 

13 

15 

10 

19 

16 

25 

14 

7 

9 

11 

17 

9 

Opacity, 

Run 

9 

28 

20 

29 

23 

45 

29 

26 

32 

34 

27 

41 

27 

36 

35 

35 

22 

20 

21 

30 

35 

24 

Percent 

10 

19 

14 

24 

18 

18 

17 

18 

27 

21 

20 

31 

20 

26 

23 

34 

20 

15 

16 

21 

26 

18 

*Transmissometer 
P.74 

TABLE D-2 

Test Data 

Black Smoke 

°£ 4fy 

Observer 

T* 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

T 

11 

360 

360 

360 

105 

225 

360 

285 

360 

360 

285 

285 

360 

180 

360 

360 

360 

90 

345 

. 180 

360 

330 

ime_>20% Opaci 

12 

360 

105 

90 

90 

45 

195 

195 

360 

360 

210 

345 

360 

-0-

360 

360 

360 

-0-

105 

-0-

345 

150 

Run 

13 

360 

360 

360 

105 

-0-

285 

120 

345 

360 

345 

360 

360 

-0-

360 

360 

360 

60 

240 

-0-

300 

210 

ty, Sec. 

14 15 

-0-

-0-

-0-

-0-

-0-

15 

-0-

-0-

60 

-0-

-0-

240 

-0-

-0-

-0-

-0-

-0-

-0-

-0-

-0-

-0-

225 

-0-

-0-

150 

-0-

180 

-0-

-o330 

135 

90 

360 

-0-

45 

360 

315 

-0-

-0-

-0-

-0-

30 

Average 

11 12 

41 

31 

25 

14 

19 

21 

21 

21 

27 

21 

21 

52 

18 

33 

31 

20 

16 

21 

17 

27 

22 

31 

16 

16 

15 

14 

20 

17 

21 

24 

18 

21 

34 

13 

20 

28 

21 

13 

16 

9 

21 

16 

Opacity, 

Run 

13 

35 

24 

22 

16 

13 

19 

16 

21 

24 

21 

28 

46 

15 

29 

27 

25 

15 

20 

11 

19 

19 

Percent 

14 15 

15 

6 

6 

6 

5 

9 

5 

6 

15 

8 

9 

19 

5 

10 

20 

12 

10 

16 

7 

17 

11 

14 

22 

16 

15 

31 

12 

16 

14 25 

11 • 

5 

6 

2 

7 

5 

19 

8 

13 

7 

14 

13 

*T, Transmissometer 
P.75 

Observer 

T* 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

TABLE D-2 

Test Data 

Black Smoke 

Time >20% Opacity, Sec. 

17 18 

360 

120 

-0-

60 

-0-

360 

60 

180 

360 

195 

255 

360 

120 

360 

360 

360 

-0-

30 

-0-

60 

225 

195 

-0-

-0-

-0-

-0-

-0-

-0-

-0-

120 

15 

-0-

150 

-0-

-0-

360 

30 

-0-

-0-

-0-

-0-

15 

Run 

19 20 

360 

165 

30 

60 

-0-

15 

. 45 

285 

360 

210 

285 

315 

120 

120 

360 

360 

15 

345 

-0-

330 

300 

-0-

-0-

-0-

-0-

-0-

-0-

-0-

-0-

-0-

-0-

-0-

-0-

-0-

-0-

-0-

-0-

-0-

-0-

-0-

-0-

-0-

Average 

17 18 

25 

17 

11 

15 

10 

20 

16 

17 

24 

17 

20 

24 

17 

22 

27 

23 

11 

14 

10 

16 

18 

20 

11 

10 

7 

5 

10 

7 

10 

17 

12 

9 

17 

15 

15 

21 

15 

7 

10 

5 

14 

14 

Opacity, 

Run 

19 

25 

17 

15 

14 

13 

12 

13 

19 . 

26 

19 

20 

21 

17 

17 

25 

24 

15 

20 

9 

20 

21 

Percent 

20 

9 

4 

5 

5 

0 

4 

4 

4 

7 

3 

4 

4 

5 

7 

7 

4 

4 

5 

0 

5 

5 

* Transmissometer 
P.76 

APPENDIX E 

Participants 
PARTICIPANTS 

• •• *• 

Raymond R. Green 

Michael A. Downs 

Harvey W. Hood 

Lynn H. Tait 

E.J. LeBoss 

Henry E. Bertot 

Louis Daley 

Mary L. Eisenbise 

Kenneth M. Roberts 

John D. Troutt 

James Polk, Jr. 

James D. Harris 

James T. Show 

Johnny B. Turner 

Roger T. Caldwell 

William E. Darling 

Ed Edmundson 

Patriciar A. Roberts 

Donald G. Niver 

Ralph A. Burt II 

*Karen Varney 

Martin Marietta Corp. 

Environmental Resource 

Consultants, Inc. (ERC) 

ERC 

ERC 

ERC 

Florida Power & Light Co. 

Florida Dept. of Environmental Regulation (DER) 

Self employed 

Conservation Consultant Inc. 

Gardinier Inc. 

C F . Industries, Inc. 

Orlando Utilities Commission 

Environmental Analysis & 

Design, Inc. 

DER 

DER 

DER 

DER 

Kraft, Inc. 

Amax Phosphate, Inc. 

University of Central Florida 

Student 

* Not certified; results not reported.