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ETA Visible Emissions Observer Training Manual Eastern Technical Associates Visible Emissions Observer Training Manual June 2013 Copyright © 1997-2013 by ETA i Eastern Technical Associates © Welcome Visible Emissions Observer Trainee: During the next few days you will be trained in one of the oldest and most common source measurement techniques – visible emissions observations. There are more people measuring visible emissions today than at any time in the 100-plus-year history of emissions observations. We have prepared this manual to assist you in your training, certification, and most important, field observations. It is impossible to give proper credit to all who developed and supported the technology that contributed to this manual. The list would probably be longer than the manual itself. We have been working in this field since 1970 and stand in the footprints of many innovators. Much of the material in this manual comes from the contributions of the many visible emissions instructors we have been privileged to work with as well as U.S. EPA documents and the contributions of our staff for more than 30 years. The purpose of this manual is to give you a hands-on, readable reference for the topics addressed in the classroom portion of our training. It should also be useful as a reference document in the future when you are a certified observer performing measurements in the field. Unfortunately, we cannot cover all of the possible situations you might encounter, but the guidance in this document combined with the training you receive in ETA’s classroom and field programs should enable you to make valid observations for more than 90% of the sources you observe. If we do not have the answers, we can usually direct you to someone that does. We hope you enjoy your experience at Smoke School and look forward to seeing you in the future. We will not wish you good luck because luck has nothing to do with certification, so we will simply wish you early success! General Manager Director of Training Jody Monk Marty Hughes For the most up-to-date information regarding ETA’s training schedule, opacity, related topics, forms, and links, please visit either www.smokeschool.com. Eastern Technical Associates © ii Eastern Technical Associates, Inc. Visible Emissions Observer Training Manual Prepared by: ETA Staff Eastern Technical Associates, Inc. P.O. Box 1009 Garner, NC 27529 (919) 878-3188 Cover by David Terry Edited by John Ashley Design and graphics by Steve Allen Copyright © 1997-2013 iii Eastern Technical Associates © Table of Contents Chapter 1 Introduction ………………………………………………………………................................................. Page 1 Chapter 2 History of Opacity …………………………………………………….................................................... Page 3 PM 10 and PM 2.5 …………………………………………………………………………………………………. Page 6 Chapter 3 Opacity Measurement Principles ………………………………………...................................... Page 7 Working definition of Opacity and impact of particle size ……………………………………….. Page 7 Variables influencing opacity………………………………………………………………………………... Page 7 Chapter 4 Method 9 ……………………………………………………………………................................................. Page 10 Chapter 5 Method 9 Procedures …………………………………………………………………………………….. Page 14 Pre-observation procedures …………………………………………………………………………………. Page 14 140-degree sun angle requirement ……………………………………………………………………….. Page 15 Perpendicular line of sight …………………………………………………………………………………….. Page 16 Steam plume classification ……………………………………………………………………………………. Page 17 Adjust field location ……………………………………………………………………………………………… Page 18 Chapter 6 Calculations …………………………………………………………………………………………………….. Page 20 Relationship between opacity and transmittance …………………………………………………… Page 20 Slant angle calculation ………………………………………………………………………………………….. Page 21 Slant angle correction table ………………………………………………………….............................. Appendix Steam plume modeling – Psychrometric charts …………………………………………………. Appendix Chapter 7 Documentation ……………………………………………………………………………………………..... Page 24 Required by Method 9 ………………………………………………………………………..……............ Page 24-26 Plume types ………………………………………………………………………………………………………….. Page 25 Sky conditions ……………………………………………………………………………………………………….Page 25 Visible emissions observation form ……………………………………………………………………. Appendix Practical exercise worksheets ………………………………………………………………………….. Page 29-31 Chapter 8 Equipment …………………………………………………………………………………………………….. Page 32 Descriptions …………………………………………………………………………………………………………. Page 32 Field equipment kit ………………………………………………………………………………………………. Page 33 Chapter 9 Quality Assurance Audit ………………………………………………………………………………. Page 36 Vertical sun angle …………………………………………………………………………………………………. Page 36 Chapter 10 Field Training and Certification………………………………………………………………….. Page 39 Field test form ………………………………………………………………………………………………… Appendix Eastern Technical Associates © iv Chapter 11 Method 22 …………………………………………………………………………………………………….. Page 42 Comparison of Method 9 and Method 22…………………………………………………………… Appendix Chapter 12 Title 40 CFR Subparts………………………………………………………………………………….. Page 46 Additional Methods …………………………….…………………………………………………………. Page 46-48 Visible Emissions Observation Forms …………………………………………………………………………. Appendix Form for Method 22 indoor observation …………………………………………………………… Appendix Form for Method 22 outdoor observation …………………………………………………………. Appendix Form for Method 9 observation …………………………………………………………………………. Appendix 1 EASTERN TECHNICAL ASSOCIATES © CHAPTER 1 Some limit opacity to a certain level averaged over a specified number of minutes (time averaged). Introduction Others set opacity limits where no single reading can exceed the standard (instantaneous or “cap”). Section 111 of the Clean Air Act requires the U.S. Environmental Protection Agency to promulgate Regardless of the exact format of the SIP opacity emission standards for pollutants that regulations, nearly all use the procedures in significantly affect air quality. The federal opacity Method 9 for conducting VE field observations and standards for various industries are found in the for training and certifying VE observers. The Codified Federal Registry (CFR). Standards of procedures contain specific instructions on proper Performance for New and Modified Stationary observation techniques, data gathering, required Sources (NSPS) can be found in 40 CFR Part 60. spatial relationships, and documentation Emission standards for Hazardous Air Pollutants requirements. The validity of the VE (NESHAP) are contained in 40 CFR Part 61 and 63. determinations used for compliance or Title V of the 1990 Clean Air Act Amendments noncompliance demonstration purposes depends further defined the process by which facilities are to a great extent on how well the field permitted. Title V and Part 64 also establish the observations are documented on the VE need for Compliance Assurance Monitoring Observation Form. This manual will stress the (CAM). type and extent of documentation needed to satisfy Method 9 requirements. CAM was a change in direction by the EPA, shifting the emissions monitoring burden to industry. In addition to the plume observation procedures, From an opacity standpoint companies are Method 9 contains data reduction and reporting required to measure and report their own procedures as well as procedures and compliance with permit conditions and standards. specifications for training and certifying qualified However, regulatory agencies do retain the ability visible emissions (VE) observers. to enforce standards and permit conditions. Federal and State Opacity Standards These standards require the use of Reference are Independently Enforceable and Method 9 or Reference Method 22 (contained in Serve as a Primary Compliance Appendix A of Part 60) for the determination by Surveillance Tool trained observers of the level or frequency of visible emissions. In addition to the plume Federal opacity standards and most SIP opacity observation procedures, Method 9 contains data regulations are independently enforceable, i.e., a reduction and reporting procedures as well as source may be cited for an opacity violation even procedures and specifications for training and when it is in compliance with the particulate mass certifying qualified visible emissions (VE) standard. Thus, visible emissions observations observers. serve as a primary compliance surveillance tool for enforcement of emissions control standards. Permits issued under State Implementation Plans Method 9, Section 2 states that the procedures (SIPs) typically include several types of opacity contained in the Method shall be performed by regulations. In some cases SIP permits may differ observers qualified in accordance with the from the federal opacity standards in terms of the certification requirements contained in Section 3. opacity limits, the measurement method or test In addition, many federal and SIP regulations and procedure, and the data evaluation technique. For construction and operating permits also require example, some SIP opacity rules limit visible owners/operators of affected facilities to assess emissions to a specified number of minutes per and report opacity data during the initial hour or other time period (time exemption). EASTERN TECHNICAL ASSOCIATES © 2 compliance tests and at specified intervals over It should be noted that much of the information the long term. presented in this manual has been derived from a number of previously published technical guides, A NSPS or SIP Opacity Violation Can manuals, and reports on Method 9 and related
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